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Jesse Handel
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Experience:  B.S. Degree Chem. & Bact. 10 yrs tax preparation.
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Is a WAP required for all TFDSs in waste managemen?

Customer Question

Is a WAP required for all TFDS's in waste managemen?
Submitted: 2 years ago.
Category: General
Expert:  Jesse Handel replied 2 years ago.

Hello and thank you for coming to Just Answer. We appreciate the opportunity to help you with your questions. First of all, I need to warn you that waste disposal regulations are complex, depend on your specific circumstances, and carry legal consequences if not followed properly. Therefore, while I will answer your question, I will also provide some EPA references that I recommend that you at least review to ensure that your specific circumstances aren't covered by specific requirements or that your specific circumstances don't exempt you from some requirements.

 

According to 40 CFR Parts 264/265, Subpart A-E), as explained in the EPA Training module that I will provide a link to for you, unless the TSDF is exempt from the requirements of Parts 264/265 (exemptions are listed in the manual) "TSDFs need to verify the composition (i.e., hazardous constituents and characteristics) of incoming waste in order to treat, store, or dispose of the waste properly. A waste analysis plan

(WAP) outlines the verification procedures, including specific sampling methods, necessary to ensure proper treatment, storage, or disposal (§264/265.13). The WAP must be written and kept on site."

The training manual is very well written in fairly plain language. It can be found at

Training manual .

Here is a training manual for waste analysis for TSDFs. Waste Analysis

Hopefully, this information will be helpful to you. Please let me know if you need more information about this question.

Customer: replied 2 years ago.
Ok so if a WAP is needed then what agency is suppose to approve it and what type of facilities would be exempt from filing a WAP and following those regulations?
Expert:  Jesse Handel replied 2 years ago.

If you look at the first reference I provided, there is a list of exempt facilities and activities on pages 7 through 10. The second reference discusses waste analysis plans, provides the requirements for WAPs, and provides example WAPs. If your facility was operating as a TSDF on November 19, 1980 and is operating under a RCRA interim permit (which is obtained from the EPA and the application requires the information listed under Part A on page 1-1). If your facility is applying for a final RCRA permit (and even a facility working under an interim permit is required to be working toward receiving a final RCRA permit), then the information required to apply to the EPA for a RCRA permit includes both the Part A and the Part B information as listed on page 1-1.

 

Detailed information about the RCRA permitting process for TSDFs can be found at 40 CFR Part 270.

 

Access to the Code of Federal Regulations (CFRs) can be found from this central federal government webpage. Federal regulations

 

I hope this information helps.

Jesse Handel, Scientist
Category: General
Satisfied Customers: 270
Experience: B.S. Degree Chem. & Bact. 10 yrs tax preparation.
Jesse Handel and 53 other General Specialists are ready to help you
Customer: replied 2 years ago.
Oh ok I'm going to read it all now then thank you

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Jesse Handel
Jesse Handel
Tax Preparer and Chemist
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B.S. Degree Chem. & Bact. 10 yrs tax preparation.