RCRA Corrective Action

Facilities that maintain hazardous-waste management units are subject to the Resource Conservation and Recovery Act (RCRA) Part B permitting process. Our lawyers often assist clients in obtaining these permits, providing experienced advice to help minimize the costs, delays and operational burdens often associated with this process.

Our lawyers have in-depth knowledge of the regulatory framework and guidance applicable to clean closure of inactive hazardous waste management units. Drawing on this knowledge, we assist our clients in successfully achieving clean closure, thereby avoiding the need to obtain a RCRA Part B post-closure permit and the attendant RCRA corrective action requirements. Where corrective action is required by administrative order or permit, we provide effective support to facility owner/operators in streamlining the corrective action process.

Representative Experience

  • Assisted a pulp-and-paper company in obtaining approval from the Arkansas Department of Pollution Control and Ecology of a clean closure certification for hazardous-waste surface impoundments at a former wood-treatment facility.
  • Represented a commercial-waste treatment facility in obtaining the first hazardous-waste treatment permit issued by the State of Georgia.
  • Counseled a chemical manufacturing company in obtaining favorable reconsideration of an initial state agency determination expanding corrective action requirements under an RCRA Part B post-closure permit to facilities previously owned by corporate affiliates on adjacent properties.
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