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Multi-media
Compliance assistance for commercial hazardous waste TSDF. Agency representation before Texas Commission on Environmental Quality (TCEQ) on NSR permit application. Provide guidance on TRRP requirements for Affected Property Assessment Report, and on RCRA closure requirements. Perform evaluation of spill response measures. Complete air compliance reports as required under 40 CFR Part 264 Subparts AA, BB, and CC and 40 CFR Part 61 Subparts J, V, and FF. Compliance assistance for major ophthalmic lense manufacturer. Provide regulatory guidance for complying with applicable programs including waste management, air quality, EPCRA reporting, safety, wastewater, storm water, etc. Compliance assistance for environmental services company. Provide regulatory analysis on issues involving waste management, permitting options, universal waste, used oil, wastewater, recycling rules, storm water, etc. Lead negotiator with EPA Region 6 to resolve alleged violations resulting from multi-media investigation of commercial hazardous waste TSDF. Programs audited during the four day inspection included RCRA, Air, storm water, EPCRA, TSCA, and FIFRA. At conclusion of negotiations, no violations were cited. Lead role in multi-media permitting effort for commercial hazardous waste TSDF, including major technical contributor in related contested case hearing proceedings. Prepared and submitted RCRA, Air, UIC, and Compliance Plan applications on compressed 6 month schedule. Lead technical role in extensive negotiations with TCEQ (formerly Texas Natural Resource Conservation Commission) on administrative enforcement order involving commercial hazardous waste TSDF. Resulting enforcement order allowed facility to continue operations while successfully addressing serious alleged violations. Conducted facility compliance audits of over 20 hazardous waste treatment, storage, and disposal facilities. Made recommendations to environmental services company on potential environmental liabilities associated with each facility. Air Quality Project management of comprehensive air compliance audit conducted at waste treatment and recycling operation under the Texas Audit Privilege Act. Negotiated constructive corrective action agreement with TCEQ. Managed corrective action projects through completion and certification within agreed timeframes. Lead technical contributor on New Source Review air permit application for waste-derived fuel blending and recycling facility. Project manager for construction of regenerative thermal oxidizer air pollution control device. Oversight of engineers and contractors on development of equipment specifications, geotechnical data, process safety management review, database system design, etc. RCRA and Solid Waste
Provided regulatory analysis and feasibility assessment for pursuing comparable fuel exclusion on behalf of chemical manufacturing facility. Made hazardous waste determination. Advised on analytical procedures. Project manager for Class 2 RCRA permit modification authorizing construction of hazardous waste storage unit with >25% capacity increase. Major modification of Contingency Plan, Closure Plan, and closure cost estimate. Prepared and published public notice. Lead role in public meeting. Project manager for RCRA permit transfer application involving commercial hazardous waste TSDF. Gained transfer approval on expedited schedule. Technical contributor in permit application development for authorizing municipal solid waste landfill in South Texas. Representation before TCEQ on technical issues regarding landfill design. Project manager for renewal of No Migration Exemption for commercial Class I disposal well. Provided technical information to EPA to address public comments. Project management of cooling tower decommissioning at major East Coast steel manufacturing facility. Responsible for developing waste transportation and disposal strategy to meet project timeline and goals.
Site Assessment and Remediation
Project manager for RCRA Facility Investigation (RFI) at solvent recycling/blending facility involving multiple stakeholders. Oversight of soil gas survey investigation and subsequent soil and groundwater investigation activities. Oversight of public relations efforts related to obtaining off-site access agreements for potentially-affected private property. Technical contributor for Affected Property Assessment Report preparation. Project Manager for final RCRA closure and corrective action activities at major commercial hazardous waste TSDF. Negotiated health-based closure requirements with TNRCC. Provided oversight of facility decommissioning activities. Provided technical guidance on site groundwater investigation and remediation under existing Texas Risk Reduction Rules program. Technical advisor to senior management of low-level radioactive waste landfill. Negotiated with EPA Region 10 staff on technical matters related to ongoing site investigation of potential subsurface contamination issues. Key participant in Environmental Due Diligence efforts related to potential acquisition of waste management sites in 3 states (Michigan, Tennessee, and Texas). Wastewater and Storm Water Preparation of wastewater discharge application for luxury jewelry repair and cleaning facility. Negotiated favorable determination that client was insignificant user thus avoiding requirement for discharge permit. Preparation of storm water pollution prevention plan for food products facility. Identified storm water outfalls, developed appropriate best management practices, assembled pollution prevention team, developed compliance documentation, etc. Developed site-specific spill prevention and response plan. Developed Storm Water Pollution Prevention Plan for solvent recycling and blending facility. Developed and implemented site-specific sampling and analysis plan. Project manager for construction of storm water retention basin on developed property to satisfy city storm water management plan requirements. Project involved the excavation and removal of over 13,000 cubic yards of soil and debris. Litigation Support, Agency Representation, and more
Project manager for development and implementation of ISO 14001 program for chemical processing facility. Identified environmental aspects and influences. Developed standard operating procedures, preventive maintenance program, and program compliance recordkeeping system. Performed employee training and conducted annual program audit. Achieved certification of program in less than 6 months with no deficiencies in the program identified by the independent UL auditor. Developed application and obtained city building permit for hazardous waste storage building. Primary oversight of architect and civil, electrical, and fire safety engineers, including developing scopes of work, executing contracts, maintaining budgets, coordinating project schedules, etc. Negotiated design specifications for fire suppression system. Lead role in litigation support related to class action personal injury lawsuit involving commercial hazardous waste TSDF. Provided deposition testimony for defense. Lead technical role in developing and implementing Sampling and Analysis Plan to investigate mixed waste issues at low-level radioactive waste processing facility in Oak Ridge, Tennessee. Provided litigation support to outside legal counsel representing company being investigated by the United States Justice Department. Lead technical role in negotiations with EPA Region 4 Enforcement Division that resulted in significant penalty reduction related to allegations of storing mixed waste without a permit.
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