Información Legal y Cumplimiento - RCA Engineering

Our approach

Start at the gate, not at the reactor

Most composite recovery projects are built backwards: a technology is selected, then a stream is found to justify it, then the numbers are fitted around both. RCA Engineering works in the opposite order — and that order is the method.

 

The sequence

Seven questions, asked in this order

The order matters more than any single answer. A step taken out of sequence carries an assumption forward that nobody revisits, and it usually surfaces during commissioning — when it is expensive.

01

Define the stream

What actually arrives at the gate: tonnage per year over the asset life, material composition, contamination, moisture, bulk density and the variability around each. Until the feedstock envelope is written down, every downstream number is a placeholder.

02

Establish the boundary

Which obligations are binding law, which are voluntary industry commitments, and which apply in the specific jurisdiction. Whether the intended operation is classified as recovery or disposal — because that determines permit, reporting and whether the client can claim compliance at all.

03

Compare the routes

Mechanical, pyrolysis, solvolysis, gasification and hybrid, evaluated against the same criteria for this stream. No route is excluded on principle and none is preferred in advance; the answer is a function of the feedstock, not of what RCA is comfortable engineering.

04

Close the physical balance

Mass and energy balance for the selected route, including every secondary stream: char, ash, effluent, off-gas, reject fraction and non-composite arisings. A balance that does not close is a case that will not survive due diligence.

05

Model the money

CAPEX and OPEX built from quotes rather than vendor optimism, revenue split between gate fee and recovered-product offtake, then NPV, IRR and DSCR with sensitivities on gate fee, CAPEX overrun, ramp-up delay and output price. If it only works in the base case, it does not work.

06

Structure the contract

Scope, interfaces and responsibilities defined before mobilisation. Feedstock specification and acceptance criteria, performance guarantees tied to the feed the plant will actually receive, liquidated damages, retention and the change mechanism both parties will use when reality diverges from the plan.

07

Verify against reality

Performance testing against the guarantee, on real feed rather than a prepared sample. Punch list, taking-over certificates, defect-notification management, and KPI tracking through ramp-up until the plant delivers what the model assumed.

 

Evidence standard

What counts as evidence, and what does not

Every project arrives with a folder of material presented as proof. Most of it is not. This is the substitution RCA Engineering applies, and it is the single largest source of difference between an optimistic case and a bankable one.

Not evidenceA vendor datasheet throughput figure

What we ask forMeasured availability and throughput from a reference plant running comparable feed, with the downtime included

Not evidenceA recovery rate demonstrated on clean manufacturing offcut

What we ask forThe same rate on post-consumer material at the contamination and moisture level the plant will actually receive

Not evidenceAn offtake price in a spreadsheet

What we ask forA term sheet, an indexation mechanism and a named counterparty — or the price modelled as a merchant risk

Not evidenceA letter of intent for feedstock supply

What we ask forCommitted volume, duration, delivered specification and the consequence if it is not met

Not evidenceAn LCA showing a favourable result

What we ask forThe end-of-life scenario selected, the allocation method used and the recovery rate assumed — because that is where the result was decided

Not evidence“Several member states have banned it”

What we ask forThe instrument, the jurisdiction and the date it becomes binding on this project

 

 

Deliverables

What the client receives

Documents that can be handed to a lender, a technical committee or a counterparty without translation, and defended line by line.

Feedstock specificationComposition, contamination limits, acceptance criteria and rejection basis, written as a contractual annex rather than a description.

Route comparisonThe five routes assessed against the same criteria for this stream, with the reasoning and the data behind each conclusion.

Mass and energy balanceClosed, with every secondary stream identified, quantified and routed to a destination that has a cost attached.

Financial modelAuditable, with assumptions visible and separated from calculations, and sensitivities the reader can rerun.

Risk registerRanked by effect on the case, not by ease of description, with owner and mitigation for each item.

Contract review memorandumClause-level, with the commercial consequence of each position and a fallback where one is available.

 

Confidential by default. NDA on request before any material is exchanged, and any conflict with a prior mandate declared before engagement rather than disclosed afterwards.

 

Working principle

Clarity is not the enemy of a good client relationship

Ambiguity always gets priced against someone later. Scope, interfaces and responsibilities are defined in writing before work starts; decisions and concessions are recorded as they are made; and variations run through the mechanism both parties already agreed, not through goodwill nobody can evidence.

That discipline is not adversarial. It is what allows a project to be governed by what was agreed rather than by whoever is most reluctant to raise the issue.

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