Waste Ban Compliance Training Program Administrative Compliance Requirements

Waste Ban Compliance Training Program Administrative Compliance Requirements April and May 2006

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

Waste Ban Compliance Plan n n 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

Waste Ban Compliance Plan n 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

Waste Ban Compliance Plan -Training n n n How Staff will be Trained (Options) Who Must be Trained Training Options

Training Options n n n 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

Training Content n n n Waste Ban Requirements / Including Materials Ongoing Monitoring Communication Recordkeeping Role in Comprehensive Inspections

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 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)

Example Signage

Sample Signage n n n 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

Waste Ban Compliance Plan n 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

Failed Load Follow-up n Inform Driver – Verbal – By Who? n n n Letter to Commercial Hauler Letter to Municipal Collection Hauler to Generator follow-up (option) – Third party haulers

Failed Load Follow-up- Hauler n 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

Failed Load Follow-up-Municipality n 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

Record Keeping -- Facilities n n n Monitoring Log (Sample in Handout) Comprehensive Inspection Log Agency Inspection of Records

Elements of Monitoring Log n Data on Load – Scale Ticket #, Hauler, – Date, Time, Truck #, Truck Type – Community, Generator n n 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

Notices / Letters n n 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)

Reporting n n n Reporting to DEP as part of Annual Report Operator should commit to answer all questions relating to the waste ban compliance plan on the facility’s annual reporting form provided by Mass. DEP. (example follows)

2005 DEP Annual Report

Opportunities for Improvement n n In discussion session List Items that require discussion