RCRA/TSCA Cleanup

For an EPA RCRA/TSCA and “adequately regulated” MCP Site, Mr. Graham has served as PM/PIC and LSP for multiple site cleanup and decommissioning projects totaling $50M. 

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Activities have included the permitting (local ConCom, Planning, and Health departments, wastewater discharge, demolition,  MassDEP Water Quality and Wetlands) and asbestos testing and self-performance of asbestos abatement and building decontamination and demolition (D&D) of 200,000 SF of RCRA-contaminated multi-story buildings, following characterization studies of roofing, soils, groundwater, and soil vapor, including MIP studies and ultimately installation and sampling of over 100 monitoring wells. Parallel site efforts included: mechanical, structural, electrical, sewer, process, spill control, and water line replacements/improvements to retrofit an existing 100,000 SF multi-story industrial space for new wire coil manufacturing; drilling, sampling and groundwater modeling involving stream and lake surface water and sediment, fish, soil and air media; feasibility studies and cost estimates; design (plans and specifications), permitting, risk assessments, procurement, construction, and initial operations and maintenance (0&M) of a 100 GPM pump and treat system with containment wall, with extraction wells to 300 feet deep in fractured bedrock, to capture CVOCs; in-situ chemical oxidation/bioaugmentation reagent injections on-site and off-site to reduce CVOC and cadmium concentrations to meet cleanup standards; preparation of 3D groundwater modelling outputs; preliminary design of soil cap; and removal of 1500 tons of a drywell’s contaminated soil, requiring excavation sheeting and seismic impact analysis for adjacent buildings; and removal of 10-ton transformers via crane and several USTs (5 to 20,000 gallons).

 

Next, after a workshop-based public participation program, he prepared. TSCA Risk-Based Disposal Plans were also prepared and approved by U.S. EPA, allowing removal of 6,000 additional tons of PCB soils and sediment, from riparian/shoreline areas and 3 acres of lake under a U.S. Army Corps 404 Dredging permit, MassDEP wetlands and waterways permits, a MEPA certificate, and local ConCom approvals. RCRA-type caps for high level cadmium-containing soils and a 1-acre asphalt cap were designed and implemented to meet EPA and MassDEP requirements. Risk assessments to meet EPA requirements and a Risk Characterization to meet the MCP have also been prepared for soils, and Ecological Risk Assessments under the MCP are in progress. Also, . thr atiities lded petitionigeMassPto rlssiya otionof thesi,fm flt1 to GW2/GW-3, allowing ales strigetlplvel o etilid, and closing out an 18-acre portion of the site using a MCP Method 3 Risk Characterization and Activity and Use Limitation (AUL); that part of the site has been sold.