Auditing Vendors to Promote Environmental Stewardship

www.chwmeg.org
33rd Annual CUHMMC – Chicago
Auditing Vendors to Promote Environmental
Stewardship and Avoid CERCLA Liability (2 of 2)
11 Aug 2015
Jeffrey A. Sacre, Executive Director - CHWMEG, Inc.
email: jeff_sacre@chwmeg.org
tel: +1 (412) 826-3056 cell: +1 (412) 596-7511
Sustainability
2005 World Summit on Social Development
Sustainability
“Fundamentally, sustainable development is a
notion of discipline. It means humanity must
ensure that meeting present needs does not
compromise the ability of future generations to
meet their needs.”
- Gro Harlem Brundtland
Presentation 2 of 2
One Case Study: A Risky Facility?
Factors
Vendor
Auditing
Vendor Auditing Approaches
Vendor Auditing Experience
Questions & Discussion
FEB 1994
AUG 1995
BELOW GROUND SUMPS
IBC WASH
BUILDING
DEC 2001
VIOLATION NOTICE:
1. Local POTW/sanitary authority
identifies unpermitted WW discharge
2. Local POTW/sanitary authority
requires permit and pre-treatment
requirements (…costly)
ANOTHER
VIOLATION NOTICE:
JUNE 2004
1. Agency identified
unpermitted, untreated
direct discharge
2. Requires permit and pre-treatment
requirements (…also costly)
DETECTED
DOWNSTREAM:
Cyanide
Lindane
Styrene
Xylene
Phenol
Acetone
DEC 2005
2 MILES DOWNSTREAM
DEC 2006
JAN 2007
JAN 2007
HOW MANY CONTAINERS?
5.87 miles high
JAMES CAMERON –
MARCH 2012
CLEANUP COMPLETE
JAN 2008
‐ 9,462 IBCs cleaned/disposed
‐ 1,282,179 gallons of non‐haz waste
‐ 84,970 gallons of haz waste
‐ 725 tons of non‐haz sludge
SOUTHERN
CONTAINER INC.
KMI CONTINENTAL
FIBRE DRUM INC.
SOUTHERN
CONTAINER LLC
SONOCO PLASTIC DRUM INC.
CARDINAL CONTAINER SERVICES INC.
SONOCO PRODUCTS
COMPANY
Who Audits Vendors?
• What is your motivation?
•
•
•
•
Risk management
Stewardship/commitment
Environmental/resource protection
Public relations
• What are your objectives?
• “Know” your vendors
• Efficiently manage risk
• ELIMINATE CERCLA liability (Mission:
IMPOSSIBLE)
Who Audits Vendors?
• Motivation can include:
•
•
•
•
Risk management
Stewardship/commitment
Environmental/resource protection
Public relations
• Ranges of objectives:
• “Know” your vendors
• Efficiently manage and actively avoid risk
• ELIMINATE CERCLA liability (Mission:
IMPOSSIBLE)
What are the
Factors of Importance
for Vendor Facilities?
FACILITY DESIGN &
OPERATIONS
FACILITY PROCESS
& SYSTEMS REVIEW
INVENTORY ….and
INVENTORY MANAGEMENT
X + Y - Z = ?
…and throughput rate
…and oldest onsite
…and processing plan
MANAGEMENT OF RESIDUALS
wastes/spent
materials (“stuff”)
other facilities
(and additional risks)
TRANS-SHIPMENT OF RECEIVED MATERIALS
wastes/spent
materials (“stuff”)
other facilities
(and additional risks)
REGULATORY STANDING
Facility/Property History
FINANCIAL STRENGTH
CLOSURE & POST-CLOSURE
INSURANCE
SECURITY
(physical & data)
MANAGEMENT/PERSONNEL
COMMUNITY RELATIONS
Considerations for Auditing Vendors
•
Frequency of “audits” & extenuating
circumstances
•
What info to collect
•
Experience of reviewer (shiny object
distraction potential…looking up & not
down, etc.)
•
Transparency of information
(especially concerning downstream
facilities)
Strategies for Auditing Vendors
1. On your own
2. Hire a consultant (using your
protocol or their protocol?)
3. Collaborative approaches (e.g.
CHWMEG)
4. “Follow the Leaders”: EPA BRS
data
http://www.epa.gov/enviro/facts/br/search.html
or simply via www.chwmeg.org/11
“Follow-the-Leaders”
1. Isolate the target facility
2. Click their handler ID
3. View the generators that reported via their
Biennial Reporting System (BRS) the
streams generated and sent to the target
facility
e.g. 2015 gen data reported by 1 Mar 2016, accessible ~10
months afterwards
4. “Leverage” the resources and experience
of other ‘exemplary’ programs to be
aware/informed of others using the facility
(and not)
CHWMEG Membership (9 Aug 2015)
www.chwmeg.org
through 2015: 1,443 unique facilities reviewed (nearly 3,675 total reviews conducted)
CHWMEG’s Shared-Cost Reviews
nearly 3,675 Waste/Recycling facility reviews…
…at 1,443 unique facilities
143
1,156
97
5
22
20
10,754
www.chwmeg.org
Over 10,000 facilities included in database (over 1,440 facilities reviewed, through 2015)
Blue pins = reviewed facilities
Gray pins = unreviewed facilities
Thank You!
CHWMEG, Inc: Globally Promoting Responsible Waste Stewardship