Frequent Questions

Is the loading/unloading area at a treatment, storage, and disposal facility (TSDF) considered a transfer facility or part of the permitted facility?

Designated facilities cannot have transfer facilities on their property (Memo, Lowrance to Svanda; August 31, 1988 (RCRA Online #11365).  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 that stores waste for a period of ten days or less is exempt from certain requirements (e.g., permitting and unit-specific requirements) (§263.12). However, the transfer facility provisions in §263.12 apply to the waste being held during the normal course of transportation. Arrival of the waste at the designated facility constitutes completion of the transportation phase (Memo, Lowrance to Svanda; August 31, 1988 (RCRA Online #11365)). Although the definition of transfer facility may include some loading/unloading areas, the normal course of transportation is completed at the designated facility. As a result, the ten-day limit and exemption from certain requirements for transfer facilities is not applicable to the loading/unloading area at the TSDF. 

Additional guidance regarding transfer facilities is available in the following documents: 
Memo, Lowrance to Ullrich; October 30, 1990 (RCRA Online #11567
Memo, Lowrance to Duprey; June 7, 1990 (RCRA Online #11520

These documents are available at the following URL:

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