INTERA

Environmental and Water Resource Consulting Firm

Environmental

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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.

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Challenge: To renew and amend a Resource Conservation and Recovery Act (RCRA) hazardous waste permit and compliance plan for a 23-acre closed hazardous waste land disposal facility.

Solution: INTERA prepared an application for renewal and major amendment of the facility’s hazardous waste permit and compliance plan. The facility is comprised of four closed hazardous waste land disposal units.  INTERA staff have been assisting with RCRA permitting, groundwater detection monitoring, groundwater compliance monitoring, site remediation and groundwater corrective actions, and other engineering and compliance related services since the 1980s.  The application preparation activities included:

  • Completion of the applicable portions of the Part A and Part B application forms and attachments 
  • Update and/or revision of the facility management plans, including personnel training plan, security plan, and inspection plan and schedule 
  • Update and/or revision of the engineering reports, including general engineering report and landfill report 
  • Update and/or revision of the post closure care plan and associated cost estimate 
  • Development of a preliminary review to address releases from solid waste management units 
  • Update and/or revision of the compliance plan portion of the application, including preparation of a Response Action Plan (RAP) to address affected groundwater at the facility

The application preparation activities included an in-depth review and incorporation of historical design and construction information, operational information, closure activities, and regulatory status for the closed land disposal units. In addition, a permitted unit was removed from the groundwater detection monitoring program, a site-specific background value was established for arsenic, concentration limits were updated for the organic monitoring parameters, and various changes were made to data evaluation procedures. Also, a compliance monitoring program was proposed for a newly confirmed release to groundwater. Additionally, the existing corrective action program was revised to establish a plume management zone, change certain alternate concentration limits, develop attenuation action levels; incorporate in-situ anaerobic bioremediation as a supplemental corrective action to enhance natural attenuation, and replace the active groundwater contaminant recovery program with a contingent program.  After submitting the application to the Texas Commission on Environmental Quality (TCEQ), INTERA facilitated TCEQ approval and assisted with negotiating permit language.  

Results: The facility’s new hazardous waste permit was successfully negotiated and issued by TCEQ.  

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· (Updated: May 2, 2023)

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Challenge: To ensure compliance with Texas Commission on Environmental Quality (TCEQ) permit requirements for industrial stormwater discharges.

Solution: For over 20 years, INTERA has played a key role in helping SACHEM comply with the requirements of TCEQ’s Stormwater Multi-Sector General Permit for Industrial Facilities (MSGP). Our initial efforts included preparing Stormwater Pollution Prevention Plans (SWPPPs) for SACHEM’s facilities in Austin and Cleburne, TX. This involved completing the following tasks at each facility:

  • Inspecting the facility to identify all chemical storage, handling, and transfer areas that may be exposed to stormwater 
  • Evaluating existing stormwater structural controls including containment and diversion structures and conveyance systems
  • Evaluating existing operating, maintenance, inspection, and training procedures
  • Identifying potential non stormwater discharges 
  • Documenting these tasks in a SWPPP compliant with the TPDES MSGP and the industry-specific requirements applicable to the facilities 

Each SWPPP includes exposed material inventories, site maps, best management practices for chemical and stormwater management, visual and analytical monitoring requirements, training and inspection requirements, and recordkeeping requirements.

INTERA conducts annual site compliance evaluations at each facility and prepares the reports and plan revisions required by the MSGP. INTERA updates the SWPPPs at least every five years when the MSGP is renewed.

Results: Both SACHEM facilities have remained in compliance with the MSGP.

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· (Updated: September 20, 2022)

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Challenge: To obtain injection well permits needed to support facility operations.

Solution: INTERA staff led the production of technical reports on geology and reservoir mechanics in support of several Class I injection well permit applications for sites operated by various companies, including Environmental Processing Systems, Pergan Marshall, US Ecology Texas, Texas Molecular, Rio Grande Resources, and ASARCO. Our efforts included using literature sources, historic data on bottom-hole pressures and injection rates, geophysical logs and petrophysical data, and pressure-fall off test results to evaluate the geology of the injection and confining zones, assess potential impacts to any underground sources of drinking water, and model future pressure buildup and waste-front propagation in the injection zone. Our model results were used to evaluate the impacts to artificial penetrations within an area of review around the proposed boreholes. INTERA staff also directly interfaced with state regulatory staff to expedite the resolution of permit application issues.

Results: All permits successfully obtained to ensure compliance with applicable regulatory requirements.

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Challenge: To address potential offsite toxicological inhalation impacts from volatile aqueous substances in a densely populated urban area with complex atmospheric and terrain features. 

Solution: INTERA prepared evaporative emissions calculations for the subject substances at several locations at the subject site. These estimations were based on the storage volume of the containers and respective containment areas. Using these emissions estimates, refined air dispersion modeling was conducted to determine offsite impacts within the vicinity of the site, which was located in a highly developed and densely populated urban area. A contour graphic with an aerial overlay was developed to demonstrate the potential impacts relative to the release location. Due to the absence of inhalation toxicological data and peer reviewed studies, a toxicological bridging analysis was conducted to develop toxicity endpoints for the subject chemicals based on chemically similar substances where health effects standards and peer-reviewed data has been established. These toxicity endpoints were established to serve the same function as the No Observed Adverse Effect Level (NOAEL) exposure level. 

Results: INTERA’s analyses provided a better understanding of the potential offsite impacts of the client’s products on neighboring properties, allowing them to be better stewards of the surrounding environment.  

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· (Updated: August 29, 2022)

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Challenge: To amend and renew a New Source Review (NSR) air permit for a batch chemical manufacturing facility 

Solution: SACHEM’s batch chemical manufacturing facility is located in the Dallas-Fort Worth (DFW) ozone nonattainment area.  The facility manufactures hundreds of batch chemicals, and consists of process equipment that includes reactors, rotary vacuum dryers, electrochemical process cells, and other relevant specialty process units. The site handles a multitude of organic and inorganic chemicals as raw materials, finished products, and co-/by-products, which were required to be speciated and evaluated for health effects per Texas Commission on Environmental Quality (TCEQ) rules. Over 100 individual chemicals required calculation, evaluation, and modeling to demonstrate off-property impacts. To amend and renew the air permit, INTERA collected information through a facility visit that included staff interviews and via a desktop review of air permits and associated compliance documents. Emissions were calculated for each stationary source using methodologies prescribed by the TCEQ, site-specific engineering calculations incorporating several thermodynamic models, EPA’s AP-42, and other industry-accepted practices as applicable. Once the emissions were calculated, they were screened using TCEQ’s Modeling and Effects Review Applicability analysis to determine which chemicals screened out as de minimis emitters and which required further modeling. Emissions modeling was conducted using the Industrial Source Complex (ISC) model for each affected emission point at a rate of 1 lb/hr to generate a Unit Impact Multiplier (UIM). Each hourly emission rate was multiplied by the UIM to determine a maximum offsite impact, which was then compared to TCEQ’s Effect Screening Levels (ESLs) and the National Ambient Air Quality Standards (NAAQS) to determine the impacts to off-property human health and vegetation. Ultimately, the modeling demonstrated that all emissions were not harmful to offsite receptors and were acceptable to TCEQ’s Toxicology Division. INTERA interacted with the site staff and the TCEQ regularly as it pertained to the progress of the review of the application, including answering clarifying questions for the agency, refining calculations and estimations as appropriate in conjunction with the appropriate stakeholders, and in negotiations of final permit content and conditions. 

Results: INTERA’s work resulted in a successfully amended and renewed NSR permit. 

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INTERA, HQ
9600 Great Hills Trail
Suite 300W
Austin, TX 78759
+1 (512) 425-2000

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