Other Permits Section Activities

MoDNR Topics

Other Permits Section Activities

Permit Modifications
Interim Status Reviews
Closure Plan Reviews
Corrective Action Oversight
Financial Assurance Reviews
Public Participation Activities

Permit Modifications
Our Section or the facility can make changes to the hazardous waste permit throughout its life. Usually the facility owner or operator asks for the permit modification. Permit modifications are labeled as Class 1, 2 or 3, depending on how much they change the original permit.

Class 1 modifications include small changes that keep the permit current with routine changes to the facility or its operation, such as renaming a building.
Class 2 modifications include necessary changes that allow the facility to respond to changes in the type or amount of wastes handled, scientific improvements and new laws.
Class 3 modifications include issues that largely change a facility or its operations. For example, a request to handle new wastes that require different management practices.

Interim Status Reviews
When Congress passed the Hazardous and Solid Waste Amendment to the Resource Conservation and Recovery Act (RCRA) in 1980, the U.S. Environmental Protection Agency (EPA) required all facilities that treated, stored or disposed of hazardous waste to either get a hazardous waste permit or stop these activities. Because of the large number of facilities that were required to get a hazardous waste permit, EPA also set up requirements which allowed facilities to operate temporarily until they received their permit.

During this "interim status" period, the facility had to file a hazardous waste permit application within a specific timeframe and meet certain operational standards. Facilities that chose not to file for a permit were required to start closure procedures. A facility is released from interim status when our Section issues them a hazardous waste permit or verifies that the facility has removed and cleaned their equipment, structures and soil. As of January 2008, there are 49 interim status facilities in Missouri.

Closure Plan Reviews
A closure plan is a detailed plan outlining how a facility will remove and clean their equipment, structures and soil when they are no longer in business. The facility must include a closure plan with their hazardous waste permit application. Our Section reviews the plan to make sure it follows state and federal laws. We approve the plan during the hazardous waste permitting process.

Interim status facilities that are not filing for a hazardous waste permit are still required to submit a closure plan to us. We must approve the plan before any cleanup activities begin.

Corrective Action Oversight
All facilities issued a hazardous waste permit are required to investigate and clean up hazardous waste pollution resulting from present and past practices. This includes releases of hazardous waste by previous owners of the facility. These cleanup activities, known as corrective action, reduce risks to human health and the environment.

Our Section and the program's Compliance and Enforcement Section are involved in overseeing the corrective action projects. We review the facilities investigation, monitoring and cleanup work plans and reports to make sure they follow the correct laws and standards.

Financial Assurance Reviews
Treatment, storage and disposal (TSD), Resource Recovery, PCB (Polychlorinated Biphenyl) and interim status facilities must show that they have resources set aside to pay for closure, post-closure, liability and corrective action costs, depending on the type of facility. These resources must be available even if the facility declares bankruptcy.

Along with their hazardous waste permit application, the facility must give us closure and post-closure cost estimates. They must also submit financial assurance instrument documents describing where and how money will be available when needed for their specific activities. Our Section reviews each Missouri facility yearly to make sure that they have enough financial assurance to cover the cost estimates for their activities.

Public Participation Activities
Public participation plays an important part in the hazardous waste permitting and corrective action processes. Not only does public input help our Section reach better technical solutions, but it can also help the facilities make better business and technical decisions. It allows members of the community to stay informed and have an active role in the decision-making process.

Each step in the hazardous waste permitting and corrective action process includes specific requirements for public participation. These requirements are outlined in the state and federal laws. Our Section notifies the public of permitting activities through newspaper legal notices, radio announcements and news releases. Everyone listed on a specific facility's mailing list receives written notice on any major activities for that facility. The public is invited to review and send written comments on permit applications and draft permits. There are many opportunities for public participation that the facility and our Section organize as the occasions arise.

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