Companies that want to actively treat, store (for more than 90 days) or dispose of hazardous waste in Missouri are required to get a hazardous waste permit. Certain “inactive” hazardous waste treatment, storage or disposal facilities may also be required to get a hazardous waste permit in order to investigate, monitor and clean up hazardous waste releases to the environment at their facility.

In Missouri, a hazardous waste permit may actually include two separate permits, depending on the facility activities. EPA has the authority to authorize the states to administer all or part of the federal hazardous waste management law, known as the Resource Conservation and Recovery Act (RCRA), through a state “RCRA-equivalent” hazardous waste program. The federal regulations Missouri adopted and EPA authorized Missouri to administer are contained in a Missouri Hazardous Waste Management Facility Part I Permit, which is issued by the Missouri Department of Natural Resources. 

In some instances, EPA will issue a Hazardous and Solid Waste Amendments Part II Permit, which contains the federal RCRA requirements administered by EPA that Missouri has either not adopted or has adopted but EPA has not yet given Missouri temporary or final authorization to administer. EPA does not issue a Part II Permit if EPA has no site-specific conditions for that particular facility, beyond those contained in the Part I Permit. If both a Part I and Part II Permit are required, they are usually issued together.

A typical permit outlines the facility design and operation, safety standards and what monitoring and reporting activities the company must perform. It also includes detailed plans outlining how the company will remove and clean their equipment, structures and soil when they are no longer managing hazardous waste. The permit may contain facility-specific requirements such as long-term monitoring and maintenance plans for areas of the property where hazardous waste will remain in place after closure is finished, such as hazardous waste landfills or surface impoundments. The permit also contain conditions requiring the company to investigate and clean up releases of hazardous waste from their facility and provide financial assurance to ensure they have enough funds set aside to close their facility and cleanup any hazardous waste releases, even if the facility declares bankruptcy. 

Permit Length

Normally 10 years (maximum period currently allowed by state and federal laws and regulations)

Laws, Rules and Regulations

How to Apply

Before submitting a permit application to build, substantially alter or operate a hazardous waste land disposal facility (e.g., a landfill), state hazardous waste regulations require the company to submit a letter of intent to the department. Before submitting a permit application for a new hazardous waste treatment, storage or disposal facility, or for an existing facility where the permit is being renewed and the company is suggesting a major change to the facility’s operation, state hazardous waste regulations require the company to hold an informal public meeting. Additional details regarding the pre-application and application process are included in the fact sheet below.

Applications

  • Resource Conservation and Recovery Act Hazardous Waste Part A Permit Application (Form 8700-23) - U.S. EPA
  • Part B is submitted in narrative form, often a very detailed, highly technical document consisting of hundreds or thousands of pages of facility-specific information. In summary, the permit application must include a description of the facility and address the following:
    • How the facility will be designed, constructed, maintained and operated to be protective of public health and the environment.
    • How potential emergencies and spills will be handled.
    • How the facility will clean up and finance any potential environmental contamination.
    • How the facility will close and clean up once it is no longer operating.

Fact Sheets

Fees

Non-refundable, $1,000 application fee. This fee is applied towards the permit fees for the first year of the new permit. The applicant must pay $1,000 per year the permit is active.

The applicant must also reimburse the department for all reasonable costs incurred by the department during certification application review including: Engineering and Geological Review Costs; Corrective Action Oversight Costs. The applicant shall also pay the Commercial Facility inspection Fee - Based on volume of hazardous waste (metric ton) received from off-site. 

Timeline/ Process

There are six steps in the permitting process before a facility may receive a hazardous waste permit. The process is lengthy and can expect to take a minimum of 495 days (timeframe varies depending on the complexity of the facility). 

Step 1: Business holds a pre-application meeting with the public to announce proposed facility; plans for the operation and proposed processes used and wastes handled. 

Step 2: Business applies for a hazardous waste permit. The permit application is divided into two parts - Part A and Part B. 

Step 3: Permitting agency receives, reviews and potential revises the permit application

Step 4: Permitting agency requests additional information if the application is not complete, which will delay the review process. The permitting agency may revise the permit application as necessary.

Step 5: Permitting agency drafts the permit for public review. 

Step 6: Permitting agency makes final decision to grant or deny the permit.

Additional details involving the timeline and process for reviewing a permit are included in the Getting Involved in the Hazardous Waste Permitting Process - PUB0916 fact sheet. EPA also has additional details about How to Obtain a Hazardous Waste Permit on their website.

Public Participation

The hazardous waste permitting process provides several opportunities for the public to express ideas and concerns and provide input, such as the pre-application meeting, public comment period and public meeting or hearing, where the public can speak with the company, the department and EPA. The complete application is made available for public review. The draft permit is made available for public review and 45-day public comment period. The department will hold a public meeting or hearing upon request. The department will issue a news releases for the draft and final permits that contain active land disposal of hazardous waste.

Additional details involving public participation process are included in the Getting Involved in the Hazardous Waste Permitting Process - PUB0916 fact sheet.

Administrative Hearing Commission

Anyone who is adversely affected by the director's decision to issue, deny, suspend or revoke a permit must appeal within 30 days of the decision to the Administrative Hearing Commission as provided by 621.250.3 RSMo. All appeals must be filed by petition and send to:

Administrative Hearing Commission
PO Box 1557
Jefferson City, MO 65102
Phone: 573-751-2422
Fax: 573-751-5018
Website: Administrative Hearing Commission

Requirements

Reporting

All generators shall complete the following forms.

Renewal

Part I and Part II permits are issued for a 10-year period, the maximum period currently allowed by state and federal laws and regulations. By limiting the length of the permit, the department can make sure it regularly reviews the company’s hazardous waste management activities. 

At least six months before their current permit expires, companies wanting to continue their active permitted hazardous waste operations, or that are required to have their permit reissued to complete post-closure care or corrective action, must send the department and EPA a new permit application. 

According to 40 C.F.R. § 270.51, which is incorporated by reference in the state hazardous waste regulations, if the company submits a timely and complete application for a new hazardous waste permit and, through no fault of the company, the department and EPA are unable to issue the new permit before the currently effective permit expires, that permit is “continued” in effect until the department and EPA issue or deny a new permit. This allows the company to continue operating under the requirements of the existing “continued” Part I and Part II permits.

Modifications

During the company's permitted term, their permits may become outdated due to changing facility conditions, scientific improvements or new laws and regulations. To address this, either the company, department or EPA can propose changes to the permit. A permit modification can vary from minor adjustments to a complete overhaul of the permit.

Additional information regarding renewal, modifications or revocation can be found in the Getting Involved in the Hazardous Waste Permitting Process - PUB0916 fact sheet.

Resources

EPA Identification Number

Federal regulations require large and small quantity generators of hazardous waste to obtain an EPA Identification (EPA ID) number using EPA Form 8700-12 and to submit the completed form to the authorized state agency or EPA regional office if the state is not authorized to implement the Resource Conservation and Recovery Act Subtitle C program. The Site Identification Form (EPA Form 8700-12) includes information such as:

  • Facility’s name and address
  • Contact information
  • A description of hazardous waste activities conducted at the site

Applicants may find additional information on How Hazardous Waste Generators, Transporters and Treatment, Storage and Disposal Facilities Can Obtain EPA Identification Numbers by visiting EPA’s website.

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