Class II RCRA Permit Modification for Storage Unit


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 permit 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 resource available or the regulatory knowledge. One such project included Cox-Colvin assistance in completing a RCRA permit modification for a new storage area which transferred existing permit capacity and increased the facility overall storage capacity. The facility also desired to limit the change to a Class II modification which is less onerous and allows for quicker agency approval. Cox-Colvin utilized a phased approach with an initial technical review of the existing application and permit, and identification of the necessary Part B requirements related to this new storage area. Next, Cox-Colvin conducted a site visit to discuss the initial list of changes to the permit.


Working closely with the facility and maintaining routine contact with the regulatory agency, Cox-Colvin prepared the necessary information for the Class II modification on schedule. Cox-Colvin also provided technical and permit related support to the facility and its construction designer to ensure that the design was being completed consistent with the permit modification. To limit agency comments and assist facility personnel with their review, Cox-Colvin completed detailed checklists developed by the regulatory agency as a cross-reference of changes. Based on Cox-Colvin’s effort, the facility felt confident in completing the remaining portions of the administrative process.