['Waste']
['TSD Facilities']
12/27/2024
Copyright 2024 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.
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Treatment, storage, and disposal facilities (TSDFs) are the final destination in the hazardous waste management process under the Resource Conservation and Recovery Act (RCRA). These facilities provide temporary storage for and final treatment or disposal of hazardous wastes.
Because TSDFs manage large volumes of hazardous waste, they must comply with strict regulations that establish how facilities and hazardous waste management units are operated and additional safety precautions to protect human health and natural resources.
Scope
Any facility that stores, treats, and/or disposes of hazardous waste is considered a TSDF and is, therefore, regulated as one. All TSDFs must obtain a RCRA permit to engage in hazardous waste management activities. Additionally, all TSDFs are subject to the standards of 40 CFR Part 264/265 unless specifically exempt. These regulations include:
- General facility standards,
- Unit-specific technical requirements,
- Contingency plan and emergency procedures, and
- Reporting and recordkeeping requirements.
Regulatory citations
- 40 CFR Part 264 — Standards for owners and operators of hazardous waste treatment, storage, and disposal facilities
- 40 CFR Part 265 — Interim status standards for owners and operators of hazardous waste treatment, storage, and disposal facilities
- 40 CFR Part 270 — EPA-administered permit programs: The hazardous waste permit program
Key definitions
- Disposal: The discharge, deposit, injection, dumping, spilling, leaking, or placing of any solid or hazardous waste into or on any land or water so that such solid or hazardous waste or any constituent thereof may enter the environment or be emitted into the air or discharged into any waters, including groundwaters.
- Facility: All contiguous land and structures, other appurtenances, and improvements on the land used for treating, storing, or disposing of hazardous waste or for managing hazardous secondary materials before reclamation. A facility may consist of several treatment, storage, or disposal operational units or combinations of them.
- Storage: Holding hazardous waste for a temporary period, at the end of which the hazardous waste is treated, disposed of, or stored elsewhere.
- Treatment: Any method, technique, or process (including neutralization) designed to change the physical, chemical, or biological character or composition of any hazardous waste to neutralize such waste, recover energy or material sources from the waste, or render such waste:
- Nonhazardous or less hazardous;
- Safer to transport, store, or dispose of; or
- Amenable for recovery, amenable for storage, or reduced in volume.
Summary of requirements
Before beginning any hazardous waste management activities, the TSDF owner or operator must apply for and receive a RCRA permit for the facility. The permit lists the types of waste management activities the facility may conduct and the conditions under which it can conduct the activities. The RCRA permit also includes the applicable regulations from Part 264/265.
Part 264 regulates TSDFs built after RCRA was enacted (permit status), while Part 265 regulates TSDFs that existed before RCRA (interim status). All TSDFs must apply for a RCRA permit.
General facility standards
These standards incorporate good housekeeping requirements. When operating a TSDF:
- Apply for a site-specific Environmental Protection Agency (EPA) Identification Number,
- Submit any required notices,
- Maintain all required records,
- Develop waste analysis plans for incoming wastes,
- Install appropriate security measures,
- Conduct inspections of the facility,
- Train personnel, and
- Take the required precautions when handling ignitable, reactive, or incompatible wastes.
Unit-specific technical requirements
TSDFs may use different types of units to treat, store, and dispose of hazardous waste. Examples include containers, tank systems, landfills, and incinerators. In addition to meeting the general facility requirements:
- Comply with the unique standards for each type of unit (contained in Subparts J through EE of Part 264/265);
- Have the required equipment at the facility, such as alarm systems and portable fire extinguishers;
- Test and conduct maintenance on the required equipment;
- Maintain aisle space; and
- Coordinate with local authorities for emergency responses.
Contingency plan and emergency procedures
A contingency plan is required to minimize hazards from fires, explosions, or any unplanned releases of hazardous waste. For each TSDF:
- Develop a contingency plan for the facility,
- Keep a copy of the plan at the facility and submit it to local authorities that may respond to emergencies, and
- Update the contingency plan immediately if any information in the plan changes.
At least one emergency coordinator must always be either at the facility or on call to respond and implement the emergency response procedures listed in 264.65/265.65.
Reporting and recordkeeping requirements
All required records and plans for the facility must be available for inspection upon request.
When receiving wastes from off-site:
- Comply with the standards for manifested waste, including:
- Evaluating the manifest for any discrepancies,
- Conducting the required actions to reconcile any discrepancies and/or return the waste, and
- Signing the manifest and sending a copy to the generator within 30 days if no discrepancies are found.
- Submit an unmanifested waste report to the regional EPA administrator within 15 days of receiving unmanifested waste from off-site.
Owners and operators of TSDFs must also comply with other recordkeeping regulations:
- Keep a written operating record on site until the facility closes,
- File the Hazardous Waste Report (also known as the Biennial Report) by March 1 of each even-numbered year, and
- Submit any additional required reports, such as facility closures or release reports.
Deciphering regulations related to chemical management in your workplace can be challenging. Our “HAZs” quick reference guide on chemical management topics is a convenient tool you can reference to help ensure compliance.
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