The Texas Risk Reduction Program

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The Texas Risk Reduction Program

• Texas Aggregates Concrete Association
  Environmental Seminar

October 9, 2007 San Antonio, Texas Chet
Clarke, PG Senior Hydrogeologist 512-494-0333
cclarke_at_geomatrix.com
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TRRP _at_ 30,000 feet

• Texas Universal Risk-Based Remediation
  Regulation. Governs
• Environmental contamination assessment
• Setting risk-based cleanup levels
• Environmental contamination remediation
• Long-term stewardship

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TRRP Focus

• Human Health Protection
• Soil ingestion, inhalation, dermal
• Groundwater ingestion
• Ecological/Environmental Protection
• Presumes future exposure to contaminants

Soil Ingestion/Dermal Exposure
Spill or Disposal
Surface water or pond
Ecological Exposure
Ecological Exposure
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TRRP Key Take Aways

• Release reporting not triggered by TRRP!
• Reports of groundwater contamination from
  facility or from off site
• Releases discovered/reported as part of facility
  operation or closure
• Avoid TRRP by preventing releases
• Responsible for your own problems only
• Site specific cleanup levels
• Remove, decontaminate or control
• Urgency driven by potential risks

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Unique Industry Factors

• Often quarrying aquifers (e.g., Edwards aquifer)
• Sand and gravel quarry
• Significant transport via primary permeability
• Potential surface water discharge
• Rock quarry
• Significant transport via fractures
• Expensive drilling costs
• Remote locations
• Potential for local domestic groundwater supply
  wells
• Potential for ecological habitat
• Large volumes of caustic materials
• Large water volumes in process or in storage
  (surface discharges or infiltration/leaching)

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TRRP Focus Quarries (examples)

• Soil or water impacts
• Fuel Lubricants
• Blasting agents
• Ammonia nitrate
• Perchlorate
• Waste disposal in abandoned/out-of-service
  quarries
• Degraded water quality

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TRRP Focus Lime Cement Plants (examples)

• Soil or water impacts
• Fuel Lubricants
• CKD ponds and landfills
• high pH infiltrate or leachate
• Refractory brick
• hexavalent chrome
• Hazardous waste-fired kilns
• VOCs, SVOCs, metals
• Degraded water quality

CKD cement kiln dust, SVOC semi-volatile
compounds, VOCs volatile organic compounds
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TRRP Cost Containment

• Due diligence
• Establish pre-operation baseline conditions
• Proactive management to prevent releases
• Site-specific cleanup objectives
• Potential use of control-based remedies, except
  if impacts to significant aquifers
• Meter response aggressiveness to risks

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