Permitting: What to Consider When Identifying a Waste Disposal Vendor
Permits, in any sense, are a form of authorization and are crucial in any regulated space. Specifically in the waste industry, there are thousands of permits that qualify waste vendors to handle and treat waste, ensuring both safety and compliance. As a customer looking for the right waste disposal or recycling vendor, permits are critical to consider.
Obtaining Copies of Current Permits
The first step in any disposal vendor partnership, is obtaining copies of all required permits and ensuring they are current. Operational permits can include, but are not limited to, RCRA Part B permits, solid waste, air, discharge, stormwater, and wastewater permits. Aside from facility operating permits, ensure the disposal vendor has all permits necessary for service; this can include contractor and business licenses, or transporter permits.
Especially when obtaining larger permits, recognize that there may be delays in permit issuance or in the approval process. Transfer, Storage and Disposal Facilities (TSDFs) are generally required to have permit applications submitted 180 days prior to the expiration, however, the process can include a lot of back and forth. If the application doesn’t get approved prior to the expiration of the previous permit, states can administratively extend the permit. In some cases, this won’t be put in writing, and therefore it’s important to contact the permit writer to get direct confirmation of the extension.
Recognizing the Variance of Permits
Permits can vary state to state, county to county, and even township to township. It’s rare to find two permits at two different facilities that look the same.
In some states, due to different waste regulations, permits can be comingled. For instance, the state of Pennsylvania regulates both hazardous and residual waste and therefore may issue a comingled permit including both types of waste, instead of requiring separate individual permits.
Depending on the county or municipality, permits for varying activities may be required. This can depend on the type of activity and the amount of waste being handled. For example, a permit may be necessary when importing a certain volume of wastewater to a treatment plant.
Understanding Permits and Ensuring Proper Certification
After obtaining the permits and understanding how they can vary, it’s key to identify the types of wastes the disposal vendor outlet can accept and process. When characterizing waste, ensure all the waste codes and descriptions are applicable in the permit, for the location.
Once you identify a disposal vendor that fits your waste needs, ensure that they issue you a certification stating their authorization, along with the permits required to accept your waste, as stated in the federal law, 40 CFR Part 264, Section 12, Paragraph (b). Keep in mind that some states may require specific language in this certification.
When in doubt, set up a call with a permit inspector or writer for confirmation. Clean Earth Approvals managers help customers match the waste stream to the appropriate treatment facility based on the material type and contaminants. Learn more about our professional services here.
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