Solano County Department of Environmental Management Solano County Department of Environmental Management Environmental Health Services DivisionEnvironmental Health Services Division

Hazardous MaterialsHazardous Materials

Hazardous Materials Hazardous Materials Presented by Mr. Brad Nicolet, Senior Environmental Health SpecialistPresented by Mr. Brad Nicolet, Senior Environmental Health Specialist

IntroductionIntroduction

Regulatory Authority:Regulatory Authority:

California Health and Safety Code (HSC)California Health and Safety Code (HSC)

California Code of Regulations (CCR) Title 19, 22, 23, 27California Code of Regulations (CCR) Title 19, 22, 23, 27

Uniform Fire Code Article 80 Uniform Fire Code Article 80 (Business Plans & Inventories (Business Plans & Inventories only)only)

What We Do:What We Do:Six ProgramsSix Programs

Hazardous Materials MgmtHazardous Materials Mgmt CHS Ch. 6.95 ArticleCHS Ch. 6.95 Article 1 1

Plan and DisclosurePlan and Disclosure

Underground Storage TanksUnderground Storage Tanks CHS Ch. 6.7CHS Ch. 6.7

Hazardous WasteHazardous Waste CHS Ch. 6.5CHS Ch. 6.5

Risk Management ProgramRisk Management Program CHS CH. 6.95CHS CH. 6.95 Article 2Article 2

(Plan)(Plan)

Aboveground Storage TanksAboveground Storage Tanks CHS Ch. 6.67CHS Ch. 6.67

Business Plan & InventoriesBusiness Plan & Inventories UFC ArticleUFC Article 80 80

In Addition:In Addition:Emergency Response:Emergency Response:

Unk. Substance, derail, spills, NIHIT, etc.Unk. Substance, derail, spills, NIHIT, etc.

Complaints:Complaints:

Residential business/hobbyist, sick Residential business/hobbyist, sick BldgBldg

Prop 65 Reports:Prop 65 Reports:

Spills, releases, tank leaksSpills, releases, tank leaks

Catch-All: Catch-All:

Shell tanker spill, SP derail, Elmira Shell tanker spill, SP derail, Elmira Pipeline Leak. Contract with FF/SS Pipeline Leak. Contract with FF/SS Sewer District.Sewer District.

Certified Unified Program AgencyCertified Unified Program Agency“CUPA”“CUPA”

Implemented in 1996.Implemented in 1996.

Intent: Reduce the burden on business by Intent: Reduce the burden on business by eliminating multiple inspections and fees.eliminating multiple inspections and fees.

Consolidate six separate programs into single Consolidate six separate programs into single inspection, permit and fee.inspection, permit and fee.

Applies to incorporated and unincorporated areas.Applies to incorporated and unincorporated areas.

Hazardous Materials Release Hazardous Materials Release Response Plan and InventoryResponse Plan and Inventory““Community Right to Know”Community Right to Know”

HMMP Applies to “business” onlyHMMP Applies to “business” only

Threshold limits:Threshold limits:55 gallons, 500, pounds, 200 cu/ft55 gallons, 500, pounds, 200 cu/ft

Chemical Inventory, Spill/Fire Response and notification, Site Chemical Inventory, Spill/Fire Response and notification, Site MapMap

Hazardous Materials Communication Labeling, MSDS, Hazardous Materials Communication Labeling, MSDS, TrainingTraining

Underground Storage Tanks (UST)Underground Storage Tanks (UST)

Purpose is to protect groundwater Purpose is to protect groundwater from contamination through from contamination through prevention using secondary prevention using secondary containment and continuous containment and continuous monitoring systems / equipment.monitoring systems / equipment.

1.1. Installation of UST’s including plan Installation of UST’s including plan checks and construction inspectionschecks and construction inspections

2.2. Annual inspectionsAnnual inspections

3.3. Tank Removal inspectionsTank Removal inspections

UST Common Violations:UST Common Violations:

No leak monitoring / broken equipment No leak monitoring / broken equipment

No annual certification of monitoring No annual certification of monitoring equipment equipment

Failure to follow permit conditionsFailure to follow permit conditions

No approved UST monitoring/response No approved UST monitoring/response planplan

No proof of financial responsibilityNo proof of financial responsibility

UST ExcavationUST Excavation

UST Removal UST Removal

UST InstallationsUST Installations

Integrity Test Integrity Test

Equipment ChecksEquipment Checks

Under Dispenser ContainmentUnder Dispenser Containment

Construction InspectionConstruction Inspection

Waste vs. Hazardous WasteWaste vs. Hazardous Waste

These rules apply to everyone!These rules apply to everyone!Hazardous Waste determinationHazardous Waste determinationEPA ID NumbersEPA ID NumbersLabelingLabelingChemical Incompatibility IssuesChemical Incompatibility IssuesFacility Design SpecificationsFacility Design SpecificationsManagement: manifests, receipts, trainingManagement: manifests, receipts, trainingRisk Communication: alarms, spill kitRisk Communication: alarms, spill kit

Common ViolationsCommon Violations

Labeling, labeling, labelingLabeling, labeling, labelingContainers not closed or securedContainers not closed or securedWaste manifests not availableWaste manifests not availableNo waste determination / illegal disposalNo waste determination / illegal disposalNo weekly or daily inspectionsNo weekly or daily inspectionsContingency/Emergency Response Plans Contingency/Emergency Response Plans and employee training inadequateand employee training inadequate

Upper left shows proper label of back flush and boiler blow down drum. Upper left shows proper label of back flush and boiler blow down drum. Remaining photos show inadequate labeling of heat transfer oil tank, wastewater Remaining photos show inadequate labeling of heat transfer oil tank, wastewater

tank (WW1) and alkyd/resin product drums.tank (WW1) and alkyd/resin product drums.

Risk Management Prevention Risk Management Prevention Program (RMP)Program (RMP)

Acutely hazardous materials that exceed thresholds Acutely hazardous materials that exceed thresholds listed on three tables.listed on three tables.

Ex. Chlorine, Anhydrous AmmoniaEx. Chlorine, Anhydrous Ammonia

Review potential for offsite consequences of Review potential for offsite consequences of airborne releaseairborne release

Up to one year to three yUp to one year to three years to ears to completecomplete

Risk Management Prevention Risk Management Prevention Program (RMP) cont’nProgram (RMP) cont’n

Uses a professional team of experts to review Uses a professional team of experts to review processes, equipment, and trainingprocesses, equipment, and training

Assess worst case and reasonable loss Assess worst case and reasonable loss condition from accident, earthquake, sabotage, condition from accident, earthquake, sabotage, etc.etc.

Subjected to third party reviewSubjected to third party review

Public Participation Period (45 days)Public Participation Period (45 days)

Emergency ResponseEmergency Response

Technical assistance to other agencies such Technical assistance to other agencies such as, fire, police, and public worksas, fire, police, and public works

Activate “toxics” superfund cleanup for Activate “toxics” superfund cleanup for hazardous waste and illegal drug labs.hazardous waste and illegal drug labs.

Hazcat contract for emergency Hazardous Hazcat contract for emergency Hazardous Materials IdentificationMaterials Identification

Prop 65 notificationProp 65 notification

Additional Areas:Additional Areas:ComplaintsComplaints

Complaints of possible HAZMAT Complaints of possible HAZMAT violations are reviewed ASAP. Typical violations are reviewed ASAP. Typical examples and response:examples and response:

1.1. Disposal of Household Hazardous WastesDisposal of Household Hazardous Wastes

2.2. Neighbor violations: illegal disposal of waste Neighbor violations: illegal disposal of waste oil or antifreezeoil or antifreeze

3.3. Odors and Sick BuildingOdors and Sick Building

Aboveground Storage Tanks (AST’s) and Aboveground Storage Tanks (AST’s) and Article 80, Uniform Fire CodeArticle 80, Uniform Fire Code

Petroleum threat to navigable waters (AST)Petroleum threat to navigable waters (AST)

Spill Prevention and countermeasure and control Spill Prevention and countermeasure and control plans (SPCC) (AST)plans (SPCC) (AST)

Article 80 Section 8001.3 duplicates HMBP in the Article 80 Section 8001.3 duplicates HMBP in the Fire Code and calls the document HMMPFire Code and calls the document HMMP