McMorsel: California tiered
permitting has many layers

California’s layer cake of permits

California’s five-tier permitting program for treating waste matches the cost and regulatory burden of a facility with the level of risk posed by a treatment activity. Where do you fall?

Full permit—Incineration and land disposal. Equivalent to a federal part B RCRA permit.

Standardized permit—Treatment and storage of non-RCRA hazardous waste received from offsite.

Permit by rule—You’re looking at one of these when treating certain aqueous wastes, hazardous soils, or inorganic acids and bases.

Conditional authorization—Useful for limited treatment operations, such as filtering, rinsing containers, drying wastes via filterpress, and separating used oil from water.

Conditional exemption—Very limited in scope, covering some used oil treatment operations and totally enclosed treatment facilities.

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McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided above. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance above is general in nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.