"The company has indicated…

"The company has indicated they can treat a wide variety of contaminants and that they conduct feasibility testing prior to treatment”. It’s exactly the issue my client's have brought up to me. What can these guys treat, what process do they follow and what is the final disposal results of the treated soils? Is it treatment to Land Disposal Restrictions?

A review of the current ECA does not clarify any of these questions. Yet, we are not allowed to see the Design Operations Pan because it is marked confidential.

Based on the ECA one can interpret the Hazardous Leachate toxic waste streams can include everything from Dioxin and Furan’s, Pesticides, BTEX, Metals, PAH’s etc. without having to demonstrate to the Approvals Branch they can technically show treatment to comply with Schedule 1 limits or Land Disposal Restrictions (LDR) for ALL CONTAMINATES BEING TREATED. I am shocked to see this wide range of approval without specific processes being evaluated individually. I recall Waste Management Branch in this e days being very Limtied as to processes they agreed with.

Specific details were required to be filed before the Ministry would consider approving any treatment process or methodology. Also any Hazardous waste classes had to be spelled out in the application and they ALWAYS appeared on the face of the ECA and formerly C of A’s.

My clients have come to me asking how this wide range ECA was issued without specific treatment methods applied to specific waste classes. Case in point, recent project they received as confirmed even by District office was PCB sediments requiring stabilization before treatment of the PCB. The District would not divulge process used being used treatment. This information should clearly appear on the face of the ECA, waste class should be show for the Treatment Conditions 9, 10 and 11, previously numbered 27, 28 and 29 incorrectly.

Condition 11: The Hot Box process shall be carried out in accordance with the following:
The heating of soil, using a natural gas burner, in a metal box to a temperature not
to exceed 100 Celsius
Associated fans, ventilation and gas collection systems.
The Hot Box shall be operated in accordance with the Environmental Compliance
Approval (Air) for the unit.
What waste classes is this ECA going to allow treatment using this method? Where is the Air Permit ECA? Why is the company allowed to receive any waste stream treatable under this condition if the final approval ECA ( Air) has not been issued? The EPA clearly states no person shall construct a waste facility without first obtaining an ECA and then only in accordance with eh ECA conditions.
This ECA has a lot of hidden information on what waste cases or specific contaminates can be treated under Condition 9, using PhysChemBio, Condition 10 Stabilization and Condition 11 The Hot Box Process process which should appear on the face of the ECA so the general public, waste professionals, consultants and prospective clients can conduct a prior due diligence before they consider using this site services. No one is asking fo their detailed process description that maybe confidential but as it reads this ECA is difficult to review and understand what waste stream,ms they treat under Conditions 9, 10 and 11.
The District office would NOT DISCLOSE WASTE CLASSES that are treatable under this ECA specific conditions and to what levels are they required to treat? It is assumed to be Land Disposal Restriction levels in O. Regulation 347?
The majority of ECA's are always issued with respective waste classes that can be treated and to what level of treatment before land disposal is allowed.