Developed hazardous waste management program for health care manufacturer with more than 30 facilities in the U.S. and Puerto Rico. This included the preparation of model Waste Analysis, Contingency, and Training Plans. Qualified and negotiated contracts with regional analytical laboratories to reduce waste analytical costs. Mr. Smith developed inspection protocols and conducted inspections of hazardous waste treatment and disposal facilities to minimize the disposal risks for the corporation.


Mr. Smith served as the Project manager for the RCRA closure of a hazardous waste storage area for a manufacturer of plastic resins. The facility's Closure Plan was revised to allow documentation of crack size in the concrete floor. Cores were then drilled through the concrete floor in only those areas with significant cracks, eliminating sampling in areas with "hairline cracks". Multiple sampling events were necessary to distinguish between impacted soil from the storage area and impacts from the facility's wastewater treatment plant. The delineation of separate plumes allowed the closure of the container storage area in a cost-effective manner.


Mr. Smith met with the state regulatory agency and negotiated an interpretation of the RCRA regulations, so that a wastewater treatment facility, which included a flow equalization basin, was not considered a RCRA surface impoundment. Although low pH wastewater was discharged to the equalization basin, the regulatory agency agreed with the interpretation that elementary neutralization was not a RCRA regulated activity. The company was then able to avoid the cost and regulatory complications of treating the equalization basin as a RCRA regulated unit and also avoided the issues associated with either obtaining a Part B permit for this basin or proceeding with RCRA Closure.


Mr. Smith prepared the Part B permit modification for the installation of an on-site stabilization facility to allow treatment of 35,000 tons per year of hazardous waste in accordance with the "land ban" regulations. The treated waste was accumulated on-site until analytical data demonstrated the treated waste was acceptable for land disposal.

The stabilization facility included several tanks, the largest of which had a capacity of greater than 30,000 gallons. Mr. Smith reviewed the designs to insure the tanks complied with RCRA requirements for design, secondary containment, and monitoring. He oversaw the initial testing of these tanks and certified their integrity and secondary containment. Mr. Smith has performed the annual tightness testing required for these tanks.

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