When it comes to managing hazardous waste, regulatory compliance isn’t just a “check the box” activity – it’s a critical component of corporate risk management. The Resource Conservation and Recovery Act (RCRA) empowers the United States Environmental Protection Agency (EPA) and delegated state agencies to oversee hazardous waste management from “cradle to grave.” Treatment, Storage and Disposal Facilities (TSDF) are responsible for treating (e.g., incinerate, chemically fix, neutralize, etc.) and disposing of hazardous waste in accordance with applicable regulations.
Under RCRA, waste generators remain responsible for their waste from the point of generation through final disposal – even when working with and relying on third party TSDFs. It’s essential for waste generators to audit the TSDFs they partner with and rely upon to ensure proper treatment, storage and disposal of their wastes in compliance with applicable standards and that minimize regulatory and financial risks to their organizations.
TSDF Audits as Corporate Risk Strategy
TSDF audits are a vital part of a proactive and robust environmental risk management strategy. They demonstrate a company’s commitment to regulatory compliance, transparency, environmental stewardship and community responsibility. Benefits include:
- Strengthening supplier relationships and accountability
- Reducing long-term liability risks
- Enhancing stakeholder trust
Waste Generator Risks
Improperly managed TSDFs can pose significant risks to waste generators and the environment. Sending waste to a facility lacking proper permits, oversight, and/or operational integrity, can result in:
- Regulatory non-compliance
- Environmental incidents
- Reputational damage
- Financial penalties
A poorly planned audit can overlook critical compliance gaps, operational inefficiencies, or safety hazards, potentially leading to costly consequences. Due diligence through systematic auditing is one of the most effective tools for eliminating or mitigating these risks.
Take a Strategic Approach to Auditing
A strategic auditing approach ensures safe and compliant hazardous waste management practices. TSDFs handle complex and dangerous wastes, making it essential to verify that their operations align with federal, state and local regulations. A well-organized and executed audit helps organizations avoid penalties, properly manage legal liabilities and promote proactive management of environmental risks.
Remote Screening
Remote screening, or desktop reviews, can be a cost-effective first step in evaluating a TSDF. This process involves reviewing publicly available information, permits and registrations from federal and state environmental databases. Satellite imagery of the facility location and nearby structures, communities and environmental features may also be used to assess the facility’s condition and operations – sometimes revealing red flags at the TSDF without the need for a site visit.
On-Site Limited Regulatory Compliance Audits
Performing a TSDF audit requires an experienced auditor to visually inspect the facility and verify that it holds the necessary environmental permits and complies with the applicable requirements. A sample of facility records will also be selected and reviewed, which may include:
- Spill Prevention, Control and Countermeasure (SPCC) Plan and associated inspections
- Stormwater Pollution Prevention Plans (SWPPP) and associated inspections
- Hazardous Waste Storage Area inspections
- Stormwater Discharge Monitoring Reports (DMRs)
- Visual Opacity Reading Records for site operations
- Semi-annual and Annual Air Quality Compliance Reports
Waste Stream Specific Regulatory Compliance Audits
A TSDF permit specifies which types of waste can be accepted at the facility. In this audit, the waste characterization and documentation for each stream are reviewed at the generator’s site to ensure compliance with the TSDF’s permit. This audit can be conducted independently or in combination with other types of audits.
Full Regulatory Compliance Audits
Multi-media environmental compliance audits of TSDFs can be performed on behalf of a waste generator or at the request of a TSDF seeking confirmation of compliance and recommendations for improvements. During these on-site audits, applicable regulations, permits and records related to waste, water, air and chemical reporting are reviewed in depth to confirm compliance and identify non-compliant conditions.
Next Steps: TRC Can Help
Generators that rely on TSDFs to manage their waste streams remain responsible for the wastes originating at the generator’s facility from the point of generation through final disposal. To ensure environmental compliance and safe work operations, it is important for generators to regularly audit the TSDFs they do business with to verify proper treatment, storage and disposal of all wastes they transport to the TSDF.
TRC’s comprehensive audit solutions ensure waste generators are compliant and confident in the capabilities of the TSDFs they utilize to manage and treat their waste. Our practitioners complete full multi-media environmental compliance audits of TSDFs on behalf of a generator or at the request of a TSDF. During these on-site audits, applicable regulations, permits and records related to waste, water, air and chemical reporting are reviewed and reported in depth.
