EXPERTISE

Provides technical and regulatory expertise in a broad range of environmental compliance issues, including RCRA permitting negotiation of state and federal orders, and regulatory compliance audits.

REPRESENTATIVE EXPERIENCE

RCRA Permits: Prepared extensive applications to amend and modify RCRA permits for several major petrochemical facilities in Texas; provided engineering design reports for waste management units (landfills, surface impoundments, incinerators, boilers, container storage areas, tanks, etc.); delayed closure of surface impoundment units converted to non-hazardous service; developed groundwater monitoring programs; and established corrective action programs for remediation of affected groundwater. Prepared facility management, waste analysis, closure, and post-closure care plans for hazardous waste management activities.

Compliance Plans: Participated in the revision of the TNRCC Groundwater Compliance Plan Application and Modification Procedures establishing groundwater protection requirements relating to compliance monitoring and corrective action program at permitted and solid waste management units in Texas. Summarized key regulatory requirements and the procedures for applying for a groundwater compliance plan in an easy-to-follow format.

Compliance Plans: Prepared applications to establish groundwater compliance plan applications for numerous industrial manufacturing facilities in Texas. Applications addressed corrective actions for managing affected groundwater, and established groundwater protection standards.

Audits: Conducted multi-media compliance audits at oil and gas facilities to evaluate compliance with applicable federal and state hazardous waste management regulations and internal corporate policies.

Regulatory Support: Researched and analyzed the applicability of federal and state environmental regulations to:
i) support comprehensive risk-based corrective action (RBCA) evaluations;
ii) determine the applicability of new requirements to client operations;
iii) identify hazardous and solid waste management and disposal requirements for compliance with state and EPA regulations;
iv) identify applicable cleanup standards for affected soil and groundwater; and
v) determine applicable or relevant and appropriate (ARAR) requirements for Superfund sites.