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In the Loop - May 2009

Some In The Loop articles and links are pertinent to EPA staff and are available to EPA Intranet users only.

Tip of the Month: Retiring Permits and Permit Documentation (20-MAY-2009)

Although permits and their supporting documentation are often retired to the Federal Records Center (FRC) together, there is no policy or guidance specifying that this must always happen. Sometimes permits and their supporting documentation are separated and are retired in different accessions. In a situation like this, it is important that one collection of documents has evidence of the existence and location of the other.

  • If the permit was retired to the FRC earlier than the supporting documentation, place a copy of the pertinent SF 135 showing the FRC accession number, location and the box list with the supporting documentation. An additional safeguard would be to place a copy of the permit in with the supporting documentation.
  • If the supporting documentation is retired first, likewise place its SF 135 showing the accession number and location with the permit file.

The second of these scenarios is most likely to arise in the case of UIC (Underground Injection Control) or RCRA (Resource Conservation and Recovery Act) permits. These permits have a permanent retention period. Other permits have shorter retention periods and in these cases it is important that retention of the supporting documentation matches that of the permits as closely as possible.

The following schedules should be consulted when considering the retirement or transfer of permits and supporting documentation:

  • Schedule 205 Permit Files (in draft) - this schedule deals with UIC, NPDES (National Pollutant Discharge Elimination System), and other permits (see Item c).
  • Schedule 210 Administrative Records - Permits - this schedule deals with administrative records required for the issuance of draft and final permits for Prevention of Significant Deterioration (PSD), RCRA, NPDES, and UIC permits. Other permits such as those associated with the Toxic Substances Control Act (TSCA) are covered by Item d.
  • Schedule 478 RCRA Generators, Transporters, and TSD (Treatment, Storage and Disposal) Facilities Files - this schedule includes RCRA permits and supporting documentation.

In the case of Schedule 210, it is possible that the administrative record will contain records that are duplicated elsewhere, for instance under Schedules 205 or 478. If the records in 210 duplicate those in 205 or 478, follow the disposition instructions in schedule 210. However if the administrative record contains the record copy of the permit documents, follow the instructions for the appropriate permitting schedule - Schedule 205 for non-RCRA permits and Schedule 478 for RCRA permits.

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