RCRA permitting & corrective action

Chemical Manufacturing Facility, Northern California

JJ&A provides regulatory services for a Resource Conservation and Recovery Act (RCRA) permitted chemical manufacturing facility located near Suisun Bay, California. Constituents of concern (COCs) are metals, depressed pH, and volatile organic compounds (VOCs) in soil, sediment, surface water and groundwater. COC sources are historic fill material containing pyrite ore used in site construction, historic waste management practices, and handling of acids. JJ&A developed a project approach consistent with the RCRA closure process that facilitated collaboration between the client,

Department of Substance Control (DTSC), San Francisco Bay Regional Water Quality Control Board (SFBRWQCB) and other stakeholders. JJ&A consolidated historic information, identified data gaps in the site conceptual model, facilitated data gap assessment work identifying complete and incomplete exposure pathways to support CMS remedial options successfully evaluated, selected and implemented to address: (1) on-site human and ecological risks, and (2) protection of off-site waters.

Project Approach

JJ&A identified the RCRA Facility Investigation objectives/goals requiring definition to move the project into the Corrective Action Phase:

  • On-site media and COCs
  • Environmental Setting and Characteristics,
  • Lateral and Vertical Extent of Impact,
  • Human Health Exposure Pathways and Ecological Receptors,
  • Water Resources and Applicable Regulatory Protection Standards,
  • Physical and Geochemical Properties,
  • Current and Future Land Use, and
  • Offsite Data Gaps for Offsite RCRA Investigation Completion.

Conceptual Site Model

Consistent with the Regulatory Strategy, we evaluated and consolidated the RFI data and additional data gap work in a site conceptual model. This included identifying the contribution of COCs from on-site and off-site sources, establishing background levels of metals in soil, sediment, surface water and groundwater, conducting aquifer tests and geochemical attenuation studies, identifying beneficial uses of waters potentially impacted by the site, estimating groundwater seepage velocities and metal migration rates, coordinated groundwater monitoring and sampling with adjacent properties to evaluate spatial, temporal, and seasonal variations, peer reviewing the regional groundwater flow model, and evaluating risks to on-site receptors and impacts to water quality.

Corrective Measures

The JJ&A successfully facilitated movement of the project into the Corrective Measures Phase of the RCRA Process.