Statement of Qualifications (PDF 683 KB)

Swan Hills Treatment Centre Operated by Earth Tech Canada Inc. Statement of Qualifications 2TABLE OF CONTENTS 1.0 EXECUTIVE SUMMARY.................................................................................................. 3 1.1 INTRODUCTION ............................................................................................................................. 3 2.0 SWAN HILLS TREATMENT CENTRE - TECHNOLOGY AND OPERATIONS ........ 4 2.1 SWAN HILLS TREATMENT CENTRE OVERVIEW......................................................................... 4 2.2 TREATMENT UNITS ........................................................................................................................ 5 2.2.1 Ford Bacon Davis (FBD) Incinerator System .....................................................................................5 2.2.2 Physical/Chemical Treatment..............................................................................................................7 2.2.3 Stabilization/Solidification ..................................................................................................................7 2.3 WASTE RECEIVING, STORAGE AND PREPARATION ................................................................. 8 2.3.1 Waste Receiving..................................................................................................................................8 2.3.2 Waste Storage......................................................................................................................................9 2.3.2.1 Drummed Waste Storage....................................................................................................9 2.3.2.2 Bulk Waste Storage ............................................................................................................9 2.3.3 Waste Preparation..............................................................................................................................10 2.3.3.1 Drummed Liquids.............................................................................................................11 2.3.3.2 Bulk Liquids .....................................................................................................................11 2.3.3.3 Drummed and Bulk Sludges .............................................................................................11 2.3.3.4 Drummed and Bulk Solids................................................................................................12 2.3.3.5 Direct Feed Solids and Liquids.........................................................................................12 2.3.3.6 Lab Packs..........................................................................................................................12 2.4 RESIDUE MANAGEMENT ............................................................................................................ 12 2.4.1 Liquid Residues.................................................................................................................................12 2.4.2 Solid Residues ...................................................................................................................................13 2.5 LABORATORY ................................................................................................................................ 13 3.0 ENVIRONMENT, HEALTH AND SAFETY.................................................................. 15 3.1 OPERATING APPROVAL .............................................................................................................. 15 3.2 MONITORING ................................................................................................................................ 15 3.3 HEALTH AND SAFETY.................................................................................................................. 16 3.4 PROCESS SAFETY AND RISK MANAGEMENT PROGRAMS ..................................................... 17 3.5 ENVIRONMENTAL MANAGEMENT SYSTEM ............................................................................. 18 3.6 STAKEHOLDER CONSULTATION ............................................................................................... 19 3.7 REGULATORY AFFAIRS ............................................................................................................... 19 3.8 FACILITY CLOSURE AND REMEDIATION ................................................................................. 20 • 31.0 EXECUTIVE SUMMARY 1.1 INTRODUCTION The Swan Hills Treatment Centre (Treatment Centre) is located near Swan Hills, Alberta, Canada. This fully integrated hazardous waste treatment and disposal facility has been in operation since 1987 and is capable of handling all hazardous wastes on-site with the exception of radioactive and explosive wastes. The facility is owned by Alberta Infrastructure, a division of the Government of Alberta, and Earth Tech Canada Inc. (Earth Tech) is the long-term operator. Earth Tech provides a “cradle-to-grave” approach as all wastes are sent to and treated at one site. Treatment options available at the Treatment Centre include High Temperature Incineration, Stabilization/Solidification and Physical/Chemical Treatment. A $100 million expansion in 1994 increased the Treatment Centre's treatment capacity and infrastructure to handle wastes. The nominal treatment capacity is 55,000 metric tonnes per year including 40,000 metric tonnes per year of incineration capacity. Solid treatment residues, rendered non-hazardous, are placed into a secure on-site landfill. Liquid non-hazardous residues are injected into an on-site deep well. All required analysis is performed in a full-service, on-site laboratory. The Treatment Centre can handle solids, liquids and sludges in drummed and bulk form employing systems for waste receiving, preparation, storage and tracking. On-site storage includes 1133 cubic metres of bulk liquid storage, a 700 cubic metre bulk solids pit and 17,000 drum spaces in various storage buildings. The commitment of the Treatment Centre to health, safety and protection of the environment is reflected in the programs in place for Health and Safety, Process Safety and Risk Management and the Environmental Management System. The Treatment Centre eliminates environmental liability completely. The Alberta Provincial Government assumes long-term liability for the site and is responsible for site closure, decommissioning and long-term monitoring of the landfill cells. 42.0 SWAN HILLS TREATMENT CENTRE - TECHNOLOGY AND OPERATIONS 2.1 SWAN HILLS TREATMENT CENTRE OVERVIEW The Treatment Centre is an integrated hazardous waste management facility located near the town of Swan Hills, Alberta. The 320 acre site is approximately 250 kilometres northwest of Edmonton in the province of Alberta. The legal description of the facility’s location is NW ¼ - 36 – 67 - W5M. The geology of the area features a native clay base, 10-15 metres (33-49 feet) thick, at the surface. The clay possesses an extremely low level of hydraulic conductivity (<10-7 cm/sec), allowing liquids to be contained on the surface, rather than migrating into groundwater. The facility was built on a dish-shaped surface to prevent the run-off of surface water which is collected in engineered ponds and used as process water. A fence to exclude wildlife and trespassers encloses the processing areas and the secure landfill cell area which represents 80 acres of the total 320-acre site. The Treatment Centre is designed and permitted to accept and treat all forms of hazardous waste, with the exception of radioactive, explosive and bio-hazardous wastes and is the only incineration facility in Canada currently permitted to dispose of Ozone Depleting Substances (ODS) and all forms of PCB wastes. The term “integrated” reflects the facility’s capability to treat waste with multiple hazardous characteristics, such as waste with both organic and inorganic attributes. This multi-step, integrated nature of the facility eliminates sending treatment residues off-site. Treatment residues from any process are analyzed to confirm the material has been rendered non-hazardous. The non-hazardous solid residue is placed in a secure landfill cell built into the clay base and lined with high-density polyethylene (HDPE) that is rated for the placement of hazardous waste. Liquid residues are also verified to meet non-hazardous criteria and then injected into a stable geological formation approximately 1800 metres (5,900 feet) below grade. This approach of treating the waste to reach a non-hazardous state, and then placing in containment rated for material of a hazardous nature allows Earth Tech to assume 5complete liability for the waste treatment process, including ALL residues, providing “cradle-to-grave” liability protection. This elimination of generator’s liability is backstopped by the Provincial Government of Alberta, where upon closure of a landfill cell, the ownership is transferred to the Provincial Government. The facility comprises three treatment units: • High Temperature Incineration – for the destruction of organic wastes (liquids, sludges and solids). Examples include wastes contaminated with PCBs, PCPs, dioxins and furans, air and water reactive materials and odorous materials. • Physical/Chemical Treatment – for the treatment of inorganic liquid wastes. Examples include acids, bases and heavy metal-bearing liquids. • Stabilization/Solidification - for the treatment of inorganic solid wastes. Solid residues from the above processes are treated here if required. This plant can also receive solid inorganic-contaminated waste direct from generators. Examples include heavy metal-contaminated soil and filter cake wastes. Other systems exist to support these three treatment processes. Support systems include waste receiving, waste storage, waste preparation, residue management, management of site run-off water, utilities, and analytical laboratory services. Qualified personnel provide support services including equipment maintenance, occupational health and safety, engineering, information technology, training, laboratory services, equipment and reagents inventory, and business administration. 2.2 TREATMENT UNITS 2.2.1 Incineration – Ford Bacon Davis (FBD) Incinerator System Two incinerator systems exist on the facility site. The primary system is the 35 megawatt rotary kiln designed and built by Ford, Bacon &Davis (FBD) of Utah. The smaller system called the C.E. Raymond is currently not in service. The FBD Rotary Kiln Incinerator System has a nominal treatment capacity of 40,000 metric tonnes per year of hazardous wastes. The kiln has inside dimensions of 4.4 metres diameter by 12 metres long. It is capable of handling bulk and drummed solids, aqueous and organic liquids and ODS using various feed systems, which permit their simultaneous introduction. 6The following describes the FBD Rotary Kiln incineration process: • Bulk or drummed liquids are transferred to an organic liquid tank farm and then injected either directly into the kiln or into the vertical secondary combustion chamber. • Air and/or water reactive wastes and ODS are injected into the kiln via a direct feed system. • Sludges are fed into the kiln via a sludge system that can handle both bulk and drummed wastes. • Bulk and drummed solids are transferred into a 700 cubic metre enclosed pit. Solid material is typically shredded before being fed into the kiln via a clamshell crane system. • Non-shreddable solids and other special wastes such as reactive and odorous solid wastes are directly fed into the kiln in drums. • Wastes are processed in the rotary kiln (primary combustion chamber) at temperatures of 800°C to 1,200°C (1,500°F - 2200°F). All organic compounds are volatilized and many compounds are destroyed at this stage. • The flue gases continue to the secondary combustion chamber where temperatures of 1,200°C (2,200°F) and a residence time of two to three seconds destroy any remaining persistent organic compounds such as PCBs and reduce them to basic elements. • The flue gases pass through a pollution control system that removes acid gases and solid particles before being discharged into the atmosphere. This system includes a spray drier, baghouse, activated carbon injection system, quench chamber/saturator, two packed bed condenser/absorber towers in parallel, a venturi collision scrubber, induced draft fan and fibreglass-reinforced plastic exhaust stack with a full complement of exhaust monitoring analyzers (O2, CO2, CO, NOx, SO2, HCL and THC). The entire system is maintained under slight negative pressure to ensure any leakage will be into, and not out of, the incineration system. • The rotating, inclined kiln directs treated ash or slag from the discharge end into collection bins. • The treatment residues are tested and further processed in the stabilization/solidification facility if required, before final placement in the secure landfill. • Annual compliance testing of the system demonstrates that 99.999999% (“8-nines”) Destruction and Removal Efficiency (DRE) is typically achieved, exceeding the regulatory requirement of 99.9999% DRE. 72.2.1 Physical/Chemical Treatment This treatment unit has a nominal capacity of 5,000 metric tonnes per year. Inorganic liquids (acids, alkalis, and heavy metal-bearing fluids) are chemically neutralized in two reactors. One reactor is used for treatment of alkalis, and the other for acids and cyanides. General facility processes include neutralization, oxidation/reduction and precipitation. The following describes these processes: • In neutralization, or pH control, reagent acids or bases (often waste materials themselves) are added to a waste stream to create neutral salt solutions. • With chemical oxidation/reduction techniques, appropriate oxidizing and reducing agents are added to a waste stream to convert hazardous components into less toxic substances. • Precipitation, a common result of the neutralization process, can be expedited by using chemical flocculation techniques to separate solids from the liquid component of a solution. Heavy metals are typically precipitated through pH control. • The solid/liquid mixtures from the above processes are passed through a filter press that separates the two phases. • The resulting liquid (water) is analyzed and further treated, if required, before being injected into an on-site deep well. • The filter cake is transferred to the Stabilization/Solidification facility for further processing. 2.2.2 Stabilization/Solidification The Stabilization/Solidification treatment unit has a nominal capacity of 10,000 metric tonnes per year. Inorganic heavy metal-bearing solids are chemically bound and solidified in a pozzolanic blend using waste-specific recipes. This chemical treatment ensures that hazardous constituents will not leach into the environment. Each recipe is tested with samples sent prior to delivery and subjected to the Toxicity Characteristic Leaching 8Procedures (TCLP) to determine the recipe’s effectiveness. The TCLP is also applied to treated waste before placement into the secure landfill. Any batches failing this test are reprocessed. This treatment consists of the following processes: • Waste materials are processed with appropriate chemical reagents in a high-speed mixer in batches according to a predetermined treatment recipe. • Samples are taken and subjected to TCLP analysis to ensure successful treatment. • The resulting cement-like slurry is discharged from the mixer and transported to the secure landfill cell for final placement. • Fugitive emission control of dust is provided by a dust collection system drawing from strategic locations in process areas. • The dusts are removed from the air stream in a wet scrubber, and the resulting clean air is discharged into the atmosphere. The liquid scrubber blowdown is reused in stabilization process or sent to the waste water plant. 2.3 WASTE RECEIVING, STORAGE AND PREPARATION 2.3.1 Waste Receiving Access to the Treatment Centre is via a paved road designated as a Dangerous Goods route. Therefore, all waste is delivered to the site via truck. Earth Tech can accept hazardous wastes in both bulk (tanker or end-dump truck) and packaged (drums, sling bags and boxes) form. Prior to acceptance of waste at the facility, the generator must complete a Waste Profile Sheet (WPS) and submit a representative waste sample to Earth Tech to determine acceptability, physical characteristics and treatment methods. Earth Tech incorporates the information from the WPS into its comprehensive, electronic Waste Management System (WMS), which contains all characteristic and analytical information for each waste. WPS information is also reviewed by the Health and Safety Coordinator to identify proper personal protective equipment and any special handling procedures for operators. The WMS and its chemical composition data are utilized by operations staff to develop treatment recipes in the appropriate treatment process. Established recipes are indexed to WPS numbers to facilitate creation of batches for processing. New batches are developed and tested internally before wastes with new WPS numbers are accepted on-site. 9 The waste is checked upon arrival against the manifest to verify quantities. Each waste container is bar-coded and scanned into the WMS. The bar-code allows tracking of the container from arrival and with each movement within the facility until final treatment/destruction. Each drum is visually inspected internally and externally and 10% of drums are sampled to ensure compliance. A probe is inserted into bung-type drums to confirm liquid content. Bulk shipments are also sampled and held until a “fingerprint” analysis is completed, which confirms that the waste compares to the sample submitted with the WPS. 2.3.2 Waste Storage 2.3.2.1 Drummed Waste Storage Drummed waste is stored on-site to optimize processing efficiency. A total of approximately 17,000 drum spaces are available at the Treatment Centre. Storage buildings are designed to meet fire and safety regulations and are complete with: • Spill containment • Foam and/or water fire suppression systems • Strategically placed fire hydrants • Carbon adsorption air management systems 2.3.2.2 Bulk Waste Storage Earth Tech is capable of receiving bulk shipments of hazardous waste and storing the wastes until they are processed. Solids Bulk solid organic wastes are received within the FBD receiving building and held in an enclosed 700 cubic metre pit capable of receiving end-dump truckloads of solid wastes. Liquids A total of 1133 cubic metres (300,000 US gallons) of bulk liquid storage capacity is available at the Treatment Centre. Storage is divided into two areas that have the following capacities: 10Organic Liquids – 1000 cubic metres (265,000 US gallons) Inorganic Liquids – 133 cubic metres (35,000 US gallons) Organic Liquids are stored in various carbon steel tanks located in the Organic Tank Farm which features a bermed concrete pad and spill containment sump, piping and valve system, filters, agitators, heaters and pumps. The complex valve arrangement allows this area to receive liquids from the Decant Area, FBD Sludge System, Physical/Chemical plant, sump system, and from the off-loading of tanker trucks. This configuration also allows for transfer between tanks and feeding to the incinerators by means of a batch process as directed by the Feed Menu Planner. All organic liquid storage tanks have a vapour recovery system and are blanketed with nitrogen to provide an inert atmosphere in the headspace of the tanks. Fire protection is provided by strategically located fire hydrants. Inorganic liquids are stored in various corrosion resistant tanks totaling 133 cubic meters (35,000 US gallons) located in the Physical/Chemical building. The building provides bermed spill containment complete with sump collection. All tanks are blanketed with nitrogen gas. Sludges Bulk Organic sludges are received and stored in a 25 cubic metre (6,600 US gallon) sludge receiving tank. The material in this tank is then transferred to a 25 cubic metre sludge-mixing tank to prepare for processing. 2.3.3 Waste Preparation Earth Tech receives waste in various forms that must be prepared in batches in order to feed these wastes through the required treatment processes. Solid wastes are fed into the kiln in a batch process controlled by the Feed Menu Planner. Wastes with appropriate characteristics, such as heating value, are selected and processed together. Similarly, liquids are batched in the Organic Tank Farm and fed into the kiln. The following sections describe this preparation of wastes. 112.3.3.1 Drummed Liquids Drums of organic liquid are taken out of storage and moved to the drum decanting building. Organic liquid waste is decanted from the drums by diaphragm pumps into the Organic Tank Farm. Personnel perform the decanting procedure wearing appropriate safety equipment, working under fume hoods to capture fugitive emissions. Any vapours captured by the fume hoods are directed to a carbon adsorption system to remove hazardous constituents prior to venting to the atmosphere. As an additional precaution, the entire drum decanting building is maintained under a slight negative pressure to prevent leakage. Building air is directed to a carbon adsorption system prior to venting to the outside air. Inorganic liquids are decanted using diaphragm pumps located within the Physical/Chemical treatment unit. 2.3.3.2 Bulk Liquids Bulk organic liquids received by tanker truck are delivered to the Organic Tank Farm and mixed according to a planned waste menu set by the Feed Menu Planner to optimize the operation of the incinerator. The organic tank farm vessels are equipped with agitation and heating capability to allow mixing and viscosity control. Bulk inorganic liquids received by tanker truck are off-loaded into tanks at the Physical/Chemical facility and processed by a predetermined treatment method. 2.3.3.3 Drummed and Bulk Sludges Drums of organic sludge are delivered to the incineration building roller conveyor system and directed to an enclosed nitrogen-blanketed system, which punctures each drum individually. A 200 tonne press then extrudes the sludge contents into a sludge-receiving tank. The pressed, empty steel drum bodies are discharged to the bulk solids receiving pit. The sludge receiving tank also accepts bulk loads of sludge delivered to the facility by tanker or vacuum truck. The bulk sludge mixing tank contains an internal mechanical mixer and has the capability for solvent addition to modify viscosity. A positive displacement pump moves material to the sludge lance of the incinerator. Inorganic sludges are processed at the Physical/Chemical facility. 12 2.3.3.4 Drummed and Bulk Solids Bulk loads of solid waste contaminated with organic compounds, and empty flattened steel drums from the sludge extrusion system are placed in the bulk solids receiving pit. This receiving pit also accepts whole steel drums or sling bags of shreddable solid waste. A crane-operated clamshell continually picks up solid waste from the floor of the pit and places the material into a shredder, which discharges back into the pit. This process maintains the material in the solids receiving pit in a well-mixed state for consistency in composition and size. The mixed material is ultimately placed on the apron feeder for incineration. Inorganic drummed solids are transferred to the Stabilization/Solidification facility for processing. 2.3.3.5 Direct Feed Solids and Liquids The Treatment Centre receives solid and liquid waste in drums, which may be incompatible with other wastes. Drummed solid wastes are introduced directly to the incinerator via a Direct Solids Feed conveyor. Similarly, drummed liquids can be decanted into a small mobile nitrogen-blanketed tank and pumped through a Direct Feed System to a liquid burner. Reactive liquids such as aluminum alkyls that are shipped in pressure vessels may be processed directly from these vessels through the Direct Feed System from the Direct Burn Pad. 2.3.3.6 Lab Packs Lab packs of both inorganic and organic wastes are removed from their shipping container within a dedicated area. Chemical technicians sort lab pack contents and ensure only compatible materials are mixed and bulked. Once the waste has been segregated and re-packaged, the wastes are sent to the appropriate processing unit for treatment. 2.4 RESIDUE MANAGEMENT 2.4.1 Liquid Residues Residue from the Physical/Chemical operation can be in the form of liquids or solids. The liquid residue is held in quarantine until analytical clearance is obtained and then injected into an on-site deep well into a geological formation at a depth of 1800 metres (5,900 feet). Hazardous liquids are not disposed in the deep well, only treated water is injected into this formation. 132.4.2 Solid Residues Solid residue from the incineration system consists of bottom ash or slag from the rotary kiln and salts and flyash from the incinerator scrubbing system. Bottom ash or slag is held in quarantine pending analysis for the landfill criteria to demonstrate that the material is non-hazardous in nature. If the residue fails the criteria, it is re-processed either through the incinerator (exceeding organic criteria) or through Stabilization/Solidification (heavy metal excursions). Compliant solid residues are then placed into a secure landfill cell. The spray dryer salt and the baghouse flyash from the incineration system typically contain leachable metals in excess of regulatory levels and therefore require further treatment. The salt/flyash is mixed with water to remove the soluble salt fraction. The insoluble fraction of the salt/flyash/water mixture is separated from the liquid by a belt filter press. The resulting saltwater fraction is held for laboratory clearance and then disposed in the deep well. The resulting filter cake is once again subjected to analytical procedures to determine if further treatment is required. Filter cake, which complies with the inorganic analytical criteria, is placed in the secure landfill cell. Each secure landfill cell is built into the native clay base and has a multi-layer containment barrier, which includes two HDPE liners as well as protective geotextile and geogrid layers. Above the HDPE liners is a leachate collection system consisting of a sump and piping system allowing for the extraction of liquid leachate, should it accumulate. A leachate monitoring system is located between the two HDPE liners to check for leaks. All leachate is collected and analyzed to ensure compliance. Once filled and closed, the monitoring and ownership of the landfill cell transfers to the Alberta Government as described in the Facility Closure and Remediation section. 2.5 LABORATORY A comprehensive analytical laboratory is staffed by on-site personnel to provide analytical services for both the on-going operation of the facility and for the analysis of samples provided by clients when profiling new wastes. The laboratory has the capability to perform detailed organic and inorganic analyses with a variety of equipment including GCECD, ICP, GCMS and AAS. Analytical results are subjected to an internal QA/QC review. 14Our laboratory is accredited by the Canadian Association for Environmental Analytical Laboratories (CAEAL), to ISO/IEC 17025 for specific tests. The laboratory also routinely participates in “round robin” analytical checks with Analytical Products Group, for inorganic analysis and Environmental Resource Associates for organic analysis and has placed in the top ten compared to environmental labs across North America. Waste samples are submitted to the laboratory by sales staff to characterize potential waste streams, identify treatment methods and determine costs. This analytical and financial information is recorded on the Waste Management System. Samples of waste received at the facility are submitted by Operations staff for “fingerprint” analysis to ensure that the waste delivered matches the characteristics of what was contracted to be delivered. Surcharges are applied to “non-compliant” waste streams. Operations staff also submits samples of batches of blended waste for menu planning. Finally, Operations personnel submit samples of waste residues to ensure that the treatment has been successful in rendering the waste non-hazardous. 153.0 ENVIRONMENT, HEALTH AND SAFETY The following sections outline key components of the environment, health and safety programs in effect for the Treatment Centre. 3.1 OPERATING APPROVAL Hazardous waste management is a provincial regulatory responsibility in Canada. Earth Tech has obtained a new 10-year Operating Approval issued by Alberta Environment on November 30, 2005 which will expire on November 1, 2015 (Approval number 1744-02-00). This Approval is final and all regulatory permitting requirements have been met. Operation of the Treatment Centre’s disposal well, which is used for the injection of treated liquid effluent and excess contained surface water, is approved by the Alberta Energy and Utilities Board (EUB), (Approval No. 7742). The EUB maintains regulatory control over all subsurface activities in the province of Alberta. The Treatment Centre is authorized to accept, store and treat all classes of hazardous waste. Exceptions include explosive and radioactive materials that fall under federal jurisdiction. Requirements for operation, including incinerator operating parameters, emission limits, landfill criteria, monthly and annual monitoring and reporting requirements are clearly presented in the comprehensive Approval. Operators are required to report all excursions from approved operating parameters immediately to Alberta Environment. These reports are phoned in and a written follow-up is required to be filed with the department within seven days. Earth Tech takes its reporting requirements very seriously and reports all potential excursions promptly. Alberta Environment defines an excursion as any deviation from the requirements set out in the Approval. Consequently, there are numerous excursions reported annually. Most of these are very minor in nature including such items as missed environmental samples (generally caused by a power outage or sampler failure and spills (including any amount of certain wastes). Earth Tech reports all excursions and tracks its response through the internal Environmental Management System. All incident reports are maintained by the Environmental department and quarterly reviews are conducted to close all completed incident investigations. 3.2 MONITORING Earth Tech and predecessor operators have maintained a very comprehensive monitoring program at the Treatment Centre. The program is likely the most extensive environmental monitoring effort conducted at an industrial facility in North America. 16The program was initiated in 1985, two years prior to commencing operation of the Treatment Centre. The original scope was developed with the assistance of the Alberta Special Waste Management Corporation, Alberta Environmental Protection, Alberta Research Council and input from environmental experts. The program was initially developed to act as an “early warning system” designed to identify potential environmental concerns associated with the operation of the Treatment Centre. The program has been enhanced over the years and functions as an ongoing evaluation of the environmental performance of the Treatment Centre. The program includes, in addition to direct monitoring of waste processes, monitoring of: • Air Quality • Water Quality – surface and ground water • Soils • Vegetation • Fish • Wildlife In addition, a toxicological assessment is conducted annually on the results. As many as 40 sites are included in the annual monitoring program. Most sites are located in the immediate vicinity of the Treatment Centre. Background and regional monitoring sites are located at distances up to 45 kilometres from the facility. Monitoring results are made available to a wide range of regional stakeholders including the Town of Swan Hills, the Swan Hills Special Waste Liaison Committee, First Nations, Metis, Trappers Association and regional communities and rural municipalities. Program is reviewed annually with stakeholders and Alberta Environment. 3.3 HEALTH AND SAFETY Earth Tech is committed to providing a safe and healthy work environment for its employees. To achieve this, the Treatment Centre has a dedicated Health and Safety Department, reporting to the Manager, Environment, Health and Safety. Safety is the responsibility of all employees, following the requirements set out in the facility’s Safety Manual. The facility measures its safety performance and has a safety performance recognition program. 17Significant effort is also placed on contamination control and worker protection under the Industrial Hygiene Program. A medical monitoring program is in place and Earth Tech employs an Occupational Physician to conduct annual examinations of all operations, maintenance and laboratory staff. Specific guidelines have been established for exposure to certain chemicals (e.g. PCBs) and programs are in place to address personal exposure levels. Earth Tech employs a training program for new employees and ongoing safety training for all staff. Strict personal protective equipment (PPE) requirements exist to minimize potential health hazards. Training programs include training in applicable regulations, company policies, permit or license obligations including a general sense of environmental awareness, health, safety, first aid, emergency response, mobile equipment driver training, contractor safety, operating procedures and materials handling. A first aid room and a fully-equipped ambulance are on-site in case of emergencies. Appropriate PPE is provided to all personnel, contractors and visitors. Eye wash stations and showers are strategically located throughout the site. 3.4 PROCESS SAFETY AND RISK MANAGEMENT PROGRAMS A comprehensive Process Safety and Risk Management (RM) program has been implemented at the Treatment Centre. The program was designed using the DuPont model and meets Occupational Safety and Health Administration (OSHA) requirements for a RM program in the United States. In the United States, companies handling chemicals similar to those treated at the Treatment Centre are required to have a RM program in place that meets OSHA requirements. The province of Alberta does not yet make RM programs mandatory. The program is a set of documented systems that define the roles and responsibilities of key personnel and the requirements for the system. Each element of the program describes how work is done at the facility. The systems are integrated into day-to-day operations of the facility and are the responsibility of the functional teams. The elements include: • Process Hazards Analysis – Systems used to methodically identify, evaluate, and control hazards in the process. 18• Operating Procedures – Documents that describe how processes are operated and the physical operating parameters. • Management of Change – A system to provide hazards and operability review and authorization of changes to physical process, equipment and procedures. • Mechanical Integrity - A comprehensive maintenance program which ensures that the soundness of the process equipment is maintained throughout the life of the facility. • Training and Performance – A program to provide initial and refresher training to established standards, and to enable employees to recognize and deal with cases of “diminished capacity” to perform jobs safely. • Contractor Safety – A system to ensure that all tasks completed by contractors are performed in accordance with established procedures and/or safe work practices consistent with good Process Safety and Risk Management principles. • Incident Investigation – A method to continuously improve safety performance by aggressively and persistently investigating all serious and potentially serious incidents. • Emergency Planning and Response – A system to provide in-depth planning and preparation that ensures effective response in emergency situations to mitigate the impact on people and the environment. • Occupational Health and Safety (OH&S) – A comprehensive program that addresses occupational health practices and monitoring, personal safety practices, safety equipment, record keeping, safety training and education. • Public Participation - Letting the public know about the risks to their communities or the environment of our business activities (facilities and transportation) and encouraging discussion about those risks. • Environmental Management System (EMS) - An integrated, systematic management framework that encompasses all environmental programs and procedures. The EMS defines all that Earth Tech does to protect the environment and meet regulatory requirements. • Waste Analysis Plan – A document that defines all of the criteria and procedures for identification and management of waste at the Treatment Centre. 3.5 ENVIRONMENTAL MANAGEMENT SYSTEM Earth Tech follows the EMS implemented by the previous operator based on the ISO 14000 framework incorporating the following key elements: • Environmental Policy • Planning • Implementation and Operation • Monitoring and Corrective Action 19• Management Review The EMS was initially developed in 1995 and is currently being further revised to better meet the finalized standard and internal requirements. Some of the individual components of the EMS were developed as early as 1985. The EMS documents all facility environmental programs and establishes specific procedures for meeting environmental responsibilities. A key feature of the EMS is an “Environmental Responsibilities Database” that documents all individual environmental responsibilities and tasks necessary to meet regulatory obligations. Position responsibility summaries are generated each month and distributed to all affected staff. 3.6 STAKEHOLDER CONSULTATION The Treatment Centre has a unique history, being the first facility of its type sited through a voluntary process in North America. Earth Tech works hard to maintain its relationships with key regional stakeholders to preserve the public trust inherent in the original siting process. To ensure effective communication with regional stakeholders, Earth Tech conducts the following; • Swan Hills Town Council – Earth Tech meets monthly with Council and provides operational updates and addresses any issues. Earth Tech holds special meetings with Council to review annual monitoring results and provides resources for an independent review of the program for the Town. • Swan Hills Special Waste Liaison Committee – The Liaison Committee is comprised of volunteer members from the Swan Hills community and auxiliary members from regional municipalities. Meetings are held monthly and all aspects of operations and environmental monitoring are shared. The Liaison Committee functions to identify community issues related to facility operation and help communicate responses. The Liaison Committee tours the facility regularly and is involved in the review of annual environmental monitoring results. These programs have resulted in an open and trusting relationship with the Town of Swan Hills and regional stakeholders. 3.7 REGULATORY AFFAIRS Earth Tech’s operations are under the direct regulatory control of Alberta Environment. In addition, Environment Canada has jurisdiction over specific components of the 20operation through the Canadian Environmental Protection Act (CEPA) and its regulations. Areas of federal jurisdiction include storage of PCBs and release reporting for any releases of “Toxic Substances” defined under CEPA. Earth Tech communicates with regulatory agencies on a regular basis and maintains good working relationships with them. Alberta Environment maintains an Inspector in Swan Hills and routine weekly inspections of the facility are conducted. In addition, monthly meetings with the Regional Director and key staff are hosted at the facility. Earth Tech also meets with Environment Canada on a regular basis to ensure there are no outstanding regulatory issues relating to the operation of the Treatment Centre. 3.8 FACILITY CLOSURE AND REMEDIATION The Treatment Centre was originally developed to ensure that treatment capability and capacity was available to treat all Alberta-generated hazardous waste. As part of its role in establishing the system, the government is responsible for site closure, decommissioning and long term monitoring of the landfill cells. Earth Tech’s responsibility for remediation is limited to proven damage caused by the breach of applicable statutes, regulations, approvals and government orders and directions while operating the Treatment Centre. Ownership of the Treatment Centre’s landfill cells belongs to the Alberta Government. The Treatment Centre initially operated small (6000 cubic metre) capacity, in-ground secure cells. A total of seven cells of this design were constructed, five of which have been closed and are now owned and monitored by the Alberta Government.