Strategies for Preparing and Submitting A Part B Application for a DoD Facility,
HART (FRED C) ASSOCIATES INC NEW YORK
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The United States Environmental Protection Agency EPA has issued regulations to ensure the protection of human health and the environment through the appropriate management of hazardous wastes under Subtitle C of the Resource Conservation and Recovery Act of 1976 RCRA. Those regulations require most facilities that treat, store or dispose of hazardous waste to obtain a RCRA permit. The application for this permit consists of two parts, Part A and Part B. Facilities in existence before November 1980 were required to submit the Part A application by November 19, 1980. These facilities were granted interim status under the regulations, which permits them to continue operations until final administrative action is taken on their permit. This requires the submittal of a detailed Part B permit application. The permit application must contain sufficient information to assure EPA that the facility design, operation and proposed closure and post-closure plans will satisfy the applicable permitting standards. The Part B process is complex, uncertain and inherently subjective. While the level of uncertainties is decreasing, the applicant can minimize the uncertainties by aggressively managing the process. The applicant must plan his strategy, pay particular attention to details and follow through daily if necessary. The long-term cost savings alone should justify the increased attention given to management of the Part B application process.