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Braun Intertec Provides Class I Underground Injection Facility Permitting and Compliance

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Client Union Processing Systems, LLC
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Braun Intertec provided Union Processing Systems with permitting, compliance and safety consulting for a Class 1 Underground Injection Facility in Conroe, Texas. The facility is permitted to accept and treat up to 504,000 gallons of wastewater a day and has been working to obtain final authorization of the underground injection control (UIC) and surface nonhazardous waste permits since approximately 2011 in order to commence operation. We were retained in 2019 to assist with developing compliance programs and to complete the permitting process requiring the approval of the Texas Commission on Environmental Quality (TCEQ) Industrial & Hazardous Waste Permit Section.

On behalf of Union, we completed and submitted a Construction Certification Report demonstrating the facility was constructed in accordance with the original 2011 permit application and subsequent permit modifications. Upon receipt, TCEQ deemed the report complete and accurately reflective fulfilling the final permit requirement in order to commence operations. With agency concurrence that Union had met all permit requirements with regard to construction and operating systems in place for operation, Union is authorized to commercially receive industrial nonhazardous wastewater for treatment and subsequent disposal in the Class 1 UIC well.

In addition to the surface and UIC permits, Braun Intertec developed and implemented site, operational and permit specific safety and environmental compliance programs at Union, as well as provided Department of Transportation (DOT) Hazardous Materials Training. Due to operations being contingent on permit compliance, these programs are integral to operations. Additionally, we provided waste acceptance review, assisted in developing the waste acceptance protocols (WAP), developed the Spill Prevention, Control, and Countermeasure (SPCC) plan, and completed various permit modifications for minor changes. All efforts positioned Union to commence operation and accept waste under TCEQ authorization. Braun Intertec continues to work with Union as the business continues to grow and operate to confirm continued and operationally sustainable compliance.

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