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W&M Finalizes MSD, VCP, Waste Management Unit Closure and Site Decommissioning

partialresponse AAAs part of the decommissioning of a 100+ acre former manufacturing facility, W&M completed an environmental assessment of this Site which included multiple Partial Response Action Areas (PRAAs).  This approach allowed for the identification of specific source areas which expedited the closure of large tracts of land at varying times as they reached completion.

After data compilation and review of regulatory closure strategies, the use of a Municipal Setting Designation (MSD) was determined to provide the most cost-effective and efficient manner of risk-based remediation for the Site groundwater.  The property borders an active shipping lane, which required additional scrutiny by the City of Houston and additional investigation by W&M for completion of the MSD.  The Site received an MSD Ordinance from the City of Houston and is the largest land area MSD ever performed in the city of Houston.  It is the 8th largest land area MSD state-wide. Affected Property Assessment Reports (APARs) were compiled and submitted to the TCEQ for each PRAA at the Site.

Solid Waste Management Units (WMUs or SWMUs) were removed during the demolition activities at the Site.  W&M commenced the WMU closure process after the investigation phase of the project was completed.  Checklists as required by the TCEQ and some additional sampling were provided to document the removal of the WMUs for a Remedy A closure, that is, without any post closure physical or institutional controls.  Remedy A closures of the WMUs was received during the response action process.

A Response Action Plan (RAP) for the PRAAs was submitted and approved by the TCEQ.  A RAP describes the soil remediation activities required/planned at a Site.  Soil remediation activities on the PRAAs included a combination of consolidation, soil recycling, land use changes, and dig and haul techniques.  In total, approximately 40,000 cubic yards of soil were removed.

Response Action Completion Reports (RACRs) were submitted to the TCEQ as each PRAA was finished.  All five RACRs have been accepted and the final Certificates of Completion (COCs) were issued for each.  This site closure was complex, and involved the preparation and approval of five APARs, a RAP, five RACRs, an MSD, and a very diligent working relationship with the TCEQ.  The site has now received certificates of completion for all of the PRAAs and is in the process of being developed.  For more information on this project please contact Gene Murray or Andy Adams.  We get projects done!

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