Hazardous Waste & Environmental Response Conference – November 25th & 26th

The Hazardous Waste & Environmental Response Conference is scheduled for November 25th & 26th at the Mississauga Convention Centre in Mississauga, Ontario.  The event is co-hosted by the Ontario Waste Management Association and Hazmat Management Magazine.

This 2-day conference provides an essential and timely forum to discuss the management of hazardous waste and special materials, soils and site remediation, hazmat transportation, spill response and cutting-edge technologies and practices. Valuable information will be provided by leading industry, legal, financial and government speakers to individuals and organizations that are engaged in the wide range of services and activities involving hazardous and special materials.

Attendees can expect an informative and inspiring learning and networking experience throughout this unique 2-day event. Session themes provide an essential and timely forum to discuss the management of hazardous waste and special materials, soils and site remediation, hazmat transportation, spill response and cutting-edge technologies and practices.

As the only event of its kind in Canada, delegates will receive valuable information from leading industry, legal, financial and government speakers who are actively engaged in a wide range of services and activities involving hazardous waste and special materials.

Company owners, business managers, plant managers, environmental professionals, consultants, lawyers, government officials and municipalities – all will benefit from the opportunity to learn, share experiences and network with peers.

CONFERENCE SCHEDULE

MONDAY, NOVEMBER 25 – GENERAL SESSIONS

8:00 am – Registration

8:45 am – Opening and Welcome Address

9:00 am – 9:40 am

OPENING KEYNOTE – Lessons Learned from Hazmat Incidents

Jean Claude Morin, Directeur General, GFL Environmental Inc.

Dave Hill, National Director Emergency Response, GFL Environmental Inc.

Jean Claude and Dave will discuss lessons learned from hazmat incidents in Canada, including, train derailments, truck turn-overs, and hazardous materials storage depot explosions. This presentation will also provide an overview of some of the more serious incidents in Canada and discuss the valuable lessons learned regarding best practices in hazmat response.

9:40 am – 10:10 am

Legal Reporting Requirements

Paul Manning, LL.B., LL.M, Certified Specialist in Environmental Law and Principal, Manning Environmental Law

Paul will provide an overview of the Canadian federal and Ontario legislation as it relates to the reporting requirements in the event of a hazmat incident and/or spill. Included in the discussion will be an examination of the case law related to hazmat incidents and failure to report.

10:10 am – 10:45 am – Refreshment Break             

10:45 am – 11:15 am

Hazmat and Spill Response Actions and the Utilization of Countermeasures

Kyle Gravelle, National Technical Advisor, QM Environmental

Kyle will be speaking on hazmat and spill response actions and countermeasures to prevent contamination. Included in the presentation will be real-world examples of incidents in Canada and advice on preparations and hazmat management.

11:15 am – 12:00 pm

PANEL DISCUSSION: Utilization of New Technologies for HazMat Emergency Response

Moderator:  Rob Cook, CEO, OWMA

James Castle, CEO & Founder, Terranova Aerospace

Bob Goodfellow, Manager, Strategic Accounts & Emergency Response, Drain-All Ltd.

Ross Barrett, Business Development/Project Manager, Tomlinson Environmental Services Ltd.

The hazmat and environmental response sector is quickly evolving. During this discussion, panelists will share their experiences on new technologies and methodologies for the management of hazmat and environmental incidents and provide advice on what companies should do to be better prepared for hazmat incidents.

12:00 pm – 1:30 pm – Luncheon Speaker

From Hacking to Hurricanes and Beyond – The New Era of Crisis Communications

Suzanne bernier, CEM, CBCP, MBCI, CMCP, President, SB Crisis Consulting, Founder & Author of Disaster Heroes

During any crisis, communicating effectively to all key stakeholders is key. This session, delivered by a former journalist and now award-winning global crisis communications consultant, will look at the evolution of crisis management and crisis communications over the past 15 years. Specific case studies and lessons learned from events like the recent terror and mass attacks across North America, as well the 2017 hurricane season will be shared, including Texas, Florida and Puerto Rico communications challenges and successes. The session will also review traditional tips and tools required to ensure your organization can communicate effectively during any crisis, while avoiding any reputational damage or additional fall-out that could arise.

1:35 pm – 2:15 pm

Fire Risk in Hazmat and Hazardous Waste Facilities – The Impact and Organizational Costs 

Ryan Fogelman, Vice President of Strategic Partnerships, Fire Rover

Fire safety is an important responsibility for everyone in the hazardous materials & waste sector. The consequences of poor fire safety practices and not understanding the risk are especially serious in properties where processes or quantities of stored hazmat and waste materials would pose a serious ignition hazard.

In an effort to prevent fires and minimize the damage from fires when they occur, owners, managers and operators of hazmat and related facilities will learn about fire safety and how to develop plans to reduce the risk of fire hazards.

Learn about:

  • Data and statistics on waste facility fire incidents
  • Materials and processes that create a fire risk
  • Planning and procedures to reduce fire risk
  • Tools and practices to detect, supress and mitigate fire damage.

2:15 pm – 2:45 pm

Implementation of Land Disposal Restrictions (LDR) in Ontario – Treatment Requirements & Associated Costs

Erica Carabott, Senior Environmental Compliance Manager, Clean Harbours Inc.

The field of hazardous waste management in Ontario is complex and places an onus on all parties involved, including, generators, carriers, transfer and disposal facility operators. Initiatives such as pre-notification, mixing restrictions, land disposal restrictions, recycling restrictions and the requirements of the Hazardous Waste Information Network (HWIN) all add to the cumbersome task. The Landfill Disposal Restrictions (LDR) place responsibilities on generators and service providers alike. This presentation aims to navigate the implementation of LDR in Ontario, with specific emphasis on the Clean Harbors Sarnia facility to accommodate LDR treatment and the significant costs associated with it.

2:45 pm – 3:15 pm – Refreshment Break

3:15 pm – 4:00 pm

New Requirements on the Shipment of Hazardous Goods – Provincial, Federal and International   

Eva Clipsham, A/Safety Policy Advisor for Transport Canada

Steven Carrasco, Director, Program Management Branch, Ontario Ministry of the Environment, Conservation and Parks (MOECP)

Current federal and provincial frameworks for regulating the movement of hazardous waste and materials are currently undergoing change. Manifesting systems are being upgraded and refocused as electronic systems that will provide efficiencies to both generators and transporters. Learn about the current federal and provincial systems and the changes that are anticipated to be implemented in the near future.

4:00 pm – 5:00 pm – All attendees are invited to attend the Tradeshow Reception!

TUESDAY, NOVEMBER 26

8:30 am – Registration

8:45 am – Opening & Welcome Address

9:00 am – 9:45 am

Management of contaminated sites & increasing complexity and cost

Carl Spensieri, M.Sc., P.Eng., Vice President Environment, Berkley Canada (a Berkley Company)

This presentation will explore the various elements contributing to the increasing complexity and cost of managing contaminated sites. Carl will examine emerging risks and speak to potential strategies we can use to mitigate them. This presentation will also highlight opportunities for conference participants to offer new services that help owners of contaminated sites best respond to existing and emerging challenges.

9:45 am – 10:10 am – Refreshment Break

TRACK 1: HAZARDOUS WASTE GENERATION, TRANSPORTATION, TREATMENT AND DISPOSAL

10:15 am – 10:55 am

A National Perspective on the Hazardous Waste

Michael Parker, Vice President, Environmental Compliance, Clean Harbours Inc.

Hear about the challenges and opportunities facing the hazardous waste, hazmat and emergency response sector from an industry leader with a national view. The industry is evolving and the business fundamentals are ever changing. Government administrative and technical burdens are increasing and the volume of hazardous waste is declining – what will the future hold?

11:00 am – 11:40 am

PANEL DISCUSSION: Hazardous Waste & Special Materials – Transportation & Transit Challenges

Jim Halloran, Regional Manager, Heritage – Crystal Clean Inc.

Doug DeCoppel, EH&S Manager, International Permitting and Regulatory Affairs, GFL Environmental Inc.

Frank Wagner, Vice President Compliance, Safety-Kleen Canada Inc.

This panel will discuss key transportation issues and compliance challenges faced by hazardous waste generators and service providers, including significant changes to the documentation, labelling, packaging, emergency planning, and reporting requirements for hazardous waste and special materials shipments resulting from updated regulations and proposed initiatives. The panel will also review key considerations when selecting service providers to manage hazardous waste and special materials.

Topics included in this discussion: E-manifests (provincial and federal – lack of e-data transfer capabilities), HWIN fees (300% increase in fees but no increase in service), Transboundary Permits (lack of e-data transfer capabilities), container integrity and generator awareness.

11:45 am – 12:25 pm

Factors Influencing Treatment and Disposal Options for Hazardous Waste in Ontario

Ed Vago, Director of Operations, Covanta Environmental Solutions

Dan Boehm, Director of Business Development, Veolia ES Canada Industrial Services Inc.

Learn about the many recycling, treatment and disposal options for hazardous waste and hazardous materials in Ontario. Hear about the regulatory and operational factors to consider when deciding on the best management approach.

TRACK 2: SITE REMEDIATION

10:15 am – 10:55 am

Soils – Dig and Dump vs. On-Site Remediation: Factors to Consider & Case Studies

Devin Rosnak, Senior Client Manager & Technical Sales Manager, Ground Force Environmental

D. Grant Walsom, Partner, XCG Consulting Limited, Environmental Engineers & Scientists

Mark Tigchelaar, P. Eng., President and Founder of GeoSolv Inc.

Developers of brownfield site are faced with decisions around how to manage excavated soils. Impacted soils and soils with hazardous characteristics as tested at the site of generation can be managed through on-site remediation, or can be removed from the site to a variety of remediation and/or disposal options. Learn about the key options and factors that contribute to determining the optimum approach to managing soils.

11:00 am – 11:40 am

The Legal Framework for the Management of Contaminated Sites and Materials      

John Tidball, Partner, Specialist in Environmental Law, Miller Thomson LLP

The management of contaminated sites and related materials, including soils, are constrained by both regulatory and legal framework. Hear from a legal expert with unparalleled experience about the regulatory and legal issues that all developers/excavators transporters and service providers should be aware of as the legal liabilities in this area can be significant.

11:45 am – 12:25 pm

Anaerobic Bioremediation & Bioaugmentation – from the Lab to the Field

Dr. Elizabeth Edwards (Professor), Dr.Luz Puentes Jacome, Dr. Olivia Molenda, Dr. Courtney Toth, Dr. Ivy Yang (all Post doctoral fellows in the lab), Chemical Engineering & Applied Chemistry, University of Toronto

Together with her Post-Doctoral team, Dr. Edwards will present an overview of anaerobic bioremediation and bioaugmentation with some examples from their research and its application to the field.

12:30 pm – 2:00 pm

CLOSING KEYNOTE & LUNCHEON SPEAKER

Andrea Khanjin, MPP Barrie-Innisfil, Parliamentary Assistant, Ministry of the Environment, Conservation and Parks (MOECP)


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Using Biosolids to Revegetate Inactive Mine Tailings

Vale Canada (a global mining company with an integrated mine, mill, smelter, and refinery complex in operations Sudbury, Ontario) has been working with Terrapure Environmental (an industrial waste management company) to utilize biosolids on its main tailings area.

For over 100 years, tailings from the milling operation have been deposited in the Copper Cliff Central Tailings impoundment. The facility is still active, but approximately 1,300 hectares are inactive and need reclamation work.

The Big Nickel in Sudbury (Photo Credit: pizzodisevo)

Over the decades, Vale has had some success in revegetation of its tailings area, but there are still large areas of bare or sparsely vegetated tailings, which have led to wind-erosion-management challenges. To control dust, Vale uses agricultural equipment to cover the tailings with straw or hay, as well as a chemical dust suppressant. These practices are costly, and they have to be done continuously to maintain an appropriate cover at all times. In 2012, Vale decided its tailings needed a permanent vegetative cover—not just to suppress dust and reduce erosion, but to improve overall biodiversity. They entered into discussions with Terrapure Organics Solutions (formerly Terratec Environmental) to collaborate on a trial project to apply biosolids on the mine tailings.

In 2012, Vale decided its tailings needed a permanent vegetative cover—not just to suppress dust and reduce erosion, but to improve overall biodiversity. They entered into discussions with Terrapure Organics Solutions (formerly Terratec Environmental) to collaborate on a trial project to apply biosolids on the mine tailings.

The Challenge

The biggest challenge was forging a new path for this type of work. Applying biosolids to mine tailings had never been done before in Ontario. Just to get the right permits and approvals took about two years. Vale Canada and Terrapure worked closely with the Ontario Environment Ministry to ensure standards compliance. Some of this work included helping to determine what those standards should be. Terrapure was able to contribute to these discussions, leveraging decades of expertise in safe biosolids application to agricultural land. Once the Environmental Compliance Approval came in April 2014, the team had to figure out the best application method and proper amount to encourage vegetation, which meant a lot of testing and optimizing.

The Solution

At first, Terrapure mixed biosolids into the surface layer of the tailings. Over time, however, the team learned that applying biosolids to the surface, without mixing, allowed for greater rates of application and coverage at a lower cost.

Terrapure also had to experiment with the right tonnage per hectare. After seeding four trial plots with different amounts of biosolids coverage—20, 40, 60 and 80 dry tonnes/hectare—it was determined that 80 dry tonnes was best for seed germination. At the time, it was the maximum allowable application rate. By the end of 2014, approximately 25 hectares of tailings were amended. Where the biosolids were applied, there were impressive results. Wildlife that had not been seen feeding in the area in years started to return. In 2015, the Ontario Environment Ministry approved an increase in the biosolids application rate to a maximum of 150 dry tonnes/hectare, which was necessary for providing higher organic matter and nutrient levels, and for stabilizing the tailings’ pH levels. This approval also increased the cap on the amount of biosolids that could be delivered to the maximum application rate per hectare. To enhance the program even more, Terrapure and Vale partnered with the City of Greater Sudbury to blend leaf and yard waste with biosolids. By blending these materials, the mixture becomes virtually odourless, its nutrients are more balanced and it allows for a more diverse application.

Glen Watson, Vale’s superintendent of environment, decommissioning and reclamation, surrounded by lush vegetation covering part of the company’s Central Tailings Facility in Sudbury

The Results

As of 2018, Terrapure has successfully covered over 150 hectares of Vale’s tailings with municipal biosolids. Vegetative growth and wildlife are well established on all areas where the team applied organics. Just as importantly, this project has diverted more than 25,000 dry tonnes of valuable biosolids from becoming waste in the landfill. Following the success of the initial trial, the Environment Ministry widened the approval to include all areas of the inactive tailings and a portion of the active tailings. At the current application rate of 150 dry tonnes/hectare, Vale’s central tailings facility could potentially require another 195,000 dry tonnes of biosolids. That’s more than 30 years of biosolids utilization, at an annual rate of 6,000 dry tonnes of material. Needless to say, Vale is very pleased with the results, and the relationship is ongoing. In fact, the Vale team is evaluating other sites in the Sudbury area for this type of remediation, ensuring a long-term, environmentally sustainable rehabilitation program.

Cost of Nuclear Waste Clean-up in the U.S. estimated at $377 Billion

A new report by the United States General Accounting Office (GAO) estimates the total cleanup cost for the radioactive contamination incurred by developing and producing nuclear weapons in the United States at a staggering $377 billion (USD), a number that jumped by more than $100 billion in just one year.

The United States Department of Energy (DoE) Office of Environmental Management (EM) is responsible for cleaning up radioactive and hazardous waste left over from nuclear weapons production and energy research at DoE facilities. The $377 billion estimate largely reflects estimates of future costs to clean up legacy radioactive tank waste and contaminated facilities and soil. 

The U.S. GAO found that EM’s liability will likely continue to grow, in part because the costs of some future work are not yet included in the estimated liability. For example, EM’s liability does not include more than $2.3 billion in costs associated with 45 contaminated facilities that will likely be transferred to EM from other DOE programs in the future.

In 1967 at the height of the U.S.–Soviet nuclear arms race, the U.S. nuclear stockpile totaled 31,255 weapons of all types. Today, that number stands at just 6,550. Although the U.S. has deactivated and destroyed 25,000 nuclear weapons, their legacy is still very much alive.

Nuclear weapons were developed and produced at more than one hundred sites during the Cold War. Cleanup began in 1989, and EM has completed cleanup at 91 of 107 nuclear sites, Still, according to the GAO, “but 16 remain, some of which are the most challenging to address.” 

EM relies primarily on individual sites to locally negotiate cleanup activities and establish priorities. GAO’s analysis of DOE documents identified instances of decisions involving billions of dollars where such an approach did not always balance overall risks and costs. For example, two EM sites had plans to treat similar radioactive tank waste differently, and the costs at one site—Hanford—may be tens of billions more than those at the other site. 

Each of the 16 cleanup sites sets its own priorities, which makes it hard to ensure that the greatest health and environmental risks are addressed first.
This is not consistent with recommendations by GAO and others over the last two decades that EM develop national priorities to balance risks and costs across and within its sites. 

By far the most expensive site to clean up is the Hanford site, which manufactured nuclear material for use in nuclear weapons during the Cold War. In 2017, the DoE estimated site cleanup costs at $141 billion.

Environmental liabilities are high risk because they have been growing for the past 20 years and will likely keep increasing.

EM has not developed a program-wide strategy that determines priority sites. Instead, it continues to prioritize and fund cleanup activities by individual site. Without a strategy that sets national priorities, EM lacks assurance that it is making the most cost-effective cleanup decisions across its sites.

The GAO is made three recommendations to DOE: (1) develop a program-wide strategy that outlines how it will balance risks and costs across sites; (2) submit its mandated annual cleanup report that meets all requirements; and (3) disclose the funding needed to meet all scheduled milestones called for in compliance agreements, either in required annual reports or other supplemental budget materials.

Canadian Federal Government Proposing New Regulations on Cross-border movement of Hazardous Waste

Environment Canada and Climate Change (ECCC), which is the Canadian equivalent of the U.S. Environmental Protection Agency, recently released draft regulations to control the cross-border movement of hazardous waste and hazardous recyclable material. The regulations, if eventually promulgated, would repeal and replace the Export and Import Regulations, the Interprovincial Movement Regulations, and the PCB Waste Export Regulations. Although the proposed Regulations would maintain the core permitting and movement tracking requirements of the former regulations, the regulatory provisions would be amended to ensure greater clarity and consistency of the regulatory requirements.

Electronic Tracking System

The proposed Regulations would provide flexibility for the electronic movement tracking system by no longer prescribing the specific form required for tracking shipments of hazardous waste and hazardous recyclable material. Instead, the proposed Regulations would require specific information to be included in a movement document (that can be generated electronically) and would allow movement document information to be passed on to different parties in parallel to facilitate the tracking rather than prescribing the handover of copies from one party to another.

Furthermore, given that movement documents would be able to be managed electronically, the proposed Regulations would no longer require that the movement document and permit physically accompany the shipment. The proposed Regulations would instead require parties to immediately produce the movement document and the permit upon request. Similar simplifications would be included in the provisions related to the movement document for interprovincial movements of hazardous waste and hazardous recyclable material.

The proposed Regulations would clarify the responsibility of a receiving (importing) facility to pass on information regarding the origin of the hazardous waste and hazardous recyclable material being transferred to a subsequent authorized facility for final disposal or recycling. As the safety of everyone is important and so is protecting the environment, it would make sense to find a contact for consultation if you need help with your company’s regulatory needs.
Clarifications would also be made to the provisions for the return and rerouting of shipments to better align those requirements with current practice and ensure that confirmation of disposal from the alternative facility is also required in order to properly complete the tracking of those shipments.

Definitions of hazardous waste and hazardous recyclable material

With respect to interprovincial movements, under the proposed regulations, the definitions of hazardous waste and hazardous recyclable material would be aligned with those of international movements. In addition, proposed changes to those definitions would ensure a more consistent application of regulatory provisions for all types of transboundary movements and would better align definitions with other jurisdictions and international agreements. Some of these proposed changes are listed below.

Toxicity characteristic leaching procedure

The proposed Regulations would reference the toxicity characteristic leaching procedure (TCLP), in its entirety. This procedure is a standard test method used to evaluate the mobility of a number of contaminants that may be found in waste and recyclable material and, therefore, their potential for release. While making reference to the TCLP, the Export and Import Regulations exclude a step requiring that the size of particles in a sample be reduced to fit into the testing apparatus. In order to ensure that the method is used consistently, hazardous waste and hazardous recyclable material undergoing testing would need to be shredded to meet the TCLP’s specific particle size requirement.

Electrical and electronic equipment

Electrical and electronic equipment (EEE) is not currently listed as hazardous under the Export and Import Regulations and must meet other criteria to fall under the definitions of hazardous waste or hazardous recyclable material, which can be difficult to ascertain. The proposed Regulations would clearly designate “circuit boards and display devices and any equipment that contains them” as hazardous waste or hazardous recyclable material to be controlled when destined for specific disposal or recycling operations. The proposed Regulations would maintain the exclusion currently under the Export and Import Regulations for this type of hazardous waste and hazardous recyclable material moving within OECD countries (including moving between provinces and territories in Canada).

Mercury

The proposed Regulations would remove the small quantity exclusion for hazardous waste and hazardous recyclable material containing mercury. Any waste or material containing any amount of mercury that meets the definitions of hazardous waste or hazardous recyclable material would be subject to the regulatory provisions for both international and interprovincial movements.

Batteries

Batteries are not currently listed as hazardous under the Export and Import Regulations and must meet other criteria to fall under the definitions of hazardous waste or hazardous recyclable material. Some types of batteries are clearly covered by the definitions; however, for some other types it is not clear. The proposed Regulations would clarify that all types of batteries (i.e. rechargeable and non-rechargeable) being shipped internationally or interprovincially for disposal or recycling are included in the definitions of hazardous waste and hazardous recyclable material.

Terrapure Battery Recycling Facility

Waste and recyclable material generated on ships

The proposed Regulations would add a new exclusion to clarify that waste or recyclable material generated from the normal operations of a ship is not captured by the definitions of hazardous waste and hazardous recyclable material. This exclusion would further harmonize the proposed Regulations with the Basel Convention (which excludes this waste) and the Canada Shipping Act, 2001 where this waste is already covered.

Residual quantities

The proposed Regulations would add a new exclusion for waste or recyclable material that is to be transported in a container after the contents of that container have been removed to the maximum extent feasible and before the container is either refilled or cleaned of its residual content. This exclusion would clarify that such waste or recyclable material is not captured by the definitions of hazardous waste and hazardous recyclable material.

Recycling operation R14

Over the years, ECCC has received numerous questions regarding recycling operation R14 found in Schedule 2 of the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations. Section 2 R14 reads as follows : “Recovery or regeneration of a substance or use or re-use of a recyclable material, other than by any of operations R1 to R10”. This recycling operation is not included in the Basel Convention or the OECD Decision. ECCC is proposing to delete this part of operation R14 to remove uncertainty about its application. This change may result in some recyclable material no longer being captured and defined as hazardous. For example, a used material that is to be used directly in another process that is not listed as a recycling operation would no longer be captured.
This change would further align regulatory provisions with international guidelines under the Basel Convention.

Exports, Imports and Transits of Hazardous Waste and Hazardous Recyclable Material 2003-2012

Proposed changes regarding waste containing PCBs

The regulatory provisions for the export of waste containing PCBs would be streamlined and integrated into those for hazardous waste and hazardous recyclable material. This would include removing the partial prohibition on exports of waste containing PCBs in a concentration equal to or greater than 50 mg/kg to allow controlled exports beyond the United States. Therefore, waste and recyclable material containing PCBs in a concentration equal to or greater than 50 mg/kg would be able to be exported provided a permit is obtained and all of the conditions of the proposed Regulations are met.

Proposed changes to improve the permitting process

The proposed Regulations would no longer require the name of the insurance company and the policy number for the exporter, the importer and carriers with the notification (i.e. permit application). In addition, copies of the contracts would no longer need to be provided with the notification. In both cases, the applicant would be required to provide a statement to the effect that valid insurance policies and contracts are in place and to keep proof of insurance coverage and copies of contracts at their place of business in Canada for five years.

The proposed Regulations would require a new notification for any changes in information, other than correcting clerical errors, on a permit.

The proposed Regulations would increase the maximum duration of a permit from 12 months to 3 years, consistent with international agreements, for the movement of hazardous recyclable material directed to pre-consented facilities within OECD countries.

The proposed Regulations would set out conditions under which a permit may be refused, suspended or revoked.

Impacts on Business – Costs and Operations

According to the consultation documents prepared by ECCC, the proposed Regulations, if promulgated, would affect 295 companies, 281 of which would be considered small businesses. For these small businesses, the proposed Regulations are expected to result in incremental compliance and administrative costs of $296,000 in average annualized costs, that is, $1,070 per small business.

If the proposed Regulations are implemented, it would result in an clarifications to the definitions of hazardous waste and would ensure a more consistent application of regulatory provisions. In addition, the proposed Regulations would help minimize environmental impacts outside Canada by ensuring that exported hazardous waste and hazardous recyclable material reach the intended disposal or recycling facilities. For any company that performs hazardous operations, the idea to try and find flexible safety doors is one that could benefit industries such as transportation and the medical field, as this helps increase safety in this process and acts as a security barrier between any hazards. The present value of compliance and administrative costs of the proposed Regulations would be $2.5 million in 2017 Canadian dollars, discounted at 3% to 2018 over a 10-year period between 2021 and 2030.

The proposed Regulations would impose incremental administrative costs on industry attributable to the completion of additional movement documents for interprovincial movements of hazardous waste and hazardous recyclable material. Provincial and territorial authorities that are using a tracking system would achieve small savings if they decided not to request movement document information. The present value of administrative costs of the proposed Regulations are expected to be $460,000 in 2017 Canadian dollars, discounted at 3% to 2018, over a 10-year period between 2021 and 2030.

Public Consultation

Public comments to the proposed Regulations are being accepted by ECCC until up to mid-February. Any person may file with the Minister of the Environment comments with respect to the proposed Regulations or a notice of objection requesting that a board of review be established under section 333 of the Canadian Environmental Protection Act, 1999 and stating the reasons for the objection. All comments and notices must cite the Canada Gazette, Part I, and the date of publication of this notice, and be sent by mail to Nathalie Perron, Director, Waste Reduction and Management Division, Environmental Protection Branch, Department of the Environment, 351 Saint-Joseph Blvd., Gatineau, Quebec K1A 0H3 (fax: 819-938-4553; email: [email protected]).

Insight into the Hazardous Waste Management Industry – A Profile of Clean Harbors Facilities

by David Nguyen – Staff Writer

Clean Harbors is a hazardous waste management company operating across North America. Their location in Mississauga is a hazardous waste terminal and transfer station, receiving, handling, and transporting flammable solids destined to the U.S. for incineration. Non-flammable solids and liquid hazardous waste is sent to their facility in Lambton, Ontario. The Lambton facility includes a hazardous waste landfill and a liquid hazardous waste incinerator, with some facilities using machines to help with their odour control while trying to improve the air quality.

Clean Harbors coordinates hazardous waste management solutions across the Canada-U.S. border with the help of something similar to this waste management software which could help keep things in order. It is makes business sense for the company to transport flammable solids that are hazardous to its U.S. incinerator instead of having a facility in Canada. “Liquid injection incinerators are a lot cheaper,” says Mike Parker, Vice President, Canadian Environmental Compliance. “There really isn’t a strong enough market to support [hazardous solid incineration] in Canada.”

Mississauga Site Activities

Carriers bring the hazardous waste to the transfer station, where the manifests and documentation are reviewed to ensure that the facility is permitted to receive the material. This is different to regular waste removal companies such as BestDealDumpsters.com who get rid of all types of household waste. Receiving times are typically planned ahead of time to prevent surges of shipments on site. Once off loaded, the waste is sampled to confirm the material profile noted in the manifest and then staged for further processing. The entire staging area is built over sealed drains leading to a blind sump to prevent any spills from leaving the site. “All the liquids from our sumps, even if it’s just rain water… get put into tanks and go down for incineration,” says Parker.

Every drum the facility receives has its contents verified, sampled, and tested. Samples are analyzed for PCBs, pH, ignitability/ flashpoint, sulfide, chloride, oxidation, cyanide, and water reactivity in order to get a profile for the waste, after which a code is attached to the drum to indicate its destination and disposal.

Staging Area (photo by David Nguyen)

This information is stored in their management system that tracks the inventory at their various facilities, including the shipping information and profiles of all items. The information is removed for approval to be received on site. The system also tracks the manifests for the generator, carrier, receiver, and the ministry, internal inspections, and monthly reports to be sent to the ministry.

After sorting and sampling, the waste is safely sorted into various streams for consolidation, bulking, or blending.

“It has to be in the same waste class to mix and match. We can’t mix something flammable with something non-flammable,” says Parker.

“Even if they are in the same waste class, we take samples from each drum, mix it together, and if nothing happens, we can do it” says Erica Carabott, Facility Compliance Manager.

Liquid waste is bulked in tank farms until there is enough to fill a taker truck to be sent to Lambton for incineration. Solid waste is loaded into pits where the material is shredded up, bulked, and mixed with a solidifying agent to take up any free liquids in the solid waste streams.

Lambton Facility Activities

Many of the materials received at the Mississauga Transfer station are transported to the Clean Harbors Lambton facility offers services including waste neutralization, incineration of hazardous waste, inorganic pre-treatment of hazardous waste, thermal desorption of solid and sludge, and landfill disposal of hazardous waste.

Liquid waste is blended in a controlled neutralization process at the acid and alkali plant before being fed to the incinerator. The liquid waste injection incinerator operates 24 hours a day, 7 days a week, consisting of a fix unit incinerator, a semi-dry spray dryer absorber, and a four-compartment baghouse. The site capacity is about 100 000 tonnes per year and can process pumpable material that does not contain PCBs, pathogens, radioactives, and cylinders.

Lambton Incinerator (Photo Credit: Clean Harbors)

The landfill is situated in natural clay, and accepts a variety of hazardous waste excluding explosives, PCBs, radioactive, pathological wastes, or compressed gasses. Due to the Land Disposal Restriction prohibiting the disposal of untreated hazardous waste on land, Clean Harbors has an inorganic solid pre-treatment processing plant which mixes inorganic waste (primarily metal bearing solids) with reagents to prevent the metals from becoming leachable.

Furthermore, a thermal desorption unit is used to condense and recover water and organics from organic solid waste. The waste is fed into a kiln that heats the waste to 400-450 degrees Celsius to strip the organics from the waste. The vapours are condensed to remove liquid organics during the process, with the remaining emissions vented to the incinerator. The residual solids are then tested for any remaining organics or metals, and then disposed of in the hazardous landfill on site.

“You can understand why it takes a lot of money to treat the stuff in the landfill. It cooks it for about a half hour – that’s a lot of heat and a lot of money” says Parker. “With testing at the front and testing at the end,” adds Carabott .

Clean Harbor’s Lambton Hazardous Waste Landfill (Courtesy: Clean Harbors)

These facilities and processes allow Clean Harbors to work with their clients to develop cost effective solutions to handling and disposing of hazardous waste materials throughout the Great Lakes Basin in both Canada and the United States. In addition, Clean Harbors conducts regular outreach programs with the local community regarding the safe operations and reporting conducted at the Lambton facility.

Special thanks to Mike Parker and Erica Carabott for taking the time to speak with me and show me around the Mississauga Transfer station.

Contaminated Site Clean-up Opportunities in China

As reported by the South China Morning Post, China’s government recently approved a new plan to tackle growing pollution threats in its countryside, and will strive to clean up contaminated rural land and drinking water and improve waste management.

The new plan, approved “in principle” by the Ministry of Ecology and Environment is the summer also mandates cuts in fertilizer and pesticide use and improved recycling rates throughout the countryside.

Industrial pollution of land in China. The authorities have been reluctant to divulge details of the localised scale of the problem (Image by JungleNews)

China is in the fifth year of a “war on pollution” designed to reverse the damage done by decades of tremendous economic growth, but it has so far focused primarily on air quality along the industrialized eastern coast, especially around the capital Beijing.

China’s countryside has struggled to cope with land and water pollution caused not only by unsustainable farming practices, but also by poorly regulated, privately-owned mines and manufacturing plants, as well as rising volumes of plastic waste.

Rehabilitating contaminated land has become a matter of urgency for the Chinese government, which is under pressure to maximize food production while at the same time it is setting aside one-quarter of the country’s land as off-limits to development by 2020.

Total arable land declined for a fourth consecutive year in 2017 as a result of new construction and tougher environmental requirements, the government said in May.

The State Council published a plan in February to deal with growing volumes of untreated rubbish dumped in the countryside, promising to mobilise public and private funds to make “noticeable improvements” to the living environment of rural regions by 2020.

It vowed to restore wetlands, plant trees and eliminate “disorderly” rural construction to improve the appearance of China’s villages, and would also focus on improving garbage and sewage treatment.

In August, the Chinese government enacted the Soil Pollution Prevention and Control Law.  This is the first time China has enacted a law targeting soil pollution.  For existing soil pollution, the law holds polluters and users (as it is rare in China for individuals to own land) accountable for a series of risk management and remediation obligations, with the polluters being primarily responsible.

According to an article by IISD, the estimated cost for remediation efforts between 2016 and 2020 at $1.3 trillion (USD). The government itself estimates it might be able to cover only a small fraction of the overall cost.  During China’s the 12th Five-year Plan (2011–2015), only $4.5 billion) was allocated to soil remediation, mainly for urban areas.

Combine polluter payments with government support and a prohibitive capital gap still exists in China’s efforts to restore land and protect public health. This gap will have to be filled by private sources.

Mesothelioma Awareness: Asbestos and Occupational Safety

by Sarah Wallace, Mesothelioma + Asbestos Awareness Center

For many years, the natural mineral known as asbestos was used in constructing buildings, insulation (check local prices), roofing, and homes. Asbestos is heavily regulated in the United States today, but many people are still exposed daily to asbestos containing materials (ACMs) that still exist in buildings, structures, and homes. During demolition, DIY, or renovation projects, asbestos can become friable and people are then susceptible to inhaling the small fibers. When asbestos becomes lodged in the body, specifically in the lining of the lungs, abdomen, or heart, it can lead to lung cancer or mesothelioma.

Even though the use of asbestos has decreased dramatically in the United States since the late 20th century, mesothelioma is still the leading occupational cancer. This is because the disease can take up to 50 years to develop, and those who were exposed to asbestos prior to the 1980s are still being diagnosed today. On top of that, professionals who work in different industries that have a history of asbestos use, such as construction, manufacturing, and shipyard work, are still at risk of exposure they may come into contact with materials and products made before regulations were put in place. Due to the microscopic size of asbestos fibers and ambiguity around where the toxin could have been used in the past, it’s important for workers to stay educated on where asbestos might be hiding and what safety precautions to take on the job.

Occupations most at risk and how to stay safe:

Construction Workers– Because asbestos was used heavily in the construction of homes and other buildings, many construction workers have been exposed to asbestos, and they are still at risk for exposure. With ACMs still existing in buildings, approximately 1 million construction workers could still be vulnerable to asbestos annually. Today, professionals in the construction industry are at risk for first-hand exposure more than any other profession. Workers in multiple trades including roofers, carpenters, electricians, and masonry should be aware of asbestos as they work. Making sure site security is tight with security cameras can improve your ability to reduce the number of people who will be exposed by the asbestos by ensuring unauthorized personnel is kept away from asbestos.

In order for workers to protect themselves, professionals in these fields should take the precaution of wearing the proper masks during any type of construction project. Understanding the age of the building and what asbestos looks like is also important because this could help workers know the risks associated with a certain structure, making them less vulnerable to exposure. Keep in mind that asbestos can exist in a variety of products including drywall, shingles, ceiling tiles, and insulation, so even those participating in DIY projects should be aware of where their health and safety could be at risk.

Firefighters– Asbestos fibers can be released into the air when a building or home catches on fire. This puts first responders like firefighters in danger of inhaling the toxin in the process of putting out a fire. This leaves firefighters at risk to develop peritoneal mesothelioma, which originates in the lining of the lungs after being inhaled. While the initial danger to firefighters is the fire itself, even after the flames are put out, asbestos could be present in the air as the structure cools off. Firefighter equipment is designed to keep out hazardous materials like asbestos, but many people do not understand that certain risks persist even after the initial fire is put out. Asbestos fibers can attach to clothing, leading to the possibility of second-hand exposure for those who might come in contact with any type of clothing used at the scene of the fire.

In order to limit exposure to asbestos particles, firefighters should wear a certified self-containing breathing apparatus (SCBA) mask that covers the mouth and nose in order to protect themselves while on the job. They should also keep masks on even after the fire has been put out while debris is cooling, because asbestos fibers could still be in the air. To eliminate risks of exposure for family, friends, and colleagues, firefighters should also remove their gear before leaving the scene and wash off before returning home.

Shipyard Workers– At one time, asbestos exposure was a large risk for laborers and those employed on ships. Due to the mineral’s strong and heat resistant attributes, was often used for things like boilers and steam pipes on Navy ships and shipyards. As a result, many shipyard laborers were exposed to asbestos, especially if they worked as electricians, painters, machinists, or “asbestos insulators.” This is one of the reasons veterans make up about 30 percent of mesothelioma diagnoses in the United States.

Shipyard workers are less likely to be exposed first-hand to asbestos today, but anyone working with older shipbuilding materials or piping should be aware of the possible risks and wear the appropriate masks to limit inhaling fibers. Workers who have been exposed in the past should let their primary care doctor know and stay up-to-date on appointments. Symptoms of mesothelioma specifically can often go undiagnosed because they are similar to symptoms of the flu, manifesting as a cough at first and eventually leading to shortness of breath and fever. If you know that you have been exposed, paying careful attention to your health and communicating with your doctor could lead to an early diagnosis, improving prognosis and life expectancy.

Preventing asbestos-related disease

If you come across asbestos on the job, contacting a professional who knows how to handle the material will be the best way to move forward. No amount of asbestos exposure is safe, and handling the mineral should be taken seriously before proceeding with a project. Mesothelioma is a deadly but preventable cancer, if the correct steps are taken by employers and employees. Although asbestos has been heavily regulated over time, there is still not a ban on the material in the United States. Taking the time to check labels before using any products and educating others in your industry on how to protect themselves are sure ways to help bring an end to mesothelioma and other health issues caused by asbestos.

If your health has been affected by your work surroundings or you’ve sustained an injury on the job, you may need to undergo a functional capacity evaluation to prove that you are not in a fit state to continue work. For more information on this, click here.

New U.S. EPA e-Manifesting System Took Effect June 30th

By Laura Ragozzino, Cohen & Grigsby P.C.

The U.S. Environmental Protection Agency (the “EPA”) launched its new Hazardous Waste Electronic Manifest (“e-Manifest”) System on June 30, 2018. The new requirements impact all U.S. companies that handle waste requiring a Resource Conservation and Recovery Act (“RCRA”) manifest, a regulated universe that includes approximately 150,000 entities across at least 45 industry segments. Under the new rules, regulated waste handlers will need to use the new paper or electronic EPA manifest form and waste receiving facilities will have to submit the new manifests to the e-Manifesting system, incurring a processing fee.

The goal of the new e-Manifesting system is to reduce costs and improve regulatory oversight and data quality. The EPA estimates that the manual processing and documentation of paper manifests costs regulators and companies $193 million to $400 million annually.

RCRA is the federal law that creates the framework for managing hazardous and non-hazardous solid waste. Since 1980, the EPA has required a RCRA manifest, a multi-copy paper form, to track hazardous waste from the time it leaves the generating facility until it reaches the off-site waste management facility that will store, treat, or dispose of it. The manifest helps the EPA verify proper waste handling.

E-Manifest requirements are effective in all states on June 30, 2018. These requirements apply to domestic hazardous waste (as defined at the federal and state level) and state-only regulated waste subject under state law to RCRA hazardous waste manifesting. The e-Manifesting system is a product of the 2012 Hazardous Waste Electronic Manifest Establishment Act and subsequent February 2014 and January 2018 final rulemakings. Starting June 30, receiving facilities are required to submit copies, whether electronic or paper, of RCRA waste manifests to the EPA within 30 days of receipt. Receiving facilities will also incur a processing fee for manifest submittal. In three years, paper manifests will be phased out of use.

The new requirements fall under RCRA enforcement policy. Noncompliance with RCRA, including improper manifesting, exposes waste handers to substantial civil penalties.

Before this e-Manifesting system’s implementation, shipments of waste across state borders could create jurisdictional issues for states with enhanced regulatory requirements. Some states impose manifesting requirements that are more stringent than RCRA’s rules, or define hazardous waste more broadly than under RCRA. When waste generated in these more stringent states was disposed of in less stringent states, the generating state lacked the ability to enforce the receipt of manifest copies from out-of-state receiving facilities. For example, if a disposal site in Ohio received waste oil from Connecticut that was classified as hazardous under Connecticut law but not classified as hazardous under Ohio law, then the Ohio disposal facility may or may not have submitted the manifest to Connecticut, and Connecticut did not have the ability to enforce its collection.

Now, under the 2012 Hazardous Waste Electronic Manifest Establishment Act, federal and state regulators can access complete cradle-to-grave waste manifesting records from the e-Manifest system because submitting manifests is compulsory. For example, as of June 30, 2018, if a disposal site in Ohio receives waste oil from Connecticut that is classified as hazardous under Connecticut law but not classified as hazardous under Ohio law, then the Ohio disposal facility must submit the manifest to the e-Manifest system, even if Ohio law does not require such submittal.

On or after June 30, waste generators, transporters, receivers, and disposers of waste regulated by the new regulations must track the waste on the new paper or electronic manifest, U.S. EPA Form 8700-22, and submit the manifest to the e-Manifest system. The EPA granted an initial extension of the 30-day manifest-receipt deadline for paper manifests received from June 30, 2018 through September 1, 2018. With this extension, receiving facilities may submit those manifests on or before September 30, 2018.

What Generators and Transporters Need to Know

Waste handling facilities should review the waste and manifest requirements that pertain to their business. It is important to understand the laws and regulations of the generating and receiving state. Any waste defined as hazardous by the generating or receiving state, or any waste requiring tracking on a RCRA manifest (i.e., a hazardous waste manifest), is subject to the e-Manifesting requirements.

Generators have the option to create and submit manifests electronically or to submit paper manifests to the e-Manifest system. The existing 6-copy manifest is being replaced with a new 5-copy form that must be ordered from a registered printer.

What Receiving and Disposal Facilities Need to Know

The new manifesting requirements will impact both RCRA-permitted disposal facilities (i.e., Treatment, Storage, and Disposal Facilities (“TSDFs”)) and non-TSDFs when such facilities receive waste that is either (1) non-hazardous but requires a RCRA manifest, or (2) is hazardous under the generating state’s laws and regulations. Therefore, the new e-Manifesting system extends the scope of regulatory obligations under federal law even if the law of the receiving state does not require a RCRA manifest for the waste at issue.

Receiving and disposal facilities must submit all RCRA manifests, paper or electronic, to the EPA. Receiving facilities need to obtain an EPA Identification number to use the e-Manifest system. To obtain an EPA ID number, facilities must submit EPA’s Site Identification form (U.S. EPA form 8700-12). EPA will charge receiving facilities a fee for each manifest submitted. Fees, which are differentiated based on how the manifest is submitted, are projected to range from $4 to $20. Late payments are subject to interest penalties.

EPA Resources:

This article was first published at the Cohen & Grigsby website.  To help its clients better understand the most efficient and cost-effective means of compliance, Cohen & Grigsby will continue to monitor this issue. If you have any questions, please contact Laura Ragozzino at (412) 297-4713 or [email protected].

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About the Author

Laura Ragozzino is regulatory compliance and environmental attorney for Cohen & Grigsby P.C.  She practices out of the firm’s Pittsburgh offices.

Ms. Ragozzino is an energetic counselor with proven success mitigating compliance risk. She practices in the areas of administrative law, energy law, EHS law, and government and regulatory affairs. She is passionate about building a compliance culture based on mutual respect for engineering, operations, and the regulations that govern their activities.

Ms. Ragozzino manages complex issues with federal, state, and local agencies to achieve results exceeding her business clients’ expectations. She brings creative, detail-oriented, and tactical thinking to the table to find effective and appropriate compliance solutions across industry sectors.

Nano-Scale Selective Ion Exchange used to Remove Radioactive Contamination from Water

Researchers from the University of Helsinki in Finland recently reported that they have developed a new method to remove radioactive contamination from water.  They claim their method of nano-scale selective ion exchange is faster than the conventional method and more environmentally-friendly as less radioactive solid waste is produced.

Risto Koivula, researcher at the University of Helsinki

The new method of selective ion exchange uses electrospun sodium titanate.  Electrospinning is a fibre production method which uses electric force to draw charged threads of polymer solutions or polymer melts up to fiber diameters in the order of some hundred nanometers  “The advantages of electrospun materials are due to the kinetics, i.e. reaction speed, of ion exchange,” says Risto Koivula, a scientist in the research group Ion Exchange for Nuclear Waste Treatment and for Recycling at the Department of Chemistry at the University of Helsinki.

One conventional method of removing radioactive ions from water is using granular sodium titanate as an ion exchange medium.  It is currently used to treat the 120,000 cubic meters of radioactive wastewater generated as a result of the Fukushima, Japan nuclear accident.  As radioactive wastewater is run through the ion exchanger, the radio-active ions are exchanged with the sodium in the sodium titantate.  The radioactive pollutants remain bound by the granules in the ion exchange unit.

Sodium Titanate fibres

The advantage of sodium titanate over other ion exchange media is that it is selective, which means that it is picks out only the radioactive ions from the water.  One disadvantage of ion exchange is that a water pollution problem is being transferred into a waste management problem.  When the ion exchange capacity is filled, the filtering material has to be switched out.  This leaves solid radio-active waste which must be managed.

The utilization of electrospun sodium titanate results in nano-scale spindles.  The result is an ion exchange solution that occupies less space but provides an equal treatment capability.  “Since less electrospun material is needed from the start of the process, the radio-active waste requiring a permanent repository will also fit in a smaller space,” says Koivula.

The electrospinning equipment at the University of Helsinki was developed and built in the Centre of Excellence for Atomic Layer Deposition, led by Mikko Ritala. The researchers successfully tried this quite simple method for working sodium titanate into fibre.  Koivula’s team studied the ion exchange features of fibre produced this way and found it worked like the commercially produced ones.

The utilization of this selective ion exchange method could be applied to the sites with groundwater contaminated with radioactive ions.

In Canada, the Town of Port Hope (located approximately 100 km east to Toronto) has over 1 million cubic metres of low-level radioactive waste as well as radioactive waste in treatment ponds.  The source of the radioactive contamination is the historic operation of the former radium and uranium refining activities of Eldorado Nuclear.  The wastewater treatment facility at Port Hope is a two-stage process that removes salts, heavy metals, and contaminants such as radium and arsenic.  The process involves chemical precipitation with clarification followed by reverse osmosis.

Canadian Government Announces Action on Pollution Prevention and Toxic Chemicals

The Canadian government recently issued a press release which states that it is undertaking actions to strengthen Canada’s approach to managing harmful substances and is committing to reform the Canadian Environmental Protection Act, 1999. The announcement is in response to a 2017 report issued by the House of Commons’ Standing Committee on Environment and Sustainable Development (“Standing Committee”) that entitled “Healthy Environment, Healthy Canadians, Healthy Economy: Strengthening the Canadian Environmental Protection Act, 1999”.

The 2017 report issued by the Standing Committee made 87 recommendations to the federal government, including prohibiting substances of very high concern unless industry can prove the substances can be used or emitted safely and there are no feasible substitutes; ensuring that vulnerable people are taken into consideration when the government assesses and manages new substances; implementing timelines throughout the Act to oblige action on toxic substances; and facilitating public participation in environmental decision-making and in enforcement of the Act.

At the time of the release of the 2017 report, the Committee Chair Deb Schulte stated, “The Act has now been in place for almost three decades. It is time to bring it into the 21st century by taking into account new scientific knowledge and evolving concepts in environmental law.”

Photography of Factory https://www.pexels.com/photo/photography-of-factory-929385/The Government of Canada is taking action to implement many of the Committee’s recommendations including:
• The development of a policy framework for considering vulnerable populations—such as children, pregnant women, and the elderly—in the assessment and management of chemicals;
• Action to protect Canadians from chemicals of high concern, such as endocrine disruptors, which can affect how hormones work and lead to long-term health issues; and
• Updating standards and developing new instruments to improve air quality and reduce air pollution from industrial sources, including oil refineries.

As a first step in the legislative reform of the Canadian Environmental Protection Act, 1999 and updating of Canada’s Chemicals Management Plan, the Canadian government will conduct a thorough review and consult with various groups