Corrective action strategy in arkansas
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Corrective Action Strategy in Arkansas. Daniel Clanton Engineering Supervisor Arkansas Department of Environmental Quality. Criteria For Success. Trust for all parties is an imperative. If the facility doesn’t trust the state and the state doesn’t trust the facility, the CAS will not work.

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Corrective Action Strategy in Arkansas

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Corrective action strategy in arkansas

Corrective Action Strategy in Arkansas

Daniel Clanton

Engineering Supervisor

Arkansas Department of

Environmental Quality

EPA Region 6 Corrective Action Conference


Criteria for success

Criteria For Success

  • Trust for all parties is an imperative. If the facility doesn’t trust the state and the state doesn’t trust the facility, the CAS will not work.

  • Commitment by management of both state and facility to quick document turn around.

  • Delegation for decision making to those parties directly involved in the project.

EPA Region 6 Corrective Action Conference


Commitment by the facility

Commitment by the Facility

  • Facility must be cooperative.

  • Facility must make commitment in resources, both in time and money, to accelerate characterization and clean-up.

EPA Region 6 Corrective Action Conference


Commitment by the state

Commitment by the State

  • State must commit to quick document turn around, frequent conference calls, and delegation of approval to those available for calls.

  • State must agree to make decisions during meetings and document those decisions in writing.

EPA Region 6 Corrective Action Conference


Three sites are currently working with us using the cas

Three Sites Are Currently Working With Us Using the CAS

  • REMINGTON ARMS

  • GREAT LAKES CHEMICAL

  • KOPPER’S/BEAZER EAST

EPA Region 6 Corrective Action Conference


Remington arms company

Remington Arms Company

  • Formerly a subsidiary of Dupont.

  • Dupont is directly involved with the current company in the investigation.

  • The CAS pilot project with EPA Region 6.

  • A letter of agreement is the implementing document.

EPA Region 6 Corrective Action Conference


Remington arms company1

Remington Arms Company

  • No investigation had begun at the time of the Letter of Agreement.

  • Scoping meeting held January 23, 2001.

  • Jamie VanBuskirk from Dupont will elaborate on the site and discuss progress under the Corrective Action Strategy.

EPA Region 6 Corrective Action Conference


Great lakes chemical company

Great Lakes Chemical Company

  • Corrective Action started as the result of a Consent Administrative Order in the late 1980s.

  • Corrective Action merged with permit when issued in 1994.

  • Extensive work done, i.e., closures, etc.

  • No remedial action decision was on the horizon.

  • Not an official pilot but is benefiting from EPA’s assistance.

EPA Region 6 Corrective Action Conference


Great lakes chemical company1

Great Lakes Chemical Company

  • Entering the process at RFI workplan approved.

  • Scoping meeting held January 31 – February 1, 2001.

  • Major contaminates are bromine related.

EPA Region 6 Corrective Action Conference


Koppers beazer east

Koppers/Beazer East

  • Corrective Action started with a RCRA 3008 (h) Administrative Order on Consent issued by EPA Region 6.

  • Post Closure Permit issued in July 1995 with provision for corrective action to go under the permit, and therefore state control, on approval of the Corrective Measures Study by EPA Region 6.

  • 3008 (h) order terminated early on approval of the CMS Workplan.

EPA Region 6 Corrective Action Conference


Koppers beazer east1

Koppers/Beazer East

  • Site originated in 1906, and has been treating railroad ties ever since.

  • Koppers Industries owns the site.

  • Beazer East is responsible for the corrective action.

  • Major contamination is from a sludge impoundment that leaked; major pool of creosote on and offsite.

  • One high efficiency recovery well on site with others to follow.

EPA Region 6 Corrective Action Conference


Koppers beazer east2

Koppers/Beazer East

  • Ground water contamination offsite.

  • Subdivisions on two sides of facility.

  • Public Participation important in decision making.

  • Scoping meeting held February 22, 2001.

EPA Region 6 Corrective Action Conference


Some parting thoughts

Some parting thoughts

  • We are planning to use the CAS for at least one other major facility on the GPRA list this year.

  • We are contemplating using it on a more wide spread basis.

  • Again, it is not a replacement for enforcement orders for some facilities.

  • CAS is a good way to get to “yes” faster for environmental indicators.

EPA Region 6 Corrective Action Conference


Visit our website on cas

Visit Our Website on CAS

  • Arkansas Department of Environmental Quality.

  • Go to www.adeq.state.ar.us.

  • Click on Divisions & Sections.

  • Click on Hazardous Waste Division.

  • Click on Active Sites Branch.

  • Click on Arkansas Corrective Action Strategy .

EPA Region 6 Corrective Action Conference


Questions

Questions?

EPA Region 6 Corrective Action Conference


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