Responsible party

The responsible party and associated regulatory responsibility to generate a hazardous waste manifest. 

Some sites are easy to elassify due to their inehision on the National Priorities List (NPL), state superfund, or other regulatory list. In other eases, debate ean and does arise to determine if a site should be treated as hazardous. Eor example, some sites eommonly referred to as brown fields have eontamination levels that are eonsidered low. Sometimes levels of eontamination are so low that exposure levels to workers do not reaeh aetion levels or permissible exposure levels (PEL). Some firms have ehosen to treat low-level eontaminated sites as if they fell under HAZWOPER requirements. This is a somewhat eonservative approaeh whieh provides a eomfort faetor for management and potentially responsible parties (PRP) or other entities. 

Site C s SSAHP elearly stated that safety and health requirements deseribed in the plan apply only to the employees of the prime eontrae-tor and subeontraetor, and to visitors under the direet eontrol of the eontraetor. As a result, the SSAHP did not eover other individuals on site sueh as EPA personnel state and loeal government personnel or employees, representatives, or eontraetors of the Potentially Responsible Party (PRP). 

Make responsible parties pay for these cleanups wherever possible... 

Following the implementation of the remedy, the state or the potentially responsible party (PRP) assumes responsibility for the operation and maintenance (O M) of the site, which may include activities such as groundwater pump and treat, and cap maintenance. Once U.S. EPA has determined that all appropriate response actions have been taken and cleanup goals have been achieved, the site is deleted from the NPL through a formal rulemaking process. 

Cleanup costs exceed the coverage requirements of the financially responsible party. 

After Action Report A post-incident analysis report gathered by a responsible party or responding agency after termination of a hazardous materials incident, describing actions taken, materials involved, impacts and similar information. 

Potentially Responsible Party (PRP) An individual or company identified by EPA as potentially liable under CERCLA for cleanup costs at a hazardous waste site. PRPs may include generators of hazardous substances, present or former owners of hazardous substances that have been disposed, site property owners, and transporters of hazardous materials to the site. 

Strict Liability The responsible party is liable even though they have exercised reasonable care. 

In the first place, PSM and RMP require that all responsible parties survey their industrial complexes where covered chemical processes are employed and to closely scrutinize these processes to determine if any of the 130+ Highly Hazardous Chemicals listed in OSHA s PSM and/or if any of the 140+ Extremely Hazardous Substances listed in USEPA s RMP are stored, handled, used, or produced on-site (e.g., off-gases, etc.). 

The central purpose of CERCLA is to provide a response mechanism for cleanup of any hazardous substance released, such as an accidental spill, or of a threatened release of a hazardous substance (Nordin et al., 1995). Section 102 of CERCLA is a catchall provision because it requires regulations to establish that quantity of any hazardous substance the release of which shall be reported pursuant to Section 103 of CERCLA. Thus, under CERCLA, the list of potentially responsible parties (PRPs) can include all direct and indirect culpable parties who have either released a hazardous substance or violated any statutory provision. In addition, responsible private parties are liable for cleanup actions and/or costs as... 

The Oil Pollution Act (OPA) of 1990 streamlined and strengthened the EPA s ability to prevent and respond to catastrophic oil spills. A trust fund financed by a tax on oil is available to clean up spills when the responsible party is incapable or... 

CERCLA established prohibitions and requirements concerning closed and abandoned hazardous waste sites provided for liabUity of persons responsible for releases of hazardous waste at these sites and established a trust fund to provide for cleanup when no responsible party could be identified. 

Certain cost items that were site specific, project specific, or the responsibilities of the site owner/responsible party were excluded from the estimate. These include the following ... 

Costs that are assumed to be the obligation of the responsible party or site owner are not included in the estimate. These costs are site-specific and include ... 

The treatment cost to remediate 20,000 tons of contaminated soil using a 10-tph VRU is estimated to be 137 per ton, if the system is online 90% of the time. Treatment costs increase as the online factor decreases. Projected unit costs for a smaller site (10,000 tons of contaminated soil) are 171 per ton projected unit costs for a larger site (200,000 tons) are 106 per ton for a 10-tph VRU and 72 per ton for a 100-tph VRU. These costs do not include site preparation, permits, regulatory requirements, monitoring, waste disposal, sampling and analysis, or posttreatment restoration, which are considered to be the obligation of the responsible party or site owner. Also not included in these estimates is profit on the part of the vendor (D10056R, pp. 16, 24). 

If an excursion occurs above an action level, as a minimum, one or more of the following action may include, but not be limited to, investigative action, corrective action, and/or informing responsible parties (Table 3). 

The audits are conducted according to the checklist. The audit program includes time frame, area, and concerned responsible parties. 

The general audit of the housekeeping is performed every six months. The findings are documented and the responsible parties are informed to initiate corrective actions. 

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