Document gDeXGZJY2n0pKb8VvmOjmMQG

Interoffice Communication To Distribution Ffom j. c. Ledvina Date April 12, 1984 Subject UNIFORM HAZARDOUS WASTE MANIFEST Attached is the final rule on Uniform Hazardous Waste Manifests. As I read it, all states, whether they have the RCRA program or not, must use this form starting 9/20/84. I'm sure your states will be providing information to you before that time. Ed Taylor Ross Oliver Dave Mahler Mike Hayes Paul Warner gU-l?34'39 UNITED STATES ENVIRONMENTSL^ROTECTiON-AGENC't WASHINGTON, C.C. 20^60 JJ. O'FiCt c* SOLlOv.ASTi AN3 EM*5CN?Y ftSON: Mr. Ronald E. Meissen Senior Environmental Engineer Travenol Laboratories, Inc. Deerfield, Illinois 60015 Dear Mr. Meissen: I apologize for not responding to your letter of March 3 sooner. As you can imagine, the last few months have been exceedingly busy for us. You.requested confirmation on a telephone interpretation I provided clarifying the totally enclosed treatment facility definition- You also said that you had received a somewhat different response from Mr. Gardner in our Office of General Counsel. Unfortunev+a]y, because of the newness of the regula tions, the number cf people involved here in their development, and their comp! axHy, it has not been uncommon for somewhat d j rf erent i nterpret-ct i ons to have arisen on occasion. There have been a lot of questions similar to y'ours con cerning the totally enclosed treatment facility. We have pre pared the enclosed clarification which I think answers your uastions. If we can be of any further assistance, please call 202/755-9135). Sincerely yours Enelosure ^JU-fT'ed W. Lindsey Deputy Director Hazardous & Industrial Waste Division (W K-5 6 5 ) A TOTALLY ENCLOSED TP.tATXrTT FACILITY # Regulatory Cl a r i f i cat * or. I* Issue: Fror. questions asked since pfor-.l gat icn of the regu lations on Kay IS, 19S0, it is clear that the definition and pracf:1 epplicatic of the term "totally enclosed treatment facility" require clarification. II* Piscussion: follows: The definition appears in 250.10(a)i as Totally enclosed treatment facility means a facility for the treatment of hazardous waste which is directly con nected to an industrial production process and which, is constructed and operated in a manner which prevents the release of any hazardous waste or any constituent thereof into the environment during treatment. An example is a pipe in which waste acid is neutralized. A facility meeting this definition is exenoted from the require ments of Parts 25* an_d 265 (See 264.1 (g) (5) and 265. 1 (c)(9)) and, .by extension, the owner or operator of that facility need net notify nor seek a permit for that process. The purpose of this provision is to remove from active regulation those treat ment processes which occur in close proximity to the industrial process which generatesNthe waste and which are constructed in such a way that there is little or, "no potential for escape of pollutants. Such facilities pos^ negligible risk to human health and the environment. The part of the definition which has generated the most uncertainty is the meaning of "totally enclosed." The Agency intends that a "totally enclosed" treatment facility be one which is completely contained on all sides and poses Ittleor z no potent tel for escape o' waste tc the en vi ronmer.c even during periods cf process unset. The facility rust be constructed so that no predictable potential for overflows, spills, caseous emissions, etc., can result from malfunction of pumps, valves, etc., associated witn the totally enclosed treatment or from a malfunction in.the industrial process to which it is connected. Natural calamities or acts of sabotage or war (earthquakes, tornadoes, bombing, etc.) are not considered predictable, how ever. As a practical matter, the definition limits "totally enclosed treatment facilities" to pipelines, tanks, and to other chemical, physical, and biological treatment operations which are car ad out in tartk-like equipment {e.g., stills, distillation columns, or pressure vessels) and which are con structed and operated to prevent discharge of potentially hazardous material to the environment. This requires consid eration cf the three primary avenues of esec leakage, spills, and emissions. To prevent leaking, the tank, pips, etc., must be cade of impermeable materials. The Agency is using the term i mp srr.ea bl e in the practical sense to mean no transmission of contained materials in quantities which wou-ld be visibly apparent. Fur ther, as with any other treatment process, totally enclosed treatnK t facilities are subject to natural deteriorate on (cor rosion, etc.) which could ultimately result in leaks. To meet the requirement in the definition that treatment be conducted UEU-i73442 A i 3 . . in a msr.nsr v/hlch prevents the release of any hazardous (' waste or- any constituent thereof ir.tc the environment - . the Agency believes that an owner or operator claiming the exemption generally will have to conduct inspections or ether discovery activities to detect deterioration and carry cut maintenance activities sufficient tc remedy it. A tank or pipe which leaks is not a totally enclosed facility. As a result, leaks must be prevented from totally enclosed facilities or the facility is in violation of the regulations. A totally enclosed facility must be enclosed on all sides. A tank or similar equipment must have a cover which would elim inate gaseous emissions and spills. However, many tanks incor porate vents and relief valves for either operating or emergency reasons. Such vents"must be designed to prevent overflows of liquids and emissions of harmful gases and aerosols, where such events might occcr through normal operation, equipment failure, or process upset. This can often be accomplished by the use of traps, recycle lines, and sorption columns of various designs to prevent spills and caseous emissio *. If effectively protected by such devices, a vented tank would qualify as a totally enclosed treatment facility. When considering protective devices for tank vents, the question arises as to whether the protective device is itself adequate. The test involves a judgment as to whether the overflow or gaseous emission passing through the vent will be C YEV-173443 I {A prevented from reaching the environment- For example, * n open catchment basin for overflows is not satisfactory if the hazardous constituents in the waste nay be emitted to the air. Similarly, it may also not be satisfactory if it is only large enough to hold the tank overflow for a brief period bef * it also overflows* However, even in this situation, alarm systems could be installed to ensure that the capacity of the catchment basin is not exceeded. Where air emissions from vents or relief valvis are concerned, if the waste is non-volatile or the emi jions cannot contain gases or aerosols which could be hazardous in the atmosphere, then no protective devices are necessary. An example might be a pressure relief valve cn a tank containing non-volatile waste . Where potentially harmful emissions could occur,- then positive steps must be taken. -For example, the vent could be connected to an incinerator or pro cess kiln. Alternately, a sorption column might be suitable if emission rates are low, the efficiency of the column approaches 100 percent, and alarms or other safeguards are available so that the upset causing the emission will be rectified before the capacity of the column is exceeded. Scrubbers will normally not be sufflcier.t because of their tendency to malfunction and. efficiencies typically do not approach 100 percent. Tanks sometimes have floating roofs. To be eligible as a totally enclosed facility, such tanks should be constructed so that the roof has a sliding seal on the side which is designed 173444 A" t 5 to :revent overflow. caseous emissions and protect against possible The part of the definition requi-ing that totally enclosed treatment facilities ts "directly connected to an industrial production process" also generates sore uncertainty. As lone as the process is integrally connected via pipe to the production process, there is no potential for the waste to be lost. The terra "industrial production process" was meant to include only those processes which produce a product, an intermediate, a byproduct, or a material which t's used back in the production process. Thus, a totally enclosed treatment operation, inte grally connected downstream from a wastewater treatment lagoon would not be eligible for the exemption because the process tc which it Is connected is not an "Industrial production process.* Neither would any totally enclosed treatment process at an off site hazardous waste management facility qual i fyy,, uni ess it vers integrally connected via pipeline to the generator's production process. Obviously, a waste transported by truck or rail is not integrally connected to the production process. Hazardous waste treatment is often conducted in a series of unit operation':, each connected by pipe to the other. As long as one end of a treatment train is integrally connected to a production process, and each unit operation is integrally con nected to the other, all qualify for the exemption if they meat the requirement of being "totally enclosed." If one unit opera tion is not "totally enclosed" or is not "integrally connected," UE'3-i 73445 ;*a then only unit cper .ions upstream ftot. that unit would qua fo*" the e xemp t i c r.. a permit. The unit and down street process would req re The device connecting the totally enclosed treatner.t facil ity to the generating process will normally be a pipe- However, some pipes (e.g.t sewers) are constructed with manholes, vents, sumps, and other openings. Pipeswith such openings may qualify as totally enclosed only if there is no potential for emissions or overflow of liquids during periods of process upset, or if equipment (sorption columns, catchment basisn, etc.) has been installed to prevent escape of hazardous waste or any potentially hazardous constituent thereof to the environment. This exemption for totalJy enclosed tr -tment facilities applies only to the facility itself. The effluent from .that facility may still be regulated. If the waste entering the totally enclosed treatment facility is listed in Subpart 0 of Part 251, then the effluent from the facility is automatically a hazardous waste and must be treated as such, unless it is "delisted" in accordance with 260.20 and 250.22. If, on the other hand, the waste entering the totally enclosed treatment facility is hazardous because it meets one of the characteris tics described in Subpart C of Part 261, then the effluent waste is a regulated hazardous west- only if the effluant meets one of the characteristics. Since the totally enclosed treat ment facility is exempted from the regulatory requirements, it is only the effluents from such p cesses which are of interest VEM-i73446 * / tc me Agency. Thus, wne:her the wa-st* in a totally snclosetf treatment facility must be considered towards the 1000 l.cj/month small quantity generator limit, depends on whether it is a regu lated hazardous waste as it exits the totally enclosed treatment faci1ity. Finally, it is important to note that if the effluents from a totally enclosed treatment facility are discharged to a surface water body (lake or stream) or to a publicly owned treatment works or sewer line connected thereto, then these wastes are not subject to the RCRA hazardous waste controls at all but are, instead, subject to the Clean Water Act and regu lations promulgated thereunder (See 45 FR 76075). III. Reso 1 ution: In sum-, a "totally enclosed treatment facil ity" must: (a) Be. completely contained on all sides. (b) Pose negligible potential for escape of constituents to the environment except through natural calamities or acts of sabotage or war. (c) Be connected directly by pipeline or similar totally enclosed device to an industrial production process which produces a product, byproduct, intermediate, or a material which* is used back In the procers. I?3t4? jbdtcc sJL---- ^ TRAVsJOL LABORATORIES. I\Z. r-*8.*f.*:d. iiirrij ?: July 7, 1531 "jtLWJj I'.L.CciVtO Mr. Alfred W. Lindsey Deputy Director Hazardous S industrial Waste Division (WK-pSS) U.S. environmental Protection Agency 401 M Street Washington, D.C. 20^50 JAi! 2 G 1SC4 Environmental Affairs RE: Totally Enclosed Hazardous Waste Treatment Facilities RCRA Hazardous Wda+e. Regulations Dear Mr. Lindsey: ,- Last spring I wrote to you requesting clarification o* regulatory re quirements, concerning Totally Enclosed Hazardous Waste Treatment Fac ilities (Refer to Attached Letter, dated March 3, 1231). To date we have not received any reply to our inquiry or. this aspect of the P.CRA Regulations. Please clarify U.S. EPA's position at your earliest convenience. Thank you for your assistance. REM/at Attachment Ronald E. Meissen, P.E. Senior Ervironrental Engineer F,/s. !?Gr /- / 45---. TR.".VN'DL LA3DR DRIES. INC March 3, ISS. Octree::. ix.isis s:r` Mr. Alfred W. Lindsey Deputy Director Hazardous & Industrial Waste Divison ( V*K-565) U.S. Environmental Protection Acancv 4 01 M Street Washington, D.C. 20450 HZ: Totally Enclosed Hazardous Waste Treatment Facilities Dear Mr. Lindsey: Travenol Laboratories, Inc. , a 1ac=e manufacturer of therapeutic radical care produ . has plants in the U.S. which generate, treat, or score hazardous waste. Per our telephc : conversation February 27, 1931, you informed me of the following: 1. If we have a Totally Enclosed Kr~ardous Waste Treatment Facility we are ccr.pl .ely exempt ^ from all P.CFA Peculations. 2. If the system is "Totally Enclosed*' we only have to check the final stream/ediluent to confirm it is not a hazardous waste. 3. Since we are exempted from P.CPA, any hazardous waste generated/treated in the system is not considered towards the 1000 kc/r.o limit. In late F ruary 1981, Mr. William Blackburn, an attorney with Trav^- .ol, s?cke with Dr. Dick Gardner, attorney for the U.S. EPA Office of General Counsel, concerning the above svoject. Mr. Gardner said the : hazardous wastes which are tre--ed in a totally enclosed treatment facility must be cov .ed in determining whether cr not a hazardous waste . .erator meets the 1000 kg. small generator exempt! Ee told Blackburn that the applicable regulatic * may 1. chanced in two months or so as a cor.sequ* -* of the recent negotiations which actress the pati .or* filed by the national Solid Waste Manaeemsr Association concerning the smell generator exemption. VEU-i73449 Kr.` Alfred vr. Lindsev VJarch 2, 1921 * Page 2 Mr. Gardner added that if we desired relief fra." -he current regulatory provisions prior to modification of the regulations, we would have to request it ir. a letter to hit. Because we have received different interpretaticrs nn this issu= we are confused- Please clarify U.S- EPA's position. Thanh you for your assistance. Sincerely, Ronald E. Meissen, P.2. Senior Environmental Engineer REM/1C (' bcc; D. Nurnherg - KK-C .S yEy-l73A50 COMPLIANCE MANUAL FOR HAZARDOUS WASTE HANDLING CONOCO CHEMICALS COMPANY BALTIMORE, MARYLAND JANUARY 6, 1981 Revised: January 1, 1984 TABLE OF CONTENTS Page INTRODUCTION ------------------- 1 GENERATOR REQUIREMENTS -------------- 3 TREATMENT FACILITY REQUIREMENTS --------- H APPENDIX: A. State Hazardous Waste Facility Permit B. EPA Hazardous Waste Facility Permit C. Annual Report Forms \73452 h c COMPLIANCE MANUAL FOR HAZARDOUS WASTE HANDLING CONOCO CHEMICALS COMPANY BALTIMORE, MARYLAND INTRODUCTION Hazardous waste activities at Conoco Chemicals' Baltimore Plant are controlled by the Federal Resource Conservation and Recovery Act (RCRA) and by the State of Maryland under the Waste Management and Enforcement Programs. The plant is currently under permit as a designated hazardous sub stance facility by the State of Maryland (see Appendix A) and has interim status as a hazardous substance generator, treatment, and storage facility through che RCRA program (see Appendix B). As required by the State permit, this Compliance Manual is designed to give a general understanding of the responsibili ties the Baltimore Plant has as a generator and treater of hazardous wastes. The requirements set by the State and Federal Governments, as well as procedures to be adhered to are out lined as follows; C 1- - VEU-173453 A I. GENERATOR Page A. Description of Wastes ----------- 3 B. Waste Material Manifesting -------- 4 C. Waste Material Packaging --------- 6 D. Accumulation of Waste ----------- 7 E. Recordkeeping --------------- 8 F. Annual Report --------------- 9 G. Exception Reporting ------------ -10 IX. TREATMENT FACILITY A. Description of Wastes -----------11 B. Waste Analysis --------------15 C. Operator Training -------------15 D. Inspection and Maintenance --------is E. Emergency (Contingency) Plan -------19 F. Security -----------------26 G. Annual Report ---------------27 e 2- - UEU-173454 A I. GENERATOR A. Description of Wastes In general, the hazardous waste streams generated by the Baltimore Plant are covered by two broad categories: corrosive waste and ignitable waste. A corrosive waste is defined as an aqueous waste with a pH less than or equal to 2.0 or greater than or equal to 12.5. An ignitable waste is a liquid having a flash point of less than 140P (60C). Most of the corrosive streams generated by the plant are product streams which are normally sold. These liquids include muriatic acid, spent sulfuric acid, spent caustic, and aluminum chloride liquor. If these materials cannot be sold due to quality or market, they are manifested and hauled away to licensed cor rosive hazardous waste disposal sites, with the exception of off-specification muriatic acid, which is neutralized on-site. The other hazardous wastes hauled from the plant will fall under the ignitable category -- these may include slop oil solids from the API separator and tank bottoms. These wastes and the above-mentioned wastes, plus any special cases, are to be handled through the plant's waste material manifesting system. -3- MEU-173455 B. Waste Material Manifesting A manifest system has been designed to initiate, approve, execute, and record the disposal of any designated hazardous waste from Conoco Chemicals' Baltimore Plant. This procedure is to be used only for those hazardous wastes which are removed from the plant site. A A The manifest specifications, as detailed by the Resource Conservation and Recovery Act of the EPA, are that it include the following: 1. A manifest document number. 2. The generator's name, mailing address, tele phone number, and EPA identification number. 3. The name and EPA identification number of each transporter. 4. The name, address, and EPA identification number of the designated disposal facility and an alternate facility, if any. 5. The proper shipping name and description of the waste, in accordance with Department of Transportation regulations. -4 - UEV-173456 6. The total quantity of each hazardous waste by units of weight or volume, and the type and number of containers loaded onto the transport vehicle. The manifest system for Conoco Chemicals' Baltimore Plant is designed around these requirements and includes: 1. An initiation procedure for hazardous waste hauling. 2. Sampling and lab verification of hazardous waste classification (by comparison with State and Federal hazardous waste classifications). 3. Plant approval of hazardous waste hauled, disposal sites, and waste transporters.' 4. A recordkeeping system including verification of receipt of waste by the disposal site. -5- MEV-173457 A C. Waste Material Packaging Any hazardous waste to be disposed of off-site is to be packaged, labeled as to its contents, and marked as a hazardous waste in accordance with the Department of Transportation regulations. Also, each container of 110 gallons or less is to be marked with the following statement:-- "HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U. S. Environ mental Protection Agency." Generator's Name and Address: Manifest Document Number: -6 - YEV-i73458 A C D. Accumulation of Waste Hazardous waste other than Slop Oil and Muriatic Acid may be accumulated on-site for less than 90 days provided that: The waste is placed in containers meeting the requirements of the Waste Material Packaging section of this manual. The date on which the waste began to be accumu lated is clearly marked on each container. The requirements of the Operator Training, C and Emergency (Contingency) Plan sections of this manual are met with respect to the stored waste. Slop Oil and Muriatic Acid may be stored on Plant for more than 90 days. C -1 VE0-Y73459 A C E. Recordkeeping The following records are to be maintained by the Director of Environmental Control, All records are to be retained for 3 years. 1. Lab analyses to determine the composition and classification of a hazardous waste disposed of outside the Baltimore Plant site. 2. Manifests of hazardous wastes disposed of off-site. C 3. Receipts confirming the delivery of a hazardous waste to a disposal facility. 4. Annual reports and exception reports. L 8- UEU-l73460 F. Annual Report An annual report for a generator of hazardous waste is to be submitted by March 1st of each year. This report is to be completed by the Director of Environ mental Control from records maintained during the year. The report consists of EPA forms 8700-13 and 8700-13A and is sent to the Maryland State Coordinator: Mr. Lou Martino -- MD Waste Management Administration 201 W. Preston Street Baltimore, MD 21201 383-5734 A copy of the annual report form is included in the Appendix. -9- YEY-173461 A G. Exception Reporting If a receipt from the hazardous waste disposal facility is not received within 35 calendar days of the date the material was accepted by the transporter, it is the Baltimore Plant's responsi bility to make inquiries. The transporter and/or the owner or operator of the disposal facility is to be contacted by the Director of Environmental Control to determine the status of the waste. An exception report is to be submitted by the Director of Environmental Control to (. Mr. Lou Martino for the State' Office of Environmental Programs (address given in Emergency Plan section) if a receipt from the hazardous waste disposal facility is not received within 45 days of the date the material was accepted by the transporter. The exception report consists of: A copy of the manifest for which the Baltimore Plant does not have confirmation of delivery. A cover letter explaining the efforts taken to locate the hazardous waste and the results of those efforts. C - 10 - VEU-173462 4 C II. TREATMENT FACILITY A. Description of Wastes The hazardous wastes treated by Conoco Chemicals at Baltimore are classified into two groups: corrosives and ignitable liquids. 1. CORROSIVE LIQUIDS -- The major corrosive liquid handled is off-specification muriatic acid. The normal treatment of this material is to neutralize it with limestone in a covered, con crete pit to a pH of 4-5 and discharge the re sulting calcium chloride and carbonic acid C solution to the inlet of the Baltimore Plant wastewater treatment facility for final treat ment prior to discharge to Baltimore's municipal sewer system. The plant wastewater facility uses caustic to adjust the pH of the combined wastewater and neutralized acid solution to 6-10, as required by Baltimore City's pretreat ment standards. L - 11 - gEy-173463 4 C 2. IGNITABLE LIQUIDS -- Process areas are curbed with collection boxes such that any oil leaks, overflows, etc., are contained by the process sewer for recovery at the wastewater treatment unit. This oil may contain suf ficient quantities of benzene and C].o"'Cl7 paraffins to be classifed as an ignitable material. Most of this oil is removed by the API separator and by oil skimming devices. The oil removed is collected in two tanks where entrained solids are allowed to settle before the oil is pumped to a large tank (T-248) for further C settling and storage. If the resulting slop oil is low enough in solids content it can be recycled to the process or burned as fuel. If the solids con tent is excessive, however, the slop oil is mani fested and hauled away to licensed flammable hazard ous waste disposal sites. A schematic diagram of the treatment process is given in Figure 1. A plot plan, showing the position of the wastewater treatment facilities in relation to the rest of the plant, is given in Figure 2. L - 12 - UEV-173464 C oc ro ----N tcD <0 I- A ' FLOW DIAGRAM OF WASTEWATER TREATMENT PLANT CONOCO CHEMICALS - BALTIMORE <u c NVc aVa *lVo. .if<_Oluj o*_> V>ou <n 4O-J <u -13- UEV-173445 --4 C L CONOCO CHEMICAOr BALTIMORE PLOT PLAN AND SwrfER LOCATION A C B. Waste Analysis No outside hazardous wastes are to be handled at Conoco Chemicals' Baltimore Plant. If any non-routine on-site hazardous wastes are to be treated, such as tank bottoms, a sample shall be sent to the lab, where a hazardous waste disposal form will be initiated. This form is to be sent to the Director of Environmental Control and the Process Superintendent for approval before disposal of the waste is begun. Operator Training The Operator whose responsibilities include the wastewater treatment facilities is to complete a training program covering the requirements for treating hazardous waste. This program is to in clude training in safety and emergency procedures, as well as on-the-job experience under a qualified Operator. The Operator is to be given an annual review of the initial training. Also, records documenting the completion of each operator's initial and review training are to be maintained by the Personnel Depart ment. L 15 UEV-173467 A D. Inspection and Maintenance The Operator is to periodically make rounds and record observations of the operating variables on a daily log sheet. These include: Acid Neutralization Basins, Wingwall, Outfall pH at wingwall and outfall temperature at outfall total flow at the outfall pressure at the blower suction, discharge, and the scrubber base (vent system of the neutralization basin). API Separator pH at the inlet pH at the first and second pH control pumps. The Operator also is to record observations on the daily log sheet as to the operation of equipment and levels of waste in tanks, including: Acid Neutralization Basins, Wingwall, Outfall need for addition of limestone to the neutralization basin level in the recovered oil tank at the wingwall. - 16 - YEV-173468 A API Separator flow back from overflow storage operation of the traveling bridge operation of the south & north roller skimmers tank dike valves closed oil level in each forebay level in the API oil sump level in the recovered oil storage tanks. The Operator is to note on the log sheet any problems with the operation of the equipment, pump or valve leaks, and general condition of the piping, tanks, acid neutralization basins, and API separator. He/she is tp initiate the necessary work orders for repairs and record on the log sheet when repairs are completed. The lab analyzes the pH of periodic wastewater samples from the inlet to the API separator, the pH control sump, the wingwall and the Patapsco River outfall. Also, if the wingwall or outfall pH meters read less than 6 or greater than 9, special samples are analyzed by the lab to check meter accuracy. Based on a comparison of lab data and the in situ meter readings, the pH probes are to be cleaned or calibrated if the meter readings differ significantly from the lab analyses. - 17 - MEM-l73469 4 Critical areas of the wastewater piping and tank system, as identified by records of past problems, are to be subjected to an on-stream inspection yearly. External thickness measurements are to be made on steel piping using a sound-wave tech nique. Visual inspection of non-metallic piping is to be done. At least one time per year each acid neutralization pit is taken out of service, cleaned out, and given a thorough inspection. A similar cleanout and inspection is provided for the API Separator every other year. Where there is identical equipment operating in parallel such, as the forebays and channels of the API separator, or back-up equipment, such as the acid neutralization pits, flow will be contained in one set of equipment while the other is inspected. The equipment will be cleaned, visually inspected, and repaired as needed. The Director of Environmental Control is to inform the Waste Management and Enforcement Programs office 5 days in advance of this inspection. For both of the above inspections, a report is to be written including the date of the inspection, the date the WMEP office was informed, the names of the inspec tors, the observations made, and repairs needed. Copies of the work orders resulting from the inspection are to be retained for 3 years. - 18 - Vey-l73470 A Files of all the information mentioned above are maintained, i.e., operator log sheets, outfall pH meter calibration and maintenance records, print outs from the outfall pH meter, inspection reports, and records of repairs resulting from the inspection. E. Emergency (Contingency) Plan It is the intention of Conoco Chemicals' Baltimore Plant to prevent spills and other emergencies through adherence to proper equipment maintenance and operat ing procedures. Therefore, this section of the Com pliance Manual is designed to inform plant personnel of practices for prevention of spills and to establish a procedure for responding quickly and effectively in the event of an emergency. The hazardous waste handling equipment has the follow- i ing design features to prevent and contain spills: ACID NEUTRALIZATION BASINS -- The plastic-lined concrete construction of the neutralization pits prevents seep age of muriatic acid into the surrounding area. The acid neutralization pit normally in service is covered and the vent gases scrubbed to reduce acid fumes. A back-up pit is available, although not covered at this time. In addition, supplies of limestone, which are ordinarily stored adjacent to the pits, will come in contact with and neutralize acid should an upset occur. - 19 - VEV-173471 4 API SEPARATOR -- A Parshall flume at the entrance to the concrete-constructed API separator is de signed so wastewater flows of greater than 800^1000 gpm overflow into sumps. These are then emptied into temporary storage facilities. The stored wastewater is returned to the separator at low flow periods. This feature guards against over loading the separator and insures that even during peak loading the separator capacity is not exceeded. The two channel separators operate in parallel so that one is not affected when the other is out of service. Also, the speed of the roll skimmer is variable in order to accommodate the volume of oil which reaches it. In the event of a power failure, a diesel-driven generator will supply electricity to instruments, lighting, and pumps for overflow service. The generator starts automatically after ten seconds without power. Instrumentation is provided to monitor levels, flows, pump discharge pressures, and pH at several points, such that upsets which may lead to spills can be diagnosed and corrected. 20 C C L A Containment of a spill on land is accomplished by a three-foot concrete dike with concrete floor surrounding the recovered oil treatment tanks.. Also# the area around the API separator is en closed by a one-foot concrete dike. If, for any reason, Conoco's Baltimore Plant does not comply with the provisions of the approved Compliance Manual or experiences a spill_of a designated hazardous substance, this is termed a non-compliance act. A spill of corrosive material occurs when a material with- a pH less than or equal to 2.0 or greater than or equal to 12.5 escapes its normal containment : facilities and moves into the environment. A reportable spill of oil as a hazardous waste occurs when more than 50 gallons of oil is released by one of the following means or if there is a chance that the oil will reach surface water. - 21 - gEU-173473 C c L A Oil is released from one of the recovery or storage tanks and overflows the concrete dike surrounding it. Oil overflows the API separator onto the ground. Oil bypasses the API separator and reaches the Patapsco River. NON-COMPLIANCE REPORTING -- Within 4 hours of becoming aware of the non-compliance, it must be reported by phone to the Enforcement Division of the Office of of Environmental Programs. This telephone call will satisfy the immediate nptification requirement for both a* hazardous waste and, if applicable, the NPDES permit. If an NPDES violation is involved both permits should be mentioned in the call. The telephone number is (301) 383-6650 (8:30 a.m. - 4:30 p.m., Monday Friday) or (30*1) 269-3181 (oil spills, evening and weekend), (301) 243-8700 (hazardous material spill, evening and weekend). The following information, for notification of a hazardous waste spill, must be provided in writing by the Director of Environmental Control within 5 days to: - 22 - UEU-173474 4 Mr. Lou Martino Waste Management and Enforcement Programs Office of Environmental Programs Department of Health and Mental Hygiene 201 West Preston Street Baltimore, Maryland 21201 (address as of 1/1/84) 1. Description of the non-compliance.. 2. Cause of the non-compliance. 3. Anticipated duration of the condition of non-compliance or, if such condition has been corrected, the actual duration of the non-compliance. 4. Steps taken or to be taken by the Conoco Baltimore Plant to bring ,the facility into compliance with the conditions of its permit. 5. Steps to be taken by the Conoco Baltimore Plant to prevent recurrence of the condition of non-compliance. 6. A description of the accelerated or additional monitoring by the Baltimore Plant to determine the impact of the non-compliance on the environ ment and public health. - 23 - MEM-i73475 A The same information, for notification of an NPDES violation, must be sent by the Director of Environmental Control within 5 days to: Mr.Paul Thompson Regional Chief Waste Management and Enforcement Programs 201 W. Preston Street Baltimore, MD 21201 (address as of 1/1/84) EMERGENCY REPORTING -- If a release, fire, or explosion occurs which could threaten human health, or the environment, outside the facility the Director of Environmental Control is to notify the National Response Center (using their 24-hour number: 800/424-8802). The call must include: 1. Name and telephone number of reporter. 2. Name and address of facility. 3. Time and type of incident. 4. Name and quantity of materials involved, to the extent known. 5. The extent of injuries, if any. 6. The possible hazards to human health, or to the environment, outside the facility. 24 ?34?6 A Before resuming operation of the affected area of the wastewater treatment facilities, the State Co ordinator {Lou Martino', 383-5734) is to be notified by the Director of Environmental Control that the equipment is clean and fit for use and the area clean up is completed. In addition, within 15 days after the incident, the Director of Environmental Control is to submit a written report to the State Co--ordinator-(Lou Martino). The report is to include: 1. Name, address, and telephone number of the facility owner (corporate). 2. Name, address, and telephone number of the facility. 3. Date, time, and type of incident. 4. Name and quantity of materials involved. 5. The extent of injuries, if any. 6. An assessment of actual or potential hazards to human health or the environment, where applicable. 7. Estimated quantity and state of recovered material that resulted from the incident. - 25 - gEV-173477 In the event of an oil spill, the Baltimore Plant's Oil Spill Containment and Clean-up Plan goes into effect. This plan includes designated action co-ordinators, a listing and description of equipment available, local authorities to be contacted, and an evacuation procedure to be used if necessary. A The Baltimore Plant also has a Fire and^Emergency Plan to be used if such an emergency should occur. The plan includes a list of emergency co-ordinators, specific duties to be performed by plant personnel, locations of emergency equipment, and local authori ties' to be contacted. F. Security Entry to the Baltimore Plant site is restricted to the front entrance where all visitors must sign in and out. Visitors are to be accompanied by a Conoco employee at all times. The perimeter of the plant is fenced except for the east end of the plant, which is bounded by the Patapsco River as a natural boundary. All Conoco employees are 26 ^7347 A C required to report any intruders to their im mediate supervisor. This is for the safety of the intruder unfamiliar with the plant, as well as the protection of the plant. Both hazardous waste treatment facilities, the API separator and the acid neutralization basin, are surrounded by posted warning signs. In addition, these areas are to be inspected regularly by the operator on his/her rounds. G. Annual Report c An annual report for a treatment facility for hazardous waste is to be submitted under the same conditions as those specified in the Annual Report section of the Generator requirements. Tine same EPA forms are used as a generator and as a treatment facility. L - 27 - UEU-i7347y