Cross Media Inspections of Solid Waste Facilities

1
Cross Media Inspections of Solid Waste Facilities

• Jerry Henderson
• CDPHE Solid Waste and Material Management Unit

2
Compliance Inspection vs. Compliance Assistance

• Compliance inspections CRS 30-20-113 gives the
  Department inspection authority.
• Violations trigger enforcement process
• Depending on severity or recalcitrance,
  violations can lead to formal compliance order or
  litigation
• Compliance assistance site visit
• To provide you with help understanding the
  regulations
• To suggest steps for improved compliance

3
Solid Waste Inspections

• FY 2007 174 inspections performed
• Landfills, transfer stations, asbestos, tire
  monofills, remediation sites, composting
• Overall compliance rate 75
• Landfills, transfer stations gt 75
• Composters, impoundments /- 50

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Cross Media Compliance Inspections

• Air Pollution Control Division Solid Waste
• -Primarily Landfills to date
• Hazardous Waste Solid Waste
• -Complaint Driven
• Local Health Depts. / Code Enforcement Solid
  Waste
• -Complaints Solid Waste Facilities
• COGCC and Solid Waste Drilling mud / fluids

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Background on Cross Media Compliance Assistance
at CDPHE

• 2003 CDPHE created cross media compliance
  assistance workgroup
• Goals
• Improved customer service
• Improved efficiency
• Engage in sector-based projects to achieve
  outcomes greater than regulatory compliance
• -Auto Salvage Sector, Correctional Facilities

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Cross Media Compliance Assistance

• Air, Stormwater and Solid Waste (or Air Solid
  Waste)
• Onsite assistance provided to operators in
  understanding and implementing the regulations
• Work in cooperative mode to identify whats going
  well, what needs improvement
• Identify and correct problems outside of
  enforcement process

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Benefits to Compliance Assistance

• Efficiency
• Training
• Chance to self-correct deficiencies outside of
  the enforcement process
• More collaborative than compliance inspection
• Better prepared for compliance inspection

8
Challenges to Implementing the Cross Media
Approach

• Coordination of inspector schedules
• Longer site visit required, more resource burden
• Reluctance to share information, requires trust

9
Ideas for Overcoming Challenges

• Always announced
• Point out what facility is doing well
• Solution oriented
• Enforcement amnesty
• Approach from a partnering standpoint, 2-way
  dialogue
• Send out inspection checklist in advance
• Increase familiarity with quarterly outreach
  meetings

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Future Directions for Compliance Inspections /
Assistance

• Regional multi-media compliance assistance Find
  host sites and invite other operators in the
  surrounding area
• Self-certification Program Compliance assistance
  prepares operators for self-audit
• Sign up sheet