How to Fill Out the RCRA Hazardous Waste Part A Permit (w/Examples) + FAQs

The RCRA Hazardous Waste Part A Permit Application, filed on EPA Form 8700-23, is the form every owner and operator of a facility that treats, stores, or disposes of hazardous waste must submit to get a federal permit under the Resource Conservation and Recovery Act. The form gives the U.S. Environmental Protection Agency, or the authorized state acting in its place, the basic facts about your site: who runs it, what processes you use, how much waste each unit can hold, and which hazardous waste codes you handle.

This form is the front door to the entire hazardous waste permit. Part A is short and factual, while Part B is the long narrative that follows. Get Part A wrong and you can lose interim status, face daily penalties, or have your whole application kicked back to the start. The version most agencies use today carries an OMB number of 2050-0024 and a printed expiration date, so confirm you are working from the current packet before you write a single entry. The EPA reports that civil penalties under RCRA can reach more than $90,000 per day per violation, which is why each box on this form matters.

Here is what you will learn in this guide:

📋 What Part A is, who must file it, and the exact deadline that triggers your duty to file.
🗂️ Every document, ID number, and map you need to gather before you open the form.
✍️ A line-by-line walkthrough of all the Site ID Form items and the Part A items, with sample entries.
👥 Three full filled-out examples following real facilities from start to finish.
⚠️ The mistakes that get applications rejected and how to dodge each one.

What the Form Is and Who Must File It

EPA Form 8700-23 is the official RCRA Hazardous Waste Part A Permit Application. It is one piece of a single combined packet that also holds the RCRA Subtitle C Site Identification Form (8700-12) and the Biennial Hazardous Waste Report. When you file Part A, you complete both the Site Identification Form pages and the separate Part A pages, because the agency reads them together as one application.

You must file Part A if you own or operate a treatment, storage, or disposal facility, known as a TSDF. The duty comes from 40 CFR 270.1, which says anyone who treats, stores, or disposes of hazardous waste needs a RCRA permit. A generator who only accumulates waste for short, allowed periods usually does not need a permit. The moment you store waste longer than your generator status allows, or you treat or dispose of it, you cross into TSDF territory and Part A is required.

The agency that receives your form depends on where you sit. Most states are “authorized,” meaning the state environmental agency runs the RCRA program in place of the EPA. In California, that agency is the Department of Toxic Substances Control. In states without authorization, you file with your EPA Regional office. The deadline rule lives in 40 CFR 270.10: existing facilities must submit Part A no later than six months after new rules first make them subject to permitting, and new facilities must file before they begin physical construction.

Miss the deadline and the consequence is steep. A facility that fails to file on time can lose its interim status, which is the legal authority to keep operating while the permit is reviewed. Without interim status, every day of operation becomes an unpermitted activity that the EPA can penalize and order to stop.

Before You Start: Documents and Information You Need

Gather everything before you open the form. The Part A asks for facts you cannot guess at, and a blank field can stall your application for weeks while the agency sends a notice of deficiency.

Your EPA Identification Number. You need this 12-character number for a revised application; a first-time applicant leaves it blank and the agency assigns one. Missing or wrong numbers cause the file to be misrouted.
Legal owner and operator names and addresses. The form needs the true legal entity, not a trade name, because the agency cross-checks ownership for liability. A wrong name can void the certification.
Facility existence date. This is the date the site first existed as a hazardous waste facility, and it decides whether you count as “existing” or “new” under the deadline rule.
NAICS codes. At least one five-digit North American Industry Classification System code describing your business. The agency uses it to group facilities by industry.
A list of all hazardous waste codes you handle. Pull the D, F, K, P, and U codes from 40 CFR Part 261. Leaving one off means that waste is unpermitted.
Process codes and design capacities. You need the storage or treatment process code, the design capacity number, and the unit of measure for every unit on site. A wrong capacity can cap how much waste you may legally hold.
A topographic map. It must extend at least one mile beyond your property line and show water bodies, intake points, and waste units. A missing map is the single most common reason for rejection.
Photographs and a scale facility drawing. Existing facilities must show aerial or ground-level photos and a scale drawing of all storage, treatment, and disposal areas.
Other environmental permits. List permit types and numbers, such as air or water permits, because the agency coordinates programs.
Original ink signatures from all owners and operators. Stamped or photocopied signatures are not accepted and will void the filing.

Where to Get the Form and How to Access It

The form lives on the EPA’s hazardous waste permitting page. You can download the Part A instructions and form packet as a PDF that holds both the Site Identification Form and the Part A pages. The EPA also offers the full RCRA Subtitle C Reporting Instructions and Forms as one combined document, which includes the code lists you will need for the waste-code and process-code boxes.

If your state runs its own program, get the form from the state agency, because some states add their own pages or state-only waste codes. A California filer downloads the form through the Department of Toxic Substances Control and follows that agency’s submission steps. Many states host their own copy of EPA Form 8700-23, and a few accept the federal electronic system known as RCRAInfo for the Site Identification portion.

Always confirm the revision and expiration date printed at the bottom of each page before you fill it in. The form carries OMB control number 2050-0024, and using an expired version can lead the agency to reject the package and ask you to resubmit on the current form. When in doubt, call your state or EPA Regional contact listed on the EPA Find Your State Contacts page before mailing.

Step-by-Step: How to Fill Out EPA Form 8700-23 Line by Line

The form has two parts. First you complete the RCRA Subtitle C Site Identification Form (Items 1 through 19). Then you complete the Hazardous Waste Permit Part A Form (Items 1 through 11). Fill them in order, type or print clearly, and mark “X” in the “Y” or “N” boxes where asked. Enter your EPA ID Number in the top corner of every page for a revised application; leave it blank on every page for a first-time application.

Site ID Form Item 1: Reason for Submittal

This box asks why you are sending the form. You select only one reason. For a permit, you mark the box reading Submitting a new or revised Part A Form.

To answer, place a single “X” in that box and nothing else. Marking more than one reason confuses the agency about how to process your file.

For example, Greenfield Solvents LLC marks only the box for Submitting a new or revised Part A Form because it is applying for its first storage permit.

A common edge case is a facility that is both updating its EPA ID and filing Part A. The rule still allows only one reason per form, so you choose the Part A box, since that is the action driving the submittal.

A frequent mistake here is marking the biennial-report reason out of habit. The consequence is that the agency may log your form as a report, not an application, and your permit clock never starts.

People often think this box is optional because it sits at the very top. It is not; a blank Item 1 makes the whole form invalid because the agency cannot tell what you are requesting.

Site ID Form Item 2: Site EPA ID Number

This field asks for the 12-character EPA Identification Number already assigned to your site. It identifies your facility in the national hazardous waste database.

To answer, write the number in the boxes, one character per box, all in capital letters. For a first permit application with no number yet, leave this blank so the agency can assign one.

For example, an existing facility writes CAD000123456 across the boxes, while a brand-new site leaves every box empty.

The edge case is a site that handled waste years ago and is unsure if it has a number. You can look it up in the EPA’s RCRAInfo system before guessing, because a wrong number routes your file to the wrong facility.

A common mistake is inventing a number or copying one from a sister site. The consequence is that your application merges with another facility’s record, which can take months to untangle.

People wrongly believe a new facility must obtain the ID first and then file. In truth, submitting Part A is one of the ways you obtain the number, so leaving it blank is correct for first-timers.

Site ID Form Items 3-5: Site Name and Addresses

These items ask for your site name, the physical location address, and the mailing address. The agency uses the location address to assign your file to the right region and inspector.

To answer, print the legal site name in Item 3, the street location in Item 4, and the mailing address in Item 5. If the mailing address matches the location, mark the Same as Location Address box.

For example, Bayview Treatment Co. enters its plant address at 1400 Industrial Way, Richmond, CA 94804 in Item 4 and checks the same-as box in Item 5.

The edge case is a facility with a gate address that differs from its legal parcel. Use the address where the waste activity physically happens, not a corporate headquarters in another city.

A common mistake is listing a P.O. Box as the location address. The consequence is that inspectors cannot find your site, and the agency may reject the form because a location must be a physical place.

People think the mailing and location address are interchangeable. They are not; the location address drives jurisdiction, while the mailing address only controls where letters go.

Site ID Form Items 6-7: Site Land Type and NAICS Codes

Item 6 asks who owns the land your site sits on, with choices like Private, Federal, State, County, Tribal, or Municipal. Item 7 asks for the NAICS code or codes that describe your business.

To answer, mark one land-type box in Item 6 and write at least one five-digit NAICS code in Item 7, listing the primary code first under letter A.

For example, Greenfield Solvents LLC marks Private and enters 32551 for paint and coating manufacturing as its primary code.

The edge case is a facility on leased federal land. You mark Federal for land type even though a private company runs operations, because Item 6 asks about land ownership, not operations.

A common mistake is leaving NAICS blank because the filer does not know the code. The consequence is a deficiency notice, since the agency uses NAICS to classify and compare facilities.

People assume any NAICS code will do. In fact, the code should match your real activity, because a mismatched code can flag your file for review.

Site ID Form Item 8: Site Contact Information

This item asks for the person the agency should call about the site. It is the day-to-day technical contact, not always the legal owner.

To answer, enter the contact’s first name, middle initial, last name, title, full address, email, and phone. Use a person who actually knows the facility’s waste operations.

For example, Bayview Treatment Co. lists Dana R. Okafor, Environmental Manager, with her direct line and work email.

The edge case is a contact who works off-site for a parent company. List that person only if they truly handle the site’s waste questions; otherwise name the on-site manager.

A common mistake is naming a contact who has left the company. The consequence is missed agency calls and notices, which can lead to a default deficiency finding.

People think this contact must be an owner. It does not have to be; the contact is whoever can answer questions, while ownership is captured separately in Item 9.

Site ID Form Item 9: Legal Owner and Operator of the Site

This item asks for the legal owner and the legal operator, with names, owner and operator types, the dates they took over, and addresses. The agency uses these for liability and certification.

To answer, complete the owner block under letter A and the operator block under letter B. Enter the date each became owner or operator in MM/DD/YYYY format, and mark the correct type box for each.

For example, Greenfield Solvents LLC lists itself as both owner and operator, with Date Became Owner 06/01/2019 and the same date as operator.

The edge case is a site where one company owns the land and a different company operates the facility. You fill both blocks separately, because both must later sign the certification.

A common mistake is entering the trade name instead of the legal entity. The consequence is that the certification can be challenged as signed by the wrong party.

People believe the owner and operator are always the same. Often they differ, and the form is built to capture two distinct parties for a reason.

Site ID Form Item 10: Type of Regulated Waste Activity

This item asks you to mark “Y” or “N” for each activity at your site, including generator status and, in Item 10.A.3, whether you are a Treater, Storer or Disposer of Hazardous Waste. Item 10.B asks you to list federal hazardous waste codes.

To answer, mark “Y” on the treater, storer, or disposer line, since that is what makes Part A required. Then list every federal waste code in Item 10.B in the order they appear in the rules, such as D001, D003, F005, U112.

For example, Bayview Treatment Co. marks “Y” for storage and lists D001, F003, F005 because it stores ignitable solvent waste.

The edge case is a facility that also generates waste. You still mark your generator category in Item 10.A.1, then mark the treater or storer line, because the form expects both where both apply.

A common mistake is listing waste codes out of order or leaving one out. The consequence is that an omitted code means that waste stream is unpermitted, which is a violation.

People think Item 10.B is only for the wastes they treat. It actually covers all federal hazardous wastes handled at the site, including those merely stored.

Site ID Form Items 11-18: Additional Activities and Comments

These items capture extra activities such as transporter status, universal waste handling, used oil work, and other notifications, ending with Item 18 for comments. Most pure TSDFs mark “N” on activities that do not apply.

To answer, mark “Y” or “N” on each line honestly, and use Item 18 to clarify any entry, writing the item number next to each comment.

For example, Greenfield Solvents LLC marks “N” on used oil and universal waste lines and uses Item 18 to note “Item 10.B: F005 added for spent toluene, effective 2025.”

The edge case is a facility that also handles universal waste lamps. You would mark Item 11.B and still complete the rest of Part A, because the activities stack.

A common mistake is skipping the comment box when an entry needs explanation. The consequence is a follow-up letter from the agency that delays review.

People think comments are informal. They are part of the official record, so keep them short, factual, and tied to item numbers.

Site ID Form Item 19: Certification and Signatures

This item is the legal certification. By signing, you swear under penalty of law that the information is true, accurate, and complete. For a Part A, 40 CFR 270.10(b) and 270.11 require that all owners and operators sign.

To answer, each owner and operator signs in ink, prints their name and title, enters the date in MM/DD/YYYY format, and adds an email. Original signatures only; stamps and photocopies are rejected.

For example, both the owner’s president and the operator’s plant manager sign, each printing “John A. Reyes, President” and dating the line 07/15/2026.

The edge case is a consultant filing for a client. The consultant may sign only as an authorized representative with written authorization from the owner on file, or the agency will not accept the certification.

A common mistake is sending a photocopied signature page. The consequence is automatic rejection, because the rule demands original ink from every required party.

People think one signature covers the whole company. For Part A, every owner and every operator must sign, so a single signature can invalidate the application.

Part A Form Item 1-2: Facility Permit Contact and Mailing Address

The Part A pages start with their own contact. Item 1 asks for the facility permit contact, and Item 2 asks for that contact’s mailing address. This is the person the permit writer will work with.

To answer, enter the contact’s name, title, email, phone, and mailing address. This may be the same person as the Site ID contact or a different permit specialist.

For example, Bayview Treatment Co. lists Dana R. Okafor again, since she also manages the permit process.

The edge case is using an outside permit consultant as the contact. That is allowed, but make sure the agency can reach them quickly during review.

A common mistake is leaving Item 1 blank because the same name appears earlier. The consequence is that the permit writer has no clear point of contact, which slows the technical review.

People think the Site ID contact carries over automatically. It does not; the Part A form has its own contact box that must be filled in.

Part A Form Item 3: Facility Existence Date

This item asks for the date your facility first existed as a hazardous waste facility. It decides whether you are an existing or new facility under the permit rules.

To answer, enter the date in MM/DD/YYYY format. Use the date operations or construction first began for the waste activity.

For example, Bayview Treatment Co. enters 03/01/1995, the date it first stored hazardous waste.

The edge case is a facility that changed owners. The existence date stays the original date the site began the waste activity, not the date the new owner bought it.

A common mistake is entering the incorporation date of the company. The consequence is a wrong existing-versus-new status, which changes your deadline and your map and photo duties.

People think this is the date they bought the property. It is the date the hazardous waste activity began, which can be much earlier.

Part A Form Item 4: Other Environmental Permits

This item asks you to list other environmental permits the facility holds. The agency uses it to coordinate across air, water, and waste programs.

To answer, enter the permit type under letter A, the permit number under letter B, and a short description under letter C for each permit.

For example, Greenfield Solvents LLC lists Air Quality Permit, BAAQMD-12345, paint booth emissions and NPDES, CA0098765, stormwater discharge.

The edge case is a facility with no other permits. You write “None” rather than leaving it blank, so the agency knows you did not skip the item.

A common mistake is omitting an active air or water permit. The consequence is a coordination gap that can surface later and delay the RCRA permit.

People think only RCRA permits go here. The box is for all environmental permits, including air, water, and underground injection.

Part A Form Item 5: Nature of Business

This item asks for a plain description of what your business does. It helps the permit writer understand your processes in context.

To answer, write one or two clear sentences naming your industry and main activity. Keep it factual and specific.

For example, Bayview Treatment Co. writes “Commercial storage of spent industrial solvents prior to off-site recycling.”

The edge case is a multi-purpose plant. Describe the part that generates and handles hazardous waste, not every product line.

A common mistake is writing a vague phrase like “manufacturing.” The consequence is follow-up questions that slow the review.

People think this duplicates the NAICS code. The narrative adds detail the code cannot, so both are needed.

Part A Form Item 6: Process Codes and Design Capacities

This is the heart of Part A. For each waste-handling unit you enter a line number, a process code, the design capacity amount, its unit of measure, the total number of units, and the unit name. This is where the form most often goes wrong.

To answer, look up the process code in the instructions, such as S01 for container storage or T01 for a tank treatment unit. Enter the design capacity amount, the unit-of-measure code, and the count of units. List one row per process type.

For example, Greenfield Solvents LLC enters S01, 20000, G (gallons), 1 unit, “Drum Storage Area A” for its container storage.

The edge case is a unit that both stores and treats. You enter a separate line for each distinct process code, because one unit can carry more than one function.

A common mistake is mixing up the design capacity unit of measure, such as entering gallons where the code calls for pounds. The consequence is a capacity figure that misstates how much waste you may hold, which can cap your operations or flag an overcapacity violation.

People think design capacity means the amount of waste on hand today. It means the maximum the unit is built to hold, which is usually a much larger number.

Part A Form Item 7: Description of Hazardous Wastes

This item ties your wastes to your processes. For each waste you enter the EPA Hazardous Waste Number, the estimated annual quantity, the unit of measure, and the process codes that handle it.

To answer, list each waste code under 7.A, the annual amount under 7.B, the unit code under 7.C, and the process codes under 7.D that manage that waste. If a process has no code, describe it in 7.D(2).

For example, Bayview Treatment Co. enters D001, 50000, P (pounds), S01 to show 50,000 pounds of ignitable waste stored in container area S01.

The edge case is one waste handled by two processes. You list both process codes on the same waste line, separated as the form allows, so the agency sees the full path.

A common mistake is leaving the process-code link blank. The consequence is that the agency cannot tell where the waste goes, which triggers a deficiency notice.

People think the annual quantity must be exact. It is an estimate, but a wildly low figure can later look like underreporting, so base it on real records.

Part A Form Items 8-10: Map, Facility Drawing, and Photographs

Item 8 requires a topographic map, Item 9 a scale facility drawing, and Item 10 photographs. These attachments let the agency see your site without visiting first.

To answer, attach a topographic map extending at least one mile beyond your property line that shows the facility outline, intake and discharge points, each waste unit, and all rivers, springs, and surface water. Add a scale drawing and clear aerial or ground-level photos of all storage, treatment, and disposal areas.

For example, Bayview Treatment Co. attaches a USGS-based map marked with its drum storage building, the storm drain outfall, and the nearby creek.

The edge case is a brand-new facility not yet built. New facilities still provide a map and drawing of planned units, even though photos of existing structures may not yet exist.

A common mistake is submitting a map that stops at the property line. The consequence is rejection, because the rule demands the one-mile radius and surface water features.

People think a simple plot plan satisfies Item 8. It does not; the topographic map with the one-mile radius is a separate, strict requirement.

Part A Form Item 11: Comments

This final item lets you add any clarification the earlier boxes could not hold. The agency reads it as part of the official application.

To answer, write short, numbered notes tied to the item they explain. Use it to flag estimates, attachments, or unusual conditions.

For example, Greenfield Solvents LLC writes “Item 6: second tank under construction, capacity to be amended upon completion.”

The edge case is a revised Part A that adds a process. Use Item 11 to state exactly what changed and the effective date, which speeds the agency’s review.

A common mistake is using comments to make legal arguments. The consequence is confusion; keep comments factual, and save legal positions for a cover letter.

People think comments are optional fluff. They are part of the record and can prevent a deficiency notice by answering a question before it is asked.

Three Filled-Out Examples Using Real Scenarios

Below are three common filers walked through the form. Each table shows the most important entries from start to finish.

Scenario 1: First-Time Container Storage TSDF

Greenfield Solvents LLC is a new paint plant in Richmond, California that will store spent solvents in drums and needs its first permit.

Form Section	What Greenfield Solvents Enters
Site ID Item 1: Reason for Submittal	X in Submitting a new or revised Part A Form
Site ID Item 2: EPA ID Number	Left blank (first-time applicant)
Site ID Item 3-4: Site Name and Location	Greenfield Solvents LLC, 1400 Industrial Way, Richmond, CA 94804
Site ID Item 7: NAICS Code	32551
Site ID Item 9: Owner and Operator	Greenfield Solvents LLC, both owner and operator, 06/01/2019
Site ID Item 10: Activity and Codes	Y storer; codes D001, F003, F005
Site ID Item 19: Certification	Original ink signatures of owner and operator
Part A Item 3: Existence Date	06/01/2019
Part A Item 6: Process Codes	S01, 20000, G, 1 unit, Drum Storage Area A
Part A Item 7: Waste Description	D001, 50000, P, S01
Part A Item 8: Map	Topographic map, one-mile radius, attached

Scenario 2: Revised Part A Adding a New Process

Bayview Treatment Co. is an existing Richmond facility that already stores solvents and now adds a tank treatment unit, so it files a revised Part A.

Form Section	What Bayview Treatment Enters
Site ID Item 1: Reason for Submittal	X in Submitting a new or revised Part A Form
Site ID Item 2: EPA ID Number	CAD000123456 on every page
Site ID Item 3-4: Site Name and Location	Bayview Treatment Co., 1400 Marina Blvd, Richmond, CA 94804
Site ID Item 9: Owner and Operator	Land owner and operating company listed separately
Site ID Item 10: Activity and Codes	Y treater and storer; D001, F003, F005
Site ID Item 18: Comments	“Item 10.B: adding tank treatment for F005.”
Part A Item 3: Existence Date	03/01/1995
Part A Item 6: Process Codes	S01, 20000, G and new line T01, 5000, G, 1 unit
Part A Item 7: Waste Description	D001, 50000, P, S01 and F005, 10000, P, T01
Part A Item 11: Comments	“New tank online 09/2026; map updated.”

Scenario 3: Interim Status Facility Filing After a Rule Change

Sierra Reclaim Inc. is an existing facility newly pulled into permitting by a regulatory change and files Part A to keep interim status.

Form Section	What Sierra Reclaim Enters
Site ID Item 1: Reason for Submittal	X in Submitting a new or revised Part A Form
Site ID Item 2: EPA ID Number	CAD000654321 on every page
Site ID Item 6: Land Type	Private
Site ID Item 7: NAICS Code	562211
Site ID Item 10: Activity and Codes	Y storer and recycler; D008, F006
Site ID Item 18: Comments	“Filing within 6 months of rule change per 40 CFR 270.10.”
Site ID Item 19: Certification	Original signatures of all owners and operators
Part A Item 3: Existence Date	11/12/1988
Part A Item 6: Process Codes	S02, 100000, P, 1 unit, Waste Pile
Part A Item 7: Waste Description	D008, 200000, P, S02
Part A Item 8-10: Map, Drawing, Photos	All three attached for existing units

How to File the Completed Form

Where and how you file depends on your state. Confirm the channel with your agency before sending, and always keep proof of what you submitted.

By mail (most common). Send the signed original form, with original ink signatures and all map, drawing, and photo attachments, to your state hazardous waste program or EPA Regional office. In Nebraska, for example, the package goes to the Nebraska Department of Environment and Energy, Waste Management Section, 1200 N Street, Suite 400, Lincoln, NE 68509-8922. There is generally no fee for the federal Part A form itself, though some states charge permit-processing fees. Use certified mail and keep the receipt and a full copy as your proof of filing.
Through a state portal. Some states accept the Site Identification portion electronically through RCRAInfo or a state system. Even then, the Part A often still needs a signed paper copy because of the original-signature rule. Save the confirmation page or email as proof.
In person. A few agencies accept hand delivery at their office. Ask the front desk to date-stamp your copy so you have proof of the filing date.
By the right agency. In California, file with the Department of Toxic Substances Control; in non-authorized areas, file with your EPA Region. Sending it to the wrong office wastes weeks while it is forwarded.

Processing time varies widely. The Part A itself is logged quickly, often within a few weeks, but the full permit decision that follows in Part B can take months or years. Keep your stamped copy and mailing receipt until the permit is issued.

What Happens After You File

After the agency logs your Part A, it checks the form for completeness. If something is missing, you get a notice of deficiency that lists what to fix and sets a deadline to respond. Answering fast and fully keeps your file moving.

For existing facilities, a timely and complete Part A is what secures interim status, letting you keep operating while the permit is reviewed. The agency then asks for the Part B application, the long narrative covering your operating plans, contingency measures, and closure. Together, Part A and Part B make up the full permit application under 40 CFR Part 270.

The agency reviews Part B, may ask for more information, and eventually issues a draft permit for public comment before a final decision. During this time you must keep your information current. If a process, capacity, or waste code changes, you file a revised Part A so the record stays accurate, because operating outside your filed Part A description is a violation that can carry daily penalties.

Mistakes to Avoid When Filling Out the Form

Filling in the EPA ID Number on a first-time application; the agency may reject or misroute the file when it should be blank.
Leaving the EPA ID Number off the top of pages on a revised application; pages can get separated and lost.
Marking more than one reason in Site ID Item 1; the agency cannot tell what you are requesting.
Listing a P.O. Box as the site location address; inspectors cannot locate a physical box.
Omitting a federal waste code in Item 10.B; that waste stream becomes unpermitted, which is a violation.
Entering the wrong design-capacity unit of measure in Part A Item 6; your legal storage limit is misstated.
Confusing design capacity with current inventory; the form wants the maximum the unit can hold.
Failing to link wastes to process codes in Item 7; the agency cannot trace where the waste goes.
Submitting a map that stops at the property line; the rule requires a one-mile radius with surface water.
Sending photocopied or stamped signatures; the rule demands original ink and will reject copies.
Having only one owner sign when both owner and operator must sign; the certification is invalid.
Using an expired version of the form; the agency may return it and ask you to refile on the current form.

Do’s and Don’ts

Do:

Do download the current form and confirm the OMB number and expiration date, because expired forms get returned.
Do gather your map, photos, and drawing before you start, because missing attachments are the top rejection reason.
Do use exact process codes and waste codes from the instructions, because the agency matches them against the rules.
Do have every owner and operator sign in original ink, because the rule requires it for Part A.
Do keep a full copy and certified-mail receipt, because that is your proof of timely filing.
Do use the comment boxes to explain estimates and changes, because it heads off deficiency notices.

Don’t:

Don’t guess at your EPA ID Number, because a wrong number merges your file with another facility’s record.
Don’t paraphrase the official field labels or codes, because the agency reads the exact codes only.
Don’t mail the form to a corporate office or the wrong agency, because it wastes weeks in forwarding.
Don’t understate annual waste quantities, because a low estimate can look like underreporting later.
Don’t skip Item 8’s one-mile map requirement, because it is a hard rule, not a suggestion.
Don’t wait past the six-month deadline, because you can lose interim status and face daily penalties.

Pros and Cons of Filing on Your Own vs. With Help

Many facilities weigh handling Part A in-house against hiring an environmental consultant or attorney. Here is how the two approaches compare.

Pros of filing on your own:

Lower cost, because you avoid consultant fees that can run into the thousands.
Faster start, since you control the schedule and do not wait on an outside firm.
Direct knowledge, because your own staff know the processes and waste streams best.
Full control of the record, so you decide exactly what each box says.
Better learning, since your team builds in-house expertise for future revisions.

Cons of filing on your own:

Higher error risk, because the process-code and capacity grid trips up first-timers.
Time burden, since gathering maps, photos, and codes pulls staff off other work.
Missed nuances, because consultants know which entries draw agency scrutiny.
Deadline danger, since an in-house team may underestimate how long attachments take.
Certification exposure, because the signer swears under penalty of law and bears the risk of mistakes.

FAQs

Do I write my EPA ID Number on a first-time Part A application?

No. Leave the EPA ID Number blank on a first-time application. The agency assigns your number when it processes the form, and inventing one can merge your file with another facility’s record.

Do both the owner and the operator have to sign Part A?

Yes. Under 40 CFR 270.10(b) and 270.11, all owners and operators must sign the certification in Item 19. One missing signature can make the entire application invalid.

Do I need a topographic map with my Part A?

Yes. Item 8 requires a map extending at least one mile beyond your property line, showing waste units and all surface water. A short plot plan does not satisfy this rule.

Do I list every hazardous waste code in Item 10.B?

Yes. List all federal hazardous waste codes handled at the site, in the order they appear in the rules. An omitted code means that waste stream is unpermitted, which is a violation.

Do photocopied signatures count on the form?

No. Stamped or photocopied signatures are not accepted. Each required owner and operator must sign in original ink, or the agency will reject the certification.

Do I enter current inventory in the Part A Item 6 design capacity box?

No. Item 6 asks for design capacity, the maximum the unit is built to hold, not the amount of waste on hand today. Mixing these up misstates your legal limit.

Do I file Part A with the EPA or my state?

Yes, you file with whichever agency runs the program where you sit. Most states are authorized, so you file with the state; in non-authorized areas you file with your EPA Region.

Do generators who only store waste briefly need to file Part A?

No. Generators who accumulate waste within allowed time limits usually do not need a permit. You only file Part A once you treat, store, or dispose beyond your generator status.

Do I write the EPA ID Number on every page of a revised application?

Yes. For a revised application, enter your EPA ID Number in the top corner of every page. This keeps pages from being separated and lost during processing.

Do I have to describe my business in Item 5 if I gave a NAICS code?

Yes. The narrative in Item 5 adds detail the code cannot, so both are required. A vague description like “manufacturing” draws follow-up questions that slow review.

Do I link wastes to process codes in Item 7?

Yes. Each waste in Item 7 must show the process codes that handle it. Leaving the link blank means the agency cannot trace the waste path, which triggers a deficiency notice.

Do I get a fee charged for the federal Part A form?

No, there is generally no fee for the federal Part A form itself. Some states, though, charge their own permit-processing fees, so check with your state agency before filing.

Do I use the date I bought the property for Item 3?

No. Item 3, the facility existence date, is the date the hazardous waste activity first began at the site, which can be far earlier than your purchase date.

Do I need to refile Part A if my processes change?

Yes. When a process, capacity, or waste code changes, you file a revised Part A. Operating outside your filed description is a violation that can carry daily penalties.

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