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June 4, 2025
1:45PM - 2:45PM
Water & Waste Track
RCRA Administrative Orders: An Example of 30-Years of Investigation, Remediation, and What’s Next
Jim McDade, GSI Global
In March 1997, USEPA issued a RCRA 3008(h) Consent Order to one of GSI’s petrochemical clients’ facilities. Since 1997, GSI Environmental has navigated the RCRA Consent Order process, which has included the completion of significant investigation activities of environmental media throughout the facility, issuance of a second Consent Order, and implementation of selected remedies. The first 10 years of the project were a flurry of investigation and remediation activities, while the remaining 20 years have been somewhat mired in post-remediation groundwater monitoring and inspections of corrective measures (soil covers). To continue to move the project to an eventual “no further action” status, GSI has utilized a strategy of periodically reducing the groundwater monitoring program (reduction in number of wells sampled, chemicals of concern analyzed, etc.) as certain groundwater plumes have remediated. USEPA has been receptive to this strategy, and the groundwater monitoring program has successfully been reduced over time. However, within the last 5-years, turnover in Project Managers at USEPA has slowed the continued progress towards “no further action”. Recently, USEPA has enlisted the project into USEPA’s Optimization Program for RCRA Corrective Action facilities in hopes to continue positive progress towards closure.
