Situations That Require RCRA Permits for TSDFs

The situations for hazardous waste facilities differ widely. For example, some facilities have been in operation for decades while others are brand new. Some facilities treat hazardous waste using combustion and other facilities are limited to research and development. Different factors such as these determine the type of permit that a TSDF must have. The different types of permits can be summarized as explained here.

RCRA Operating Permit - This is an EPA-issued permit that a company must apply for and obtain before it can begin the construction of a new hazardous waste management facility. The RCRA operating permit is maintained across the active life of the facility and during closure activities. Some facilities may be required to obtain a special form of permit instead of, or in addition to, an operating permit.

Interim Status Permits - An interim status permit is a temporary permit issued to a facility that is already in operation at the time a regulation becomes effective. This type of permit allows the facility to continue to operate while the facility is being brought up to a condition where it can meet the requirements of the effective regulation. An interim status permit can also be issued during the period when a facility's RCRA permit is being processed. Note, however, that an interim status facility is not considered to be a permitted facility.

Special Forms of Permits - If a facility does not meet the criteria for a standard operating permit, then the situation is likely to require the use of a special type of permit. In some cases, facilities must obtain an operating permit in addition to a special form of permit (for example, a facility may also need to apply for a combustion permit).

Standardized Permit - This is a special type of permit available to owners and operators of facilities that generate hazardous waste that is stored or non-thermally treated (that is, not treated by combustion) in containers, tanks, or containment buildings on sites that they own. The EPA developed the standardized permit to streamline the permitting process for these generators.

The typical RCRA permit is effective for a period of up to ten years.

To learn more about RCRA visit our RCRA Hazardous Waste Safety Online Training web page.