Representative Projects

Waste Characterization for an Impacted Legacy Site

A self-determined hazardous waste pile had the potential to cost a company $2.5 million in disposal costs when they sought guidance from Novesis. Our RCRA experts correctly characterized the waste as nonhazardous with approval of state regulators.

Our RCRA experts applied their 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.

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HRS and NPL Expert Witness Services

When a litigation team needed an expert who understood the Hazard Ranking System (HRS) they turned to Novesis.

When a litigation team related to a closed rocket manufacturer in California needed an expert in the Hazard Ranking System (HRS) who  understood EPA procedures for identifying and listing sites on the National Priorities List (NPL) they turned to Novesis. As former regulators and senior environmental managers, our experts have extensive expertise in the HRS and NPL.

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RCRA Corrective Action

Waste characterization can have alarming costs. Novesis experts use RCRA-approved approaches to correctly analyze and characterize waste to not only control project costs, but also to make remediation safe and fully compliant.

Our experts utilized a 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 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.

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Expert Witness Testimony

When a client needed an expert witness to help resolve a dispute, they turned to Novesis to communicate the complex situation in clear, understandable terms.

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.

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RCRA Facility Investigation Experts

An international chemical company received a devastating EPA RFA Report and turned to Novesis for confirmation of the findings.

In their investigation, our RCRA experts discovered that many of the identified SWMUs in the EPA RFA were not accurately classified. Through analytical testing and negotiation, the site is now down to a single SWMU with minimal impacts.


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Waste Characterization Dispute

A hazardous wastestream was costing a chemical manufacturer more than $1 million per year in disposal costs. Novesis successfully disputed the waste’s incorrect characterization with full approval of state regulators.

Our experts crafted a 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”.

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Litigation Support

In a lawsuit involving a large 500,000-gallon storage tank, Novesis experts were called in for expertise in the characterization of what the container in question held. Our testimony helped the case move from impasse to settlement.

A Novesis expert was called to serve as expert witness for a case involving RCRA hazardous waste. Specifically, the characterization issues that could arise when a mixture of potentially “listed” wastes co-mingled in a vast 500,000-gallon storage tank. Our expert was able to resolve the issue of listed waste for the court and the case was settled to our client’s satisfaction.

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Wastewater Sludge Clean Water Act Exclusions

When it comes to waste characterization, every state has unique requirements and exclusions. The Novesis team understands the nuances of environmental law from state to state and helped a New York chemical company get their sludge characterized correctly and in accordance with state regulations.

Our team crafted an argument for a publicly held chemical company in the State of New York 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.

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An Uncommon CERCLA Remediation Strategy

A South Carolina steel company acquired a fabrication facility — and any potential CERCLA liability — in a merger and acquisition. When an area of the facility was found to be impacted, Novesis developed a clean-up plan that was fast, cost-effective, and met the goals of state regulators.

A steel company acquired a South Carolina fabrication plant as a part of a merger and acquisition. As part of the acquisition, the company 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 property. The company brought in Novesis experts to develop a remediation strategy that satisfied state regulators. The plan, which focused on site remediation and removal of impacted soils using field screening methods, took just six months from discovery to state acceptance of clean up and resulted in savings of more than $550,000 for the company.

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Enforcement Assistance

The threat of state or federal penalties can be alarming. One company facing a steep fine turned to Novesis for an opinion about RCRA citations levied by the EPA — citations that were ultimately found to have no standing at the state level.

A company faced a steep, proposed penalty for RCRA citations. The company, which had blended low BTU fuels destined for burning in an RCRA Interim Status Boiler and Industrial Furnace (BIF), had been deemed to be in violation of EPA guidelines. Novesis successfully argued against the violation based on EPA guidance being superseded; the state never adopted the guidance as regulation.

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