The following information should be gathered during the on-site visit which will enable you to make an intelligent, informed decision as to whether the facility meets not only U.S. environmental regulations but also your own.

• How is electrical equipment being processed in-house?

• Are oil storage tanks equipped with overfill alarms?

• Is the oil storage area diked within roof and walls as required by the regulations?

• What type of in-house cleaning equipment is employed for removal of oily residues on metal? How are the residuals disposed?

• Is anything stored outside? If so, is there any chance of accidental contamination via leaking or seepage into the ground?

• Inquire as to any spills, indoors or outdoors, in the facility's history.

• Is all loading or unloading done inside the building? Check the ceiling height to ensure that untanking of substation transformers can be accomplished inside.

• Does the facility have an impermeable membrane liner beneath the flooring?

• Check the condition of floors - are all construction joints and cracks caulked to prevent oil seepage beneath the concrete?

• Are floors coated with sealer which is represented by the manufacturer to resist PCBs?

  What type of washing process is used to remove residuals from:

  Distribution and Substation Transformer Tanks

  Silicon Laminations

  Core and Coil Frames

  Copper & Aluminum Coils

  Substation Radiators

  and Bushings

• Check sampling protocol and standards to be obtained through cleaning process? Are they cleaning all metals to <10mg/100 sq. cm?

• Check volume and date of on-hand inventory to verify that first in, first out processing is used and that the company will be capable of processing your material in a timely manner. Does the facility have the necessary capacity to handle anticipated or represented volumes?

• Check finished scrap material for oily residues.

• Where are solvents stored, recycled or disposed?

• Where is incinerator ash stored or disposed? Review any analysis of incinerator ash to determine if it contains hazardous waste other than PCBs.

• Are all metals washed regardless of contamination?

• Does the facility have permits for waste water discharge, and/or air emissions? Review permits, reports and the results of any and all inspections regarding air and water?

• Training programs should include Hazardous Communications, WHMIS, Respirators, Confined Space Entry, Hazardous Waste Handling, Metal Cutting Training, etc.

• Is an in-depth medical monitoring program in place for all process employees?

• What analysis does the company perform to insure against PCB contamination (indoors, outdoors, and transportation equipment).

• Review the perspective company’s medical monitoring plan.

• Documents of Incorporation - Is there a clear line of ownership of the facility or do you get lost in "subsidiaries of subsidiaries.?"

• Was the site audited prior to construction or start-up of the operation, establishing a background history of possible PCB contamination?

• Review the company’s contingency plan, closure plan, and spill prevention control and counter measure plan.

• Previous land ownership and use - What is the history of use for the site and others owned by the company (especially the use of the land prior to the 1979 PCB regulations)?

• Where is non-regulated material disposed?

• Obtain copies of steel, copper & aluminum mill weight tickets, for the purpose of mass balance determination where the company disposes of metal, be it a scrap yard or smelter.

• Financial - Has the company made any investments in the past year to improve or expand its processes?