What you don't know can hurt! Reducing hazardous waste liability through the prudent use of audits

The liabilities and cleanup costs associated with the transportation, treatment, storage, and disposal of hazardous wastes can be significant, frequently costing millions of dollars. Many examples exist, some of which are documented in the paper. The costs are covered under two classifications: removal actions and remedial actions. Removal actions are those taken to provide immediate protection to the public or the environment. This might include fencing in the area, providing alternate water supplies, or providing temporary housing. Remedial actions are those required to treat the site and to provide permanent solutions. The distribution of liabilities for these costs are generally allocated to all companies or parties involved in the problem including the generators. The factors that have been used in making "fair share allocations" are: a. The ability of each party to distinguish their contribution to the problem, b. The amount of waste involved, c. The degree of toxicity of the hazardous waste involved, d. The degree of involvement in the generation, transportation, treatment, storage, or disposal of the hazardous waste, e. The care exercised by each party, f. And, the cooperation given to Federal, State, and local officials should a problem arise. This paper describes the approach taken by Plasma Physics Laboratory (PPPL) of Princeton University to protect itself and the Department of Energy and reduce future liabilities and costs. This protection is achieved through the prudent use of audits of the hazardous waste transporters and treatment, storage, and disposal facilities used by PPPL. These audits increase PPPL's confidence level that our hazardous wastes are properly managed, demonstrate a level of involvement and care by PPPL, and can serve as legal evidence should problems later occur to demonstrate that PPPL was prudent. Finally, the paper documents the lessons learned of this process.