RCRA Compliance
Resource Concepts, Inc. has extensive experience assisting companies in compliance with RCRA.
Niotan, Inc – Moundhouse, NV
Niotan, Inc is constructing and operating a Tantalum ore processing facility in Moundhouse, Nevada. Tantalum ore is processed at only five facilities throughout the world. Tantalum is the preferred metal used in capacitors for the new electronic devices used by man including cell phones, computers, and other wireless equipment.
Tantalum processing requires the use of large quantities of hazardous materials including elemental sodium, argon gas, as well as hydrofluoric, nitric, and hydrochloric acids. The process also requires the use of large quantities of ionized water and the operation of a wastewater treatment facility to support the tantalum process. Since tantalum production processes were patented in the 1960s and the demand for significant quantities of specific grades of tantalum only began in the 1980s, the tantalum process still requires a significant amount of research and development to perfect.
RCI has assisted Niotan with civil engineering, environmental, and regulatory assistance during the construction and “start-up” of the facility. These services include assistance with hazardous material storage and permits, hazardous waste determination, hazardous generator compliance (corrosive and ignitable waste), Chemical Accident Prevention Program evaluation, Air Quality permits, and Washoe County – Lockwood Regional Landfill authorization permits.
Hi-Shear Industries and Aerojet General Corporation, Nevada
Hi-Shear Industries (Defense Systems Corporation) was operating a thermal treatment unit for disposal of solid propellants generated at the facility under an interim status authorization from the Nevada Division of Environmental Protection. As a result of violations of their interim status permit, Hi-Shear was ordered to cease and desist all thermal treatment and all process operations, which generated hazardous waste. RCI was retained to address the numerous violations cited. These activities required RCI to prepare an action plan to identify all hazardous waste generated at the facility and prepare a hazardous waste management plan consistent with 40 CFR 262. This plan required the development of a contingency plan and emergency procedures. In consideration of the explosive nature of the waste and regulatory concerns, a “cradle-to-grave” on-site manifest system was developed to track the generation, transportation, and treatment of hazardous waste.
RCI was responsible of the development of a RCRA – Part B permit application for on-site thermal treatment (open burning) of all solid propellants and materials contaminated with ammonium perchlorate or propellant at the facility. This RCRA – Part B required the identification of the 100-year flood plain; construction of storage facilities; and the design, construction, and preparation of operation and maintenance procedures for the open burn facility.
The RCRA Part B permit application was assumed by Aerojet Nevada following purchase of the property. RCI conducted investigation of ammonium perchlorate contamination resulting from the violations at the original open burn facility, remediation, and closure of the original open burn facility, as well as design of a new open burn facility to be operated under the RCRA – Part B permit.
During this period, an assessment of the site for additional contamination by ammonium perchlorate was initiated by RCI. Working closely with Defense Systems Corporation, Aerojet Nevada, and the Nevada Division of Environmental Protection, RCI identified contaminated areas, assessed the health and safety affects of ammonium perchlorate in soils, and supervised remediation and disposal activities.
Little Mondeaux Limousine Ranch – Genoa, Nevada
The Little Mondeaux Limousine Ranch operated a small landfill for the disposal of refuse generated as a result of their ranching operation. The Nevada Division of Environmental Protection determined that the Ranch had inadvertently disposed of approximately 80 to 100 drums within this landfill. As a result of this determination, Nevada Division of Environmental Protection issued an order to the owner requiring the preparation of an action plan to determine the types of materials disposed of in the landfill and the extent of contamination. In consideration of this order, the owner retained RCI to answer the specific requirements noted. This resulted in the preparation of an action plan to conduct a reconnaissance of the landfill to determine what materials were disposed of and the location of deposition. The initial reconnaissance found that solvents, diesel fuel, oils, and greases had all been disposed of in the landfill, resulting in an expansion of the investigation to determine the depth of contamination and whether or not the ground waters and surface waters in the immediate area had been contaminated. This revised plan required the drilling of wells in and around the landfill, moderate sampling of the soils during construction of these wells, and sampling of the ground water.
Results of the preliminary investigation prompted NDEP to require additional site assessment and hazardous waste remediation at the landfill. A site Safety/Contingency Plan was developed by RCI designating health and safety measures, monitoring equipment and procedures, personal protective equipment, and emergency response procedures. RCI prepared a remediation and closure plan, which provided for the construction of a new cell adjacent to the existing landfill.
Mallory, Inc. / Carson City, Nevada
RCI provided services to Mallory Inc. for their inadvertent disposal of hazardous waste in the Ormsby Sanitary Landfill. The disposal of waste containing the characteristic of hazardous waste, as defined by EPA Toxicity, required an assessment of its potential impact on the landfill and leachate. This assessment, which included an evaluation of landfill solid-liquid loading rates and predictive water balance based on atmospheric and man-induced liquid loadings, determined that the potential for leachate from the landfill was remote. The assessment provided recommendations for improved management of the landfill with respect to short-term and long-term drainage requirements.