A recent article posted by the Environmental Resource Center raised an interesting question; can you treat waste without a permit? Surprisingly enough, in some cases, you can. 40 CFR 270.1(c) states that hazardous wastes listed in 40 CFR 261 require a permit for treatment, storage, and disposal. In 40 CFR 270.1(c)(2), however, you can find a list of exclusions from the requirement to have a RCRA permit. These exclusions include the following generator types and instances:
According to the ERC, “40 CFR 262.34 requirements include the 90-day and 180-day accumulation regulations for large quantity generators (LQGs) and small quantity generators (SQGs), meaning that as long as a generator complies with the requirements of 40 CFR 262.34, they do not need a RCRA permit.”
The Environmental Resource Center also points out that, “most of the treatment technologies identified at 40 CFR 268.42 do not require a permit—with the technologies that do require a RCRA permit usually involving combustion.” Additionally, they provide a list of some of the treatment types that generators in compliance with 40 CFR 262.34 are able to perform without a permit. These include, among others, the following:
It is important to note that the exemptions listed apply only in states that allow for them. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.
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