HYDRO METAL (M) Sdn Bhd 16 April 2012

Recovery License number 002201

SEKSYEN 18(1) EQA, 1974 Offsite recovery for schedule waste: SW110, SW104, SW 202, SW 204, SW 206, SW 325, SW 410, SW 411 and SW 414 Valid from 1/05/2011 to 30 April 2012

Transport license

SEKSYEN 18(1A) EQA 1974 Offsite storage facilities: Collecting, Transferring and Transporting schedule waste: SW110, SW104, SW 202, SW 204, SW 206, SW 325, SW 410, SW 411 and SW 414 Valid from 1/05/2011 to 30 April 2012

SCHEDULED WASTE MANAGEMENT Is there an updated scheduled waste inventory?

REMARKS

Yes, however there is no document that shows the evidence of organization statement. What quantity of petroleum products Unidentified / liquid chemicals is stored on site? Do any underground tanks exist on No site?

List monthly volumes and types of 1) SW110 scheduled and non-scheduled waste Minimum 1 tonne/month generated at this facility. 1) SW104 Minimum 1 tonne/month 1) SW202 Minimum 1 tonne/month 1) SW204 Collecting 204 tonnes/month 1) SW206 1% by product of process SW204 1) SW325 Minimum 1 tonne/month 1) SW410 Minimum 1 tonne/month 1) SW411 Not operate 1) SW 414 Not operate

List and briefly describe each waste Storage area located at a specific storage area. store room, and outside the store room. The store room unable to cater the large amount of waste that had in the organization. How long are wastes stored? Less than 1 month, every month the wastes are transported to landfill and Offsite dispose facility Are wastes treated or disposed of on Waste treated in site and disposed at site? off site What waste streams are generated by SW206 generated as by product of this facility? SW204, and SW501 generated during treatment process or recovery of schedule waste, whereas the other are supply by the other organization around the country.

Are the waste streams generated on The waste continuously generated as a regular basis, or are they one-time long as the process continuous events? (regular basis) and the amount are depends on the amount of main product. Which processes or operations The filtration process through sludge generate the waste? reduction and effluent filtration (Sludge is pumped into the filter as typically a 5% solids slurry. This is reduced to around a 55% dry solids filter cake which is suitable for landfill)

Are wastes from different sources Yes, the waste that generate the mixed? schedule waste from the SW204 which is sludge that come from metals (chromium, copper, nickel, zinc, mercury, lead, cadmium, tin, aluminium, vanadium and beryllium), and the other SW501 waste collects from waste water treatment plant.

ENVIRONMENTAL QUALITY (SCHEDULED WASTE) REGULATIONS, 2005

Reference regulation Regulation 3 Notification of the generation of scheduled wastes

Guidance

Compliance/ Noncompliance 1. The generation of 1. Compliance scheduled waste has 2. Not compliance been notified to the 3. Not compliance DOE (using format in Second Schedule) within 30 days of its generation? 2. Check if waste codes are correctly assigned. 3. Are there any waste that have not been notified to DOE? (including new categories and quantities of waste generated as a result of any alteration at the plant)

Remarks 1. Interview without evidence from the organization. 2. All 9 listed wasted had been register, however the SW501 are not mention in the license. 3. SW501 not include in the license. (1% schedule waste by product generate at every amount of the total main waste)

Regulation 4 Disposal of Scheduled Wastes

Regulation 5 Treatment of scheduled wastes

1. Is scheduled waste disposed of, at a prescribed premise? 2. Do they have copies of the latest valid licence 1. Is scheduled waste treated at a prescribed premise or at on-site treatment facility? 2. Do they have copies of the latest valid licence from the prescribed premise? 3. Are the residuals from the treatment of scheduled waste disposed to prescribed premise?

1. Not Compliance 2. Not Compliance

1. Schedule waste dispose at the offsite dispose facility 2. No license

1. Not compliance 2. Not compliance 3. Not compliance

1. The wastes are not treated but recover at the facility. 2. No license 3. The residual dispose at prescribed premise.

Regulation 6 Recovery of material or product from scheduled waste

1. Compliance 1. Is scheduled 2. Compliance waste recovery 3. Compliance done at a prescribed premise or at on-site recovery facility? 2. Do they have copies of the latest valid licence from the prescribed premise? 3. Are the residuals from the recovery of scheduled waste disposed to prescribed premise?

1. This company is Recovery Company which also generated the schedule waste. 2. The license valid from 1 Mei 2011 to 30 April 2012 1. Some of the waste without special disposal process was dispose on site, where the other are send to offsite disposal facility.

Regulation 7 Application for special management of scheduled wastes

1. Has application 1. Compliance been submitted in 2. Compliance 3. Compliance writing to DOE prior to implementing special management? 2. Has DOE issued approval? 3. Did the approval come with conditions? What are the conditions and do they comply with the conditions

1. Interview without evidence from the organization 2. Interview without evidence from the organization 3. Interview without evidence from the organization, the organizer mention that they already have the certificate of ISO.

Regulation 8 Responsibility of waste generator

1. Compliance 1. Is there any 2. Compliance scheduled waste that has not been properly stored, treated on-site, recovered on-site or not been sent to a licensed facility for storage/treatment/r ecovery? 2. Are the scheduled wastes that are to be moved or transferred out of the plant properly packaged, labelled, and transported?

1. All waste are properly stored, recovered onsite 2. Scheduled waste that transferred out of the plant under condition of properly packaged (drums, jumbo bag, with pallet), labelled, and transported (truck and tanker).

Regulation 9 Storage of scheduled wastes

1. Compliance 1. Are scheduled 2. Compliance wastes stored in containers which are 3. Compliance durable and which are able to prevent spillage or leakage of the scheduled wastes into the environment? 2. Are containers clearly labelled in accordance with the Third Schedule? 3. Are the containers of scheduled waste always closed except where necessary to add or remove the scheduled waste? approval letter from DOE?

1. Stored in drums, jumbo bag, durably and seemly can avoid prevent spillage or leakage of the scheduled wastes into the environment 2. All container clearly labelled (stick on with paper and printed on the container) 3. Interview without evidence from the organization

Regulation 9 Storage of scheduled wastes

4. Are the areas for 1. Compliance 2. Compliance the storage of the containers designed, constructed and maintained adequately to prevent spillage or leakage of scheduled wastes into the environment? 5. Has scheduled waste been stored > 180 days and/or > 20 tonnes? If so, is there

1. There is no leaking or spillage that has been observed during the visit (this is due to the regular maintenance and monitoring process from the organization) 2. Schedule wastes store less than a month, and less than 20 tonnes.

1. Compliance Regulation 10 Do labels on Labelling of scheduled waste Scheduled Waste containers at the central storage locations have date generated, name, telephone number and address of waste generator, First Schedule waste code, Third Schedule hazard signage

1. All criteria are shown at the container.

Regulation 11 Waste generator shall keep an inventory of scheduled wastes

1. Compliance 1. Is scheduled 2. Compliance waste inventory (Fifth Schedule) accurate and up-todate on the quantities and categories of scheduled wastes being generated, treated and disposed of? 2. Have they kept records for at least 3 years?

1. Interview without evidence from the organization, the organizer mention that they already undergoes external audit from DOE. 2. Interview without evidence from the organization, the organizer mention that they already undergoes external audit from DOE.

Regulation 12 Information to be provided by waste generator, contractor and occupier of prescribed premises

1. Compliance 1. Is scheduled 2. Compliance waste inventory (Fifth Schedule) accurate and up-todate on the quantities and categories of scheduled wastes being generated, treated and disposed of? 2. Have they kept records for at least 3 years?

1. Interview without evidence from the organization, the organizer mention that they already undergoes external audit from DOE. 2. Interview without evidence from the organization, the organizer mention that they already undergoes external audit from DOE.

Regulation 13 Scheduled waste transported outside waste generators premises to be accompanied by information

1. Compliance 1. Has the waste generator prepared information in accordance with the Seventh Schedule in respect of each category of scheduled wastes to be delivered to the contractor and informed the contractor of this information.

1. Interview from the organization and the description of the waste characteristics also attach at the container.

Regulation 15 Conduct

1. Compliance 1.Is the staff involved in identification, handling, labelling, transportation, storage, spillage or discharge response properly trained?

1. Interview with chief and the worker of organization. Most of worker do multiple work and had go through training from the start work and continuously briefing by their chief of organization.

Conditions of Approval

1. Compliance 1. Check the Conditions of Approval and determine if all conditions have been met for e.g. validity period of the Conditions of Approval volume of scheduled waste generated does not exceed allowed volume monitoring parameters and frequency reporting to DOE