Treatment Storage And Disposal Requirements

Treatment, storage, and disposal facilities (TSDs) are the last link in the cradle-to-grave hazardous waste management system. All TSDs handling hazardous waste must obtain operating permits and abide by treatment, storage, and disposal regulations. TSD regulations establish performance standards for owners and operators to minimize the release of hazardous waste into the environment.

The original RCRA establishes two categories of TSDs based on permit status. Section 3005(a) of the act specifies that TSDs must obtain a permit to operate. The first category consists of interim status facilities that have not yet obtained permits. Congress recognized that it would take many years for the EPA to issue all permits, therefore, the interim status was established. This allows those who own or operate facilities existing as of November 19, 1980, and who are able to meet certain conditions, to continue operating as if they have a permit until their permit application is issued or denied. The second category consists of facilities with permits.

Under Section 3004(a) of the act, the EPA was required to develop regulations for all TSDs. Although only one set was required, the EPA developed two sets of regulations, one for interim status TSDs and the other for permitted TSDs. While developing TSD regulations, the EPA decided that owners and operators of interim status facilities should meet only a portion of the requirements for permitted facilities.

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