Aerospace Client Permitting & RCRA Compliance

Cameron-Cole conducted a multimedia (RCRA/Air/Stormwater/SPCC/Storage Tanks) compliance evaluation for a newly constructed aircraft maintenance, repair, and overhaul facility at a regional airport in North Florida. Cameron-Cole completed a comprehensive inventory of all waste streams including oil products, paints, solvents, and other waste materials generated by the company's previously established operations in other states. This information was used in conjunction with management estimates of throughput for the new facility to conduct a Hazardous Waste Determination and determine generator status. Cameron-Cole coordinated with management and the facility’s selected waste transporter to identify appropriate waste codes for the hazardous wastes generated and completed a Form 8700 to obtain an EPA ID number for the new facility. Working with facility personnel, Cameron-Cole helped identify opportunities for waste minimization as well as segregation of non-hazardous waste streams (oily rags versus solvent rags). This included an evaluation of paint spraying and spray gun cleaning operations as well as management of overspray when painting was required outside the paint spray booths (aircraft fuselage). With input from facility operation, Cameron-Cole recommended appropriate locations and access controls for waste storage areas including 8 satellite accumulation areas and spill response kits. Cameron-Cole assisted management in identifying appropriate hazardous waste container labeling, accumulation, and recordkeeping requirements based on the established generator status. Cameron-Cole then coordinated and attended a courtesy facility compliance audit with representatives of FDEP's Hazardous Waste and Air Permitting sections to evaluate the facility compliance with regard to RCRA and applicable air permitting requirements. The facility was determined to be in compliance at the time of the inspection. Through the use of a rigorous and proactive multimedia compliance auditing program, the client facilitated the responsible development of previously unused airport property and retained a long-term tenant with global reach that currently employs more than 300 full-time personnel at the airport.