Waste Combustion Facility Services SYA's technical expertise in the areas of CAA and RCRA combustion-related regulations and RCRA TSD regulations is nationally recognized. Our expertise in working with the regulated community, in addition to the federal, state and local agencies is an outgrowth of our unique experience in the design, development, permitting and operation of waste management facilities. Some of the key services we provide to hazardous waste facilities include (additional details below):
SYA has extensive experience assisting clients in complying with the complex requirements of RCRA and CAA regulations. We worked with industry to coordinate with EPA during the development of the BIF and MACT hazardous waste combustion rules. We have developed RCRA and CAA permit applications and compliance plans for many facilities, and work extensively with the cement industry in communicating regulatory and technical issues. We represented the Cement Kiln Recycling Coalition (CKRC) in meetings with the Administrator and key officials of the EPA. We also organized and coordinated work groups for the past several years addressing BIF and MACT compliance issues with the cement industry, the EPA (Regions 4, 5 and 7) and associated state agencies. The constant change and development of environmental regulations continues to have a significant effect on waste management facilities. Our in-depth understanding of the regulations that are applicable to the hazardous waste industry has made us a leader in providing technical assistance in interpreting, developing, and implementing regulatory programs. Environmental Compliance Audits SYA has considerable experience performing comprehensive environmental audits for the waste combustion industry. An on-site inspection of the facility and a detailed examination of applicable records are conducted to determine the facility's compliance with CAA, CWA, RCRA, SARA, and other applicable environmental regulations. We have particular expertise auditing facilities to assess their procedures for operating in compliance with the BIF and MACT rules. Trial Burn/Comprehensive Performance Tests and Risk Assessments We provide planning and implementation of trial burn/comprehensive performance tests and coordinating risk assessments under RCRA and the CAA. We cover all aspects of compliance testing including preparing test plans, agency negotiations, overseeing testing, data quality assurance, and preparing comprehensive test reports. Our staff has also been extensively involved in coordinating with industry, EPA, and risk assessment firms on preparing risk assessment protocols and reports for combustion facilities as part of the overall permitting process. Regulatory Interpretation and Agency Communication Experienced assistance and representation of combustion facilties for both prevention and resolution of enforcement actions. Collectively, our staff has over 50 years of experience working for state or federal regulatory agencies. This experience not only helps in interpreting regulations, but also in working with the agencies to develop plans for implementing compliance. We routinely work with corporate attorneys or with outside legal representation to develop and implement compliance and business strategies. Clean Air Act Services Services specific to CAA requirements include CAA compliance audits, air permitting (including PSD, NSR and Title V permits), emissions inventories, air toxic evaluations, MACT compliance requirements, stack/source testing, CEM certification, process hazard review, ambient air monitoring, visual emissions assessments, air contaminant dispersion modeling, and data management. We provide engineering, modeling, permitting and testing services using in-house personnel and resources, allowing our clients an option to assess emissions, ensure compliance, and develop permits utilizing the services of only one firm. Technical Studies and Research We perform technical studies on issues ranging from dioxin, metals, and hydrocarbon emission determinations to appropriate practices for management of wastes. Our experience in working with dioxins and furans includes working with clients, regulatory agencies, and the public in developing and implementing dioxin testing programs and source testing programs. Since 1979, we have studied the formation and behavior of dioxins and furans and have presented data to EPA headquarters as well as several EPA regions and state agencies. In 1994, we were retained by the Cement Kiln Recycling Coalition to analyze and prepare a report on dioxin testing results from several cement plants. SYA's extensive background in dioxin research and combustion technology allows us to develop dioxin strategies specific to a particular facility. Communication and Public Relations Support We will work independently with the client or in conjunction with a public relations firm to provide technical support for public meetings and media events. Our experience includes coordinating industry work groups to collectively communicate environmental concerns to state and federal regulatory agencies. Having the necessary background in the sensitivity of public issues, the regulations, and in the technical aspects of hazardous waste management and cement operations, we support our clients in achieving the goal of building trust and a foundation upon which to exchange information within a community. Other services our firm provides include OSHA training for HAZWOPER and operations training with respect to combustion issues, as well as the development of health and safety plans, community exposure evaluations and health profiles.
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