R E G U L A TIONS AND MANAGEMENT PROCEDURES … · 2016-08-05 · Byron Station Havana Coal Dock...

I. INTRODUCTION J. A. Freitag Environmental Affairs

II. REGULATIONS AFFECTING WASTE OIL DISPOSAL J. A. Freitag Environmental Affairs

A. Special Wastes/Hazardous Wastes

B. Problems with Mixtures of Waste Oil And Chlorinated Solvents

III. WASTE OIL MANAGEMENT PROCEDURES F. M. Nemes Environmental Affairs

A. Segregating Waste Oil and Chlorinated Solvents

B. Disposal of Waste Oil with Greater Than 1000 ppm Chlorine

C. Disposal of Waste Oil with Less Than 1000 ppm Chlorine

IV. CLOR-D-TECT DEMONSTRATION F. M. NemesEnvironmental AffairsH. Brooks/ Wm. E. Phillips, Inc. and Dexsil Corp.

V. ADJOURN

Reprinted with permission of Commonwealth Edison Chicago, ILL. 60690-0767J. A. Freitag, Environmental Affairs, F. M. Nemes, Environmental Affairs

R E G U L ATIONS AND MANAGEMENT PROCEDURES FOR WASTE OIL DISPOSALCommonwealth Edison, Chicago, Ill.

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DEXSIL CORPORATION www.dexsil.comOne Hamden Park Drive • Hamden, Connecticut, 06517 • Phone 800.433.9745 • Fax 203.248.6523 • Email [email protected]

WASTE OIL SEMINAR AND CLOR-D-TECT DEMONSTRAT I O N

June 7, 1989

D. H. Richardson (G.O. Ext. 4438)

Zion

Byron

Briadwood

Dresden

LaSalle

Quad Cities

F. M. Nemes (G.O. Ext. 4441)S. Pulido (G.O. Ext. 4453)

State Line

Joliet 9

Joliet 29

Kincaid

Collins

Powerton

Waukegan

Will County

Crawford

Fisk

Western Division

Northern Division

Production Training Center

Rock River Division

Chicago North

Chicago South

Sangamon Garage

Edison Building

Villa Park Garage

Southern Division

J. A. Freitag (G.O. Ext. 3016)

Technical Center

General Warehouse

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ATTACHMENT 1

Environmental Affairs Contact Personnel

SOLID WASTE AND TOXICS GROUPDisposal Area Contact: J. A. Freitag (G.O. Ext. 3016)

Individual Facility Contacts:

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Waste oil which has had chlorinated solvent inadver-tently mixed with it is considered a hazardous wasteby definition. Waste oil recyclers will not collect oilthat is contaminated with 1000 ppm or greateramounts of chlorinated solvents. This concentration isequivalent to about cup of solvent* in a 55-gallondrum. However, certain waste oil vendors will takewaste oil with up to 5% (by weight) (50,000 ppm)chlorine when they are provided with specific conta-mination documentation. The revenue received by theCompany from this oil with the higher chlorine con-centration is approximately one half the revenuereceived from non-contaminated waste oil. Waste oilwith greater than 50,000 ppm of chlorine contamina-

tion must be disposed of by incineration. Collectionand disposal fees that Edison must pay for incinera-tion of such waste oil are quite high and currentlyrange from $1.70 to $2.00 per gallon.

The attached procedure, which is based firstly on reg-ulatory concerns and secondarily on economic incen-tives, is to be used as a guideline for managing wasteoil and solvent mixtures.

* P a rtial list of chlorinated solvents: 1,1,1-t r i c h l o roethane, dichloroethylene, chloro o c t a d e c a n e ,t r i c h l o robenzene, methylene chloride, per-o c h l o roethylene, freon 113, monochloro b e n z e n e ,PCB, and barc o t h a n e .


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This procedure is for the following CommonwealthEdison locations:

Collins Station LaSalle County Station

Crawford Station Quad Cities Station

Fisk Station Zion Station

Joliet 9 Station Bloom Peaker

Joliet 29 Station Dixon-Hydro

Kincaid Station Sabrooke Peaker

Powerton Station Electric Junction Peaker

State Line Station Lombard Peaker

Waukegan Station Calumet Peaker

Will County Station General Warehouse

Braidwood Station Technical Center Shops

Byron Station Havana Coal Dock

All Division General Office Production Locations Training Center

1. Provide a designated drum(s) for collection of sol-vent only. Labels which read “Waste Solvents Only”can be obtained from Environmental Affairs.

2. Do not mix waste solvents in the designated wasteoil drums or the waste oil storage tank. Labelswhich read “Waste Oil Only” can be obtained fromEnvironmental Affairs.

3. Keep waste solvents segregated from the waste oil.

4. To schedule a pickup of your waste oil, contact theInvestment Recovery Department at the GeneralWarehouse at Extension 303.

MANAGEMENT OF WASTE OIL AND WASTE OIL SUSPECTED OF BEINGCONTAMINATED WITH CHLORINATED (HALOGENATED) SOLVENTSEnvironmental/Regulatory Concerns

ATTACHMENT

PROCEDURE FOR MANAGEMENT OF WASTE OIL AND WASTE OIL SUSPECTED OF BEING CONTAMINATED WITH CHLORINATED SOLVENTS

5. To arrange for disposal of your waste solvent,contact Environmental Affairs and follow the pro-c e d u re for “Disposal of Drummed Chlorinatedand Non-Chlorinated Solvent Waste” datedDecember 18, 1987.

6. If waste solvents are inadvertently mixed with yourwaste oil, you must run a “screening” test prior toarranging a waste oil pickup. The waste oil vendorwill return any waste oil which has been contami-nated to greater than 1000 ppm with chlorine.

SCREENING TEST INSTRUCTIONS:

A.Take a representative sample of your waste oil.Waste oil and solvents will tend to separate intolayers. Be sure to collect oil through the entirevertical column of the storage container asdescribed in more detail in the attached sam-pling procedure (Appendix I).

B. Use the CLOR-D-TECT field screening test kitto perf o rm the analysis. These kits are avail-able as a Stores Item No. 134145. Follow thed i rections provided with the kit. The re s u l t sf rom this screening test will indicate whetheryour sample contains more or less than 1000ppm chlorine.

7. If your screening test shows that the waste oil hasless than 1000 ppm chlorine, then you may pro-ceed with arranging a waste oil pickup through theInvestment Recovery Department as previouslydescribed in Item 4 of this attachment.

8. If your screening test shows that the waste oil hasgreater than 1000 ppm chlorine, then contact yourEnvironmental Affairs representative listed inAppendix II for guidance on determining an appro-priate disposal method.

9 . E n v i ronmental Affairs will provide assistance inmaking arrangements for disposal of waste oil cont-aminated with chlorine. Your facility will be re s p o n-sible for perf o rming the following, as necessary :

•Obtain a representative sample

•Arrange for delivery of sample to appropriatelaboratory for analysis, as determined byEnvironmental Affairs

• Provide a function number or small purchaseorder for payment of laboratory fees

• Provide security for the waste

• Provide weekly visual inspections of the waste to assure that there are no leaks.

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The Clor-D-Tect 1000 kit was developed by DexsilCorporation in response to the EPA decision to regu-late the chlorine content in waste oils. Research waspartially sponsored by EPA Region II.

The result of this program is a simple, reliable anddefinitive kit that can be used in the field by non-technical personnel.

The kit is designed to permit collectors of used orwaste oil for reprocessing or disposal to test for conta-mination in a generator’s oil before picking up theload. The kit can also be used by enforcement author-ities to spot-check suspected materials as they arebeing generated, transported or sold.

In an EPA study it was reported: “The kit (Clor-D-Tect1000) can probably be used as a screening kitthroughout the used oil industry, from the generatorto the recycler to the transporter and burner. There

are few false positives and negatives and minimalmatrix effects. The kit is simple to use. One does notneed to understand the chemical reactions that occurto obtain accurate results. A complete test requiresapproximately 15 minutes to complete. The greatestutilities for their regulation are the portability andaffordability of the kit”.1

1 A. Gaskill, Jr., E.D. Estes, D.L. Hardison, Evaluationof Methods for Determining Chlorine in Used Oils.Final Report, EPA Contract No. 68-01-7075, WorkAssignment No. 51, US EPA, Office of Solid Waste,August 1986

*CLOR-D-TECT Kit information from DexsilCorporation product brochure.

**For Kit users, CLOR-D-TECT color literature isavailable by contacting the Environmental AffairsDepartment.

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APPENDIX I

CLOR-D-TECT KIT SAMPLING METHOD* AND OTHER GENERAL INFORMATION ABOUT THE KIT**

INTRODUCTION

ABOUT THE KIT

STEP #1

Assemble capillary-syringe sam-

pler by inserting glass capillary

about 1⁄ 8" into the plastic tub-

ing at end of syringe. Insert

bottom of glass capillary into

oil sample.

STEP #2

Using the syringe, slowly draw

oil up the glass capillary until it

reaches the flexible tubing.

Wipe off glass capillary with

the supplied tissue.

STEP #3

Unscrew white dispenser cap

and put capillary inside tube.

Bend tubing to release capil-

lary. Crush capillary by squeez-

ing bottom of tube several

times, being careful not to

break reagent ampules.

STEP #4

Break the lower (colorless)

ampule in the tube by com-

pressing the sides of the tube.

Mix thoroughly by shaking the

tube vigorously for about 30

seconds. Break top (gray)

ampule in the tube and shake

thoroughly for about 20 sec-

onds. Allow reaction to proceed

for one minute, shaking intermit-

tently several times.

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SAMPLING PROCEDURESTEP-BY-STEP DIRECTIONS

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STEP #5

Remove the caps from both tubes

and pour the clear buffer solution

from Tube #2 (with yellow cap)

into Tube #1. Replace the white

cap tightly on Tube #1, and shake

vigorously for 10 seconds. Vent

the tube by partially unscrewing

the dispenser cap. Close securely

and shake well for an additional

10 seconds. Vent tube again, tight-

en cap and stand tube upside-

down on its cap. Allow the phases

to separate for two minutes.

STEP #6

After layers have separated, put

filtration funnel in Tube #2. Open

nozzle of white cap and dispense

5 ml of the buffer solution through

funnel and up to the line in the yel-

low capped tube. Replace cap

and then break lower (colorless)

ampule and shake for 10 seconds;

then break top (colored) ampule

and shake for 10 seconds and

observe color.

STEP #7

Observe color immediately. If the

solution appears purple, the oil

sample contains less than 1000

ppm chlorine. If it appears yellow

or colorless, the sample contains

more than 1000 ppm chlorine.

• Wear rubber gloves and safety glasses.

• When assembling capillary-syringesampler insert the glass capillaryapproximately 1⁄8" into plastic tub-ing, making for easy removal inStep 2A.

• When crushing glass ampules,press firmly in the center of theampule once. Never attempt torecrush broken glass in the testtube since glass may sever theplastic and cut fingers.

• In case of accidental breakage ontoskin or clothing wash with largeamounts of water. All the ampulesare poisonous and should not betaken internally.

• The kit works well on all types ofused and waste oils includingcrankcase, hydraulic, diesel, lubri-cating, fuel oils and kerosene.

• In step #6, observe the colorimmediately and compare to thechart. The purple color may fadeout over time.

• Perform the test in a warm, dryarea with adequate light. In coldweather, a truck cab is sufficient.

• The numbers assigned to the purplecolors are for approximation only.

• The test works on the principle ofchloride detection, therefore, cont-amination by salt (sodium chlo-ride), sea water, perspiration, etc.,may give a false positive result.

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SUGGESTIONS FOR USING THE CLOR-D-TECT KIT

When crushing glass capillary, squeezeonly at the bottom of the tube whiletapping the glass down, being carefulnot to break the glass ampule.

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• When taking oil samples with the syringesampler slowly draw the oil up to the rub-ber tubing then wipe off the capillary anddisconnect it into Tube #1.

• Be sure that your oil sample is uniform andrepresentative of the whole lot.

• The kit should be examined upon openingto see that all the components are presentand that all ampules (two in each tube) arein place and not leaking. The liquid in theyellow-capped tube should be approximate-ly 1⁄ 2"-inch above the 5 ml line inscribed onthe tube and the tube should not be leak-ing. The ampules are not supposed to becompletely full.

• The Clor-D-Tect test will not work on asample that contains more than 30% water.If, in step 2, the tube loses its gray color,the sample contains water and the testshould not be run.

• Dispose of kits properly.

• With samples that contain water, theremay be a small pre s s u re build-up in tube1; simply vent the tube by unscrewing thecap 1⁄ 2 t u rn .

• Freezing of the buffer solution does notdamage the kit, but the solution should becompletely melted before running the test.

• Remember that the kit is designed for useon many types of used oil. It may work onother fluids; contact Dexsil before using thekit in other applications.

Before using a kit, make sure that theexpiration date has not passed.

ENVIRONMENTAL/REGULATORY CONCERNS

Spent solvents, both chlorinated (such as 1,1,1-trichloroethane, barcothane, freon and non-chlorinat-ed* (mineral spirits), are considered hazardous waste.As such, disposal of these spent materials must meetthe following specific requirements:

1 . Mixing waste solvents with any liquid orsolid waste renders the entire mixture a haz-a rdous waste.

2. Landfilling of liquid hazardous waste is banned.

3.Drummed waste chlorinated solvents must bedisposed of by incineration.

4. Drummed nonchlorinated waste solvent may berecycled instead of incinerated depending on acase-by-case review performed byEnvironmental Affairs Department.

Based on these concerns, the attached procedures areprovided for handling waste solvents and mixtures ofwaste solvents.

DISTINCTION BETWEEN DRUMMED SOLVENTWASTE AND SAFETY-KLEEN SOLVENT WASTE

The attached instructions are for drummed chlorinat-ed/non-chlorinated solvent waste. They are not forsolvent waste accumulated in barrels integrally associ-ated with Safety-Kleen solvent parts washers.Instructions regarding disposal of the latter, whichinvolves only manifesting and/or recordkeeping, have

previously been sent to those Commonwealth Edisonlocations that use the Safety-Kleen parts washer ser-vice. If you require a copy, please contact your EADSolid Waste & Toxics Group Contact (Figure 2).

The principal reason that an additional solvent dis-posal method is required is that Safety-Kleen will onlyrecycle their own non-chlorinated solvent waste.Since a number of our facilities use a variety of chlori-nated solvent suppliers, there is a need to dispose ofthis waste separately from Safety-Kleen solvent.However, if an Edison facility decides to use only nonchlorinated solvents, it is advised that they considerthe Safety-Kleen solvent (or similar vendor) option toreduce disposal costs and associated liabilities associ-ated with chlorinated solvent waste disposal.

ECONOMIC CONSIDERATIONS

Disposal costs are continuing to increase. The chargefor incineration of one drum of non-chlorinated sol-vent waste is approximately $170 to $200 whereasthe charge for incineration of one drum of chlorinatedsolvent is approximately $275. Analytical, permittingand transportation costs are additional.

These costs are expensive. However, in choosing theincineration option, Commonwealth Edison’’ liabilityrisk in case the waste is mismanaged by some otherdisposal option is greatly reduced. In addition to theregulatory requirements listed above, the associatedliability concerns are economic incentives to managewaste solvent properly.

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Revised 1/88Replaces Procedure Dated 9/23/85 and 1/28/86

DISPOSAL OF DRUMMED CHLORINATED AND/OR NON-CHLORINATED SOLVENT WASTE

*With flashpoint of less 140°F or 60°C (check your MSD sheet).

This procedure is for the following CommonwealthEdison locations:

Collins Station LaSalle County Station

Crawford Station Quad Cities Station

Fisk Station Zion Station

Joliet 9 Station Bloom Peaker

Joliet 29 Station Dixon-Hydro

Kincaid Station Seabrooke Peaker

Powerton Station Electric Junction Peaker

State Line Station Lombard Peaker

Waukegan Station Calumet Peaker

Will County Station General Warehouse

Braidwood Station Technical Center Shops

Byron Station Havana Coal Dock

All Division Locations General Office Production Training Center

1. Waste solvent liquids must not be mixed withwaste oil. Every effort must be made to preventaccidental mixing of solvents with waste oils.

2. Waste solvent liquids must not be contaminatedwith PCB oil, nor with any other liquid wasteincluding water.

3. Waste solvent must be placed into a non-leaking55 gallon drum, with either a non-removable orremovable lid. The lid must be equipped with abung hole for sampling purposes.

Generators of hazardous waste are allowed tos t o re wastes on-0site only for specified periods oftime, after which they must be removed. To storeor accumulate larger quantities of hazard o u swastes places the facility into a higher level of

re q u i red re c o rdkeeping. The following items (4t h rough 7) detail storage/accumulation re q u i re-ments in such a way as to minimize the impactof this additional regulation on each facility.

4.When one (1) 55-gallon drum is full, place ahazardous waste label on the drum side and fillin all of the information required on the labelexcept the Manifest Document Number. TheDate of Generation/Accumulation should befilled in with the date when the drum was com-pletely filled. Refer to Figure 1, Example of“Hazardous Waste Label.”

When subsequent drums are filled, label themexactly as above, using the actual date thosedrums were filled. Each drum must now beremoved off-site within 90 days from the datethat the drum became filled.

5. A reas where drums are stored must be inspect-ed weekly to assure that no drums are leaking.The IEPA re q u i res that a written re c o rd be keptto document these inspections. A “Hazard o u sWaste Container Inspection Weekly Check-OffLog” as provided in Figure 3 to re c o rd pert i-nent information and document these weeklyinspections. The re c o rds of your weeklyinspections must be readily accessible toE n v i ronmental Affairs and to the IEPA duringcompliance re v i e w s .

6. When a facility re q u i res removal/disposal ofd rummed solvent waste, call your Enviro n m e n t a lA ffairs Department contact for assistance. A listof EAD Contracts is provided in Figure 2. Bep re p a red to state the number of drums involved,the location of the drums, and the contents, i.e.,chlorinated, non-chlorinated, or mixture of sol-vents in the drums. A Material Safety Data Sheet(MSDS) should also be pro v i d e d .

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ATTACHMENT I

PROCEDURE FOR DISPOSAL OF DRUMMED CHLORINATED AND/OR NON-CHLORINATED SOLVENT WASTE

7. Environmental Affairs Department will contactthe waste broker on your behalf. EnvironmentalAffairs Department and the broker will consultregarding all regulatory matters, however, yourfacility will be invoiced for the various technicalservices performed. Services performed mayinclude the following, if necessary, if required bythe disposal contractor and at the direction ofEnvironmental Affairs:

Waste Sampling and Analysis

Waste inventory

Waste transfer from bad to good drums

Overpack of leaking drums

Preparation of regulatory and disposal site documentation

Preparation of manifest and additional labels

Pick-up of waste

Transportation of waste to disposal facility

8. Your facility will be responsible for performingthe following:

Provide vendor access to sample and inventory waste

Provide security for the waste

9. E n v i ronmental Affairs will inform your facility ofthe date when the waste is scheduled to be pickedup. The waste broker will present a completedmanifest which re q u i res your signature. Route themanifest according to the Pro c e d u re at right.

Manifest Routing Instructions (6 copies per manifest form)(1 form per shipment)

Copies 1 through 4 are given to the hauler.

Copy 5 (green) must be mailed by theCommonwealth Edison Facility to the IEPA(address is listed on the manifest) Withintwo working days.

Copy 6 (yellow) is to be retained on file byyour facility.

Copy 1 (white) should be returned to thefacility by the ultimate disposal site withinone month. If this does not happen, contactthe disposal facility and request that themanifest be sent to you. If Copy 1 has notbeen received within 45 days of the datewhen the waste was picked-up, then con-tact your Environmental Affairs representa-tive who must prepare a letter of explana-tion to the IEPA.

Copies 1 and 6 should be compared for dis-c repancies. Contact Environmental Affairs forassistance if there are discre p a n c i e s .

A photocopy should then be made of copy1 and sent to Environmental Affairs formaintenance in the manifest database. Yourfacility must keep copies 1 and 6 on file.This file must be readily accessible toEnvironmental Affairs and IEPA personnelfor inspection purposes.

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Generators name – Provide station/facility name, i.e., LaSalle Station

Address – Provide mailing address of facility

Manifest Document Number – This number is obtained from actual manifest to be used toship this drum. That number is a red pre-printed number in the upper right hand portion of themanifest. Put that number on each drum(s) label to be shipped.

EPA ID# – Provide USEPA Generator ID # for your facility.

EPA/DOT Shipping Name – Provide proper EPA/DOT shipping name, i.e., Waste FlammableLiquid N.O.S., flammable liquid, UN1993

Date of Generation/Accumulation – Provide date when drum is filled and ready for disposal.

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FIGURE IHAZARDOUS WASTE LABEL

HAZARDOUS WASTE CONTAINER INSPECTION WEEKLY CHECK-OFF LOG

Hazardous Waste Container(s) Location ________________________

Week of ________________________ Through __________________

Date ___________________________ Name ____________________

For storage/accumulation of hazardous waste designated for off-site disposal.

1. Storage Area Location ________________________

2. Number of Solvent Containers at This Location ________________________

3. Waste Name _________________________

4. Volume of Container (gallons) _________________________

5. What Fraction of Container is Full _________________________

6. Container Labeled Hazardous Waste? Yes _________ No _________*

7. Accumulation Start Date Marked? Yes _________ No _________**

8. Container in Good Condition? Yes _________ No _________*

9. Container Leaking? Yes _________* No _________

10. Container Completely Closed? Yes _________ No _________*

11. Has the waste been stored for 75 days or more? Yes _________* No _________

*Report immediately to Regulatory Compliance Coordinator or appropriate individual.

**Put the date when the drum is completely filled.

NOTE: Containers must not be handled or stored in a manner which may ru p t u re the container or cause it to leak. Report any such occurring conditions to the RegulatoryCompliance Coord i n a t o r.

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FIGURE 3

2 6 6 7 e / J A F : p p

R E G U L A TIONS AND MANAGEMENT PROCEDURES … · 2016-08-05 · Byron Station Havana Coal Dock...

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