PERMIT EXEMPTION STRATEGIES FOR ONSITE WASTE PROCESSING FACILITIES

摘要

Onsite hazardous waste processors often findobtaining a Treatment Storage and Disposal (TSD) permit oneof their first major challenges. Some processors may spend thetime and money required by the permitting process, only to findout later that a permit was not necessary.This paper will present and analyze four strategies thatprocessors may use to avoid obtaining a TSD permit. Somefacilities will be able to remove their waste streams fromRcRA's oversight by ensuring the material is not "hazardous"waste. Parties that treat waste while it is in process may beable to avoid generating "waste" altogether. certain treatmentfacilities have been specifically exempted by EPA. Finally,treatment of waste while it is in generator storage tanks may beallowed without a RCRA TSD permit.Hazardous waste point of generation, an importantdetermination relating to these strategies, will also be discussed.Generators and processors will find this paper useful whenevaluating their permit exemption potential.