United States
Environmental Protection
Agency
Research and Development
in<1ustr,al Environmental
Laboratory
Cincinnati OH 45268
NPDES Best
Management
Practices Guidance
Document
RECEIVED
2 71986
"OP PROCESS
-------
EPA-eoo/9-79-045
3c?vflto Dsartora, StT39t December 1979
NPDES
BEST MANAGEMENT PRACTICES
GUIDANCE DOCUMENT
by
J. G. Cleary
0. D. Ivins
G. J. Kehrberger
C. P. Ryan
C. W. Stuewe
HYDROSCIENCE, INC.
Knoxville, Tennessee 37919
Contract No. 68-03-2568
Project Officers:
Alfred B. Craig, Jr.
Industrial Pollution Control Division
Industrial Environmental Research Laboratory
Cincinnati, Ohio 45268
Harry M. Thron, Jr.
Permits Division, Office of Water Enforcement
Washington, D.C. 20460
INDUSTRIAL ENVIRONMENTAL RESEARCH LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
U.S. Environment! Protection Agency.
Reclcn V, Li'::;-£r-
230 South Dc-,-:,:;rn Hrcst
Chicago, UliAoU 6Q5QA
-------
DISCLAIMER
This report has been reviewed by the Industrial Environmental Research
Laboratory, U.S. Environmental Protection Agency, and approved for publi-
cation. Approval does not signify that the contents necessarily reflect
the views and policies of the U.S. Environmental Protection Agency, nor
does mention of trade names or commercial products constitute endorsement
or recommendation for use.
. Environmental Protection Agency
-------
FOREWORD
When energy and material resources are extracted, processed, converted, and
used, the related pollutional impacts on our environment and even on our
health often require that new and increasingly more efficient pollution
control methods be used. The Industrial Environmental Research Labora-
tory Cincinnati (lERL-Ci) assists in developing and demonstrating new and
improved methodologies that will meet these needs both efficiently and
economically.
This document presents the results from a study of the best management
practices used in industry to prevent or minimize the release of toxic and
hazardous substances to the surface waters. Guidance in this document
should prove useful to industry in complying with NPDES requirements and to
regulatory agencies in administering the NPDES program. For further infor-
mation, please contact the Metals and Inorganic Chemicals Branch in
Cincinnati.
David G. Stephan
Director
Industrial Environmental Research Laboratory
Cincinnati
111
-------
ABSTRACT
This guidance document was developed for the EPA for use in providing guid-
ance to NPDES permitting authorities for evaluation of a best management
practice (BMP) program for industry. BMPs are required under the 1977 Clean
Water Act for the control of discharge of toxic and hazardous substances
from industrial plant site runoff, spillage and leaks, sludge and waste dis-
posal, and drainage from raw-material storage areas to receiving waters.
This document provides a basis for reviewing and evaluating BMP programs,
for prescribing BMP alternatives to upgrade BMP programs, and for recommend-
ing additional BMPs where necessary. Its use requires engineering experi-
ence and knowledge of industrial operations and of the BMP alternatives, as
well as of the applicable current laws and regulations. The criteria that
should be considered in the decision-making process relative to accepting a
program or recommending revisions to a program are reviewed. Final recom-
mendations on the acceptability of a BMP program or the prescribing of BMP
alternatives based on the evaluation of a specific situation requires engi-
neering judgment and experience.
The guidance in this document has been developed based on a review of cur-
rent practices used by industry to prevent the release of toxic and hazard-
ous substances to receiving waters. Included in the review were published
articles and reports, technical bulletins on specific compounds, and discus-
sions with industry through telephone contacts, written questionnaires, and
site visits. This available information on current BMPs was evaluated, and
BMPs were grouped into general categories of base line and advanced. BMPs
were related to pollutant sources (ancillary sources) and physical and chem-
ical properties of the compounds. A classification scheme was developed for
the toxic and hazardous substances, based on important physical and chemical
properties relevant to identification of applicable BMP alternatives. A
method of identifying applicable BMPs based on chemical and source is pre-
sented.
An approach was developed to assist the document user in evaluating a BMP
program and prescribing BMP alternatives. The review format involves an
examination of a BMP program to assess compliance with regulations and to
assess effectiveness of both base-line and advanced BMPs for prevention of
significant discharges of toxic and hazardous substances to receiving
waters. Methodology is presented for evaluation of the impact on the water
quality of a release of material to several types of receiving water bodies.
This report was submitted by Hydroscience, Inc., in fulfillment of Contract
68-03-2568 under the sponsorship of the U.S. Environmental Protection
Agency. This report covers the period June 13, 1978, to February 26, 1979.
iv
-------
ACKNOWLEDGMENT
The authors wish to acknowledge those who gave so generously of their time
during the compilation of this document. In particular, the helpful sugges-
tions of the following individuals are greatly appreciated: Thomas Charlton
of the EPA-Office of Water Enforcement, Oil and Special Material Control Di-
vision, Washington; and Ira Wilder, John Brugger, and Joseph Lafornara, EPA-
ORD, IERL, Oil and Hazardous Materials Spills Branch, Edison, New Jersey.
Our appreciation is also extended to the American Paper Institute, Manufac-
turing Chemists Association, National Council of the Paper Industry for Air
and Stream Improvement, and National Forest Products Association for their
cooperation and assistance. In particular we acknowledge the considerable
contribution made by Howard Schwartzman, Chairman of the NPDES Task Force of
the MCA.
We gratefully acknowledge the following companies who contributed to this
study:
Allied Chemical Co.
Celanese Fibers Co.
E. I. du Pont de Nemours & Co.
Hooker Chemicals and Plastics Corp.
Procter and Gamble Co.
Shell Chemical Co.
Stauffer Chemical Co.
Union Carbide Corp.
v
-------
CONTENTS
Page
Foreword iii
Abstract iv
Acknowledgment v
Figures and Tables viii
1. Introduction 1
Background 1
Applicable laws and regulations 1
Study purpose and methodology 2
2. Conclusions and Recommendations 4
Conclusions 4
Recommendations 4
3. Best Management Practices 7
Ancillary sources 7
Definition of BMPs 8
Data base 8
Base-line best management practices 9
Advanced best management practices 20
4. Classification of Toxic and Hazardous Substances 41
Introduction 41
Chemical group definitions 42
Classifications 46
5. Methods for Evaluating BMP Programs and Prescribing BMP
Alternatives 56
Evaluation of a BMP program 56
Prescribing BMP alternatives 75
Appendices
Appendix A. Literature Surveyed and Industrial Contacts Made . . 90
Appendix B. BMP Keyword Summary 105
Appendix C. BMPs for Specific Toxic and Hazardous Chemicals . . 107
Appendix D. Summary of Industrial Survey 115
Appendix E. Analytical Mathematical Solutions 164
Glossary 167
FIGURES
Number
1 Decision Tree for BMP Program Evaluation 58
2 Spatial Concentration 81
3 Temporal Concentration Distribution at Various Distances . . 82
4 Example of Toxicity Data 86
5 Example of Calculating Percent Survival 88
vii
-------
TABLES
Number Pa
1 Advanced-BMP Alternatives 21
2 Chemical Group Classifications 43
3 Liquid Group Classification 47
4 Solids Group Classification 50
5 Gases Group Classification 55
6 Questions and Decision Aids Relative to Decision Tree Shown in
Fig. 1 59
7 Minimum Requirements of a BMP Program 60
8 Advanced-BMP Alternatives 67
9 Example 1 69
10 Example 2 70
Vlll
-------
SECTION 1
INTRODUCTION
BACKGROUND
This study was undertaken to provide the National Pollutant Discharge Elimi-
nation System (NPDES) permitting authorities with a protocol for evaluating
the best management practice(s) [BMP(s)] for industry in controlling dis-
charges of toxic and hazardous substances to receiving waters. Under Section
304(e) of the 1977 Clean Water Act (the Act), the Administrator may publish .
regulations to control the discharge of toxic or "priority pollutants" (149)*
and hazardous pollutants (20) from the following sources: plant- site run-
off, spillage or leaks, sludge or waste disposal, and drainage from raw-
material storage areas. Best management practices are the most practical and
effective measures or combinations of measures which, when applied to an
industrial activity, will prevent or minimize the potential for release of
toxic and hazardous pollutants in significant amounts to surface waters from
the sources cited above. These potential sources of toxic and hazardous pol-
lutants are defined as those associated with or ancillary to the industrial
manufacturing or treatment process that may contribute significant amounts of
such pollutants to navigable waters.
APPLICABLE LAWS AND REGULATIONS
Pursuant to Section 311 of the Act, the Environmental Protection Agency has
proposed (40 CFR Part 151) requirements for spill prevention control and
countermeasure (SPCC) plans to prevent discharges of hazardous substances
from facilities subject to NPDES permitting requirements. The guidelines
proposed for SPCC are very similar to those developed and used in the oil
prevention regulation, 40 CFR, Part 112.
Criteria and standards for imposing BMPs for ancillary industrial activities
pursuant to Section 402 of the Act (40 CFR, Part 125, Subpart K) revise the
existing regulations governing the NPDES in order to reflect new controls on
toxic and hazardous pollutants under the Act. The proposed regulation in-
dicates how BMPs for on-site industrial activities may be imposed in NPDES
*See Appendix A for references indicated by numbers in parentheses throughout
the text of this report.
-------
permits to prevent the release of toxic and hazardous pollutants to surface
waters.
The NPDES regulations (40 CFR, Part 125, Subpart K) require that those who
must obtain an NPDES permit and who use, produce, or discharge any of the
toxic and hazardous pollutants cited in ref. 149 or listed in Appendix A must
develop a BMP program. Paragraph 125.104(b)(4)(iii) of the NPDES regulations
published in the June 7, 1979 Federal Register (44FR32954) directs readers to
this BMP guidance document for additional technical information on BMPs and
the elements of a BMP program. The BMP program will be documented and sub-
mitted as part of an NPDES permit application. The BMP program will include
a specific objective for the control of toxic and hazardous substances and
BMPs that will facilitate implementation of that objective. The program will
also cover the following activities: liquid and raw-material storage areas;
plant-site runoff; truck and railcar loading and unloading areas,- in-plant
transfer, process, and material handling areas; preventive maintenance and
housekeeping; release of rainwater from diked or other drainage areas,- man-
agement of solid and hazardous waste; materials handling; and BMP-related
employee training.
STUDY PURPOSE AND METHODOLOGY
Tasks
Based on Section 304(e) of the 1977 Act and the proposed rule for criteria
and standards for imposing best management practices (40 CFR, Part 125), the
Environmental Protection Agency initiated work to develop a BMP guidance doc-
ument for use by NPDES permitting authorities. The purposes of this study
were to provide a list of BMPs currently used by industry to control the dis-
charge of toxic and hazardous substances and to develop the criteria required
by permitting authorities to evaluate a BMP program. The work included the
following major tasks:
an extensive literature review,
site visits and personal contacts with industry to evaluate and document
existing BMPs,
grouping the toxic and hazardous substances into a manageable number of
categories so that existing BMPs could be applied,
developing the criteria required for evaluation of the BMP program.
Methodology
The toxic and hazardous substances were classified according to their physi-
cal state at normal temperatures and pressures [20 to 25°C and 1 X 105 Pa
(1 atm)]. The substances were further categorized as to their chemical and
biological properities, such as toxicity to humans, flammability, corrosive-
ness, reactivity, solubility, biodegradeability, and toxicity to aquatic
life.
The known existing applicable BMPs are divided into two groups: base line
and advanced. Base-line BMPs are defined as those management practices
-------
generally considered to be good practices that are low in cost and are appli-
cable to broad categories of industry and types of substances. The practices
are independent of the type of industry, ancillary source, specific chemical,
group of chemicals, or plant-site locations. Advanced BMPs are defined as
those best management practices specific to groups of toxic and hazardous
substances and related to one or more ancillary source. The advanced BMPs
are divided into four general categories: prevention, containment, mitiga-
tion, and ultimate disposition. The ancillary sources considered for the
advanced BMPs are material storage areas; in-plant transfer, process, and
materials handling areas; loading and unloading areas; plant-site runoff; and
sludge and hazardous-material disposal areas.
The criteria developed for evaluating BMP programs were based on acceptable
base-line BMPs, advanced BMPs, and the potential impact on the environment.
A method is presented relating applicable BMP alternatives to the toxic and
hazardous substances and to the ancillary sources. A check list in the form
of questions is provided for base-line and advanced BMPs to assist in the
evaluation of a BMP program.
Base-line BMPs are applicable to all industrial activities and can be incor-
porated into a BMP program as a minimum requirement. Advanced BMPs, however,
will be controlled by such specific factors as the site location, the topog-
raphy, the age of the plant, the engineering design, the company's safety and
spill programs, and the location of toxic and hazardous materials. To pro-
vide the guidance needed to evaluate a BMP program a list of alternative
advanced BMPs was developed based on the specific ancillary source, the chem-
ical's physical state, and the chemical's characteristics.
The water quality impact evaluated for a spill will influence the degree and
level of management practices recommended for a specific case. Methodology
is presented to provide guidance in that evaluation. Relatively simple
mathematical analytical solutions are given for streams and estuaries that
illustrate the techniques that should be considered in the evaluation of a
BMP program. The criteria to be used in the evaluation of an impact analysis
presented in a BMP program are also included in the form of a check list.
-------
SECTION 2
CONCLUSIONS AND RECOMMENDATIONS
The following conclusions and recommendations are based on a review of the
available data on BMPs and on a study of the relationships between the ancil-
lary sources, the toxic and hazardous substances, the specific industrial
practices, and the applicable regulations.
CONCLUSIONS
BMPs, those Used by industry for preventing spills of material to receiving
water, are essentially the same traditional practices used by industry for
pollution control, safety, industrial hygiene, fire protection, protection
against loss of product, insurance company requirements, and public rela-
tions.
BMPs are related to the source (ancillary source) of the spilled material and
to groups of toxic and hazardous compounds with similar physical and chemical
characteristics rather than to specific compounds.
The toxic (priority pollutants) and hazardous substances lists are combined
into a single list of 302 materials, which eliminated the duplication of com-
pounds on both lists. These compounds are classified by physical state (sol-
id, liquid, gas) at normal temperatures and pressures and by chemical group-
ings with similar physical and chemical properties relevant to identification
with applicable BMPs.
BMPs can be grouped into two general categories: base line and advanced.
Base-line BMPs are those practices that are generally applicable to all
industries, are relatively low in cost, and are independent of chemical com-
pound, ancillary source, and industrial facility location. Advanced BMPs are
those practices that provide an additional level of protection in preventing
spills and are specific to groups of toxic and hazardous substances and to
one or more ancillary source.
Base-line BMPs are applicable to all industrial activities and can be incor-
porated into a BMP program as a minimum requirement. Advanced BMPs, however,
will be controlled by such specific factors as the site location, the topog-
raphy, the age of the plant, the engineering design, the company's safety and
-------
spill programs, and the location of toxic and hazardous materials. A list of
alternative advanced BMPs that were developed based on the specific ancillary
source, the material's physical state, and its chemical group classification
can be used as guidance in evaluating a BMP program.
Advanced BMPs can be grouped into general categories of prevention, contain-
ment, mitigation, and ultimate disposition. Prevention and containment BMPs
are used to prevent a spill from occurring and to contain a spill, precluding
loss to a receiving water. Mitigation and ultimate disposition BMPs are
associated with cleanup, treatment, and ultimate disposition of a material
after it has been released from its primary location.
With few exceptions, all the liquids, independent of chemical grouping, can
be handled by the same advanced BMPs. Also, in general all dry chemicals are
handled by the same group of BMPs, with some exceptions. The BMP categories
of prevention, containment, and mitigation-treatment can be applied to gases;
however, mitigation-cleanup and ultimate disposition may not be applicable to
gases.
In developing or reviewing a BMP program the primary criteria include the
history and/or possibility of spill incidents at the site, the potential im-
pact of a spill on the water quality, and the effectiveness and costs of the
BMPs.
Costs to implement a base-line BMP program vary with the size and complexity
of the facility but are relatively independent of the specific plant loca-
tion.
Costs to implement advanced BMPs are specific to site and situation; thus it
is not possible to assign general costs to advanced BMPs independent of their
evaluation and implementation at a defined installation. Costs to implement
various BMPs at different plant sites can vary considerably. Therefore in
the evaluation of BMP programs for cost effectiveness and potential impact,
each specific case may require that several iterative steps be taken in the
overall process of prescribing BMPs, that estimated costs be developed, that
the probability of incidents be determined, and that the potential impact on
receiving waters be determined before final recommendations are made on the
implementation of specific BMPs or BMP programs.
The selection of an advanced BMP program can depend in part on the impact of
the spilled material on the receiving water. Appropriate mathematical model-
ing techniques are available to define the concentration of a toxic and haz-
ardous material in a receiving water resulting from unexpected spills. The
impact that the material may have on the water quality can only be assessed,
by comparing the calculated concentration with appropriate water quality cri-
teria. Water quality criteria are required for the toxic and hazardous sub-
stances and should be based on human and aquatic toxicity.
-------
RECOMMENDATIONS
This document should be used for guidance in developing BMP programs; how-
ever, its limitations with respect to site-specific conditions should be
recognized and considered in an evaluation of a BMP program.
Exemplary BMP programs instituted by many major industries and information
and details on the programs should be used to supplement the guidance infor-
mation contained herein. References containing this information are included
in Appendix A.
Personnel of the NPDES authorities assigned to the task of reviewing and pre-
scribing BMP programs should be trained engineers with sufficient knowledge
and experience to properly assess the specific conditions of a site and to
relate them properly to the guidance and criteria presented herein for review
of BMP programs.
Training sessions are recommended in which the permitting authority personnel
will be instructed in the proper use of this guidance document and the rela-
tionship of BMPs to other requirements under the Clean Water Act, Toxic Sub-
stances Control Act, Spill Prevention Control and Countermeasure Plans,
Resource Conservation and Recovery Act, Occupational Safety and Health Act,
and other applicable laws and regulations.
To provide more objective bases for evaluating BMP programs, additional
information should be generated through further development of the following:
Water quality criteria for toxic and hazardous substances based on human
and aquatic toxicity levels.
Probability of and risks involved in spills associated with industrial
manufacturing operations and the degree of risk reduction by implementa-
tion of specific BMPs.
-------
SECTION 3
BEST MANAGEMENT PRACTICES
This chapter discusses BMPs that can be utilized to prevent or reduce the
release of toxic and hazardous substances to the environment. The primary
sources of toxic and hazardous pollutants to be controlled by BMPs are plant
site runoff, spillage or leaks, sludge or waste disposal, and drainage from
raw-material storage, which are associated with or ancillary to the indus-
trial manufacturing or treatment process. The ancillary sources include but
are not limited to ancillary manufacturing operations, material storage,
material handling, and waste treatment and disposal.
ANCILLARY SOURCES
The ancillary sources are divided for discussion in this report into five
categories: material storage areas,- in-plant transfer areas, process areas,
and material handling areas; loading and unloading areas; plant site runoff;
and sludge and hazardous-waste disposal sites.
Material storage areas include storage areas for toxic and hazardous chemi-
cals as raw materials, intermediates, or final products. Included are liquid
storage vessels that range in size from large tanks located at a tank farm to
55-gal drums, storage of dry chemicals in bags, tanks, bins, silos, boxes,
and stockpiles for storage of any chemicals tanks and vessels for storage of
gaseous materials.
In-plant transfer areas, process areas, and material handling areas encompass
all in-plant transfer operations from raw material to final product. Various
operations could include transfer of liquids or gases by pipelines with
appurtenances such as pumps, valves and fittings, movement of bulk materials
by mechanical conveyor-belt systems, and fork-lift truck transport of bags,
drums, and bins. All process area operations with a potential for release of
toxic and hazardous substances to other than the process waste water system
are addressed in this grouping.
Loading and unloading operations involve only the transfer of materials to
and from trucks or railcars but not in-plant transfers. These operations
include pumping of liquids or gases from truck or railcar to a storage
facility or vice versa, pneumatic transfer of dry chemicals to or from the
-------
loading or unloading vehicle, transfer by mechanical conveyor systems, and
transfer of bags, boxes, and drums from vehicles by fork-lift trucks.
Plant runoff is generated from rainfall on a plant site. Runoff from mate-
rial storage areas, in-plant areas, loading and unloading areas, and sludge
disposal sites potentially could become contaminated with toxic and hazardous
substances. Heavy metal pollutants from sludge disposal sites are of special
concern. Fallout from air emissions settling on the plant site may also
become a source of contaminated runoff. Contaminated runoff may reach a
receiving body of water through overland flow, drainage ditches, storm or
clean cooling water sewers, or overflows from combined sewer systems.
Sludge and hazardous-waste disposal areas are sources of potential contami-
nation of receiving waters. The operations include landfills, pits, ponds,
lagoons, and deep-well injection sites. Depending on the construction and
operation of these sites there may be an existing potential for leachates
containing hazardous materials to seep into the ground water or for liquids
to overflow to surface waters from these disposal operations.
DEFINITION OF BMPs
The BMPs are divided into categories of base-line and advanced. Base-line
BMPs are defined as those management practices generally considered to be
good practices that are low in cost and are applicable to broad categories of
industry and types of substances. Within these broad categories base-line
BMPs are independent of the type of industry, ancillary source, specific
chemical or group of chemicals, and physical site conditions such as land
area and topography. Advanced BMPs are defined as those best management
practices specific to groups of toxic and hazardous substances and related to
one or more ancillary sources.
DATA BASE
The data and information compiled and evaluated during this study were gen-
erated from an extensive literature review, from telephone inquiries of
industrial companies and from plant visits. The literature review consisted
of a review of 161 articles and reports, including conference proceedings,
and, a review of various trade association publications and technical bulle-
tins. The OHM-TADS (Oil and Hazardous Materials Technical Assistance
Data System) and the Lockheed Data Retrieval System were utilized for con-
ducting a computer search for pertinent information and reports. The latter
was used to perform a literature search using key words to identify addi-
tional articles and reports for review. The references are given in
Appendix A. A tabulation of BMP keywords, with the corresponding literature
or site source, is presented in Appendix B.
-------
To supplement the literature data collected, several industries were con-
tacted, either by a site visit or discussion by telephone, to obtain infor-
mation on their programs of best management practices. On-site visits were
made to Hooker Chemical Co., Niagara Falls, New York; Procter and Gamble,
Engineering Office, Cincinnati, Ohio; and Allied Chemical, Hopewell,
Virginia. The intent of these visits and telephone contacts was to verify
and amplify information obtained from the literature and was not meant to be
an all-inclusive survey of each company's practices.
Telephone contacts were made to several companies. A general guestionnaire
was sent to each company from Hydroscience through the Manufacturing Chemists
Association (MCA). Followup telephone contacts were then made to each com-
pany to discuss the questionnaire, and, when requested, specific question-
naires were sent. Then telephone conversations were held with each company
to obtain additional verbal responses to specific questions. The purpose of
these conversations was to identify base-line BMPs used by industry and spe-
cific BMPs used for specific compounds or groups of compounds. Summaries of
the telephone contacts and copies of the written responses are given in
Appendix D.
Information generated from the telephone conversations indicated that BMPs
are utilized by industry for many reasons, including safety programs, fire
protection, and protection against loss of product in addition to protection
from spills to surface waters. Relative to prevention and containment prac-
tices, it was found that, in general, all liquids as a group are subjected to
the same BMPs rather than each chemical or groups of chemicals being sub-
jected to specific BMPs.
BASE-LINE BEST MANAGEMENT PRACTICES
The base-line BMPs, as well as most of the advanced BMPs, are essentially
the same practices used by industry for pollution control, for SPCC plans
for oil and hazardous materials, for Occupational Safety and Health Act
(OSHA) programs, for fire protection, for protection against loss of valuable
raw materials or products, and for insurance policy requirements. The BMPs
listed below can be included in BMP programs for all industrial sites inde-
pendent of the nature of the toxic and hazardous chemicals, the ancillary
sources, or plant location: Spill Control Committee, spill reporting, mate-
rial inventory, employee training, visual inspection, preventive maintenance,
good housekeeping, materials compatability, security. These BMPs require
personnel commitments and procedural actions and are therefore relatively
low in cost compared to advanced BMPs.
-------
Spill Control Committee
The Spill Control Committee would be responsible for implementing and main-
taining a BMP program and would function similarly to a fire prevention or
safety committee. Responsibility and authority would be assigned by manage-
ment for carrying out management policy and achieving BMP program objectives.
Resources and manpower would be assigned as required. Although the group is
conveniently termed the "Spill Control Committee," its scope should include
all aspects of the facility's BMP program. The Committee may typically
include employees from production, engineering, research and development,
and waste treatment. The size and diversity of personnel on the committee
would reflect the size and complexity of the plant and the chemicals under
consideration. Authority and responsibility for immediate action in the
event of a spill would be clearly established and documented in the BMP
program, with the committee possibly directly or indirectly involved in that
responsibility. The committee should advise management on the technical
aspects of environmental incident control but should not impede the decision-
making process for preventing or mitigating spills and incidents.
The main responsibilities of the committee could include identification of
toxic and hazardous materials handled (materials inventory), identification
of potential spill sources, establishment of spill reporting procedures and
visual inspections programs, review of past incidents of spills and counter-
measures utilized, coordination of all departments in carrying out goals of
a BMP program, coordination of the activities for spill cleanup, notifica-
tion to authorities, and establishment of training and education programs
for plant personnel. A spill control committee would have overall responsi-
bility for the BMP program, for reviewing and evaluating the BMP program,
and for instituting appropriate changes at regular meetings. The committee
could also be responsible for the necessary review of new construction and
process changes at a facility relative to spill prevention and control. The
committee should also evaluate the effectiveness of the overall BMP program
and make recommendations to management in support of corporate policy on
BMP-related matters.
Spill Reporting
A spill reporting system is used to keep records of spills for the purpose
of minimizing recurrence, expediting mitigation or cleanup activities, and
complying with legal requirements. Spill reporting procedures that could be
defined by the committee include notification of a spill to appropriate plant
personnel to initiate immediate action, formal written reports for review
and evaluation of spills and revisions to the BMP program, and notification
as required by law to governmental and environmental agencies in the event
that a spill reaches the surface water.
The spill reporting system would designate the avenues of reporting and the
responsible company and government officials to whom the incidents would be
10
-------
reported. A list of the names, office telephone extensions, and residence
telephone numbers of key employees in the order of responsibility would be
utilized for immediate reporting of spills and incidents for implementation
of emergency response plans.
A communications system would be designated and available for notification
of an impending potential or actual spill. Reliable communications with the
person or persons directly responsible would expedite immediate action and
countermeasures to prevent spills if possible, and if not, to contain them
and to clean up after a spill. Such a communication system could include
telephone or radio contact between various sections of the plant, direct
audible or code signals between transfer operations, and alarm systems that
would signal the location of a spill.
Formal written reports on all spills or other BMP-related incidents would be
submitted to the plant's Spill Control Committee for review. Written reports
would include the date and time of the spill, weather conditions, nature of
the materials involved, duration, spill volume, cause, environmental prob-
lems, countermeasures taken, people and agencies notified, and recommended
revisions of the BMP program, operating procedures and/or equipment to pre-
vent recurrence.
A procedure would be defined for notifying the U.S. Coast Guard and federal,
state, and local regulatory agencies of all spills. The individuals respons-
ible for contacting the agencies and a list of their telephone numbers would
be included in the BMP program. In addition, municipal sewage authorities,
public water utilities, other industrial water users, and water recreation
areas would be listed for notification, if applicable.
Material Inventory System
A material inventory system would involve the identification of all sources
and quantities of toxic and hazardous materials handled or produced at a
particular site. The sources of the toxic and hazardous materials should be
clearly indicated on plant drawings and plot plans, along with the quantity
of materials used. A simplified materials flowsheet showing major process
operations can be used to indicate the direction and quantity of flow of
materials from one area to another. The direction of flow of potential major
spills could also be estimated based on site topography and indicated on the
plant site drawings. A material inventory system would also include physi-
cal, chemical, toxicological, and health information (e.g., technical bulle-
tins or safety data sheets) on the toxic and hazardous substances handled,-
the quantities involved in various operations or ancillary sources,- and the
prevention, containment, mitigation, and ultimate disposition techniques
that are used or would be used in the event of a spill.
The inventory would serve to identify those materials that might be released
and allow for an assessment of the potential water quality impact. The
11
-------
inventory and the assessment or risk evaluation can be used to identify
those areas requiring BMPs for spill control.
New materials planned for use should be investigated for safety and handling
hazards, biodegradeability, aquatic and human toxicity, and applicable alter-
natives for spill prevention, containment, mitigation, and ultimate disposi-
tion. As appropriate, testing of new materials, intermediates or products
should be required to provide the information necessary for assessing the
potential impacts and needed BMPs before their introduction into the plant
manufacturing processes. This information would be incorporated into the
materials inventory system and the BMP program revised as required.
Employee Training
Employee training programs are used to instill in personnel, at all levels
of responsibility, a complete understanding of the BMP program, the processes
and materials with v/hich they are working, the safety hazards, the practices
for preventing spills, and the procedures for responding properly and rapidly
to spills of toxic and hazardous materials. Employee training meetings
should be carried out frequently enough to assure adequate understanding of
the goals and objectives of the BMP program and the individual responsibili-
ties of each employee. Typically, these meetings could be a part of routine
employee meetings for safety and/or fire protection. Such meetings would be
directed to highlighting known spill events or failures, malfunctioning com-
ponents, and recently developed precautionary measures and to reviewing the
BMP program and procedures used to control toxic and hazardous materials.
Just as fire drills are used to evaluate an employee's reaction to a fire
emergency, spill or environmental incident drills may serve to evaluate the
employee's knowledge of BMP-related procedures.
Of particular importance would be the strong commitment and periodic input
from top management to the employee training program to create the necessary
climate of concern required for a successful program. A plant manager or
visiting vice-president might accomplish more in a brief, face-to-face,
appearance than an elaborate, impersonal training program would accomplish.
Adequate training in a particular job and process operation and its effect
on other operations is essential for understanding potential spill problems.
Knowledge of specific manufacturing operations and how spills could occur,
or have occurred in the past, is important in reducing human error or pro-
cess upsets that can lead to spills.
The training program would also be aimed at making employees aware of the
protocol used to report spills and notify the people responsible for spill
response so that immediate countermeasures could be initiated. In addition,
personnel involved in spill response would be trained in how to use spill
cleanup materials such as sorbents, gelling agents, foams, and neutralizing
agents. They would be educated in safety precautions, in the side effects
12
-------
of the chemicals they are working with, and in possible chemical reactions.
Operating manuals and standard procedures for process operations would
include appropriate sections on the BMP program and the spill control pro-
gram and would be readily available for reference as needed. Spill response
drills, suggestion boxes, and posters can be used to motivate employees to
be alert to the potentiality of spills and to their prevention.
Visual Inspection
Visual inspection consists of touring or patrolling the plant facilities
to detect spills or evidence of potential spills or other conditions that
could lead to an environmental incident. There are two types of visual
inspection: routine and detailed.
Routine visual inspections can be performed by plant security personnel and
may include visual observations of storage facilities, transfer pipelines,
and loading and unloading areas for detection of leaks and spills. The per-
sonnel could make these observations from a vehicle or on foot while patrol-
ling the plant and could be conducted especially during periods of low pro-
duction, such as night shifts or weekends.
Detailed inspections relate to specific areas of the plant and should be
made by plant personnel responsible for the individual processes and/or
plants. During normal plant operations these inspections would include
examination for pipe and pump leaks, tank corrosion, windblowing of dry
chemicals, deterioration of supports or foundations, stains on walls, stains
along drainage ditches and old tanks, and other forms of deterioration of
primary or secondary containment facilities. They could also be utilized to
evaluate the need for preventive maintenance and the adequacy of good house-
keeping, which are other base-line BMPs. The frequency of inspection should
be determined by the chemical, the age of the facility, the additional BMPs
utilized such as those for containment, and the potential impact of a loss.
It has been reported in the literature that some companies inspect the
exterior of their bulk storage tanks monthly (26, 53) and inspected the tank
foundations (26) every six months.
A comprehensive visual inspection program would include both routine and
detailed inspections. Potential spill problems would be reported to the
Spill Control Committee for review. Visual inspection program considera-
tions relative to each of the ancillary sources are discussed below.
Raw-material storage areas for dry chemicals would be inspected for evidence
of or the potentiality for windblowing of materials to other areas and possi-
bly to a receiving body of water or for evidence of the buildup of solids on
the ground due to poor housekeeping. Liquid storage areas would be inspected
for leaks in or corrosion of tanks, for deterioration of foundations and/or
supports, and for closure of drain valves in containment facilities. Inspec-
tion could include an examination of seams, rivets, nozzle connections,
valves, and pipelines directly connected to a tank. Internal examination or
13
-------
inspection of storage tanks would involve evidence of corrosion, pitting,
cracks, abnormalities, and deformation and such evidence would then be eval-
uated.
For in-plant transfer and materials handling of liquids visual inspections
would provide evidence of leaks, splits, cracks, bulges, corrosion, and
deterioration of pipelines, pumps, valves, seals, and fittings. The general
condition of such items as flange and expansion joints, pipeline supports,
locking valves, catch or drip pans, and metal surfaces would be assessed.
The frequency of inspections would be similar to that for material storage
areas and be a function of the potential impact of a spill. For in-plant
transfer and materials handling of solids visual inspections would focus on
leaks of dry chemicals from conveying systems, windblowing of dry chemicals,
damage to packaged containers and drums by transfer operations, and good
housekeeping practices used in the plant.
For loading and unloading operations visual inspections during transfer of
hazardous chemicals would permit immediate response if a spill occurred.
The conditions of pipelines, pumps, valves, and fittings for liquid transfer
systems and pneumatic conveying systems used for transferring dry chemicals
would be inspected. Visual inspections together with monitoring would be
used to ensure that the transfer of material is complete before flexible or
fixed transfer lines are disconnected prior to vehicular departure. Before
any tank car or tank truck is filled, the lower-most drain valve and all
outlets of such vehicles would be closely examined for evidence of leakage
and, if necessary, tightened, adjusted, or replaced. Before departure, all
tank cars or tank trucks would be closely examined to ensure that all trans-
fer lines were disconnected and that there is no evidence of leakage from
any outlet.
For plant runoff visual inspections would be used for examining the integrity
of the stormwater collection system and diversion or overflow structures and
for ensuring that drain valves and pumps for diked areas are properly closed.
Any liquid, including rainwater, from these diked areas would be analyzed
before release to a receiving water.
For sludge and hazardous waste disposal sites visual inspections would
include examinations for leaks, seepage, and overflows from land disposal
sites such as pits, ponds, lagoons, and landfills. Visual inspections would
also identify the need for preventive maintenance and the adequacy of good
housekeeping.
Preventive Maintenance
Preventive maintenance (PM) involves inspection of plant equipment and sys-
tems to uncover conditions that could cause production breakdowns, harmful
depreciation, or environmental insult and correction of those conditions by
adjustment, repair, or replacement of worn parts before the equipment or
system failed. Preventive or precautionary maintenance has been practiced
14
-------
predominantly in those industries where excessive downtime is extremely
costly. As a BMP, PM would be practiced selectively to eliminate or mini-
mize spills of hazardous or toxic substances to receiving waters. In prac-
tice the preventive maintenance BMP for many facilities would be an exten-
sion of the current plant PM program.
Elements of a good PM program relative to BMPs include the following:
(1) identification of equipment or systems to which the PM program should
apply by analysis for potential failures and spills and for spill impact,-
(2) periodic inspections of identified equipment and systems, which would
overlap the visual inspection BMP; (3) periodic testing of such equipment
and systems, which might include vibration analysis, ultrasonic testing,
thermography, detection of flaws or cracks with penetrants or optical sys-
tems, and verification of calibration for environmental monitoring systems
and would overlap the nondestructive testing BMP; (4) appropriate adjustment,
repair, or replacement of parts; and (5) maintenance of complete PM records
on the applicable equipment and systems.
Good Housekeeping
Good housekeeping is essentially the maintenance of a clean and orderly work
environment. A clean and orderly work area reduces the possibility of acci-
dental spills caused by mishandling of equipment and should reduce safety
hazards to plant personnel. Examples of good housekeeping include neat and
orderly storage of chemicals; prompt removal of small spillage,- regular gar-
bage and rubbish pickup and disposal; maintenance of dry and clean floors by
use of brooms, vacuum cleaners, or cleaning machines,- and provisions for
storage of containers or drums to keep them from protruding into open walk-
ways or pathways. Dry chemicals would be swept or cleaned up to prevent
possible washdown to drainage ditches or windblowing to other areas of the
plant, and small liquid accumulations on the ground or on a floor in a
building would be cleaned up to prevent further transport to other areas and
possibly into a receiving water.
Maintaining employee interest in good housekeeping is a vital part of the
program. Methods for maintaining good housekeeping goals could include
regular housekeeping inspections by supervisors and higher management; dis-
cussions of housekeeping at meetings; and publicity through posters, sug-
gestion boxes, bulletin boards, and employee publications.
Materials Compatability
Materials compatibility encompasses three aspects: compatibility of the
contents with the materials of construction of the container, compatibility
of different chemicals upon mixing such as in a landfill or in a container,
15
-------
and compatibility of the container with its environment. The BMP would pro-
vide procedures such that the applicable aspects of materials compatibility
are adequately covered in the design and operation of all equipment handling
toxic and hazardous materials.
The selection of proper materials of construction typically would be con-
sidered in the engineering design of a facility by personnel having expertise
in materials engineering. A successful materials compatability program
requires a materials engineering study. Before changes are made in raw mate-
rials, process operations, or products, for which the materials of construc-
tion were originally selected, they would be studied to determine whether
the materials of the tanks, pipelines, etc., are adequate for the new con-
ditions. Periodically, the physical and chemical properties of the chemi-
cals being handled at a particular site would be reviewed for compatibility
with the materials of construction. In conjunction with this review visual
inspection, testing, and preventive maintenance programs would also be
reviewed to identify historical, materials-engineering performance data.
Compatibility of different chemicals upon mixing is defined as the absence
of any significant physical or chemical effects. Mixing two or more chemi-
cals that are incompatible could result in an exothermic reaction, fire,
explosion, and possible release of noxious or lethal vapors. Situations
involving the mixing of chemicals would be reviewed by personnel having
expertise in reaction chemistry before such mixing is authorized by manage-
ment. Testing for compatibility, which is common in complex situations, may
be required. Ultimate disposal of chemical wastes in a landfill is an
example of storage of incompatible wastes. Proper inventorying and labeling
of locations of hazardous chemical disposal sites in a landfill would be
followed to prevent the mixture of incompatible wastes. Thorough cleaning
of storage vessels and equipment before being used for another chemical would
be standard practice to ensure that there is no residual of a chemical that
is incompatible with the second, or later, chemical to be used.
Consideration of the compatibility of a container with its environment, such
as a buried storage tank or pipeline, would be similar to the selection of
the proper materials of construction for compatibility with the contents.
As an example various means of protecting a buried pipeline or storage tank
from corrosion would be considered such as coatings or cathodic protection.
Security
A security system would be used to prevent accidental or intentional entry
to a facility that could possibly cause a chemical release. Protection
measures against vandalism, theft, sabotage, or other improper and illegal
use of plant facilities include routine patrol of the plant by security
guards in vehicles or on foot; fencing to prevent intruders from entering
the plant site,- good lighting; vehicular traffic control; a guardhouse or
main entrance gate, where all visitors are required to sign in and obtain a
visitor's pass; secure or locked entrances to the plant; drain valves and
16
-------
pumps for chemical storage tanks, and loading and unloading facilities; and
television monitoring of areas of the plant most susceptible to a spill.
Many of these measures are used routinely by industries to prevent theft and
vandalism, with the major concern being property damage and/or product or
equipment loss. These measures have the additional benefit of protecting
the plant site from potential release of hazardous chemicals to the environ-
ment.
Security personnel can be instructed to observe leaks from tanks, valves, or
pipelines while patrolling the plant and can also be instructed on the pro-
cedures to follow when a spill is detected. The security patrols are an
integral part of the best management practice of visual inspection programs
since security personnel are normally available throughout the day to per-
form visual inspections to identify spills or other potential environmental
incidents as they conduct routine plant patrols.
Summary
In summary, the important aspects of each base-line BMP include the fol-
lowing:
Spill Control Committee
Responsibility and authority defined by management.
Assignment of resources and manpower to the Committee.
Inclusion of representatives from production, engineering,
research and development, and waste treatment.
Responsibility for materials inventory.
Responsibility for identifying potential spill sources.
Establishment of spill reporting procedures and visual inspection
programs.
Review of past incidents of spills.
Coordination of all departments in carrying out goals of the BMP
program.
Establishment of employee training programs.
Responsibility for BMP program implementation and subsequent
review and updating.
Responsibility for meetings on the BMP program.
Review of new construction and process changes relative to spill
prevention and control.
Spill Reporting
Maintenance of records of spills through formal reports for
internal review.
Notification as required by law to governmental and environmental
agencies should a spill reach the receiving water.
Procedures for notifying the appropriate plant personnel.
n
-------
Identification of responsibile company and government officials.
A list of names, office telephone extensions, and residence tele-
phone numbers of key personnel.
A communication system for reporting spills in-plant (i.e., tele-
phone, alarms, radio, etc.).
Materials Inventory System
Identification of all sources and quantities of toxic and hazard-
ous substances handled or produced.
Plant drawings and plot plans with sources clearly labeled.
A simplified materials flow diagram.
Physical, chemical, toxicological, and health information on the
toxic and hazardous chemicals on-site.
Investigation and evaluation of new materials relative to spill
prevention and control.
Employee Training
Meetings held at intervals frequent enough to assure adequate under-
standing of program goals and objectives.
Spill drills.
Periodic input from management.
Adequate training in particular job and process operation and the
effect on other operations.
Transmission of knowledge of past spills and causes.
Making employees aware of BMP program and spill reporting proce-
dures .
Training in the use of cleanup measures for spills of sorbents,
gelling agents, foams, and neutralizing agents.
Operating manuals and standard procedures.
Review and interface with safety program on associated health
risks of chemicals handled.
Motivating employees concerning spill prevention and control.
Visual Inspections
Routine inspections with visual observations of
storage facilities,
transfer pipelines,
loading and unloading areas.
Detailed inspections of
pipes, pumps, valves, and fittings,
tank corrosion (internal and external),
windblowing of dry chemicals,
tank support or foundation deterioration,
stains on walls,
18
-------
stains along drainage ditches and old tanks,
deterioration of primary or secondary containment,
housekeeping,
drain valves on tanks,
damage to shipping containers,
conveying systems for dry chemicals,
integrity of stormwater collection system,
leaks, seepage, and overflows from sludge and various waste
disposal sites.
Preventive Maintenance
Identification of equipment and systems to which the PM program
should apply.
Periodic inspections of identified equipment and systems.
Periodic testing of such equipment and systems.
Appropriate adjustment, repair, or replacement of parts.
Maintenance of complete PM records on the applicable equipment
o »"i *-4 f**Tft- £±-m f
and systems.
Good Housekeeping
Neat and orderly storage of chemicals.
Prompt removal of small spillage.
Regular garbage and rubbish pickup and disposal.
Maintenance of dry and clean floors by use of brooms, vacuum
cleaners, etc.
Proper pathways and walkways and no containers and drums that
protrude onto walkways.
Minimum accumulation of liquid and solid chemicals on the ground
or floor in a building.
Stimulation of employee interest in good housekeeping.
Materials Compatibility
Evaluation of process changes or revisions for materials compata-
bility.
Periodic review of properties of chemicals handled to ensure com-
patibility with materials of construction.
Evaluation of means of disposing of chemicals and of possible
incompatibility with other chemicals present.
Cleansing of vessels and transfer lines before they are used for
another chemical.
Use of proper coatings and cathodic protection on buried pipelines
if required to prevent failure due to external corrosion.
19
-------
Security
Routine patrols of plant by security personnel.
Fencing.
Good lighting.
Vehicular traffic control.
Controlled access with guardhouse or main entrance gate.
Visitor passes.
Locked entrances.
Locks on drain valves and pumps for chemical storage tanks.
Television monitoring.
ADVANCED BEST MANAGEMENT PRACTICES
The advanced BMPs are methods or means to be used in addition to the base-
line BMPs and are specific to groups of chemical substances and one or more
of the ancillary sources. The advanced BMPs have been divided into the four
main categories of prevention, containment, mitigation, and ultimate dis-
position. Prevention BMPs are those practices beyond the base-line BMPs
that provide additional protection against releases. Nondestructive testing
is an example of a prevention BMP that is more effective than the base-line
BMP of visual inspection. Visual inspections normally would not allow a
structural weakness in a tank to be identified before there is evidence of
failure or severe corrosion. Nondestructive testing might provide warning,
through measurements of tank wall thickness, of impending failure.
Containment BMPs are the physical structures or collection equipment used to
confine a release of material after it escaped from its primary location or
containment. Dikes surrounding material storage tanks are the most common
example of containment.
Mitigation is the cleanup or treatment of a substance after it has spilled.
Mitigation is used to separate a substance for recovery or to reduce the
potential impact of a spill before ultimate disposition of the substance.
Sorbents, gelling agents, and treatment processes such as carbon adsorption
and biological treatment are considered to be effective mitigation methods.
Ultimate disposition is the final step in the overall handling of a sub-
stance that is released from its original location. Examples of ultimate
disposition include landfills, surface impoundments, and ocean disposal.
Environmental regulations may make one disposition method preferable over
another or, in some cases, may preclude an ultimate disposition method alto-
gether.
Each advanced BMP is discussed for its applicability to the various ancillary
sources. The material storage areas, in-plant transfer areas, process areas,
material handling areas, and loading and unloading areas are discussed as
one group of ancillary sources since most of the BMPs for them are essen-
tially the same and are generally applicable. These ancillary sources
20
-------
release substances to the environment in similar ways, such as through leaks
from tanks, pumps, valves, or pipelines or through windblowing of dry chemi-
cals from storage and handling operations. BMPs used for potential spills
from these three sources are therefore very similar. The BMPs for plant site
runoff and for the sludge and hazardous waste disposal areas are discussed
separately. The advanced BMP alternatives are listed in Table 1 under the
four categories of prevention, containment, mitigation, and ultimate disposi-
tion.
Table 1. Advanced-BMP Alternatives
BMP Category
Prevention
Containment
Mitigation
Cleanup
Methods
Treatment
Methods
Advanced- BMP
Alternative
PI
P2
P3
P4
P5
P6
P7
Cl
C2
C3
C4
C5
Ml
M2
M3
Tl
T2
T3
- Monitoring
- Nondestructive
testing
- Labeling
- Covering
- Pneumatic and
vacuum
conveying
- Vehicle posi-
tioning
- Dry cleanup
- Secondary con-
tainment
- Flow diversion
- Vapor control
- Dust control
- Sealing
- Physical
- Mechanical
- Chemical
- Liquid-solids
separation
- Volatilization
- Carbon adsorp-
tion
Advanced-BMP
BMP Category Alternative
Treatment
Methods
(continued) T4
T5
T6
T7
T8
T9
Ultimate
Disposition III
U2
U3
U4
U5
U6
U7
U8
- Coagulation/
precipitation
- Neutralization
- Ion exchange
- Chemical oxida-
tion
- Biological
treatment
- Thermal oxida-
tion
- Deep-well
injecton
- Landfill
- Surface impound-
ment
- Ocean disposal
- Direct discharge
to receiving
water
- Reclamation
- Municipal sewer
system
- Contract dis-
posal
21
-------
Prevention
Prevention BMPs are those practices that provide additional protection beyond
the base-line BMPs and involve closer control of plant operations and equip-
ment to prevent release of chemicals from their primary containments. They
are relatively less costly than the containment BMPs, which frequently
involve major construction and capital expenditures.
Monitoring Monitoring is the measuring of process parameters to determine
operating conditions of a process or piece of equipment. Instrumentation is
the method, measure, or equipment used for monitoring a particular process.
Monitoring can be used, for example, to detect changes in process parameters
such as the liquid level in tanks, or the conductivity of solutions, and the
total organic carbon (TOC) concentration in stormwater. Monitoring can be
used to initiate a warning of the need for immediate corrective action to
prevent a release of chemicals to the environment. For example, detection
of a high liquid level could trigger manual or automatic shutdown of the
incoming flow. A detected increase in TOC in the stormwater sewer, which
would indicate contamination by organics, could be a warning that the stream
should be diverted to holding ponds. A monitoring system should be used
with an efficient communication or alarm system to immediately notify
appropriate plant personnel of abnormal conditions.
For material storage areas monitoring may include liquid-level detectors,
pressure and temperature gages, and pressure-relief devices for bulk storage
tanks. Numerous types of instrumentation incorporating various measuring
principles are available including floats, electrical devices such as capaci-
tors, pressure and temperature gages, pneumatic systems, and ultrasonic and
radio-frequency instruments. Monitoring of process variables such as pH,
conductivity, total organic carbon, and specific chemicals can be performed
with pH meters, conductivity meters, TOC analyzers, and gas chromatographs.
Air collection funnels can be used to monitor vapor and gas spills by gas
chromatography. Instrumentation measurements should be recorded or dis-
played at a location where plant personnel can observe measurements. An
alarm system can be used to warn of abnormal conditions in the event that an
operator does not identify the condition by reading the instruments. Gauges
for reading the tank level can also be located at the storage tanks so that
an operator will know the volume of a tank at any time for such procedures
as loading and unloading, internal inspections, and testing.
For in-plant transfer areas, process areas, and materials handling areas,
monitoring systems can include pressure-drop devices, shut-off devices, flow
meters, thermal probes, valve positioning indicators, and equipment opera-
tional lights. These devices can be utilized to detect the reductions in
flow, an abnormal temperature condition, and the condition of valves and
other equipment. An abnormal condition indicated by any of these systems
may indicate a release that could initiate immediate countermeasures.
For loading and unloading operations, monitoring systems may include devices
for measuring the initial volume of tanks before loading, for weighing
vehicles or containers, and for determining the rate of flow during loading
22
-------
and unloading and excess flow valves that shut off when a predetermined flow
is exceeded and therefore could result in a spill.
Monitoring can be used to measure the quality of plant site runoff to deter-
mine whether discharge to a receiving water is appropriate. Monitoring the
quality of runoff could involve measurement of pH, turbidity, conductivity,
total organic carbon (TOC), total oxygen demand (TOD), or specific ions in
storm sewers, drainage ditches, holding ponds, and diked areas. Monitoring
results would be used to determine further courses of action such as dis-
charge of noncontaminated stormwater to the receiving stream or bleeding of
contaminated runoff into a treatment system at a controlled rate. The
stormwater collection system may be designed to collect the initial or most-
contaminated runoff portion in a holding pond and to discharge the remaining,
less-contaminated, runoff if it does not exceed the effluent discharge limits
specified in an NPDES permit. System designs could include automatic diver-
sion of runoff to a holding basin. A valve or gate can be triggered by a
TOC or TOD instrument. Separate areas of the plant site could also be moni-
tored to detect which areas are the major contributors to the runoff contami-
nation. These contaminated areas may then be isolated and segregated for
separate treatment and disposal.
For sludge and hazardous waste disposal sites such as landfills, surface
impoundments, and deep-well injection sites, monitoring primarily involves
measurement of the ground-water quality to detect contamination due to seep-
age from these disposal sites. Any leachate collected from such sites can
be monitored to detect levels of contamination. Monitoring wells can be
used near the disposal site to indicate the impact of the site on the
ground-water quality. Monitoring could typically involve routine collection
of samples for appropriate analysis such as total dissolved solids, chemical
oxygen demand, nitrates, and specific toxic or hazardous compounds believed
to be present based on the use and contents of the disposal site. Monitor-
ing could also include measuring the liquid level in surface impoundments
such as ponds and lagoons to ensure adequate freeboard so that potential
overflows are detected and corrections instituted.
Redundant instrumentation such as backup instrumentation or secondary meas-
uring devices can be used to monitor the process if the primary instrumenta-
tion should malfunction. This type of instrumentation sometimes will util-
ize a different measuring principle to ensure against the backup system mal-
functioning because of the same reasons or process variables that affected
the primary instrumentation devices. Redundant instrumentation may be used
where there is a history of instrument failure and/or frequent instrument
maintenance requirements. For example, two liquid-level alarms could be
used on a material storage tank of a corrosive liquid to provide an extra
degree of protection. One level detector could be a float and the backup
could be an electrical device.
Nondestructive Testing Nondestructive testing is the testing of a struc-
ture or vessel without is being altered, modified, or disassembled. Non-
destructive testing involves the application of measuring methods to examine
the structural integrity of tanks, pipelines, pumps, valves, and fittings.
Testing methods include hydrostatic pressure tests for storage tanks, pipe-
23
-------
lines, valves, and fittings and acoustic emission (ultrasonic) testing for
the thickness of shell walls and the structural integrity of pipelines and
tanks. Nondestructive testing is most applicable to storage tanks, in-plant
transfer, process, and materials handling equipment and to loading and
unloading operations. These testing procedures have minimal application to
plant runoff and sludge and hazardous-waste disposal areas although acoustic
emission testing can be used on dikes and surface impoundments to determine
locations susceptible to leaks.
In hydrostatic testing a test pump is used to apply a hydrostatic pressure
on the tank that is 1 to 1.5 times the maximum allowable working pressure
and then, with all valves closed off, observing whether there is a drop in
the measured pressure in the tank. A drop in pressure would indicate a weak-
ness of the tank walls or the presence of leaks. Hydrostatic testing can
also be applied to pipelines, valves, and fittings to determine their sus-
ceptibility to leaks and spills.
Acoustic emission testing is used to determine the structural condition of
buried pipelines and dikes. Acoustic emissions are the internally generated
sounds that a material produces when it is placed under certain stress con-
ditions. A sensor (an accelerometer or a transducer) is used to detect the
acoustic emissions in the form of sounds, which are recorded and related to
the basic material characteristics to determine the relative stability of
the tank or pipeline being tested. Similar acoustic emission principles can
be used to measure tank-wall thickness with an audigage. Tank wall thick-
ness measurements are normally made at various locations around the circum-
ference of the tank. Records of the measurements would be kept to determine
whether weaknesses were developing in structural condition. Tank replace-
ment schedules would be determined and implemented, based on measured cor-
rosion rates. Recommended hydrostatic and ultrasonic testing frequencies
for bulk storage tanks vary in the literature from two to five years for
hydrostatic testing (26, 106) and one to five years for ultrasonic testing
(26, Rl, 83).
Labeling Labeling refers to marking such items as tanks, pipelines, drain-
age ditches, and equipment to inform personnel of the particular chemical
being stored or handled and the potential hazards involved. Labeling is
applicable to all the ancillary sources although for plant runoff there may
only be minimal application, such as labeling drainage ditches to distin-
guish stormwater from process wastewater. A labeling system used by the
Department of Transportation (DOT) based on the degree of hazard associated
with corrosive, radioactive, reactive, flammable, explosive, and poisonous
characteristics is one example of the kind of labeling system that can be
utilized.
Hazardous-chemical storage tanks, pipelines, and buildings would be labeled
so that employees and visiting contractors are easily made aware of poten-
tial hazards. Hazardous labels using DOT designations or color coding of
tanks and pipelines, with periodic markings to explain the color code, can
be beneficial in rapidly identifying the contents of a tank or transfer
24
-------
pipeline. Labeling is used to alert personnel and visitors to be extremely
cautious when working or traveling in dangerous areas of the plant.
Labeling also may be used to provide handling and ultimate disposal instruc-
tions for chemical wastes. Examples include notices of material compati-
bility and designation of locations of various hazardous materials in land-
fills to ensure that personnel and outside contractors are informed of the
proper procedures to use in handling and disposing of wastes.
Covering Covering comprises the partial or total physical enclosure of
material, equipment, or process operation. Covering is applicable to storage
areas for dry chemicals, plant runoff, and surface impoundments used for
sludge and hazardous waste disposal. Covering such as tarpaulins can be
used to cover outdoor storage stockpiles of dry materials to prevent wind-
blowing and runoff contamination. Covering in the form of a building or a
roof over an outside process area can be used to prevent rainwater contami-
nation and subsequent runoff contamination. Drainage from a roof or build-
ing can be captured and directed to the stormwater sewer or drainage system
to prevent it from coming in contact with chemicals used in the process
areas. Protective coverings such as grass, rock, and synthetic materials
can be used on surface impoundments such as dikes, ponds, and lagoons to
protect against wind and runoff erosion, which would cause an overflow to a
receiving water. Landscaping (planting of trees, grass, and shrubs) also
may serve to absorb runoff and reduce windblowing to accomplish the same
objectives as covering.
Vehicle Positioning Vehicle positioning is the practice of properly locat-
ing the loading or unloading vehicle so that it is stable and cannot be
moved during transfer operations. Physical barriers can be used to prevent
truck or rail car movement. It also includes the proper positioning of
vehicles relative to containment or flow diversion systems should the trans-
fer connections or lines develop a leak. Examples include positioning
vehicles either over a drain or on a sloped pavement that drains to some
form of containment. Wheel chocks on vehicles provide another safeguard
against accidental vehicle movement and rupture of transfer lines.
Pneumatic and Vacuum Conveying Pneumatic and vacuum conveying is the
transfer of chemicals, normally in the dry form, from one vessel to another
and applies mainly to in-plant transfers, materials handling, and loading
and unloading areas. Pneumatic conveying utilizes air pressure, whereas
vacuum conveying uses suction to transfer chemicals.
Pneumatic transfer eliminates the need for mechanical, conveyor-belt systems
and the use of water to form pumpable slurries. Pneumatic systems have
become popular because of their simplicity and the relative speed with which
they can be loaded and unloaded. They also serve to minimize the potential
for spills due to the total, enclosed nature of the system, whereby the
chemicals are not exposed as with mechanical conveyors but are contained
during the entire transfer operation. Dry chemicals are simply moved by air
25
-------
pressure from truck or rail car to storage tanks by connecting hosing or
pipeline. A safety-relief valve and a dust collector are mounted on top of
the storage vessel to exhaust the air used for conveying and to separate out
the dry chemicals. Air slide trucks and rail cars are also used in pneu-
matic conveying of dry chemicals. With these units the dry chemical is
fluidized by low-pressure air and conveyed in a slightly inclined trough to
the discharge end of the truck or car. A mechanical conveyor is then
normally used with this type of system to transfer the dry chemical.
A vacuum conveying system is similar to the pneumatic conveying system; how-
ever, a suction system is used to transfer the chemicals. A dust collection
device and a drainage air lock such as a rotary gate or trap-door feeder are
normal components of a vacuum conveying system.
Although pneumatic and vacuum conveying systems can be good BMPs, proper
design and operation can be critical and essential to eliminate serious air
emission problems. This is particularly true with pressurized systems since
all leaks are outward and the toxic or hazardous dust or gas must be ade-
quately removed from the conveying fluid before it is exhausted to the
atmosphere.
Dry Cleanup Dry cleanup is simply physical and mechanical cleanup for dry
chemicals rather than hosing down the dry chemicals to the drainage ditch or
sewer collection system. This BMP applies to material storage, in-plant
transfer areas, process areas, materials handling areas, loading and unload-
ing areas, and sludge and hazardous-waste disposal sites. Cleanup and
reclamation of dry chemical spills from these sources with shovels, brooms,
and vacuum cleaning systems are very effective practices in preventing the
chemicals from reaching a receiving water. Dry cleanup of material spilled
at sludge disposal sites, rather than washdown with water, is also an
effective BMP to prevent contamination to the surface or ground water.
Containment
Containment BMPs are used to physically contain or capture a release of
material. Containment BMPs are a second line of defense and thus augment the
effectiveness of the prevention BMPs by preventing a release of material from
reaching the receiving water since the release is physically confined and
prevented from moving any further. Containment has been subdivided into
secondary containment, flow diversion systems, dust control, vapor control,
and sealing. Each of these BMPs is defined and discussed.
Secondary Containment Secondary containment is the physical confinement of
material at its original location. Secondary containment is accomplished by
physical structures or by collection equipment such as a storage tank, pipe-
line, truck, or rail car, to contain the material after it has been released
from its original container. Secondary-containment BMP alternatives include
26
-------
dikes, curbs, depressed areas, storage basins, sumps, drip pans, liners,
double-walled piping, and sewer collection systems. These BMPs can be
applied to any of the ancillary sources. However, they are related to the
volume of material to be contained and the ancillary source as discussed
below.
Dikes and depressed areas are normally used around those areas where large
volumes of chemicals are stored. Drip pans are used for relatively small
volumes of leaks from pumps, valves, and fittings. Sewer collection systems
are used to collect and contain plant runoff, and liners are used to contain
material in landfills and surface impoundments to prevent percolation of
material to the ground water. Cleanup materials such as sorbents, foams,
and gelling agents, which are discussed later in this section can also be
used for immediate containment when physical containment is not available.
The use of foams that solidify to form a physical barrier or dike can be
used to form secondary containment. Application of secondary containment
relative to the various ancillary sources is discussed as follows.
For material storage areas, secondary-containment alternatives include
dikes, berms, retaining walls, curbs, depressed areas, storage or holding
basins, and wastewater treatment plants. The containment volume is normally
sized to capture the volume of the largest tank in the drainage area, with a
reasonable allowance made for rainfall based on local historical rainfall
records. A containment volume of 110% of the largest tank or the largest
volume tank plus a 24-hour, once in 10-year, rainfall event is a common
practice used for sizing of secondary containment. Sizing for the once-in-
25-year rainfall event provides an extra margin of safety. Final sizing,
however, to fit the specific situation and circumstances would be determined
from good engineering practice. There are a number of engineering and opera-
tional aspects that should be considered in the design of the containment
structure. The secondary-containment structure should be sufficiently
impervious to contain a spilled material and prevent seepage to the outside
or to the surface or groundwaters. The material used for containment should
be compatible with the chemicals to be contained. Materials such as con-
crete, asphalt, or clay typically are used. A layer of crushed limestone or
clam shells can sometimes be used on top of the dike base or flooring to
neutralize acids. There should be sufficient distance between the contain-
ment walls and the storage tanks that the hydrostatic head will not cause a
discharge over the containment wall. The sewer system should have no drains
or openings that could permit gravity flow. Manually controlled pumps and
manual valves should be considered for emptying the containment volume for
receiving or disposal. Operators should be suitably trained on when to turn
on pumps and open valves so that there will be no uncontrolled release of
material. The composition and quantity of a spill would be determined
before subsequent recovery, treatment, and disposal options are decided on.
The group of applicable secondary-containment alternatives for in-plant
transfer, process areas, materials handling, and loading and unloading areas
will be slightly different from those for the material storage areas. The
alternatives include dikes, curbs, depressed areas, drip pans, sumps, foam
dikes, storage or holding basins, and double-walled piping. These BMPs can
be applied for liquids and dry chemicals and would be utilized for pipelines,
27
-------
pumps, valves, fittings, and mechanical conveyor belts at locations of
potential release. The use and sizing of these secondary-containment alter-
natives are related to the volume of the potential release. Minor- or small-
volume leaks from pumps, valves, or fittings may be contained by drip pans,
depressed areas, or curbing, whereas larger releases from loading and unload-
ing operations may require dikes, depressed areas, sumps, or storage or hold-
ing basins. Double-walled piping, in which one pipe is contained within
another pipe, is a form of secondary containment used to confine a leak from
a pipeline and can be used for transfer pipelines.
For plant site runoff, secondary-containment alternatives include collection
of runoff in stormwater or combined sewer collection systems, diked areas,
holding or diversion ponds, and curbed areas. Containment of plant-site
runoff involves a collection system, with diversion of the flow to some form
of containment or treatment. Since it is uneconomical to size the collection
system and storage to contain all rainfall events, stormwater overflow is
inevitable at times. Sizing of containment facilities for runoff is normally
based on the statistical properties of the rainfall in an area and on a cost-
versus-impact analysis. The reader is referred to ref. 79 in Appendix A for
a more detailed discription of approaches available for developing plot-
runoff control strategies. Monitoring, discussed previously, can be used to
detect and divert contaminated runoff to holding basins and for effluent dis-
charge consistent with limitations and other conditions defined in NPDES per-
mits .
For sludge and hazardous-waste disposal areas, secondary-containment alter-
natives include dikes, liners, and leachate collection systems. Diked areas
can be used to contain runoff and overflow from waste disposal sites such as
landfills and surface impoundments. Liners and leachate collection systems
can be used to prevent leachate from landfills and surface impoundments from
seeping into the ground water or discharging to surface water. Liners may
consist of natural materials such as clay or of synthetic materials such as
polyethylene, hypalon, and butyl rubber. Liners can be used to drain the
leachate to an underground collection system for transfer to treatment and/or
disposal facilities.
Flow Diversion Flow diversion is used to divert a flow or discharge from
its original location to containment or treatment, usually at another loca-
tion. Secondary containment, previously discussed, is usually associated
with and located close to the source of a potential release. Flow diversion
systems are applicable to all ancillary sources and may be applicable at
sites where it is physically impossible to locate complete or total second-
ary containment. Systems include trenches, drains, graded pavement, grating,
overflow structures, sewers, and culverts. The flow diversion systems would
ultimately transport the spilled material to remote secondary-containment
facilities, such as storage or holding basins, ponds, and lagoons. Sluice
gates and valves can be triggered by monitoring instrumentation to divert
flow to a holding pond when a spill is detected. For volatile compounds,
closed diversion systems such as pipelines may be more appropriate than open
drainage ditches.
28
-------
A system of trenches, drainage ditches, and sewers can be used to segregate
plant runoff from process wastewater and spill-prone areas, to prevent con-
tamination of the runoff. Flow diversion systems can also be used to segre-
gate individual process waste streams to contain a spill, to protect treat-
ment facilities, or to minimize a release to the surface waters.
For sludge and hazardous-waste disposal sites flow diversion systems such as
drainage ditches and trenches can be utilized to divert runoff from the dis-
posal sites and to collect and divert contaminated leachate to subsequent
treatment and disposal operations.
Vapor Control Vapor control is the collection or containment of volatile
fumes, vapors, and gases to prevent release to the atmosphere where deposi-
tion, due to condensation, rainfall, etc., may wash the chemicals to the
ground and subsequently to the receiving water. Vapor control techniques
include water spraying, vapor space, and vacuum exhaust.
In water spraying a water mist is sprayed over the spill of a volatile mate-
rial or gas to reduce its dispersion in the air. A water supply must be
available, and secondary containment or diversion to treatment must be pro-
vided for the resulting contaminated water stream. Water spraying, which
removes water-soluble vapors and gases from the air, will help to protect
plant personnel from noxious fumes and vapors and thus may serve simultane-
ously as both a BMP and an occupational safety measure.
Vapor space is the use of a secondary wall around a storage tank or a pipe
surrounding another pipe to capture fumes or gases that may be released.
This BMP is used for the capture of vapor and fumes from volatile liquids
and gas releases. One company utilizes this approach for containment of
vapors from a tank containing an ammonium hydroxide solution. In some cases
partial control can be achieved by minimizing the surface area of spilled
fuming materials.
Vacuum exhaust is the collection of vapors or gases from storage vessels by
a suction-type ventilation system. For example, during unloading or loading
operations a vacuum device can be connected to a rail car's vapor ports and
exhaust vapors into a collection header. The exhausted vapors can then be
treated by various methods such as incineration, caustic-spray, adsorption,
etc., to control odors and vapor emissions. A practiced example of this
approach is the containment and collection of chlorine gas and mitigation
with an alkaline absorption system. Air emissions from exhaust systems
should comply with applicable air pollution regulations.
Dust Control Dust control is the collection or containment of chemical
dusts. Control of dust can prevent potential spreading and fallout in other
areas of the plant, where runoff may eventually transport the material to
the sewer collection system or directly to a receiving water. Dust may also
need to be controlled for safety and fire protection. Dust control systems
apply mainly to in-plant transfer, process areas, materials handling, and
loading and unloading areas and may include hoods, cyclone collectors, bag-
29
-------
type collectors, filters, negative-pressure systems, and water spraying.
Hoods can be used to minimize the spread of dust when drums or bags are being
filled or emptied. Cyclone collectors separate the dry chemicals and the
air by centrifugal force. Bag collectors and fabric filters remove dust by
filtration. Storage of the collected dust should be carefully considered so
that it does not become a source of fugitive dusts. Negative-pressure sys-
tems minimize the release of dust from an operation by maintaining a slight
negative pressure or suction to confine the dust to the particular opera-
tion. Water spraying confines and settles the dust from the air and pre-
vents further spread to other areas. With water spraying, secondary collec-
tion, and containment, recovery or disposal means must be provided for the
liquid waste. Where practical, dry cleanup is preferred.
Sealing Sealing is the technique or practice of plugging leaks in a vessel
or container to minimize the volume of material released. Foamed plastic
compounds are used to plug leaks in vessels. A leak plugging system can be
applied to storage vessels and pipelines and consists of a foam supply
device and an applicator that places the foam in the opening of the ruptured
containers so as to plug the leak. Portable, easily operated, one-man
application units are used to apply urethane foams, which harden and expand
within and outside a tank or pipe wall, effectively sealing the leak.
Dikes, ponds, and lagoons sometimes leak as a result^of improper design,
erosion, or other causes. Materials such as Volclay , which swell upon con-
tact with water, may be used to seal leaks of this type.
Mitigation Cleanup Methods
Mitigation BMPs listed in Table 1 have been divided into two categories:
cleanup and treatment. Once a hazardous material spill occurs and is con-
tained, the material has to be cleaned up and disposed of to protect plant
personnel from potential health and fire hazards and to prevent the release
of the substance to surface waters. The health and safety of personnel are
of primary consideration when BMP programs are designed and specific BMPs
are selected.
Cleanup BMPs are the practices used to physically, mechanically, or chemi-
cally remove a spilled material. Containment of the material is, of course
a prerequisite to effective and complete cleanup operations. Wide disper-
sion of a spill or its loss into a receiving water could greatly minimize
the effectiveness of a cleanup operation. Cleanup BMPs are independent of
ancillary source and would be utilized for immediate cleanup of a substance
for subsequent recovery, treatment, or disposal. Sorbents, gelling agents,
and foams can also be used for secondary containment when diking, curbing,
and holding basins are not available.
Physical Physical methods for cleanup of dry chemicals include the use of
brooms, shovels, or plows. Containers must be provided for the material to
30
-------
be removed, and cleanup crews can be assigned beforehand to handle this task.
After cleanup, the materials could be reclaimed or disposed of in appropriate
sludge and hazardous-waste disposal sites. Physical cleanup is an alterna-
tive to a water hosing of the chemical to the sewer system and is an effec-
tive BMP that can be included in a good housekeeping program. The physical
cleanup devices would be readily available for use with releases of dry chem-
icals from sources such as mechanical conveyor systems and packaging opera-
tions.
Mechanical Mechanical methods for cleanup include the use of vacuum clean-
ing systems and pumps. Vacuum cleaning includes vacuum cleaners or vacuum
trucks, and pumping could include pumping to a storage vessel or tank.
Mechanical methods could be used for liquid and solid chemicals before they
are recovered, treated, and ultimately disposed of. A portable pump/bag
cleanup system incorporating a collapsible, chemically resistant, bag, pump,
hoses, connectors, and power supply has been used on spills of up to
7000 gal.
Chemical Chemical cleanup of material can be accomplished with the use of
sorbents, gells, and foams. Sorbents are compounds that remove materials by
surface adsorption or by adsorption and absorption in the sorbent bulk. Sor-
bents include materials such as activated carbon, polyurethane, polyolefins,
"universal sorbent material," clays, sawdust, straw, and fly ash. Sorbents
adsorb or absorb only those materials that impinge on their surface and
therefore must be mixed into the material or the material must be passed
through the sorbent, either in a support bed or in a column.
Sorbents are available in many physical forms, from particles to foams.
Granular or powdered activated carbon can be mixed with liguids to adsorb
organics. In some cases in situ mixing of pollutants with a material such as
granular activated carbon may be a viable method. Organics diluted with
water can be passed through a carbon column to remove organics from the
liquid. The carbon can be regenerated by several techniques. Polyurethane
and polyolefin are imbibitive polymers available in the shape of spheres,
beads, or foam belts. Polyurethane has an open-pore structure that absorbs a
variety of such liquid chemicals as benzene, chlorinated solvents, epichloro-
hydrin, and phenol, similar to a sponge absorbing water. Polyolefin is simi-
larily used to remove organic solvents, such as phenol and various chlori-
nated solvents. Typically, spheres and beads are mixed into a spill by use
of a blower and are skimmed from the surface by an oil boom. The foam belt
is passed continuously through the liquid and is regenerated by squeezing to
remove the absorbed material for recovery and disposal. "Universal sorbent
material" (USM) is an amorphous silicate glass foam consisting of spheroid
shaped particles with numerous cells and is a suitable sorbent for many
classes of compounds, including acids, alkalis, alcohols, aldehydes,
arsenates, ketones, petroleum products, and chlorinated solvents. Clays and
sawdust can also be used to absorb materials, and are spread, usually over a
small area, with shovels.
31
-------
Gelling agents chemically interact with the sorbate by concentrating and con-
gealing it to form a rigid or viscous material more conducive to mechanical
cleanup than the chemical itself is. The gel components selectively interact
with the appropriate chemicals by polymerization and thickening, as opposed
to sorbents that absorb or adsorb the chemicals. Gelling agents include
polyelectrolytes, polyacrylamide, butylstyrene copolymers, polyacrylonitrile,
polyethylene oxide, and a "universal gelling agent," which is a combination
of these materials. The universal gelling agent can be used to seal narrow
slits in containers, immobilize liquid on land, prevent percolation to the
soil, and reduce the surface spreading of a spill. It can be applied by
mobile dispensing units. The gel is then recovered for subsequent treatment
or disposal.
Foams are mixtures of air and aqueous solutions of protein and surfactant-
based foaming agents. Types of foams include rockwood alcohol, protein,
fluroprotein, aqueous-film-forming foam, polar liquid foam, and surfactant-
based foam. Many of the foams are commonly used for extinguishing flammable-
liquid fires, and as a result have been applied to control spills of highly
volatile and flammable substances. A foam blanket reduces vapor concentra-
tion above the spill surface, decreases the evaporation rate, provides a bar-
rier to thermal or solar radiation, and inhibits ignition or flame propaga-
tion by blocking radiant energy, diluting the spill surface, and absorbing
the vapors. Foam spreading is accomplished by surfactants, which lower the
surface tension of the applied solution. Foams also can be applied through a
water sprinkler system. Foams are normally effective for 30 to 60 minutes
and require reapplication at appropriate intervals to maintain vapor suppres-
sion.
Mitigation Treatment Methods
Treatment is a method of mitigation to reduce the potential impact of a mate-
rial on the water quality, to pretreat a material before ultimate disposal,
or to separate valuable materials for recovery. In order to apply treatment
practices to a spilled material, the material first has to be collected or
contained. Materials to be treated could include dust or dry chemicals,
liquid materials collected in secondary-containment facilities, and contami-
nated storm water collected in diked or curbed areas. Treatment alternatives
that may be considered include a process wastewater treatment plant, a sepa-
rate treatment facility such as a neutralization step, a municipal treatment
facility, or a portable treatment system contained in a trailer or similar
mobile device. The effectiveness of the available system to treat the spill
depends on the rate, concentration, volume, and nature of the toxic and haz-
arous substances involved. Previous testing through a materials inventory
program (base-line BMP) will provide guidance for the appropriate treatment
method or methods. Numerous references, text books, and journal articles are
available that review in detail treatment technologies. For a detailed
description of these treatment processes and the typical design criteria
used, the reader is referred to the references cited in Appendix B under
"Treatment General." While the requirement that specific chemicals receive
32
-------
adequate treatment is within the scope of BMPs, the details of the treatment
systems are normally left to the discretion of the discharger.
Treatment processes can be classified as physical, chemical, biological, and
thermal oxidative processes. Physical treatment processes can be used to
mitigate material spills through removal of floating and settleable mate-
rials, volatile constituents, and dissolved organic materials from the waste-
water. Some of the more popular physical treatment processes that can be
used to treat toxic and hazardous substances include liquid-solids separa-
tion, volatilization, and carbon adsorption. Chemical treatment processes
are used to remove dissolved organics and inorganics from a wastewater and to
adjust the hydrogen or hydroxyl ion concentration for pH control. The more
common chemical treatment processes include chemical coagulation and precipi-
tation, neutralization, ion exchange, and chemical oxidation. Biological
waste treatment is used to remove dissolved organics from wastewater by con-
tact with a concentrated population of microorganisms, which stabilize the
organics to carbon dioxide and water. Thermal oxidation (incineration) is
used to oxidize organics, by controlled burning at high temperatures. A
brief discussion of some of the more common treatment processes is presented
to provide a general understanding of the types and applicability of the pro-
cesses commonly used for treating toxic and hazardous substances.
Liquid-Solids Separation Liquid-solids separation processes are used to
physically separate particulate or floating matter from a wastewater. Some
examples of liquid-solids separation processes include screening, clarifica-
tion, air flotation, filtration, and dewatering. Liquid-solids separation
processes are commonly used as pretreatment prior to other treatment pro-
cesses such as chemical or biological treatment.
Volatilization Volatilization is used to remove volatile constituents in
wastewater. The volatile components of the wastewater are separated to a gas
phase or stream, which can then be recovered or treated by thermal oxidation
(incineration) or chemical oxidation. The gas phase must be collected and
treated to minimize the release of toxic and hazardous vapor releases to the
atmosphere. Some examples of volatilization processes include distillation,
stripping, and evaporation.
Carbon Adsorption Carbon adsorption is used to remove dissolved organics
from a wastewater by the adsorption or attraction of substances to the sur-
faces within the porous structure of the carbon. Granular and powdered acti-
vated carbons are used as adsorbents for wastewater treatment. Carbon
adsorption processes include fixed-bed columns and direct addition and con-
tact with the wastewater in a mixed basin. Carbon can be removed from the
column or basin and regenerated for reuse by thermal processes, solvent
regeneration, or steam regeneration. The organic substance stripped from the
carbon during regeneration can be reclaimed or disposed by some other method
such as chemical or thermal oxidation.
33
-------
Chemical Coagulation/Precipitation Chemical coagulation/precipitation is
used to remove suspended and colloidal particles from solution by adding
chemicals to destabilize the forces that keep colloidal and suspended par-
ticles apart. The destabilized particles, which are aggregated together to
form chemical floes, are removed by such processes as sedimentation or fil-
tration. Some examples of chemical coagulants include aluminum sulfate,
lime, copperas, ferric sulfate, ferric chloride, sodium aluminate, and poly-
electrolytes. In chemical precipitation, which is used for removal of
organic and organic heavy-metal compounds from solution, chemicals such as
calcium hydroxide or sodium hydroxide are added to form an insoluble precipi-
tate. Chemical precipitation is normally followed by liquid-solids separa-
tion for removal of the insoluble precipitate.
Neutralization Neutralization is the addition of an alkali to an acid or
an acid to an alkali to adjust the pH of a wastewater. Examples of neutrali-
zation are adjustment of the pH of a wastewater to a neutral range of about
7.0 as a pretreatment to biological treatment or the adjustment of the pH to
a relatively high level of 10 to 11 for chemical precipitation of heavy
metals. The more common neutralizing chemicals include sodium hydroxide,
calcium hydroxide, and sodium bicarbonate for acid neutralization and sul-
furic and hydrochloric acids for neutralization of alkali.
Ion Exchange Ion exchange is used mainly to remove inorganics; however,
some organics such as phenol and amines can also be removed by ion exchange.
Ion exchange removes these materials by adsorption onto a natural or arti-
ficial resin material such as zeolite or synthetic materials such as styrene
divinyl benzene compounds. Ion exchange resins can be regenerated by using
a solution of the anion or cation used in the resin.
Chemical Oxidation Chemical oxidation is used to completely oxidize
organics to innocuous end products or to partially oxidize organics for
detoxification. Chemical oxidation involves the transfer of electrons from
one species to another. Chemical oxidation can be used for materials that
are not amenable to biological treatment such as organics containing heavy
metals, chlorinated hydrocarbons, and pesticides. Some examples of chemi-
cals used for chemical oxidation include chlorine, sodium hypochlorite,
ozone, hydrogen peroxide, potassium permanganate, and chlorine dioxide.
Biological Treatment Biological waste treatment can be aerobic, anaerobic,
or both, and the microorganisms can be present as flocculated suspensions or
as a fixed film on some support medium. Some examples of biological waste
treatment processes are activated sludges, trickling filters, stabilization
ponds and lagoons, rotating biological contactors, fluidized-bed systems,
and anaerobic filters. Specific toxic substances such as heavy metals and
pesticides can inhibit biodegradation if they are present in the wastewater
at inhibitory concentrations. In some cases, through gradual acclimation,
microbial populations can be specifically adapted for the oxidation of wastes
34
-------
normally resistant to biological degradation. Treatment for pH adjustment
and for removal of suspended solids, oil and grease, and heavy metals is
usually, required preceding biological treatment.
Thermal Oxidation Thermal oxidation can be applied to solid, liquid,
and/or gaseous organic materials and may require control systems such as
flue gas scrubbers to minimize the release of toxic and hazardous vapors to
the atmosphere. Some examples of thermal oxidation systems include the
rotary-kiln, multiple-hearth, and fluidized-bed types. End products of the
oxidation are carbon dioxide, water, and, depending on the nature of the
waste material, hydrogen chloride, sulfur dioxide, and other by-products.
Ultimate Disposition
Ultimate disposition BMPs are associated with the final disposal of a spilled
material. Typical disposal alternatives listed in Table 1 include deep-well
injection, landfills, surface impoundments, ocean disposal, direct discharge
to a receiving water, reclamation of the material, discharge to the munici-
pal sewer system, and contract disposal. BMPs for sludge and hazardous waste
disposal sites, which were considered previously in this chapter as ancillary
sources, have already been discussed under prevention and containment BMPs.
There are a number of detailed references available which discuss ultimate
disposition in detail. A general discussion of ultimate disposition alter-
natives is presented to provide some familarity with the available alterna-
tives for final disposal of a spilled material. For a detailed description
of ultimate disposition techniques the reader is referred to the references
in Appendix B.
When considering ultimate disposition of toxic and hazardous wastes, guide-
lines and criteria set forth in the Resource Conservation and Recovery Act
(RCRA) also need to be addressed. Guidelines and best management practices
for landfills, surface impoundments, and contract disposal are discussed in
proposed RCRA regulations (162).
Subtitle C of the proposed regulations set forth a management scheme that
provides for "cradle to grave" regulations which include: (a) an identifi-
cation and listing of "hazardous wastes" according to specific criteria
(Section 3001); (b) standards of performance (Section 3004) for those who
store, treat, or dispose of such wastes,- (c) permits (Section 3005) for
storage, treatment, and disposal facilities for generators having onsite
waste handling facilities; (d) a manifest system (Section 3002) which
requires labeling by the waste generator to direct and trace the movement of
the waste from point of generation to ultimate disposal; and (3) notification
requirements (Section 3010) for generators, transporters, and treatment,
storage, and/or disposal facilities. The states will be authorized to run
the hazardous-waste program,- EPA will implement it until the states are
authorized.
35
-------
Deep Well Injection Deep well injection is the pumping of toxic and haz-
ardous wastes into a porous and permeable subsurface strata. The wastes are
sealed and confined between impervious strata such as rock or clay to prevent
seepage into groundwater aquifers. The objective of deep well injection is
to place the water in a safe subsurface site where it will not affect the
environment. A difficulty encountered with this practice has been a failure
to prevent seepage of toxic or hazardous waste into the groundwaters and the
subsequent migration of the waste to the surface waters. The EPA has
recently proposed regulations for deep well injection which must be con-
sidered before selecting this disposal method.
Landfill A landfill, in this document, is considered to mean a "secure"
landfill, a term which has come to be associated with landfills for the dis-
posal of hazardous wastes. A landfill operation involves the deposition of
the waste in a controlled manner into a prepared portion of a carefully
selected site followed by spreading and covering or blending with soil.
Landfill sites have been ultimately reused after the site is closed and
properly sealed to prevent release of toxic and hazardous materials. Land-
fills are applicable to liquids, sludges, or solid chemical wastes. Some
examples of secure landfill base materials include bedrock, shale or clay or
material with synthetic liners to prevent seepage to groundwater.
BMPs such as visual inspections, monitoring, and containment are incorporated
at these disposal facilities to protect the environment and human health.
Potential problems associated with these landfills include leaching of mate-
rial into the groundwater with subsequent migration to the surface waters,
contamination of rainwater and runoff, and release of gases and vapors to
the air with subsequent dispersal and contact with surface waters.
Surface Impoundments Hazardous wastes can be disposed to suitable natural
or man-made impoundments such as pits, lagoons, or ponds and other depres-
sions in the land or built-up diked areas. Surface impoundments are nor-
mally uncovered and can utilize natural soil or synthetic liners to prevent
seepage of leachate to the surface or groundwater. Due to the open exposure
to the atmosphere, odor problems can occur and isolation in the form of a
buffer zone is required for aesthetic and public health reasons. The surface
impoundments are more applicable at isolated plants in warmer climates where
the surface impoundment could be utilized as an evaporation pond (if the
contaminant is not volatile) for recovery or final disposition.
Ocean Disposal Ocean disposal of toxic and hazardous wastes is the dis-
charge of these wastes into ocean waters at designated waste disposal areas.
Ocean disposal requires a discharge permit and a monitoring program to deter-
mine the impact of the discharge. Use of this disposal technique for concen-
trated untreated wastes and sludges is discouraged by EPA and may be discon-
tinued in the future. Presently, EPA regulations require all ocean dumping
to be stopped by 1981; however, some extensions may be granted in specific
cases.
36
-------
Discharge to a Receiving Water Discharge of toxic and hazardous materials
to a receiving water may be a feasible alternative, depending upon the water
quality impact and the terms and conditions specified in the NPDES wastewater
discharge permit. Disposal of a spilled material by discharge to a receiving
water would require treatment to levels consistent with applicable effluent
limitations, either in separate treatment facilities or in facilities treat-
ing the plant process wastewaters. Examples of discharge to receiving waters
may include discharge of diluted neutralized acid spills or discharge of a
low concentration of residual organics from a spill material after biological
treatment. Chapter 5 provides a methodology for evaluating water quality
impact and discusses considerations relative to receiving water such as
aquatic toxicity and the temporal and spatial impact of a release of mate-
rial on the receiving water.
Reclamation Reclamation is the recovery of the spilled material for further
processing as a raw material, intermediate, or product. Many spilled mate-
rials, in sufficient volume, are valuable materials and would normally be
reclaimed if economically attractive rather than disposed of to treatment
and disposal sites. Determining the feasibility of reclaiming solids,
liquids, or gases, however, can be a simple or complex problem depending
primarily on the degree of contamination with other chemicals, the nature of
the specific contaminants, the volume, and the frequency of occurrence. In
relatively simple situations, reclaiming the material can be readily accom-
plished. Reclamation of liquids could be feasible where the spill was caught
in a "clean" secondary containment facility. The liquid could be removed by
pumping and transferred to the appropriate material storage tank. "Clean"
solid materials could be reclaimed by an appropriate dry cleanup method fol-
lowed by transfer of the solids to the appropriate material storage tank.
Reclamation could also be attractive in cases where the contaminants do not
diminish the usefulness of the material. Each situation would have to be
evaluated on its individual merits.
Municipal Sewer System For industrial plants which normally discharge their
process wastewater to a municipal treatment facility, this alternative may
also be available for handling material spills. Discharge to the municipal
sewer system would depend on the compatibility of the material with the
municipality's treatment system and local pretreatment requirements. A spill
could be diverted to the normal process wastewater that is treated at the
municipal treatment facility. Pretreatment, such as equalization and neu-
tralization at the industrial site, is commonly required to prevent harm to
the municipal treatment system. The discharge to the municipal system would
have to conform to any applicable pretreatment requirements to avoid exceed-
ing discharge limitations imposed on the industrial contributor. The indus-
try would also need to conduct a routine monitoring and sampling program for
its discharge. The municipality should also be notified prior to any dis-
charge which may be harmful to the municipal treatment plant.
Contract Disposal Contract disposal of waste materials is the ultimate dis-
position of wastes by a second party or contractor for a fee. The contract
37
-------
disposal of hazardous waste must be in accordance with applicable regu-
lations under the Resource Conservation and Recovery Act (RCRA). The outside
contractor and the company should fully understand the obligation and poten-
tial liabilities involved to ensure safe and proper disposal of the material.
Careful consideration has to be given to the experience, responsibility, and
reputation of the contractor prior to selection. Central treatment facili-
ties and waste exchange centers are possible alternatives to contract dis-
posal. Such facilities can offer an expertise in the handling, treatment,
and disposal of hazardous wastes.
In summary, elements that may be applicable for each of the advanced BMPs
include the following:
PREVENTION
Monitoring
Liquid-level detectors
Alarm systems
Pressure and temperature gauges
Pressure-relief devices
Analytical testing instrumentation
Pressure-drop shut-off devices
Flow meters
Valve positioning indicators
Equipment operational lights
Excess-flow valves
Automatic runoff diversion devices
Routine sample collection
Redundant instrumentation
Nondestructive Testing
Hydrostatic pressure tests
Acoustic emission testing
Records of tank wall thicknesses
Labeling
Department of Transportation designation on tanks and pipelines
Color coding of tanks and pipelines
Warning signs
Covering
Tarpaulin over outdoor dry chemical stockpiles
Building or roof over outside process
Vegetation, rock, or synthetic covering on surface impoundments
Pneumatic and Vacuum Conveying
Loading and unloading by air pressure or vacuum
Safety-relief valves
Dust collectors
Air slide trucks and rail cars
Vehicle Positioning
Physical barrier (e.g., wheel chocks)
Underlying drain
Designating loading and unloading area
Dry cleanup
Shovels, brooms, vacuum systems
38
-------
CONTAINMENT
Secondary Containment
Dikes
Curbs
Depressed areas
Storage basins
Sumps
Drip pans
Liners
Double piping
Sewer collection systems
Foam dikes
Leachate collection systems
Flow Diversion
Trenches
Drains
Graded pavement
Grating
Overflow structures
Sewers
Culverts
Vapor Control
Water spraying
Vapor space
Vacuum exhaust
Dust Control
Hoods
Cyclone collectors
Bag-type collectors
Filters
Negative-pressure systems
Water spraying
Sealing
Foamed plastic compounds used for plugging leaks in tanks
MITIGATION
Cleanup Methods
Physical
Brooms
Shovels
Plows
Mechanical
Vacuum systems (e.g., trucks)
Pumps
Pump/bag system
Chemical
Sorbents
Activated carbon
Polyurethane and polyolefin spheres, beads, and foam belts
Amorphous silicate glass foam
39
-------
Clay
Sawdust
Gelling agents
Polyelectrolytes
Polyacrylamide
Butylstyrene copolymers
Polyacrylonitrile
Polyethylene oxide
Foams
Rockwood alcohol
Protein
Fluroprotein
Aqueous-film-forming foam
Polar liquid foam
Surfactant-based foam
Treatment Methods
Liquid-solids separation
Screening
Clarification
Air flotation
Filtration
Dewatering
Volatilization
Distillation
Stripping
Evaporation
Carbon adsorption
Coagulation/precipitation
Neutralization
Ion exchange
Chemical oxidation
Biological treatment
Thermal oxidation
ULTIMATE DISPOSITION
Deep-Well Injection
Landfill
Surface Impoundments
Pits
Ponds
Lagoons
Ocean Disposal
Discharge to a Receiving Water
Reclamation
Municipal Sewer System
Contract Disposal
40
-------
SECTION 4
CLASSIFICATION OF TOXIC AND HAZARDOUS SUBSTANCES
INTRODUCTION
A classification of individual toxic and hazardous substances was developed
for relating BMP alternatives to groups of toxic and hazardous substances.
Review of the information collected on BMPs indicated that specific BMPs are
related to the physical and chemical characteristics of substances and there-
fore apply to groups of substances with similar characteristics rather than
exclusively to a specific chemical compound.
This section presents a classification for the 129 materials classified as
priority pollutants and the 299 compounds classified as hazardous compounds
described in Section 1. Of the 299 hazardous substances listed, 126 com-
pounds are included on by the priority-pollutant list, leaving 173 compounds
classified as hazardous compounds only. The combined list of 302 compounds
was evaluated in developing the classification.
Several methods of classifying toxic and hazardous substances were reviewed.
These classifications systems included the following: Department of Trans-
portation Hazardous Materials Designation Method (DOT) (119),* Standard
Transportation Commodity Codes (STCC) (119), Modified IMCO/Gesamp Methodology
Classification (119), EPA Physical/Chemical/Dispersal Method (119), EPA
Toxicity Classification Method (21), National Fire Protection Association
Hazardous Identification System (121), Hazardous Potential Index (119), Envi-
ronmental Impact Index Manufacture and Distribution Factors (119), Environ-
mental Hazard Index (119), Rice University Classification by Chemical Family
Groups (50), and Allegheny Sanitary Authority Classification (48). These
classifications are based on such parameters as transportation hazards,
physical and chemical properties (i.e., density, volatility, and solubil-
ity), aquatic toxicity, hazards related to fire prevention and control,
quantity of chemical manufactured, and chemical family. These classifi-
cations apply mainly to the hazardous substances,- only a few of the priority
pollutants are included. Several of the physical and chemical properties
identified in these classifications were considered to be important in
identifying BMP alternatives. These properties include the physical state
(solid, liquid, or gas) and the physical and chemical characteristics of the
substances, such as human toxicity, flammability, corrosiveness, reactivity,
and volatility. These same physical and chemical characteristics of sub-
stances are commonly important design considerations safety and fire pro-
tection programs and can be similarly useful for BMPs.
41
-------
The first grouping of the compounds was based on the physical state of the
compound at normal temperatures and pressures [20 to 25°C, 1 X 10 Pa
(1 atm)]. Of the 302 chemicals, 175 are solids, 111 are liquids, and 16 are
gases. The chemical's physical state will directly determine which BMPs may
be applicable to the chemical. For example, the BMPs used for the cleanup
of liquids will differ from those used for solids or dry chemicals. Solids
are normally cleaned up by physical and mechanical methods before being pro-
cessed for recovery.
Table 2 lists the classifications developed based on the important physical
and chemical characteristics of the compounds. The following chemical group
definitions were obtained from the chemical classifications systems reviewed:
CHEMICAL GROUP DEFINITIONS
Human Poisons (119)
All substances poisonous to humans are ranked as Class A or Class B poisons
by the Department of Transportation, which are defined as follows:
Class A A poisonous gas or liquid which, when mixed in small amounts with
air, is dangerous to life.
Class B A substance, liquid or solid, known to be so toxic to man as to
constitute a hazard to health during transportation or presumed to be toxic
to man because it falls within any one of the following categories when
tested on laboratory animals:
Oral toxicity: a single dose of 50 mg or less per kilogram of body weight
when administered orally produces death within 48 hr in half or more than
half of a group of 10 or more white laboratory rats weighing 200 to 300 g.
Toxicity on inhalation: continuous inhalation for 1 hr or less at a con-
centration of 2 mg or less per liter of vapor, mist, or dust produces death
within 48 hr in half or more than half of a group of 10 or more white labora-
tory rats weighing 200 to 300 g.
Toxicity by skin absorption: when administered by continuous contact with
the bare skin for 24 hr or less produces death within 48 hr in half or more
than half of a group of 10 or more rabbits tested at a dosage of 200 mg or
less per kilogram of body weight.
42
-------
Table 2. Chemical Group Classifications
Liquids
Solids
Gases
HP - Human poisons
Fl - Flammables
C - Corrosives
R - Reactives
V - Volatiles
F - Floaters
BT - Amenable to BWT*
B - Biodegradeables
A - Highly toxic to
aquatic life
HP - Human poisons
Fl - Flamnables
C - Corrosives
R - Reactives
BT - Amenable to BWT*
B - Biodegradeables
S - Solubles
A - Highly toxic to
aquatic life
HP - Human poisons
Fl - Flammables
C - Corrosives
R - Reactives
A - Highly toxic to
aquatic life
*Biological waste treatment.
43
-------
Flammables (119)
Flammables are any liquid that have a flash point below 100°F (38°C). Any
solid liable to spontaneous ignition in air, including solids that react
with air or the moisture in air to produce extremely flammable products; and
any solid liable to ignition in air by friction or slight heating, including
solids that react with air or the moisture in air to'produce flammable
products.
Corrosives (119)
Corrosives are defined as any substance that significantly chemically attacks
common metals or metal alloys, including ferrous metals. [This definition
and the designations of specific chemicals as corrosive are from the Rice
report (119). Rice utilized designations provided by the Department of
Transportation where available. DOT defines a corrosive material as a
"liquid or solid that causes visible destruction or irreversible altera-
tions in human skin tissue at the site of contact, or in the case of leakage
from its packaging, a liquid that has a severe corrosion rate on steel"; and
"a liquid is considered to have a severe corrosion rate if its corrosion rate
exceeds 0.250 inches per year on steel (SAE 1020) at a test temperature of
130°F.]
Volatiles (119)
All chemicals with vapor pressures greater than 1.3 X 103 Pa (10 mm Hg) at
10°C are defined as volatiles.
Floaters (119)
Floaters are all materials that will float on the surface of water in a
spill situation and all chemicals with solubilities of less than 1% and spe-
cific gravities of less than 1.0.
Reactives (121)
Reactive materials are defined as those materials which in themselves or in
contact with water are readily capable of detonation or of explosive decom-
position or explosive reaction at normal temperatures and pressures and as
44
-------
those materials which are sensitive to mechanical or localized thermal shock
at normal temperatures and pressures.
Solubles (119)
Solubles are solids with solubilities in water of greater than 0.1% or 1000
ppm.
Solids or Liquids Amenable to Biological Treatment (48, 49, 109, 126)
These compounds are defined as those which, while not necessarily biodegrad-
able, are amenable to biological waste treatment in that they can be
accepted into biological waste treatment systems without causing adverse
impact on treatment of the pollutants normally present. Compounds in this
classification group would have to be fed to biological treatment systems at
rates so as not to cause a toxic or inhibiting effect on the treatment
process.
Biodegradables (48, 109, 126)
Compounds that can be degraded by microorganisms to normal biological end
products, such as carbon dioxide and water, are considered to be biodegrad-
able. Biochemical oxidation requires an acclimated seed of microorganisms
and dilution of the chemical compounds to levels that will not be toxic or
inhibitory to the microorganisms.
Compounds Highly Toxic to Aquatic Life (20)
Compounds that have an LC,. (concentration of material that is lethal to
one-half of the test population of aquatic animals upon continuous exposure
for 96 hr or less) of less than 1 mg/liter are considered to be highly toxic
to aquatic life and include all compounds classified as X and A by EPA Clas-
sification of hazardous substances (20).
45
-------
CLASSIFICATIONS
The toxic and hazardous substances classified as solids, liquids, or gases,
as well as their chemical and physical characteristics, are given in
Tables 3, 4, and 5 respectively. The physical state of the particular sub-
stance is based on the pure chemical form in the absence of information on
its use at a particular plant. Some of the compounds listed as solids and
gases may in reality exist in solutions with solvents and/or water. These
compounds are identified in Tables 4 and 5 and may be listed under more than
one physical state classification. Examples are phosphoric acid, sodium
hydroxide, and formaldehyde. In the absence of data several compounds were
grouped in the same categories as the chemical family. Assumed groupings
are so noted in the tables.
In evaluating BMP programs the use and/or occurrence of the chemical at a
particular facility has to be determined so that the appropriate chemical
group can be defined. Some of the compounds are characterized by more than
one group, whereas others are basically classified as solids or liquids
since they do not have any of the special features of the chemical groups.
In Tables 3, 4, and 5, the chemical compound under consideration is classi-
fied according to the appropriate chemical grouping or groupings. After the
appropriate chemical group or groups have been determined, the approach pre-
sented in Section 5 can be used to determine which BMP alternatives are
applicable as a function of the chemical group and the ancillary source.
Review of the classifications and the BMPs for the 302 compounds indicated
that the number of chemical groups important to the evaluation and selection
of BMPs depends on the nature of the specific BMPs. Less information will
be required to identify BMPs for prevention and containment of a substance
than in adequately define BMP alternatives for ultimate disposition of the
substance. For example, the important properties to be considered when BMPs
are evaluated for prevention and containment are the physical state, vola-
tility, reactivity, and corrosiveness of the substances. When treatment and
ultimate disposition BMPs are to be evaluated, important additional
properties, which are unrelated to prevention and containment BMPs, should
be considered. These properties include biodegradability, specific gravity,
and aquatic toxicity.
46
-------
a
Table 3. Liquid Group Classification
Liquid
Acetaldehyde
Acetic acid
Acetic anhydride
Acetone cyanohydrin
Acetyl bromide
Acetyl chloride
Acrolein
Acrylonitrile
Allyl alcohol
Allyl chloride
Ammonium hydroxide
Amyl acetate
Aniline
Benzene
Benzonitrile
Benzoyl chloride
Benzyl chloride
Bis (chloromethyl) ether
Bis (2-chloroisopropyl) ether
Bis (2-chloroethoxy) methane
Bis(2-chloroethyl) ether
Bis(2-ethylhexy) phthalate
Bromoform (tnbroroomethane)
Butyl acetate
Butylamine
Butyl benzyl phthalate
Butyric acid
Carbon disulfide
Carbon tetrachloride
Chlordane
Chlorobenzene
Chlorodibromo me thane
Chloroe thane
2-Chloroethyl vinyl ether
Chloroform
o
4J
(n V flj
3 •-> > o o
c in to in -H -H
o c E o -u 4J
n rc E n o in
-H E fti ^ (0 f-t
o 3 •-< o o o
cu a: b. u a; >
- X - - X
- - X - -
- - X X -
X - - - -
---XX-
X - X X
X X - X X
- X - - X
X X - - X
X X - - X
- - X - -
- X - - -
X - - - -
X - - X
-----
- - X X -
— - X - -
X - - - X
- - - - X
b b b b b
X - - - X
X - - - X
-----
X
- X - - X
-----
- - X - -
- X - - X
X
_
- X - - -
- - - - x
X X - - X
X - - X
X
111
4J
n
O
b.
-
-
-
-
-
-
-
-
-
X
-
X
-
X
-
-
-
-
-
b
-
X
-
X
-
-
-
-
-
-
-
-
X
-
-
1 C
O a>
'H B
o u
•4J ^4
EH
a
xi n
a u
C -H
o o>
e o
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
^
X
X
-
-
X
X
X
X
-
-
-
X
-
X
X
X
t-t
o
o
T3
a
a>
-)
>< -H
c. a
0> D
x <
-
-
-
X
-
-
X
-
-
-
-
-
-
-
-
-
-
ND
ND
ND
ND
ND
ND
-
-
-
-
-
-
X
-
ND
ND
ND
ND
3X denotes chemical is in this category, - denotes chemical is not in this category,
ND denotes no data available.
Assumed values, based on chemical groups of similar type substances.
47
-------
00
g
0*
ft
rt
3-
H-
O
3
1
1
1
1
1
1
1
1
X
w M a: i a: ••) "J
V) W *< *•< ft C O
o o a. a x M n
M 3" O O O C H
fl> O rti O P' 1 fl
3 »1 (-• ST h- Oi
O O C t-» O J-1 Cu
ro i M o H
o n c
rt
o o a
p. H- H-
0j D- O
w. w. ^
It
1 1 1 1 1 1 1
X 1 1 1 1 1 1
1 1 X X 1 X X
1 1 1 1 1 1 1
X 1 1 1 1 1 1
X X 1 1 1 1 1
X X X X X X X
XXI 1 1 X X
1 Z 1 1 Z 1 1
D O
PlP!P)MMMaOC1OOOOai-'*J>-' >-•
3-3-3-3-1- a a w i i 3 t t o ia to to -» !-•
•<•<•< H. O1ltcl3|3(trtrt3-| 1 lJ>Ji-JO3-H nPlI rt3'3'l-'DDDHD
33(t o 'ionc'<»j>-'nnnn' O.
a
IXIIXIIXIXIIIIXII 1
XIXIXIIIIIIIXIXIX X
IXIIXIXIIIIIXXIXI 1
1 1 t 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
IXXIIIIIXXXXXIX'X X
1 1 X 1 1 1 1 1 1 1 1 1 X 1 1 1 1 I
XXXIXIXIXXXXXIXIX 1
tr
XXXIXIXIXXXXXIXIX 1
tr
i i IXIXZZEZZZZXIZI z
oaaoooD D o
l-'t-Ono*-w
MMO wMoio o ^nn
i 1 3" t I N 1— ' 3 O P ^
??s:p;35§-c:ss'5-
S-5-S8-3-§xS^33
oonoo aat-h^fD-
HHOMM OroOCuCa
g S § & cr H 11
rt rt 3 ID m ani-t-
tr 3- (D 3 3 "'mm
01 BI rt N N S S.
3 3 tr It It 2 ?
0 » P 3 3 K' 2
y it n> D- .9
it ^,
It
ft
3-
(t
1 1 1 1 1 1 1 X 1 X, X
tr tr
XXI 1 1 1 X X 1 II
tr *-i
1 1 1 1 1 1 1 X X I I
tr tr
1 1 1 1 1 1 1 1 X I 1
cr tr
XXI 1 1 1 X X 1 Xg. I
1 1 1 1 1 1 X X 1 1 I
tr
XXIXXIXXX'X
XXIXXIXXXIX
1 Z Z 1 1 Z X 1 Z 1 1
D a D o
-,
'^,
Poisonous to
Humans
Flammable
Corrosive
Reactive
Volatile
Floater
Amenable to Bio-
logical Treatment
Biodegradeable
Highly Toxic to
Aquatic Life
i-3
0)
cr
m
U)
O
0
3
rt
H-
3
C
(V
-------
Table 3. (Continued)
o
(/} (1) O
3 r-< > 0
c in
O
•H
m
-
X
-
X
-
X
-
-
X
X
-
-
X
X
X
-
X
-
-
-
-
-
-
X
X
X
X
X
X
X
X
X
X
o
U 01
•H U-t
X -H
O ->
>1 -H
•-H 4J
£ 10
C> 3
•H
-------
Table 4. Solids Group Classification3
Solid
Acenaphthylene
Acenapthene
Adipic acid
Aldrin
Aluminum sulfate
Ammonium acetate
Ammonium benzoate
Ammonium bicarbonate
Ammonium bifluoride
Ammonium bisulfite
Ammonium carbarnate
Ammonium carbonate
Ammonium chloride
Ammonium citrate dibasic
Ammonium fluoborate
Ammonium fluoride
Ammonium oxalate
Ammonium silicof luoride
Ammonium sulfamate
Ammonium sulfide
Ammonium sulfite
Ammonium tartrate
Amraonium thiocyanate
Ammonium thiosulfate
Anthracene
Antimony
Arsenic
Asbestos
1 , 2-Benzanthracene
Benzidine
3 , 4-Benzof luoranthene
11 , 1 2- Benzof luoranthene
Benzole acid
3 , 4-Benzopy rene
Q
4J
W
3 0 0
a •-< >
c at -a -1
O c n m
™ g i °
01 •"" b O
-
-: X
- - X
X
_
_
_
-
_
-
-
-
- - -
_
_
-
_
-
_
- X -
- - -
-
-
-
-
X - -
X - -
_
b
-
- - -
-
-
-
D
•§
o
in
-
-
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-
-
-
-
-
X
-
-
-
-
JJ
( C
O 0
03 jj
10
O 0
a
r-t rH
f*l nj
a o
C -H
E O
-
-
X
-
X
X
X
X
X
X
X
X
X
X
xb
X
X
xb
X
X
X
X
X
X
-
-
-
ND
-
X
-
-
X
-
01
ft)
•o
Hi a
> l<
JJ Q)
0 -O
ft) o
O -H
Ce: CO
-
-
X
-
-
X
X
-
-
-
X
-
-
X
-
-
X
-
X
-
-
X
X
-
-
X
-
ND ND
- -
X
-
-
X
-
0
U D
X -H
0
>, -rt
~H AJ
.= CJ
- <
-
ND
-
X
-
-
-
-
-
-
-
-
-
-
-
-
_
-
-
_
-
-
-
-
ND
-
-
ND
ND
ND
ND
ND
-
ND
X denotes chemical is in this category, - denotes chemical is not in this category.
ND denotes no data available.
Assumed values, based on chemical groups of similar type substances.
Normally exists as liquid solution.
50
-------
Table 4. (Continued)
o
4J
w o
3 t-J
0 jj
CM To
O C E
M fl g
•^ E ra
Solid £ •* C
1,12-Benzoperylene
Beryllium X
a-BHC (hexachlorocyclohexane) x
6-BHC (hexachlorocyclohexane) x
A-BHC (hexachlorocyclohexane) x -
4-Bromophenyl phenyl ether
Cadmium
Calcium carbide - X
Calcium dodecylbenzenesulfonate - -
Calcium hydroxide
Calcium hypochlorite
Calcium oxide - -
Captan
Carbaryl
Carbofuran ND ND
2-Chloronapthalene -
Chromium
b b
Chrysene - -
Cobaltous bromide
Cobaltous formate
Cobaltous sulfamate -
Coumaphos X
Copper
Cresol X
Cyanide X -
1,4-Dichlorobenzene - -
2,4-Dichlorophenoxy acetic acid - -
2,4-Dichlorophenoxy acetic - -
acid esters
4,4' -ODD *
4, 4 '-DDE X
DDT x
b b
1 , 2 , 5 , 6-Dibenzanthracene
Dicamba
Dichlorbenil
Dichlone
3,3'-Dichlorobenzidine
2 ,4-Dichlorophenol
0
•H 111
in rH
2 11
0 O
(j en
-
-
-
-
-
-
-
X
X
X
X X
X
X
-
ND ND
-
-
b
X
X
X
— —
X
-
-
-
X
X
-
~ ~~
X
b _b
X
X
X
-
-
XI
1 C
o n
o u o
o u ja
u !* a
f" •O
0) Q) 10
^ ~i > it
j% ro *H cn
10 O W CJ
c -i o "a
O D1 10 O
15 £ 3
_
_
x - x
X - X
X - X
-
_
X
xb - xb
X - -
X - -
XX-
_
- - -
ND ND ND
X - X
_
b
_
-
_
b b
X - -
X - X
XXX
X - X
-
-
b "
b _ _b
-
b
~
— - —
-
- - -
X - X
X - X
o
O a
X -H
P *3
0
>, -H
jc a
O> 3
-H O*
ND
-
X
X
X
ND
-
-
-
-
-
-
X
-
X
ND
-
ND
-
-
-
X
X
ND
X
-
-
-
ub
X
xb
X
ND
—
-
X
ND
ND
51
-------
Table 4. (Continued)
Solid
Dieldrin
2,4- Dime thy Iphenol
Dinitrobenzene
4 , 6-Dinitro-o-cresol
2 , 4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
1 ,2-Diphenylhydrazine
Diquat
Diuron
Chlorpyrifos
Endosulfan sulfate
d-Endosulfan
B-Endosulfan
Endrin
EDTA
Ferric ammonium citrate
Ferric ammonium oxalate
Ferric chloride
Ferric fluoride
Ferric nitrate
Ferric sulfate
Ferrous ammonium sulfate
Ferrous chloride
Ferrous sulfate
Fluroanthene
Fluorene
Fumaric acid
Guthion
Heptachlor
Heptachlor epoxide
Hexachlorobenzene
Hexachlorocyclopentadiene
Hexachloroethane
Indeno (l,2,3-c,d) pyrene
Isopropanolamine
dodecylbenzenesulfonate
o
W OJ o
O J3 -H 01
c m a in ^
o c g o J3
in
X - - X
-
- - - x
X - - -
-
b
_b b b b
b b b b
X
X
- - - X
- - - X
- - - X
- - - X
- - - X
- — — -
- - - X
_
- - X X
- - - X
X
- - - X
- - - X
- - - X
X
-
- - -
- - X X
X
X - - X
x - - -
_
_
_
b b _b _b
X
1 C
O 0
••4 c
O 4->
nj
O
fr-
OI
r-* r-t
(0 O
C -H
I JD
-
X
-
X
X
X
X
-
-
-
-
-
-
-
-
b
X
X
X
X
X
X
X
X
X
X
-
-
X
X
-
b
-
X
-
-
xb
o
4J
u
-H O O
.3 H M-)
•a o J
01 c H
> l< 0
AJ CJ *H 4J
o -a £ n
ai a = <
- - x
X HD
-
- X ND
X X HD
X
-b x
b
HD
-
-
- - ND
- - X
- - X
- - X
- - X
b
X
- X -
- X -
-
-
-
- - -
-
-
-
ND
- - ND
- X -
X X
- - X
b
ND
ND
- - X
- ND
-b - HD
- X ND
52
-------
Table 4. (Continued)
Solid
Kel thane
Kepone
Lead
Lindane
Maleic acid
Maleic anhydride
Mercaptodimethur
Mercury
Methoxychlor
Methyl parathion
Naled
Napthalene
Nickel
2-Ni'Crophenol
4-Nitrophenol
N-nitrosodiphenylamine
Nitrotoluene
Parachlorometa cresol
Para formaldehyde
Phenanthrene
Pentachlorophenol
Phenol
Phosphoric acid
Phosphorus
Phosphorous pentasulfide
Potassium hydroxide
Potassium permanganate
Propargite
Pyrene
Pyrethrins
Resorcinol
Selenium
Silver
Sodium
Sodium bifluoride
Sodium bisulfite
0
" " >
o c "« "" •-*
™ 2 i 8 •§
M a 8 s
_
X - - -
- - -
- - - X
X
- - - X
X ND ND
X - - -
X
X - - X
- - X X
- - -
- - - -
X - - X
X - - X
X - - -
X - - -
- - - X
- - - X
-
X - - -
'X - - X
X X
X
X - X
X
- - - X
ND ND 1JD
b b b
X
X
- - - X
_ _ _
_
- X - X
- - - X
- - - X
Amenable to Bio-
logical Treatment
X
-
-
-
X
X
X
-
-
X
-
X
-
X
X
-
X
X
X
X
-
X
X
X
X
X
X
ND
b
-
-
-
ND
X
X
X
Reactive
Biodegradable
X
-
X
-
X
X X
X
X
-
X
X
X
-
X
X
-
X X
X
X X
X
-
X
-
-
X
-
-
ND
b
-
-
-
-
X
-
-
o
o o
X "-*
e J
o
>, -H
X (3
•H C"
-
X
-
X
-
-
X
X
X
X
X
-
-
-
-
ND
ND
ND
-
ND
X
-
-
-
-
-
-
ND
ND
-
-
-
X
-
-
-
53
-------
Table 4. (Continued)
Solid
Sodium dodecylbenzenesulfonate
Sodium fluoride
Sodium hydrosulfide
Sodium hydroxide
Sodium hypochlorite
Sodium methylate
Sodium nitrite
Sodium phosphate dibasic
Sodium phosphate tribasic
Strychnine
Thallium
2,3,7, 8-Tetrachlorodibenzo-p-
dioxin (TCDD)
Toxaphene
Trichlorfon
2,4, 6-Trichlorophenol
Poisonous to
humans
Flammable
-
-
-
-
-
-
-
-
-
X
X
X
-
-
-
Corrosive
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Soluble
X
X
X
X
X
X
X
X
X
-
X
-
X
X
-
4J
.2 1
tn oj cj
a -i
O ~J ^
JJ V< TJ
E- TJ
O 0) 10
^t r~* > ^
ja ro -H CP
(0 U -U OJ
c •- o t>
E O fl> -H
2 -i <£ Q
xb - xb
X - -
X - -
X - -
X - -
XXX
X - -
X - -
X - -
-
ND X ND
_
-
- - -
X - X
o
Highly Toxic
Aquatic Life
-
-
-
-
-
-
-
-
-
X
-
ND
X
X
X
2,4,5-Trichlorophenoxy acetic X - -
acid
2,4,5-Trichlorophenoxy acetic - - - -
acid, esters
b b
2-(2,4,5-Trichlorophenoxy) - - X - - - -
propanoic acid
2-(2,4,5-Trichlorophenoxy) - - X - - - -
propanoic acid esters
2,4,5-Trichlorophenoxy acetic - - - X - - -
acid, sodium salt
b b
Triothanolamine - - - X X - X
dodecylbenzenesulfonate
Uranyl acetate (radioactive) x - - -
Uranyl nitrate (radioactive) - - - X - -
Vanadium pentoxide - - - X
Vanadyl sulfate - - - X
Xyleneol - - - X X - X
b b
Zectran (Mexacarbate) X - - X - - -
Zinc - - - X X X -
Zirconium nitrate - - - X - - -
Zirconium potassium fluoride - - - X
Zicronium sulfate - - - X
Zicronium tetrachloride - - X X - X
54
-------
a
Table 5. Gases Group Classification
Gas
Ammonia
Chlorine
Cyanogen chloride
o
-P
in
3
o
C en
0 C
tn rt
•H 6
0 3
f\i |TJ
-
X
X
OJ
rH
•a
5
fl3
rH
Hi
-
-
X
0)
j>
•rH
0
J_l
o
o
X
-
-
0)
•r-l
4J
0
(0
a)
05
-
-
-
o
4-1
0 Q)
•H m
X -rH
0 i-q
0
iH -P
X
-------
SECTION 5
METHODS FOR EVALUATING BMP PROGRAMS AND PRESCRIBING BMP ALTERNATIVES
This section provides both industry and NPDES permitting authorities with
guidance on developing BMPs and evaluating BMP programs. The measure of the
success of the BMP program is its effectiveness in preventing environmental
incidents. Certain minimal requirements are essential to a good BMP program.
Methods for evaluating BMP programs are presented in this section to aid the
user in making BMP decisions. Although this information will be useful to
permittees and permitting authorities, it cannot be used as a substitute for
sound engineering judgement and knowledge of the particular circumstances of
the facility under consideration.
EVALUATION OF A BMP PROGRAM
A company's BMP program may be evaluated by the permitting authority for a
number of reasons, including a recent spill of toxic and/or hazardous sub-
stances to navigable waters, a history of incidents, a citizens complaint, a
fishkill, or an application for a renewed or a new NPDES discharge permit.
Since the extent of practices utilized at a particular site is directly
related to factors such as plant size and location, topography, specific
chemicals, ancillary sources, water quality impacts, and quantity of mate-
rials on-site, there may be differences in advanced BMPs used by facilities.
However, all BMP programs should include the minimum requirements of the
base-line BMPs and of the advanced BMPs where necessary. A BMP program
should be reviewed for these requirements. Although this study reviews a
great number of the BMPs currently used by industry, there may be others
that are acceptable in some instances. These practices would have to be
evaluated by the user for effectiveness and applicability.
A step-wise approach has been developed for the evaluation of a BMP program,
and is shown in Fig. 1. Figure 1 must be used in conjunction with Table 6,
which lists the questions associated with each block and the aids recom-
mended for reaching a decision on whether to accept or reject the BMP pro-
gram.
56
-------
Minimum Requirements
The minimum requirements of a BMP program are listed in Table 7. The BMP
program should be put together and described in an orderly narrative docu-
ment format and should be reviewed by the plant engineering staff. A
description of the facility, including the type of plant and the products it
manufactures, should be included in the document and a map should be given
showing the location of the facility and the adjacent receiving waters. The
document should include a statement of the objectives of the BMP program,
including the prevention of the release of toxic and hazardous substances to
the receiving waters. An evaluation or description of the potential risks
of a spill from the plant to the receiving water should be included and
should identify any sources that, in the event of a spill, could result in
discharge to the receiving water. A final requirement is that all the base-
line BMPs discussed in Section 3 and listed in Table 7 be addressed to some
degree in the document. The base-line BMPs are primarily procedures for
certain events and/or operations. They are broadly applicable to all indus-
tries and would be included in any effective BMP program. If any one of
these items is not in the program, the reason for the omission should be
explained. The BMP program should be considered as inadequate if all the
requirements are not fulfilled or until reasonable explanations are given for
the omission.
Questions for Evaluating Minimum Requirements in BMP Programs
The following list of questions is provided to assist the document user in
evaluating whether the minimum requirements of a BMP program have been met.
1. Does the facility have a BMP program in a narrative form?
2. Has the BMP program been reviewed by the responsible facility officials
and plant engineers?
3. Was the BMP program developed by the engineering staff?
4. Who should be contacted for further technical details on the BMP pro-
grams?
5. Was the program submitted as part of the facility's current NPDES per-
mit application?
6. Has the BMP program been implemented within one year of the date of the
facility's current NPDES permit?
7. Has the BMP program been amended since its initial development?
8. Is the BMP program readily available for review?
9. Does the overall program appear to be comprehensive, understandable,
and well organized?
10. Is the senior engineer or another technical person at the facility
familiar with the program, its implementation, status, and effective-
ness?
11. Are the people trained in BMP use?
57
-------
NO
NO
YES
NO
NO
YES
YES
YES
YES
NO
Accept**
YES
YES
YES
Accept
NO
Accept
Accept
*Rejection would require company to modify program satisfactorily
and then resubmit.
**Acceptance always implies that acceptance is subject to review
if the BMP program is changed, if the sources subject to BMPs
are changed, or if incidents occur.
Fig. 1. Decision Tree for BMP Program Evaluation
(To be used in conjunction with Table 6)
58
-------
Table 6. Questions and Decision Aids Relative to
Decision Tree Shown in Fig. 1
Block
No.
Question
Decision Aid
1 Does BMP program fulfill
minimum requirement?
2 Does company satisfactorily
justify less than minimum
BMP program requirements?
3 Does company have history
of incidents?
4 Are reasons for the
spill(s) known?
5 Have satisfactory cor-
rective actions been
taken to minimize
risk of repeat?
6 Are base-line BMPs ade-
quate?
7 Are satisfactory changes
to base-line BMP program
being made?
8 Are advanced BMPs included
in program or needed?
Are advanced BMPs in the
program satisfactory?
Use Table 7 for requirements; use
question for evaluating minimum
requirements in BMP program
Primary responsibility of company to
satisfy user
Review historical spill data from
company and in EPA and state files
Review available incident analyses
and data from company, EPA, and
state files
Primary responsibility of company to
satisfy user through documentation,
site visits, incident analyses
Use questions in text for evaluating
base-line BMPs
Primary responsibility of company to
to satisfy user
Review incident analyses; use Table 8
for advanced-BMP alternatives based
on industry practice,- consider
potential water quality impact; use
questions in text for evaluating
the impact on the water quality
Use Table 8 for advanced-BMP alterna-
tives; use questions in text for
evaluating advanced BMPs
59
-------
Table 7. Minimum Requirements of a BMP Program
Statement of facility policy
Narrative document format
Reviewed by plant engineering staff
Description of facility
Statement of company objectives of the BMP program
Evaluation of risks of potential spills
Base-line BMPs
Spill Control Committee • Visual inspection
Spill reporting • Preventive maintenance
Material inventory • Good housekeeping
Employee training • Materials compatibility
Security
60
-------
12. Is there a description of the plant facility with a location map? Are
the adjacent receiving waters, outfall loations, and drainage patterns
shown?
13. Does the BMP program state the objectives for control of toxic and haz-
ardous substances?
14. Does the BMP program include an evaluation of the potential risks of
spills from the various locations of toxic and hazardous substances?
15. When a reasonable potential for a spill exists, are the quantity, rate
of flow, and predicted direction of flow described?
16. Does the BMP program description include past spills, causes, contain-
ment and mitigation steps utilized, and revisions to the BMP program or
spill plan to prevent recurrence?
17. What are the ancillary sources associated with the various locations of
toxic and hazardous substances?
18. Does the plant have a Spill Prevention and Countermeasure Plan (SPCC)?
19. What base-line BMPs are identified in the BMP program (see Fig. 1)?
Which base-line BMPs are not mentioned?
20. What BMPs or spill prevention and containment measures are mentioned in
the SPCC plan?
21. Is there a recognition of the need to periodically review and update
the facility's BMP program as manufacturing conditions and applicable
federal and state regulations change?
Assessment of Incident History
As discussed previously, an important criterion in determining the effective-
ness of a BMP program is the history of incidents at the plant. A history
of no incidents suggests that the practices and procedures at the site are
effective. Review of past incident data should be part of every BMP program
evaluation. If the BMP program meets the minimum requirements and the plant
does not have a history of incidents, the BMP program generally would be
considered to be adequate.
For a plant site with a history of incidents it is important to investigate
the reasons for the spills and the response of the company in minimizing the
potential of a recurrence. Are the reasons for the spills known? A review
should be made of available incident or spill analyses, as well as other
data provided by the company or available from EPA or state files. What was
the impact on water quality? Was it minor or substantial? Has the facility
demonstrated good-faith efforts to prevent a recurrence. This aspect should
have bearing on the company's response and should be considered in judging
the adequacy of the corrective actions taken. An example of corrective
actions that can be taken concerns a company that had several incidents in
which sulfuric acid, used as pickling acid, was released from a badly cor-
roded pipeline in an old pipeway on the riverbank. Sulfuric acid is the
only hazardous substance handled in bulk at the plant. Following the last
incident, the company replaced the plant manager, hired a contractor to per-
form thickness testing on their acid tanks, installed redundant level alarms
on the tanks, replaced and rerouted the pipeline away from the riverbank,
61
-------
and instituted a visual inspection program and operator training in spill
prevention and control.
Did the company take satisfactory corrective action to prevent a recurrence?
The company should have the primary responsibility for satisfying the user
through documentation, site visits, or incident analyses that the corrective
action is adequate and the probability of another incident is small. The
user may consider accepting the program at this point in the evaluation if
satisfied that it can be effective. Otherwise, further evaluation is
required.
Evaluation of Base-Line BMPs
The next step, assuming that all the minimum requirements for a BMP program
have been met, is to evaluate the adequacy of the base-line BMPs. At this
point the user must determine whether changes are required in the base-line
BMP program. For example, a facility may have a visual inspection program,-
however, the frequency of inspection may be inadequate if a spill, which
should have been predetermined and corrected, was not identified in the
inspection and reported according to predetermined spill reporting proce-
dures.
For a plant with a good pollution control program the BMP program would
probably include minimum requirements and possibly some of the less expens-
ive advanced BMPs, such as those associated with prevention and/or cleanup.
However, the adequacy of the BMP program can be evaluated only after con-
siderable review of the plant's program relative to the BMP program and the
spill control plan, spill (incident) history, the materials inventory (quan-
tity and location), the potential spill impact on the receiving water, the
effectiveness of the current program, and the cost to implement a detailed
control and countermeasure program. Again, the company should bear the
responsibility for demonstrating that any inadequacies in the base-line BMP
portion of the plan have been or are being corrected.
To assist the user in evaluating the extent and effectiveness of the base-
line BMPs, the following list of questions is provided. These questions are
not to be used to evaluate a BMP program by tallying the number of "Yes" or
"No" answers, but rather are to be used as a guide in assessing the extent
and effectiveness of the base-line BMPs.
Spill Control Committee --
1. Is there a clear statement of the management's policy with respect to
BMP-related matters?
2. Is there a clear statement of who is responsible for BMP-related matters?
3. Is the responsible party aware of his or her BMP-related responsibili-
ties?
4. Has a spill control committee been assigned responsibilities for the
BMP program? What are the Committee's duties (spills, safety, environ-
mental control)?
62
-------
5. Is a list of personnel responsible for spill control (i.e., foreman,
area supervisor, department manager, safety coordinator, environmental
control coordinator) provided?
6. Are the appropriate office and home telephone numbers of the committee
indicated?
7. Are these personnel available at all times? Are backup people listed
with phone numbers?
Spill Reporting
1. Is there a procedure for immediate notification of incidents to plant
personnel (i.e., personnel names, phone numbers) in order of priority?
2. Are telephone numbers provided for the appropriate governmental regu-
lating agencies (Federal, state, and local) which are to be notified in
the event of a release of toxic and hazardous material to the receiving
water?
3. Who is responsible for reporting the spill?
4. Is there a standard format for submitting a report for internal review
on a spill or near-spill?
5. Is this report adequate (i.e., area of spill, volume defined, duration,
control measures, countermeasures used)?
6. Who reviews the report?
7. Have any revisions been incorporated in the BMP program based on these
reports?
8. Is there a standard format for reporting to the appropriate govern-
mental regulating agency spills that reach the receiving water?
9. Is there a listing of others to be contacted in the event of a spill
such as the Public Water Supply agency, the Fish and Game Commission,
and the municipal sewage treatment plant?
10. Is a communication system available to immediately notify appropriate
plant personnel of a spill?
11. What is the communication system (radio, telephone, public address sys-
tem, or an alarm system)?
12. Is the communication system affected by power outages?
13. Is there direct communication between both ends of a transfer operation
such as loading and unloading of tanks and rail cars or to and from
storage areas?
14. Is there a plant warning system that utilizes alarms to alert personnel
of an unexpected release of material?
15. Is the alarm system code posted and/or is it familiar to all plant per-
sonnel?
16. Do alarm systems such as high-liquid-level alarms for notification of
impending spills adequately alert plant personnel?
17. Are these alarms or signals displayed on a central control panel so
that immediate communication to the supervisor or operator is achieved?
18. Are communication signals such as indicator lights, horns, sirens, or
combinations of these used at the plant?
Materials Inventory System
1. Is there an inventory describing quantity and location of toxic and
hazardous compounds on the plant site?
2. Are locations clearly indicated on plant layout drawings and/or plot
plans?
63
-------
3. Is the direction of flow of spilled materials predicted and clearly
indicated?
4. Is the receiving water in the area clearly shown in the plot plans?
5. Are there any losses of material (quantity and location) identified in
the inventory?
6. Are new materials and products tested for material compatability with
other chemicals used at the facility?
7. Are these materials tested or analyzed for their impact on the environ-
ment?
8. Has the aquatic toxicity been evaluated for these materials?
9. Has the impact of potential spills on the process wastewater treatment
system or municipal treatment system been evaluated?
10. Have safety and handling hazards been evaluated?
Employee Training Programs
1. Is there an employee training program relative to the BMP program and
spill prevention and control?
2. Is the program coordinated with others programs such as safety and fire
protection or is it a separate program?
3. Who is responsible for carrying out this program?
4. What techniques (i.e., meetings, films, lectures, spill drills, job
performance ratings, posters, newsletters, posting of individual's plant
performance) are utilized to ensure education of plant personnel rela-
tive to BMPs?
5. How frequently are meetings held?
6. Are employees, picked at random, familiar with BMP program objectives?
7. Are plant area supervisors and operators familiar with interactions
between their operations and other process areas?
Visual Inspections
1. Are visual inspection programs addressed in the BMP program?
2. Who performs these inspections (i.e., security, personnel, supervisors)?
3. Do these visual inspections include all the ancillary sources and the
locations of potential incidents?
4. What is the frequency of visual inspection for all the sources of poten-
tial incidents?
5. Are there internal and external visual inspections for material storage
tanks? How often?
6. Who performs these inspections (i.e., security, personnel, supervisor)?
7. Are reports submitted on each inspection?
8. Do these reports include recommendations for corrective action?
9. Does the Spill Control Committee review these reports?
10. Is the frequency of inspections reasonable (see Table 3.2 for bulk
storage tanks)?
11. Was the frequency of visual inspections increased after an incident?
If not, were any other actions taken after the incident?
Preventive Maintenance
1. Are preventive maintenance procedures covered in the BMP program?
2. Have additional preventive maintenance procedures, beyond those
normally used for safety and for minimizing downtime, been discussed
relative to BMPs and spill prevention and control?
64
-------
3. What are these procedures?
4. How often are they conducted?
5. Do preventive maintenance procedures cover all the potential sources of
incidents of toxic and hazardous substances?
6. Are there records of preventive maintenance repairs, lubrications,
etc.?
7. Is there a replacement schedule for vessels and tanks based on age and
on the corrosiveness of the material used?
Good Housekeeping
1. Is good housekeeping included in the BMP program?
2. What is the general condition of the facility relative to orderliness,
appearance, adequate space in work areas, garbage and rubbish pickup,
and storage of chemicals?
3. Are walkways and passageways easily accessible, safe, and free of pro-
truding objects and equipment?
4. Are building interiors and equipment kept in neat and orderly condi-
tion?
5. Is there any evidence of drippings from equipment or machinery?
6. Is cleanup equipment properly stored away in appropriate locations?
7. Is there evidence of dust in the air or on the floor?
8. Are there regular housekeeping inspections?
9. Are publicity posters, bulletin boards, and employee publications used
for good housekeeping programs?
10. Is physical and mechanical cleanup equipment readily available?
11. Is the material involved in small incidents recovered or flushed to the
sewer with water?
12. Are packaged and bagged chemicals properly stored in storage areas?
13. Are dry cleaning operations used for solids?
Material Compatability
1. Is material compatability treated in the BMP program?
2. How old is the facility?
3. Was the original design of the facility reviewed by the Spill Control
Committee or reviewed relative to material compatability and spill con-
trol?
4. Are new designs and plant expansions, involving the use of existing
vessels and pipelines for other than the original chemical for which
they were designed, reviewed relative to materials compatability and
spill control?
5. Is material compability considered for mitigation and/or ultimate dis-
position operations?
6. Are the wastes being disposed of at a particular location compatible?
Security
1. What form of security system is used at the facility?
2. Is the plant protected from vandalism by fencing and locked entrance
gates?
3. Are entrance gates to the plant guarded by security personnel?
4. Is television surveillance used?
5. How often is the plant patrolled by security personnel?
6. Are these patrols by car or by foot?
65
-------
7. Are chemical storage tanks, drums, valves, and/or pumps locked?
8. Are starter controls on all transfer pumps from tanks and vessels locked
or electrically isolated in the off position?
9. Are loading and unloading connections from pipelines and tanks capped or
blank flanged when not in service?
10. Is there adequate lighting around the facility?
11. Are there vehicular traffic control regulations (i.e., a designated
route for trucks, etc.)?
Evaluation of Advanced BMPs
At this point in the evaluation the user should be able to assess the extent
and adequacy of the base-line BMPs incorporated in the program. The next
step in the evaluation would be to evaluate any advanced BMPs in the program.
If no advanced BMPs are included, consideration should be given to the poten-
tial water quality impact and the effectiveness of the present base-line BMPs
before a decision is made on acceptability of the BMP program.
As discussed previously, a history of spills will indicate an obvious inef-
fectiveness of the BMP program that may be due to inadequate advanced BMPs.
The advanced BMPs should be reviewed as to their effectiveness in preventing
spills to receiving waters. If there is no history of spills, if the minimum
requirements are met, and if the base-line BMPs and any advanced BMPs are
judged to be adequate, the BMP program would be acceptable. If the BMP pro-
gram is found to be inadequate, then revisions to the base-line BMPs and/or
new or improved advanced BMPs may be recommended.
To assist the user in evaluating advanced BMPs and to aid in prescribing
additional ones should the program be found to be ineffective, a method of
identifying the advanced BMP alternatives has been developed. Table 8 sum-
marizes advanced-BMP alternatives as a function of ancillary source and
chemical grouping. The data in Table 8 are based on information derived from
the literature, industrial contacts, technical bulletins, and experience, and
were developed to facilitate the identification of applicable BMPs for the
5 ancillary sources and the 302 toxic and hazardous substances. BMPs are
grouped into categories of prevention, containnent, mitigation, and ultimate
disposition. Mitigation is subdivided into cleanup and treatment. These
BMPs are described in Section 3. Chemical classification groups are defined
and discussed in Section 4. The chemical groups for a particular substance
can be determined by referring to Tables 3—5. Since the BMP alternatives
for the first three of the five ancillary sources are similar, they have been
combined except for those indicated by footnotes. Advanced BMPs for the
other two ancillary sources (plant site runoff and sludge and hazardous waste
disposal areas) are listed separately.
After the ancillary source and the chemical group or groups have been identi-
fied, Table 8 can be used to determine BMP alternatives for each BMP category
(prevention, containment, mitigation, and ultimate disposition). If a par-
ticular chemical falls in more than one chemical group, BMPs are identified
66
-------
Table 8. Advanced BMP Alternatives
Ancillary Chemical
Source Group
In-plant transfer areas,
process areas, Material ^
Loading and unloading areas
Liquids
c
V
A
r
Solid!
M
c
K
A
BT/B
Gases
^All gases
Plant site runoff All liquids
and solids
Sludge and hazardous-waste All liquids
PO
f b
1.2,3,5,6
1.2, 3. 5,6
1,2.3.5.6
1.2,3,5,6
1,3,4
3,4,5
3,4,5
3,4,5
3,4.5
1.2.3.5
1,4,7
1,2,3,6
(b
1,2,5
1,2.3,5
1.2,5
1,2,5
1.4
1
1
1,4
1
3,5
1,2
1.2
Mitigation UJtJ
Cleanup Treaunent Dispoa
1,2,3 1,3,5,8 1 — 8
1,2 9 4,6.1
1,2 II. A. 2,3.4
1,2 N.A. 4.6,8
1,2 9 2,3.4
1.2 9 2,3,4
N.A. 3,6,9 N.A.
N.A. 1,4,5,8 5,7
1,2.3 6,8,9 5,7.1
Kate
it ion
8
.6.8
.6,8
.6,8
Prevention
PI Monitoring
P2 Nondestructive
testing
P3 Labeling
P4 Covering
PS Pneumatic/vacuum
conveying
P6 Vehicle positioning*
P7 Dry cleanup
Containment
Cl Secondary containment Ml Physical
C2 Flow diversion
C3 Vapor control
C4 Dust control
CS Sealing
H2 Mechanical
H3 Chemical
Tl
T2
T3
T4
T5
T6
T?
T6
T9
Treatment
Liquid-solids separation
Volatilization
Carbon adsorption
Coagulation/precipitation
Neutralization
Ion exchange
Chemical oxidation
Biological treatment
Thermal oxidation
01timat e_D11 spot i t ion
Ul Deep-well injection
02 Landfill
03 Surface impound-
ment
04 Ocean disposal
US Direct discharge
U6 Reclamation
07 Municipal sewer
systea
08 Contract disposal
See Table 2 for chemical groups.
See Legend on this table for identity of BHPs listed under each category.
CMot to be used for flammable liquids and solids.
For loading and unloading areas only.
N.A. denotes not applicable.
67
-------
for each chemical group. For example, at a material storage area for a
liquid, which is poisonous to humans and is volatile, containment BMPs would
include those BMPs listed under these chemical groupings (poisonous to humans
and volatile). Thus alternatives 1, 2, 3, and 5 would apply.
If a dry chemical or a gas is being evaluated, consideration of how the sub-
stance is handled on-site is necessary (as a solid or gas or as a liquid).
Those solids and gases normally handled as liquids are listed in Tables 4 and
5. It will be noted that, if a soluble dry chemical is diluted with water,
it could be treated as a liquid for purposes of identifying treatment BMPs.
Examples to Illustrate Identification of BMP Alternatives
Two examples are presented here to illustrate the use of Table 8 in identify-
ing BMP alternatives. These examples represent a case of one chemical at one
ancillary source. In evaluating a BMP program for a facility more than
likely there will be several chemicals in several areas and ancillary
sources, each one requiring an evaluation using the same approach and similar
considerations as exemplified here.
Example 1. A Storage Tank for Acrylonitrile The first step in evaluating
the advanced BMPs is to compare them to the advanced-BMP alternatives that
are applicable (use Table 8). Table 9 outlines the approach for identifying
the BMP alternatives. The ancillary source (material storage) is identified
and the chemical group classifications for acrylonitrile are identified from
Table 3. Using Table 8, the advanced-BMP alternatives are identified for
each chemical and each of the major categories of advanced BMPs (i.e., pre-
vention, containment, mitigation, and ultimate disposition). The total
number of BMPs applicable is additive except for the Treatment category under
Mitigation and for Ultimate Disposition. Containment BMP 3 (vapor control)
is applicable for volatiles but not for the other chemical groups,- therefore
the total number of BMPs applicable for containment includes vapor control.
For the Treatment and Ultimate Disposition category, only those BMP alterna-
tives common to all the pertinent chemical groups are applicable.
Example 2. A Transfer Operation This example involves phenol transport by
pipeline from material storage tanks to the loading operations. This example
relates to the transfer pipeline. In this case phenol is transferred above
41°C as a liquid, but since it will solidify if spilled at ambient tempera-
tures, the spilled phenol is handled as a liquid after the solidified phenol
is dissolved in water. Table 10 outlines the approach for this example. As
in the previous example the applicable advanced BMPs are identified for each
pertinent chemical grouping and BMP category. In the evaluation of the BMP
program the loading/unloading operation and the material storage areas would
also need to be evaluated relative to BMPs.
68
-------
Table 9. Example 1
Company:
Chemical:
Ancillary Source:
Chemical Grouping:
(from Table 3)
Acrylonitrile
Material storage (bulk storage tanks)
Liquid, flammable, volatile, floater, amenable
to BWT, biodegradable
a
Advanced-BMP Alternatives
Chemical
Grouping
Flammable
Volatile
Floater
Amenable to
BWT, biode-
gradable
Total
Prevention
1,2,3
l,2,3,5b
1,2,3
1,2,3,5
1,2,3
Contain-
ment
1,2,5
1,2,3,5
1,2,5
1,2,5
1,2,3,5
Mitigation
Cleanup
1,2,3
1,2,3
1,2,3
1,2,3
1,2,3
Treatment
1,2,3,5,6,
8,9
1,2,3,8,9
1,2,3,8,9
1,2,3,4,5,
6,7,8,9
1,2,3,8,9
Ultimate
Disposition
1,4 — 8
1,4—8
1 — 8
1—8
1 — 8
See Itgend in Table 8 for BMPs that correspond to the number listed.
Prevention (P5) pneumatic conveying not applicable for flammables.
69
-------
Table 10. Example 2
Company:
Chemical:
Ancillary Source:
Chemical Grouping:
(from Table 9)
B
Phenol
In-plant transfer (pipeline from storage to dock
facility)
Solid, poisonous to humans, soluble, amenable to
BWT
Advanced-BMP Alternatives
Chemical Contain-
Grouping Prevention ment
Poisonous 1,2,3,5 1,2,5
to humans
Amenable to 1,2,3,5 1,2,5
BWT, biode-
gradable
Total 1,2,3,5 1,2,5
Mitigation
Cleanup Treatment D
1,2,3 1,2,3,4,5,
6,8,9
1,2,3 1,2,3,4,5,
6,7,8,9
1,2,3 1,3,4,5,6,
8,9
Ultimate
'isposition
1 — 8
1 — 8
1 — 8
Phenol solidifies when spilled at ambient temperature and would be
dissolved in water for clean up; therefore the liquid grouping would
be used for this example; see text for further explanation.
See legend in Table 8 for BMPs that correspond to the number listed.
70
-------
Questions for Evaluating Advanced BMPs
At this point the user has compared the advanced BMPs proposed or used in a
program with the applicable alternatives listed in Table 8. Also, the
history of incidents and the potential water quality impact of an incident
have been considered. The next step in the evaluation of the advanced BMPs
is to determine whether they are satisfactory.
The following list of questions is provided as a guide for evaluating of the
extent and effectiveness of the advanced BMPs. For convenience, the ques-
tions were developed based on the prevention and containment procedures for
each ancillary source. A separate list of questions was developed for miti-
gation and ultimate disposition. Final decisions on whether the advanced
BMPs are adequate should also include consideration of historical spill inci-
dents, potential water quality impacts, effectiveness, and implementation
costs. These factors are discussed later in this section.
Material Storage Areas
1. Are chemicals stored in large tanks or in small containers, such as
55-gal drums?
2. What is the volume of the chemical storage tanks?
3. What is the location, number, and maximum capacity of the 55-gal drum
storage areas?
4. Is there some form of containment around the drum storage area? Is the
floor impervious? Is there a sump?
5. Is storage outside or inside?
6. Is storage covered in any way?
7. Are storage tanks above or below ground or both?
8. Is protective coating provided in the tanks?
9. Are tanks insulated?
10. Are tanks cathodically protected?
11. Are high-liquid-level alarms provided? What type?
12. How do these alarms signal overflow conditions (i.e., by horn, siren,
indicator light, etc.)?
13. Is there an automatic cutoff system between the tank and the pumping
station?
14. Is there a direct visual level indicator on the tank?
15. Is the tank labeled?
16. Is a nondestructive testing program employed?
17. If so, what type (i.e., hydrostatic, ultrasonic)?
18. Are records of shell or wall thickness measurements available?
19. Is secondary containment provided?
20. If so, is the volume of secondary containment sufficient?
21. Is secondary containment impervious and without gravity drains?
22. Are dikes of sufficient height and distance from the tanks to prevent
the hydrostatic pressure of a leak from causing a discharge over the
dike?
23. Are dikes or other forms of containment influenced by physical factors
such as slope, runoff, flooding, soil conditions, etc.?
24. Is the property underlaid by shallow ground water that would be subject
to pollution via percolation of spills through the soil or tank seepage?
71
-------
25. Are any flow diversion systems utilized? Where and to what form of con-
tainment is the flow diverted?
26. Are any vapor control techniques utilized?
27. Are dust control measures employed?
28. Are sealing techniques used and are sealants and applicators available
for plugging a leak in a vessel or tank?
In-Plant Transfer Areas, Process Areas, and Material Handling Areas
1. What kind of operations are involved at the facility (i.e., pipelines,
mechanical or pneumatic conveying of dry chemicals, etc.)?
2. Are pipelines above or below ground?
3. Are transfer pipelines visually inspected? How often? By whom?
4. Are flange joints, valves, catch pans, pipeline supports, locking of
valves, and condition of exterior surfaces addressed in visual inspec-
tion reports?
5. Are transfer pipelines tested? What is the testing method? What is the
frequency of testing?
6. Are transfer operations clearly labeled relative to chemicals handled
and potential hazards?
7. Are handling operations for dry chemicals such as mechanical and pneu-
matic transfer systems visually inspected for spills? How often? By
whom?
8. Is the above-ground piping protected from vehicular traffic?
9. Are clearances indicated for piping over roads?
10. Are cleaning operations for tanks and vessels included in the BMPs? How
is the wash water disposed of?
11. Is covering or shielding used to protect solids handling systems, such
as conveyor belts, from windblowing and rainwater?
12. Is secondary containment provided? Is the volume adequate? Is it
impervious? Are there gravity drains?
13. Is water used to wash down spills to the sewer?
14. Are flow diversion systems utilized? Where is the flow diverted?
15. Is vapor control utilized?
16. Is dust control provided for operations in which dry chemicals are
handled?
17. Are sealing techniques and sealant applicators available to plug leaks
in pipelines?
Loading and Unloading Areas
1. What type of vehicles are used for loading and unloading (i.e., truck,
rail car, barge)?
2. What procedures are followed relative to vehicle positioning (i.e.,
physical barriers, designated markings on the ground, interlocked
warning light, or horn)?
3. Is there a central facility for loading and unloading or are loading and
unloading facilities scattered throughout the plant site?
4. Are loading and unloading operations attended during actual transfer of
chemicals? By whom (i.e., plant personnel or outside contractors)?
5. Is attendant instructed in procedures for spill control?
6. What transfer systems are used for transferring dry chemicals (i.e.,
mechanical, pneumatic, and/or combinations)?
72
-------
7. Are drains and outlets on tanks, trucks, and rail cars checked for
leakage before they are loaded or unloaded?
8. Are any monitoring procedures used (i.e., flow measurements, volume on
tanks being loaded, pressure-drop alarm, liquid-level alarms)?
9. Is there evidence of spill materials in the loading and unloading areas?
10. Is there a drainage or containement system? What volume?
11. Is the system adequate for the volume of materials that are to be trans-
ferred?
Plant-Site Runoff
1. Are plant runoff and stormwater covered in the BMP program?
2. How is stormwater collected, treated, and discharged from the facility?
3. Are sewers segregated or combined?
4. Is segregation of spills from the various plant areas possible?
5. Is noncontaminated runoff from areas such as parking lots segregated and
discharged separately?
6. Is roofing provided over process areas and spill-prone operations?
7. Is covering provided for material stockpiles of dry chemicals?
8. What procedures are followed for monitoring stormwater sewers or drain-
age ditches (i.e., TOC, conductivity, pH, and flow measuring instru-
ments)?
9. Is the rainwater contained in dikes adequately tested for contamination
before it is discharged to the receiving water?
10. Is some form of containment or holding basin provided for stormwater?
What is the volume?
11. Are automatic diversion systems utilized to prevent discharge of con-
tainment runoff?
12. Can stormwater be diverted from spill areas?
13. Are sewer blockage and backup flooding problems?
14. Is noncontact cooling water segregated in the sewer system and dis-
charged separately?
15. Is there available capacity in the process wastewater treatment system
(or municipal treatment system) for the contaminated stormwater?
Sludge and Hazardous-Waste Disposal Areas
1. What ultimate disposition techniques are used?
2. Is spilled material disposed of with the facility's normal solid waste
and sludge?
3. Is there a permit under RCRA?
4. What practices are followed relative to RCRA guidelines and regulations?
5. Is labeling used at these sites?
6. For landfill, how is leachate monitored and disposed?
7. Are contract disposal contractors experienced and reputable?
8. Are wells used for monitoring of landfill and surface impoundments and
deep-well injection sites?
9. Are monitoring records kept for deep-well injection, landfills, and
surface impoundments to determine the effects on ground water in the
area?
10. Are there odor problems associated with the disposal sites?
11. Are landfills and surface impoundments protected from plant runoff? Is
runoff diverted from around these disposal sites?
73
-------
12. Are liners used for landfill and surface impoundments to protect seepage
to ground water?
13. What type of liner is used?
14. Are liners or vegatative covering used around the side slopes of surface
impoundments to prevent overflows and to provide protection from wind
and rain erosion?
15. Are visual inspections used for these areas? How often? By whom?
The following questions are provided to assist the document user in evalua-
ting of the BMP program relative to mitigation and ultimate disposition of a
material that has been spilled and contained and requires disposal. The BMPs
for mitigation and ultimate disposition are normally related to the chemical
groups and not related to the ancillary sources. Therefore the questions for
these BMPs are not divided into the different ancillary sources, as was done
for prevention and containment BMPs, but rather are divided under mitigation
and ultimate disposition.
Mitigation Cleanup
1. Are sorbents, gells, or foams identified as cleanup measures in the BMP
program?
2. What materials are used? Are they readily available at the facility?
3. Do appropriate personnel know where these materials are stored and are
the locations and listings of these materials indicated in the BMP pro-
gram?
4. How are these materials applied to the spilled material?
5. Are sorbents regenerated and reused?
6. How are these materials finally disposed of after use?
7. Are physical or mechanical cleanup devices utilized? Are they readily
available?
8. How are the dry materials disposed of? Are they reclaimed, incinerated,
disposed of by outside contract, landfilled, etc?
Mitigation Treatment
1. What treatment facilities are available for a spilled material (i.e.,
process wastewater treatment plant, separate treatment, municipal plant,
or portable trailer treatment system)?
2. Are they readily available?
3. What is the treatment process used at the facility?
4. What was the basis for the methods selected (testing, monitoring)?
5. Are they applicable (see Table 8 for applicable treatment alternatives)?
6. Do the compounds in question have any adverse effects on the treatment
plant (industry and/or municipal)?
7. Is equalization, neutralization, or storage required or needed?
8. Can the treatment system handle rainfall runoff?
9. What procedures are available for storing the runoff if the plant cannot
handle the spill?
10. Where is the material disposed of or discharged to after treatment?
11. Do the treatment systems receive the particular compounds present?
12. What monitoring program is used to evaluate the treatment (TOC, pH, TDS,
etc)?
13. Does the treatment facility used for spilled materials have an NPDES
discharge permit?
74
-------
14. What are the effluent requirements for specific compound in the permit?
Ultimate Disposition
1. What means of ultimate disposal are available and utilized for spill
materials?
2. Are they located on the plant site?
3. How do the ultimate disposition practices compare with the applicable
alternatives (see Table 8)?
4. Are spilled materials disposed of with the normal plant facility solid
wastes and sludges?
5. Are the RCRA guidelines being followed for ultimate disposal in land-
fills and other land disposal sites?
6. Is contract disposal used?
7. How long will the capacity be available at these disposal sites?
8. What is the BMP program for these sludge and hazardous-waste disposal
areas?
9. If the spilled material is to be sent to the municipal plant, will there
be an adverse impact on the municipal plant? What are the procedures
for notifying the local plant when a spill occurs?
10. Is ocean disposal used? How often? How long is the permit applicable?
Are there any provisions of ocean disposal that cannot be used?
11. After treatment, are the spilled materials discharged to the receiving
stream? What is the basis of this practice? (See the next section for
discussion of water quality impact.)
PRESCRIBING BMP ALTERNATIVES
At this point in the evaluation the user should be in a position to assess
whether the base-line and advanced BMPs proposed or utilized in the BMP pro-
gram can be effective in preventing releases of material to the receiving
water. If the BMP program is still considered to be inadequate, the user may
want to prescribe or develop advanced-BMPs alternatives to make the BMP pro-
gram acceptable.
BMP alternatives can be prescribed to develop a BMP program to recommend
alternative additional BMPs for upgrading a BMP program, or to assist an
industry in developing or improving its BMP program. A procedure similar to
evaluating a BMP program would be used to prescribe BMPs for specific plant
sites. The minimum requirements indicated in Table 7, including the base-
line BMPs, would be included in the program. The selection of the advanced
BMPs would be based on the following:
Specific chemicals, their quantity and location
Potential for spill
Probability of spilled material reaching the receiving water without
treatment
Effect on the plant's treatment system
Effect on the municipality's treatment system
Impact on the receiving stream
75
-------
Applicable advanced BMP alternatives (Table 8)
Cost
Incorporating the minimum requirements in any BMP program will assist in
evaluating the need for advanced BMPs. For example, a review of the plant's
materials inventory information will provide the data base for defining the
quantity and location of the toxic and hazardous materials. This data base
should also assist in evaluating the potential loss of these materials and
their adverse impact on the industry's or municipality's treatment system. A
review of the industry's prior spills or record of potential spills and site
plot plans will provide the basic framework for evaluating the probability of
the spilled materials reaching the receiving water. After all the base-line
BMPs are reviewed and then incorporated in the program, the next step is to
evaluate the impact that a potential incident could have on the water
quality. If the impact analysis suggests that the spill will have a signifi-
cant effect and the base-line BMP program is not considered to be adequate,
then advanced BMPs could be recommended as outlined in Table 8.
Receiving-Water Quality Impact Analysis Methodology
A BMP program offers protection to surface waters from spills of hazardous
and toxic materials at industrial sites. The probability that a hazardous
material will not reach the surface waters or the degree of protection
afforded by a BMP program cannot always be quantified. An estimate of the
impact of a hazardous material on the surface water should a spill occur can
provide a basis for judgment in assessing the adequacy or the degree of pro-
tection provided by a BMP program.
This section presents a general methodology that can be used to evaluate the
effect of potential hazardous and toxic spills on water quality. The inter-
pretation of the impact of a potential spill must be based on the expected
concentration of the particular material in the receiving body of water and
on the time of exposure of the particular aquatic species present to differ-
ent concentrations of the spilled material.
General Methodology The first step in determining the impact of a spilled
substance is to estimate the concentration level of the material in the
receiving water. The main factors governing the impact on aquatic life are
the concentrations to which the organisms are exposed and the duration of the
exposure to the concentrations. The spatial extent to which the receiving
water is affected and the length of time that concentration levels exist
should be addressed to evaluate impact. Knowledge of the concentration pro-
files in the receiving water as a function of space and time allows potential
harmful quantities to be determined with respect to the EPA classification of
hazardous materials (20) based on aquatic toxicity (LC 96-hr bioassay
test). The hazardous compounds are classified into five categories according
to aquatic toxicity, ranging from a highly toxic (acute) level to a least
toxic level.
76
-------
The second step is to interpret the data from the observed or calculated con-
centration profiles in the receiving water by means of existing bioassay test
data. The degree of survival of test organisms is a direct function of con-
centration and time of exposure. A comparison of the bioassay test data with
the calculated concentration profiles will assist in determining potential
harmful quantities should they be discharged or after they have been dis-
charged. The analysis would define the hazardous or toxic level in the
receiving waters after a spill or assist in assessing potential impacts due
to potentially future discharges (spills). This method of interpreting the
data is discussed in the subsection Impact Evaluation.
This section discusses the analytical methodologies available for estimating
the concentration levels in the receiving water due to hazardous material
spills. This section also discusses a method that could be utilized to
assess the harm caused by these hazardous material concentrations in the
water body.
Basic Modeling Factors Several methods are available for estimating the
spatial and temporal concentration profiles of the spilled material to a
receiving water. The effect that a mass release of a hazardous material has
on the receiving water is very specific to site and event. The factors that
affect the concentration profiles include the mass of the hazardous material
spilled; the duration of the spill; how the material was spilled with regard
to initial dilution,- the receiving water characteristics, such as width,
depth, flow, and temperature,- and the nature of the spilled material, such as
reactivity, solubility, and specific gravity. In addition the type of
receiving water (small stream, river, estuary, lake, or coastal waterway) has
a direct bearing on the mathematical method that can be used to calculate
concentrations. When a substance is discharged into the receiving water, the
location and the concentration of the mass are affected in varying degrees by
dilution, advection, dispersion, and reaction.
Dilution refers to the mixing of the material contained in the discharge with
the receiving water at the point of discharge or, more generally, to the
mixing of any water containing the substance with another water source con-
taining a lesser concentration of this substance. Although the concentration
of the substance is altered by dilution, the total mass of the material
remains unchanged.
Advection is the displacement of the material in a downstream direction at a
rate equal to the mean velocity of the river flow. The amount of fresh water
flow and the source's discharge to the receiving water govern the advective
force.
Dispersion refers to the mechanisms that cause a concentrated mass of sub-
stance to spread out upon release into a water body. Dispersion acts in all
directions. Lateral and vertical dispersions cause the mass to be distrib-
uted over the width and depth of the receiving water, whereas longitudinal
dispersion causes the mass to extend itself along the length of the water
body, with some particles moving faster and others moving slower than the
mean flow velocity.
77
-------
Reaction is a general term describing the removal of the substance from the
water column. This removal may be due to physical, biological, or chemical
occurrences, such as settling, decomposition, or actual chemical reactions.
Reactivity, also termed decay, is the only mechanism by which the total mass
of the substance in the water body may be reduced. Some materials are termed
conservative. These materials do not decay and are removed from the
receiving water only through the advective and dispersive forces. For
example, soluble heavy metals are considered to be conservative.
The basic equation representing these phenomena is presented in Appendix E
[Eq. (E.I)]. The equation is developed from a mass balance around a volume
element in the receiving stream and serves as a basis for evaluating numerous
conditions that could occur in a receiving stream. For this particular
application, analytical solutions are presented for a variety of cases to
illustrate the use of mathematical modeling to assist in evaluating spill
impacts on water quality. More sophisticated techniques are also available
for evaluating more complex problems using finite difference approaches
(37,161).
Review of Available Data Before attempting to employ the techniques dis-
cussed in this section, any data available on the receiving water should be
reviewed. In the methodologies that will be discussed, specific input infor-
mation is required in order to estimate the receiving water response. Such
information includes receiving-water geometry, flow, dispersion coefficients,
hazardous-material reaction rate, and mass and spill rate of the hazardous
material.
Receiving-water characteristics such as geometry and flow can be measured.
This information is also often available from United States Geological Survey
maps, navigational charts, and water height and fresh-water discharge moni-
toring programs conducted by the USGS.
Longitudinal, lateral, and vertical dispersion coefficients are not immedi-
ately available but can be estimated by relating them to such physical char-
acteristics as river geometry, river bed slope, and flow. Methods of esti-
mating these coefficients can be found in the literature (154, 155, 156, 157,
159). One method of estimating the longitudinal dispersion coefficients is
presented in Appendix E.
The nature of the hazardous material must be established with regard to its
reactivity, such as its biodegradability or chemical interactions. If this
information is not readily available, the substance can be treated as a non-
reactive substance. This would provide a conservative estimate of the con-
centration levels, with the material being removed from the receiving water
only by dispersion and advection.
The mass entering the receiving water can be estimated by establishing the
maximum quantity of material that has the potential of spilling. This can be
established after the locations and quantities of hazardous materials on the
78
-------
industrial site are pinpointed. The mass can be assumed to spill instantane-
ously, or the spill rate (volume per time) can be calculated if this informa-
tion is available.
Available Analytical Modeling Techniques The analytical solutions presented
are not specific to a particular type of water course but are specific to the
variation of the the concentration in the receiving stream. For example, a
one-dimensional system with longitudinal dispersion can be applied to a total
river or an estuary, whereas the two-dimensional system could have direct
application to an estuary or a spill near shore, where the concentrations
could vary with the width and length of the study area.
Case I. Stream or Small River For a stream or small river, where it is
often appropriate to assume that the spilled material is instantaneously
mixed vertically over the depth and laterally across the width, the maximum
concentration due to a mass discharge can readily be determined. A loading
rate, W (mass/time), can be calculated if the spill rate (volume/time) and
the concentration C (mass/volume), of the material are known. The dispersive
action in the stream can be ignored, and the mass of the spilled material is
diluted by the total stream flow, Q (volume/time). The concentration in the
stream can be calculated from the equation
C = W/Q . (1)
For a conservative material this concentration level moves as a plug down-
stream at a rate equal to the stream velocity, u. The extent of this plug
along the stream length is a distance equal to the stream velocity times the
spill duration.
If the spilled material is reactive, for example, biodegradable, the concen-
tration is diminished with time as the plug moves downstream. This can be
estimated by a first-order reaction and the stream concentration can be cal-
culated by Eq. (2):
C = W/Q • exp [-Kx/u] , (2)
where K = first order reaction rate, I/time, and x = distance downstream from
discharge.
Case II. Larger Rivers Even in water bodies in which dispersion is an
important force and the material is reactive, Eq. (1) could be used as an
initial estimate of the maximum concentration levels. Equation (1) would
conservatively overestimate the concentration in the water body due to the
fact that reaction and dispersion would actually diminish these levels.
In some water bodies, typically, large rivers (i.e., tidal rivers, estu-
aries), the effects of both advection and dispersion can be considered.
Assuming that the material is instantaneously spilled and mixed uniformly
over the cross section of the receiving water at the point of discharge, the
variation in concentration in time and distance from the discharge is given
by the following:
79
-------
c(x,t) = (M/2A VlEt) • exp [-(x - ut)2/4Et - Kt] (3)
where c(x,t) is the resulting concentration at a distance x from the dis-
charge and a time t after the discharge (mass/volume) started, M is the mass
release, A is the cross-sectional area of the receiving water (constant over
length), u is the mean advective velocity (constant flow), E is the longi-
tudinal dispersion coefficient (constant over length), and K is the reaction
coefficient.
Equation (3) is developed based on the assumption that the spill occurs
instantaneously and that the coefficients are constant over the length of the
river. In many cases an instantaneous spill concept is a reasonable assump-
tion. However, some spill incidents occur over a period of several hours or
longer, and Eq. (3) can be modified to simulate these circumstances. The
resulting equation is presented in Appendix E [Eq. (E-2)]. In essence the
overall spill can be divided into a series of successive short-term instan-
taneous releases. Each instantaneous release contains an amount of material
equal to the total mass divided by the number of releases. Equation (3) can
then be applied to each instantaneous release and the results for each spike
added to yield the effect of the total release at any distance from the dis-
charge and at any time since the beginning of the discharge.
The usefulness of Eq. (3) to estimate the response of a receiving water to a
spill incident can be demonstrated by the following example. A spill of
200 Ib of a hazardous material is discharged to a typical large river having
the following characteristics: river flow of 15,000 cfs, velocity of
3.6 fps, and dispersion of 4.6 mi /day. The material spilled is treated as a
conservative material (K = 0). Similar profiles could be developed for the
case where the material is reactive (biologically, chemical settling, etc.).
Figure 2 shows the calculated concentration of the material in the receiving
water on the y axis versus the distance along the length of the river from
the spill discharge. The spatial profiles are plotted for several points in
time (1,3,5,7, and 9 days). The top exhibit of Fig. 2 displays the profiles
for the case of a spill of 200 Ib of material occurring within 1 hr. The
display of the calculated concentrations in this manner is useful in visual-
izing what portions of the river are affected by the spilled material and at
what concentration levels. The dashed lines on the figure indicate the peak
concentrations that may develop along the river.
The remaining exhibits on Fig. 2 display the calculated concentrations if the
release of the same 200 Ib of materials to the same river took 12 and 24 hr
of time to occur. The differences between the distributions are the results
of the duration of the release, which tends to reduce the concentration, due
to the effect of dispersion.
Figure 3 presents the temporal distribution of the same spill. The calcu-
lated concentrations are plotted on the y axis versus time from the begining
of the spill for several locations along the length of the river (50, 150,
300, 450, and 600 miles) from the spill discharge. This display is particu-
larly useful in pointing out the time at which concentrations may begin
80
-------
CD
O.
Q.
20
15
10
Ul
O
O
o
CD
a.
O-
a:
LU
o
o
CO
Q-
O_
\l DAY
/ HOUR SP/l. L DURA TION
MASS: 200 LBS.
RIVER FLOW : 15,000 CFS
INFLOW: 40.9 CFS/MI.
VELOCITY : 3.6 FPS
DISPERSION : 4.6 MSPD
DECAY: O.O/DAY
\
\
\
\
\3DAYS
£J)AYS
II ~~~7P-- 9 DAYS
A JOr
100 200 300 4OO 50O 600 700
DISTANCE FROM RELEASE (MILES)
_ 12 HOUR SPILL DURATION
I
100 2OO 300 400 500 600 700
DISTANCE FROM RELEASE (MILES)
24 HOUR SPILL DURATION
z
LU
O
O
100 200 30O 400 5OO 600
DISTANCE FROM RELEASE (MILES)
700
Fig. 2. Spatial Concentration
81
-------
00
NJ
2 5
20
m
Q.
D.
— 15
O
1—
rc
a 10
•%_
o
o
5
\
\
\
\
- \
5O MILES
—
\
\
\
\
\
\
^X/50 MILES
-.
^
/ HOUR SPILL DURATION
MASS : 200 LBS.
RIVER FLOW : 15,000 CFS
INFLOW : 40.9 CFS/MI.
VELOCITY: 3.6 FPS
DISPERSION: 4.6 MSPD
DECAY: 00/DAY
"-- — 3OO MILES
P\ ~~~~ — — 450 MILES
/ 7\ 600 MILES
A , A TV
0 50 100 150 200 250 300
HOURS FROM BEGINNING OF SPILL
Fig. 3. Temporal Concentration Distribution at Various Distances
-------
appearing and the length of time that the material may remain at particular
locations along the river. The peak concentration that may develop along the
water course as a consequence of this discharge is indicated by the dashed
line.
The significance of the results presented in Figs. 2 and 3 is that there are
relatively simple techniques available to calculate the concentration of a
material in the rivers as a function of distance downstream and time. This
type of information can be used to compare with known bioassay data to esti-
mate whether harmful quantities are in the receiving stream. In this par-
ticular example it was assumed that the discharged material was uniformly
mixed across the width of the river and throughout the depth.
Case III. Two- and Three-Dimensional System Depending on the mixing char-
acteristics and geometry of the water body or the manner in which the spilled
material enters the receiving water, it is often not appropriate to assume
that the material is instantaneously mixed across its width and depth. Typi-
cal of this case would be spill discharges near the shoreline to very wide or
deep rivers, estuaries, lakes, coastal embayments, and coastal zones. In
these cases the concentrations would be not only a function of length and
time but also of width and depth. The analytical solutions for the two- and
three-dimensional cases, estimating the receiving-water concentrations due to
a spilled discharge, are presented in Appendix E [Eqs. (E-4) (E-5)].
In the analytical solutions for the one-dimensional case, (Eq. 3) and the
two- and three-dimensional cases presented in Appendix E it is assumed that
the parameters are constant throughout the receiving water. Such parameters
as fresh-water flow, cross-sectional area and dispersion are considered to be
constant throughout the spatial extent of the receiving water under analysis.
For the two- and three-dimensional case it is assumed in this application
that there are no physical boundary constraints. Although they may have some
basic limitations due to the assumption assigned to develop these basic
analytical solutions, the use of these models should be considered as a basic
engineering tool for initially assessing the impact of spilled materials on
the water quality. If the results define questionable impact, more sophisti-
cated modeling techniques may be required.
Analytical solutions become increasingly difficult or impossible to formulate
as the problem dimension and complexity increase and become particularly
unwieldy to use. Where a detailed analysis is required for handling the more
complex problems, the finite-difference approximation is the approach often
used. The technique that can be used to solve these more complex type of
problems (37) illustrates the discharge of a conservative substance and the
the discharge of a strong acid. Computer-type programs are readily available
to handle these more complex techniques.
Impact Evaluation Once the temporal and spatial concentration profiles
caused by a spilled material are estimated, the following question must be
asked: How harmful are these concentration levels? The method which is pre-
dominately utilized for determing the measure of harm is aquatic toxicity.
The effect of hazardous materials on aquatic organisms has been studied, with
emphasis given to determining the concentration levels that produce immediate
83
-------
harm (acute toxicity) and the concentration levels existing over a long term
that have a detrimental effect (chronic toxicity) (118, 51, 20, 162).
Another factor that should be considered is the potentiality for toxicity to
humans. The use of the receiving water is a major factor that must be con-
sidered. Municipal and industrial water supply intakes, recreational areas
for boating, fishing, and swimming, areas for commercial fishing, and irri-
gation supply intakes must be identified. In this particular review toxicity
is discussed relative to aquatic and chronic levels based on bioassy test
data. Certainly, in critical areas where human consumption or use is the
predominant factor, stricter and more effective water quality criteria must
exist to safeguard the public's welfare.
The method commonly accepted as a measure of acute toxicity is the LC,_n bio-
assay test. In this procedure aquatic organisms, usually fish, are exposed
to different concentration levels of the tested substance for a specific
period of time, normally 96 hr. The concentration of the substance at which
50% of the organisms survive or die is designated as the lethal concentration
(LC,-n) for the 96-hr exposure time.
The results of LC,-0 bioassay tests for a specific hazardous material can vary
due to different testing procedures. The primary factors include the species
utilized in the test, the exposure time, the method of determining the haz-
ardous material concentration, and the type of test tank (static or flow-
through) . The EPA has proposed methodology for standardizing the measured
data for a specific material to obtain a single LC,- , 96-hr value (163).
This is accomplished by applying correction factors, based on statistical
analysis of the measured data, to adjust for variable test conditions.
Chronic toxicity levels are commonly measured as the highest concentration of
the hazardous material that has no adverse effect on survival, growth, or
reproduction of a species. This level is also known as the Maximum Accept-
able Toxicant Concentration (MATC). Tests conducted over the life cycle or
partial life cycle of a species determines the limits within which the MATC
must fall. MATC data, based on long-term studies, are not always readily
available. The EPA has proposed methodology (163) for estimating the chronic
toxicity concentration based upon LC 96-hr measurements.
The EPA is recommending a dual concentration criterion (criteria guidelines)
in the receiving water (163). It consists of a maximum concentration based
on the final acute toxicity level and an average concentration over a 24-hr
period based on the final chronic toxicity level. For a specific hazardous
material the acute and chronic toxicity levels of the substance can be com-
pared with the concentrations calculated or observed in the receiving water
as the result of a spill. This comparison would indicate, on a first-approx-
imation basis, whether a potential problem exists and whether additional data
on aquatic toxicity are required. The basis for additional data and/or
modeling needs will depend directly on the comparison of the criterion and
the concentrations in the receiving waters. When the concentrations are
lower than the criterion, additional monitoring would not be required. If
the expected concentrations are near to or exceed those in the proposed cri-
terion, additional analysis will be required to assess the magnitude of the
84
-------
problem. One factor, which is not considered a major impact, is the time of
the exposure of the test species. This is certainly true in receiving
streams, where aquatic life is exposed for shorter periods of time but at
higher concentrations. It is this type of situation that has to be evaluated
so that natural interpretation of potentially harmful levels can be evalu-
ated.
A more detailed approach can be taken to quantify the harm caused by a haz-
ardous material spill. The impact of a spill relative to aquatic toxicity is
specific to site and event. Analogous to laboratory toxicity studies, the
impact depends on such factors as the type of species present, the nature of
the hazardous material, the concentration levels to which organisms are
exposed, and the exposure time. The main factors governing organism survival
are the concentration levels that the organisms are exposed to and the dura-
tion of exposure. It is the combination of the concentration level and
exposure time that determines the level of organism survival. For example
the number of organisms that can be killed during a shorter period of time
but at a higher concentration level is equivalent to the number killed at a
lower concentration level for a longer period of time.
Aquatic toxicity data are most readily available in the form of LCrn, 96-hr
values. However, it has been found that acute toxicity to fish generally
occurs within the first 96 to 100 hr of exposure time. Also, it is reason-
able to assume that any condition that produces 50% mortality of the fish
population is obviously a harmful condition. To assess the impact of a spill
more quantitatively, it is necessary to establish a range of survival rates
for various concentration levels and exposure time combinations.
When a bioassay study is conducted at a specific concentration level, the
percent survival can be measured at several times instead of only after
96 hr. This test can be repeated at several concentrations and a series of
curves can be developed as indicated in Fig.4(A), which shows the percent
survival versus exposure time for several concentrations of the test mate-
rial. The test data can be arranged into the more usable form indicated in
Fig. 4(B), a plot of concentration versus exposure time for a range of sur-
vival rates. For any concentration and exposure time combination the percent
survival can be determined.
When sufficient measured data are not available for generating the curves in
Fig. 4(B) approximate methods are available to estimate the relationship for
LC5Q. On the basis of statistical analysis the EPA has proposed methodology
for relating the LC 96-hr concentration to the LC5 concentrations at
exposure times of 24, 48 and 72 hr (163). Another study has related the LC5
concentration for the 96 hour exposure time to the 6 hour exposure time (51;.
From these relationships for the 50% survival rate the concentration—
exposure-time curve can be estimated similar to the relationship shown in
Fig. 4(B) for 50% survival.
The EPA has also proposed methodology for relating the 50% survival concen-
tration to the concentration likely to be lethal to 0 to 10% of the aquatic
population (163). For the 90 to 100% rate the concentration—exposure-time
curve can be estimated. Therefore based solely on LC 96-hr measurements,
85
-------
%
SURVIVAL
Z
O
tr
t-
UJ
O
(A)
C,
-------
when no additional bioassay data are available, the upper bound (50% sur-
vival) and the lower bound (90 to 100% survival) curves of Fig. 4(B) can be
approximated.
Using the concentration exposure-time relationships from actual data or
from the approximated relationships in conjunction with the calculated
temporal concentrations of the hazardous material at various locations along
the length of the receiving water, the impact of a spill can be quantified in
terms of percent survival. This evaluation procedure is illustrated in
Fig. 5. Figure 5(A) displays the calculated concentration profile of the
hazardous material in the receiving water at a specific location (station A)
with respect to time from the beginning of the spill. This profile would be
developed from the analytical modeling techniques previously discussed and
illustrated by the calculated concentration profiles in Figs. 2 and 3. The
curve in Fig. 5(A) can be divided into a series of time periods. During time
period At an average concentration, C,, in the receiving water is estimated.
The effect of this concentration and exposure time (Wt) combination can be
determined from Fig. 4(B) in terms of percent survival. This procedure is
repeated for the subsequent time periods, and the percent mortality (or sur-
vival) is plotted for each time interval as in Figure 5(B). The percent sur-
vival is accumulated over time from Figure 5(B) as illustrated by Fig. 5(C).
This entire procedure is repeated at different locations to obtain the cumu-
lative percent survival along the length of the receiving water. This analy-
sis takes into account the concentration levels of the spilled hazardous
material, which vary in the receiving water over time and over space as shown
on Figs. 2 and 3. By applying this technique to different river stations,
the stretches of the receiving water that are critically impacted in terms of
percent mortality can be determined.
As illustrated above, by using the concentration—exposure time—percent sur-
vival bioassay relationships and the spatial and temporal concentration
levels calculated in the receiving water as a result of a spill, the impact
can be quantified in terms of organism survival. However, it is not the pur-
pose of this discussion to establish that 80, 90, 95, 97, or even 100% sur-
vival is necessary in order to determine that a potential spill would not be
harmful. The methodology presented can be used to quantify the effect of a
spill and subsequently provide input for a decision to be made on the ade-
quacy of the level of protection provided by a BMP program.
Summary In summary methodology has been presented to estimate the concen-
tration levels of hazardous materials in the receiving water due to a spill
and to assess the harm caused by this material to the water body. Due to
site and event specificity some situations would require a more detailed and
complex analysis. However, in many cases relatively simple analytical calcu-
lations can be used to initially approximate the concentration levels. The
water quality estimation coupled with basic aquatic toxicity information can
provide the basis for assessing the harm that could be caused by a potential
spill of hazardous materials.
87
-------
o
p
<
O
o
STATION A
o:
o
2
STATION A
(A)
A
At, | Atz I At, | TIME AFTER SPILL
(B)
TIME AFTER SPILL
100
LJ
>
13
O
(O
STATION A
TIME AFTER SPILL
Fig. 5. Example of Calculating Percent Survival
88
-------
Questions for Evaluating the Impact on Water Quality
The following list of questions was developed to assist the user in evalu-
ating the impact of a hazardous spill on water quality. The potential water
quality impact should have a direct input on the degree and extent of the
BMPs that should be imposed on an industry.
1. What are the uses of the receiving water (municipal or industrial water
supply; recreational activities as fishing, boating, swimming; commer-
cial fishing,- and irrigation supply)?
2. Has a mathematical model been developed to simulate the response of the
receiving water to a spill of the hazardous material?
3. Has the model been calibrated?
4. Has the model been verified against any data sets?
5. What is the data base (geometry, flow, type of receiving stream)?
6. Have aquatic toxicity studies been performed for those hazardous mate-
rials having spill potentiality? What was the aquatic organism used?
7. Has a comparison been made between aquatic toxicity and the calculated
concentrations relative to percentage survival?
8. If no modeling analysis has been done, are there sufficient data avail-
able for a preliminary assessment of the potential impacts (geometry,
flow, water uses, type of receiving water etc.)?
9. Is the material in question poisonous to humans (see Tables 3, 4, and
5)?
89
-------
Appendix A
LITERATURE SURVEYED AND INDUSTRIAL CONTACTS MADE
ARTICLES AND REPORTS
1. J. E. Glattly, "Spill Control and Contingency Response Plan," pp. 13—18
in Proceedings of 1978 National Conference on Control of Hazardous Mate-
rial Spills, Miami Beach, Florida.
2. William B. Katz, "A New Pair of Eyes," pp. 1—7 in Proceedings of
1976 National Conference on Control of Hazardous Material Spills,
New Orleans, Louisiana.
3. H. Schwartzman and R. J. Wiese, "Spill Protection Engineering for
Industry—An Integrated Approach," op. cit., pp. 33—38.
4. P. L. D'Allesandro and C. B. Cobb, "Hazardous Material Controls for
Bulk Storage Facilities," op_. cit., pp. 39—43.
5. L. E. Carlson, J. F. Erdman, and G. J. Hanks, "How One Chemical Company
Is Attacking the Spill Problem," pp. 106—116 in Proceedings of 1974
National Conference on Control of Hazardous Material Spills,
San Francisco, California.
6. J. Barber, "Phosphoric Acid Storage and Containment at Fertilizer
Plants," op_. cit., pp. 130—134.
7. J. W. Corley, "Process Plant Design for Control of Hazardous Material
Spills," pp. 15—17 in Proceedings of 1972 National Conference on
Control of Hazardous Material Spills, Houston, Texas.
8. James L. Kern, "Control Systems for Prevention of Hazardous Material
Spills in Process Plants," op. cit., pp. 19—23.
9. W. H. Weiss, "Spill Prevention and Control: A Special Report,"
Pollution Engineering, pp. 22—29 (November 1976).
10. G. N. McDermott, "Industrial Spill Control and Pollution Incident Pre-
vention," Journal, Water Pollution Control Federation, pp. 1629—1639
(August 1971).
90
-------
11. H. E. Brown, W. S. Cameron, and R. G. Bennett, "Spill Control at
Proctor and Gamble's Iowa City Plant," Proceedings of the Iowa
Academy of Sciences, Vol. 79 (1972—73).
12. Manufacturing Chemists Association, Guidelines for Chemical Plants in
Prevention, Control, and Reporting of Spills, 1972.
13. American Petroleum Institute, Suggested Procedure for Development of
SpillPrevention Control and Countermeasure Plans, 1974.
14. WPCF Manual of Practice No. 3, Regulation of Sewer Use, pp. 15 and 34,
Water Pollution Control Federation, Washington, 1975.
15. W. B. Neely and R. J. Mesler, "An Emergency Response System for
Handling Accidental Discharges of Chemicals into Rivers," pp. 19—23
in Proceedings of 1978 National Conference on Control of Hazardous
Material Spills, Miami Beach, Florida.
16. S. M. Pier et al. , "Methods of Categorization of Hazardous Materials,"
o£. cit., pp. 27—31.
17. T. J. Charlton et al., "Relating Handling of Hazardous Materials to
Spill Prevention," op. cit., pp. 32—35.
18. N. J. Sell and F. Fischbach, "Insufflation Permits Dust Recycling in
the Cement Industry," Pollution Engineering, pp. 32—34 (November 1976).
19. Environmental Protection Agency, "Oil Pollution Prevention. Nontrans-
portation Related Onshore and Offshore Facilities," Federal Register
38(237), Part II, 34164—34170 (Dec. 11, 1973).
20. Environmental Protection Agency, "Water Programs. Hazardous Sub-
stances," Federal Register 43(49), Part II, 10474—10508
(Mar. 13, 1978). —
21. California Department of Health, Vector and Waste Management Section,
California Characterization and Assessment System for Hazardous and
Extremely Hazardous Wastes (March 1978).
22. C. R. Corbett, "A Dynamic Regional Response Team," pp. 4—8 in
Proceedings of 1978 National Conference on Control of Hazardous
Material Spills, Miami Beach, Florida.
23. G. Moein, "Magnitude of the Chemical Spill Problem — A Regional Over-
view," op. cit., pp. 84—90.
24. M. D. Ryckman and T. J. Weise, "REACT1s Response to Hazardous Mate-
rials Spills," 0£. cit., pp. 24—26.
25. M. Kirsh, R. W. Melvold, and J. J. Vrolyk, "A Hazarodus Materials Spill
Warning System," pp. 84—90 in Proceedings of 1976 National Conference
on Control of Hazardous Material Spills, New Orleans, Louisiana.
91
-------
26. J. E. Amson and J. L. Goodier, "An Anaysis of the Economic Impact of
Spill Prevention Control on the Chemical Industry," pp. 39—45 in
Proceedings of 1978 National Conference on Control of Hazardous Mate-
rial Spills, Miami Beach, Florida.
27. R. W. Landers and H. V. Johnson, "Photo Interpretation Keys for
Hazardous Substances Spill Conditions," op. cit., pp. 124—127.
28. R. M. Koerner e_t al. , "Detection of Seepage and Subsurface Flow of
Liquids by Microwave Interference Methods," op. cit., pp. 287—292.
29. B. M. Willmoth, "Procedure to Reduce Contamination of Groundwater by
Hazardous Materials," op. cit. , pp. 293—295.
30. J. P. Lafonara e_t al., "Soil Surface Sealing to Prevent Penetration of
Hazardous Material Spills," op. cit., pp. 296—302.
31. R. C. Mitchell, R. L. Cook, and I. Wilder, "Systems for Plugging Leaks
of Hazardous Materials," op. cit., pp. 332—337.
32. K. R. Huibregtse, J. P. Lafornora, and K. H. Kast, "In-Place Detoxifi-
cation of Hazardous Material Spills in Soil," op. cit., pp. 362—370.
33. J. G. Michalovic, C. K. Akers, R. W. King, and R. J. Pilie, "Develop-
ment of Means for Applying Multipurpose Gelling Agent to Spilled
Hazardous Materials," op. cit., pp. 378—381.
34. R. E. Temple and W. T. Gooding, "A New Universal Sorbent in Hazardous
Spills," op_. cit., pp. 382 and 383.
35. L. D. Witny and R. E Shaffer, "Feasibility Study of Hazardous Vapor
Amelioration Techniques," op. cit., pp. 384—392.
36. E. C. Norman and H. A. Dowell, "The Use of Foam to Control Vapor Emis-
sions from Hazardous Material Spills," op. cit., pp. 399—405.
37. J. A. Nusser, T. W. Gallagher, and J. P. St. John, "Mathematical
Modeling for Impact and Control of Hazardous Material Spills,"
op. cit., pp. 422—426.
38. D. T. Tsahalis, "Mitigation of Chemical Spills RIOIS: A River Dis-
persion Model," op. cit., pp. 427—431.
39. B. A. Benedict, "Analytical Models for Toxic Spills," op_. cit. ,
pp. 439—443.
40. R. M. Koener, A. E. Lord, and J. N. Deishes, "Acoustic Emission Stress
and Leak Monitoring to Prevent Spills from Buried Pipelines," pp. 8—15
in Proceedings of 1976 National Conference on Control of Hazardous
Material Spills, New Orleans, Louisiana.
92
-------
41. S. A. Wiener and S. A. Heard, "Spill Prevention and Material Sensory
Devices," op. cit., pp. 16—23.
42. A. J. Houghton, J. A. Simmons, and W. E. Gonso, "A Fail Safe Transfer
Line for Hazardous Fluids," op. cit., pp. 29—32.
43. John Buckley and S. A. Weiner, "Documentation and Analysis of Histori-
cal Spill Data to Determine Hazardous Material Spill Prevention
Research Priorities," pp. 85—89 in Proceedings of 1974 National
Conference on Control of Hazardous Material Spills, San Francisco,
California.
44. W. T. Musser, "The Ocean Disposal Permit Program," op. cit.,
pp. 99—101.
45. R. S. Allen, "Considerations in the Design and Operations of PVC Resin
Plants," op. cit., pp. 102—105.
46. R. M. Keener and A. E. Lord, "Earth Dam Warning System to Prevent
Hazardous Material Spills," op_. cit. , pp. 119—126.
47. R. H. Hall and D. H. Haigh, "Automatic Sealing Imbiber Valves,"
op. cit., pp. 127—129.
48. Allegheny County, Sanitary Authority, Pittsburgh, Pennsylvania, Effects
of Hazardous Spills on Biological Waste Treatment, PB-276 724
(December 1977).
49. Envirex, Inc., Milwaukee, Wisconsin, Environmental Science Division,
Manual for the Control of Hazardous Material Spills. Volume I: Spill
Assessment and Water Treatment Techniques, PB-276 734 (November 1977).
50. C. H. Ward et al., Rice University, "Handling Practices," Vol. Ill of
Report of Activities February 1976—December 1977 Research on
Hazardous Substances in Support of Spill Prevention Regulations
(January 1978).
51. G. W. Dawson, M. W. Stradley, and A. J. Shuckrow, Battelle, Pacific
Northwest Laboratories, Executive Summary, Methodologies for Deter-
mining Harmful Quantities and Rates of Penalty for Hazardous Sub-
stances, Vol. I; Technical Documentation, Vol. II; and Appendices,
Vol. Ill (draft final reports) (October 1974).
52. B. F. Wirth, "Preventing and Dealing with In-plant Hazardous Spills,"
Chemical Engineering, pp. 82—96 (Aug. 18, 1975).
53. J. B. Cox, "Prevention, Containment and Countermeasure (SPCC) Plan of
the Refuse Act Permit Program," pp. 27—34 in Proceedings of the 1972
National Conference on Control of Hazardous Material Spills,
Houston, Texas.
93
-------
54. B. W. Mercer et al. , "Current Methodology for Disposal of Spilled
Hazardous Materials," pp. 190—195 in Proceedings of 1978 National
Conference on Control of Hazardous Material Spills, Miami Beach,
Florida.
55. Environmental Protection Agency, "NPDES Proposed Requirements for Spill
Prevention Control and Countermeasure Plans to Prevent Discharge of
Hazardous Substances from Certain Facilities," Federal Register,
43(171), Part V, 39276—39280 (Sept. 1, 1978).
56. Environmental Protection Agency, "NPDES Criteria and Standards for
Imposing Best Management Practices for Ancillary Industrial Activities,"
Federal Register 43(171), Part VI, 39282—39284 (Sept. 1, 1978).
57. E. I. du Pont de Nemours & Co., Inc., Elastomer Chemical Department,
Beaumont Works, Spill Prevention Control Program (Mar. 30, 1973).
58. E. W. Lawler, T. L. Ferguson, and A. F. Meiners, "Methods for Disposal
of Spilled and Unused Pesticides," pp. 329—335 in Proceedings of 1974
National Conference on Control of Hazardous Material Spills,
San Francisco, California.
59. S. S. Gross, "Evaluation of Foams for Mitigating Air Pollution from
Hazardous Material Spills," pp. 394—398 in Proceedings of 1978 National
Conference on Control of Hazardous Material Spills, Miami Beach,
Florida.
60. J. Smith, "Fire Service Evaluation and Field Tests of EPA-Developed
Hazardous Spills Control Devices," op. cit., pp. 444—446.
61. Ralph Stone, "Disposal of Hazardous Waste in Sanitary Landfills,"
pp. 314—324 in Proceedings of 1974 National Conference on Control
of Hazardous Material Spills, San Francisco, California.
62. J. R. Cannon, "Chemical Fixation of Hazardous Material Spill Residues,"
pp. 416—423 in Proceedings of 1976 National Conference on Control of
Hazardous Material Spills, New Orleans, Louisiana.
63. L. H. Frisbie, "Safe Disposal Practices for Pesticide Waters,"
op. cit. , pp. 434—436.
64. E. C. Lazar, "Summary of Damage Incidents from Improper Land Disposal,"
op. cit., pp. 437—400.
65. Andre Boily, "Central Hazardous Waste Treatment at Your Disposal,"
op. cit., pp. 441—443.
66. Office of Water Enforcement, Permits Division, Technical Guidance for
the NPDES Program BMP's for Liquid Transfer Operations, Preventive
Maintenance and Housekeeping, Plant Site Runoff, Truck and Railcar
Loading and Unloading, draft copy (July 1978).
94
-------
67. R. I. Epstein and S. R. Eckhaus, "Ultimate Disposal of Demilitarized
Chemical Agent Residues," pp. 424—428 in Proceedings of 1976 National
Conference on Control of Hazardous Material Spills, New Orleans,
Louisiana.
68. R. J. Buchanan and A. A. Metry, "Closing the Gap in Hazardous Waste
Management in New Jersey," pp. 196—201 in Proceedings of 1978 National
Conference on Control of Material Spills, Miami Beach, Florida.
69. S. E. Soden and J. C. Johnson, "Burial and Other High Potential Response
Techniques for Spills of Hazardous Chemicals That Sink," op. cit.,
pp. 202—207.
70. Gary Perket, "An Assessment of Hazardous Waste Disposal in Landfills,
The State of the Art," op_. cit. , pp. 208—212.
71. L. H. Frisbie, "State Disposal Practices for Hazardous Wastes,"
op. cit., pp. 213—216.
72. J. R. Conner, "Ultimate Disposal of Liquid Wastes by Chemical Fixation,"
pp. 906—922 in Proceedings of the 29th Annual Purdue Industrial Waste
Conference, West Lafayette, Indiana, 1975.
73. N. K. Thumg ejt al., "Biodegradation of Spilled Hazardous Materials,"
pp. 217—220 in Proceedings of the 1978 National Conference on Control
of Hazardous Material Spills, Miami Beach, Florida.
74. A. J. Darnell, "Disposal of Spilled Hazardous Materials by the
Bromination Process" op. cit., pp. 221—225.
75. S. D. Erk, M. L. Taylor, and T. 0. Tiernan, "Environmental Monitoring
in Conjunction with Incineration of Herbicide Orange at Sea," op. cit.,
pp. 226—231.
76. Hydroscience, Inc., Westwood, New Jersey, Spill Analysis for the Rhine
River Below Basel, Switzerland, internal report (April 1977).
77. Environmental Protection Agency, "Preliminary Notification of Hazardous
Waste Activities, Proposed Procedures," Federal Register 143(133),
Part IV, 29908—29916 (July 11, 1978).
78. M. Gruenfeld, F. Freestone, and I. Wilder, "EPA's Mobile Lab and Treat-
ment System Responds to Hazardous Spills," Industrial Water Engineer-
ing, pp. 18—23 (September 1978).
79. D. M. Ditoro and M. J. Small, "Stormwater Interception and Storage,"
Journal of the American Society of Civil Engineers, Environmental
Engineering, pp. 43—54 (February 1977).
80. D. Lazurchik, "Pennsylvania's Pollution Incident Prevention Progam,"
p. 528—533 in Proceedings of the 25th Industrial Waste Conference,
Purdue University, Lafayette, Indiana, May 1970.
95
-------
81. Robert A. Bove, "Recognizing and Dealing with Dangerous Gases,"
Pollution Engineering, pp. 34—37 (November 1978).
82. A. McRae, L. Whelchel, and H. Rowland, Toxic Substances Control Source-
book, Aspen Publications, Germantown, MD, 1978.
83. Allied Chemical Company, Corporate Pollution Control Guidelines SPCC
Plans, internal report (May 4, 1978).
84. "Occupational Safety and Health Standards," Federal Register 39(125),
Part II, 23502—23828 (June 27, 1974). —
85. A. Dikulik, "Manually Operated Valves," Chemical Engineering, Deskbook
Issue, pp. 119—126 (Apr. 3, 1978).
86. R. Welch, A. Marmelstein, and P. Maughan, "Aerial Surveillance Spill
Prevention System," Proceedings of 38th Annual Meeting, American
Society of Photogrammetry, Washington, D.C., March 1972.
87. "Ocean Incineration Anew," Environmental Science and Technology,
pp. 236 and 237 (March 1977).
88. "Outlook Garbage Is a Waste Is a Hazard Is a Resource," Environmental
Science and Technology, pp. 230—232 (March 1977).
89. Metcalf & Eddy, Inc., Wastewater Engineering: Collection, Treatment,
Disposal, McGraw-Hill, New York, 1972.
90. W. Weber, Physiochemical Processes for Water Quality Control,
Wiley-Interscience, New York, 1972.
91. R. Gulp, G. Wesner, and G. Gulp, Handbook of Advanced Wastewater
Treatment, 2d ed., Van Nostrand, Reinhold, New York, 1978.
92. W. W. Echenfelder, Industrial Water Pollution Control, McGraw-Hill,
New York, 1966.
93. N. Nemerow, Liguid Waste of Industry Theories, Practices and Treat-
ment, Addison-Wesley, Reading, MD, 1971.
94. E. Schrolder, Water and Wastewater Treatment, McGraw-Hill, New York,
1977.
95. E. Thackston and W. W. Eckenfelder, Process Design in Water Quality
Engineering New Concepts and Developments, Jenkins Publishing Co.,
Austin, TX, 1972.
96. L. G. Rich, Unit Processes of Sanitary Engineering, Wiley, New York,
1963.
97. R. Gulp and G. Gulp, Advanced Wastewater Treatment, Van Nostrand,
Reinhold, New York, 1971.
96
-------
98. T. J. Mulligan and R. D. Fox, "Treatment of Industrial Wastewaters,"
Chemical Engineering, pp. 49—66 (Aug. 31, 1976).
99. R. Treybal, "Mass-Transfer Operations," Chemical Engineering Series,
McGraw-Hill, New York, 1968.
100. Allied Chemical Company, Operating Spill Prevention, Containment, and
Countermeasure Plan, Frankfort Technical Report (October 1977).
101. R. J. Pilie et al., Methods to Treat, Control and Monitor Spilled
Hazardous Materials, EPA-670/2-75-042 (June 1975).
102. J. L. Buckley and S. A. Wiener, Hazardous Material Spills: A Docu-
mentation and Analysis of Historical Data, EPA-600/2-78-066
(April 1978).
103. National Lime Association, Lime Handling Application and Storage,
Bulletin No. 213 (May 1976).
104. The Chlorine Institute, New York City, Chlorine Manual, 1969.
105. The Chlorine Institute, New York City, Chlorine Tank Can Unloading,
Pamphlet No. 61 (February 1975).
106. The Chlorine Institute, New York City, Facilities and Operating Proce-
dures for Chlorine Storage, Pamphlet No. 5 (October 1977).
107. The Chlorine Institute, New York City, Emergency Shutoff Facilities for
Chlorine Tank Can Loading and Unloading Operations, Pamphlet No. 57
(Feb. 2, 1965).
108. The Chlorine Institute, New York City, Container Procedure for Chlorine
Packaging, Pamphlet No. 7 (December 1973).
109. Murray P. Strier, EPA, Treatability of Organic Priority Pollutants,
Part C, Their Estimated (30-day Average) Treated Effluent Concentra-
tion A Molecular Engineering Approach (July 11, 1978).
110. George A. Schultz, "In-Plant Handling of Bulk Materials in Packages and
Containers," Chemical Engineering, Deskbook Issue, pp. 29—38 (Oct. 30,
1978).
111. Philip Newton, W. R. Von Tress, and J. S. Bridges, "Liquid Storage in
the CPI," Chemical Engineering, Deskbook Issue, pp. 9—15 (Apr. 3,
1978).
112. Leon R. Kileny and Harry Scheffer, "Liquid Transportation Technology,"
Chemical Engineering, Deskbook Issue, pp. 17—23 (Apr. 3, 1978).
113. H. Heukelekian and M. C. Rand, "Biochemical Oxygen Demand of Pure
Organic Compounds," Sewage and Industrial Waste, pp. 1040—1053
(September 1955).
97
-------
114. J. J. Bulloff and J. R. Sinclair, "Agents for Amelioration of Dis-
charger of Hazardous Chemicals on Water," pp. 227—287 in Proceedings
of 1976 National Conference on Control of Hazardous Material Spills,
New Orleans, Louisiana.
115. C. H. Ward, J. L. Breyette, and C. E. Sanner, Rice University, "Regula-
tory Review," Vol. IV of Report of Activities February 1976—
December 1977 Research on Hazardous Substances in Support of Spill
Prevention Regulations (January 1978).
116. C. H. Ward, J. L. Breyette, L. K. Holder, Rice University, "Data Sheets,
Part 1," Vol. V of Reports of Activities February 1976—December 1977
Research on Hazardous Substances in Support of Spill Prevention
Regulations (January 1978).
117. C. H. Ward, J. L. Breyette, and L. K. Holder, "Data Sheets, Part 2,"
Vol. V of Reports of Activities February 1976—December 1977 Research
on Hazardous Substances in Support of Spill Prevention Regulations
(January 1978).
118. C. H. Ward and M. W. Curtis, Rice University, "Toxicology," Vol. VI of
Reports of Activities October 1976—December 1977 Research on Hazardous
Substances in Support of Spill Prevention Regulations (January 1978).
119. C. H. Ward e_t al., Rice University, "Categorization," Vol. II of Reports
of Activities February 1976—December 1977 Research on Hazardous
Substances in Support of Spill Prevention Regulations (January 1978).
120. National Council of the Paper Industry for Air and Steam Improvement,
Inc., Spill Prevention and Control Aspects of Paper Industry Wastewater
Management Programs, Stream Improvement Bulletin No. 276 (August 1974).
121. National Fire Protection Association, Fire Protection Guide on
Hazardous Materials, 6th ed., 1975.
122. Manufacturing Chemists Association, Housekeeping in the Chemical
Industry, Safety Guide SG-2 (March 1960).
123. Manufacturing Chemists Association, Loading and Unloading Corrosive
Liguids, Technical Bulletin TC-27 (1975).
124. Manufacturing Chemists Association, Loading and Unloading Liguid
Caustic Tank Cars, Technical Bulletin TC-28 (1975).
125. Manufacturing Chemists Association, A Guide for Landfill Disposal of
Solid Waste, Technical Guide SW-1 (1974).
126. Philip Powers, How to Dispose of Toxic Substances and Industrial
Wastes, Noyes Data Corporation, Park Ridge, NJ (1976).
98
-------
127. "Development of a Kit for Detecting Hazardous Material Spills in
Waterways," Environmental Protection Technology Series, March 1978,
EPA-600/2-78-055.
128. USEPA, Hazardous Waste Management Division, Implementing a BMP for
Residuals: The Waste Exchange, EPA-440/9-76019 (June 1976).
129. "Diversified Hauler Develops System for Handling Both Solid and Liquid
Wastes," Solid Wastes Management/RRJ, pp. 16—18 (January 1978).
130. W. Walker, "Monitoring Toxic Chemicals in Land Disposal Sites,"
Pollution Engineering, pp. 50—53 (September 1974).
131. J. Lafornara, "Cleanup After Spills of Toxic Substances," Journal of
the Water Pollution Control Federation, pp. 617—627 (April 1978).
132. R. H. Hiltz and F. Foehlich, Emergency Collection System for Spilled
Hazardous Materials, EPA-600/2-72-162 (August 1977).
133. Iowa Department of Environmental Quality, Sanitary Landfill Operator's
Manual, NITS PB-268-708 (May 1977).
134. PEDCO Environmental, Inc., Cincinnati, Ohio, Residual Waste Best Man-
agement Practices: A Water Planner's Guide to Land Disposal, NTIS
PB-258-849 (June 1976).
135. Environmental Protection Agency, The Report to Congress: Waste Disposal
Practices and Their Effects on Ground Water Executive Summary, NTIS
PB-265-364 (January 1977).
136. EPA, Washington, D.C., Assessment of Industrial Hazardous Waste Prac-
tices, Rubber and Plastics Industry, Appendices, NTIS PB-282-073
(March 1978).
137. Manufacturing Chemists Association, A Guide for Contract Disposal of
Solid Waste, Technical Guide SW-2 (1974).
138. Manufacturing Chemists Association, A Guide for Subsurface Injection of
Waste Fluids from Chemical Manufacturing Plants, Technical Guide WR-1
(1976).
139. Manufacturing Chemists Association, A Guide for Incineration of
Chemical Plant Wastes, Technical Guide SW-3 (1974).
140. Manufacturing Chemists Association, Recommendations for Covered Hopper
Cars Eguipped with Vacuum Pneumatic Outlets for Transport of Dry Bulk
Chemicals and Plastics, Technical Bulletin TC-13 (1970).
141. R. H. Hiltz and J. V. Friel, "Application of Foams to the Control of
Hazardous Chemical Spills," pp. 293—302 in Proceedings of 1976
National Conference on Control of Hazardous Material Spills,
New Orleans, Louisiana.
99
-------
142. Manufacturing Chemists Association, Recommendations for Facilities for
Receipt of Dry Bulk Chemicals and Plastics in Pneumatic Hopper Highway
Vehicles, Technical Bulletin TC-12 (1970).
143. Manufacturing Chemists Association, Recommendations for Preloading
Inspection of Single Compartment Pneumatic Hopper Highway Vehicles
for Transport of Dry Bulk Chemicals and Plastics, Technical Bulletin
TC-14 (1970).
144. Manufacturing Chemists Association, Recommendations for Facilities for
Receipt of Dry Bulk Chemicals and Plastics in Pressure Differential
Hopper Cars, Technical Bulletin TC-16 (1971).
145. Manufacturing Chemists Association, Recommendations for Facilities for
Receipt of Dry Bulk Chemicals and Plastics in Covered Hopper Cars
Equipped with Vacuum-Pneumatic Outlets, Technical Bulletin TC-17
(1971).
146. Manufacturing Chemists Association, Recommendations for Terminal
Facilities for Pneumatic Transfer of Dry Bulk Chemicals and Plastics,
Technical Bulletin TC-18 (1977).
147. J. R. Hyland, Control of Oil and Other Hazardous Materials,
EPA-430/1-74-005 (June 1974).
148. Roy F. Weston, Inc., Pollution Prediction Techniques for Waste
Disposal Siting, A State-of-the-Art Assessment, NTIS PB-283-572 (1978).
149. "National Resources Defense Council vs. Train," Consent Decree 8,
Environmental Reporter Cases, pp. 2121—2136 (June 8, 1976).
150. R. C. Mitchell, J. J. Vrolyk, and R. W. Melvold, "Prototype System for
Plugging Leaks in Ruptured Containers," p. 225 in Proceeding of 1976
National Conference on Control of Hazardous Material Spills,
New Orleans, Louisiana.
151. R. C. Mitchell e_t al., "Methods for Plugging Leaking Chemical Con-
tainers," pp. 103—107 in Proceedings of 1972 National Conference on
Control of Hazardous Material Spills, Houston, Texas.
152. R. Cleary and D. Aldrian, "New Analytical Solutions for Dye Diffusion
Equations," American Society of Civil Engineers, Environmental Engi-
neering, pp. 213—227 (June 1973).
153. N. Yotsukura and F. Kilpatrick, "Tracer Simulation of Soluble Waste
Concentration," American Society of Civil Engineers, Environmental
Engineering, pp. 499—515 (August 1973).
154. 0. Road and E. Holly, "Critical Oxygen Deficit for Bank Outfall,"
American Society of Civil Engineers, Environmental Engineering,
pp. 661—678 (June 1974).
100
-------
155. H. Liu, "Predicting Dispersion Coefficient of Streams," American
Society of Civil Engineers, Environmental Engineering, pp. 59—69
(February 1977).
156. E. P. Holley, Transversal Mixing in Rivers, Delft Hydraulics Lab,
University of Illinois, Urbana (December 1971).
157. W. Stumm and J. J. Morgan, Aquatic Chemistry, Wiley-Interscience,
New York, 1970.
158. K. Verschueren, Handbook of Environmental Data on Organic Chemicals,
Van Nostrand, Reinhold, New York, 1977.
159. R. C. Koh, and Loh-Nien Fan, Mathematical Models for the Prediction of
Temperature Distributions Resulting from the Discharge of Heated Water
into Large Bodies of Water (October 1970) (on file at EPA, Washington,
D.C.).
160. P. A. Jensen and R. W. Hann, The Interrelationships of Material
Toxicity, Stream Properties and Quality of Spilled Material in
Assessing the Risk of Hazardous Material Spills, Texas A&M University
(May 1975).
161. R. V. Thomann, Systems Analysis and Water Quality Management, Environ-
mental Sciences Services Division, Environmental Research and Appli-
cations, Inc., New York, 1972.
162. Environmental Protection Agency, "Hazardous Waste, Proposed Guidelines
and Regulations and Proposal on Identification and Listing," Federal
Register 43(243), Part IV, p. 58946—59028 (December 18, 1978).
163. Environmental Protection Agency, "Waste Quality Criteria," Federal
Register 43(97), 21506—21518 (May 18, 1978).
TECHNICAL BULLETINS
Technical bulletins for specific toxic and hazardous compounds are normally
available to the general public and were requested and obtained through tele-
phone contacts with the industry and through questionnaires. The technical
bulletins were reviewed to obtain information relative to BMPs for specific
chemicals. Technical bulletins were received from several industries and are
referred to as Material Safety Data Sheets by Union Carbide, Shell Chemical
Company, and Celanese Chemical, as Technical Data Sheets by the Dow Chemical
Company, and as Chemical Safety Data Sheets by the Manufacturing Chemists
Association. A complete list of the technical bulletins reviewed during the
project follows.
101
-------
Typical contents of these technical bulletins include information on specific
chemicals relative to physical and chemical properties, hazardous ingredi-
ents, fire and explosive hazards, health hazards, reactivity, spill or leak
procedures, special safety precautions, and loading and unloading precau-
tions. Information obtained from these technical bulletins relative to BMPs
for specific chemicals is summarized in Appendix C.
Technical Bulletins
Reference
Numbers
Chemical
Company
Tl Dursban
T2 Methylenechloride
T3 Chlorobenzene
Dichlorobenzene
Trichlorobenzene
T4 Trichloroethylenes
T5 Methylchloride
T6 Pentachlorophenol
T7 Chlorine
T8 Acetic anhydride
T9 Butyl acetate
T10 Ethylenediamine
Til Formic acid, glacial
T12 Formic acid, 90%
T13 Phenol
T14 Propionic acid
T15 Toluene
T16 Triethylamine
T17 Carbaryl
T18 Carbaryl 50%
T19 Carbaryl 85%
T20 Carbaryl 95%
T21 Carbaryl 97.5%
T22 Acetic acid
T23 Acrolein
T24 Benzene
T25 Butyric acid
T26 Diethylamine
T27 Ethylbenzene
T28 Methyl chloride
T29 Vinyl acetate
T30 Amyl acetate
T31 Xylene
T32 Styrene
T33 Hydrochloric acid
T34 Acrolein
T35 Allyl alcohol
T36 Epichlorohydrin
T37 Allyl chloride
Dow Chemical
Dow Chemical
Dow Chemical
Dow Chemical
Dow Chemical
Dow Chemical
Chlorine Institute
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Union Carbide
Shell Chemical
Shell Chemical
Shell Chemical
Shell Chemical
102
-------
Technical Bulletins (Continued)
Reference
Numbers
Chemical
Company
T38 Vinyl chloride
T39 Para-Xylene
T40 Ortho-Xylene
T41 Xylene
T42 Toluene
T43 Cyclohexane
T44 Sulfuric acid
T45 Tetrachloroethane
T46 Maleic anhydride
T47 Nitrobenzene
T48 Nitric acid
T49 Paraformaldehyde
T50 Caustic potash
(potassium hydroxide)
T51 Phosphorus
T52 Hydrofluoric acid
T53 Phosphorus oxychloride
T54 Phosphorus trichloride
T55 Chlorosulfonic acid
T56 Methyl bromide
T57 Hydrochloric acid
T58 Acetic acid
T59 Ammonium dichromate
T60 Sodium
T61 Benzyl chloride
T62 Allyl chloride
T63 Vinyl acetate
T64 Diethylamine
T65 Acetic anhydride
T66 Acetic acid
T67 Benzene
T68 Chlorine
T69 Phosgene
Shell Chemical
Shell Chemical
Shell Chemical
Shell Chemical
Shell Chemical
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Manufacturing Chemists
Celanese Chemical
Celanese Chemical
Celanese Chemical
Manufacturing Chemists
Manufacturing Chemists
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
Association
INDUSTRIAL CONTACTS
A list of the industrial contacts that were made follows the list of techni-
cal bulletins reviewed.
103
-------
Industrial Contacts*
Reference
Numbers
SI
S2
S3
PI
P2
P3
P4
P5
P6
Rl
R2
R3
Site visit -
Site visit -
Site visit -
Phone contact
Phone contact
Phone contact
Phone contact
Phone contact
Phone contact
Questionnaire
Questionnaire
Questionnaire
Description
Procter and Gamble Cincinnati, Ohio
Hooker Chemical Company, Niagara Falls, New York
Allied Chemical Company, Hopewell, Virginia
- Allied Chemical Company
- Union Carbide Corporation
- Shell Chemical Company
- Stauffer Chemical Company
- Celanese Chemical Company
- E. I. du Pont de Nemours & Co., Inc.
Response - Celanese Chemical Company
Response - Shell Chemical Company
Response - Union Carbide Corporation
*See Appendix D for synopses of site visits and telephone contacts and for
questionnaire responses from the chemical companies.
104
-------
Appendix B
BMP KEYWORD SUMMARY
BMP
BASELINE
Spill committee
Spill reporting
Materials compatability
Materials inventory
Visual inspection
Security
Employee training
Preventive maintenance
Good housekeeping
ADVANCED
Prevention
Monitoring/instrumentation
Nondestructive testing
Labeling
Covering
Pneumatic/vacuum conveying
Vehicle positioning
Dry cleanup
References
1,2,5,12,18,57,78,83,100
1,2,3,8,9,12,15,22,44,49,54,78,83,100
6,43,44,50,53,64,85,111,112,138,P4,
P1,T44,T48,T58
12,78,83,100
2,4,5,7,9,12,13,21,24,27,29,40,44,45,
57,83,100,104,106,108,123,124,125,
143,144,145,146,P4,R1,T5,T43,T44,T46,
T47,T48,T50,T52,T53,T54,T55,T56,T57,
T61,T64,R3
2,26,45,50,61,83,100
1,2,5,8,12,44,78,83,84,100,104,105,
T43-T64,R3
1,4,5,12,13,21,42,43,53,106
1,4,5,12,13,21,42,43,53,122,P2,R3
3,4,5,7,8,9,12,13,21,25,26,28,29,40,
41,42,44,45,53,54,57,60,68,78,83,100,
105,106,107,125,130,138,T3,T4,T43,
T45,T46,T47,T48,T49,T50,T52,T53,T54,
T56,T57,T62,R3
4,40,44,46,100,106,112,R1,R3
5,21,50,61,111,125,T35,T36,T37,P4/
T43-64
7,11,61,67,68,103,R1,R3
50,103,124,140,142,143,144,145,146,
T44,T48,T52,T53,T54,T55,T57,T60,R3
123,124,T5,T48,T53,T54,T55,T57,
T61-T64
5,50,T49,T50,T59,R3
105
-------
BMP
References
Containment
Secondary containment
Flow diversion
Vapor control
Dust control
Sealing
Mitigation
Cleanup
Gelling agents
Foams
Sorbents
Physical methods
Mechanical methods
Treatment
General
Carbon adsorption
Volatilization
Liquids-solids separation
Ion exchange
Neutralization
Coagulation/precipitation
Incineration
Biological
Chemical oxidation
Ultimate Disposition
General
Deep-well injection
Landfill
Surface impoundments
Ocean disposal
Direct discharge
Reclamation
Municipal system
Contract disposal
1,2,3,4,5,6,7,9,10,11,12,13,17,21,
24,29,32,44,46,47,49,50,52,53,54,57,
61,62,68,78,83,100,112,125,Til,T14,
T16,T22,T26,T29,T35,T36,T37,T38,T41,
T42,T66,T67,PI,P2,P4,S2,S3,Rl,T63,R3
5,7,10,11,12,13,17,26,57,66,78,T43,R3
35,36,57,59,S3,T2,T3,T38,T44,T45,T46,
T52,T54,T55,T56,T57,T58,T61-T63,R3
50,103,110,142,144,145,146,T17,R3
6,7,30,31,60,150,151
2,9,24,31,33,34,47,49,60,101
36,49,59,60,101,141,P1,T23,T34,R3
2,9,24,33,34,36,47,49,60,100,101,114,
T13,T35,T37,T41,T42,T67,T45,T48,T53,
T54,T55,T63
S3,T17,P1,P2,T13,P4
9,47,60,78,T34,T35,R3
49,89,90,91,92,94,98,109,126
49,61,109,126
109,126
9,12,22,24,49,61,62,109,126,134
49,61,101,114,134
9,12,22,23,32,52,53,57,101,114,126,
134,S2,R1,T65,T44,T46,T48,T50,T52,
T53,T55,T58,T60,T61,R3
9,12,22,24,49,61,62,101,T59
12,54,61,63,101,126,134,139,T4,T6,T7,
T8, T9, T10 , T13 , T14, T15, T22, T23, T24,
T25,T26,T27,T28,T34,T35,T36,T37,T41,
T42,T65,T66,T67,S2,T43,T46,T47,T49,
T57,T60,T61,T62,T63,T64
48,49,61,109,126,134,T55,T58
32,126,134
58,61,65,69,89,90,126,128,139,155
7,54,61,63,126,138
18,54,61,63,64,125,126,133,134,T4,
T17,T41,T42,T67,T46,T47,T49,R3
6,7,12,30,61,63,120,P2,T44
44,61,126,T44,T6,R3
10,11,12,100,126,T44,T63,R3
12,52,61,63,65,126,PI,P2,S2,S3,P4,T4,
T41,R3
11,T47
65,68,128,137,S2,T51
106
-------
Specific Compound
or Group
Acetaldehyde
Appendix C
BHPs FOR SPECIFIC TOXIC AND HAZARDOUS CHEMICALS
BHPs Identified
Diversion, drainage control, holding ponds,
waste treatment
Incineration
Reference
Number
T7
Acetic anhydride
Incineration
Incineration, neutralization
T8
T65
Acetic acid
Containment, incineration
Dikes, incineration
Diversion, drainage control, holding ponds
waste treatment
Vapor control, employee training, labeling,
biological treatment, neutralization
T22
T66
7
T58
Acid
Containment, curbs, dikes, catchment basins
Neutralization
Dead-end sumps, ditches, curbing, good
housekeeping, preventive maintenance
Crushed lime, bicarbonate, soda ash
Dikes, high-level alarms
10
23
1
23
57
Acrolein
Dikes, neutralization, water spray, foam,
treatment
Foams, sodium sulfite, incineration
Foams, vacuum trucks, controlled burning
57
T23
T34
Acrylonitrile
Sorbents
Concrete diked areas
34
57
Adipic acid
Dry cleanup
53
107
-------
Specific Compound
or Group
Allyl alcohol
BMPs Identified
Sorbents, dikes, vacuum trucks, labeling,
controlled burning
Reference
Number
T35
Allyl chloride
Sorbents, containment, labeling, controlled T37
burning
Vapor control, monitoring (vapor), employee T62
training, labeling, vehicle positioning,
incineration
Ammonium dichromate
Labeling, dry cleanup, employee training,
chemical precipitation
T59
Benzene
Sorbents
Foam, vapor control
Incineration
Sorbents, dikes, incineration, landfill
34
59
T24
T67
Benzyl chloride
Butyl acetate
Employee training, labeling, visual inspection, T61
vehicle positioning, vapor control, neutralization,
incineration
Incineration T9
Foam, vapor control
59
Butyric acid
Calcium hydroxide
Carbaryl
Incineration
Flow diversion
T25
57
Dust control, drip pans, good housekeeping, dry R3
cleanup, vacuum cleanup devices, visual
inspection, sand bag containment, reclamation,
landfill, pneumatic conveying, employee training
Dust control, dry cleanup, landfill with
lime or caustic
T17
Chlorinated organics
Dead-end sumps, diking, curbing, good
housekeeping, preventive maintenance
108
-------
Specific Compound
or Group
Chlorine
BMPs Identified
Chlorobenzenes
Chlorosulfonic acid
alkaline absorption monitoring, liquid-level
alarms, water spraying, foam, neutralization,
nondestructive testing
Covering (roof)
Dead-end sumps, diking, curbing, good
housekeeping, preventive maintenance
Increased inspections, redundant
instrumentation, labeling
Level alarms, vapor control, pump transfer
(no air transfer)
Employee training, labeling, pneumaticconveying,
vehicle positioning, visual inspection, vapor
control, sorbent, neutralization, biological
treatment
Reference
Number
R3
Rl
1
P4
T3
T55
Corrosive liquids
Dikes, flow diversion, waste treatment, direct R3
discharge
Visual inspection, nondestructive testing Rl
Dikes PI
Separate dikes P2
Containment, materials compatability P4
Cyclohexane
Monitoring (vapor), labeling, visual inspection,
drains, curbs, incineration, employee training
T43
Employee training, labeling, vehicle positioning, T64
visual inspection, incineration
Diethylamine
Diethylether
Dry chemicals
Containment to treatment plant incineration T26
Foam, vapor control 59
Dry cleanup, good housekeeping, reclamation P2
Dry cleanup, reclamation PI
109
-------
Specific Compound
or Group
Epichlorohydrin
BMPs Identified
Dikes
Reference
Number
T36
Ethyl benzene
Foams, vapor control
Incineration
59
T27
Ethyl ether
Ethylenediamine
Ferric chloride
Foams, vapor control
Incineration
Sorbents
59
T10
34
Flaramables
Foams
PI
Formaldehyde
Sorbents
34
Formic acid
Hydrochloric acid
Containment, incineration
Vapor control, monitoring (vapor), employee
training, labeling, neutralization, visual
inspection, vehicle positioning, pneumatic
conveying
Til
T57
Hydrofluoric acid
Containment, neutralization 52
Dead-end sumps, diking, curbing, good 1
housekeeping, preventive maintenance
Neutralization, employee training, labeling, vapor T52
control, pneumatic conveying, visual inspection,
monitoring, alkaline absorption (vapors)
Human poisons
Maleic acid
Dust control, drip pan, good housekeeping, dry R3
cleanup, vacuum cleanup devices, visual
inspection, sand bags, reclamation, landfill,
pnuematic conveying, employee training, dikes,
flow diversion, waste treatment
Dikes, materials compatability PI
110
-------
Specific Compound
or Group
Maleic anhydride
Methyl bromide
Methyl chloride
BHPs Identified
Reference
Number
Employee training, labeling, monitoring (vapor) T46
visual inspection, vapor control, neutralization,
landfill, incineration
Employee training, vapor control, labeling, visual T56
inspection, monitoring (vapors)
Stop source of leak, incineration
Vehicle positioning, inspection
T28
T5
Methylene chloride
Vapor control
T2
Nitric acid
Employee training, monitoring (vapors), labeling, T48
sand sorbents, pneumatic conveying, materials
compatability, visual inspection, vehicle
positioning, neutralization
Sorbents 34
Nitrobenzene
Monitoring (vapors), employee training, labeling,
visual inspection, incineration, landfill,
municipal sewage system
T47
Paraformaldehyde
Monitoring (vapors), employee training, explosion
relief devices, labeling, dry cleanup,
incineration, landfill
149
PCBs
Covering, curbing, visual inspection, labeling R3
Surface impoundment P2
Contract disposal 52
Dead-end sumps, diking, curbing, good 1
housekeeping, preventive maintenance
Pesticides
Dead-end sumps, incineration
52
111
-------
Specific Compound
or Group
Phenol
BHPs Identified
Sorbents
Sorbents, dry cleanup, incineration
Sorbents, nondestructive testing,
monitoring, containment, security, drip
pans, depressed areas, inspections
Dikes, sumps, paving, reclamation
Reference
Number
34
T13
100
53
Phosgene
Alkaline absorption, monitoring, doubled-walled R3
tanks, cathodic protection, alarms (pressure,
temperature, and liquid level)
Increased inspections, redundant P4
instrumentation, labeling
Phosphoric acid
Containment, dikes, holding ponds, storage
Sorbents
6
34
Phosphorus
Employee training, labeling, contract disposal,
incineration
T51
Phosphorus oxychloride Employee training, labeling, monitoring, visual
inspection, pneumatic conveying, vehicle posi-
tioning sorbents, neutralization, vapor control
T53
Phosphorus trichloride Monitoring, employee training, labeling, sand T54
sorbent, vapor control, visual inspection, vehicle,
positioning, neutralization, pneumatic conveying
Potassium hydroxide
Employee training, monitoring (vapors), labeling, T48
dry cleanup, neutralization, materials
coropatability, visual inspection
Propionic acid
Containment, incineration
T14
Sodium
Employee training, labeling, vacuum conveying,
incineration, neutralization
T60
112
-------
Specific Compound
or Group
Sodium hydroxide
BHPs Identified
Sodium hypochlorite
Solids
Solvents
Styrene
Sulfuric acid
Sorbents
Dead-end sumps, curbing, good housekeeping,
preventive maintenance
Containment, neutralization, reclamation
Dikes, sumps, paving, reclamation
Curbing
Containment, chemical treatment,
neutralization, chemical oxidation
Dry cleanup, reclamation
Containment, sumps, neutralization
Containment, chemical treatment
neutralization, chemical oxidation
Labeling, employee training, materials
compatability, visual inspection, pneumatic
conveying, vapor control, neutralization, surface
impoundments, direct discharge
Containment, sumps, neutralization
Containment, treatment
Dikes, sumps, paving, reclamation,
Sorbents
Reference
Number
34
1
52
53
57
32
P4
Rl
32
T44
Rl
32
53
34
Tetrachloroethane
Monitoring (vapors), vapor control, sorbents,
employee training, labeling
T45
Trichloroethylene
Reclamation, incineration, landfill
Dead end sumps, diking, curbing, good
housekeeping, preventive maintenance
T4
1
Triethylamine
Containment, incineration
Foam, vapor control
T16
59
113
-------
Specific Compound
or Group
Toluene
BHPs Identified
Incineration
Dikes, sorbents, incineration, land burial
Sorbents
Foam, vapor control
Reference
Number
T15
T42
34
59
Vinyl acetate
Vinyl chloride
Containment, treatment
Waste treatment
T29
7
Vapor control, monitoring, employee training, T63
labeling, vehicle positioning, dikes, incineration,
direct discharge, sorbent (paper)
TV inspection
Dikes, water spraying
45
T38
Volatiles
Forced dispersal, heating, burning,
water spraying
35
Xylene
Dikes, sorbents, reclamation, incineration
landfill
T41
114
-------
Appendix D
SUMMARY OF INDUSTRIAL SURVEY
This appendix consists of a synopsis of telephone contacts and site
visits for obtaining information relative to BMPs in the chemical, pulp
and paper, and soap and detergent industries. It also includes ques-
tionnaire responses from several chemical companies.
When the reference number given in the "Telephone Contact" section is
preceded by a P, it refers to the phone number listed under "Industrial
Contacts" in Appendix A. When it is preceded by an R, it refers to the
questionnaire response listed in the same section of Appendix A. When
it is not preceded by a number, the reference can be found in the
"Articles and Reports" section of Appendix A.
115
-------
TELEPHONE CONTACT
Reference No: Pi
Date: November 14, 1978
Company: Allied Chemical Company
Location: Discussed Allied plants in general
Contact: Mr. Bob Fawcett, Morristown, New Jersey
Toxic and Hazardous Substances: phenol, sulfuric acid, ammonia, maleic
acid
BMPs Utilized: Secondary containment, foams, vapor control, recovery,
inspections, flow diversion, nondestructive testing
BMPs for Specific Chemicals:
Corrosive liquids - dikes
Maleic acid - dikes with acid resistant materials
Ammonium hydroxide - vapor control (double walled tank)
Flammables - foams used for fire protection
Dry chemicals - dry cleanup and reclamation
Phenol - dikes, reclamation
BMPs for Specific Ancillary Sources:
Material storage - secondary containment, vapor control, foams,
dry cleanup
Loading/unloading - paving to sumps, trenches to sumps
General Comments:
1. Secondary containment BMPs are the same for all
liquids regardless of chemical.
2. In most cases materials that are contained are
pumped out of containment for recovery.
3. Inspections frequencies for storage tanks should
be related to the volume of material and the
corrosiveness of the material.
References: 83, 100, 53
116
-------
TELEPHONE CONTACT
Reference No: P2
Date: November 28, 1978
Company: Union Carbide Corporation
Location: Union Carbide plants in general
Contact: Mr. Ed Hall, South Charleston, West Virginia
Toxic and Hazardous Substances: PCBs, dichlorobenzene, formic acid,
hydrochloric acid, propionic acid
BMPs Utilized: Dikes, drains, materials compatability, dry cleanup,
encapsulation in concrete, holding ponds, surface
impoundments, good housekeeping
BMPs for Specific Chemicals:
Corrosives - separate dikes
Solids - dry cleanup, recovery, good housekeeping
PCBs - surface impoundments
BMPs for Specific Ancillary Sources:
Material storage - dikes
Runoff - treatment, holding ponds
Loading/unloading - dikes
General Comments: 1. Drain dikes as soon as possible for safety and
fire protection.
2. RCRA guidelines followed for landfill disposal.
References: 5,R3
117
-------
TELEPHONE CONTACT
Reference No: P3
Date: November 15, 1978
Company: Shell Chemical Company
Location: Discussed Shell plants in general
Contact: Mr. V.W. Wilson for Mr. John Hallett, Houston, Texas
Toxic and Hazardous Compounds: allyl alcohol, allyl chloride,
epichlorohydrin
BMPs Utilized: secondary containment, inspections, materials
compatability
General Comments: No detailed discussion was pursued over the phone.
A specific list of questions was requested by
Shell for written response by Mr. Hallett.
Reference: R2
118
-------
TELEPHONE CONTACT
Reference No: P4
Date: December 5, 1978
Company: Stauffer Chemical Company
Location: Stauffer plants in general
Contact: Mr. Ed Conant, Westport, Connecticut
Toxic and Hazardous Substances: phosgene, chlorine
BMPs Utilized: inspections, redundant instrumentation, employee
training, dry cleanup, labeling
BMPs for Specific Chemicals:
Phosgene and chlorine - increased inspection, redundant instrumentation,
labeling
Solids - dry cleanup, recovery
Corrosives - containment, materials compatability
BMPs for Specific Ancillary Sources:
Material storage - inspection, instrumentation, containment,
labeling
General Comments: 1. All liquids are contained the same way.
2. Dry chemicals are stored inside in packages, no
stockpiles.
3. Dry chemicals spills are cleaned and recovered.
119
-------
TELEPHONE CONTACT
Reference No: P5
Date: December 13, 1978
Company: Celanese Fibers Company
Location: Charlotte, North Carolina
Contact: Mr. James Pullen
Toxic and Hazardous Substances: acetic acid, benzene, sulfuric acid
BMPs Utilized: curbing, separate sewer, covering
BMPs for Specific Chemicals: corrosive liquids, curbing;
solids, covering
BMPs for Specific Ancillary Sources: plant runoff - separate sewers
General Comments: No detailed discussion of BMPs was pursued over
the phone. A specific list of questions was
requested by Celanese for written response.
Reference: Rl
120
-------
TELEPHONE CONTACT
Reference No: P6
Date: December 12, 1978
Company: E.I. du Pont de Nemours & Co., Inc.
Location: Du Pont plants in general
Contact: Mr. Lloyd Falk, Wilmington, Delaware
BMPs Utilized: dikes, trenches, ditches, containment, dry cleanup
landfill, surface impoundments
BMPs for Specific Chemicals:
Corrosives - landfill, surface impoundments
Aromatics - landfill, surface impoundments
Human poisons - landfill, surface impoundments
Heavy metals - landfill, surface impoundments
BMPs for Specific Ancillary Sources:
Bulk storage - dikes, trenches, ditches
Plant runoff - containment
In-plant transfer - dry cleanup of solids
General Comment: No detailed discussions of BMPs was pursued over the
phone. A specific list of questions was requested
by Du Pont for written responses
Reference: 57
121
-------
SITE VISIT
Reference No: Si
Company: Procter and Gamble (plants in general)
Location: Cincinnati, Ohio
Date of Visit: August 9, 1979
Attendees: Curt Barton (P&G) Chuck Stuewe (Hydroscience)
Jan Whitfield (P&G) George Kehrberger (Hydroscience)
Howard Schwartzman (P&G) Fred Craig (EPA)
Philip Deemer (P&G) H. Thron (EPA)
Toxic and Hazardous Substances: caustic, chlorine, acids, benzene,
toluene
BMPs Utilized: curbing, covering, roof drains, catchment basins,
materials inventory, sumps, spills, reporting, visual
inspections, materials compatability, neutralization,
dry cleanup, good housekeeping, solvent traps,
pressure-drop alarms, vents, cathodic protection,
contract disposal, testing of new materials, spill drills
BMPs for Specific Chemical:
Acid/bases - materials compatability, curb separately,
neutralization
Solids - good housekeeping, dry cleanup
Benzene, toluene - containment, solvent traps
BMPs for Specific Ancillary Source:
Plant runoff - covering, containment, segregation of
wastestreams, monitoring
In-plant transfer - vents or tanks, cathodic protection
Loading/unloading - curbs, grading, sumps, chocks
General Comments: 1. No gravity drains are used in spill-prone areas.
2. Pumps for emptying containment are manually
operated.
3. Spills are cleaned up without water where possible.
4. Operator supervision during land volume transfers.
Estimated Costs: None available
Estimated Implementation Time: No estimate available
References: 3, 10
122
-------
SITE VISIT
Reference No: S2
Company: Hooker Chemicals and Plastics Corp.
Location: Niagara Falls, New York
Date of Visit: August 23, 1978
Attendees: Steve Warner (Hooker) C. Stuewe (Hydroscience)
James Glattly (Hooker) E.J. Donovan (Hydroscience)
H. Thron (EPA) F. Craig (EPA)
Toxic and Hazardous Substances: chlorine, sodium hydroxide, pesticides,
acids, anhydrous hydrogen fluoride,
PCBs
BMPs utilized: dikes, dead-end sumps, curbing, drip pans, monitoring,
flow diversion, contract disposal, dry cleanup,
employee training program, vapor control and collection
to scrubber, preventive maintenance, segregation of
cooling water and process sewer, materials compatability,
labeling, discharge to municipal sewage system, visual
inspection, centralized loading and unloading, redundant
instrumentation monitoring, good housekeeping
BMPs for Specific Chemicals:
PCBs - contract disposal
Hydrofluoric acid - containment, neutralization
Sodium hydroxide - containment, neutralization, reclamation
Pesticides - dead-end sumps, incineration
BMPs for Specific Ancillary Sources:
Loading/unloading - centralized facilities
Plant runoff - covering, roof collection gutters,
flow diversion
Sludge & hazardous - labeling, materials inventory
waste disposal areas
BMP Implementation Costs: $4—5 Million
Implementation Schedule: 3 years
Reference: 1
123
-------
SITE VISIT
Reference No: S3
Company: Allied Chemical Company, Fibers Division Plant
Location: Hopewell, Virginia
Date of Visit: October 25, 1978
Attendees: Ed Giebell (Allied) H. Thron (EPA)
Wayne Sullivan (Allied) Fred Craig (EPA)
George Crawford (Allied) Thomas Charlton (EPA)
J.O. Kirksey (Allied) George Kehrberger (Hydroscience)
Bob Fawcett (Allied) Joseph Cleary (Hydroscience)
Joe Clegg (Allied)
Toxic and Hazardous Substances: adipic acid, ammonium sulfate, phenol
sulfuric acid, sodium hydroxide
BMPs Utilized: spill control committee, spill reporting, employee
training programs, visual inspections, materials
compatability, security, monitoring, covering,
secondary containment (dikes, curbs, sumps, holding
ponds), flow diversion systems (drainage ditches,
trenches, drains), dry cleanup, doubled-walled tank
BMPs for Specific Chemicals:
Adipic acid - dry cleanup
Phenol, sulfuric acid, caustic - dikes, sumps, paving
Ammonia solution - doubled-walled tank
BMPs for Specific Ancillary Sources:
Material storage areas - dikes, curbing, doubled walled tank
Loading and unloading - paving, sumps, reclamation
Plant runoff - monitoring (TOC instruments), flow
diversion
Proposed BMPs: secondary containment, flow diversion
BMP Implementation Costs: Phase I - $5.2 Million
(see Table D-l)
Implementation Schedule: 3 years
124
-------
Table D.I. Estimated Costs of Proposed BMPs*
(Allied Chemical Company, Hopewell, Virginia, Plant)
to
in
Chemical
Ammonia solution
Sulfuric acid
Sulfuric acid and
sodium hydroxide
Ammonia solution
Ammonia sulfuric and
sodium hydroxide
Ammonium hydroxide
Ammonium carbonate
Ammonium hydroxide
EDTA
Sulfuric acid
Sulfuric acid
Sulfuric acid and
sodium hydroxide
Ancillary
Source
Loading/ unloading
Material storage
Material storage and
loading/unloading
Material storage
Material storage,
loading/unloading
Material storage
Material storage
Material storage
loading/unloading
Material storage
Material storage
Material storage
Loading/unloading
BMP
Curbs, paving
Curbing
Relocate tanks, dikes
paving, drains
Dikes, drains
Sewer system, pump
station
Dikes, paving, drains
Dikes, paving, drains
Curbing, drains, sumps
Curbing
Containment, relocate
pumps
Curbing, paving, drains
Curbing, paving, drains
Capacity
(gal)
12,000
1,000
17,000
18,000
750 gpra
376,000
4,800,000
132,000
4,000
480,000
600,000
15,000
Estimated
Capital Dollars
(as of 1978)
$ 280,000
50,000
400,000
190,000
1,300,000
500,000
950,000
700,000
10,000
100,000
600,000
70,000
$5,150,000
*For toxic and hazardous substances only.
-------
IELANESE
FIBERS COMPANY
January 9, 1979
JCP-79-08
(QUESTIONNAIRE RESPONSE—REF 1)
Mr. Joseph 6. deary
Hydroscience, Inc.
363 Old Hook Road
Westwood, Mew Jersey 07675
SUBJECT: BMP Questionnaire
Dear Mr. Cleary:
Attached is the completed questionnaire on Best Management
Practices for control of toxic and hazardous materials. If
you have further questions, call me on 704/554-2377.
Very truly yours,
C. Pullen
Manager, Environmental Activities
/gh
Attachments
cc: Mr. J. D. Underwood - New York
CELANESE FIBERS COMPANY . BOX 1414. CHARLOTTE. N C 23232 . TELEPHONE. 704—554 2000
A DIVISION or CELANESE CORPORATION
126
-------
Question 1
How will the proposed regulations on Spill Prevention (SPCC) and
Best Management Practices (BMP) relative to the hazardous compounds
and priority pollutant affect your plants?
Answer
In addition to requiring spill containment facilities for process
and storage areas, the proposed regulations will require submission
of a great deal of (unnecessary) paperwork. As an example, EPA and
the state must be notified in writing whenever a spill has occurred—
required information will include maximum storage and handling capa-
city of the facility and normal daily throughput; description of
the facility, including maps, flow diagrams and topographic maps;
cause(s) of the spill including a failure analysis of the system or
subsystem in which the failure occurred.
We also are concerned that the regulations might require collection
and treatment of rain water runoff from coal storage area and pro-
cess area streets. Neither of these are included in the cost
estimate of question 2, but both would be very costly.
Question 2
Do you have any SPCC or BMP plans being incorporated into the design
of future plants? Are these techniques any different for existing
plants?
Answer
Celanese Fibers Company (CFC) does not presently have any designs
in progress for new plants.
Question 3
Does your company have any experience with EMP's related to the
hazardous chemicals or with chemicals you consider hazardous?
Answer
BMP's for the chemicals we handle have generally been to provide
containment facilities—curbs, dikes, suirps, etc. Many of our
"hazardous" chemicals are biodegradable, so any spills of these
materials are directed toward the chemical sewer and biological
wastewater treatment system.
Question 4
For liquids, what spill prevention practices are utilized? Are these
practices any different for aromatic compounds such as a benzene and
toluene versus a corrosive liquid such as sulfuric acid? How are
corrosive liquids contained? Are all liquids handled the same rela-
tive to spill prevention and secondary containment?
127
-------
Answer
Hazardous liquid tanks are placed within diked or curbed areas,
or are buried underground. The tanks are equipped with high level
alarms, and overflow pipes are directed toward chemical sewers, if
possible. Chemical sewers are equipped with pH alarms, and in some
plants, a Total Organic Carbon analyzer monitors the main chemical
sewer for solvent spills. Spill prevention practices are essentially
identical for acids and solvents in our plants. Secondary contain-
ment will differ in that major acid spills are neutralized and di-
luted in the equalization ponds before they are sent to w/w treat-
ment, while solvents are simply diluted.
Question 5
Along the lines of spill prevention, containment, cleanup and dis-
posal, what practices are utilized for solids such as adipic acid?
Answer
CFC plants do not handle any hazardous solids except lime, which is
kept inside buildings in bagged form.
Question 6
How is chlorine or other gases handled relative to BMP's for pre-
vention and containment of spills?
Answer
Chlorine cylinders are kept in a remote area, under roof. No spill
facilities are provided.
Question 7
Do you conduct inspection programs for evaluating condition of storage
tanks, pipelines, valves, purrps, etc.? How frequent are these in-
spections and are they visual, structual testing or both?
Answer
The plants visually inspect tanks, pipes, valves, and pumps on a non-
routine basis. Tanks in corrosive service are checked for metal
thickness every 2-3 years. When material balances indicate excessive
chemical losses, equipment and piping are checked thoroughly.
Question 8
Are spill prevention and containment measures any different depending
on the potential source of the hazardous chemical spill, such as:
material storage area, loading and unloading areas, inplant transfers
and handling, runoff from plant site, and sludge or hazardous material
disposal sites? What are the practices used for these potential
sources of hazardous material spills?
128
-------
Answer
In our plants, the primary factors which effect containment facili-
ties are (1) the chemical or solvent itself, (2) the distance ro a
chemical sewer and (3) the potential quantity of a spill.
For a material such as a strong acid (HgStty), containment will be
in a sump to allow neutralization before directing the material to
the chemical sewer. For a weak acid (acetic), the material will
generally flow directly to trenches and/or sev/ers to the w/w
treatment facilities. Solvents are generally treated the same as
weak acid.
In a remote area, such as an unloading station, containment may be
a sump. Any spill would then have to be puirped to the chemical
sewer. In the (storage) tank farm, the volumes are so great that
earthen dike containment is used.
Question 9
How would you dispose of a hazardous material if contained in a
dike or sump? Would the chemicals be for example: reclaimed,
drained to the process wastewater for treatment, disposed or in
landfill? Would these procedures be any different for acetic acid,
benzene, sulfuric acid or any of the other chemicals handled at the
plant?
Answer
Large quantities (over 1000 Ibs.) of contained spilled materials
will be reclaimed if possible. Most of our spills are drained to
the w/w treatment facilities. Occasionally, an acid spill in a
rercote sump will be neutralized and landfilled. Reclaiming is
frequently precluded by contamination of the desired material.
Question 10
What practices are used to control hazardous chemicals from entering
the plant runoff?
Answer
Spills in our plants can enter the storm sewer system only through
manhole covers. Our usual practice to prevent this is to sandbag
the cover until the spill is cleaned up. In addition, oily materials
are trapped by an oil boon before the final outfall.
Question 11
Can you supply us with any_ cost information relative to developing
and implementing (e.g.,"By area, by chemical, by plant) a BMP plan
at your plant? Can you provide us with a project timing schedule
to implement a BMP plan?
129
-------
Answer
We presently have in one of our plants an approved appropriation
to install SPCC facilities for our process tanks and unloading
stations, to modify some of the sewers, to build a diversion pond
and to regrade critical areas. Cost will be $300 M, and timing
will be 15-18 months.
Question 12
Could you send us any technical bulletins or other information on
the specific hazardous chemicals you buy, use or make?
Answer
MSDS for acetic acid, acetic anhydride, and benzene are attached.
Question 13
Would you like to be put on our mailing list for a copy of the final
report?
Answer
Yes.
130
-------
Shell Oil Company
One Shell Plaza
P O Box 2463
Houston, Texas 77001
February 6, 1979
(QUESTIONNAIRE RESPONSE—Ref 2)
Mr. Joseph G. deary
Hydroscience, Inc.
363 Old Hook Road
Westwood, NJ 07675
Dear Mr. deary:
Your letter of November 16, 1978 requested response to a series of questions
relating to Best Management Practices (BMP) for chemical manufacturing, several
of which identified specific Shell products. Shell has always participated
to the greatest extent possible in assisting EPA and its contractors in the
development of effective and realistic regulations; despite the delay in our
response, this is no exception.
We have given the BMP matter considerable and careful thought, and find that
our response must be constrained by what we believe to be the legislative intent
regarding BMP for industry, as set forth at Section 304(e) of the Clean Water
Act (CWA). Unfortunately, it appears from several aspects that EPA's approach
to BMP exceeds the bounds set forth in both the law and its legislative history.
The proposed rules relating to BMP and the introductory narrative to your "BMP
Questions" reflect the agency-broadened approach. Rather than reiterate our
position on this matter here, we attach our letter of November 17, 1978 to
EPA, which conveys that position.* In addition, we draw your attention to the
similar posture taken by the Manufacturing Chemists Association in their
November 17, 1978 statement to EPA on the same proposed rules. Finally, as
our assessment of BMP contemplates SPCC requirements, we attach a copy of our
November 17, 1978 statement to EPA on SPCC proposed regulations.
Within the constraints of our position, we have responded to your questionnaire
as best we can. Hopefully, as this matter progresses, a more precise definition
of BMP will be established and more specific response can be made.
Along with our response and the referenced statements, we enclose materials
requested in Question 12. Please contact us if we can be of further assistance.
J\ D. Hallett, Staff Engineer
JDH:ddj trrvironmental Affairs
Attachments
cc: Mr. Howard Schwartzman, Proctor & Gamble
Mote by authors: Letter not reprinted here.
131
-------
1. How w-ill the proposed regulations on Spill Prevention (SPCC) and Best
Management Practices (BMP) relative to the hazardous compounds and
priority pollutant affect your plants?
We assume, first, that the yet to be established hazardous substances
will be essentially the same as those promulgated under the earlier list, now
in abeyance. Second, our response is based on the premise that SPCC regulations
for hazardous substances are similar in scope to those currently in place for
oil, and further, that BMP regulations reflect precisely Congressional intent
and statutory authority, no more. On this basis, we would anticipate the
expenditure of modest capital and expense monies in developing and implementing
SPCC plans at each site. Should the agency's current approach on an expanded
definition of BMP prevail, however, extensive time, money and effort will likely
be expended.
2. Do you have any SPCC or BMP plans being incorporated into the design of
future plants? Are these techniques any different for existing plants?
Shell incorporates SPCC plan requirements for oil as a matter of
practice, as we do for those chemicals we consider hazardous, despite the lack
of any regulatory requirement for the latter. When SPCC plan regulations are
developed for EPA's hazardous materials, we will incorporate whatever additional
SPCC or BMP practices and facilities may be required. With regard to BMP,
Shell believes it already practices BMP through application of standards, use
of SPCC plan facilities and as a matter of corporate policy. Note should be
taken that in keeping with this belief, Shell has applied such standards and
practices for those materials it considers aopropriate whether or not they
appear on the hazardous substances list and/or the toxic substances list.
As to differences between SPCC/BMP plans at existing and future olants,
we submit that differences are extremely likely, since each facility must be
evaluated on its own merits. Some such differences could be insignificant,
others vast.
3. Does your company have any experience with BMP's related to the hazardous
chemicals or with chemicals you consider hazardous?
Yes, we consider BMP to be largely a matter of good judgment and sound
engineering practice.
4. a) For liquids, what spill prevention practices are utilized? b) Are these
practices any different for aromatic compounds such as a benzene and toluene
versus a corrosive liquid such as sulfuric acid? c) Is acrolein or epichloro-
hydrin treated differently from other liquids? d) How are corrosive liquids
contained? e) Are all liquids handled the same relative to spill prevention
and secondary containment?
In general, spill prevention practices are no different from those
found in the literature and in general use. Where special concerns arise, such
practices may be modified. Specific practices depend upon the properties of
the material in question. Even here, practice may vary from location to
location for a host of site-specific reasons. Be that as it may, the ultimate
goal is to protect employees and citizens, the environment, and property.
132
-------
5. Along the lines of spill prevention, containment, cleanup and disposal,
what practices are utilized for solids?
See Question 4.
6. How is chlorine or other gases handled relative to BMP's.for prevention
and containment of spills?
See Question 4.
7. Do you conduct inspection programs for evaluating condition of storage
tanks? How frequent are these inspections and are they visual, structural
testing or both?
Yes. Frequency differs depending on materials of construction, the
service(s) of the tank, location of the facility, etc. Structural, visual, and
instrumental testing may be employed, depending on need.
8. Are spill prevention and containment measures any different depending on
the potential source of the hazardous chemical spill, such as: material .
storage area, loading and unloading areas, inplant transfers and handling
runoff from plant site, and sludge or hazardous material disposal sites?
What are the practices used for these potential sources of hazardous
material spills?
Yes. Practices are highly site-specific and dependent upon the material
in question.
9. How would you dispose of a hazardous material if contained in a dike or
sump? Would the chemicals be for example: reclaimed, drained to the process
wastewater for treatment, disposed of in landfill? Would these procedures be
any different for acrolein, ally! alcohol, ally! chloride, epichlorohydrin,
vinyl chloride, or isophene?
Any of these options is possible, depending upon the specific material
and circumstance of a spill.
10. What practices are used to control hazardous chemicals from entering the
plant runoff?
In general, the practical acproaches described in literature are
effective. See Question 4.
11. Can you supply us with any cost information relative to developing and
implementing (e.g., by area, by chemical, by plant) a BMP plan at your plant?
Can you provide us with a project timing schedule to implement a BMP plan?
To reiterate our response to Question 2, Shell believes proper BMP
requirements are already met, as we perceive Congressional intent relating to
and establishing this approach. Even should EPA expand upon that intent, it is
impossible to provide any meaningful information qn costs or timing at this stage
of BMP development.
133
-------
12. Could you send us any technical bulletins or other information on the
specific hazardous chemicals you buy, use or make (such as acrolein,
ally! alcohol, allyl chloride, epichlorohydrin, vinyl chloride, xylene,
toluene, and isoprene)?
Yes, they are attached for the materials you listed. Please note
that these items are intended primarily for customer safety information and
that spill and leak information emphasizes avoiding the contamination of public
drinking water supplies.
13. Would you like to be put on our mailing list for a copy of the final
report?
Yes.
134
-------
UNION CARBIDE CORPORATION
i^.UAUJ CHEMICALS AND PLASTICS
P. O BOX 3361, SOUTH CHARLESTON, w VA. 2530J
February l*t, 1979
(QUESTIONNAIRE RESPONSE REF 3)
Mr. Charles P. Ryan, P.E.
Hydroscience, Inc.
363 Old Hook Road
Westwood, NJ 07&75
Dear Mr. Ryan:
Your Valentine is enclosed!
Except for questions you may have and our inability to generate
cost data, the enclosed documents are provided in answer to
your inquiry on Best Management Practices and Spill Prevention,
Control and Countermeasure Plans for Toxic and Hazardous Materials.
Question 1 - Attached are the following:
a) Chemical Safety Data Sheet SD-80, Chlorine
b) Chemical Safety Data Sheet SD-95, Phosgene
c) Phosgene/Chlorine Leaks or Spills Control
in Areas of Loading, Unloading, Storage
Transfer and Processing Units
d) Chlorine Transfer, Containment and Emergency
Procedures
Question 2 - Attached are the following:
a) Clarification of PCS Storage
b) Carbaryl SEVIN Packaging Practices
and Procedures
c) Precautions and Housekeeping Practices,
SEVIN
Question 3 ~ Attached are the following:
a) Clarification of drainage of
field storage tanks
b) Field Storage Tanks
Questions 3,^,5 ~ Attached are the following:
a) Poisons, toxics, corrosives, flammable and
vo latilti liquids.
Concerning cost data, we can provide you with a cost estimate for
simply developing the document similar to the Oil SPCC Plan at
each of our locations. We need some guidelines to develop costs
for capital expenditures to meet BMP or SPCC requirements.
135
-------
Mr. Charles P. Ryan, P.E.
Page 2
February 14, 1979
The invitation remains open for you to visit our Kanawha Valley
and Texas Plants. We think it is important to you to compare
facilities where conditions of plant age, unlimited space as
compared to confined areas, product mix, etc., before BMP and
SPCC guidelines aie written.
Please inform me if I can be of further assistance.
Very truly yours,
M. E. Hall
MEH/klw
Attachments
136
-------
BMP (SPCC) QUESTIONS
1. How is phosgene (or other hazardous gases) handled
relative to BMP's (SPCC'3} for prevention and containment
of spills? In all areas (loading/unloading, storage,
transfer points, process) what practices are utilized
to prevent a leak? What is done if a leak does occur?
2. For solids (such as carbaryl, 7) in all areas (loading/
unloading, storage, transfer points, process) what
spill prevention and containment practices do you use?
You mentioned a simple dry operation - sweep up and
recovery. Anything else?
You mentioned a waste stockpile of PCS's. If this is
outside, how do you prevent the material from reaching
the surface waters? i.e, problems with runoff, windblowing?
Is material covered? drummed?
3. For flanmables and highly volatile liquids, what is
done regarding spill prevention and containment in the
various areas of the plant? Are they treated like any
other liquid? Are special storage tanks utilized? If
a spill occurs you mentioned draining as soon as possible.
Anything else? like foams?
4. For corrosives (hydrochloric, propronic, formic acids)
you mentioned isolated diked areas in tank storage
areas. In the tank farm and other areas of the plant,
what else is done regarding spill prevention and
control? Are corrosives treated like any other liquid?
5. For human poisons (we mentioned dichlorobenzene) what
spill prevention and containment practices are utilized
in the various areas of the plant? Are they treated
like any other material or are special measures taken?
137
-------
PHOSGENE AM) CHLORINE LEAKS OR SPILLS CONTROL IN AREAS
OF LOADING/UNLOADING, STORAGE, TRANSFERS AND PROCESSING UNITS
Leaks, spills or emissions of small amounts of phosgene or chlorine
into surrounding areas of the above-mentioned locations are controlled by
water curtain. Other means of controlling leaks are as summarized below:
A. Evacuation System - Designed to clean up by evacuation of
chlorine or phosgene equipment before removing out of service
for maintenance works. Evacuation headers are located in all
storage areas and processing units and they discharge into a
caustic vent scrubber.
Caustic Vent Scrubbers - Caustic solution is used to react
chlorine or pnosgene in all blowoff streams and evacuation
header discharges. All safety valves discharge into the vent
scrubbing systems. Vent scrubbers are located in storage areas
and the processing unit.
1. Chlorine Storage Area - There are two vent scrubbers, the
old and the new sniff towers. Tney are used interchangeably,
while one is in service the other will be on standby. The
old sniff tower is capable of handling 300 pounds per hour
of chlorine vapors while the new tower can handle 1,100
pounds per hour of chlorine vapors.
2. The Field Storage Vent Scrubber - Single vent scrubber,
capable of handling 1,720 pounds per hour of toxic vapors.
The vent scrubber is tie-in to the unit vent scrubbers and
can transfer feed to the unit vent scrubbers.
3. The Unit Vent Scrubbers - There are two vent scrubbers at
the processing unit. The normal vent scrubber whicn is
constantly used is capable of treating t>,000 pounds per
hour of toxic vapors. The second vent scrubber which is
normally on standby condition has the capacity larger
than the maximum discharge capacity of any single safety
valve in the concerned unit. It can handle a maximum
toxic vapor load of 46,000 pounds per hour.
138
-------
Besides the above leak control means, strict safety design
considerations were taken into account when designing systems to
prevent massive releases of the toxic vapors such design consideration
can be outlined as follows:
C. Phosgene Converter System - The following safety provisions in
the phosgene convertersystem are aimed primarily at the prevention
of a major phosgene or chlorine leak:
1. All equipment is designed under the lethal service provision
Of the ASME Code.
2. All chlorine and phosgene piping is for 300 psig.
3. All safety valves that discharge vapor into the existing
vent header have:
a) A rupture disc under the safety valve.
b) A pressure alarm to indicate a rupture disc leak.
c) A bellows to allow for the maximum expected vent '
header back pressure of 40 psig.
4. All safety valves that discharge liquid into the vent header
are set sufficiently below the maximum allowable working
pressure of the protected equipment to allow for the 40-psig
maximum back pressure.
5. The'chlorine vaporizers are equipped for two hazardous
conditions:
a) The steam supply will be automatically shut off if the
chlorine pressure in the vaporizer becomes too high.
b) Two independent alarms will sound and the chlorine
supply motor valve will close if the chlorine liquid
level in the vaporizers becomes too high.
G. The chlorine and carbon monoxide feeds to the phosgene
reactors will be automatically shut off under any of these
emergency conditions:
a) High Reactor Inlet Temperature - High temperature at this
point, after mixing the chlorine and carbon monoxide feeds,
would be an indication of methane or hydrogen contamination
in the carbon monoxide feed.
b) Low Carbon Monoxide Feed Pressure - Chlorine feed would
continue to the reactor and might contaminate the
phosgene.
139
-------
C. 6. contd.
c) Low Reactor Shell Liquid Level - This condition would
reduce the heat removal capability and might result in
a tube failure. Two independent liquid-level systems
are provided for extra protection against this hazard.
d) High Condenser Outlet Gas Temperature - High-tempera-
ture vapor from any ofthe phosgene condensers would
indicate loss of river water or brine cooling.
7. Automatic Brine Dump - Brine will be automatically dumped
from the phosgene condensers if conditions exist for a brine
leak into the phosgene. Normally the phosgene side pressure
is higher than the pressure on the brine side. If this
pressure differential becomes too low, motor valves in the
brine supply and return headers will automatically close
and the brine in the condensers will be automatically
dumped to the sewer. With no brine cooling, a high con-
denser outlet gas temperature will result, and the chlorine
and carbon monoxide feeds to the reactors will be automati-
cally shut off.
D. Phosgene Storage System - The phosgene storage system has been
designed with three ma^or safety considerations in mind:
1. That a massive release of phosgene should not occur from
mechanical damage or instrument failure.
2. That the stored phosgene should not become contaminated
with anything that might lead to a phosgene release.
3. That the tanks can be safely emptied and cleaned.
E. Protection Against Massive Release - The phosgene tanks have the
following mechanical and instrumentation features to protect
against a large phosgene release:
1. Underground, double-wall tanks were selected as the safest
method for providing new phosgene storage.
2. Three tanks are provided and one will always be empty as
an emergency spare.
3. The inner tank shell is designed for 250 psig versus the
normal 60 psig or less operating pressure to provide a
large margin of safety against overpressure.
4. The jacket is designed for 100 psig to contain the phosgene
in case of a failure of the inner tank.
5. All connections to the inner shell are 1-1/2 inches minimum
size, are of extra heavy construction, and are located on
one 26-inch diameter manhead in the top of the tank to
avoid having nozzles spread throughout the surface on the
tank.
140
-------
E. contd.
6. A top quality shutoff valve is provided on each tank
nozzle to reduce the frequency of evacuating and purging
these large tanks for the simple replacement of a leaking
valve.
7. A retaining yoke is installed around the phosgene tanks
to ensure that an empty tank will not be lifted out of the
ground by underground water.
8. The tanks are protected against corrosion by a waterproof
coating and by cathodic protection.
9. The inlet and outlet phosgene lines to the tanks have:
a) Automatic shutoff valves that close if a line ruptures.
b) Remote control, on/off valves located as near to the
tank nozzles as practical that can be closed from the
control room to isolate the phosgene tanks in the event
of a known pipeline rupture.
10. All phosgene pumps have a high-low ampere alarm to indicate
conditions that require the pump to be manually shut down.
11. High temperature, high pressure, and two independent high
liquid-level alarms are provided for the inner tank.
12. A high-pressure alarm for the outer shell indicates a
probable phosgene leak in the inner shell.
F. Protection Against Contamination - The most hazardous phosgene
contaminants present in the phosgene production and storage systems
are water, caustic, and calcium chloride brine (30%). The reaction
of phosgene with these contaminants is exothermic and if uncon-
trolled, could create conditions leading to a major release of
phosgene. The following features have been provided to minimize
the possibility of contaminating the stored phosgene, and to
minimize the effects of contamination should it occur.
1. The phosgene cooling system is designed to prevent stored
phosgene from becoming contaminated with the coolants.
Phosgene is cooled with chloroform in an external heat
exchanger with the pressure higher on the phosgene side. The
chloroform is cooled with brine in a second heat exchanger
with the pressure higher on the.brine side to prevent con-
taminating the brine. A phosgene or brine leak into the
chloroform will build up in the chloroform surge tank where
a high-level alarm has been provided. Phosgene contaminated
with chloroform could be used in the TDI and methyl isocyanate
processes with no hazardous results.
141
-------
F. contd.
2. A trap tank is installed in the vent collection header
upstream of the vent scrubber to avoid the possibility of
caustic contaminating the stored phosgene. This trap tank
will normally operate empty, and any level increase in the
tank, which is measured by two completely independent
liquid-level devices, will indicate the following abnormal
conditions:
a) Caustic blowback from the vent scrubber.
b) A leaking tube in the phosgene cooler or the chloroform
cooler which would overflow from the chloroform tank into
the trap tank.
c) Overfilling the phosgene tank which would overflow
into the vent header.
3. The vent header, both upstream and downstream of the trap
tank has check valves installed as added protection against
backflow from the vent scrubber into the phosgene tanks.
4. The cooling system is designed to keep phosgene at a
maximum temperature of 0°C where the reaction from caustic
or water contamination is very slow.
5. The safety valves on the phosgene storage tanks are sized
to release the gases that would evolve from the reaction
of phosgene with caustic or water at 8°C.
6. A separate caustic vent scrubber is installed in the
storage tank area to treat all normal and emergency vents
prior to discharge to the existing flare tower. The
existing caustic scrubber in the SEVIN area would have
been a potential source of contamination from the many
processes that discharge into it. Also, the SEVIN vent
scrubber is about 600 to 700-feet away, too far for
dependable service.
G. Cleaning and Evacuation Provisions - The phosgene tanks are
designed and installed with features to facilitate cleaning:
1. The tanks slope toward the end where the manhead is located
and where the outlet pipe takes suction.
2. The intern.il uLiCConing rings are perforated for liquid
to drain to the low end of the tank on both the inner
tank and in the shell side.
3. The phosgene transfer pump takes suction from a sump and no
more than five gallons should be left in the tank after
pump-out.
4. The inner tank is designed for an external pressure of 25
psig to permit the residual phosgene to be evacuated by
rvjlln" •'sc'iv in the ip.mr tank vhile lew-pressure steam
is placed on the shell side.
142
-------
Control of Chlorine Leaks or Spills - Chlorine gas is only
slightlysoluble in water;therefore, turning a stream of
water on a leaking container or fitting will only aggravate
the situation by supplying heat to the liquid chlorine confined
in the container, causing it to evaporate faster and thus in-
creasing the gas flow. Furthermore, water increased the
corrosive action of chlorine and may make the leak worse.
Shutting off the source of chlorine or plugging the hole, if
possible, is the most effective action to be taken.
The evolution of gas from unconfined liquid chlorine, such as
when spilled on the ground or in open vessels, can. be reduced
by spraying with cool water as at the low temperature of uncon-
fined (freely evaporating) liquid chlorine it forms crystals
of chlorine hydrate with water. These crystals contain about
33-percent chlorine by weight, and although they are formed at
temperatures up to 49.3T (9.6°C), they evolve chlorine gas
readily even at 32°F (0°C), and are of negligible advantage in
warm weather.
A more effective method of controlling the rate of evaporation
of chlorine from a liquid spill is to use fire-fighting foam
which acts as an insulating layer over the surface of the
liquid chlorine. Suitable compounds are Kerr's Proform Angus'
Micerol, or Pyrene Standard Protein Compound. Other types of
foam such as chemical foam, high expansion foam, or mechanical
foam from all-purpose or alcohol-resistant foam compounds must
NOT be used as they are not stable.
This procedure utilized a six-inch layer of foam applied in-
directly to the surface of the chlorine spill to reduce the rate
of evaporation to about 1/4 the normal rate. A crust of ice
(and chlorine hydrate) forms under the foam which is protecting
a chlorine spill may provide some time to achieve other emergency
activities such as evacuation of personnel, preparation for
permanent removal or destruction of the chlorine, etc.
Destruction of chlorine from a liquid spill may be accomplished
by spraying with a solution of caustic soda or soda ash if
available. This type of treatment requires at least 1-1/4 pound
of caustic soda or 3 pounds of soda ash per pound of chlorine.
For example, to absorb 100 pounds of chlorine, use:
1. 125 pounds solid or flake caustic soda dissolved in 40 gallons
water to form about 42 gallons (oil barrel) of 27.5 percent
solution; or,
2. 300 pounds soda ash dissolved in about 100 gallons of water
to form about 105 gallons (2-1/2 oil barrels) of a 26.5
percent solution.
143
-------
J. contd.
3. Phosgene Leak Detector - Air sampling detectors in the
range of 0 X _ 0.1 ppm have been installed in all three
level structure of the processing unit. An alarm will
sound to alert the operator in the control room if the
air sample on any level contains more than 0.05 ppm
phosgene concentration.
All personnel working to stop leaks or spills must have approved
protective equipment underlined on section under safety of the unit
operation procedure. There is no other procedure beside these
mentioned above.
YAM/nh
Reference Sources
1. Phosgene System SOP (1978) .
2. Chlorine System SOP (1978).
3. Safety Consideration Report (1970)
144
-------
CHLORINE TRANSFER, CONTAINMENT, AND EMERGENCY PROCEDURES
Chlorine
A. Unloading and Transfer of Liquid Chlorine
I. Leak containment - new installations
a. Piping is fabricated and installed per chlorine
Institute anc UCC approved specifications.
b. All piping and equipment is degreased and
cleaned before installation.
c. Piping is hydrostatically tested to 550 psig.
d. All piping and equipment is dried with H, to
a dew point of -40°C. Care is taken to
eliminate water at low points.
e. Vapor Cl- is first introduced and all flanges
and fittings tested for leaks with a 25% ammonium
hydroxide solution.
f. All hoses are tested at 500 psig and tagged
with test date and pressure.
2. Leak containment - normal operations
a. Connections to tank cars and barges are leak
tested under H pressure, then under vapor Cl
pressure with 25% ammonium hydroxide before
liquid C12 is introduced.
b. Max line pressure is controlled at 75% of
design working pressure.
c. Cl_ from hoses and necessary lines is evacuated
to a caustic scrubber before hoses are disconnected.
d. Hoses are hydros tatically tested to 500 psig at
least yearly.
B. Chiorlna '.sloasas
I. Depending on *-i*e of leak, appropriate emergency response
taken is (a) local gas alarm, (b) plant-wide gas alarm, and
c) activation of KVIEPC". All include emergency response
to varying degrees, including fire squads, rescue squads,
evacuation procedures, and communication.
2. Leaking lines or equipment are immediately evacuated to a
caustic scrubbing system. Small leaks may be temporarily
clamped pending evacuation and maintenance.
3. Liquid spillage may be covered by a water fog. Water is
prevented from reaching the leak itself.
145
-------
Chlorine is extremely toxic to most forms of life and leaks or
spills present severe air and water pollution hazards. Concentrations
of 0.1 percent in the air may be lethal if inhaled (2) and concentra-
tions of 1 ppm in water may be toxic to aquatic life (16). Because
of its bactericidal properties, chlorine cannot be disposed of in
biological waste treatment facilities and because it is nonflammable,
it cannot be disposed of by incineration.
Chlorine is effectively disposed of by absorption and neutrali-
zation with alkalies or alkaline solutions.
I. Other Ways of Preventing Chlorine Leaks or Spills
1. These are remote shutoff valves at all necessary locations
in all chlorine transfer lines with controls for closing
valves located in personnel shelters to immediately shut
off loading storage tanks or feeding from tank to processing
units in case of hose or line rupture.
2. Four tanks are provided with one low-pressure tank as an
emergency spare.
3. Also the Institute Plant is a member of the Tri-State
Pollution Prevention and Cleanup Committee. Resources
are available to contain and clean up any major spills
by calling 304-344-3609.
J. Leak Detection
There are two ways of detecting chlorine and phosgene leaks in
the unit.
1. The Use '-of 10-Percent Ammonium Hydroxide Solution - Leaks
higner tnan an elusive type or hignly nonvisible type leak
can easily be found by spraying a 10-percent ammonium
hydroxide solution in the area where the leak is detected.
Phosgene reacts rapidly with ammonia to form a dense blue-
white cloud.
CAUTION: Use coverall goggles to avoid severe eye burns
caused by ammonia. Approach leak cautiously to
avoid exposure. Also, do not use ammonia straight
from lab plastic bottle since the concentration
is higher than 10 percent. Dilute it with water
in 5-1 ratio of water to ammonium hvdroxice
solution. It may be difficult to find leak by
applying ammonia when it is raining.
2- Use of Draoer-Tubes - An elusive type leak or testing equip-
ment wnich nas been on evacuation, use a Drager instrument.
Carefully blow down through a drain valve at several points
and use the Drager detector tube. By drawing gas through the
tube with five squeezes of the bul,;, the tube will indicate
tr.e ppm cf p h c 3 5 e r. e present.
CAUTION: DC sure to exhaust Use ili.-Luct.or bulk several
times before taking it inside the control room.
It may contain phosgene.
146
-------
't. Breathing air equipment is provided for operating and
emergency personnel. Escape-type respirators are also
stored in appropriate locations.
KVJEPC - Kanawha Valley Industrial Emergency Procedures
Committee - An emergency alert system which activates valley
police and fire departments, ambulance, emergency, and hospital
service.
JJH
147
-------
PCB STOr.ftGE
The Environmental Protection Agency proposed in the February 7, 1973,
Federal Register, regulation for "Polychlorinated Biphenyls (PCBs) Disposal
and Harking". The section from these regulations on storage follows:
the storage facility meeting the re-
quirements of paragraph .
(8) Any PCB container used for the
storage of liquid PCB chemical sub-
stances or liquid PCS mixtures shall
comply with the specifications of the
Department of Transportation (DOT).
40 CFR 173.348, revised December 31.
1378. For 35 gallon drums, an 18 gauge
steel or heavier and 2-biuig head shall
be used. For 5 gallon drums, 24 gauge
steel or heavier shall be used. They
must also meet DOT Specification
17E. Any PCB container used for the
storage of non-liquid PCB mixtures,
PCB articles, or PCB equipment shall
meet the requirements of the DOT
Specifications S, 8B. or 17C with a re-
movable head.
(7) PCB articles and PCB containers
shall be dated when they are placed in
storage under r^arosrraph tb) or sub-
paragraphs (cXl) or (cX2). The stor-
age shall be managed so that the PCB
articles and PCB containers can be lo-
cated by the date they entered stor-
age.
(8) Owners or operators of storage
facilities shall establish and maintain
records as provided In Annex VT.
! 111.il Storu* tat dUpoul.
(a) Any PCB article or PCB contain-
er stored for disposal before January
1. 1983, shill be removed from storage
and disposed of as required by this
Part before January 1. 1984. Any PCB
article or PCB container stored for dis-
posal after January 1, 1883, shall be
removed from storage and disposed of
as required by this Part within one
year tram the elite when It was first
placed Into storage.
(b) Except as provided in paragraph
(c) of this section, after July 1. 1978.
owners or operators of any faculties
used for th* itoraae of PCB's designat-
ed for disposal shall comply with the
foUovtag requirements:
(1) Such facilities shall have:
(1) An adequate roof and walls to
prevent rain water from reaching tn«
Komi PC3s.
(11) An tcequate Door which has con-
tinuous Curbing With a minimum six
Inch high curb. Such floor and curblna
must provide a ccnt&inment volume
equal to at least two tiawa tbe Internal
volume of the largest PC3 article or
PCB container stored therein or 23
percent of the totil Ir.tsmal volume of
all PCB equipment or container*
stored therein, whlchsver is greater.
(Ill) No drain valves, floor drains, ex-
pansion Joints, tswer lines, or other
openlnes that could permit liquids to
flow from the curbed area.
(lv> Floors and curblns constructed
of continuous czaooth and Impervious
materials such as Portland cement
concrete or steel to prevent or mini-
mize penetration of PCB chemical sub-
stances or mixtures.
(v) No storage facility shall be locat-
ed at a site which la below the 100-year
flood water elevation.
(cXl) Non-leaking PCB articles and
equipment may be stored temporarily
In an area that does not comply with
the requirements of paragraph for
up to thirty diva from the date of re-
moval from service.
(2) Storage of non-leaking and struc-
turally undamaged PCB large high
voltage capacitors on pallets next to a
storage facility meeting the require-
ments of paragraph (b) stull be per-
mitted until January 1, 1983. auch
storage will be permitted only when
LJCC plants are in compliance with this requirement.
148
-------
CARBARYL SEVIN PACKAGING PRACTICES AND PROCEDURES
ENGINEERING CONTROLS
A. Dust Collection and Control
1. Permanent hooding and air removal capability is provided in
areas in which dust level in the air might be expected to
otherwise exceed TLV during normal operations. These- areas
include:
a. Bag Packer
b. Primary Conveyor Transfer Points
c. Bag Flattener
Systems are engineered to reduce dust level well below TLV
during normal operation.
2. Additional dust collection facilities are provided at locations
at which dust generation during other-than-normal operations
might exceed TLV. These include:
a. Transfer System Rotary Valve Cleanout Ports
b. Bag Packer Surge Bin Access Port
c. Packer Cleanout Ports
d. Broken Bag Hopper
3. Permanent catch pans are provided under elevated conveyors
to prevent dust emitted from broken or sifting bags from
spreading over an extended area.
A. The dust collection system is interlocked with other systems
to prevent transfer of material to the packaging area when
the collection system is not in service.
5. Air removed is filtered in a reverse-jet type bag collector
before being discharged to the atmosphere. No air is
recycled. Dust collection system capability is 5000 cfn.
6. Breathing air outlets are provided in all critical areas
for use in case of gross equipment malfunction.
7. Respirators are provided and their use required when dust
level is obviously high. Such situations might occur in
case of broken bags, spill cleanup, and equipment cleaning.
8. All equipment is designed and maintained dust tight.
9. The packaging area is classified as Class II, Group G,
Division 1, and the remainder of the building as Class II,
Group G, Division 2. All electrical equipment meets the
appropriate I!E."A designation for these cl as's i fi cat ions.
149
-------
10. All equipment and building structural steel are grounded to
eliminate potential accumulation of static electricity.
B. Environmental Temperatures and Humidity
1. Bag packaging area is supplied with cooled, conditioned air.
System capacity = 5 tons. Packaging area volume = 7000 ft.3
2. Cooling and ventilation in the bag palletizing and storage
areas is provided by makeup and exhaust blowers.
Building area = 7800 ft.2
Blower volume = 20000 cfm
Natural convection roof ventilators = 13 ~ '8" diameter
3. Heating is supplied by a packaged forced air, steam heating
uni t.
HOUSEKEEPING PROCEDURES
1. Janitors are provided on each shift. Duties include:
a. General housekeeping in packaging and warehousing areas
b. Cleanup of spi1 Is
c. Recycle of broken bags
d. Recycle of recoverable material collected in
Act i v i t i es a & b
e. Cleaning of rest rooms and lunch facilities
2. A vacuum system with multiple pickups is provided for recovery
of spills, material buildup on equipment and building structural
steel, etc. This material is recycled to process.
3. Material not recoverable by vacuuming is removed in one of two
ways:
a. Material on floors is mopped up.
b. The entire building interior is water-washed at
regular intervals of approximately 3 months.
Wash water is directed to a process sewer.
4. Waste packaging materials (i.e. pallets, cardboard, empty bags)
are collected daily for disposal through normal plant procedures
outlined elsewhere (landfill).
SANITATION
1. Clean outer clothing, including clean shirt and trousers,
and new gloves and socks are provided each work day. Additional
clean clothing is provided if required.
2. Disposable clothing is discarded via standard plant disposal
procedures (landfill). Dirty shirts and trousers are stored
in plastic bags for laundering.
150
-------
3. Thirty minutes of shower time are provided at the end of each
shift. Shower facilities are separate from but adjacent to the
packaging facilities. Additional shower time is provided during
working hours in case of above-normal exposure.
k. A lunch room is provided in a remote area of the packaging building.
The lunch room is supplied with conditioned, outside air. Wash up
is required prior to eating.
ENGINEERING CONTROLS
Housekeeping - Unit inspections are made monthly; Plant Management
Inspections at least once annually. Gross spills of Carbaryl are prevented from
entering the process sewer by placing sand bags around the sewer openings. In
addition, the process sewer flows to an interceptor decanter so that Carbaryl
or other organic materials may be pumped back to the unit tanks for disposal.
An automatic pump at this decanter operates on interface control. Spills of
dried Carbaryl are recovered using a large vacuum unit to pick up the material
and transfer it to a bin. In-process Carbaryl is shoveled up and placed in
fiber-paks or open top dumpsters for disposal at a landfill. Slurry samples
and other in-process samples are collected in fiber-paks and disposed of in
the landfill. Samples of dry Carbaryl are collected in a fiber-pak and reclaimed
with the vacuum apparatus. Slurry leaks onto process equipment and piping are
removed with high-pressure water with the Carbaryl water slurry then entering
the process sewer.
The process is controlled from a central control room. This room also
contains lunch room facilities and toilets for the operating personnel. The
control room is air conditioned for summertime comfort.
Carbaryl is transferred from one piece of process equipment to another
in closed conduits. Transfer of dry Carbaryl is done pneumatically.
PERSONAL PROTECTIVE DEVICES
All operating and maintenance personnel working where Carbaryl is present
are provided with a coverall program. Clean coveralls are provided daily for
their use. The dirty coveralls are collected daily and laundered by a commercial
cleaner. Lockers are provided for street clothes. The coverall program is
optional; however, essentially all employees are participants.
Rubberized over garments are available for each employee should he or his
supervisor deem them necessary, (generally used when a lot of water is present;
for example, high-pressure water washing equipment). If an employee will be
working in a dusty atmosphere (Carbaryl), a dust mask is issued for light dust.
A full face mask (covering the eyes) that is connected to the plant breathing
air header or a Scott Air-pak is required if the dust atmosphere is severe.
Judgment of the severity of the atmosphere is the responsibility of the immediate
superv i sor.
All e—oloy-je; 3r?. iss'.'^-i olcvs d^sicnjd for chemical service. Replacement
gloves are readily available at all times.
151
-------
System Initial Cost Annual Cost Energy Cost
Dust Collection 29,100 2,500 It, 100
Packer Blower 1,500 100 500
Vacuum System ^5,000 2,000 900
Makeup Air Heating 20,000 500 2,300
Air Conditioning 16,000 1,000 kQO
(1) Maintenance 6 Spare Parts
(2) Electrical Cost, except for Makeup Air Heating
PERSONAL PROTECTIVE EQUIPMENT COST
Cost per Employee/Yr Total/Yr
Gloves $0.93/pr $2<(2 $2,662
Socks $0-39/pr 101 1,115
Respirators (not required to use)$0.15 10 110
Coveralls $1.05 per change 257 2,830
PERSONAL HYGIENE
Thirty minutes for personal cleanup time is allowed at the end of
each shift. At standard rates, cost would be $1,350/yr per man.
Employees share a shower/locker facility with others. Estimated cost
based on the ratios of employees is $15,000.
JJH/err
152
-------
Plant Safety Department Records
Personnel Training; Operational and Maintenance Control; Emergencies;
Environmental Control
Appendix A: SEVIN Reaction Training Schedule
Appendix B: Training Information, Physical and Chemical Properties,
Specifications, Toxicology, Safety for Formulators,
Dust Explosions, Fire Safety, Waste Disposal
Appendix C: Training Information, Safety for Formulators
Appendix D: Training Information, Reactive and Hazardous Chemicals
Manual Sheet
Appendix E: Training Information, Health Hazards
Appendix F: Training Information, Choi ines terase Inhibition
Appendix G: Master Card Tagging and Lockout Procedure
Appendix H: Rules Governing Entry into Vessels and Confined Spaces
Appendix I: Order for Waste Removal
Engineering Controls, Physical Stresses, Housekeeping, Sanitation, Personal
Protective Devices, Safe Handling in Formulator's Plants. (Includes
considerable duplication of training information).
Product Technical Bulletin:
No. F 43382, Dec. 1970
Product Technical Bulletin:
Food and Fiber, No. 2-2353,
Facts on SEVIN Carbaryl Insecticide—
SEVIN Carbaryl Insecticide— For Abundant
153
-------
PRECAUTIONS AND HOUSEKEEPING PRACTICES USED AT THE SEVIN UNIT
(158 DEPARTMENT) DEALING WITH SEVIN AND SEVIN SLURRY SPILLS
SEVIN Slurry Spi 11 s
Spills of this nature generally occur when slurry pump seals fail or
when a slurry line develops a leak. These types of leaks can be easily
isolated or stopped.
Once the leak is stopped, laborers wearing coveralls, boots, gloves,
and standard plant safety equipment shovel the spilled SEVIN slurry into
properly marked trash pans. These pans are than emptied in accordance
with UCC standards at the Goff-Mountain Landfill.
After the SEVIN slurry is removed, the pad is water-washed to further
clean the effected area. Oil layers are skimmed and returned to the
system. The water layer is discharged to the wastewater treatment unit.
Minor SEVIN Spi1 Is
At the Production Unit, SEVIN spills occur around the drying and
transfer equipment. These spills can also be easily isolated and cleaned
up. The SEVIN in these types of spills becomes contaminated with particles
from the surrounding area and is unable to be reclaimed.
The SEVIN is cleaned up and disposed as noted above under "SEVIN
Slurry Spi1 Is".
DAJ/nh
154
-------
FIELD STORAGE TANKS - DIKE VALVE CONTROL
Dikes surround field storage tanks. Generally, the dikes were built to
hold slightly in excess of the volume of the largest tank within that dike.
At older plants, some of the dikes do not meet this criteria - the basic
philosophy then was to contain the stormwater from a heavy rain and tank
leakage (usually valves) or spills; it was not based on a catastrophic tank
rupture.
Dike valves, usually positioned outside the dike, are kept in the closed
position, and opened only to drain rainwater out of the diked area. At most
of the plants, the water, if it is clean, is discharged to the receiving stream.
If the water is contaminated, it is pumped out of the dike for recovery of
the "goodies", or if the concentration is such (low) that recovery is infeasible
then it is pumped to the process sewer for treatment at the wastewater treatment
uni t.
UNIT TANKS
The basic philosophy on unit tanks incorporates a balance between safety
and the environment. A fire in a unit tank farm where a dike exists and the
valves are closed would endanger the production unit(s) and other storage
tanks, and probably would result in more damage to the environment than
immediate discharge to the sewer - even to the cooling water sewer or directly
to the receiving stream.
TANK CAR/TANK TRUCK LOADING/UNLOADING
Generally, drainage from tank car/tank truck loading/unloading facilities
is directed to the process sewer through an underflow/overflow sewer arrangement.
Under normal conditions spills from the facility will discharge to the
wastewater treatment plant; but, in the case of a rainstorm, the initial
flow and thereafter a measured amount will discharge to the wastewater treatment
plant but the excess flow is discharged to the receiving stream. This is
necessary in order not to overload, hydraulica1ly, the wastewater treatment
plant.
MEH
155
-------
BEST MANAGEMENT PRACTICES FOR CONTROL OF
HUMAN POISONS, TOXICS, CORROSIVES, AND FLAMMABLE AND VOLATILE LIQUIDS
In addition to standard controls already discussed,
design criteria, equipment, and procedures for the manufacturing,
processing, storing, handling, and distributing are developed
for each type of chemical listed in the heading.
MEH
156
-------
E. 1. DU PONT DE NEMOURS & COMPANY
iNco.roR.Tco (QUESTIONNAIRE RESPONSE REF 1)
WILMINGTON, DELAWARE 19898
March 30, 1979
Mr. George J. Kehrberger
Hydroscience, Inc.
363 Old Hook Road
Westwood, NJ 07675
Dear George:
In connection with a best management practices (BMP) study Hydro-
science is doing for EPA, you asked us to supply information in
response to certain questions about eight chemicals Du Pont pro-
duces: aluminum sulfate, ammonium chloride, dimethylamine,.
formaldehyde, methoxychlor, methyl methacrylate, phosgene, and
vinyl acetate.
Since Du Pont produces or uses one or more of the eight chemicals
at more than one site, I have tried to respond in a comprehensive
manner rather than in detail. The degree of control required for
a particular chemical will vary depending on its physical,
chemical, and biological properties.
Attached is our response. I have taken up each question in turn
and referred to particular chemicals as appropriate.
I have included several pieces of Du Pont literature on some of
the compounds of interest. I shall try to locate others and for-
ward to you.
If you have any questions, please do not hesitate to let me know.
Very truly yours,
ENGINEERING SERVICE DIVISION
,- /'
L. L. Falk
LLF:rbw
Atch
157
-------
HYDROSCIENCE BMP STUDY QUESTIONNAIRE
QUESTION 1.
Are spill prevention and containment measures any different depend-
ing on the ancillary source where a hazardous chemical spill or loss
could occur (such as: material storage area, loading and unloading
areas, inplant transfers and handling, runoff from plant site, and
sludge or hazardous material disposal sites)? What are the common
practices used for these ancillary sources?
RESPONSE
Spill prevention and containment measures may, and often do, differ
depending on the source. For example, in storage areas procedures
emphasize containment by diking. At loading, unloading and other
auxiliary sources, emphasis is greater on collection (as well as
containment) with subsequent disposal or diversion to waste treat-
ment or disposal areas.
An illustration is vinyl acetate, delivered to one of our plants in
railroad cars. The car unloading area has collection trenches
leading to a sump. Small spills collect in the sump. The vinyl
acetate storage tank is within earthen dikes for containing a spill.
Operating procedures require that the dike drain valve be closed
unless rainwater is being drained. Runoff from either facility is
further controlled by other dams within the plant drainage system.
Sometimes only relatively small quantities of a hazardous substance
may be involved in storage and use. Formaldehyde usage in some
plants is small enough so that it can be received in "drum"
quantities. Drums are stored in a "secure" area. The formaldehyde
may either be pumped to the area of use or taken there in the drum
itself where metered quantities are withdrawn. The use area is
designed to contain inadvertent spills or releases until appropriate
disposal can be made.
Where larger quantities of such chemicals as formaldehyde, dimethyl-
amine, and methyl methacrylates are involved, practices for
auxiliary sources may include the following:
a. Prepare written instructions and procedures on how to respond
properly to spills;
b. Equip storage tanks with high level alarms and automatic shut-
offs to prevent overfilling;
c. Check and inspect level gages and shut-off devices on a schedule.
d. For methacrylates, to be more precise, provide emergency shut-
off for all transfer loading and unloading pumps at a main
control station. This control shuts off power to all pumps in
the event of line leaks, ruptures, etc.;
158
-------
e. Avoid unnecessary traffic past unloading and loading locations
through use of barricades during transfer processes;
f. Provide pans beneath pump seals, hose connections, sample ports,
etc., to collect liquids;
g. Direct liquid spills in truck unloading stations by diversion
structures to collection or containment areas;
h. If deemed necessary, use an inflation balloon in conduits to
natural drainage ditch to capture spills;
i. Inspect unloading operations frequently during periods of
unloading if not manned continuously;
j. When routine inspections during operations are reduced, as on
holidays, inspection patrols specifically include plant storage
areas;
k. When possible, tie diversion systems directly into the waste
treatment plant or a wastewater diversion system for gradual
release or treatment;
1. Design training procedures to emphasize prevention and cleanup
of even the very small spills; restrict loading and unloading
operations to trained personnel;
m. Make available equipment (trucks, pumps, etc.) to remove liquid
wastes, spills, etc. from containments, etc. at all times;
n. Keep materials at hand in storage areas for containment (drums)
and cleanup (adsorbents);
o. Only release liquids in diked areas after checkout of liquids
and rainwater for contamination, etc.;
p. Make formal written spill reporting procedures a part of normal
operating practice; emphasize corrective action in reports;
q. Design security measures to restrict access only by authorized
and trained personnel;
r. Keep storage within fenced plant boundaries.
QUESTION 2.
How would you dispose of a hazardous material if contained in a
dike or sump? Would the chemicals be for example: reclaimed,
drained to the process wastewater for treatment, disposal or in
landfill?
159
-------
- 3 -
RESPONSE
Disposal of contained material depends on the quantity and proper-
ties. Contained material is not reclaimed if even minor contami-
nation makes it unsuitable for use. Large quantities and concen-
trated material are often contracted for off-plant disposal or
incinerated on-site, if possible. Smaller quantities of liquids
may be drummed before loading onto trucks for ultimate disposal at
approved liquid disposal sites.
If the plant has a biological treatment facility and the hazardous
material is biodegradable, it would probably be treated there.
Some plants have emergency retention basins to which such materials
are diverted for subsequent treatment. The rate at which the
material can be returned for treatment is governed by the loadings
the treatment plant can handle within NPDES permit limitations.
QUESTION 3.
For liquids, what spill practices are utilized? Are these practices
any different for compounds such as formaldehyde or dimethylamine
versus a corrosive liquid. Is methylmethacrylate or vinyl acetate
treated differently from other liquids? How are the corrosive
liquids contained? Are all liquids normally handled the same
relative to spill prevention and secondary containments?
RESPONSE
Practices for liquid spills vary depending on physical and chemical
properties. For example, amines and formaldehyde spills would be
diluted as necessary to stop air pollution. Acid spills are
neutralized with a base such as caustic soda, soda ash, or lime.
The neutralization may be specific to the spill or be accomplished
in the plant's normal treatment system.
In processing areas, floor drains are often connected to collection
sumps which route chemicals to the waste treatment plant. In the
event of spillage, the material may be hosed with water into floor
drains.
Some plants have a spill control approach based on providing primary
and secondary containment. This means that individual areas or
processes have internal (primary) spill containment in the form of
dikes or curbed areas with sumps. Outside of an area, the overall
site has spill containment facilities (secondary) such as retention
ponds and in-place drainage control dams. Exceptions in primary
retention might be, for example, for highly flammable liquids stored
within a process area, where diversion trenches would move the
liquid into a more remote location for containment.
QUESTION 4.
Along the lines of spill prevention, containment, cleanup and dis-
posal, what practices are utilized for solids (eg, aluminum sulfate,
methyoxychlor)?
160
-------
- 4 -
RESPONSE
If a dry material can be recovered for reuse, such is done. If not,
and depending on the quantity involved, it could be collected for
contract disposal. For highly hazardous solids, dry cleanup rather
than washdown of spills is more desirable.
QUESTION 5.
How is phosgene or other gases handled relative to prevention and
containment of spills?
RESPONSE
The Manufacturing Chemists Association has prepared "Chemical Safety
Data Sheet SD-95" on the handling and use of phosgene, recently
revised in 1978. It contains a considerable amount of information
which should be of use to Hydroscience.
QUESTION 6.
Do you conduct inspection programs for evaluating the condition of
storage tanks? How frequent are these inspections and are they
visual, structural testing or both?
RESPONSE
There is no set practice for inspection of storage tanks. In general,
nonpressurized vessels are visually inspected externally for evidence
of maintenance needs. Frequently operating personnel make daily
observations as a means of inspection for leaks. Training and oper-
ating procedures require immediate reporting and prompt containment
and/or cleanup of leaks or spills. In remote areas, such as tank
farms, field check-sheets include a check for leaks.
Storage tank integrity is checked frequently by various means:
visual checks after cleaning by entering, ultrasonic testing of wall
thickness, x-ray checks of welds, visual evidence of corrosion, dye
checking and hydrostatic tests. Safety and relief valves also may
have testing schedules.
QUESTION 7.
What common practices are used to control hazardous chemicals from
entering the plant runoff?
RESPONSE
Some of these practices have been discussed in response to question 1
Dikes, curbing and diversion to waste treatment facilities are the
principal practices to prevent hazardous materials from entering
plant runoff.
161
-------
- 5 -
In the design of new equipment and installations, spill consider-
ations often affect equipment selection, location, mode of operation,
etc. Emphasis is on prevention, containment, or elimination of
leaks which could eventually enter surface water drains, ditches,
etc.
QUESTION 8.
Can you supply us with any cost information relative to developing
and implementing (eg, by area, by chemical, by plant) a BMP plan at
one of Du Font's plants? Can you provide us with a project timing
schedule to implement a BMP plan?
RESPONSE
Obviously, both the cost and timing for developing and implementing
a BMP plan depend on the facilities involved. One of the problems
in developing the cost for a BMP is that such practices are often
normally required for the safe handling of hazardous materials on
a plant site. Personnel safety, fire protection, assurance of
proper wastewater treatment facility operation, etc., are all'
factors influencing plant operating practices which can also be
considered BMP. Some of these operating practices would undoubtedly
become part of a BMP. But other considerations would also have to
be added.
The size of a manufacturing facility as well as the number of
hazardous substances made or used and the number of ancillary facili-
ties all influence the development and implementation costs.
QUESTION 9.
Could you send us any technical bulletins or other information on
the specific hazardous chemicals presented in Table 2.
RESPONSE
In answer to question 5, we referred to the MCA's Chemical Safety
Data Sheet SD-95 on handling and use of phosgene. The MCA has other
such sheets dealing with some of the specified hazardous chemicals.
These are:
SD-1 Formaldehyde
SD-57 Methylamines
SD-75 Vinyl Acetate
SD-79 Methyl and Ethyl Acrylate
In addition, the following items of Du Pont origin are attached
herewith:
Data Sheet - Aluminum Sulfate
Quick Product Review - Aluminum Sulfate
Material Safety Data Sheet - Aluminum Chloride
162
-------
- 6 -
Data Sheet - Aluminum Chloride
Quick Product Review - Formaldehyde
Formaldehyde Solutions - Properties, Uses, Storage
and Handling
QUESTION 10.
Would you like to be put on our mailing list for a copy of the final
report?
RESPONSE
Yes. Address to: L. L. Falk
Engineering Dept. - L-1339
E. I. du Pont de Nemours & Co.
Wilmington, DE 19898
163
-------
Appendix E
ANALYTICAL MATHEMATICAL SOLUTION
A. BASIC MASS BALANCE DIFFERENTIAL EQUATION:
The basic differential equation describing the movement of a mass dis-
charge of a substance (c) to a water body is given as:
§f c ^-'l - - fj ] + 'if
-------
D = duration of the continuous release
N = number of instantaneous releases into which the continuous
release is divided
ESTIMATE OF LONGITUDINAL DISPERSION
Longitudinal dispersion with attenuates concentrations in natural
streams depends upon such factors as flow, shear velocity, and channel
characteristics. A literature review of recent longitudinal dispersion
coefficient information indicates the relationship155:
has had the greatest degree of success in estimating applicable longi-
dispersion coefficients. In the above formulation,
Q = stream flow
Uj. = shear velocity = JgRs
where g = gravitational acceleration
and s = channel slope
R = hydraulic radius, or mean depth in large, wide rivers
and |3 = dimensionless coefficient
Typical values of (3 range from 0.001 to 0.1. To define a likely value
for p, the relationship
P = 0.18 (
where U = mean velocity has been suggested.
D. TWO AND THREE DIMENSIONAL ANALYTICAL SOLUTIONS
For two and three dimensional cases, Eguation E-l can be integrated to
yield the following relationships:
c(x,y,t) = (M/47ttVE E ) • exp [ - (x - ut)2/4 E t) •
x y x
exp [ - (y - vt)2/4 E t] • exp ( - Kt) (E-4)
c(X,y,z,t) = (M/8ntVE E E rtt) • exp [ - (x - ut)2/4 E t]
x y & 24
• exp [ - (y - vt)2/4 E t) • exp [ - (z - wt)2/4 E t)
y z
• exp ( - Kt)
where M is the total instantaneous mass of material released, c is the
concentration of that material at time t at location x and y in a hori-
zontal reference plane and z in the vertical, and K is the decay rate
associated with the material. Advective transport is described by u,
165
-------
the velocity in the x-direction, v, the velocity in the y-direction and
w, the velocity in the z-direction; dispersive transport is given by E ,
E , and E , the dispersion coefficient in the x, y, and z directions
respectively.
These equations are approximate and are based upon the assumptions of an
instantaneous discharge of soluble material, no physical boundary con-
straints, and constant coefficients of dispersion, net velocity or flow,
and geometry. Solutions are available for the two and three dimensional
case which incorporates the effects of vertical and lateral boundaries,
but are not included here.152
166
-------
GLOSSARY
Advanced BMP: Those best management practices which include BMPs specific to
groups of toxic and hazardous substances, and/or one or more ancillary
sources.
Ancillary source: Those activities which are associated with or ancillary to
the industrial manufacturing or treatment process and may contribute
significant quantities of pollutants to navigable waters. The ancillary
sources as defined in this report are material storage areas; loading
and unloading areas; inplant transfer areas, process areas, and material
handling areas,- plant-site runoff; and sludge and hazardous disposal
areas.
Baseline BMP: Those best management practices generally considered good
practice, low in cost, and applicable to broad categories of industry
and type of substances. Those BMPs that can be used independent of
ancillary source and type of substance.
Best management practice (BMP): The most practical and effective measures,
or combination of measures, which, when applied to an industrial
activity, will prevent or minimize the potential for the release of
toxic or hazardous pollutants in significant amounts to surface waters.
Containment: The physical structures or collection equipment used to confine
a material after it is released from its primary location (or contain-
ment) .
Hazardous substances: Those compounds designated as hazardous by 40 CFR 116
(Reference 20). (See Table 1.1)
Incident: Any spill that reaches the surface waters. (Please see definition
of spill below.)
LC5Q (lethal concentration): The concentration of material which is lethal
to one-half of the test population of aquatic animals upon continuous
exposure for 96 hours or less.
Mitigation: The cleanup or treatment practices or methods used to reduce the
pollutant load associated with a spilled material.
Prevention: Those practices used to provide additional protection beyond the
baseline BMPs for spill prevention and which involve closer control of
plant operations to prevent release of chemicals from their primary con-
tainment.
167
-------
GLOSSARY (continued)
Primary location (containment): The confinement of a material in areas such
as storage, transfer operations, or disposal sites.
Spill: Any release of material from plant site runoff, spillage or leaks,
sludge or water disposal, and drainage from material storage areas.
Toxic substances (priority pollutants): Those 129 compounds designated by the
EPA in accordance with the National Resources Defense Council vs. Train
Consent Decree (Reference 149). (See Table 1.2)
Ultimate disposition: The final handling and removal of a substance from the
site of the release.
168
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-600/9-79-OU5
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
NPDES Best Management Practices Guidance Document
5. REPORT DATE
December 1979
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
J. G. Cleary, 0. D. Ivins, G. J. Kehrberger, C. P.
Ryan, C. W. Stuewe
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Hydroscience, Inc.
90^1 Executive Park Drive
Knoxville, Tenn. 37919
10. PROGRAM ELEMENT NO.
1BB610
11. CONTRACT/GRANT NO.
3-03-2568
12. SPONSORING AGENCY NAME AND ADDRESS
Industrial Environmental Research Lab. - Cinn, OH
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, OH ^5268
13. TYPE OF REPORT AND PERIOD COVERED
Task Final: 1/78 - 10/7Q
14. SPONSORING AGENCY CODE
EPA/600/12
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This document has been developed based on a review of current practices used by
industry to prevent release of toxic and hazardous substances to receiving waters
from non-point sources. Including in the review were published articles and reports,
technical bulletins on specific compounds, and discussions with industry through
telephone contacts, routine questionaires, and site visits. The information availablf
on current BMPs was evaluated and grouped into general categories of baseline and
advanced concepts. BMPs were related to pollutant sources and physical and chemical
properties of the compounds. A classification scheme was developed for the toxicant
hazardous substances, based on important physical and chemical properties revelent
to identification of applicable BMP alternatives. The method of identifying BMPs
based on chemical and source is presented.
This document was developed for EPA to provide guidance to NPDES Permiting
Authorities to evaluate best management practices as required under the 1977 Clean
Water Act to control discharge of toxic and hazardous substances from industrial
plant site run-off, spillage and leaks, sludge and waste disposal, and drainage from
raw materials storage areas to receiving waters.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Pollution Abatement
Wastewater Control
Fugitive Emissions
Ancillary Sources
Pollution Abatement
BMPs Spills
SPCC Clan
68D
18. DISTRIBUTION STATEMENT
Release to Public
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
177
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
169
lUS GOVERNMENT PRINTING OFFICE 1980-657-146/5497
------- |