Resource Conservation and Recovery Act (RCRA) Compliance at a Refinery

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.