On September 5, 2017, the U.S. Environmental Protection Agency awarded North Carolina Department of Environmental Quality (NCDEQ) for the third time in fiscal year 2017 with $1,018,260. This monetary award was given to NCDEQ to support their hazardous waste programs. Initially, the EPA awarded $1,352,976 to NCDEQ to support their hazardous waste-related environmental programs. I wanted to give you some perspective on two recent visits that my clients received from NCDEQ, and discuss how these visits can be a good thing and not something generators should be nervous about. If you would like to learn more about the specifics please click here.
I personally partner with organizations to manage their environmental responsibility and mitigate their liability. This year I have seen more NCDEQ visits, or interactions, at new generators of hazardous waste and generators that haven't had a visit from the regulatory agency yet.
Two companies I partner with (one is a new generator, the other is a SQG that's never had a visit) were approached by NCDEQ with fair warning in order to set up a visit. In both cases, NCDEQ treated the visit as a compliance review that would only be considered an official audit if all went well. The new generator had my team and I assist them in program set up. We wrote their plans and procedures, created signage for their main accumulation area, helped set up their MAA and conducted RCRA training for their staff. In the case of the SQG, we had started two weeks prior providing onsite support services with one of our environmental specialists. Through this presence we made sure we prepared the client for the audit prior to the regulators arrival. This included housekeeping activities, inspections review, paperwork and training documents review, as well as being present for the day of the audit. In both instances, I make it a priority to be present the day of the audit/compliance review.
NCDEQ seems committed to capitalizing on the recent monetary support provided to them. Here were my key takeaways from the two separate visits:
- At both client locations, there were two separate agents who conducted the review/audit. All four individuals were helpful and used similar processes to conduct the review/audit.
- As the article states, the auditors put forth a collaborative effort to assist my clients in achieving compliance. The three parties were able to have a dialogue in person and follow up via email for clarification.
- If there’s a process that draws a red flag from the regulator at your facility, ask for suggestions. At one of my client’s facilities there was an issue with their waste collecting tank according to 40 CFR 265.201 Subpart J. We asked for help, and in turn NCDEQ set up a meeting with a local facility's EH&S professional who could show us how they engineered their system at his site.
- Building relationships with your regulators is important. When the two auditors came to my client's facility which just became a new generator, they were impressed with their main accumulation area. In fact, they took pictures of the area to display in their RCRA training of what a MAA should look like. Now, you can’t tell me there wasn't some level of trust gained from the experience between the two parties.
If you are a generator, prior to the agency's visit it is important to ensure your trainings, paperwork, plans, procedures, and accumulation areas are compliant. Utilize your environmental service vendor's expertise if you want reassurance. If your environmental provider is a strong partner there should be no issue here. If you have any questions regarding this grant or need help preparing for your visit, please click the button below to contact us and talk to one of our hazardous waste experts.