Site Location / Description
Non-hazardous materials from a project site are required to be sent to properly permitted end use facilities by law. As a developer, general contractor, or consultant it is vital that materials shipped to beneficial use facilities are handled properly in order to protect yourself, your client, and the environment. During the process of selecting a facility it is important to follow steps that will ultimately protect your company and your client from cradle to grave liability. Researching andselecting a facility can become quite an overwhelming and tedious job. HCA provides the tools and experts our customers need to make the best decision, and provide thebest solution possible for your project.
Part 1 Conducting an Audit
Facilities are audited by various state and federal environmental agencies throughoutthe year as part of routine inspections. Some of these agencies provide online compliance logs to the public available for your review. The EPA Enviro Facts and PADEP e-facts are a few examples of environmental agency online databases. Within these databases you will find a variety of reports including compliance inspections, violations and permits of facilities. Another option or step in guiding your selection process for a facility is to request the facility complete an evaluation form. A company can create their own evaluation form, or general evaluation forms can be found on the Internet.
A thorough evaluation form should include line items such as:
- Facility Profile
- Description of Operations
- Site History, Compliance History, and Permits of the receiving facility and any end market facilities they use to dispose of their treated material.
- Permit Status and Regulatory Compliance
- Regulatory Agency Contact
- Personnel & Training
- Insurance coverages (environmental / professional liability)
- Waste Analysis
- Security & Emergency Response
- Business Continuity Considerations as well as consideration of the eventual closure of the facility and if it will be managed by EPA, DEP, RCRA, TSCA or ISRA regulators or regulations which could expose you to unnecessary environmental liability costs.
In addition, a physical audit of the facility should be conducted and have the evaluation form as a point of reference during the physical audit. Request that the General Manager, EH&S Manager, and Approvals Manager are present for the audit. It is important that the correct persons attend to answer all questions.
Sample questions that you may want to consider for your physical audit might include:
- Does the facility “pass through” soil to end market facilities which are not owned by the facility you sent it to? Or, where does the material go after they treat / blend your material?
- Does the permit that the facility operates under offer you transfer of liability protection as is offered by PA Act 1995-2 (a.k.a. “Act 2”) CHAPTER 5 Section 501 or PADEP General Permit WMGR096 condition 30?
- Does the facility control all of the material that is accepted at their end market facilities?
- What other legacies are you exposing yourself to because the treatment facility does not own the final “grave” where your material will rest.
- Review all the different types of operations (chemical/physical treatment, solvent recovery, hazardous waste.) that the facility provides at that location.
- Discuss the different types of wastes accepted at the facility / are the wastes comingled or sent off site to be co-mingled with other waste materials at off-site “end market” facilities?
- Does the facility provide certificates of disposal and does that certificate include the end market or final resting place of your material?
- What are the maximum quantities of wastes is the facility is allowed to accept each day / do you need to request “slots” for disposal?
- What is their policy for “debris”? Is brick, ash, glass, concrete, asphalt, block considered debris?
- What is the policy for rejecting material that contains “debris”?
Facilities also have the option to be reviewed by outside vendors such as CHWMEG, Inc., and ISNetworld. TSDF facilities willing to have their facility reviewed with companies such as this hold a strong, reliable presence in the soil remediation marketplace.