Hazardous Materials Remediation

southwest hazard control, inc. (SHC) has provided hazardous materials remediation contracting and technical services since 1986 and has performed approximately $9,000,000 in contracts throughout the Southwest and Colorado.  SHC has an excellent reputation for performance with several Arizona municipalities, the City of Tucson, Pima County, the State of Arizona, Sandia National Laboratories, the General Services Administration, several large copper producers, railroads, military installations, commercial facilities, industrial facilities, and the EPA as a teaming subcontractor for the Emergency Response and Remedial Services contract for Regions 6, 8, 9, and 10. 

SHC utilizes a team concept of experienced, qualified professionals to deliver a full spectrum of services to our clients. 

A few of the hazardous substances which SHC professionals have remediated include: concentrated sulfuric acid, nitric acid, hydrofluoric acid, chlorinated hydrocarbons, petroleum hydrocarbons, sodium cyanide, hydrogen cyanide, lead, arsenic, picric acid, corrosives, pesticides and herbicides, mercury, lead, other heavy metals, reactive, compressed gases, flammables, waste oils, PCBs, and low level radiation products. 

All laboratories, transportation contractors and waste disposal facilities used by SHC are subject to our investigation for reliability and their certifications are reviewed on a predetermined schedule.  SHC personnel work as a team with other environmental specialists as required. 

Regulatory Background

The Environmental Protection Agency (EPA) may authorize states to promulgate regulations at least as stringent as the federal regulations.  Similarly states may delegate regulatory authority to environmental districts, counties and municipalities.  A complex structure of rules, regulations, laws and statutes has evolved. southwest hazard control, inc. takes special pride in correctly interpreting and applying these regulations for our clients.  

Beginning with the National Environmental Policy Act of 1970, the Legislature enacted several Acts of Congress, which became Public Law.  The EPA was created on December 2, 1970 to implement these Acts of Congress, Public Laws, and Executive Orders.  The EPA was assigned Title 40, Chapter 1 of the Code of Federal Regulations to promulgate environmental regulations.  This important reference is commonly cited as 40 CFR. 

Air quality is protected by the Clean Air Act (CAA), the Energy Supply and Environmental Coordination Act (ESECA), the Radon Gas and Indoor Air Quality Research Act (RGIARA), and by a portion of the National Energy Conservation Policy Act (NECPA).  The EPA regulations for air quality are found in 40 CFR 51-86, 600, 610.  Water quality is assured by the Federal Water Pollution Control Act (FWPCA), the Oil Pollution Act (OPA), the Rivers and Harbors Act of 1899 (The Refuse Act), the Water Resources Planning Act (WRPA), the Port and Waterways Safety Act (PWSA), the Marine Protection, Research, and Sanctuaries Act (MPRSA), the Safe Drinking Water Act (SDWA), the Deep Water Port Act (DPA), and the National Ocean Pollution Planning Act (NOPPA).  The EPA regulations for water quality are found in 40 CFR 109-501.  In addition, 18 CFR and 33 CFR also protect water quality and assign certain specific responsibilities to the Coast Guard and the Army Corps of Engineers, respectively.  

Hazardous and toxic materials and wastes are addressed by many of the water quality acts and also by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Super fund), the Superfund Amendments and Reauthorization Act (SARA), the Emergency Planning and Community Right-to-Know Act (EPCRA) also referred to as SARA Title III, the Toxic Substances Control Act (TSCA) and the Resource Conservation and Recovery Act (RCRA).  The EPA regulations for hazardous wastes are found in 40 CFR 240-281.  EPCRA (SARA Title III) authorizes all federal agencies to develop programs for health and safety when dealing with hazardous materials and wastes.  The Department of Transportation (DOT) has developed specific packaging, labeling, manifesting, and transportation requirements for hazardous materials and wastes that are covered in 49 CFR.  Through a memorandum of understanding, EPA requested that the Department of Labor (DOL) develop standards for hazardous waste worker safety training.  DOL's Occupational Safety and Health Administration (OSHA) was given the assignment and now regulates the training and personal protective equipment (PPE) requirements for workers handling hazardous materials and wastes.  These regulations are covered under 29 CFR 1910.120 and 40 CFR 311.  

Remediation Practices

All work shall be performed in accordance with applicable rules, regulations and statutes as promulgated by the Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), and any state, regional or local authority in effect at the time of work. 

SHC will furnish all labor, materials, employee training, pollution & general liability insurance, errors and omissions insurance, expertise, and equipment necessary to carry out the specified hazardous waste remediation, site investigation, waste characterization, emergency response incident analysis and response.  SHC can secure all required permits including any necessary state, regional and local licenses at the request of our client.  Although the owner is responsible for providing required notification to the EPA and any regional, state or local authority having jurisdiction on projects for regulated hazardous material, SHC will provide assistance to the owner as required.

Qualification Submittals

SHC will submit upon request the following materials in order to establish its competency and capability to perform the specified work: 

§         Educational qualifications and other background information that attests to the ability of SHC and SHC employees to competently complete the task.  This includes, but is not limited to, OSHA HazMat worker and supervisor training as covered by 29 CFR 1910.120.

§         Proof that all samples will be analyzed in an EPA and state qualified laboratory.

§         Proof that all workers have had medical examinations as required by OSHA.

§         The name of one or more transportation and/or disposal companies that will be used for waste disposal and assurance that all regulations pertaining to such disposal will be met.

§         Evidence of pollution/general liability insurance coverage, workman's compensation insurance and vehicle insurance.

§         When required by the client, an industrial hygienist will be provided to oversee the implementation of all aspects of safety and health procedures.

Hazard Communication Standards

SHC maintains a written hazard communication program for the work place. The HazCom program contains a list of all hazardous chemicals present.  Employees are notified of the presence of hazardous chemicals present in their workplace and are instructed where to find the SHC “Right to Know Center” which contains copies of Material Safety Data Sheets (MSDS) and educational material for maintaining a safe workplace. 

A copy of the SHC Hazard Communication Program is available to all clients upon request.

Site Emergency Preparedness

The client will provide SHC with current copies of the site Emergency Response Plan (ERP) and Spill Prevention, Containment, and Countermeasure (SPCC) plan for their facility(s) or work area.  SHC's Project Manager will familiarize all workers with the details of these plans prior to entering the site. 

Only authorized SHC workers, who have received 29 CFR 1910.120 training and who are currently certified will be permitted on site.

Pre-construction Meeting/Tailgate Safety Meeting

Prior to the beginning of actual remedial activities, a pre-construction/tailgate safety meeting will be held between the owner, consultant and SHC.  SHC will present a written description of the following: 

§         Remediation Plan(s) and/or Site Safety Plan(s), which include decontamination facilities and their location, work area isolation and containment plans and safety procedures.

§         A description of protective clothing and approved respirators that will be used.

§         A description of remediation, clean-up, and waste disposal procedures and an explanation of decontamination procedures.

Warning Signs, Labels and Posters

OSHA and/or EPA required warning signs might be required to be posted around the workplace and at every potential entry to the work area.  SHC personnel are aware of the circumstances and will provide signs when necessary. 

OSHA, DOT and/or EPA labels are secured to drums or other containers utilized to transport contaminated material to the approved disposal site. 

Other signs, labels, warnings, and posted instructions are provided to protect, inform, and warn of the hazard of exposure.

Protective Equipment

Each project encountered by SHC is analyzed for specific PPE requirements, compatibilities, and durability.  Workers are required to wear and maintain personal protective equipment (PPE) as directed by site supervisor and/or Site Safety Plan when working within any zone of contamination. 

Protective equipment is inspected thoroughly before each use, and defective equipment is replaced immediately. 

Proper decontamination and/or disposal procedures are followed after exposure to hazardous wastes.

Safe Work Practices

Work areas are secured to prevent unauthorized entry and will be properly posted with OSHA and/or EPA approved warning signs or caution tape. 

All workers, foremen, superintendents, authorized visitors, and inspectors are supplied with appropriate respiratory equipment for the type of work being performed and the anticipated exposure levels defined by 29 CFR 1910.134.  When respirators with disposable filter cartridges are employed, a change out schedule will be prepare prior to donning of PPE. 

All workers will don appropriate protective equipment and clothing prior to entering controlled work areas. 

Weekly meetings are held at each job site to discuss accident prevention.  Subjects will include safe use of electricity, water, scaffolding, hoses, lighting, etc.  Daily tailgate meetings are also held to discuss hazards specific to current job sites. 

Emergency and fire exits are established for each work area and SHC is prepared to administer first aid to injured personnel.  Seriously injured personnel will be treated immediately or evacuated without delay for unnecessary decontamination.  Emergency evacuation due to injury or safety will be performed in a manner that minimizes exposure and contamination.

Hazardous Material Packaging

SHC will characterize hazardous materials in accordance with 49 CFR 172-173.  SHC will determine that the packaging or container complies with and has been manufactured, assembled, and marked in accordance with 49 CFR 173.7(a), 178, and 179. 

All waste chemicals are packed to meet DOT specifications for shipping and separating waste streams into specific compatible categories: 

§         Flammable liquid

§         Flammable solid

§         Combustible liquid

§         Corrosive material (acid/base)

§         Poison B

§         Oxidizer

§         Organic peroxide

 

All lab packs are packed so that internal containers can be transported without the risk of breakage.  Sufficient absorbent is included as a precautionary measure should breakage occur. 

All containers are manifested using federally approved forms and, where appropriate, forms approved by the state where the TSD facility is located.  The forms include the following information as a minimum: 

§         Shipping name

§         Hazard class

§         Identification number

§         Type of container

§         Total quantity

§         Weight and volume 

On Site Container Maintenance and Storage

Containers are inspected regularly for proper storage, condition and identification.  Leaking or corroded containers will be immediately removed from service and re-packed as required.  

Containers are considered empty only after thorough cleaning and testing.  Incompatibles (as indicated by MSDSs) are kept separate on the job and in storage.  Substances are never mixed without full assurances of safety.  Storage areas will have impervious floors with no cracks.

Transportation of Hazardous Waste

A Hazardous Waste Manifest accompanies all hazardous waste shipments. 

SHC is a licensed hazardous materials/hazardous waste transporter.

Disposal of Hazardous Waste

Materials for scheduled for hazardous waste disposal are sent to an EPA approved and licensed facility.  Subcontracted treatment, storage and disposal facilities (TSDF’s) are audited through site visits, questionnaires and/or interviews. 

Disposal/Recycling methods are dependent upon type of waste, long term liability and costs. 

Completed manifests and Certificates of Destruction (when available) are reviewed by SHC upon receipt and copies are immediately forwarded to the generator representative for submittal to ADEQ. 

Technical Services

Southwest HAZARD CONTROL, INC. also offers the following technical services which assist property owners in evaluating the environmental status of a property or in addressing environmental issues related to their property or business.

Compliance with Environmental Protection Agencies

The EPA hazardous waste regulations are set forth in 40 CFR (Code of Federal Regulations) parts 124 and 260 through 272.  Requirements have been imposed upon the generation, transportation, storage, and ultimate treatment or disposal of hazardous waste.  SHC is prepared to develop all documentation and procedures for the client to meet these requirements.

Chemical Packaging & Manifesting

When preparing hazardous waste for shipment, proper containers, packaging and labeling are needed to insure the safety of the persons who will receive the delivery.  SHC's personnel are fully trained and experienced in all requirements and documentation.

Shipping Documents

Proper shipping documents (manifests) must accompany all transportation of hazardous waste.  Along with licensed transporters, SHC is experienced in arranging shipment of hazardous wastes.

Chemical Identification System (HazCat)

SHC offers a unique identification system on site to identify unknown liquid and solid waste at your facility without the costly analytical charges from local laboratories.  The HazCat Chemical Identification System is designed for on-site identification or categorization of virtually any spilled or abandoned material.  The HazCat system identifies over 1,000 hazardous and non-hazardous substances, including flammables, corrosives, caustics, poisons, metals, paints, plastics, pesticides, oxidizers, explosives, water-reactives, and asbestos.

SHC Professionals and Technicians are Trained to:

§         Be knowledgeable with regulations affecting environmental compliance issues.

§         Plan Remedial Actions.

§         Conduct Emergency Response Actions

§         Use the most effective technologies for remedial design.

§         Recognize the dangers of hazardous materials and wastes and the importance of handling them properly.

§         Comprehend the requirements for hazardous waste container labels (present on all containers; legible and in good condition; include substance identity, generator's name and EPA identification number, and warning against hazardous disposal).

§         Understand the information and data included on Material Safety Data Sheets (MSDS), and its application.

§       Be proficient in the use and selection of personal protective equipment (PPE).

§    Have knowledge of site safety planning.