Eight Ways to Treat Hazardous Waste Without a Permit

Because many hazardous wastes are quite dangerous (e.g., they are toxic, flammable, carcinogenic, etc.), treatment of such materials can present serious risks to human health and the environment. To help ensure that hazardous wastes are treated safely and responsibly, EPA generally requires that facilities conducting such activities obtain a RCRA permit. However, many facility owners/operators are reluctant to expose themselves to the process of obtaining and maintaining a RCRA permit. Getting a RCRA permit 1) is difficult and requires considerable resources, and 2) exposes the facility to the RCRA corrective action program that requires owners/operators to investigate their entire site and implement extensive cleanup measures if contamination is found. Thus, facility owners/operators frequently ask whether their handling of certain types of hazardous waste comprises “treatment” and, if so, whether such treatment requires a RCRA permit. In this paper, we begin by examining EPA’s definition of hazardous waste “treatment.” Then we identify eight ways to treat hazardous waste that do not require a RCRA permit. That is, a hazardous waste generator could engage in one of these eight activities and remain just a generator. The eight ways to treat hazardous waste without a RCRA permit are listed below.

1. Elementary neutralization units,

2. Totally enclosed treatment facilities,

3. Adding absorbents to wastes,

4. Immediate responses,

5. Wastewater treatment units,

6. Treatment in 90/180-day accumulation units,

7. Recycling processes, and

8. Burning small quantities of hazardous waste in onsite BIFs