805 WASTE MGMT.
GENERAL SAFETY PROCEDURES
WASTE MANAGEMENT
Procedure Number: GSP-805
TABLE OF CONTENTS
WASTE MANAGEMENT – GSP-805
1.0 PURPOSE 1
2.0 SCOPE 1
2.1. Personnel Covered by this Procedure 1
2.2. Activities Covered by this Procedure 2
2.3. Other Items Covered by this Procedure 3
2.4. Exemptions from this Procedure 3
3.0 TRAINING / PERSONNEL REQUIREMENTS 3
4.0 PROCESS OVERVIEW OF WASTE MANAGEMENT 5
5.0 PROCESS OVERVIEW OF WASTE STORAGE 6
6.0 PROCESS OVERVIEW OF OFF-SITE WASTE MANAGEMENT 7
7.0 PROCESS OVERVIEW OF SAMPLING AND ANALYSIS 8
8.0 WASTE MANAGEMENT 9
8.1. Instructions For Waste Specification Sheets 9
8.2. Waste Handling 9
8.3. Pollution Prevention Opportunities 9
8.4. Roles and Responsibilities 9
8.5. Reporting Requirements 9
8.6. Documentation and Record Retention 9
9.0 STORAGE OF INDUSTRIAL WASTE 9
9.1. Activities Covered By Storage Or Generation Of Waste 9
9.2. Exemptions From This Procedure 9
9.3. Other Requirements 9
9.4. Instructions Storage Area Requirements 9
9.5. Selection Of Waste Storage Containers 9
9.6. Determining Label Requirements 9
9.7. Labeling Containers 9
9.8. Filling Containers 9
9.9. Handling Containers 9
9.10. Inspecting Containers 9
9.11. Satellite Accumulation 9
9.12. Storage Reporting Requirements 9
9.13. Federal and State Reporting Requirements 9
9.14. Documentation and Record Retention 9
10.0 OFFSITE SHIPMENT OF WASTE 9
10.1. Prerequisites for Shipping Waste Offsite 9
10.2. Other Requirements 9
10.3. Select Disposal Site 9
10.4. Select Transporter 9
10.5. Schedule Shipment 9
10.6. Package Waste For Shipment 9
10.7. Label Container 9
10.8. Prepare Shipping Documentation. 9
10.9. Offer Placarding 9
10.10. Conduct Pre-Transportation Inspection 9
10.11. Log Shipment 9
10.12. Verify Return Of Manifest 9
10.13. Reporting Requirements For Waste Shipments 9
10.14. Documentation And Record Retention For Waste Shipments 9
11.0 WASTE SAMPLING 9
11.1. Activities Covered By Waste Sampling 9
11.2. Exemptions from Waste Sampling 9
11.3. Equipment Requirements 9
11.4. Other Requirements 9
11.5. Instructions for Waste Sampling 9
11.6. Sample Container Labels 9
11.7. Sample Collection Requirements 9
11.8. Sample Shipment 9
11.9. Analytical Report 9
11.10. Roles And Responsibilities For Sampling Waste 9
11.11. Reporting Requirements For Waste Sampling 9
11.12. Waste Sampling Documentation And Record Retention 9
12.0 APPENDIX A - GLOSSARY 9
13.0 APPENDIX B - WSS EXPLANATION 9
14.0 APPENDIX C - OTHER WASTE MANAGEMENT PROGRAMS 9
15.0 APPENDIX D - SAMPLING EQUIPMENT 9
16.0 APPENDIX E - SAMPLE COLLECTION METHODS 9
17.0 APPENDIX F - CHAIN OF CUSTODY 9
18.0 APPENDIX G - FEDERAL HAZARDOUS WASTE CLASSIFICATION 9
19.0 APPENDIX H - STATE NON-HAZARDOUS WASTE — TEXAS 9
20.0 APPENDIX I - HAZARDOUS WASTE DETERMINATION 9
APPENDIX J - WASTE STORAGE AREA ACTIVITY AND INSPECTION 9
21.0 APPENDIX K - MATRIX OF GENERATOR STATUS AND ACCUMULATION TIME 9
22.0 APPENDIX L - LABELS 9
PURPOSE
The purpose of this procedure is to provide guidance and information necessary for the proper management of industrial wastes in compliance with the applicable laws and regulations, as well as in compliance with Valero Terminaling and Distribution Company (Valero) policies. This procedure addresses the following:
• An overview so that industrial waste generated from Valero operations can be properly managed
• Steps to follow when storing industrial waste at Valero facilities
• Provide instructions for obtaining appropriate and representative samples of the waste
• Enable personnel to submit representative samples for certified analysis so the waste may be characterized
• Compliance with the federal program which regulates hazardous waste (RCRA) as well as applicable state regulations for both hazardous and non-hazardous wastes
• Ensure that the shipping, disposal and reporting requirements for industrial waste are met.
• Use of the Waste Specification Sheet (WSS – Form - 675, see Appendix B). WSS's provide detailed waste management information about a specific waste. Consult local Environmental Health &Safety (HSE)Representative.
• Disposal of wastes within applicable holding times. Exceeding the storage time limits specified on the Waste Specification Sheet may result in enforcement action by regulatory agencies.
• Transportation and disposal of industrial waste in accordance with applicable regulatory requirements.
SCOPE
1 Personnel Covered by this Procedure
This procedure applies to all personnel, company or contractor, working in or on the Valero owned, operated or maintained pipelines or facilities that generate and manage industrial waste. Industrial waste management primarily occurs at terminal and pipeline facilities, but may also occur in some office settings (e.g., where copier toner or some drafting wastes are generated).
2 Activities Covered by this Procedure
This procedure applies to management of the Valero’s industrial waste.
Generation is the term used to describe when a material becomes a waste. A material is not considered a waste if it can still be used in the same system or process in which it was generated. For example, all the free liquid from a crude sump which can be re-injected into the pipeline is not a waste. When the material is removed from the process and cannot be reused in the system as is, it must be managed as a waste. The following are some examples of when materials become wastes:
• Internal scale from a pipeline becomes a waste when it is removed from a scraper trap.
• Pipeline coating becomes a waste when it is removed from the pipe, or when the pipe is dismantled.
• A commercial product becomes a waste at the time it can no longer be used for it intended purpose (e.g., product is past its expiration date).
Industrial waste does not include:
• Office refuse (e.g., paper, cardboard, etc.), with the exception of copier toner cartridges, some drafting waste (i.e., blue line machine solution, waste ammonia)
• Uncontaminated construction debris/rubble
• Food waste
Proper waste management at Valero facilities requires that the following conditions are met:
• Waste must be managed in accordance with this procedure and the applicable WSS.
• Waste sampling must be conducted per Section 11.
• Waste storage must be conducted per Section 9.
• Off-site waste management must be conducted per Section 10.
• All wastes must be managed in appropriate containers.
• Waste may not be stored beyond the regulatory time limits specified on the WSS.
• Valero facilities are not permitted to receive hazardous waste from off-site.
• Valero facilities are not permitted to treat hazardous waste without prior approval of the HSE Representative.
3 Other Items Covered by this Procedure
Many of these practices also apply to recycled materials. Contact the HSE Representative to discuss which recycling activities should have a WSS. See Appendix C for a listing of additional waste management programs which may apply to your waste stream.
4 Exemptions from this Procedure
The waste characterization process will be performed by the HSE representative.
TRAINING / PERSONNEL REQUIREMENTS
Personnel who manage hazardous waste must successfully complete a program of classroom instruction and on-the-job training (within six months after the date of their employment or assignment to the facility) to perform their job in a way that ensures the facility's compliance. New employees must not work in unsupervised positions until they have completed the above training. Facility personnel must take part in an annual review of the initial training program.
The training program must be directed by a person trained in hazardous waste management procedures, and must include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed. All persons managing waste must meet all OSHA required training requirements. For large quantity generators this includes 40 hours of HAZWOPER("Hazardous Waste Operations and Emergency Response") with 8 hour annual refresher.
Cited in the Code of Federal Regulations as 29 CFR 1910.120. Minimum training requirements for hazardous waste site workers are outlined in paragraph 1910.120(e) of HAZWOPER: 40 hours of training and three days of supervised field experience is required for general site workers; 24 hours of training and one day of supervised field experience is required for workers who are on site only occasionally for a specific limited task who are unlikely to be exposed over permissible exposure limits (PELs) and published exposure limits; 24 hours of training and one day of supervised field experience is required for workers who are on site regularly and will only enter areas that have been fully characterized, indicating that exposures are under the PELs and published exposure limits. HAZWOPER is not required for workers where there is no potential for exposure to hazardous substances.
An example of individuals who do not need to be trained in accordance with 1910.120(e) are personnel who work solely in offices or trailers next to the site. These personnel should be made aware of the boundaries of exclusion, or "hot zones", and the places of refuge in case of an emergency.
Personnel directly responsible for loading trucks, and/or preparing shipping documents for hazardous waste must also be trained in DOT regulations.
Other Requirements
1 A current or interim Waste Specification Sheet must be obtained before using this procedure.
2 Facilities that generate hazardous waste must have an identification number issued by the EPA or equivalent State agency. If a facility is expected to generate hazardous waste and it does not have an ID number listed in the applicable system/facility manuals, contact HSE to obtain an ID number.
PROCESS OVERVIEW OF WASTE MANAGEMENT
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PROCESS OVERVIEW OF WASTE STORAGE
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PROCESS OVERVIEW OF OFF-SITE WASTE MANAGEMENT
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PROCESS OVERVIEW OF SAMPLING AND ANALYSIS
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WASTE MANAGEMENT
1 Instructions For Waste Specification Sheets
Verify the existence for a Waste Specification Sheet (WSS) for the subject waste stream. If a WSS is not available contact the designated HSE representative.
Evaluate whether the WSS is up-to-date:
1 Has the process changed since waste was last generated?
2 Has the expiration date of the WSS been exceeded?
If the answer is yes to either questions contact HSE to update the WSS.
2 Waste Handling
Manage waste in accordance with the WSS, Sampling and Analysis procedure starting in section 11, Waste Storage starting in section 9 and Off-Site Waste management starting in section 10. Waste Sampling will not always be used if there is direct generator knowledge of the components of the waste.
NOTE: A WSS must be completed for all industrial waste generated in Valero regardless of whether the waste is hazardous or non-hazardous.
3 Pollution Prevention Opportunities
Evaluate the Pollution Prevention Procedure to determine how the volume or toxicity of a hazardous material can be reduced or eliminated.
4 Roles and Responsibilities
Responsibilities of the Supervisor
The Supervisor is responsible for:
1 Compliance with the Waste Management Procedures and the regulations pertaining to waste management
2 Determining when a new or revised WSS is needed due to operational changes or expired WSS's
3 Obtaining the waste containers
4 Selecting the storage area
5 Security of the accumulation site
6 Containerizing the wastes
7 Labeling, handling, storage, and inspection of waste containers
8 Ensuring an appropriate disposal facility is selected
9 Ensuring waste is packaged and shipped properly
10 Ensuring shipping documents are completed properly
Responsibilities of Employees
The Terminal/Pipeline employees are responsible for collecting samples or arranging for laboratory to collect. HSE will work with the Team to develop the sample plan and determine the analytical requirements.
Responsibilities of the Designated HSE Representative
The Environmental Representative is responsible for:
1 Providing regulatory guidance
2 Communicating new regulatory requirements and initiating the update process when required because of a change in the regulations
3 Developing and revising WSS's due to regulatory changes
4 Providing disposal facility choices on the Waste Specification Sheet and conducting profiling
5 Completing or revising the Waste Profile and submitting it to the TSD for their approval. The HSE Representative is also responsible for evaluating the sample results and making the characterization determination. See Appendix G for an overview of the characterization criteria.
Overall Responsibilities of Valero
Valero is ultimately responsible for regulatory compliance from the moment the waste is generated through all subsequent management steps including disposal. This philosophy is known as "cradle to grave” responsibility.
5 Reporting Requirements
General Reporting Requirements
1 Copies of Activity and Weekly Inspection Logs (Form-678) for the month must be sent to HSE by the 15th of the following month.
2 The Supervisor or his designee will be notified when abnormalities are noted on the weekly inspection log.
3 The Supervisor or his designee and the HSE group will be notified if hazardous waste is released from the container.
Federal And State Reporting Requirements
1 If a spill exceeds the reportable quantity the NRC and State agencies must be notified by the Supervisor or his designee. All spills must be reported to the HSE Representative.
2 Contingency plan implementation follow-up documentation to the agencies is the responsibility of the HSE group.
Valero Reporting Requirements
• Waste quantities and waste management costs are required for Valero's Pollution Prevention Inventory.
Federal / State Reporting Requirements
• Some generators are required to submit a bi-annual report to the EPA and/or equivalent State agency detailing hazardous waste activities. Some states require reports more frequently. This requirement is usually triggered if a threshold amount of waste is exceeded. HSE will coordinate preparation of these reports with input from the unit teams.
6 Documentation and Record Retention
Required Documentation
The following documents and records must be maintained at the facility office for all personnel involved in hazardous waste management:
1 The job title for each position at the facility related to hazardous waste management and the name of employee filling each job
2 A written job description for each position listed above, including the requisite skill, education, or other qualifications and duties of facility personnel assigned to each position
3 A written description of the type and amount of both introductory and continuing training that will be given to each person filling a position listed above
4 Records that document the training or job experience has been given to, and completed by facility personnel.
Required Documentation for Waste Storage/Accumulation
Activity and Weekly Inspection Logs (Form-678) will be used to document compliance with storage requirements.
Documentation and Record Retention for Waste Storage/Accumulation
Activity and Weekly Inspection Logs (Form-678) will be kept for a minimum of three years at Team office.
Other Documents which may be required:
1 A contingency plan for large quantity generators in the event of a release or fire ( typically can use SPCC plan as long as waste locations are included along with fire fighting capabilities)
2 Documentation that local hospitals and emergency response organizations, (i.e. police, fire and local hospitals) have been notified of contingency plan
3 A listing of each waste generated at the facility and storage locations
4 Documentation of Storage and Retention Time
5 All documentation mentioned in this section should be maintained at the facility office and be kept indefinitely unless otherwise noted.
6 Training records on former employees must be kept for at least three years from the date the employee last worked at the facility. Training records may accompany personnel transferred within the same company.
Reporting Requirements for Waste Shipments
1 Valero Reporting Requirements
• A copy of each month's manifests and Bill of Lading must be sent to the HSE Representative by the 15th of the following month.
• The disposal facility and HSE must be contacted if a signed Uniform Hazardous Waste Manifest (UHWM) copy is not received back from the disposal facility within 35 days. Document date and person contacted if a manifest is not returned.
2 Federal Reporting Requirements
• If the signed UHWM manifest is not received within 45 days, an exception report (contact HSE Representative) must be sent to EPA and/or state and a copy to the TSDF.
• Bi-annually a full report of all hazardous waste shipments for that selected year must be filed with EPA and certain states.
3 State Reporting Requirements
Check with your State.
Documentation And Record Retention For Waste Shipments
1 Required Documentation to be maintained by the hazardous waste generator:
2 Copies of all UHWMs
3 Land Disposal Restriction (LDR) certification or treatment standard information must be kept with the UHWM
4 Exception reports
5 A legible copy of the manifest for which you have not received TSD confirmation
6 Non-hazardous waste generators must maintain copies of all shipping papers
Document Storage and Retention Time
Copies of all waste records must be sent to the HSE group. After three years, shipping papers may be scanned and maintained as a computer copy, or otherwise reduced for easy storage. Ensure that these records are retrievable when needed and retained indefinitely.
STORAGE OF INDUSTRIAL WASTE
1 Activities Covered By Storage Or Generation Of Waste
This procedure describes the steps necessary for proper management of containerized waste. It includes the requirements for the storage area, container selection and management, container labeling, container inspection, and contingency plans. This procedure may be used for characterized and non-characterized waste.
This procedure addresses only waste stored in approved containers. Hazardous waste may not be stored in tanks designated for petroleum or slop storage.
2 Exemptions From This Procedure
The requirements of procedure Sampling & Analysis and Off-Site Waste Management procedures are not included in this procedure and must be taken into account when conducting these activities.
3 Other Requirements
A current or an interim Waste Specification Sheet must be obtained before using this procedure.
As part of the storage area contingency plan requirements per regulations (40CFR265 Subpart C and D) the storage area must be operated and maintained to minimize the possibility of fire, explosion, or a sudden or non-sudden release of hazardous waste which could threaten the environment. The storage area contingency plan must be incorporated into the Emergency and Oil Spill Response Plans.
The storage area contingency plan is designed to ensure personnel can respond effectively to emergencies by familiarizing them with emergency procedures, equipment, and systems, including where applicable:
1 Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment
2 Communications or alarm systems
3 Response to fires or explosions
4 Shutdown of operations
4 Storage Area Requirements
The Supervisor or his designated representative will select a storage area meeting the following requirements:
Location
1 The storage area must be located within the facility fence line. All hazardous waste must be stored at least 50 feet within the facility fence line.
2 The storage area must also be separated from sources of ignition or sparks such as, open flames, smoking areas, and welding/cutting operations.
Separation
1 If incompatible wastes (e.g., acids and bases) are stored, ensure that wastes are physically separated and sealed in approved containers.
2 The storage area may contain hazardous and non-hazardous waste but they should be physically separated.
Size
Storage areas should be sized to handle bulk containers such as frac tanks, roll off boxes, cutting boxes, etc.
Security Requirements
The storage area must be secured when no employees are on site.
Design and Construction — Recommended Practices
The following are recommended design and construction guidelines for storage of hazardous waste:
1 Secondary containment should be provided to ensure none of the waste will leave the storage area in the event of a spill
2 Secondary containment should be impervious to the wastes stored
3 Storage area must be capable of containing rainfall plus 10% of the aggregate waste volume or volume of the largest container (liquid containers only)
4 Storage area should be designed and constructed to prevent rainwater runoff from exiting the storage area
5 Selection Of Waste Storage Containers
Refer to the Waste Specification Sheet for proper container types. Container selection will depend on the type and amount of waste generated. Ensure that the waste container is a DOT approved container. If the container does not meet DOT requirements, Subpart CC rules may require VOC testing and analysis per 40 CFR 264/265 if a large quantity generator. Consult the HSE Representative for Purchasing for guidance.
6 Determining Label Requirements
All containers must be labeled. Refer to the Waste Specification Sheet for proper container labeling. Three types of labels may be used-
Hazardous Waste
Non-Hazardous Waste
Waste Pending Analysis. A Waste Pending Analysis label must be placed on containers until characterization is complete.
Consult the HSE Representative for approved labeling materials.
7 Labeling Containers
Waste containers must be labeled per the Waste Specification Sheet using an indelible marker. If the material requires characterization, the waste pending analysis label will be replaced with the proper label once the characterization is complete.
Appendix L contains examples and descriptions of hazardous waste, non-hazardous waste and waste pending analysis labels.
8 Filling Containers
Don any required Personal Protective Equipment (PPE) when handling wastes. The MSDS and Waste Specification Sheet contain lists of required PPE's. Call the HSE Representative when needed.
Keep trash and other non-hazardous waste (e.g., soda cans, etc.) out of potentially hazardous materials
Prior to transferring a waste into a container, the container must be examined for signs of deterioration, or any other defects that may impair its integrity. Transferring wastes to containers should be conducted over a protected (plastic or impermeable) surface, in order to prevent contamination of the area. Containers should be filled to between 90-95% of capacity. Liquid and solid wastes must be containerized separately.
9 Handling Containers
Handle containers in accordance with the following requirements:
1 Place containers in designated storage area
2 Keep containers closed except when adding or removing wastes
3 Handle and store containers in a manner which will not cause the container to be damaged, ruptured, or the contents to be spilled
4 Store drums on pallets whenever feasible
5 Store containers with adequate aisle space (24” minimum spacing recommended) to allow the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment in the event of an emergency.
10 Inspecting Containers
Inspect containers weekly and complete Activity and Weekly Inspection Log, Form-678 (see Appendix J)
Containers and the containment area must be examined for signs of leakage or deterioration, including spilled or leaked waste, and accumulated water. Inspections should include number of containers, verify no leakage, adequate aisle space (at least 24 inches). Check that all containers are sealed, labeled, and the accumulation time to ensure containers do not exceed the legal limit for storage time.
These logs should be filled out even when no waste is in the storage area (note if waste is hazardous and is not in a DOT approved container; VOC monitoring may be required).
Correct any non-compliance situations immediately. If this cannot be accomplished, the Supervisor or his designee must be notified. The Supervisor or his designee is responsible for taking corrective action to remedy the abnormality, making the required notifications and documenting the corrective action on the Inspection Log.
11 Satellite Accumulation
Hazardous waste can be accumulated at or near the point of accumulation for up to 12 months in a Satellite Accumulation Area. The following procedures must be observed:
1 One container of waste is permitted near or at the point of generation in the direct view of the operator.
2 The container must be identified as Hazardous Waste and a description of the contents provided.
3 Only 55 gallons of material are permitted at one satellite location
4 Once the container is full it must be labeled, dated and moved to 90-day storage within 3 days.
5 The Satellite Accumulation Area must be documented as a storage area and noted in the contingency plan
6 The area should be inspected once a week for compliance.
7 DOT Approved Containers must be used.
12 Storage Reporting Requirements
Copies of Activity and Weekly Inspection Logs (Form-678) for the month must be sent to HSE by the 15th of the following month.
The Supervisor or his designated representative will be notified when abnormalities are noted on the weekly inspection log.
The Supervisor or his designated representative and HSE will be notified if hazardous waste is released from the container, (Valero-140 or GO-140 must be submitted.)
13 Federal and State Reporting Requirements
If a spill exceeds the reportable quantity the NRC and State agencies must be notified by the Supervisor or his designated representative. See reporting requirements in the EOSR plan.
Contingency plan implementation follow-up documentation to the agencies is the responsibility of HSE.
14 Documentation and Record Retention
Required Documentation
Activity and Weekly Inspection Logs (Form-678) will be used to document compliance with storage requirements.
Documentation and Record Retention
Activity and Weekly Inspection Logs (Form-678) will be kept for a minimum of three years at Team office.
Other Documents which may be required:
1 A contingency plan for large quantity generators in the event of a release or fire ( typically can use SPCC plan as long as waste locations are included along with fire fighting capabilities)
2 Proof that local hospitals and emergency response organizations, (i.e. police, fire and local hospitals) have been notified of contingency plan
3 A listing of each waste generated at the facility and storage locations
OFFSITE SHIPMENT OF WASTE
This procedure covers the requirements necessary to properly dispose of industrial waste at a Valero approved facility. This procedure also applies to industrial material that is being sent off-site for recycling. It details the requirements for packaging, transporting and documenting waste for disposal. This procedure is to be used with procedures , “Waste Management,” “Sampling and Analysis,” and “Waste Storage.”
Hazardous waste can be transported off-site only by registered transporters and can only be disposed of in permitted hazardous waste Treatment Storage and Disposal Facilities (TSDF). Both transporter and TSDF must have an EPA I.D. number. Employees must not transport hazardous waste off-site. All waste transportation must be conducted by an approved waste hauler.
Hazardous waste can be transported within a facility without a registered transporter.
1 Prerequisites for Shipping Waste Offsite
The training requirements of Waste Management Section 1.0 must be satisfied for all Valero personnel involved in transportation and disposal of industrial waste.
Certified, approved transporters must be used.
2 Other Requirements
A current Waste Specification Sheet must be obtained before using this procedure.
A disposal facility that is currently on the Valero "Selected for Use" list must be used. Disposal facilities not on the approved list must be audited prior to use. Valero's Corporate HSE group will conduct all audits.
Approved profiles for all hazardous waste and some non-hazardous waste streams must be on file at the disposal facility before they can be accepted. Profiles will be managed by the HSE group.
Hazardous waste must meet the Land Disposal Restriction prior to disposal in a landfill. If the waste does not meet the requirements, additional treatment must be conducted (usually by the Treatment, Storage, and Disposal Facility). Free liquids may not be disposed of in a landfill.
3 Select Disposal Site
Review the Waste Specification Sheet and select the disposal site. The selection of a disposal site includes:
1 A profile must be in place for hazardous waste disposal. If a number is not listed on the Waste Specification Sheet, contact the HSE Representative.
2 Only Valero's approved facilities may be used for industrial waste. Industrial material destined for off-site recycling may only use Valero approved facilities (e.g., contaminated drums to drum reconditioner).
4 Select Transporter
Only approved transporters may be used to transport waste.
5 Schedule Shipment
Contact transporter and disposal site to schedule the shipment. In many cases the disposal site can arrange transportation.
6 Package Waste For Shipment
Package hazardous waste in DOT approved containers as described on the Waste Specification Sheet and in Waste Storage and ensure that containers are in good condition prior to shipping. Replace or repair damaged containers immediately. Repairs can include changing a lid that is damaged or using an overpack drum. When using an overpack drum, the damaged container is placed in the overpack drum. This can be costly, but eliminates transferring the waste out of one container and into another.
NOTE: Transportation companies will not transport wastes that are not properly packaged or containers that are in poor condition.
Containers with wastes that are sent to a landfill must not contain any free liquids. Containers placed in landfills (i.e., drums) must be 90% full, crushed, or very small.
If there are several small containers of chemicals that need to be disposed of, an environmental contractor may be used to pack the small containers into a lab pack prior to transport. The containers will be lab packed as follows.
1 Each small container of the chemicals meets all applicable DOT specifications
2 Small containers are placed in an open-head metal DOT shipping container (lab pack) with a maximum capacity of 110 gallons
3 Incompatible materials are not placed in the same shipping container
4 Small containers in the overpack are surrounded by absorbent material which will not react with the chemicals
5 Adequate absorbent material is provided to completely absorb all containerized liquid in the overpack drum
6 Reactive waste, other than cyanide or sulfide-bearing waste are rendered non-reactive before packaging
7 Label Container
A label is a specific hazard symbol that informs persons handling the package of possible hazards. Examples of labels are "POISONOUS", "CORROSIVE", "IRRITANT", etc.. In addition, lab packs, over packed drums, and containers less than 55 gallons must be marked with "THIS SIDE UP" or "THIS END UP", as appropriate to indicate the upward position of the inside packaging. A label must be attached prior to transporting.
NOTE: DOT uses different terminology for transportation than EPA requires for storage. For transportation purposes labels are hazard symbols, etc. Hazardous waste labels as described in Waste Storage starting in section 9 are considered markings by DOT.
8 Prepare Shipping Documentation.
Hazardous Waste Shipping Documentation
The shipping documentation for hazardous waste is the Uniform Hazardous Waste Manifest (UHWM)(note the hazardous waste manifest must be from the State the waste is being shipped to. Example-an Arkansas manifest must be used if shipping from Texas to Arkansas). In Texas UHWM is also used for shipments of all Class 1 non-hazardous waste. Some states use a modified UHWM. A generic copy of a UHWM is available from your local HSE Representative.
The generator of waste is responsible for completing Items 1 through 16. The shaded areas must be completed based on state requirements. These are Business Unit and/or state specific. The UHWM must be signed by a Valero person who has been trained on the requirements for handling hazardous wastes. All copies of the UHWM must be legible.
UHWMs are used for the transportation of hazardous waste (and in some instances non-hazardous waste) to company approved treatment, storage, or disposal facilities.
CAUTION: Manifest discrepancies are the most common and most often fined violations of hazardous waste regulations.
For shipments of hazardous waste a Land Disposal Restrictions Notification form may also be required. This form is usually provided by the TSDF. It describes the treatment requirements that must be met prior to land disposal and identifies whether the waste meets the requirements. Information about the form and its content should be reviewed with your local HSE representative.
Non-Hazardous Waste Shipping Documentation
1 The preferred shipping documentation for non-hazardous industrial waste is the Bill of Lading (BOL), Form-15. Some facilities require that generators use their Non-hazardous Waste Shipping Form (NHWSF). Although using these forms are for the most part self-explanatory, the guidelines in Appendices D and E will assist in their proper completion.
2 Complete the non-hazardous waste shipping documentation.
9 Offer Placarding
A placard is a large diamond-shaped sign placed on a transport vehicle carrying hazardous materials. Consult the Waste Specification Sheet for proper placards.
Each person offering a hazardous material for transportation by highway shall make available to the carrier the placards required for the waste at the time it is offered for transport, unless the transporter's vehicle is already properly placarded for the waste material.
NOTE: A non-hazardous waste may be a hazardous material and require placarding.
10 Conduct Pre-Transportation Inspection
A pre-transportation inspection will be conducted while the waste is being loaded onto the transporters vehicle. Complete the Waste Pre-Transportation Checklist . Checklist items are as follows:
1 Check shipping containers
2 Check transport labels
3 Observe transporter loading
4 Inspect truck placards
5 Verify the correct UN or NA identification numbers
6 Check shipping papers
7 Complete and review the UHWM, BOL, or the NHWSF
8 Verify that the transporter who accepts the shipment signs and dates the UHWM, BOL, or NHWSF and gives a copy of it to a Valero employee before leaving the site
9 Sign and date the UHWM, BOL, or NHWSF
10 File the UHWM, BOL, or NHWSF
11 Log Shipment
Log shipment on Activity and Weekly Inspection Log, Form-678, for more information see Appendix J.
12 Verify Return Of Manifest
Verify that manifest is signed and returned from the TSDF within 35 days of transport. If it is not received within 45 days complete the additional steps required in section 21.2.
13 Reporting Requirements For Waste Shipments
Valero Reporting Requirements
A copy of each month's manifests and Bill of Lading must be sent to the HSE Waste Specialist by the 15th of the following month.
The disposal facility and HSE must be contacted if a signed UHWM copy is not received back from the disposal facility within 35 days. Document date and person contacted regarding manifest not being returned. If a copy of the TSDF manifest is sent in replacement of the return manifest, insert a note to file as to why a copy is attached to the original manifest.
Federal Reporting Requirements
If the signed UHWM manifest is not received within 45 days, an exception report (contact HSE Representative) must be sent to EPA and/or state and a copy to the TSDF.
State Reporting Requirements
Check with your State.
14 Documentation And Record Retention For Waste Shipments
Required Documentation
The following documentation must be maintained by the hazardous waste generator
1 Copies of all UHWMs
2 Land Disposal Restriction (LDR) certification or treatment standard information must be kept with the UHWM
3 Exception reports
4 Legible copy of the manifest for which you have not received TSD confirmation.
Non-hazardous waste generators must maintain copies of all shipping papers
Document Storage and Retention Time
Copies of all waste records must be sent to the HSE group. After three years, shipping papers may be scanned and maintained as a computer copy, or otherwise reduced for easy storage. Ensure that these records are retrievable when needed and retained indefinitely.
WASTE SAMPLING
1 Activities Covered By Waste Sampling
This procedure describes what is required to obtain a representative sample to perform an accurate waste characterization. An accurate waste characterization is used to properly apply and complete Waste Management procedures Waste Storage, and Off-site Waste Management and therefore, manage the waste in accordance with applicable regulations.
1 This procedure does not address sample analysis. Analysis for waste characterization must be completed by third party certified laboratories. Valero company labs are not an acceptable resource for waste classification characterization analysis. A list of approved laboratories is available from the HSE Group.
2 Characterization is briefly described in Appendices E - J, however this task will be performed by HSE.
2 Exemptions from Waste Sampling
After careful review of the waste with an HSE representative if the waste is known and can be identified with its components without analysis then sampling may not be required. The HSE representative may make this determination. Examples may include: waste previously sampled from same component or a pure chemical from a spill, i.e. gasoline.
3 Equipment Requirements
Uncontaminated sampling equipment and sample containers must be used.
Required PPE must be used to prevent personnel exposure to the waste.
4 Other Requirements
A current or interim Waste Specification Sheet must be obtained before using this procedure.
The determination that sampling is required must be made as described in Waste Management Procedures prior to proceeding.
5 Instructions for Waste Sampling
Sample Collection Requirements
One of the most important principles in sampling is collecting a representative sample. A representative sample is an accurate representation of the entire contents of the container(s) and it is required to correctly characterize and profile the waste.
Review the Waste Specification Sheet for analysis required and refer to Appendix E for collection methods. Appendix D contains a list of sample equipment.
Contact HSE to develop a sample plan which will include:
• Types of Analysis Required
• Number of Samples
• Collection Method
• Equipment and Resources Required (Equipment or sampling personnel may be needed from a third-party contractor)
• Equipment decontamination procedures
Contact laboratory (refer to Waste Specification Sheet for laboratory contact) and discuss the following:
• Scheduling
• Shipping arrangements
• Number and types of container(s)
• Sample preparation and packaging
• Hold time
• Arrangement for results to be sent to HSE
6 Sample Container Labels
Fill out container labels. See Appendix L for an example of a completed label (figure 8.1).
7 Sample Collection Requirements
Collect sample according to sampling plan developed in 4.12 then:
1 Refer to Waste Specification Sheet and Material Safety Data Sheet for any personal protective equipment requirements.
2 Use only clean DOT approved containers and sampling equipment.
3 Decontaminate sampling equipment and personal protective equipment if necessary.
8 Sample Shipment
Complete the Chain of Custody Form (COC); see Appendix F for an example.
Complete the Bill of Lading .
Refer to the Waste Specification Sheet for laboratory information.
Pack the sample in labeled DOT approved shipping container.
Pack the sample on ice.
Seal the ice chest.
Ship the sample.
9 Analytical Report
Receive and evaluate Analytical Report with the HSE Representative.
10 Roles And Responsibilities For Sampling Waste
Responsibilities of Employees
The Terminal/Pipeline employees are responsible for collecting samples or arranging for laboratory to collect. HSE will work with facility personnel to develop the sample plan and determine the analytical requirements.
Responsibilities of the HSE Representative
The HSE Representative is responsible for completing or revising the Waste Profile and submitting it to the TSD for their approval. HSE is also responsible for evaluating the sample results and making the characterization determination. See Appendix G for an overview of the characterization criteria.
11 Reporting Requirements For Waste Sampling
None
12 Waste Sampling Documentation And Record Retention
Required Documentation
• Analytical reports and approved profiles must be retained.
Document Storage and Retention Time
• Original analytical reports will be retained at the Team office indefinitely. HSE will retain copies of analytical reports and profiles indefinitely.
APPENDIX A — GLOSSARY
Accumulation Time
The time waste can be stored on site without obtaining a permit. This time limit is dependent on generator status. Exceeding the accumulation time limit classifies a facility as a storage facility without a permit which is a serious violation of hazardous waste regulations.
Auger
A tool commonly used to collect soil samples
Bailer
Generally an open ended, tubular, hollow device with a closeable valve at or near the bottom end, designed to retrieve water or liquid samples
BOL
Bill of Lading
CFR
Code of Federal Regulations
Characterization
The act of determining whether a waste is hazardous or non-hazardous and the nature of the hazard. This is accomplished by using process knowledge and/or sample analysis results.
COC
Chain of Custody. Form that must accompany lab samples
Corrosivity
One of four characteristics used to determine if waste is hazardous. Corrosivity applies only to liquids with pH of 2 or less, or 12.5 or greater.
DOT
Department of Transportation
EPA
Environmental Protection Agency
Facility
Entire facility, inside the fence line boundary of the pump station or terminal
Generator
Persons who produce hazardous waste including facilities that generate waste infrequently or accidentally
Generator ID
Site-specific numbers issued by the EPA. This is used for all shipments of hazardous waste.
Hazardous Waste
Solid waste that is specifically listed or fails a characteristic test
Hold Time
The maximum amount of time that can elapse between when a sample is collected and when the laboratory conducts the analysis. Once a sample exceeds its hold time, it is no longer considered a valid sample.
Ignitability
One of four characteristics used to determine if a waste is hazardous. Ignitability applies to liquid waste with a flash point of less than 60°C (140°F) or non-liquid waste which, under standard temperature and pressure, are capable of causing fire.
Industrial Waste
Waste which is generated during facility operations. Industrial waste does not include:
• Office refuse (paper, cardboard, etc.), with the exception of copier toner cartridges, some drafting waste (blue line machine solution, waste ammonia)
• Uncontaminated construction debris/rubble
• Food waste
Labeling
A warning label is a specific hazard symbol which informs persons handling the package of possible hazards. Prior to shipment, generators must place any warning labels required by DOT for that type of material on each container.
Lab Pack
A DOT approved container used to pack smaller individual containers of waste for transportation
LDR
Land Disposal Restrictions. "Land Ban" which restricts the land disposal of untreated hazardous waste
Listed Waste
A waste which meets a listing developed by EPA and is automatically regulated as a hazardous waste
MSA
Master Service Agreement. A contract between Valero and a vendor with standard terms and conditions. This agreement can be used by any Valero facility.
MSDS
Material Safety Data Sheet
Non-Hazardous Waste
A material that is a solid waste, but is not listed and does not exhibit a hazardous characteristic
On-site
Within the facility boundary or within the main or outer fence of the facility
NORM
Naturally Occurring Radioactive Material
pH
A scale from 0 to 14 used to measure the acidity or alkalinity of a substance. 0 represents acidity and 14 represents alkalinity.
PPE
Personal Protective Equipment
PPM
Parts per million
Process Knowledge
The use of information available about a process to determine if any waste generated from that process is hazardous
Profile
A Waste Characterization form required by all TSD facilities
Pollution Prevention
Reduction or elimination of all emissions, discharges and generation of hazardous and non-hazardous waste
RCRA
Resource Conservation Recovery Act. Federal Law that covers hazardous waste management
Reactivity
One of four characteristics used to determine if a waste is hazardous. Reactivity identifies those wastes which have the potential to explode or release toxic gas during the management process.
Roll-off Box
A 20, 30 or 40 cubic yard container used to store and transport waste
SME
Subject Matter Expert
Solid Waste
Any discarded material. Note that the term solid does not refer to the physical form of the material, as this definition includes solids, liquids, semi-solid and gases.
TAC
Texas Administrative Code
TCLP
Toxicity Characteristic Leaching Procedure (TCLP) is the laboratory test for wastes to determine if they exhibit the RCRA characteristic of toxicity.
Toxicity
One of four characteristics used to determine if a waste is hazardous. Toxicity Characteristic (TC) identifies those waste which, if disposed of in the environment, have the potential of leaching any of thirty-nine constituents in levels at or above regulatory thresholds.
TSD
Treatment, Storage and Disposal
TSDF
Treatment, Storage and Disposal Facility
UHWM
Uniform Hazardous Waste Manifest. Standard form that must accompany hazardous waste and certain non-hazardous waste during transportation.
Waste Characterization
The process of determining if specific wastes are hazardous or non-hazardous
Waste Generation
Term used to describe when a material becomes a waste
Waste Specification Sheet (WSS)
A two page form (Form-675) which provides current information needed to properly manage and dispose of all waste. These completed forms are located in the system or facility manuals.
WMP
Waste Management Procedures
APPENDIX B — WSS EXPLANATION
The WSS format is shown in this appendix.. The descriptions below explain what is covered in each section, and demonstrates what information is required to complete a new WSS.
WASTE NAME (Item 1)
A unique and descriptive name is given to the waste to avoid confusion with other wastes.
SOURCE (Item 2)
Describes what system, location and/or facility from which the waste material was generated
METHOD OF GENERATION (Item 3)
States the method by which the waste was generated including the specific process name, when applicable. For example, tank bottoms from cleaning diesel fuel storage tanks or monthly pig trap clean-outs.
WASTE DESCRIPTION (Item 4)
Describes the physical nature of the waste material (e.g., liquid, sludge, solid), any known chemical contaminants, distinctive color, odor or other properties
MANAGEMENT METHOD (Item 5)
Lists acceptable management practices for handling the waste when it is generated. For example, scraper wax is removed monthly and is securely stored in a 55 gallon drum, until full. This waste is typically recycled via re-injection into the pipeline or disposed in a TSD fuels blending program (recycled).
CLASSIFICATION (Item 6)
The item checked indicates the waste classification based on regulatory guidelines and/or based on Valero knowledge of the waste and of the process by which the waste was generated. (This information is a result of the Waste Characterization process.)
WASTE CODES (Item 7)
Includes all applicable EPA and state, Waste Codes. EPA and Texas Waste Codes are derived from the Waste Characterization process. For Hazardous Waste, the appropriate hazard class(es) are checked (see Waste Characterization, Procedure Appendix B).
MSDS REFERENCE (Item 8)
An MSDS name and number is inserted in this space if the waste consists of a large percentage of a commercial product which has an MSDS on file (see the facility/system’s HAZCOM binder for MSDS’s.)
NOTE: Most wastes will not have specific MSDS’s. Use the MSDS’s for those products that resulted in the production of the waste. For example, use the crude petroleum MSDS for crude tank bottoms.
PPE REQUIREMENTS (Item 9)
Describes handling precautions to be used to avoid skin contact, ingestion, eye contact or inhalation. Mandatory PPE to be used are eye protection and protective gloves consistent with the material being handled. Consult the MSDS for specific guidance.
SAMPLING FREQUENCY (Item 10)
Indicates the frequency that this waste needs to be sampled for re-characterization. (Often the TSD Facility determines the frequency requirements). At a minimum, waste should be sampled and re-characterized when the generation process changes.
ANALYSIS AND METHODS (Item 11)
Information in this space is obtained from the Waste Characterization process to determine what chemical or physical analytical procedures need to be followed to answer any unknowns about the waste (see Waste Characterization).
APPROVED LABORATORIES (Item 12)
Entered is the name, telephone number and contact person at the approved laboratory and an alternate approved laboratory to be used for the analyses associated with the characterization of the waste. Always try to use the primary laboratory.
HANDLING EQUIPMENT (Item 13)
Listed are necessary handling equipment and materials. For example: forklift, pallet jack, drum dolly, pallets, 15/16” socket and ratchet, bung wrench.
CONTAINER TYPE (Item 14)
Identifies the type and DOT code of the container which should be used for the waste material. Additional information is provided in Valero’s HAZMAT Guide.
LABELS (Item 15)
Gives a description of the type and location of labels that must be placed on the appropriate container in order to be in compliance with storing and/or transportation requirements. Example labels include, but are not limited to:
• Hazardous Waste
• Non-Hazardous Waste
• Waste Pending Analysis
• Hazard Class(es) from shipping name in item 20
• Arrow pointing to the top of the container, as appropriate (see HAZMAT Guide)
INCOMPATIBILITIES (Item 16)
Storage of the waste in incompatible containers are addressed here as well as storing incompatible materials within the same area of containment (e.g., do not store acids and bases together).
STORAGE LOCATION (Item 17)
Identifies the proper storage area within the facility where waste will be stored while awaiting transport. Acceptable storage areas would include:
• Hazardous Waste container storage area
• Non-Hazardous Waste container storage area
• Hazardous Waste bulk container storage area
• Non-Hazardous Bulk Waste storage area
STORAGE TIME (Item 18)
Designates how long the generated waste may stay at the facility. Depending on the facility’s generator status and waste classification, disposal may have to occur within 90 days from generation. The HSE group will determine generator status.
SHIPPING PAPERS (Item 19)
Identifies which type(s) of shipping papers will be required to transport the waste once the waste characterization is complete
PLACARDS (Item 20)
The hazard class identifies which placard is required for shipping. It is Valero's responsibility to offer placards to the transporter carrying the waste.
PROPER D.O.T. Shipping Name (Item 21)
The D.O.T. proper shipping name, UN/NA #, and hazard class are determined once the Waste Classification is complete. The UN/NA # goes in block 11 of UHWM.
CERCLA REPORTABLE QUANTITY (RQ) (Item 22)
If waste has a Reportable Quantity (RQ) specified for spills, the letters RQ must be added to shipping papers and package markings. If applicable, the Reportable Quantity limit will be noted.
TRANSPORTER (Items 23)
Name(s), EPA ID #s, address(es), telephone number(s), and personal contact name(s) of one or more Valero approved waste transporters.
APPROVED TSDF (Item 24 )
Name(s), EPA ID #s, address(es), telephone number(s), and contact name(s) of one or more Valero approved treatment, storage, and disposal facilities to be used to handle this material.
PROFILE NUMBER (Item 25)
The number that is issued by the TSD which identifies a specific waste from a facility. If a profile number is not included or instructions are not given for where to find the profile number, contact HSE.
EMERGENCY PHONE NUMBER (Item 26)
A 24 hour number of a person who is knowledgeable about the waste load and will be available to address any questions that may arise
APPENDIX C — OTHER WASTE MANAGEMENT PROGRAMS
The following are examples of specific materials that are handled as waste, but are generally exempt from RCRA. There are still special handling requirements for these materials. Check with HSE for which requirements apply.
Hydrotest Water
Waters generated in pipeline and storage tank integrity testing procedures are usually subject to State-specific regulations. Some areas require this water to be handled as a waste while other areas allow surface discharge of this water with sampling and effluent limitations.
NORM
Naturally occurring radioactive materials are regulated by State programs and are not usually considered a Hazardous Waste.
NPDES
National Pollution Discharge Elimination System. Some facilities have permits for industrial waste water or storm water that is a point source discharge and subject to regulation under the Clean Water Act.
TSCA
Toxic Substance Control Act. Regulates the disposal of certain materials, including polychlorinated biphenyl's (PCBs). Although some states currently regulate PCBs as Hazardous Wastes, Federal RCRA Regulations exempt PCBs regulated under TSCA.
Asbestos
RCRA Regulations do not classify asbestos waste as a Hazardous Waste although many states do.
Used Batteries
Not specifically listed as hazardous waste but may exhibit one or more hazardous waste characteristics. Lead acid batteries exhibit characteristics of Corrosivity and Toxicity (i.e., lead). However, while these used batteries are hazardous waste, they may be exempt from regulation when recycled.
Used Oil
RCRA defines used oil as any oil that has been refined from crude oil, used, and, as a result of such use, is contaminated by physical or chemical impurities. Examples include car and truck crank case oil, transmission fluid, brake fluid, compressor or turbine and bearing oils, hydraulic oils, metal working oils, gear oils, electrical oils and spent industrial process oils. Used oil must not be mixed with a Hazardous Waste or be burned for energy recovery.
Non-Hazardous Oil Field Waste (NOW)
Waste that is generated in exploration and production (E&P) activities. These wastes are generated from pipelines and tankage before the crude oil undergoes lease custody transfer. Federal regulation excludes these wastes from the hazardous waste regulations.
APPENDIX D — SAMPLING EQUIPMENT
Solids Sampling Equipment
• Trowel
• Spoon
• Shovel
• Spatula
• Auger — for sampling drums below the top foot of material
• Mixing bowl — for composite sampling
• Grain Sampler
• Plastic bag large enough to hold contaminated sampling equipment
Soils Sampling Equipment
• Hand auger — for sampling below surface soils or interior of a pile
• Core punch — for sampling below surface soils or interior of a pile
• Shovel
• Post hole diggers
Liquids Sampling Equipment
• Sample tube
• Coliwasa
• Bailer
• Pump
• Bucket
NOTE: All equipment must be either disposable or decontaminated between samples.
APPENDIX E — SAMPLE COLLECTION METHODS
GENERIC WASTE SAMPLING PROTOCOL
Pre-Sampling Practices
1 Identify the number, volume, and location of samples to be taken.
2 Select the appropriate sampling equipment. Depending on the material to be sampled and the waste container, different types of equipment may be required. For example, the exact number of samples will depend on factors like amount of material, composition of material and accessibility of sampling locations.
3 Determine sample type.
• Most of the samples taken will be “grab samples.” This means that the waste is uniform throughout and that only one sample is required to get a representation of the composition of the waste in the container (e.g., drum of oil, drum of filters used in the same service, etc.).
• There are times when “composite samples” will be required. A composite sample is required when the waste is not uniform throughout; therefore the sample needs to be taken from different parts of the waste container (e.g., drum which contains crude contaminated rags, product contaminated rags, etc. In this instance, try to send a sample of each type of rag).
4 Determine appropriate safety precautions (Hazwoper, confined space entry, etc.).
5 Check appropriate MSDSs to help determine appropriate personal protection to be used during sampling, decontamination, and sample packaging (rubber gloves, rubber boots, disposable suits, etc.).
Sampling Practices
6 Open the waste container and document the physical characteristics of the collected material. The laboratory can provide sampling bottles and “Chain of Custody” papers when given advanced notice.
7 Place the collected sample in a clean sample bottle (do not reuse sample bottles or use previously used containers). Seal the bottle. Clean the outside of sample bottle. Complete and sign the “Chain of Custody” form to accompany the samples to the laboratory. Request the laboratory to forward a copy of the analytical report to the HSE group. Complete all the information on the sample bottle label. See Figure 8.1.
Figure 8.1-Example
.CUSTOMER: THE PREMCOR REFINING GROUP INC.
9405 W. PORT ARTHUR RD., BEAUMONT, TX 77705
SAMPLE ID: WASTE PAINT SOLIDS
DATE: January 10, 1996 TIME COLLECTED: 2:00 P.M.
PRESERVATIVE: YES/NO SAMPLED BY: John D. Pipeliner
ANALYSIS: TCLP Metals , HALOGENATED , AND NON-HALOGENATED SOLVENTS
Sample Bottle Label
Determine methods to prevent samples from being cross contaminated.
Containers should be opened, sampled and closed one at a time to avoid cross contamination of samples and to minimize the risk of exposure.
Sampling equipment contaminated during waste sampling must be cleaned before collecting another sample to reduce the risk of spreading contamination from one sample to the next.
Contaminated, disposable sampling equipment must be disposed of properly.
Soil Sampling
• Backhoes are often utilized in shallow, subsurface soil sampling programs. Samples may either be collected directly from the backhoe bucket or collected from the trench wall if proper safety protocols are followed. Samples taken from backhoe buckets should be collected from material which has not been in contact with the bucket surface.
• Trenches allow collection of samples from very specific intervals and allow visual correlation with vertically and horizontally adjacent material. Prior to collecting samples from trench walls, the wall surface must be dressed with a stainless steel shovel, spatula, knife or spoon to remove the surface layer of soil which was smeared across the trench wall as the bucket passed. All applicable safety precautions must be followed prior to entering any excavation.
• Surface soils may be collected with a wide variety of equipment. Spoons, shovels, hand-augers, punch tubes and post-hole diggers, made of the appropriate material, may be used to collect surface soil samples.
Samples From Drums
• Liquid samples from drums can be collected using a four-foot length of glass tube. In most instances, glass tubes with a 1/2 inch or less inside diameter work best. The tube is inserted into the opening of the drum or barrel as far as possible. The open end is then sealed either with the thumb or a rubber stopper to hold the sample in the tube while removing the tube from the container. The sample is then placed in the appropriate container and the procedure is repeated until an adequate amount of sample is collected. Sample volume should be held to the absolute minimum required for analysis. For homogenous liquids, a disposable bailer may be used in some cases.
• Samples of solids in drums are usually taken with a plastic disposable scoop or a grain sampler.
Sampling Tank Bottoms
Obtaining a representative sample of tank bottoms is especially important due to the quantity generated and the composition of the material. This type of waste is commonly generated in large quantities and can be layered. Collecting single samples of this type of material from discharge valves is not recommended due to the potential stratification of the material resulting in a non-representative sample. Collecting a representative bottom material sample from a product or crude oil storage tank requires a careful planned sampling protocol. Samples should be collected from enough locations and to a depth sufficient enough to identify all consistency changes due to material stratification.
Post Sampling
Remove all sampling equipment from the work zone. Transfer all equipment contacted by the sampled material to a pre-designated decontamination area. Decontaminate equipment following techniques appropriate for the level and type of contamination. Store contaminated materials for proper disposal with the waste stream.
Sample Transportation
Fill out all required paperwork for sample including “Bill of Lading (BOL)” and “Chain of Custody.” Prior to shipping, the designated HSE representative can provide guidance on the correct DOT shipping information. In addition to the usual DOT required information. The BOL must contain the following :
• Sample collector’s name, mailing address, and telephone number
• Laboratory’s name, mailing address, and telephone number
• Quantity of the sample
• Date of shipment
• Description of the samples
When transferring samples, the transferee and receiver must sign and record the date and time on the “Chain of Custody” form. All samples sent to the laboratory must have a “Chain of Custody” accompanying the transfer or a valid analysis cannot be conducted. Copies of the shipping papers and the “Chain of Custody” should be kept with all other paperwork for this waste stream.
• A sample is in someone's “custody” if it is:
o In his/her actual possession;
o In his/her view, after being in their possession;
o In his/her physical possession and then locked up so that no one can tamper with it
o Kept in a secured area, restricted to authorized personnel only
APPENDIX F — CHAIN OF CUSTODY
NOTE: Your COC may not look the same as this example, however, most COCs contain the same general information.
1. Client / Project — Company name — facility location.
2. Field Sample No. / Identification. Use name of waste or material as listed on WSS. Write down as much information as is available—how generated, what system or location, etc..
3. Date and Time — Enter when sample was collected.
4. Grab — Mark this column if the entire sample came from one location.
5. Comp — Mark this column if the total sample volume is made up of smaller samples collected at various locations.
6. Sample Container — Enter the size of the sample(s).
7. Sample Type — Describe the physical characteristic of the sample (e.g., liquid, solid, sludge, etc.).
8. Preservative — All samples should be packed in ice. List this and any other preservatives required by the lab.
9. Analysis Requested — List the analysis required as developed in 5.1.2.
10. Samplers — Enter the name of the person who took the sample.
11. Relinquished by — Enter the name of the person who prepared the sample for shipment.
12. Data Results to — Enter where the sample results should be mailed.
APPENDIX G — FEDERAL HAZARDOUS WASTE CLASSIFICATION
The Resource Conservation Recovery Act defines two ways that a solid waste can be a hazardous waste — listed or characteristic.
Listed Waste
Generally, there are three categories of listed Waste: 1) Waste from non-specific sources; 2) Specific source waste; and 3) Discarded commercial chemical products. An example of listed waste for Valero is paint solvent.
Characteristic Waste
Characteristic Hazardous Wastes exhibit one or more of the following:
• Ignitability (D001)
With liquid wastes, the basic measure of Ignitability is the temperature at which the material or its vapor catches fire in an enclosed space in the presence of a source of ignition. If the liquid has a flash point below 60°C (140°F), it meets the criteria for Ignitability and is a Hazardous Waste. Examples: spent varsol and naphtha.
• Corrosivity (D002)
With aqueous liquids, the test for corrosivity is a simple measurement of pH. If the pH is 2.0 or less or if it is 12.5 or more, then the waste is corrosive. Example: Acids and caustics, ammonia.
• Reactivity (D003)
A Solid Waste is reactive if it meets any of the following criteria:
a) It is normally unstable and readily undergoes violent change without detonating.
b) When mixed with water, it reacts violently, forms potentially explosive mixtures or emits toxic fumes in dangerous quantities.
c) It is readily capable of detonation, explosive decomposition or reaction at standard temperature and pressure.
d) It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gas vapors or fumes. Wastes are usually considered reactive if they have a concentration of greater than 500 ppm H2S and more than 50 ppm CN.
• Toxicity Characteristic (D004-D043)
Toxicity Characteristic (TC) identifies those wastes which, if disposed of in the environment, have the potential of leaching any of thirty-nine constituents in levels at or above regulatory thresholds.
Table 708.1
|Contaminant |EPA Waste Code |Contaminant |EPA Waste Code |
|Arsenic |D004 |Hexachlorobutadiene |D033 |
|Barium |D005 |Hexachloroethane |D034 |
|Benzene |D018 |Lead |D008 |
|Cadmium |D006 |Lindane |D013 |
|Carbon tetrachloride |D019 |Mercury |D009 |
|Chlordane |D020 |Methoxychlor |D014 |
|Chlorobenzene |D021 |Methyl ethyl ketone |D035 |
|Chloroform |D022 |Nitrobenzene |D036 |
|o-Cresol |D023 |Pentrachlorophenol |D037 |
|m-Cresol |D024 |Pyridine |D038 |
|p-Cresol |D025 |Selenium |D010 |
|Cresol |D026 |Silver |D011 |
|2,4-D |D016 |Tetrachloroethylene |D039 |
|1,4-Chlorobenzene |D027 |Toxaphene |D015 |
|1,2-Dichloroethane |D028 |Trichloroethylene |D040 |
|1,1-Dichloroethylene |D029 |2,4,5-Trichlorophenol |D041 |
|2,4-Dinitrotoulene |D030 |2,4,6-Trichlorophenol |D042 |
|Endrin |D012 |2,4,5-TP |D017 |
|Heptachlor |D031 |Vinyl Chloride |D043 |
|Hexachlorobenzene |D032 | | |
• K-Listed Hazardous Wastes: K-listed hazardous wastes are source-specific wastes that are generated by specific industries such as refining, iron and steel production facilities. K-listed hazardous wastes are not likely to be found in a laboratory.
• F-Listed Hazardous Wastes: F-listed hazardous wastes are non-specific source wastes that are generated by particular industrial processes that can occur in various industries. Industrial processes that generate F-listed hazardous wastes include wood preservation, electroplating and other metal finishing processes, and processes that generate waste solvents.
• P- and U-Listed Hazardous Wastes: The P- and U-listed hazardous wastes are pure and commercial grade formulations of specific unused chemicals that are considered wastes. Unused chemicals may be considered wastes because they are no longer needed, they are spilled, or they are off-specification.
APPENDIX H— STATE NON-HAZARDOUS WASTE — TEXAS
In Texas there are three distinct classes of non-hazardous waste (Class 1, Class 2, and Class 3).
Class 1
The most protective standard under non-hazardous.
A waste which meets any of the following five criteria is Class 1:
• Waste which contain levels of specific constituents which meet or exceed the EPA's TCLP list.
• The waste is ignitable or is a liquid having a flashpoint greater than 140 degrees Fahrenheit but less or equal to 150 degrees Fahrenheit.
• The waste is corrosive if the waste is a semi-solid or solid and when mixed with water, produces a solution having a pH less than or equal to 2 or greater than or equal to 12.5.
• Insufficient information to indicate Class 2 or 3 determination.
• Provided it is not hazardous waste, any waste may be managed as Class 1 without any data or knowledge to support that classification.
Industrial waste containing friable asbestos is a Class 1 Waste.
Containers which held a hazardous waste or substance or a Class 1 Waste will be classified as a Class 1 Waste.
Waste containing greater than or equal to 50 ppm PCB's will be classified as a Class 1 Waste.
Wastes containing greater than 1,500 ppm TPH will be classified as a Class 1 Waste.
Class 2
Defined in the negative, it is not a hazardous waste, does not meet the Class 1 criteria and is not a Class 3 Waste.
• A container may be classified as a Class 2 Waste if it has a capacity of five gallons or more and the residue has been completely removed by triple rinsing with a solvent or hydro blasting or other equivalent methods.
• Aerosol cans may be classified as a Class 2 Waste if properly emptied.
• A container which held a Class 2 Waste may be classified as a Class 2 Waste.
• Paper, cardboard, food wastes and general plant trash are considered "plant refuse" and may be classified a Class 2.
Class 3
Wastes which are inert, insoluble and pose no threat to human health and/or the environment
This includes but is not limited to:
• Rock
• Brick
• Glass
• Dirt
• Certain Plastics and Rubber
APPENDIX I — HAZARDOUS WASTE DETERMINATION
Hazardous Waste determinations can be made by using process knowledge or laboratory analysis. Process knowledge is using the information available about a process to determine if any waste generated from that process is hazardous. MSDS sheets often provide useful information about materials involved in the process to aid with the determination.
A complete hazardous waste determination is requested in two parts:
• The first part, a determination of reactivity (contains sulfide or cyanide), corrosivity (acid or caustic) and ignitability is requested as “RCI Analysis.”
• Second, “TCLP” Analysis is requested. If the waste is suspected to contain benzene, "TCLP-Benzene" or TCLP Semi-Volatiles”. If metals are suspected request TCLP Metals If the waste is suspected to contain lead, "TCLP-Lead" is requested. When nothing is known about the waste, it is wise to request full TCLP and RCRA Characteristics analysis.
The TCLP Procedure was established in 1990. As a result, many petroleum industry waste streams that were once considered non-hazardous are now considered potentially hazardous and must be tested for an accurate determination. Some examples of waste that may fail TCLP are:
• Creosote pilings generated from some of Valero's renovation and demolition work may fail the TCLP because the expanded list now includes cresols.
• Oiled absorbents and clean-up articles may fail the TCLP because of benzene.
• Tank water draws and hydrotest water may also fail TCLP because of benzene.
Spent sandblast grit from sandblasting a tank may be hazardous because of leachable metals in the paint (e.g., lead) or in the grit itself.
RCRA also regulates mixtures of Hazardous Waste and Non-hazardous Solid Waste. If any amount of a listed Hazardous Waste is added to any amount of a Solid Waste, the entire mixture is regulated as a Hazardous Waste.
Application of Process Knowledge
The following list of questions are designed to stimulate the thought process of what is known about a certain waste or product stream. These questions are usually discussed between facility personnel and the HSE Representative.
1. Has this material ever been analyzed before? Is the data available? Does an MSDS exist on the possible contaminants?
2. Has another facility in Valero generated this waste before? (Is there a Waste Specification sheet on a similar waste from another facility?)
3. Is it reasonable to expect the materials (analysis) and conditions in the table below to be found at threshold levels in the waste? The analysis are grouped in the table below. Answer yes, no, or don't know to the question above.
|ANALYSIS AND | | |DON'T KNOW |EPA TEST METHOD |SAMPLE SIZE |
|CONDITIONS |YES |NO | | | |
|Heavy metals | | | | | |
|Herbicides and Pesticides | | | | | |
|Semi-volatile Compounds | | | | | |
|Volatile Organic Compounds | | | | | |
|Contain PCB's | | | | | |
|Is it Corrosive? | | | | | |
|Is it Ignitable? | | | | | |
|Is it reactive? (Does it contain H2S?) | | | | | |
|Does it contain Diesel? | | | | | |
|Does it contain Gasoline? | | | | | |
For every Yes or Don't Know answer, an analysis will be required.
APPENDIX J — WASTE STORAGE AREA ACTIVITY AND INSPECTION LOG
If the container is not in good condition the waste must be transferred to a container in good condition. The checklist must have a comments/disposition box where the inspector can list items of noncompliance and the actions taken to remedy the situation. It is critical that the compliance loop be closed by documenting and dating the corrective action
APPENDIX K — MATRIX OF GENERATOR STATUS AND ACCUMULATION TIME
|Generator Status |Quantity Limitations |Maximum Accumulation Time |Maximum Limit on |Comments |
| | | |Storage | |
|Large Quantity |1000 kilograms (2200 pounds) or about|90 days |None | |
| |five 55 gallon drums or more in any | | | |
| |calendar month. | | | |
|Small Quantity |More than 100 kilograms (220 pounds |180 days or 270 days if |6000 kilograms of | |
| |or about 1/2 of a 55 gallon drum) and|located more than 200 |hazardous waste. | |
| |less than 1000 kilograms in any |miles from disposal | | |
| |calendar month. |facility. | | |
|Conditionally Exempt |Less than 100 kilograms (220 pounds |See WSS |1000 kilograms of | |
|Small Quantity |or about 1/2 of a 55 gallon drum) in | |hazardous waste | |
| |any calendar month. | | | |
|Non-Hazardous Waste |None |See WSS |None |Non-hazardous waste must be |
| | | | |clearly labeled non-hazardous and|
| | | | |physically separated from |
| | | | |hazardous waste within the |
| | | | |storage area. |
NOTE: The WSS for a waste have more stringent requirements which override this matrix.
APPENDIX L — LABELS
Waste Pending Analysis Label
|A. |Facility Name |Name and address of facility. |
|B. |Accumulation Date |Date when waste first goes into container. There are time restrictions on how long |
| | |waste can be stored on site. |
|C. |Source |From where and what work process generated the waste. |
|D. |Content Description |Describe the waste in the container (i.e., crude oil contaminated soil, or paraffin |
| | |wax). |
|E. |Solid / Liquid / Sludge |Check the appropriate box. |
|F. |MSDS# of Materials |Enter MSDS number of contaminant, if known. |
|G. |Hazard Warning |Hazard communication regulations require that the hazards of the container's contents|
| | |be identified. This communication may be descriptive or use symbol systems such as |
| | |HFR (see example label) or NFPA. The numbering systems for both HFR and NFPA are the|
| | |same and are explained in Exhibit 709.4 of this appendix. They are listed on the |
| | |applicable MSDS. |
FIGURE .1
|WASTE PENDING ANALYSIS |
|WARNING: |
|UNKNOWN WASTES ARE TO BE CONSIDERED TOXIC. PROTECTIVE EQUIPMENT MUST BE WORN DURING HANDLING |
|FACILITY NAME ____________A_________________ |
|ACCUMULATION DATE __________B______________ |
|SOURCE ____________________C_______________ |
|CONTENT DESCRIPTION ______D_______________ |
|MSDS NUMBER ____________F_______________ |
| |
|_E__ SOLID ___ LIQUID ___ SLUDGE |
|HFR RATING |
|HEALTH HAZARD _____G______ |
|FIRE HAZARD ___________ |
|REACTIVITY ___________ |
|WASTE PENDING ANALYSIS LABEL |
NOTES: This is an example of a Waste Pending Analysis label. Labels obtained from different vendors may look different, but will require the same basic information. For proper use of this label, see section 2.9.
Hazardous Waste Label
CAUTION: There is more than one type of hazardous waste label. Most states can use a label similar to Fig. 2.
|A. |Proper DOT Shipping Name|Shipping name defined in DOT regulations. This can be found in block #21 of the Waste Specification Sheet. |
|B. |UN or NA No. |This is a four digit identification number for hazardous materials, prefixed by the letters UN or NA on |
| | |shipping papers or package markings depending on whether the material is regulated internationally (UN), or |
| | |regulated in the U.S. and Canada (NA for North America). See WSS block #21. |
|C. |Name |Valero Terminaling and Distribution Company (Valero) followed by the facility name. |
|D. |Address / City / State /|Facility address where waste is located. |
| |Zip | |
|E. |EPA ID No. |This number is assigned to the site where waste is generated. A listing of facility EPA ID numbers is |
| | |included in system or facility manual. Not all facilities have been assigned an EPA ID number. If your |
| | |facility is not listed, contact the HSE Representative. |
|F. |EPA Waste No. |RCRA hazardous waste identification number defined by the EPA. This is a three digit number preceded by |
| | |either a F, D, K, P, or U. This number can be found in block #7 on the WSS. |
|G. |Accumulation Start Date*|Date when waste first goes into container. There are limits on how long waste can be stored on site (see |
| | |Appendix K). |
|H. |Manifest Document No. |Enter assigned number from manifest. Some states have preprinted numbers on the manifest. |
|I. |State Waste No. |Hazardous waste number identified by the State (if applicable). This number can be found in block #7 of the |
| | |WSS. |
FIGURE.2
|HAZARDOUS WASTE |
|HANDLE WITH CARE |
|FEDERAL LAW PROHIBIT IMPROPER DISPOSAL |
|IF FOUND, CONTACT THE NEAREST POLICE OR PUBLIC SAFETY AUTHORITY, U.S. ENVIRONMENTAL PROTECTION AGENCY |
|GENERATOR INFORMATION |
|NAME _________________C____________________________ |
|ADDRESS _________________D____________________________ |
|CITY, STATE, ZIP ________________________________________ |
|ACCUMULATION START DATE ______G_____________ |
|EPA ID NO. ______E________ EPA WASTE NO. ______F_______ |
|STATE WASTE NO. _____I______ |
|MANIFEST DOCUMENT NO. ________________H________________ |
|D.O.T. PROPER SHIPPING NAME AND UN OR NA NO. WITH PREFIX |
|________________________A________________________________________ |
|_________________________B________________________________________ |
|CONTAINS HAZARDOUS OF TOXIC WASTES |
FIGURE NOTES: This is an example of a Hazardous Waste label. These labels are usually yellow. Labels produced by different manufacturers may look different, but will require the same basic information.
Non-Hazardous Waste Label and Non-Hazardous Oilfield Waste
|A. |Shipper |The Valero Terminaling and Distribution Company (Valero) - name of your facility. |
|B. |Address/City/State/Zip |The physical address of the facility where waste is located. |
|C. |Content Description |Describe the waste in the container (i.e., crude oil contaminated soil, or paraffin |
| | |wax), and include the date the waste was generated. |
NOTE: Hazard communication regulations require that the hazards of the container's contents be identified. This communication may be descriptive or use symbol systems such as HFR or NFPA. The numbering systems are the same and are explained in this appendix. They are listed on the applicable MSDS.
| |BLUE |RED |YELLOW |
|Signal |IDENTIFICATION OF HEALTH HAZARD |IDENTIFICATION OF FLAMMABILITY |IDENTIFICATION OF REACTIVITY |
| |Type of Potential Injury |Susceptibility to Burning |Susceptibility to Energy Release |
|4 |Materials which on very short exposure |Materials which will rapidly or |Materials which are readily capable of |
| |could cause death or major residual |completely vaporize at atmospheric |detonation or of explosive decomposition or |
| |injury even though prompt medical |pressure and normal ambient temperature, |reaction at normal temperatures and pressures.|
| |treatment were given. |and which will burn. | |
|3 |Materials which on short exposure could |Liquids and solids that can be ignited |Materials that are capable of detonation or |
| |cause serious temporary or residual |under almost all ambient temperature |explosive reaction but require a strong |
| |injury even though prompt medical |conditions. |initiating source, or that must be heated |
| |treatment were given. | |under confinement before initiation, or react |
| | | |explosively with water. |
|2 |Materials which on intense or continued |Materials that must be moderately heated |Materials that are normally unstable and |
| |exposure could cause temporary |or exposed to relatively high ambient |readily undergo violent chemical changes but |
| |incapacitation or possible residual |temperatures before ignition can occur. |do not detonate; also materials that may react|
| |injury unless prompt medical treatment is| |with water violently, or that may form |
| |given. | |potentially explosive mixtures with water. |
|1 |Materials which on exposure would cause |Materials that must be preheated before |Materials that are normally stable, but that |
| |irritation but only minor residual injury|ignition can occur. |can become unstable at elevated temperatures |
| |even if no treatment is given. | |and pressures, or that may react with water |
| | | |with some release of energy, but not |
| | | |violently. |
|0 |Materials which on exposure under fire |Materials that will not burn. |Materials that are normally stable even under |
| |conditions would offer no hazard beyond | |fire explosive conditions, and that are not |
| |that of ordinary combustibles. | |reactive with water. |
|NFPA Hazard Signals |
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