Choosing a TSDF and closure requirements

• Facilities must comply with certain requirements in the regulations when choosing to close a location, part of a facility, or hazardous waste unit.

Here are some important considerations when choosing a treatment, storage, and disposal facility (TSDF):

• Be sure the facility is permitted by the Environmental Protection Agency (EPA) and/or the state for the specific types of wastes the business handles;
• Find out if EPA or the state conducts frequent inspections of the facility;
• Check online to be sure the TSDF is listed as an acceptable facility on EPA’s or the state’s website. Optionally, call and ask to speak to state inspectors for their take on a TSDF in consideration.
• Check online for the enforcement and compliance history of the facility. Has it been cited for improper treatment or storage? EPA maintains a database with information on many facilities at its EPA government website. Many states also post enforcement histories online.
• Be sure the facility has the financial backing and assurances required by EPA or the state to ensure it can properly close or clean up any releases.
• Visit the site. Ask lots of questions, including:
  • How will the facility handle the waste?
  • Does the facility plan to ship the waste offsite? (In that case, check out that site.)
  • Is the facility equipped to deal with the specific waste?
  • Will the facility be notified of the final disposal of the waste in writing?
  • Does the TSDF have an environmental compliance expert onsite?
• Once a facility has begun using a particular TSDF, be sure to drop by unannounced every now and then. See how the facility operates when they’re not expecting anyone. Is the operation running smoothly, or is there a lot of scrambling upon arrival?

Closure requirements

Facilities must comply with certain requirements in the regulations when choosing to close a location, part of a facility, or hazardous waste unit.

Large quantity generators (LQGs) must notify EPA using Form 8700-12 at least 30 days before closing a facility or hazardous waste unit and within 90 days after closing the facility or unit. A facility that fails to do these things will be classified as a landfill.

The point is to prevent environmental damage that can occur (and has occurred) when containers of waste are abandoned.