DPRA has over 20 years experience consulting with federal agencies on waste management issues relative to the requirements of the Resource Conservation and Recovery Act (RCRA), the Toxic Substances Control Act (TSCA), the Clean Air Act (CAA), the Clean Water Act (CWA), and the Department of Transportation (DOT) requirements, as well as the application of these laws in concert with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

We offer consulting in the following areas, independently or as part of a comprehensive package that can be dovetailed with our pollution prevention and other environmental compliance services. Our clients include the Department of Energy (DOE), Environmental Protection Agency (EPA), Department of Defense (DoD), and the U.S Postal Service.

  • Regulatory Analysis

  • Waste Characterization and Disposition Options

  • Assessment Waste Package and Shipping 

  • Technology Evaluation and Demonstrations

DPRA offers clients complete waste management compliance services incorporating applicable regulatory requirements and best management practices in the areas of permitting, reporting, storage, shipment, recycling, reusing, selling, and disposal.

In addition, our staff is experienced in planning, coordinating, and conducting audits of both government and commercial treatment, storage, and disposal facilities to evaluate the potential for liability and plan compliant disposition of client wastes.

DPRA professionals are experienced in understanding the market factors, both economic and regulatory, that drive the feasibility of a technology. DPRA has conducted numerous technology evaluations for a variety of waste streams generated from various industry sectors. Our clients have included federal agencies, multinational corporations, financial corporations, and law firms.

Our staff members have identified and implemented technologies, provided third-party review of proposed technologies, and assessed the effects on treatment technologies of major modifications to existing processes. DPRA staff has also evaluated the potential market, along with marketing strategies, for new and innovative waste treatment technologies.

DPRA continuously reviews new and past interpretations of regulations issued by environmental agencies, technical clarifications of regulations, proposed rules, final rules, preamble language, and legislative history. This enables us to maintain our regulatory expertise and provide clients with real-time notices of potential problems. As a result, clients are able to minimize the effects of regulatory changes on their overall operations, compliance, and efficiency.

Selected Projects

The following project descriptions demonstrate how DPRA's expertise in waste management benefit our clients.

Waste Packaging and DOT Compliance Analyses for DOE Oak Ridge National Laboratory (ORNL)

DPRA consults with the DOE ORNL on matters of procurement, standard procedures, specification development, and compliance with waste shipment requirements, including material classifications, manifesting, labeling, and placarding.

DPRA professionals have decades of experience in providing Department of Transportation (DOT) support to ensure timely, compliant, and safe shipments of wastes and hazardous materials both internationally and domestically. DPRA constantly monitors any changes in DOT regulations and interpretations. As changes occur, specifications used across the DOE complex for packaging are quickly modified. Subsequently, DOE uses these specifications to maintain the supply of appropriate packaging for storage and shipment available at each facility.

These specifications are made available to all DOE facilities via the Internet. DPRA further assists ORNL by reviewing and releasing all packaging orders and preparing quality assurance inspection checklists to ensure compliance with DOT regulations as well as ORNL procedures and DOE orders.

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Waste Management Baseline Review for DOE Oak Ridge Operations (ORO) Environmental Management

Over the last two years, DPRA performed a baseline review for Bechtel Jacobs Company of 133 hazardous waste-generating projects in the life-cycle baseline at the Oak Ridge Reservation and off-site projects. This review was done for the Facility Assets Utilization division of the DOE/ORO office.

The purpose of the review was to provide alternative methods to reduce waste generation, enhance project performance, suggest systems changes to increase efficiency, reduce waste generation, reduce disposal capacity needed, and offer reasonable suggestions for project sequencing while maintaining adequate protection of personnel, the public and the environment.

All project, cost, and waste generation information available was reviewed and key project management personnel were interviewed. These efforts culminated in a set of recommendations that included corporate systems changes and a suggested short list of projects that would provide the most benefit to the DOE, the public, and the environment. If implemented, DPRA's recommendations will result in a cost savings of approximately $271,423,000 and a reduction of 26,864,525 cubic feet in disposal capacity requirements.

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Regulatory Analysis for Scrap Metal Disposition

DPRA recently completed a detailed review of the federal regulations governing the management, recycling, reuse, and disposal of DOE scrap metal. This analysis included an in-depth review of pertinent case law, preamble language, legislative history, and regulatory interpretations of RCRA, CERCLA, TSCA, and the newly enacted Superfund Recycling Equity Act.

DPRA provided the DOE/ORO Facility Assets Utilization division with reasonable options for managing a constantly growing inventory of scrap metal with no additional environmental impact. The review included information regarding recycling, reuse, sale, and disposal of scrap metal and waste items.

This analysis will be used by DOE to compile a handbook for generators of scrap metal at DOE facilities to help them make wise, efficient, and effective decisions regarding the disposition of these materials.

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Development of DOE Waste Recycling Facility Audit Plan and Checklists

In FY 2000, DPRA provided regulatory oversight checklists and procedures to be used by DOE for evaluation of commercial recycling operations that express an interest in receiving scrap metal from the DOE complex.

This task required extensive knowledge of RCRA, TSCA, CERCLA, CAA, CWA, Occupational Safety and Health Administration (OSHA), DOE Quality Assurance (QA), and Nuclear Regulatory Commission (NRC) requirements for safe management of wastes and hazardous materials.

DPRA's thorough understanding of DOE waste management processes, together with our extensive experience in commercial facility audits, enabled us to satisfy our client's needs. We provided an audit program capable of identifying and evaluating potential environmental liability and compliance concerns at commercial recycling facilities interested in supporting DOE's metals recycling program.

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Analysis of the Cost-Effectiveness of Hazardous Waste Technologies

DPRA has assessed the feasibility of a variety of hazardous waste treatment and disposal technologies for EPA's Office of Solid Waste. The purpose was to determine their viability as waste management alternatives in light of land disposal restrictions, hazardous waste listings, and recycling analyses conducted for the office.

For example, in support of EPA's Report to Congress, DPRA conducted an analysis of the capital and operating and maintenance costs, savings, and income associated with three cement kiln dust (CKD) recycling technologies.

Engineering analyses and cost estimates for a range of CKD generation rates, characteristics, and facility locations were developed for an alkali leaching process, a fluid-bed dust recovery system, and aflue gas recovery scrubber.

Cost equations were developed, reflecting the variability of CKD generation and facility size, to measure the effectiveness of each technology in removing waste constituents and reducing waste by-products.

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