Innovative approaches – superior solutions.
Ron Harvey’s engagements have afforded an opportunity to innovate, design and implement outstanding solutions, produce unmatched results and to deliver true strategic and competitive advantages.
I. Waste Management Compliance Program Development
The Customer: Advanced Environmental Solutions, Inc., Belen, New Mexico
The Challenge: This startup environmental services company needed to lay the groundwork for a small hazardous waste facility. Noteworthy challenges were to convince the State of New Mexico issue an authorization to receive hazardous waste, and allow the implementation of arcane regulations, allowing them to receive hazardous waste without a full permit. The State was reluctant to because a similar authorization was issued to another company previously and they abused it, and were shut down.
Our Approach: We decided to take advantage of federal rules for fully permitted facilities and adapt them for a smaller facility via a Best Practices approach. Secondly, we elected to develop a waste and facility management plan for the State Environment Department, and then ask for authorization to operate under the specific conditions of the cited regulation.
The Solution: Detailed, task-oriented procedures that met the key requirements of 40 CFR 265 for waste consolidation, segregation, storage, transportation and disposal were enacted. Waste sampling, analysis and characterization routines were established and emergency procedures were developed. All Environmental, Health and Safety requirements were met and all employees were trained. Additionally, transportation contracts with carriers were established in accordance with acceptable criteria.
The Results: Within three weeks of the initial meetings with the state regulators, a Letter of Authorization was issued to the company and they launched the company. This was only the second authorization of this type issued by the State. Ron Harvey’s efforts and presentation overcame the challenges and the company is operating under this authorization over 10 years later.
II. Transportation Compliance Review
The Customer: GEL Laboratories, Charleston, South Carolina
The Challenge: They had an enormous number of waste types (about 20, most companies have 1 to 5) different waste streams and there had never been a systemic review to ensure compliance with DOT requirements. The training requirements were outdated or missing. Several return copies of hazardous waste manifests were missing.
Our Approach: We developed a company-wide review and identification of the chemical makeup of all waste types, the volume of each waste, and comparison with accepted and Best Practices packaging, labeling and shipping requirements. It was deemed critical to discover which wastes could be consolidated in order to reduce shipping costs. Moreover, a review of the training requirements for employees handling the waste was deemed prudent.
The Solution: Every waste-generating process was inspected and wastes identified, and questionable wastes were sampled for testing. The files for all waste shipments were examined to ensure that document record keeping was consistent with DOT requirements. Numerous unapparent and subtle deficiencies were identified. Using the test results, we determined, for each waste: the hazard class and packing group, proper shipping name, packaging requirements and labeling and marking requirements. A Master Shipping Log was developed to track shipments and record keeping protocols were enhanced. Missing documents were recovered. A task schedule was developed and those employees who met the definition of a “HazMat Employee” were assigned a training level requirement.
The Results: The result was a fully compliant HazMat transportation program that ensured all DOT requirements were met. Several compliance deficiencies were corrected which could have resulted in fines, associated problems in the company’s operations and long term vitality.
III. Air Shipment of Dangerous Goods
The Customer: Guala Distributing, Italy with offices in Mount Pleasant, SC and Monclova, OH.
The Challenge: This was a contract for international air shipment of product samples that were dangerous goods and shipped to testing facilities in Europe and Central America. The samples were often presented in containers that were not suitable for proper packaging, and moreover, had never been classified for air shipment.
Our Approach: Ron Harvey determined that every sample needed to be individually evaluated to determine its chemical and physical properties. After material classification, each sample needed to be evaluated against air shipment volume limitations. Furthermore, for each shipment of samples, we needed to ensure that the packages, labeling and documentation conform to IATA requirements for air shipment of dangerous goods.
The Solution: A worksheet was developed that compassed all possible shipping classes. The MSDS for the material was used to complete the worksheet and classify the material. Selection of a proper shipping name gave the volume limits per cargo and passenger aircraft shipments. The sample was then packaged, labeled, documented (from the IATA Guidebook associated UN Number) and could then be shipped to the correct destination. A logistics methodology was also developed to cut the amount of time the samples waited for clearance by customs.
The Results: Ron’s methodology cut the time the shipment was in customs by almost 50%. Quicker arrival of samples allowed the client to obtain test results faster, and close more deals per unit of time, significantly increasing cash flow. Due to our diligence, no shipments have ever been refused for improper packaging or documentation and all shipments have been completed without incident.
IV. Waste Minimization
The Customer: GEL Laboratories, Charleston, South Carolina.
The Challenge: This analytical laboratory wanted to maintain its status of a Small Quantity Generator of Hazardous Waste, to avoid the tenfold increase in state fees and additional regulatory burdens imposed upon Large Quantity Generators. The monthly volume of waste being generated by the lab was within just a few hundred pounds of the upper limit of 2200 lbs. The laboratory technicians did not have a thorough grasp of waste generating processes and could not find ways to reduce waste volumes; moreover, there were numerous types of wastes, which added to the complexity of the problem.
Our Approach: Each existing waste stream needed to be identified, classified and measured. Compiling a list of wastes would then allow us to distinguish non-hazardous from hazardous wastes and categorize them according to EPA requirements. The regulatory status of some of the waste types were unclear, so confirmatory analytical tests needed to be performed. Also, the different types of wastes were so numerous that consolidation of wastes was unavoidable. In some lab areas that generated waste, a collection container needed to be set up and the lab personnel trained on the placement of different wastes into the proper containers which could then be consolidated into larger containers.
The Solution: We designed a comprehensive methodology for waste segregation, multiple lab wash methods and more. Each worker in the labs who generated waste was instructed on the importance of keeping their wastes separated, maintenance of their waste containers, and communicating with the waste manager when a new waste stream is encountered.
Client’s Results: After implementing Ron’s recommendations and process changes in their hazardous waste management program, the laboratory cut hazardous waste generation by 50% – from close to 2000 pounds of hazardous waste per month to approximately 1000 pounds per month. This was well within the Small Quantity Generator limits, resulting in significant cost savings and increased operational efficiencies.
V. OSHA Compliance, Personnel Protection &Training
The Customer: Advanced Environmental Solutions, Albuquerque, New Mexico
The Challenge: This startup environmental services company had no established Employee Safety and Health program, and needed to develop and implement all required plans and training prior to start of business operations. Moreover, each employee’s duties engendered exposure to unique and variable chemical and physical hazards.
Our Approach: Ron Harvey interviewed the company owner to determine all possible health and safety scenarios, and applied OSHA regulations and common sense solutions to mitigate anticipated hazards associated with each position. Pursuant to this, we needed to develop programs for the specifically identified hazards, and then designate and train an individual to both continuously monitor the safety of personnel and provide job hazard analyses.
Our Solution: In order to fully provide for employee safety and to protect the business from accident-related risks, written programs for many OSHA requirements were established including emergency response, confined space and respiratory protection. We also authored a customized 40-hour HAZWOPER training program for all operations emergency personnel. Standard Operating Procedures for all hazardous waste operations at the facility, including liquid waste consolidation and lab pack preparation were produced. A selection of Personal Protective Equipment (PPE) was placed in stock for all potential job hazards.
Client’s Results: The business was opened on of schedule, and all OSHA required programs were in place, all equipment was installed and ready for operation and all employees were trained. This enabled the business to pursue rapid and sustainable growth.
VI. Radioactive & Mixed Waste Program Compliance.
The Customer: GEL Laboratories, Charleston, South Carolina
The Challenge: The mission-critical initiative was to control all aspects needed to properly manage radioactive and mixed waste, from generation to disposal. A key problem was that radioactive waste consisted of only 15% of the waste generated by the lab, but consumed 80% of the waste management budget. Furthermore, the expanded capture of mixed waste resulted in more waste streams that were not clearly delineated. Also, the chemical constituents of the neutralized radioactive wastewater were poorly monitored.
Our Approach: Ron Harvey determined that the Radioactive Waste Program needed to be top-down assessed and re-built from the bottom up. The generation of radioactive PCB’s needed to be closely examined because of the high cost of disposal cost – up to $25,000 per drum. Each waste stream needed to be scrutinized, tested for chemical and radiological constituents, and classified, and consolidation and segregation schemes needed to be developed and implemented. Consolidation and segregation schemes needed to be developed and implemented to control waste movement and reduce disposal costs.
Our Solution: A comprehensive Radioactive Waste Program was developed. Key initiatives included developing processes to separate radioactive PCB oils from contact waters. Segregation of tritium/carbon 14 scintillation vials from other radioactive isotopes was intensified. Processes for testing waste streams to accurately classify them according to DOT, EPA and NRC requirements were put in place, as was a sampling and testing protocol for neutralized radioactive wastewaters to confirm disposal status. Many other components of the program were designed and were mutually supportive and internally consistent.
The Results: This program reduced the waste generation of radioactive PCBs by 75% – from about four drums per year to about one drum per year. Mixed waste consolidation operations were modified, disposal outlets established, and existing waste profiles were adapted. New ways were put in place to automatically calculate isotopic concentrations for wastes that varied greatly with every drum. The waste management for this facility was inspected twice by the Department of Energy Compliance Assessment Team, and no findings or deficiencies were discovered. Moreover, Standard Operating Procedures ensured the safe and efficient management of radioactive and mixed waste.
VII. Fully Compliant Hazardous Waste Management
The Customer: GEL Laboratories, Charleston, South Carolina
The Challenge: This analytical laboratory had dozens of instruments and numerous procedures that generated various wastes, and a process needed to be developed to review all aspects of hazardous and non-hazardous waste generation and handling. Simply put, the waste management process needed to be brought under control.
Our Approach: It was clear to us that all laboratory managers and technicians needed to be interviewed to minimize bias and identify every waste-generating process. The character of these wastes needed to be identified and cataloged, and consistent management plans were needed to design and implement the best possible solution.
The Solution: We compiled a detailed list of wastes generated by every single process in the laboratory, including waste accumulation, waste testing, characterization and documentation. The regulatory status of each waste was identified and handling methods for each waste from each lab were developed. We also instituted standardized treatment and handling protocols for all personnel in the waste management department, and trained all personnel on the proper handling techniques for the various wastes.
The Results: Several opportunities were identified for consolidation of wastes, adaptation of procedures, and application of other techniques to reduce costs. A buyer was identified for one solvent waste stream that was previously shipped for disposal, creating additional cash flow. Ron’s efforts kept the lab from becoming a large quantity generator and increased waste management efficiencies. The waste management for this facility was inspected twice by the Department of Energy Compliance Assessment Team and no findings or deficiencies were discovered.