Annex B

Task 7 - Prepare Hazardous Waste Permit Application 

Prepare all permit applications required by national and local authorities for HWMFs. The US HWMF regulations require a very comprehensive permit application and permitting process, which has become a model for other countries. The application preparation process should include the following steps: 

Step 7.1 Prepare Listing of All HWMF Facility Units.  List HWMF types, design capacities, and annual throughputs.

Step 7.2  Prepare Listing of All Hazardous Wastes.  List hazardous waste sources, types, and amounts. and concentrations to be accepted.

Step 7.3  Prepare a Waste Analysis Plan.  Describe in detail how wastes, their hazard characteristics, and handling requirements will be identified before and after arrival at the facility gate, including detailed sampling and analytical methods, record-keeping, and reporting.

Step 7.4 Prepare Inspection Plan.   Describe the plan for conducting regular self-inspections of the facility, including who will inspect, what will be inspected, the inspection schedule, and procedures for reporting inspection results.

Step 7.5 Prepare Contingency Plan.   Address how to identify and respond to emergencies due to spills, leaks, fires, and explosions, including notification of local authorities, evacuation signals and routes, control and cleanup methods, and reporting procedures.

Step 7.6 Prepare Personnel Training Plan. Provide for all job positions, their job description, education, experience, and certification requirements; training curricula, trainer credentials, and training schedules.

Step 7.7  Prepare Plan for Environmental Monitoring.  Depending on the specific type of thermal treatment employed at the facility, include monitoring parameters, sampling and analysis techniques, monitoring staff, monitoring schedules, and procedures for reporting.

Step 7.8  Prepare Closure Plan.  Include dismantling and decontamination of equipment and buildings; treatment or disposal of residual contamination; and permanent covering, contouring, and re-vegetation of waste disposal and other site areas.

Step 7.9 Prepare Financial Assurance Plan.  Address lengths of operation and closure periods, cost estimates for closure, and sources and mechanisms for setting aside sufficient funds from the beginning to pay closure costs after the HWMF ceases to earn revenues.

Step 7.10 Follow the Permit Application Process.  The US permitting process calls for submitting a draft permit application to the regulatory authority and making the document available to the public for review and comment, holding a public hearing to present the project and respond to the public’s questions and comments, making revisions in the draft application in response to comments from the public and regulatory agencies, and the regulatory agency setting permit conditions, issuing a record of decision, and publishing the permit.  Most HWMF permitting processes also extend into the future after initial permit issuance, and include procedures for permit monitoring, inspection, and enforcement; and for renewal, revision, and termination.