Hazardous and Dangerous Waste Permitting

The tendency of some environmental consultants is to write these Plans to appease the agency reviewer…

Permitting for RCRA Subtitle C Treatment, Storage or Disposal Facilities (“TSDFs”) is a long and sometimes convoluted process.  Plans for all aspects of facility operation need to be developed by the permit applicant and approved by the reviewing agency.  The tendency of some environmental consultants is to write these Plans to appease the agency reviewer rather than strictly adhering to relevant standards and procedures as promulgated in the administrative rules or as established in applicable agency policy.  This can lead to unnecessary constraints on facility operation and, inevitably, to penalty assessments for violation of the final permit (of which the Plans are an enforceable part.)  Thomas Benke, Environmental Compliance’s Managing Member, began his career as a hazardous waste permitting engineer for the State of Texas, drafting and enforcing permits for some of the country’s largest hazardous waste disposal facilities.  With degrees in Chemical Engineering and Law, he has the training and experience to represent any TSDF with respect to its permitting issues.