chwmeg, inc. 2012 facility review program …€¦ · n warsaw financial centre - 11th floor ......

CHWMEG, Inc. www.chwmeg.org

Worldwide Headquarters n 470 William Pitt Way n Pittsburgh, PA 15238 USA Tel: +1 (412) 826-3055 n Fax: +1 (586) 461-1856 n [email protected]

Asia-Pacific Support n Singapore Land Tower 37th Floor, 50 Raffles Place n Singapore 048623 Tel: +65 9237 8445 n Fax: +65 6829 7070 n [email protected]

Europe Support n Warsaw Financial Centre - 11th Floor Emilii Plater 53 n 00-113 Warsaw Poland Tel: +48 60 733 9012 n Fax: +48 22 528 6701 n [email protected]

Confidential December 19, 2011

CHWMEG®

Globally Promoting ResponsibleWaste Stewardship

CHWMEG, INC. 2012 FACILITY REVIEW PROGRAM PRE-BID WEBINAR December 19, 2011

Agenda

Opening/Welcome/Introductions Overview of CHWMEG Organization – http://www.chwmeg.org Overview of Typical CHWMEG Facility Review Program Milestones Review Details Concerning Questionnaires/Tailored Questionnaires Review Risk Assessment System (RAS) Details Review Project Management Details Review Facility Feedback from 2011 Facility Review Program - Pending Guidance Questions and Answers

***** ***** *****

1. CHWMEG Background 2. Pre-Bid Meeting / Bid Form Review 3. Bids Reviewed by Board of Directors & Award Decision Made 4. CHWMEG Telephonically Notifies Facility Review Firm of CHWMEG Decision 5. CHWMEG Sends Notification Letters to Facilities Introducing Selected Facility Review Firm 6. CHWMEG Conveys Written Notification and Contract Exhibit A to Facility Review Firm

a. Final Questionnaire Template b. Executive Summary Template c. Tailored Questionnaires (as appropriate) d. Final RAS file template (Excel) e. Copies of Introductory Letters Conveyed to Facilities f. Progress Table (Excel) by Awarded Bundle g. PDF Excerpts of Previous CHWMEG Facility Review Report (as appropriate)

7. Facility Review Firm Contacts Facility to Coordinate

a. Conveys Questionnaire/Tailored Questionnaire (Via Email) b. Schedules Site Visit c. If Facility Balks or Delays, Facility Review Firm Contacts CHWMEG Administrator with

Facility POC Info – Members Contact Facility to Obtain Support d. Three Way Confidentiality Agreements (e.g., WMI, Clean Harbors, Allied Waste, Safety-Kleen)


8. Facility Review Firm Contacts Regulatory Agencies to Gather Required Info 9. Questionnaire and Executive Summary Details

a. Always Use Correct Questionnaire / Executive Summary b. Executive Summary Template c. About the Watermark and How to View/Complete Questionnaire d. Word Form Capabilities and Drawbacks (Search, Spelling, Editing) e. Layout of Individual Sections f. Layout of Section C Modules g. Three Types of Questions h. Facility Response Boxes vs. Facility Review Firm Comment Boxes i. Adding Clarifying Facility Review Firm Comments to Facility Response Boxes j. Modifying Facility Comments When Response is Blank or Wrong k. Blank Responses: Check Boxes, Text Fields, and Drop-Down Boxes

(1) Incorrect Responses: Check Boxes and Drop-Down Boxes (2) Incorrect Responses: Text Fields

l. Facility Review Firm Comments Cannot Be Blank m. Applicable Facility Comments Cannot Be Blank n. When Facility Does Not Complete Any of the Questionnaire o. Questions A37 and A38 p. Tables Which Must Be Completed in the Questionnaire (A12, A34, B2a, D2a, H1a, J1) q. Long Tables that Can Be Included as Attachments (A27, C25, C26f, etc.)

10. Tailored Questionnaire Details

a. All of the Above Apply b. Facility Review Firm Must Verify Previous Information (Questionnaire Can Be Up to 10 Years Old) c. We Can Tell if the Information Hasn’t Been Changed at All

11. RAS Details

a. RAS File Works in MS Excel Versions - any b. RAS Worked on Exclusively by Facility Review Firm Representative; Never Shared or Conveyed

to Anyone Other than CHWMEG c. Always Start with the File Named “RAS2012.xls” Then Save as a New File Name d. Entering Facility Information e. RAS Modules

(1) Numbered Sections (2) Potential vs. Observed

f. Navigation g. Answering Questions (Use Worst Case Scenario) h. Supplemental Information Handout i. Confidence Factors j. Questions with Numeric Answers k. Questions with “Helpful Hints” l. Fixing Errors m. Financial Information Input n. Final Question in RAS o. Reviewing Responses p. Help File

12. Facility Review Firm Project Manager Reviews Report for Internal QA/QC, Format, Consistency with CHWMEG Direction


13. Facility Review Firm Conveys Draft Report to Reviewed Facility (and Corporate, if applicable) for Review & Comment

a. Executive Summary, Questionnaire, Photos, and List of Attachments Conveyed as Secured PDF via Email Attachment

b. If Email Not Available, Executive Summary, Questionnaire, Photos, and List of Attachments Sent Via Guaranteed Overnight Delivery as Hardcopy Printout

c. CHWMEG Recommended Transmittal Language template

(1) Facility to Provide Comments Within 10 Business Days (2) Facility to Return or Destroy All Electronic and/or Hardcopy Materials

d. Contact Facility to Solicit Facility Response if Delay is Apparent e. Concurrence Assumed If Facility Fails to Respond

14. Facility Review Firm Addresses Facility Comments (Becomes Attachment A of CHWMEG Report) 15. Review of Attachments Template

a. Handling “Empty” Attachments b. Attachment C: Photographs and Contingencies c. Handling Items for Attachment H for Enclosing Existing Information d. Attachment Titles e. Handling Permit Excerpts f. All Attachment Items Submitted Single-Sided and Unbound in Letter Size Only or in PDF Format g. Attachments Conveyed as Hardcopy Via Guaranteed Overnight Delivery (We Recommend You

Keep a Copy) 16. Facility Review Firm Compiles and Conveys Draft Final Report to CHWMEG for QA/QC Review and Comment

The Executive Summary, Questionnaire, Attachment Sheets will be MS Word Documents (any version), the Photos file will be a PDF file, and the RAS will be an Excel file. These Five Files are Conveyed to CHWMEG, Inc. Via a Single Email as a Zip Attachment. (We Recommend You Keep the Word Version of the Photos)

17. CHWMEG QA/QC Comments Conveyed to Facility Review Firm Project Manager Via Email Within 9 Business Days (Average) 18. Facility Review Firm Returns Final Final Report to CHWMEG Administrator

a. Final Executive Summary and Questionnaire Word Versions Via Single Email as a Zip

Attachment b. If Necessary, RAS and Attachment Covers Via Single Email as a Zip Attachment c. If Necessary, Additional Hardcopy Attachment(s) Via Guaranteed Overnight Delivery

19. Project Manager Expectations

a. Coordination of Issues, Templates, Comments Received from CHWMEG, etc. Within Firm b. Complete QA/QC of Reports Conducted by Firm Prior to Conveyance of Draft Report to

Reviewed Facility c. Report Progress Monthly Before 25th of Each Month Using Excel Table

20. CHWMEG Pays Monthly Based Upon Progress As Per Progress Report 21. Facility Feedback from 2011 - Pending


Worldwide Headquarters 470 William Pitt Way Pittsburgh, PA 15238 USA Tel: +1 (412) 826-3055 Fax: +1 (586) 461-1856 [email protected]

Asia-Pacific Support Singapore Land Tower 37th Floor, 50 Raffles Place Singapore 048623 Tel: +65 9237 8445 Fax: +65 6829 7070 [email protected]

Europe Support Warsaw Financial Centre - 11th Floor Emilii Plater 53 00-113 Warsaw Poland Tel: +48 60 733 9012 Fax: +48 22 528 6701 [email protected]

MEMBER COMPANIES

For Limited Dissemination Page 1 of 4 as of: 12/12/11

CHWMEG®


AB Volvo Abbott Laboratories Ascend Performance Materials, LLC Advanced Micro Devices, Inc. Air Products and Chemicals, Inc. Albemarle Corporation Alcatel-Lucent USA Inc. Allergan, Inc. Altria Client Services Inc. Alyeska Pipeline Service Company America Online, Inc. Amgen Inc. AMR Corporation Anadarko Petroleum Corporation Applied Materials Arkema Inc. AstraZeneca Pharmaceuticals, LP AT&T Services, Inc. Avaya Inc. BAE Systems, Inc. Baxter International, Inc. Bayer Corporation BBA Aviation plc Becton Dickinson and Company BHP Copper Pinto Valley Operations Boehringer Ingelheim USA Corporation The Boeing Company BP America Brewer Science Inc. Bristol-Myers Squibb Company Buckeye Partners, L.P. The California State University Calumet Superior, LLC Cambrex Corporation Carestream Health, Inc. CenterPoint Energy, Inc. Central Hudson Gas and Electric Corporation Chevron Phillips Chemical Company LP Chevron Corporation Chrysler LLC CITGO Petroleum Corporation CNA Holdings, Inc. Commercial Metals Company Communications & Power Industries, Inc. ConAgra Foods, Inc. ConocoPhillips Constellation Energy Group, Inc. ConvaTec Inc. Cooper U.S., Inc. Cooper Tire & Rubber Company Corning Inc. Cytec Industries Inc. Deere & Company Delta Air Lines, Inc. Dixie Chemical Company, Inc. The Dow Chemical Company Dow Corning Corporation Dow Jones & Company, Inc. DSM Holding Company USA, Inc. Duke Energy Corporation Dynegy, Inc. E.I. DuPont De Nemours and Company Eastman Chemical Company Edison Mission Energy

Edwards Group Ltd. Eisai, Inc. El Paso Corporation Elan Corporation plc Eli Lilly & Company Energen Entergy Corporation ERGON, INC. Estee Lauder Companies, Inc. Eveready Battery Company, Inc. Exelis, Inc. Exelon Corporation ExxonMobil F. Hoffmann-La Roche Ltd. Fenwal, Inc. FMC Corporation Freeport McMoRan Copper & Gold, Inc. Freescale Semiconductor Inc. FUJIFILM Holdings America Corporation Galata Chemicals, LLC General Dynamics, Inc. General Electric GenOn Energy, Inc. Georgia Gulf Corporation GlaxoSmithKline plc GLOBALFOUNDRIES U.S., Inc. Goodrich Corporation GrafTech International Ltd. Harris Corporation Harvard University Henkel of America Hess Corporation Hewlett-Packard Company Hitachi Global Storage Technologies, Inc. Honeywell International HOVENSA LLC Human Genome Sciences, Inc. Huntington Ingalls Industries, Inc. Huntsman International LLC I.P.R. Pharmaceuticals, Inc. Imation Corporation Infineum USA L.P. Ingersoll-Rand Company Limited Innophos, Inc. Intel Corporation International Business Machines (IBM) Corporation International Rectifier Corporation International Specialty Products Inc. ITT Corporation JHP Pharmaceuticals, LLC Johns Manville Johnson & Johnson Kaiser Permanente Kiewit Corporation Koch Industries Inc. KRATON Polymers U.S. LLC Lawrence Livermore National Security Lenovo Group LTD Levi Strauss & Co. Lexmark International, Inc. Lockheed Martin Corporation Lonza America, Inc. L’Oreal USA, Inc. LSI Corporation

MEMBER COMPANIES (Continued)


LyondellBasell Industries Marathon Oil Corporation Marathon Petroleum Corporation Martek Biosciences Corporation Masco Corporation Mead Johnson Nutrition MeadWestvaco Corporation Medco Health Solutions, Inc. Media General, Inc. MedImmune, LLC Medtronic, Inc. Merck & Co., Inc. Micron Technology, Inc. Miller Coors, LLC Millipore Corporation Monsanto Company Moog, Inc. Murphy Oil Corporation National Semiconductor Corporation NBCUniversal Media LLC Nektar Therapeutics, Inc. Nexen Petroleum U.S.A. Inc. NextEra Energy, Inc. Nike, Inc. Northern Natural Gas Company Northrop Grumman Systems Corporation Northstar Aerospace (Canada) Inc. Novartis Corporation NRG Energy Inc. Occidental Petroleum Company Omaha Public Power District OXEA Corporation Pacific States Cast Iron Pipe Company Panasonic Corporation of North America PBF Energy Company LLC Pepco Holdings, Inc. Permian Mud Service, Inc. Pfizer Inc. PG&E Corporation Pinnacle West Capital Corporation Pitney Bowes Inc. Pittsburgh Glass Works, LLC PPG Industries, Inc. PPL Corporation The Procter & Gamble Company R.T. Vanderbilt Co., Inc. Raytheon Company Rechargeable Battery Recycling Corporation Reynolds American Inc. Rhodia Inc. Rockwell Collins, Inc. SABIC Innovative Plastics Holding BV Salt River Project Sanofi-Aventis U.S. Inc. Sanofi Pasteur Inc. SCANA Corporation Schlumberger Technology Corporation The Scotts Company, LLC

Seagate Technology LLC Sempra Energy Shell Global Solutions (US) Inc. The Sherwin-Williams Company Sigma-Aldrich Corporation Solutia Inc. Solvay America, Inc. Southern California Edison Southern Star Central Gas Pipeline, Inc. Southwest Research Institute Spectra Energy Corp. Stanford University Stanley Black & Decker, Inc. Sunoco, Inc. Syngenta AG Talisman Energy, Inc. Taminco, Inc. Tampa Electric Company Teradyne Inc. Tesoro Corporation Teva Pharmaceutical Industries Ltd. Texas Instruments Incorporated Texas Petrochemicals, Inc. Transform Manufacturing, LLC Tribune Company TriQuint Semiconductor, Inc. TOTAL Petrochemicals USA, Inc. TransMontaigne Product Services Inc. TRW Automotive, Inc. Tyco Healthcare Group LP Tyco International Holding S.a.r.l. U.S. Borax Inc. Union Pacific Railroad Company, Inc. United Technologies Corporation University of California University of Minnesota University of Pennsylvania University of Southern California University of Texas System Valero Refining & Marketing Company Verizon Services Group (Telesector Resources Group) Verizon Wireless Vishay Siliconix Voltaix, LLC W.R. Grace & Co. – Conn. Wal-Mart Stores, Inc. Watson Pharmaceuticals, Inc. Western Refining Southwest, Inc. Westinghouse Electric Company LLC Westlake Chemical Corporation WICOR Americas Inc. Wisconsin Energy Corporation Xcel Energy Services Inc. Xerox Corporation

CHWMEG, INC. 2011-2012 BOARD OF DIRECTORS

Name Board Position Company Telephone Philip Shinn Chair Eli Lilly & Company (317) 276-8989 Jeb Wallace Vice Chair Exelis, Inc. (540) 561-0371 Tim Greenway Treasurer The Scotts Company LLC (937) 578-5725 Duane Moss Secretary SCANA Corporation (803) 217-7324 Justin Vick At-Large Pepco Holdings, Inc. (202) 872-3430 Jackie McHugh At-Large San Diego Gas & Electric Company (858) 654-1771 Mike Cakouros At-Large Human Genome Sciences, Inc. (240) 372-8487 Beth Troxler At-Large Shell Global Solutions (US) Inc. (281) 544-7693

MEMBER COMPANY AFFILIATES (wholly-owned subsidiaries or joint ventures of the member enterprise having access to CHWMEG information and bound to confidentiality provisions)


Abbott Bioresearch Center, Inc. Abbott Diabetes Care Sales Corporation Abbott Diabetes Care, Inc. Abbott Equity Investments LLC Abbott Exchange, Inc. Abbott Healthcare Products, Inc. Abbott International LLC Abbott Laboratories International Co. Abbott Laboratories, Inc. Abbott Molecular Inc. Abbott Pharmaceutical Corporation Abbott Point of Care Inc. Abbott Spine Inc. Abbott Vascular Inc. Advanced Cardiovascular Systems, Inc. Aeropharm Technology, LLC Alabama Gas Corporation Alcon Laboratories, Inc. American Airlines, Inc. Amgen Manufacturing Limited AMR Eagle Holding Corporation Applied Materials Chamber

Performance Services APS Arco Environmental Remediation, L.L.C. Armor Holdings, Inc. Arthur Kill Power LLC Aristech Chemical Corporation AstraZeneca Limited Partnership Atlantic Richfield Company Aventis Pharmaceuticals Inc. BAE Network Solutions BAE Systems Controls Inc. BAE Systems Inc. BAE Systems Information and

Electronics Integration, Inc. BAE Systems Land & Armaments Inc. BAE Systems Norfolk Ship Repair BAE Systems San Diego Ship Repair

Inc. Baltimore Gas and Electric Company Barr Laboratories, Inc. Barr Laboratories Canada, Inc. Barr Pharmaceuticals, LLC Basell USA, Inc. Bayer CropScience LP Bayer HealthCare LLC Bayer MaterialScience LLC Bayer Pharmaceuticals Corporation Ben Venue Laboratories, Inc. Boehringer Ingelheim Chemicals, Inc. Boehringer Ingelheim Freemont, Inc. Boehringer Ingelheim Pharmaceuticals,

Inc. Boehringer Ingelheim Vetmedica, Inc. Boeing Australia Boeing Satellite Systems, Inc. BP America Production Company BP Amoco Chemical Company BP Company North America Inc. BP Corporation North America Inc. BP Exploration & Production Inc. BP Pipelines (North America) Inc. BP Products North America Inc. BP West Coast Products LLC Bristol-Myers Squibb Medical Imaging Buckeye Pipe Line Co., LP Buckskin Mining Company California Community News California Polytechnic State University,

San Luis Obispo California State Polytechnic University,

Pomona

California State University, Channel Islands

California State University, Chico California State University, East Bay California State University, Fullerton California State University, Long Beach California State University, Northridge California State University, Sacramento California State University, San Marcos California State University, Stanislaus Cambrex Charles City, Inc. Cameco Industries Capsugel Div. of Pfizer Carrier Corporation Catlettsburg Refining LLC Celanese Acetate LLC Celanese Chemicals, Inc. Celanese, Ltd. Champion Technologies, Inc. Chevron Environmental Management Company

Chevron Global Downstream LLC Chevron Oronite Company LLC Chevron Oronite Technology B.V. Chevron Philippines Inc. Chevron Pipe Line Company Chevron Shipping Company LLC Chevron South Africa (Pty) Limited Chevron U.S.A. Inc. Climax Molybdenum Company – Climax Mine

Climax Molybdenum Company – Fort Madison, IA

Climax Molybdenum Company – Henderson Mine and Mill

Climax Technology Center Club Car, Inc. Commonwealth Edison Company Connecticut Jet Power LLC Constellation Generation Group, LLC Continental Maritime of San Diego Conwood Company, LLC Cooper Lighting, Inc. Deerfield Urethane Inc. Depuy Orthopaedics, Inc. DSM Chemicals North America DSM Desotech DSM Dyneema LLC DSM Engineering Plastics, Inc. DSM NeoResins, Inc. DSM Nutritional Products, Inc. DSM Pharmaceuticals, Inc. DSM Resins, U.S., Inc. Dynegy Generation Dynegy Midwest Generation, Inc. Dynegy Northeast Generation, Inc. Duke Energy Generation Services Edo Corporation Edo Western Corp. Edwards Vacuum, Inc. Elan Drug Delivery, Inc. Elan Holdings, Inc. Elan Management Limited Elan Pharma International Limited Elan Pharmaceuticals, Inc. Entergy Arkansas, Inc. Entergy Gulf States, Inc. Entergy Louisiana, Inc. Entergy Mississippi, Inc. Entergy New Orleans, Inc. Entergy Nuclear Operations, Inc. Entergy Operations, Inc. Entergy Services, Inc.

Equistar Chemicals, LP Esso Belgium, division of ExxonMobil Petroleum and Chemical, BVBA

Ethicon, Inc. Exelon Generation Company ExxonMobil Environmental Services Company

ExxonMobil Pipeline Company F. Hoffmann-La Roche Inc. Flint Hills Resources, L.P. Florida Power & Light Company Freeport-McMoRan Bagdad, Inc. Freeport-McMoRan Chino Mines Company

Freeport-McMoRan Cobre Mining Company

Freeport-McMoRan Copper Products Freeport-McMoRan Corp. Copper Queen Branch

Freeport-McMoRan Corporation, Ajo Improvement Company

Freeport-McMoRan Corporation, Ajo Operations

Freeport-McMoRan Corporation, United Verde Branch

Freeport-McMoRan Morenci, Inc. Freeport-McMoRan Safford, Inc. Freeport-McMoRan Safford Process Technology

Freeport-McMoRan Sierrita Inc. Freeport-McMoRan Specialty Copper Products

Freeport-McMoRan Tyrone Mining, LLC Freescale Semiconductor (China) Ltd. Freescale Semiconducteurs France Freescale Semiconductor Japan Limited Freescale Semiconductor Malaysia Sdn.

Bhd. Freescale Semiconductor UK Limited FUJIFILM Dimatix, Inc. FUJIFILM Electronic Materials U.S.A., Inc.

FUJIFILM Hunt Chemicals U.S.A., Inc. FUJIFILM Imaging Colorants, Inc. FUJIFILM USA, Inc. Funk Manufacturing Gallup Refinery GB Biosciences Corporation GE Infrastructure, Waste & Process

Technologies General Construction General Dynamics, C4 Systems General Dynamics, Land Systems Georgia Monomers Company Georgia Gulf Chemicals & Vinyls, LLC Georgia Pacific The Gillette Company GlaxoSmithKline Inc. GlaxoSmithKline, LLC Glenn Springs Holdings, Inc. GPSG North America, a Unit of Alza

Corporation Graftech International Holdings Inc. Graftech Mexico S.A. de C.V. Graftech USA LLC Guidant Endovascular Solutions, Inc. Humboldt State University Hussmann Corporation Houston Refining, LP IEP Pharmaceutical Devices, LLC IM Flash Technologies, LLC Imation Enterprises Corp. Imclone Systems Corporation Immunex Rhode Island Corporation

MEMBER COMPANY AFFILIATES (Continued)


Ingalls Shipbuilding Ingersoll-Rand Company INVISTA Management (Shanghai)

Company Limited INVISTA Resins & Fibers GmbH INVISTA, s.a.r.l. INVISTA (Singapore) Pte. Ltd. INVISTA Textiles Germany GmbH INVISTA Textiles (UK) ITT Space Systems IVAX Corporation IVAX Pharmaceuticals Canada, Inc. IVAX Pharmaceuticals, Inc. Kerr-McGee Oil & Gas Onshore LP Kiewit Constructors Inc. Kiewit Infrastructure Co. Kiewit Infrastructure South Co. Kiewit Infrastructure West Co. Kiewit Power Constructors Co. Kiewit Texas Construction LP Kiewit Western Co. Kinetics Knoll Pharmaceutical Company Koch Business Solutions, LP Koch Carbon, Inc. Koch Chemical Technology Group Koch Exploration Koch Fertilizer, LLC Koch Mineral Services, LLC Koch Nitrogen Company Koch Pipeline Company, L.P. Koch Supply & Trading Koch Supply Company, LP Kos Life Sciences, Inc. Kos Pharmaceuticals, Inc. Kwikset Corporation Lane Limited Lawrence Berkeley National Laboratory Lilly de Caribe, Inc. Lonza Biologics Lonza Hopkinton, Inc. Lonza Rockland, Inc. Lonza Walkersville, Inc. Lonza, Inc. - Mapleton Lonza, Inc. - Riverside Lonza, Inc. - Williamsport Los Angeles Times Communications

LLC Louisiana Generating LLC Lyondell Chemical Company Lyondell Chime Nederland, B.V. Mack Trucks, Inc. Marathon Petroleum Company Marathon Pipe Line LLC Masco Retail Cabinet Group, LLC Mass. Electric Construction Co. Mead Johnson Nutritionals Merck Frosst Canada & Co. Merck, Sharp & Dohme (Ireland) Ltd. McNeil Consumer Healthcare McNeil PPC, Inc. Middletown Power, LLC Millennium Petrochemicals Inc. Millennium Specialty Chemicals Inc. Mobil Oil Australia Pty Ltd. Montville Power LLC Moog Components Group, Blacksburg

Operations Moog Inc. Aircraft Group East Aurora Moog Medical Devices Group

Operations

Moog Industrial Group Moog Torrance Operations Moog, Inc. SDG East Aurora Murphy Exploration & Production Murphy Oil USA, Inc. Natural Supplement Association, Incorporated

Newport News Shipbuilding Noramco of DE, Inc. Northrop Grumman Aerospace Systems Sector

Northrop Grumman Electronic Systems Sector

Norwalk Power LLC Novartis Animal Health US, Inc. Novartis Institutes for BioMedical

Research Novartis Over-the-Counter Novartis Pharmaceuticals Corp. Novartis Vaccines and Diagnostics NRG El Segundo Operations, Inc. NRG Energy Center Minneapolis LLC NRG Energy Center San Diego LLC NRG Texas LP NRG Thermal LLC Occidental Chemical Corporation Occidental Oil & Gas Corporation Ortho-Clinical Diagnostics Oswego Harbor Power LLC Pacific Gas & Electric Company Peoples Gas Peter Kiewit Infrastructure Co. Pfizer Pharmaceuticals LLC Phelps Dodge Refining Corporation Pinnacle West Energy Plantex USA, Inc. PPG Coatings (Tianjin) Co. Ltd. PPG Industrial do Brasil Tintas e

Vernizes Ltda. PPG Industries UK Ltd. PPL Electric Utilities PPL Services Corporation Pratt & Whitney The Procter & Gamble Distributing LLC The Procter & Gamble U.S. Business

Services Company Raytheon Technical Services Company

LLC Regen Technologies Reiss Remediation Inc. Remedium Group, Inc. Rio Tinto Minerals, Inc. RJ Reynolds Tobacco Company Roxane Laboratories, Inc. SABIC Innovative Plastics BV SABIC Innovative Plastics Management

(Shanghai) Co. Ltd. SABIC Innovative Plastics US LLC San Diego Gas & Electric Company San Diego State University San Francisco State University San Jose State University Sandoz Sanofi-Synthelabo Research Santa Fe Natural Tobacco Co., Inc. Schlage Lock Company Seadrift Coke LP Seagate US, LLC Sempra Pipelines & Storage Sheffield Plastics Inc. Sicor, Inc. Sikorsky Aircraft Corporation

Sirtris Pharmaceuticals, Inc. Solvay Advanced Polymers, LLC Solvay Chemicals, Inc. Somerset Power LLC Sonoma State University Southern California Gas Company Spectra Energy Transmission, LLC Speedway LLC Standard Oil Company Inc. Stiefel, a GlaxoSmithKline company Sun Pipeline Company Sunoco, Inc. (R&M) Syngenta Agro S.A. (Spain) Syngenta Asia Pacific Pte. Ltd. Syngenta Crop Protection AG Syngenta Crop Protection, LLC Syngenta Crop Protection Monthey SA Syngenta International AG Syngenta Protecao de Cultivos Ltda. Syngenta S.A. (Panama) Talisman Energy USA, Inc. Tennessee Gas Pipeline Company Tesoro Alaska Company Tesoro Hawaii Corporation Tesoro Petroleum Companies, Inc. Tesoro Refining and Marketing

Company Teva Animal Health, Inc. Teva Biopharmaceuticals USA, Inc. Teva Canada Innovation G.P. - S.E.N.C. Teva Canada Limited/Teva Canada

Limitee Teva Global Respiratory Research, LLC Teva Neuroscience, Inc. Teva Parenteral Medicines, Inc. Teva Pharmaceuticals USA, Inc. Teva Respiratory, LLC Teva Women’s Health, Inc. Teva Women’s Health Research, Inc. Tevapharm Canada Inc. Thermo King Corporation TIC - The Industrial Company Ticona Polymers, Inc. Toledo Refining Company LLC Trane US Inc. TriQuint Semiconductor Florida TRW Automotive U.S. LLC TRW Vehicle Safety Systems Inc. Tyco International Management

Company University of California, Berkeley University of California, Davis University of California, Irvine University of California, Los Angeles University of California, Merced University of California, Riverside University of California, San Diego University of California, San Francisco University of California, Santa Barbara University of California, Santa Cruz Volvo Trucks North America Von Duprin LLC Watson Laboratories, Inc. Weidmann Electrical Technology Inc. West Coast Power LLC Western Gas Resources, Inc. Western Gas Resources-Texas, Inc. Westlake Longview Corporation Wisconsin Electric Power Company ZonePerfect Nutrition Company





CHWMEG®


CHWMEG, Inc. Overview CHWMEG, Inc. (CHWMEG) is a non-profit trade association consisting of manufacturing and similar companies, individual government installations, and educational/research institutions. Membership as of December 2011 is comprised of 240 enterprises comprising over 650 world-class companies through inclusion of participating subsidiaries. CHWMEG’s objective is to assist its members and industrial companies in general with their efforts in managing corporate stewardship and risk management systems related to their manufactured wastes. The scope of the activities includes transportation, treatment, disposal, storage, recycling, and reclamation of waste streams manufactured by industrial activities. CHWMEG members are keenly aware of the environmental aspects of the wastes that inherently result from their operations, and focus primarily on the elimination, minimization, and recycling/reuse of these wastes. However, because complete elimination of waste generation can rarely be accomplished, the proper management of these wastes must be ensured. CHMWEG members evaluate these external business risks to support their generator-borne cost-avoidance and environmental product stewardship programs. CHWMEG accomplishes its goals by conducting no-cost, high value informational meetings; developing and maintaining the proprietary CHWMEG protocol; and through implementing its third-party facility review program. Meetings often include presentations on managing external environmental risk control programs and review of evolving regulatory requirements directly impacting manufacturing concerns or indirectly impacting manufacturers via requirements affecting recycling and waste processing facilities. CHWMEG’s waste facility review program addresses facilities of interest to the membership. The frequency of facility evaluations is determined by the needs of member companies. While most companies require updated facility information on an established cycle, changes affecting the facility often create a need for updated information. Situations that may indicate a need for more frequent facility reviews include facility operational changes (addition/expansion or deletion/reduction of on-site capability or capacity); changes in facility management; changes in facility ownership; changes affecting facility regulatory status; and incidents at or proximate to the facility. The financial wherewithal of a facility’s parent company is an important factor for evaluating the long-term stability of the facility, and in turn a manufacturing company’s (customer’s) possible potentially responsible party (PRP) Superfund-type waste generator liability. Financial strength has been a factor included in each of over 2,500 facility reviews (1,000+ unique facilities) performed globally since 1995. The initial scope of CHWMEG’s reviews was limited to hazardous waste management facilities located in the USA. The evolution of corporate environmental management systems (EMS) and emerging waste generator-borne risk (i.e. Superfund PRP liability) at hazardous and non-hazardous recycling and waste processing facilities has created demand for an expanded scope of facility reviews. The composition of CHWMEG’s Programs since 1999 reflect the expansion of scope by addressing many types of facilities including battery recyclers, fluorescent light tube processors, ballast processors, mercury recovery facilities, RCRA-exempt oil field waste processors, naturally-occurring radioactive materials (NORM) disposal facilities, and computer demanufacturing facilities. Similarly, CHWMEG’s programs have expanded to address facilities outside the USA. Consistent with the needs of its members, CHWMEG has expanded the scope since 1995 to include geographic reviews of facilities in Argentina, Australia, Belgium, Brazil, Canada, Chile, China, Columbia, Costa Rica, Dominican Republic, Finland, France, Gabon, Germany, Guatemala, India, Indonesia, Ireland, Italy, Japan, Malaysia, Mexico, New Zealand, Norway, Philippines, Poland, Russia, Saudi Arabia, Singapore, South Africa, Sri Lanka, Taiwan, Thailand, The Netherlands, Turkey, Ukraine, United Kingdom (England), USA, and Vietnam to extend support to members having a global presence, and provide additional cost savings opportunities. CHWMEG’s organizational costs are borne by its member companies. The member companies establish the administrative fee annually. The membership cost for 2012 is US$2,200., which is pro-rated quarterly for new members. Increased membership has resulted in a downward trend in the annual membership fee. Members pay no registration fees to attend the meetings. Costs for facility review reports are shared by the members participating in each facility review program. Member “shared cost” for non-North American facility review reports to be performed in 2012 are US$1,300. each – a net savings for members of nearly US$2,500. per report! Member “shared cost” for North American facility review reports to be performed in 2012 are US$800. each – a net savings for members of nearly US$2,000. per report! Reports are available to members as electronic files via secure online access, or distributed on CD ROM.





CHWMEG®


CHWMEG, Inc. Facts CHWMEG, Inc. (CHWMEG) is a non-profit trade association consisting entirely of manufacturing and similar companies, individual

government installations, and educational/research institutions. Membership includes 240 members comprising over 650 individual companies (as of December 2011) interested in good corporate stewardship of the waste inherently created from their own operations or those of others related to their products (end-of-life).

Current membership represents companies of varying size, representing the chemical, petroleum, pharmaceutical, utility, printing,

electronic and other manufacturing sectors; colleges and universities; and government installations. To review the current member list , see: http://www.chwmeg.org/asp/members.asp.

CHWMEG’s objectives include assisting manufacturing companies in assessing and minimizing their business risk associated with

the management of manufacturing-related wastes. Activities include a third-party program to conduct reviews of recycling and waste processing facilities. Through 2011, CHWMEG

will have conducted nearly 2,500 reviews of over 1,000 unique facilities in Argentina, Australia, Belgium, Brazil, Canada, Chile, China, Columbia, Costa Rica, Dominican Republic, Finland, France, Gabon, Germany, Guatemala, India, Indonesia, Ireland, Italy, Japan, Malaysia, Mexico, New Zealand, Norway, Philippines, Poland, Russia, Saudi Arabia, Singapore, South Africa, Sri Lanka, Taiwan, Thailand, The Netherlands, Turkey, Ukraine, United Kingdom (England), USA, and Vietnam.

Member “shared cost” for non-North American facility review reports to be performed in 2012 are US$1,300. each – a net savings

for members of nearly US$2,500. per report! Member “shared cost” for North American facility review reports to be performed in 2012 are US$800. each – a net savings for members of nearly US$2,000. per report! Costs for CHWMEG reports are far less than those using internal or external resources to perform less comprehensive reviews. To view report cost trends, see: http://www.chwmeg.org/html/trends.html#cost; and report price details, see: http://www.chwmeg.org/asp/cost.asp.

Members establish the annual membership fees. At US$2,200., 2012 annual fees are more than 60% lower than 1995’s

membership fees. See membership fee trends at: http://www.chwmeg.org/html/trends.html#fees. Consistent with the needs of its members, CHWMEG has expanded the scope to include geographic reviews of facilities in Europe,

Latin America, and the Asia-Pacific regions to extend support to members having a global presence, and provide additional cost savings opportunities.

CHWMEG reports are the lowest-cost and highest quality option for obtaining objective and value-added supplier information

about recycling/refurbishment waste processing facilities, and facilities offering waste treatment and disposal services. Value-added information contained in CHWMEG’s recycling and waste processing facility review reports includes comparison of

facility information against key benchmarks. Reports incorporate CHWMEG's proprietary Risk Assessment System (RAS), which characterizes relative environmental risk by

exposure/release pathway and quantifies information for comparative use. Members use facility review reports to replace or augment corporate supplier review and monitoring programs, thereby reducing

costs and freeing resources to apply toward other value-added efforts. Information contained in facility review reports generally satisfies all requirements to evaluate potential liability associated with a

facility -- environmental, operational, and financial risks are included. Periodic recycling and waste processing facility reviews are recognized as "best environmental management practice", and are

incorporated into many management systems initiatives (e.g. American Chemistry Council’s Responsible Care®, ISO 14001 Environmental Management Systems, and other recognized industry and national standards).

Involvement by members' supply and customer chain in CHWMEG promotes management of product life cycle environmental risks

and cost-effective management of the external aspects of environmental stewardship programs. CHWMEG’s standard protocol ensures consistent, thorough, detailed information including:

Physical/geologic setting Neighboring activities Compliance history/regulatory standing

Organizational structure and staffing Facility design Incident history

Operational concerns Financial strength Waste acceptance procedures





(over)

CHWMEG®


CHWMEG, Inc. Synopsis Incorporated in 1995, CHWMEG, Inc. (CHWMEG) is a non-profit association of manufacturing and similar companies, individual government installations, and educational/research institutions. CHWMEG’s objective is to assist its members with their efforts in managing corporate stewardship and risk management systems related to their manufactured wastes. One aspect of CHWMEG includes conducting comprehensive, independent facility reviews of recycling and waste processing facilities, and facilities offering waste treatment and disposal services. The facilities reviewed are selected by the members, and the evaluations are performed according to a standard protocol by independent and experienced environmental contractors under contract to CHWMEG. The cost of the facility reviews are shared by the member companies. LEGAL CONSIDERATIONS CHWMEG was established with careful consideration to legal concerns of the members including antitrust, confidentiality, and potential liability. The corporation has adopted many procedures that are intended to protect individual member companies. Decisions to use or not to use particular disposal facilities are entirely the decisions of each member company. An independent administrator is employed to operate CHWMEG and to manage all transactions on a confidential basis, thereby assuring that no member is aware of the purchases of any other member. Information regarding the reviewed facilities is held in strict confidence by the members, and is not shared or discussed. FACILITY REVIEW PROGRAM CHWMEG's members, in collaboration with the facility review contractors, have developed a comprehensive facility review protocol, questionnaires, and a sophisticated data management system. These are applied on behalf of CHWMEG to the recycling and waste processing facilities being reviewed by the consultants to compile information into the facility review report which members use to evaluate their risk associated with a particular facility. The CHWMEG facility evaluation program considers all aspects of each facility including its history, regulatory standing and requirements, setting, design, operations, management, and financial strength. The focus in all cases, however, is on environmental risk and the inherently-associated financial risk. Members of CHWMEG benefit from activity in the facility review program by realizing significant cost savings through reduced facility review costs, or by augmenting their in-house facility review program with the information provided by the inexpensive CHWMEG facility review reports. MEMBERSHIP New members can join CHWMEG at any time. Membership fees are determined annually by the members, and are pro-rated quarterly for new members. The member assessment is based, each year, upon the number of members, the activity of the organization, and the number of facility reviews to be conducted in that particular year. At US$2,200., 2012 annual fees are more than 60% lower than 1995’s membership fees.

RISK CATEGORIES The CHWMEG evaluation program divides risk into three primary categories: Environmental, Operational, and Financial. ENVIRONMENTAL RISK includes analyzing the source, pathway, and receptors of all contamination and releases. Both existing and potential risks are evaluated for the following environmental pathways: groundwater, surface water, air, and fire/explosion risk.

OPERATIONAL RISK involves evaluating a facility's management proficiency, types of equipment and technology used, training, and maintenance programs, since these all provide insight into the risk associated with facility operations. FINANCIAL RISK involves considering the financial strength of the facility owners, since CHWMEG recognizes that members and industrial companies cannot rely on a TSDF that is not financially stable. Financial failure could result in the generators' having to pay for costly closure or post-closure care. Moreover, financial stability may balance the risk scale for a TSDF in a positive way, whereas financial instability may negatively affect the risk scale.

FACILITY REVIEW PROCEDURE The CHWMEG facility evaluation procedure results in a final facility review report that includes a succinct executive summary (3-7 pages) and a completed detailed evaluation questionnaire.

FACILITY VISIT Field evaluation teams collect, record, and assemble the required data on a facility using the current questionnaire. The CHWMEG questionnaire controls the scope of every facility review using a core checklist which addresses general aspects of any recycling and waste processing facility, and modules specific to the particular facility’s technologies and functions. Therefore, with minimal training and guidance, qualified environmental professionals from different consulting firms are able to produce comparable facility review results.

RISK ASSESSMENT SYSTEM Since qualitative facility comparisons are difficult to make and nearly impossible to reproduce, a Risk Assessment System (RAS) has been developed establishing a method whereby selected qualitative information from the three protocol documents is assigned weighted values based on the facility review team's observations and evaluations. The RAS formula combines these values to generate scores for each facility: Environmental, Operational, and Financial. Further, the scores are broken down into both observed and potential environmental risks, including groundwater, surface water, and air releases, and also fire and explosion risks. By using these RAS scores, the unique contribution and identity of each element is preserved. CHWMEG members may then rate their individual concerns according to three separate but related RAS values. Members can also perform "what if" scenarios on the RAS input when the data are presented in this way.

FACILITY REVIEW COSTS Member “shared cost” for non-North American facility review reports to be performed in 2012 are US$1,300. each – a net savings for members of nearly US$2,500. per report! Member “shared cost” for North American facility review reports to be performed in 2012 are US$800. each – a net savings for members of nearly US$2,000. per report! Costs for CHWMEG reports are far less than those using internal or external resources to perform less comprehensive reviews. Individual members have realized cost savings in excess of US$1 million through their CHWMEG facility review program participation; aggregate member savings now exceeds US$40 million. As new members join CHWMEG and increase the facility review activity of the organization, the cost of facility review reports will continue to decrease. All previously-completed facility review reports can be purchased by new members. A list of available facility review reports and costs is available upon request.

2012 FRP Contractor Instructions

CHWMEG, Inc. 2012 Facility Review Program Instructions to Facility Review Contractors

Objective The primary goal of the CHWMEG, Inc. (CHWMEG) facility review program is to compile and report objective information, including potential generator-borne liability associated with waste/residual management facility operations. Approach The facility review contractor (contractor) should collect objective information to address questions and support responses presented in the questionnaire. The report will satisfy the informational needs of the members of CHWMEG, Inc., and assist them in making well-informed risk-based decisions regarding facility selection. Deliverables See “Definition of Stages of Completion and Materials Included with Each Stage”, provided separately. CHWMEG Contractor Representation In conducting reviews and interfacing with facility contacts, the contractor represents CHWMEG, its members, and its Board of Directors. The contractor is expected to be knowledgeable of CHWMEG’s objectives, the membership of CHWMEG, its status as a non-profit trade association, and its activities. The contractor is expected to accurately reflect this information to facility representatives at all times. General information about CHWMEG is available at the internet site: http://www.chwmeg.org, or by contacting Jeff Sacre, CHWMEG Administrator at (412) 826-3056. The contractors are expected to be courteous and professional when dealing with facility representatives. If delays or roadblocks occur, the contractor should notify the CHWMEG Administrator immediately. The contractor must notify the CHWMEG Administrator of any individual process step delays which persist two weeks (including facility non-responsiveness, confidentiality concerns, delays in scheduling site visit, and postponement of site visit). The contractor must address each delay lasting two weeks. Questionnaire Completion The majority of the questionnaire is intended to be completed by the facility; however, this is not always the case and lack of completion or update of the questionnaire is not a valid reason for delays. The facility representative should return the completed questionnaire to the contractor prior to the site visit. Email transfer of files is perfectly acceptable (see section pertaining to virus protection). Additional materials necessary for the report include review of financial information about the facility (previous three years, to afford the facility a positive disposition in the event of single year aberrations), legible plot plans, and flow charts. The intent is for the contractor to obtain this completed information prior to the site visit, however, in order to maintain an acceptable schedule, the contractor may have to be flexible in the level of response expected prior to the site visit.


Handling Delays Efficiency in completing and finalizing awarded facility reviews has always been of interest to CHWMEG. In order to ensure that facility-related delays are quickly identified and addressed, contractors are requested to specifically communicate the situation with the Administrator promptly so that necessary action can be taken. One suggestion is through the use of specific email to the Administrator, such as: Subject: DELAY NOTICE: FACILITY – City, ST USA Priority: high Message: Be advised that we are experiencing trouble in moving forward with this facility review. (insert situation here). Facility POC: FIRSTNAME LASTNAME Tel: (XXX) XXX-XXXX ext. ZZZZ Typical Situations: …We are having inordinate difficulty making a connection with the facility to coordinate and schedule the site visit. …The facility has requested a confidentiality agreement. …The facility POC indicates that they refuse to support this effort. …The facility POC indicates that they refuse to support this effort, specifically demanding to know which members are participating in their review. …The facility POC indicates that they will support the effort, but has requested that they be informed of which CHWMEG members are participating in their review. …The facility has promised information that is not being provided after many attempts to contact them with these requests (requested information includes x, y, z) …etc. These email notices should be sent to: [email protected], with a copy to: [email protected] The Administrator will endeavor to assist in addressing the situation (may involve engaging member reps to contact the facility) to allow the contractor to move forward on the effort. Site Visit The on-site portion of the facility review begins by reviewing the questionnaire with facility representatives for incomplete or unclear responses. These issues should be resolved. Further, the contractor should amend the facility response with additional information, as necessary. The contractor is responsible for field-verifying all significant information and responses provided by the facility representative. Separate data entry areas are provided to distinguish between facility and contractor information. In addition, the contractor is required to complete the “contractor only” portions of the checklist (especially important areas are indicated by heavy boldface double boxes). If the contractor is required to provide responses intended to be provided by the facility, please note these objective responses (just the facts) by placing hard brackets [ ] around the response (within the single box area). Reserve “contractor perspective” or descriptive information for the “Contractor Only” response for the appropriate question.


Report Format Format for completion and delivery of the Executive Summary and the completed questionnaire for the 2012 Facility Review Program will entirely be electronic-based, using the template “form” file. Facilities that have not been reviewed by CHWMEG within the past ten years (prior to 2001) will use the “blank” template form. For facilities reviewed by CHWMEG in 2001-2011, the template form will be tailored with “facility-specific” information inserted appropriately (excluding date-sensitive information such as injuries/illnesses – only “Contractor Only” sections will not be included in the electronic file. Note that CHWMEG will also provide PDF excerpts from these reports to the awarded contractor. The excerpts will include the Executive Summary, the entire completed questionnaire, and the attachments less the BRS data and RAS data. The “Contractor Only” responses WILL be included in the PDF version, thus supporting the contractor's effort to complete the report, without biasing the facility against the current contractor unfairly because of the previous contractor’s “Contractor Only” responses. See “Definition of Stages of Completion and Materials Included with Each Stage” provided separately. Report Attachments If you feel an existing document or portion of a document (maybe a document describing the site history) addresses one of the questions, it is acceptable to briefly summarize the information and simply reference the existing information. Include the item as an attachment rather than typing out the same information on the questionnaire. Ensure that the response to the question references the attachment, and that the attachment is appropriately marked (see sticky note instructions) to allow the reader to quickly access the information. Within the attachment, the specific portion of the attachment should be preceded by an insert page (see Attachment handouts, and electronic file containing same will be provided to contractor with award package) using the provided template (“Referred from Question XXX”). Note that a large document included as an attachment because of the information it contains can be included as an attachment in its entirety (extraneous information should not be included). However, specific references from the questionnaire should be called from the relevant section of that attachment. Permit Review Contractors should review all relevant permits to determine specific requirements established by the regulatory agency. Facility compliance history against these requirements is very important. In addition to responses from appropriate regulatory agency representatives, contractors should review objective evidence pertaining to the monitoring, sampling and analysis, control equipment installation and operation, etc. compared with the established regulatory and permit-specific requirements to determine programmatic compliance. Contractors should also review all permits to determine issuance and expiration dates. This information should be tabulated and included in the relevant questionnaire sections. Attaching Permits The goal is to be sure that the facility has the required permits, yet not make unnecessary copies of voluminous permits. Facility-specific requirements are important and should be attached, but administrative portions of permits with little relevance to actual requirements are


not necessary. Where you perceive a problem or questionable activity - ask for the permit. Contacting the regulatory agency first may allow the contractor to focus on more important requirements or issues during the site visit. Voluminous Permits Many permits are large and do not need to be copied. Examples include Title V permits, air emissions permits (an excellent source of “excerptable” facility plot plans and flow charts), RCRA Part A & B permit applications, and RCRA permits. These permits should be reviewed (see next section) but do not need to be included as attachments. “Non-Standard” Permits Contractors should obtain copies of “non-standard” permits (or excerpted permit conditions or operating limits) and include them as attachments. This is vitally important for smaller waste management facilities that may operate outside of the traditional RCRA regulated environment. Examples include industrial waste processing permits, residual waste permits, medical waste processing permits, and other special waste processing approval letters from the state environmental agency, specific operating conditions, required pollution control equipment, acceptable discharge parameters from the county or local health department, POTW permits, and NPDES permits. Ensure that established facility-specific requirements are provided as attachments to the report. Reviews of Non-English-Speaking Facilities For reviews conducted in locations that do not speak English, your facility review team on the ground conducting the site visit must be comprised of:

a. an individual well versed and directly experienced in conducting CHWMEG reviews (knowledgeable of intent/perspective, and processes/procedures)

b. an individual well versed and knowledgeable regarding local language, local customs, and local operating/regulatory requirements

It is understood that the contractor may need to engage a local subcontractor to address the requirements for element “b”. That arrangement is exclusive to the CHWMEG contractor, and CHWMEG’s cost in US$ and interface/direction will be limited to the CHWMEG contractor only. For reviews of facilities located outside of the USA the assumption is that workable English will be spoken by your facility contacts*; however, note that Spanish, French, Mandarin and Simplified Chinese, Indonesian (Bahasa), Brazilian Portuguese, Japanese, Turkish, Vietnamese, Dutch, German, Thai, Finnish, Korean, Polish, Russian, Italian, and Norwegian translations of questionnaires (at various stages of modification over the past six years) are available as a tool to help gather the information. These translations may have been completed prior to rewording of the question or addition/deletion of a small percentage of the questions in the current document, and should remain to be greatly useful to your efforts. The draft report should be conveyed to the facility for their review and written comment, as is routinely done. The exception for these reviews is that the draft conveyed should also include a local language version of the Executive Summary. It is possible that their review and comments will be limited to the local language version of the Executive Summary only. The questionnaire and other materials will be included in the draft version in English, nonetheless.


The resulting report is required to be delivered to CHWMEG as:

a. Executive Summary in local language and English (as translated from their review and comments of the draft local language Executive Summary). b. Questionnaire completed in English and as revised from facility comments received (if using a translation of the questionnaire to gather information, the information must be reverse-translated into English and included in the current English questionnaire).

c. Local language questionnaire used to collect facility information (to be submitted electronically in the local language to CHWMEG with the rest of the electronic files when submitting the draft-final report).

Foreign Language Attachments For reviews incorporating foreign language attachments, include only key pages/relevant excerpts of documents, and either:

a. Translate the entire included contents into English, providing the English translation immediately in front of the foreign language excerpt attachment, or

b. Provide an English summary of the content of the excerpt immediately following – emphasizing the highlighted details/information and provide the English summary immediately in front of the foreign language excerpt attachment

Questionnaire Management Every question in the pertinent sections of the questionnaire should be completed or an explanation should be provided as to why it was not completed. There should never be any doubt about whether or not the requested information was pursued. Regulatory Agency Interviews Call all relevant regulatory agencies to obtain information on the facility’s compliance history, results of recent inspections, history of cooperativeness, etc. In fairness to the facility, the contractor’s experience and judgment is important in discerning true facility uncooperativeness from potential regulator bias. It is suggested that regulatory agencies be contacted in advance of the site visit. Experience shows that this method helps to reduce delays from surprise information provided by agency representatives after the site visit is completed, and helps to identify focus areas during the site visit. Significant or noteworthy information should be included in the Executive Summary. Use of Existing Information CHWMEG encourages all of its contractors to use existing information whenever possible. Little value is added by recreating existing information. Make use of all sources of information that make your work easier, but recognize that EPA databases and other information sources may not be accurate or may contain outdated information. If your source of information is copyrighted, recognize that the information cannot be conveyed to CHWMEG members without appropriate authorization. If an information service requires payment for compiling information, but all information is obtained from public-domain databases or other sources, the information can be conveyed through CHWMEG without concern.


In the event that regulatory agency contacts are not forthcoming with information pertaining to the facility, the contractor is encouraged to gather any pertinent timely information regarding the compliance and public perception status of the facility. Financial Model Each contractor will be provided a brief discussion concerning the Altman Z financial strength model, and CHWMEG’s history with this approach. For all public companies reviewed, CHWMEG will provide financial data to be entered by the contractor in both the questionnaire and the RAS. For privately-held companies, the contractor is advised to request the financial information from the facility. Determine whether these financials have been independently verified by a third-party financial auditor, and if so, to what level of review (e.g., audit, review, etc.). The intent is to include their financial data in the questionnaire and in their entirety as an attachment. Should the facility decline to provide financial data (this is perfectly acceptable), at a minimum the facility should provide a financial POC name with contact information. That individual should be notified that CHWMEG members will be making contact if their company requires review of financials in order to approve or maintain the facility on the member’s “approved” list. Note that financials are always sought for the lowest level possible (i.e., facility, then division, and if necessary company-wide data). Inclusion of only calculated Altman Z scores is discouraged. If the facility refuses to provide financial data that allows justification of Altman Z calculations, the calculated scores by themselves should not be included. Facility Concurrence The CHWMEG facility review contractor must always provide the facility with the opportunity to review and provide written comments on the draft report (executive summary, completed questionnaire, photos, attachment cover pages). Regardless of the means of conveyance, the CHWMEG suggested transmittal letter or a reasonable facsimile should be used to transmit the draft documents to the facility. The contractor requests a response in writing from the facility within ten business days of contractor’s request. If email transmittal to the facility is available, only PDF versions (secured to prevent changes to the document, printing allowed, and requiring a separate password to open the file – suggested “file open” password is the last name of the facility representative of the reviewed facility) of the draft executive summary, completed questionnaire, photos, and attachment cover pages should be transmitted via email attachment. When transmitting draft reports to the facility via email, CHWMEG must be “cc’d” on that email transmittal (see separate “Definitions of Stages of Completion for details). If the facility cannot accept documents via email, the contractor must transmit (via CD ROM or hard copies) the executive summary, completed questionnaire, photos, and attachment cover pages (as appropriate) to the facility using the transmittal letter and guaranteed overnight delivery. If hard copies are transmitted, the contractor must fax the transmittal letter and draft Executive Summary (only) to CHWMEG concurrent with conveyance to the facility. The fax number for this transmittal is (586) 461-1856. This is an important part of the CHWMEG facility review process, and provides the opportunity for the facility to correct inaccuracies and misunderstandings. In addition, it provides a mechanism for the facility to explain any mitigating factors related to facility operations or history. The facility’s response(s) and contractor rejoinder are required attachments to the facility review report.


Centralized Project Management Responsibilities The contractor’s Project Manager is responsible for all issues concerning work conducted on behalf of CHWMEG, including contractor assignment and oversight, site visit scheduling, facility coordination, and report QA/QC.


2012 CHWMEG, Inc. Facility Review Program Overview The following approach is provided for the 2012 Facility Review Program: 1. Administrator immediately notifies all contractors of CHWMEG, Inc. decision by telephone closely followed by written correspondence (including versions of the current electronic questionnaires). 2. Administrator notifies FACILITY in writing (sent via FedEx) that a CHWMEG facility review has been requested by the membership, and introduces the corresponding contractor. Administrator provides electronic PDF copy of its facility correspondence to awarded contractor firm responsible for that facility. 3. Contractor coordinates site visits with facilities. Note that several facilities included in the bid requests are highlighted (shaded). CHWMEG requests, but does not require, that these facilities be placed toward the front of the scheduling of the awarded contractors program, if at all possible. 4. Contractor sends letter confirming dates of site visit, relationship of contractor with CHWMEG, Inc. (may also include list of CHWMEG, Inc. member companies), initial request for access to financial information (and call-out other specific portions of the questionnaire requiring special handling - e.g., corporate ownership), and request for permission to obtain site photographs during the site visit for inclusion in the report. Contractor provides hardcopy version or electronic template form version saved as Microsoft Word any version -compatible file of questionnaire to facility representative, requesting that they complete all sections except those marked "contractor only". Facility is requested not to retain questionnaires (hardcopy or electronic) – see recommended transmittal letter language asking for facility review and written comments. 5. In the event that the facility hesitates to support the facility review due to confidentiality concerns, contractor promptly notifies Administrator. Administrator immediately initiates a three-way confidentiality agreement (CHWMEG, Inc. - contractor - facility) to address and alleviate concerns of all parties (example current version provided to contractors during pre-bid meeting). The Administrator transmits the agreement directly to the facility for their signature, who then forwards to contractor for signature, who transfers to Administrator for final execution. Copies of the fully-executed agreement are provided to all signatory parties. If originals are required, three original agreements will be transferred as above. CHWMEG, Inc. will distribute all originals of fully-executed agreement to signatory parties. 6. <<As early as possible>> If the facility hesitates to release financial information or balks at allowing the contractor to photograph the site, the contractor notifies the Administrator. The Administrator immediately notifies the interested members and encourages them to call the facility. Member involvement is expected to influence the facility’s position on photographing the site. 7. Facility representative returns completed questionnaire to contractor in advance of site visit (goal is at least one week prior to visit). 8. Contractor contacts pertinent environmental regulatory agencies to determine compliance and permit status (preferably in advance of site visit, while awaiting completed questionnaire). A knowledgeable and experienced representative for each relevant program area (air pollution control, wastewater, solid/hazardous waste, etc.) should be included in these contacts.


9. Contractor conducts site visit, completing all "contractor only" portions of the questionnaire, field-verifying facility responses, and appending facility responses with necessary information. 10. Specific instruction has been provided in the Instructions to Facility Review Contractors regarding how delays should be communicated to the CHWMEG Administrator to garner assistance in maintaining progress toward report completion. 11. The CHWMEG facility review contractor must always provide the facility with the opportunity to review and provide written comments on the draft report (executive summary, completed questionnaire, photos, attachment cover pages). Regardless of the means of conveyance, the CHWMEG suggested transmittal letter or a reasonable facsimile should be used to transmit the draft documents to the facility. The contractor requests a response in writing from the facility within ten business days of contractor’s request. If email transmittal to the facility is available, only PDF versions (secured to prevent changes to the document, and requiring a separate password to open the file – suggested “file open” password is the last name of the facility representative of the reviewed facility) of the draft executive summary, completed questionnaire, photos, and attachments cover pages should be transmitted via email attachment. When transmitting draft reports to the facility via email, CHWMEG must be “cc’d” on that email transmittal (see separate “Definitions of Stages of Completion for details). If the facility cannot accept documents via email, the contractor must transmit (via CD ROM or hard copies) the executive summary, completed questionnaire, photos, and attachments cover pages (as appropriate) to the facility using the transmittal letter and guaranteed overnight delivery. If hard copies are transmitted, the contractor must fax the transmittal letter and draft Executive Summary (only) to CHWMEG concurrent with conveyance to the facility. The fax number for this transmittal is (586) 461-1856. This is an important part of the CHWMEG facility review process, and provides the opportunity for the facility to correct inaccuracies and misunderstandings. In addition, it provides a mechanism for the facility to explain any mitigating factors related to facility operations or history. The facility’s response(s) and contractor rejoinder are required attachments to the facility review report. 12. In the event that the contractor's FINAL report summary requires the addition or modification of significant findings/concerns not previously acknowledged by the facility representative, or lack of facility support requires the contractor to complete portions (especially sensitive items) of the questionnaire, the contractor must provide the material to the facility for written concurrence or comment. This may include providing the rewritten Executive Summary and/or completed Questionnaire or portions thereof for additional facility review and comments. The facility acknowledgement(s) (or written rebuttal) will be attached to each completed report. As detailed previously, the transmittal of the DRAFT report to the facility for the 2012 Facility Review Program will be in electronic format. 13. Contractor prepares the DRAFT FINAL report in the provided Word template form file. 14. Contractor transmits DRAFT FINAL report to CHWMEG Administrator for review. CHWMEG’s QA/QC review will consist of format, completeness, and language use precision and clarity (avoiding inflammatory language, contradictions, etc.). CHWMEG Administrator provides any comments to contractor via email to the contractor POC within nine business days. Note: The DRAFT FINAL report consists of the electronic files for the Executive Summary, the completed questionnaire, attachments cover pages, the completed RAS, all attachments to


include digital color photographs (per template), and to include contractor request for facility written comments, facilities reply, and contractor’s rejoinder. 15. Contractor sends FINAL report electronic files (any and all files impacted by addressing Administrator comments) to the CHWMEG Administrator. These files are expected to include Executive Summary, completed questionnaire, and possibly the RAS file. 16. Contractors will be paid monthly based upon aggregate progress within each awarded bundle for which the contractor submitted a tabulated progress report by the 25th day of the month (should the 25th occur on a weekend, the progress report would be due the Friday before the 25th). The progress payment will be based upon 60% complete at delivery of DRAFT report/questionnaire portions to facility, 80% complete at delivery of DRAFT FINAL report to CHWMEG Administrator, and 100% complete at delivery of FINAL FINAL report to CHWMEG Administrator. Payment will be initiated in the first week of the following month. It is anticipated that incremental progress payments will be forwarded to the contractors within 30 days of receipt of tabulated progress report.

EXAMPLE

Contractor Capabilities: XXX Contractor Companies applications of CHWMEG protocol

and other facility review experience

Contractor's Name

CHWMEG Facility Review Experience (list facilities audited)

Other TSDF Facility Reviews Conducted

(Number conducted and protocol used since 1995)

On Staff or Associate

Groucho Marxx Chem Waste, Emelle, AL (2005) Safety-Kleen, Rock Hill, SC (2007) Bethlehem Apparatus, Hellertown, PA (2003)

3 using CHWMEG protocol 12 using WSIG protocol 6 using US Steel protocol

associate

Kim Novak Rollins OPC, Los Angeles, CA (2002) Rollins, Deer Park, TX (2001) Rollins, Baton Rouge, LA (2008) Heritage Environmental, Indianapolis, IN (2003) International Petroleum Corp., New Orleans, LA (2006) Safety-Kleen, East Chicago, IN (2004)

6 using CHWMEG protocol 18 using WSIG protocol

on staff

December 19, 2011

2012 FRP December 19, 2011

Contractor Capabilities: CONTRACTORNAME HERE Experience Conducting CHWMEG Reviews

and Other TSDF/Recycling Facility Review Experience

Auditor's Name

CHWMEG Reviews Conducted Since 2004 (list facilities reviewed and year in which review was conducted)

Other Recycling Facility/TSDF Reviews Conducted (Number

Conducted and Protocol Used Since 2004)

Employee/ On Staff

or Associate

Insert/Copy add’l rows as needed

EXAMPLE: CHWMEG, INC. INTRODUCTION LETTER TO FACILITY DATE FACILITY CONTACT NAME FACILITY NAME FACILITY ADDRESS Dear XXXXXXX: On behalf of its 240 member enterprises (over 600 separate companies), CHWMEG, Inc. (CHWMEG) has selected your facility for evaluation as part of the CHWMEG 2012 Facility Review Program. The member companies of CHWMEG are the motivation for this facility review and represent significant customers and potential customers of your facility. I have attached a list of the member companies and CHWMEG’s 2011-2012 Board of Directors for your information. CHWMEG has selected CONTRACTOR COMPANY to complete the facility review of your facility on behalf of its members. CONTRACTOR NAME of CONTRACTOR COMPANY Corporation will be contacting you to coordinate this effort and to schedule the site visit. CONTRACTOR NAME is located in their CONTRACTOR COMPANY LOCATION office, and can be reached at (XXX) XXX-XXXX. Based upon feedback received from facility contacts, CHWMEG has made a number of streamlining improvements. Please note that changes implemented by CHWMEG allow for the use of facility information from previous efforts if the facility has been reviewed by CHWMEG within the past. This change should result in a reduction of effort if your facility meets this criteria, and will allow for a more streamlined effort should members nominate your facility again in the near term. Distribution of CHWMEG reports is limited to member companies only. Each member company has agreed to confidentiality provisions that prevent them from disclosing the information outside of their organization. The attached information fully describes CHWMEG’s program, and is provided for you or other appropriate individuals at your facility. CHWMEG’s members have emphasized the importance of access to all areas of the facility, “representative” photos of the site, and disclosure of audited financial information. Their expectation for CHWMEG’s facility review reports presumes that this will be part of the review and final report. If you have any questions regarding CHWMEG or this request, please call me at (412) 826-3056 or email: [email protected]; or Mr. David Chng, CHWMEG, Inc. Director, Asia-Pacific, at +65 9237 8445 or email: [email protected]; or Mr. Randy Mott, CHWMEG, Inc. Director, Europe, +48 60 733 9012 or email: [email protected]. You may also contact any of the members of CHWMEG’s Board of Directors identified on the attached list. On behalf of CHWMEG’s member companies, thank you in advance for your support. Sincerely, Jeffrey A. Sacre, P.E. CHWMEG, Inc. Administrator attach: CHWMEG, Inc. Member and Board of Directors List CHWMEG, Inc. Information Materials

cc (w/o): CHWMEG, Inc. Board of Directors FON: for facility FAX: for facility

C O N F I D E N T I A L

EXHIBIT A6-1-2011CHWMEG, INC. 2010 FACILITY REVIEW PROGRAM

PREFERRED CONTRACTOR AWARD

Environmental Compliance Co. LLCAwarded Bundles, Schedule Dates, and Payment Schedule

FACILITY LOCATION Waynesburg, MI

E. Liverpool, OH

Toledo, OH

AWARD AMOUNT FOR BUNDLE TEN: $9,100

ADJUSTMENTS FROM ORIGINAL BID PACKAGE:1

NOTES:*

‡

DELIVERY SCHEDULE:• 30% of all reports due in draft-final format by May 28, 2010• 65% of all reports due in draft-final format by July 30, 2010• Balance of all reports due in draft-final format by October 8, 2010

PAYMENT SCHEDULE:

•

•

•

Scheduling: CHWMEG requests your consideration in scheduling these facilities as early in the program aspossible. If this is not possible or conducive to your efficient completion of all awarded facility reviews, nodetrimental impact to you/your firm will result

BUNDLE TEN: Detroit - Toledo (3 facilities)FACILITY NAME

WMI American Landfill‡

Dropped EQ Resource Recovery, Romulus, MI from Bundle 10. Original bid amount decreased by $1,900 from$11,000 to $9,100. (5/22/2010)

AWIN Vienna Junction Landfill* Heritage-WTI Inc.‡

Payment of 20% upon delivery of final-final report to CHWMEG, Inc.

The payments will be made at the end of the month, based upon the status of the current reports. Status will beapplied to the completion status within each bundle. For example, if for a bundle of five reports, the status that monthis: one report submitted in final, two reports submitted in draft-final to the administrator, and one report submitted indraft to the facility, the payment for completion for that month would be (1/5)(100%)+(2/5)(80%)+(1/5)(60%), orpayment of 64% of the bundle cost, based upon this completion status.

Accompany the Facility Reviewer: Member would like to accompany the reviewer. Please contact Jeff Sacre at(412) 826-3056 once these site visits are arranged.

The Board of Directors has established a standard payment schedule for 2007 and subsequent Facility ReviewPrograms. Payments will be made at the end of each month according to the following schedule:

Payment of 60% upon delivery of draft report to facility for their review and comment. Please provide a copy ofthe transmittal letter that accompanies the facility draft report via fax to Jeff Sacre at (586) 461-1856.

Payment of 20% upon delivery of draft-final report to CHWMEG, Inc. Administrator's staff for QA/QC review.

Page 1 of 2

C O N F I D E N T I A L

Note that the CHWMEG Board of Directors reserves the right to accelerate contractor progress recognition payments(in favor of the contractor) at CHWMEG's fiscal year end (or other key fiscal dates) where the Board determines thatremaining payments are small and timely contractor delivery/conformance is anticipated shortly after the currentpayment date.

Your status report submitted prior to COB the 26th day of the month will serve as our record of report status. If yourinvoicing department requires that they send out documented invoices, please continue. You may either add thestatus report as an attachment to the invoice, or submit the status report to the Administrator directly in advance ofthe invoice (preferred).

Page 2 of 2

Example 1 Provided by CHWMEG Contractor

Documents to be Reviewed1 CHWMEG Audit

• General Audit Package (if available)

• Certificates of Insurance

• Part B application2

• Hazardous waste permit and annual reports for the past three years2

• Agency inspection records for the past three years

• A random sampling of incoming and outgoing manifests and land disposal restriction

forms.

• OSHA 200 logs for the past three years2

• Internal inspection logs for the current year

• Internal operations logs for the current year

• Laboratory log for the current year

• Contingency Plan/SPCC Plan/SWPP Plan2

• Training program and records

• Closure Plan and costs2

• Waste Analysis Plan or equivalent

• Community Right to Know notifications

• Air permits2 and reports

• Wastewater and stormwater permits2 and reports

• Enforcement actions including consent orders2

• Site hydrogeological and groundwater sampling information2

• Subsurface geology information

• Process flow diagram2

• Site plan2

1 Some information many not be available for your facility based on operations and permit status. 2 Copies of these documents or portions of the document will be requested by the auditor.

Example 2 Provided by CHWMEG Contractor Documents for Review Waste Analysis Plan Injury Records Equipment Specifications Operational Diagrams Site Plan Annual Throughput Amounts Permits Violation Notices Consent Orders Regulatory Inspection Reports Facility Inspection Forms SPCC Plan Emergency Contingency Plan Training File (representative) List of Training Topics Site Assessments Groundwater Results Incident Reports Closure Funding Post Closure Funding Insurance Sudden and Non-Sudden coverage Facility Security Plan Transportation Security Plan Tank List Container Inventory


CHWMEG AUDIT Documents To Be Reviewed(1)

Request that copies of the following documents or portions of these documents are copied and available for me at the start of the site visit:

• Site location map and facility layout plan

• Process flow diagram(s)

• Site hydrogeological and groundwater sampling information(2)

• Waste permits(3), waste analysis plan, and past two annual reports

• Wastewater and stormwater permits(3) and reports

• Air permits(3) and reports

• Closure plan and closure cost estimate

• Agency inspection records and enforcement actions for past three years

• OSHA logs for the past three years

• Financial data or Annual Report and Certificate of Insurance Request that these documents are available for review during the site visit:

• Contingency plans

• Random sampling of incoming and outgoing manifests (or bills of lading) and land disposal restriction forms for the previous six months

• Training program and records

• Community Right-to-Know notifications

• Operating, laboratory, and inspection logs for the past year

NOTES: (1) Some information may not be available for your facility based on your operation and permit status.

(2) Key information is location of wells, parameters sampled, and summary of recent sampling results. (3) Transmittal letter from agency, permit cover page, and all site specific requirements.


CHWMEG AUDIT Documents To Be Reviewed(1)

NAME requests that copies of the following documents or portions of these documents be made available for review and/or copy during the site visit:

• Site location and plot plan(2) • Process flow diagram(s)(2) • Site hydrogeological and groundwater sampling information(3)(2) • Waste permits(4), waste analysis plan(2), and past two annual reports • Wastewater and storm water permits(4) and reports • Air permits(4) and reports • Closure Plan, Post Closure Plan and cost estimates(2) • Closure and Post Closure cost assurance documents(2) • Agency inspection reports, records, and enforcement actions for the past three years(2) • OSHA logs for the past three years(2) • Certificate of Insurance(2) • If a privately held company, copies of the three previous years financial reports (audited), or the

name and telephone number of the contact that can provide this information. NAME requests that these documents be available for review during the site visit:

• Contingency plans • SPCC Plan • A random sampling of incoming and outgoing manifests (or bills of lading) and land disposal

restriction forms for the previous six months • Training program and records • Community Right to Know notifications • Operating, laboratory, and inspection logs for the past year

NOTES:

• Some information may not be applicable to your facility based on your operation and permit status.

• Copies of these documents are requested. • Key information such as location of wells, parameters sampled, and summary of recent sampling

results. • Transmittal letter from agency and site specific requirements (copies of permit cover sheets only

are requested). • It is the auditors’ intention to take photographs that represent facility operations on the day of the

review. If advance notice or permission is required by the facility, please accept this as initial notification. It is our policy to avoid photographs that identify your clients, employees, or proprietary processes.

Thank you for your assistance in preparing for this audit. The length of time on-site will be reduced depending on the availability of the documents listed and the thorough answers on the questionnaire. If you have any questions or need assistance, please contact NAME at (412) 555-1212.


Documents to be Reviewed for CHWMEG Audit Information needed for verifying questionnaire responses: • Current and maximum inventories (untreated and treated waste) • Waste-to-date treated onsite (remaining onsite e.g. landfill, waste piles) • Information on air pollution control equipment, if any • Info on stormwater collection and secondary containment systems and monitoring and inspections • Name and phone # of water supplier, sanitary and/or industrial sewage Copies of documents needed: • Plot /site plan • Process flow diagram, if available • Closure Plan and cost estimates, financial assurance documentation • Current insurance certificate(s) • Sample Certificate of Disposal/Destruction • Waste analysis characterization/ waste profile form • Financial report (audited) Documents needed for review/ may need some copies: • Air permits and reports (including Title V) • Water, wastewater, stormwater permits and reports • Waste and hazardous waste permits and reports (including annual report for past 2 years) • Part B application, if appropriate • Any enforcement actions (notice of violation, notice of noncompliance) • Annual OSHA 300 logs for last 3 years (shows lost time, accidents, etc.) • A random sample of incoming and outgoing manifests, bills of lading, waste tracking system

documentation and land disposal restriction forms for the previous 6 months • Maintenance program / work order system and records • Operating records for last 2 years to date • Internal inspection log for last 2 years to date • Laboratory log for last 2 years to date • Any facility assessment reports / site investigations • Any Agency inspection reports (federal, state or local) from last 5 years to present • Training program and internal records • Contingency Plan (e.g. SPCC) • Waste Analysis Plan • Annual precipitation, 24-hr maximum precipitation, annual evapotranspiration • Is site in 100-year flood plain? Are there wetlands or critical habitats nearby? • Site hydrogeological and groundwater sampling information • Surface water proximity and use • Residential/commercial/industrial proximity • Community Right-to-Know notifications • Union/non-union workforce Note: Some information might not be available or applicable based on your facility’s operations and permit status.

confidentiality agreement Page 1 of 4 CHWMEG, Inc./ revision: January, 2012 CHWMEG CONTRACTOR NAME/ (unchanged from 2010 FRP) FACILITY COMPANY – FACILITY NAME

CONFIDENTIALITY AGREEMENT THIS CONFIDENTIALITY AGREEMENT (this “Agreement”) is entered into this January 15, 2012 by and between CHWMEG, Inc., a Pennsylvania non-profit corporation with offices at 470 William Pitt Way, Pittsburgh, Pennsylvania 15238 (hereinafter referred to as "CHWMEG"); LOCAL COMPANY NAME WILL BE ENTERED HERE, whose facility LOCAL FACILITY NAME WILL BE ENTERED HERE is located in CITY, STATE COUNTRY WILL BE ENTERED HERE (hereinafter referred to as "Facility"); and CHWMEG CONTRACTOR NAME WILL BE ENTERED HERE, (hereinafter referred to as "CHWMEG Contractor") which is a consulting firm under contract to CHWMEG and whose CHWMEG project management offices are located in CHWMEG CONTRACTOR OFFICE LOCATION WILL BE ENTERED HERE. WHEREAS, CHWMEG is an incorporated association of member companies representing manufacturing and other industrial activities; and WHEREAS, all CHWMEG members are bound by membership-related confidentiality agreements which prevent them from sharing any information gained through CHWMEG with any entity outside of their organization (CHWMEG Membership Agreement and Antitrust Policy incorporating these requirements are available upon request); and WHEREAS, CHWMEG’s Bylaws preclude the membership and involvement of certain other corporate entities, including those involved in commercial waste management activities; and WHEREAS, CHWMEG’s activities include collecting, assimilating, and assembling information regarding treatment, storage, disposal, and recycling facilities/companies; and WHEREAS, CHWMEG, as reflected by the interest of its member companies, desires that its CHWMEG Contractor conduct a site review of Facility and prepare a Facility Review Report in the proprietary CHWMEG format; and WHEREAS, CHWMEG Contractor shall use a confidential and proprietary questionnaire which is owned by CHWMEG, and which will be disclosed to Facility during said review to help in assembling the required information; and WHEREAS, CHWMEG Contractor and CHWMEG may receive from Facility information related to Facility which is deemed by Facility to be confidential and proprietary and use same to generate a Facility Review Report in the standard CHWMEG format for distribution to CHWMEG member companies only. NOW THEREFORE, the parties hereto agree as follows: 1. Facility shall be provided a reasonable opportunity to clarify information or to provide additional explanatory information that may be incorporated into or otherwise addressed prior to finalization of the applicable Facility Review Report. CHWMEG Contractor shall provide to


Facility a Draft Report, comprised of the Executive Summary, completed questionnaire, and listing of report attachments/appendices (including photos obtained during the site visit), for review by Facility representative(s). Comments from multiple Facility representatives shall be coordinated by Facility and submitted in a consolidated form. Facility representative shall provide comments in writing to CHWMEG Contractor. Facility’s written comments shall be included in their entirety in the final Facility Review Report. Comments shall be addressed accordingly by CHWMEG Contractor in the final Facility Review Report. Facility acknowledges and agrees that the questionnaire (including both the form and the completed versions) and the Draft Report (hereinafter referred to as "CHWMEG Confidential Information") are confidential and proprietary information owned by CHWMEG. Facility shall not retain or disclose to any third party the questionnaire or Draft Report (in whole or in part; either with or without facility information included). 2. During said site review, CHWMEG and CHWMEG Contractor may encounter information that is deemed by Facility to be confidential and proprietary. Any such information that Facility deems to be confidential and proprietary shall be so marked by Facility and the confidentiality thereof explicitly brought to the attention of CHWMEG Contractor and CHWMEG at or before the time of disclosure. All such information so identified shall hereinafter be referred to as "Facility Confidential Information." CHWMEG and CHWMEG Contractor shall maintain Facility Confidential Information as secret and confidential, and shall use same only for the purpose of completing the Facility Review Report as described above. 3. CHWMEG Confidential Information and Facility Confidential Information shall hereinafter be collectively referred to as the "Confidential Information." 4. Facility shall only disclose the CHWMEG Confidential Information to those of its employees with a need to know for assisting CHWMEG and CHWMEG Contractor in the review of Facility, including any Facility comments as set forth in section 1 above (“Facility Comments”). Facility may not make copies of the CHWMEG Confidential Information, except for the sole purpose of Facility Comments, without the prior written consent of CHWMEG and shall promptly return to CHWMEG the CHWMEG Confidential Information and all copies thereof upon request. 5. CHWMEG may only disclose the Facility Confidential Information to those of its employees, administrative personnel and CHWMEG Contractors with a need to know for conducting the review of Facility. CHWMEG, may not make copies of the Facility Confidential Information without the prior written consent of Facility, and shall promptly return to Facility the Facility Confidential Information and all copies thereof upon request. The foregoing restriction does not apply to Facility Confidential Information that is reflected in the Facility Review Reports, provided such Facility Review Reports are distributed only to CHWMEG member companies. CHWMEG’s confidentiality requirements and Antitrust Policy bind all CHWMEG member companies. 6. CHWMEG Contractor may only disclose the Facility Confidential Information to those of its employees with a need to know for conducting the review of Facility. CHWMEG Contractor may not make copies of the Facility Confidential Information without the prior written consent of Facility, and shall promptly return to Facility the Facility Confidential Information and


all copies thereof upon request. The foregoing restriction applies to CHWMEG Contractor with the exception that it reserves the right to retain one (1) archival copy of any document that it includes in its Facility Review Report delivery to CHWMEG. 7. The obligations of Facility and CHWMEG to maintain the Confidential Information secret and confidential shall not apply to any part of the Confidential Information which (a) was already known to the other party at the time of disclosure or becomes so other than by an act of the non-owning party subsequent to its disclosure without a breach of this Agreement; or (b) is in the public domain or (c) is disclosed to the non-owning party by a third party which has a right to so disclose. 8. This Agreement shall be binding on and inure to the benefit of the parties hereto and their respective successors and assigns, and can only be modified by a subsequent written agreement among the parties. CHWMEG represents that the CHWMEG Membership Agreement and Antitrust Policy bind any entity with which it will share Confidential Information. 9. This Agreement shall be construed, enforced, and performed in accordance with the laws of the Commonwealth of Pennsylvania without regard to choice of law provisions.

10. This Agreement contains the entire agreement and understanding among the parties with respect to the subject matter referenced herein, and all prior or contemporaneous discussions, proposals, or agreements whether oral or written are merged herein and are superseded hereby.

11. Facility may require CHWMEG Contractor to execute a separate agreement

confirming receipt of information related to safety procedures and site access and committing to follow those requirements while conducting the review at the Facility.

REMAINDER OF PAGE LEFT BLANK INTENTIONALLY TO ACCOMMODATE ALL SIGNATURES


IN WITNESS WHEREOF, the parties have caused this Agreement to be executed by their duly authorized representatives as of the day and year first above written. CHWMEG, Inc. By:

Jeffrey A. Sacre, P.E. CHWMEG, Inc. Administrator FACILITY COMPANY (FACILITY NAME) By: Authorized Representative's Signature By: Representative's Printed Name Title CHWMEG CONTRACTOR NAME By: Authorized Representative's Signature By: Representative's Printed Name Title

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CHWMEG, Inc. 2012 Facility Review Program Corporate Contacts, Conf Agreements & Draft Report Arrangement Details

Waste Facility Parent Company* CHWMEG’s General Corporate POC

Corporate Contact for Facility Insurance Coverage Info Confidentiality Agreements Draft Report Conveyance

Clean Harbors (all)

Mr. John "Scott" Kuhn Clean Harbors Environmental Services, Inc. 200 Arbor Lake Dr. Suite 300 Columbia, SC 29223 tel: (803) 691-3426 fax: (803) 691-3493

[email protected]

current records should be maintained at facility; contact

corporate contact if not

Jeff will proactively initiate Conf Agrs for all known Clean Harbors facilities with copies furnished to affected contractors so that they know they are in the works.

All draft reports are to be sent to the facility POC only – no corporate POC to be included in draft report distribution.

Heritage Environmental Services (all)

Mr. Steve Danenman Heritage Environmental Services, LLC 7901 West Morris Street Indianapolis, IN 46231 tel: (317) 243-0811 fax: (317) 486-5991 [email protected]



Jeff will proactively initiate Conf Agrs for all known Heritage Env Svcs facilities with copies furnished to affected contractors so that they know they are in the works.

All draft reports to be conveyed to facility POC only.

Philip Services Corporation (all)

Mr. Michael Hawksley Corporate Accounts Manager PSC Industrial Services PMB #144; 532 Old Marlton Pike Marlton, NJ 08053 tel: (215) 822-2676 alt: (856) 424-5643 [email protected]

current records should be maintained at facility; if not,

contact the following (provided by Michael

Hawksley):

Mr. Ralph Sepe Director, Risk Management

tel: 800-726-1300

Jeff will proactively initiate Conf Agrs for all known PSC facilities with copies furnished to affected contractors so that they know they are in the works.

All draft reports to be conveyed to facility POC only.

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RSR Corporation(Revere Smelting & Refining; Quemetco)

Ms. Therese "Terry" Cirone Revere Smelting & Refining - RSR (Quemetco) Corporation 2777 Stemmons Freeway Suite 1900 Dallas, TX 75207 tel: (214) 583-0232 fax: (214) 631-6146 [email protected]



Jeff will proactively initiate Conf Agrs for all known RSR facilities with copies furnished to affected contractors so that they know they are in the works.

All draft reports to be conveyed to facility POC and to Ms. Terry Cirone, the RSR corporate POC; comments will be returned by facility POC, and separately, any additional comments provided by corporate POC will be returned to the contractor within one business day of receipt of facility comments.

Rineco

Mr. Monte Dilick Vice President Sales and Marketing Rineco Chemical Industries, Inc. 1007 Vulcan Road Haskell, AR 72015 tel: (501) 778-908 fax: (501) 778-8505 [email protected]

contacts are identical

Jeff will proactively initiate Conf Agr for Rineco with copy furnished to affected contractor so that they know they are in the works and can be completed well in advance of the site visit

All draft reports to be conveyed to facility POC only

Republic Services (includes all former Allied Waste Industries; Republic; and BFI facilities)

Mr. Tony Walker Republic Services 18500 N. Allied Way Phoenix, AZ 85054 tel: (480) 627-2700 x7088 fax: (480) 718-4160 [email protected]

Tony Walker can assist with insurance coverages per

facility

Jeff will proactively initiate Conf Agrs for all known Republic Svcs facilities with copies furnished to affected contractors so that they know they are in the works.

All draft reports to be conveyed to facility POC and to Mr. Tony Walker, the AWIN corporate POC; comments will be returned by facility POC, and separately, any additional comments provided by corporate POC will be returned to the contractor within one business day of receipt of facility comments.

Safety-Kleen (all) None current records should be

maintained at facility; contact Jeff Sacre if not

None required at present. All draft reports to be conveyed to facility POC only.

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United Oil Recovery, Inc. [applies to: Bridgeport United Recycling, Inc. (Bridgeport, CT); United Oil Recovery (Meriden, CT); Norlite Corporation (Cohoes, NY); Environmental Compliance Corporation (Stoughton, MA)]

Mr. Rick Baker Environmental Compliance United Oil Recovery, Inc 47 Gracey Avenue Meriden, CT 06451 tel: (203) 334-1666 [email protected]



Jeff will proactively initiate Conf Agrs for all related facilities with copies furnished to affected contractors so that they know they are in the works.

All draft reports to be conveyed to facility POC only

Waste Management/ Chemical Waste Management (all)

Ms. Karie Bright Mgr, Compliance Audit Services Waste Management, Inc. 1001 Fannin Suite 4000 Houston, TX 77002 tel: (832) 457-5166 fax: (713) 286-7447 [email protected]



Jeff will proactively initiate Conf Agrs for all known Chem Waste and WMI facilities with copies furnished to affected contractors so that they know they are in the works.

All draft reports to be conveyed to facility POC and to Ms. Karie Bright, the WMI corporate POC; comments will be returned by facility POC, and separately, any additional comments provided by corporate POC will be returned to the contractor within one business day of receipt of facility comments.

We will identify all those facilities included for 2012 FRP reviews known to be affiliated with these parent companies. If you discover that a facility that you are reviewing is affiliated with one of these parent companies, and that facility has not previously been recognized as such (e.g. apparent from CHWMEG naming convention for facility), please advise Jeff Sacre ASAP so that we can promptly create and distribute the confidentiality agreements. Confidentiality agreements for any other facilities will be promptly addressed upon request.

VERSION 2012 – DO NOT DELETE THIS HEADER!

Facility Name – City, State i Month DD, YYYY

EXECUTIVE SUMMARY Facility Information: Facility Name Address City, State Zip fon (xxx) xxx-xxxx fax (xxx) xxx-xxxx Facility POC: POC Name POC Title Performed by: Name Contractor Company Site Visit Date: Month, DD, YYYY I. Facility Operations/Site History/Design: Facility Operations: This first paragraph describes the name of the facility, facility affiliation, what the facility does (i.e., is it a landfill, incinerator, etc.), its physical/geographic setting (including proximity to nearby towns, residences, waterways), and its operating hours and current staffing. Describe the size of the property and the amount of property used for waste treatment operations (total and active acres). Mention whether the facility’s property is owned or leased, and whether there are other related or unrelated tenant activities occurring on the property. Briefly note nearby population within 0.5-miles and 1-mile. This second paragraph describes what the facility is actually permitted to do – and includes a listing of the various waste management operations conducted at the site. Not a detailed description of the processes (that is saved for the design section), but a general description so the reader knows at the start of the second paragraph what the facility actually does. The third paragraph should describe the types of wastes accepted at the site (and not accepted at the site). It should also include a summary of the total amount of wastes processed/received in the prior calendar year. The fourth paragraph describes how wastes are transported to the site (company trucks, third party trucks, rail, spaceship, etc.), as well as how they are received at the site (containers, bulk solid, bulk liquids, etc.), and how they are transferred while on-site. Issues related to on-site movement and inventory vs. storage capacity should be included here. On- and off-site (non-contiguous) staging areas should be addressed here. The fifth paragraph summarizes the waste acceptance procedures, as well as the waste receipt procedures, including a description of any on-site laboratory operations. The sixth paragraph summarizes how residual wastes are managed at the site. Site History: The first paragraph(s) should describe the general history of ownership and operations. The subsequent paragraphs should describe historical contamination or other issues. The last paragraph should summarize whether there have been any major fires, spills, explosions in the last five years. Any remarkable issues about fire protection systems, fire response and coordination with local emergency responders, self-response (having own fire responders on-site), etc. should be described here.


Facility Name – City, State ii Month DD, YYYY

Design: First paragraph should briefly describe the main features of the site (paved, fenced, buildings, and the main processing areas). Next paragraph should describe receiving and storage areas (both container and bulk, including tanks), and include information about containment provided for those areas. Subsequent paragraphs should describe the design and operation of each of the major waste management operations at the site. Provide a separate paragraph for each operation. This information comes from the C sections of the questionnaire. Next to last paragraph should describe pollution controls (or lack thereof) including air/water/etc., if not already discussed in prior paragraphs about the major waste management operations. Last paragraph should describe how stormwater is managed. Noteworthy Items:

• The first bullet item should be a summary of how site operations (acceptance programs, residuals management, training, inspections, safety performance, regulatory performance, etc. compare to state of the art, or summarize where things are not SOTA. A great summary bullet about operations.

• The second bullet item should be a summary of how site design (containment, controls, processes, equipment, etc.) compare to SOTA, or not. Again, a great summary about the overall design.

• The third bullet item should summarize the potential for spills and releases, and what measures are in place to minimize spills and releases (or not). Another great summary.

• The fourth bullet should summarize fires, explosions, spills, releases in the last five years and their impact on site operations and the environment – if none, so state it.

• The fifth bullet should summarize the employee safety performance of the site – DART rate, number of injuries, and type of injuries (i.e., slip and fall vs. chemical exposure).

• The sixth bullet should describe the general condition of the site observed during the site visit – housekeeping, odors, stains, condition of equipment etc.

• Remaining bullets to describe many other pertinent operations/history/design aspects not included in the first six bullets.

II. Regulatory Compliance: The regulatory compliance paragraph should identify who regulates the facility, and provide a summary of the permits (with expiration dates). The permit summary should identify the relevant/issuing agency for each. Noteworthy Items:

• The first bullet should indicate the frequency of regulatory inspections by each regulator, and when the last inspection was conducted.

• The second bullet should provide a summary of all recent compliance inspections, including a list of NOVs. A separate bullet should be used for each regulatory agency or media – i.e., a bullet for waste, a bullet for air, etc.

• The third bullet should provide a summary of any consent orders, or fines paid by the facility. • The fourth bullet should provide a summary of the response from regulators contacted about the

site. • The fifth bullet should provide a summary of any pending permit revisions or renewals. • The sixth bullet should identify if there is any pending or proposed regulations that would impact

site operations in the future. • Remaining bullets provide other pertinent regulatory related information.


Facility Name – City, State iii Month DD, YYYY

III. Site Geology/Groundwater: Site Geology and Groundwater: The site geology and groundwater paragraph(s) should provide a general summary of the geology and hydrogeology, including nature of underlying geology (sediments, fractured bedrock, etc.) and underlying aquifers. Depth to water table and depth to major aquifers should be specified in this paragraph. Comment on the general terrain of the area (landscape). Noteworthy Items:

• The first bullet should identify if site-specific geology/hydrogeology information is available (or not). • The second bullet should identify the nature of the potable water supply for the site and

surrounding areas – this should include the provider, source of water, and distance from the site of water sources.

• The third bullet should identify if groundwater monitoring is (or ever has been) conducted at the site (or not), and provide details of the monitoring program – number of wells, frequency of sampling, sampling parameters, etc.

• The fourth bullet (or more) should identify the nature and extent of any groundwater or soil contamination found at the site, as well as any corrective actions currently underway, planned, or completed.

• The fifth bullet should summarize any nearby sources of contamination that may impact the site, if any.

• Remaining bullets provide other pertinent geology/hydrogeology related information. IV. Financial Strength/Insurance/Closure: Financial Strength: First paragraph should provide a summary of the sales, total assets, total equity, profit in current year, debt to equity ration, and current ration. Percentage changes in sales, income, net worth, and working capital (as obtained from the RAS) should be summarized. Finally, the Altman Z scores for the last three years should be provided. The second paragraph should describe how much capital investment has been made at the site in the last three years, and what capital investments are proposed for the next few years – include dollar amounts and brief description of investments. The third paragraph should describe any litigation, PRP involvement, and other environmental financial obligations of the facility (or parent company). Insurance: The following insurance policies and coverage are in effect:

• General Liability coverage at $X million (aggregate) and $X million (each occurrence). • Automobile Liability coverage, at $X million (combined single limit). • Excess Liability coverage at $X million (each occurrence/aggregate). • Workers Compensation coverage at $X million each accident. • Environmental Impairment Liability or Pollution Legal Liability coverage at $X million (each

occurrence/aggregate). This policy has a deductible or self-insured retention of $X. Indicate the current expiration date of coverage Closure/Post-closure: First paragraph should provide a summary of closure activities, including requirements for financial assurance, amount of financial assurance, type of financial assurance mechanism, and brief summary of things covered (or not covered) under closure. Second paragraph should provide a summary of post-closure activities (including length of post-closure activities), including requirements for financial assurance, amount of financial assurance, type of financial assurance mechanism, and brief summary of things covered (or not covered) under post-closure. Describe any units already in post-closure care.


Facility Name – City, State iv Month DD, YYYY

V. Third-Party Certification/Management Personnel/Community Relations/Security: Noteworthy Items:

• First bullet – provide a summary of how the facility participated in the CHWMEG review (i.e., cooperative, timely document submission, responsive, combative, etc.)

• Second bullet – provide a summary of whether or not the facility conforms to any ISO or similar management standard, or has any other management systems in place.

• Third bullet – provide a summary of management qualifications, staff turnover, labor relations, etc. • Fourth bullet – provide a summary of the types of training conducted at the facility, and describe

any emergency drills/planning conducted at the site (include date of last emergency drill) • Fifth bullet – provide a summary of the types of inspections conducted at the site. For

inspections, briefly describe: via regulatory agencies, use of corporate resources, related to conformance with third-party certification, etc.

• Sixth bullet – provide a summary of primary emergency equipment available at the site, and current status of emergency plans/contingency plans (dates of last revision)

• Seventh bullet – provide a summary of any auditing functions conducted at the site. • Eighth bullet – provide a summary of community relations – complaints, opposition, community

programs, media coverage. • Ninth bullet – provide a summary of the site security measures – perimeter controls, access

controls, surveillance, and other special security features. • Remaining bullets provide other relevant information about management, community relations,

security, etc. VI. Significant Facility Modifications or Changes Since CHWMEG’s Month, Year Facility Review: Operational or Technology Changes: In this section, please indicate any operational changes that have taken place which directly affect operations at the facility. Examples would include the addition of processing units, such as an increase in the number of cement kilns at the facility which process hazardous waste fuel in their operation. Another example would be the installation and operation of an acid liquid waste processing operation that previously was not included in the facility’s capabilities. Approval to accept and process additional waste streams, as may occur through a permit revision would also exemplify information which should be mentioned. Use a bullet list. Similarly, the removal or deletion of technologies or processes should be mentioned. An example would be that the facility has no longer operates an on-site incinerator (explain if the unit remains on site for potential future use, has been permanently shut-down, or has been removed from the site). Please do not include mention of corporate changes (i.e. capabilities or changing capabilities of other facilities within the corporate structure). It would be acceptable to mention alliances that the facility may have implemented during the hiatus (e.g. all blended fuels are now shipped from this facility to the XYZ cement kiln – Springfield, IL whereas previously blended fuels were shipped to ABC or were sent to various facilities for energy recovery). Facility Status Changes: In this section, please summarize the significant changes at the facility with regard to environmental compliance or environmental risk since the previous CHWMEG evaluation. Permit extensions, expansions, or renewals are the regulatory focus of this section. However, in the event of significant NOVs or compliance problems since the previous review, this information should also be conveyed. Similarly, any changes in potential environmental risk, including that not necessarily tied to regulatory compliance, should be mentioned here. If these issues are summarized above in the operational Noteworthy Items, it is not necessary to restate them here. Use a bullet list. [NOTE TO CHWMEG FACILITY REVIEWER: IF FACILITY HAS NOT BEEN RECENTLY (within past 5 years) REVIEWED BY CHWMEG, REPLACE SECTION VI WITH (be sure to delete this text):]


Facility Name – City, State v Month DD, YYYY

VI. Significant Facility Modifications or Changes Since CHWMEG’s Most Recent Facility Review: Not applicable; this facility has not been reviewed by CHWMEG within the past five years. OR: Not applicable; this facility has never been reviewed by CHWMEG. [NOTES (Delete this section from submissions):

• The Executive Summary should be at least 4 pages, and no more than 8. • Always follow the layout of the template provided for the most recent Executive Summary. • Include pertinent information that accurately describes operations, regulatory compliance,

geology, finance, management, and changes. The reader should know what activities are conducted after reading the Executive Summary

• Do not include references to attachments, unless absolutely necessary.]

EXECUTIVE SUMMARY

Facility Information: Facility NameStreet AddressCity, ST 00000 fon: (xxx) xxx-xxxxfax: (xxx) xxx-xxxx

Facility POC: First LastFull Title

Performed by: John DoeEnvironmental Contractor, LLC

Date of Inspection: July 8, 2011

I. Facility Operations/Site History/Design:

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II. Regulatory Compliance:

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III. Site Geology/Groundwater:

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July 8, 2011


Clean Harbors Environmental Services, Inc. Kimball, NE i March 23, 2011

EXECUTIVE SUMMARY Facility Information: Clean Harbors Environmental Services, Inc. (CHES) 2247 South Highway 71 Kimball, NE 69145 fon (308) 235-4012 fax (308) 235-4307 Facility POC: Danielle Reader Compliance Specialist Performed by: Auditor Name Auditor Company Site Visit Date: March 23, 2011 I. Facility Operations/Site History/Design: Facility Operations: Clean Harbors Environmental Services, Inc. (CHES), a wholly owned subsidiary of publicly owned Clean Harbors Inc. (NYSE: CLH), operates a thermal oxidation unit (TOU, i.e., incinerator) facility for both hazardous and non-hazardous waste destruction near Kimball, Nebraska. The facility site is situated in a very rural agricultural region in the grasslands of western Nebraska, approximately 5 miles south of Kimball (population 2,600), 60 miles east of Cheyenne, WY, and 165 northeast of Denver, CO. CHES currently operates on a company owned 640-acre tract, of which the main operations portion of the facility is situated on 11 acres, the ash monofill encompasses 64 acres, and the remainder is buffer around the facility. Surrounding land uses within 5 miles include agricultural and grazing lands, small oil wells, and nuclear missile silos. There are approximately 30 residents living within a 3 mile radius of the facility. The facility operates 24 hours per day/7days per week, and currently employs 115 people. The CHES facility is primarily a TOU operation with an on-site landfill dedicated for ash disposal, but also operates as a containerized waste storage and transfer facility. The TOU operation consists of pre-treatment in the form of consolidation and shredding of dry and wet solid materials (i.e., size reduction to allow the waste to be efficiently fed into the TOU), and bulking and blending of liquid wastes prior to conveyance for combustion in the TOU. Ash from the TOU is stabilized or fixated to meet delisting requirements prior to disposal at the on-site monofill. Wastes are received in drums, totes, roll-off bins, tank trucks, dump trucks, vacuum trucks, vans and trailers. Most D-listed, F-listed, K-listed, P-listed, and U-listed wastes are acceptable for incineration at the site. Typical waste streams include contaminated soils and debris, waste sludges, energetic liquids, lean waters, and direct burn materials, including off-specification consumer products (non-hazardous). The facility burned over 44,000 tons of waste in 2010, and also handled over 42,700 containers as part of its storage and transfer operation (which is mostly a 10-day storage operation). Approximately 90% of incoming waste is transported by 3rd party transporters, with the remaining 10% by CHES equipment. With respect to liquid wastes, approximately 50% of the incoming liquid waste to the facility is via rail transfer at a separately permitted siding in Sterling CO (owned and operated by Clean Harbors – primarily bulk waste). Another rail siding is maintained in Kimball for bulk solids and drum off-loading, but its use is very infrequent. The facility maintains a very thorough waste prequalification process. All waste profiles are initially reviewed by the corporate CHES profiling group, which identifies the CHES facility which is most appropriate for handling the waste stream. After designation by the corporate profile group, the on-site staff is consulted to ensure that the facility can handle the waste from an operations, capacity, and treatment perspective. There is also a very detailed waste receipt procedure, and 100% of incoming


Clean Harbors Environmental Services, Inc. Kimball, NE ii March 23, 2011

wastes (except those stored for off-site transfer) are sampled and analyzed (Great Eight fingerprint analysis) in either the drum warehouse satellite laboratory or the fully equipped main on-site laboratory. The primary residual wastes generated from the TOU operation, including delisted bottom and fly ash, refractory, and fluidized bed residuals are disposed in the on-site monofill. Other TOU operation wastes, including process waters, are also treated in the TOU. Landfill leachate, and storm-water from process areas is collected and evaporated on-site using dedicated evaporation basins. Non-processable solids from TOU operations, non-reusable containers, and ash that does not meet delisting requirements are disposed off-site at one of the Clean Harbors Subtitle C landfill facilities in Deer Trail, CO, Grassy Mountain UT, or Lone Mountain, OK, and reusable empty containers are sent off-site for recycling at Industrial Container Services (Chicago, IL). Non-hazardous office trash is sent to the nearby Kimball City Landfill for disposal. Finally, the facility uses a wide variety of approved designated facilities for outbound material that is transshipped from the site. The approved list is maintained by Clean Harbors corporate management, and all facilities are subject to periodic corporate audits to ensure suitability for use. Site History: AMOCO Oil Company purchased the site in 1988 and started construction of the incinerator in 1989 on former agricultural lands. The facility was primarily designed to handle waste streams generated by AMOCO operations in North America, including chemical waste, high BTU and lean liquids, and contaminated soil. Initial shakedown operations began in 1993, and trial burn tests commenced in 1994 – the permit capacity test burn was completed in December 1994. AMOCO activities were originally conducted under the name of Waste-Tech Services (WTS); AMOCO changed the facility name to ECOVA in 1994, reportedly to avoid any confusion with the WTI incinerator in East Liverpool, Ohio. Clean Harbors purchased the facility on May 12, 1995, and has operated it since that time. Ash from incinerator operation has been disposed in the onsite monofill since incineration operations began in 1994. Monofill Cell 1 and Cell 2 are now closed and capped (an alternative final cover (ET Cover) was installed on Cell 1 in 2005 and on Cell 2 in fall of 2007). Cell 4 was completed and began receiving waste in late spring 2006. Ash is considered delisted according to State of Nebraska regulation if it meets certain analytical requirements; ash that does not meet requirements must be stabilized prior to disposal in the monofill. Cell 5 will be constructed in summer 2011. Cells 3 and 6 are permitted but have not yet been constructed. It is unknown if any type of environmental assessments have been done at the facility beyond the soil and groundwater monitoring that is routinely conducted as part of permitted operations. The facility has not been subject to any RCRA corrective action studies. There is no history of major releases, spills, fires, or explosions, although there have been minor fire incidents (mostly associated with shredder operations) since waste management activities began in 1990. Design: The CHES Kimball facility has several major operations: Waste Storage – Drum storage is conducted both outside and inside of buildings. Outside storage is in designated areas (mostly staging for processing) that are paved and have secondary containment features. Waste containers are segregated based upon DOT description and waste compatibility. Containers are on pallets and are stacked no more than two high. Most containers are 55 gallons in size, although smaller containers and IBCs may also be received and staged. Inside container storage is conducted primarily within the fully enclosed Area 57 Warehouse. The container unloading area (and 10-day transfer storage area) has floor trenches and sumps to contain any spills (Area 57A), and all containers destined for on-site storage are stored on 3-tiered rack systems with independent spill bins for collection of any spills (Area 57B). All containers are segregated by waste type and compatibility. Containers are stored in the racks on pallets, and are stored no more than one high on the pallet (large containers). There is automatic fire suppression on each level of the racks. The concrete in this area also has been treated with a special penetrate to protect the pavement. The facility


Clean Harbors Environmental Services, Inc. Kimball, NE iii March 23, 2011

is permitted to store 16,626 drum equivalents in five separate storage areas (Areas 25, 40, 50, 57, and 95). Bulk container storage (roll offs) is all conducted outdoors. Bulk container storage areas are concrete (exception - rolloffs with stabilized incinerator ash are staged over gravel), and some rolloffs with waste are staged for off-site transfer stored over dirt, in the RCRA permitted 90 day storage area. One bulk container area is permitted for free liquids and has secondary containment. The facility is permitted to store 640 twenty cubic yard equivalents in three separate storage areas (Areas 25, 70C, and 95. There is also a liquid waste storage tank farm (permitted storage capacity 240,000 gallons), which consists of 14 above-ground storage tanks ranging in size from 600 gallons to 20,000 gallons, all situated within a secondary containment structure. Incinerator waste tanks have high level alarms and also have nitrogen blanketing and are vapor balanced – vapors route to the incinerator or to an activated carbon vessel when the incinerator is offline. There are also 5 other ASTs at the site used for water and wastewater storage, as well as diesel fuel for incinerator operations. Water and diesel tanks vent to the atmosphere, and wastewater and diesel tanks also have secondary containment structures. Waste Processing – All waste processing is conducted inside covered buildings, all of which have secondary containment structures as well as air pollution control devices. Both container and bulk solids (either dry or wet) are processed initially by mixing and/or shredding and screening, prior to conveyance to the TOU on conveyors for direct burn. Vapors from the waste processing areas are routed through particulate control and carbon adsorption or vented directly to the TOU. Thermal Oxidation Unit Operations – The on-site incinerator is a fluidized bed unit that measures 7’ x 15’ in rectangular cross section and is about 5’ deep. The bed holds approximately 90,000 pounds of inert granular silicate. Waste is fed directly into the middle of the fluidized combustion bed, and low pressure air is distributed uniformly across the bed to provide the fluid effect. A unique cone-within-cone design at the base of the bed permits the removal and recycling of the bed material while ash is carried out of the unit in the gas stream. The rated heat release is 40-70 million BTU/hr, and the bed temperature is maintained at 1400 - 1600 degrees F. Air pollution controls on the incinerator include a spray dry absorber, a carbon injection system, and a bag house prior to exhaust through a 140 foot high stack. All incinerator operations are computer controlled with multiple safety interlocks and automatic shutoff controls, as well as continuous air emissions monitoring which is also available for real-time off-site monitoring by the regulatory agency. All ash generated from the TOU must pass TCLP testing prior to on-site landfill disposal. The ash is stored in day bins prior to treatment in a dedicated ash treatment building. All ash is subject to rehydration and stabilization (if necessary) using fly ash, lime, cement kiln dust or other stabilization reagents and are allowed a two-day curing period prior to disposal. Landfill - The facility currently operates a monofill disposal area for the disposal of TOU generated solid wastes. The facility is currently disposing waste in Cell #4, and a new cell (cell #5) will be completed later in 2011. Cells #1 and #2 have been closed, and Cell #3 and Cell#6 have not yet been constructed. The current and future cells have a design capacity of 116,000 cubic yards each. The estimated remaining life of permitted landfill cells is in excess of 10-20 years, with substantial room for additional expansion if necessary in the future. The liner consists of a double layer of geosynthetic clay liner (GCL) at the bottom, overlain by a secondary (40 mil HDPE) and primary (60 mil HDPE) liner system. There is also a leachate collection system installed above the primary liner. Leachate is manually pumped out and evaporated in a nearby lined impoundment. Finally, all active area storm water (i.e., storm water that falls within containment of outdoor storage areas, as well as driveway areas) is collected and pumped to holding tanks and subsequently reused in the TOU process. Non-active area storm water is also collected and placed in a lined impoundment for evaporation. There is generally no storm water discharge from the facility. Noteworthy Items:


Clean Harbors Environmental Services, Inc. Kimball, NE iv March 23, 2011

• Site operations generally reflect state-of-the-art (SOTA) with respect to waste prequalification, waste receiving, and on-site waste tracking procedures (bar codes), capable on-site laboratory operations, highly experienced and long term staff, management of most residual wastes on-site, relatively good regulatory compliance record as well as good safety record and additional emphasis on health and safety programs (including OSHA VPP Star program designation). Although there is no formal environmental management system, the existing internal corporate management system appears suitable for this facility. Periodic minor fires in the waste processing areas require diligent monitoring, although most do not cause any stoppage of main operations.

• The facility has been operating for approximately 15 years, so the design of most operations is also considered SOTA with respect to thermal oxidation technology (the only commercial fluidized bed incinerator in the USA), automated incinerator controls, the use of spill prevention and containment structures facility wide, on-site ash management, tank storage systems that use inert gas for fire protection, and landfill liner design. Containerized waste is stored primarily indoors, although there are outdoor staging areas, and all bulk waste is also stored outdoors. Further, a new shredder operation has been planned that will incorporate inert gas blanketing for fire protection - this will eventually replace the existing shredder operation which is prone to periodic minor fires.

• The potential for spills or releases from waste handling and transfer operations at the site is considered low. Although there is a large quantity of waste in storage at the site at any given time, all main waste storage and processing areas are situated within buildings or within secondary containment. All liquid pipelines and waste conveyors are above grade for ease of monitoring and inspection. Although some bulk solids are stored in areas outside of containment, any spills from these containers can be easily remediated.

• In June 2009 the facility received the “Star” designation from the Occupational Safety and Health Administration (OSHA) Voluntary Protection Program (VPP) for its Treatment, Storage, and Disposal Facility (TSDF) here. This is a move up from the “Merit” designation earned by the facility in 2008. The Star Designation is OSHA's highest recognition for meeting or exceeding workplace safety and health standards. Companies in the VPP achieve average injury and illness rates at least 50 percent below the Bureau of Labor Statistics average for other companies in their respective industries. The Kimball Facility is the first Hazardous Waste Incineration facility in the United States to make this designation. The facility DART incidence rate for 2008 through 2010 has been well below the industry average for NAICS 5622 (Waste Treatment Disposal).

• Minor fires periodically occur at the site, primarily associated with the waste shredding process - however the fires in the past have not required implementation of the Contingency Plan, and there have been no injuries or major equipment damage to date. All fires are routinely put out by onsite personnel. There were two shredder fires reported in 2010 and only one fire reported to date in 2011. There were a total of 9 fires in 2009.

• The laboratory is currently accredited (renewed April 2009) through the National Environmental Laboratory Accreditation Program (NELAP) with accreditation in Utah and Texas. Note that the State of Nebraska has no accrediting authority, but does recognize the NELAP accreditation authority of other states. The Texas and Utah accreditations have been obtained since the on-site laboratory provides analytical support to other Clean Harbors facilities in those states.

• A new shredding tower operation has been designed to be constructed adjacent to the Area 57 warehouse building, however, the capital funding to construct this project has not yet been appropriated. It is uncertain when this new processing facility will be constructed. The new shredding tower will replace the existing shredding operations in Area 55 once it is completed in the future.

• The CHES facility is the only TSDF in Nebraska, and the ash delisting regulation was written exclusively for this facility. Many of the delisting levels included in the Nebraska administrative code for certain parameters are substantially higher than the RCRA Land Disposal Restriction (LDR) Universal Treatment Standard (UTS) for those parameters. Consequently, although this waste can be disposed in the on-site monofill as allowed under the Nebraska code, this waste would possibly not meet LDR requirements for disposal at an off-site hazardous waste landfill Subtitle C landfill facility without additional pre-treatment prior to disposal.


Clean Harbors Environmental Services, Inc. Kimball, NE v March 23, 2011

II. Regulatory Compliance: Operations at the facility are regulated primarily by the Nebraska Department of Environmental Quality (NDEQ), and CHES maintains a Part B equivalent RCRA permit for a hazardous waste management facility (expires May 2014); a Permit to Operate a Class 1 Title V Contaminant Source (expires August 2014); a NPDES permit (expires December 2014); a Soil Permit to accept USDA regulated soil (expires December 2012); and a solid waste management permit for the landfill (expires November 2014). The facility is subject to semi-annual inspections by the regulators. Most inspections are conducted by the NDEQ, but USEPA (Region 7) also conducts periodic inspections alone or with the NDEQ. The most recent NDEQ inspections were conducted in March 2010 and March 2011, and USEPA conducted an inspection in July 2010. Noteworthy Items:

• The NDEQ conducts frequent inspections, and there have been mostly minor notice of violations (NOV) and areas of concern identified during nearly every inspection, most of which are quickly resolved. For example, the NDEQ March 2010 inspection identified 5 violations (including failure to properly mark 90-day accumulation containers, failure to conduct daily inspections, failure to mark miscellaneous units, and failure to comply with maximum permitted pumping rate for the TOU. In all cases the facility responds to the issues within 30 days of a NDEQ notice, and NDEQ subsequently issues documentation in each case that all compliance issues were fully addressed. The NDEQ regulators contacted about the facility indicated that there are currently no major outstanding compliance issues, although there were some minor issues identified in the March 2011 inspection.

• The facility is currently under a compliance order issued by the USEPA in June 2010 related to violations documented by USEPA in September 2007 and NDEQ in April 2008. CHES was assessed a $150,000 penalty under the compliance order. The order remains open.

• USEPA also issued a NOV in July 2010 following an inspection that identified improperly closed containers, improper Subpart BB tagging, containment coating cracks, documentation deficiencies for waste storage, and incompatible waste storage. The issues were resolved reportedly without penalty after written response and documentation of corrective actions.

• The NDEQ Air Quality Division issued a NOV in March 2010 for failure to achieve the mercury emission limit during the October 2009 Hazardous Waste Combustor maximum achievable control technology MACT Comprehensive Performance Test (CPT). The facility performed a re-test in February 2010 and the mercury emission limit was demonstrated. No further action was required. Note that the last MACT CPT was performed in 2004.

• The facility entered into an Expedited Settlement Agreement with the EPA for failure to file a Risk Management Plan (RMP) update on March 29, 2010 and was fined $1200. Plan was filed on time in 2009, but it was apparently was lost in the EPA Central Data Exchange (CDX) system and was not certified. This issue is now fully resolved.

• All NDEQ and USEPA regulators contacted indicated that the facility is cooperative with regulators.

• The results of the annual stack testing conducted in December 2010 demonstrated that the unit is operating in compliance with most applicable state and federal permit requirements. However, there was a failed RCRA dioxin emission limit, the cause of which has not yet been determined. NDEQ issued a notice of violation on March 8, 2011 for a violation of the dioxin emission limit - note that three tests were conducted, and only one exceeded the limit. The NDEQ has not yet received a response from Clean Harbors on the NOV regarding this dioxin emission limit exceedance.

• In addition to the required stack testing, the operating permit requires the assessment of surficial soils in each major drainage area of the facility and at locations to which represent the maximum receptors from TOU operations. The facility samples surface soil for contaminant deposition at five areas every five years and two areas out of the five every quarter. Analyses are for semi-volatiles (including dioxins), metals and phosphates. There have been no depositional issues


Clean Harbors Environmental Services, Inc. Kimball, NE vi March 23, 2011

identified since sampling began in the 1990’s except for occasional detections of phosphates, which may be due to prior fertilizer use. The most recent sampling event conducted in December 2010 indicated no SVOCs were detected above their limit of quantitation, and metals were not detected above regional background levels.

III. Site Geology/Groundwater: Site Geology and Groundwater: The facility is covered by a thin deposit of very fine, moderately silty sand. The Ogallala Formation underlies the facility. It consists of alternating layers of clay, silt, sandstone, and sand and gravel. The beds of sandstone, sand, and gravel, where they are filled with groundwater, are not tightly connected and provide the high yield drinking water sources in Kimball County. The depth to water at the site is approximately 140 feet below ground surface (bgs). Note that the facility conducts groundwater monitoring at the site with wells screened between 150’ and 180’ bgs. The Ogallala Formation is an important aquifer in the vicinity of the facility. It supplies water to all wells on the upland, including a few large discharge wells, and many public-supply and irrigation wells in the area. It is the only source of water for several towns in the region, including Kimball. The town of Kimball has 14 municipal wells ranging in depth from ~50’ bgs to 367’ bgs. In addition, there are a number of domestic wells in the aquifer in the general vicinity of the facility, one as close as ½ mile from the site. The depths of these wells are typically between 100’ and 400’ bgs, but can be as shallow as 50’ bgs. Noteworthy Items:

• The geology and hydrogeology of the site have been well characterized as part of the original facility siting process and on-going investigations, and were considered to be conducive for this type of waste treatment and disposal facility.

• The facility is subject to ground water monitoring as part of its operating permit, and maintains 5 wells that are sampled annually. The 2010 Annual monitoring report concluded that facility operations to date have not impacted the groundwater beneath the facility. All current groundwater data are compared to baseline data that were collected in 1993 prior to the start of site operations.

IV. Financial Strength/Insurance/Closure: Financial Strength: Parent company Clean Harbors Inc. had sales of $1.731 billion United States Dollars (USD) in 2010, with total assets of over $1.6 billion USD, and total equity estimated at nearly $781 million USD. It earned over $130 million USD in 2010, and had a profit margin ratio of 8%. The company debt-to-equity ratio is 1.05, and the current ratio is 2.46. During the period 2009 through 2010, Clean Harbors realized a 61% increase in sales, a nearly 256% increase in income, a 27% increase in net worth, and the working capital increased over 15% during that period. Altman Z scores for 2008 through 2010 were 4.25, 3.27, and 4.21, respectively. The company has invested several million dollars in capital improvements at the facility in the last three years (including the new container warehouse and associate buildings), and has new capital expenditures planned for the coming years (new landfill cell, new shredder operation, new TOU control room), although the investment amount was not specifically provided. Parent company Clean Harbors had recorded $29.7 million of reserves in the Company’s financial statements at the end of 2010 for actual or potential liabilities related to the legal and administrative proceedings. However, the Kimball facility is not currently involved with any environmental litigation. Clean Harbors also estimated their remedial liability costs at the end of 2010 to be $137.6 million in terms of present value, and has been named as a PRP in connection with 62 sites. Closure and post closure costs (present value) accrued on the 2010 balance sheet were estimated to be $38.6 million, with about


Clean Harbors Environmental Services, Inc. Kimball, NE vii March 23, 2011

78% associated with landfill operations. The total amount of the closure and post-closure financial assurance which Clean Harbors is required by regulators to provide is approximately $324.4 million for U.S. facilities and $22.4 million for Canadian facilities. Note that the total liability currently accrued for all environmental liabilities (~ $176 million) is only 36% of the actual estimated cost for closure, post-closure and remedial liabilities (~ $484 million) going forward for all Clean Harbors facilities. Insurance: The following insurance policies and coverage are in effect:

• General Liability coverage at $3 million (aggregate) and $2 million (each occurrence). • Automobile Liability coverage, at $5 million combined single limit. • Excess Liability coverage at $10 million (aggregate) and $10 million (each occurrence). • Workers Compensation coverage at $2 million each accident. • Pollution Liability coverage at $10 million (aggregate) and $10 million (each occurrence). • Sudden and Non-sudden Liability coverage is covered under Pollution Liability coverage at $6

million (aggregate) and $3 million (each occurrence). Closure/Post-closure: There are two closure plans applicable for the facility - one closure plan for the main facility, and one closure plan for the monofill. The closure plan for the main facility includes disposal and decontamination specifications for the storage and process areas, TOU and off-gas treatment and discharge areas, chemical sewer system, and analytical laboratory. It also includes provisions for containment and soil sampling and analysis. The monofill closure requirements include final cover of existing landfill cells, and preparation for post-closure monitoring. The only post-closure care plan is required for the monofill, and includes maintenance of the cover systems and ground-water monitoring for a period of 30 years. As of September 2010, the total closure estimate is $16,098,051 for the Thermal Oxidation Unit, and $944,476 for the monofill. The post-closure cost estimate for the monofill is $2,426,987. Financial assurance is funded by an insurance policy. Note that unit costs for the closure/post closure were most recently updated as part of the new 2009 permit, and the estimate was updated in 2010 to reflect the new permitted storage warehouse. V. Third-Party Certification/Management Personnel/Community Relations/Security: Noteworthy Items:

• The facility staff enthusiastically supported the CHWMEG review, including the prompt update of the questionnaire and providing access to multiple staff for support during the CHWMEG site visit.

• Clean Harbors does not have any third party certified ISO or similar management systems, however, it does have established procedures for all aspects of the operation, as well as an internal and corporate auditing program which collectively comprise an equivalent environmental management system. All Clean Harbors facilities also participate in the corporate “Best in Class” management system. However, the facility is currently developing an environmental management system (EMS), and expects to roll out the plan over the next two years.

• The facility conducts a wide variety of training, and all training activities are documented according to the permit and corporate requirements. There is also a dedicated on-site training manager whom is responsible for executing all the required training programs at the facility.

• The facility RCRA Contingency Plan was last updated in January 2009, and the last emergency drill was conducted in December 2010. The facility has extensive on-site emergency response capabilities.

• CHES is required by permit to conduct a variety of documented daily, weekly, monthly, quarterly, and annual inspections. In addition to the internal inspections and audits, the facility is also subject to CHES corporate audits every 2 to 3 years for both environmental and health and safety – the last corporate audit was conducted in July 2010. Note that the internal audit findings are handled through the CHES legal department.


Clean Harbors Environmental Services, Inc. Kimball, NE viii March 23, 2011

• There is no recent record of public complaints or opposition to the CHES operations at this location. There were no public comments against facility operations during the most recent permit renewal public comment period. Further, the facility also funds a Citizen’s Monitoring Committee to oversee activities at the facility. The group meets once per month to discuss facility activities.

• The incinerator facility and the monofill are separately fenced. Each barrier consists of a 6’ high chain link fence with 3 strands of barbed wire. The access to the incinerator facility is controlled through the security gate staffed 24 hours per day/7 days per week. There have been no security incidents at the facility in the last five years.

VI. Significant Facility Modifications or Changes Since CHWMEG’s April 2010 Facility Review: Operational or Technology Changes:

• A container storage building for oxidizers (Area 57D) and a thaw building (Area 57F) remains under final construction, and are expected to be completed and permitted by late 2011.

• The air collection system employed at Area 55 (shredder operation) is now connected to the incinerator for direct treatment of the emissions generated from the shredding operation, which was previously handled with a scrubber system that used carbon filtration.

• The TOU control room equipment, including all original controls and monitors from the early 1990’s, are expected to be replaced and upgraded with a Delta V control system in late April 2011 as part of semi-annual maintenance shutdown of the TOU.

Facility Status Changes: None

2012 Questionnaire/Executive Summary Changes Executive Summary New Executive Summary template that incorporates a standard list of items to include in each section by paragraph. See the new Executive Summary template (Document #14). Section A A12: Last column “Telephone” will be changed to “Telephone and E-mail” Section B B2a: Minor wording change in the instructions: “intended exclusively for disposal elsewhere” will now say “intended for onsite disposal or disposal elsewhere”. This is for clarity only; all contractors were using this approach anyway. B6g1: The question will include the link (http://www.osha.gov/pls/imis/establishment.html) to OSHA’s Establishment Search website. A quick search can find the most recent OSHA inspection and results. Section H H6e: Minor wording change in instructions: “Non-European Facilities: Answer H6e-H6g” will now say “All Facilities: Answer H6e-H6g” Various Sections: We have received a request from a few members to include some questions in various sections regarding Commercial Hazardous Waste Combustion Facilities. The list below is not final. We will update this document once the following have been considered and added to the questionnaire. Please feel free to offer any feedback on the items below.

1. A40 Management Systems – insert a question such as “how does the facility monitor applicable upcoming regulations and how does the facility keep current on new compliance interpretations of existing regulations?”

2. B1e – insert similar questions to WAP regarding the Feedstream Analysis Plan that is required under the HWC MACT.

3. B4b – add “parametric process measurements” and “continuous emission measurements.”

4. B4e3 – for combustion units “are process measurements being stored in accordance with the HWC MACT….1 minute averages and rolling averages stored each minute?”

5. C3 – somewhere in here there should be a question about whether the facility recovers energy or materials through combustion, and whether it is bona fide.

6. C4 – There should questions on energy (and materials recovery) and an evaluation of the effectiveness of the recovery.

7. C45b – should request and examine the Operation and Maintenance Plan and determine if it is being followed.

8. C47b – should request a copy of the Notification of Compliance, and Finding of Compliance (if issued by Agency).

9. C48 – should be modified to include other HWC MACT parameters, esp pressure, APC parameters, and residence time indicator.

10. C49 – should add oxygen, mercury, other metals. 11. D1 – add Clean Air Act Title V 12. D4 – add review of recent Title V compliance reports and note significant or

repeating self-reported violations, or malfunctions. (Note – HWC MACT is self-implementing wrt compliance).

13. Is facility meeting the operator training requirements of the HWC MACT?

CHWMEG, Inc. Risk Assessment System (RAS) INTRODUCTION The CHWMEG Risk Assessment System (RAS) uses TSDF information collected by the auditor to calculate quantitative environmental, operations, and financial scores for the facility. This document provides an introduction to the RAS and an explanation of model logic. The CHWMEG Risk Assessment System is a computer model designed to quantify the risk of using a particular treatment, storage, or disposal site. The principal purpose of the RAS is to provide a standardized, objective interpretation of the information gathered when auditing a facility. The RAS interprets data gathered during the audit, summarizes the interpretations and presents the summarized information in the form of scores which enables CHWMEG member companies to quantitatively judge the risks associated with a facility. The RAS produces scores, ranging from 0 to 100, which numerically quantify the risks associated with a facility in the areas described below. It is intended that the scores are approximately proportional to the risks – the higher the score, the greater the risk (i.e., 0 is the lowest risk, 100 the highest). Each individual score is the combination of several subscores. The scores are only indicators and rough measures of risk, and should be used in combination with the rest of the report as much as possible. The scoring system is described in general terms below. RAS SCORES The model produces ten separate scores:

Observed Releases Potential Releases Groundwater Groundwater

Surface Water Surface Water

Air Air

Fire & Explosion Fire & Explosion

Facility Operations

Financial Strength Observed Releases: This score is calculated as a combination of two sections – the first asks “was there a release?” and the second asks “how bad were the chemicals?” Potential Releases: This score is calculated as a combination of three subscores – Sources (technology and chemicals), Pathways, and Receptors. The logic behind the potential release score is that a release requires three conditions: a source (including both chemicals and technology), a pathway, and a receptor to be impacted by the release. Potential Air Releases and Potential Fire & Explosion Releases are the combination of two subscores, sources and receptors. No Pathway analysis is performed since it is assumed that air is a perfect medium for the transmission of releases.

Source Subscore Each existing technology at the facility is assessed according to standards for design and operation as well as the amount and type of waste disposed. The source subscore is never less than the maximum individual technology score.

Pathway Subscore The pathway subscore is based on such questions as soil type and permeability, depth to groundwater, etc. It is a weighted average of the answers from the individual questions.

Receptor Subscore The receptor subscore is a weighted average of questions concerning the population near the facility, proximity to controlled natural habitats, etc.

These subscores are combined using a geometric mean to produce the Potential Score. The technology with the highest Source score is called out by the model, since this technology has the greatest affect on the overall score. The model weights the Source and Pathway subscores more than the Receptor score. Calculating the Potential Release score as a geometric mean of the subscores allows any one of the subscores to have a large affect on the overall score. The model allows the absence of Sources or Pathways to reduce the score to zero. Facility Operations The Facility Operations score is based on six subscores. These are: 1. Operational history of the site and facility 2. Present operations at the facility 3. Facility management 4. Regulatory compliance 5. Inclusion on Superfund or NPL lists 6. Health and safety Each of these subscores is calculated as a weighted average of between one and fifteen questions. The subscores are combined using a root mean square formula to calculate the Facility Operations score. If the facility is listed as a potential or current Superfund site, this is noted separately in the RAS summary. Financial Score The financial section of the RAS uses various financial data to determine the strength of the business operating the facility and whether or not assets exceed liabilities (including environmental liabilities) should the business be liquidated. The score is based on four major areas: 1. Economic trends 2. Financial rates 3. Bankruptcy potential 4. Liquidity The financial strength score is calculated using a root mean square average of the four subscores. CONFIDENCE LEVELS The auditor is instructed to input confidence levels for each question in the RAS. These confidence levels vary between 0 and 1, and indicate the relative confidence the auditor has in each answer. A confidence level of zero indicates that the auditor has no evidence supporting the answer. A value of 0.5 indicates the question is based on the testimony of knowledgeable plant personnel, with no hard data to support it. A level of 1 indicates the answer is based on visually verified observations or inspections or well-documented reports. Values of 0.25 and 0.75, indicating intermediate confidence levels, may also be assigned. The weighted average confidence levels for each section are reported to give the reader a rough idea of the auditor's confidence in the answers incorporated into each score. FLAGS AND NOTES For the Groundwater, Surface Water, Air and Fire & Explosion Potential Release Scores, the system lists the technology that produced the greatest contribution to the Potential Release Score. For any particular score, if the minimum and maximum subscores comprising that score vary by more than 40 points, a flag to "See Detail" appears in the score summary page. This flag alerts the reader that high variability existed within the subscores, and therefore that some subscore may be considerably higher than the overall score. This is intended, again, as a flag to encourage the reader to look into the report. For example, if the groundwater potential risk technology subscore were very high (90, for example, with a landfill as the chief constituent) while the pathway and receptor scores were very low (say, 2 out of 100), the overall Groundwater Potential Score would be 11. The system flags such instances because the reader may well want to note that the RAS produced a very high risk figure for the

landfill technology (liners, wastes dumped, etc.) and the reader may want to focus attention on the descriptions in that section of the report. Finally, the system flags the Facility Operations score for facilities that are being considered or already on the National Priority List (NPL) or Superfund lists. Again, the intent is to encourage the reader to look more closely at the report summary. RAS CHARTS Eight major categories of facility types are graphed for each RAS score, with an additional category representing “other” facility types not related to the major categories. The legend further describes each category, the facilities that comprise each category, and the tally of the constituent facility types within the category. Note that wherever reviewed facilities are comprised of multiple facility types, they are counted for each applicable facility type in the legend tally. For example, a reviewed facility that is comprised of both an incinerator and a landfill will be counted toward each of these two facility types in the legend tally and the RAS graphs (counted in each the incinerator/thermal treatment and landfill categories). Wherever reviewed facilities represent multiple facility types within a given category, they are counted as such in the legend tally, but represented only once for the specific category in the RAS graphs. For example, a facility that is comprised of a hazardous landfill operation and a contiguous but separate non-hazardous landfill will be counted in the legend tally for each of these facility types, but will be counted only once in the RAS graph “landfill” category. The resulting RAS graphs are more useful, since they allow the reader to compare the facility score against other facilities within the category which offer similar services. Additionally, for facilities that offer multiple types of services, the reader can focus on the service type that most directly relates to their specific waste streams processed at the site. For example, a member that uses a facility for solvent recovery only can focus on the RAS score related to the solvent/oil recovery category. Another member using the facility for both solvent recovery and landfill services can evaluate the facility’s RAS score against both facility type categories (solvent/oil recovery and landfill categories).

CHWMEG, INC. RISK ASSESSMENT SYSTEM -- SUMMARY OF RAS SCORES

Facility: Clean HarborsLocation: El Dorado, Arkansas Note: Aside from routine QA/QC checks, this

Parent Company: Clean Harbors Environmental Services data is provided "as-is" from the auditingAudit #: H004.12 contractor. CHWMEG Inc. makes no

Audit Date: March 25, 2011 warranty to the accuracy of the data.Contractor: Contractor

Auditor Name: Name

Lower scores reflect lower risks

ENVIRONMENTAL ISSUESObserved Release: Potential Release:

Greatest Criterion Score Conf. Notes Score Conf. Contributor Notes Groundwater 85 0.75 51 0.71 Containers Surface Water 0 0.57 51 0.81 Containers * See detail Air 0 0.60 77 0.88 Tanks Fire & Explosion 0 0.91 * See detail 86 0.77 Incineration

Score Conf. Notes FACILITY OPERATIONS: 37 0.81 * See detail

Score Conf. Notes FINANCIAL STRENGTH: 41 0.97 * See detail

FY 2008 Z-Score: 4.29 FY 2007 Z-Score: 2.65 FY 2006 Z-Score: 2.38

See the description of the Risk Assessment System for information on the above scores.

Chart Legend and Distribution of FacilitiesThe description and color coding below corresponds to the legend presented on each following RAS score chart

Technology Type = This facility falls into this particular category

Fuel Blending: 110Energy Recovery: 25

Waste to Energy Plant: 10

Incineration or Thermal Treatment: 55

Landfill, Non-hazardous or MSW: 133Landfill, Hazardous: 30

Land Treatment: 12

Mercury Recycling (including lamp retort): 14Non-Ferrous Metals Recycling: 43

Ferrous Metals Recycling: 18Precious Metals Recycling: 38

Lamps Processor (crushing and sorting): 24Battery Recycling: 22

Stabilization and/or Solidification: 128

Solvent Recovery: 48Oil Recovery: 82

Storage, Consolidation and Transshipping ONLY: 72

Wastewater Treatment: 98Aqueous Neutralization or Treatment: 30

Landfill, TSCA: 9Landfill, Radioactive: 5

Transformer/Ballast Draining (PCB or non-PCB): 20Carbon Regeneration: 8

Mixed Wastes Treatment: 2Drums / Drum Reconditioning: 24

Injection Well: 13Radioactive Waste Processors: 8

Computer & Electronic Demanufacturing: 27Medical Waste Incineration: 13Medical Waste Sterilization : 16

Compressed Gas Mangement: 5Miscellaneous Treatment: 15

Catalyst Recovery: 11

0 25 50 75 100 125 150

Note that some facilities may be counted more than once based on services provided.

OBSERVED Groundwater Score Distribution For CHWMEG, Inc. Facility Review Reports Conducted Since 2007

Risk Increases with increasing score

This facility has an OBSERVED groundwater score of 85, which places it in the highlighted range.There are an additional 503 facilities with a score of 0 not shown on this chart. Total facilities = 680

There are 47 facilities with a higher score, 8 facilities with the same score, and 624 facilities with a lower score.

Observed Groundwater Score

This chart includes facility audits shipped on or before June 04, 2009

0

10

20

30

40

1 - 9 10 - 19 20 - 29 30 - 39 40 - 49 50 - 59 60 - 69 70 - 79 80 - 89 90 - 100

Fuel Bld / En Recov Incin / Thermal Landfill / Land TmtMetal Recovery Stab / Solid Oil / Solv RecovTransfer Only Comm Water Tmt Other

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See "Chart Legend & Distribution of Facilities"

Score: 85


OBSERVED Surface Water Score Distribution For CHWMEG, Inc. Facility Review Reports Conducted Since 2007


This facility has an OBSERVED surface water score of 0.There are a total of 634 facilities with a score of 0 not shown on this chart. Total facilities = 680


Observed Surface Water Score


0

10

20

30

40

1 - 9 10 - 19 20 - 29 30 - 39 40 - 49 50 - 59 60 - 69 70 - 79 80 - 89 90 - 100


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OBSERVED Air Score Distribution For CHWMEG, Inc. Facility Review Reports Conducted Since 2007


This facility has an OBSERVED air score of 0.There are a total of 599 facilities with a score of 0 not shown on this chart. Total facilities = 680


Observed Air Score


0

10

20

30

40

1 - 9 10 - 19 20 - 29 30 - 39 40 - 49 50 - 59 60 - 69 70 - 79 80 - 89 90 - 100


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OBSERVED Fire & Explosion Score Distribution For CHWMEG, Inc. Facility Review Reports Conducted Since 2007


This facility has an OBSERVED fire & explosion score of 0.There are a total of 582 facilities with a score of 0 not shown on this chart. Total facilities = 680


Observed Fire & Explosion Score


0

10

20

30

40

1 - 9 10 - 19 20 - 29 30 - 39 40 - 49 50 - 59 60 - 69 70 - 79 80 - 89 90 - 100


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OBSERVED Facility Operations Score Distribution For CHWMEG, Inc. Facility Review Reports Conducted Since 2007


This facility has an OBSERVED facility operations score of 37, which places it in the highlighted range. Total facilities = 680.


Observed Facility Operations Score


0

50

100

150

0 - 9 10 - 19 20 - 29 30 - 39 40 - 49 50 - 59 60 - 69 70 - 79 80 - 89 90 - 100


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Score: 37


OBSERVED Financial Risk Score Distribution For CHWMEG, Inc. Facility Review Reports Conducted Since 2007


This facility has an OBSERVED financial risk score of 41, which places it in the highlighted range.There are an additional 210 facilities with 'no score' not shown on this chart. Total facilities with a score = 470


Facilities with 'no score' result from financial information not being provided, recalled by the facility, or not available.

Observed Financial Risk Score


0

50

100

150

0 - 9 10 - 19 20 - 29 30 - 39 40 - 49 50 - 59 60 - 69 70 - 79 80 - 89 90 - 100

Fuel Bld / En Recov Incin / ThermalLandfill / Land Tmt Metal RecoveryStab / Solid Oil / Solv RecovTransfer Only Comm Water TmtOther

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Score: 41


POTENTIAL Groundwater Score Distribution For CHWMEG, Inc. Facility Review Reports Conducted Since 2007


This facility has a POTENTIAL groundwater score of 51, which places it in the highlighted range. Total facilities = 680


Potential Groundwater Score


0

25

50

75

100

0 - 9 10 - 19 20 - 29 30 - 39 40 - 49 50 - 59 60 - 69 70 - 79 80 - 89 90 - 100


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See "Chart Legend & Distribution of Facilities"Score: 51


POTENTIAL Surface Water Score Distribution For CHWMEG, Inc. Facility Review Reports Conducted Since 2007


This facility has a POTENTIAL surface water score of 51, which places it in the highlighted range. Total facilities = 680


Potential Surface Water Score


0

25

50

75

100

0 - 9 10 - 19 20 - 29 30 - 39 40 - 49 50 - 59 60 - 69 70 - 79 80 - 89 90 - 100


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Score: 51


POTENTIAL Air Score Distribution For CHWMEG, Inc. Facility Review Reports Conducted Since 2007


This facility has a POTENTIAL air score of 77, which places it in the highlighted range. Total facilities = 680


Potential Air Score


0

25

50

75

100

0 - 9 10 - 19 20 - 29 30 - 39 40 - 49 50 - 59 60 - 69 70 - 79 80 - 89 90 - 100


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Score: 77


POTENTIAL Fire & Explosion Score Distribution For CHWMEG, Inc. Facility Review Reports Conducted Since 2007


This facility has a POTENTIAL fire & explosion score of 86, which places it in the highlighted range. Total facilities = 680


Potential Fire & Explosion Score


0

25

50

75

100

0 - 9 10 - 19 20 - 29 30 - 39 40 - 49 50 - 59 60 - 69 70 - 79 80 - 89 90 - 100


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Score: 86


Altman Z-Score Distribution For CHWMEG, Inc. Facility Review Reports Conducted Since 2007

The past three Z-scores are 4.29 (FY 2008), 2.65 (FY 2007), and 2.38 (FY 2006), respectively, and are noted by the arrows.

Altman Z-Score

*See the Altman Z-Score description for information on the ranges in this chart. This chart includes facility audits shipped on or before June 04, 2009

0

50

100

150

200

<=–0

.4

to –

0.1

to 0

.2

to 0

.5

to 0

.8

to 1

.1

to 1

.4

to 1

.7

to 2

.0

to 2

.3

to 2

.6

to 2

.9

to 3

.2

to 3

.5

to 3

.8

to 4

.1

to 4

.4

to 4

.7

to 5

.0

to 7

.0

to 1

0.0

to 1

5.0

>15.

0

Num

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Lower Financial Strength* Higher Financial Strength*Indeterminate*

FY 07

FY 06

FY 08


CHWMEG, Inc. Risk Assessment System -- Detailed Calculations

Audit # H004.12 Clean Harbors El Dorado, ArkansasParent: Clean Harbors Environmental Services March 25, 2011

DETAILED CALCULATIONS

1.0 GROUNDWATER Sum Max Conf. OBSERVED RELEASE 1.1.1 54 66

1.1.2 8 9

GW OBSERVED RELEASE SCORE: 85.3 0.750

POTENTIAL RELEASES (Source x Pathway x Receptor)GW Sources; sect 1.1.3 * 4.1.4

Score Conf.Containers 56.2 0.889Tanks 53.5 0.738Surface Impoundments 37.9 0.711Waste Piles 0.0 1.000Landfills 0.0 1.000Landfarms 0.0 1.000Underground Injection 0.0 1.000

GW Pot. Source Subscore: 65.4 0.891 Major Contributor: Containers

GW Route subscore Score Conf.1.2 36.4 0.556

GW Receptors subscore Score Conf.1.3 62.9 0.688

GW POTENTIAL RELEASE SCORE: 51.3 0.711




2.0 SURFACE WATER Sum Max Conf. OBSERVED RELEASE 2.1.1 0 46

2.1.2 0 9

SW OBSERVED RELEASE SCORE: 0.0 0.568

POTENTIAL RELEASES (Source x Pathway x Receptor)SW Sources; sect 2.1.3 * 4.1.4

Score Conf.Containers 56.2 0.889Tanks 53.5 0.738Surface Impoundments 37.9 0.724Waste Piles 0.0 1.000Landfills 0.0 1.000Landfarms 0.0 1.000Physical Treatment 0.0 0.934Chemical Treatment 0.0 1.000Biological Treatment 0.0 1.000Thermal Treatment 0.0 0.934Incineration 54.6 0.778Solvent reclamation 42.9 0.697Oil Reclamation 0.0 1.000Fuels Blending 51.6 0.724Metals Recovery 0.0 1.000

SW Pot. Source Subscore: 64.8 0.890 Major Contributor: Containers

SW Route subscore Score Conf.2.2 76.2 0.786

SW Receptors subscore Score Conf.2.3 13.8 0.750

SW POTENTIAL RELEASE SCORE 50.8 0.808




3.0 AIR Sum Max Conf. OBSERVED RELEASE 3.1.1 1 42

3.1.2 0 12

AIR OBSERVED RELEASE SCORE: 0.0 0.602

POTENTIAL RELEASES (Source x Receptor)AIR Sources; sect 3.1.3 * 4.1.4

Score Conf.Containers 57.7 0.897Tanks 57.7 0.735Surface Impoundments 30.6 0.721Waste Piles 0.0 1.000Landfills 0.0 1.000Landfarms 0.0 1.000Underground Injection 0.0 1.000Physical Treatment 0.0 0.931Chemical Treatment 0.0 1.000Biological Treatment 0.0 1.000Thermal Treatment 0.0 0.931Incineration 49.5 0.778Solvent reclamation 37.2 0.694Oil Reclamation 0.0 1.000Fuels Blending 33.1 0.722Metals Recovery 0.0 1.000Energy Recovery 0.0 1.000

Air Pot. Source Subscore: 64.3 0.753 Major Contributor: Tanks

Air Receptor subscore: Score Conf.3.2 91.2 1.000

AIR POTENTIAL RELEASE SCORE 76.6 0.876




4.0 FIRE & EXPLOSION Sum Max Conf. OBSERVED RELEASE 4.1.1 17 31

4.1.2 0 15

F&E OBSERVED RELEASE SCORE: 0.0 0.912

POTENTIAL RELEASES (Source x Receptor)F&E Sources; sect 4.1.3 * 4.1.4

Score Conf.Containers 73.0 0.895Tanks 66.7 0.738Surface Impoundments 0.0 0.722Waste Piles 0.0 1.000Landfills 0.0 1.000Landfarms 0.0 1.000Underground Injection 0.0 1.000Physical Treatment 0.0 0.913Chemical Treatment 0.0 1.000Biological Treatment 0.0 1.000Thermal Treatment 0.0 0.921Incineration 79.2 0.776Solvent reclamation 56.9 0.675Oil Reclamation 0.0 1.000Fuels Blending 63.0 0.663Metals Recovery 0.0 1.000Energy Recovery 0.0 1.000

F&E Pot. Source Subscore: 83.3 0.782 Major Contributor: Incineration

F&E Receptor Subscore Score Conf.4.2 91.2 0.750

F&E POTENTIAL RELEASE SCORE: 86.1 0.766




5.0 FACILITY OPERATIONS Score Conf.5.1 Historical Components 89.3 0.8755.2 Current Operations 11.5 0.7505.3 Management 8.3 0.8755.4 Regulatory Assessment 8.9 0.8445.5 CERCLA/Supefund 0.0 0.7505.6 Occupational H & S 4.8 0.750

OPERATIONS SCORE: 37.1 0.807




6.0 FINANCIAL STRENGTH Score Conf.6.1 Economic Trends 10.0 1.0006.2 Business Performance 75.0 1.0006.3 Bankruptcy Potential 0.0 1.0006.4 Orderly Liquidation 33.3 0.875

FINANCIAL SCORE: 41.3 0.969

CHWMEG, Inc. -- RIsk Assessment System Scores Page 1 of 10

H004.12 Clean Harbors El Dorado, Arkansas March 25, 2011Wtd Wtd

Ques # Question Score CF Multi Total Max Max Conf1.0 GROUNDWATER SCORE1.1 SOURCE COMPONENTS1.1.1 OBSERVED RELEASE -- GROUNDWATER1.1.1.1 Evidence of GW contamination 2 0.75 25 50 2 50 191.1.1.2 Extent of GW contamination 1 0.75 2 2 4 8 21.1.1.3 Effectiveness of remed action 1 0.75 2 2 4 8 21.1.2 RELEASED WASTE CHARACTERISTICS1.1.2.1 Toxicity of contaminants 3 0.75 2 6 3 6 21.1.2.2 Persistence of contaminants 2 0.75 1 2 3 3 11.1.3 TECHNOLOGY/CONTAINMENT1.1.3.1 Container Storage1.1.3.1.1 Load/Unload design & permeabil. 1 0.75 1 1 3 3 11.1.3.1.2 Design and surface permeability 1 0.75 2 2 3 6 21.1.3.1.3 Spill prevention effectiveness 1 0.75 1 1 3 3 11.1.3.1.4 Adequacy of inspection procedure 1 0.75 1 1 3 3 11.1.3.2 Tank Storage1.1.3.2.1 Load/Unload design & permeabil. 1 0.75 1 1 3 3 11.1.3.2.2 Design and surface permeability 1 0.75 2 2 3 6 21.1.3.2.3 Spill prevention effectiveness 1 0.75 1 1 3 3 11.1.3.2.4 Adequacy of inspection - ASTs 1 0.75 1 1 3 3 11.1.3.2.5 Adequacy of monitoring - USTs 1 0.75 1 1 3 3 11.1.3.2.6 Adequacy of integrity testing 0 0.75 1 0 3 3 11.1.3.3 Surface Impoundments1.1.3.3.1 Load/Unload design & permeabil. 1 0.75 1 1 3 3 11.1.3.3.2 Oper. design and permeability 1 0.75 2 2 3 6 21.1.3.3.3 Spill prevention effectiveness 1 0.75 1 1 3 3 11.1.3.3.4 Adequacy of inspection procedure 1 0.75 1 1 3 3 11.1.3.3.5 Adequacy of monitoring procedure 2 0.50 1 2 3 3 11.1.3.4 Waste Piles1.1.3.4.1 Load/Unload design & permeabil. 0 1.00 1 0 3 3 11.1.3.4.2 Oper. design and permeability 0 1.00 2 0 3 6 21.1.3.4.3 Spill prevention effectiveness 0 1.00 1 0 3 3 11.1.3.4.4 Adequacy of inspection procedure 0 1.00 1 0 3 3 11.1.3.4.5 Adequacy of monitoring procedure 0 1.00 1 0 3 3 11.1.3.5 Landfills1.1.3.5.1 Load/Unload design & permeabil. 0 1.00 1 0 3 3 11.1.3.5.2 Oper. design and permeability 0 1.00 2 0 3 6 21.1.3.5.3 Spill prevention effectiveness 0 1.00 1 0 3 3 11.1.3.5.4 Adequacy of inspection procedure 0 1.00 1 0 3 3 11.1.3.5.5 Adequacy of monitoring procedure 0 1.00 1 0 3 3 11.1.3.6 Landfarms1.1.3.6.1 Load/Unload design & permeabil. 0 1.00 1 0 3 3 11.1.3.6.2 Oper. design and permeability 0 1.00 2 0 3 6 21.1.3.6.3 Spill prevention effectiveness 0 1.00 1 0 3 3 11.1.3.6.4 Adequacy of inspection procedure 0 1.00 1 0 3 3 11.1.3.6.5 Adequacy of monitoring procedure 0 1.00 1 0 3 3 11.1.3.7 Underground Injection1.1.3.7.1 Load/Unload design & permeabil. 0 1.00 1 0 3 3 11.1.3.7.2 Oper. design and permeability 0 1.00 2 0 3 6 21.1.3.7.3 Spill prevention effectiveness 0 1.00 1 0 3 3 11.1.3.7.4 Adequacy of inspection procedure 0 1.00 1 0 3 3 11.1.3.7.5 Adequacy of monitoring procedure 0 1.00 1 0 3 3 11.2 ROUTE COMPONENTS1.2.1 Depth to Groundwater 2 0.50 2 4 3 6 11.2.2 Depth to Usable Aquifer 0 0.50 2 0 3 6 11.2.3 Aquifer Thickness & Permeability 2 0.50 1 2 6 6 11.2.4 Confining Layer Thick & Permeab. 3 0.50 1 3 6 6 11.2.5 Unsaturated Zone Permeability 1 0.50 1 1 3 3 11.2.6 Groundwater/Flow Direction 1 0.50 1 1 3 3 11.2.7 Seismic Activity 1 1.00 1 1 3 3 11.3 TARGET COMPONENTS1.3.1 Use of Uppermost Groundwater 3 0.75 1 3 5 5 11.3.2 Use of Usable Aquifer 4 0.75 2 8 5 10 21.3.3 Proximity to Downgradient Wells 3 0.75 2 6 4 8 21.3.4 Population Served By Groundwater 2 0.50 2 4 5 10 11.3.5 Natural Receptors (w/in 1 mile) 1 0.75 1 1 2 2 1



Ques # Question Score CF Multi Total Max Max Conf2.0 SURFACE WATER CONTAMINATION2.1.1 OBSERVED RELEASE2.1.1.1 Evidence of SW contamination 0 0.50 15 0 2 30 82.1.1.2 Extent of SW contamination 0 0.50 2 0 4 8 12.1.1.3 Effectiveness of remedial action 0 0.50 2 0 4 8 12.1.2 RELEASE WASTE CHARACTERISTICS2.1.2.1 Toxicity of contaminants 0 1.00 2 0 3 6 22.1.2.2 Persistence of contaminants 0 1.00 1 0 3 3 12.1.3 TECHNOLOGY/CONTAINMENT2.1.3.1 Container Storage2.1.3.1.1 Loading/unloading des & permeab. 1 0.75 1 1 3 3 12.1.3.1.2 Oper. design & containment 1 0.75 2 2 3 6 22.1.3.1.3 Run-on/run-off control effect. 1 0.75 1 1 3 3 12.1.3.1.4 Adequacy of inspection procedure 1 0.75 1 1 3 3 12.1.3.2 Tank Storage2.1.3.2.1 Loading/unloading des & permeab. 1 0.75 1 1 3 3 12.1.3.2.2 Oper. design & containment 1 0.75 2 2 3 6 22.1.3.2.3 Run-on/run-off control effect. 1 0.75 1 1 3 3 12.1.3.2.4 AST insp. proc. adequacy 1 0.75 1 1 3 3 12.1.3.2.5 UST monit. proc. adequacy 1 0.75 1 1 3 3 12.1.3.2.6 Integrity testing proc. adequacy 0 0.75 1 0 3 3 12.1.3.3 Surface Impoundments2.1.3.3.1 Loading/unloading des & permeab. 1 0.75 1 1 3 3 12.1.3.3.2 Oper. design & containment 1 0.75 2 2 3 6 22.1.3.3.3 Run-on/run-off control effect. 1 0.75 1 1 3 3 12.1.3.3.4 Adequacy of inspection procedure 1 0.75 1 1 3 3 12.1.3.3.5 Adequacy of monitoring procedure 2 0.75 1 2 3 3 12.1.3.4 Waste Piles2.1.3.4.1 Loading/unloading des & contain. 0 1.00 1 0 3 3 12.1.3.4.2 Oper. design & containment 0 1.00 2 0 3 6 22.1.3.4.3 Run-on/run-off control effect. 0 1.00 1 0 3 3 12.1.3.4.4 Adequacy of inspection procedure 0 1.00 1 0 3 3 12.1.3.4.5 Adequacy of monitoring procedure 0 1.00 1 0 3 3 12.1.3.5 Landfills2.1.3.5.1 Loading/unloading des & contain. 0 1.00 1 0 3 3 12.1.3.5.2 Oper. design & containment 0 1.00 2 0 3 6 22.1.3.5.3 Run-on/run-off control effect. 0 1.00 1 0 3 3 12.1.3.5.4 Adequacy of inspection procedure 0 1.00 1 0 3 3 12.1.3.5.5 Adequacy of monitoring procedure 0 1.00 1 0 3 3 12.1.3.6 Landfarms2.1.3.6.1 Loading/unloading des & contain. 0 1.00 1 0 3 3 12.1.3.6.2 Oper. design & containment 0 1.00 2 0 3 6 22.1.3.6.3 Run-on/run-off control effect. 0 1.00 1 0 3 3 12.1.3.6.4 Adequacy of inspection procedure 0 1.00 1 0 3 3 12.1.3.6.5 Adequacy of monitoring procedure 0 1.00 1 0 3 3 12.1.3.7 Physical Treatment2.1.3.7.1 Loading/unloading des & contain. 1 0.75 1 1 3 3 12.1.3.7.2 Oper. design & containment 1 0.75 2 2 3 6 22.1.3.7.3 Run-on/run-off control effect. 1 0.75 1 1 3 3 12.1.3.7.4 Adequacy of inspection procedure 1 1.00 1 1 3 3 12.1.3.7.5 Adequacy of monitoring procedure 2 0.75 1 2 3 3 12.1.3.8 Chemical Treatment2.1.3.8.1 Loading/unloading des & contain. 0 1.00 1 0 3 3 12.1.3.8.2 Oper. design & containment 0 1.00 2 0 3 6 22.1.3.8.3 Run-on/run-off control effect. 0 1.00 1 0 3 3 12.1.3.8.4 Adequacy of inspection procedure 0 1.00 1 0 3 3 12.1.3.8.5 Adequacy of monitoring procedure 0 1.00 1 0 3 3 12.1.3.9 Biological Treatment2.1.3.9.1 Loading/unloading des & contain. 0 1.00 1 0 3 3 12.1.3.9.2 Oper. design & containment 0 1.00 2 0 3 6 22.1.3.9.3 Run-on/run-off control effect. 0 1.00 1 0 3 3 12.1.3.9.4 Adequacy of inspection procedure 0 1.00 1 0 3 3 12.1.3.9.5 Adequacy of monitoring procedure 0 1.00 1 0 3 3 12.1.3.10 Thermal Treatment2.1.3.10.1 Loading/unloading des & contain. 1 0.75 1 1 3 3 12.1.3.10.2 Oper. design & containment 1 0.75 2 2 3 6 22.1.3.10.3 Run-on/run-off control effect. 1 0.75 1 1 3 3 12.1.3.10.4 Adequacy of inspection procedure 1 0.75 1 1 3 3 12.1.3.11 Incineration2.1.3.11.1 Loading/unloading des & contain. 1 0.75 1 1 3 3 12.1.3.11.2 Oper. design & containment 1 0.75 2 2 3 6 22.1.3.11.3 Run-on/run-off control effect. 1 0.75 1 1 3 3 12.1.3.11.4 Adequacy of inspection procedure 1 0.75 1 1 3 3 1



Ques # Question Score CF Multi Total Max Max Conf2.1.3.12 Solvent Reclamation2.1.3.12.1 Loading/unloading des & contain. 1 0.75 1 1 3 3 12.1.3.12.2 Oper. design & containment 1 0.75 2 2 3 6 22.1.3.12.3 Run-on/run-off control effect. 1 0.75 1 1 3 3 12.1.3.12.4 Adequacy of inspection procedure 1 0.75 1 1 3 3 12.1.3.12.5 Adequacy of monitoring procedure 2 0.75 1 2 3 3 12.1.3.13 Oil Reclamation2.1.3.13.1 Loading/unloading des & contain. 0 1.00 1 0 3 3 12.1.3.13.2 Oper. design & containment 0 1.00 2 0 3 6 22.1.3.13.3 Run-on/run-off control effect. 0 1.00 1 0 3 3 12.1.3.13.4 Adequacy of inspection procedure 0 1.00 1 0 3 3 12.1.3.13.5 Adequacy of monitoring procedure 0 1.00 1 0 3 3 12.1.3.14 Fuel Blending2.1.3.14.1 Loading/unloading des & contain. 1 0.75 1 1 3 3 12.1.3.14.2 Oper. design & containment 1 0.75 2 2 3 6 22.1.3.14.3 Run-on/run-off control effect. 1 0.75 1 1 3 3 12.1.3.14.4 Adequacy of inspection procedure 1 0.75 1 1 3 3 12.1.3.14.5 Adequacy of monitoring procedure 2 0.75 1 2 3 3 12.1.3.15 Metals Recovery2.1.3.15.1 Loading/unloading des & contain. 0 1.00 1 0 3 3 12.1.3.15.2 Oper. design & containment 0 1.00 2 0 3 6 22.1.3.15.3 Run-on/run-off control effect. 0 1.00 1 0 3 3 12.1.3.15.4 Adequacy of inspection procedure 0 1.00 1 0 3 3 12.1.3.15.5 Adequacy of monitoring procedure 0 1.00 1 0 3 3 12.2 ROUTE COMPONENTS2.2.1 Site Topography & Terrain 1 1.00 1 1 3 3 12.2.2 Dist. to Nearest Surface Water 3 0.75 2 6 3 6 22.2.3 One-Year 24-Hr. Precipitation 3 0.75 1 3 3 3 12.2.4 Flood Potential 1 0.50 1 1 3 3 12.2.5 Annual Precipitation 3 0.75 1 3 3 3 12.2.6 Annual Evapotranspiration 2 1.00 1 2 3 3 12.3 TARGET COMPONENTS2.3.1 Surface Water Use Within 3 Miles 1 0.50 2 2 4 8 12.3.2 Proximity to Closest User Intake 0 0.75 2 0 4 8 22.3.3 Pop. Served by Surface Water 0 1.00 2 0 5 10 22.3.4 Proximity to sens. nat'l recept. 2 0.75 1 2 3 3 1



Ques # Question Score CF Multi Total Max Max Conf3.0 AIR CONTAMINATION3.1.1 OBSERVED RELEASE3.1.1.1 Evidence of air contamination 0 0.50 15 0 2 30 83.1.1.2 Extent of air contamination 1 0.75 1 1 4 4 13.1.1.3 Effectiveness of remedial action 0 0.50 2 0 4 8 13.1.2 Release Waste Characteristics3.1.2.1 Toxicity of contaminants 0 1.00 2 0 3 6 23.1.2.2 Reactivity of contaminants 0 1.00 1 0 3 3 13.1.2.3 Volatility of contaminants 0 1.00 1 0 3 3 13.1.3 TECHNOLOGY/CONTAINMENT3.1.3.1 Container Storage3.1.3.1.1 Load/Unloading design & emiss. 1 0.75 1 1 3 3 13.1.3.1.2 Design and emission controls 1 0.75 2 2 3 6 23.1.3.1.3 Adequacy of inspection procedure 1 0.75 1 1 3 3 13.1.3.2 Tank Storage3.1.3.2.1 Load/Unloading design & emiss. 1 0.75 1 1 3 3 13.1.3.2.2 Design and emission controls 1 0.75 2 2 3 6 23.1.3.2.3 Adequacy of inspection procedure 1 0.75 1 1 3 3 13.1.3.3 Surface Impoundments3.1.3.3.1 Load/Unloading design & emiss. 1 0.75 1 1 3 3 13.1.3.3.2 Design and emission controls 1 0.75 2 2 3 6 23.1.3.3.3 Adequacy of inspection procedure 1 0.75 1 1 3 3 13.1.3.3.4 Adequacy of monitoring procedure 2 0.75 1 2 3 3 13.1.3.4 Waste Piles3.1.3.4.1 Load/Unloading design & emiss. 0 1.00 1 0 3 3 13.1.3.4.2 Design and emission controls 0 1.00 2 0 3 6 23.1.3.4.3 Adequacy of inspection procedure 0 1.00 1 0 3 3 13.1.3.4.4 Adequacy of monitoring procedure 0 1.00 1 0 3 3 13.1.3.5 Landfills3.1.3.5.1 Load/Unloading design & emiss. 0 1.00 1 0 3 3 13.1.3.5.2 Design and emission controls 0 1.00 2 0 3 6 23.1.3.5.3 Adequacy of inspection procedure 0 1.00 1 0 3 3 13.1.3.5.4 Adequacy of monitoring procedure 0 1.00 1 0 3 3 13.1.3.6 Landfarms3.1.3.6.1 Load/Unloading design & emiss. 0 1.00 1 0 3 3 13.1.3.6.2 Design and emission controls 0 1.00 2 0 3 6 23.1.3.6.3 Adequacy of inspection procedure 0 1.00 1 0 3 3 13.1.3.6.4 Adequacy of monitoring procedure 0 1.00 1 0 3 3 13.1.3.7 Underground Injection3.1.3.7.1 Load/Unloading design & emiss. 0 1.00 1 0 3 3 13.1.3.7.2 Design and emission controls 0 1.00 2 0 3 6 23.1.3.7.3 Adequacy of inspection procedure 0 1.00 1 0 3 3 13.1.3.7.4 Adequacy of monitoring procedure 0 1.00 1 0 3 3 13.1.3.8 Physical Treatment3.1.3.8.1 Load/Unloading design & emiss. 1 0.75 1 1 3 3 13.1.3.8.2 Design and emission controls 1 0.75 2 2 3 6 23.1.3.8.3 Adequacy of inspection procedure 1 0.75 1 1 3 3 13.1.3.8.4 Adequacy of monitoring procedure 2 0.75 1 2 3 3 13.1.3.9 Chemical Treatment3.1.3.9.1 Load/Unloading design & emiss. 0 1.00 1 0 3 3 13.1.3.9.2 Design and emission controls 0 1.00 2 0 3 6 23.1.3.9.3 Adequacy of inspection procedure 0 1.00 1 0 3 3 13.1.3.9.4 Adequacy of monitoring procedure 0 1.00 1 0 3 3 13.1.3.10 Biological Treatment3.1.3.10.1 Load/Unloading design & emiss. 0 1.00 1 0 3 3 13.1.3.10.2 Design and emission controls 0 1.00 2 0 3 6 23.1.3.10.3 Adequacy of inspection procedure 0 1.00 1 0 3 3 13.1.3.10.4 Adequacy of monitoring procedure 0 1.00 1 0 3 3 13.1.3.11 Thermal Treatment3.1.3.11.1 Load/Unloading design & emiss. 1 0.75 1 1 3 3 13.1.3.11.2 Design and emission controls 1 0.75 2 2 3 6 23.1.3.11.3 Adequacy of inspection procedure 0 0.75 1 0 3 3 13.1.3.11.4 Adequacy of monitoring procedure 0 0.75 1 0 3 3 13.1.3.12 Incineration3.1.3.12.1 Load/Unloading design & emiss. 1 0.75 1 1 3 3 13.1.3.12.2 Design and emission controls 1 0.75 2 2 3 6 23.1.3.12.3 Adequacy of inspection procedure 1 0.75 1 1 3 3 13.1.3.12.4 Adequacy of monitoring procedure 0 0.75 1 0 3 3 13.1.3.13 Solvent Reclamation3.1.3.13.1 Load/Unloading design & emiss. 1 0.75 1 1 3 3 13.1.3.13.2 Design and emission controls 1 0.75 2 2 3 6 23.1.3.13.3 Adequacy of inspection procedure 1 0.75 1 1 3 3 13.1.3.13.4 Adequacy of monitoring procedure 0 0.75 1 0 3 3 1



Ques # Question Score CF Multi Total Max Max Conf3.1.3.14 Oil Reclamation3.1.3.14.1 Load/Unloading design & emiss. 0 1.00 1 0 3 3 13.1.3.14.2 Design and emission controls 0 1.00 2 0 3 6 23.1.3.14.3 Adequacy of inspection procedure 0 1.00 1 0 3 3 13.1.3.14.4 Adequacy of monitoring procedure 0 1.00 1 0 3 3 13.1.3.15 Fuel Blending3.1.3.15.1 Load/Unloading design & emiss. 1 0.75 1 1 3 3 13.1.3.15.2 Design and emission controls 0 0.75 2 0 3 6 23.1.3.15.3 Adequacy of inspection procedure 1 0.75 1 1 3 3 13.1.3.15.4 Adequacy of monitoring procedure 0 0.75 1 0 3 3 13.1.3.16 Metals Recovery3.1.3.16.1 Load/Unloading design & emiss. 0 1.00 1 0 3 3 13.1.3.16.2 Design and emission controls 0 1.00 2 0 3 6 23.1.3.16.3 Adequacy of inspection procedure 0 1.00 1 0 3 3 13.1.3.17 Energy Recovery3.1.3.17.1 Load/Unloading design & emiss. 0 1.00 1 0 3 3 13.1.3.17.2 Design and emission controls 0 1.00 2 0 3 6 23.1.3.17.3 Adequacy of inspection procedure 0 1.00 1 0 3 3 13.1.3.17.4 Adequacy of monitoring procedure 0 1.00 1 0 3 3 13.2 TARGET COMPONENTS3.2.1 Population Within 3 Miles 5 0.75 2 10 5 10 23.2.2 Proximity to Nearest Residence 4 0.75 2 8 4 8 23.2.3 Proximity to Comm/Ind Complex 4 0.75 2 8 4 8 23.2.4 Predominant Land Use W/in 3 Miles 2 0.75 1 2 4 4 13.2.5 Proximity to Sens. Populations 3 0.75 1 3 4 4 1



Ques # Question Score CF Multi Total Max Max Conf4.0 FIRE AND EXPLOSION SCORE4.1 SOURCE COMPONENTS -- FIRE & EXPLOSION4.1.1 RECENT INCIDENTS4.1.1.1 Recent fires/explosions 1 1.00 5 5 2 10 54.1.1.2 Personal injuries 0 1.00 1 0 3 3 14.1.1.3 Facility Damage 2 0.75 1 2 3 3 14.1.1.4 Responses to Prevent Recurrence 2 0.75 5 10 3 15 44.1.2 RELEASED WASTE CHARACTERISTICS4.1.2.1 Waste Flammability 0 1.00 1 0 3 3 14.1.2.2 Waste Reactivity 0 1.00 1 0 3 3 14.1.2.3 Waste Volatility 0 1.00 1 0 3 3 14.1.2.4 Waste Toxicity 0 1.00 2 0 3 6 24.1.3 TECHNOLOGY/CONTAINMENT4.1.3.1 Container Storage4.1.3.1.1 Fire response capabilities 2 0.75 1 2 3 3 14.1.3.1.2 Unloading area design and op 2 0.75 1 2 3 3 14.1.3.1.3 Treatment design and op 2 0.75 1 2 3 3 14.1.3.1.4 Sensor and control adequacy 2 0.75 1 2 3 3 14.1.3.1.5 Proximity to heat or ignition 0 1.00 1 0 2 2 14.1.3.1.6 Grounding (for flam. liq.) 0 0.75 1 0 1 1 14.1.3.2 Tank Storage4.1.3.2.1 Fire response capabilities 2 0.75 1 2 3 3 14.1.3.2.2 Unloading area design and op 2 0.75 1 2 3 3 14.1.3.2.3 Treatment design and op 2 0.75 1 2 3 3 14.1.3.2.4 Sensor and control adequacy 2 0.75 1 2 3 3 14.1.3.2.5 Proximity to heat or ignition 0 0.75 1 0 2 2 14.1.3.2.6 Grounding (for flam. liq.) 0 0.75 1 0 1 1 14.1.3.2.7 Explosion proofing measures 0 0.75 1 0 3 3 14.1.3.3 Surface Impoundments4.1.3.3.1 Fire response capabilities 0 0.75 1 0 3 3 14.1.3.3.2 Unloading area design and op 0 0.75 1 0 3 3 14.1.3.3.3 Treatment design and op 0 0.75 1 0 3 3 14.1.3.3.4 Sensor and control adequacy 0 0.75 1 0 3 3 14.1.3.3.5 Proximity to heat or ignition 0 0.75 1 0 2 2 14.1.3.4 Waste Piles4.1.3.4.1 Fire response capabilities 0 1.00 1 0 3 3 14.1.3.4.2 Unloading area design and op 0 1.00 1 0 3 3 14.1.3.4.3 Treatment design and op 0 1.00 1 0 3 3 14.1.3.4.4 Sensor and control adequacy 0 1.00 1 0 3 3 14.1.3.4.5 Proximity to heat or ignition 0 1.00 1 0 2 2 14.1.3.5 Landfills4.1.3.5.1 Fire response capabilities 0 1.00 1 0 3 3 14.1.3.5.2 Unloading area design and op 0 1.00 1 0 3 3 14.1.3.5.3 Treatment design and op 0 1.00 1 0 3 3 14.1.3.5.4 Sensor and control adequacy 0 1.00 1 0 3 3 14.1.3.5.5 Proximity to heat or ignition 0 1.00 1 0 2 2 14.1.3.6 Landfarms4.1.3.6.1 Fire response capabilities 0 1.00 1 0 3 3 14.1.3.6.2 Unloading area design and op 0 1.00 1 0 3 3 14.1.3.6.3 Treatment design and op 0 1.00 1 0 3 3 14.1.3.6.4 Sensor and control adequacy 0 1.00 1 0 3 3 14.1.3.6.5 Proximity to heat or ignition 0 1.00 1 0 2 2 14.1.3.7 Underground Injection4.1.3.7.1 Fire response capabilities 0 1.00 1 0 3 3 14.1.3.7.2 Unloading area design and op 0 1.00 1 0 3 3 14.1.3.7.3 Treatment design and op 0 1.00 1 0 3 3 14.1.3.7.4 Sensor and control adequacy 0 1.00 1 0 3 3 14.1.3.7.5 Proximity to heat or ignition 0 1.00 1 0 2 2 14.1.3.8 Physical Treatment4.1.3.8.1 Fire response capabilities 2 0.75 1 2 3 3 14.1.3.8.2 Unloading area design and op 2 0.75 1 2 3 3 14.1.3.8.3 Treatment design and op 2 0.75 1 2 3 3 14.1.3.8.4 Sensor and control adequacy 2 0.75 1 2 3 3 14.1.3.8.5 Proximity to heat or ignition 0 0.75 1 0 2 2 14.1.3.8.6 Grounding (flammable liquids) 0 0.75 1 0 1 1 14.1.3.8.7 Explosion proofing measures 0 0.75 1 0 1 1 14.1.3.9 Chemical Treatment4.1.3.9.1 Fire response capabilities 0 1.00 1 0 3 3 14.1.3.9.2 Unloading area design and op 0 1.00 1 0 3 3 14.1.3.9.3 Treatment design and op 0 1.00 1 0 3 3 14.1.3.9.4 Sensor and control adequacy 0 1.00 1 0 3 3 14.1.3.9.5 Proximity to heat or ignition 0 1.00 1 0 2 2 14.1.3.9.6 Grounding (flammable liquids) 0 1.00 1 0 1 1 1



Ques # Question Score CF Multi Total Max Max Conf4.1.3.9.7 Explosion proofing measures 0 1.00 1 0 1 1 14.1.3.10 Biological Treatment4.1.3.10.1 Fire response capabilities 0 1.00 1 0 3 3 14.1.3.10.2 Unloading area design and op 0 1.00 1 0 3 3 14.1.3.10.3 Treatment design and op 0 1.00 1 0 3 3 14.1.3.10.4 Sensor and control adequacy 0 1.00 1 0 3 3 14.1.3.10.5 Proximity to heat or ignition 0 1.00 1 0 2 2 14.1.3.10.6 Grounding (flammable liquids) 0 1.00 1 0 1 1 14.1.3.10.7 Explosion proofing measures 0 1.00 1 0 1 1 14.1.3.11 Thermal Treatment4.1.3.11.1 Fire response capabilities 2 0.75 1 2 3 3 14.1.3.11.2 Unloading area design and op 2 0.75 1 2 3 3 14.1.3.11.3 Treatment design and op 2 0.75 1 2 3 3 14.1.3.11.4 Sensor and control adequacy 2 0.75 1 2 3 3 14.1.3.11.5 Proximity to heat or ignition 0 0.75 1 0 2 2 14.1.3.11.6 Grounding (flammable liquids) 0 0.75 1 0 1 1 14.1.3.12 Incineration4.1.3.12.1 Fire response capabilities 2 0.75 1 2 3 3 14.1.3.12.2 Unloading area design and op 2 0.75 1 2 3 3 14.1.3.12.3 Treatment design and op 2 0.75 1 2 3 3 14.1.3.12.4 Sensor and control adequacy 2 0.75 1 2 3 3 14.1.3.12.5 Proximity to heat or ignition 2 0.75 1 2 2 2 14.1.3.12.6 Grounding (flammable liquids) 0 0.75 1 0 1 1 14.1.3.13 Solvent Reclamation4.1.3.13.1 Fire response capabilities 2 0.75 1 2 3 3 14.1.3.13.2 Unloading area design and op 2 0.75 1 2 3 3 14.1.3.13.3 Treatment design and op 2 0.75 1 2 3 3 14.1.3.13.4 Sensor and control adequacy 2 0.75 1 2 3 3 14.1.3.13.5 Proximity to heat or ignition 0 0.50 1 0 2 2 14.1.3.13.6 Grounding (flammable liquids) 0 0.75 1 0 1 1 14.1.3.13.7 Explosion proofing measures 0 0.50 1 0 1 1 14.1.3.14 Oil Reclamation4.1.3.14.1 Fire response capabilities 0 1.00 1 0 3 3 14.1.3.14.2 Unloading area design and op 0 1.00 1 0 3 3 14.1.3.14.3 Treatment design and op 0 1.00 1 0 3 3 14.1.3.14.4 Sensor and control adequacy 0 1.00 1 0 3 3 14.1.3.14.5 Proximity to heat or ignition 0 1.00 1 0 2 2 14.1.3.14.6 Grounding (flammable liquids) 0 1.00 1 0 1 1 14.1.3.14.7 Explosion proofing measures 0 1.00 1 0 1 1 14.1.3.15 Fuel Blending4.1.3.15.1 Fire response capabilities 2 0.50 1 2 3 3 14.1.3.15.2 Unloading area design and op 2 0.50 1 2 3 3 14.1.3.15.3 Treatment design and op 2 0.50 1 2 3 3 14.1.3.15.4 Sensor and control adequacy 2 0.50 1 2 3 3 14.1.3.15.5 Proximity to heat or ignition 0 0.75 1 0 2 2 14.1.3.15.6 Grounding (flammable liquids) 0 0.75 1 0 1 1 14.1.3.15.7 Explosion proofing measures 0 0.50 1 0 1 1 14.1.3.16 Metals Recovery4.1.3.16.1 Fire response capabilities 0 1.00 1 0 3 3 14.1.3.16.2 Unloading area design and op 0 1.00 1 0 3 3 14.1.3.16.3 Treatment design and op 0 1.00 1 0 3 3 14.1.3.16.4 Sensor and control adequacy 0 1.00 1 0 3 3 14.1.3.16.5 Proximity to heat or ignition 0 1.00 1 0 2 2 14.1.3.16.6 Grounding (flammable liquids) 0 1.00 1 0 1 1 14.1.3.16.7 Explosion proofing measures 0 1.00 1 0 1 1 14.1.3.17 Energy Recovery4.1.3.17.1 Fire response capabilities 0 1.00 1 0 3 3 14.1.3.17.2 Unloading area design and op 0 1.00 1 0 3 3 14.1.3.17.3 Treatment design and op 0 1.00 1 0 3 3 14.1.3.17.4 Sensor and control adequacy 0 1.00 1 0 3 3 14.1.3.17.5 Proximity to heat or ignition 0 1.00 1 0 2 2 14.1.3.17.6 Grounding (flammable liquids) 0 1.00 1 0 1 1 1



Ques # Question Score CF Multi Total Max Max Conf4.1.4 WASTE CHARACTERISTICS BY TECHNOLOGY4.1.4.1 Container Storage4.1.4.1.1 Maximum Daily Waste Quantity 5 1.00 1 5 5 5 14.1.4.1.2 Physical State 2 1.00 1 2 2 2 14.1.4.1.3 Waste Flammability 3 1.00 3 9 3 9 34.1.4.1.4 Waste Reactivity 3 1.00 2 6 3 6 24.1.4.1.5 Waste Volatility 3 1.00 2 6 3 6 24.1.4.1.6 Waste Toxicity 3 1.00 2 6 3 6 24.1.4.1.7 Solubility 3 0.75 1 3 3 3 14.1.4.1.8 Persistence 2 0.50 1 2 3 3 14.1.4.2 Tank Storage Wastes4.1.4.2.1 Maximum Waste Storage Capacity 5 1.00 1 5 5 5 14.1.4.2.2 Physical State 2 0.75 1 2 2 2 14.1.4.2.3 Waste Flammability 3 0.75 3 9 3 9 24.1.4.2.4 Waste Reactivity 3 0.50 2 6 3 6 14.1.4.2.5 Waste Volatility 3 0.75 2 6 3 6 24.1.4.2.6 Waste Toxicity 3 0.75 2 6 3 6 24.1.4.2.7 Solubility 3 0.75 1 3 3 3 14.1.4.2.8 Persistence 3 0.75 1 3 3 3 14.1.4.3 Surface Impoundment Wastes4.1.4.3.1 Maximum Waste Storage Capacity 3 0.75 1 3 5 5 14.1.4.3.2 Physical State 2 0.75 1 2 2 2 14.1.4.3.3 Waste Toxicity 0 0.75 3 0 3 9 24.1.4.3.4 Waste Reactivity 0 0.75 2 0 3 6 24.1.4.3.5 Waste Volatility 0 0.75 2 0 3 6 24.1.4.3.6 Waste Toxicity 1 0.50 2 2 3 6 14.1.4.3.7 Solubility 0 0.75 1 0 3 3 14.1.4.3.8 Persistence 0 0.75 1 0 3 3 14.1.4.4 Waste Pile Wastes4.1.4.4.1 Maximum Daily Waste Quantity 0 1.00 1 0 5 5 14.1.4.4.2 Physical State 0 1.00 1 0 2 2 14.1.4.4.3 Waste Flammability 0 1.00 3 0 3 9 34.1.4.4.4 Waste Reactivity 0 1.00 2 0 3 6 24.1.4.4.5 Waste Volatility 0 1.00 2 0 3 6 24.1.4.4.6 Waste Toxicity 0 1.00 2 0 3 6 24.1.4.4.7 Solubility 0 1.00 1 0 3 3 14.1.4.4.8 Persistence 0 1.00 1 0 3 3 14.1.4.5 Landfill Wastes4.1.4.5.1 Total Waste Quantity to Date 0 1.00 1 0 10 10 14.1.4.5.2 Physical State 0 1.00 1 0 2 2 14.1.4.5.3 Waste Flammability 0 1.00 3 0 3 9 34.1.4.5.4 Waste Reactivity 0 1.00 2 0 3 6 24.1.4.5.5 Waste Volatility 0 1.00 2 0 3 6 24.1.4.5.6 Waste Toxicity 0 1.00 2 0 3 6 24.1.4.5.7 Solubility 0 1.00 1 0 3 3 14.1.4.5.8 Persistence 0 1.00 1 0 3 3 14.1.4.6 Landfarm Wastes4.1.4.6.1 Total Waste Quantity to Date 0 1.00 1 0 10 10 14.1.4.6.2 Physical State 0 1.00 1 0 2 2 14.1.4.6.3 Waste Flammability 0 1.00 3 0 3 9 34.1.4.6.4 Waste Reactivity 0 1.00 2 0 3 6 24.1.4.6.5 Waste Volatility 0 1.00 2 0 3 6 24.1.4.6.6 Waste Toxicity 0 1.00 2 0 3 6 24.1.4.6.7 Solubility 0 1.00 1 0 3 3 14.1.4.6.8 Persistence 0 1.00 1 0 3 3 14.1.4.7 Underground Injection Wastes4.1.4.7.1 Total Waste Quantity to Date 0 1.00 1 0 10 10 14.1.4.7.2 Physical State 0 1.00 1 0 2 2 14.1.4.7.3 Waste Flammability 0 1.00 3 0 3 9 34.1.4.7.4 Waste Reactivity 0 1.00 2 0 3 6 24.1.4.7.5 Waste Volatility 0 1.00 2 0 3 6 24.1.4.7.6 Waste Toxicity 0 1.00 2 0 3 6 24.1.4.7.7 Solubility 0 1.00 1 0 3 3 14.1.4.7.8 Persistence 0 1.00 1 0 3 3 14.1.4.8 Physical Treatment Wastes4.1.4.8.1 Maximum Daily Throughput 0 1.00 1 0 5 5 14.1.4.8.2 Physical State 0 1.00 1 0 2 2 14.1.4.8.3 Waste Flammability 0 1.00 3 0 3 9 34.1.4.8.4 Waste Reactivity 0 1.00 2 0 3 6 24.1.4.8.5 Waste Volatility 0 1.00 2 0 3 6 24.1.4.8.6 Waste Toxicity 0 1.00 2 0 3 6 24.1.4.8.7 Solubility 0 1.00 1 0 3 3 14.1.4.8.8 Persistence 0 1.00 1 0 3 3 1



Ques # Question Score CF Multi Total Max Max Conf4.1.4.9 Chemical Treatment Wastes4.1.4.9.1 Maximum Daily Throughput 0 1.00 1 0 5 5 14.1.4.9.2 Physical State 0 1.00 1 0 2 2 14.1.4.9.3 Waste Flammability 0 1.00 3 0 3 9 34.1.4.9.4 Waste Reactivity 0 1.00 2 0 3 6 24.1.4.9.5 Waste Volatility 0 1.00 2 0 3 6 24.1.4.9.6 Waste Toxicity 0 1.00 2 0 3 6 24.1.4.9.7 Solubility 0 1.00 1 0 3 3 14.1.4.9.8 Persistence 0 1.00 1 0 3 3 14.1.4.10 Biological Treatment Wastes4.1.4.10.1 Maximum Daily Throughput 0 1.00 1 0 5 5 14.1.4.10.2 Physical State 0 1.00 1 0 2 2 14.1.4.10.3 Waste Flammability 0 1.00 3 0 3 9 34.1.4.10.4 Waste Reactivity 0 1.00 2 0 3 6 24.1.4.10.5 Waste Volatility 0 1.00 2 0 3 6 24.1.4.10.6 Waste Toxicity 0 1.00 2 0 3 6 24.1.4.10.7 Solubility 0 1.00 1 0 3 3 14.1.4.10.8 Persistence 0 1.00 1 0 3 3 14.1.4.11 Thermal Treatment Wastes4.1.4.11.1 Maximum Daily Throughput 0 1.00 1 0 5 5 14.1.4.11.2 Physical State 0 1.00 1 0 2 2 14.1.4.11.3 Waste Flammability 0 1.00 3 0 3 9 34.1.4.11.4 Waste Reactivity 0 1.00 2 0 3 6 24.1.4.11.5 Waste Volatility 0 1.00 2 0 3 6 24.1.4.11.6 Waste Toxicity 0 1.00 2 0 3 6 24.1.4.11.7 Solubility 0 1.00 1 0 3 3 14.1.4.11.8 Persistence 0 1.00 1 0 3 3 14.1.4.12 Incineration Wastes4.1.4.12.1 Maximum Daily Throughput 3 1.00 1 3 5 5 14.1.4.12.2 Physical State 2 1.00 1 2 2 2 14.1.4.12.3 Waste Flammability 3 0.75 3 9 3 9 24.1.4.12.4 Waste Reactivity 3 0.75 2 6 3 6 24.1.4.12.5 Waste Volatility 3 0.75 2 6 3 6 24.1.4.12.6 Waste Toxicity 3 0.75 2 6 3 6 24.1.4.12.7 Solubility 3 0.75 1 3 3 3 14.1.4.12.8 Persistence 3 0.75 1 3 3 3 14.1.4.13 Solvent Reclamation Wastes4.1.4.13.1 Maximum Daily Throughput 1 0.50 1 1 5 5 14.1.4.13.2 Physical State 2 0.75 1 2 2 2 14.1.4.13.3 Waste Flammability 3 0.50 3 9 3 9 24.1.4.13.4 Waste Reactivity 1 0.75 2 2 3 6 24.1.4.13.5 Waste Volatility 2 0.75 2 4 3 6 24.1.4.13.6 Waste Toxicity 2 0.75 2 4 3 6 24.1.4.13.7 Solubility 1 0.75 1 1 3 3 14.1.4.13.8 Persistence 1 0.75 1 1 3 3 14.1.4.14 Oil Reclamation Wastes4.1.4.14.1 Maximum Daily Throughput 0 1.00 1 0 5 5 14.1.4.14.2 Physical State 0 1.00 1 0 2 2 14.1.4.14.3 Waste Flammability 0 1.00 3 0 3 9 34.1.4.14.4 Waste Reactivity 0 1.00 2 0 3 6 24.1.4.14.5 Waste Volatility 0 1.00 2 0 3 6 24.1.4.14.6 Waste Toxicity 0 1.00 2 0 3 6 24.1.4.14.7 Solubility 0 1.00 1 0 3 3 14.1.4.14.8 Persistence 0 1.00 1 0 3 3 14.1.4.15 Fuel Blending Wastes4.1.4.15.1 Maximum Daily Throughput 2 0.75 1 2 5 5 14.1.4.15.2 Physical State 2 0.75 1 2 2 2 14.1.4.15.3 Waste Flammability 3 0.75 3 9 3 9 24.1.4.15.4 Waste Reactivity 2 0.75 2 4 3 6 24.1.4.15.5 Waste Volatility 2 0.75 2 4 3 6 24.1.4.15.6 Waste Toxicity 3 0.75 2 6 3 6 24.1.4.15.7 Solubility 1 0.50 1 1 3 3 14.1.4.15.8 Persistence 2 0.50 1 2 3 3 14.1.4.16 Metals Recovery Wastes4.1.4.16.1 Maximum Daily Throughput 0 1.00 1 0 5 5 14.1.4.16.2 Physical State 0 1.00 1 0 2 2 14.1.4.16.3 Waste Flammability 0 1.00 3 0 3 9 34.1.4.16.4 Waste Reactivity 0 1.00 2 0 3 6 24.1.4.16.5 Waste Volatility 0 1.00 2 0 3 6 24.1.4.16.6 Waste Toxicity 0 1.00 2 0 3 6 24.1.4.16.7 Solubility 0 1.00 1 0 3 3 14.1.4.16.8 Persistence 0 1.00 1 0 3 3 1



Ques # Question Score CF Multi Total Max Max Conf4.1.4.17 Energy Recovery Wastes4.1.4.17.1 Maximum Daily Throughput 0 1.00 1 0 5 5 14.1.4.17.2 Physical State 0 1.00 1 0 2 2 14.1.4.17.3 Waste Flammability 0 1.00 3 0 3 9 34.1.4.17.4 Waste Reactivity 0 1.00 2 0 3 6 24.1.4.17.5 Waste Volatility 0 1.00 2 0 3 6 24.1.4.17.6 Waste Toxicity 0 1.00 2 0 3 6 24.1.4.17.7 Solubility 0 1.00 1 0 3 3 14.1.4.17.8 Persistence 0 1.00 1 0 3 3 14.2 TARGET COMPONENTS 4.2.1 Population Within 3 Miles 5 0.75 2 10 5 10 24.2.2 Proximity to Nearest Residence 4 0.75 2 8 4 8 24.2.3 Proximity to Commerc. Complex 4 0.75 2 8 4 8 24.2.4 Predominant land use w/in 3 mi 2 0.75 1 2 4 4 14.2.5 Prox. to sensitive populations 3 0.75 1 3 4 4 15.0 FACILITY OPERATIONS5.1 HISTORICAL COMPONENTS 5.1.1 Years site used - waste. mgt. 3 1.00 2 6 3 6 25.1.2 Previous Site Use 3 1.00 3 9 4 12 35.1.3 Closed Waste Management Units 2 0.75 2 4 2 4 25.1.4 Unregulated waste mgt units 2 0.75 3 6 2 6 25.2 CURRENT OPERATIONS 5.2.1 Laboratory Operations 0 0.75 1 0 2 2 15.2.2 Quality Controls 0 0.75 1 0 3 3 15.2.3 Housekeeping 0 0.75 2 0 3 6 25.2.4 Maintenance 0 0.75 2 0 3 6 25.2.5 Residuals Management 1 0.75 3 3 2 6 25.2.6 Security 0 0.75 1 0 3 3 15.3 MANAGEMENT 5.3.1 Management Qualifications 0 1.00 2 0 3 6 25.3.2 Labor Relations 1 0.75 1 1 3 3 15.3.3 Public Relations 0 0.75 1 0 3 3 15.4 REGULATORY ASSESSMENT 5.4.1 Hazardous Waste/Substance Mgt5.4.1.1 Permit Status - Haz Waste 0 1.00 3 0 3 9 35.4.1.2 Compliance Record (for 5 yrs) 0 1.00 2 0 3 6 25.4.1.3 Agency Opinion of Facility 0 1.00 1 0 2 2 15.4.2 Waste Water Discharges 5.4.2.1 Permit Status - Water 0 0.75 2 0 3 6 25.4.2.2 Compliance Record (for 5 yrs) 1 0.75 2 2 3 6 25.4.2.3 Agency Opinion of Facility 0 0.75 1 0 2 2 15.4.3 Air Emissions 5.4.3.1 Permit Status - Air 0 0.75 2 0 3 6 25.4.3.2 Compliance Record (for 5 yrs) 1 0.75 2 2 3 6 25.4.3.3 Agency Opinion of Facility 0 0.75 1 0 2 2 15.5 CERCLA/Superfund 0 0.75 1 0 2 2 15.6 OCCUPATIONAL HEALTH AND SAFETY 5.6.1 Adeq. of Mgt System Implement. 0 0.75 1 0 3 3 15.6.2 Health Monit & Surveillance 0 0.75 1 0 3 3 15.6.3 Observed Use of PPE 0 0.75 1 0 3 3 15.6.4 Emergency Response Capability 0 0.75 2 0 3 6 25.6.5 Adequacy of HazCom Program 0 0.75 1 0 3 3 15.6.6 Facility Safety Record 1 0.75 1 1 3 3 16.0 FINANCIAL STRENGTH6.1 ECONOMIC TRENDS 6.1.1 Net Sales 1 1.00 1 1 2 2 16.1.2 Net Income 0 1.00 1 0 2 2 16.1.3 Net Worth 0 1.00 1 0 2 2 16.1.4 Working Capital 0 1.00 2 0 2 4 26.2 BUSINESS PERFORMANCE 6.2.1 Current Ratio 0 1.00 1 0 1 1 16.2.2 Debt Equity Ratio 1 1.00 2 2 1 2 26.2.3 Return on Equity Ratio 0 1.00 1 0 1 1 16.2.4 Profit Margin Ratio 2 1.00 2 4 2 4 26.3 BANKRUPTCY POTENTIAL 0 1.00 1 0 2 2 16.4 ORDERLY LIQUIDATION 6.4.1 Secured Funds vs Mitigat. Cost 2 0.75 1 2 3 3 16.4.2 Ability to Fund Mitigation 0 1.00 1 0 3 3 1

Risk Assessment System (RAS)

Supplementary Information

This handout contains descriptions of questions contained in the RAS that require additional information that may not be required to complete the CHWMEG, Inc. questionnaire. This information is confidential and is only to be used by CHWMEG, Inc. preferred auditing contractors.

©2011 CHWMEG®, Inc.

Risk Assessment System i © 2011 CHWMEG, Inc.

ADDITIONAL RAS INFORMATION Certain RAS questions require additional information or knowledge not currently collected in the questionnaire. This document provides some awareness to these additional information requirements. Some information resources are provided. It is the auditor’s responsibility to ensure that all applicable RAS questions are answered The following table contains a reference to questions that may need information not specified in the questionnaire:

Number Question / Necessary Information 1.2.3 Aquifer thickness and permeability. The question is answered

using a matrix in the RAS file. Required are the thickness in feet and permeability in cm/sec.

1.2.4 Confining layer thickness and permeability. The question is answered using a matrix in the RAS file. Required are the thickness in feet and permeability in cm/sec.

2.2.1 Site topography and intervening terrain. The question is answered using a matrix in the RAS file. Required are the terrain average slope and type of intervening terrain.

2.2.3 – 2.2.6 Annual weather information. Required are the one year 24 hour precipitation, flood potential, annual precipitation, and annual evapotranspiration.

2.3.4 Proximity to sensitive natural receptors. Required is the distance to wetlands and critical habitats.

4.1.1.3 Facility damage in US dollars from fire or explosion damage 5.1.3 Closed waste management units

5.4.1.2, 5.4.2.2, 5.4.3.2,

5 year compliance record for hazardous waste, water, and air emissions.

See the following sections for additional RAS information.

Additional RAS Information: Section Title 1.0 Example RAS Questions Requiring Additional Information 2.0 SAX Toxicity Levels 3.0 NFPA Toxicity Levels 4.0 Table 1. HRS Persistence Level for Common Chemicals 5.0 Table 2. HRS Persistence Level for Organic Compounds 6.0 NFPA Flammability and Reactivity Levels

Risk Assessment System ii © 2011 CHWMEG, Inc.

SPECTRUM CHEMICALS WEBSITE Many questions in the RAS ask for the “worst-case” chemical treated, stored, or disposed in any given on-site unit. For observed releases, you need to know the “worst-case” chemical released. Once the chemical is known, there are some resources available to determine the RAS values for these chemicals. A useful on-line resource is the “Spectrum Chemicals” website: http://www.spectrumchemical.com When you get to the home page, there is a “Search” box on the top of the page. Type the chemical of interest in the box and click the “GO” button. If the chemical is found, you will either get a list of products. Click on the most appropriate product (i.e., “reagent grade”). Once you are at the page for that chemical, you will see the following at the top of the page (the example search string was “trichloroethylene”):

The most useful information is the blue-red-yellow box that shows 3 properties of this chemical for the RAS: H: 2 This is the NFPA Health Hazard (or Toxicity). For this chemical, all RAS

questions for toxicity would be answered with a “2”. F: 1 This is the NFPA Flammability. For this chemical, all RAS questions for

flammability would be answered with a “1”. R: 0 This is the NFPA Reactivity. For this chemical, all RAS questions for reactivity

would be answered with a “0”. Note that a Health, Flammability, or Reactivity value of “4” equates to a score of “3” in the RAS. Next, you could use the table in Section 5.0 of this document to determine that the Persistence is “2”. IMPORTANT! When completing the RAS, please understand that there may be different “worst-case” chemicals in each on-site unit. However, at some facilities, the chemical may be the same for all on-site units.

Risk Assessment System 1-1 ©2011 CHWMEG, Inc.

1.0 Example Questions Requiring Additional Information I. Example questions from RAS that may require information not required for the protocol. A) “SAX Level” Example (22 questions): Waste Toxicity • None - Sax Level 0 0 • Low - Sax Level 1 1 • Moderate - Sax Level 2 2 • High/Carcinogenic - Sax Level 3 3 Recommendations: “Sax Level” is equivalent to “NFPA Health Hazard”. Auditing contractor needs to know the specific worst-case chemical from OBSERVED contamination, and the worst-case chemical in waste streams (for each treatment type) that can cause the greatest POTENTIAL harm with respect to toxicity. Next, use Section 2.0 or 3.0 of this document (auditor’s preference) to determine toxicity level. You can also refer to the “Spectrum Chemicals” website referenced in the introduction of this document. B) “Persistence of Contaminants” Example (19 questions): Persistence of contaminants • None - USEPA HRS Level 0 0 • Low - USEPA HRS Level 1 1 • Moderate - USEPA HRS Level 2 2 • High - USEPA HRS Level 3 3 Recommendations: Auditing contractor needs to know specific chemicals from OBSERVED contamination, and chemicals in waste streams (for each treatment type) that can cause the greatest POTENTIAL harm with respect to persistency. Next, use Section 4.0 (basic list of chemicals) or Section 5.0 (more comprehensive list) to determined the persistence. C) “Seismic Activity” Example (1 question – 1.2.7): Seismic activity • None - USGS Zone 0 0 • Low - USGS Zone 1 1 • Moderate - USGS Zone 2 2 • High - USGS Zones 3 and 4 3 Recommendations: Auditing contractor should see if facility personnel know the answer. If not, use the map in the RAS2009.xls file that is next to question 1.2.7 to best approximate the answer based on facility location. D) “Reactivity of Contaminants” Example (19 questions): Reactivity of contaminants • Not reactive - NFPA Level 0 0 • Low - NFPA Level 1 1 • Moderate - NFPA Level 2 2 • High - NFPA Levels 3 and 4 3


Recommendations: Auditing contractor needs to know the specific worst-case chemical from OBSERVED contamination, and the worst-case chemical in waste streams (for each treatment type) that can cause the greatest POTENTIAL harm with respect to reactivity. Next, use Section 6.0 of this document to determine the reactivity. You can also refer to the “Spectrum Chemicals” website referenced in the introduction of this document. E) “Waste Flammability” Example (17 questions): Waste Flammability • Not flammable - NFPA Level 0 0 • Low - NFPA Level 1 1 • Moderate - NFPA Level 2 2 • High - NFPA Levels 3 and 4 3 Recommendations: Auditing contractor needs to know the specific worst-case chemical from OBSERVED contamination, and the worst-case chemical in waste streams (for each treatment type) that can cause the greatest POTENTIAL harm with respect to flammability. Next, use Section 6.0 to determine the flammability. You can also refer to the “Spectrum Chemicals” website referenced in the introduction of this document. F) Site Topography and Intervening Terrain Example (for surface water, question 2.2.1):

Intervening Terrain Terrain Average Slope Less Terrain Terrain Terrain Than 3% or Site Separated Avg. Avg. Avg. Site in from Water Body Slope Slope Slope Surface By Areas of Facility Slope Higher Elev. 3-5% 5-8% Over 8% Water

Facility is closed basin 0 0 0 0 3 Facility average slope <3% 0 1 1 2 3 Average slope 3-5% 0 1 2 2 3 Average slope 5-8% 0 2 2 3 3 Average slope Over 8% 0 2 3 3 3 Recommendations: Auditing contractor should have a fair knowledge of the facility and intervening terrain. The above matrix is then used to answer the question. This matrix is also in the RAS2009.xls file next to question 2.2.1. II. The following is to let the auditing contractor aware of other information to look for during the

site visit: A) Prevention of Release from Treatment Technologies: • Adequacy of monitoring procedures for below ground tanks • Adequacy of monitoring procedures (with respect to groundwater, surface water, air, and fire &

explosion releases) for the following technology types: Container Storage, Tank Storage, Surface Impoundments, Waste Piles, Landfills, Landfarms, Underground Injection.


B) Groundwater: • Aquifer Thickness and Permeability • Confining Layer Thickness and Permeability • Unsaturated Zone Permeability • Population Served By Groundwater (within 3 miles) • Natural Receptors (within 1 mile) C) Surface Water: • One-Year 24-Hr. Precipitation • Annual Precipitation • Annual Evapotranspiration • Surface Water Use Within 3 Miles • Proximity to Closest User Intake • Population Served by Surface Water Within 3 Miles • Distance to wetlands and critical habitats D) Air Releases: • Population Within 3 Miles • Proximity to Nearest Residence • Proximity to Nearest Commercial/Industrial Complex • Predominant Land Use Within 3 Miles (No defined use, Agricultural, Commercial/Industrial,

Residential, or Parks/Game Preserves) • Vapor pressure of materials processed E) Fire & Explosion Releases: • Facility Damage from Fire or Explosion (dollar value) • Responses to Prevent Recurrence • Proximity of All Technology Types to Heat or Ignition Source • Grounding Measures (for wastes) • Explosion Proof Measures (for technologies) F) Waste Management Operations: • Maximum Daily Waste Quantity in Storage (in drums) • Maximum Daily Waste Quantity in Storage (for tanks in gallons) • Maximum Daily Waste Quantity in Storage (for surface impoundments in gallons) • Maximum Daily Waste Quantity in Storage (for waste piles in cubic yards) • Total Waste Quantity to Date Including Closed Cells (for landfills in cubic yards) • Total Waste Quantity to Date Including Closed (for landfarms in acres) • Total Waste Quantity to Date (for underground injection in gallons) • Physical Treatment Wastes Maximum Daily Throughput (in tons, cubic yards, or gallons) • Chemical Treatment Wastes Maximum Daily Throughput (in tons, cubic yards, or gallons) • Biological Treatment Wastes Maximum Daily Throughput (in gallons) • Thermal Treatment Wastes Maximum Daily Throughput (in tons) • Incineration Treatment Wastes Maximum Daily Throughput (in tons) • Solvent Reclamation Wastes Maximum Daily Throughput (in gallons) • Oil Reclamation Wastes Maximum Daily Throughput (in gallons) • Fuel Blending Wastes Maximum Daily Throughput (in gallons) • Metals Recovery Wastes Maximum Daily Throughput (in tons, cubic yards, or gallons) • Energy Recovery Wastes Maximum Daily Throughput (in tons)


G) Site History & Current Operations: • Years Site Used for Waste Management • Previous Site Use • Closed Waste Management Units • Unregulated Waste Management Units • Labor Relations (Non-union workforce, Good union relations, or Potential labor conflicts) H) Financial Operations: NOTE: Be sure to enter responses to the last question of the RAS! This is often overlooked

since the rest of the responses in Section 6 of the RAS are automatically calculated! This is question 6.4.2.

Auditing contractor should be able to provide all of the financial information requested in the RAS (question 6.0). The Altman Z-Scores and financial ratios are automatically calculated when this section is completed. The administrator will provide the necessary financial information for publicly traded firms and facilities with publicly traded parent companies (see Figure 1-1). The information requested for the most recent three fiscal years are: • Total Assets • Total Liabilities • Current Assets • Current Liabilities • Long Term Debt • Earnings Before Interest or Taxes (EBIT); a.k.a. Operating Profit/Loss • Retained Earnings (cumulative) or, if negative, Accumulated Deficit • Net Sales • Net Income The following are brief definitions of some financial terms: Term Definition Current Assets: Cash, accounts receivable, inventory, and other assets that are likely

to become cash within a year. Current Liabilities: Debts or other obligations coming due within a year. Current Ratio: Current assets divided by current liabilities. The current ratio is a

measure of the firm's immediate financial health and its ability to meet current obligations.

Debt to Equity Ratio: The long-term debt divided by the shareholder’s equity. Earnings Before Interest or Taxes:

Earnings before interest and taxes. This is the figure for operating income after depreciation but without allowing for debt service or what is owed to the government for taxes.

Long Term Debt: Loans and financial obligations lasting over one year on which interest is paid.

Net Income: Also known as earnings or profit. Net income is probably the most closely watched item in a company's financial reports.

Net Sales: This represents all net sales of the corporation plus any other revenues associated with the main operations of the business (or those labeled as operating revenues). It does not include dividends, interest income, or non-operating income.

Net Working Capital: Current assets minus current liabilities. A firm's working capital is the money it has available to meet current obligations (those due in less than a year).


Term Definition Profit Margin Ratio: Subtract cost of goods sold from net sales, and divide the result by net

sales, or net income divided by net sales. Retained Earnings: The portion of net income retained for reinvestment in the company

rather than being paid in dividends to shareholders. If negative, it is sometimes “Accumulated Deficit”.

Return on Equity Ratio: The net income divided by the shareholder’s equity. Stockholder’s Equity: This is the net worth of a company, the amount by which total assets

exceed total liabilities. It's also known as “book value”. Total Assets: Current assets plus non-current assets. Non-current assets are

assets not expected to be converted into cash, sold, or exchanged within the normal operating cycle of a company, typically one year.

Total Liabilities: The sum of total current liabilities and total non-current liabilities. Non-current liabilities are liabilities due after one year.


Figure 1-1. Example of Financial Information Provided for Publicly Traded Companies.

Risk Assessment System 2-1 ©2011 CHWMEG, Inc

2.0 Sax Toxicity Levels (Auditor can also use NFPA Toxicity in Section 3.0)

0 = No Toxicity (None) This designation is given to materials which fall into one of the following categories: (a) Materials which cause no harm under any conditions of normal use. (b) Materials which produce toxic effects on humans only under the most unusual

conditions or by overwhelming dosage.

1 = Slight Toxicity (Low) In general, those substances classified as having “slight toxicity” produce changes in the human body which are readily reversible and which will disappear following termination of exposure, either with or without medical treatment. (a) Acute local. Materials which on single exposures lasting seconds, minutes, or

hours cause only slight effects on the skin or mucous membranes regardless of the extent of exposure.

(b) Acute systemic. Materials which can be absorbed into the body by inhalation, ingestion, or through the skin and which produce only slight effects following single exposure lasting seconds, minutes, or hours, or following ingestion of a single dose regardless of the quantity absorbed or the extent of exposure.

(c) Chronic local. Materials which on continuous or repeated exposures extending over periods of days, months, or years cause only slight and usually reversible harm to the skin or mucous membranes. The extent of exposure may be great or small.

(d) Chronic systemic. Materials which can be absorbed into the body by inhalation, ingestion, or through the skin and which produce only slightly usually reversible effects extending over days, months, or years. The extent of the exposure may be great or small.

2 = Moderate Toxicity (Moderate)

Those substances classified as having “moderate toxicity” may produce irreversible as well as reversible changes in the human body. These changes are not of such severity as to threaten life or to produce serious physical impairment. (a) Acute local. Materials which on single exposures lasting seconds, minutes, or

hours cause moderate effects on the skin or mucous membranes. These effects may be the result of intense exposure for a matter of seconds or moderate exposure for a matter of hours.

(b) Acute systemic. Materials which can be absorbed into the body by inhalation, ingestion, or through the skin and which produce moderate effects following single exposure lasting seconds, minutes, or hours, or following ingestion of a single dose.

Risk Assessment System 2-2 ©2011 CHWMEG, Inc

(c) Chronic local. Materials which on continuous or repeated exposures extending over periods of days, months, or years cause moderate harm to the skin or mucous membranes.

(d) Chronic systemic. Materials which can be absorbed into the body by inhalation, ingestion, or through the skin and which produce moderate effects following continuous or repeated exposures extending over periods of days, months, or years.

3 = Severe Toxicity (High/Carcinogenic)

(a) Acute local. Materials which on single exposures lasting seconds or minutes

cause injury to skin or mucous membranes of sufficient severity to threaten life or to cause permanent physical impairment or disfigurement.

(b) Acute systemic. Materials which can be absorbed into the body by inhalation, ingestion, or through the skin and which can injury of sufficient severity to threaten life following a single exposure lasting seconds, minutes, or hours, or following ingestion of a single dose.

(c) Chronic local. Materials which on continuous or repeated exposures extending over periods of days, months, or years can cause injury to skin or mucous membranes of sufficient severity to threaten life or cause permanent physical impairment, disfigurement, or irreversible change.

(d) Chronic systemic. Materials which can be absorbed into the body by inhalation, ingestion, or through the skin and which can cause death or serious physical impairment following continuous or repeated exposures to small amounts extending over periods of days, months, or years.


3.0 NFPA Toxicity (Health Hazard) Levels (Auditor can also use Sax Toxicity in Section 2.0) From NFPA 704 System: 0 No Hazard 1 Can cause irritation 2 Can cause injury upon exposure. Respiratory protective equipment is necessary. 3 Can cause serious injury on short exposure. Gives off highly toxic combustion

products. Full protective clothing is necessary. 4 Too dangerous to approach without specialized protective equipment. Can cause

death. This equates to a RAS response of “3”. From 40 CFR, Part 300, Appendix A: 0 Materials which on exposure under fire conditions would offer no health hazard beyond

that of ordinary combustible material. 1 Materials only slightly hazardous to health. It may be desirable to wear self-contained

breathing apparatus. 2 Materials hazardous to health, but areas may be entered freely with self-contained

breathing apparatus. 3 Materials extremely hazardous to health, but areas may be entered with extreme care.

Full protective clothing, including self-contained breathing apparatus, rubber gloves, boots and bands around legs, arms and waist should be provided. No skin surface should be exposed.

4 A few whiffs of the gas or vapor could cause death, or the gas, vapor, or liquid could be

fatal on penetrating the fire fighters’ normal full protective clothing which is designed for resistance to heat. For most chemicals having a health 4 rating, the normal full protective clothing available to the average fire department will not provide adequate protection against skin contact with these materials. Only special protective clothing designed to protect against the specific hazard should be worn.

Once the NFPA Level is determined, the score converts to RAS scores using the following table:

NFPA RAS Level 0 0 Level 1 1 Level 2 2 Level 3 or 4 3


4.0 HRS Persistence Level for Some Common Chemicals

Use the score given below as the answer to RAS questions. If the compound is not listed, see Section 5.0.

Chemical HRS Chemical HRS Acetaldehyde 0 Isopropyl Ether 1 Acetic Acid 0 Lindane 3 Acetone 0 Methane 1 Aldrin 3 Methanol 0 Ammonia, Anhydrous 0 Methyl Ethyl Ketone 0 Aniline 1 Methyl Parathion in Benzene 1 Xylene Solution 0 Carbon Tetrachloride 3 Napthalene 1 Chlordane 3 Nitric Acid 0 Chlorobenzene 2 Parathion 0 Chloroform 3 PCB 3 o-Cresol 1 Petroleum, Kerosene m- p-Cresol 1 (Fuel Oil No. 1) 1 Cyclohexane 2 Phenol 1 Endrin 3 Sulfuric Acid 0 Xylene 1 Toluene 1 Formaldehyde 0 Trichlorobenzene 3 Formic Acid 0 α-Trichloroethane 2 Hydrochloric Acid 0 Xylene 1


5.0 HRS Persistence Level for Some Organic Compounds (by Level)

Chemicals are grouped by level, then alphabetical. Use the “Level” to answer RAS questions.

Level 3 (High) Level 2 (Moderate) Level 1 (Low) Level 0 (None) aldrin acenaphthylene acetylene dichloride acetaldehyde benzopyrene atrazine behenic acid, methyl ester acetic acid benzothiazole (diethyl) atrazine benzene acetone benzothiophene barbital benzene sulfonic acid acetophenone benzyl butyl phythalate borneol butyl benzene benzoic acid bromochlorobenzene bromobenzene butyl bromide di-isobutyl carbinol bromodichloromethane camphor 3-caprolactam docosane bromoform chlorobenzene carbon disulfide eicosane bromoform butanal 1,2-bis-chloroethoxy ethane o-cresol ethanol bromophenyl phyntyl ether b-chloroethyl methyl ether decane ethylamine carbon tetrachloride chloromethyl ether 1,2-dichloroethane hexadecane chlordan chloromethyl ethyl ether 1,2-dimethoxy benzene methanol chloroform 3-chloropyridine 1,3-dimethyl napthalene methyl benzoate chlorohydroxy benzophenone di-t-butyl-p-benzoquinone 1,4-dimethyl phenol 3-methyl butanol bis-chloroisopropyl ether dichloroethyl ether dioctyl adipate methyl ethyl ketone chloromochloromethane dihyrocarvone n-decane 2-methylpropanol m-chloronitrobenzene dimethyl sulfoxide ethyl benzene octadecane DDE 2,6-dinitrotoluene 2-ethyl-n-hexane pentadecane DDT cis-2-ethyl-4-methyl-1,3-dioxolane o-ethyl toluene pentanol dibromobenzene trans-2-ethyl-4-methyl-1,3-dioxolane isodecane propanol dibromodichloroethane guaiacol isopropyl benzene propylamine dibutyl phthalate 2-hydroxyadiponitrile limonene tetradecane 1,4-dichlorobenzene isophorone methyl ester of lignoceric acid n-tridecane dichlorodifluoroethane indene methane n-undecane dieldrin isoborneol 2-methyl-5-ethyl-pyridine diethyl phthalate isoprophenyl-r-isopropyl benzene methyl napthalene di (2-ethylhexyl) phthalate 2-methoxy biphenyl methyl palmitate dihexyl phthalate methyl biphenyl methyl phenyl carbinol di-isobutyl phthalate methyl chloride methyl stearate dimethyl phthalate methylindene napthalene 4,6-dinitro-2-aminophenol methylene chloride nonane dipropyl phythalate nitroanisole octane endrin nitrobenzene octyl chloride heptachlor 1,1,2-trichloroethylene pentane heptachlor epoxide trimethyl-trioxo-hexahydrotriazine isomer phenyl benzoate 1,2,3,4,5,7,7-heptachloronorborene phthalic anhydride hexachlorobenzene propyl benzene hexachloro-1,3-butadiene 1-terpineol hexachlorocyclohexane toluene hexachloroethane vinyl benzene methyl benzothiazole xylene pentachlorobiphenyl pentachlorophenol 1,1,3,3-tetrachloroacetone tetrachloroethane tetrachlorophenyl thiomethylbenzothiazole trichlorobenzene trichlorobiphenyl 1,1,2-trichloroethane trichlorofluoromethane 2,4,6-trichlorophenol triphenyl phosphate

(not used here, see NFPA

Toxicity Levels)

(not used)

4. Readily capable of detonation or explosive reaction at normal temperatures.

3. May detonate if exposed to heat or shock.2. Undergo violent chemical change at

elevated temperatures and pressures.1. Normally stable. Can be unstable at

elevated temperatures and pressures.

4. Rapidly vaporize or are readily dispersed in air. Will burn readily in air. Extremely flammable

3. Ignite under normal conditions. Produce hazardous atmospheres with air.

2. Will ignite when moderately heated.1. Must be preheated before ignition can occur.

6.0 FLAMMABILITY AND REACTIVITY - NFPA LEVEL(From the NFPA 704 System)

NFPALevel 0 (Blank)

Level 1Level 2Level 3Level 4

RAS01233

Score Conversion

Once the released, or waste chemicals are known, the NFPA ratings should be used to determine the flammability, reactivity, and toxicity levels by researching the NFPA label for that chemical!

Flammability Hazards

Reactivity Hazards

Health Hazards

Special Hazards

Flammability Hazards

Health Hazards

Reactivity Hazards

Special Hazards

RAS Assessment System © 2011 CHWMEG, Inc.6-1

Risk Assessment System (version RAS 98)

INSTRUCTION MANUAL

Initial Release – February, 1999

PROPRIETARY

Provided to preferred CHWMEG, Inc. auditing contractorsfor the sole purpose of support to CHWMEG, Inc. Nocopies or distribution to any other party (including auditingcontractor employees who directly support CHWMEG, Inc.and with a bona fide need-to-know) is authorized withoutexpress written consent of CHWMEG, Inc.

Brian Bosilovich

Brian Bosilovich

Brian Bosilovich

Brian Bosilovich

See the "Help" file link in the RAS file for more info!

Brian Bosilovich

CHWMEG, Inc. Proprietary Document ©1999 CHWMEG, Inc.Risk Assessment System

i

TABLE OF CONTENTS

Section Page

1.0 Introduction.....................................................................................................1

1.1 Features.................................................................................................11.2 Terminology ...........................................................................................1

2.0 System Requirements ....................................................................................3

3.0 Completing a Facility RAS .............................................................................4

3.1 First Time Use........................................................................................43.2 Getting Started.......................................................................................4

3.2.1 Opening the File ..........................................................................43.2.2 Saving the File.............................................................................43.2.3 Home Screen ..............................................................................5

3.3 Entering Data .........................................................................................5

3.3.1 Facility Information ......................................................................53.3.2 Questions and Answers...............................................................6

How to Answer Drop-Down Questions ........................................6Error Messages ...........................................................................7Manually Entered Answers..........................................................7Confidence Factors .....................................................................8

3.3.3 Financial Information ...................................................................8

4.0 Additional Information...................................................................................10

Appendix A................................................................................................................11


ii

LIST OF FIGURES

Figure Page

1 View of Drop Down Boxes .............................................................................6

2 Error Messages...............................................................................................7

3 Drop Down Box in Financial Information Section........................................8

LIST OF TABLES

Table Page

1 HRS Persistence Level for Some Common Chemicals ...........................A-4-1

2 HRS Persistence Level for Some Organic Compounds ..........................A-5-1


1

1.0 INTRODUCTION

1.1 Features

This file has been created to replace the previous version of the CHWMEG, Inc. RiskAssessment System (RAS), which required Lotus 1-2-3 version 3.0 or later to run. Thisfile runs in Microsoft Excel 97, and has been designed with the following features:

• Mouse point and click to answer most of the questions• Mouse point and click to answer all confidence factors• Built in error checking to determine if a question has been answered incorrectly

(“incorrectly” in this sense refers to selecting a “blank line” as an answer – this willbe discussed in detail later)

• Input of readily available financial information automatically answers some questions– and computes information such as Debt to Equity Ratio, Z-scores, etc., that arealso required in the protocol

• A help file which contains instructions, hints, contacts, and information about theprogram

• Links are available, so you can instantly “jump” to any section of the RAS file• Write protection to prevent inadvertently saving a RAS facility file over the original

file

It is highly recommended that you have the RAS98.xls file open when reviewing theseinstructions for the first time.

1.2 Terminology

This section contains some definitions used in this manual and the RAS98 file.

Confidence factors – answered through the use of “drop-down boxes,” confidencefactors cannot cause an error message.

Drop down boxes – a box that contains the responses for each question and confidencefactor. Simply click on the down arrow at the right of the box, then select a response.

Drop down questions – questions that consist of a box that contains the question and allanswers. Select an answer from the list with the mouse cursor.

Error messages – messages that appear at the top of the screen if you (1) answer amanually answered question incorrectly or (2) select the blank line or 2nd line of aquestion as a response

Facility information – location to enter information about the facility and audit, such asfacility name, parent company name, city, state, date of visit, auditor name, andauditor’s company. Only the parent company can be left blank.


2

Facility RAS file – an individual file created when making a RAS. Due to writeprotection, the file cannot be saved as “RAS98.xls.” You must “Save As… ” and give thefile a unique name (such as “RAS Laidlaw, Westmorland, CA.xls”

File header – a range of 6 lines at the top of the sheet that is frozen so it is always at thetop. The header contains the help file, links, and error messages.

Financial information – basic information from recent forms 10-K or annual reports. Thisinformation is used in Section 6.0 to calculate ratios, Z-scores, etc. All financialinformation asked for is required!

Go to top – a “clickable” link at the beginning of each section that returns the cursor tothe top of the sheet.

Help file – this file is opened by double clicking on the “RAS Help” icon at the top of thepage. (NOTE: if a dialog box opens warning of possible hazards, click “Yes” tocontinue).

Links – are at the top far right of the file header. Single click on any link to instantlyjump the cursor to that section.

List of questions – the original list of questions can be accessed by clicking on the“Questions” worksheet tab.

Manually answered questions – four of the questions are based on matrices rather thanlists. Use the table (usually to the right of the question) to find the best response, thentype the answer in the shaded, double boxed cell. If the answer is out of range, you willget an error message.

RAS98 file – this is the original file, in which all questions default to an answer of 0, andall confidence factors default to an answer of 1.00. Always select “Save As… ”immediately after opening, and save your current file with a new name. Never, ever,ever try to save the current file on top of the original RAS98.xls file.

Worksheet protection – all elements of the sheet are protected so the math thatcalculates the RAS scores are protected. This prevents the user from inadvertently (1)deleting something important, (2) altering the calculations, (3) changing formatting, (4)etc. You get the point.

Write protection – the file is write protected so that Excel automatically tells you to use“Save As… ” to save the file. This protects the integrity of the original file.

IMPORTANT NOTE: Always start with the original file (RAS2003.xls) when starting a newRAS facility file so that ALL of the questions and confidence factors are set to defaults.If you try to alter an existing RAS file, you may miss something important, causing thescores to be erroneous!

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3

2.0 SYSTEM REQUIRMENTS

The CHWMEG, Inc., Risk Assessment System (RAS) requires Microsoft Excel97, whichis part of the Office97 package. Excel97 is a standard component of both Office97Standard and Office97 Professional is required.

The filename is “RAS98.xls” and will not work with prior versions of Excel (versions 95of 6.0). The following table lists the system requirements, and the recommendedsystem requirements for Office97.

System Requirements Recommended

Personal or multimedia computer with a 486 orhigher processor

Pentium processor at 133 MHz

Microsoft Windows 95 operating system orMicrosoft Windows NT® Workstation 3.51 ServicePack 5 or later (will not run on earlier versions)

Microsoft Windows 95

For use on Windows 95: 8 MB of memoryrequired to run applications individually

12 MB required to run Microsoft Access; morememory may be required to run additionalapplications simultaneously

For use on Windows NT Workstation: 16 MB ofmemory required to run applications individually

More memory may be required to runadditional applications simultaneously

Office Standard hard-disk space required: 60–167MB

Approximately 102 MB required for typicalinstallation, depending on configuration

Office Professional hard-disk space required: 73–191 MB

Approximately 121 MB required for typicalinstallation, depending on configuration

For Office Installation: CD-ROM drive (3.5” high-density disks available free of charge fromMicrosoft)

CD-ROM drive

VGA or higher-resolution video adapter Super VGA, 256-color recommended

Standard 2-button mouse or compatible pointingdevice

Standard 2-button mouse

CHWMEG, Inc., is not responsible for loss of data or other malfunction during theinstallation of the Microsoft Office97 package. Consult your system administrator orMicrosoft directly for technical support regarding any aspects of the installation ofOffice97.

CHWMEG highly recommends setting your display to a resolution of at least 800 x 600(or higher), with small fonts. Other display settings may limit the on-screen display ofthe CHWMEG, Inc. file. The user would then have to scroll left and right, which couldbe time consuming.


4

3.0 COMPLETING A FACILITY RAS

3.1 First Time Use

CHWMEG is supplying the RAS program on a high density 3.5” floppy diskette. The fileis entitled “RAS98.xls”, and is approximately 1,270 kilobytes (1.27Mb).

CHWMEG highly recommends copying the RAS98.xls file to a dedicated subdirectoryon your hard drive prior to use. This will allow the 3.5” diskette to be used as a backupshould the copied file become corrupt or deleted.

3.2 Getting Started

3.2.1 Opening the File

Every time you open the file, you will see the following dialog box:

The reason this box appears is because some of the features used in the program (e.g.,drop-down boxes) are interpreted as macros, although they are not truly Excel Macros.You should always click “Disable Macros” to finish opening the file. This allows normaloperation of the RAS98 file, and also protects the user in the event that the file wasinfected with a macro virus.

3.2.2 Saving the File

CHWMEG Inc. has taken several precautions to protect the integrity of the originalRAS98.xls file, and any subsequent facility RAS files created from this file.

• Write Protection – The original RAS98.xls file is write protected to prevent saving afacility RAS file over the original version.

• Protected Sheets – All of the worksheets in the file are password protected so thatonly necessary changes can be made to the sheet. This prevents inadvertentchanges from being made to the file, and protects the final RAS scores.


5

NOTE: Because of the write-protection, CHWMEG strongly recommends saving the filewith the new file name before beginning every RAS session. Use the “Save-As” command under the “File” menu.

Use common sense file names when saving, since Windows 95 supports long filenames. For example, if the audit is for Safety Kleen in Dolton, Ohio, save the file assomething like: “RAS S-K, Dolton, OH.xls”. The CHWMEG administrator is trying toavoid receiving files with names such as: “RAS023045.xls”.

3.2.3 Home Screen

The user should have a basic understanding of Microsoft Excel before attempting tocreate a RAS file. Call Brian Bosilovich at (412) 826-3060 if you have any technicalquestions.

Upon opening, the RAS98 file should be at the very top of the sheet, with the cellpointer in cell A7. Rows 1 through 6 are locked and will always be at the top of theviewing area. These rows contain some information about the file, the column headers,and error messages. The error messages will be discussed later in section 3.3.2.

These rows also contain other useful features: The RAS Help file and links (at the topfar right) to every section in the RAS file. Double click the RAS Help box to start thehelp program. A single click on any of the links will move the cursor to that section.

All of the scores default to “0” and all of the confidence factors default to “1.00”. Also,all of the questions in the drop-down boxes default to their initial position. Drop-downboxes will be discussed in section 3.3.

NOTE: When starting a new RAS file for a different facility, ALWAYS use theRAS98.xls file. This will ensure that all scores default to “0” and all confidencefactors default to “1.00”

3.3 Entering Data

The RAS98 file allows data entry in two methods: drop-down boxes for the questionsand confidence factors, and manual entry for facility information, financial information,and certain questions.

3.3.1 Facility Information

The first step is to enter the following facility information in the appropriate boxes:

• Facility Name• Parent Company Name• Location (City, State)


6

• Audit Date (Month DD, YYYY)• Auditing Contractor Company• Auditor’s Full Name (Enter ALL On-Site)

Please do not leave any of these cells blank, except for the Parent Company, whichshould only be left blank if there is no parent company! An error message will appear ifany of the other information is left blank.

3.3.2 Questions and Answers

Take a few moments to study the layout of the questions. All RAS questions arenumbered the same way they were in the previous Lotus version, except that thequestions that require responses have been replaced with drop-down boxes. SeeFigure 1 for a view of the drop-down boxes.

How to Answer Drop-Down Questions

For example, the facility has a “remedial action in place, with high effectivenessdocumented”, in the old Lotus version, the answer would be manually changed from “0”to “1”. In this version, you click on the down arrow next to the question. The entirequestion should now be visible, as well as a list of responses, including the numericalscore and what the score represents. Click on the line that says “1 -- Remedial action inplace; High effectiveness documented”. The drop-down box will now close and thescore changes to “1”. Follow the same procedure for all questions and confidencefactors.

Figure 1. View of Drop-Down Boxes


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HELPFUL HINTS

• Questions automatically default to the “0” response. Therefore, any questions thatare “Not Applicable” can be left alone, and they will be scored as a “0”.

• Questions that score a zero can either be answered “0” or left alone.• Be careful when clicking drop down boxes, so that you don’t accidentally click

outside the box once it expands. This will keep the response at the default.• Each section is color coded (i.e., ground-water, surface water, etc.) to provide the

user with a quick reference of the current section.• Although the full text of the question is included in the drop-down box, to see the full

question, click on the worksheet tab for “Questions” and scroll down to theappropriate question.

Error Messages

The only way to erroneously answer a question is by clicking on the blank line under aquestion, or the second line of a question. When this happens, the score is replacedwith “ERR”, and a red error message appears at the top of the screen. The messagereads: “1 Question error(s). Question 1.1.1.2 contains the first error”. This message isto let you know that one question was answered wrong and should be fixed, and it tellsyou the question number of the first error, if there are more than one.

See Figure 2 for a look at the red error messages. In this example, question 2.3.1 isincorrect, so the user should scroll down to that question and fix the response.

Figure 2. Error Messages.

Manually Entered Answers

The RAS98 file contains four questions that must be answered manually because theresponse is based on a matrix, rather than a list. These questions are numbered 1.2.3,1.2.4, 2.2.1, and 2.3.4. For these questions, you have to use the table to the right of thequestion to determine the response. Next, enter the response in the appropriateshaded double-boxed cell. Entering any value outside of the legal responses will causea different error message to appear at the top of the screen. Figure 2 shows the errormessage when all four of these questions are answered incorrectly. If only one is out-of-range, the error message will display only the incorrect question, and so on.


8

Confidence Factors

Confidence factors are also entered using a drop-down box. The responses are limitedto the following values: 0.00, 0.25, 0.50, 0.75, and 1.00. As mentioned earlier, allconfidence factors are set to “1.00” as a default. Confidence factors cannot cause anerror.

GUIDELINES FOR CONFIDENCE FACTORS

• 0.00: No evidence to support the answer, hearsay, etc.• 0.50: Answer is based on available information or from knowledgeable plant

personnel, with some hard data to support it.• 1.00: Answer is based on verified observations, inspections, or well-documented

reports• 0.25 and 0.75 are intermediates for the above

3.3.3 Financial Information

The financial information section begins at Section 6.0. In this version, the beginning ofthe section now contains shaded boxes to input financial information for the last 3 fiscalyears. This information is readily available in standard balance sheets! Mostcompany’s annual reports contain 2 to 3 years of financial information, and the mostrecent form 10-K usually contains the last 5 years information!

NOTE: It is very important that information is input for the proper fiscal year, orelse the calculations do not work correctly. Also, BE CONSISTENT WITH THENUMBERS! For example, if you truncate three zeroes (000) on one number,truncate 3 zeroes on all numbers! Use the drop down box as a reminder! Thefigure below shows the drop-down box -- it is in the line with the instructions forSection 6.0.

The figure below shows the drop-down box is checked on “Actual Values”. If you leaveit like this, it serves as a reminder to enter ALL VALUES as-is. See financial informationhints for additional information.

Figure 3. Drop Down Box in Financial Information Section

The information required (for the last 3 fiscal years) is:

• Total Assets• Total Liabilities


9

• Current Assets• Current Liabilities• Net Sales (a.k.a. Net Reserves, value of sales before expenses and taxes are paid)• Net Income (a.k.a. Retained Earnings, earnings less expenses and taxes)• Net Worth (a.k.a. Stockholder's Equity)

As this information is added, the worksheet automatically calculates the following:

• Working Capital = Current Assets - Current Liabilities• Net Sales Trend = % difference in Net Sales from most recent FY to previous FY• Net Income Trend = % difference in Net Income from most recent FY to previous FY• Net Worth Trend = % difference in Net Worth from most recent FY to previous FY• Current Ratio = Current Assets / Current Liabilities• Debt to Equity Ratio = Total Liabilities / (Total Liabilities + Stockholder's Equity)• Return on Equity Ratio = Net Income / Stockholder's Equity• Profit Margin Ratio = Net Income / Net Sales• Altman Z-scores:

- Z-score from 2 year previous fiscal year- Z-score from previous fiscal year- Z-score from most recent fiscal year

The worksheet then automatically answers questions 6.1.1, 6.1.2, 6.1.3, 6.1.4, 6.2.1,6.2.2, 6.2.3, 6.2.4, and 6.3 based on the financial information provided. If there isn'tenough information to calculate a needed value, that question will remain colored red,and the answer does not appear. Also, tips appear next to the calculated values (suchas the Debt to Equity Ratio, Z-scores, etc.) when there isn't enough information.

THE BEST WAY TO AVOID ANY PROBLEMS IS TO COMPLETE ALL FINANCIALINFORMATION!!

Don’t forget to answer the last two questions of the RAS, which are after the Z-score.These questions are not automatically answered.

bosilovb

Don’t forget to answer the last two questions of the RAS, which are after the Z-score.

bosilovb

These questions are not automatically answered.


10

4.0 ADDITIONAL INFORMATION

Certain questions require further auditor knowledge to be answered. This sectionattempts to provide some awareness to the information required above the informationnecessary to complete the protocol.

The following table contains a reference to questions that may need information notspecified in the protocol:

Section Question / Necessary Information1.2.3 Aquifer thickness and permeability1.2.4 Confining layer thickness and permeability2.2.1 Site topography and intervening terrain

2.2.3 – 2.2.6 Annual weather information (one year 24 hour precipitation,flood potential, annual precipitation, annual evapotranspiration)

2.3.4 Proximity to sensitive natural receptors4.1.1.3 Facility damage (in $, from fire or explosion damage)5.1.3 Closed waste management units

5.4.n.2 (n = 1, 2, or 3) 5 year compliance record for hazardous waste, water, and airemissions

See the following Appendix A for additional RAS information.

*If there is a significant delay of more than 3 business days between electronic file submittal and receipt of hard copies, the date of receipt of hard copies shall be the official date. ~ page 1 ~

DEFINITION OF STAGES OF COMPLETION AND MATERIALS INCLUDED WITH EACH STAGE

STAGE OF COMPLETION DEFINITION INCLUDES

DRAFT

Date that contractor sends transmittal letter or email to facility accompanied by draft Executive Summary, Questionnaire, Photos, and Attachment Cover Pages as secured PDF files. Transmittal letter or email must include standard points (example letter and email disclaimer provided by CHWMEG).

Hard copy via guaranteed overnight delivery, or electronic PDF file via email attachment conveyed as Secured PDF files (no changes and password to open*) to FACILITY POC for FACILITY review & comment of: • Draft Executive Summary (~ 5 pages) • Draft of completed Questionnaire • Attachments Cover Pages • Photos with captions • *Suggested password to open file = last name of facility POC • If conveying entire attachments to the facility for their review and comment,

send them a copy of the attachments (at the discretion of the contractor).

If transmitting by hard copy, fax transmittal letter and executive summary to Jeff Sacre at (586) 461-1856; if transmitting PDFs to facility by email, include as email copy to:

cc: [email protected] cc: [email protected]

DRAFT FINAL

Date that contractor submits* DRAFT FINAL to CHWMEG, Inc. All comments from facility are addressed (changes incorporated or for changes not incorporated, a brief statement supporting the original contractor position, additional materials/information from facility included [provide as separate subsection(s) to Attachment H], and the itemized contractor response to the facility comments).

Submittal via email attachment with single attachment zip file containing: Electronic files of: • Completed RAS (Excel file – any version) • Photos in PDF (retain Word file) • Draft Final Executive Summary and Questionnaire (Word doc- any version) • Attachment cover pages (Word doc- any version)

to: [email protected] cc: [email protected]

Submittal via guaranteed overnight delivery of all hard copy attachments (List of Attachments thru H-XXX only). If you receive an excerpted copy for a facility review that is a repeat review, you can choose to “re-use” the attachments. Print page(s) from the old report (PDF report excerpts will be provided) and insert the page(s) into the appropriate place in the new attachments, or if creating attachments as a PDF file, extract the page(s) from the excerpt and insert in the new PDF attachments file. (See Tips for Attachments)

FINALFINAL

Date that contractor submits* FINAL FINAL report to CHWMEG, Inc. All CHWMEG, Inc. comments are addressed (changes incorporated in completed questionnaire, Attachments, or RAS as necessary).

• Final copy of Executive Summary, Questionnaire, and completed QAQC comments via email attachment

to: [email protected] cc: [email protected]

• Hard copy replacement pages for Attachments, as necessary via guaranteed overnight delivery or via email as PDF file

• Replacement of electronic RAS file, if necessary, sent via email attachment to [email protected]

~ page 2 ~

The following wording format is strongly recommended for use in email subject lines and electronic files transmitted to the facility and CHWMEG. By using this format, we will be able to file the emails and electronic files properly, and be able to locate them much quicker when necessary.

EMAIL SUBJECT LINE WORDING FORMAT ELECTRONIC FILE(S) WORDING FORMAT

Draft PDF to Facility for Review

Subject: Draft PDF CHWMEG Report for Review to Facility Name-City-State (Contractor Name)

Example:

Subject: Draft PDF CHWMEG Report for Review to CWM-Emelle-AL (DES)

Draft PDF to Facility for Review

All files zipped into a single zip file attachment

Draft PDF for Review to Facility Name-City-State.zip

Example:

Draft PDF Rpt for Review to CWM-Emelle-AL.zip

Draft Final to CHWMEG

Subject: Draft Final Rpt to CHWMEG for Name-City-State (Contractor Name)

Example:

Subject: Draft Final Rpt to CHWMEG for CWM-Emelle-AL (DES)

Draft Final to CHWMEG


Draft Final to CHWMEG for Facility Name-City-State.zip

Example:

Draft Final to CHWMEG for CWM-Emelle-AL.zip

Final Final to CHWMEG

Subject: Final Final Rpt to CHWMEG for Name-City-State (Contractor Name)

Example:

Subject: Final Final Rpt to CHWMEG for CWM-Emelle-AL (DES)

Final Final to CHWMEG


Final Final to CHWMEG for Facility Name-City-State.zip

Example:

Final Final to CHWMEG for CWM-Emelle-AL.zip

VIA OVERNIGHT DELIVERY [Date] [FACILITY POC] [FACILITY] [ADDRESS] [CITY], [STATE] [ZIP-FOUR] RE: CHWMEG, Inc. Draft Report for Facility Review and Comment Dear [FACILITY POC]: Thanks to you and the other staff at [FACILITY] for your assistance during my visit representing CHWMEG, Inc. The CHWMEG, Inc. standard process includes a request for the facility to review the draft report and provide comments and corrections as necessary. Enclosed are the draft Executive Summary and completed Questionnaire. The draft is based upon the information that you and others from [FACILITY] provided in support of this effort. Please review the enclosed materials and provide your comments in writing. Please especially note any substantive items, such as permit numbers, issuance/expiration dates, historical aspects of the facility, and recent or current operational issues. If representatives of [FACILITY] would like to provide additional explanation or clarification of issues (including but not limited to remedial activities on-site, PRP actions, or regulatory agency negotiations), they will be included in the report. Please provide your comments in writing to me at the above address by [DATE OF THIS TRANSMITTAL PLUS 10 BUSINESS DAYS]. Please contact me as soon as possible if this date is not convenient, so the CHWMEG, Inc. Administrator can notify the report recipients that the process will be delayed. If we do not receive comments from you by the date above, your concurrence with the information conveyed in the attachments will be assumed. You are kindly requested to return all hard copies and electronic copies of this Executive Summary and completed questionnaire with your written comments. The format and questionnaire/protocol are proprietary to CHWMEG, Inc. and its member companies. Unauthorized use of these materials is prohibited. CHWMEG, Inc. will not be responsible for any issues arising from discovery of unauthorized copies of these materials. If you have any questions regarding this request, please contact me at (###) ###-#### or Jeff Sacre, CHWMEG, Inc. Administrator at (412) 826-3056. Thank you again for your assistance. Sincerely, YOUR NAME YOUR TITLE cc or bcc (your choice): Jeff Sacre, CHWMEG, Inc. Administrator via fax: (586) 461-1856

This sequence shows the recommended approach by contractor (read from bottom – up) for conveying draft report materials to the reviewed facility POC (remember that for some facilities, corporate POC is also to be copied on this communication – see CHWMEG’s contractor website for which this applies to). This procedure allows the facility POC to either confirm successful receipt of the original email requesting review and written comment, or for them to reply to indicate that they never received the original message and/or attached draft report files! If you send the password and files in a single message to the facility, you may never know that they did not receive the original message and/or attachments (email could be blocked or attachments stripped off because of the number or size of the files). Also: Securing (“opens” password) all pdf files conveyed (suggestion: use the facility POC’s last name…noting that password is case-sensitive and hyphens + spaces matter) helps to eliminate the possibility that a facility can inadvertently open the wrong files that you might accidentally send to the facility (they won’t be able to open them, and you’ll be able to correct the problem without accidentally disclosing information about a potentially competing facility!).

CONTRACTOR’S RESPONSE FOLLOWS --- NOTE THAT THE EMAILS CONTAINING DRAFT FILE ATTCHS NEVER MADE IT THROUGH TO THE FACILITY:

----- Original Message ----- From: "Gary A McDonald-Powerstein" <[email protected]> To: <[email protected]> Cc: <[email protected]>; <[email protected]> Sent: Monday, July 27, 2009 10:54 AM Subject: Re: Information for review of draft CHWMEG report No files received here - please re-send! Gary A. McDonald-Powerstein Facility Manager - Binghamton ES Phone - 607-723-8254 ext 226 Cell- 607-743-4822 Notes FAX - 859-357-4712

THIRD (MOST RECENT) AND INTENDED-TO-BE *FINAL* EMAIL FROM CONTRACTOR FOLLOWS:

----- Original Message ----- From: [email protected] To: [email protected] Cc: [email protected] ; [email protected] Sent: Saturday, July 25, 2009 7:07 PM Subject: Information for review of draft CHWMEG report Gary, THE CASE-SENSITIVE PASSWORD TO OPEN ALL THE PDF FILES IS:

McDonald-Powerstein I have just sent you two emails with a transmittal letter and attached zip files containing the Executive Summary, the completed Questionnaire, the attachment cover pages, and the site photos for your review and comment. Please let me know if you did not receive the emails or if you have any problem opening the files attached to either of the two emails. I look forward to receiving your written comments by August 10th. Duane Utecht Oak Fair Environmental Services, L.L.C.

SECOND EMAIL FROM CONTRACTOR FOLLOWS:

----- Original Message ----- From: [email protected] To: [email protected] Cc: [email protected] ; [email protected] Sent: Saturday, July 25, 2009 7:03 PM Subject: Draft PDF CHWMEG Report photos for Review to Ashland Distribution-Binghamton-NY (OFES) Gary, Here is the file containing site photos for your review and comments. Duane Utecht Oak Fair Environmental Services, L.L.C.

ORIGINAL EMAIL FROM CONTRACTOR FOLLOWS:

From: [email protected] To: [email protected] Cc: [email protected] ; [email protected] Sent: Saturday, July 25, 2009 7:00 PM Subject: Draft PDF CHWMEG Report for Review to Ashland Distribution-Binghamton-NY (OFES)

OAK FAIR ENVIRONMENTAL SERVICES, L.L.C. Duane E. Utecht Phone: 281 361-75501442 Kingwood Drive, #124 Fax: 281 360-6113Kingwood, TX 77339 [email protected] July 25, 2009 Mr. Gary A. McDonald-Powerstein Ashland Distribution 3 Broad Street Binghamton, NY 13904 RE: CHWMEG, Inc. Draft Report for Facility Review and Comment Dear Mr. McDonald-Powerstein: Thank you for your assistance during my recent visit to the Ashland Distribution facility in Binghamton representing CHWMEG, Inc. The CHWMEG, Inc. standard process includes a request for the facility to review the draft report and provide written comments and corrections as necessary. Enclosed are the draft Executive Summary, completed Questionnaire, site photographs, and attachment cover pages. The draft report is based upon the information that Ashland Distribution personnel provided in support of this effort. Please review the enclosed materials and provide your comments in writing. Please especially note any substantive items, such as permit numbers, issuance/expiration dates, historical aspects of the facility, and operational issues. If representatives of Ashland Distribution would like to provide additional explanation or clarification of issues (including but not limited to activities onsite, regulatory agency interactions, etc.), this information will be included in the report.

Please provide your comments in writing to me at the above address by August 10, 2009. Please contact me as soon as possible if this date is not convenient, so the CHWMEG, Inc. Administrator can notify the report recipients that the process will be delayed. If I do not receive comments from you by the above date, your concurrence with the information conveyed in the attachments will be assumed.

You are kindly requested to return all hard copies and electronic copies of the enclosed materials with your written comments. The format and Questionnaire/protocol are proprietary to CHWMEG, Inc. and its member companies. Unauthorized use of these materials is prohibited. CHWMEG, Inc. will not be responsible for any issues arising from discovery of unauthorized copies of these materials.

If you have any questions regarding this request, please contact me at (281) 361-7550 or Mr. Jeff Sacre, CHWMEG, Inc. Administrator at (412) 826-3056. Again, I want to thank you for your assistance in conducting this review. Sincerely,

Duane E. Utecht Duane E. Utecht President cc: Jeff Sacre, CHWMEG, Inc. Administrator P.S. Due to the size of the files, the site photographs will follow in a second email.

LIST OF ATTACHMENTS

A - FACILITY COMMENTS & CONTRACTOR RESPONSE B - SITE PLOT PLAN C - SITE PHOTOGRAPHS WITH REFERENCE PLOT PLAN D - FIGURES E - CLOSURE PLAN & CLOSURE COST ESTIMATE F - FINANCIAL INFORMATION: FY 2009, 2010, & 2011 G - INSURANCE INFORMATION H - ADDITIONAL RELEVENT INFORMATION PROVIDED BY FACILITY [examples]

H - 1: Tank Listing H - 2: RCRA Inspections H - 3: Cease & Desist Order H - 4: Lithology H - 5: Ground-water Conditions H - 6: Regional Setting with Well Locations

ATTACHMENT A - FACILITY COMMENTS & CONTRACTOR RESPONSE

Contractor’s Response to [FACILITY]’s Reply

Written Reply from [FACILITY] to [CONTRACTOR] dated xx March, 2012 Transmittal Letter from [CONTRACTOR] to [FACILITY] dated xx March, 2012

ATTACHMENT B - SITE PLOT PLAN

ATTACHMENT C - SITE PHOTOGRAPHS WITH REFERENCE PLOT PLAN

[INCLUDE AS NECESSARY]

FACILITY REFUSED THE CONTRACTOR’S REQUEST TO TAKE PHOTOS DURING THE SITE VISIT FOR REASONS OTHER THAN TO

PROTECT PROPRIETARY PROCESSES

[INCLUDE AS NECESSARY] FACILITY PROHIBITED CONTRACTOR FROM PHOTOGRAPHING

CERTAIN AREAS ON THE PROPERTY FOR REASONS OTHER THAN TO PROTECT PROPRIETARY PROCESSES; THE

RESULTING PHOTOS INCLUDED HEREIN ARE NOT NECESSARILY REPRESENTATIVE OF THE FACILITY PROPERTY

[INCLUDE AS NECESSARY]

FACILITY LIMITED the CONTRACTOR TO THE LIMITED NUMBER OF ATTACHED PHOTOS

View this facility via Google Maps in a separate browser window (click link below):

[chwmeg to insert link here]

insert plot plan identifying location of photographs, photograph reference numbers, and

orientation/direction of photographs

Site Photographs: Use one of the templates provided by the Administrator on the CD.

ATTACHMENT D - FIGURES

ATTACHMENT E - CLOSURE PLAN & CLOSURE COST ESTIMATE

ATTACHMENT F - FINANCIAL INFORMATION

[for publicly-traded companies] MOST RECENT 10K REPORT CONTAINING

FINANCIAL INFORMATION FOR:

FY 2009 FY 2010 FY 2011

and

CURRENT 10Q REPORT (e.g. 1Q FY 2012)

Access This Company’s 10K Filings

[CHWMEG TO INSERT LINK HERE]

Access This Company’s 10Q Filings

[CHWMEG TO INSERT LINK HERE]

[for privately-held companies]

AUDITED FINANCIAL REPORTS FOR THREE MOST RECENT FISCAL YEARS:

FY 2009 FY 2010 FY 2011

[for privately-held companies refusing to release financial

information]

Facility Refused to Release Financial Information to CHWMEG, Inc. for detailed financial information, please contact:

Mr. Joseph Smith

Title fon (###) ###-#### fax (###) ###-####

ATTACHMENT G - INSURANCE INFORMATION

ATTACHMENT H - ADDITIONAL RELEVANT INFORMATION PROVIDED BY FACILITY

[Examples]

H - 1: Tank Listing H - 2: RCRA Inspections and Results H - 3: Cease & Desist Order H - 4: Lithology H - 5: Ground-water Conditions H - 6: Regional Setting with Well Locations

H-1: Tank Listing

TIPS FOR ATTACHMENTS (for DRAFT FINAL and FINAL FINAL Submittal)

• Always use the attachment template provided by the administrator. • All titles on the attachment cover pages should reflect the information that is contained

within the attachment (e.g., Attachment E, Closure Plan and Closure Cost Estimate) – you can change the template for each facility.

• For H Attachments: Try to keep the title to one line of text. Only include one relevant

item per attachment. • Provide all attachments unbound (all bindings and staples removed) and on

single-sided pages only

• The only paper size that will be accepted is letter (8 ½ x 11). All brochures, A4 paper (Non-NA paper size), legal, ledger, business cards, and miscellaneous sizes should be copied/reduced to 8 ½ x 11.

• Include only the important information so the attachments are not larger than they

should be. The following are examples, and not all inclusive:

• Permit cover pages and pertinent information, not the entire permit. • The financial information and notes from annual reports, not descriptions of the

company and photos of the CEO • Pertinent information from the WAP; groundwater monitoring report; inspection

checklist; RFI; etc., not the entire document. • Previous Attachments: If you receive an excerpted report for a facility review

that is a repeat review, you can “re-use” the attachments. IMPORTANT: Print the page(s) from the old report (PDF report excerpts will be provided) and insert the page(s) into the appropriate place in the new attachments; or if creating attachments as a PDF file, extract the page(s) from the excerpt and insert in the new PDF attachments file.

Reminder: Previous attachments from CHWMEG, Inc. reports are to be used solely for CHWMEG, Inc. reports.

• Remember: If it’s in the attachments, it should be relevant and referred from the questionnaire.

Site Photographs: CHWMEG, Inc. Report of ABC Metals, Anytown, PA, 7/8/2011

Page C-1 of C-10

Photo #1: Stick figure standing in front of large tank. Note how rough this drawing is considering EMS’ sophisticated graphics capabilities.

Photo #2: Tank farm #2 looking east. Note that the “artist” didn’t draw any containment structures.

LARGE TANK

Header

Page number (note format)

Photo number

Photo number

Landscape photo presented in correct

orientation

Landscape photo presented in correct

orientation

2 landscape photos per page

Photo captions in matching Arial font

Border around photos is optional

Stick figure standing in front of large tank. Note how rough this drawing is considering EMS’ sophisticated graphics capabilities.

Tank farm #2 looking east.

LAR

GE

TA

NK

X Missing page number

X Portrait photo presented landscape

X Portrait photo presented landscape

X Missing header

X Missing photo number

X Missing photo number


Page C-1 of C-10

Photo #1: Stick figure standing in front of large tank. Note how rough this drawing is considering EMS’ sophisticated graphics capabilities.

LARGE TANK

Portrait photo presented in correct

orientation

Page number

Photo number

Header

1 portrait photo per page

Border around photos is optional


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Copy photos into the first line of the document.A good size is 4" x 6"

They may need to be slightly smaller if captions are longer.

2nd photo goes here, using the same guidelines.

If you are adding portrait photos, you can make them as large as you want, but remember that there can be only

one portrait photo per page.

Photo #1 Put caption here. Font should be 10-point Arial. There should be enough room for a 2-line caption. If more room is needed, reduce the photo size slightly.

Photo #2 Put caption here. Captions should accurately describe the important parts of the photo. I used an indent of 0.75".

Use the following header/footer settings for the document:Header: 0.5"Footer: 0.5"

Use the following margins for the document:Top: 0.75" Left: 1"Bottom: 0.75" Right: 1"

Photo boundary (don’t need a border)

Photo boundary (don’t need a border)


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Select this text, go to “Insert…Picture…From File” to place the photo

Photo #1: This is where the caption goes. Try to keep the caption concise, but without going into more

than 2 lines. Font is 10-point Arial. Recommended picture size is 4” height. To set picture height, double click the picture and choose the “Size” tab.


Photo #2: Use the same caption rules as above. If captions are more than 2 lines, you may have to

shrink the picture height. Duplicate this page as necessary. When finished, hit Ctrl+Enter to start a new page.


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Photo #1: This is where the caption goes. Try to keep the caption concise, but without going into more than 3 lines. Font is 10-point Arial. Recommended picture size is 4” height. You can double-click the photo to adjust the size.

Select this text, go to “Insert…Picture…From File” to place the photo Photo #2: Use the same caption rules as above. Note: to insert a “tab” character, use Ctrl+Tab, since

this is a table. If captions are more than 3 lines, you may have to shrink the picture height. Hit Ctrl+Enter outside the table to start a new page. Then copy this table.


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2006 Facility Review Program QA/QC Page 1 of 28 © 2006 CHWMEG, Inc.

SECTION/PAGE QA/QC COMMENTS

Exec. Summ., p. i Facility Information: The name here should match the name in A2. Please fix where appropriate.

Exec. Summ., p. i Facility Information:, “Facility title” here should match the “Official Name of Facility”, in A2 of the Questionnaire.

Exec. Summ., p. i Facility Operations section:

• You mention that solvents are received in bulk; however, there are no waste tanks. You should clearly state that tankers are also transferred through the facility.

• The questionnaire mentions bulking of solvents. Since there are no waste tanks, how is this done?

• What types of solvents can be accepted under the CUP? You only mention the generic term “solvents”

Exec. Summ., p. i Facility Operations section:

• Briefly describe the “blending” process in the appropriate area. No more than 1-2 sentences.

• What residuals are generated, and where (and how) are they sent?

Exec. Summ., p. i Facility Operations section: Add a paragraph to describe the “consolidation” operations. For example, do they consolidate drums to tankers? If so, how? Do they consolidate solids to rolloffs? If so, how?

Exec. Summ., p. ii Facility Operations section: Briefly describe the “fill” part of “return and fill”. For example, how are fresh solvents received and removed from the site. Just one paragraph should suffice.

Exec. Summ., p. i-ii Facility Operations Section: Briefly describe the acceptance procedure. How are wastes pre-qualified? Is there any sampling or analysis? Where does off-loading occur?

Exec. Summ., p. i Facility Operations section: Can you provide a rough breakdown of waste accepted? Does the facility accept fluorescent lamps? Do they accept drums of crushed lamps? Do they crush lamps?

Exec. Summ., p. i-ii Facility Operations section: How much waste is treated on an annual basis? Include where appropriate (perhaps the 2nd paragraph).

Exec. Summ., p. i Facility Operations section: Is there any acceptance program or profiling of industrial waste?

Exec. Summ., p. i Facility Operations section: Mention any residuals that haven’t already been discussed.

Exec. Summ., p. i Facility Operations section: Perhaps use the 1st paragraph to mention that this is a wastewater treatment and incineration facility; otherwise, it doesn’t appear until page ii.

Exec. Summ., p. i Facility Operations Section: Provide a brief description of acceptance procedures. Perhaps a 3rd paragraph on page i. Include things like prequalification, transport, any onsite inspections or radiological scans, etc.

Exec. Summ., p. i-ii Facility Operations section: Where are batteries sent? Perhaps add this near the end of the section with the residual discussion.

Exec. Summ., p. i Facility Operations, 1st bullet: To be consistent with the other bullets, please note the quantity of wastewater treated in 2006.

Exec. Summ., p. i Facility Operations, 1st paragraph, 3rd line: The acreage numbers here do not agree with the ones in Section C.5A. Please fix where appropriate. Further, 10 active acres seems low. Even further, how many acres are permitted?

Exec. Summ., p. i Facility Operations, 1st paragraph: Include some additional information: active and total acreage; briefly describe any immediate neighbors.

Exec. Summ., p. i Facility Operations, 1st paragraph: Of this 40+ million acres, how many are constructed? Are they all permitted?

Exec. Summ., p. i Facility Operations, 1st paragraph: The 1st sentence calls it the “Smithfield” Recycling Center, but the title at the top has “New Castle” recycle center. Please be consistent.

Exec. Summ., p. i Facility Operations, 2nd bullet, 1st line: Typo; “aqueous” should be “aqueous wastes”



Exec. Summ., p. ii Facility Operations, 2nd paragraph on page,

• 5th line: What kind of container is the compacted waste stored in?

• 5th line: According to Section VI, the compacted waste is no longer sent to this landfill. Please clarify.

• How long is each autoclave cycle? How is it loaded/unloaded?

Exec. Summ., p. i Facility Operations, 2nd paragraph, 2nd line: How are lamps accepted (drums, in boxes, already crushed in drums, etc)?

Exec. Summ., p. i Facility Operations, 2nd paragraph, 7th line: Please clarify “The ash and slag occupy about 3% and 15% of the total volume respectively.” Is this the percentage of incoming waste, or percentage of residual waste.

Exec. Summ., p. i Facility Operations, 2nd paragraph:

• Give examples of the industrial waste that they receive.

• Are containers accepted? If so, how are they handled? Are there container storage areas? Tell the reader.

Exec. Summ., p. i Facility Operations, 2nd paragraph: Callout “UWEDs” here rather than the 3rd paragraph. Which of the devices listed in this paragraph are considered UWEDs?

Exec. Summ., p. i Facility Operations, 2nd paragraph: For clarity, is this oil received in bulk? Are containers received?

Exec. Summ., p. i Facility Operations, 2nd paragraph: Is there any inspection or screening (radioactive, etc) upon receipt?

Exec. Summ., p. i Facility Operations, 2nd paragraph: These MSW landfills typically accept waste from certain counties or metropolitan areas. Since this has the highest rate in Georgia, please note where the MSW comes from.

Exec. Summ., p. i Facility Operations, 2nd paragraph: This paragraph begins by describing the entire facility, including the kilns. Are there any other residuals from the kilns and cement processing, such as CKD or refractory?

Exec. Summ., p. i Facility Operations, 2nd paragraph: What types of containers are accepted? 55-gallon drums only?

Exec. Summ., p. i Facility Operations, 2nd paragraph: What types of treatment does the facility conduct? This section never mentions any specific treatment types. Is this considered wastewater treatment?

Exec. Summ., p. i Facility Operations, 3rd bullet on page: This is the first mention of KBI in Lancaster, OH. Perhaps use the 1st paragraph to list all company locations.

Exec. Summ., p. i Facility Operations, 3rd bullet: Is there any sampling or analysis of containers?

Exec. Summ., p. i Facility Operations, 3rd bullet: This mentions an underground tank. This tank should probably be mentioned in the Storage bullet. Are the 2 ASTs mentioned in the Storage bullet connected to the incinerator?

Exec. Summ., p. ii Facility Operations, 3rd full paragraph on page: Is this all stormwater, or just contact stormwater? It appears that non-contact water is not treated. Perhaps provide more detail.

Exec. Summ., p. ii Facility Operations, 3rd paragraph on page: Replace “MM” with “million”

Exec. Summ., p. i Facility Operations, 3rd paragraph, 1st sentence: Elaborate on “solid waste.” Is it non-hazardous? Do they accept MSW, industrial waste, C&D, etc? (No need to provide specific industrial waste examples; the 4th paragraph does that very well.)

Exec. Summ., p. i Facility Operations, 3rd paragraph, 1st sentence: This is too generic; please specify these employees by title. Or, if they are management, simply replace “employees” with “facility managers”



Exec. Summ., p. i Facility Operations, 3rd paragraph:

• 1st sentence: What kind of batteries? These should be identified, especially since they are sent to a landfill.

• You mention fluorescent lamps in the first sentence, but you never state how they are treated or where they are sent.

Exec. Summ., p. i Facility Operations, 3rd paragraph:

• Briefly define “Class I landfill”

• The questionnaire specifically mentions the acceptance of “special waste” and “industrial non-hazardous waste”. These aren’t mentioned here. Please provide a few examples of the types of industrial or special wastes received.

• You should probably state that liquids are not accepted, and there is no onsite treatment.

Exec. Summ., p. i Facility Operations, 3rd paragraph: 4th sentence: Give examples of the Class 1 and 2 waste that they send offsite.

Exec. Summ., p. i Facility Operations, 3rd paragraph: Do they accept hazardous or non-hazardous materials? Or both?

Exec. Summ., p. i Facility Operations, 3rd paragraph: Does the facility accept liquids? Will they accept industrial waste? I’m assuming they accept the latter, since a member wanted this reviewed.

Exec. Summ., p. i Facility Operations, 3rd paragraph: Does the facility receive LWDF from generators or other TSDFs? Is there any mixing in the receiving tanks, or is it burned as-is? The questionnaire mentions grinders. If there is any type of blending conducted, it should be described.

Exec. Summ., p. i Facility Operations, 3rd paragraph: How are containers handled?

Exec. Summ., p. i Facility Operations, 3rd paragraph: Please give some examples of “special waste” and “liquid waste”

Exec. Summ., p. i Facility Operations, 3rd paragraph: Please revise the 1st person language in “in excess of our own requirements”

Exec. Summ., p. i Facility Operations, 3rd paragraph: This entire paragraph discusses “vehicle” used oil. What is the process for “non-vehicle” oil?

Exec. Summ., p. i Facility Operations, 3rd paragraph: You should briefly note specifically where (non-SK facilities) these solids are sent.

Exec. Summ., p. i Facility Operations, 4th bullet: Please list the “residues”. I would assume that this list should include activated carbon, sludge, and other residuals from the APC system, too.

Exec. Summ., p. i Facility Operations, 4th paragraph, last sentence: Does this mean that they sample each 6-gallon pail from a load?

Exec. Summ., p. i Facility Operations, 4th paragraph: Attachment H-2 describes a random load inspection process, and working face inspections. These should probably be summarized here.

Exec. Summ., p. i Facility Operations, 4th paragraph: For the average reader: What are F032 & P-code wastes?

Exec. Summ., p. i Facility Operations, 4th paragraph: Please elaborate on “semi-dry type reactor” and “dry type reactor”. Are there more common names for these? Note: If you want to change them, I can search-and-replace the questionnaire.

Exec. Summ., p. i Facility Operations, 4th paragraph: Please verify “10,100,000-million”. Should it be “10.1 million” or maybe just “10,100,000”?

Exec. Summ., p. i Facility Operations, 4th paragraph: Provide a little more detail on the breakdown of equipment. Give examples of the equipment that is received. How is it manually dismantled (cutting torches, etc)? Does the equipment contain oil?

Exec. Summ., p. i Facility Operations, 4th paragraph: Which cardinal directions are “upstream” and “downstream”?

Exec. Summ., p. i Facility Operations, 5th paragraph, 4th sentence: Where is the “more thorough inspection” conducted? What makes it more thorough?

Exec. Summ., p. i Facility Operations, 5th paragraph, 5th line: How is the ash collected? Where is it stored? How often is it sent to the landfill?



Exec. Summ., p. i Facility Operations, 5th paragraph: Do they store any treated waste rolloffs, or are they immediately taken to the landfill? If stored, what is the capacity? If there is a designated storage area for rolloffs, then please describe in the 2nd paragraph under Design.

Exec. Summ., p. i Facility Operations, 5th paragraph: Is the waste filtered or screened to remove solids or debris?

Exec. Summ., p. i Facility Operations, 5th paragraph: You should probably state that there is no treatment nor consolidation onsite.

Exec. Summ., p. i Facility Operations, 6th paragraph, 4th line: According to C32b, anti-freeze is bulked and sent offsite for recycling.

Exec. Summ., p. ii Facility Operations, 6th paragraph: What residuals are generated? How are they handled onsite? Table B2a lists several wastes sent offsite to Clean Harbors, La Porte, TX

Exec. Summ., p. ii Facility Operations, bullet list of residuals: Detail like this is great for the questionnaire, but too much for the Executive Summary. In the future, simply list the waste stream and its destination (omit the amount and waste code). Leave this one as-is.

Exec. Summ., p. i Facility Operations, Last paragraph on page: You note that the limit on WDF is 18.1 tph. As a comparison, how many total tons of fossil fuel per hour are used?

Exec. Summ., p. i Facility Operations, last paragraph on page: You should probably move the phrase “and transports it back to the facility” to the end of the paragraph where you discuss the return of solvent. It may cause confusion it its current location.

Exec. Summ., p. i Facility Operations, last paragraph: Are there BTU/lb limits for fuel-blending materials?

Exec. Summ., p. i Facility Operations, list of bullets: According to the bullets, it appears that “parts washer waste” (1st bullet) and aqueous parts cleaner and brake cleaner (3rd and 4th bullets) are consolidated into the same 15,000 gallon tank. Is this accurate?

Exec. Summ., p. ii Facility Operations, Waste Consolidation: “Onyx” is now “Veolia”

Exec. Summ., p. i Facility Operations: 1st paragraph, last sentence – “…hazardous, low level radioactive…” should read “…hazardous, low activity radioactive…” as the facility is not permitted to receive “Low-Level Radioactive Waste as defined in Federal Regulations” as mentioned in A35

Exec. Summ., p. i &C36b, p 47

Facility Operations: 3td paragraph, 4th sentence – states that the offspec lube oil are shipped to Fuel Processors in Portland. C36b indicates that some of the used oil is sold directly to users in California and only light ends goes to Fuel Processors. Need to review and reconcile.

Exec. Summ., p. i Facility Operations: 5th paragraph

Adding up the waste %’s cited going to the landfill comes up to 112% (42+40+15+5+10). Suggest reviewing and reconciling to 100%.

The last sentence indicates that PCB liquids are transferred to the Veolia Incinerator in Deer Park, TX. This incinerator is owned and operated by Clean Harbors. Veolia owns and operates a hazardous waste incinerator in Port Arthur, TX. I note that this was specified by plant in their review of report (Att A), but it appears that they referred to the wrong owner or location.

Exec. Summ., p. i Facility Operations: in the 2nd or 3rd paragraph, can the auditor mention “average facility throughput”?

Exec. Summ., p. i Facility Operations:, 1st bullet, 2nd paragraph, 3rd sentence, can the auditor explain how trace organics are “oxidized”?

Exec. Summ., p. i Facility Operations:, 1st paragraph, 1st sentence, identify if this is the owners’ only operation. If not, also identify the other affiliations.

Exec. Summ., p. i Facility Operations:, 1st paragraph, briefly mention any parent company affiliations.

Exec. Summ., p. i Facility Operations:, 2nd paragraph, 1st sentence, for a point of clarification, please add “plastic” between “250,000” and “drums”.

Exec. Summ., p. i Facility Operations:, 3rd paragraph, 1st bullet, For clarity, I recommend:

“Direct landfilling of MSW, (510,000 tons in 2006) special wastes including, friable and non-friable asbestos, animal carcasses, treated medical wastes, sludges (91,000 tons in 2006), into active Cell 5, a fully-lined RCRA Subpart D landfill.”

Exec. Summ., p. i Facility Operations:, 3rd paragraph, 3rd sentence, can the auditor clarify what “Other CKD…” is generated?



Exec. Summ., p. i Facility Operations:, 3rd paragraph, following 2nd sentence, provide a brief description of this solidification activity/process.

Exec. Summ., p. i Facility Operations:, 3rd paragraph, include information about the “Average Annual Throughput”.

Exec. Summ., p. i Facility Operations:, 4th paragraph, the detailed waste information provided here does not correspond to the detailed information provided in the Questionnaire, table A34, p. 8, please correct where appropriate.

Exec. Summ., p. i Facility Operations:, last paragraph on p. i and 1st on p. ii, you list WMU 33 as a “active surface impoundment” and a “closed waste management unit”, is this possible?

Exec. Summ., p. i Facility Operations: “Leachate” paragraph: Use “discharged” or “trucked” (whichever is applicable) instead of “shipped”

Exec. Summ., p. ii Facility Operations: 1st whole paragraph on page, last sentence: Please list the residual wastes, even if you don’t list where they are sent. Include site generated wastes (PPE, sludge, air treatment waste, activated carbon, drums, etc).

Exec. Summ., p. ii Facility Operations: 1st whole paragraph on page: Please give locations (city, ST) for these facilities.

Exec. Summ., p. i Facility Operations: 2nd bullet: “50 million BTUs” should probably be “50 million BTU/hr”

Exec. Summ., p. i Facility Operations: 2nd bullet: What are the typical reagents used?

Exec. Summ., p. ii Facility Operations: 3rd paragraph, 2nd sentence: How is the leachate sent to the POTW? Via pipe? Truck?

Exec. Summ., p. ii Facility Operations: 6th paragraph on page, last sentence: Please check this; I don’t think that Spring Grove Resource Recovery recycles fluorescent bulbs. Perhaps this should be “transfer”.

Exec. Summ., p. i Facility Operations: FUELS BLENDING paragraph: Are there any plans to start fuel blending again?

Exec. Summ., p. ii Facility Operations last paragraph, last sentence, where are the “readings” entered? Log book?, computer?

Exec. Summ., p. ii Facility Operations: Last paragraph on page, last sentence: Please clarify “five cells”; Operational or Technology Changes section mentions completion of a 7th cell. Is there a “Cell 6”?

Exec. Summ., p. ii Site History section: According to Attachment A, the remanufacture of solvents started in 1987; this should probably be mentioned.

Exec. Summ., p. i Site History paragraph: Please clarify “The area was exited January 2006, Current plans are to cap the area at the end of 2007 to first of 2008.” I’m not sure what you mean by “exited”. Also, please clarify “to first of 2008” – this doesn’t make sense grammatically.

Exec. Summ., p. i Site History section: Have there been any significant fires, releases, etc. in the last 5 years?

Exec. Summ., p. ii Site History section: Have there been any spills or other releases? Any assessments? What were the results? Has the fire caused any contamination? Were there any other fires?

Exec. Summ., p. ii Site History section: What was the land use before construction of the facility? If known, when was it reclaimed from the bay?

Exec. Summ., p. ii Site History section: 5th paragraph: What caused the explosion? What has been done to prevent recurrence? Have there been any fines from it?

Exec. Summ., p. i Site History section: Have there been any releases or fires when Cyn was operating? Aside from the UST removal, has there been any remediation or assessments?

Exec. Summ., p. i Site History section: Provide a brief list of past owners and operations conducted at the site.

Exec. Summ., p. ii Site History section: You mention cells 1,2,3,5,6,7,8 and 14. Are there cells 4,9-13?

Exec. Summ., p. iii Site History, 1st paragraph on page, last sentence: The reader is not familiar with the names of these active units. Please provide a brief description of each.

Exec. Summ., p. ii Site History, 1st paragraph: What happened with the other 23 SWMUs? No further action?



Exec. Summ., p. iii Site History, 3rd paragraph: Was outside assistance required to put out the fire? Include as necessary.

Exec. Summ., p. ii Site History, 4th paragraph, 4th line: Please define “To date”. Perhaps it should be “As of the site visit”

Exec. Summ., p. iii Site History, last paragraph: Have any of these spills or releases been outside containment? Was any remediation required? I’m interested in large spills that may have impacted the site.

Exec. Summ., p. ii Design section:

• What is the warehouse used for; it doesn’t appear to be waste storage.

• What are the storage time limits (days)?

• Do they ever “break” the aisle spacing in the trailers? If so, does that affect the storage time limits?

Exec. Summ., p. ii Design section:

• Add a paragraph (after the 2nd) to describe the design of the ash monofill, if different than the Subtitle D landfill.

• Have any sections of the landfill been closed and/or capped? According to the photos, it is a continuous process. Perhaps briefly describe.

Exec. Summ., p. ii Design section: Briefly describe any container storage areas: containment, stacking, spacing, permitted capacity, etc. How many tanks/tank farms are there? What is the capacity?

Exec. Summ., p. iii Design section: Include a brief paragraph that describes the handling of contact and non-contact stormwater.

Exec. Summ., p. ii Design section: Please include a design description of the active landfill and liner. This should be fairly detailed and include all layers as well as a description of the leachate and gas collection systems. Is the current landfill design to Subtitle D standards? Is the landfill divided into cells? How many cells (or acres) are currently active (as opposed to permitted)? What is the estimated remaining life of the landfill?

Exec. Summ., p. iii Design section: Where is compacted waste stored? What kind of container? Describe any containment, etc. How long is it stored before taking it to the landfill?

Exec. Summ., p. ii Design section: Add a paragraph after the first to elaborate on the stabilization/solidification process (equipment used, reagents, testing, etc) and the micro- and macro-encapsulation (how it’s conducted).

Exec. Summ., p. ii Design section: Are there any closed cells? Any pre-Subtitle D cells? How are those lined?

Exec. Summ., p. ii Design section: Either here (or Facility Operations, 5th paragraph), briefly describe the solidification pit (location, materials of construction, capacity, liner, etc).

Exec. Summ., p. iii Design section: Is fuel accepted by railcar? It isn’t clear from the Executive Summary. Is the spur on Energis property, and how are liquids transferred to the blend/burn tanks? Is the rail unloading area contained? Provide a brief description.

Exec. Summ., p. iii Design section: Is there any ambient air monitoring? Briefly describe (frequency, equipment, etc) in a new paragraph.

Exec. Summ., p. ii Design section: Perhaps include a brief (1 paragraph) description of the stabilization, such as process equipment, location, and waste movement methods.

Exec. Summ., p. ii-iii Design section: The Executive Summary and the questionnaire mention “Unit 1” and “Unit 3”. You should briefly describe all unit numbers and what they are.



Exec. Summ., p. iii Design section: These are all additional elements that should be included, but they don’t have to be in a single paragraph.

• What is the capacity of the container storage area? How are containers handled (landfilled or opened and treated)?

• Describe the design of stabilization areas (type of pits, how waste is mixed, where it is staged until landfilled, how it is tested, etc.). Is there any emission control?

Exec. Summ., p. iii Design section: Use a new paragraph to briefly describe the landfill liner system.

Exec. Summ., p. ii Design, 1st paragraph, last sentence: For consistency with Section VI, you should probably note that the tire feed system is idled. Are they still accepting tires?

Exec. Summ., p. ii Design, 1st paragraph: Is the gas-to-energy plant operational? The phrase “expected to produce” seems to indicate that it isn’t. The questionnaire uses “estimated to produce”

Exec. Summ., p. i Design, 1st paragraph: This is all text from the template; please delete.

Exec. Summ., p. iii Design, 2nd & 3rd bullets on page: Replace “Ca(OH)2“ with “calcium hydroxide” and “NaOH” with “sodium hydroxide”

Exec. Summ., p. ii Design, 2nd paragraph, 1st sentence: You should note that there are no synthetic liners used in the liner system.

Exec. Summ., p. iii Design, 2nd paragraph: How is the storm water “inspected”?

Exec. Summ., p. ii Design, 2nd paragraph: Name the landfill, city, and state where the soil is sent. What is its use?

Exec. Summ., p. iii Design, 2nd paragraph: Please describe the design details of the liner in the current active cell.

Exec. Summ., p. iii Design, 3rd paragraph, last sentence: What is this weir monitored for?

Exec. Summ., p. ii Design, 3rd paragraph: Are tanks equipped with mixers? Alarms? Automatic cutoffs?

Exec. Summ., p. iii Design, 3rd paragraph: How do materials (glass, metal, powder) leave the crusher? Do they fall out into containers or rolloffs? Where are they stored? How often are end caps and glass analyzed (and where)?

Exec. Summ., p. iii Design, 3rd paragraph: Please elaborate on “All tank areas are sealed.” I’m assuming that you mean the concrete containment is sealed; however, you should state this.

Exec. Summ., p. ii Design, 4th paragraph: What are the materials of construction for these sumps?

Exec. Summ., p. iii Design, 5th paragraph, 4th line: Change “83MM” to “83 million”

Exec. Summ., p. ii Design, 6th bullet: Are these tractor trailers used for storage? If so, what is stored? Are they in containment?

Exec. Summ., p. iv Design, 9th bullet: What if the stormwater is contaminated?

Exec. Summ., p. ii Design, last paragraph: “spillage of waste or liquids” – does the facility accept liquids for landfill?

Exec. Summ., p. ii Design, last paragraph: There are no discharge treatment requirements for air & water, but are there any sampling requirements and/or discharge criteria?

Exec. Summ., p. iii Design, Noteworthy Items, 1st bullet: Was a reason given why these documents weren’t provided for review?

Exec. Summ., p. ii Design, Noteworthy Items, 2nd bullet: Are the containers “recyclable” or would they be considered “reusable”?

Exec. Summ., p. iii Design, Noteworthy Items, 3rd bullet: What is the time limit for storage in this “drop yard”

Exec. Summ., p. iv Design, Noteworthy Items, 3rd bullet: Why were you unable to enter these areas?

Exec. Summ., p. iii Design, Noteworthy Items, 4th bullet: Can we use “RCRA Subtitle D standards” instead of “RCRA standards”? Your call.



Exec. Summ., p. iii Design, Noteworthy Items, 4th bullet: Please go back a consistent 5 years in the Executive Summary.

Exec. Summ., p. iii Design, Noteworthy Items, 4th bullet: The industry DART of 4.7 is for 2005 (not 2006).

Exec. Summ., p. iii Design, Noteworthy Items, 6th bullet, 1st sentence: insert “DART” before “lost time incidence rate”

Exec. Summ., p. iii Design, Noteworthy Items, 9th bullet: Please replace “[RESULTS]” with the appropriate info.

Exec. Summ., p. ii Design, paragraph after bullet list: Please list the APC system treatment steps. Are any residuals generated? They didn’t seem to be listed in the Facility Operations section.

Exec. Summ., p. iii Design,1st paragraph: This is the first mention of the 844,000-gallon tank. What is its use? According to the questionnaire, it is out of service. This should be noted here.

Exec. Summ., p. i Design:, 1st paragraph, briefly describe the facility layout and how the electronic scrap material is processed (e.g. disassembled by hand, how is it segregated, how is material moved around, how is it stored before removal from the site, how long can it stored, etc).

Exec. Summ., p. i Design:, 1st paragraph, provide information on the landfill design regarding the layout of cells, how many are closed, how many are active, how many are in the design process. In addition, mention if the facility has weight scales, administrative office building, and vehicle maintenance facility.

Exec. Summ., p. ii Design:, 2nd paragraph, 2nd sentence, Noteworthy Items:, 3rd bullet, total number of tanks do not add up, 9 vs. 10.

Exec. Summ., p. ii Design:, 2nd paragraph, the auditor should include information about drum storage, such as, is the drum storage in a building? On a pad? On bare ground? Is there any lining provided?

Exec. Summ., p. ii Design:, 3rd paragraph, the auditor should mention what happens to “contact stormwater”.

Exec. Summ., p. iii Design:, 7th paragraph, please provide addition landfill design information regarding original cell/subcell deigns, naming conventions, numbers, closed or inactive, and future design.

Exec. Summ., p. ii Design: “On-site processes” bullet list paragraph: You should probably include a brief description of the compressed gas treatment process.

Exec. Summ., p. ii Design: “Stockpiles” bullet: Are stockpiles on pads? Are they contained? Etc.

Exec. Summ., p. ii Design: 1st paragraph after bullets, would this be considered contact or non-contact stormwater? Please clarify. What happens to contact stormwater? Are there retention tanks? Size?

Exec. Summ., p. iii Regulatory Compliance paragraph: Attachment H-6 notes a USEPA TSCA inspection. Do they have some kind of TSCA permit or approval?

Exec. Summ., p. iii Regulatory Compliance paragraph: Does the Florida DEP really issue the wastewater discharge (to POTW) permit?

Exec. Summ., p. ii Regulatory Compliance section: You had previously noted that they can send excess leachate to the POTW. Do they have a permit for this? Are there any discharge criteria?

Exec. Summ., p. ii Regulatory Compliance,

• When was the last inspection?

• Last sentence: What is the time frame for “no compliance problems”?

Exec. Summ., p. ii Regulatory Compliance, 1st paragraph: Are all permits current? Who issued them?

Exec. Summ., p. iii Regulatory Compliance, 3rd paragraph:

• Typo; “RIF” should probably be “RFI”

• Here you use OEPA, where previously you used OH EPA; be consistent. Perhaps go back to the 2nd paragraph and change “OH EPA” to “Ohio EPA (OEPA)”.



Exec. Summ., p. iii Regulatory Compliance, 4th paragraph: Please clarify “waste stream B”

Exec. Summ., p. iii Regulatory Compliance, Noteworthy Items, 1st bullet: Please update this; we use DART instead of LTI, and provide the rates for 2004, 2005, 2006.

Exec. Summ., p. ii Regulatory Compliance, Noteworthy Items, 1st sentence: Who is “Mr. Logan”? Provide a title and organization.

Exec. Summ., p. ii Regulatory Compliance, Noteworthy Items, 2nd bullet: Please go back a consistent 5 years in the Executive Summary.

Exec. Summ., p. iii Regulatory Compliance, Noteworthy Items, 4th bullet: Delete the sentence “See Attachment H-2, TCEQ Default Judgment, for specific information.” We try to refrain from using references in the Executive Summary unless absolutey necessary.

Exec. Summ., p. iii Regulatory Compliance, Noteworthy Items, 4th bullet: Perhaps change “facility is operating in compliance at this time” to “facility was operating in compliance as of the site visit” or similar.

Exec. Summ., p. iv Regulatory Compliance, Noteworthy Items, 4th bullet: This is the first mention of an aerosol device. Are gases accepted?

Exec. Summ., p. iii Regulatory Compliance, Noteworthy Items, last sentence: Perhaps change “below average” to “below the industry average”

Exec. Summ., p. iii Regulatory Compliance, Noteworthy Items: Briefly describe compliance history. When was the most recent waste inspection? What were the results? Has the facility ever received NOVs, fines, etc? Please describe, even if there hasn’t been any inspections, NOVs, etc.

Exec. Summ., p. ii Regulatory Compliance, Noteworthy Items: Has the facility ever had any exceedances on the discharge to the POTW?

Exec. Summ., p. iii Regulatory Compliance, Noteworthy Items: Include a bullet regarding compliance. Discuss the most recent inspection (name the agency), the results, and briefly discuss compliance history within 5 years.

Exec. Summ., p. ii Regulatory Compliance, Noteworthy Items: New bullet: Might want to comment on the DART rate of zero for the last 3 years.

Exec. Summ., p. iii Regulatory Compliance, Noteworthy Items: Provide a bullet on solid waste compliance. When was the last inspection? Have there ever been any waste violations?

Exec. Summ., p. ii Regulatory Compliance, Noteworthy Items: When was the last inspection? Who did it? What were the results? What is the frequency? What is the compliance history? The first bullet is rather vague.

Exec. Summ., p. ii Regulatory Compliance, Noteworthy Items: When was the last inspection? Name the agency, date, and results. What is the inspection frequency?

Exec. Summ., p. iii Regulatory Compliance, Noteworthy Items: When was the most recent RCRA waste inspection? What were the results?

Exec Summ. p. iii Regulatory Compliance: High incidence rate in 2005-2006 as discussed in B6fA should be included as a Noteworthy Item in this section.

Exec. Summ., p. iv Site Geology and Groundwater:, Noteworthy Items:, 1st bullet: To avoid confusion with the 3rd bullet, change “no wells” to “no drinking water wells”

Exec. Summ., p. iii Site Geology paragraph: Who uses the groundwater? What is the distance to wells? Are they private wells or municipal?

Exec. Summ., p. ii Site Geology section: Either here or in the Noteworthy Items section: Provide the drinking water source for local residents or municipalities. If groundwater, provide the distance to wells and well depth. If surface water, name the source and distance.

Exec. Summ., p. ii Site Geology section: Please note the source (and distance) for local drinking water.

Exec. Summ., p. iii Site Geology section: Where do local residents or municipalities get their drinking water? If surface water, provide distance and source. If groundwater, provide depth and distance to wells.

Exec. Summ., p. v Site Geology section: Where do the local residents get their drinking water?

Exec Summ. p. iii Site Geology, 1st bullet: Groundwater for golf course irrigation is not an agricultural use (i.e. food production). Suggested wording – “…being used for irrigation at the adjacent golf course.”



Exec. Summ., p. ii Site Geology, 1st paragraph: Is the depth of the municipal wells known?

Exec. Summ., p. iv Site Geology, Noteworthy Items, 2nd bullet: Are they currently treating the groundwater? The 3rd bullet mentions pump and treat, but doesn’t say if they are actually treating the groundwater.

Exec. Summ., p. iii Site Geology, Noteworthy Items, 2nd bullet: Is their well tested? If so, you may want to note it in an auditor comment box in Section E, as well.

Exec. Summ., p. iv Site Geology, Noteworthy Items, 3rd bullet: Please define “intrusive investigation”

Exec. Summ., p. iii Site Geology, Noteworthy Items: 1st bullet: Please name drinking water the source and provide the approximate distance from the facility.

Exec. Summ., p. iv Financial Strength paragraph: Are the owners known? Please name them.

Exec. Summ., p. iii Financial Strength paragraph: Has the facility ever been bankrupt or involved in any significant litigation?

Exec. Summ., p. iv Financial Strength section, 1st paragraph: It appears that the z-scores are reversed.

Exec. Summ., p. iii Financial Strength section: Include any information regarding environmental legal issues at the facility, as well as PRP status for the facility or corporate.

Exec. Summ., p. iii Financial Strength section: Please provide a contact (name, title, and phone) for members to request financial and insurance information.

Exec. Summ., p. iii Financial Strength section: Provide Mr. McGill’s title.

Exec. Summ., p. iii Financial Strength, 1st paragraph, 1st sentence: Please provide these individuals’ names and titles.

Exec. Summ., p. iv Financial Strength, 1st paragraph, 2nd sentence: Please modify the sentence: “Financial information for Veolia Environment was provided by CHWMEG.” The data was assembled from Veolia’s form 20-F.

Exec. Summ., p. iv Financial Strength, 1st paragraph: It appears that EBIT and retained earnings were not provided. Z scores cannot be calculate without these numbers. You should probably be state that “Altman Z scores could not be calculated based on the limited data provided” or similar.

Exec. Summ., p. iv Financial Strength, 1st paragraph: Remove “OES” from the list – Onyx no longer exists in any form.

Exec. Summ., p. ii Insurance paragraph: Please delete template material: “[Include bracketed material if it applies]”

Exec. Summ., p. iv Insurance, 1st bullet: The General Liability limits are $2 million and $4 million.

Exec. Summ., p. v Insurance, 2nd bullet: For consistency with the other bullets, change “$9,000,000” to “$9 million”

Exec. Summ., p. v Insurance, 5th bullet: Please replace “deductible” with “self-insured retention”. There is a major difference between a SIR and a deductible.

Exec. Summ., p. iv Insurance, 5th bullet: You should mention that the SIR limit is $5,000,000.

Exec. Summ., p. iii Insurance: The auditor should clearly state that all dollars values are represented as Canadian dollar

Exec. Summ., p. iii Insurance: 2nd bullet: Delete the template material in [brackets]

Exec. Summ., p. iv Insurance: Include bullets for Excess Liability and Auto, and state that 1) either they don’t have that coverage, or 2) the certificate wasn’t provided.

Exec. Summ., p. iii Closure paragraph: 2nd sentence: What is the post-closure period? What kind of maintenance and monitoring?

Exec. Summ., p. iii Closure paragraph: Are they required to maintain closure plans and funding?

Exec. Summ., p. iii Closure paragraph: Delete the 1st closure paragraph since it is entirely made up of Executive Summary template language.

Exec. Summ., p. iii Closure paragraph: Insert a paragraph to describe closure activities at the site before discussing closure funding.



Exec. Summ., p. iv Closure, 1st paragraph: Perhaps change “The facility does not have a formal closure plan” to “The facility is not required to have a formal closure plan” or similar.

Exec. Summ., p. v Closure, 2nd sentence: “…is required by our solid waste processing…” Please delete the first-person grammar (“our”).

Exec. Summ., p. iv Closure/Post-closure:, 1st paragraph, 1st sentence, please clarify the statement “…as described in Insurance, above…” there is no reference to “petroleum storage tanks” in the Insurance section above.

Exec. Summ., p. iv Closure: The closure plan seems to assume that the incinerators will be operational at time of closure. Is there any contingency if they are not?

Exec. Summ., p. iv Management, Noteworthy Items: Is there anything to add regarding community or security?

Exec. Summ., p. v Operational or Technology Changes: It appears from B6i1 and C11a2A that the facility has recently constructed new dehydrators. Has this been added since the prior review? If so, it should be mentioned here as well as A30A.

Exec. Summ., p. vii Operational, 1st bullet: Please elaborate. Why was the roof replaced? If it isn’t relevant, then perhaps we should just remove it.

Exec. Summ., p. vii Operational: You should probably mention the RCRA closure of the solidification area.

Exec. Summ., p. v Operational…: Were there any regulatory requirements for closing and removing the old blend tanks?

Atlman Z Table, p. 102 The z-score here does not match the one in the Executive Summary. Please fix where appropriate.

A1, p. 2 Please verify whether or not this is the New Castle or Smithfield recycle center. Tell me what it should be, and I will search & replace in the questionnaire.

A2, p. 2 In order to be consistent use the exact name provided in the

A3, p. 2 EPA RCRIS database shows an EPA ID of FLD984206003 – is this valid?

A4a, p. 2 Minutes and seconds in lat and long cannot be greater than 59. Try this…

43 degrees 59 minutes 55 seconds N (North or South) 84 degrees 48 minutes 47 seconds W (East or West)

A4a, p. 2 The hemisphere for longitude should be W (not E)

A4a, p. 2 These coordinates are on the Delaware River. The plant itself is at a longitude of: 75° 29' 42" W (latitude is OK as-is). No need to update the population estimates.

A4a1, 2 Provide zip code in physical site address

A6, p. 2 It appears that you have contacted the facility by phone. Please provide the phone number.

A8a, p. 2 The email address doesn’t match either POC.

A8b, p. 2 Their website is located at www.sipimetals.com (delete the hyphen)

The email addresses are correct; Sipi owns that domain, as well.

A9, A10, p. 2 These should be names (not email) of the individuals.

A9, p. 2 The POC’s title does not match the one in the Executive Summary. Please fix where appropriate.

A11a, p. 2 Please check this phone number. It appears to be the fax number. Should (0531) be (0532)?

A11A, p. 3 What type of number is in A3 since it’s not an EPA ID.



A11c, p. 3 You should note that this is a SIC code, or delete.

A12, p. 4 Were any of these individuals contacted “in person” or “by email” as noted in i8?

A12, p. 4 According to D4A2, you only contacted one regulator. You should revise the “Contact Means” for the other 3. You also need to revise A12A, since there was only one conversation.

A12, p. 4 Two of the regulators are missing the “Contact Means”. It appears that they should be [Did not return calls] or similar

A12, p. 4 Please specify a “Contact Means” in the first column. Note: i8 indicates that conversations were “In person”

A12A, p. 4 Provide the URL for the internet search of the South Coast Air Quality Management District site.

A14a3, p. 5 Provide the city, state, zip

A16A, p. 3 • Please comment on facility ownership.

• If the private owners are known, please name them.

A16A, p. 5 Since the overall parent is in Plano, TX, please elaborate on the relationship with the facility in Elgin, IL..

A16A, p. 5 2nd paragraph: Please provide the locations (city and state) of these subsidiaries.

A20, p. 5 The lease termination date is in the past; please clarify.

A22, p. 6 This answer is not easily found in Attachment H-1; please provide a response, then refer the reader to the attachment.

A24, p. 6 The acreage here does not match the Executive Summary.

A25, p. 5 Since they no longer have an evening shift, should the hours be different? You may want to comment in A26A1.

A25, p. 5 Change the first box to 0700-1530, and the last two to [closed] if that is the case.

A26, p. 6 If you are going to use the average number of employees from the OSHA logs, then you should use the actual hours worked from these logs, as well. From 2006 to 2004, they are: 201,285, 199,149, and 189,056

A26, p. 6 Please check the hours worked…6x2,000=12,000

A26A1, p. 6 You should comment (in a new paragraph) that the hours presented in A26 are the actual hours worked from the OSHA logs.

A27, p. 7 Check the line for Manufacturing of ordnance – should the “Year Activity Suspended” be updated?

A27, p. 7 For future reports: This table should be completed with the most recent activities at the top. I’ll fix this one.

A27, p. 7 Check the dates; these haven’t been updated for the most recent site visit (3 occurrences).

A27, p. 7 1st row: Do they still perform oil recycling and asphalt production? If not, then this should be modified.

A27, p. 7 Top row, 1st column: You should probably add solidification and oil filter crushing to the activities.

A27A, p. 7 The table notes that Sipi came in 1918, while the auditor comment box says 1949. Please clarify.

A28A, p. 8 This auditor comment box might be a good place to mention the comment in the Executive Summary: Emerald is not listed as a Potentially Liable Party (PLP) in the area-wide study or clean-up.

A28a, p. 8 According to this, the “facility” is claylined. Does this mean the entire facility? Or is this referring to the “old” landfill? This paragraph is rather vague; please provide more detail.

A28A, p. 8 This is asking about “potential” releases. 23 years of solvent transfers probably qualifies.

A28A, p. 9 Brackets ([…]) in 3td paragraph are not needed as this is an auditor comment box.



A29A, p. 8 Technically, this should be “yes” since the last site visit was 5/15/2002.

A30a, p. 8 Is this 1,500 feet above sea level, or 1,500 feet above grade?

A30a, p. 8 Add Renewal of Part B permit for consistency.

A30a, p. 9 Provide a full name and title for Vincent

A30A, p. 8 You should probably add the info from section VI of the Executive Summary for consistency.

A30A, p. 8 These changes are different than the ones noted in Section VI in the Executive Summary.

A31, p. 8 One of these should be the primary PP activity.

A32a, p. 9 For consistency, you should check the “Other” box and put [Solidification] in the text box.

A32a, p. 9 Remove the X’s for “Battery Recycle” and “Used Oil Recycling” since they don’t conduct these operations. A33 explains this very well

A32a, p. 9 Put an X in the box for “Thermal Treatment (specify)”

A32a, p. 9 Silver Recovery isn’t mentioned in the Executive Summary at all. Please clarify.

A33, p. 9 I’m not sure what this comment is trying to say. According to the Executive Summary, the facility currently accepts and treats (via bio-remediation) “petroleum contaminated soil”. How is this different from oil tainted soil? What is oil tainted soil?

A33, p. 9 Does the facility accept liquids? Will they accept industrial waste? I’m assuming they accept the latter, since a member wanted this reviewed.

A33, p. 9 Is there any testing of solidified material?

A33, p. 9 May want to mention that the landfill is for site generated CKD only.

A34, p. 10 1st row & 5th row: Perhaps change 100% to 100% after pretreatment or similar.

A34, p. 10 The “Totals” row should probably be [~26,000,000]

A34, p. 10 Top 2 rows:

• Since these materials are blended, the amount transferred offsite should not be 100%, since the treatment is occurring here. In this case, you can just say 100% [after blending]

• Note that Refer to audit packet does not answer the question. List a few of the facilities that are used, and be sure to refer to an actual attachment. It appears to be Attachment H-6

A34, p. 10 For the 2nd and 6th rows: These wastes are treated onsite. For consistency with the instructions, change the 100% to [0%] and Waste Management, Simi Valley, CA to Waste Management, Simi Valley, CA [after treatment]

A34, p. 10 1st row, last column: For consistency, add the city and state to each facility.

A34, p. 10 According to the Executive Summary, the top 3 rows are all treated onsite without transferring the waste. The “Amount Transferred” column should probably be 0% in the first 3 rows, and delete the destination facilities. Use table B2a to indicate where residuals (wastewater, crushed filters) are sent and C36b to indicate where products (refined fuel oil) are sent.

A34, p. 10 This table should include a new entry for Antifreeze in the first column, with the rest of the columns [Not provided], except for Amount Transferred, which should be [100%]

A34, p. 10 Perhaps change the “Method of Handling” to [Toll processing] or similar

A34, p. 10 Perhaps change dirt to [soil]

A34, p. 10 2nd row: Should the “Method of Handling” be [solidification & transfer] or similar?



A34, p. 10 3 occurrences of Onyx that should be Veolia. I will search and replace the entire Executive Summary and questionnaire.

A34, p. 10 5th row: Is the throughput known?

A34, p. 10 A36A, p. 12

Since Attachment H-3 contains many facilities, you may want use A36A to state the following from the Executive Summary: A34: Non-fuels are sent offsite for incineration at either Onyx in Port Arthur, TX, Von Roll America in East Liverpool, OH, or Clean Harbors in Deer Park, TX or Ross Incineration in Grafton, OH.

A34, p. 11 • Spent Methylene Chloride row: Onyx should be Veolia

• Miscellaneous Special Wastes row: Teris should be Clean Harbors

A34, p. 12 Can this list be broken down into waste types (fuel, wastewater, haz solids, etc) instead of waste industry? If not, you should comment in A36A why this table is organized this way.

A34, p. 9 While volumes of individual waste streams are not known, the overall volume was reported in the Exec Summ (13,170,000 gal/yr) – suggest that this be entered at the bottom of the table.

A34, p. 9 This only lists MSW and C&D waste. According to the Executive Summary, they accept Special and Industrial Waste. Please clarify. Use A36A to provide examples of Special and Industrial Waste.

A34, p.12 Please replace the ditto marks with the appropriate information.

A35, p. 11 All boxes should be completed. “Other materials” boxes under Halogenated and Non-halogenated are left blank; should be CC

A35, p. 11 According to the Executive Summary, “Liquid waste solidification is performed within a designated area”. This indicates that they receive liquid waste. Please clarify.

A35, p. 11 It appears that Appendix I mentioned in the facility comment is included in Attachment H-2. The auditor comment box should probably contain a reference. I’ll fix the cover sheets.

A36A, p. 12 You should probably note the percentage of carbon in A34 that is hazardous and non-hazardous.

A36A, p. 12 Please define special wastes

A36A, p. 12 May want to reiterate that they only accept Canadian waste at this time.

A36A, p. 12 Give examples of Industrial waste and Special waste from table A34.

A37 & A38, pp. 12-13 The “Methods of Delivery” in each table do not agree; please revise.

A37, p. 12 This is the first mention of “Gas” being received at the facility. Please verify, and this should probably be included in the Executive Summary.

A38, p. 13 Table A37 also contains “Rolloff truck” and “Tank truck” as Methods of Delivery. Those should be included here, as well.

A38, p. 13 Please fix; each row is to have one PP

A38a2, p. 13 The photos show a wheel wash area. This (and disposition of the wash water) should be described here.

A39, p. 14 Companies and locations are reversed

A39, p. 14 Provide a city and state for the last 2 rows.

A39, p. 14 This is a 5-7 year old list of clients. Is it still valid or representative today?

B1a, p. 16 This is asking about pre-qualification of waste. This response appears to address inspection upon receipt.

B1a, p. 16 What about parts washer solvent and other “core” Safety-Kleen materials?

B1a, p. 16 This is asking about the prequalification process. This doesn’t seem to describe the process from beginning to end.



B1a, p. 16 Please elaborate. Is there any kind of waste profile sheet? Further, A35 alludes to some type of generator certification.

B1a3, p. 16 If pre-qualification samples are not sent to this facility, then where are they analyzed?

B1a3, p. 16 This should not be answered based on the “no” in B1a2.

B1a3, p. 16 Please elaborate. Give the most common analyses. Further, the facility has no lab. How are analyses conducted?

B1a3, p. 16 Move this comment to B1a5. Once in B1a5: What analyses are conducted?

B1a5, p. 16 Please review the question; it is asking for the conditions where analyses could be accepted in lieu of a sample.

B1a5, p. 20 The 1st sentence of B1a3 should probably be in this box; it seems to answer this question.

B1a8, p. 16 If the intent of None means that “All waste requires profiling”, then please use the check box. Otherwise, elaborate on None

B1a8, p. 16 Does MSW require profiling? If not, it should be listed in this response. Also, if not, you should remove the X from the box.

B1aA, p. 17 Typo; Appendix should be Attachment

B1b, p. 16 What are the titles of these last 2 individuals?

B1b, p. 17 Last sentence: What happens if the regulatory agency doesn’t respond after 5 days? Is concurrence assumed?

B1c4, p. 17 These screens are most likely not completed at receipt; however the sampling is.

B1c4, p. 17 What analyses are conducted?

B1c4, p. 17 The Executive Summary mentions a thorough inspection on 2 loads per week. Please describe briefly here.

B1c4, p. 17 Since all loads are visually inspected at the scale and working face, what is different about the random 5 MSW and 2 special waste load inspections?

B1c5, p. 17 What about bulk loads?

B1c5, p. 17 Does the 100% apply for containers, too?

B1c7, p. 17 Please clarify this; both the Executive Summary and A34 note that autoclave waste is first stored in refrigerated trailers.

B1dA, p. 18 Where are samples sent since there is no onsite lab?

B1eA, p. 19 Where are samples analyzed since there is no lab?

B1fA2, p. 19 For future reports, include the text Attachment C with photo references. Example: Photo 4 should be Attachment C, Photo 4

B2a, p. 19 3rd column: The top 2 rows are not “Offsite Management Methods”; please clarify

B2a, p. 19 Are there any other residuals such as CKD, refractory, etc?

B2a, p. 20 These do not appear to be facility generated residuals (except for containment water). Please review this table and delete all table items that represent through put waste.

B2a, p. 20 Systech is a fuel blender; you may want to change the Offsite Management Method to [Kiln Fuel] or similar.

B2a, p. 20 • Table: There are more residuals listed in the Executive Summary than listed here. Please be consistent.

• 3rd row: According to the Executive Summary, the dust is sent to several locations. Please reconcile.



B2a, p. 20 “Additional comments” box:

• Where is refractory sent when not reused in the process?

• Is there a current CKD monofill on the Holcim property (based on the phrase disposed onsite)? Please mention that it is beyond the scope of this review.

B2a, p. 20 • You need to at least provide a list of the “Offsite Management Methods” for each row instead of Various. Examples include Landfill, Fuel Blending, etc

• Further, Recycled isn’t sufficient for used oil. Is it re-refined, burned in a BIF, etc?

B2a, p. 20 1st row: For consistency with the Executive Summary, change Landfill to [Stabilization (if required then)] Landfill or similar.

B2a, p. 20 6th row (1st Empty Drums row):

• Based on B2d4, change Empty Drums to Empty Drums [and Totes]

• Provide a facility and location for Empty Drums [and Totes]; use [not provided] if the facility didn’t release this info.

B2a, p. 20 Replace the ditto marks with the actual information.

B2a, p. 20 1st row: You should add the reapplication of leachate to the landfill as another destination.

B2a, p. 22 6th row: Please check the disposition of drums; the Executive Summary notes that unusable drums are sent only to the “North Weld County Sanitary Landfill”

B2a, p. 23 • 9th row: Teris should be Clean Harbors

• 10th row: Onyx should be Veolia

B2d4, p. 20 According to the Executive Summary, “Empty drums are sent to a metal recycler”. Please revise where appropriate.

B2d4, p. 21 The way this is written, drums can be painted, and then crushed. Please clarify.

B2d4, p. 21 The Executive Summary, p. ii, states that drums can be “washed with hot water and detergent, and returned to generators”. Please clarify.

B2d4, p. 21 Perhaps replace smashed with crushed

B3A1, p. 20 Was there any wind-blown trash?

B3A1, p. 21 How was housekeeping, overall?

B3A1, p. 23 Why were you unable to enter these areas?

B3A2, p. 21 What type(s) of odor?

B3A7, p. 21 Please check this comment; the Executive Summary and A27 state that the facility was constructed in 1999.

B3A7, p. 23 Please provide more detail; where was the rust visible? Generally, what was the condition of the processing equipment?

B4e1, p. 23 Provide a reason why both “yes” and “no” are checked.

B4g, p. 22 Is this for all waste loads, or just special/industrial/asbestos/etc loads?

B5A, p. 23 You should indicate something like: B5c, B5d: There is no storage of treated or processed waste.

B5A, p. 23 Please provide a brief description of how long solidified material has to wait before being disposed. A few hours? Until testing proves it is ok?

B5A, p. 23 For consistency, you should probably include the comment from the Executive Summary: All liquid waste is solidified within the next working day of receipt of the liquid waste.



B5A, p. 24 This might be a good place to note that there are no storage time limits.

B5c, p. 22 Check the units – tons/year – this is asking for current inventory

B5c, p. 23 Provide the estimated current inventory. From C24b, you can use [1,750]

B5c, p. 24 Please confirm the units (yd3) in the “Drums” row.

B5c, p. 24 Should the permitted tank capacity even be listed? The Executive Summary notes that there are no tanks in service at the facility.

B5d, p. 23 Use this table to list the amount of processed waste (such as ash and slag) onsite at the time of the site visit.

B5f, p. 23 Replace to date with an actual date.

B5f, p. 24 To fully answer the question: What is this waste?

B5f, p. 26 I don’t understand the response [No later than 2006]; please provide a date or estimated date.

B6a1, p. 24 In most of the incidents listed, what was done to prevent recurrence?

B6A2, p. 26 Please elaborate on the PPE at the facility.

B6c, p. 26 The DART (Days Away, Restricted activity, job Transfer) injuries are calculated by adding boxes H and I on the OSHA 300A form. By doing this, I arrive at… B6c1: 39 B6c2: 8 B6c3: 5

B6c1,2,3, p. 24 Please change these to 4, 4, 1 respectively. The equations will just confuse some members.

B6cA, p. 24 Since the OSHA (or MSHA) logs are not included, did you verify the injury numbers? Please comment here.

B6cA, p. 25 Were the OSHA logs available for review? Were these numbers confirmed?

B6cA, p. 25 Was the OSHA log for 2006 reviewed? You should probably comment. It’s not included in the attachment.

B6d, p. 26 • From the 300A’s Box K, I get: B6d1: 435 B6d2: 230 B6d3: 0

B6dA, p. 24 You state that the facility has had no lost time in 2006; however, you list 13 days lost time in B6d1. Perhaps you meant 2007? Otherwise, this discrepancy needs clarified.

B6e, p. 24 You say that the facility used the actual hours worked to calculate the DART rates. Thus, I cannot verify the DARTs; however, there are several inconsistencies:

• B6c1 shows 6 injuries and B6c3 shows 2 injuries. Therefore, the corresponding DARTs in B6e1 and B6e3 cannot be roughly the same values (5.39 and 5.40).

• B6c2 shows 0 injuries in 2005. Therefore the corresponding DART should be 0.00

B6e1, B6e3, p. 26 These are reversed; 2006 should be 2.92 and 2004 should be 0.97. They are also reversed in the Executive Summary.

B63, p. 26 From the injuries above, and the actual hours worked in the form 300A, I get: B6e1: 61.5 B6e2: 16.3 B6e3: 0

B6eA, p. 26 If you have the actual hours worked, then please complete that section in A26.

B6fA, p. 24 For this and future reports, please include the actual industry sector DART number.

B6fA, p. 25 Insert DART before incident rate

B6fA, p. 25 Provide the industry DART rate for comparison, especially since this has a different NAICS code than 5622. From BLS, I get an industry average of 2.3 for 4-digit NAICS 4239.

B6fA, p. 28 The DART can’t be zero for 2006 since B6cA states that there were restricted duty days in 2006. Please clarify.



Section C, p. 28 Put X’s in the boxes for Section C.2 and Section C.3 since you completed those sections.

C11a1, p. 29 Based on comments provided in C11a1A, it would be acceptable to place an “X” also in the “Operations are technically more advanced than typical…” box.

C11a1A, p. 29 Please provide a response; this is never blank. Explain why this landfill is considered “similar” to others.

C11a1A, p. 30 This all sound typical for the fuel blending industry. Please highlight the processes or activities that caused you to rate it as “advanced” in C11a1.

C11a2A, p. 29 Briefly summarize the age and appearance of onsite treatment equipment.

C11d, p. 29 When is the flare used if there is an energy plant?

C11e, p. 29 According to the instructions, the percentage should include lined landfill areas.

C11g, p. 30 Reviewing Attachment C, photo #26, it appears that these roll-off are on bare ground.

C12a, p. 31 The Executive Summary stated that facility size is 300 acres.

C12c2, p. 29 This mentions a sedimentation basin; the Executive Summary describes three unlined ponds. Please reconcile.

C12c2, p. 30 Please elaborate on the statement managed according to applicable regulations.

C12c2, p. 30 This contradicts the Executive Summary and C24g: “Contact storm water is observed and if a sheen is present, it is sent offsite for treatment. If clean, it is discharged off-site.”

C12c2, p. 30 Please review the question; what is the treatment process?

C12c2, p. 30 1st paragraph, last sentence: According to the Executive Summary, this is used as quench water. Please fix where appropriate.

C12c2, p. 34 Contact and non-contact stormwater are treated the same. Please check this; according to the Executive Summary: “Contact stormwater is collected and handled with process wastewater (incinerated). Non-contact stormwater is collected and sent to a dedicated onsite evaporation pond (separate from the one used for the monofill leachate)”.

C12c2, p. 34 Elaborate on inspected. Is it analyzed (if so, for what), or just visually inspected?

C12c2, p. 34 For consistency with the Executive Summary, you should probably change Contact stormwater is collected to Contact stormwater and contaminated groundwater is collected

C12d3, p. 30 Give some general examples before referring the reader to the attachment.

C12e, p. 30 This question is asking to describe the analysis. This should list where it is sampled and the frequency.

C12e, p. 35 This doesn’t answer the question. It is difficult to find this in H-2.

C13A, p. 31 Add a comment regarding what happens to the storm water after entering the storm water retention ponds.

C13A, p. 32 You should probably comment that all operations are indoors, therefore, there is no contact stormwater.

C14 and following, pp. 31-32

This section is for site-generated wastewater (not stormwater). According to the Executive Summary, there is a wastewater stream generated. Don’t forget to use C14A to note where it is sent.

C14, p. 33 This section is for wastewater only (stormwater is in C12-C13, and sanitary can be ignored).

C14A, p. 31 C14a notes that wastewater is also sent offsite (not to POTW). Please provide the location. How is this wastewater generated?

C14a, p. 31 Based on comment in C14A, you should probably X the box for “Disposed onsite…”

C14A, p. 31 The leachate may also be sent offsite. Please note this, and note the offsite facility, city and state.



C14A, p. 32 This would be a good place to mention that the leachate is trucked to the POTW. Also, from the Executive Summary: The facility is in the process of obtaining right-of-ways for a direct pipe line to the Jacksonville POTW for leachate disposal.

C14A, p. 32 What wastewater is generated? If section C14 is describing stormwater, then you should probably remove all responses from section C14 since stormwater is covered in C12.

C14A, p. 35 Please state why the POTW details (C14c) weren’t provided.

C14b1,b2, p. 31 Remove the responses to avoid confusion. Stormwater was addressed in C12-C13

C14b2, p. 31 What are the discharge criteria for sending leachate to the POTW?

C14d, p. 32 Please mention the destination facility, city and state.

C14d, p. 36 Provide some brief, general limits, then refer the reader to the attachment. These limits aren’t easily found in the attachment.

C15a, C15b, p. 32 These can’t be NA since these units are present. If there are no controls, then replace NA with None or No controls

C15a, p. 32 Please clarify; according to the Executive Summary, tanks are nitrogen blanketed and emissions are routed to the incinerators.

C21, p 33 Put an X in the box for “Stockpiles” since you completed that section.

C21, p. 32 Put an X in the box for “Storage Tanks…”

C21, p. 34 Containers box should be checked.

C21, p. 36 Put an X in the box for “Stockpiles”

C22, p. 33 Provide more detail on how material is handled which could cause potential for spills – e.g. methods used to transfer material from drums or boxes to process where spillage is possible.

C24a, p. 33 This is the first mention of rolloffs. According to B5c & B5d, there is no storage as all waste is disposed on receipt. Please clarify.

C24a, p. 33 Elaborate on the storage area (stacking, spacing, containment, etc)

C24A, p. 34 How do they handle chemotherapeutic and pathological waste? I’m assuming they keep it refrigerated until they have a truckload for transfer. Most comments regarding the trailers indicate that they are available if needed. Please describe, if known.

C24A, p. 34 • All drums are solid. Please replace Solid drums with Drums containing solids or similar.

• This is the first mention of stabilization; do you mean solidification? Further, why would solids require solidification?

C24A, p. 34 This auditor comment box is for comments regarding container storage. Since there is no container storage, this shouldn’t be answered. Perhaps move this to C25A1.

C24b, p. 37 Both the Executive Summary and B5c state that the permitted limit is 27,410. Please fix where appropriate. Looking at Attachment A, you should probably change the Executive Summary and B5c to the value in C24b.

C24c2 and C24A, p. 33 This section is for containers, not tanks. If they do not store containers of waste (for example, if they only have a drum of oil), then the container section should not be completed. Use C25 to discuss the oil tank.

C24c2, p. 34 Please comment on the “condition of containers” and “open containers”, since C24c1 has 2 questions answered both “yes” and “no”

C24g, p. 34 Please describe the procedure to handle spills.

All C24 Questions, pp. 33-34

Since there is no container storage (other than empty rolloffs), then these questions shouldn’t be answered.



C25a, p. 34 • The “Date of Last Testing” column is blank. Include the date or [unknown]

• Provide a bottom geometry type. Or note in the auditor comment box that these are horizontal tanks.

C25a, p. 35 • The tanks are listed in H-7 (not H-4)

• Add the units (e.g., gal) after each volume.

• If there is more than one tank listed on each line, then change the volume to 15,000 gal ea

C25a, p. 35 Complete the 2nd column.

C25a, p. 35 This table also needs to include all USTs

C25A1, p. 36 • What is the testing frequency?

• You should probably add another paragraph to note that tanks 7,8,9 are the burn tanks.

C25A1, p. 36 This wood be a good place for the comment from the Executive Summary: The facility uses only above ground storage tanks in the maintenance area for diesel fuel, gasoline, waste oil, and other automotive fluids. All tanks have secondary containment.

C25A1, p. 37 Perhaps mention that the 4 lab waste tanks are not in containment.

C25A3, p. 37 If known, provide details on tanks removed in 1998.

C25c, p. 34 After the 3rd sentence, add the following from the Executive Summary: No waste fuel is stored in tanks at the present time; however, there are plans to do so in the near future.

C25f, p. 35 Please elaborate. How are spills and/or precipitation in containment handled?

C25f, p. 37 This appears to address stormwater only; what would be done with spills?

C25i,j,l,m, p. 36 Please provide responses; most likely “no”. If any are “yes”, then answer C25o-x.

C25k, p. 36 This should mention the fuel oil tank, too.

C25m, p. 39 This should probably be “no” since pits are excluded as USTs – see the instructions above C25i. You may want to check the responses to the next few question to ensure they are consistent with the facility not having USTs.

C25o, p. 36 Remove the X to avoid confusion; there are no USTs onsite.

C25p, p. 37 You should mention that the tank is tested annually (as first mentioned in C25c).

C25q, C25s, p. 42 Remove the X’s since there have never been any storage tanks.

C26, p. 38 In the future, this section should be completed for waste or material to be recycled, not raw materials. Thanks.

C26a1, C26b1, C26b2, pp. 38-39

Remove the Xs from these responses – this section is N/A based on C26a0.

C26a2, p. 37 Photo #3 in Attachment C shows turnings outside, and not under cover. Please clarify.

C26A3, p. 41 This contradicts C26c, which seems to indicate that the stockpile is raw material. Please fix where appropriate.

C26A3, p. 41 Perhaps change inspection to site visit

C26b1, p. 37 According to the Executive Summary, some of the stockpiles are on pads in buildings. Perhaps this should be both “yes” and “no”, and provide a comment in C26A3.

C32a, p. 41 In the comment add “solidification”



C32a, p. 41 “Other” text box: You should probably replace stabilization with solidification

C32a, p. 42 Put an X in the “Other” box.

C32b thru C35, p. 41 Complete the these questions with regards to the “solidification process”

C32b, p. 41 Is the recovered glass and metal tested for mercury?

C32b, p. 42 2nd paragraph: Is any testing conducted to ensure material is solidified?

C32b, p. 42 Briefly describe how catalysts are handle before the smelting. This would be a good place to describe the “labor intensive” aspects of the recycling.

C32b, p. 43 2nd paragraph: This paragraph should include the equipment used for stabilization. Describe any pits and mixing equipment. It appears that stabilized material is put into drums. This should be mentioned.

C32b, p. 44 Perhaps change (Not currently operational) to (Not operational as of the site visit; reportedly operating after the site visit according to site personnel) or similar.

C32b, p.41 2nd paragraph – reference to Portland cement should be removed as done in Exec Summ per facility comments in Att A.

C33, p. 41 Include a description of the compressed gas treatment.

C33, p. 41 • What happens to waste after stabilization? Where is it staged until it cures/passes analytical tests?

• Describe the micro- and macro-encapsulation processes. The information in the Executive Summary should suffice.

C33, p. 41 What is the final product? Is it a solution, or metal ingot? Please elaborate on the process.

C33, p. 41 Where are the analyses conducted since there is no onsite lab?

C33, p. 42 You note that the limit on WDF is 18.1 tph. As a comparison, how many total tons of fossil fuel per hour are used?

C34, p. 41 This is most likely conducted in batch. Please indicate the approximate run time.

C34, p. 42 Provide a paragraph to answer this for stabilization and electronics dismantling.

C35, p. 42 Provide the parameters.

C35, p. 42 Provide a paragraph to answer this for stabilization.

C36 thru C37 Appears to me these questions should not be answered, since they send this material for disposal.

C36, C37, p. 42 These should be completed for the recovered oil.

C36a, p. 42 Put an X in the box.

C36b, p. 44 For consistency with the instructions, please delete the 1st row since these are sent offsite as wastes. Leave the fuels.

C37b, p. 44 If deleting the 1st row in C36b, then delete this response. Are the fuels tested before shipping?

C42, p. 45 Insert the number of rotary kilns in the space provided.

C43, p. 44 Add F after 340

C43, p. 44 BTUs should probably be BTU/hr

C43, p. 49 “Year Constructed” response: Please verify the date; the Executive Summary notes that food grade equipment was installed in 2002.

C43, p. 51 We see various uses of the term M. Please replace 45,000 - 60,000 MBtu/hr with 45 – 60 million Btu/hr. Thanks!



C45a, p. 45 Please verify 5 days per week; this does not match the “hours of operation” in Section A.

C45c, p. 46 The 2% seems awfully low. This indicates that, of the total downtime, only 2% is planned.

C47a, C47b, p. 47 Are stack tests required?

C4A1, p. 43 Blank auditor comment box; please provide a response. I recommend: Kiln 1 is coke fueled and Kiln 2 is permitted to burn hazardous waste (the primary fuel is coke, with a maximum of 30% waste fuel allowed to be used).

C4A1, p. 44 Slag generated is about 15% of the waste – From the Executive Summary, this should be 15% by volume. Also, is the 15% based on incoming waste? Same comments for the ash at the end of the paragraph.

C4A2, p. 50 C32b describes a stack test; please clarify.

C4A4, p. 47 Please provide the reason the incinerator wasn’t operating.

C5A1, C5A2 & C5A4, p. 48

The numbers provided in the Executive Summary, Facility Operation, 1st & 2nd paragraph, do correlate to the values given here, please correct where appropriate.

C5A2, C5A3, p. 48 You should specify the units in these 2 responses. Most likely [acres]

C5A2, p. 48 This states that 99 acres are permitted; many other locations in the Executive Summary and questionnaire state 100 acres. Please fix where appropriate.

C5A2, p. 48 This should probably be 197 to be consistent with the Executive Summary and Section A

C5A3, p. 48 This should include the “old landfill” mentioned in the Executive Summary.

C5A6, p. 50 According to the last paragraph in the Executive Summary, they have begun some sort of airspace permitting process; please fix where appropriate.

C5A6, p. 54 Has the remaining life been estimated?

C5A6A p. 49 This might be a good place to note that the east landfill hasn’t been constructed yet.

C5A6A, p. 47 Will the expansion prevent facility closure in 2 years? Is the size of the expansion (and how it will affect remaining life) known?

C5A6A, p. 48 Please mention the current status of the expansion mentioned in C5A1. Where is the location of the expansion? When is construction anticipated?

C5A7c, p. 48 This is actually asking for the thickness of the liner material that makes up the sidewalls.

C5A7g, p. 47 Please describe the entire liner system.

C5A8, p. 48 Perhaps add a new paragraph describing cells 1-3, and why they were exhumed.

C5A8, p. 50 Is this 1,500 feet above sea level, or 1,500 feet above grade?

C5A8A, p. 53 Attachment H-14 also shows just about every design aspect of the closed cells. You should probably reference it from this response.

C5A9d, p. 49 For consistency, this should mention that leachate can be trucked offsite.

C5A10i, p. 50 According to other areas, the bioremediated soil can be used for landfill cover. Please fix where appropriate.

C5A10k, p. 50 You should probably add micro- and macro-encapsulation, and bio-remediation.

C5A10m, p. 50 Who owns the gas treatment plant? If WMI, where are residuals (condensate, old filters, etc) sent?

C5A10r5, p. 50 Please provide a response since C5A10r3 is “no”

C5B11a2, p. 51 Please verify the “yes” response. There is no indication of waste storage in impoundments.



C5B11h1, p. 53 Please provide the information required to complete this table.

C81b, p. 58 Attachment H-8 contains the air monitoring analysis; the inspection reports don’t seem to be included in the attachments.

Section C.9, p. 65 In the future, you don’t have to complete this section for facilities that only clean drums which didn’t arrive empty.

D1, p. 63 You should probably put the X in the box for “RCRA (or local equivalent)” since they have a hazardous waste permit.

D1a, p. 63 Perhaps mention that the Part B permit allows for treatment, but none is conducted.

D2a, p. 64 This shows the Part B permit being expired. Use D3A1 to comment on how they are still operating. The should probably be mentioned in the Regulatory Compliance section in the Executive Summary, as well.

D2a, p. 64 This table is a requirement. We typically ask for the major permits. I recommend listing permits 1, 3, and 4 from the attachment.

D2a, p. 65 It appears that the USEPA RCRA Part B permit expired before the site visit. Please explain in D3A1 and the Executive Summary.

D2b, p. 67 The “Date Submitted” for the RCRA permit is in the future. Please clarify.

D4a2, p. 64 There are 2 agencies that inspect the facility. Please include a frequency for each. It appears that the city of Indy inspects annually.

D4A2, p. 65 Include the agency with each regulator.

D4A2, p. 66 Question A12 lists 6 regulators that were contacted; however, there are only 4 conversations here. Please clarify.

D4A2, p. 68 Question i8 noted that you used an internet database for regulatory contact. If any information was compliance related, please present it here.

D4A2, p. 69 Add an additional comment about not being able to contact the other regulatory contacts.

D4a3, p. 64 Briefly describe the scope of the inspections before referring the reader to the attachment.

D4b1a, D4b1b, p. 64 What were the dates of these inspections? Were inspection reports available?

D4b1a, p. 64 Which agency conducted this inspection?

D4b1a, p. 64 Describe the inspection results before referring the reader to the attachment.

D4b1a, p. 65 This is very minimal compliance information. You should go back a few years, briefly list the violations, and then refer the reader to the compliance history in Attachment H-9.

D4b1a, p. 66 Last paragraph: Attachment H-8 contains the reports from 2005 and 2006, as well.

D4b1a, p. 66 Replace last few years with a fixed time frame (e.g., last five years) if possible.

D4b1b, p. 65 Please elaborate. If air inspections aren’t conducted, then this should be [Air inspections not conducted] or similar

D4b1d, p. 66 This space is for “Other” inspections. What medium is this comment describing?

D4b2a, p. 67 Please go back a consistent 5 years, especially since the last review was only a year ago, and different members are sponsoring/purchasing this report.

D4b2a, p. 68 It appears that the compliance history is through 10/12/2006 (not September 2005). Please clarify.

D4b2d, p. 74 It may be important to note that, along with the fine, they had to undertake a supplemental environmental project (SEP) totaling at least $120,000. This is from the letter in Attachment H-2.

D4b3a, p. 65 This shouldn’t be N/A; change to [None] unless there were any fines.

D4c1 & D4c2, p. 65 D4c1 should be “no” and D4c2 should be blank since this is asking about “other than inspection” incidents. This one was clearly from an inspection.



D5a, p. 66 This can’t be “N/A” since D4b2b mentions violations.

D5a1a, D5a1b, p. 70 These responses are for unresolved issues. These should probably be None

E1a, p. 67 Provide more detail. I recommend copying the Site Geology paragraph from the Executive Summary into this response.

E1a, p. 69 You should probably copy the comment from E1A into this space; include in [brackets]. This way, if we ever visit the site again, this information will be copied into the tailored report.

E1a, p. 73 Is there anything else known regarding the subsurface? This doesn’t really give much information.

E2a, p. 66 Wrightsville buys water from Little Rock which gets water from Lake Maumelle, approximately 35 miles northwest from here. This contradicts the statement in the Executive Summary: “The City of Little Rock derives its water supply from surface water from the Arkansas River.” Please correct where appropriate.

E2a, p. 67 This should probably be “Local groundwater” only

E2b, p. 71 Can the auditor identify the “surface water body” that is the municipality supply source as indicated in E2a?

E2d5, p. 69 Either delete this comment, or put an X next to “Bottled water” in E2d1.

E2e1, p. 61 Since the facility is on city water, remove the X from “surface water”.

E5a3, E5b3, p. 69 These questions are asking for the local and/or regional use. Examples include drinking water, irrigation, process water, etc.

E9c1, p. 72 E9b notes that there are 6 downgradient wells. E9f states there are 12 total wells. Please fix where appropriate.

E9f, p. 69 Please provide some of the monitoring parameters.

E9f, p. 70 Provide the frequency, if known.

E9f, p. 73 Provide a brief response (e.g., examples) before referring the reader to the attachment.

E9h, p. 75 This doesn’t answer the question; provide detail such as: how often groundwater is sampled, what agency (or agencies) the results are submitted to, etc.

E9j, p. 73 Is there any information available regarding the DCA and DCE in the groundwater? This was mentioned in the Executive Summary; however, there is no mention here.

F2a, p. 72 Elaborate on industrial. What kind of businesses are these?

F2a, p. 72 North, South, East: These can’t be None. Please describe the land use in all cardinal directions, even if it Vacant, Agriculture, etc.

F2a, p. 73 Please identify the neighbors in each direction, not just the industry.

F2a, p. 74 Looking at the satellite map, there are several buildings around this one. Please revise the Open Land comments. Describe the facility neighbors in each approximate cardinal direction.

F2c1, F2c3, p. 73 Perhaps update the population estimates; the coordinates in A4a were a fair distance off.

F2c2, p. 73 In this response, also include the workers on-site at this facility.

F3a, p. 72 What is the distance to this river?

F5a, p. 73 Please provide a response; if there are no buffers, then use [No buffers] or similar

G1a2, p. 76 Perhaps change this to 1,000 gallon fuel oil spill in 2003; See Item A28a or similar.

G1a2, p. 78 The question asks to go back 5 years. You should include a brief description of the 2003 spill, as well.



G2b2, p. 76 This should probably tell the reader which fire, since there are 2 listed in G2a2, and one didn’t require outside assistance.

G2b2, p. 79 Why was the contingency plan activated on this date? It appears to be a drill.

G3A, p. 77 The fire report notes that the sawdust is used for solidification. Section C5A indicates that solidification is not conducted. Please clarify; here and in the Executive Summary, Facility Operations section.

GA, p. 80 Since ENVA is treating the groundwater, are they also paying for it? Is anything known about the remediation funding?

H1a & H2a, p. 79 In H1a, list only the employees that are “Onsite Management” and in H2a, list “List Parent Company personnel available part-time at site:” and complete all the information required in the corresponding columns.

H1a, p. 78 The “Experience” values for this individual are identical to what they were over 5 years ago. Please update.

H1a, p. 82 Please verify the experience numbers; they are unchanged from last year’s report.

H1a, p. p. 79 This notes that Larry Bressman is the Landfill Manager. Ensure that this matches the Executive Summary and A8 / A9 / H8a

H1b, p. 85 If known, include the size of the environmental staff [in brackets]

H2A1, H2A1, p. 81 FYI: These don’t require responses when H2a and H2b are blank.

H3g2, p. 79 Please provide the date; especially since it is documented.

H3g2, p. 82 What is meant by “The actual event that occurred this day was used as a drill.” ? What event?

H5d1, p. 81 Please check the response; this is asking for the primary power source.

H6a2, p. 81 Please fix the date and provide the type of plan.

H7a1, H7a2, p. 82 If H7a1 is “Union”, then H7a2 should be answered. Please clarify.

H7a3, p. 80 This applies, regardless if the facility is Union or Non-Union.

H8A, p. 82 Please elaborate on the “Conducted By” column – replace the abbreviations with names and titles.

H8a, p. 82 If they don’t conduct these reviews, then put [No] in the 1st column of every row.

H8b,c,d, p. 82 These responses help to describe inspections in H8a. Since there are no inspections, please remove the responses.

I1a1-I1a4, p. 83 Remove the Xs from the boxes; these don’t require answers if no financials are given.

I1a2, p. 86 Put an X in the box, since the financial information is for this entity.

I1a3, p. 84 Provide the owner’s contact info here.

I2A, p. 82 Provide a contact and phone number (or at least a phone number) for members to request the financial information.

I2a, p. 85 For consistency, you should put an X in the box for “Other” and include the text SEC form 20-F

I2a, p. 85 Put an “X” in the box for “SEC form 10-K”, delete the other two X’s and the comment.

I2a, p. 87 The information we provided was from the SEC form 20-F filed by Veolia. Please delete [provided by CHWMEG].

I2a, p. 91 You should probably X the box for “Audited or verified Accounting report”

I2a, p. 97 Since you put an X in the “Other” box, please provide a response in the space provided.

I2b, p. 87 This should be [2006]

I6A, p. 84 Provide the U.S. dollar equivalent rate.



I8a, p. 85 You should probably note that there is no requirement for closure.

I8a, p. 86 Briefly, what are the closure steps? Include tank areas, solidification areas, steps for capping, etc.

I8a, p. 87 Briefly describe general closure activities before referring the reader to the attachment.

I8a, p. 88 The closure plan seems to assume that the incinerators will be operational at time of closure. Is there any contingency if not?

I8b, p. 84 What is the post-closure period?

I8b, p. 87 This should probably be [No post-closure anticipated] or similar.

I8b, p. 87 Briefly describe the post-closure steps.

I9a1, p. 85 Please provide a response; most likely [RCRA Subtitle C]

I9a1, p. 90 This question is asking for the regulatory requirement for closure.

I9a2, p. 96 Please review the response; the Executive Summary states that funding is through an irrevocable letter of credit.

I9aA2, p. 89 For consistency with the Executive Summary, mention that this funding includes present day adjustment for inflation.

I9aA2, p. 89 Is there a reason why the amount of coverage in I9a3 is significantly less than the cost estimate in I9a1?

I9b1, p. 93 Since this is a hazardous waste landfill, this should probably be Subtitle C

I9d1 through I9d4, p. 100

Even if closure and post-closure don’t apply, these questions always do since they discuss any type of “other” closure. Please provide responses.

I9d2, p. 91 This should probably describe the TSCA closure?

All questions in I10, I11, and I12

These questions are required to be answered.

I11b1, I11b2, p. 91 Based on the Executive Summary, change I11b1 to “yes” and I11b2 to: The facility is a PRP at Mercury Refining in New York and was entered as a de-minimus contributor. This has been paid and resolved. Veolia NA has a landfill in WI as an NPL site, and is currently in the process of cleanup.

I11b1, p. 88 This question is asking about the parent company, too. Please review.

I11b2, p. 86 There are a number of references to “we”. They should be changed to “Allied”

I12a, p. 92 Technically, this should be “yes” since they were in bankruptcy up until 12/2003. I12b can be [See IA]

IA, p. 88 Reiterate that financials weren’t provided.

Altman Z Table, p. 91 Use the drop-down box to specify the currency type.

J1, p. 89 “Expiration Date” row: These should all be 10/31/2007

J1, p. 90 The policy number for this facility should be WC4785226, which is the policy number for Ohio facilities.

J1, p. 90 The Auto combined single limit is $1,000,000 (not $10,000,000)

J1, p. 91 Lockton Companies of Huston is the producer, or agent. The “Carriers” are: ACE American Insurance Company for General, Auto, Excess and Indemnity Insurance Co of North America for Workers Comp.

J1, p. 92 Insurance information does not reflect what is provided in Attachment G

J1, p. 95 Replace the --- with either [Not Provided] or [No coverage] or [Whatever]



J2, p. 92 You presented the info for the Contractors Pollution Liability; the EIL is immediately beneath this on the certificate. Everything is the same, except for the following:

• J2a2 should be: PLC374393606

• J2a3 should be: 5/1/2007

J2a4, J2a5, p. 90 Based on the insurance certificate, these should be $10 million and $10 million

J2a6, p. 103 A comprehensive list of exclusions is included in Attachment G. You should probably include a reference to See Attachment G

J2a7, p. 92 Based on the certificate, there is a $1,000,000 self-insured retention (SIR)

J2a8, p. 88. Perhaps this should be [No claims] or similar.

J2b1, p. 91 This section should probably be N/A since the facility is non-hazardous.

J2b1a, p. 89 Please provide a response; most likely Insurance

JA, p. 89 You should probably comment that the EIL certificate was not provided.

JA, p. 92 Are companies in China required to carry any type of liability insurance?

JA, p. 95 Can you say that the insurance is expired? Did you request a current certificate? Perhaps state that the facility did not provide a current certificate.

K1b, p. 101 Can you provide a date or date range?

K2b, p. 101 Please check past years – perhaps you meant to add a number.

K3c, p. 91 This should probably be “no”; they don’t conduct drills per H3g1.

KA, p. 91 This would be a good place for your comment from the Executive Summary: No information was provided concerning complaints from the community; however, a negative image is unlikely since the facility is a major employer in the area with over 300 employees and over 350 contractors at the site.

L1a1, p. 94 If operations are conducted indoors, then this should be “yes” with L1a2 being [Building walls] or similar

L2c, p. 103 These hours don’t match the ones presented in A25; please fix where appropriate.

L2c, p. 107 Another reference to 24/7 operation. Please revise employee hours if they indeed follow the schedule that you provided in A26A1.

L3b, p. 94 Please answer the 2nd part of the 1st question – when is the gate locked?

L4a2, p. 95 Based on the photos, this should probably be: [Permit number, hours of operation, tipping fees, “No Hazardous Waste Accepted”, emergency contact info] or similar.

L4a2, p. 97 Briefly define Proposition 65 for us non-Californians.

L5A, p. 94 This box is for auditor comments regarding security plans. Please move this comment to be the 1st comment in LA.

List of Attachments The text [examples] appears after the attachment H title

Attachment A In the future, Attachment A should contain your response to the facility comments. It should say whether or not you incorporated their comments into the report.

Attachment C Photo 15: In the future, please do not take photos where the faces can be easily seen.

Attachment C Headers all have incorrect date (2/6/07)



Attachment C Page 10 of 10 Blank

Attachment C Pictures seemed small in both size and resolution. Please review the equipment used to take photos for future reviews.

Attachment C Photo 5: There is no caption, just an empty box. Sorry, we can’t fix this in the PDF. Please re-submit the page once you add a caption. You can send this page only, if you wish.

Attachment C In the future, when facility refuses to let you take pictures, then take some photos from outside the property line, if possible.

Attachment C In the future, you should note on the cover that the facility requested certain photographs be removed, and give the reasons from Attachment A. Thanks.

Attachment D In the future, if not including figures, the cover should be:

ATTACHMENT D – FIGURES

None Included

Attachment E In the future, make sure the cover page reflects what is contained in the attachment. For example, this one should be:

ATTACHMENT E

CLOSURE COST ESTIMATE & CLOSURE ASSURANCE

Attachment E The cover states that no closure/post-closure plan are required. This is contradictory to the answer provided in I9b1, p. 86, and the Executive Summary. Please provide a the closure plans.

Attachment G The insurance certificate is not provided. Do you have a copy?

Attachment H The cover pages list an Attachment H-16; however, the last attachment is H-15. It appears that the Attachment H-16 cover is missing (the content is there). I will find it and put it where it belongs.

Attachment H-1 Attachment H-1 is missing; please provide. Sending a PDF version through email may be the best way so you don’t have to FedEx.

Attachment H-15 In the future, only include permit cover sheets and reference or relevant parts of the permit. This attachment is very long.

Attachment H-8 In the future, there is no need to include 30+ page NPDES permits in their entirety. We typically need only the cover letter and discharge requirements.

Attachment H-9 In the future, include only one plan per attachment.

All H-Attachments Provide a brief plain English summary for each attachment. In addition, for attachments with more than one document, provide an English list of all documents included in the attachment. Examples:

• Attachment H-3, which is the process sketch, should be fully translated.

• Attachment H-5, permits, should include a list of the permits included, and there should be a plain English description of key permit information.

CHWMEG, Inc. 2012 Facility Review Program Status Report

Facility Name Bundle Contractor Award DateAssignedReviewer Site Visit Date

H021.12 Clean Harbors Deer Park(fka/aka: Rollins; Safety-Kleen) - Deer Park, TX USA 19 AACME 1/11/2012 Bo Snerdley 1/18/12

H031.10 Veolia ES Technical Solutions(fka/aka: Onyx Environmental Services; CWM; USA Waste) - Port Arthur, TX USA

19 AACME 1/11/2012 Bo Snerdley 1/20/12

H046.8 Safety-Kleen Corporation - Denton, TX USA 20 AACME 1/11/2012 Bo Snerdley 1/22/12

H109.7 Clean Harbors(fka/aka: Safety-Kleen; Laidlaw) - La Porte, TX USA 19 AACME 1/11/2012 Bo Snerdley 1/25/12

H161.3 Newpark Environmental Services(fka/aka: Big Hill Site) - Winnie, TX USA 19 AACME 1/11/2012 Bo Snerdley 1/27/12

H183.3 Newpark Environmental Services(fka/aka: Fannett Facility) - Hamshire, TX USA 19 AACME 1/11/2012 Bo Snerdley 1/29/12

H196.1 WMI Baytown LF(fka/aka: Waste Management, Inc.) -Baytown, TX USA 19 AACME 1/11/2012 Bo Snerdley 2/8/12

H211.1 Republic CSC Landfill - Avalon, TX USA 20 AACME 1/11/2012 Bo Snerdley Canceled

H212.5 Texas Molecular(fka/aka: Disposal Systems; GNI Group) - Deer Park, TX USA 19 AACME 1/11/2012 Bo Snerdley 2/10/12

Please enter two items for each awarded facility:1. Your firm's assigned Lead Facility Reviewer2. Site visit dates for each and entered as: #/#/2012 for completed site visits, Pending for no contact/coordination made as of yet, and P #/#/2012 ("P" followed by -2- spaces and the date as #/#/2012) for site visits scheduled but not yet conducted

CHWMEG 2012 FRP Progress Rpt Page 1 of 1

this is bundle: 27 (includes 5 facilities) $10,200 (check amount paid through most recent monthly progress report)bundle name: Land O' Lincolncontractor is: AACME Progress (Month: Payment Made)

your reference code is: 2012-abcd $0 January: 2/1/2012 current/revised award amount for this bundle: $10,200 $0 February: 3/1/2012

count of drafts conveyed to date: 5 $1,020 March: 3/30/2012count of draft-finals conveyed to date: 5 $510 April: 4/30/2012count of final-finals conveyed to date: 5 $0 May: 5/29/2012

bundle progress is: 100.0% $1,530 June: 6/30/2012progress value per award amount: $10,200 $1,530 July: 7/27/2012

less amount paid previously: $10,200 $510 August: 8/26/2012amount to be paid for this progress payment: $1,530 $2,040 September: 9/28/2012

$1,530 October: 10/29/2012amount remaining for this bundle: $0 complete $1,530 November: 11/30/2012

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Report Number Facility Name City State CONT Bundle Site Visit

PDF to Facility

Draft Final Rec'd

RAS Rec'd

Attach Rec'd

Date to QAQC

QAQC Rev'r

Comments Out

Final Rec'd

Date Dist

H010.8 AAJAX Lincoln IL AACME 27 2/19/12 2/23/12 3/24/12 3/24/12 3/26/12 3/30/12 BEB 4/9/12 4/10/12 4/30/12H020.4 Spectacular Waste Cabintown IL AACME 27 2/17/12 2/25/12 3/24/12 3/24/12 3/26/12 4/2/12 BEB 4/14/12 4/15/12 4/30/12H030.8 Treating Everything Pekin IL AACME 27 2/16/12 3/2/12 4/20/12 4/20/12 4/22/12 4/28/12 BEB 5/7/12 5/8/12 5/27/12H110.2 More Waste Than U Peoria IL AACME 27 2/18/12 2/24/12 3/24/12 3/24/12 3/26/12 4/13/12 BEB 4/21/12 4/21/12 4/30/12H422.0 Volum3 Petokin IL AACME 27 9/10/12 9/17/12 10/1/12 10/1/12 10/6/12 10/12/12 BEB 10/20/12 10/20/12 10/29/12

2012 FRP Tracking Spreadsheet 12/19/2012

Expectations for All CHWMEG Reviews Note Especially for Non-English-Speaking Facilities Elements Comprising the Facility Review Team The following pertains to all CHWMEG reviews. For reviews conducted in locations that do not speak English, the elements of your facility review team on the ground conducting the site visit are especially important. Your team conducting all facility reviews must be comprised of two elements:

Element A. at least one individual well-versed and directly-experienced in conducting CHWMEG reviews

Element B. at least one individual well-versed and knowledgeable regarding local language, customs, and EHS/etc. requirements (including operating parameters)

The CHWMEG contractor may need to engage additional individual(s) to address Element B, such as an employee from a subsidiary, affiliate, or sister office to their firm. Alternatively, the CHWMEG contractor may need to engage a local subcontractor to address Element B. The arrangement will pertain exclusively to the CHWMEG contractor, and CHWMEG’s cost in US$ and interface will be limited to the CHWMEG contractor only. Further, currency fluctuations will be a matter for the CHWMEG contractor only --- no deviations from the award amount will impact CHWMEG as relates to their internal arrangements with their in-country/local subcontractor. Note: The CHWMEG contractor’s Element B support must take into consideration CHWMEG’s “possible conflicts of interest” points. A subcontractor or employee engaged by the CHWMEG contractor from a sister/affiliate of the firm may not be engaged in separate work for the facility, its parent company, and/or the government/regulatory agency. Local Language For reviews of facilities located outside of the USA the assumption is that workable English will be spoken by your facility contacts. We will attempt to clarify if technical expertise at the facility allows the effort to be completed in English, or otherwise in a different local language. We will notify the contractor at the bid request stage what the language expectation is (e.g. English, or specific local language). Note that translations of the CHWMEG questionnaire (specific to program years, and not necessary reflecting in its entirety the current version of the questionnaire) are available in a number of languages to assist in the gathering of information (e.g. Spanish, French, Mandarin and Simplified Chinese, Thai, and Vietnamese). Please advise if you encounter a situation where one of these translated questionnaires will be useful in gathering the comprehensive information. While these translations may have been completed to reflect previous versions of the questionnaire and may not include all subsequently-added questions or restructuring/rewording of questions, the translated questionnaires should be greatly useful to your efforts.

Deliverables Draft Report to Facility: The CHWMEG contractor will convey the draft report to the facility for their review and written comment, as is routinely done. The exception for these reviews is that the draft conveyed should also include a local language version of the Executive Summary (at minimum: convey the local language version of the questionnaire if that was used to gather information and it was augmented by the CHWMEG contractor/subcontractor for any substantive content). It is possible that the facility’s review and comments will be limited to the local language version of the Executive Summary only. If the questionnaire was completed in English only (not a local language version of the questionnaire), then the questionnaire and other materials will be included in the draft version in English, nonetheless. See CHWMEG’s most current “stages of completion” for the determination of the composition of the draft report to be conveyed to the facility for review and comment. Draft Final/Final Final to CHWMEG: Conveyance to CHWMEG will be delivered as follows:

a. Executive Summary in local language and English (as modified and translated from their review and comments of the draft local language Executive Summary, and as applicable, from their review and comments of the draft local language questionnaire). b. Questionnaire completed in English and as revised from facility comments received. If using a translation of the questionnaire to gather information, the facility’s comments in the local language questionnaire must be addressed and the resulting information translated and included in the current English questionnaire. If the facility’s comments were limited to the local language Executive Summary, the changes affecting the English language questionnaire content should also be made prior to finalizing the English language questionnaire (i.e. do not fail to change the questionnaire content to reflect the changes impacting the Executive Summary).

c. If a local language questionnaire was used to collect the facility information, submit the electronic local language questionnaire file to CHWMEG with the rest of the electronic files when submitting the draft-final report. This file will be retained by CHWMEG for reference only, so we will not require it to be modified during the final-final submission.

Foreign Language Attachments For reviews incorporating foreign language attachments, include only key pages/relevant excerpts of documents, and either:

a. Translate the contents in their entirety into English, providing the English translation immediately in front of the foreign language excerpt attachment, or

b. Provide an English summary of the content of the excerpt immediately following – emphasizing the highlighted details/information and provide the English summary immediately in front of the foreign language excerpt attachment.