Regulatory Compliance Solid waste permits

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A new facility which will generate solid wastes, or liquid wastes that cannot bedirectlydischarged to an outside watertreatmentfacility or under an NPDES permit, may face additionalregulatory requirements. To the Venture Manager, it is paramount that licensed waste disposal outlets are found for the proper handling,treatment, and disposal of wastes. before the new process begins operation and the wasteis, in fact. generated. While this obligation may appear too obvious to even mention. finding such outlets can prove difficult and time consuming. This will require a characterization of the waste, providing samples (from pilot or laboratory work) to the potential outlets for their analysis and for the outlets to secure permission a n d o r permits from their regulatory authority in order to legally receive and treat the waste. If the wastes to be generated are "hazardous" as defined by the US ResourceConservation and RecoveryAct, permits mayberequired of the generator, the Owner of the new process, to legally generate, treat, store, or dispose of thenewwastes. Thiscan add considerable length tothe permitting process andtoadministrative and engineering costs. Waste management issues (and waste minimization obligations) should be carefullyconsidered, as theyare equallyimportant as are airand water matters. Environmental impact studies Occasionally, a project may involve movement of facilities into "protected" areas, i.e.,wetlands. These projects mayinvolvethesubmissionof an Environmental Impact Study. This can be extremely costly and time consuming and could involve:

- Endangered species impacts, flora and fauna. - Protection of migratorybirds. - Surface andground water studies.
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Set back requirements from protected areas or surface waters.

- Anything else covered by the environmental regulations.

If this study is required, it must be identified as early as possible. Projects been known to have been held up years by this process. have