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Frequent Questions about RCRA Standardized Permits
Additional Questions
Find answers to more permitting questions- Who is eligible for a RCRA standardized permit?
- How do I apply for a standardized permit?
- How long will it take to issue a standardized permit?
- Can a commercial treatment, storage, disposal facility (TSDF) manage hazardous wastes in tanks, containers or containment buildings under a standardized permit?
- How long is the term of my standardized permit?
- Does the standardized permit rule apply to large quantity generators storing hazardous waste in tanks?
- Does the standardized permit rule apply to storage of mixed (hazardous and radioactive) waste?
Who is eligible for a RCRA standardized permit?
You may be eligible for a standardized permit if:
- You generate hazardous waste and then store or non-thermally treat the hazardous waste on-site in containers, tanks, or containment buildings; or if
- You receive hazardous waste generated off-site by a generator under the same ownership as your facility, and then you store or non-thermally treat the hazardous waste in containers, tanks, or containment buildings.
How do I apply for a standardized permit?
An owner/operator applies for a standardized permit by submitting a Notice of Intent, with supporting documents, to the regulatory authority. The Notice of Intent is not an actual form, but a letter sent to the state informing the regulatory authority that the applicant is applying for a standardized permit. All the additional information mentioned at 40 CFR 270.275 would accompany the letter. The regulatory authority then reviews these submissions to determine whether the applicant is eligible for a standardized permit, and if so, issues a draft permit decision for public comment.
How long will it take to issue a standardized permit?
The time to issue a standardized permit may vary, but will be substantially less than the current permit process. The time from when an owner or operator first applies for a permit, to the issuance of a draft permit for public comment, may take as little as 120 days. After the comments on the draft permit have been addressed, a final permit can be issued. There is no set time-frame for the regulatory authority to address public comments and issue the final permit.
Can a commercial treatment, storage, disposal facility
(TSDF) manage hazardous wastes in tanks, containers or containment buildings
under a standardized permit?
Generally, commercial TSDFs may not manage waste under a standardized permit, because the wastes a commercial TSDF manages are usually generated off-site by many different generators. As described under "Who is eligible for a RCRA standardized permit?," you may be eligible for a standardized permit if:
- You generate hazardous waste and then store or non-thermally treat the hazardous waste on-site in containers, tanks, or containment buildings; or if
- You receive hazardous waste generated off-site by a generator under the same ownership as your facility, and then you store or non-thermally treat the hazardous waste in containers, tanks, or containment buildings.
How long is the term of my standardized permit?
The term of a standardized permit is the same as for individual RCRA permits. Generally, the term of a RCRA permit is ten years. However, because individual states may have different requirements, you need to contact your state environmental authority to get specific information.
Does the standardized permit rule apply to large quantity
generators storing hazardous waste in tanks?
No. The standardized permit rule applies only to those facilities already required to obtain a RCRA permit. Large quantity generators (LQGs) storing waste in tanks are exempt from the RCRA permitting requirements, as long as their waste is stored for less than the time limits established by 40 CFR 262.34. If LQGs store beyond the time limits of §262.34, then a permit must be obtained, and in that case, a standardized permit may be an option, if they meet the eligibility criteria.
Does the standardized permit rule apply to storage of
mixed (hazardous and radioactive) waste?
The standardized permit rule could, in fact, apply to the management of mixed waste, presuming eligibility criteria and other applicable regulatory conditions were met.
