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					     GUIDANCE MANUAL
   FOR FACILITY OWNERS,
 COMPLETERS AND VERIFIERS


           VERSION 2

  For Use with the Waste Facility
Environmental Review (Revision 2 B)




             October 1999
Waste Facility Environmental Review                                                       October 1999
Guidance Manual Version 2                                                                       Page i


                                             Foreword

Thank you for participating in the Waste Facility Environmental Review (WFER) Program.
Introduced in 1997, WFER has demonstrated its value as a thorough and systematic data
collection system for waste facility assessments. Both waste generators and facility owners alike
appreciate the consistent, objective format and its adaptability to virtually any waste facility risk
assessment, or marketing tool.

This guidance manual is intended as an aid to those completing the WFER protocol. As you
complete and verify your WFER, please remember that the WFER questions themselves are not
a test or a direct measure of performance. WFER is not an audit in which findings are compared
directly to performance, design standards, or individual company assessment criteria. Each
prospective waste generator/client will have his or her own set of criteria to rate the facility and
its operating practices. Honest, candid and un-opinionated responses will make their own
internal evaluation programs much easier to complete than working with some one else‟s
interpretation of acceptable or unacceptable criteria. Responses should be descriptive “painting a
full picture of the facility”.

About WCAR:

The Western Canadian Auditing Roundtable (WCAR) is an ad-hoc committee comprising
western Canadian companies with an interest focus on environmental auditing. Companies
representing the petroleum industry, utilities, mining, and manufacturing developed the WFER
form as their primary data acquisition tool for waste facility assessments. To-date, over
40 companies across Canada have endorsed and use WFER. Please access the WCAR web-site
www.wcar.org to view a complete listing of companies that have endorsed WFER and waste
facilities that have completed their WFERs. This document and the WFER Protocol can be
downloaded from the WCAR website.

NOTE: Acceptance of a completed WFER to the WCAR web-site registry does not constitute an
      endorsement of any waste facility by WCAR.




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Waste Facility Environmental Review                                                      October 1999
Guidance Manual Version 2                                                                      Page ii


                                          SUMMARY

The Waste Facility Environmental Review (WFER) is a voluntary, systematic WFER, which
describes the setting, design, operation, and risk management practices of a waste facility.
Though its primary function is to provide prospective clients of the facility with sufficient
information to conduct a risk assessment/environmental audit, WFER has also provided
numerous other benefits to owner/operators of waste facilities. For example:

   Use as a reference document for permit, licence and approval applications;

   Release as a compendium of information (or sections of information) for public relations;

   Submission to financial institutions and insurers for the purposes of establishing lines of
    credit, financial assurance or liability insurance;

   Internal use by facility employees for general information;

   Release as marketing information; and

   Improve practices while completing the document and from feedback from potential
    customers.




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Waste Facility Environmental Review                                                                                           October 1999
Guidance Manual Version 2                                                                                                          Page iii


                                                   TABLE OF CONTENTS

                                                                                                                                      Page

SUMMARY .................................................................................................................................... i

A)        INTRODUCTION......................................................................................................... A-1
B)        FACILITY OWNER’S GUIDANCE ...........................................................................B-1
C)        WFER COMPLETER’S GUIDANCE ....................................................................... C-1

1.0       WASTE FACILITY INFORMATION ........................................................................... 1
2.0       EXISTING DOCUMENTATION ................................................................................... 1
3.0       REGULATORY AFFAIRS.............................................................................................. 3
          3.1 Permits, Licences and Approvals ............................................................................ 4
          3.2 Regulatory Liaison .................................................................................................. 5
          3.3 Permit Requirements ............................................................................................... 5
              3.3.1       Scope of Operations Allowed by Permits, Licences or Approvals ....... 5
              3.3.2       Storage .................................................................................................. 5
              3.3.3       Permitted Emissions/Discharges ........................................................... 5
              3.3.4       Regulatory Status .................................................................................. 6
          3.4 Environmental Monitoring Requirements and Results ........................................... 6
          3.5 Regulatory Monitoring............................................................................................ 7
          3.6 Violations ................................................................................................................ 7
4.0       FACILITY DESIGN ......................................................................................................... 7
               4.1.1        Current Disposal and/or Recovery Options .......................................... 7
               4.1.2        Historic Company Operations............................................................... 8
               4.1.3        Future Operations.................................................................................. 8
          4.2  Subcontracted/Off-Site Facilities ............................................................................ 8
          4.3  Landfills .................................................................................................................. 9
          4.4  Biodegradation ...................................................................................................... 10
          4.5  Surface Impoundments ......................................................................................... 10
          4.6  Thermal Treatment................................................................................................ 11
          4.7  Injection Wells ...................................................................................................... 12
          4.8  Waste Storage ....................................................................................................... 12
          4.9  Processing of Recyclables..................................................................................... 13
          4.10 Waste Treatment/Processing ................................................................................. 13
          4.11 Transportation ....................................................................................................... 14
          4.12 Other On-Site Operations ..................................................................................... 15
5.0       FACILITY OPERATIONS ........................................................................................... 15
          5.1  Waste Confirmation and Quality Control ............................................................. 15
          5.2  Change Management Process ............................................................................... 16
          5.3  Site Security .......................................................................................................... 16
          5.4  Worker Safety ....................................................................................................... 17


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Guidance Manual Version 2                                                                                                          Page iv


        5.5       Worker Experience and Training .......................................................................... 17
        5.6       Contractor Management........................................................................................ 17
        5.7       Self Inspection and Environmental Risk Management ......................................... 17
        5.8       Release Prevention and Emergency Management ................................................ 18
        5.9       Fire Safety ............................................................................................................. 18
        5.10      Ancillary Operations ............................................................................................. 19
6.0     FACILITY FINANCIAL AND INSURANCE AFFAIRS........................................... 19
        6.1  Finances ................................................................................................................ 19
        6.2  Closure Plans ........................................................................................................ 19
        6.3  Insurance ............................................................................................................... 20
        6.4  Waste Ownership .................................................................................................. 20
7.0     ENVIRONMENTAL SETTING ................................................................................... 20
        7.4  Surface Water........................................................................................................ 20
             7.4.2      Stormwater Management .................................................................... 21
             7.4.3      Process Effluent Discharge ................................................................. 21
             7.4.4      Off-Site Surface Water Monitoring .................................................... 21
             7.4.5      Surface Water Impacts ........................................................................ 21
        7.5  Groundwater ......................................................................................................... 22
             7.5.1      Groundwater Characterization ............................................................ 22
             7.5.2      Groundwater Monitoring .................................................................... 22
             7.5.3      Groundwater Impacts .......................................................................... 22
        7.6  Air Quality ............................................................................................................ 22
             7.6.1      Air Quality Monitoring and Emissions ............................................... 22
             7.6.2      Air Quality Impacts............................................................................. 23
        7.7  Surficial Geology, Soils and Vegetation ............................................................... 23
             7.7.1      Surficial Geology and Soils Characterization ..................................... 23
             7.7.2      Soil Monitoring ................................................................................... 23
             7.7.3      Soil Impacts ........................................................................................ 23
             7.7.4      Vegetation Characterization................................................................ 23
        7.8  Reportable Releases .............................................................................................. 23
        7.9  Off-Site Monitoring .............................................................................................. 24
        7.10 Remediation Requirements ................................................................................... 24
8.0     WFER REVALIDATION .............................................................................................. 24

D)      VERIFIER’S GUIDANCE........................................................................................... D-1


                                                        APPENDICES

APPENDIX A              CEAA Code of Ethics
APPENDIX B              WFER Working Papers
APPENDIX C              Provincial Compliance Tracking Information




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Waste Facility Environmental Review                                              October 1999
Guidance Manual Version 2                                                            Page A-1




A) INTRODUCTION
The WFER is designed to provide information that will help identify and describe compliance,
management systems and areas of risk. Although waste generators will use WFER to compare to
their own criteria, WFER itself does not include any evaluation criteria or performance
yardsticks. A properly completed WFER should be the first steps in meeting the assessment
requirements of any interested party. By providing complete and unbiased responses, your
WFER will reduce the amount of time required to address facility risk assessments by
prospective clients.

The original WFER document was developed from facility audit checklists, formerly employed
by member companies of the Western Canadian Auditing Roundtable (WCAR).

Version 1 was released after a series of trials on three different waste facilities. The current
document, Version 2, incorporated comments from various industry stakeholders and private
verifiers after one-year of Version 1 use. This document has been endorsed by over
45 companies, (as of August 1999).

The WFER is designed to address the most common environmental considerations with respect
to a waste facility. It does not address every conceivable environmental issue or management
practice. In addition, a facility may have unique aspects, which are not addressed in the WFER.
It remains to the discretion of the generator as to what additional information is important for
their internal purposes. The document is intended for use as a basic tool, and must not be
substituted for common sense and good judgment on the part of the generator.

Although there is no regulatory obligation for waste facilities to provide the information
requested, waste generators may require a completed WFER as a condition of their contract for
services. Customer-oriented facilities will initiate the WFER proactively to satisfy existing
customers and help attract new ones. They may also use the information provided by the review
process to help improve their own operations and facilities.

The WFER involves three parties:

   the generator – the party that will use the information provided by the review to make a
    judgment on the suitability of a waste facility for subsequent use;

   the waste facility owner – the waste receiver, transporter or broker that is subject of the
    review; and

   the verifier – an independent third party that confirms the accuracy of the information
    provided in the WFER.

This guidance manual describes the various components of a WFER, the expected roles and
responsibilities of each party and the procedures to be followed in completing, verifying and
using the WFER.


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Guidance Manual Version 2                                                              Page B-1




B) FACILITY OWNER’S GUIDANCE

a) The WFER Process

The typical WFER process and the parties responsible for each step of the process are depicted in
Figure B-1 and described below.

Initiation of the process is intended to be the responsibility of the waste facility owner. A
proactive facility will initiate the process voluntarily so that it can maximize the marketing
advantages of having completed the process. The generator who wants to have the process
completed prior to using a facility‟s services, may make completion of a WFER a condition for
use of a facility.

b) Acquire a Registered WFER

The WFER document can be downloaded free-of-charge from the WCAR website
(http://www.wcar.org). Companies and individuals acquiring WFER are asked to provide
information on an on-line form. This information will be used to track WFER users and set up
distribution lists for updates to the WFER program. The most recent version of this guidance
manual will also be available for downloading at this site. NOTE: if this manual does not
address all questions about WFER, immediate assistance can be obtained from the WFER Help
Desk at 403-235-8138 8:00 am to 5:00 pm (mountain time).

c) Data Entry into the WFER

The next step is the entry of information into the WFER. Usually the initial data entry completed
by the facility operator or other staff, as this is the most cost-effective approach. It is acceptable,
however, to have the third party verifier complete all of the information and perform verification
simultaneously.

Section C of this manual provides instruction and guidance to complete the WFER.

d) Verification of the WFER

Once the data entry is complete, the waste facility will contact a verifier to provide independent
confirmation of the completeness and accuracy of the information contained in the WFER.
Typically, the verifier will be a qualified environmental professional who is registered with a
recognized professional association (i.e., professional engineers, biologists, certified
environmental auditors, etc.). The waste facility is well - advised to select the verifier carefully,
as the subsequent perception of the validity of the verification will be influenced by the
reputation of the selected firm or individual. Discrepancies within the like found by prospective
clients may also influence the waste generators‟ decision to use the facility




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Figure B-1
                                      The WFER Process

Process Element                                              Responsibility

         Initiation                                          Waste Facility Owner
                                                             (see Guidance Manual Section B)

      Completion of                                          Waste Facility
       Document                                              (see Guidance Manual Section C)


      Verification of                                        Verifer
       Document                                              (see Guidance Manual Section D)


   Document Control
     and Issuance                                            Verifier and Waste Facility Owner


       Use of the                                            Waste Generator
   Verified Document

      WFER Review                                            Western Canada
          and                                                Auditing Roundtable
      Improvement




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WCAR strongly recommends that verification of the WFER form should be completed by an
individual or organization with a strong background in environmental management,
environmental auditing and/or risk assessment. In particular, individuals who are certified or
have a professional designation (i.e., CEA, P. Eng. P. Biol.) from an organization, which has an
enforceable code of conduct available in the event of unsatisfactory performance, are
recommended.

The following criteria should be considered when selecting a verifier for your WFER:

   Established history of quality service;
   Expertise in waste management;
   Knowledge of local conditions and sensitivities;
   Expertise in environmental auditing and site assessment; and
   Reputation of integrity.

Section C of this manual contains detailed information for the verifier.

Initiation consists of acquiring a WFER package from the authorized distributor.

e) Document Control and Issuance

Document control is necessary to ensure the integrity of the WFER information after its
verification. The following document controls have been specified by WCAR:

   A completed, signed-off original copy and working papers must be held in the files of the
    verifier.

   Copies for issuance must be individually stamped or marked as official copies by the verifier
    using colored ink with signatures/initials affixed to each page.

   If issued by the verifier, copies should be released only with written authorization from the
    waste facility.

   Copies will not be issued after their expiry date.

The WFER document must be updated every three years. WFER will also be considered expired
if here have been significant changes in operations at the facility before the three-year term has
passed. Examples of significant changes would include, but are not limited to:

   addition of a waste management process not described on the existing WFER;
   expansion of operations not addressed in the existing WFER;
   significant changes to operating procedures or equipment;
   closure of a portion of the facility;
   changes in the ownership or the operator of the facility; or
   major regulatory enforcement action affecting the facility.


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It is acceptable to release the WFER with minor updates and amendments that have been verified
by an independent verifier. These changes are usually introduced as an attachment to the WFER
with references to the original sections. The original section should include a notation from the
verifier indicating that the sections have been updated. If the facility owner chooses to
implement only minor changes, the original expiry date of the document will not be affected. If,
however, the facility owner opts to have the entire WFER re-verified, the WFER will remain
valid for three years as of the re-verification date.




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C) WFER COMPLETER’S GUIDANCE
The WFER comprises 10 sections. Sections 1 through 7 contain the main body of information
that is generally completed by the facility operator and confirmed by the verifier. Section 8
contains the Validation portion of the WFER signed off by the facility owner and the verifier
while Section 9 is an attachment of key documents and records that support information in the
WFER.

Guidance to complete specific portions of Sections 1 through 7 is offered here. Please note that
self-explanatory questions contained in the WFER are not reviewed in this guidance manual. If
there are sections that are not adequately explained either in the WFER directly, please contact
the WFER Help Desk at 403-235-8138.

DECLARATION
The person responsible for completing WFER information must read the Guidance Manual and
sign the Declaration at the beginning of the WFER document.

1.0      WASTE FACILITY INFORMATION
Section 1 provides general information about the facility including:

     the name and address of the facility;

     the contacts for the facility (NOTE: the primary contact(s) to obtain further information
      about the facility should be listed first);

     directions to arrive at the facility from the closest populated centre;

     legal land description; and

     ownership of property

(Other arrangements could include facilities that are owned by one company or individual, but
operated by an independent company under the owner‟s approval, permit, or licence. Provide
documentation to the verifier regarding the operator‟s agreement with the facility owner).


2.0      EXISTING DOCUMENTATION
The table in section 2 is a checklist of documents and records that will be used by the verifier to
confirm information in the WFER.




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1. Make copies of any available items marked with an asterisk (*). These copies must be
   appended to the WFER as Section 9. NOTE THAT ALL LICENCES, APPROVALS AND
   PERMITS MUST BE ATTACHED.

2. Assemble all of the requested available items for inspection by the verifier (NOTE: it is
   always helpful if the requested items can be arranged in piles according to the major
   headings listed in the checklist.

3. Note any requested data, which is not available by checking the N/Avail column.

4. Provide the reference information for each document. If the document is a permit, approval
   or licence, please indicate the issuing agency. For reports and company documents, please
   identify the author (person or company).

5. If the document has an expiry or validity date, please indicate that date in the “Date of
   Expiration/Issue” column. Otherwise, indicate the date the document was issued. Please
   also note any dates of revision to the document in this column (i.e., revised 1992, 1996,
   1998).

6. Identify the location(s) where the document or record is kept. If the facility and head office
   are in the same location, both “Head Office” and “Facility” columns may be checked.

7. Insert any other relevant document titles under the appropriate heading

8. Remember to check all attached documents in the right-hand column. (This step can be left
   to the final document assembly process, to ensure that all required documentation is
   included).

SPECIAL NOTES:

Insurance Certificates

   Attach the most recent copies of insurance certificates. The certificates should indicate the
    term of coverage (effective date to expiry date), type(s) of insurance provided (i.e., general
    liability, automotive, environmental impairment, design exposure liability, etc.).

ISO 14001, ISO 9000

   If the facility is registered with the International Organization for Standardization for
    ISO 14001 (Environmental Management Systems), or ISO 9000 (Quality Control), please
    indicate the registration numbers for each system. If the facility has alternate environmental
    management and/or quality control systems, please reference them in the section for “Plans
    and Procedures”.




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Regulatory Inspections

     Indicate the most recent inspection certificates or report issued by the Provincial
      Environmental Ministry, Environment Canada, Fire Marshall, or any other regulatory board.

Standard Operating Procedures

     Attach only the table of contents or index to the operating procedures.

Compliance Tracking (History) Reports

     Compliance tracking reports are to be obtained by the verifier and attached to the WFER (see
      Manual Section 8).

Health and Safety Records

     Indicate the period covered by the facility health and safety records in the Expiry/Issue Date
      column.

     Identify the origin of the records (i.e., First Aid Log, Workers‟ Compensation Board Claims,
      Health and Safety Files).

Training Records

     Indicate the period covered by the facility training records in the Expiry/Issue Date column.

Facility Layout and/or Other Descriptive Material

     Attach a layout diagram for the facility or some other narrative to describe the structures and
      equipment located on the site. This information can be taken from the facilities standard
      marketing literature.


3.0      REGULATORY AFFAIRS
General

This section identifies the operating approval permit and/or licence requirements and conditions,
key regulatory contacts, and reviews the compliance history of the facility. Monitoring
requirements required by the regulatory authorities are also summarized in this section.

Please note from Section 3 to Section 7 inclusive, responses in the WFER will require references
to supporting documentation or other evidence. The supporting evidence for the statements
contained in the WFER must be accessible to the verifier. Some of the documents and records
forming part of the supporting evidence will be found in the Table in Section 2 of the WFER



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(existing documentation). In general, examples of documents and records that may be used as
supporting evidence beyond the Section 2 table will include:

     written policies, procedures and work instructions;
     job descriptions;
     employee training requirements;
     file indices;
     contracts; and
     business plans.

Types of records reviewed may include:

     reports from previous audits, reviews, other environmental studies and previous WFERS;
     monitoring records;
     inspection records;
     reports sent to the government;
     file correspondence with regulatory agencies;
     routine internal operational reports;
     insurance certificates;
     records of public complaints or inquiries;
     employee training records;
     environmental and health and safety compliance databases from provincial agencies; and
     internal environmental files.

3.1       Permits, Licences and Approvals

     Ensure that all documents, which certify, register, licence, or grant approval to perform an
      activity are identified in this section.

     Reference # refers to any registration or serial number on the document.

     Remember to consider and include documents issued from all levels of regulatory bodies
      including:

         Federal agencies;
         Provincial departments and agencies;
         Municipal or district councils;
         Industry boards (i.e., Natural Resources Conservation Board, Energy and Utilities Board,
          International Organization for Standardization).

         Indicate “Not Applicable” in the Expiry Date column if the document does not have an
          expiry date.




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        In the space provided, identify any of the documents or registrations that are currently in
         the process of renewal. Also identify applications for new permits, licences, approvals,
         certificates or registrations currently in progress for the facility. For these new
         applications, please indicate the regulatory authority and nature of the activity requiring
         approval by the regulatory authority.

        Ensure that all documents and certificates identified in this section have also been
         identified in Section 2, are attached to the WFER in Section 9.

3.2      Regulatory Liaison

Identify at least one regulatory contact who is familiar with the facility, or has been involved in
permitting, licensing, registering or inspecting the facility. The verifier will be contacting all of
the identified agencies regarding any concerns, present studies, history, investigations, or
charges.

3.3      Permit Requirements

NOTE: THIS SECTION MUST BE DUPLICATED AND COMPLETED FOR EACH
LICENCE, PERMIT OR APPROVAL.

3.3.1        Scope of Operations Allowed by Permits, Licences or Approvals

This section identifies the general operations and waste or recyclable materials permitted at the
site.

From the terms or conditions of the operating approval, permit or licence, identify:

     the wastes or recyclables that can be legally accepted;

     the treatment and/or disposal operations that can legally be performed at the site; and

     identify any materials or practices, which are explicitly prohibited by the permit, licence or
      approval. This may include concentrations and/or quantities (also see Section 3.3.2 below)

3.3.2        Storage

     Identify any limits on quantities or time periods for storage facilities on the site.

     Identify any other specific restrictions on waste or recyclable material storage at the site.

3.3.3        Permitted Emissions/Discharges

     If the facility has permitted emissions to the atmosphere or has any permitted discharges of
      effluent to local receiving waters, groundwater or another off-site treatment or disposal
      facility, please complete the table in Section 3.3.3.



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     If the permit, licence or approval does not address emissions or discharges, please enter “Not
      Applicable” in the first column of the first row of the table.

3.3.4        Regulatory Status

NOTE: The facility operator does not have to complete this section of the WFER. This section
is to be completed by the verifier. (See Section D Verifier‟s Guidance)

3.4      Environmental Monitoring Requirements and Results

For each of the media that requires monitoring in accordance with the permit approval or licence,
please identify the following in columns noted:

     Parameters Monitored: list each parameter for which monitoring must be completed for each
      of the environmental media.

     Frequency of Monitoring: identify the schedule or frequency of monitoring for each of the
      listed parameters.

     Monitoring Methods Specified or Employed: identify the methods used to monitor the
      specific parameters (i.e., grab-samples and laboratory analysis, automated composite
      sampling devices and laboratory analysis, continuous emission monitors, manual field tests,
      etc.).

     Reports and Recipients of Reports: identify any daily, weekly, monthly, annual or other
      summary reports for the monitored parameters. It is permissible to identify the type of report
      by its frequency of issue (i.e., weekly, monthly, annual, etc.) and note the parameters that are
      reported in that submission. Please also identify the regulatory agencies, company officials
      and any other organizations that receive the reports.

     If no monitoring requirements are mentioned for a particular environmental media, enter
      “Not Applicable” into the column (Parameters Monitored) adjacent to that media.

     If there are other monitoring and reporting requirements in the licence, permit or approval
      that have not been addressed in the table, please complete the response in the information
      request below the table. If there are not other monitoring or reporting requirements, enter
      “Not Applicable” in that portion of the WFER.

     If there have been exceedances of any limits (ambient quality or release limits) associated
      with any monitored parameter in the last two years, please identify the nature of the
      exceedance (Parameter and Measurement) and the date(s) of the exceedance(s) and
      corrective action details.

     If exceedances are reported, be sure to provide the necessary details in the relevant portions
      of Section 7 of the WFER.



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3.5      Regulatory Monitoring

This section of the WFER asks how the facility keeps abreast of changes to legislation,
regulation, environmental standards and guidelines. Training, seminars, memberships in
associations, bulletins and newsletter subscriptions, staff or contracted environmental specialists
and environmental audits are some examples of methods that some companies have used to
remain aware of regulatory changes which may affect their operations.

The second portion of this section asks how the facility adapts to changes or implements new
policy or procedures to address regulatory changes.

The remainder of Section 3 requests details about the compliance history of the facility. Please
provide details concerning all violations, convictions and enforcement actions.

NOTE TO THE VERIFER - THE VERIFIER IS REQUIRED TO CHECK PUBLICALLY
ACCESSIBLE DATABASES FOR SIMILAR INFORMATION (See Appendix D for guidance
to obtain compliance history information from provincial agencies).

3.6      Violations

Describe violations and enforcement orders in this section. Be sure to include descriptions of
corrective actions taken to address any enforcement actions.


4.0      FACILITY DESIGN
This portion of the WFER addresses the specific design features of the facility. Only the
sections that are relevant to the facility must be completed.

4.1.1        Current Disposal and/or Recovery Options

The table in WFER Section 4.1.1 describes 15 disposal facilities, 13 recycling facilities, and also
includes one generic category for waste transporters. Basel Convention Waste Management
Codes are provided for reference only. These codes are established to assist out-of-country
waste generators identify the facility type and for use in documentation for international waste
transactions. The codes are not used anywhere else in the WFER form.

To complete this section:

     Enter an “X” in the third column adjacent to the description(s) of operations carried out at
      your facility. Please be sure to check all operations that apply.

     After completing WFER Sections 4.1 and 4.2, complete the sections indicated in the
      right-hand column (column 4) applicable to the facility.




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4.1.2        Historic Company Operations

The purpose of WFER Section 4.1.2 is to provide details for assessing potential liability
associated with former or previous operations.

4.1.3        Future Operations

The purpose of WFER Section 4.1.3 is to provide information for the waste generator to assess
future potential for liability and/or to become aware of potential new services. This section will
also indicate the progress toward procuring necessary approvals, licences or permits and the
degree of environmental planning required to become operational.

4.2      Subcontracted/Off-Site Facilities

This section will provide the waste generator with information relevant to the “cradle-to-grave”
tracking of wastes. In many jurisdictions, the waste generator retains liability for his or her
waste streams regardless of their final disposition. Therefore, it is necessary for the waste
generator to have complete knowledge of all facilities that may be involved in the treatment
and/or disposal of the waste stream or any of its remnants remaining after treatment.

SPECIAL NOTES FOR COMPLETING THIS SECTION:

     This section should be completed if waste streams or any portion or component of the wastes
      received and/or treated at the facility are taken off-site for further treatment or disposal.

     This section should also be completed if the wastes are managed at the same address as your
      facility, but treated by a different approval holder such as a sister company or mobile
      contractor operating at your location under a different approval, licence or permit.

     This section does not apply to ancillary waste streams generated at the facility by equipment
      or workers (i.e., used oil from process equipment, worker‟s lunch room wastes, office waste,
      domestic sewage). These ancillary waste streams are addressed by WFER Section 4.12.

     In describing the process used to determine where wastes are transferred, the waste generator
      wishes to know what due diligence steps are taken to ensure that the off-site facility is
      capable of handling waste streams sent to it. Your answer should describe any pre-
      authorization checks, inspections, and/or environmental assessments done on the facility.

     For referencing any environmental assessments and environmental audits completed on the
      off-site facility, it is acceptable to maintain reports done by a third party (i.e., another waste
      generator, government agency or a consultant). It is worthwhile to note whether or not the
      offsite facility has completed its own WFER, however, please remember that the WFER is
      not an assessment report in itself. WFERs only provide the information required to do an
      environmental/liability assessment. Be sure to describe the assessment process using the
      WFER in the previous question.



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SPECIAL NOTES FOR COMPLETING SECTIONS 4.3 to 4.12

These sections must be completed according to the items checked in the table in WFER
Section 4.1.1. If your facility does not operate the facility-type identified in WFER Sections 4.3
to 4.12, please enter “Not Applicable” immediately after the header for that section.

4.3       Landfills

     The government designation is the official descriptor assigned to landfill by the provincial
      environmental agency or the regulatory authority responsible for licensing or approving the
      facility.

     If the facility is designed to a more rigorous specification (i.e., over-design) than its official,
      licenced designation, please mention these details in the subsequent sections, which address
      landfill design.

     “Waste Quantity Received” in the third column of the summary table implies actual
      quantities recorded at the scale. If actual recorded quantities are not measured, please
      indicate that the figures provided are estimates.

     “Approved Quantity” in the fourth column of the summary table refers to the limits imposed
      by the operating permit, approval or licence for receiving waste. If there is no limit specified
      in the operating permit for a particular waste stream, enter “Not Applicable” in the fourth
      column.

     “Leachate Detection” refers to a monitoring system beneath the landfill liner that notifies the
      operator when a breach has occurred or permits the operator to visually inspect for signs of
      leachate escaping through the liner.

     “Leachate Collection Systems” refers to the drainage network at the landfill base (above the
      liner(s)) that removes leachate from inside the landfill cell and conveys it to a collection
      facility. Include details of the collection system and describe any management practices
      (including treatment) of collected leachate.

     “Liner” refers to the engineered barrier between the waste in the landfill and surrounding
      ground. The engineered barrier can be compacted in-situ or imported clay or a geosynthetic
      liner. Be sure to mention the thickness of the liner and its permeability (cm/s).

     “Associated Storage Areas” generally refer to areas within or adjacent to the facility, which
      are used for interim storage of wastes or recyclables prior to disposal in the landfill or
      transfer to another facility. Examples could include areas and facilities for storage of:

         salvageable metal;
         white goods;
         used motor oil;


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         lead acid batteries; and
         other recyclable goods

     “Storm Water Runoff Controls” refer to any permanent or temporary structures designed to
      keep storm runoff or spring runoff from entering the landfill area.

     When describing landfill cover practices, please mention the materials used as cover and
      their finished thickness.

     When describing the requirements for landfill closure, please reference the landfill closure
      plan (if available) and mention any requirements from the regulatory jurisdiction. Include
      details of the final cover, site preparation and the intended final land use.

     When mentioning post-closure care, be sure to include the time period requirement and the
      maintenance and monitoring requirements. Note that cost estimates for closure/post-closure
      are addressed in WFER Section 6.

4.4       Biodegradation

     Biodegradation facilities typically use aerobic (requiring atmospheric oxygen), facultative
      (operating with or without atmospheric oxygen), or anaerobic (operating without an
      atmospheric oxygen) micro-organisms to treat wastes to simple, innocuous material.

     Typical process that fall under this category include:

         waste water lagoons and sewage treatment facilities;
         composting facilities, biopiles, and biocells;
         landfarms; and
         anaerobic digestors.

     “Liners”, “leachate detection” and “leachate collection systems” have the same meaning as
      for landfills (see Special Notes for Completing Section 4.3). These features generally apply
      only to facilities that operate in earthen pits or landfarms.

4.5       Surface Impoundments

The section should only be completed if the facility stores wastes from off-site (i.e., consigned
wastes) in surface impoundments. Surface impoundments for wastewater that is collected from
some other on-site process (i.e., leachate, blowdown) or runoff should be described in WFER
Section 4.12 Ancillary Operations.

     “Surface Impoundments” refer to lined or unlined in-ground ponds for temporary or long
      term storage of liquid wastes. Evaporation ponds would also be included in this definition.




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     “Waste Quantity Received” should be based on actual measured quantities or best estimates
      from available records.

     “Approved Quantity” refers to the amount of waste that the facility is permitted by the
      regulatory authority to receive.

     “Estimated Total Capacity” should not include free-board.

     When describing the containment system, describe any liners (material and synthetic) and
      mention the rated permeability of the liner. Also describe any overflow protection and/or
      secondary containment facilities.

     “Drainage System” refers to the run-on, runoff controls near the surface impoundment(s).

     “Leachate detection” and “leachate collection” have the same meaning as for landfills.

4.6      Thermal Treatment

     “Thermal Treatment” generally covers all processes using thermal energy for waste treatment
      only (e.g., flaring, incineration, thermal desorption, plasma arc, microwave). If the thermal
      process is used for processing recyclables (e.g., distillation, pyrolysis, or other thermal
      processes, which convert the recyclable material into useful product), please complete
      Section 4.9 instead.

     “Estimated Total Capacity” refers to the equipment manufacturer‟s rating for the total
      capacity of the thermal treatment unit in tonnes per day.

     With reference to “Are the wastes segregated?”, please mention whether or not wastes of
      different types or from different customers are treated separately in the thermal treatment
      unit.

     In describing the emission controls, mention methods and removal efficiencies for target
      contaminants, such as fly ash, NOx, SOx and other acid gases (where applicable). Also
      indicate the residence time for the waste in the treatment process.

     “Flare Treatment System”: if vapours or off-gases are flared, describe the flaring system

     For disposition of remnant wastes, identify the remaining waste (e.g., ash, metal) and identify
      the destinations and methods for treating the residual after thermal treatment.

     In describing system controls, focus on systems responsible for maintaining the processes
      operating parameters, emergency shutdown, and QA/QC.




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4.7       Injection Wells

     For the table in WFER Section 4.7, identify the different types of liquid wastes accepted by
      the facility for injection. Identify the quantity of waste disposed annually (please include
      units in tonnes or m3 per year). Also identify the maximum quantities the facility is approved
      to receive (in tonnes or m3 per year) by the regulatory authority.

     Identify the injection rate (m3 per hour or per day) approved by the regulatory authority.

     Re: “Are wastes segregated?” if wastes are segregated prior to injection, identify the
      segregation groups and the materials that may be admitted to the various groups.

4.8       Waste Storage

This section should be completed only if the primary function of the facility is to accumulate
wastes or recyclables in temporary storage to permit economic shipment to appropriate treatment
and/or disposal facilities. Types of facilities that should complete this section will include
transfer stations, warehouses, bulk facilities and terminals.

On-site storage facilities that are operated as an ancillary part of another treatment or processing
operation should be addressed in WFER Sections 5.10.

     For the Storage Summary Table, “Waste Quantity Received” should reflect actual quantities
      recorded from waste tracking systems. Quantities should include units in either m 3 or tonnes
      per year. “Approved Quantity” refers to the maximum quantity the facility is permitted to
      receive annually under the terms and conditions of the operating approval, licence or permit
      granted by the regulatory authority.

     For completing the summary table for aboveground and underground storage tanks, please
      note the following:

         “Identification” refers to the tank number identity or reference used internally by the
          facility to identify the tank. Each tank should be assigned its own unique identifier.

         “Provincial Registration” (e.g., PTMA in Alberta) should be provided if applicable.
          Most underground storage tanks and some aboveground storage tanks require registration
          with provincial authorities. Enter “Not Applicable” if the tank does not require
          registration.

         For the “Age or Year Installed”, please report the age of the tank if it was not new at the
          time of installation.

         “Contents” in this table refers to tanks used for incoming waste or recyclable storage and
          does not include fuel, lubricants or chemicals used by processing equipment or vehicles
          at the facility.



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     For the remaining questions on tank storage systems, use the tank identification numbers or
      descriptors from the preceding table to provide information related to a particular tank, or
      group of tanks if the group shares common characteristics or facilities.

     In describing the structural integrity inspection and testing programs, please indicate the
      methods employed for testing and inspection, the frequency of testing and inspection, and
      identify persons or companies responsible for testing.

     For inventory controls, describe methods to track the inventory (i.e., meters, scales) and
      methods used to confirm or reconcile the measurements (e.g., daily tank dipping) wherever
      applicable.

     In describing waste segregation practices, identify the different segregation groups or classes
      and describe the process to separate the waste streams (e.g., separation at source by the waste
      generator, manual sorting at site, etc.).

     In describing how waste containers are protected from damage, describe the measures taken
      to protect portable containers (e.g., drums, boxes, bins) from physical damage: during
      handling on-site from weather effects, secondary containment and protection from access by
      unauthorized personnel.

4.9      Processing of Recyclables

This section should be completed only if the facility accepts materials for recycling or recycles
residual material from other waste treatment processes at the site. For the summary table:

     “Waste Quantity Received” refers to actual quantities received by the facility and should be
      based on facility records.

     “Approved Quantity” refers to the material quantities that are approved under the facility‟s
      licence, permit or approval issued by the regulatory authority.

     For the “Process Used to Recycle Waste” indicate the type or name of the process in the
      table. Further details related to each recycling process are solicited later in WFER
      Section 4.10.

4.10     Waste Treatment/Processing

     This section applies to facilities that treat waste using technologies other than thermal
      biodegradation. This may include but is not limited to neutralization or physical or chemical
      stabilization processes.

     For the summary table, identify the name or type of technology utilized for treatment for
      each waste type. Information to describe the treatment process is requested later in this
      section.



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4.11    Transportation

This section contains questions that must be completed by all types of facilities.

   For the various transportation arrangements used to bring wastes to the facility, be sure to
    check “YES” for all arrangements that apply.

   In describing methods for confirming driver training, please note the following:

    -   TDG (Transportation of Dangerous Goods): All drivers that haul hazardous waste or
        hazardous recyclables must have a valid certificate of TDG Training from their employer.
        Training certificates are valid for three years and must be renewed with re-fresher
        training.

   For the table describing the types of vehicles available for transporting waste, please observe
    the following:

    -   Vehicle Description: type (van, tanker, trailer) and capacity of vehicle (gross vehicle
        weight, litres); and

    -   Ownership: indicate whether the vehicle is contracted or facility owned.

   For the description of waste types and quantities transported, indicate the quantity of waste
    or recyclables transported, and the annual quantities permitted by the regulatory jurisdiction
    (if applicable) in the fourth and fifth columns, respectively.

   For transportation related incidents, include all spills or accidents, which have occurred in
    the last three years. Be sure to include the dates (year) that each incident occurred. If the
    vehicle involved was a contract vehicle, describe only the incidents that occurred on the
    waste facility property.

   For the description of contaminant impacts to soil, groundwater, or surface water, include all
    impacts, which have occurred at or near the waste facility. As well as the off-site impacts
    caused by facility-owned vehicles.

   For descriptions of the types and lengths of roadways, include details of the road or access
    design (i.e., gravel, asphalt) and approximate width.

   For the description of the cleaning methods for contract and facility-owned vehicles, it is
    important to describe cleaning methods for truck beds, trailers and tankers. Be sure to
    describe any facilities for managing wash water or cleaning agents.

   In describing inspection methods for vehicles, be sure to identify:

    -   the types of inspection (i.e., Provincial standards, safety, special equipment); and


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      -   who completes the inspection (company technicians, licenced mechanics).

     In describing the control procedures for vehicles entering and leaving the property the key
      points to consider include:

      -   accounting for all vehicles on site at any given time; and

      -   ensuring that vehicles are restricted from prohibited areas.

     In describing National Safety Code or TDG Act violations, also include:

      -   the nature of the violation (overweight, improper documentation, improper markings,
          etc.); and

      -   describe all violations occurring within the last three years.

4.12      Other On-Site Operations

This section should be completed if the facility performs waste handling operations that have not
been addressed in Items 4.2 to 4.11 of the WFER.


5.0       FACILITY OPERATIONS
This section of the WFER should describe basic operational aspects pertaining to the facility. In
responding to questions in this section, be sure to emphasize operating practices that demonstrate
due diligence.

5.1       Waste Confirmation and Quality Control

     Waste confirmation implies to a process by which the receiving waste facility confirms that
      the characteristics and qualities of the wastes meet the facility‟s acceptance criteria and
      match the description of the waste on accompanying documentation.

     For the first question regarding screening of consignments prior to accepting wastes, the
      response should describe the procedures for determining if the waste material is acceptable
      for treatment and/or disposal at the facility before consignment is arranged.

     For the second question regarding the composition of incoming waste at the site, the response
      should describe the procedure for confirming that waste matches the waste WFER, other
      accompanying documentation, or previous analytical data.

     In describing the practices to confirm the incoming quantity of waste, identify and describe
      systems for measuring weights or volumes of wastes received at the facility.



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     In describing methods for monitoring inventories of wastes and recyclables at the facility,
      note the following:

      -   records may include logbooks, inventory records, computer databases or other inventory
          tracking systems appropriate for the materials handled; and

      -   the information contained in the inventory system should identify the material, its origin,
          location on-site and include dates of any inventory transactions.

     For the description of the person(s) responsible for analytical work, recognize that this could
      include off-site or contracted laboratories.            Provide corporate qualifications and
      accreditations or certification of such facilities, where applicable.

     For the location and security of analytical records, identify all measures to prevent
      unauthorized access to information. Details on security measures for fire, theft and damage
      are requested later in this section.

     In addition to the length of time that samples are routinely kept for reference, also mention
      the storage practice for reference samples (e.g., locked cold room, freezer, storage racks at
      room temperature, etc.).

     In describing methods for determining waste compatibility with intended disposal methods,
      describe methods used to establish appropriate treatment of wastes and/or recyclables.
      Identify the general approach to establish compatibility (e.g., bench-scale testing, laboratory
      analysis to define parameters for comparison with established criteria, etc.).

     With regard to co-mingling of wastes, provide details of how the tracking system can trace
      waste to the original waste generator. Identify the point in processing or disposal operations
      at which it is no longer possible to track wastes or waste components to the original waste
      generators, if applicable.

     In describing details about radiation monitoring (if applicable), mention the maximum
      radiation levels that are allowed at the facility.

5.2       Change Management Process

The change management process should address how the facility implements changes in process,
staff, organization, equipment and hardware, software, and administration. Describe the
planning and implementation steps to ensure that save and duly diligent facility operation is not
interrupted during changes.

5.3       Site Security

This section of the WFER considers the measures to prevent unauthorized individuals from
gaining access to the facility.



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     In describing who has access to the facility, mention the groups or individuals who have
      keys, pass-cards or other means of access to the facility (i.e., managers, cleaning staff,
      security personnel, etc.).

     For facility signage, describe the signs posted at entrances to the facility, including those with
      emergency contact numbers.

5.4      Worker Safety

     Written policies reflecting commitment to safety, health and the environment should be
      considered valid for the purposes of WFER only if they have been endorsed (signed) by
      management and have been displayed in the workplace.

     For lost time injury and total recordable injury rates, make reference to Workers‟
      Compensation Board reports, where available.

     For employee health/medical monitoring programs, it is expected that monitoring programs
      would only be necessary at sites where there are potential risks to employees. It is not
      expected that every facility will have such programs.

5.5      Worker Experience and Training

The purpose of this section is to obtain information on the level of training and experience of
employees and management at the facility. Training programs identified in this section should
be relevant to waste management operations, health and safety, emergency preparedness,
transportation and handling, analytical methods or regulatory affairs.

5.6      Contractor Management

This section applies to facilities that occasionally or routinely contract other companies to
perform specific operations or maintenance at the facility (do not include those contractors in
Section 4.2). Waste generators will use this information to assess how the facility ensures the
safety of personnel who do not work regular shifts at the facility.
.

5.7      Self Inspection and Environmental Risk Management

This section should address details of the facility‟s internal risk management programs. This
generally implies the existence of an environmental management system, but is not necessarily
mandatory that such a system must be ISO 14001 registered.

     For internal inspection protocols, refer to those inspections for which records (i.e., logbooks,
      checklists) are kept only.

     For descriptions of internal environmental audit programs, schedules, include details such as:




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      -   scope of audits done (i.e., regulatory compliance, company policy compliance,
          environmental, health and safety, schedules etc.);

      -   audit team composition (i.e., team composed of facility employees, corporate audit team
          from outside the facility, consultants); and

      -   process for developing action plans and implementing modifications after auditing (i.e.,
          follow-up programs, budgeting).

     ISO 14001 refers to the International Organization for Standardization standard for
      environmental management systems.

5.8       Release Prevention and Emergency Management

This section addresses the contingency plans that the facility has implemented to manage spills,
leaks, and unauthorized atmospheric releases. Five emergencies are addressed in the next
section.

     For the description of the emergency response plan:

      -   mention the contingency plans that have been developed (i.e., spill evacuation, bomb
          threat, etc.);

      -   identify the response teams that have been established for emergency response
          (i.e., facility spill response team, contracted emergency response team, divers, etc.); and

      -   arrangements made with local municipalities, fire departments, police departments,
          nearby residents, etc. for evacuation and emergency response.

     Mutual aid agreements are arrangements to share emergency equipment and response
      capabilities with other facilities. In return, these facilities may also provide resources for
      emergency response at the facility.

5.9       Fire Safety

This section addresses the fire management component of the emergency preparedness plans for
the facility.

     In describing the facility management component of the emergency preparedness plans for
      the facility.

      -   describe roles of staff for dealing with a fire at the facility;

      -   mention the types of response teams available to respond to a fire at the facility (i.e., site
          fire team, local fire department);



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      -   mention evacuation plans for the facility and surrounding area, if applicable; and

      -   mention the frequency of fire drills and the date of the last drill.

5.10      Ancillary Operations

Ancillary operations are the general support and maintenance functions at the facility. Of
particular interest are the management and storage of hazardous materials used at the facility and
the management of wastes produced by ancillary operations.


6.0       FACILITY FINANCIAL AND INSURANCE AFFAIRS
This section of the WFER will be used by waste generators to assess the financial stability of the
facility, provisions for closure, liability insurance coverage and contractual arrangements for
waste acceptance. The WFER does not request specific financial information; however,
individual waste generators may request evidence of financial stability as part of their own
facility assessment program.

6.1       Finances

     For “Number of years in operation” also indicate the year the company commenced
      operation (not necessarily the site).

6.2       Closure Plans

     In describing financial arrangements and requirements for closure and post-closure, it is
      acceptable to refer to the table in this section.

     Identify closure and post-closure costs separately in the second column of the table.

     Identify specific areas and operations that have been addressed by closure plans and the
      associated costs.

      -   mention the scenario model that closure is based on (i.e., clean up to original land use
          criteria, development as a recreational facility, clean up for resale as industrial land;

      -   mention any assumptions used in the derivation of costs (i.e., degree of clean up required,
          decommissioning costs, monitoring intervals, interest rates for present value costs, etc.);
          and

      -   note that it is not industry practice to include salvage values of equipment and facilities in
          closure estimates.




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6.3       Insurance

This section addresses liability insurance for the facility. Provide the requested information for
environmental impairment liability, general liability, and vehicle insurance, as applicable. If
other insurance coverage has been obtained (i.e., design exposure liability for proprietary
equipment and processes), please include the details for this coverage using the same format as
the other listed coverage.

Waste generators may request up-dated certificates of insurance if the WFER is more than one
year old at the time of the assessment.

     For Workers‟ Compensation Board information, the Experience Rating refers to the
      surcharge or discount applied to premiums, based on the facility‟s accident record. This
      record is derived in relation to other similar operations in the same industrial sector. Be sure
      to indicate whether the rating is a surcharge or discount. This rating is frequently expressed
      as a percentage or ratio, depending upon the province.

6.4       Waste Ownership

This section requests details about the contractual arrangement for the transfer of waste
ownership from the generator to the receiver.

     If the contractual terms for waste ownership are available as a separate document, it is
      acceptable to attach a copy to Section 9 of the WFER, however, the contractual terms should
      be mentioned in Section 6.4.


7.0       ENVIRONMENTAL SETTING
This section is intended to provide information on the physical setting and location of the
facility. This information is necessary to assess risk to surrounding property.

There are no special notes for completing Sections 7.1 (Community Relations), 7.2 (Setting),
7.2.1 (Historical Land Use), or 7.3 (Buffer Zones/Set Backs). If there are any concerns
completing these sections, please contact the WFER Help Desk at 403-235-8138.

7.4       Surface Water

     For creek designations:

      -   Ephemeral: refers to a creek that lasts a very short period of time (i.e., spring runoff, and
          heavy rains only).

      -   Intermittent: refers to a creek that undergoes cycles of flow and dry conditions over the
          course of the year (i.e., controlled flow, flow only after precipitation events).




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    -   Perennial: refers to creeks that flow at all times of the year.

   When describing all local surface water use, include local surface water uses within 5 km;
    when describing regional surface water, use the watershed basin as the area under
    consideration.

   Mention the major use of water in the region (i.e., hydro power generation, fishery,
    municipal water supply, cattle, recreation, etc.).

7.4.2       Stormwater Management

   Run-on refers to storm or melt water that can enter the facility from adjacent properties.

   Run-off refers to storm or melt water that can leave the facility and enter adjacent properties.

When describing culverts, drains and ditches located on the property, also mention storm sewers
located on or at the edge of the property.

NOTE:           The meaning of floodplain should be considered to be the area affected by a 1 in
                100 year flood.

7.4.3       Process Effluent Discharge

   Effluent for the purposes of this section does not include runoff/run-on, but does include
    process water, cooling water, plant drains, and wastewater.

   For discharge volumes, provide annual volumes and normal discharge rates (l/hour, m3/day).

7.4.4       Off-Site Surface Water Monitoring

This section is intended to assemble details regarding voluntary (i.e., non-regulated) monitoring
performed by the facility. If monitoring to meet regulatory requirements (i.e., permit, licence, or
approval) conditions is done only, direct the reader to Section 3.5 of your WFER for details of
your monitoring program.

7.4.5       Surface Water Impacts

This section applies to both regulated and non-regulated surface water monitoring programs,

   Background levels refer to the concentration of the monitored parameters upstream of the
    effluent receptors, in unaffected areas, or baseline concentrations prior to the facility
    commencing operation.




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7.5       Groundwater


7.5.1        Groundwater Characterization

     In identifying the water table depth below potential sources of contamination, the potential
      sources of contamination should include, but are not limited to:

      -   bottom of landfill cells;
      -   underground storage tanks;
      -   above-ground tanks;
      -   storage facilities; and
      -   dispensing and loading/unloading facilities.

     Baseline groundwater quality should be based on groundwater quality prior to construction
      and operation of the facility, or quality measured off-site in areas that are not affected by
      plant operations.

     The principal aquifer is the water-bearing formation that may be used for a potable water
      supply.

     Regional groundwater use should refer to the area utilizing the principal aquifer. Describe
      the major groundwater uses in the area (i.e., municipal potable water supply, industrial
      process water, air conditioning, etc.)

7.5.2        Groundwater Monitoring

This section is intended to assemble details regarding voluntary (i.e., non-regulated) monitoring
performed by the facility. If monitoring to meet regulatory requirements (i.e., permit, licence, or
approval) conditions is done only, refer to Section 3.5 of your WFER to direct the reader to the
details of your monitoring program.

7.5.3        Groundwater Impacts

     Background levels of parameter concentration have the same meaning as baseline levels.

7.6       Air Quality


7.6.1        Air Quality Monitoring and Emissions

This section is intended to assemble information on air monitoring programs (source and/or
ambient) that are performed in addition to monitoring required by approvals, permits and
licences. If the facility conducts air quality monitoring to meet approval, permit or licence
conditions only, it is acceptable to refer to the information already provided in Section 3.5 of
your WFER. Be sure, however, to supply any of the requested information in this section that
was not identified in Section 3.5 (i.e., number and locations of sampling sites).


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     Fugitive air emissions should include any potential unintentional atmospheric releases with
      the exception of the emissions described in the dust control program.

7.6.2        Air Quality Impacts

     Be sure to mention the efficiency (effectiveness) of implemented measures to control
      emissions.

7.7      Surficial Geology, Soils and Vegetation


7.7.1        Surficial Geology and Soils Characterization

     Describe the local surficial geology and soil characteristics native to the site prior to
      development of the facility. Describe these characteristics for the immediate surrounding
      area if there is considerable variation in the area.

7.7.2        Soil Monitoring

This section is intended to assemble information on soil monitoring programs that has not been
described in Section 3.5 of the WFER (which covers monitoring required by permits, approvals,
and licences). It is permissible to refer to Section 3.5 of your WFER; however, be sure to
include any requested information not previously provided in Section 3.5 (i.e., number and
locations of sampling sites).

7.7.3        Soil Impacts

     Background levels refer to parameter concentrations in nearby locations that have never been
      affected by facility operations, or at the facility site prior to construction and operation of the
      facility.

     When commenting on any remedial implemented measures to clean up contaminated sites,
      be sure to comment on the effectiveness of the remediation efforts to-date.

7.7.4        Vegetation Characterization

     Indicate the percentage of area covered by vegetation (as described in the table) based on
      visual estimates

     In describing on-site vegetation management methods, describe practices used for weed
      control, prevention of fire hazards, and maintaining grounds.

7.8      Reportable Releases

     Reportable releases are those releases that must be reported to regulatory authorities due to
      the nature of the substances and the quantities released.


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7.9     Off-Site Monitoring

This section should be completed if there are other environmental monitoring programs that have
not been previously addressed in your WFER.

7.10    Remediation Requirements

This section should be completed if any remediation efforts to address spill clean up are in
progress or planned.


8.0     WFER REVALIDATION
This section must be completed by both the WFER completer and the verifier. Also note any
areas that were not described in the WFER due to inaccessibility, snow cover, or other
hindrances in the limitations section.




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D) VERIFIER’S GUIDANCE
Unless the information was entered into the WFER directly by the verifier, the verifier will be
responsible for confirming the accuracy of the information in a separate step of the WFER
process. The general process for verifying information in the WFER is conducted using
principles of environmental auditing. Efficient verification of the WFER is dependent upon
good planning. The following tasks ensure that the work is focussed and achieves the objectives
in the most efficient and economic manner.

DECLARATION

The lead verifier must read the Guidance Manual and sign the Declaration at the beginning of the
manual.

Define Scope and Objectives

The WFER is intended to represent a comprehensive review of operations at a single facility.
The cost of verifying this information and the resources that must be committed to it are heavily
dependent upon the scope and nature of waste management services provided at the facility.

If a waste management company wishes to include several facilities in the verification process,
planning will have to be done and documents prepared for each. Each facility may require a
different level of effort, emphasizing the need to define the scope clearly. Note that the WFER
must be completed and verified for each individual facility separately.

While the primary objective is to verify that the WFER represents the current state of
environmental affairs as accurately as possible, the verifier should be mindful of the objectives
of those companies and individuals using the results of this environmental review, which may
include:

1) assessing regulatory compliance;
2) assessing environmental risks;
3) identifying waste management capabilities and opportunities;
4) identifying potential cost savings; or
5) assessing due diligence

with respect to the operations of the waste facility. The verifier is to ensure that the WFER
provides sufficient information to support each of these objectives.

The scope and objectives of the review may be expanded beyond what is described here, at the
discretion of the waste facility. The waste facility owner is at liberty to retain the verifier to
perform other services while verifying the WFER. Improvements to the facility design and
operation suggested to the owner can be implemented before release of the final WFER
document without affecting the overall objectives of the WFER program. However, it should be
made clear, between the verifier and the client, that WCAR bears no responsibility whatsoever
for any work related or unrelated to completion of a WFER.

Obtain Background Information

To prepare for the WFER process, the verifier or verification team should have a familiarity
with:

1)   the characteristics of the facility to be reviewed;
2)   the services provided by the facility;
3)   the types of environmental issues present;
4)   the names of those who hold environmental management responsibilities;
5)   the characteristics of the environmental management system;
6)   which aspects of the facility are regulated through licences, permits and approvals;
7)   the environmental history of the facility;
8)   the regulatory requirements for waste management in the province of operation; and
9)   regulatory compliance tracking systems available in the province of operation.

Verifiers will require a review of preliminary documents to help them determine the information
specified above. The most important document for the verification process is the WFER and its
attachments. It is advisable that the completed WFER should be obtained and reviewed in
advance of going to the facility for the verification. Other supporting documentation includes:

1) environmental orders, directives, exemptions, permits and licences approvals specific to the
   site;

2) any environmental reports that may have been completed previously, such as old or expired
   WFERs, environmental impact assessments, spill reports and environmental audit reports;

3) corporate policies and procedures, such as the corporate environmental policy, spill response
   procedures, etc.;

4) insurance certificates, Workers Compensation Board Premium statements and reports;

5) inventories of hazardous substances, hazardous wastes and storage tanks (including age and
   contents);

6) detailed site maps and site drainage plans indicating discharges to surface water bodies; and

7) a list of key personnel available to provide information during the review.

Facility management should be notified of the need for this documentation, which should be
obtained and reviewed prior to visiting the facility.
Selection of Verifiers

It is essential that the verification be conducted by an individual or a team of professionals that
has the skills and experience to understand and assess the operations and activities involved. The
various topics to be addressed during the verification process will be allocated to individuals
having the appropriate expertise. The verifier(s) will be provided with appropriate information
to review the relevant sections of the WFER well in advance of the actual verification date.

The characteristics of a good verifier are described below.

Familiarity with the Operations

Verifiers should have a general familiarity with the type of operations being reviewed and the
issues likely to be encountered.

Technical Training and Experience

Verifiers must have sufficient and appropriate technical training, and related practical experience
to allow them to understand the facility‟s technical design, operating practices, and regulatory
compliance procedures.

Understanding of the Verification Process

The Lead Verifier (and the Verification Team, if applicable) must have an understanding of the
basic WFER verification process and procedures, as well as the experience to apply them. In
addition, verifiers should ascribe to a Code of Ethics that binds them to certain standards of
conduct. A modified version of the Canadian Environmental Auditing Association Code of
Ethics has been adopted for the WFER process (Appendix B). The skills and disciplines
associated with environmental auditing could be of significant value to the verification process.

Knowledge of Regulations

Each verifier should have a working knowledge of the regulations, industry codes of practice,
assessment criteria and standards appropriate to the specific topic(s) he/she is reviewing.

The verifier or verification team should possess a mix of skills so that the facility can be
reviewed from various perspectives. For instance, these skills may include chemical engineering
for comprehending the process and the pollution control devices; hydrogeology background to
recognize the fate of contaminants released to the ground; chemistry for recognizing the toxicity
and other hazards associated with the chemicals handled, and so on.

Set Verification Schedule

The verification schedule should be prepared in consideration of:

1) the facility's ability to accommodate the review;
2) the practical considerations of the time required to complete the verification properly; and
3) the likelihood of snow cover or adverse weather imposing limitations on the site inspection.

The time required and the duration of the overall verification process will depend on the
availability of the required information and the size and scope of the facility. The schedule
should specify dates and times for arrival on-site, the opening meeting, the closing meeting and
submission of the completed WFER.

It is expected that the WFER completion and verification process will be repeated once every
three years or whenever operations or processes are changed or added which could result in
significant environmental concerns.

Logistical Considerations

There are several logistical considerations that need to be addressed well in advance of the actual
verification date. Arrangements need to be made for travel and accommodations. Local
transportation may be required if the accommodations are distant from the site. Safety
requirements for working on the site need to be identified, and verifiers need to be appropriately
trained and equipped.

The personnel assignments (if more than one person is involved in verification), schedule and
logistics form the verification plan, along with the scope and objectives. The plan should be
prepared in written form for reference by the verifier(s) and the waste facility management such
that all involved are adequately prepared for the verification process.

INFORMATION-GATHERING ACTIVITIES

Information-gathering activities are the primary verification activities and are conducted at the
facility. Prior to arriving at the site, the verification team should inform the facility management
that they require the following support to ensure efficient execution of the verification process:

1) a commitment of time from the facility management and operating staff to assist in
   inspections, document retrieval and interviews;

2) a room to be used as a working room for the verifiers; and

3) access to a photocopier and telephone.

The verifiers will record their results within the WFER and on the associated working papers.
The verifier should ensure that sufficient detail is provided in the WFER to allow an independent
reader to gain an understanding of the facility operations and that sufficient detail is provided in
the working papers to demonstrate that the verification was completed thoroughly and diligently.
Opening Meeting

On-site activities commence with an opening meeting with the facility management.            The
objectives of this meeting are to:

1)   introduce the verifier(s) and the key facility staff;
2)   review the scope and objectives;
3)   discuss the activities to be undertaken;
4)   discuss the schedule of activities;
5)   clarify the needs for working space and other support;
6)   review any confidentiality requirements;
7)   obtain permission to take photographs and make photocopies; and
8)   discuss safety requirements.

Following the opening meeting, a brief site tour is to be conducted by knowledgeable facility
representatives to familiarize the verification team with the facility.

The verification team will then undertake its information-gathering and verification tasks. While
information-gathering, the verifier(s) will focus on collecting and documenting information to
verify the content of the WFER.

Verification Activities

The objectives of this task are to develop a detailed understanding of the environmental issues,
which the facility must manage and to confirm environmental management practices with respect
to these issues. Specifically, the objectives are to identify:

1)   areas of potential environmental risk;
2)   procedures and activities implemented to reduce risk;
3)   physical controls installed to reduce risk; and
4)   monitoring systems.

Information is verified through:

1) visually observing relevant activities and processes;
2) visually inspecting operating areas, storage areas and grounds;
3) interviewing operating staff;
4) interviewing management staff;
5) interviewing officials of local regulatory agencies;
6) acquiring information from compliance databases and through “Freedom of Information”
   searches;
7) reviewing documented policies, programs and procedures; and
8) reviewing environmental records and reports.

Physical sampling is not part of the verification process. Such information is obtained through
waste facility records, or if not available, then it is indicated as not available.
The verifier should approach the information gathering by identifying the areas of environmental
risk, then identifying the management practices in place and, finally, verifying the existence of
these practices through observation of operating practices and review of documents and records.

Copies of documents and records may be retained by the verifiers to substantiate their
observations.

The types of documents reviewed may include:

1)   written policies, procedures and work instructions;
2)   job descriptions;
3)   employee training requirements;
4)   file indices;
5)   contracts; and
6)   business plans.

The types of records reviewed may include:

1)   reports from previous audits, reviews or other environmental studies;
2)   monitoring records;
3)   inspection reports or other government reports;
4)   reports sent to the government;
5)   routine internal operational reports;
6)   records of public complaints or inquiries;
7)   employee training records; and
8)   environmental files.

A complete list of the types of documents and records that may be subject to the review can be
found in Part 2 of the WFER.

During the verification activities, the verification team will systematically verify all items in the
WFER and will generate a series of working papers (see Appendix C). Working papers are
written records that document the verifier‟s observations. They may be supported with physical
evidence such as photographs or photocopies of documents.

The goal of the verifier is to ensure that sufficient information has been gathered to verify the
accuracy of the content of the WFER. Sufficient information would be considered to be:

1) direct visual observation of a physical control, or the active implementation of stated
   practices or procedures;

2) verbal confirmation by regulatory authorities that the facility operates in the stated manner;
   or

3) verbal consensus from at least three knowledgeable facility staff that supports the
     information provided in the WFER.
COMPLIANCE TRACKING REPORTS

Note that in Section 2 of the WFER, compliance-tracking reports are required as one of the
attached documents in the review. The verifier is responsible for completing a review on the
facility‟s compliance history and verifying that the facility is in compliance with all licence,
approval, or permit conditions at the time of the site visit. The compliance history review should
consider the following information:

1)   environmental enforcement actions (i.e., stop orders, control orders);
2)   charges under provincial, federal or municipal acts;
3)   convictions and fines; and
4)   unauthorized releases.

In general, this information can be obtained from provincial environmental ministries under
“Freedom of Information” legislation. Appendix D of this manual contains information on the
various provincial agencies that can provide the required information. Search request details
have also been provided in Appendix D. It suggested that the search request be initiated early
during the WFER verification process, since some of these agencies must perform manual file
searches to obtain the required information.

WFER Section 3.2 Regulatory Liaison

The verifier is required to contact all of the listed regulatory contacts. During these contacts, the
verifier should inquire about any concerns, present or recent studies, part history, investigations
or charges related to the facility.

WFER Section 3.3.4 (Compliance with Licences, Permits and Operating Approvals)

Section 3.3.4 of the WFER requires the verifier to confirm that the facility is in compliance with
all terms and conditions of their operating approvals, licences and permits. During the
verification of the WFER, the verifier should identify any clauses with which facility is not in
compliance and identify the measures that are being taken to regain compliance. If the facility is
in full compliance with all conditions of its operating approvals, permits, and licences, the
verifier should initial the statement certifying that the facility is in full compliance.

Verification of WFER Statements

If the verifier is satisfied that the statement on the WFER is complete and accurate, the verifier
will place his or her initials in the “Verification” column beside the statement. If the verifier has
reason to believe that the statement is not complete or accurate, then he or she should discuss the
matter with the representative of the waste facility to either amend the statement or to uncover
additional information to support the statement. Certain terms and conditions may be difficult to
confirm full compliance because they are subjective. Such terms and conditions may obligate
the approval licence, or permit holder to “take all reasonable steps” or “accomplish to a practical
extent” some action or program (i.e., implement a waste minimisation program). In these cases,
the verifier needs only to confirm that the approval holder has taken, or is taking some action to
address the term or condition.

The verifier should keep in mind during this process, that it is intended to be an open,
cooperative process to complete an information document accurately. It is not an evaluation that
produces a report card on performance. Whenever there are discrepancies between the contents
of the WFER and what the verifier perceives to be reality, the discrepancy should be openly
discussed to obtain consensus on the matter.

The verifier should also ensure that the information has been provided in the WFER in a clear
and concise manner, such that any potential reader will clearly understand what has been written.
If clarity is a problem, this should be communicated to the facility management to allow them to
reword their response.

If the verifier is completing the WFER him- or herself, then the related information should be
summarized clearly and concisely, written in the appropriate place in the WFER, and the
“Verification” column initialled to identify who prepared the statement.

COMMUNICATION OF RESULTS

After the information has been gathered, the verifiers will communicate the results of the
verification process to the waste facility management. This is done by means of a closing
meeting and the finalization of the WFER.

Closing Meeting

Before the verifier(s) leave(s) the site, a closing meeting is held with facility management to
review and discuss the team's work. There are two objectives related to this task:

1) to inform facility management of any unresolved discrepancies; and

2) to allow facility management to discuss the WFER with the verifier(s); this allows any
   misperceptions or misinterpretations to be clarified, acts as quality control for the
   verification, and helps to ensure that the completed WFER will be a useful tool for both
   facility management and generators.

Finalize WFER

The verification process is completed by preparing the final copy of the WFER and working
papers, ensuring that each item of information is properly documented and justified, and is
correctly and clearly worded. The verifier will also complete Part 8 Validation of the WFER,
ensuring that the waste facility does so as well.

The original completed WFER and working papers will be retained in the verifier‟s files. The
working papers are not considered to be part of the WFER. The WFER will be made directly
available to the waste facility‟s clients on an as requested basis with the written authorization of
the waste facility.

The WFER and working papers will be retained for a period of at least seven (7) years. They will
be kept confidential, unless the information has been authorized for release by the waste facility.
Authorization will be on a case-by-case basis.
                               GLOSSARY


Ancillary operations       Any activity that is not part of the primary waste
                           management process; includes equipment maintenance,
                           vehicle operation, etc.

Background levels          The normal expected level of a parameter in the
                           environment if development had not occurred.

Contaminant                Any physical or chemical agent that is present at levels
                           exceeding normal background levels.

Due diligence              The taking of all reasonable steps to prevent the occurrence
                           of an offence or damage to the environment.

Generator                  The party that sends waste to a waste facility.

Impact                     The effect of an activity on any component of the
                           environment.

Leachate                   Liquids emanating from an accumulation of waste.

Pathway                    The route a contaminant might take to reach a receptor.

Receptor                   A component of the environment that may be affected by a
                           contaminant.

Reportable release         An emission or discharge of a contaminant that exceeds a
                           government-defined threshold that requires reporting to the
                           government.

Surface runoff             Water that collects on the ground surface as a result of
                           precipitation or snow melt.

Verifier                   A person independent from a waste facility that confirms
                           the accuracy of information provided in the WFER.

Waste facility             An industrial or commercial operation that receives waste
                           for the purpose of burial, storage, treatment, destruction or
                           transfer by any means.

Waste management process   The handling of waste by burial, storage, treatment,
                           destruction or transfer by any means.
Working papers      The written notes prepared by the verifier during the
                    verification process.

WFER                Waste Facility Environmental Review: An information
                    document that describes the operations and environmental
                    issues of a waste facility.


                      APPENDIX A

                 CEAA CODE OF ETHICS
               Canadian Environmental Auditing Association

                              Code of Ethics

Each CEAA member will endeavour to:

    Be honest and candid and perform professional services with
     integrity and due care.

    Be competent, having the required skills, knowledge, and
     experience to perform the services undertaken.

    Continually seek to         maintain      and     improve       professional
     knowledge and skills.

    Serve the client in a conscientious, diligent, and efficient
     manner.

    Hold in strict confidence, except as required by law, all
     information concerning the business and affairs of the client in
     acquired in the course of the professional relationship, and not
     use this information for personal gain.

    Remain free of any influence, interest, or relationship that
     impairs professional judgement, independence, or objectivity,
     while providing professional services.

    Commit   to    honest,    thorough,    and    straightforward
     communication in the performance of professional duties.

    Not be associated with any report, statement, or representation
     known to be false or misleading.

    Conduct him/herself toward other professional auditors with
     courtesy and good faith.

    Endeavour at all times to enhance the public regard for the
     profession.




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    APPENDIX B

WFER WORKING PAPERS
WASTE FACILITY ENVIRONMENTAL REVIEW - WORKING PAPERS
This document provides a means by which verifiers can record their observations and comments
related to the completion or verification of a Waste Facility Environmental WFER.

The goal of the verifier is to ensure and verify that the WFER is completed fully and accurately
as it applies to the facility under review. The verifier will accomplish this goal by gathering
information to support the statements provided on the WFER. This is accomplished by:

   (V) visually observing physical controls, operations, facilities and the implementation of
    practices and procedures;

   (T) interviewing employees of the facility and regulatory officials to obtain testimonial
    information; and

   (D) reviewing documents and records for written information.

The results of these information-gathering activities will be recorded in these working papers
with reference to the means (V, T or D) of obtaining the information. If the information on a
particular item has been gathered only from verbal sources, then this should be noted on the
WFER as well, next to the verifier‟s initials.

It is advisable and recommended that visual evidence be gathered when the ground and weather
conditions are conducive to a thorough site inspection. If the ground surface is obscured by
snow cover, for example, this presents a limitation on the verification process and should be
noted on the WFER, Section 8.

Any document or record referred to during the verification process should be identified in the
verifier‟s notes on these working papers. Copies should be attached only if the document or
record provides information that cannot readily be summarized or is crucial to the completeness
of the working papers.

The working papers provide some guidance as to the information required and the suggested
means to provide verification, but this guidance should be considered the minimum required. It
is contingent upon the individual verifier to obtain the information required by the means
necessary to satisfy him- or herself that the statements on the WFER are adequately verified.

The verifier‟s conclusion on the verification is to be included in these working papers for each
individual section of the WFER. Those sections that are verified should be indicated as such,
and the verifier should initial beside the statement on the WFER. If the verifier is completing the
WFER on behalf of the facility or a client, then the initials will indicate that the statements
prepared by the verifier for inclusion in the WFER have been prepared to the satisfaction of the
verifier.




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All sections of the WFER should be addressed. If sections are not applicable, then this should be
indicated both on the working papers and the WFER. Where this could be confused with the
words „not available‟ the verifier should make clear what is meant.

The completed working papers are to be filed by the verifier and retained for a minimum of
seven (7) years after completion of the verification. All working papers will remain confidential
and must not be released without approval of the waste facility. The original completed WFER
is to be filed with the working papers.




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Waste Facility Environmental Review - Working Papers    Page B-1
Facility Name:     Verification Date:


1.0     Waste Facility Information

This section consists of general information, most of which is public information and readily available.
Verification of this information is not required.




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Waste Facility Environmental Review - Working Papers    Page B-2
Facility Name:     Verification Date:


2.0     Existing Documentation

This section of the WFER is provided for reference and as a summary of available documents and
records. Verification of this section is not required.

The listed documents and records should be referenced elsewhere in these working papers wherever
they are used to verify a statement. The verifier should indicate in this section whether the documents
were available and/or used for reference. This listing provides a convenient reference listing for
subsequent use by the verifier.

The verifier should note whether the documents required to be attached to the completed WFER have
been attached as required.




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Waste Facility Environmental Review - Working Papers    Page B-3
Facility Name:     Verification Date:

3.0     Regulatory Affairs

3.1     Permits, Licences and Approvals

The list of permits, licences and approvals should be verified by reviewing copies of the listed
documents. The verifier should use his or her knowledge of regulatory approval requirements to
determine whether the list is complete, and what, if any, documents should be added to the list. (D,T)

Also list any documented exemptions to any regulatory requirement. Exemptions may include TDG
shipping document exemptions for facility vehicles. (D,T)

If any permits, licences or approvals are listed as being in the application stage, review copies of the
application and note key points. (D,T)

With respect to declaration of being within allowable maximums for waste volumes, review the
method of calculation and comment on what it considers. (D,T)

3.2     Regulatory Liaison

Contact each listed regulatory contact for comments on the environmental performance of the facility
and any related regulatory enforcement actions. This may be done in advance of the site work.
Permission for release of this information may have to be obtained in advance from the facility. Use
this information when verifying Section 3.5. (T)

3.3     Permit Requirements (Items 3.3.1 to 3.3.3, inclusive)

Copies of this section should have been completed for each permit, licence and approval listed in
Section 3.1. Verify the Scope of Operation, Storage limits, and Permitted Emissions/Discharges by
visual observation, review of the referenced document and/or interviews of those likely to be involved
with the related activity or facility. (D,T,V)

3.3.4 Regulatory Compliance Status

This section is to be completed by the verifier. Review each term and condition of each of the
licences, permits, and approvals covered in Section 3.3. Verify by visual observation, review of
documents, and/or interviews with staff likely to be involved with activities required to maintain
compliance (D,T,V). If all conditions and terms were being complied with at the time of the review,
complete Item (I) and initial the statement. If there area any terms or conditions that are not being
completely complied with, complete Item (ii).

3.4      Monitoring Requirements and Results

Confirm that all requirements are listed. (D)

Confirm exceedances, or the lack thereof, by comparing a sampling of the monitoring data with the
regulated limits described in the related permit, licence or approval. (D)
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Facility Name:     Verification Date:



Confirm parameter levels above background levels, or the lack thereof, by comparing a sampling of
the monitoring data with the normal background levels for the area. The verifier may have to use
related government guidelines or personal knowledge to provide a basis of comparison, if a reliable
source of parameter background data is not available. (D)

The process described to evaluate test results may include: quality control, comparison criteria, person
responsible, distribution of results, etc. (D,T).




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Waste Facility Environmental Review - Working Papers   Page B-5
Facility Name:     Verification Date:


                       Document                                   Verified?                            Verifier Notes
                       Section #                                              {Verified by (D)ocumentation / (T)estimonial / (V)isual Observation}
                                                                  Y N n/a
3.1      Permits, Licences and Approvals




                                                                                                                               Append additional pages as required.
Completed by: __________________________                                                      Date: ____________________

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Waste Facility Environmental Review - Working Papers    Page B-6
Facility Name:     Verification Date:

3.4     Regulatory Monitoring

Confirm that the process described to track changes to pertinent legislation, regulations, environmental
standards and guidelines is capable of detecting changes introduced by Federal, Provincial, and
Municipal jurisdictions. In some cases, changes, guidelines, or codes of practice may be introduced by
public boards (i.e., The Alberta Energy and Utilities Board) or industrial associations (SWANA).

3.5      Violations

The regulatory agency interview results from Section 3.2 will help to verify the information provided
here. Review regulatory, legal and correspondence files for additional information. Interview senior
environmental and managerial staff and legal counsel. (D,T)

Remedial actions may be identified in letters to regulators or internal reports. Review these letters or
reports and determine the present status of indicated actions. (D,T,V)




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Waste Facility Environmental Review - Working Papers    Page B-7
Facility Name:     Verification Date:

4.0 Facility Design

4.1 Design Overview

View the facility to confirm that its design and operations are accurately described and classified in the
Table in Section 4.1.1. Look ahead in the WFER to confirm that the Sections indicated in the table
have been completed. (V)

View the facility for indications of past waste management activities. Review historical descriptive
literature, aerial photos, etc. for any indication of previous operations different from those now
undertaken. Interview long-time employees for additional information on past operations. (V,D,T)

Interview senior personnel for information on future plans for development or expansion of the
facility. Obtain and review any environmental impact statements or assessments (draft or final) with
respect to these developments. (D,T)

4.2 Subcontracted/Off-Site Facilities

Review waste records and manifests to confirm the list of waste facilities used for further treatment or
disposal. Discuss the selection of these facilities with the responsible manager. Obtain and review
copies of any audits or assessments conducted on these facilities. (D,T)

4.3 to 4.12       Detailed Design Descriptions

The Government designation for the classification of the facility and the types of wastes approved for
handling, treatment or disposal may be found on the operating permit, licence or approval. (D)

Waste types actually handled, treated or disposed by the facility may be confirmed by observing the
associated waste processes, reviewing waste manifests for incoming materials, reviewing facility
inventories and other records, and interviewing waste receiving personnel. (V,D,T)

Detailed design information may be confirmed by visually observing the facility, reviewing
engineering documents, drawings and specifications, and interviewing engineering staff. (V,D,T)

Storage tank information should be obtained by visual inspection of the tanks, review of registration
documents for design information, and review of engineering specifications. Tank management
practices such as volume reconciliation and tank inspection and testing, may be described in operating
manuals. Information may also be obtained by interviewing responsible operating and maintenance
staff. (V,D,T)

Closure requirements, plans and future intended land use may be described in the environmental
impact assessment associated with the facility. Information may also be obtained by interviewing
senior environmental or engineering staff. (D,T)



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Waste Facility Environmental Review - Working Papers   Page B-8
Facility Name:     Verification Date:


                       Document                                   Verified?                                Verifier Notes
                       Section #                                                  {Verified by (D)ocumentation / (T)estimonial / (V)isual Observation}
                                                                  Y N n/a
4.1      Design Overview




                                                                                                                                   Append additional pages as required.
Completed by: __________________________                                      Date:                                               ____________________

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Facility Name:     Verification Date:

Impacts of facility operations may be confirmed through visual observation of the site and surrounding
areas, and review of monitoring data, reports submitted to government agencies, spill reports, records
of public complaints and regulatory enforcement actions. (V,D)

Transport and vehicle related information may be obtained by observing related operations,
interviewing drivers, vehicle maintenance personnel and security staff, and reviewing spill reports.
(V,D,T)




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Waste Facility Environmental Review - Working Papers    Page B-10
Facility Name:     Verification Date:

5.0 Facility Operation

5.1 Waste Quality and Quantity Control

Waste quality and quantity control is likely to be a standardized procedure, whether or not it is in
written form. Interview waste receiving personnel to determine what procedures they follow, and what
they use for reference. Obtain and review copies of any written guidance documents. (D,T)

If the facility has its own laboratory facilities, interview lab personnel for information on waste testing
procedures, sample retention policies, lab report distribution and retention, and qualifications of
personnel. Review related written procedures. (T,D)

Review waste receiving records, including manifests, recycle dockets, receiving receipts, and testing
results for information on the receiving criteria and acceptance/refusal process. (D)

5.2 Change Management

Note that monitoring for changes in regulations was addressed in WFER Section 3.5. if the facility is
large, with several personnel, obtain an organizational chart and determine what responsibilities are
attached to each position for change management. Interview a sample front-line personnel, foreman
and manager to verify that they are involved in the change management process. Check written
procedures to ensure that duties of revision are indicated in procedures. If the total number of staff is
small (i.e., three or less), interview all personnel about their roles in the change management process.

5.3 Site Security

Visually inspect the facility and its perimeter to identify and verify security measures in place.
Interview security staff to identify and verify access, entry and surveillance procedures, and any
security breaches. Review facility incident reports for further information. (V,D,T)

5.4 Worker Safety

Visually inspect materials storage areas for labelling and signage practices. Interview environmental
and/or safety personnel on procedures and guidelines for identifying and controlling health hazards.
Obtain and review related documents. (V,T,D)

Review injury and incident reports and statistics for the past three years. Note any trends. (D)

Visually inspect the facilities for safety equipment, including personal protective equipment, safety
showers, fire extinguishers, etc. (V)




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Facility Name:     Verification Date:

5.5 Worker Experience and Training

Obtain and review copies of the environmental, health and safety policies or their equivalent, and any
documents relating to the health and safety program to confirm that their main features are adequately
described in the WFER. (D)

Obtain and review the worker training program and training records. Interview workers to confirm
their receipt of the indicated training. Interview a sample of the key staff identified in the experience
table to verify their levels of experience. (T) (D,T)

5.6 Contractor Management

Obtain and review contractor management procedures, orientation literature, permits, and training
certificates. If contractors are on-site verify that they have received orientation training and area aware
of the site rules for contractors. Interview facility personnel (if applicable) who are responsible for
issuing work permits. Inquire about methods used to manage contractors (V,T,D)

5.7 Self Inspection and Environmental Risk Management

Obtain and review copies of facility inspection forms and procedures. Review the file of completed
forms to verify inspection frequency. Interview responsible individuals to discuss the focus of the
inspections and procedures to address deficiencies. (T,D)

Follow a similar procedure for the audit program. (T,D)

5.8 Spill Prevention

Obtain and review a copy of the spill response plan. Visually inspect the facility for spill response
equipment and materials. Interview operating personnel to determine their familiarity with the plan
and related procedures. Interview senior personnel to identify any mutual aid agreements in place.
(V,T,D)

5.9 Fire Safety

Visually inspect the facility to determine what fire protection and detection systems have been
installed. Obtain and review a copy of the facility‟s fire protection plan, which may be contained in
the emergency response plan. Also, review insurance company reports for verification that the fire
safety provisions are satisfactory. (V,D)

Interview personnel for information on any fire-related incidents at the facility. Review related
reports. (D,T)

5.10 Ancillary Operations

Inspect the facility for hazardous materials used in facility operations, wastes generated by facility
operations and their means of storage. Review waste disposal records to confirm means of disposal.
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Waste Facility Environmental Review - Working Papers    Page B-12
Facility Name:     Verification Date:

Examine the office areas for the means of sewage disposal. View the backup power generator, if one
exists. (V,D)




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Waste Facility Environmental Review - Working Papers   Page B-13
Facility Name:     Verification Date:


                        Document                                   Verified?                              Verifier Notes
                        Section #                                               {Verified by (D)ocumentation / (T)estimonial / (V)isual Observation}
                                                              Y      N    n/a
5.1      Waste Quality and Quantity Control




                                                                                                                                 Append additional pages as required.

Completed by: _______________________________                                                   Date: ____________________



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Waste Facility Environmental Review - Working Papers    Page B-14
Facility Name:     Verification Date:

6.0 Facility Financial and Insurance Affairs

6.1 Financial Affairs

Obtain copies of the facility‟s financial and/or annual reports. Review their contents for the requested
information. Historical reports may have to be referenced to determine the requested historical
information. (D)

6.2 Closure Plans

Interview senior personnel to discuss closure plans and arrangements. Obtain and review documents
submitted to regulatory authorities on closure cost estimates, closure security or bonds in place, and
involved financial institutions. Interview appropriate personnel to discuss the methods of closure cost
calculation. (D,T)

6.3 Facility Insurance

Obtain and review copies of relevant insurance certificates and WCB correspondence. (D)

6.4 Waste Ownership

Review contractual terms and company literature for statements of waste ownership. (D)




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Waste Facility Environmental Review - Working Papers   Page B-15
Facility Name:     Verification Date:


                         Document                                  Verified?                               Verifier Notes
                         Section #                                               {Verified by (D)ocumentation / (T)estimonial / (V)isual Observation}
                                                                   Y   N   n/a
6.1      Financial Affairs




6.2      Closure Plans




                                                                                                                                  Append additional pages as required.

Completed by: _________________________________                                                 Date: ____________________

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Waste Facility Environmental Review - Working Papers    Page B-16
Facility Name:     Verification Date:

7.0 Environmental Setting

7.1 Community Relations

Obtain and review copies of press reports and public complaints. Discuss with senior staff the
approach to dealing with such events. Discuss also how the facility actively seeks out opinions from
the public and other stakeholders. (D,T)

7.2 Facility Setting

Travel around the facility to make note of adjacent and nearby land uses. Review maps and aerial
photos to provide additional information. Contact the local municipality for information on water
supplies in the area. (V,D)

Obtain and review a copy of the original environmental impact assessment for the facility to determine
the site selection process. If the EIA is not available, discuss this with senior staff. (D,T)

7.3 Buffer Zones / Set Backs

Discuss buffer zones and set backs, and related restrictions, with senior staff and a representative of the
local municipality. (T)

7.4 Surface Water

While travelling around the facility to note land uses, make note also of surface water bodies.
Additional information can be obtained from maps and aerial photos. (V,D)

Contact the local municipality for information on surface water use in the area. (T)

Visually inspect the site for surface run-off and run-on controls. Review engineering documents for
additional information on the design of the controls. (V,D)

Visually inspect the site and review facility process drawings and plans for process effluent points.
Identify the receptor of the effluent. (V,D)

Review process design plans and specifications for information on waste water treatment systems.
Discuss with senior environmental staff the testing procedures and quality criteria for waste water.
(T,D)

Inspect facilities and review the spill response plan for procedures and equipment to prevent spills
from contaminating floor drains.

Discuss with senior environmental staff what surface water monitoring is conducted and the design of
the program. Obtain and review related monitoring reports. Determine what criteria is used for
decision making on monitoring results and how the results are used. (D,T)

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Facility Name:     Verification Date:

If the interpretation of monitoring results has indicated an adverse impact, review related documents
and discuss with senior environmental staff what actions will be or have been taken and how these
actions have been determined. (T,D)

7.5 Groundwater

Review groundwater monitoring reports, EIAs and local hydrogeological maps for information on
groundwater in the vicinity of the facility. Contact the local municipality for information on
groundwater use in the area. (D,T)

Discuss the design and operation of the groundwater monitoring program with senior environmental
staff. Review how groundwater data is evaluated, including the criteria used to make decisions. (D,T)

Obtain and review groundwater monitoring and spill reports for information on impacts on
groundwater. Discuss remedial measures with senior environmental staff. (D,T)

7.6 Air Quality

Discuss the design and operation of the stack sampling and air monitoring programs with senior
environmental staff. Review how data is evaluated, including the criteria used to make decisions.
(D,T)

Observe facility operations to determine if dust or other fugitive emissions are issues and how control
is accomplished. Discuss the issue with senior environmental and operations staff. (V,T)

Discuss with senior environmental staff and review monitoring reports for information on any adverse
impacts of air emissions. Discuss remedial measures planned and implemented, and their
effectiveness. (T,D)

7.7      Reportable and Non-Reportable Releases

Review spill and release reports for type, frequency and dates of releases. This section applies to
releases of all descriptions, including those to air, water and soil. Discuss reporting criteria with senior
environmental staff. (D,T)

7.8      Surficial Geology, Soils and Vegetation

Review the facility EIA and local surficial geology maps for information on the local area. (D)

Discuss the design of any soil monitoring programs with senior environmental staff. Review how
monitoring data is evaluated, including the criteria used to make decisions. (D,T)

Obtain and review copies of soil monitoring reports. Discuss with senior environmental staff how it is
determined that soil contamination has occurred. Discuss planned remedial measures. Review past
remedial measures and their success. (D,T)

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Facility Name:     Verification Date:

Visually inspect the site for areas where soil erosion may potentially occur. Examples of such areas
include steep slopes and unvegetated areas. Discuss how erosion is prevented or controlled. (V,T)

Visually inspect the site and neighbouring areas for the types of vegetation present, evidence of
vegetation control, and indications of vegetation damage. Discuss with senior staff the site vegetation
control program and its goals. (V,T)

7.9      Historic Land Use

Review company records, land titles, aerial photographs, historical business directories and historical
municipal records for information on prior land uses on or adjacent to the site. Interview long time
employees for additional information. Land uses of interest include any land use that may have
resulted in residual environmental liabilities. (D,T)

Review pre-acquisition site assessments and those conducted more recently for information on
potential residual liabilities from these previous land uses. Discuss this with senior environmental staff
to determine what actions will be taken. (D,T)




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Waste Facility Environmental Review - Working Papers   Page B-19
Facility Name:     Verification Date:


                                  Document                         Verified?                        Verifier Notes
                                  Section #                                      {Verified by (D)ocumentation / (T)estimonial / (V)isual
                                                                                                    Observation}
                                                                   Y   N   n/a
7.1      Community Relations




7.2      Facility Setting




                                                                                                                   Append additional pages as required.
Completed by: __________________________________                                 Date: ____________________

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Waste Facility Environmental Review - Working Papers   Page B-20
Facility Name:     Verification Date:


8.0 Validation

Complete this section fully and have the verification team leader sign the Declaration. It
is the responsibility of the team leader, prior to signing, to ensure that the verification has
been conducted thoroughly and that the results are accurate.

Have the authorized representative of the facility sign the declaration as well. Ensure that
the representative has been informed of all the results prior to signing.




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Waste Facility Environmental Review - Working Papers   Page B-21
Facility Name:     Verification Date:


9.0 Supporting Documentation

This section is to contain all the documents required by the WFER to be attached. These
documents must include copies of:

   all applicable permits, licences and approvals;
   certificates of insurance coverage;
   a facility site plan; and
   compliance history searches.

Additional documents may be included if they contribute substantially to the content of
the WFER. Otherwise, additional documents should be retained and filed with these
working papers.

Following this page is a blank working paper that can be copied as needed and used with
each of the preceding sections for additional working space.




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Document                         Verified?                                   Verifier Notes
Section #                                          {Verified by (D)ocumentation / (T)estimonial / (V)isual Obse
                             Y      N        n/a




                                                                Append additional pages as required.
            Completed by: _________________________________                                            Date: ___________
                                             APPENDIX C

                PROVINCIAL COMPLIANCE TRACKING INFORMATION
Waste Facility Environmental Review                                                October 1999
Guidance Manual                                                                        Page C-1



Information for obtaining compliance histories through provincial agencies or private
organizations is listed below.

Alberta:

Alberta Environmental Law Centre
The library at the Alberta Law Centre maintains a database of court decisions and
enforcement actions taken by the provincial environmental department.

Contact:        Iris Dujfors, Enforcement Search Service Coordinator
Phone:          (780) 424- 5099
Fax:            (780) 424- 5133
Address:        Alberta Law Centre
                204, 10709 Jasper Ave
                Edmonton, Alberta, T5J 3N3

Database Description:

This database records warnings, enforcement actions and charges, convictions for
permitted facilities. Records date back to 1980‟s.

Database Search Requirements:

 Legal registered name of the company being searched in Alberta.
 Requests must be submitted in writing by fax or mail.
 A valid credit card is required to charge services.
 Results are usually returned by fax the same day as the request.

Cost of Service:

$25 plus GST per search.

British Columbia:

Information from 2 provincial databases should be consulted to complete Section 3 for
BC waste management facilities:

COORs (Conservation Officers’ Online Registry)

Contact:        Dave Mead, Applications Manager
Phone:          (250) 387-6310
Fax:            (250) 387-1041
Address:        Enforcement Unit
                Resource Stewardship Branch
                Ministry of Environment, Lands and Parks


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Waste Facility Environmental Review                                                October 1999
Guidance Manual                                                                        Page C-2



                P.O. Box 9338 Stn Prov. Govt
                Victoria, British Columbia, V8W 9M1

WASTE (database)

Contact:        EMS Help Desk
Phone:          (250) 356-1924
Fax:            (250) 356-6337
Address:        EMS Help Desk
                Ministry of Environment, Lands and Parks
                P.O. Box 9344 Stn Prov. Govt
                Victoria, British Columbia, V8W 9M1
e-mail:         emshelp@gems5.gov.bc.ca

Database Description:

This database records warnings, enforcement actions and charges, convictions for
permitted facilities. Records date back to 1990.

Database Search Requirements:

   Legal registered name and the commercial name of the company being searched.
   Street Address of the facility.
   Permit Number.
   All requests must be submitted in writing (can be faxed , mailed or e-mailed).
   Most searches are completed in one to two working days but may require up to one
    week for searches that requiring accessing regional office information.

Cost of Service:

$50 per search.

Manitoba:

Manitoba Environment can provide an overview of the compliance history of a facility
from central and regional files. Requests for information are circulated through various
branches of the department rather than searched on a single database.

Manitoba Environment Records:

Contact:        Marie Collins, Coordinator
Phone:          (204) 945-7098
Fax:            (204) 984-2338
Address:        File Search
                Manitoba Environment


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Waste Facility Environmental Review                                                October 1999
Guidance Manual                                                                        Page C-3



                123 Main Street, Suite 160
                Winnipeg, Manitoba, R3C 1A5

Database Description:

There are no single computerized databases. Search requests are forwarded to all
branches (central and regional) to assemble information from departmental files.
Available information includes compliance and enforcement action histories, TDG
violations, contaminated site reports, and public complaints received by provincial
inspectors. Some files have over 25 years of catalogued data.

Database Search Requirements:

   A File Search Request Form (attached) must be submitted.

Cost of Service:

$75.00 plus GST per facility.

Ontario:

Compliance information is available from files maintained by the Freedom of
Information Office. Several databases and files are accessed during a search.

Contact:        Fred Ruiter, Freedom of Information Coordinator
Phone:          (416) 314-4075
Fax:            (416) 314-4285
Address:        Freedom of Information Office
                Ontario Ministry of the Environment
                9th Floor, 40 St. Clair Ave West
                Toronto, Ontario M4V 1M2

Database Description:

Several databases and files can be accessed at the main office as well as at district offices.
The main electronic databases that can be used include:

   Occurrence Reporting Information System (ORIS): which records spills, releases and
    other reporting incidents.

   Enforcement Tracking Information System (ETIS): which records enforcement
    actions, warnings, charges and convictions.

Database Search Requirements:



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Waste Facility Environmental Review                                                October 1999
Guidance Manual                                                                        Page C-4



   Legal registered name of the company being searched.
   Address of the facility and/or the head office location.
   All requests must be submitted in writing (can be faxed in advance of the original by
    mail).
   Most search are completed in one to two working days.

Cost of Service:

$30 per hour, minimum 1 hour charge.

Quebec:

Waste management facilities in Quebec are registered through Ministère de
l'Environnement Direction de la coordination opérationnelle. Compliance histories for
individual facilities are available from the corresponding regional office files.

Contact: Mr. Guy Garant
Phone: Not available at this time.
Fax: Not available at this time.
Address:       Ministère de l'Environnement Direction de la Coordination Opérationnelle
               675, boulevard René-Lévesque Est
               Québec (Québec) G1R 5V7


Saskatchewan:

Saskatchewan Environment and Resource Management (SERM) can provide an
overview of the compliance history from central and regional files under their Freedom
of Information Act request system. Requests for information are circulated through
various branches of the department rather than searched on a single database.

Contact:         Teresa Katzberg
Phone:          (306) 787-6542
Fax:
Address:        Unavailable at this time


New Brunswick:

Compliance information is available under the provincial Freedom of Information Act.

Phone:          (506) 453-3827

No details available at this time.



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Waste Facility Environmental Review                                                October 1999
Guidance Manual                                                                        Page C-5



Newfoundland:

Compliance information is available from the Department of Environment and Labour
files.

Contact:        Mr. Toby Matthews, Manager of Environment
Phone:          (709) 729-5793
Fax:            (709) 729-6969

No further details available at this time.


Nova Scotia:

Compliance information is available from Department of Environment files.

Contact:        Ms. Lyla Hailey
Phone:          (902) 424-2549




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