Abstract: A Practical Approach to Environmental Compliance Under RCRA

Sally W. Bilodeau

As consultants facing an economic decline in the 1990s we are challenged to assist our clients in meeting strict federal and state regulations regarding environmental compliance. Typical compliance issues involve operations and maintenance, environmental assessment, waste management, waste minimization, clean up, closure, and monitoring of active and inactive sites. The economic burden for environmental compliance in California is one of the highest in the nation. It is credited as being partially responsible for the exodus of industry from the state. Meeting the intent of the regulations while scientifically managing the inherent uncertainty in the evaluation process is a technique well suited to environmental compliance issues. Case histories are explored to apply the concept of det rmining data sufficiency for decision making. Concepts and procedures for managing uncertainty have been identified as follows: (1) Acquisition of more data does not necessarily reduce the uncertainty regarding contamination at the site. (2) The data collection efforts should be focused on collecting only the data required to meet the objective of site remediation or closure. (3) The identification of probable remediation alternatives early in the process can help to focus the data collection efforts. (4) The use of a conceptual site model and the observational approach are well suited to this process. EMCON has successfully acquired several landmark permits for closure or operation of hazardous waste facilities. The lessons learned through this process apply to many other active project .

AAPG Search and Discovery Article #90981©1994 AAPG Pacific Section Meeting, Ventura, California, April 27-29, 1994