| Appendix F | Hazardous Waste Transporters |

Waste Management Facilities

Required Permits, etc.

Treatment, storage, or disposal facilities (TSDFs) should have:

1. An EPA/state identification number;
2. Authorization to treat hazardous waste (e.g. a RCRA permit, an interim status document (ISD), or a variance for non-RCRA waste management); and
3. Applicable local, regional, and state permits (e.g. HazMat permit, industrial waste discharge permit, air quality district permit, etc.

Safety, Equipment & Training

You will want to make sure that the facilities or transporters you choose operate under strict safety and training standards to minimize the potential for accidents or spills involving your waste. Look for services which offer financial indemnification for any costs related to the negligence or misconduct on the part of the service provider, its employees, or contractors.

Both transporters and TSDFs should have training programs which address:

1. Facility evacuation
2. Use and inspection of safety and emergency equipment
3. Emergency response procedures and contingency plan follow-through
4. Container labelling and vehicle placarding
5. Regular facility/vehicle maintenance checks

Contingency plans should designate equipment and trained personnel for emergency/spill response.

TSDF operation plans should address all aspects of facility operations, including equipment maintenance and provisions for security (e.g. fencing and adequate warning signs).

All hazardous materials/waste handlers are required to have on-the-job and formal training that includes (1) general training for recognition and identification of hazardous materials, (2) function/job-specific training, and (3) safety training (emergency response and accident/exposure prevention). These training requirements maybe met by a one-time 40-hour Hazardous Waste and operations training course and 8-hour annual refresher courses.

Training records or copies of employee training certificates can verify fulfillment of training requirements. Training record information is also available in inspection reports (see below).

Liability Insurance

To minimize your liability, be sure the services you select meet or exceed minimum liability requirements (a copy of the Certificate of Insurance will show the amount of insurance coverage held by the company).

TSDFs currently permitted with DTSC and US EPA are required to maintain liability coverage for sudden and accidental occurrences of at least $1 million per occurrence and annual aggregate of at least $2 million, exclusive of legal defense costs.

TSDFs that contain surface impoundments, landfills, and land treatment units must also have coverage for non-sudden accidental occurrences of at least $3 million per occurrence, with an annual aggregate of $6 million, exclusive of legal defense costs.

Inspection Records

Many of the criteria described above can be checked using available inspection reports:

TSDFs are inspected annually by DTSC in their compliance evaluation inspection (CEI). The CEI evaluates the following aspects of a facility:

1. Containers (including labelling requirements), tanks, and containment areas;
2. Pipes, valves, and pumps;
3. Emergency equipment such as self-contained breathing apparatus (SCBA) units, fire extinguishers, showers, and eye ash facilities;
4. Emergency lights, gates, and fences;
5. Personal protection equipment; and
6. Operation records, including training plans, contingency plans, closure plans, inspection plans, biennial reports, and compliance with financial and land disposal restriction (LDR) requirements.

To obtain general site information and violation history on a TSDF, call DTSC at (510) 540-3954 and ask the duty of firer for the inspector of that facility. Ask the inspector about the TSDF's operating record and current regulatory status, when the last inspection was conducted, whether the facility is under any consent orders to correct past deficiencies, whether the facility is a state or federal superfund site or under other cleanup orders, whether the company is working to remedy any violations or contamination, and any other pertinent information.

For out-of-state facilities, you will need to contact the regulatory agency in the state in which the facility is located (DTSC should be able to direct you).

References

Transporters and TSDFs should be able to provide you with a list of customers in your geographic area who generate a similar wastestream(s). Call some and ask about the length of service, satisfaction with service, company reliability, safety practices, whether there have been any spills, emergency incidents, or other mishaps, and any other information pertinent to your circumstances.

Disposal Options

Know where your waste is going, how:it is being managed, and the final disposition of any residues, ash, or empty containers. Ask how "off-spec" waste shipments will be handled.

Contact more than one potential TSDF to get an idea of your options. Choose a service which will assist you to select the most cost-effective and environmentally sound disposal option.

Choose options which minimize potential future liability. Whenever possible, have your hazard- ous wastes recycled, reclaimed, or treated, in that order of priority.

Compliance Assistance

It is important that your service provider keep up-to-date withhazardous waste transportation/disposal requirements and regulations. Larger firms may have full-time environmental staff, but even small companies can subscribe to publications, attend workshops, or contract for part-time consulting services. Ask companies how they keep abreast of new requirements and choose one which is informed.

Some companies provide customers with private consultations, classes on proper labelling and manifesting, and/or newsletters highlighting new developments and regulations. Look for companies that will assist you in sampling, profiling, manifest preparation, and waste sample shipment, as well as provide you with the 24-hour emergency phone number required for your hazardous waste shipments.

Cost

Ask the sales staff about minimum charges and options for reducing costs which may not be obvious (e.g. pick-up as needed vs. regularly scheduled pick-up).

TSDFs must have a "profile" identifying a wastestream's characteristics before accepting it. This usually involves sampling and chemical analysis. Most TSDFs provide profiling services, but some may require or allow outside chemical analysis. Profiling fees range widely from being part of the service contract, to $50, to $350 or more in private labs. Shop around for reasonable rates. Disposal fees will vary depending on the type of waste and type of recycling/treatment/disposal. Choose the option which will minimize current and future costs.

Site Visit

If possible, make a site visit before contracting for services. Look for:

• A clean and orderly site and well-maintained equipment/vehicles
• Clear hazard signs and safety warnings
• Properly contained and organized hazardous waste storage areas (no large backlog or stockpiling of empty containers, etc.)
• Adequate supervision of operations
• Appropriate employee safety precautions
• Easy access to safety and emergency response equipment and MSDSs
• Control points and spill containment possibilities
• Adequate security provisions (e.g. fences, locks, alarms, warning signs, etc.)
• Organized record keeping system (how do they track manifests, how often do they inspect the facility, etc.)

Most transporters working with specific TSDFs audit them periodically to ensure xninimum standards are met. If you cannot visit the site yourself, you can use one of these transporter services, a consulting service which evaluates TSDFs, customer referrals, and/or inspection reports.

Additional Information

Appendix E and the Vendor Directory can assist you in locating hazardous waste management service providers. A larger listing of commercial recyclers servicing California is also provided in the Directory of Industrial Recyclers and Listing of Hazardous Wastes Available for Recycling published by the California Waste Exchange of DTSC. Call (916) 322-3670 to request a free copy.