The complex federal, state and local regulations governing handling and management of hazardous wastes can appear to be a bewildering and overwhelming labyrinth to navigate, but AEM’s staff understand and stay current in the latest rules and compliance obligations, and have successfully assisted industrial, institutional and commercial clients in maintaining compliance with these rules.  We have prepared 30+ Part B Hazardous Waste Permit Applications pursuant to the Resource Conservation and Recovery Act (RCRA), the federal “cradle to grave” regulations governing management and handling of hazardous wastes.  AEM has successfully performed both RCRA Facility Assessments and RCRA Facility Investigations, Corrective Measures Studies, and Corrective Action Implementation at numerous sites, as well as the parallel process under Superfund:  Preliminary Assessment/Site Investigation, Remedial Investigation/Feasibility Studies, and Remedial Design/Remedial Investigations.  AEM will be glad to have one of our experienced RCRA or Superfund managers discuss ways we can assist with complex hazardous waste issues.


Hardware Manufacturing Facility - Lawrenceville, Georgia
AEM has provided complete environmental consulting services for a RCRA-regulated hardware manufacturing facility in Georgia which formerly included an extensive electroplating operation for the past 18 years. Previous primary operations included the production of casket hardware and fabric liners. Operations formerly included zinc, nickel and copper plating, vacuum metalizing, phosphate priming, powder coating, spray painting, and metal (slush) casting.

AEM is presently managing all RCRA-regulated activities at the facility including the on-going operation and maintenance of two groundwater recovery and remediation systems. Site activities have included completion of Part B permit application and modification, closure, and certification of all regulated units. Post-closure care activities currently include semiannual monitoring and reporting required under RCRA regulations to document effectiveness of the corrective action.

EPD classified four tanks and associated process lines as RCRA units. A RCRA clean closure was not possible as there was contamination of groundwater and soil. AEM was responsible for the following activities that were undertaken in response to EPD's findings:

• RCRA closure plan development, oversight, and certification of all units (landfill, evaporation tanks, and process tanks).
  
• Assessment of soil and groundwater for metals, VOCs, and cyanide to background.
  
• Development of an RCRA Part B Permit for Post-Closure Care.
  
• Corrective action design and implementation of groundwater at RCRA units including multiple aquifer zones (residuum and bedrock) for metals and cyanide.
  
• Reduction by over 80 percent of the number of solid waste management units (SWMUs) and areas of concern (AOCs) at the site requiring investigation as part of an RFI through negotiation with EPD.
  
• Conduction of a site-wide, multiple SWMU and AOC multimedia RFI delineation to determine the nature and extent of contamination.
  
• Conduction of Risk Assessment to determine cleanup concentrations and preparation of an RFI report.
  
• Conduction of Corrective Measures Study to identify appropriate corrective action technologies for off-site VOC contamination; design and implementation corrective action of SWMUs to include carbon treatment of groundwater.
  
• Development of Interim Corrective Action Plan approved by EPD and implementation by AEM.
  
• Corrective action ongoing at RCRA-regulated units and SWMUs. AEM is performing daily operations and maintenance of systems.
  
• Semiannual groundwater monitoring and semiannual reporting to the agencies per the post-closure permit for RCRA-regulated Units and SWMUs.
  
• Part B Permit revisions as necessary, public notices and meetings.