U.S Postal Service, Nation-Wide Locations, Environmental Compliance Reviews

DPRA, under a national contract with the U.S. Postal Service, conducts multi-media environmental compliance reviews (ECRs) at USPS facilities all across the country. The ECR Program helps minimize USPS environmental liabilities by identifying areas of non-compliance and providing recommendations to remedy these deficiencies. The program provides a determination of facility conformance with applicable federal, state, and local environmental laws and regulations as well as an assessment of the adequacy of environmental compliance management programs and systems. Over the past six years DPRA has conducted hundreds of ECRs at Mail Processing and Distribution Centers, Bulk Mail Centers, Vehicle Maintenance Facilities, and Main Post Offices ranging in size from a few hundred to over a million square feet. DPRA has performed these reviews in 31 states, Washington, DC, and Puerto Rico.

DPRA performed Hazardous and Solid Waste Amendments (HSWA) completeness reviews of approximately 100 hazardous waste facilities in eight U.S. EPA regions and evaluated the responses in accordance with the provisions of the 1984 amendments to RCRA. Facilities reviewed included petroleum refineries, chemical plants, waste recycle and reclamation, DOE installations, military bases, metal fabricators, steel mills, wood treaters, munitions facilities, and research institutions. The majority of this work involved completing a RCRA facility assessment (RFA) for each facility, under the corrective action provision of HSWA. A three-phased approach was taken at each facility. The first phase of the RFA required a thorough desktop review of all documents available on solid and hazardous waste management activities at a facility. Documents reviewed included the facility's Part A and Part B applications, Part B application Notice of Deficiency responses, Exposure Information reports, correspondence with regulatory agencies, National Pollutant Discharge Elimination System (NPDES) files, Comprehensive Environment Response, Compensation, and Liability Act (CERCLA) files, and Air Permit files. Completion of this phase involved gaining an in-depth technical understanding of the production processes, wastes generated and waste management activities at the facility in question. The second phase of the RFA consisted of a site visit to the facility to visually inspect each solid waste management unit (SWMU), gain additional information on waste management activities, and determine necessary sampling locations. The last phase of the RFA involved sampling at the facility to determine if releases from any SWMU have occurred. A final RFA report was prepared for each facility incorporating the information obtained from the three phases. This report determined the release potential for each SWMU and recommended action to the regulatory agency.  

The objective of this project was to provide training to USPS environmental staff from all over the country on the performance of environmental compliance reviews. This assistance included development of a training program that was tailored to the USPS ECR program requirements and the specific issues or situations encountered at USPS facilities during the performance of ECRs. DPRA developed a training agenda, presentations, and handouts that were used for one and a half day training sessions. DPRA referenced USPS ECR program documents that addressed each topic covered and relied on industry standards to complement existing USPS materials. Training materials included examples or situations typically encountered at USPS facilities and used modeling and role-playing exercises, as appropriate, as training tools. The training sessions focused on ECR skills and included the following topics: General Principles, Pre-Visit Activities, Site Visit Activities, Post-Visit Activities, and Other Issues such as demeanor, dispute resolution, timing and scheduling, documentation, and communication.

DPRA performed a wide variety of environmental compliance support services at two facilities in northeast Wisconsin, one facility manufacturing stainless steel laboratory tables and another facility manufacturing wood cabinets. Environmental compliance activities at this facility include air permit compliance, hazardous waste generation and management, and wastewater discharge monitoring. The facilities included operations involving the cutting and forming of stainless steel, powder coating of stainless steel, cutting of wood and fabricated wood materials, application of varnishes to wood cabinets, and the operation of boilers burning scrap wood and natural gas. Tasks completed by DPRA personnel included development of air control equipment operation and maintenance plans, waste stream identification and characterization, air emissions recordkeeping and reporting, and Toxic Release Inventory reporting.