Zephyr has performed closures of hazardous (including permitted units) and non-hazardous waste management units including container storage areas, tank systems, and boilers. Projects include waste removal, decontaminating units and containment, removal of equipment, and sampling to confirm successful completion of closure objectives. Zephyr utilizes the Texas Risk Reduction Program (TRRP) for comparisons to document that releases to environmental media have not occurred. In situations where outdoor asphalt areas were used for drum storage, Zephyr has successfully demonstrated that the removal of the drums and the secondary containment pallets satisfied the closure requirements.
In response to an enforcement inspection of the site, Zephyr was tasked by the owner with the closure of hazardous and non-hazardous waste management units at a polyethylene plant that had undergone demolition. Utilizing historical aerial photographs, RCRA Facility Investigation documents, closure documents on file at the TCEQ, and information provided by former employees, Zephyr identified the locations of the former waste management units and utilized historical documents to demonstrate that some units previously had been closed, but the TCEQ did not update the facility’s Notice of Registration (NOR). Zephyr also conducted rinsate sampling of secondary containments for former drum and tank storage areas, and soil sampling for a roll-off storage area. Utilizing these analytical results, and groundwater data from prior investigations, as well as other TCEQ documentation, Zephyr was able to successfully demonstrate closure of all of the waste management units formerly associated with this plant that were listed on the NOR and resolve all of the enforcement issues without the need for an Agreed Order.