Interim Status Permits

A TSDF may operate under an interim status permit. This temporary type of permit is issued to facilities that already existed when RCRA legislation came into effect. An interim status permit allows a facility to operate while the facility's permit applications are being reviewed. An interim status permit also allows a facility to operate while the facility implements upgrades to its physical plant, equipment, or procedures that are required for compliance with the RCRA regulations. For example, an interim status permit allows time for the owners and operators of an existing TSDF to train their employees about new operating procedures that must be adopted before a RCRA operating permit can be issued. Note that an interim status facility is not considered to be a permitted facility.

In a moment, we will examine the two-part RCRA permit application. Interim status is ended when the EPA makes a final decision on Part B of the application. When the RCRA regulations were first introduced, it was mandated that the rules for existing facilities and the rules for the yet-to-be-constructed new facilities should be as similar as possible. So, the regulations listed in 40 CFR 265 "Interim Status Standards" are a near match to those listed in Part 264.

To learn more about RCRA safety standards visit our RCRA Refresher Online Training web page.