RCRA Services for Flare Manufacturer

EnSafe developed synergistic Part B and Title V permits that provide operational flexibility for this military flare manufacturer. EnSafe wrote the revised Part B permit application in accordance with updated Resource Conservation and Recovery Act (RCRA) Subpart X regulations for miscellaneous units. The significant portion of this project involved human health and ecological risk assessments evaluating the soil, water, groundwater, and air pathways.

EnSafe’s RCRA responsibilities for this 20+-year client include:

• Developing the air pathways assessment,
• Performing thermodynamic and dispersion modeling of the burn scenarios to predict the products of combustion from the unit and their subsequent transport and deposition in order to conduct a predictive risk assessment,
• Evaluating AP-42 emission factors for specific wastes generated and including them in the modeling scenarios to determine their subsequent deposition in order to conduct the risk assessment,
• Engineering designs for improvements to the unit,
• Completing closure and post-closure plans, and
• Preparing the application in accordance with RCRA Subpart X regulations.

EnSafe partnered with state regulators, providing application sections as they were completed to expedite review and minimize revisions that would delay approval.

Services Provided

• RCRA Part B Subpart X permitting
• Title V permitting
• Dispersion modeling
• Risk assessment
• Regulatory negotiation
• Clean Water Act compliance
• Spill Prevention, Control, and Countermeasure Plans
• Storm Water Pollution Prevention Plans
• Industrial hygiene surveys (asbestos and mold)