PPC: 9523.1994(01)
EPA: 530-R-94-005i
NTIS: PB94-922 409

Permit Application and Renewal

In order to treat, store, or dispose of hazardous waste, a facility owner or
operator must apply for and receive a RCRA permit. Once a RCRA permit has
been approved, it is valid for a period of up to ten years (40 CFR 270.50). If an
owner/operator wishes to continue an activity regulated by the permit after its
expiration date, the owner/operator must apply for and obtain a new permit
(270.30(b)). What are the application requirements for obtaining or renewing a
hazardous waste permit?

To obtain the original hazardous waste permit, the owner/operator must submit
a two part application, consisting of part A and part B. The part A (form 8700-23)
requires owners/operators to supply basic information such as facility name and
address, description of hazardous waste processes, and topographical maps. For
the part B, owners/operators must fulfill the information requirements of 270.14-
29. These sections require an owner/operator to detail, in a narrative format,
how they will demonstrate compliance with the general TSDF standards, as well
as the unit-specific requirements (270.1(b)).

When an owner/operator reapplies for a hazardous waste permit, the
owner/operator must submit an permit application, including parts A and B,
revised as necessary to reflect changed conditions since the previous application.
The revised part B should: fulfill all the requirements of a new permit
application; incorporate any new regulations that were promulgated or came
into effect since the issuance of the permit; and include any approved permit
modifications.

The owner/operator may continue operation under the existing permit beyond
the permit's expiration date while the renewal application is being considered if
the owner/operator submits the revised part B at least 180 days before the
expiration date of the existing permit (270.10(h)) and the Regional Administrator,
through no fault of the permittee, does not issue a permit with an effective date
on or before the expiration date of the existing permit (270.51(a)). Failure to file a
timely application would require the owner/operator to cease operations under
the expired permit and apply, as a new applicant, for a new hazardous waste
permit. (September 1994 Monthly Hotline Report)

RO 13695

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