TSDF.RF_Evaluation_Questionnaire.pdf

Waste and Recycling Review Committee

TSDF/RF EVALUATION QUESTIONNAIRE

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SECTION A

General Facility Information

Facility Name

Website

Mailing Address

Physical Address

County

Facility Owner Name: Title:

Environmental Manager’s Contact Information

Name: Title:

Office #: Cell #:

E-mail Address:

Facility Ownership _____ Publicly Owned ______ Privately Owned

Facility Status _____ Subsidiary ______ Joint Venture ______ Division of Parent Corporation

Parent Corporation

Name:

Address:

Parent Corporation Status _____ Publicly Owned ______ Privately Owned

Property Owner

Name:

Address:

Property Type _____ Owned _____ Leased _____ Rented

Tax Map/Parcel ID#

NAICS Codes

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SECTION B

Permit/License Information Summary

RCRA Facility EPA ID#:

Hazardous Waste Generator Status: _____ TSDF _____ LQG _____ SQG _____ VSQG

Recycler Status: _____ Intermediate Facility _____ Recycling Facility _____ Downstream Facility

Universal Waste Generator Status: _____ LQH _____ SQH

Used Oil Generator Status:

CERCLA Off-Site Rule Status:

RCRA Permit #’s: _________ Effective Date:______ Expiration Date:_______(attach additional sheet if necessary)

Other:

Air Air Permitting Status: _____ Title V _____ Minor _____ Exempt

Air Permit #’s: _________ Effective Date:______ Expiration Date:_______(attach additional sheet if necessary)

Water POTW Permit #: _________ Effective Date: _______ Expiration Date: _______

Stormwater Notice of Intent #: _____________________

NPDES Permit #: _________ Effective Date: _______ Expiration Date: ______

Receiving Waters: ______________________________________

Solid Waste Solid Waste Status:

Solid Waste Permit #’s: ____________ Effective Date: __________ Expiration Date: __________

Radioactive Material License #: ______________ Effective Date: __________ Expiration Date: ___________

Basic Limits: _____________________________________________

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SECTION B….continued Permit/License Information Summary

Regulatory Oversight Agency

DOE/SRNS Contract # Statement of Work # __________________________ Purchase Order/Subcontract #__________________

NOTES:

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SECTION C

Environmental Compliance Regulatory Status and History

QUESTIONS RESPONSE REFERENCES

Permit/Certification Status:

1. What environmental permits does the facility have?

Examples include, but are not limited to:

a. Waste Management (e.g. RCRA Part B, Recycling Facility)

b. Air

c. Water (i.e. NPDES, POTW)

d. Stormwater

e. Groundwater Wells

f. TSCA

If applicable provide copy of permit

Permit #:

a.

b.

c.

d.

e.

f.

2. List the following information about each permit:

a. Expiration date;

b. Summary of any permit modifications made during the last two years; and

c. Copy of any significant site specific permit conditions.

b.

c.

3. What type of certifications does the facility have?

Examples include, but are not limited to:

a. ISO Certification Standards (e.g. 9001, 14001)

b. E-Stewards

c. R2

d. Recycling Industry Operating Standard – RIOS

e. OHSAS 18001

If applicable provide copy of certification.

ISO 9001 certification (for quality management) ISO 14001 certification (for environmental management) Stewards R2 certification Recycling Industry Operating Standard (RIOS) certification OHSAS 18001 certification (for occupational health and safety

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SECTION D

Environmental Compliance Regulatory Status and History

QUESTIONS RESPONSE REFERENCES

Compliance History:

4. Has any enforcement actions been taken against the facility in the last three years, including, but not limited to:

a. Consent Orders;

b. Consent Agreements;

c. Administrative Complaints; and

d. NOVs; NODs; NONs, and RODs.

d.

5. Is the facility currently operating under any Consent Orders or Agency agreements? If so, describe.

Future Regulatory Status:

6. Will the facility be able to:

a. Renew its permits?

b. Comply with new or proposed regulations?

c. Comply with enforcement actions or corrective action requirements?

NOTE: These questions are intended to determine the viability of the facility and the potential its customers could assume CERCLA liabilities should this facility be forced to cease operations and initiate closure activities.

Reporting and Recordkeeping Requirements:

7. What environmental notification and/or monitoring reports is the facility required to submit (i.e..stormwater, hazardous waste, recycling, etc...)

NOTE: Review/Verify reports

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SECTION E

Financial Criteria Questions

QUESTIONS RESPONSE REFERENCES

8. Has the facility been included on the National Priorities List (NPL) or similar state specific listing? If so:

a. Is the listing relevant to management of the particular waste stream that will be treated or recycled; and

b. What mechanisms of resolution have been initiated to resolve the problem?

9. Is the facility currently subject to any RCRA Corrective Action Consent Order, any other compliance order for cleanup, or has a RFI been conducted?

NOTE: If so, contact the agency responsible for oversight.

10. Does the facility have a Post-Closure Plan and Post-Closure Plan cost estimate? If so:

a. What is the Post-Closure Plan cost estimate;

b. Is the estimate adequate; and

c. How is the Post-Closure Plan funded? (i.e. what company guarantees the funding)

NOTE: The above plans must be reviewed to determine whether they are adequate. Explain why or why not you believe the plan is adequate. This is important to ensure we, as a generator, do not assume CERCLA-type liabilities because the above funding was not adequate.

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Financial Criteria Questions

11. Is the facility a subsidiary or division of another corporation?

If so:

a. What is the name and address of the parent corporation;

b. Is it a subsidiary or division;

c. Is the parent corporation publicly or privately owned;

d. How long has the parent corporation owned the facility;

e. Does the parent company guarantee Closure and Post- Closure funding; and

f. If so, how is this funding guaranteed?

If not:

g. Is the company which owns the facility publicly or privately owned; and

h. How long has the company owned the facility?

c.

g.

h.

12. Provide the following information about the company which owns the facility or the parent corporation, if they guarantee Closure and Post-Closure funding:

a. Tangible Net Worth;

b. Total Assets;

c. Revenues for the past three years;

d. A three year history of operating profits;

e. A three year history of asset to debt ratio; and

f. The Dun & Bradstreet Paydex score for the facility.

c.

d.

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Financial Criteria Questions

QUESTIONS RESPONSE REFERENCES

13. Provide the following information about the company which owns the facility or the parent corporation, if they guarantee Closure and Post-Closure funding:

a. Tangible Net Worth;

b. Total Assets;

c. Revenues for the past three years;

d. A three year history of operating profits;

e. A three year history of asset to debt ratio; and

f. The Dun & Bradstreet Paydex score for the facility.

c.

d.

14. Does the facility have adequate insurance coverage for the following potential losses:

a. Worker's Compensation;

b. Employer's Liability;

c. Public Liability (Bodily Injury and Personal Disability);

d. Sudden and Non-sudden Accidental Occurrences; and

e. Excess Liability Umbrella Form.

If so, provide copy of certificate(s)

NOTE: Determine if c, d, and e coverages require full payback by the TSDF/RF if a claim is made. If so, ensure this does not jeopardize the TSDF's/RF’s viability.

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Financial Criteria Questions

QUESTIONS RESPONSE REFERENCES

15. Has the facility experienced any releases? (i.e…to Air, Water, Land?)

a. What substances were involved;

b. What response measures were taken;

c. How was the permit or response plan amended because of the release; and

d. To whom was the release reported?

NOTE: Contact the agency responsible for oversight.

16. What procedures/plans are in place to assure that the facility has adequate spill prevention and emergency response plans to minimize the potential for a significant release to the environment.

NOTE: Was there visual evidence of a release and a SPCC Plan certified by a PE?

17. If the TSDF/RF will be managing CERCLA waste, is the facility certified by the EPA to receive CERCLA waste?

NOTE: Verify or obtain documentation if your GOCO site intents to use this TSDF to manage DOE CERCLA waste.

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SECTION F

Recycling Process Material and Residues

QUESTIONS COMMENTS REFERENCES

18. What type(s) of recyclable material or item(s) does the facility accept? (i.e..scrap metal, batteries, electronics, tires, fluorescent lamps, mercury containing equipment, circuit boards, CRTs, etc…)

NOTE: Obtain a copy of the Waste Acceptance Criteria

19. What type(s) of recyclable material or item(s) does the facility NOT accept.

20. Does the facility utilize other locations to collect, receive, sort, consolidate, warehouse, or store materials prior to being processed or after processing?

If so, complete separate checklist for each location.

21. How is the recyclable material or item(s) managed prior to being recycled? (i.e..type of container, labeling, storage indoors/outdoors…)

22. What activities are performed to the recyclable material or item prior to being processed/recycled?

a. Tested (i.e., Direct reuse of tested working equipment & components)

b. Refurbished (i.e., Refurbishment and repair for reuse)

c. Demanufactured (i.e., Materials recovery for use in new products)

d. Shredded (i.e., mechanical size reduction and separation)

e. Disposal

*Please list individual component disposal routes for items that are being dismantled for recycling and reuse purposes (Any items not internally reused provide disposition path).

a.

b.

c.

23. Please provide a detailed description of the recycling facility’s operations (inputs/outputs) and identify all of the recyclable material (product) streams as well as waste material (non-product) streams generated from these operations (Use attachment and include a process flow diagram).

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24. What residual waste streams (e.g. process waste water, solid waste) are generated by the facility? Provide the following information for each:

a. A description of the waste stream

b. What RCRA waste codes apply

c. How each residual waste stream is managed, treated and disposed

d. Name of off-site facility used for each residual waste stream.

25. What practices/procedures are in place to assure that each residual waste stream generated by the facility is properly managed and when applicable, compliance with LDR treatment standards?

NOTE: Review the Waste Analysis Plan and LDR notifications and certifications completed by the facility for their residual wastes.

26. Does the facility utilize Downstream Processors, End Refurbishers, Intermediaries, End Processors, Brokers, and Final Disposal facilities?

If so, provide facility information.

27. Describe your process to review and audit downstream processors.

If so, provide a sample audit questionnaire.

28. Does the facility export materials?

If so, how facility document compliance with Organization for Economic Cooperation and Development (OECD), the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal or Basel Ban Amendment.

29. Does the facility maintain verifiable records of incoming and outgoing shipments or transfers of recyclable materials/ item(s) as well as waste disposal records? (i.e., shipping logs, invoices, bills of lading, acknowledgements of receipt from receiving facilities).

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QUESTIONS COMMENTS REFERENCES

BLANK FOR ADDITIONAL QUESTIONS

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Resource Conservation and Recovery Act (RCRA)

QUESTIONS RESPONSE REFERENCES

1. Does the facility have an EPA identification number

2. What type of hazardous waste(s) does the facility generate?

3. Does the facility have a container management program in place that ensures waste is stored in good condition, compatible with the waste container, and all containers are closed unless waste is being added or removed?

Do the waste storage areas require/have an adequate containment system?

4. What environmental permits does the facility have?

Examples include, but are not limited to: TSD Permit, Recycling Permit, etc…

5. Are RCRA-permitted units maintained in compliance with the permit, including labeling, aisle spacing, inspections, monitoring, leak detection, reporting and recordkeeping, emergency planning and preparedness, training, and financial assurance?

6. Has the facility had any releases from solid waste management units? If so, explain.

7. Does facility ship hazardous waste to a TSDFs? If so, does the facility have a documented program to ensure that the TSDF manage hazardous waste in compliance with appropriate RCRA regulations?

(If facility ships DOE wastes or byproduct of DOE waste treatment to another contractor then they are required to flow down the DOE QA requirements.)

8. What is the date of the most recent RCRA agency inspection and results?

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Air (CAA)

QUESTIONS RESPONSE REFERENCES

9. Is the facility a CAA Title V major source for criteria air pollutants?

10. Does the facility have air permits for required operations?

(Review facility operations and applicability to State air regulations. Review compliance with permit conditions.)

State Regulations

11. Recovery/Recycling (Freon? Recovery/Reclamation?)

12. Is the facility subject Risk Management Plan (RMP) requirements?

13. What system is used to monitor the facility’s applicability to RMP requirements?

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Clean Water Act Industrial Wastewater / NPDES

QUESTIONS RESPONSE REFERENCES

14. Does the facility have an NPDES permit?

Is the monitoring and reporting in compliance with permit conditions? (Note any exceedances and reasons over the last three years.)

15. Does the facility discharge to the sanitary sewer system?

If so, are there any reported discharge violations?

16. Does the facility have a current Storm water Runoff Permit and storm water pollution plan? (Verify plan has been implemented and is current.)