Q.01

What is a TSDF for hazardous waste?

A TSDF is a treatment, storage, or disposal facility: a site that treats, stores or disposes of hazardous waste. In the US it needs a RCRA permit and has to meet EPA's owner/operator standards. RCRA (42 U.S.C. chapter 82) doesn't use the acronym "TSDF" itself. It says "facilities for the treatment, storage, or disposal of hazardous waste" [1].

What each activity means under RCRA §6903

  • Treatment: any method, technique or process, including neutralization, that is designed to change the physical, chemical or biological character or composition of a hazardous waste. The aim is to neutralize it or make it nonhazardous, safer for transport, amenable for recovery or storage, or reduced in volume [2].
  • Storage: holding hazardous waste "either on a temporary basis or for a period of years" in a way that does not amount to disposal [2].
  • Disposal: the discharge, deposit, injection, dumping, spilling, leaking or placing of waste into or on land or water, so that the waste or any of its constituents may enter the environment, including groundwater [2].

Why being a TSDF matters

  • Permit (§6925): EPA "shall" require each person owning or operating an existing or planned TSD facility to hold a permit. Treating, storing or disposing of listed or identified hazardous waste, or building a new facility for it, is prohibited except in accordance with that permit [3]. If the waste is treated, stored or disposed of at the site where it was generated, the permittee must certify at least once a year that it has a waste-minimization program and that its treatment, storage or disposal method minimizes present and future threats to human health and the environment [3].
  • Standards (§6924): owners and operators have to meet performance standards, including:
    • the operating methods used to handle waste received
    • contingency plans
    • criteria for where facilities may be located
    • financial responsibility
    • corrective action for releases from any solid waste management unit at the facility, whenever the waste was placed there, and beyond the facility boundary where necessary [1]

Outside the US: India's Central Pollution Control Board (CPCB) also uses the term for its common hazardous-waste TSDFs. Its list describes them as integrated sites (secured landfill plus incinerator) or as landfill-only or incinerator-only sites. One example is M/s Maharashtra Enviro Power Ltd., Nagpur unit, listed as an integrated facility with both a secured landfill and an incinerator [4].

Approach: I read the RCRA statute (2023 edition of 42 U.S.C. chapter 82, §§6903, 6924 and 6925) and India's CPCB list of common hazardous-waste TSDFs. I did not review EPA's detailed TSDF regulations in 40 CFR.

Q.02

How do common TSDFs work in India?

In India, a common TSDF is a shared facility, mostly privately operated, that takes hazardous waste from many generating industries and treats or disposes of it. CPCB's current list sorts the 55 sites into three types: 26 integrated (both secured landfill and incinerator), 17 secured-landfill only and 12 standalone incinerator. A new common TSDF needs prior environmental clearance under the EIA Notification, 2006. I could not open the governing text, the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, so the obligations it puts on generators and operators are not covered here.

Facility types and spread (CPCB list)

  • Integrated: one example is BEIL Infrastructure, Ankleshwar; another is Mumbai Waste Management, Taloja [5].
  • Secured landfill only: for example Vapi Green Enviro [6] and Kerala Enviro Infrastructure, Kochi [7].
  • Standalone incinerator: for example Detox India, Dahej [8].
  • Where they are: the sites cover 20 states and UTs, but unevenly. Gujarat has 14 (from BEIL Ankleshwar to Varni Enviro Care [9]). Karnataka has 9, and most of those are incinerators. One site serves Delhi: Re Sustainability at Bawana [10].
  • The same list appears in CPCB's 2024-25 National Inventory [11].
  • Some operators run more than one activity on a site. Hyderabad Waste Management Project at Dundigal is reported as "TSDF & Common Hazardous Waste Incinerator & AFRF" [12].

How a common TSDF gets approved and overseen

  • Environmental clearance: item 7(d) of the Schedule to the EIA Notification, 2006 (original S.O. 1533(E) text) lists "Common hazardous waste treatment, storage and disposal facilities (TSDFs)". It puts "All integrated facilities having incineration & landfill or incineration alone" in one category column and "All facilities having land fill only" in the other, and states "General Condition shall apply" [13].
  • Escrow tracking: CPCB keeps a separate list of 19 TSDF operators in 12 states and UTs and tracks whether each has an escrow account. For one Karnataka entry the list notes that an "Escrow account has been opened" but clarification is "awaited from Karnataka SPCB" on whether it is "as per OM dated 16.04.2009 of MOEF&CC" [14]. The source does not say what the account is for.
  • Links to recycling and utilisation approvals: CPCB's October 2015 procedure for utilisation approvals (under Rule 11 of the 2008 Rules, now historical) is one example. It set the condition that "The residue generated shall be utilized in process or shall be sent to common TSDF or captive disposal facility". It also required that "The TSDF operator shall submit quarterly report on receipt of residue disposed of by the unit" [15]. I did not find the same TSDF wording in the parts I read of CPCB's revised 2019 procedure under Rule 9 of the 2016 Rules [16].

Not covered here: I could not open the official text of the 2016 Rules on India Code or on CPCB's rules portal. So I have not set out who identifies TSDF sites, how operators are authorised, how long waste may be stored, or the rules on manifests, records and liability.

Approach: I searched CPCB's common TSDF list and escrow-status list, CPCB's National Inventory reports, CPCB's hazardous-waste archive, and the MoEF gazette archive (which has the 2006 EIA Notification and the 2008/2009-era Hazardous Wastes Rules notifications, not the 2016 Rules). The inventory figures for each TSDF are printed without column headings, so I have not quoted capacities or quantities.

Q.03

How do US hazardous waste facilities differ?

The main difference is that the US has no separate "common TSDF" category like India's. Under RCRA, every facility that treats, stores or disposes of hazardous waste needs its own permit under 42 U.S.C. §6925 and must meet the §6924 standards, whether it is a commercial site taking other companies' waste or a unit at the plant that made the waste. India's CPCB, by contrast, lists shared facilities in three types (integrated, secured-landfill only, incinerator only) [4], and new ones need prior environmental clearance under the EIA Notification, 2006 [13].

1. How facilities are classed and tracked

  • EPA's RCRAInfo register gives each site a handler record. It shows the site's generator status and whether it is a transporter, a recycler, receives waste from off site, is federally or state regulated, or is a commercial TSD.
  • One site often does several of these. Chemical Waste Management at Emelle, Alabama is flagged as a large-quantity generator, a transporter and a commercial TSD that receives off-site waste [17]. Wayne Disposal in Belleville, Michigan is flagged the same way, except as a transporter [18].
  • Federal government sites are included. The US Department of Energy's Hanford Facility is recorded as both a federally regulated and a state-regulated TSDF [19].
  • Generators can store waste on site without becoming a TSDF, within limits. For generators of more than 100 kg but less than 1,000 kg a month, on-site storage without a permit may last up to 180 days. It may last up to 270 days, for no more than 6,000 kg, if the waste must travel over 200 miles [20].

2. Permits instead of clearance categories

  • Permit term: a permit is for a fixed term, "not to exceed 10 years". Permits for land disposal facilities "shall be reviewed" five years after issue or reissue [3].
  • Revocation: a permit "shall" be revoked if the facility does not comply [3].
  • Interim status: a facility that existed when the permit requirement started to apply to it, notified EPA and applied for a permit is treated as permitted until its application is decided [3].
    • Interim-status landfills and surface impoundments still have to meet the liner rules for new units when they expand [21].
  • Research permits: EPA "may" issue research, development and demonstration permits for innovative treatment. Each runs for up to one year and can be renewed no more than three times [3].

3. Who regulates: EPA or an authorised state

  • A state with an EPA-authorised programme issues and enforces TSD permits in place of the federal programme. Its actions have "the same force and effect" as EPA's [22].
  • EPA "shall" withdraw a state's authorisation if the state does not run the programme properly and does not correct it in time [22].
  • An authorised state programme must make information on TSD facilities publicly available [22].

4. Technical standards set in the statute

  • Land disposal ban: listed wastes are banned from land disposal above set concentrations. Examples are liquids with free cyanides at or above 1,000 mg/l, mercury at or above 20 mg/l, PCBs at or above 50 ppm, and halogenated organics at or above 1,000 mg/kg.
    • Storing banned wastes is prohibited except to accumulate the quantities needed for proper recovery, treatment or disposal [1].
  • Minimum technology: new landfill and surface-impoundment units need two or more liners, a leachate collection system and groundwater monitoring. Permitted incinerators must reach the required minimum destruction and removal efficiency [1].
  • Corrective action: a permit must require cleanup of releases from any solid waste management unit at the facility, whenever the waste was placed there. Where necessary, the cleanup extends beyond the facility boundary [1].

5. Financial assurance

  • US: an operator may show financial responsibility by insurance, guarantee, surety bond, letter of credit or self-insurance. If the operator is bankrupt, claims may be made directly against the guarantor [1].
  • India: CPCB only tracks whether TSDF operators have opened escrow accounts [14].

6. Tracking waste from generation to disposal

  • Generators: they must use a manifest so that waste "arrives at" a permitted facility. They must also report every two years on the quantities they generate and where the waste went [23].
  • Transporters: they may carry waste only to the permitted facility named on the manifest [24].
  • On-site facilities: where waste is treated, stored or disposed of at the site that generated it, the permittee must certify at least once a year that it has a waste-minimisation programme [3].

Approach: I used the RCRA statute (2023 edition of 42 U.S.C. chapter 82) and EPA's RCRAInfo handler register, and drew the India points from the CPCB lists covered earlier. EPA's detailed TSDF regulations in 40 CFR were not among the sources I searched, and I have not decoded RCRAInfo's single-letter facility-type codes because the register does not define them.

Q.04