Waste Ban Compliance Training Program

1
Waste Ban Compliance Training Program

• Administrative Compliance Requirements
• April and May 2006

2
Compliance Activities

• Administrative Responsibilities
• Waste Ban Compliance Plan
• Record Keeping
• Notices/Letters
• Reporting
• Hands On Responsibilities
• On-Going Monitoring
• Comprehensive Inspections

3
Waste Ban Compliance Plan

• Document that Meets Specific Requirements
• DEP Guidance
• Responsibility -- Transfer / Handling and
  Disposal Facilities
• Submitted to DEP, Reviewed and Approved
• Includes
• On going Monitoring System
• Detection
• Record Keeping
• Comprehensive Load Inspections
• Frequency
• Load Selection Procedure
• Record Keeping

4
Waste Ban Compliance Plan

• Includes
• How Staff will be Trained
• Description of Signage
• On going Monitoring System
• Detection
• Record Keeping
• Comprehensive Load Inspections
• Frequency
• Load Selection Procedure
• Record Keeping

5
Waste Ban Compliance Plan -- Training

• How Staff will be Trained (Options)
• Who Must be Trained
• Training Options

6
Training Options

• Requirements of waste ban compliance plan be
  communicated to relevant staff
• Conduct annual waste ban training to staff
• Distribute / Make Available Waste Ban Compliance
  Plan to staff
• Discussion at regularly scheduled meetings
• Other

7
Training Content

• Waste Ban Requirements / Including Materials
• Ongoing Monitoring
• Communication
• Recordkeeping
• Role in Comprehensive Inspections

8
DEP Suggested Sign Language

• Massachusetts state regulation 310 CMR 19.017
  prohibits the disposal, or transfer for disposal,
  of the following materials
• Asphalt Pavement, Brick, and/or Concrete
• Cathode Ray Tubes
• Glass Containers
• Lead Batteries
• Leaves and yard waste
• Metal
• Metal Containers
• Recyclable Paper
• Single Polymer Plastics (Narrow-neck Plastic
  Containers)
• White Goods
• Whole Tires (at landfills only)
• Wood (at landfills only)
• (taken from Attachment F to DEP Guidance)

9
Example Signage
10
(No Transcript)
11
Sample Signage

• Meets Waste Ban Compliance Requirements
• Will be Updated by July 1, 2006 for Asphalt,
  Brick, Concrete, Wood Metal
• Signs may be Waste Ban Specific or may also
  include other Prohibited Materials such as
  Hazardous Waste, Universal Waste and Asbestos

12
Waste Ban Compliance Plan

• Requirement to Modify / Update
• Changes in Operations
• Changes in Compliance Approach
• Change in DEP Policy or Regulations
• Bag Opening after 9/11 example
• New Waste Ban Materials
• Asphalt, Brick, Concrete, Wood and Metal from
  Construction
• Other Changes

13
Failed Load Follow-up

• Inform Driver
• Verbal
• By Who?
• Letter to Commercial Hauler
• Letter to Municipal Collection
• Hauler to Generator follow-up (option)
• Third party haulers

14
Failed Load Follow-up- Hauler

• Key Elements of Letter
• Reference Specific Event
• Truck, Material, Source if Known
• Reference and Provide Copy of DEP Fact Sheet
• Suggest Notifying Generator
• Becoming More Important with DEP enforcement up
  the chain
• Potential Consequence of Not Accepting Future
  Loads with Recurring violations
• Potential Additional Fees

15
Failed Load Follow-up-- Municipality

• Key Elements of Letter
• Reference Specific Event
• Date, Time, Material
• Potential Additional Fees
• Potential Consequence Risk DARP Status
• Potential Consequence of Not Accepting Future
  Loads with Recurring Violations

16
Record Keeping -- Facilities

• Monitoring Log (Sample in Handout)
• Comprehensive Inspection Log
• Agency Inspection of Records

17
Elements of Monitoring Log

• Data on Load
• Scale Ticket , Hauler,
• Date, Time, Truck , Truck Type
• Community, Generator
• Material Causing Load to Fail
• How Load was Managed
• Separate Recycle, Reject and Reload
• Dispose or Transfer
• Reason for Disposal
• Date Failed Load Letter Sent

18
Notices / Letters

• Sample Document (from DEP Guidance)
• Sent in a Sensible, regular time frame,
  consistent with administrative approach
• Track that the Letters are sent
• Assess additional charges for failed Loads
  (optional)

19
Reporting

• Reporting to DEP as part of Annual Report
• Operator should commit to answer all questions
  relating to the waste ban compliance plan on the
  facilitys annual reporting form provided by
  MassDEP.
• (example follows)

20
2005 DEP Annual Report
21
Opportunities for Improvement

• In discussion session
• List Items that require discussion