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Special Forms of Permits for TSDFs

There are situations in which the standardized RCRA permit is not an option. Some examples of special forms of permits include:

Combustion permits - A combustion permit specifies the operating conditions at a facility where waste is burned (such as the unit temperature and the rate at which waste may be fed into the combustion device). Before a facility can apply for a combustion permit, the facility must first obtain an RCRA operating permit.

Emergency permit - The EPA may issue an emergency permit to a non-permitted TSDF in the event of an imminent and substantial endangerment to human health and the environment. The emergency permit is limited to 90 days.

Land treatment demonstration permits - A land treatment demonstration permit is available to owners and operators of a proposed land treatment facility. (Land treatment facilities use biodegradation to treat waste that is then placed on top of the soil or incorporated into the soil.) With this permit, the owners and operators may perform a treatment demonstration to verify that the waste will be completely degraded, transformed, or immobilized in the treatment zone.

Permits-by-Rule - Some facilities are subject to other federal regulations, such as the Clean Water Act. To avoid duplicate regulation, a non-RCRA permit may take the place of an RCRA permit, if the facility is in compliance with that permit and with basic RCRA administrative requirements.

Post-Closure Permit - A post-closure permit is required for facilities that close their operations while still holding an interim permit. The standards for permitted facilities include post-closure requirements. Interim facilities do not yet have the operating permit, which contains the regulatory guidelines for post-closure care. The post-closure permit fills this gap, and ensures that an interim status facility will meet the same standards for closure that a permitted facility must meet.

Remedial Action Plans (RAPs) - A remedial action plan is a special type of RCRA permit that authorizes the permit holder to remediate wastes. (Remediation involves removing contamination from the surrounding environment.) This type of permit requires a separate application process.

Research, development, and demonstration (RD&D) permits - These permits are designed to encourage innovative research, development, and demonstration efforts by allowing the construction of TSDFs for this purpose. Facilities with RD&D permits may only receive wastes that pertain to the treatment technology under development.

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

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