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Treatment Storage and Disposal Facilities

Hazardous waste facilities that treat, store, and/or dispose of waste are called treatment, storage, and disposal facilities (TSDFs). These types of facilities must have a permit in order to be constructed and operate.

Treatment involves various processes such as blending, neutralization, incineration, that are designed to make the waste less hazardous or alter its physical, chemical or biological character or composition. Incineration or combustion is used for destructing the waste to reduce volume but may result in energy or material recovery.

Storage facilities temporarily hold waste before treatment or disposal.

A disposal facility is where waste is placed in or on the land (e.g., landfills, underground injection).

Permits

Hazardous waste facilities needing a permit:

  • Facilities that receive "off-site" hazardous waste for storage, treatment, or disposal
  • Large quantity generators (LQGs) who store hazardous waste on-site for more than 90 days
  • Small quantity generators (SQGs) who store hazardous waste on-site for more than 180 days. Exception: SQGs may accumulate hazardous waste on-site for 270 days without a permit if they ship the hazardous waste to a TSDF that is more than 200 miles away.
  • Any generator of hazardous waste who treats the waste in something other than a tank, container, containment building, or drip pads, or disposes of the waste on-site.

A permit is a legally binding document that defines the activities allowed at the facility and the conditions under which they may be conducted. It outlines facility design, process information, emergency plans, and employee training plans. IDEM has the authority to issue or deny permits and is responsible for monitoring the facility to ensure that it is complying with the conditions of the permit.

Types of Hazardous Waste TSD Operations

Container Storage or Treatment

Containers represent one of the most commonly used and diverse forms of units for hazardous waste storage. Containers are mobile, allowing an owner or operator to use only one unit for storage, transportation, and disposal. The regulations covering management of hazardous waste stored in containers are found in 40 CFR Part 264 and 40 CFR Part 265, Subpart I.

Tank Storage or Treatment

Tank is a stationary device. Tanks are widely used for storage, accumulation and/or treatment of hazardous waste because they can accommodate large volumes, and because of their structural strength. Tanks must comply with the regulations in 40 CFR Part 264 and 40 CFR Part 265, Subpart J.

Drip Pads

Drip pads are hazardous waste management units that are unique to the wood preserving industry to collect dripping preservatives from the wood treatment. These are mostly managed as generator units. There are no permitted drip pads in Indiana. The design standards for drip pads are in 40 CFR 264.573 and 40 CFR 265.443 (Subpart W).

Containment Buildings

A containment building is a completely enclosed structure (i.e., possessing four walls, a roof, and a floor) that houses an accumulation of non-containerized waste. Containment buildings are designated as hazardous waste management units to address the difficulties associated with management of bulky, large volume hazardous wastes and to comply with the land disposal restrictions. Regulations to containment buildings are in 40 CFR Part 264 and 40 CFR Part 265, Subpart DD.

Incinerators

Incineration is a commonly employed technology used to treat hazardous waste. However, some energy or material recovery may occur. 40 CFR Part 264 subpart O emission standards for hazardous waste incinerators have been replaced by of the maximum achievable control technology (MACT) requirements of Part 63, Subpart EEE (Clean Air Act regulations) emission standards.  State RCRA requirements may include emission limits more stringent than the MACT requirements if necessary to protect human health and the environment based on human health and/or ecological risk assessment.

Boilers and Industrial Furnaces (BIFs)

Combustion in BIFs is used to burn hazardous waste for energy recovery, treatment, or for material recovery or as an ingredient. 40 CFR 266 Subpart H standards for hazardous waste have been replaced by the MACT requirements of Part 63, Subpart EEE (Clean Air Act regulations) standards to regulate the emissions that result from the combustion process. See 40 CFR 266.100 for exclusions from this Subpart.  Area source boilers may choose to comply with the BIF regulations for emissions of organics, carbon monoxide, HCl, PM, and metals instead of the MACT requirements.  However, state hazardous waste requirements may include more stringent emission limits based on human health or ecological risk assessment.

Waste Piles

Waste piles are essentially noncontainerized piles of solid, nonflowing hazardous waste, in temporary units used for storage or treatment only (40 CFR 260.10). Regulations governing the management of hazardous waste in waste piles are found in 40 CFR 264 Subpart L. There are no permitted waste piles currently in Indiana.

Surface Impoundments

Surface impoundments are either a natural topographic depression, manmade excavation, or diked area formed primarily of earthen materials, such as soil (although the unit may be lined with manmade materials) generally used for temporary storage or treatment of liquid waste. 40 CFR 264 Subpart K contains the design and operating standards for surface impoundments. There are no permitted hazardous waste surface impoundments currently in Indiana.

Landfills

Landfills are used as final disposal sites. They are monitored during their entire active life, including closure, and the post-closure period. The regulations concerning hazardous waste landfills are in 40 CFR 264 Subpart N. Landfills must be designed, constructed, and installed with a liner system, including leachate collection and removal system and leak detection system, to prevent any migration of wastes out of the landfill to the adjacent subsurface soil or ground water or surface water at any time during the active life (including the closure period) of the landfill. The liner must be constructed of materials that prevent wastes from passing into the liner during the active life of the facility. At final closure or partial closure, the landfill must be provided with a final cover to minimize migration of liquids through the final cover and maintenance of the cover. Land disposal facilities have groundwater monitoring requirements. Other units upon end of operation that do not remove waste may close according to these regulations.

Land Treatment Units

Land treatment involves the application of waste on the soil surface or the incorporation of waste into the upper layers of the soil in order to degrade, transform, or immobilize hazardous constituents present in hazardous waste. Essentially, the waste is treated within the matrix of the surface soil. The regulations for hazardous waste land treatment units are in 40 CFR 264 Subpart M. There are no permitted hazardous waste land treatment units currently in Indiana.

Miscellaneous Units

Miscellaneous units cover diverse technologies and units, including chemical, physical and biological treatment and under-ground injection. Miscellaneous units must be located, designed, constructed, operated, maintained, and closed in a manner that will prevent any unsafe releases into the groundwater, subsurface environment, surface water, wetlands, soil surface, or air. The regulations are in 40 CFR 264 Subpart X. These regulations are general, not technology-specific.

U.S. EPA provides a training module with additional information on these units.

Additional Information