Projects
Challenge
Large chemical and industrial facilities are subject to numerous regulations, including the Resource Conservation and Recovery Act (RCRA). To comply with RCRA, a hazardous waste facility must develop and maintain several management and monitoring plans, conduct regular hazardous waste reporting, prepare for potential emergency situations, minimize waste generation, remediate any spills or historical waste management areas and plan for eventual closure of the waste management areas and the facility. Refineries are typically operated as Treatment, Storage and Disposal Facilities (TSDFs), which are subject to additional operating and permitting requirements. TSDFs are required to apply for a RCRA Part B Permit and maintain the Permit Application to reflect current facility conditions and to implement a groundwater monitoring program where applicable. In addition, TSDFs must prepare and maintain Closure and Post-Closure Care Plans for all hazardous waste management units.
Solutions
TRC provides RCRA support to a major oil refinery in the Midwest. This support covers the full spectrum of RCRA hazardous waste generator and TSDF compliance including:
- Agency audit preparation and response
- Facility inspections and audits
- Manifesting guidance
- Universal waste management and reporting
- Used oil management
- Operating record maintenance
- Documentation of applicable exemptions
- Preparation and review of the facility hazardous waste reports
- Development of standard operating procedures
- Preparation and maintenance of refinery RCRA Contingency
Plans and RCRA Part B Permit Applications TRC is also uniquely qualified to develop and implement hazardous waste management unit closure plans. We have completed the design and construction for land farm closure at this midwestern refinery including:
- GIS elevation model
- Calculations for required and available stormwater management controls
- Engineering design for berms and grading to manage stormwater run-on and run-off
- Stormwater and RCRA permitting
- Specifications and bid package for related services
- Construction oversight, final certification and reporting
Results
For nearly 25 years, TRC has enabled this refinery client to maintain compliance with complicated RCRA regulations, thereby minimizing liability to the facility owner and operator, minimizing operating costs, and developing strong positive relationships with the regulators and surrounding communities.
Sharing Our Perspectives
Our practitioners share their insights and perspectives on the trends and challenges shaping the market.
EPA Releases Clean Water Act Facility Response Plan Rule
June 19, 2024
This Regulatory Update is the first in a series summarizing the Rule and how it may affect your facility.
PM2.5 Annual NAAQS Revised
May 7, 2024
The U.S. EPA issued a final rule based on its reconsideration of its 2020 decision to retain the primary and secondary National Ambient Air Quality Standards (NAAQS) for particulate matter (PM) without revision.
What You Need to Know About MSHA’s Final Rule on Crystalline Silica Dust
April 8, 2024
Regulatory Changes Will Impact Mine Operators and Better Protect Employee Health and Safety.
Changes to EPA’s Risk Management Program (RMP) Regulations Are Here
April 3, 2024
Changes to the Risk Management Program (RMP) regulations were signed into a final rule on February 27, 2024, by EPA Administrator Michael S. Regan.
Changes to EPA’s Risk Management Program (RMP) Regulations Are Coming
April 14, 2023
Changes to the Risk Management Program (RMP) regulations were signed into a final rule on February 27, 2024, by EPA Administrator Michael S. Regan.
Phase I ESA ASTM Standard Update: The Wait is Over
December 21, 2022
The USEPA published a Final Rule making the ASTM E1527-21 Phase I ESA standard AAI compliant.
Proactive Enforcement is Key in the EPA FY2022-2026 Strategy
October 19, 2022
A core element of the EPA FY2022-2026 Strategic Plan focuses on environmental compliance.
Preparing for EPA Inspections in Environmental Justice Communities
October 4, 2022
The EPA Office of Enforcement and Compliance Assurance Have Expanded Goals to Strengthen Enforcement and Protections Within EJ Communities
New National Emerging Contaminants Research Initiative
September 12, 2022
The Executive Office of the President of the United States announced a National Emerging Contaminant Research Initiative
Climate Action and Environmental Justice are at the Forefront of EPA’s Strategic Plan
June 14, 2022
The EPA issued its Fiscal Year 2022-2026 Strategic Plan. Although the strategic plans emphases often change with administrations, we can be reasonably certain that the Plan reflects priorities through 2024.
CCR Removal and Its Effects on Soil and Groundwater Geochemistry
October 25, 2021
Many utilities are implementing corrective action at coal combustion residual (CCR) surface impoundments under Federal or State CCR Regulations, with implications for groundwater protection standards.
NJDEP Implements New Jersey Environmental Justice Law Through Administrative Order
October 5, 2021
On September 22, 2021, the New Jersey Department of Environmental Protection (NJDEP) Commissioner announced the issuance of Administrative Order (AO) No. 2021-25 to implement New Jersey’s Environmental Justice (EJ) Law. This order is effective immediately, and applicants seeking to site new major source facilities, renew major source permits or expand existing facilities with major source permits (e.g., Title V air permits) in overburdened communities are affected. There are more than 4.5 million people that live within 331 municipalities that are overburdened communities in the state of New Jersey.
OSHA’s Call for Comments on Mechanical Power Press Standard Changes
September 30, 2021
OSHA has recently published a call for comment regarding mechanical power presses. The reason behind OSHA’s request is that the American National Standards Institute (ANSI) consensus standard for mechanical power presses has been updated numerous times since the implementation of OSHA’s standard.
Managing EHS & ESG Risks Through Integrated Systems Today and Beyond
July 22, 2021
It has been more than 50 years since the development and establishment of the federal Environmental Protection Agency (EPA) and the federal Occupational Safety & Health Administration (OSHA) which were formed to protect our environment and workplaces across the United States. Significant laws, policies and regulations followed to establish the “regulatory programs” that all applicable businesses and entities must address and meet to ensure these compliance-driven legislative programs would create a foundation to protect our society.
EPA Resource Conservation & Recovery Act (RCRA) Corrective Action (CA)
January 11, 2021
The EPA RCRA Corrective Action (CA) Program recently provides a review and update on CA set in 2004 and new CA set for 2030.
EPA continues to aggressively address PFAS wastewater with two new strategies
January 4, 2021
EPA takes steps toward PFAS wastewater and storm water permitting, and analytical methods for testing.
2020 TSCA Chemical Data Reporting (CDR)
December 7, 2020
Earlier this year, EPA revised the CDR rule to reflect the 2016 amendments to TSCA, including changes for foreign-owned businesses and the reporting responsibilities of suppliers and contractors, as well as an exemption for small businesses.
Ecological Risk of PFAS from AFFF-Impacted Sites
June 30, 2020
The facts on evaluating exposure to wildlife
TRC Chosen to Provide Array of Integrated Services on Midship Pipeline Project
August 28, 2018
TRC has been awarded contracts for environmental consulting, engineering and field services and another for stem-to-stern Engineer, Procure and Construct (EPC) contract for three compressor stations.