Arvada, Colorado June 8, 2016 source
The Environmental Daily Advisor reported that there are 7 RCRA Violations That Can Send a Range Owner to Jail and the #1 reason is one that should cause major concern. If the contractor chosen “transports hazardous waste to a non-permitted facility,” the range is held responsible.
The range manager must ask the contractor how they would be handling the lead waste or if the lead recycling facility they took the lead to, is properly permitted.
Range owners must always maintain on-site written records of the Lead and Contaminated Waste Disposition!
When these violations come up, there may also be the additional consequence of an enforcement action for costly cleanup and remediation including regulatory fines and penalties. Recent firing range environmental cases and projects have shown that a typical OSHA or EPA regulatory fine is in the range of $250,000-$500,000. Additionally, when the EPA has to step in, range cleanups with their oversight involved can be in the $5,000,000-$8,000,000 range.
When dealing with the environmental hazards of lead, the range cannot assign the risk away, they always retain significant liability and risk for their waste, the range owner or operator is the generator of lead-impacted waste.
There are 5 critical validations range owners must demand from a lead reclamation contractor to protect themselves and their range:
- Contractor must be able to document, with audited financials, sufficient company assets that could allow it to sustain defending a claim or actual violation without going bankrupt.
(Suggested is minimum $500,000 and preferred is $1,000,000)
- Comprehensive insurance package:
· Minimum $5Million General AND Pollution Liability. Pollution Liability is the only coverage for lead and hazardous materials.
· Recent Certificate of Insurance and range named as additionally insured and include Worker’s Comp and auto liability.
- Comprehensive contract with FULL owner-indemnification to protect and defend against all contractor activities and a list of prior regulatory agency violations, fines or penalties from any Agency.
Minimum 5 years (preferably 10 years) of continuous operating history with business registrations with minimum 5 prior similar projects successfully completed in the last 3 years. Comprehensive written work and safety/health plans specific to the range and a detailed waste-management plan describing actual activities to occur, and providing certification for all transport and disposal. Do NOT take the contractor’s word for it. Get it in writing.
“We are proud to provide these critical range owner protections when submitting our complete bid when requested,” stated James Barthel, MT2 CEO.
· MT2 is the Leading Nationwide Professional Lead Reclamation Contractor for BOTH Indoor & Outdoor Firing Ranges.
· MT2’s patented ECOBOND® lead treatment technology, prior EPA approved, has been used on over 10 Million tons of waste. It provides a unique solution eliminating the need to generate hazardous waste, saving money and minimizing range owner liability.
· MT2, as the Nation’s leading provider of environmental and maintenance firing range services, has served approximately 1,000 public and private indoor and outdoor firing ranges for military, law enforcement and municipalities nationwide in all 50 States since 2000. MT2 is committed to protecting law enforcement officers who protect and serve our communities.
· MT2 carries $8,000,000 of General AND Lead Pollution Liability & Worker’s Comp Insurance
Over the past decade, MT2 has recycled over 12 MILLION tons of lead, returning over $4,000,000 dollars to ranges owners without a single regulatory violation, while working closely with range owners to implement firing range Best Management Practices (BMPs).
MT2’s proven record of firing range services include: complete range maintenance & improvements, lead remediation services, lead reclamation, OSHA & environmental consulting, operational maintenance and range closure. MT2’s zero-tolerance for regulatory violations gives range owners the peace of mind that their project will be successfully completed on a guaranteed schedule.
No one can complete a firing range lead reclamation project quicker and safer than MT2.