Attachment 7 Site Visit Contractor Final Report.docx

ATTACHMENT 7

SITE VISIT CONTRACTOR FINAL REPORT

1. Cover Sheet

2. Table of Contents

3. Executive Summary with Risk Ranking

4. Site Visit Date, Location, Site Point of Contact(s) (POC) with phone number

5. Site Visit Team with phone numbers

6. Description of the site visit scope

7. Description of facility location and on-site buildings with authorized photos and internet map aerial view.

8. Description of facility operations and processes including, but not limited to:

a. Type of Landfill, type of incinerator, type of reclamation, etc.

b. Type of Management Method Codes (MMCs) authorized at the facility.

c. Type of property permitted to receive:

i. Regulated, Non-regulated, solid waste, liquids and/or Hazardous Material (HM) only.

ii. Resource Conservation and Recovery Act (RCRA) Hazardous Waste (HW); flammable, ignitable, corrosive (acidic or alkaline), reactive, or toxic waste.

iii. Toxic Substances Control Act (TSCA) waste.

iv. Other types of unique waste received at facility; cylinders, lithium sulfur dioxide batteries, Per-and polyfluoroalkyl substance (PFAS) related waste, etc..

d. Descriptions on how incoming waste is sampled/analyzed, segregated and stored.

e. Provide an overview of the laws and regulations that are applicable to facility operations and processes.

f. What permits (RCRA Part B, Clean Air Act (CAA), Clean Water Act (CWA), etc.) are required for facility operations and processes in addition to the following, but not limited to:

i. Expiration dates listed.

ii. What regulatory entity issued the permit(s)?

iii. Provide permit copies in attachments.

g. What type of insurance (pollution, general, closure mechanism, etc.) is required for facility operations and processes in addition to the following, but not limited to:

i. Expiration dates listed.

ii. How and who determined the type and total amount of insurance required for this facility?

iii. Is the type and amount of insurance consistent with other facilities with similar operations and processes?

iv. Provide copies of insurance in attachments.

h. If ultimate disposal doesn’t occur at this site, list what type of waste goes to what specific downstream facility with Environmental Protection Agency (EPA) ID.

i. What type of waste (RCRA regulated or non-regulated) is generated from the process and list the downstream disposal facilities with EPA ID for such waste.

j. Description of facility tracking capabilities in addition to the following, but not limited to:

i. Results on matching sampled Government shipment records with facility processing records (see Section 4).

ii. List manifest or Bill of Lading (BOL) numbers for sampled downstream Government waste shipments and include as attachments.

iii. For sampled Government waste shipments where Government waste was sent to downstream facilities, list these TSDFs with EPA IDs.

iv. List process dates and MMC for sampled Government waste shipments.

v. Is there currently any stock from Government shipments, what are the quantities, what is the condition, and how long has it been in storage?

9. List the results of recent regulatory compliance inspections in addition to the following, but not limited to:

a. Who provides regulatory inspections (fed, state, local, etc.)?

b. List regulatory POCs with phone numbers.

c. What is the frequency of inspection?

d. Does the facility have a positive relationship with regulators?

e. The site visit contractor will pull EPA’s Environmental Compliance History Online (ECHO) report for each site and include as attachment. Identify if ECHO shows the facility as having a Significant Non-Compliance (SNC) or High priority Violation (HPV).

f. List corrective actions for any SNCs and HPVs and include as attachment.

g. If there are discrepancies between facility provided findings and ECHO listed findings, have the facility provide a justification for the discrepancy.

h. Is the site listed as a Potential Responsible Party (PRP) with Comprehensive Environmental Response Compensation and Liability Act (CERCLA) or classified as a CERCLA, National Priorities List (NPL), or Brownfield site?

10. Site visit contractor observations for issues identified with each of the following applicable statutes, disposal contract requirements and/or HM sales contract requirements including, but not limited to:

a. RCRA

b. TSCA

c. CERCLA

d. Department of Transportation (DoT) Regulations

e. Clean Water Act (CWA)

f. National Pollutant Discharge Elimination System (NPDES)

g. Clean Air Act (CAA)

h. Occupational Safety and Health Administration (OSHAA)

i. Overseas Environmental Baseline Guidance Document (OBEGD)

j. Final Governing Standard (FGS)

k. Other Federal, State, and local (County, City, etc.) regulations

l. HM Sales Statement of Intent (SOI) and Invitation For Bid (IFB)

m. Disposal contract terms and conditions

n. Miscellaneous observations

11. Conclusion

12. List of attachments/appendices

a. Government provided files – reports and completed inspection checklist

b. Site related process diagrams, pictures and maps

c. Compliance information - ECHO, regulatory inspection reports, consent decrees

d. Site certifications, permits and insurance

e. Site miscellaneous/correspondence

13. Actual attachments/appendices