Document D5gDQxb8jo7qdp4MbJZrox3O

ENVIRONMENTAL QUALITY MANUAL CONOCO CHEMICALS COMPANY ABERDEEN CHEMICAL PLANT August 1983 DTH 000095665 ENVIRONMENTAL QUALITY MANUAL CONOCO CHEMICALS COMPANY ABERDEEN CHEMICAL PLANT Table Of Contents ENVIRONMENTAL POLICY EMERGENCY CALLOUT RELATING TO POLLUTION INCIDENTS PLANT ENTRY BY POLLUTION CONTROL AGENCIES PUBLIC POLLUTION COMPLAINTS PVC RESIN DISCHARGE GUIDELINES VCM REGULATIONS PLANT WASTEWATER DISCHARGE REQUIREMENTS SPCC PLAN (OIL DISCHARGE) RCRA HAZARDOUS WASTE TRAINING MANUAL RCRA HAZARDOUS WASTE CONTINGENCY PLAN WASTE OIL DISPOSAL PCB OIL TOXIC SUBSTANCE CONTROL REPORTING SUPERFUND - HAZARDOUS SUBSTANCE SPILL AND RELEASE REPORTING REQUIREMENTS DTH 000095666 DTH 000095667 ENVIRONMENTAL POLICY As an energy company, Conoco's activities have an Impact on the environment in which the Company operates--on the land, air, water and the life forms found there. It is the policy of the company to conduct all operations in a lawful and environmentally responsible manner. Specifically, it is Conoco policy to: 1) Comply fully with all environmental laws and regulations related to environmental quality in all of its activities. 2) Employ Conoco's scientific and technical skills to reduce pollu tion and promote environmental conservation in the Company's operations. 3) Use accepted reclamation practices to restore production and mining sites. 4) Maintain an environmental quality assurance program to ensure that operations are in compliance with Conoco policies, permit limitations, and other regulatory requirements. 5) Routinely review Conoco's products, processes, and control facilities as new information is available for the purpose of making environmental quality improvements beyond those legally required where such improvements bear a reasonable relationship to their cost. 6) Train Conoco employees involved in environmental quality activi ties, and keep them abreast of new developments relating to that responsibility. 7) Maintain contingency plans to clean up spills of oil or other materials caused by the Company. Such plans include providing competent personnel and effective equipment. 8) Determine that each new and existing product can be made, used, handled, and disposed of safely and consistent with appropriate environmental quality, public health, and safety criteria. 9) Cooperate with government to help promulgate sound environmental laws and regulations and inform government of the impact of such laws and regulations on the Company. 10) Communicate Conoco's environmental commitment to employees, stock holders, and the general public. 11) Monitor public attitudes on environmental matters so that the Company's environmental policies and public statements can be responsive to those attitudes. DTH 000095668 000095669 dth EMERGENCY CALLOUT RELATING TO POLLUTION INCIDENTS An emergency is considered to be a condition or situation requiring assis tance over and above that which can be supplied in the normal manner". With respect to pollution incidents, an emergency situation will exist when there is an immediate threat to people, property, equipment or the environment. In general, it is always the responsibility of the Supervisor to recognize when a pollution incident has occurred, and to notify the correct management personnel of the incident. It is not the responsibility of the Supervisor or any other Operations personnel to contact Government agencies or the Press. All contact with the Government or the Press must be made ONLY by Plant Management. If there are ever any questions concerning response to a pollu tion incident. Process Engineering should be contacted for assistance. The following pollution incidents will require emergency callout as outlined below. The first person on the call list should contact the second person, etc. 1) A minor VCM release to the atmosphere. a) Shift Supervisor b) Operations Supervisor-Primary Operations Superintendent-Alternate c) Plant Superintendent d) Environmental Engineer-Primary Chief Process Engineer-Alternate Senior Process Engineer-Alternate 2) A massive VCM release to the atmosphere. a) Follow Emergency Callout Procedure in the Plant Fire Prevention and Emergency Plan. 3) A massive resin discharge to the atmosphere. a) Shift Supervisor b) Operations Supervisor-Primary Operations Superintendent-Alternate c) Plant Superintendent d) Environmental Engineer-Primary Chief Process Engineer-Alternate Senior Process Engineer-Alternate 4) An oil spill which cannot be contained within the Plant boundaries. a) Shift Supervisor b) Operations Supervisor-Primary Operations Superintendent-Alternate c) Plant Superintendent d) Environmental Engineer-Primary Chief Process Engineer-Alternate Senior Process Engineer-Alternate 5) A chemical spill (i.e. caustic soda, acid) to the storm sewer. a) Shift Supervisor b) Utilities Supervisor-Primary Mechanical Superintendent-Alternate c) Plant Superintendent-Alternate d) Environmental Engineer-Primary Chief Process Engineer-Alternate Senior Process Engineer-Alternate DTH 000095670 EMERGENCY CALLOUT RELATING TO POLLUTION INCIDENTS (Continued) 6) A massive chemical spill to the process sewer. a) Shift Supervisor b) Utilities Supervisor-Primary Mechanical Superintendent-Alternate c) Plant Superintendent d) Environmental Engineer-Primary Chief Process Engineer-Alternate Senior Process Engineer-Alternate 7) A wastewater bypass or other wastewater permit violation. a) Supervisor b) Operations or Mechanical Superinten dent c) Plant Superintendent d) Environmental Engineer-Primary Chief Process Engineer-Alternate Senior Process Engineer-Alternate 8) A PCB oil spill. a) Supervisor b) Mechanical Superintendent-Primary c) Plant Superintendent d) Environmental Engineer-Primary Chief Process Engineer-Alternate Senior Process Engineer-Alternate 9) A hazardous waste spill that cannot be contained by readily available means. a) Shift Supervisor b) Operations Supervisor-Primary Operations Superintendent-Alternate c) Plant Superintendent d) Environmental Engineer-Primary Chief Process Engineer-Alternate Senior Process Engineer-Alternate 10) A non-permitted and non-routine discharge of any hazardous substance to the environment (See SUPERFUND Section). a) Shift Supervisor b) Operations Supervisor-Primary Operations Superintendent-Alternate c) Plant Superintendent d) Environmental Engineer-Primary Chief Process Engineer-Alternate Senior Process Engineer-Alternate DTH 000095671 PHONE NUMBERS The following phone numbers may be needed during a pollution incident: Plant Superintendent Vinyl Superintendent Compound Superintendent Chief Process Engineer Mechanical Superintendent Environmental Engineer Senior Process Engineer Safety Director Plant Manager Chief Plant Chemist Warehouse Supervisor Vinyl Supervisor Compound Supervisor Maintenance Supervisor 1 & E Supervisor Utilities Supervisor Contract Supervisor Charlie Miller Pete Markey Paul Kober Dick Frohreich Rick Snowden Dave Mahler Veldon Messick Al Sather John Friend Larry Stoltz Rex Shackelford Doug Miller Ronnie Gilreath Jerry Horstman Charlie Davis Dennis Knight Gilbert Morgan 369-9100 369-6019 369-7096 1-328-3628 1-327-7382 1-327-4540 1-327-0741 369-9271 369-7377 1-205-698-8459 369-9234 369-7745 369-6005 369-8780 1-205-698-9545 369-6522 Mississippi Department of Business Hours Natural Resources Non-Business Hours Jerry Banks (Primary Air Contact) Robert May (Primary Water Contact) Cindy Rich (Primary Hazardous Waste Contact) Dwight Wylie (Alternate Air Contact) Bill Barnett (Alternate Water Contact) David Lee (Alternate Hazardous Waste Contact) 1-961-5171 1-961-5340 National Response Center 1-800-424-8802 EPA - Atlanta 1-404-881-4062 DTH 000095672 DTH 000095673 PLANT ENTRY BY POLLUTION CONTROL AGENCIES Government pollution control personnel or their agents are not to be allowed entry into the Plant unless they are accompanied by authorized Plant person nel. Before entry, the person(s) requesting entry must complete and sign the Request For Entry form, and the form must be given to Process Engineering. At least one of the following Plant personnel or an appointee must be contac ted and present before entry into the Plant is made: 1) Plant Superintendent 2) Environmental Engineer 3) Chief Process Engineer 4) Plant Manager 5) Operations Superintendent While in the Plant it is the responsibility of the person accompanying the visitor(s) to make sure that the visitor(s) abides by all Plant Safety rules. It is Conoco's policy to cooperate with regulatory agencies whenever possi ble. Toward this goal all employees who come into contact with these people will be cooperative and courteous. All questions will be answered honestly. Under routine circumstances the following responsibilities are assigned to handle these visits, in accordance with the Plant Security Plan. The Plant Manager will be contacted by the individual assigned and advised of all but the most routine visits. A preliminary meeting with the visitor, the em ployee responsible for handling the visit and the Manager may be required at that time. ALTERNATE AGENCY RESPONSIBILITY RESPONSIBILITY 1) EPA - NESHAPS, RCRA, Water Environmental Engineer Chief Process Engineer 2) Miss. Department Of Natural Resources Environmental Engineer Chief Process Engineer 3) Coast Guard Chief Process Engineer Plant Manager Only the Manager is authorized to: 1) Commit the company to special demands such as compliance programs. 2) Release information which might reveal a trade secret. 3) Permit photographs of Plant facilities. DTH 000095674 REQUEST FOR ENTRY 1. My name is. I represent (agency or bureau) > which is established by the laws of the (United States) (State of . My business address is 2. In my official capacity, I am requesting admission to (plant or facility) for the purpose of: ( ) a. Gathering scientific research information and/or studying technology development, under (statute or popular name of act) ()b Making a regularly scheduled inspection of the facilities, under; (statute or popular name of act) ( ) c. Making a special inspection of the facilities for the follow ing purposes: under (statute or popular name of act) ( ) d. Other; specifically _____________________________________ under (statute or popular name of act) DTH 000095675 3. I specifically wish to see the following units or activities: 4. 1 agree to provide split samples of all samples of whatever nature obtained, and to furnish you all analytical results from all test con ducted. Samples will be analyzed for the following parameters:_________ using the following methods by (Analytical laboratory performing analyses) 5. I understand that 1 will be furnished a guide and such other assistance as I may require for information or safety. I agree to comply with all safety regulations and instructions, whether written or oral, while on the premises. 6. I agree to indemnify and hold you harmless from and against any loss, costs, expense or liability arising out of any loss, claim, or cause of action for loss of or damage to my property or equipment, or that of my employees or agents^ and injuries to or death of persons caused by, resulting from or incidental to the entry authorized hereby; provided, however, that except for loss of or damage to my property or equipment, or that of my employees or agents, such indemnification and hold harmless shall not apply to claims for loss, damage, injury or death if caused by your sole negligence. I, and my employees and agents, agree to treat and maintain as confiden tial property of the Agency, and, except as is necessary to perform the work envisioned hereunder, shall not use or disclose to others, either during the term of this entry or thereafter, any information (including any technical information, experience, or field data) regarding products, plans, programs, plants, processes, costs, equipment, operations, or customers which may be disclosed to or come within my knowledge, or that of my employees or agents, during the entry authorized hereby. The pro visions of this paragraph shall not apply to any information Referred to herein which I can establish (i) has been published and has become part DTH 000095676 of the public domain, other than by my or my employees or agents acts or omissions, (li) has been furnished or made known to me by third parties (other than those acting directly or indirectly for or on behalf of you) as a matter of legal right and without restriction on disclosure, or (ill) is required by law to be disclosed. (Date) (Time) (Visitor) (Title) (Agency or Bureau) DTH 000095677 DTH 000095678 PUBLIC POLLUTION COMPLAINTS All calls received at the Plant are handled by the guard at the front gate. When handling a public complaint the following guidelines should be followed: 1) Be sure to request and accurately record the caller's name, address and telephone number. 2) Be polite and courteous, but don't make any statements admitting responsibility. 3) If the Plant is obviously in an upset condition, assure the caller that the Plant personnel are working as quickly as possible to return the units to routine operation. 4) Tell caller that someone from the Plant will contact him to discuss the complaint. After receiving the complaint fill out the Citizen Complaint Report. Immedi ately notify the Safety Supervisor, and distribute the Citizen Complaint Report to the Plant Manager and Department Heads. The original report should be given to the Safety Supervisor. If the complaint is the result of an up set condition in the Plant, notify the Shift Supervisor so that steps can be taken to correct the condition if possible. The Safety Supervisor will then call the Plant Manager or the Plant Superin tendent to discuss the problem, and the complainant will be called back by a designated person. DTH 000095679 CITIZEN COMPLAINT REPORT NAME:_____________________________ ________________ ADDRESS: ___________________ DATE: TIME: TEL. NO.:_ COMPLAINT: REPORT TAKEN BY: TEMPERATURE:____________________________ WIND DIRECTION: FROM TO WIND SPEED: 1. Tell caller that someone from the plant will contact him to discuss the complaint. 2. Immediately notify Shift Supervisor and Safety Supervisor. 3. Send orginal to Safety Supervisor. DTH 000095680 4. Send copies of complaint to: Plant Manager, Department Heads. DTH 000095681 PVC RESIN DISCHARGE GUIDELINES The Plant has an air permit from the State Of Mississippi which outlines the quantity of certain air contaminants that the Plant can discharge to the air. This permit is primarily concerned with particulate emissions, such as PVC dust. Particulate emission sources around the Plant are the PVC dryer stacks, the PVC and compound storage silo baghouses, miscellaneous ventila tion systems in the compound area and open resin piles or spills. In general, process equipment in the Plant is capable of meeting all of the applicable emission limitations in the air permit, however process equipment malfunctions may result in air permit excursions that must be reported to the State. The following guidelines must be noted with regards to PVC dust emissions to the air. 1) If a dryer or silo dust collector bag ruptures, notify the Shift Supervisor and take immediate action to stop the discharge. 2) If a resin discharge appears to have been massive, i.e. a cloud of resin blows out of the Plant, notify the Operations Supervisor or Superintendent. Process Engineering must then be contacted so that they can notify the State of the discharge as soon as possible. 3) If resin Is spilled on the ground or on building structures, take immediate steps to keep the resin from blowing out of the Plant. During or after cleanup wash the area down with water. 4) If slurry is spilled on the ground or on building structures, wash the slurry down before it can dry out and become an open dust source. 000095682 DTH VCM REGULATIONS The Federal GovemmenC has developed regulations which limit the quantity of VCM that can be emitted to the atmosphere. Compliance with these limitations is accomplished by using the Standard Operating Procedures. Emissions From The Reactors VCM emissions from each reactor are limited to 420 pounds per million pounds of PVC produced. In order to comply with this requirement, every PVC batch is steam stripped, sampled during dump and subsequently analyzed for VCM residual. The Plant is required to report the daily VCM residual averages to the State every six months. Emissions From Relief Valves Discharges of any amount of VCM through relief valves on equipment in VCM service is prohibited with the exception of emergency relief valve dischar ges. The person who detects the release must notify the Shift Supervisor and take any steps that are necessary to stop the discharge. The Shift Super visor must then notify the Operations Supervisor and the Operations Superin tendent . Within ten days of any relief valve discharge to the air, the Plant must sub mit a written report to the State concerning the discharge. The report must describe the source, nature and cause of the discharge, the date and time of the discharge, the approximate total VCM loss during the discharge, the method used for determining the VCM loss and the action that was taken to prevent future discharges. Emissions From Equipment Venting The venting of equipment in VCM service to the atmosphere is prohibited, unless the equipment has been recovered and purged out properly. If pressure must be reduced in a piece of equipment in VCM service, the equipment should be vented to another piece of equipment in VCM service, one of the recovery systems or one of the incinerators. The VCM incinerators are used to burn gases which must be vented from VCM containing equipment in the Plant. The incinerator reduces the VCM concen tration in the gases to less than 10 ppm, which is the maximum VCM concentra tion that should be discharged from the incinerators. One of the fixed point monitor points is tied into the incinerator exhaust stacks to monitor the VCM emissions. In addition, weekly grab samples are taken from the incinerator exhaust by Process Engineering and analyzed for VCM. If there is 10 ppm of VCM or more in the incinerator exhaust, the incinerator should be taken out of service and the Operations Supervisor or Operations Superintendent should be contacted. Periods during which the VCM concentration in the incinerator stack exceeds 10 ppm, averaged for an hour and commencing on the hour, must be reported to the State in the Semi-Annual Report. DTH 000095684 Emissions From Process Waste Water The release of process wastewater which contains more than 10 ppm VCM is pro hibited, with the exception of stripped reactor slurry. In general, water which has been in contact with VCM must be either steam stripped in process equipment before the equipment is opened, or transferred to the blowdown tank or water strippers. Emissions From Equipment Opening EPA regulations limit the amount of VCM that can be emitted from equipment that is opened to the atmosphere for any reason. The procedure for opening equipment in VCM service depends on the size of the equipment. Small pieces of equipment and piping which contain less than 25 gallons of VCM at atmospheric temperature and pressure (0.4 pounds of VCM) can be opened when the following requirements are met: 1) The equipment does not contain any liquid VCM. 2) Any VCM-contaminated wastewater contained in the equipment has been either steam stripped or transferred to the blowdown tank or water strippers. Larger pieces of equipment and piping which contain more than 25 gallons of VCM at atmospheric temperature and pressure (0.4 pounds of VCM) can be opened when the following requirements are met: 1) The equipment does not contain any liquid VCM. 2) The equipment has been depressured and then either steam stripped or flushed to a VCM containment system until the VCM content is less than 2% (20,000 ppm), as verified by a portable hydrocarbon analyzer or Test Method 106. Alternatively, other Plant proce dures may be used to recover the equipment, where applicable. 3) Any VCM-contaminated wastewater contained in the equipment has been either steam stripped or transferred to the blowdown tank or water strippers. It should be noted that opening of equipment at the VCM concentrations allowed by EPA regulations can result in employee exposure to VCM. When opening equipment, all efforts should be made to reduce the VCM content in the equipment to as low as possible. Emissions From Railcar Unloading The EPA allows the Plant to vent a small amount of VCM to the atmosphere whenever a VCM unloading hose is disconnected from a railcar. In order to be in compliance with this regulation, the pressure in each unloading hose must be reduced to at least 10 in. Hg vacuum using the Emission or Large Recovery System before uncoupling with the railcar. DTH 000095685 Emissions From Rotating Equipment EFA regulations require double mechanical seals on rotating shafts on equip ment In VCM service. The pressure between the two seals must be kept higher than the VCM pressure in the equipment with a high pressure fluid such as water or DOP. If a seal develops a leak under these conditions, the seal fluid leaks into the equipment instead of the VCM leaking out of the equip ment. Equipment must not be operated if the seal fluid is not at a higher pressure than the VCM pressure in the equipment. Alternatively, the pressure between the two seals can be lower than the VCM pressure in the equipment, if the seal fluid or the space between the two seals is vented to a recovery system or other closed system. VCM Leaks EPA regulations require the Plant to have a program to detect and eliminate VCM leaks. Major leaks are found by the fixed point monitoring system. If any fixed point monitoring sample point indicates three consecutive readings above 5 ppm, a panel leak alarm sounds and the operating personnel must locate and repair the leak. A leak reporting form must be completed for every leak detected by the fixed point monitor. If operations cannot repair the leak, a work order must be written and the leak must be repaired by Maintenance. Smaller leaks are detected during an area survey with a portable analyzer. The Plant program requires that certain valves and flanges be checked weekly during this survey. A leak reporting form must be completed for every leak detected with a portable analyzer. Massive VCM Release Should a massive release of VCM occur, efforts must be made to prevent fur ther emissions and evacuate personnel. An employee who observes a massive release of VCM must take measures to stop the flow if possible and contact the Shift Supervisor. The Shift Supervisor will evaluate the situation and contact the Operations Supervisor or Superintendent. Procedures for handling massive releases of VCM are outlined in the Emergency Plan Section of the Plant Health And Safety Manual. Immediately after a massive release of VCM, the Plant Manager or his designee must report the incident to OSHA and the State. In addition, the release must be reported to the National Response Center as required by the SUPERFUND regulations. DTH 000095686 DTH 000095687 PLANT WASTEWATER DISCHARGE REQUIREMENTS The Plant has a wastewater permit from the State Of Mississippi which out lines the quantities of water contaminants that the Plant can discharge to James Creek, and the frequency by which the Plant must monitor the discharge for these contaminants. These quantities and other discharge requirements are summarized below: I. OUTFALL 001 (Bioponds) Parameter BOD, Monthly Average - December 1 through April 3 - May 1 through November 30 BOD, Daily Maximum - December 1 through April 30 - May 1 through November 30 COD, Monthly Average - December 1 through April 30 - May 1 through November 30 COD, Daily Maximum - December 1 through April 30 - May 1 through November 30 Suspended Solids, Monthly Average Suspended Solids, Dally Maximum Limitation Monitoring Frequency 32 ppm (431 lbs/day) 26 ppm (357 lbs/day) Once/Week Once/Week 43 ppm (800 lbs/day) 40 ppm (774 lbs/day) Once/Week Once/Week 1,461 lbs/day 1,212 lbs/day Once/Week Once/Week 2,712 lbs/day 2,523 lbs/day Once/Week Once/Week 674 lbs/day 1,396 lbs/day Once/Week Once/Week Ammonia, Monthly Average 13 lbs/day Ammonia, Daily Maximum 28 lbs/day Flow -- Temperature ^95 F ph Dissolved Oxygen 6.0 - 8.5 >7.0 ppm OUTFALLS 002, 003 (Storm Sewers) Once/Week Once/Week Continuously Once/Week Once/Week Once/Week Suspended Solids, Monthly Average 100 ppm Suspended Solids, Daily Maximum 200 ppm Flow -- Temperature ph 95 F 6.0-8.5 Twice/Month Twice/Month Twice/Month Twice/Month Once/Month DTH 000095688 PLANT WASTEWATER DISCHARGE REQUIREMENTS (Continued) III. OUTFALL 004 (Breathing Air Compressor) Parameter Limitation Monitoring Frequency Flow Twice/Month Temperature ph S.95 F 6.0-8.5 Twice/Month Once/Month IV. RAW WASTEWATER BYPASS The bypassing of raw, untreated wastewater around the bioponds is pro hibited, except where unavoidable to prevent loss of life or severe damage to Plant facilities. The diversion of raw wastewater, in any quantity or quality, around the bioponds and out of the Plant is con sidered to be a bypass. This includes wastewater spillage as a result of heavy rains, equipment malfunctions, sewer failures, pumping, dredg ing, etc. V. NON-COMPLIANCE NOTIFICATION If any Plant employee becomes aware of an existing or imminent wastewater permit excursion condition, he should notify his Supervisor immediately. If there is any immediate action that can be taken to correct the condition, the employee or his Supervisor should take the appropriate action steps as soon as possible. The Supervisor should then contact the Operations Superintendent or the Plant Superintendent, who will contact Process Engineering for assistance. The Plant must notify the State in writing of any permit excursion within five days of becoming aware of the excursion. In the case of a wastewater bypass, the State must be notified in writing within three days of the bypass. DTH 000095689 DTH 000095690 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN FEBRUARY 1, 1983 WORK BY: Dave Mahler Environmental Engineer /--N APPROVED BY Chief Process Engineer DTH 000095691 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN CONTENTS SECTION I SECTION II SECTION III SECTION IV SECTION V SECTION VI APPENDIX A APPENDIX B INTRODUCTION PLANT DRAINAGE AND RUNOFF CONTROL INSPECTIONS SPILL ORGANIZATION REPORTING TRAINING AVAILABLE SPILL CLEAN-UP EQUIPMENT DIKE AND TRENCH INSPECTION REPORT DTH 000095692 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN I. INTRODUCTION Federal regulations require that facilities which could reasonably be expected to discharge oil prepare an SPCC Plan (Spill Prevention, Control and Countermeasure Plan). The intent of the SPCC Plan is to minimize the potential for harmful oil discharges to navigable waters within the U.S. A harmful oil discharge is defined as any oil discharge which causes a visible sheen on, or discoloration of, the surface of water. Harmful oil discharges are prohibited by law. The Aberdeen Plant uses a variety of oils during routine operations, such as plasticizers, alcohols, lubricants and chemical substances. Most of these oils are handled in diked, curbed or trenched-in areas which drain to the process sewer, however it is possible that oil could be spilled outside of these areas and subsequently run to the storm sewer. In order to trap any free oil which may have been spilled to the storm sewer, there are concrete basins with underflow baffles upstream from each storm sewer outfall. All potential spill areas are under plant security. The plant facilities are enclosed in a fenced area, and all the gates are locked except the main gate where a guard is present at all times. II. PLANT DRAINAGE AND RUNOFF CONTROL Oily substances are stored or handled at several locations within the plant. The following preventive measures have been taken to minimize the potential for an oil discharge from the plant. A. Plasticizer-Alcohol Tank Farm Bulk quantities of plasticizer, alcohol and caustic soda are stored in tanks at the Tank Farm. The area is enclosed by a three foot high concrete dike which will contain spills. Oil which is spilled at the Tank Farm tfill collect on the surface of the API Separator and will subsequently be recovered to the process. All of the tanks at the Tank Farm have level gauges. The Tank levels are checked daily and recorded on a form. The drains on all of the tanks are either blinded or plugged. B. Diesel Oil Storage Area The two small diesel oil storage tanks on the north side of the Tank Farm are enclosed by concrete curbing. There is a valve between the plasticizer-alcohol Tank Farm and the diesel oil storage area which can be opened in order to drain the diesel oil storage pad to the Tank Farm. DTH 000095693 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN /-N C. Alcohol Unloading Area Alcohol is unloaded from trucks on the south side of the Tank Farm. The area around the hookup stations Is enclosed by a trench In the roadway which drains to the API Separator. Oil which Is spilled at the unloading station ,in any quantity must be cleaned up Immediately. This should be accomplished by washing the spilled oil into the trench with water or cleaning up the spilled oil with sorb all. Failure to clean up oil promptly will result in the spreading of the oil onto the roadway by vehicles. D. T-450, 460 Area The area around T-450 and T-460 tanks on the east side of the plasti cizer building is enclosed by concrete curbing, and the curbed area drains to the API Separator. The two above ground tanks which are located within the curbed area have level gauges which are checked daily and recorded on a form. E. Plasticizer Reactor Relief Knockout Tank If a plasticizer reactor were to overpressure or relieve for some reason, the discharge would pass through the plasticizer reactor relief knockout tank. Entrained liquid in the discharge would collect in the tank instead of being discharged to the area around the plasticizer building. Although the tank is normally empty, there is a trench around the tank which drains to the API Separator. F. Large Drum Storage Area There is a large drum storage area located on the south side of the east warehouse. This area is enclosed by a concrete dike, fenced-in, locked and covered by a roof. There is a valve at the southeast corner of the dike which can be opened in order to let out rainwater. G. Waste Oil And Slop Oil Tanks There are two tanks on the north side of the API Separator which are used to store waste oil and oil which has been recovered from the API Separator. Both of these tanks are surrounded by a con crete dike, and the diked-in areas drain to the API Separator. Each tank has a level gauge. DTH 000095694 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN H. Empty Drum Storage Pad Empty drums from around the plant are drained and stacked on a concrete pad east of the API Separator. The concrete pad Is enclosed by a concrete curb, and oily drainage from the pad Is collected In a small sump at the north end of the pad. The sump Is pumped out to the waste oil storage tank or the API Separator as necessary. If the level In the sump becomes too high, the sump and the concrete pad will overflow to the API Separator. I. Lubricating Oil Storage Area Lubricating oils are stored on a concrete pad east of the truck scales. The pad is surrounded by a trench and a concrete curb, and covered by a roof. There is a drain valve on the south side of the curb which is blanked-off, and is not to be opened under any circumstances. Oil which is collected in this trench must be drummed and transferred to the waste oil sump by the API Separator. J. Drum Storage Areas At Reactor Units There is a small drum storage pad at each of the reactor units which is enclosed by a concrete curb. These areas drain to the process sewer. In the event of a chemical spill within these areas, there is a drain valve which can be closed if necessary. K. Glycerine Storage Area Glycerine drums are stored on a concrete pad at the north side of the V-1I dryer building. The pad is enclosed by a trench which drains to the process sewer. In the event of a spill within the area, there is a drain valve which can be closed if necessary. L. Firewater System Diesel Oil Storage Tanks There are two small diesel oil storage tanks at the firewater pond deluge building and at the Pond 5 deluge building. The area under the Pond 5 deluge diesel oil storage tanks is contained by a concrete curb, however if oil is spilled outside of the curbed area the oil will run into the wastewater treatment ponds. The situation at the firewater pond is similiar. If diesel oil is spilled outside of the curbing and it runs to the firewater pond, there is an underflow baffle which will keep the oil from being discharged from the plant. M. The Sphere And The Bullets The sphere and the bullets are surrounded by a concrete dike, which will contain VCM that may be spilled during a massive VCM release. DTH 000095695 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN N. Storm Water Runoff If there is an oil spill outside of any of the above areas, there is a possibility that the spill could reach the storm sewer instead of the process sewer. In order to prevent oil from being discharged from the plant via a storm sewer, there is a concrete basin upstream from each storm sewer outfall. These basins have two underflow baffles which will trap any free oil which may get into the stormwater runoff. Oil which collects on the basins must be cleaned up as soon as possible, since the oil will eventually become entrained or dissolved in the stormwater. III. INSPECTIONS A. Dikes And Trenches All dikes and trenches around potential oil spill areas are to be inspected semi-annually by Process Engineering. The attached inspection form must be completed and filed during this inspec tion. Cracked dikes or plugged trenches must be promptly repaired or cleaned out as necessary. B. Storm Sewer Basins The storm sewer concrete basins must be inspected for oil at least once per week by Process Engineering. If oil is observed on the basins during these inspections, or during an inspection by any other employee, the Environmental Engineer and the Contract Supervisor must be notified. The oil must then be cleaned up promptly and the source of the oil Identified if possible. IV. SPILL CLEANUP In the event of an oil or chemical spill, efforts must be made to prevent the spill from leaving the plant's boundary. Any employee who observes a spill must take immediate action to control the spill, and if the spill is too large to control by ordinary means, the Supervisor of the affected area must be contacted. The Supervisor will make an evaluation of the spill and will notify the Operations Supervisor or Superintendent, who will coordi nate cleanup of the spill. If the spill enters a storm sewer or approaches a plant boundary. Process Engineering must be contacted for assistance. Spills which occur to grade should be contained with whatever materials are available and the spill area should be roped off. Spills which enter the plant's sewers should be cleaned up whenever the spilled material reaches the concrete settling basins. Sorbent booms should be placed at the storm sewer outfall if oil is spilled to the storm sewer. When spilled material is cleaned up, the necessary Safety and Environmental disposal procedures must be used. If there is any doubt concerning the safe and proper cleanup and disposal of certain materials. Safety and Process Engineering must be contacted for assistance. DTH 000095696 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN /-N V. REPORTING If there is any visible oil discharge from the plant, the incident must be reported to the Mississippi Department of Natural Resources and the National Response Center. The following personnel are authorized to report oil discharges from the plant. The report must be made as soon as possi ble after becoming aware of the spill, but no later than within 24 hours of the spill. Chief Process Engineer Environmental Engineer Senior Process Engineer Plant Superintendent Plant Manager Vinyl Operations Superinten dent Compound Operations Superin tendent Mechanical Superintendent Dick Frohreich Dave Mahler Veldon Messick Charlie Miller John Friend Pete Markey Paul Kober Rick Snowden 1-327-6070 1-327-4540 1-327-0741 369-9100 369-7377 369-6019 369-7096 1-327-7382 The following numbers may be useful when reporting an oil spill: MDNR Between 7:30 a.m. - 4:30 p.m. call: (601) 961-5171 After 4:30 p.m., weekends and holidays call: (601) 961-5340 Robert May Bob Rogers Bill Barnett Wastewater Specialist Emergency Coordinator Wastewater Coordinator National Response Center All Hours 1-800-424-8802 VI. TRAINING Employees engaged in the operation and maintenance of equipment which could reasonably be expected to spill oil must be trained in the SPCC Plan. This training is to be conducted during the annual pollution train ing. Records of the employees who attend these training sessions are to be kept for at least three years. DTH 000095697 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN APPENDIX A AVAILABLE SPILL CLEAN-UP EQUIPMENT (1) VACUUM TRUCKS - Vacuum trucks are availabe from the following truck service companies: A. Nason Trucking - LOCATION: Aberdeen, MS PHONE: 369-9383 ARRIVAL TIME: 15 Minutes B. G. B. Smith, Inc. - LOCATION: Hattiesburg, MS PHONE: 649-1220 ARRIVAL TIME: 3.5-4 Hours C. Industrial Maintenance Cleaning Contractors Incorporated (I.M.C.C.I) LOCATION: Besemer, AL PHONE: 205-428-0621 ARRIVAL TIME: 6 Hours D. Hydro-Tech Inc. - LOCATION: Mobile, AL PHONE: 205-456-8477 ARRIVAL TIME: 6 Hours (2) SKIMMING PUMP - Skimming pumps available from the Nason Trucking. (3) ALUMINUM BOAT - An aluminum boat is available from the waste treatment ponds. (4) Spill booms, rolls and pads of oil sorbent materials are available from storeroom to remove oil from the creek or settling pits. (5) Sorbent materials for liquid spills on concrete areas or the ground are available in drums at the following locations in the plant. AREA LOCATION Vinyl Area New Reactor Module 743 Reactor Old Reactor Module D-500 Reactor Compound Plasticizer (1) Line III and Line V Area (2) Second Floor Outside Compound Control Room Plasticizer Lab V-ll Area Shop Air Compressors East Shop Area Warehouse PVC Baggers DTH 000095698 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN APPENDIX B SPCC PLAN DIKE AND TRENCH INSPECTION REPORT Date: Inspector: Item Plasticizer Tank Farm Dike: VCM Tank Farm Dike: Lagoons Acid Dike: Alcohol Unloading Area: Curbed Area East Of P-I: Diesel Oil Storage Areas: Waste Oil And Slop Oil Dikes: Empty Drum Storage Pad: Lubricating Oil Storage Area: Reactor Drum Storage Pads: Glycerine Drum Storage Area: Large Drum Storage Area By East Warehouse: Status The following problems should be checked for and noted, along with any other obvious discrepancies: 1. Cracks or damage to dike walls, curbing. 2. Trenches that are full of solid debris and will not drain. 3. Liquid-full trenches or curbed areas. 4. Obvious signs of oil spillage outside of the contained area. 5. Drain valves that are open where the area to be drained does not tie into the process sewer system. DTH 00009 6. Write "W.O. Written" under status column after a work order has been written to correct a discrepancy* HAZARDOUS WASTE DISPOSAL I DTH 000095700 RCRA HAZARDOUS WASTE TRAINING MANUAL ABERDEEN CHEMICAL PLANT March 4, 1983 DTH 000095701 RCRA HAZARDOUS WASTE TRAINING MANUAL ABERDEEN CHEMICAL PLANT Table Of Contents I. INTRODUCTION II. HAZARDOUS WASTES IN THE ABERDEEN CHEMICAL PLANT III. HAZARDOUS WASTE PACKAGING AND LABELING REQUIREMENTS IV. HAZARDOUS WASTE MANAGEMENT - API SEPARATOR V.HAZARDOUS WASTE MANAGEMENT - HAZARDOUS WASTE DRUM STORAGE AREA VI. HAZARDOUS WASTE MANIFESTS dth 0095702 RCRA HAZARDOUS WASTE TRAINING MANUAL ABERDEEN CHEMICAL PLANT I. INTRODUCTION The management of hazardous waste is regulated by the Resource Conserva tion and Recovery Act of 1976 (RCRA). This law requires all facilities which treat, store or dispose of hazardous waste to conduct classroom training for facility personnel who handle hazardous waste. This train ing is necessary to ensure that facility personnel are familiar with the hazardous waste management and emergency procedures relevant to the positions in which they are employed. This manual provides an outline of the training which facility personnel who handle hazardous waste receive. All personnel who attend the train ing sessions receive general training in the areas of hazardous waste recognition, packaging, labeling, storage and emergency procedures. More specific training is given to the individual departments, with emphasis on the hazardous waste management procedures relevant to their area(s). II. HAZARDOUS WASTES IN THE ABERDEEN CHEMICAL PLANT It is important for plant personnel to recognize which wastes in the plant are hazardous, in order to avoid the possibility of improper waste disposal. The following materials are hazardous wastes when discarded. A. Plasticizer Filter Cake Plasticizer filter cake contains a significant amount of DOP, which has been identified by EPA as a toxic hazardous waste when disposed of. B. API Solids The sludge that accumulates on the bottom of the API Separator contains a significant amount of DOP, and is therefore a hazardous waste. C. All Other POP-Contaminated Wastes Any material which contains a significant amount of DOP and is dis carded must be considered to be hazardous waste. This includes, but is not limited to DOP spill cleanup residues, DOP-saturated sludge generated during process equipment cleanout, or DOP-saturated absor bent booms. D. Waste Phthallc Anhydride Phthalic anhydride has been identified by EPA as a toxic hazardous waste when disposed of, therefore any spilled phthalic anhydride which is cleaned up and discarded must be considered to be a hazardous waste. TH 000095703 RCRA HAZARDOUS WASTE TRAINING MANUAL ABERDEEN CHEMICAL PLANT E. Barium, Cadmium, or Lead Stabilizer Wastes Any barium, cadmium, or lead stabilizers which cannot be used and are discarded must be disposed of as hazardous waste. Likewise, any waste materials contaminated with significant amounts of these stabilizers must be disposed of as hazardous waste as well. F. Unknown Materials Waste materials which have an unknown composition should be analyzed before disposal. If there are any questions about a waste material, contact Process Engineering for assistance. III. HAZARDOUS WASTE PACKAGING AND LABELING REQUIREMENTS Hazardous wastes which are disposed of in drums must be properly pack aged and labeled before they can be stored at the Plant's hazardous waste drum storage area and subsequently shipped to an off-site haz ardous waste disposal facility. A. Packaging All hazardous wastes must be packaged in 55 gallon steel drums before disposal, unless the waste is shipped in bulk form. All drums which are used for hazardous waste disposal must be in good condition and must not leak. If a drum leaks, the material must be transferred to a good drum. Appropriate safety gear should be worn when filling drums with hazardous waste (i.e. gloves, disposable coveralls or a dust respirator). Drums with open tops must be secured with a metal rim and bolt; all drums must be entirely closed and clean of waste material on the outside of the drums. The drums must then be palletized using pallets which are in good condition, and then banded around the middle in groups of four with metal or plastic banding. B. Labeling The proper labeling of hazardous waste drums is of the utmost importance. Each drum of waste must have clearly visible the com mon plant name, the EPA identification code numbers, and the DOT regulation names and identification numbers. Each drum must have a hazardous waste label and any other label required by DOT. The attached table gives code number and names for this label as well as the DOT and plant labeling requirements. The accumulation date must be placed on the hazardous waste label. This is the date material was first placed in the drums. The EPA I.D. number for the plant is MSD007031230. The manifest document number will be assigned when the waste is removed from the drum storage area for disposal at a hazardous waste disposal site. The current disposer. Chemical Waste Management, requires that their approval code for each specific waste be placed on top of each drum before they will accept the material. These codes are given on the attached table. DTH 000095704 HAZARDOUS WASTE DISPOSAL PROM LABELING REQUIREMENTS w Hto H Pd zo ho o^ 9 > <Z OPS sCMr r-> o m CoO o CSI O co o -a* o-H /-S sCM-/ .>CT*M-\ u<U u0) oQ SG CM o o z Z Si ^ pa w pH< CHO oOHN CCMO o C0M0 o to vO OO oo w < 5 & & r=> woZ 8H H ON 0H0 ON 0H0 00 Ch 00 ON ON ON ON <<<< zzzz to <N CO M<H1 EId g W1 w 1 g E1d g oo o o H Pd 0) at at at O pp 9 9 c 9 oooO Zz Z z z O z t-H PS Ed Ed M< QZZ PS CO H O O t 0) 4-1 co at co Z o co 9Z O TJ > IM TS CO -H N .-t at o Z co QJ 4J CO <0 CO z o CO DZ o 'Cu *o CO *H bi H CO O SC co # at 4-> go eg co Z o co 9Z O a tJ T3 CO -rH N .-I at o Z co * QJ 4- CO CO <0 z o CO 9 o Tl T3 M -H at 9 N o* at *h zz Ed S<S Z --H H Z < Ed ZH O zz O o at a H M o z>N c < u H rH at z 4J z CO T3 H rH o CO w Dh < V 4J iH H Pm H cu N a H QJ 4J ^ CO CQ CO U rH Ph s 9H 6M a at CO N O -H i-H i-t BZ 9 at H 4-) Eh CO 9 PQ QJ > H 0) O 0) a 0> Q) o 4- QJ 5s B0 u O uc T3 CO a to o x: T3 QJ QJ o --1 o H a a c rH 0) 0 u > CO o QJ Da p3 CL < 4J (0 Jg 0 X CJ CO Ed H rH CM Z jDTH 000095705 RCRA HAZARDOUS WASTE TRAINING MANUAL ABERDEEN CHEMICAL PLANT HAZARDOUS WASTE MANAGEMENT - API SEPARATOR The API Separator must be managed as a hazardous waste storage tank since hazardous waste accumulates on the bottom of the separator. The job title for the facility personnel who manage the API Separator is utility technician. It is the responsibility of the utility technician to monitor the operation of the API Separator. The following procedures further detail the responsibilities of the utility technician relevant to the RCRA regulations. A. API Separator Operation Organic material from the plasticizer tank farm and the plasti cizer building flows into the API Separator where organic and aqueous materials are separated. The API Separator must be skimmed periodically, to recovery any plasticizers which float to the surface of the separator. After being skimmed these plasti cizers are transferred back to the plasticizer building to make a plasticizer product. The water phase flows to the bioponds for physical and biological treatment prior to discharge to James Creek. According to RCRA regulations, the API Separator must be operated with a minimum freeboard of two feet. The normal level of the API Separator is much below this, however if the outlet pipe plugs or if the plant sewers back up, it is possible for the API Separator water level to rise. If the water level rises until there is less than two feet of freeboard, the utility supervisor and the plasti cizer operator should be notified immediately. During periods of high level the water level should be monitored closely, and all feed to the API separator cut off if necessary. If an overflow situation is imminent, the Plant Superintendent must be notified so that plant operations can be cut back until the problem is solved. The water level in the API Separator must be inspected daily and recorded on the utility daily logsheet. In addition, the Process Engineering group must inspect the API Separator weekly for obvious signs of leakage. The results are to be recorded on the "Hazardous Waste Weekly Survey". The solids that collect in the API Separator consist of sand, dirt, carbon black, PVC resin, alcohols and plasticizers. The solds must be periodically removed to allow the API Separator to operate pro perly. The solids are removed with a vacuum truck, and sent to a DTH 000095706 RCRA HAZARDOUS WASTE TRAINING MANUAL ABERDEEN CHEMICAL PLANT IV. HAZARDOUS WASTE MANAGEMENT - API SEPARATOR (Continued) B. API Solids secure hazardous waste landfill. The following procedure should be used to clean out the API Separator. 1) Measure the volume of the sludge in the API Separator, and determine the number of vacuum trucks that will be needed. If the vacuum trucks come from Chemical Waste Management, it may be necessary to order the trucks two weeks in advance. 2) The plasticizer operation must be shutdown before the API Separator is cleaned out. Skim the API Separator until it is free of oil before taking the API Separator out of service. 3) Block off the inlet to the API Separator, and pump the standing water out of the API Separator until only oil and sludge remain. The water must be pumped to the process sewer. 4) Vacuum the sludge out of the API Separator using air lances or water hoses to fluidize the sludge as necessary. If the sludge is too thick at the north end, dilute the sludge with oily water from the slop oil tank until the sludge flows freely. 5) When the sludge has been vacuumed out, fill the API Separator with water and allow any remaining sludge to settle before the API Separator is put back in service. V. HAZARDOUS WASTE MANAGEMENT - HAZARDOUS WASTE DRUM STORAGE AREA The hazardous waste drum storage area is used to store hazardous waste drums before they are shipped to the disposal site. The job title for facility personnel who manage the hazardous waste drum storage area is warehouse worker. It is the responsibility of the warehouse worker to make sure that all drums which are stored in the hazardous waste drum storage area are packaged and labeled properly, and that the hazardous waste drum storage area is maintained in a meat and orderly manner. A. Moving Hazardous Waste Drums Before moving hazardous waste drums to the hazardous waste drum storage area, the following items should be checked: 1) Make sure pallets are in good condition and that drums are positioned correctly on the pallets. 2) The drums should be in good condition, with all openings closed, and the drums must not be leaking. DTH 000095707 RCRA HAZARDOUS WASTE TRAINING MANUAL ABERDEEN CHEMICAL PLANT V. HAZARDOUS WASTE MANAGEMENT - HAZARDOUS WASTE DRUM STORAGE AREA (Cont.) A. Moving Hazardous Waste Drums (Continued) 3) The drums should be properly labeled. 4) Drums must be banded around the middle with plastic or metal banding. 5) Waste material Is to be cleaned from outside the drums. If any of these items are not done, the warehouse worker should not move the drums to the hazardous waste drum storage area until the discrepancies are corrected. If the drums are acceptable for storage the warehouse worker should move the drums to the hazardous waste drum storage area east of the warehouse dock. The drums should be placed along the north wall. Drums should never be left outside the drum storage area except when preparing drums for shipment. Care should be taken in driving the forktruck so that none of the drums fall off. It is easier to take a little longer to transport drums than to clean up the contents of a drum that would fall and rupture. If a drum does fall and rupture, the warehouse supervisor should be immediately contacted. Sorb-all should be put on oily wastes. The contents of the ruptured drum and any materials used in the clean-up operation should be placed into drums that are in good condition. Any remaining material in the ruptured drum should be transferred into a good drum and the ruptured drum should be cleaned out. Again, any materials used in the clean-up should also be placed in drums. These good drums should be properly labeled and placed in the hazardous waste drum storage area. B. Storage of Hazardous Waste Drums The drum storage area is diked with a fence around it and a roof over the top. Access to the area is controlled by a locked gate. Drums of hazardous waste should be stored along the north wall. Other raw materials are also stored in the drum storage area. These drums should not be stored immediately next to hazardous waste drums. Any evidence of leaking drums should be reported immediately to the stores supervisor so that the contents of the leaking drum can be tranferred to another drum. Since some of the wastes stored in the hazardous waste storage area are flammable, there is a possibility of a fire. If this should occur, guidelines in the Fire Protection and Emergency Plan or RCRA Contingency Plan should be used. DTH 000095708 RCRA HAZARDOUS WASTE TRAINING MANUAL ABERDEEN CHEMICAL PLANT HAZARDOUS WASTE MANAGEMENT - HAZARDOUS WASTE DRUM STORAGE AREA (^Continued) ' C. Records and Inspection The hazardous waste drum storage area is to be inspected weekly by the Process Engineering group. A copy of the "Hazardous Waste Weekly Survey" is attached. Items that are inspected and recorded are: 1) Obvious leaks or material around drums. 2) Signs of serious corrosion or deterioration of drums. 3) All drums should be closed. 4) Number of drums of each waste, with EPA identification number. DTH 000095709 Page 1 of 3 HAZARDOUS WASTE WEEKLY SURVEY DATE: NAME OF PERSON CONDUCTING SURVEY: 1. Hazardous Wastes in Drum Storage Area a. Any obvious leaks or material around drums? Yes ______________________No If yes, describe extent of material around drums and locate where material is coming from b. Any signs of corrosion or deterioration to drums? Yes ______________________No If yes, describe extent of corrosion or deterioration. c. Are all drums closed? Yes _____________________ No If yes, describe which drums are not closed. _____________ _________________________________________ _______ 000095710 Page 2 of 3 HAZARDOUS WASTE WEEKLY SURVEY (continued) DATE: NAME OF PERSON CONDUCTING SURVEY: 2. Hazardous Waste Drum Storage Record DESCRIPTION OF WASTE EPA ID NUMBER NUMBER OF DRUMS DATE DRUMS FIRST STORED IN AREA DTH 000095711 RCRA HAZARDOUS WASTE TRAINING MANUAL ABERDEEN CHEMICAL PLANT Page 3 of 3 HAZARDOUS WASTE WEEKLY SURVEY (Continued) DATE: NAME OF PERSON CONDUCTING SURVEY: 3. API Separator Inspect the API separator for any obvious signs of leakage. Record results below: DTH 000095712 RCRA HAZARDOUS WASTE TRAINING MANUAL ABERDEEN CHEMICAL PLANT VI. HAZARDOUS WASTE MANIFESTS No hazardous waste is to leave the plant without a manifest. The purpose of the manifest is to assure generators and government authorities that hazardous wastes are being properly transported to a disposal site after leaving the plant. A. Filling Out Manifests Attached is a copy of the hazardous waste manifest that must accompany each shipment of hazardous waste that leave the plant. Below is a detailed description of how to complete the manifest. 1) The generator is Conoco Chemicals Company, P. 0. Box 91, Aberdeen, MS 39730. The EPA ID code is MSD007031230. 2) Currently, all hazardous wastes are sent to Chemical Waste Management. This company is also the transporter. The name, address, phone, and EPA ID code of Chemical Waste Management is placed on the line labeled transporter No. 1. These items are identical to the items marked disposer. Since Chemical Waste Management is the only transporter used, the space provided for transporter No. 2 is to be left blank. 3) The number of drums of each type of waste is placed in the space for container No. The container type will usually be 55 gallon drums. 4) The proper DOT shipping name and DOT hazard class as found in the table in Part III of this manual should be placed in the space provided for description/class. If the proper DOT shipping name is "hazardous waste", a description of the hazardous material in the waste should be included. For example, for API solids and plasticizer filter cake, the words "contains Bis (2-ethylhexyl) phthalate" should be included. 5) Total quantity is usually the number of drums and unit is "drum". 6) EPA hazardous waste ID NO. and CWMA waste codes are found In the table in Part III. 7) The space marked "weight" should be left blank except when a bulk shipment is made. DTH 000095713 RCRA HAZARDOUS WASTE TRAINING MANUAL ABERDEEN CHEMICAL PLANT VI. HAZARDOUS WASTE MANIFESTS A. Filling Out Manifest (Continued) 8) Only the stores supervisor or someone from the Process Engineering group who has witnessed loading the shipment and double checked the wastes that were loaded should sign the manifest as the generator. 9) If more than three types of wastes are shipped on one truck, additional manifests must be used. The person who signs the manifest must personally check the drums to see that all necessary information is on the drums and that the information on the manifest accurately describes the wastes actually loaded on the truck. B. Manifests Procedures A copy of each hazardous waste manifest is to be retained in the plant by the Process Engineering group. The other copies are to accompany the waste shipment. The transporter is to retain a copy of the manifest and other copies of the manifest are to accompany the waste. When the waste has been delivered to the disposer and it has been checked, the disposer will sign the manifest accepting the waste and return's copy to the plant as verification that he has accepted the waste. The disposer also sends a copy of the manifest to the proper government authorities. A copy of the manifest signed by the disposer indicating accep tance of the waste must be received by the plant within 35 days from the date of shipment. If the manifest is not located within 35 days, a search for the manifest must be initiated. This search will be conducted by the Process Engineering group. If the manifest is not received within 45 days of the date of shipment, an exception report must be sub mitted to the State of Mississippi and the State of Alabama. The report must include a copy of the manifest and an explanation of efforts and results to locate the hazardous waste. (See section 402.5-32 or Mississippi Hazardous Waste Management Regulations). DTH 000095714 ALABAMA HAZARDOUS WASTE MANIFEST IPjMTIWCATlOH INFORMATION ADORESS PHONE CWMA : 74314 EPA ID CODE TBTT TEST oposn 1--fcFt--y V lac. F.O.B--55 I I I I I I I I I III II II lI I II III I Il I I I I IIIII 205-652-9531 t|U|D|Q|0|e||2||4||4 CONTAINER NO. TYPE DESCRIPTION/CLASS 'r . EMERGENCY INFORMATION ZT.IHCT NOS.: -- (SOS) M2-P511 ; 01NIRAT0R --(- SPECIAL INSTRUCTIONS: TOTAL QUAN. UNIT EPA Hasardous Waste ID No. 111 111 i1l 111 1I1 111 111 111 1i1 111 1 1 1 =y=L CWMA WASTE CODE WEIGHT US COAST GUARD 1-S00-424-SS02 CERTIFICATION Tfcfc is la certify Hwt Hm abovs cl--IflaJ, IncHM, pckgS, marked aad labeled aid etc la proper caadMee ( Mm applicable msliHrn af Hw af TraaeperteHon, Hm U.S. larlraaaiaalal PutacHaa Agsacyt Ganarator TNc b b eetHfy aceaptaace af Hm baaawtam -- sMpaMi Title Data Transporter #1 Transporter #2 Thic la la certify <iccaptaaca af Hm hacai Title Title eat deecrtbed abase far treatment, stetepe ar dispeeel: Data Data 1 f i Diip--r DISPOSAL INFCIRMATION CWMA WASTE CODE QUANTITY UNIT r PROCESS CODE Title SB LOCATION TRENCH LEVEL QUAD Dote COMMENTS DTH 000095715 " PRODUCER NO. 1 STATE OF ALABAMA DIVISION OF SOLID WASTE AND VECTOR CONTROL Instructions for the preparation of the Hazardous Waste Manifest: A. IDENTIFICATION INFORMATION: 1. Generator and Transporter's) name, address, phone number and EPA ID Code are listed here. B. WASTE INFORMATION: 1. Container, no., and type are listed here. For container type use drums, tank, bag, carton, bulk, roll-off, etc. 2. Description/Class: List the proper US DOT Shipping Name and US DOT Hazard Class for each waste as kfcntified in 49 CFR 171 through 177. When a waste is described by on N.O.S. description, the technical narmris) of tha hazardous constituents) must be identified in addition to the proper shipping name. Common or trad* names are not acceptable For example: waste, cement, liquid, n.o.s (hexane, toluene, 2-butonone), flammable liquid. When shipping PCB's use one of the following descriptions: CLASS DESCRIPTION A PCB Articles B PCB Equipment PCB Article C container D PCB Mixtures PCB Chemical E Substances F PCB Container SPECIFIC EXAMPLES Transformers (drained & flushed) Capacitors, Elec. Motors. Pumps. Pipe Mfd. Items (except class C or F) Containing Class A items - Such as fluorescent ballasts. Microwave Ovens, etc. Any Drum, can, package, barrel, etc. containing Gass A or B items But which is not in surface contact with PCB's. PCB contaminated soil, debris, sludge, slurries, rags, etc. with (Must be non-liquid fo be acceptable) Over 500 ppm PCB * Askorel, Arochlor, etc. - NOT ACCEPTABLE Any container with Class A, B, D, or E items but where surfaces hove been PCB contaminated. Example = Drum of soil 3. Quantity and unit are listed here. For unit use drums, eu. ft., gallons, etc. 4. EPA Hazardous Waste ID Number: The EPA Hazardous Waste numbers are listed in 40 CFR Part 261. Tha number or combination of numbers describing the woste are to be placed in this section. 5. CWMA Waste Code: Enter the Waste Code Number given to you by Chemical Waste Management-Alabama when waste wos approved. 6. Weight: Self-explanatory. C. EMERGENCY INFORMATION: Indicate special handling instructions. D. CERTIFICATION: Self-explanatory. Only a Generator's authorized representative con sign the manifest. E. DISPOSAL INFORMATION: For Disposer's use only. ROUTING OF MANIFEST After the Generator has completed his portion of the manifest he must have Transporter No. 1 sign and certify receipt of shipment. The Generator will then retain Producer's No. 1 copy and forward all other copies with the shipment. If there is more than one Transporter, Transporter No. 1 must have Transporter No. 2 sign and certify receipt of shipment. Transporter No. 1 must make a photocopy for his records. Do not retain any original copies. When shipment has been received at TSD Facility, the TSD Facility's authorized representative will sign for acceptance storage or disposal. Transporter's copy will be given to the delivering Transporter and Producer's Copy No. 2 will be returned to the Generator. The Regulatory copy will be forwarded to the Regulatory Agency by the Disposer. DTH 000095716 HAZARDOUS WASTE S P ILLS 000095717 dth