Daily Operations in a Hazardous

Daily Operations in a Hazardous Waste Treatment Facility

Cliff Berry is an hazardous waste disposal firm based out of Ft. Lauderdale, Florida. They operate several facilities around Florida and Virginia, with a total of 180 full-time employees. They have expanded rapidly over the past couple of decades, and now service a region including the entire Southeast U.S. And the Caribbean. They provide a wide range of services including site remediation, industrial maintenance and emergency response, including oil spills. The company services the major ports of South Florida and Cape Canaveral. The focus of this report will be the Miami facility, which forms the core of Cliff Berry's operations.

The Facility and Its Operations

Their Miami facility, situated on the banks of the Miami River, is home to their petroleum and petroleum-based disposal facility. It has run by Phillip Pierre-Louis for over half a decade. This facility is situated along key transportation corridors. The river is a heavily-industrialized river, and flows into Biscayne Bay at the Port of Miami. The port is one of the largest container ports on the East Coast and is also a major hub for cruise ship traffic. Having access along the river provided Cliff Berry with easy access to this business. They are also located along a railway line, and near to a major Interstate and Miami International Airport. This gives them ideal access to the customers with oil waste disposal needs.

The facility specializes in many forms of oil waste treatment and disposal, utilizing a storage capacity of 1.3 million gallons. From this facility, a team is available to contain and clean up oil spills at remote sites. The marine environment of the region is highly sensitive, and contains many rare species. It is integral that spills be contained and cleaned as soon as possible. The Cliff Berry team is able to mobilize quickly. They are equipped with a variety of tools such as vacuum trucks and booms to contain spills. Some of these are held at the Miami facility and workers trained to use them are on call.

Waste treated at this facility is either incinerated or recycled, depending on the type of waste. The wastes treated at the plant fall into EPA categories F037, F038, K048-052, and K169-172.

While incineration is sometimes required, Cliff Berry is a major proponent of recycling and has sophisticated programs in place. They have developed recycling programs aimed at oily wastewater and used oil filters. For example, they process over 10 million gallons per year of oily wastewater that comes from the bilges of large vessels in the adjacent waters. They divert 1,600,000 pounds of used oil filters, melting them down and converting them to manhole covers.

The system for wastewater management is run by a full-time chemist, and tracked using state of the art computerized systems. The pre-treatment facility uses a process called dissolved air flotation. In this system, the wastewater is placed in a pressurized tank and then air is dissolved into it. The pressure in the tank is returned to normal atmospheric pressure, which forces the dissolved air to the surface of the liquid. The oil particles attach themselves to the air and thus float to the surface as well. The oil at the surface is then skimmed and disposed of. Cliff Berry's Miami facility has the capacity to treat 6.3 million gallons per month in this manner. The used oil is then incinerated or, if possible, recycled as it still retains energy value. Incineration is carried out off-site. The water is then recycled back into the public works system.

To facilitate transport of hazardous materials to and from the plant, CBI maintains a fleet of specialized vehicles. They utilize railway containers and a fleet of trucks, some of which have segregated holds to allow for the transport of multiple forms of waste from a single customer.

Customers

The primary sources of waste at the Miami plant of Cliff Berry are the ships that ply the waters around South Florida. The area is home to two major cruise ship hubs at Miami and Fort Lauderdale, as well as two major container ports, the Port of Miami and Port Everglades. Oily bilge water from these ships is processed through this plant. They also service other major area hubs such as Tampa and Cape Canaveral. They work with all the major cruise lines that operate in South Florida.

As well, the plant services the petrochemical industry in the Southeastern U.S.. As the major provider of petroleum waste disposal in the state, they handle material from a wide variety of industrial customers. These include several major oil companies (Chevron, BP Amoco, Mobil, Shell and CITGO). They process millions of gallons of used oil from Quicklube, do-it-yourself drop-off centers and various fleet operations facilities.

There are also governmental customers as well. This is especially for the emergency response function of the Miami facility. For example, CBI is on call for cleanup of oil spills in the region, and also for dealing with hazmat emergencies in Miami-Dade County Schools. They also do on-site work, dealing with industrial site around the Southeastern U.S. And the Caribbean. They have worked on several extraordinary projects, including ship groundings, plane crashes, chemical spills, and plant decomissionings.

Challenges

There are several major challenges facing Cliff Berry. The first is the development of new technologies. The company has sought a leadership role, particularly in the area of recycling. They have a system in place to continually evaluate their processes for improvements, but the development of new technologies is an expensive proposition. They remain a company dedicated mainly to the service side of the business, so are unable to expend too much fiscal capital on research and development, despite the potential for competitive advantage.

Another challenge are the regulatory issues. As the company expands, it finds itself dealing with an ever-increasing set of jurisdictions. Aside from the federal regulations, there are state and county regulations, and the penetration into the Caribbean market has forced them to deal with differing sets of standards and regulations for each island. Moreover, regulations concerning all manner of environmental considerations are becoming more stringent. Although CBI strives to be a leader in developing techniques and technologies for companies to stay ahead of the prevailing regulations, this must still be considered a challenge to be managed.

The company has faced legal proceedings in the past for some of its activities. Two senior employees were charged in 2005 with a handful of charges relating to an alleged scheme to steal jet fuel from a facility CBI was servicing at the Miami International Airport and resell it.

Another challenge is human resources. Cliff Berry has emerged as a leader in the industry, but finding top technical talent remains a challenge. Hazardous waste treatment is a specialized field and the competition for talent can be intense. In a city such as Miami, people's interests often lie more towards sexier occupations than cleaning up oil spills and operating dissolved air flotation units.

Another issue is that of criticism of the hazardous waste disposal industry. The industry is under constant scrutiny to ensure that it is not only adhering to existing codes but is also adhering to more general principles of public safety. Technologies that are relatively new may be sanctioned by the various governing bodies, but can still be at risk of releasing hazardous substances into the environment. This presents an ongoing challenge to Cliff Berry in their operations.

For example, the use of incinerators has come under scrutiny. Studies have shown that people who live adjacent to a commercial hazardous waste incinerator suffer adverse health consequences. This type of study poses an operating risk to Cliff Berry in that it could prompt new, costly regulations, or even a major facilities overhaul.

Another challenge facing the company is the threat of new competition. Given the size of the local ports, the potential market is huge, and this could give rise to new competitors in the marketplace. Cliff Berry prefers to compete on the basis of service and technology, rather than price, but increased competition could reduce the amount of money available for research and development.

Major Regulatory Issues

The treatment and disposal of hazardous wastewater is regulated at the federal, state and county levels. The primary overarching federal body is the Environmental Protection Agency (EPA). The EPA manages hazardous waste through the Code of Federal Regulations (CFR) and the Resource Conservation and Recovery Act (RCRA). Under RCRA, Congress has granted the EPA the authority to develop and manage strict requirements for all aspects of hazardous material management. This includes treatment, storage and disposal. Also included are requirements regarding recordkeeping and reporting at hazardous waste disposal facilities. The strict regulations enforce tracking of hazardous materials at all stages of their lifecycle, described in the industry as "cradle-to-grave."