Business Objective

A chemical manufacturing facility provides a host of specialty chemical products for commercial, industrial and agricultural clients. The facility is located in close proximity to residences and other sensitive receptors, with increased oversight from both the public and environmental agencies. Our client identified its hazardous waste compliance program as a key performance indicator, and turned to ALG to optimize and refine this program to assure ongoing compliance with both federal and state regulatory program.

Technical Approach

To meet our client’s objectives, ALG implemented a phased approach. First, we confirmed that all individual waste streams were properly characterized This technical analysis included reviews of Safety Data Sheets (SDS), prior laboratory analysis, and additional testing to assure that all waste characterizations were accurate and defensible. Once complete, ALG submitted Solid Waste Registration requests and individual waste stream codes through the State of Texas Environmental Electronic Reporting System (STEERS), which are electronically approved by the state and documented within the STEERS system for the client’s ongoing use.

In the second phase of the project, acting as an authorized agent, ALG reviewed generated waste volumes and validate waste generator classification within the state’s hazardous waste compliance database. This analysis allowed our client to streamline reporting under the state’s hazardous waste program. Finally, we developed customized compliance tools for ongoing monitoring, recordkeeping and reporting and trained our client’s compliance staff on proper use of these tools.

Results

As a result of ALG’s hazardous waste optimization program, our client can now document that all waste streams are properly characterized under both state and federal hazardous waste control programs. This allows for clear and transparent communication agency staff and public. Our strategic compliance analysis provides for reduced recordkeeping and reporting, and the new compliance tools have been fully integrated into our client’s ongoing operation and maintenance programs. Taken together, ALG’s hazardous waste optimization program has reduced overall compliance costs with enhanced performance, assuring our client’s management that the plant will continue to meet this key performance indicator.