A chemical-processing facility in Washington hired Barr to provide a third-party applicability and compliance review of the Resource Conservation and Recovery Act (RCRA) following an inspection by the regulating agency. The facility uses flammable liquids as solvents in their synthesis process and produces hazardous waste consisting of those solvents. Barr completed an independent review of the requirements focused on Subparts J, AA, BB, and CC, which encompass the hazardous waste tanks and piping systems. Barr then supported negotiations with the regulatory agency to resolve the alleged violations.
As part of this work, Barr supported the specification, procurement, and mechanical and structural design for the installation of closure devices for sump and hazardous waste tank systems. The scope of work also consisted of completing necessary inspections as well as developing hazardous waste tank system certifications and applications for flammable and combustible liquids stationary tank and piping permits for the modifications to the tank systems. Barr also scoped the leak detection and repair (LDAR) program requirements under Subpart BB for implementation by the facility and a local contractor.
The modified hazardous waste tank system was certified following installation of the closure devices. As a result, the facility was able to resolve the alleged violations and continue operations.
Vice President Environmental Engineer
Senior Chemical Engineer
Senior Environmental Engineer