Cross Media Inspections of Solid Waste Facilities Jerry Henderson CDPHE Solid Waste and Material Management Unit

Compliance Inspection vs. Compliance Assistance  Compliance inspections: CRS gives the Department inspection authority. Violations trigger enforcement process Depending on severity or recalcitrance, violations can lead to formal compliance order or litigation  Compliance assistance site visit To provide you with help understanding the regulations To suggest steps for improved compliance

Solid Waste Inspections  FY 2007: 174 inspections performed  Landfills, transfer stations, asbestos, tire monofills, remediation sites, composting  Overall compliance rate – 75%  Landfills, transfer stations > 75%  Composters, impoundments +/- 50%

Cross Media Compliance Inspections  Air Pollution Control Division & Solid Waste -Primarily Landfills to date  Hazardous Waste & Solid Waste -Complaint Driven  Local Health Depts. / Code Enforcement & Solid Waste -Complaints & Solid Waste Facilities  COGCC and Solid Waste: Drilling mud / fluids

Background on Cross Media Compliance Assistance at CDPHE  2003: CDPHE created cross media compliance assistance workgroup  Goals:  Improved customer service  Improved efficiency  Engage in sector-based projects to achieve outcomes greater than regulatory compliance: -Auto Salvage Sector, Correctional Facilities

Cross Media Compliance Assistance  Air, Stormwater and Solid Waste (or Air & Solid Waste)  Onsite assistance provided to operators in understanding and implementing the regulations  Work in cooperative mode to identify what’s going well, what needs improvement  Identify and correct problems outside of enforcement process

Benefits to Compliance Assistance  Efficiency  Training  Chance to self-correct deficiencies outside of the enforcement process  More collaborative than compliance inspection  Better prepared for compliance inspection

Challenges to Implementing the Cross Media Approach  Coordination of inspector schedules  Longer site visit required, more resource burden  Reluctance to share information, requires trust

Ideas for Overcoming Challenges  Always announced  Point out what facility is doing well  Solution oriented  Enforcement amnesty  Approach from a partnering standpoint, 2-way dialogue  Send out inspection checklist in advance  Increase familiarity with quarterly outreach meetings

Future Directions for Compliance Inspections / Assistance  Regional multi-media compliance assistance: Find host sites and invite other operators in the surrounding area  Self-certification Program: Compliance assistance prepares operators for self-audit  Sign up sheet