Waste Management Permitting Technical Support

The U.S. Environmental Protection Agency Region 5’s Waste Management Permitting Section needed comprehensive technical and regulatory support to review complex Resource Conservation and Recovery Act (RCRA) Part B permit applications under the state’s authorized RCRA program. These permit reviews required detailed evaluations of treatment, storage, and disposal facility (TSDF) operations; waste analysis plans; applicability of 40 CFR 264/265 Subparts AA, BB, and CC for organic air emissions; land disposal restriction requirements; and human health risk assessments for hazardous waste combustion facilities. Region 5 needed clear, consistent documentation to identify permit deficiencies and ensure facilities met federal and state hazardous waste regulations.

ERG provided comprehensive technical, analytical, and regulatory support throughout the permit review process. Our team evaluated permit applications for TSDFs, including combustion and fuel-blending facilities, to confirm regulatory compliance and technical adequacy. This included reviewing elements ranging from waste characterization requirements to TSDF operating standards and air emission applicability. The ERG team produced clear, standardized deliverables for the reviews, including structured checklists, documented findings, and best practice recommendations. Together, these resources created a uniform framework for determining the adequacy of permit applications and identifying their shortcomings under all relevant RCRA requirements. ERG also developed concise summaries of the most frequently observed deficiencies, providing Region 5 with a clear view of common issues and opportunities for strengthening future submissions. By providing consistent, defensible evaluations, ERG strengthened Region 5’s ability to implement their waste permitting program and improve the overall quality and completeness of permit submissions.