This chemical manufacturing plant, classified as a TSDF (Treatment Storage and Disposal Facility), was the subject of a RCRA Facility Assessment (RFA) conducted by EPA Region 4. The RFA identified Solid Waste Management Units (SWMUs) at the facility and a draft Administrative Order on Consent was subsequently issued mandating that RCRA Facility Investigations (RFIs) be performed on eleven SWMUs. The subject SWMUs include an on-site non-hazardous waste landfill, seven former sludge lagoons, three former wastewater treatment ponds, the former sub-grade industrial sewer, two former process ditches, four former sandbeds, one former sludge holding area, three former burn pits, and a fire training area.

Hart & Hickman presented the findings of on-going assessment and remedial design efforts and was successful in obtaining for more favorable placement of the subject SWMUs within the RCRA process. The final Order specifies that eight of the SWMUs are at the point of corrective action approval, two SWMUs require Corrective Measure Studies, and six SWMUs require Confirmatory Sampling. The cost saving associated with the more favorable SWMU placements is estimated to be more than $300,000.

Hart & Hickman is currently preparing for Confirmatory Sampling, Corrective Measures Studies, and completion of the Closure Design for the landfill and design of a 1000 ft. long ground water interceptor.

Battery casings, lead components, and solid wastes were dumped on the surface and in borrow pits in a wooded area situated between several large manufacturing operations. A group of four manufacturers entered into a RCRA Consent Agreement with the State and hired Hart & Hickman to conduct an investigation of potential impacts at the site.

Based on the hydrogeologic conditions and the nature of the contaminants present, Hart & Hickman made a strong technical case that only soil sampling needed to be conducted, and the State agreed. Hart & Hickman performed extensive evaluation of the wastes including test pit excavations to determine the nature and extent of the wastes and collected samples to determine the potential for soil and ground water impacts. A risk-based evaluation of the data was conducted and Hart & Hickman was able to demonstrate that impacts did not pose an unacceptable risk to soil or ground water.

Corrective actions will be limited to removal of hazardous wastes and select solid wastes. The majority of the solid wastes will be used as beneficial fill into existing borrow pits. Other materials will be recycled at approved facilities and hazardous waste will be properly disposed.

Hart & Hickman recently completed a Feasibility Study under CERCLA for the former waste solvent recycling site in South Carolina. The site was used for waste solvent treatment and storage from the mid-60s through the early 1980s until it was ordered to cease operations. The potential impacts to soils and ground water at the site include primarily chlorinated solvents and metals resulting from on-site disposal of waste solvents and burial of drums.

As part of the Feasibility Study, Hart & Hickman completed natural attenuation treatability testing in accordance with EPA Region 4 natural attenuation guidance for chlorinated solvents, as well as three-dimensional fate & transport modeling in support of a natural attenuation remedial strategy. Site-specific leaching tests are being performed on site soils to identify the soil concentrations that are protective of ground water. Hart & Hickman has initiated preliminary remedial design and obtained EPA and DHEC concurrence on a selection of cost effective and innovative in-situ and passive remedies for the soil and ground water impacts at the site.