TSDFs

What are the known or potential problems/concerns with above TSDF sites or transporters ... 

Under the RCRA exemption, wastes intrinsically associated with the exploration and development of oil and gas do not have to follow Subtitle C regulations for disposal. Under Subtitle C, hazardous wastes must follow strict guidelines for storage, treatment, and transportation and disposal. The cost of handling materials under the Subtitle C scenario is overwhelming. Under the exemption, the operator is allowed to dispose of wellsite waste in a prudent manner and is not obliged to use licensed hazardous waste transporters and licensed Treatment, Storage, and Disposal Facilities (TSDF). 

Most nonexempt nonacute hazardous waste generated on location is considered a small quantity. In this case, the waste may remain on location for 90 days. At that time, a Department of Transportation licensed motor carrier must transfer the waste to a EPA certified TSDF for disposal. Appropriate documentation and packaging must be conformed to. The operator continues to be liable for the waste as denoted by the cradle to grave concept [233],... 

Permitting To ensure that only facilities meeting the TSDF standards are treating, storing, and disposing of hazardous waste and to provide each TSDF with a record of the specific requirements applicable to each part of its operation, RCRA requires owners and operators of these facilities to obtain a permit. 

Enforcement To ensure that RCRA-regulated facilities, from generators to TSDFs, comply with these regulations, RCRA provides U.S. EPA with the authority to enforce provisions of the Act. 

Store used oil in tanks and containers. Storage of used oil in lagoons, pits, or surface impoundments is prohibited, unless these units are subject to hazardous waste TSDF standards. 

Universal waste destination facilities are facilities that treat, dispose of, or recycle a particular category of universal waste. These facilities are subject to the same requirements as fully regulated hazardous waste TSDFs. Full regulation includes permit requirements, general facility standards, and unit-specific standards. The universal waste program includes only two additional specific universal waste requirements for destination facilities. These requirements are procedures for rejecting shipments of universal waste and the documentation of the receipt of universal waste. 

HAZARDOUS WASTES REGULATIONS GOVERNING GENERATORS, TRANSPORTERS, AND TSDFs... 

Permitted or interim status hazardous waste TSDF... 

Transporter requirements do apply to shipments between noncontiguous properties that require travel on public roads. Examples of such on-site transportation include generators and TSDFs transporting waste within their facilities, or on their own property. 

With some exceptions, a TSDF is a facility engaged in one or more of the following activities ... 

Disposal The discharge, deposit, injection, dumping, spilling, leaking, or placing of any solid or hazardous waste on or in the land or water. A disposal facility is any site where hazardous waste is intentionally placed and where the waste will remain after a TSDF stops operation. 

The standards include full operation and management requirements for permitted facilities (new) and less stringent provisions for interim status facilities (existing). The TSDF standards require facilities to comply with... 

TSDFs owners and operators can treat, store, or dispose of waste in a variety of units. Each unit has its own specific standards governing unit design, construction, operation, and maintenance. Owners and operators can manage their waste in any of the following units1 2 3 4 5 6 7 8 9 ... 

LQGs accumulating waste in containers, containment buildings, drips pads, and tanks are subject to the interim status TSDF standards for these units. SQGs accumulating waste in containers and tanks are subject to the interim status standards for these units. 

The TSDF standards also establish requirements to ensure that hazardous waste management units are closed in a manner that protects human health and the environment. The closure provisions require the facility to stop accepting waste remove all waste from management units and decontaminate all soils, structures, and equipment. Some units (i.e., land treatment units, landfills, and surface impoundments) serve as places for the final disposal of hazardous waste. These land disposal units must comply with additional postclosure requirements to ensure proper long-term unit maintenance. 

Because closure and postclosure activities can be very expensive, the TSDF standards require owners and operators to demonstrate financial assurance. These provisions also require all TSDFs to set aside funds in order to compensate third parties for bodily injury and property damage that might result from hazardous waste management operations. 

RCRA s TSDF standards also include provisions to protect groundwater and air resources from hazardous waste contamination. RCRA requires owners and operators of land-based units (i.e., land treatment units, landfills, surface impoundments, and waste piles) to monitor the groundwater below their TSDF for possible contamination, and clean up any discovered contamination. 

In order to protect air resources, TSDFs are required to install unit controls to prevent organic emissions from escaping into the air. The air emission controls apply to process vents, equipment leaks, containers, surface impoundments, and tanks. 

Because hazardous waste combustion units are a type of TSDF, they are subject to the general TSDF standards in addition to combustion unit performance standards and operating requirements. Combustion units are also subject to specific waste analysis, inspection and monitoring, and residue management requirements. 

In addition, these units are also subject to the general TSDF facility standards under RCRA. Flazardous waste incinerators and hazardous waste burning cement kilns and LWAKs are also subject to the CAA MACT emission standards. A complete overview of the MACT standards and additional information about hazardous waste combustion can be found in Ref. 13. 

In order to obtain a permit, a TSDF owner and operator must comply with specific application procedures. The permitting process consists of the following stages2 ... 

Compliance monitoring is used to determine a handler s level of compliance with RCRA s regulatory requirements. The primary method of collecting compliance monitoring data is through an inspection. Either U.S. EPA or an authorized state may lead inspections. Inspections must be conducted annually at all federal- or state-operated facilities and at least once every two years at each TSDF. The six types of inspections conducted under the RCRA program are2... 

U.S. EPA uses the guidelines in the Civil Penalty Policy for assessing penalty amounts and uses the Final U.S. EPA Supplemental Environmental Projects Policy to allow for flexibility in assessing penalties. Enforcement of RCRA at federal facilities is now similar to enforcement at TSDFs, as a result of the Federal Facility Compliance Act of 1992. 

The cleanup of a site with hazardous waste contamination may be handled under either CERCLA, as described above, or RCRA. RCRA authorizes U.S. EPA to require corrective action (under an enforcement order or as part of a permit) whenever there is, or has been, a release of hazardous waste or constituents at TSDFs. The RCRA statute also provides similar corrective action authority in response to releases at interim status facilities. Further, RCRA allows U.S. EPA to require corrective action beyond the facility boundary. U.S. EPA interprets the term corrective action to cover the full range of possible actions, from studies and interim measures to full cleanups. Anyone who violates a corrective action order can be fined up to 27,500/d of noncompliance and runs the risk of having their permit or interim status suspended or revoked. 

U.S. EPA has also developed organic air emission regulations for TSDFs and LQGs under RCRA. However, these RCRA regulations have been designed to minimize, to the extent possible, any overlap with CAA regulations. 

Air emissions from RCRA incinerators and other TSDFs must comply with applicable CAA NAAQS and emission limitations... 

EPCRA Some RCRA TSDFs must submit annual reports to EPA detailing releases of chemicals to air,... 

MPRS A MPRS A prevents waste from an RCRA generator or TSDF from being deposited into the... 

OSHA RCRA hazardous waste generators and TSDFs may need to comply with OSHA training and... 

The primary interaction between RCRA and EPCRA is that some RCRA TSDFs treating hazardous waste are required to submit annual reports to U.S. EPA of their releases of chemicals to air, land, and water.2... 

There are two major areas of overlap between MPRSA and RCRA. MPRSA prevents waste from an RCRA generator or TSDF from being deposited into the ocean, except in accordance with a separate MPRSA permit. In addition, dredged materials subject to the requirement of an MPRSA permit are not considered as hazardous wastes under RCRA.2... 

HAZWOPER regulations may be applicable to RCRA corrective action cleanup activities and to hazardous waste operations at generator facilities and TSDFs. 

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