Meet Dave Backus (Part II): Environmental Regulations
Last week we introduced you to Dave Backus and learned more about his plans for complementing CTEH’s TERP program. For this part of our conversation with Dave, we asked him to elaborate more on his second goal for the environmental sciences division.
Inside CTEH: On the second goal of creating a sustainable traditional environmental sciences practice, please explain more about the type of activities involved with this service.
Backus: Those activities are typically planned, as opposed to emergencies, and include site investigations, audits, plans, and permits to comply with the various environmental regulations our clients are required to follow.
For example, many corporations in industries we serve manage wastes in their normal day-to-day operations. Those wastes sometimes meet the definition of hazardous according to the Resource Conservation and Recovery Act (RCRA). RCRA is the “cradle to grave” regulation whereby companies must document the process that generates the waste, manage the waste in accordance with the regulation, and dispose of it properly. Each step must be carefully documented and these corporations must also submit annual reports summarizing the volume of hazardous wastes generated.
In addition to all the documentation of the lifespan of the wastes, these companies are required to demonstrate to regulators a release has not occurred. This is achieved by regulators investigating the plant or property, specifically in the areas where those wastes are managed or stored. The investigation is three phased, starting with (1) a RCRA Facility Assessment (RFA) to define the Areas of Concern (AOCs) or Solid Waste Management Units (SWMUs); then (2) each AOC and SWMU must be investigated to determine if there has been a release. That investigation is called a RCRA Facility Investigation(RFI) and is very comprehensive, covering all potential pathways of exposure for released chemicals. Finally, if concluded there has been a release, the company must determine the risk that chemical poses to human health and the environment. The company must also determine the best way to mitigate that risk to a very stringent set of cleanup criteria, based on the specifics of the site and surrounding area. That third step in the process is (3) a Corrective Measures Study (CMS).
I have been assisting clients with RCRA compliance for many years and managed several large investigations from start to finish. Most of these investigations span a period of five to 10 years with numerous site visits, regulatory meetings, and actual investigations. That is the type of work I enjoy and believe CTEH is definitely qualified to perform for our clients.