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Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Michigan Hospital Enter into Consent Agreement

Written by Walter Wright, Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

The United States Environmental Protection Agency (“EPA”) and Spectrum Health Hospitals (“Spectrum”) entered into an October 29th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource Conservation and Recovery Act (“RCRA”) hazardous waste regulations. See Docket No. RCRA-05-2021-0003.

The CAFO provides that Spectrum operates a facility (“Facility”) in Grand Rapids, Michigan.

The Facility is stated to include actions or processes causing the production of hazardous waste as that term is defined under 40 C.F.R. § 260.10. Therefore, Spectrum is stated to be a generator of hazardous waste under the relevant regulations.

The Facility is stated to have during the 2019 calendar year generated 1,000 kilograms or greater of hazardous waste, or generated 1 kilogram or greater of acute hazardous waste in some calendar months (qualifying it as a large quantity generator) which it shipped off-site to a treatment storage or disposal facility.

EPA is stated to have provided Spectrum the identification of potential RCRA violations. The Facility is stated to have engaged with EPA to expeditiously assess the matter and agrees to the entry of the CAFO.

The alleged violations include:

  • Notification of Change of Hazardous Waste Activity (failure to submit for the 2019 calendar year a notification of the change of the Facility’s type of hazardous waste activity to Large Quantity Generator status)
  • Annual Reporting (failure to prepare and submit a biennial report by March 1, 2020)

The CAFO requires that Spectrum file with the Michigan environmental agency an updated Notification of RCRA Subtitle C Activities and a Biennial Hazardous Waste Report covering the 2019 calendar year.

Spectrum neither admits nor denies the factual allegations in the CAFO.

A civil penalty of $11,471 is assessed.

A copy of the CAFO can be downloaded here.


About the Author

Walter Wright has more than 30 years of experience in environmental, energy (petroleum marketing), and water law.  His expertise includes counseling clients on issues involving environmental permits, compliance strategies, enforcement defense, property redevelopment issues, environmental impact statements, and procurement/management of water rights. He routinely advises developers, lenders, petroleum marketers, and others about effective strategies for structuring real estate and corporate transactions to address environmental financial risks.

Ontario: Discussion paper on modernizing hazardous waste reporting

The Ontario Ministry of the Environment, Conservation and Parks (MECP) recently announced that it received 76 comments on its “Modernizing Hazardous Waste Reporting in Ontario” discussion paper.

The MECP made changes to the Resource Recovery and Circular Economy Act (RRCEA), and the Environmental Protection Act (EPA) in Fall 2019, which allow the RPRA to provide digital reporting services, fee setting and collection for a wider range of waste and resource recovery programs.

The MECP issued a written letter of direction instructing the RPRA to prepare to deliver a digital reporting service for the Hazardous Waste program. The new hazardous waste digital reporting service would align with the open for business red tape reduction strategy by making it easier for the regulated community to track and report on waste.

Comments contributed to the proposed regulatory amendments and new proposed regulation and the MECP will continue to consider these comments as they take steps to update the Registration Guidance Manual for Generators of Liquid Industrial and Hazardous Waste and transition to the new digital reporting service.

Proposed Regulatory Changes

1. Amend Regulation 347 under the EPA to transition the delivery of hazardous waste digital reporting services to the RPRA

A. Transition delivery and operation of the hazardous waste digital reporting service

The MECP is proposing to amend Regulation 347 under the EPA to require the regulated community (including waste generators, carriers and receivers) to report waste management information to the RPRA instead of to the MECP, as they currently do. This would enable the RPRA to deliver and operate the hazardous waste digital reporting service, including collecting reports and fees from the regulated community.

B. Change registration and reporting requirements to support electronic service delivery

The amendments would also include changes to registration and reporting requirements to support a fully electronic reporting service. The new digital reporting service is intended to replace www.hwin.ca and paper document submissions.

Annual registration

The MECP is proposing to remove the annual registration renewal requirement (currently between January 1st to February 15th) and only collect information from generators at the time the business has a waste management activity to report (i.e. onsite storage/disposal/processing, or offsite movement of subject waste).

This would mean that businesses would complete an initial waste management activity report when they are reporting their first activity (using the new registry for the first time).

To ensure ongoing accuracy with facility, contact and payment information, the RPRA would require that businesses review and update their initially reported information when they are ready to report their first waste management activity after 365 days from the last time they reviewed and confirmed this information.

Reporting requirements

The MECP is proposing to amend Regulation 347 to provide more clarity about what waste management activities need to be reported to the RPRA and when they need to be reported. Reportable activities include both onsite and offsite management of subject waste and would remain the same. Reporting requirements for the Hazardous Waste program would be consolidated into one section.

The following activities would continue to be reportable waste management activities under the Hazardous Waste program:

  • Offsite management:
    • prior to completing the first off-site shipment of a subject waste
  • Onsite management:
    • within 90 days of generating and storing a subject waste where such waste is to be temporarily stored for more than 90 days and less than two years
    • prior to processing a subject waste onsite with the applicable Environmental Compliance Approval
    • prior to disposing of a subject waste onsite with the applicable approvals
    • prior to storing a subject waste for longer than two years with a valid Environmental Compliance Approval

Businesses that generate subject waste would be required to report their activities on, or prior to, the date that the activity takes place or within 90 days of generating or temporarily storing the subject waste if no other waste management activity has taken place. No generator of subject waste would be permitted to store subject waste for a period of greater than 90 days without reporting an activity to the RPRA. No generator would be permitted to manage such waste without reporting the activity to the RPRA.

In the near term, the ministry’s approach is to ensure that the proposed amendments would support the continued use of paper manifesting as an alternative to electronic reporting through the RPRA’s Registry, in a manner similar to that currently provided for under Regulation 347. Such reporting would continue to be provided directly to the ministry (director).

Report Completion

The MECP is proposing to amend Regulation 347 to clarify that reporting information would not be accepted in the new hazardous waste digital reporting service unless:

  • The entire waste management activity report is completed in a manner consistent with the requirements of the Regulation.
  • Any applicable fee payable by the generator is paid by or on behalf of the business.

This is intended to ensure that all members of the regulated community provide accurate information, on a timely basis and that they are paying for the subject waste that they generate in a timely manner.

Delegating Authority

The MECP is proposing that the new hazardous waste digital reporting service would allow delegates to register, report, and pay fees on behalf of generators. The generator would remain responsible for the subject waste that they generate and the information that is reported on their behalf. The RPRA would be responsible for ensuring confidential business information remains protected. The MECP is proposing to amend Regulation 347 to include a definition for ‘Delegate’ that would clarify this role.

The ability to delegate authority would provide flexibility for businesses (waste generators) to comply with the new hazardous waste digital reporting service, and ensure that the most accessible, knowledgeable and capable individuals are able to act on behalf of a business, should it be needed.

Paper-based reporting

The rules for paper-based reporting would remain the same in Regulation 347 because there is still a possibility that paper documents could be used in certain circumstances. In situations where paper manifests are used, businesses would continue to be required to ensure their manifest travels with the waste and applicable filing requirements are met with the ministry.

C. General housekeeping amendments to provide more clarity

The MECP is proposing to amend Regulation 347 to make various minor changes to provide more clarity and ensure consistency with other regulations.

Align with Federal regulatory phrases

Aligning with Federal regulatory phrases under the Transportation of Dangerous Goods Act(TDGA) would make it easier for businesses to learn and comply with both federal and provincial rules.

  • Align with the Federal phrasing in the TDGA by replacing “packaged” to “means of containment”.
  • The word “issued” should be removed when referencing TDGA manifests – because TDGA no longer “issues” manifests.
Definitions

Changes are needed to some existing definitions to provide more clarity for the regulated community.

  • The ‘field operation’ definition would be amended to clarify that specific medical clinics (blood donation/vaccinations and flu clinics) are included in the definition. This would reduce burden as these sites will not need to register and manifest at every site.
  • The ‘empty pesticide container’ definition would be updated to match the definition in Pesticides Act to help clarify and align with existing requirements.
  • The ‘reactive waste’ definition would be updated to correct a grammatical error and make it clear that the definition of reactive waste contains an independent list of criteria and not a multi-checklist of requirements. For example, if the waste meets any one criterion in the list, then it meets the reactive waste definition.
  • Both the ‘ignitable waste’ and ‘reactive waste’ definitions would be updated to align with the actual federal titles.

Some new definitions (i.e. RPRA, Registrar, Registry) would be needed so that the RPRA can deliver and operate the new hazardous waste digital reporting service. These definitions would have the same meaning as in the RRCEA. Other defined terms may also be required or desirable.

2. Create a new regulation under the RRCEA to carry over fee exemptions for certain activities related to hazardous waste – the RPRA would be required to consider the exemptions when setting program cost recovery fees.

The MECP is proposing a new regulation under the RRCEA that would carry over fee exemptions for certain activities related to hazardous waste from Regulation 347. The RPRA would be required to consider these exemptions, which would be based on the current exemptions when setting fees to recover the full cost of the Hazardous Waste program.

All fee setting references in Regulation 347 would be revoked when the new hazardous waste digital reporting service is implemented because the RPRA would have the responsibility to set and collect fees. The RPRA would be required to consult with stakeholders prior to establishing or amending fees for 45 days and post these fees on their website.

Read about and comment on the related proposed new regulation under the RRCEA.

Maintain government oversight for the hazardous waste program

Government would continue to play an important and on-going role in protecting the health and safety of the people of Ontario, and the environment. With respect to the Hazardous Waste program, the ministry would maintain compliance and enforcement, and program and policy oversight activities.

The RPRA would be responsible for operating the hazardous waste digital reporting service to ensure reports are complete and related fees are collected. The RPRA would also notify the ministry of any suspected non-compliant activities. All incidents of non-compliance with program requirements would continue to be followed-up on by the ministry.

The ministry would continue to ensure all generators, carriers, and receivers are complying with requirements under the EPA and Regulation 347 to safely store, transport, process, and manage subject waste in Ontario. The ministry would continue to do this by conducting compliance inspections and following up on reported incidents of improper management of waste. The ministry would also continue to enforce program requirements through investigations and prosecutions.

Benefits of the new digital reporting service

A new digital reporting service for the Hazardous Waste program, would make reporting simpler, faster and more cost-effective. This change would also help us to meet our goals to:

  • Go digital – Implementing a modern digital reporting service that replaces the existing paper-based manifest program would improve our existing service and knowledge base, making it easier to report activities related to subject waste (i.e. hazardous waste and liquid industrial waste as defined in Regulation 347).
  • Hold polluters accountable – Implementing a modern digital reporting service would allow for more effective and timely compliance monitoring and enforcement actions.

Improved electronic data tracking and reporting would provide the regulated community and the ministry with an important set of tools that reduce administrative burden, saving time and money. For example, the service would:

  • Reduce unnecessary manual data entry.
  • Reduce the amount of time and money businesses spend preparing and mailing paperwork to the ministry, correcting administrative errors on paper, or searching for missing paperwork.
  • Provide the ministry with more accurate and timely information to inform decision making and policy development.
  • Allow the ministry to focus on risk-based compliance and enforcement to ensure subject waste is appropriately managed.

This new hazardous waste digital reporting service would align with Ontario’s Digital Service mandate by eliminating outdated approaches to processes, such as reporting using the existing online system (i.e. Hazardous Waste Information Network – HWIN) and using the more burdensome paper-based submission processes (e.g. paper manifests) that prevent the delivery of people-centered services.

The new hazardous waste digital reporting service would align with the Made-in-Ontario Environment Plan by modernizing the way that the regulated community tracks and reports on subject waste (i.e. hazardous waste and liquid industrial waste as defined in Regulation 347 of the EPA). A better digital reporting service will enable more efficient and timely compliance monitoring and enforcement actions, which would provide assurance for Ontarians that polluters are held accountable, and subject waste is being appropriately and safely managed.

 

CarMax Settles Lawsuit related to Unlawful Handling and Disposal of Hazardous Materials

Seventeen District Attorney’s in California recently settled an environmental protection action against CarMax Auto Superstores California, LLC. The settlement was based on the unlawful handling and disposal of various hazardous materials and hazardous wastes. The action was filed in Orange County Superior Court.

Waste inspections conducted at various CarMax locations in the seventeen Counties uncovered systemic violations of the management and disposal of hazardous waste items and confidential customer information.

“Today’s settlement is a win for the environment,” stated Alameda District Attorney Nancy O’Malley in a news release. “I want to make it very clear to any business operating in Alameda County and the state of California: there is no excuse for improper disposal of hazardous waste. You put us all at risk when you pollute our soil and our waterways. The state as well as local district attorneys will continue to work together to investigate and bring to justice businesses that ignore our important environmental protection laws.”

Nancy E. O’Malley, Alameda County District Attorney

CarMax Auto Superstores California, LLC. is an automotive retailer that operates more than 190 dealerships in at least 28 states, including California. In the ordinary course of business, CarMax handles, transports, stores, manages, uses and disposes of hazardous materials. Additionally, CarMax generates regulated quantities of hazardous waste from its automotive inspection, service and repair departments. Numerous inspections by the California Department of Toxic Substances Control along with local environmental regulators found that CarMax facilities were out of compliance with the hazardous materials and hazardous waste laws.

District Attorney Investigators from several counties conducted undercover inspections of CarMax’s trash containers, which revealed the illegal disposal of hazardous auto body sanding dust, sanding pads, automotive paints, clear coats, solvents, non-empty aerosols, other hazardous substances used during the auto body repair process, and confidential customer information.

In accordance with the Hazardous Waste Control Law and Hazardous Materials Release Response Plans and Inventory Law, the stipulated judgment mandates training, reporting and compliance with the regulations on hazardous materials, and hazardous wastes. The settlement totaling $ 1,600,000 requires CarMax to pay $1,000,000 in civil penalties and $300,000 for investigative costs. CarMax will also make an additional payment of $300,000 to fund supplemental environmental projects furthering consumer protection and environmental enforcement in California. CarMax was cooperative throughout the investigation and implemented training and compliance programs at each of its facilities.

The case was brought in conjunction with the District Attorney’s offices of Orange, Riverside, Los Angeles, San Bernardino, Fresno, Stanislaus, Kern, Ventura, Sacramento, Placer, San Diego, Solano, Sonoma, Santa Clara, San Mateo and Contra Costa counties, where CarMax facilities are located.

Posted on Jun 11, 2020

Crystal Geyser Gushes $5 Million in Hazardous Waste Fines

Written by Dawn DeVroom, IDR Environmental Services

The recent federal case against the company that bottles Crystal Geyser Natural Alpine Spring Water proves that the improper handling of hazardous waste can be costly.

Recently, CG Roxane pled guilty in U.S. District Court to unlawful storage of hazardous waste and unlawful transportation of hazardous material. The plea agreement to the two counts came with a $5 million criminal fine.

The charges stemmed from allegations that over the last 15 years, CG Roxane has dumped wastewater contaminated with arsenic into a man-made pond at the company’s Olancha, California, facility. Samples taken by the Lahontan Regional Water Quality Control Board revealed arsenic levels were eight times higher than legally allowed.

This case underscores the importance of proper identification, transportation and disposal of hazardous waste. It also stresses the consequences of not working with the right certified company to ensure your business is meeting all state and federal regulations. Not doing so can result in substantial fines and negative publicity that can have a disastrous effect on your business.

Improper Waste Disposal Can Be Costly

hazardous wasteFailure to manage hazardous waste streams according to state and federal guidelines can bring unwanted consequences for both the environment and your company.

As CG Roxane discovered, costly criminal fines often accompany cases in which companies are found guilty of improper hazardous waste management. Two other companies may find themselves in trouble from this case as well. CG Roxane hired United Pumping Services Inc. and United Storm Water Inc. to transport and treat the wastewater. Both could face fines of up to $8 million if found guilty for their role in the case.

Other multimillion-dollar companies have faced similar consequences. Companies like FedEx, Rite Aid and Walmart have been fined millions of dollars over the past few years for improper waste management practices. Walmart, in particular, agreed to pay more than $81 million after pleading guilty in 2013 to six counts of violating the Clean Water Act.

In addition to fines, improper waste disposal can be a nightmare for a company’s public image, and worse, become a risk to public safety. Spills, fires, explosions and exposure to toxic chemicals can stem from the mishandling of hazardous waste.

How To Ensure Proper Waste Management

It is critical for hazardous waste generators to ensure compliance with regulations by providing ongoing training opportunities for employees and by working with an experienced hazardous waste disposal company.

The onus falls on you to ensure any hazardous waste you generate is disposed of properly. That responsibility does not end once your waste is removed from company property. Under the Resource and Recovery Act of 1976 (RCRA), you are legally and financially responsible for the appropriate treatment and proper disposal of that waste … from cradle to grave.

Choosing the wrong vendor can prove costly, too.

So, how do you properly vet a company for the best business practices and avoid the nightmare scenarios described above?

1. Begin with a thorough background check of a vendor.

In addition to checking state and federal licenses, set up an interview with the vendor. Ask questions such as:

  • Do you have a Dun & Bradstreet report or a bank letter of credit?
  • Do you meet minimum insurance requirements and have coverage for accidents?
  • Do you have adequate personnel that are properly trained and certified?
  • Can you provide a statement of qualifications (SOQ)?
  • How do you deal with unknown chemicals?
  • Are you legally permitted for the transportation, storage, treatment and disposal of hazardous waste materials?
  • Can you provide a list of references on past related projects?

More ideas for questions to ask a vendor can be found in our article, What Manufacturers Must Know About Hazardous Waste Disposal.

2. Confirm the experience of any vendor being considered.

A hazardous waste generalist, for example, is used to working in different environments and has a broad base of experience working with different toxic chemicals.

Check to make sure the vendor includes these services:

  • Identification of waste streams by profiling and testing them
  • Development of site-specific plans, including training and emergency preparation
  • Transportation to recycling and disposal sites
  • Manifest preparation and any other paperwork that must be completed

3. Look for a certified hazardous waste disposal company that is consultative.

In other words, look for a company that offers a hazardous waste walk-through program.

Areas of focus should include:

  • Waste manifesting
  • Hazardous waste procedures
  • Waste storage evaluation
  • Emergency readiness
  • Hazardous waste evaluation
  • Employee training procedures

A waste walk-through program will help you stay atop any regulatory changes at the local, state and federal levels.

Better Safe Than Sorry

The improper handling of hazardous waste can have devastating effects on the environment, community and your business.

Many companies that do not take the proper precautions to ensure the waste they generate is properly disposed of find themselves tangled up in a legal mess for years. At the end of that mess is rarely a positive outcome for the company.

Working with a certified hazardous waste disposal service will help you avoid costly fines and a tarnished public image, as well as allow you to be assured that the hazardous waste your company generates is being transported and disposed of safely and legally.


About the Author

Dawn DeVroom is the CFO at IDR Environmental Services based in California. The company specializes in hazardous waste disposal.

Hazardous Waste Enforcement: U.S. EPA and Electronics Recycling Facility Enter into Consent Agreement

Written by Walter Wright Jr.Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

The United States Environmental Protection Agency (“EPA”) and AERC Acquisition Corporation dba AERC Recycling Solutions (“AERC”) entered into a February 25th Consent Agreement (“CA”) addressing alleged violations of the Resource Conservation and Recovery Act (“RCRA”) regulations (which the State of Virginia has adopted). See Docket No. RCRA-03-2020-0070.

The CA provides that AERC performs electronics and universal recycling at a facility (“Facility”) in Richmond, Virginia.

The Facility is described as consisting of 40,000 square feet of building space that has been in operation as an electronics recycler since 2013. The Facility is stated to have begun recycling waste lamps in 2014.

AERC is stated to have submitted to the Virginia Department of Environmental Quality (“VDEQ”) May 6, 2014, and May 30, 2017, notifications indicating the Facility is a small quantity generator of hazardous waste at the Facility. Such notices are also stated to have indicated the Facility was a large quantity handler of universal waste along with being a transporter and a transfer facility.

The Facility is stated to not have a permit for the treatment, storage, or disposal of hazardous waste.

An inspector from EPA is stated to have undertaken a Compliance Evaluation Inspection (“CEI”) of the Facility on August 22, 2017. The purpose of the CEI was stated to be the examination of the Facility’s compliance with Subtitle C of RCRA and associated Virginia regulations.

EPA is stated to have sent an information request letter to AERC to acquire additional information. AERC responded to the request in a letter dated September 16, 2019.

A Request to Show Cause was also provided to AERC to which EPA and AERC met to discuss alleged violations.

The CA alleges the following violations have occurred at the Facility:

  • Operating a treatment, storage, and disposal facility without a permit or interim status
  • Failure to label or mark clearly a number of containers of hazardous waste lamps with the prescribed words
  • Boxes stored in a manner that prevented the inspector from observing whether they were properly labeled and dated
  • Failure to mark containers of waste lamps with the date upon which each period of accumulation began
  • Failure to mark with the date upon which accumulation began, or otherwise track accumulation start date for certain containers of hazardous waste lamps
  • Failure to maintain a tracking system documenting the length of time the containers are accumulated on site
  • Failure to meet certain requirements of the Generator Accumulation Exemption
  • Failure to keep containers storing waste lamps closed except when it is necessary to add or remove waste
  • Failure to minimize risk of release, and failure to immediately contain all releases of waste lamps

The CA assesses a civil penalty of $10,000.

The CA also provides that AERC will within 90 days of the effective date of the document conduct an electronics recycling event within and in coordination with the City of Richmond, Virginia. The cost of such event will be no less than $40,000.

A copy of the CA can be downloaded here.


About the Author

Walter Wright has more than 30 years of experience in environmental, energy (petroleum marketing), and water law.  His expertise includes counseling clients on issues involving environmental permits, compliance strategies, enforcement defense, property redevelopment issues, environmental impact statements, and procurement/management of water rights. He routinely advises developers, lenders, petroleum marketers, and others about effective strategies for structuring real estate and corporate transactions to address environmental financial risks.

Water company pleads guilty to hazardous waste violations

As reported by the Associated Press, A California-based water company recently pleaded guilty to illegally storing and transporting hazardous waste and agreed to a $5 million fine.  The company produces Crystal Geyser bottled water.

The hazardous waste was generated at the company from the sand filters used to remove arsenic out the spring water at the CG Roxane LLC’s facility in Owens Valley.  When the sand filters were back washed with sodium solution, thousands of gallons of arsenic-contaminated water was generated.  The company entered the pleas to one count of unlawful storage of hazardous waste and one count of unlawful transportation of hazardous material.  The  company was accused of discharging the wastewater into a man-made pond over the course of approximately 15 years.

Pond sampling by local water quality officials in 2013 found arsenic concentrations above the hazardous waste limit, as did subsequent sampling by state authorities and the company.  State officials instructed the company to remove the pond.  The two companies hired to manage the wastewater were not informed the wastwater was considered hazardous material, resulting in 23,000 gallons (87,064 litres) being discharged into a sewer without proper treatment.

 

Ontario: Wind up of Municipal Hazardous or Special Waste Program

On November 21, the Ontario Resource Productivity and Recovery Authority (RPRA) closed a 45-day consultation period on Stewardship Ontario’s proposed Municipal Hazardous or Special Waste (MHSW) Program Wind-Up Plan. RPRA held two webinars and five in-person sessions across the Province to solicit feedback from interested stakeholders. The Authority has been directed to approve the proposed Wind-Up Plan no later than December 31, 2019.

The MHSW Program allows Ontario residents to safely dispose of household products that require special handling, such as single-use batteries and propane tanks. Industry stewardship organizations are responsible for recovering additional hazardous waste products, including automotive materials; paints and coatings; pesticides, solvents and fertilizers; and proprietary carbon dioxide cylinders.

Background

In April 2018, the then Ontario Minister of the Environment and Climate Change directed the wind up of the MHSW Program on December 31, 2020 as per the Waste Diversion Transition Act, 2016. Following wind up, hazardous or special materials will transition to the new, mandatory individual producer responsibility (IPR) framework under the Resource Recovery and Circular Economy Act, 2016.

In December 2018, the Minister of the Environment, Conservation and Parks (MECP) amended the timeline for the wind up of the single-use batteries component of the MHSW Program to June 30, 2020.

In July 2019, the Minister issued new directions including extending the timeline to wind up the MHSW Program to June 30, 2021; the Batteries Program wind up remains June 30, 2020.

Stewardship Ontario submitted its proposed MHSW Wind-Up Plan to the Authority by the September 30, 2019 deadline set by the Minister. As part of the wind-up process, the Minister directed the Authority to consult on the proposed plan before considering approval. As directed by the Minister, the Authority anticipates its approval of the plan by the end of the year.

MHSW Program wind up

Until the wind-up date, the MHSW Program will continue to operate without disruption. This includes the operation of the industry stewardship plans managed by the Automotive Materials Stewardship, Product Care Association, and SodaStream.

Single Use Batteries

The Minister of the Environment, Conservation and Parks has directed Stewardship Ontario to wind up the program for single-use batteries on June 30, 2020. This change will allow for a coordinated policy approach with the wind up of the Waste Electrical and Electronic Equipment Program.

 

 

 

Researchers Perfect Nanotechnology Tool for Studies of Nuclear Waste Storage

Researchers at the University of Guelph (U of G) recently published an article in Nature Scientific Reports in which they describe the first every use of antimatter to investigate processes connected to potential long-term storage of nuclear waste.  The team studied radiation chemistry and electronic structure of materials at scales smaller than nanometres.

The U of G team worked with collaborators at the French Alternative Energies and Atomic Energy Commission and utilized the TRIUMF particle accelerator in Vancouver.  Based on these first-ever measurements at the accelerator, the team able to to show that their system is a proven tool that will enable radiation studies of material to be used to store nuclear waste.

“This system can now be applied along with other measurements to determine and help to potentially design the best material for containers and barriers in nuclear waste management”, said the U of G professor Khashayar Ghandi, the lead author of the research paper.

Currently, used nuclear fuel bundles – still highly radioactive — are held in vaults in temporary storage.  Long-term, experts aim to use deep geological repositories to permanently entomb the material. Buried in rock formations hundreds of metres underground, the fuel containers would be held in engineered and natural barriers such as clays to shield people and the environment from radiation. It takes almost 100,000 years for radioactivity from nuclear waste to return to the level of natural uranium in the ground.

The researchers also discovered the intriguing properties of clays that may make them useful in other industries. Clays may serve as catalysts to change chemicals from one form to another – a benefit for petrochemical companies making various products from oil. Other industries might use clays to capture global-warming gases such as carbon dioxide and use those gases to make new products.

The research may ultimately help in designing safer underground vaults for permanent storage of radioactive waste.  Other applications of the nanotechnology tool include new ways of generating and storing hydrogen, and technologies for capturing and reusing greenhouse gases.

EPA Finalizes Universal Waste Rule for Hazardous Aerosol Can Wastes, Streamlining Requirements for Their Management

Written by Aaron H. Goldberg, Principal, Beveridge & Diamond

On November 15, 2019, the Administrator of the U.S. Environmental Protection Agency (EPA) signed a final rule to classify and regulate hazardous aerosol can wastes as “universal wastes” under the federal Resource Conservation and Recovery Act (RCRA) hazardous waste rules. Once the rule becomes effective, hazardous aerosol can wastes will be subject to substantially reduced requirements for collection and transport, in order to facilitate and encourage environmentally sound recycling or disposal. However, the ultimate recycling and disposal facilities will remain subject to essentially the same requirements as currently apply. As discussed below, even though the final rule is largely consistent with existing requirements for other universal wastes, and even though EPA has finalized the proposal with only limited changes, there are several aspects of the rule that warrant special attention.

The final rule builds on existing universal waste requirements for other ubiquitous hazardous wastes, such as batteries, lamps, mercury-containing equipment, and certain pesticides. See generally 40 C.F.R. Part 273. Among other things, the aerosol can wastes will no longer have to be labeled as hazardous wastes (although they will be subject to reduced marking requirements), they may be stored for up to one year or even longer in some cases (rather than just 90 days for large quantity generators), they may be transported offsite without a hazardous waste transporter or hazardous waste manifest, and collection facilities not engaged in treatment or disposal will not have to be permitted as hazardous waste storage facilities. In addition, only large handlers of universal wastes (e.g., facilities that accumulate 5000 kg or more of total universal wastes at any time) will be required to notify EPA and track shipments of the hazardous aerosol can wastes. Aerosol can wastes generated by households and Very Small Quantity Generators (VSQGs) meeting applicable requirements will remain exempt from the RCRA regulations. However, all aerosol wastes will remain subject to applicable requirements under the U.S. Department of Transportation (DOT) Hazardous Materials Regulations (HMR) (although under those rules, if aerosol cans are classified as universal wastes, they will not be subject to the enhanced DOT requirements that normally apply to RCRA hazardous wastes). See 49 C.F.R. § 171.8 (defining “hazardous wastes” for purposes of the HMR as materials subject to federal hazardous waste manifest requirements).

Several key aspects of the final rule are discussed below. We note that the discussion here is based solely on the pre-publication version of the final rule and preamble. It is possible (though unlikely) that there may be some substantive changes in the rule when it is published in the Federal Register. In addition, EPA’s Response-to-Comments document and economic assessment for the rule (neither of which are currently publicly available) may provide a further gloss on some of the issues addressed here.

Definition of Aerosol Can

The proposed rule would have limited the definition of “aerosol cans” subject to the rule to containers that use gas to “aerate and dispense any material … in the form of a spray or foam.” In this way, the proposal would have excluded cans that dispense products without aeration (e.g., shaving gels) and cans that release only gas (e.g., spray dusters or aerosol horns). In response to comments, EPA modified the definition in the final rule so that it is more inclusive and consistent with DOT rules. Under the final rule, cans that dispense products without aeration will be eligible for management as universal wastes. However, gas-only products will be excluded. DOT is currently considering a petition to revise its definition to include these products, consistent with international rules for dangerous goods transport. See Petition of the Consumer Specialty Products Association, et al. to DOT (September 28, 2017). Unfortunately, the preamble to EPA’s final rule does not mention this petition, and it is unclear if the Agency would amend the definition in the universal waste rule if/when DOT changes its definition.

Status of Aerosol Cans with Evidence of Leakage/Damage

The proposed rule would have excluded from the scope of the universal waste rule any aerosol cans that “show evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions.” Commenters expressed concern that this proposed limitation was highly ambiguous, could effectively eviscerate the rule and was unnecessary from an environmental perspective (since EPA could simply require more protective packaging for leaking aerosol cans). In the final rule, the Agency agreed with the commenters and added new provisions specifying that “[u]niversal waste aerosol cans that show evidence of leakage must be packaged in a separate closed container or overpacked with absorbents, or immediately punctured and drained.” EPA also modified the definition of aerosol can so that it no longer requires that cans be “intact” to be classified as universal wastes.

Status of Empty Aerosol Cans

The final rule, like the proposed rule, excludes aerosol cans that meet the regulatory definition of an empty container. This exclusion raises a number of issues, as discussed below:

  • Commenters on the proposed rule asked EPA for clarification about when aerosol cans are properly deemed empty. They noted that it is unclear how the regulatory definition of empty and related Agency guidance applies to aerosol cans. EPA largely side-stepped this issue in the final rule. It merely restated the regulations and guidance and said that further clarifications or modifications to the relevant rules were outside the scope of the rulemaking.
  • Commenters raised questions about the relationship of the exclusion for empty cans with past EPA statements that such cans may sometimes exhibit the characteristic of reactivity. See EPA, RCRA Hotline Report (September 1987) (RCRA Online #13027) (“Irrespective of the lack of contained waste, [empty] aerosol cans would be a RCRA hazardous waste [to the extent] they demonstrate the hazardous characteristic of reactivity”). Neither the final rule nor the preamble addresses this issue.
  • The proposal left open the question as to whether empty cans could voluntarily be managed as universal wastes. In the preamble to the final rule, EPA clarified that empty cans may be managed as universal wastes, even though they do not have to be.

Other Issues Related to the Applicability of RCRA to Aerosol Cans

Commenters on the proposed rule asked EPA for guidance on several fundamental issues associated with the applicability of RCRA to aerosol cans in the first instance. For example, they requested guidance on the extent (if any) to which aerosol cans destined for recycling are properly classified as solid wastes (and thus potentially hazardous wastes). The commenters also asked the Agency for guidance about when (if ever) waste aerosol cans (empty or non-empty) might be classified as reactive hazardous wastes, and (as noted above) when aerosols cans qualify as empty. However, the final rule and preamble are essentially silent on these issues. Moreover, even though EPA had previously committed to providing such guidance as part of its 2016 strategy for addressing the applicability of RCRA to the retail sector, the preamble to the final rule states that “EPA has [now] completed all commitments made in the Retail Strategy,” which suggests that the guidance may not be forthcoming. See EPA, “Strategy for Addressing the Retail Sector under the Resource Conservation and Recovery Act’s Regulatory Framework” (September 12, 2016) at 6 (“EPA is developing a guide on how to recycle aerosol cans under the existing Subtitle C recycling exclusions”).

Allowance of Certain Processing Activities by Handlers

The final rule allows handlers of universal waste aerosol cans to perform certain limited activities, “as long as each individual aerosol can is not breached and remains intact”:

  • Sorting aerosol cans by type.
  • Mixing intact cans in one container.
  • Removing actuators to reduce the risk of accidental release.

Although there may be some uncertainty, it appears that these activities may only be performed with intact containers, even though (as noted above) EPA has modified the definition of aerosol can to eliminate the “intact” requirement. For these purposes, it appears that a can with a removed (or possibly missing) actuator would still be viewed as intact, assuming the integrity of the can has not otherwise been compromised.

Special Rules for Puncturing and Draining of Aerosol Cans

Even though puncturing and draining of hazardous aerosol cans is currently exempt from RCRA regulation if performed as part of a recycling process, the final rule imposes new requirements for puncturing and draining by handlers of universal waste aerosol cans (whether they are processing their own aerosol can wastes or those generated by others). For example, these activities will have to be performed using a device (commercial or “homemade”) that is specifically designed to do so in a safe manner that effectively contains residual contents and emissions. The handler will have to develop and follow written procedures to ensure proper operation of the equipment (including segregating incompatible wastes and preventing fires/releases) and to respond to any spills or releases, and it will have to ensure relevant employees are adequately trained. The contents drained from the aerosol cans will have to be “immediately” transferred to a tank or container meeting applicable hazardous waste generator requirements (e.g., the requirements for 90-day accumulation units or satellite accumulation units). A hazardous waste determination will have to be performed on the drained contents, and the materials will have to be managed accordingly. The drained cans will have to be recycled, and since they will be eligible for the RCRA exemption for recycled scrap metal, they will not have to be subjected to a hazardous waste determination. EPA notes that all of these activities must be conducted in compliance with all applicable federal, state, and local laws and regulations related to solid or hazardous wastes, as well as occupational safety and health.

Adoption by the States

EPA states that the final rule is “less stringent than the current federal program” and thus “states … will not have to adopt the universal waste regulations for aerosol cans.” However, as noted above, the new rules for puncturing and draining are more stringent than current rules (because those activities are currently exempt from regulation if performed as part of a recycling process), which casts doubt on the Agency’s claim that the final rule (in its entirety) is less stringent.

Shipments Between States

Despite requests from commenters for EPA to address this issue, the final rule and preamble are silent on the requirements that will apply to aerosol cans shipped from, to, or through states that do not adopt (or have not yet adopted) a universal waste rule for aerosols. In prior universal waste rules for other wastes, EPA has claimed that, in such circumstances, the waste would have to be transported in the non-universal-waste states by a hazardous waste transporter and with a hazardous waste manifest. See, e.g., 64 Fed. Reg. 36,466, 34,483 (July 6, 1999) (universal waste rule for lamps) (“[if] a [federal universal waste is] transported across a State in which it is subject to the full hazardous waste regulations … [t]ransport through the State must be conducted by a hazardous waste transporter and must be accompanied by a manifest”); 70 Fed. Reg. 45,508, 45,517 (August 5, 2005) (universal waste rule for mercury-containing equipment) (same). However, there appears to be a strong argument under the Hazardous Materials Transportation Act (HMTA) that state rules requiring a manifest are preempted if (as would be the case here) federal law does not require a manifest. See, e.g., Letter from Michael Shapiro, Director, Office of Solid Waste, EPA, to Richard J. Barlow, Chair, Northeast Waste Management Officials’ Association (June 11, 1996) (RCRA Online #14135) (“[although] preemption authorities are [generally] quite foreign to RCRA … they are introduced into the transporter area by the statutory directive in RCRA to maintain consistency with the DOT framework”); 49 Fed. Reg. 10,490, 10,492 (March 20, 1984) (federal law “prohibit[s] States from requiring separate State manifests or other information to accompany waste shipments”); id. at 10,494 (“States are not precluded from setting up another system of forms . . . as long as the system does not interfere with the actual shipment of waste [and] transporters [are] not . . . required to carry these forms”). Similar arguments may apply with respect to state requirements to use a hazardous waste transporter for a federally designated universal waste.

Next Steps

The final rule is expected to be published in the Federal Register in the next few weeks and will become effective at the federal level six months later, or approximately in early June 2020. The rule will not become effective in most states unless and until they act to adopt the rule, which (as discussed above) EPA says they will not be required to do (on the ground that the rule is less stringent than existing requirements). However, because several states have previously classified hazardous aerosol can wastes as universal wastes (e.g., California, Colorado, Utah, New Mexico, and Ohio) and another is poised to do the same (i.e., Minnesota), it can be reasonably expected that virtually all states will eventually follow EPA’s lead on this issue (possibly with some variations).

For more information about the final rule and its potential implications, please contact Aaron Goldberg or any other members of our Waste and Recycling practice group.

This article has been republished with permission of the author.  It was first published on the Beveridge & Diamond website.  


 

About the Author

Aaron applies his encyclopedic knowledge of hazardous waste regulatory law to help companies comply under federal and state laws—throughout all 50 states—and abroad.

He holds an advanced degree in chemistry, has extensive training in economics, and is a former U.S. Environmental Protection Agency consultant. His unique, multidisciplinary background—law, science, economics, and government—informs nearly every aspect of his work and makes him a useful bridge between attorneys, engineers, business managers, consultants, and regulators.

Aaron has focused on hazardous waste issues since the beginning of the federal regulatory program in 1980. With this historical experience, he offers clients comprehensive regulatory counsel on hazardous waste matters, including compliance strategy, advocacy, rulemaking challenges, end-of-life product management, permits, variances, and enforcement action response. His clients consist of companies and trade associations in the chemicals, electronics, recycling, petroleum, pharmaceuticals, retail, steel, and mining industries.

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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