Projects

Representative Projects

  • Applied our comprehensive understanding of RCRA to design an effective sampling plan, for an international steel manufacturing company, utilizing statistical concepts allowed by the regulations, to collect a “representative data base” of samples. This allowed an appropriate determination of non-hazardous for a substantial remediation waste pile which had had been initially determined (by the Company) to be hazardous under RCRA. This determination, fully approved by the State regulatory agency, saved the Company over $2.5 million in disposal costs.
  • Crafted successful argument for German company’s US chemical manufacturing facility that their low pH (<1.5 pH) acid liquid, generated after completion of the manufacturing process, should not be classified as RCRA hazardous waste.  The cost to dispose of this acid as hazardous waste was budgeted for over $1.5MM/year.  The State of South Carolina agreed (in writing) with our position that this liquid was excluded from being characterized as a “Solid Waste” under RCRA as a “sludge”.
  • Expert witness services for litigation involving a closed rocket manufacturer in California.  Provided consulting expert services with respect to the Hazard Ranking System (HRS) and EPA procedures for identifying and listing sites on the National Priorities List (NPL).
  • Utilized RCRA approved approach for accurately creating a “Representative Database” to properly characterize a large on-site contaminated soil remediation project (at a RCRA Permitted Facility, as part of RCRA Corrective Action on a newly identified SWMU). the initial determination by the company, based on several TCLP grab samples, was that the entire pile needed to be managed as hazardous waste.  Our approach resulted in determination of the remediation pile of metals impacted soil could be managed as be non-hazardous solid waste.  The State agreed with our characterization and allowed the soil stockpile (45,000 CYs) to be sent to a local subtitle D landfill.  The savings to the company was estimated to be several million dollars in transportation and disposal costs.
  • Crafted persuasive argument for a global chemical company’s site in Illinois that pesticide impacted soils on a legacy site should not be characterized as RCRA Hazardous based on the specific language of 40 CFR 261.33(d) “Commercial Chemical Products” definition, guidance and preamble discussion.
  • Comprehensive RCRA multi-day audit for automobile manufacturer.
  • Expert witness services for a private client for RCRA violations cited by State government on a “Speculative Accumulation” issue that also involved Mixed (Radiological) Waste.
  • RCRA RFA Confirmatory Sampling and RFI for International Chemical Company.  Eliminated a number of SWMUs identified in the initial EPA RFA Report, through analytical testing and negotiation. Site is now down to a single SWMU with minimal impacts.
  • Expert witness services on litigation that involving RCRA hazardous waste characterization issues for mixing of potentially “listed” wastes in a large (500,000 gallon) storage tank.  Case was settled to client’s satisfaction once the issue of potential “listed waste” was resolved.
  • Crafted an argument for a publicly held chemical company in the State of NY that sludge in a wastewater lagoon should be classified as non-hazardous waste due to interpretation of 40 CFR 261 exclusions for wastewater systems with CWA 404 Permits.  Review and position paper based on regulations and preamble discussions.
  • Provided testifying expert for publicly held corporation involved with mile long chlorinated solvent groundwater plume.  Testified with respect to SC environmental regulations, the SC Pollution Control Act, and DHEC internal operations and procedures.
  • Provided project oversight for Voluntary Assessment and clean-up in a Southeastern State, as part of a multi-site due diligence and purchase agreement.
  • A Steel Company client acquired a S.C. fabrication plant as a part of a merger and acquisition and assumed all CERCLA liability. Shortly after beginning significant investment on the facility it was discovered that lead based paint and drums had been buried on the back portion of the property. Our approach was to work with State regulators and have them agree to advance past significant pre-remedial work and focus instead on site remediation and removal of impacted soils, utilizing field screening methods. This resulted in savings for the company of over $550,000 and completion of the project from discovery to state acceptance of the clean-up in less than 6 months.
  • Successfully defended a client against RCRA citations for blending low BTU fuels destined for burning in a RCRA Interim Status Boiler and Industrial Furnace (BIF).  Argued against applicability of BIF violation based on EPA Guidance being superseded and the State never adopting EPA that guidance as regulation.  Company avoided a significant monetary penalty that had been proposed.
  • Completed multi-State due diligence audits for client’s intended acquisition of a regional hazardous waste management company.
  • Completed audit for German company’s evaluation for potential acquisition of a regional chemical company located in Georgia.
  • Managed a Global Manufacturing company’s due diligence for determination of potential acquisition of a South Carolina based military vehicle manufacturer.
  • Managed a USEPA Region 2 (West Virginia) Corrective Action remediation for NPL pesticide blending facility.
  • Managed a remediation of a pesticide and fertilizer warehouse fire in Georgia.  This project required interaction and with Lloyd’s of London, the client’s insurer for the facility.
  • Prepared and submitted of numerous RCRA Part B permit applications.
  • Prepared and submitted numerous RCRA Part B permit modification requests and/or permit renewal applications.
  • Preparation of TSCA permit for PCB storage facility at a RCRA permitted TSD Facility.
  • Client representative on multi-party NPL Site in North Carolina that was a former RCRA permitted TSD.
  • Managed in-situ soils remediation project (bioaugmentation and biostimulation) at a closed chemical manufacturing facility in SC.
  • Managed mixed LNAPL and DNAPL plume from two separate sources at an automobile dealership in North Carolina.  Monitored Natural Attenuation was the approved remedy for the site, with long term monitoring and data review.
  • Managed a RCRA Closure of an Arsenic groundwater plume at a Wood Treatment Facility.