Tora assisted client with response to Agency NOV issued subsequent to an unscheduled RCRA inspection. Tora performed regulatory analysis, drafted response to agency and obtained extension due to holidays. Tora also partnered with internal and external legal counsel and onsite operational personnel to develop comprehensive response to all Agency concerns. Compiled tracking list for all needed improvements. Tora conducted RCRAInfo manifest review, vendor and facility interviews, and improvements to labeling, storage, waste determinations, and work practices. Followed up facility visit to ensure all corrective actions were implemented and made suggestions for long-term management.
Working closely with internal and external legal counsel, as well as onsite operational staff, Tora developed a comprehensive response plan that addressed all agency concerns. This included compiling a tracking list of required corrective actions and coordinating with facility staff to implement improvements.
Tora’s work also involved:
- RCRAInfo manifest reviews
- Vendor and facility interviews
- Onsite enhancements to labeling, storage, waste determinations, and work practices
Following the initial response, Tora conducted a follow-up site visit to confirm that all corrective actions were completed and provided additional recommendations for long-term compliance management.