Phone (609) 208-1885

TSDF Reviews and Risk Sharing Evaluation

ENVISION performs Treatment, Storage and Disposal Facility (TSDF) reviews for our clients to identify the risk in the continuing use of such facilities and to minimize potential liabilities. We have developed a TSDF environmental site audit program and perform audits annually for our clients, who are mostly manufacturing firms generating both hazardous and non-hazardous wastes. The liability for wastes is “cradle to grave”, resulting in risks to a generator if a waste is improperly disposed of, especially if the waste disposal facility improperly handles the wastes. Our clients understand the need for meaningful audits of the TSDFs that they send waste to; however they have limited time and expertise to perform these audits. This is why they call on ENVISION to perform the audits on their behalf.

ENVISION offers customized, professional audit protocols and inspections of TSDFs. Our cost effective approach assists our clients based on their needs and the relative risk profile of the TSDFs used. We typically use a three (3) phased approach, which saves our clients significant money associated with travel expenses.

  • In Phase 1 – Desktop Review, we start by completing a paperwork review of the subject TSDFs to give our client an overview and to prioritize TSDF risks. All TSDFs used by a client are reviewed during this phase and a report is generated to identify and prioritize key risks and concerns for each TSDF. ENVISION can then generate a Focus List, prioritizing the top 50% of TSDFs from the Phase 1 review, where more investigation and information is warranted.
  • In Phase 2 – Focus List Analysis, we analyze the prioritized TSDFs and the client’s risk concerns (compliance, waste volumes, manifest reviews, cost, past and future liability, possible TSDF replacement, etc). We obtain documentation from the TSDFs, the client and independent environmental databases and financial reviews to aid in this evaluation. At this point we determine financial stability, risk sharing, Superfund liability, civil and criminal enforcement actions, compliance status, safety record, etc. From this review, some of the TSDFs may be recommended for our Phase 3 – Onsite Audits program.
  • Phase 3 – Onsite Audits. After we have narrowed down the TSDF list, we perform comprehensive onsite audits of the critical TSDFs for our clients. A comprehensive report is generated based on the site visit and recommendations for further action are provided. ENVISION personnel are well versed in waste regulations and the proper method of conducting onsite audits. Our audits reduce time and costs, and minimize concerns, in order to better assess and manage potential risks for our clients.

    ENVISION personnel have experience auditing the following types of TSDFs in North America:
     
  • Fully Regulated Part B TSDFs (allowed to treat RCRA hazardous waste)
  • State Permitted Facilities
  • Used Oil Recyclers/Refineries/Rerefineries
  • Used Oil Storage, Transportation and Generation Facilities
  • Antifreeze Refining Operations
  • Fluorescent Lamp Recyclers and Universal Waste Handlers
  • Scrap Recycling Facilities
  • Landfills