A Totally Enclosed Treatment Facility, sometimes referred to as a Totally Enclosed Treatment Unit, is an exclusion in the RCRA regulations available to generators of hazardous waste.  It allows a generator to conduct on-site treatment (definition below) of its hazardous waste without being subject to the RCRA permitting requirements of 40 CFR Parts 264 or 265; the exclusions are found in §264.1(g)(5) and §265.1(c)(9), respectively.  Further, if the hazardous waste is managed immediately upon generation in a Totally Enclosed Treatment Facility and the treated effluent is a non-hazardous waste, then the waste is not subject to RCRA regulations from its point of generation and does not count toward the facility’s generator status [§ 261.5(c)(2)].  Though it sounds enticing, “So long, Large Quantity Generator status!” the scope of the TETF exclusion is very limited; the purpose of this article is to explain the definition of a Totally Enclosed Treatment Facility for hazardous waste.

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