Releases or threatened releases of hazardous substances and the management of hazardous wastes are subject to a complex web of EPA regulations issued under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, also called Superfund) and Subtitle C of the Resource Conservation Act (RCRA). SCS Engineers has assisted clients in complying with these regulations from the outset; our professionals understand not only what the regulations say, but why they say what they say.

  Superfund

Superfund addresses uncontrolled releases or spills of hazardous substances. SCS assists clients in each phase of the Superfund process, from identification and preliminary assessment through screening investigations, comments on proposed listings, remedial investigations, feasibility studies, remedial design, construction engineering, and long-term operation and maintenance.

To avoid possible conflicts of interest, we work only for entities potentially responsible for Superfund response costs (the firm does no work for the U.S. Environmental Protection Agency regarding Superfund enforcement).

Much of our Superfund experience has been for solid waste landfills included on the National Priorities List (NPL). Landfill sites present numerous challenges for the Superfund program, and SCS professionals are experts in the unique problems associated with these sites.

Normally, it is better (and significantly less expensive) for a potentially responsible part (PRP) to take control of the remedial investigation/feasibility study (RI/FS) process, rather than to allow the EPA, the state, or their contractors to conduct the RI/FS. By retaining qualified consultants, PRPs can gather enough (and only enough) information to support the selection and design of a cost-effective remedial action. SCS helps PRPs control the RI/FS process and keep it focused.

  Remedial Design and Construction Engineering

SCS is an engineering firm. Our study work is oriented towards finding practical solutions to problems. Once a solution is identified, we help implement it by preparing construction plans and specifications, and by providing continuing technical oversight (construction quality assurance) for remedial actions. Throughout these and all assignments, cost control is a first priority. We thrive on repeat client business and realize this comes only when technically correct solutions are also economically sound.

  Construction and Operations

Through our Field Services group, SCS offers construction and design-build services for remedial actions. Field Services also provides specialized expertise in long-term operation and maintenance of remedial action technologies.

  RCRA Subtitle C

The Subtitle C program regulates hazardous waste generators; transporters; and treatment, storage, and disposal (TSD) facilities. SCS helps the regulated community comply with all phases of the Subtitle C program, from determining whether their wastes are hazardous, to permitting and design of TSD facilities, to the design of closure plans and corrective action for releases.

  RCRA Subtitle C Compliance and Permitting

EPA's hazardous waste regulations (and similar state regulations) are complicated; even those responsible for enforcing the regulations are inconsistent in interpreting them. Compliance audits conducted by experienced, independent professionals can often suggest improvements in operations to minimize the possibility of unintentional violations.

  Corrective Actions

Facilities requiring a permit (including a post-closure care permit) under the Subtitle C program are subject to the corrective action requirements of RCRA. The corrective action program applies to releases from regulated hazardous waste units as well as almost any other portion of the facility. The challenges for those subject to the corrective action program are to remain focused on the real problems during the RCRA Facility Investigation/Corrective Measures Study (RFI/CMS) process, and to implement necessary interim and final corrective measures without unnecessary study or delay.

  Expert Testimony and Private Cost Recovery Support

SCS professionals are often called as expert witnesses for plaintiffs and defendants in cost recovery litigation under Superfund. Such litigation typically involves the question of whether responses have been consistent with EPA's National Contingency Plan.

SCS professionals also provide expert testimony on the technical requirements of the Subtitle C program. Often, such testimony is provided as part of the response to an enforcement action before an administrative law judge.

SCS offers comprehensive Superfund and hazardous waste services to assist you in complying with the complex web of EPA regulations.

  Superfund

• Technical Assistance in Negotiating Administrative Consent Orders
• Preparation, Negotiation, and Implementation of Work Plans
• Risk Assessment for Human Health and Environmental Effects
• Preparation of Construction Plans and Specifications
• Construction Quality Assurance
• Long-Term Operation, Maintenance, and Monitoring
• Technical Support for Private Cost Recovery

  RCRA Subtitle C

• Design of New Facilities and Upgrades to Existing Facilities
• Preparation of Hazardous Waste Permit Applications
• Waste Minimization Plans
• Regulatory Compliance Support
• Closure Plans and Construction Overview
• Preparation and Implementation of RFI/CMS Work Plans for Corrective Action
• Interim and Final Corrective Measures
• Post-Closure Monitoring and System Operation and Maintenance