Background

The management of hazardous waste has become one of the most difficult, time consuming, and expensive aspects of environmental compliance. With the passage of the Resource Conservation and Recovery Act (RCRA) in 1978 and Hazardous and Solid Waste Amendments of 1984 (HSWA), it has become increasingly difficult to know what constitutes a hazardous waste and how to handle it. Failure to comply with these regulations has resulted in significant penalties for many unsuspecting facilities. Both civil and criminal liabilities are a real concern for facility managers.

These regulations deal with:

  • Generator requirements
  • Accumulation point management
  • Transportation requirements
  • Special requirements for permitted treatment, storage, and disposal (TSD) facilities

Services

Davis & Floyd, Inc. has provided RCRA consulting services since promulgation of the original Act. Through our understanding of the RCRA program, we have assisted industries in complying with the requirements of the Act and have represented clients before State and Federal agencies.

RCRA-related services we provide include:

  • Part B Permit Application Preparation
  • Waste Characterization
  • Hazardous Waste Training
  • Groundwater Assessments
  • Groundwater Sampling
  • Hazardous Waste Sampling
  • Laboratory Analysis
  • Closure Plans
  • Post Closure Care Plans
  • Topographic Surveys
  • Remedial Investigation/Feasibility Studies (RI/FS)
  • Corrective Action Plans
  • Delisting and ACL Petitions
  • Hazardous Waste Characterization
  • Design of Hazardous Waste Facilities
  • Auditing of RCRA Compliance
  • Risk Assessments
  • Experience

We have been involved in RCRA consulting for all types of facilities including:

  • Hazardous Waste Generators
  • Hazardous Waste Incinerators
  • Hazardous Waste Treatment Units
  • Hazardous Waste Landfills
  • Hazardous Waste Piles
  • Hazardous Waste Storage Facilities (both bulk and containers)
  • Hazardous Waste Surface Impoundments

Representing operators of these facilities before various regulatory agencies and providing expert witness testimony in civil lawsuits, our staff has an in-depth understanding of the Federal and State regulations addressing hazardous waste. With this knowledge and experience, we have been successful in assisting industry in obtaining favorable rulings that impact their overall hazardous waste management programs and their bottom lines. Our staff routinely provides RCRA compliance audits to facilities and trains their personnel in the proper handling and disposal of hazardous waste.

We have provided hazardous waste management consulting to various industrial facilities; Federal, State, and local governmental agencies; commercial facilities; and private individuals. We have worked with very simple, small quantity generators to large, complex National Priorities List (NPL) sites. We have managed projects involving the excavation and removal of drums containing flammable hazardous wastes from a municipal landfill to the design of contaminated groundwater treatment systems.

Our in-house environmental laboratory allows us to make quick, knowledgeable decisions on how to handle specific wastes. Our ability to characterize these materials quickly has enabled us to make timely decisions, often while construction equipment and personnel were standing by awaiting instructions. Such services have resulted in significant cost savings to our clients.