All waste entering the facility must undergo an approval process as specified in the permit. When a client is seeking approval of a new waste stream the starting point is completion of the Waste Product Questionnaire (WPQ), supported with analytical reports (less than one (1) year old, by SW846 approved methods) to confirm proper characterization and compliance with Land Disposal Restrictions (LDR). Once received at ESOI, the WPQ is reviewed for completeness and acceptability.
Once ESOI determines acceptability of the waste represented on the WPQ, the terms and conditions for acceptance are transferred to a contract that both the Client and ESOI must sign prior to release of the final authorization. Final approval is indicated with the release of the Waste Stream Identification Number, or WSID. The WSID is a unique number assigned to each waste stream and associated with all waste tracking activities. Documentation of all waste approval activities, Waste Product Questionnaires, analytical, etc. is retained in the facility operating record in compliance with applicable regulatory requirements.
Pre-acceptance samples are typically not required unless ESOI will be performing treatment on the waste; the waste is subject to LDR standards and the laboratory that performed the analysis is not an ESOI Customer Selected Laboratory, and/or waste compatibility is in question. If a pre-acceptance sample is required the sample must be accompanied by a chain of custody.
Material that is subject to Land Disposal Restrictions must obtain an additional ESOI internal "Corporate Approval". This additional review ensures that all LDR requirements will be met.
By permit, ESOI is required to request updated confirmatory analysis, and proper characterization certifications, on an annual basis for ongoing waste streams. Ninety day before a waste approval expires, ESOI notifies you of the updated confirmatory analysis requirement and of the necessary information to meet the requirement, i.e., analytical parameters, forms, etc.
Waste Acceptance Process
All waste shipments received by Envirosafe must be scheduled in advance. Each waste shipment must undergo a stringent acceptance process to ensure that the waste shipped meets the requirements of the waste approval. Therefore, once a shipment arrives at the facility the shipping papers, i.e., manifest (RCRA or uniform nonhazardous), LDR (if applicable), analysis (if required), etc. are reviewed for completeness and the truck is scaled for gross weight. While at the scale platform, the waste is visually inspected to ensure a match with the physical description found in the composition section of the Waste Product Questionnaire and composite sampling is performed. One hundred percent (100%) of all bulk waste shipments are visually inspected and sampled. With containerized waste shipments, one hundred percent (100%) of the containers are visually inspected; ten percent (10%) are sampled.
The composite sample is taken to the on-site QC lab where it is analyzed as specified in the Waste Analysis Plan. ESOIís on-site QC lab houses two ICP units, microwave digester, extractors, X-ray (used for metal screening), pH meters, radiation detectors, flashpoint testers, TLV Sniffer, and etc. Typical verification analysis for incoming waste includes, check for radioactivity, flashpoint screening, pH (10% solution in deionized water), metal screening, heat and gas generation, etc. LDR verification analysis is also performed by the on-site QC lab on waste that has undergone ESOIís stabilization and microencapsulation processes. The frequency in which this testing is performed is specified in the Waste Analysis Plan.
While the on-site QC lab performs the verification analysis on the incoming waste, the shipment is directed to the appropriate processing area where it waits in line for final acceptance approval. Once the Laboratory has approved the material for receipt, other compliance requirements specified in the permit for annual or periodic waste analysis are checked. After all terms and conditions are verified, the final approval is transmitted to the Scale Master who signals field operations to proceed with off loading procedures. The visual inspection continues during off loading to verify uniformity and to ensure compliance requirements are met. Once the waste is off-loaded, the empty truck is then scaled for a tare weight and sent off-site. The received weight is compared with the manifested weight to verify that the correct amount of waste was delivered.
Waste requiring treatment prior to disposal is directed to the stabilization and containment building, where it is off-loaded and processed before landfilling. Waste for direct disposal is off-loaded directly into the disposal cell. Once the waste is off-loaded into the disposal cell, it is then pushed to a known X,Y,Z coordinate in the cell. The coordinate is recorded with the shipmentís manifest information in an electronic database.
Nonconforming loads are evaluated through the application of Standard Operating Procedures to bring the waste within specifications, i.e., free liquid elimination, dust suppression, void space filling for containerized waste, and etc., initiate off specification procedures, or return of the waste shipment to the generator.
Documentation of all disposal activities, manifest, LDR, analysis, and etc. is retained in the facility operating record in compliance with applicable regulatory requirements.