Solid & Hazardous Waste Management - TSDF Standards

TSDF Standards

TSDF General Standards

• If a TSDF is not exempt, it must comply with the standards for fully regulated TSDFs.
• TSDF owners/operators must:
  • Notify EPA of the types of hazardous waste they plan to treat, store, or dispose of.
  • Apply for an EPA identification (ID) number.
  • Analyze waste shipments.
• The permit will list the types of hazardous waste that a facility is allowed to handle.
• Analyzing waste received ensures:
  • The facility only handles wastes they are permitted to handle.
  • Wastes are treated, stored, or disposed of properly.

TSDF Waste Analysis Plan

• The written waste analysis plan is kept on-site.
• It has procedures to ensure proper treatment, storage, or disposal by determining:
  • The waste received is the same as that described on the manifest.
  • The waste constituents can be analyzed by the TSDF.
  • How samples are to be taken.
  • The type of testing and analytical methods used.
  • How often waste is retested.
  • The acceptance and rejection criteria for each waste stream.
• Waste analysis must be repeated periodically to ensure information on a given waste is accurate and current.
• At a minimum, analysis is repeated when:
  • The TSDF is notified or has reason to believe that the process or operation generating the HW has changed.
  • Inspection indicates the HW received does not match the information on the manifest.

TSDF Security Provisions

• To prevent accidental or unauthorized entry where HW is treated, stored, or disposed, the facility must install:
  • 24-hour surveillance system that continuously monitors and controls entry (i.e., television monitoring, guards).
  • An artificial or natural barrier (i.e., a fence) that completely surrounds and serves to control facility entry at all times through gates or entrances.
  • A sign in English or other predominant language reading: “Danger—Unauthorized Personnel Keep Out” at each entrance.

TSDF Inspections

• The owner and operator must:
  • Visually inspect the facility for malfunction, deterioration, operator errors, and leaks.
  • Follow a written inspection schedule developed by the owner and operator.
• The schedule:
  • Identifies the types of problems to be checked and how often inspections are conducted.
  • Identifies where spills are more likely to occur (i.e., loading and unloading areas, must be inspected daily when in use).
  • Includes unit-specific inspections or requirements.
• The owner and operator must:
  • Record inspections in a log or summary.
  • Remedy any problems identified during inspections.

TSDF Personnel Training

• TSDF owners and operators must provide training to ensure that employees at the facility understand the risks posed by management of hazardous waste.
• Employees must be prepared to respond in the case of an emergency.
• The training program must be completed within:
  • Six months from the date the facility is subject to the TSDF standards.
  • Six months after the date a worker is newly employed.
• The training program must be reviewed annually.

TSDF Requirements for Ignitable, Reactive, or Incompatible Waste

• If ignitable and reactive wastes are handled, must demonstrate these wastes are protected from ignition sources:
  • "No Smoking" signs placed where ignitable and reactive wastes are stored.
  • Designation of separate smoking areas.
  • No combined storage of wastes that might react dangerously with one another, or with the unit in which they are stored (i.e., a fire or explosion, or the release of toxic dusts, gases, or fumes).
• RCRA regulations list common potentially incompatible wastes (40 CFR Part 264, Appendix V).
• If not listed, the owner or operator may need to test the waste and unit for compatibility.

Potentially Incompatible Wastes Examples:

• Acids (i.e., spent sulfuric acid) with alkaline (i.e., lime sludge) generates heat & violent reaction.
• Reactive metals (i.e., magnesium, sodium, zinc, aluminum) with acids or alkaline wastes generate fire or explosion due to the generation of flammable hydrogen gas.
• Spent cyanide and sulfide solutions with acids generate toxic hydrogen cyanide or hydrogen sulfide gas.
• Strong oxidizers (i.e., chlorine, nitrates, peroxides, permanganates) with acids or reactive metals or reactive solvents (i.e., hydrocarbons or alcohols) generate fire, explosion, or violent reaction.

TSDF Location Standards

• Certain types of terrain may increase the dangers associated with managing HW.
• To protect people and the environment, RCRA imposes restrictions on locations where new TSDFs can be built (i.e. floodplains, earthquake-sensitive areas, non-containerized or bulk liquid hazardous waste in a salt dome, salt bed formation, or underground mine or cave).
• Congress has granted one exception to this rule: DOE’s Waste Isolation Pilot Project (WIPP) in New Mexico.

WIPP Site Cleanup

• WIPP is a Department of Energy facility designed to safely isolate defense-related transuranic (TRU) waste from people and the environment.
• Began waste disposal operations in 1999 and is located 26 miles outside of Carlsbad, New Mexico.
• Waste temporarily stored at sites around the country is shipped to WIPP and permanently disposed of in rooms mined out of an ancient salt formation below the surface.
• TRU waste destined for WIPP consists of clothing, tools, rags, debris, residues, and other disposal items contaminated with radioactive elements - mostly plutonium.
• Numbers associated with WIPP:
  • 1,000 people are employed at WIPP.
  • 11,894 shipments safely transported more than 14 million loaded miles.
  • 24 hrs/day shipments are tracked and monitored around the clock by satellite.
  • Seven waste disposal rooms in each disposal panel measuring 300 ft. long, 33 ft. wide, and 13 ft. high.
  • 171,064 containers have been emplaced in the WIPP underground.
  • 11,894 m^3 of waste disposed of in the underground mine.
  • 2,150 feet distance to disposal rooms below the surface, compared to the Empire State Building at 1,454 feet high.

TSDF Contingency Plan

• Describes emergency response arrangements with local authorities.
• Lists the names, addresses, and telephone numbers of all facility personnel qualified to work with local authorities as emergency coordinators.
• A list of emergency equipment and evacuation plans.
• Must be reviewed and amended when:
  • If regulations or facility permits are revised.
  • If the plan fails in an emergency.
  • If there are changes to the facility, the list of emergency coordinators, or the list of emergency equipment.
• A copy of the contingency plan must be kept at the facility and provided to all local emergency authorities.

TSDF Emergency Coordinator

• The owner and operator must designate an emergency coordinator to guide emergency response activities.
• The emergency coordinator is responsible for assessing emergency situations and making decisions on how to respond.
• There must be at least one employee either on the facility premises or on call with the authority to commit the resources needed to carry out the contingency plan.

TSDF Emergency Procedures

• During an emergency, measures must be taken to ensure that fires, explosions, and releases do not occur, recur, or spread.
• In the event of an imminent or actual emergency situation, the emergency coordinator must immediately activate internal facility alarms or communication systems and notify appropriate state and local authorities.
• If the coordinator determines that the emergency threatens human health or the environment outside of the facility and finds that evacuation of local areas may be advisable, the coordinator must notify appropriate authorities and either the designated government official for the area or the National Response Center.

TSDF Manifest

• The owner and operator must sign and date all copies of the manifest to verify that the waste has reached the appropriate designated facility.
• A copy is kept for records, and a copy is sent back to the generator within 30 days.
• If a shipment originates in a foreign country, the owner and operator must send a copy of the signed and dated manifest to EPA within 30 days of delivery.
• If the owner and operator must send the waste to an additional TSDF for further treatment or disposal, they must initiate a new manifest.
• A new manifest is also used for rejected shipments or container residues sent to another TSDF or returned to the actual generator.
• If the entire waste shipment is rejected before the transporter leaves the facility, then the TSDF may use the original manifest.

TSDF Operating Record

• The owner and operator is required to keep, until the facility closes, a written operating record describing:
  • All waste received.
  • Methods and dates of treatment, storage, and disposal.
  • The location of wastes within the facility.
  • Waste analysis results.
  • Emergencies requiring implementation of contingency plan.
  • Inspection results (kept for 3 years).
• Information is cross-referenced with manifest number.
• Records may be kept in computer files, but the owner and operator must keep original, signed copies of all manifests.

TSDF Biennial Report

• TSDFs report to EPA Regional Administrator on March 1 of each even-numbered year.
• Report on the types and amounts of hazardous wastes generated, received, treated, stored, and disposed of.
• If TSDF generates HW during on-site treatment, storage, or disposal:
  • Describe waste minimization efforts taken to reduce the volume and toxicity of wastes generated.
  • Describe the changes in volume or toxicity achieved, compared with those achieved in previous years.
• States may require submission of such reports annually.

Standards for Units Used by TSDFs

Containers

• Containers are any portable device in which HW is stored, transported, or treated (i.e., drums, tanker trucks, railroad cars, buckets, test tubes).
• Containers must be:
  • In good condition.
  • Not deteriorating (e.g., cracked, rusted, or leaking).
  • Kept closed, except when adding or removing waste.
  • Not handled, opened, or stored in a way that might cause them to leak.
  • Visually inspected periodically for leaking and deterioration.
  • If holding liquid HW, must have a secondary containment system.
  • If holding ignitable or reactive wastes, must be located at least 50 feet from the facility’s property line.

Containment Building

• Used to store or treat HW (i.e., bulky, high volume HW debris).
• Designed to be:
  • Enclosed with four walls, a floor, and a roof.
  • Made of materials strong enough to withstand movement of wastes, personnel, and heavy equipment and chemically compatible with HW.
  • Control dust from HW.
• If it deals with liquid HW, then must have:
  • A primary barrier must prevent migration of HW.
  • A liquid collection system.
  • A leak detection system beneath the floor.
  • A secondary barrier around the unit to contain leaks.
• Containment building operating requirements include:
  • Free of significant cracks, corrosion, or deterioration.
  • Repair or replace coatings or liners subject to wear.
  • Limit waste pile height.
  • Maintain dust control devices at all openings.
  • A decontamination area within the building (i.e., for washing vehicles and equipment prior to leaving).
  • Inspected at least once every 7 days and recorded.
  • Repair leaks and contain the released waste, verified to EPA Regional Administrator by a professional engineer.

Drip Pads

• At wood-preserving plants, collect wood preservative drippage (along with rainwater or surface water enters, if outside) and convey it to a container until the waste may be recycled, treated, or disposed.
• The liquid collection system must contain all inflow and have a leak detection system.
• Inspected weekly and after storms to assure no leaks.

Land Treatment Units (Land Farms)

• Seldom-used treatment that applies HW to the upper soil surface above the water table.
• Degrade, transform, or immobilize hazardous constituents by microbes (biodegradation) and sunlight (i.e., petroleum refinery wastes).
• A treatment demonstration must first show it to be effective at treatment.
• Must:
  • Prevent run-on from rainwater and run-off of leachate.
  • Prevent wind from carrying off particles of HW (i.e., by a cover).
  • Control soil acidity and moisture to enhance microbial growth.
  • Be inspected weekly or after storms.
• If HW is sinking toward the water table, must notify EPA Regional Administrator within 7 days.

Landfill (Secure Landfill)

• The ultimate grave for a significant portion of the HW generated in the U.S., with 21 HW secure landfills in the U.S.
• To minimize potential for leachate to leak, EPA design standards include:
  • Double liner (synthetic over 3 feet of clay).
  • Double leachate collection and removal system.
  • Leak detection system.
  • Run-on, run-off, and wind dispersal controls.
  • Construction quality assurance - identifies how construction materials and their installation will be monitored and tested and how the results will be documented prior to any input of waste.
• HW Landfill operating requirements include:
  • No liquid HW accepted unless in very small containers (i.e., ampules) or contain small amounts of liquid (i.e., batteries or lab packs of drums filled with many small containers packed in non-biodegradable absorbent materials).
  • Inspect leachate collection system sump liquid levels to determine if upper liner is leaking.
  • Response action plan outlines short- and long-term actions in the event of a leak (i.e., short-term action might be shutting off the flow of HW into the landfill, long-term action might be emptying unit for repair of damaged liner or leachate collection system).

Surface Impoundments

• Used to store, treat, or dispose of HW.
• EPA design standards similar to HW landfills:
  • Double liner.
  • Double leachate collection and a removal system.
  • Leak detection system.
  • Dikes or berms to create the impoundment.
  • Freeboard – the distance between the surface of the waste and the top of the impoundment (dike) needs to be sufficient to prevent overflow.
  • Construction quality assurance.

Tanks

• Stationary devices to store or treat hazardous waste.
• Tanks must:
  • Have an adequate foundation, structural support, and protection from corrosion to prevent collapse or leak.
  • Be designed and tested by a professional engineer to certify it meets these requirements.
  • Have leak detection and secondary containment before being placed in service.
  • All ancillary equipment (i.e., pipes, valves, trenches connected to the tank or tank system) must have full secondary containment.

Waste Pile

• An open pile used for treating or storing non-liquid hazardous waste.
• The standards for these units are very similar to those for landfills (i.e., double liner, double leachate collection, leak detection).
• Waste piles may be used for temporary storage and treatment only, not disposal.

Underground Injection Control Wells

• Units into which HW is permanently disposed of by injection 1/4 mile below an aquifer with an underground source of drinking water.
• Regulated jointly by the Safe Drinking Water Act (SDWA) and RCRA.
• SDWA regulates the design, operating, and closure standards for the well itself.
• RCRA regulates any other hazardous waste-related activities at that facility up until the point of injection.
• Class I wells inject hazardous wastes, mostly located at industrial facilities to dispose of waste generated onsite.
• Class II wells inject fluids from oil and natural gas production, primarily brines (salt water). Over 2 billion gallons of brine are injected every day in the U.S..
• Oil & gas production wastes are not regulated by RCRA but by EPA or state to protect drinking water under the SDWA.

Closure of the TSDF

• Closure is the period directly after a TSDF stops normal operations.
• During this period, a TSDF:
  • Stops accepting HW.
  • Completes treatment, storage, and disposal.
  • Disposes of or decontaminates equipment, structures, and soils.
• Clean closure occurs if all HW is completely removed.
• The owner and operator must show the levels of hazardous contaminants on site do not exceed EPA-recommended exposure levels.
• A closure plan details exactly how and when facility closure will take place.
• The owner and operator submits to the implementing agency or local zoning authority a survey plat indicating the location and dimensions of the closed hazardous waste units.

Post-Closure of TSDF

• Post-closure is the period after closure during which owners and operators conduct monitoring and maintenance activities to preserve the integrity of the disposal system and continue to prevent or control releases from the disposal units.
• Post-closure cost estimates are based on projected costs for an entire post-closure period of 30 years.
• Post-closure care consists of two primary responsibilities:
  • Groundwater monitoring.
  • Maintaining the waste containment system (i.e., covers, liners, leachate collection and removal).

Financial Assurance for TSDFs

• Unexpected events could damage third parties by impacting human health or property outside the facility.
• In order to compensate third parties for injury or damage that might result from such events (known as liabilities), the RCRA regulations require TSDF owners and operators to demonstrate that they have the financial resources to pay for bodily injury or property damage that might result from waste management.
• The closure, post-closure, and liability financial resource requirements are called financial assurance.

Ground Water Monitoring for TSDF

• Groundwater monitoring is required of owners and operators of land-based units to monitor the groundwater that passes beneath their TSDF in order to detect leaks of HW and facilitate cleanup as soon as possible.
• Monitoring wells are required to detect contamination in the aquifer nearest the ground surface.
• Water sampling semi-annually compares results from monitoring wells to the background groundwater levels to determine if there is an increase in contamination.
• If groundwater protection standards are exceeded, then the owner and operator must either remove the hazardous constituents from the groundwater or treat them in place.

TSDF Air Emissions

• During TSDF processes, hazardous constituents can escape into the air (i.e., volatile organics).
• If the average volatile organic concentration emission goes above 500 parts per million by weight (ppmw):
  • Tanks and surface impoundments must install a control device (i.e., flare the VOCs) or prevent volatilization by installing a floating roof or floating membrane or install a closed-vent system routed to a volatile organic control device.
• Process vent (vented to the atmosphere) emissions or equipment leaks greater than 10 ppmw must have closed-vent systems.
• Containers over 26.4 gallons (0.1m^3) may need a closed vent system, depending on vapor pressure and the volume of content escape.
• A closed-vent system is not open to the atmosphere and transports the gas or vapor to a control device which can reduce or recover the organic emissions vented to it by at least 95% by weight.

Fugitive Emissions

• EPA studies estimate valves and connectors account for more than 90% of emissions from leaking equipment, with valves being the most significant source.
• Open-ended lines and sampling connections may account for as much as 5-10% of total VOC emissions from equipment leaks.
• Facilities can control emissions from equipment leaks by implementing a Leak Detection and Repair (LDAR) program or by modifying/replacing leaking equipment with “leakless” components.