A transfer facility is any transportation related facility including loading docks, parking areas, storage areas and other similar areas where shipments of hazardous waste are held during the normal course of transportation (40 CFR §260.10). A transfer facility is not required to operate under a RCRA storage permit if the hazardous waste is being stored during the normal course of transportation and the waste is manifested, kept in DOT specification containers, and stored less than ten days at the transfer facility (§263.12). A transporter may not store hazardous waste in stationary tanks and still take advantage of the reduced transfer facility requirements because such tanks are not portable (Monthly Call Center Report Question; June 1996 RCRA Online #13786). If the waste is held for more than ten days at a particular location, the transfer facility must obtain a RCRA permit, and the transporter must comply with all applicable storage standards and permit requirements (Memo, Lowrance to Duprey; June 7, 1990 RCRA Online #11520).
The regulations referenced above are available online at www.ecfr.gov.
Additional guidance regarding transfer facilities is available in the following documents:
Memo, Shapiro to Regions; October 17, 1994 (RCRA Online #11881)
Memo, Shapiro to Dickhut; August 17, 1994 (RCRA Online #13692)
Memo, Petruska to Igli; June 21, 1994 (RCRA Online #11846)
Monthly Call Center Report Question; November 1991 (RCRA Online #13511)
Memo, Lowrance to Ullrich; October 30, 1990 (RCRA Online #11567)
Memo, Stoll to Eastwood; April 10, 1986 (RCRA Online #12611)
These documents are available at the following URL: