Challenge: Renew and amend a Resource Conservation and Recovery Act (RCRA) hazardous waste permit for a commercial recycling facility.

Solution: INTERA staff prepared an application and provided processing support for the renewal and major amendment of an industrial facility’s hazardous waste permit.  The facility offers recycling services for businesses that generate metal-containing industrial solid wastes, and some of the wastes are classified as hazardous.  The metal waste, as well as purchased materials, are used as feedstock in various recycling processes to reclaim metal resources that can be re-purposed as usable products.  In addition to the recycling processes and operations, the principal features of the facility include two container storage units that are used for management of industrial and hazardous wastes prior to recycling and for storage of site-generated wastes.  These units are authorized by the Texas Commission on Environmental Quality (TCEQ) under Hazardous Waste Permit No. 50203.

INTERA performed an in-depth review of facility operations and prepared an application for renewal and major amendment of their hazardous waste permit.  Engineered design drawings and waste management plans were developed to expand the size and storage capacity of the two existing container storage units, and to request permit authorization for a new container storage unit.  Other activities completed by INTERA staff included: preparation of facility siting information; development of new security, inspection, contingency, and waste analysis plans; preparation of fault delineation information; development of new engineering reports; development of a new closure plan and associated closure cost estimates; preparation of the required financial assurance and financial disclosure information; and preparation of a preliminary review of releases from solid waste management units and/or areas of concern.  INTERA produced electronic and paper copies of the application documents for TCEQ submittal, and subsequently provided application processing support to facilitate TCEQ approval of the application. 

Results: The application was approved by the TCEQ and the hazardous waste permit was issued in December 2019.