Class III RCRA Permit Modification for Containment Building

Treatment, storage, and disposal facilities (TSDFs) are required to obtain a RCRA permit to ensure that operations conform to regulations and protect human health and the environment. The application, which forms the basis of the permit, is often lengthy and consists of numerous inter-related documents that describe how the facility is designed, constructed, maintained, and operated; how emergencies and spills are address; and how the facility will close once operations cease. If a permitted TSDF wants to change something related to their operations, a formal permit modification is required. Depending on the type of change, the modification can be simple and straight forward (i.e., Class I modification) or it can be complex and require a significant effort to complete (i.e., Class II and III modifications).

Many of Cox-Colvin’s clients are permitted TSDFs. As such, we have unique experience and regulatory understanding to assist with permit modifications when the facilities either do not have the time available or the technical knowledge. One such project included Cox-Colvin assistance in completing a Class III modification to reflect a new containment building that would increase facility storage capacity by greater than 25%. Given the complexity of the modification, Cox-Colvin developed a phased approach consisting of a technical review of the existing application and permit as well as the specific requirements related to a Class III modification for a containment building. Next, Cox-Colvin conducted a site visit and a series of conference calls with the facility to identify and discuss the specific information that needed to be prepared as well as the documents and sections within the application that required updating. Cox-Colvin also outlined the complex administrative process required to approve the modification so the facility would understand the timeline and could plan accordingly.

By working closely with the facility and maintaining routine contact with the regulatory agency, Cox-Colvin prepared the necessary information for the Class III modification ahead of schedule. The permit application documents with the most significant changes included the siting criteria document, closure plan, inspection program, training program, and design document. Cox-Colvin completed detailed checklists developed by the regulatory agency as a cross-reference of changes. At the request of the facility, Cox-Colvin also revised other language throughout the permit application that was un-related to the modification for the purpose of creating a more succinct and user-friendly documents. Based on Cox-Colvin’s effort, the facility felt confident to complete the remaining portions of the administrative process.


Outcome and Benefits

  • Assisted the facility in completing a complex Class III modification that affected nearly all parts of the permit application.
  • Saved the facility from having to redirect significant responsibilities of their personnel.