Transporters of hazardous waste are subject to many of the same regulatory requirements as generators. For instance, a transporter must adhere to strict recordkeeping and labeling requirements and must comply with the manifest system (RCRA §3003, 42 USC §6923). Additional requirements are found at 40 CFR part 263.


The types of TSDFs vary as much as the technologies for handling hazardous waste. For instance, a TSDF can be an incinerator; chemical, physical, or biological treatment plant; or a container or tank system. They also include generators that store hazardous waste onsite for more than ninety days as well as those generators that treat or dispose of wastes themselves.

The RCRA (§3004, 42 USC §6924; 40 CFR pts. 264, 265, 267) places controls on TSDFs. All TSDF owners and operators must obtain an RCRA permit or be designated as interim status to be legally operating (RCRA §3005, 42 USC §6925; 40 CFR pt. 270). The permit must last the life of the unit, including the closure period. Interim status applies to facilities which:

1. Are in existence on or prior to November 19, 1980, or the effective date of statutory or regulatory changes which make the facility subject to the RCRA's permit requirements

2. Have complied with the general notification requirements of section 6930

3. Have applied for an RCRA permit

Part A of the RCRA permit requires applicants to provide their name, address, and facility location. Also required are the operator's name and address; a general description of the business; a scale drawing of the facility; a description of the processes used to treat, store, and dispose of hazardous waste; as well as a list and an estimate of the quantity of hazardous waste onsite. In addition, Part A requires a list of the permits which the facility holds under other environmental programs.

Part B of the permit calls for detailed technical information explaining the type of TSDF involved (e.g., an incinerator) and a thorough chemical and physical analysis of the facility's hazardous waste. It also requires a description of security procedures; the facility inspection schedule; as well as procedures for preventing spills, runoff, contamination, and exposure. Applicants must also provide an outline of training programs, a copy of the facility closure plan, and proof of insurance coverage. Finally, the permit must be signed by a responsible corporate officer.

TSDFs have numerous other requirements under the RCRA. A TSDF, for instance, must obtain an identification number from the EPA. They must also comply with notice requirements, analyze all wastes that their facility produces, and develop a waste analysis plan.

Releases and Groundwater Monitoring

The RCRA regulations (40 CFR pts. 264-265, subpts. F) establish procedures to follow in the event of a release from a TSDF. To assure detection, compliance, and corrective action, TSDFs must practice groundwater monitoring by installing monitoring wells.

Facilities must initially perform detection monitoring for hazardous constituents listed in their RCRA permit. When groundwater protection standards are exceeded for the facility's hazardous constituents, more stringent compliance monitoring is also required.

Certain facilities are excluded from groundwater monitoring requirements. Facilities are excluded if they:

1. Receive and contain no liquid

2. Are designed and operate without liquid

3. Contain inner and outer layers of containment enclosing

4. Have a leak detection system

5. Have continual operation and maintenance of a leak system

6. Do not allow migration of hazardous constituents beyond the outer containment layer.


TSDFs must assure their financial ability to cover any liability involved in closure before they are granted a permit to open (40 CFR pts. 264-265, subpts. G). TSDF permits contain closure plans which assure a regulated closing. When a TSDF plans to close, it must meet requirements which assure a clean closure (i.e., no contaminated equipment or contamination in the soil or groundwater on the facility site remains).

Underground Storage Tanks

The RCRA sought to regulate underground storage tanks after its 1984 amendments (RCRA §§9001-9010, 42 USC §6991-6991i), but final regulations for the underground storage tank program were not promulgated until 1988 (53 FR [23 September 1988] 37082). The regulations require release detection and prevention, as well as corrective action.

Underground storage tanks are defined as "any one or combination of tanks (including underground pipes connected thereto) which is used to contain an accumulation of regulated substances, and the volume of which (including the underground pipes connected thereto) is 10 per centum or more beneath the surface of the ground (RCRA §9001[1], 42 USC §6991[1]).

Owners or operators of underground storage tanks must notify the EPA of their existence. Tanks installed after December 22, 1988, must comply with a national code of practice. This code establishes requirements for new tanks, such as corrosion protection and leak detection devices. All underground storage tank owners must comply with the regulations for releases of regulated substances. The regulations also impose requirements for closure of tanks as well as various aspects of financial responsibilities.

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