Approaches to the RCRA Corrective Action process sometimes adopt a “Penny Wise, Pound Foolish” strategy and efforts associated with early assessment phases are minimized. However, a hasty RCRA Facility Assessment results in too many open questions and poorly framed defenses, which regulators use to leverage more expensive investigations and remedies than may be necessary.
The number, area and history of SWMUs and AOCs at a facility directly affect Corrective Action costs. Responsibly narrowing the focus of cleanup activities is imperative for cost control.
BBJ Group’s approach to RCRA Corrective Action utilizes our expertise in Environmental Forensics to develop Conceptual Site Models. These are electronic files with all relevant and necessary site assessments, findings and data. This methodology helps stakeholders focus on important key issues, rather than allowing “what-if scenarios” to expand the overall project scope. As a result, less time and money is spent on the expensive and burdensome Corrective Measures Studies and Remedy Implementation phases.
John Tanaka, P.E.
Ron Hutchens, P.E.
Principal, Corporate Consultant