Although most day-to-day RCRA compliance is handled by environmental management staff at industrial facilities, the RCRA hazardous waste management regulations remain a “mind-numbing labyrinth” where interpretation of even the apparently simplest rule may involve tricky issues or have unexpected ramifications. 

RWCS attorneys are very experienced in RCRA hazardous waste management and corrective action issues such as the following:

• In-depth understanding of RCRA generator, transport, storage, land disposal restriction, TSD facility, and air emission standard requirements and issues.
• Recycling exemptions and reclamation activities likely to come under EPA’s new (October 2008) Definition of Solid Waste Rule (at varying stages of adoption or pending adoption in Oklahoma and other states).
• Identification of solid and hazardous waste including application of 40 CFR 261.2, Table 1 rules to secondary materials.
• Auditing RCRA compliance.
• Interplay of Clean Water Act and RCRA regulations with regard to applicability and scope of domestic sewage exclusion.
• RCRA corrective action program and requirements.

Representative experience includes:

• Mark Coldiron handled a ten-year case involving a major CERCLA Superfund/RCRA corrective action site in Bartlesville, Oklahoma where the RCRA corrective action program was the main remedy driver.  Coldiron advised on all aspects of the corrective action requirements for the site from negotiation of a consent decree through implementation and facility closure.
• Keith Klein and Don Shandy investigated RCRA compliance issues at a major industrial research facility; including allegations of improper storage, disposal, and transportation.
• Keith Klein has years of experience with RCRA hazardous waste management and corrective action issues from his involvement with these issues at military installations and in advising industrial facilities in private practice.