Challenge: Renew, amend, and successfully facilitate an updated Resource Conservation and Recovery Act (RCRA) hazardous waste permit and compliance plan for a commercial hazardous waste storage, treatment, and disposal facility.

Solution: INTERA staff provided various services to support Veolia’s application renewal and amendment for their RCRA hazardous waste permit and compliance plan for their Port Arthur facility.  The Veolia Port Arthur facility is a commercial hazardous and industrial waste management facility situated on approximately 157 acres in Jefferson County, Texas.  The primary features of this existing facility include a commercial waste incinerator that accepts virtually all hazardous waste codes and associated storage containers, storage and treatment tanks, miscellaneous units, and other support equipment.  INTERA staff have been supporting the Veolia Port Arthur facility with RCRA permitting, corrective action, and other engineering and compliance related services since 1983. Preparation of the permit application renewal and amendment included the following tasks:

  • Completion of the applicable portions of the Part A and Part B application forms and attachments
  • Updates of facility management plans, including a personnel training plan, security plan, inspection plan and schedule, and contingency plan
  • Update of the waste analysis plan;
  • Updates to engineering reports, including a general engineering report, container storage units report, tank systems report, incinerator report, and miscellaneous units report;
  • Updates of closure and post-closure care plans and associated cost estimates
  • Updates of the compliance plan portion of the application, including preparation of a Response Action Plan (RAP) to address affected groundwater at the facility

Preparation of the application renewal and amendment involved in-depth engineering and regulatory analyses to support the permit changes requested by Veolia.  The changes included management of additional types of waste materials, such as listed dioxin/furan wastes; authorization of a new container storage and process support building; addition of six tank systems and the transload building; increases in permitted storage capacities of container storage areas; and revisions to the incinerator feed rate limits, operating parameters, and operating limits based on analysis of performance testing data.  Comprehensive updates to the closure cost estimates were also required.  In addition, changes to the existing corrective action program for historical releases associated with the former owner of the property were requested, including reduction of the semi-annual monitoring and reporting requirements to annual monitoring and reporting.  After submitting the application to the Texas Commission on Environmental Quality (TCEQ), INTERA staff provided application processing support to facilitate regulatory approval of the amendments and assisted with negotiating permit language. 

Results: The renewed and amended permit, including authorization to store and incinerate listed dioxin/furan wastes, was issued by TCEQ in May 2019.