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Planning for Environmental Protection 163
wastes, however, does not necessarily remove liability for what subse-
quently happens to those wastes. Because the company that generated
the wastes normally retains liability, great care should be exercised
in selecting and using commercial waste disposal facilities. One way
to minimize the risk of liability after custody of the waste has been
transferred is to develop a formal certification process (Steingraber et
al., 1990).
The first step in the certification of a waste disposal facility is to
gather as much information about the facility as possible. This infor-
mation includes institutional information, which includes its conform -
ance record for existing rules and regulations, its operational and
physical capabilities, and the geologic and hydrologic conditions at the
site. A detailed site visit should also be conducted. A set of criteria
for deciding whether a facility is acceptable or not must also be
developed. If a facility has been certified to be acceptable and wastes
are shipped to it, the facility should be reevaluated on a regular basis.
Part of the certification process for off-site disposal of wastes is
an evaluation of how the wastes are transported to the facility. Reput-
able haulers that have all necessary permits for waste transportation
must be selected. Manifests of all materials shipped are also required
to maintain a paper trail on the disposition of the wastes.
5.5 CONTINGENCY PLANS
Contingency plans are needed to prepare a facility to minimize the
impact of any foreseeable emergency. Contingency plans for environ-
mental protection outline the response of all personnel to an accidental
release of materials that can impact the environment. These plans
describe ways to eliminate the source of the release, to assess the
character, amount, and extent of the release, to identify ways of
containing the release so any impacts are minimized, to recover all
lost or contaminated materials, and to notify relevant regulatory
authorities. Contingency plans must carefully and completely document
the response of all personnel in the event of an emergency (Tomlirt
and Snider, 1994).
Contingency plans supplement, but do not replace, waste manage-
ment plans. They provide a framework to prepare for and handle all
significant risk scenarios. Like all waste management plans, contin-
gency plans should be in writing. A contingency plan must be accepted