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CERCLA/RCRA Support

     TechLaw is at the forefront of the development of innovative strategies for streamlining the corrective action process, with focus on comprehensive management approaches to complex facility remediation. Our staff has extensive experience supporting clients in the oversight and enforcement of CERCLA and RCRA Investigation and Remediation activities. TechLaw has worked on National Priorities List (NPL) sites, facilities subject to closure under Base Realignment and Closure (BRAC), commercial properties being redeveloped, and commercial and government properties to address prior environmental impacts. Our services include the following:

Investigation Services

  • Preliminary Assessments (PAs), Site Inspections (Sis), and Pre-CERCLIS Screenings
  • Expanded Site Investigations (ESIs)
  • Responsible Party Searches and Cost Allocations
  • CERCLA Site Hazard Ranking System (HRS) Prioritization
  • Oversight of Time-Critical Removal Actions, Non-Time-Critical Engineering Evaluations/Cost Analyses (EE/CAs), and Sampling Activities

Remedial Services

  • Preparation and review of Work Plans, Health and Safety Plans (HASPs), Quality Assurance Project Plans (QAPPs), Community Relations Plans, and Sampling and Analysis Plans (SAPs)
  • Field Oversight for Remedial Investigation/Feasibility Studies (RI/FS), Remedial Design/Remedial Action (RD/RA), Corrective Measures Implementation (CMI), and RCRA Facility Investigation (RFI) activities
  • Review of RI/FS Reports, RD/RA Reports, Human Health and Ecological Risk Assessments, Records of Decision (RODs), and RFI Reports
  • Field Sampling and On- and Off-Site Laboratory Analytical Support
  • Geographic Information System (GIS) and Computer Assisted Drafting and Design
  • Drilling, Direct Push Technology (DPT), and Laboratory Subcontracting Coordination
  • Evaluation of Findings of Suitability to Transfer (FOST), Findings of Suitability to Lease (FOSL), and Findings of Suitability to Early Transfer (FOSET) documents
  • Technical support in meetings with state, federal, community, and regulated facility representatives during the planning, implementation, and reporting stages of the work
  • Evaluation of Stabilization and Interim Measures (IM) Work Plans and Reports, and oversight of RCRA Voluntary Corrective Actions
Projects

National Capital Revitalization Corporation – NCRC
TechLaw provided oversight for redevelopment activities taking place at a former gas station located in Washington, D.C. under a contract with the NCRC. Staff assisted with preparation of the scope of work and evaluation of contractor bids for the project, revised the Underground Storage Tank Removal and Test Pit Excavation Oversight Work Plan, and conducted on-site oversight of activities.
Army Depot Site

TechLaw has provided support to EPA for all phases of this site’s remedial activities, leading to transfer of property from DoD to a private entity. Work has included field oversight to ensure RI activities are conducted in accordance with Work Plans.

TechLaw has also provided document review, including Sampling and Analysis Plans and Quality Assurance Project Plans, EE/CA Work Plans, and FOSL documents; technical meeting support; and oversight of on-site excavation, treatment, and disposal of RCRA-hazardous wastes and non-hazardous solid wastes from an Open Burning Ground. TechLaw reviewed a FOSL document submitted by the Army as part of the BRAC transfer process and conducted inspections of buildings covered under this FOSL to ensure reported environmental problems were accurately presented.

Air Force NPL Site

For more than five years, TechLaw has successfully provided technical support to EPA for this site, which has resulted in site cleanup and property transfer. TechLaw has reviewed RI reports for nine Operable Units; provided technical support for treatability studies on a wide range of technologies from surfactant-enhanced subsurface remediation to remedial process optimization; assisted EPA in reviewing the FS Reports; and provided technical support in overseeing removal activities at 23 Soil Vapor Extraction sites, one non-VOC site, and a time-critical radiation removal action.

Over 220 related deliverables have been provided on schedule to EPA. TechLaw's oversight of post-ROD activities includes technical support for a groundwater containment system and a PCB-contamination cap. During transition from an active base to base closure, we provided technical support for base closure oversight by reviewing more than 30 Environmental Baseline Surveys, FOSTs, and FOSLs.

 
Former Shipyard Site

TechLaw has been providing invaluable support at this high priority Brownfields site for the City of San Francisco over the past seven years. We provide EPA with technical oversight for all activities related to identifying and characterizing site contamination; assessing risk to human health and the environment; remedial design; treatability; field sampling; quality assurance; and monitoring to ensure no off-site migration of contaminated media.

As a technical team participant, TechLaw reviews documents prepared to support the implementation of land use controls after property transfer and the risk management process. We also provide field oversight of remediation, including the collection of split samples and preparation of field observation reports to describe remedial activities. TechLaw regularly attends meetings to provide technical support.

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