Frequent Questions

What must the owner or operator of a treatment, storage, and disposal facility (TSDF) do in the case of a significant manifest discrepancy?

When the owner or operator of a TSDF discovers a significant manifest discrepancy they must attempt to reconcile the discrepancy with the waste generator or transporter. The owner or operator of a TSDF must immediately submit a letter to the Regional Administrator describing significant discrepancies that are not resolved within fifteen days of receiving the waste (§§264.72(b) and 265.72(b)).

Manifest discrepancies are defined as differences between the quantity or type of hazardous waste designated on the manifest and the quantity or type of hazardous waste a facility actually receives (§§264.72(a) and 265.72(a)). Significant discrepancies consist of variations in piece count for a batch shipment of waste and variations of greater than 10% by weight for a bulk shipment of waste (Memo, Petruska to Berry; September 14, 1995 (RCRA Online #11918)).

Additional guidance on manifest discrepancies is available in the following guidance documents: 
Monthly Report Question; September 1, 1985 (RCRA Online #12451
Monthly Report Question; March 1, 1984 (RCRA Online #12191
Monthly Report Question; January 1, 1983 (RCRA Online #12083)

These documents are available at the following URL:

www.epa.gov/rcraonline

 

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