Hazardous Waste

Strategic Environmental Analysis , L.C. (SEA) is an environmental management consulting firm that serves clients in all fields of waste management including: hazardous waste, toxic waste, solid waste, radioactive and nuclear waste, recycling and industrial wastewater. SEA's primary service involves analyzing the impact of business, regulatory and technology factors on the waste management marketplace, and devising strategies to cope with future market conditions. SEA's other areas of practice include: analysis of EPA, DOE and state regulations; custom market surveys; due diligence investigations; expert witness testimony and litigation support; technology assessment; multi-client research; and policy development and representation.                    <Expert Witness/Litigation Support>

SEA’s Hazardous Waste Projects typically involve the following: a Market Study or Technology Evaluation for a commercial waste management firm; a Regulatory Analysis of RCRA regulations agency; an Expert Report on the basis and purpose of RCRA’s Corrective Action, Closure and/or Lagoon Retrofitting Provisions for an insurer; a Due Diligence investigation for a private equity firm; assisting a commercial firm with changes to Federal regulatory policy or local permitting decisions. The links listed below summarize some of SEA’s recent and historical Hazardous Waste Projects, particularly those involving Federal and State RCRA/CERCLA regulatory programs:

Coal Combustion Residuals Rulemaking

SEA was retained by a consortium of national environmental groups to analyze the historical impact of RCRA regulations on the recycling of hazardous waste since the inception of the Program in 1980.  Final report also analyzed the many false claims of “stigma” purportedly associated with RCRA regulation of waste recycling practices. 

Dry cleaning Wastes II

Served in a consulting capacity to a litigation team attempting to determine what the dry cleaning industry knew about the health and environmental hazards of the land disposal of PCE and when it knew it.

Dry cleaning Wastes III

Served as a consultant to a litigation team attempting to determine the state of knowledge regarding the potential for dry cleaning wastes, particularly PCE, to leak from sewer systems and contaminate groundwater.

Environmental Services Demand

Conducted a market study/due diligence investigation for a private equity firm seeking to invest in an environmental services company. The project involved assessing the firm’s competitive posture relative to its peers and the likelihood of sustained demand for the firm’s services.

International Seminar on Preventive and Remediation Technologies

SEA was retained by various Federal agencies to prepare a detailed presentation on the structure of the U.S. hazardous waste regulatory programs, and the preventive and remediation technologies that have been developed to implement these programs.  Presentation was used as the basis for a seminar on waste treatment technologies for a group of academicians and government officials from several Middle Eastern countries.

Mercury Recycling Regulations

SEA worked with a leading recycler of mercury wastes to address various loopholes in current regulations and to develop new legislation to enhance the recovery of mercury from a wide range of manufacturing and consumer wastes.

Organic Chemical Exposures

Was retained as a RCRA/CERCLA/Industry Practices Expert in a case involving land disposal of chlorinated organic wastes. Prepared an Expert Report on state of knowledge regarding the potential for chemicals involved and the land disposal practices to cause groundwater contamination.

Organic Chemical Exposures II

SEA was retained as a RCRA/CERCLA/Industry Practices Expert in a case involving property damage and lost property values resulting from the disposal of chlorinated organic wastes. Prepared an Expert Report on state of knowledge regarding the potential for chemicals involved and the land disposal practices employed at the site to cause groundwater contamination.

RCRA Corrective Action

Served in a consulting capacity to assist a client group in determining the applicability of RCRA’s Corrective Action provisions to various operational units at a complex manufacturing facility.

RCRA Corrective Action II

Served in a consulting capacity to a client group assessing the applicability of RCRA’s Corrective Action, closure, and post-closure requirements to various land-based units managing inorganic, metal-bearing wastes.

RCRA Corrective Action  III

SEA provided background research and consulting support to a group of private parties defending against an enforcement action claiming violation of RCRA’s Corrective Action provisions.

RCRA Non-compliance at a Steel Plant

A group of private parties retained SEA to provide guidance on the applicable RCRA regulations and to prioritize the historical and ongoing violations at a major steel production facility.

Remediation Waste Arbitration

SEA was retained as a RCRA regulatory compliance and benefits of non-compliance expert in an arbitration involving the allocation of RCRA and Superfund cleanup costs between the current and original site owners.  Prepared an expert report which compared the compliance history of the firms involved,  and analyzed the impact of various dilatory actions of the current site owner on the overall remediation of the site.  Report was largely used in assigning a value to the equitable factors in the cleanup cost allocation formula.

Surface Impoundment Retrofitting

Prepared an Expert Report for a client group on the scope and basis of RCRA’s surface impoundment retrofitting provision. Report examined the extent to which such activities reflect compliance with permit requirements and therefore were considered a routine business expense.

Unpermitted Burning

Was retained by a government agency to support an ongoing enforcement action against a recycling facility burning and blending hazardous waste without possessing the proper RCRA permit. Prepared an Expert Report regarding the scope and applicability of RCRA’s incineration and thermal destruction regulations to the facility in question.

Historical Projects

Analysis of EPA Petroleum Recycling Regulations Boilers and Industrial Furnace (BIF)  Catalyst Recycling Market Study Closure Of Wastewater Treatment Lagoons  Comprehensive Hazardous Waste Market Study Dry Cleaning Waste Hazardous And Solid Waste Market Comprehensive Study Inorganic Chemical Recycling Inorganic Recycling Interpretation Of Recycling Regulations Lagoon Closure Insurance Coverage Case Legal Challenge to State Permitting Standards Legal Challenge to State Facility Siting Requirements

Mercury Waste Treatment Mexican Hazardous Waste Combustion Market Forecast National Engineering Lab - Mission Redefinition New Waste Treatment Technology Organic Chemicals Recycling Paint Waste Management Technology Petroleum Waste Listing Litigation Recycling of Filter Media  Recycling: Strategic Evaluation Recycling of Steel Industry Wastes Remediation Technology Assessment Soil Remediation Strategy Solvent Recycling Sector Specific Application of an Environmental Technology Thermal Destruction Markets Thermal Destruction Services Underground Storage Tank Cleanup: Status and Outlook