Document 85VrZakaQ4z4wQvrpMqBVMykZ
KERR-McGEE CHEMICAL CORPORATION
INTERNAL CORRESPONDENCE
TO
from
Don Oakes S. W. Beckstead
DATE SUBJECT
July 28, 1982 Southwestern Refining Co. Inc.
-hrri-. .Attached is a copy of Otto Laursen's report covering our ...recent .plant
-visit."
'"'i'ir.--/'
..__ _ The-main purpose of this report Is to record our observations and discussions
' ...vrV.: ^and to enable us to better assist you-with J30T and Hazardous Waste matters
-in -the future.
-... ..
The report and additional information to.:;be. developed will serve as the basis for a Hazardous Materials Specification .Shipping Manual..
S. W. Beckstead
SWB/ses
Attachment
cc: Burnell Brown/attachment Dick Watson/attachment Mac Jordan/Lew Albright/attachment
KERR-McGEE CHEMICAL CORPORATION
INTERNAL CORRESPONDENCE
TO S. W. Beckstead
date" July 13, 1982
FROM 0. D. laursen
subject Trip Report--Southwestern Refining Company, Inc.
On 8-and 9-July, 1982, S. W. Beckstead,.Kerr-McGee Chemical Corporation, and the .under signed,: visited the-Southwestern Refining Company, Inc. at Coxrpus Christi, TX. -We departed Kerr-McGee Center at mid-day on the 7th of July and returned to Oklahoma City on Julyt9,-1982; -this itinerary enabled us to devote about a day -and a half to the - study of^the company's operations, -with emphasis on the shipment of hazardous materials, ^ substances -and wastes.
We contacted the following key .personnel:
-- - --
Burnell Brown - General Manager
'TDon Oakes -- V.P. -Engineering-and Technical Services
Roger Clark -- Environmental Control Manager
Jim Moody - Operations Supervisor
Joe Roper - Laboratory Supervisor
Bob Ratliff - Terminal Supervisor
Johnny Kalenda --.Terminal Supervisor
Dick Watson - Environmental Control Technician
Gene Palmer - Laboratory Technician
We held an in-briefing with company officials on the morning of July 8th and discussed our activities and purpose with the company General Manager in the afternoon of the same day. The tour of facilities was conducted by various supervisors and operating personnel depending on the area of interest. We examined the following operations by questioning of personnel, study of documents, and direct observation:
Pipeline Operations Shipping Operations (Main IN and OUT Points) Hazardous Waste Disposal and Shipping Warehouse Shipping laboratory Sample Shipping We learned that the-company ships a large number of hazardous materials (bulk and samples), and several, hazardous wastes. Samples of pertinent documentation were obtained for further study-and are attached ato This report. Company -officials also offered other written materials, including a complete listing of all materials shipped by mode of transport, to be forwarded to this office at a later date.
The following chart`depicts the anode of transport, shipping place, type of-material shipped and whether it is shipped 'into-or out of the plant (our primary concern being outgoing shipments):
SWRf/Asbestos 0790
1A 153973
MODE
I LABORATORY:
Motor Freight (Alamo Express, Southwestern ;Motor Transport, UPS).
PLACE
Main Laboratory (Samples)
Air-Freight '-.(Federal Express, Emery -- European destinations).
NOTE: Most Laboratory shipments go by air express
IN
Radioactive device (Fe 55) used for Sulfur determination.
Laboratory chemicals
Product samples, catalysts.
Waste samples
Waste water samples (treatment facility).
.WAREHOUSE:
Federal Express (air) Cargo Tank
Warehouse Production Unit (see item IV).
WASTES: Closed-trailer motor freight,
PCB collection point (s).
capacitors, transformers
or drums,per
P & L instructions
this office.
Cargo Tanks (contract carrier) to Chemical Waste Management or . Texas Ecologists for disposal.
Production Units
Cargo Tank (common carrier) to Southwestern . Ref. Co. land farm.
Oily sludge pits near waste water treatment facility.
-
2 SWRf/Asbestos 0791
OUT
Jet fuel; Nickel soap (catalyst) Alkylate; Platformate; No. 6 oil; Spent alky lime; Cumene; Solvent 100; Gasoline; Benzene; Toluene; Xylene: Slurry oil; Light Cycle oil; . Kerosene; Butane; Propane; Isobutane; Diesel fuel; Dimate (naphtha); Raffinate (naphtha); No. A oil; Crude oil; Weak caustic; Radioactive device (Fe 55) used for Sulpl detection.
Spent catalyst sample; Spent caustic {paperw; only).
Polychlorinated biphenyls (PCB1 s).
Hydrofluoric alkylation waste (spent lime liquid slurry).
Oily wastes (mixed) consisting of: DAF float; API separator sludge; heat exchange bundle cleaning sludge; slo; oil emulsion solids .
153974
MODE
PLACE
IN
Cargo Truck; Packaged ia polyethylene bags; company Truck used to ship toTexas Ecologists.
Near No. 1 Terminal
Cargo Tank
No. 3 Terminal
Cargo Tank (Tank -Car could be used later).
No. 3 Terminal (Near Tank 4-1).
V BULK (SURFACE): Cargo Tank
No. 2 Plant
Cargo Tank
Cargo Tank Tank Car Cargo Tank
Near Tanks 5-3 and 5-4.
No. 3 Terminal
Rail car rack
Gasoline Truck loading rack and vicinity.
No. 4 fuel oil
Anti - leer Lead tetraethyl Propane Isobutane
Cargo Tank Cargo Tank
Texas Crude
Crude oil
Gathering System
No. 1 Terminal
Cargo Truck
i7 BULK (VESSEL): 'Barge
Waste water treatment fac ility.
Alum; Strong caustic.
Barge dock
Ship
Ship dock
OUT NOTE: The above four refiner wastes are indexed and regul ated by EPA (per RCRA in 40 CFR 261.32), as separate entities. Waste asbestos
Dilute sulfuric acid solutic Spent caustic solution (Dimersol).
Spent caustic solution (Merichem) (with cresylic acid).
Gasoline Diesel Propane Isobutane
Light Cycle Oil (fuel oil).
Xylene Benzene Toluene Crude oil Solvent 100 Gasoline Xylene Benzene
3
SWRf/Asbestos 0792
1A 153975
MODE
PLACE
IN
OUT
Toluene Crude Oil Solvent 100 Gasoline No. .2 oil Jet fuel No. 6 oil Diesel fuel
The following significant factors were either observed or related to us by refinery officials:
(1) Southwestern Refining Company, Inc. conducts no pipeline operations except intra-plant. Coastal States Refining Company picks up custody at the property line and is responsible for -pipeline transport from there to the next outlet.
(2) Southwestern operates a hazardous wastes land farm about 20 miles southwest of the "refinery. The site is 120 acres in area, with three 20-acre cells currently in use. Two of these are active for farming and the third is used as an evaporation reservoir. Generally, the farm is used for oily wastes. All wastes that cannot be farmed at this facility are disposed of by use of professional waste management companies.
(3) It was understood that a Texas Department of Water Resources (TDWR) hazardous waste manifest was in use to satisfy both state and federal (EPA) shipping requirements (sample attached to this report).
(4) Portable tanks and tank cars (rail) were not in use for bulk shipments. The rail car rack for loading out Dimersol caustic was ready for operation but not in use.
(5) Operators at the various loadout points check shipments to varying degrees (e.g. cursory to detailed checklist). However, routine checks of cargo tanks loading gasoline and diesel fuel are not made to determine if DOT specifications are being met. Two vehicles from major petroleum companies were observed loading these fuels, but a proper DOT specification number could not be located on either. One of the.vehicles only had three of the required four hazard warning placards displayed. It was not evident that the company was actively engaged in offering correct placards to deficient carriers.
(6) Bills of lading from Triangle Refineries Inc. were still reflecting improper wording for diesel fuel in the description column (should be "Fuel oil, diesel, Combustible liquid, NA1993", instead of "Diesel fuel...................NA1993"); also there was no signature block included for the certification statement displayed on the form. Both of these errors were recently pointed-out to KMRC officals so Triangle could correct the forms.
(7) The refinery laboratory was well-equipped to run DOT-required tests on flammables and combustibles not specifically provided for in the DOT hazardous materials tables, to insure their proper classification and handling according to law (e.g. tests for flashpoint, vapor pressure, viscosity, etc.).
Study continues on the above and other KMRC problem areas already identified, in order to develop a thorough understanding of refinery and terminal operations so this office can render better and more comprehensive assistance to KMRC.
Otto D. Laursen
1A 153976
, SWRf/Asbestos 0793
Attachments: TAB A - Chemical Locations (IN shipments) TAB B - Sample Bill of Lading TAB C - Hazardous Waste Manifest (TDWR) TAB D - Procedure - HW Manifesting TAB E - Procedure - HW Packaging and Labeling
SWRffAshestos 0794
1A 153977
5
CHEMICAL LOCATIONS
BACK WAREHOUSE
LEAD HOUSE OR DYE HOUSE
''ANTI-FREEZE/COOLANT (41-020003) CHEMOLUBE H HYDRAULIC FLUID (41-107001)
'ETHYLENE DICHLORIDE (41-080001) HONOETHANOLAMINE (41-144001) .*
UNIVOLT N-61
CHEMICAL WAREHOUSE
ETHYL GASOLINE ADDITIVE 108 -TSOCTANE
METAL DEACTIVATOR OIL SOLUBLEDYE - RED OIL SOLUBLEDYE - ORANGE OIL SOLUBLEDYE - YELLOV? PETROMEEN DM-775 PETROMEEN EB-911
Ammonium polysulfide
BETZ AFS (5 GAL.)
MAIN WAREHOUSE
BETZ FOAM-TRCL 144 (5 GAL.
*7. CVCO3
ANTIFOAM DB-100 (41-018001) -
^COREXIT 202
^CHLOROTHENE NU (OR VG) (41-0400C
COREXIT 303
COMBUSTION PROMOTER (41-044001)
COREXIT 7327
(27-080001) CCX-77 CHAIN & CABLE CONDITION
CORROGEN CATALYZED SODIUM SULFITE
DEGREASER XL-9 8 (41-064001)
FUNGICIDE F-16
(41-092005) FOAM, DOW,' CORNING 200 FLUID
LIGHT WATER 3% CONCENTRATE
FOAM LIQUID CONCENTRATE (41-092(
LIQUIMINE VI.
^LITHIUM CHROMATE INHIBITED
NALCO 7715
OAKITE 19 (41-160001)
OCTAFILM T-3
. /SODIUM NITRITE (41-208001)
PETROMEEN OS-16 PETROMEEN 775
THERMINOL 66 (41-220001)' OAKITE 204 (41-160003)
SLIMICIDE C-30
TRETOLITE KONTOL
VARI CHEM PYRCCAT SWF
HYDROEON SLAB
XH-600 CYL. OIL (1764) (41-163009) EE-120 AVIATION OIL (41-163011) 18 35C PAWNEE OIL (41-163001) 1848E PAWNEE OIL (41-163003) DEXRON II AUTOMATIC TRANSMISSION FLUID (41-163008) SAE 30 MOTOR OIL (41-163006) ECOKOLITH NO. 2 (41-100002) SAE 10W/4 0 MOTOR OIL (41-163014) 1812 PAWNEE OIL (41-163002) VIS CIRCULATING OIL 68 (41-163013) 1854 OIL FOR AMARILLO GEAR (41-163004)
85-140 MULTI-LUBE GEAR OIL (41-163015)
3-30W-SHD K-M OIL (41-163005)
CASTOR OIL (41-163012)
150AW GULF HARMONY (41-163010)
SWRf/Asbestos 0795
TfiBA
7A 153978
RECEIVEO, subject to the clasaincations and tariffs In ffvcl on the data of the issue of this BUI of Lading. Shipper's No.
.IX Agent's No.
SOUTHWESTERN REFINING COMPANY
atCORPUS CHRTSTI. TEXAS
i W/ 19
By --* TRANSPORT COMPANY OF`TEXAS^l_______________________________________________-v
--C:
the properly-described below. In apparent food order* eecept as noted (contents and condition of contents of packages unknown), marked, consigned, and destined, as indicated which said carrier (the word carrier being understood throughout this contract as meaning any person or corporation in possession of the property under the contract) agrees to c its usual place of delivery at said destination If on its route,otherwise to deliver to another carrier on the route to said destination. It b mutually agreed, as to each carrier or at! or said property over U or any portion of aald route to destination, and as to each party at any time interested in all or any of said property, that every service to be performed hei shall be subject 1 ail the terms end conditions of the Uniform Domestic Straight Bill of Lading set forth (1) in Official. Southern, Western and lllinob Freight Classification* in c( the date hereof, if thb b a rail or tab-waler shipment, or (2) in the applicable motor carrier classification or tariff if this fa a motor earner shipment.
Shipper hereby certifies that he farzuTtnr wfthjlU the terras and conditions of the said bill of lading set forth in the classification or tariff which govt the transportation of this shipment, and the said terras and-conditions arc hereby agreed to by the shipper and accepted for himself and hu assigns.
Consigned to
...
(Mall or-street address of consignee--For purposes of notification only)
mdrtpkfm company
_________________________________ l__ ______ ___________ ____'
Pectination
TTnnSTnw, ;'
___________________ , ~State__ :!:____
County
Route - -
Delivery Addrest '
TRANSPORT COMPANV DP TRYAS ___I________________________ _______________ II'
Car or
1914 PADFTW ROAD_______
________________ :Vehicle Initials_________________
No.
(To beTIHed In only when shipper desires and govemlngtarlffs provide fordellyery thereat.*)
. `
JHO.O*-.
TankCars
A.Tank ~ ^ffUCkt;.
*
iptton'ofva r
SdtWeiGHTir vtusiorS Subject to Section 7 o
EkCSPTlONSTggpj'^gg^
SutJ/Jto'cdnil ss&m
tftlons of- applicable e Lading, If-this ihlpm.nl
/' X
>^' sj^-"-------
be delivered to the -con
(RO .) AT.KATjTNFI fCDRROSTVR uiTQTTTD . '
without -recourse -on -th
* V--r-------------
signor, theconsignor sha
KOS. iKOnTTIM -RYnROyTDFl . rORROSTVR
the following statements
' 1
MRTPRTATj r NA1719 r KPRNT CAUSTIC SODA srnnn rations.
TIm carrier shall not delivery of this shipment out payment of freight a other lawful charges.
(Signature of Consign
If charges are to t paid, write or stamp he< be Prepaid.** *
nnPBncTw placards sttppt.tp.d to drtvrr_____
MAIL COPIES OF SCALE TICKETS TO:
THIS IS A TRIP LEASED CAR YES NO'
MERICHEM COMPANY, S & D DEPARTMENT 19U HADEN ROAD, HOUSTON, TX. 77015
f'xx
Received $ to apply in prepayment charges on the proper scribed hereon.
A9ent or Cashier.
RAILROAD COMM.TENDERhO.'S.W. CAR SEAL NOS.
^
vc
Ih
c. E -
*|
ao. --c
TRANSPORTATION CHARGE
(Tax Included)
.
-SHELL;'*'
.'
DOME
- ISSUED GROSS GALS.
LOADING TEMPERATURE
-*F
NET GALS.
Per (The signature here ac
edges only the amount pr
Charges Advanced:
-
%
IT the shipment move* between two porta by a carrier by'water, the law requires the bill ot lading shall state whether It Is ''carrier's or shipper's weight". NOTE-
Lhe rate Is dependent oa value, shipper* are required to state speelTIcally lo writing the agreed or declared value of the property. ""This Is lo certify that the above-earned materiel* are properly classified, described, packaged, marked, and labeled, and are In proper condition for transportation,
__ tog to the applicable regulations cl the Department of Transportation^/
Tba arreed or declared value of the property Is bervby specifically stated by the shipper to be not exceeding.
..
--
--
sv.*ZXXX SOUTHWESTERN REFINING. COMPANY
t*>r. Per, 1A 153979 -
1718 B
INVOICE COPY
SWRf/Asbestos 0796
Texas Department of Water Resources P.0. Box 13087, Capitol Station Austin, Texas 78711
I Vi_'w--1 i
UL 1198a
TEXAS WASTE SHIPPING-CONTROL -TICKET
(Please Type or Print Clearly) 'ENGrJT'Ii,'-c'T" -S'
Ticket No.0060171:
(Satisfies TDWR/TDH and U.S. EPA requirements for hatardous'or class I waste manifest)
PARTI: To be completed by'Generator(see reverse-aide foninstaictionsl, :o
TDWR/TDH Registration No.jS |o IcpL^ksI
Company Name
Business Address Bo.
7&TAS. ~?Rq-}l.
mmmmmm
i- revf/vru-'
ji'vijlioaH Gil! .avvuiiOi ec
:-6uaiiq s>)>sw c.'pniuj
y.cnvtq tot jio*}firf.-:Oin. niiij
Address From Which ShipmentpO5 ngmate---rs->: _ - - -.stabs ttw&utueneujOci mmee ,* tnjc*."?.*b.A.'A....
T^flO -NL)c-S
~nU/D. -
________________________a Emergency<Phqne.A/^7a-. | Sf.j/l
'deStinatton?"'" ; : -w's^weran -
:^bvinv ^ -a?'
TM
:-r
i-r V:1 `i~rrXS
TDWR/TDH Permit No/; ':'Rr7 tClj.la -Qi
,-jrimryTgn Fira'lity^lawix ^Ca^K^VCAL. - VVASTS KA.Aff/g^^'ltS.T'I'V
'
-1 _ -.-- __ a^JF>a#.-ia
smi fo r0li6SC!-i>r<r.i
Business Address T O. Pq^
z'^^JTSD.Fac.#^JGRraHSPBEgraafS!
igagnttiylStAl./fcldrest^^,,^
..ir
.z;s>l3!; ifcdoiTibDt. "TDWR/TOHTermftNo.l nmj-irt'' I <h I I
Business Address____________________ ' -.destination4Sit>e),Addi*s*r..i._ LRR n.~ ;xluyj;..?-rlX
!N H >
m*c.`l-vB.itAnivSTllSSDPJtIasc)..-,#nrU.' -'J' bUTi /l H 1 1 PhonaaA/e,lt _ s;;;0,!T,,t-,,; :)---------- !------
1. -TEXAS WASTE CODE
^QUANTITY'-0`-UKiiTS*^ 3:botWASTEN07'': 4tnoof i 5,i0 bUi:D01TDESCeiPTf0N; fb)7T?TiP-AND;G'
HAZ. CLASS .... , NUMBER OF CONTAINERS ..
X". .Ng^;c*f,r
I-2,,3-4,.
11 Sri: -
1
t
1
1
....
.W a Jux-tntoo 'pi-P rvrrtiji -
VWLfo
U-(sOO
1 (2) 3 4
1 1 1 1^1 All Ni S \ *7 16 it O-iDL.
emi.Tfi
CTA ' /r*. zi.1 Xr Tto rnepA
12 3 4
i i i >' i i ii i ii
_ | ' '1
(.-. JJ,,... 1 .-l1.| ...l1 PIqo-- -rrjpiy,
/f `i'aer&rfft*cr'wnrtrfnif*t;jrvu,Fcf-?UjC1:lru7fija4f0
;
''
-:nl pq?i3k4:
"t--n.OvSi-maicttjmrHyflroxiaei-------------------
b'lBtf-cr* -bs^orn^
r` trTi
fi^tTOSS- ART--*r.;>ngtjj
TAtflS'tr: -n -,-i` = -l nA |;ssi'
i
2_3'<ei
f'fO-Jfettrt 111
hfiz 1
Cl ih* &ut 3^0 oi
1
HE'S prii.'.6toabiin6 llGtlblEm ejesv. v:.j
T2
3
4-
dvi^r?fi njiwjsiotnrr liruanvj`I 1 1 1
ed/ soiijpM-JYRcc-
rsfnD-n*6jOT f)OTAi>3;43L:
--Special 4i
?g. #
-a,.*J
_=-_S.: R 3 VR' H2i/!ART SK^^Sf^auRTZ,-
This-istorcertifythat'thb'.above atamScffhatenalS'arre'properly'classified, :.rr\u>\\*S)jj: described;packagedj;markedrjandUabe1ed andVejo<brdperrcoridiifon for :1-3 S
-/;u jC&*?*_
transportation-according totheapplicable.regulationsofit>ejDOT;.TDWR,
rC.TRcits.a -.-
-and .TDhQ-^^i^^ rf-aBAti r-o- :*i *:. joy .-sbi^-v
?vy*u.*.:.
PART II: To be completed by the Transporter/Driver (see reverse side for-instructions) TDWR/TDH Trans'. No. '
-f- n
fiefairS' '-'I'tih < ~SAr *' : :
r't. `Hc;v. .citr. ^ .
Carrier Name-_
____ V--IMrfeQ-- -------- ------------------------- ,,v
" -.
y.i;, . : i RAi.sui.i-Jf: siiorn v-..^3i>T.i!riC,:rl> EPA*Trans-No.
fQ?jralj ^nn?f5EEE3=ia!E;
Business Address I CD ^OV. Yi(cfa___ rfcPr
13>--3S2S^
^
Phone-Number a~
~ &S~Lfs'----------.r .--'
I certify (or declare) that the materials in the quantities described above are -received r by. me - for_-shipmentijtOfithe-.above, namedadestination.'
PART III: To be completed'byTreatment, Storage and Disposal (TSD) '
Facility Owner/Opetatnr l (see -reverse side for instructions)
TSD Facility Name
C.;L 0^7
Phone Number ___
Site Address
___
TSD Facility Owner/Operator Comments:..
1A 153980
THJ
' -A' SSoSKr!
\VC po\
f 'TTION for TRANS-
the quantities described in Part I
RECfJUTV^^tfS!!?^ WDOABtf
^rffliTray'^^RTMENT OF Pink - TSD Facility SiPA. , .
Yellow - Transporter
TDWR/TDH Permit No7 -EPATSD.Fac.#
v ry*** -
it* n*ciw>' -
K
Sip<vtur* of Autt>omd
a
Green - Generator's First Copy
SWRf/Asbestos 0797
SWRf/Asbestos 0798
1A 153981
MANIFESTING
A. General Requirements: 1. Southwestern Refining Co., Inc. -when transporting or offers for transportation, hazardous r.waste for off-site treatment, storage, or disposal must prepare a manifest before trans porting the waste off-site. 2. Southwestern Refining Co., Inc. must designate on the manifest one facility which is permitted to handle the waste described on the manifest. 3. Southwestern Refining Co., Inc. may also designate on the man ifest one alternate facility which is permitted to handle the waste in the event an emergency prevents delivery of the waste to the primary designated facility. A. If the transporter is unable to deliver the hazardous waste to the designated facility or the alternate facility, Southwestern Refining Co., Inc. must either designate another facility or instruct the transporter to return the waste.
B. Required Information: 1. A manifest document number. 2. Southwestern Refining Co., Inc. mailing address ( P. 0. Box 9217, Corpus Christi, Texas 78A08) and EPA identification number (Refinery is TXD066447376 and the Landfarm is TXD000807859).
p\\so ^Vstivje,
,
1A 153982
SWRf/Asbestos 0799
3. The name and EPA identification number of each transporter. 4. The name, address-and EPA identification number of the desig
nated facility and an alternate facility if any. 5. The-description-Sof the waste or wastes required by regulations
of_the U. S. Department of-Transportation in -49 CFR 172.101, 172.-202 and 1727203. 6. The total quantity of each ^hazardous -waste by ^units -of^weight or volume, iand^the'^type and inumber of-containers as loaded into or onto the transport vehicle. 7. The following-certificationmust appear on the-manifest:
'!This is to ^certify that the above named materials are properly classified, described, packaged, marked, and labeled and are in proper condition for transportation according to the applicable regulations of the Department of Transportation sand the EPA."
8. The -manifest consists of at least the number of copies which will provide the generator (Southwestern Refining Co., Inc.), each transporter and the owner or operator of the designated facility with one copy each for their records and another copy to be re turned to the generator (Southwestern Refining Co., Inc.)
Use Of The Manifest: 1. Southwestern Refining Co., Inc. authorized representative must sign
the manifest certification by hand. 2. -Obtain the handwritten signature of the initial transporter and
datenof acceptance on the manifest. 3. Retain one copy for record keeping.
1A 153983
SWRf/Asbestos 0800
4. Southwestern Refining Co-, Inc. must give the transporter the remaining copies of the manifest.
5. For shipment of hazardous waste within the United States solely by railroad or solely by water (bulk shipments only), Southwestern Refining Co., Inc. must send three copies of the.manifest dated and signed in accordance with Part 1 of this section to the owner or operator of the designated facility. [~Coples,of the manifest are not required for each transporterT]
D. Record Keeping:
1. Southwestern Refining Co., Inc. must keep a copy of each manifest
signed in accordance under Section C (Use of the manifest) for
three years or until Southwestern Refining Co., Inc. receives a
signed copy from the designated facility which received the waste.
This signed copy must be retained as a record for at least three
years from the date the waste was accepted by the initial
transporter, i.e. - refers to shipment by railroad or solely by
water. 2. Southwestern Refining Co., Inc. must keep a copy of each Annual
Report and Exception Report for a period of at least three years
from the due date of the report (March 1).
a.) Annual Report: 1. Do for hazardous waste shipped off-site.
2. Use EPA forms 8700-13 and 8700-13A according to the
instructions on the form.
3. Send to the Regional Administrator for the Region in
which Southwestern Refining Co., Inc. is located.
4. This will be sent no later than March 1 for the
preceding calendar year.
SWRf/Asbestos 0801
1A 153984
b.) Exception Reporting: 1. If Southwestern Refining Co., Inc. has not received a copy of the manifest with the handwritten signature of the owner or operator of the designated facility within 35 days of the date the waste was accepted by the :;initial transporter must contact the transporter and/br=:the owner^or operator of the designated facility to determine the status-of the hazardous waste 2. Southwestern Refining Co., Inc. must submit an Exception Report :to the EPA Regional Administrator for the Region in-which Southwestern Refining Co., Inc. is located if these have not been received, a copy of the -manifest with the handwritten signature of the owner or operator of the designated facility within 45 days of the date the waste was accepted by the initial transporter. 3. The report must include: a.) a legible copy of the manifest for which Southwestern Refining Co., Inc. does not have confirmation of delivery, b.) a cover letter signed by Southwestern Refining Co., Inc. authorized representative explaining the efforts taken to locate the hazardous waste and the results of those efforts.
SWRf/Asbestos 0802
1.A 153985
PACKAGING AND LABELING REQUIREMENTS/PETROLEUM REFINING WASTES III
SWRf/Asbestos 0803
1A 153986
BY*' jU ** Un-t-x p-ur-t-wW^ Lruifc-- Lc-/_^,
PACKAGING AND LABELING REQUIREMENTS/PETROLEUM REFINING WASTES
___j k* An.
The packaging, labeling, marking, placarding, and shipping paper requirements for the Petroleum Refining wastes that Southwestern Refining Company, Inc. lias specified are as follows:
1. TThe .following wastes will.be shipped as a mixture:.
K0A8 - Dissolved -air flotation (DAP) float from Pet. Ref. Ind. K049 - Slop oil-emulsion solids. K051 - API separator-sludge. K052 - Tank bottoms (leaded). K050 - Heat exchanger bundle cleaning -sludge. F001 - Spent halogenated solvents used in degreasing. P002 - Spent halogenated-solvents. F003 - Spent non-halogenated solvents. F005 - Spent non-halogenated solvents.
I. DOT Requirements
A. Package - No DOT specification packaging required. A DOT specifi cation MC 312 Tank will be acceptable. (Appendix A)
B. Labeling - No DOT labeling required
C. Marking - No DOT marking required
D. Placarding The cargo tank must be placarded with a "combustible" placard.
E. Shipping papers - The description and classification for the shipping papers.is as follows: "Waste combustible liquid, n.o.s.,
{^combustible liquid ,\NA 1993"
II. Manifest requirements - The manifest lmust contain all of the following information:
A. A manifest document number.
B. The generators name, mailing address, telephone number and EPA identification number (Southwestern Refining Co., Inc., P. 0. Box 9217, Corpus Christi, Texas 78408. Tel No. 512 884-8863 and EPA I.D. No. is TXD066447376).
C. The name and EPA identification number of the designated facility.
D. The description of the waste - "Waste combustible liquid, n.o.s., {7Combustible liquid,jNA 1993"
SWRf/Asbestos 0804
1A 153987
E. Total quantity.
F. The following certification must appear on the manifest:
"This is to certify that the above named materials are properly-classified, described, packaged, marked, and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation and the EPA".
G. DOT hazard class code - 01.
2. Spent Dimersol Caustic
I. DOT requirements:
A. Package - DOT specification MC 312 cargo tank.
B. Labeling - No DOT labeling required.
'yWJU-'
C. Marking - No DOT marking required. /
D. Placarding - The cargo tank must be placarded on 4 sides with a "corrosive" placard.
E. . Shipping papers - The description .and classification for the shipping papers is as follows: "Waste corrosive liquid, n.o.s., corrosive material, UN 1760"
II. Manifest requirements - The manifest must contain all of the following information:
A. A manifest document number.
B. The generators name, mailing address, telephone number and EPA identification number.
C. The name and EPA identification number of the designated facility.
D. The description of.the waste - "Waste corrosive liquid, n.o.s., Corrosive material, UN 1760"
E. Total quantity.
F. The following cerfification must appear on the manifest:
"This is to certify that the above named materials are in proper condition for transportation according to the applicable regulations of the Department of Transportation and the EPA".
G. DOT hazardj^code - 02.
1A 153988
SWRf/Asbestos 0805
3. Spent Alkylation Lime
I. DOT Requirements:
A. Package - DOT specification MC 312 cargo tanks.
B. Labeling -'HoDOT labeling required.
: v. :
C. Marking - No .DOT .marking required. ^
l
'
A. )
D. Placarding--uThe-cargo tank must be placarded with a "Corrosive" placard.
E. Shipping papers - The description and classification for the shipping-papers is as follows: "Waste corrosive iiquid. ji.o.s.^ Corrosive material, UN 1760".
II. Manifest Requirements - The manifest must contain all of the following information:
A. A manifest document number.
B. The generators name, mailing address, telephone number and EPA identification number.
C. The name and EPA identification number of the designated facility.
D. .The description of the waste - "Waste corrosive liquid, n.o.s., corrosive material, UN 1760".
E. Total quantity.
F. The following certification must appear on the manifest:
"This is to certify that the above named materials are properly classified, described, packaged, marked, and labeled and are in proper condition for transporation according to the applicable regulations <^oj) the Department of Transportation and the EPA".
G. DOT hazard class code - 02.
4. Ethylaluminum dichloride (EADC)
I. DOT Requirements
A. Package - Place the material in a metal can made of at least 28 guage electro-coated tin plate. Close by positive means. Metal can not to exceed 1.gallon, and openings of can are not to exceed 1 inch. Put JL2 one-gallon cans in a DOT 17C,55 gallon drum, 4 cans per tier, 3 tiers high. Each tier must be separated with a tin plate separator. Cushion can with vermiculite.
1A 153989
SWRf/Asbestos 0806
B. Labeling - The outside of the drum must be labeled with a "Flammable liquid" label. A product label with precautionary information should be put on the outside of the drum. The information would include the following:
Ethylaluminum Dichloride WARNING
Keep away from heat, sparks and open flame Keep container closed Use with adequate ventilation
\
C. Marking - The outside of the drum must be marked "Waste pyrophoric liquid, n.o.s." The drum must also be marked "THIS END UP" to indicate upward position of.the inside packagings. The letters must be at least 2 inches high. The outside^of the drum-must be marked with the following information:
"HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal- If found, contact the nearest police or public safety authority or the U. S. Environmental Protection Agency. Generator's Name and Address___________________
Manifest Document Number
D. Placarding - The motor vehicle must be placarded on 4 sides with
a "Flammable liquid" placard if the aggregate gross weight of the
material exceeds 1,000 pounds, (-fa,
\ ^ <=~*-
crw
uj / p-fl-* < w --i
E. Shipping papers - The description and classification for the shipping papers is as follows: "Waste pyrophoric liquid, n.o.s.,
Flammable liquid, UN 2845"
II. Manifest Requirements - The manifest must contain all of the following information:
A. A manifest document number.
B. The generators name, mailing address, telephone number and EPA identification number.
C. The name and EPA identification number of the designated facility.
D. The description of the waste - "Waste pyrophoric liquid, n.o.s., Flammable liquid UN 2845"
E. Total quantity.
F. The following certification must appear on the manifest:
"This is to certify that the above named
materials are properly classified, described,
packaged, marked, and labeled and are in
proper condition for transportation according
to the applicable regulations of the Depart
ment of Transportation and the EPA"
1A 153990
SWRf/Asbestos 0807
DOT hazard class code - 07
SWRf/Asbestos 0808
1A 153991
APPENDIX A Definition of MC 312 Tank
Design pressure shall not be less than the pressure used for unloading. If unloading pressure exceeds 15 psig build in accordance-with ASME code. Line tanks if material hauled is not compatible with tank material or provide corrosion allowance for 10 years of normal service. Relief ''devices" to be capable of limiting over-pressure to 1.5 times design .pressure. "If air inlet devices are provided a relief valve shall have adequate capacity to limit tank pressure to'"130 percent of design pressure at max inlet flow." Outlet valves at top must be as "close as practical" to outlet nozzle. Bottom outlets must have.emergency valves capable of being operated from a min of 10' away. If the liquid is "corrosive with solids in suspension in sufficient quantity that settling may form a layer of solid material that may interfere with sealing of the valve seat" the bottom remote emergency valve is not required.
SWRf/Asbestos 0809
1A 153992