United States
Environmental Protection
Agency
Office of Enforcement and
Compliance Assurance
EPA315-B-00-001
Summer 2000

A Guide for Ship Scrappers
Tips for  Regulatory Compliance

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   A GUIDE FOR SHIP SCRAPPERS:
TIPS FOR REGULATORY COMPLIANCE

             SUMMER 2000
               Prepared for:

       U.S. Environmental Protection Agency
   Office of Enforcement and Compliance Assurance
       Federal Facilities Enforcement Office
              Ariel Rios Building
         1200 Pennsylvania Avenue, N.W.
            Washington, D.C. 20460

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                                      NOTICE
       This document provides guidance to assist regulated entities to understand their
       obligations under environmental laws; however, for a complete understanding of all
       legal requirements, you must refer to applicable federal and state statutes and
       regulations.  This guide is a compliance assistance tool only, and it neither changes nor
       replaces any applicable legal requirements, nor does it create any rights or benefits for
       anyone. This guide also describes in a summary fashion the roles and activities of
       federal agencies; however, the guidance does not limit their otherwise lawful
       prerogatives, and the agencies may act at variance with it, based on specific
       circumstances. This guidance may be revised without prior notice.  Mention of trade
       names or commercial products in this document, or in associated references, does not
       constitute an endorsement or recommendation for use.
       RECOMMENDATIONS FOR USING THE GUIDE

       We recommend that users organize this guide in 3-ring binders.  Each separate stand-alone
       section can then be removed from the binder, copied, and easily posted or handed out to
       workers undertaking specific ship scrapping operations. Each section can also be used in
       training workers about the best practices for specific ship scrapping operations.  Additionally,
       Appendix C, which is a series of summaries of inspector highlights, can be used to review
       important regulatory requirements for each process. Users may want to laminate copies of the
       summaries for each worker or to post the summaries near the job site as reminders of
       regulations and best practices. It would be helpful to have someone translate the information if
       your workers are more familiar with a language other than English.
                   SURVEY REQUEST  !!!!!!!!!!!!

You are invited to share your opinions and thoughts about this document. Please complete the survey
questionnaire-A Guide for Ship Scrappers Survey.  It is located on the U.S. EPA Web Site at:
http ://www. epa. gov/oeca/fedfac/fflex.html.
A Guide for Ship Scrappers:
Tips for Regulatory Compliance               i                                       Notice

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                                    PREFACE
       This guide is intended to provide site supervisors at ship scrapping facilities with an
       overview of the most pertinent environmental and worker health and safety
       requirements to assist them in ensuring compliance at their facilities.  The guide is
       structured by specific processes (e.g., asbestos removal, metal cutting, fuel and oil
       removal) that occur in ship scrapping operations. Taking a process-specific approach
       allows the guide to be a more manageable and useful reference tool for key ship
       scrapping facility personnel. Ship scrappers can review key environmental, safety, and
       health requirements for each process. References of where to find the requirements in
       the Code of Federal Regulations have been provided throughout the guide, and
       readers are encouraged to review these regulations in detail. Where possible, helpful
       shadow and check boxes have been provided to emphasize guidance or tips.

       This guide was prepared by EPA's Federal Facilities Enforcement Office (FFEO) in the Office
       of Enforcement and Compliance Assurance. Technical research, writing, editing, and  document
       design/layout were provided under EPA Contract No. 68-C7-0011. To obtain additional
       copies of this document, please contact:

       The Federal Facilities Enforcement Office (2261 A)
       U.S. Environmental Protection Agency
       1200 Pennsylvania Ave. NW
       Washington, D.C. 20460
       Telephone: (202) 564-2461
       Fax: (202)  564-0069

       Copies of the document also can be obtained on-line at the FFEO Web site:
       http ://www. epa. gov/oeca/fedfac/fflex.html.
A Guide for Ship Scrappers:
Tips for Regulatory Compliance               ii                                      Preface

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                         ACKNOWLEDGMENTS
      The leadership for the development of this guide came from the U.S. Environmental
      Protection Agency's Federal Facilities Enforcement Office (FFEO) within the Office of
      Enforcement and Compliance Assurance (OECA) and the Manufacturing, Energy and
      Transportation Division (METD) of the Office of Compliance (OC). To assist in the
      development of the guide, EPA formed the Interagency Ship Scrapping Compliance
      Manual/Guide Workgroup.  In addition to EPA personnel, the workgroup included
      representatives from the following agencies:

             •      Occupational Safety and Health Administration (OSHA)
                   United States Coast Guard (USCG)
                   United States Department of the Navy
             •      Defense Logistics Agency (DLA)
             •      Defense Reutilization and Marketing Service (DRMS)
             •      United States Maritime Administration (MARAD)
             •      National Enforcement Investigations Center (NEIC)
             •      National Oceanic and Atmospheric Administration (NOAA).
      Cover Photo:
      Photographed by John T. Ellison, Environmental Investigations Specialist, USEPA
      National Enforcement Investigations Center (now retired).
A Guide for Ship Scrappers:
Tips for Regulatory Compliance              iii                          Acknowledgments

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                         TABLE  OF CONTENTS
1. INTRODUCTION                                                                   l-l
   1.1   The Guide                                                                 1-1
         Whatitis; Whatitdoes	    1-1

2. ASBESTOS REMOVAL AND DISPOSAL                                                2-1
   2.1   Information About Asbestos  	    2-1
         What is asbestos?  	    2-1
         Why has asbestos been so widely used?	    2-2
         Where is  asbestos found on a ship?	    2-2
         What are the four classes of asbestos work?  	    2-3
         How can exposure to asbestos occur?	    2-3
         What are the effects of exposure to asbestos?  	    2-4
   2.2   Who Regulates Asbestos Removal and Disposal?	    2-5
   2.3   Asbestos Removal Practices and Procedures                                  2-5
         2.3.1  Worker Protection Practices	    2-6
               Are exposure assessments and monitoring conducted as required?	    2-6
               Are worker exposure limits met?	    2-6
               Medical surveillance requirements	    2-6
               Are workers and supervisors trained in asbestos removal?	    2-7
               Do workers wear personal protective equipment as required?  	    2-8
               Do workers use hygiene facilities and follow hygiene practices
                      during asbestos removal work?	    2-8
         2.3.2 Asbestos Removal Activities 	    2-8
               Is a supervisor present for all removal activities?	   2-8
               Has a survey of asbestos-containing materials on the ship
                      been conducted?	    2-9
               How can asbestos be identified? 	   2-10
               Has a notification been submitted?	   2-10
               Will RACM be removed before scrapping activities begin?  	   2-11
               Are wet methods being used during RACM removal and disposal?  	   2-12
               To remove units or sections with RACM	   2-13
               Regulated areas must be established and clearly marked	   2-14
               Are other engineering controls and work practices used to control
                      asbestos emissions during removal?	  2-15
   2.4   Disposal Procedures for Asbestos-Containing Waste Material                2-16
         Is the ACWM properly contained? 	   2-16
         Is the ACWM labeled?	   2-17
         Are there visible emissions during disposal activities?   	   2-17
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             TABLE OF CONTENTS  (CONTINUED)
         Is there visible material on the ground that appear to be ACM?	   2-17

         Are waste shipment records included with ACWM shipments?	   2-18
         Is ACWM transported to an appropriate disposal site?  	   2-18
         Is asbestos a hazardous waste? 	   2-19

3.  SAMPLING^ REMOVAL AND DISPOSAL OF POLYCHLOKENATED BIPHENYLS (PCBs)         3-1
   3.1   Information About PCBs                                                  3-1
         What are PCBs?	     3-1
         Why were PCBs widely used?	     3-2
         Where can PCBs be found on a ship?  	     3-2
         How can exposure to PCBs occur?	     3-2
         What are the dangers of exposure to PCBs?  	     3-2
   3.2   Who Regulates PCBs?                                                    3-3
   3.3   Sampling, Removing and Managing PCBs	     3-4
         3.3.1  Worker Protection Practices	     3-4
              How to meet worker protection limits  	     3-4
              Do workers wear personal protective equipment as required? 	     3-4
              Medical surveillance requirements	     3-5
              Are workers trained in PCB removal and disposal?  	     3-5
         3.3.2 Sampling for PCBs on Ships	     3-5
              How is sampling for PCBs conducted? 	     3-6
              Is the "assumption policy" no longer used when determining the PCB concentrations
                     in electrical equipment that is being disposed of?  	     3-7
              Are manifests used when sending samples for PCB analysis? 	     3-7
              Maintaining records of sampling and analysis results	     3-8
         3.3.3  Removal and Storage Requirements	     3-8
              What are PCB-containing materials and wastes called
                     in the PCB regulations?	     3-8
              Are storage-for-disposal requirements for certain PCBs
                     and PCB items met?	     3-9
              Has a TSCA identification number been obtained for storing PCBs?	   3-10
              Establishing a PCB storage-for-disposal facility	   3-11
              Can an existing building or a portion of an existing building be used
                     to properly store PCBs?	   3-11
              Storing PCBs temporarily prior to disposal 	   3-12
              Marking PCB items and PCB storage areas	   3-13
              Are inspections of PCB storage areas conducted?	   3-14
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              TABLE  OF CONTENTS (CONTINUED)
               Are appropriate PCB storage containers used for storage and shipment?  ...   3-14
               Maintaining appropriate PCB storage practices and records	   3-14
               PCBs stored onsite must be disposed of within one year 	   3-15

               How are PCB liquids, items,  and wastes disposed of? 	   3-15
               When disposing of electrical cables, are PCB materials
                     in the cables separated from non-PCB materials?	   3-16
   3.4   PCB Spill Reporting Requirements	   3-16
         Are PCB spills reported?	   3-16

4. BILGE AND BALLAST WATER REMOVAL                                              4-1
   4.1   Information About Bilge and Ballast Water	     4-1
         What is bilge water and where is it found on a ship?	     4-1
         What is ballast water and where is it found on a ship?	     4-1
         What are the potential impacts of bilge and ballast water discharges?  	     4-2
   4.2   Who Regulates Bilge and Ballast Water Removal?                            4-3
   4.3   Removing Bilge and Ballast Water   	     4-5
         4.3.1  Removal Activities	     4-5
               Has the bilge and ballast water been tested?	     4-5
               Is transfer operations equipment inspected prior to removal activities?  	     4-6
               Are booms immediately available to contain accidental discharges?	     4-6
         4.3.2 Cleaning Tanks/Compartments Onboard	     4-6
               Are spaces cleaned after removal of bilge and ballast water?  	     4-6
               Are confined or enclosed spaces determined to be safe for entry?  	     4-7
               Are workers entering confined or enclosed spaces appropriately trained? ...     4-8
   4.4   Discharging Bilge and Ballast Water	     4-8
         4.4.1 Direct Discharges  	     4-8
               Is wastewater discharged directly to waters of the United States?	     4-8
               Does your facility have an NPDES permit?  	     4-9
               Complying with the effluent limits specified in the NPDES permit	     4-9
               Is wastewater monitoring conducted in accordance with
                     the NPDES permit?  	   4-10
               Are all monitoring records maintained as required by the
                     NPDES permit? 	   4-10
               Are additional NPDES reporting requirements met?	   4-11
         4.4.2 Indirect Discharges 	   4-11
               Is wastewater discharged to a POTW?	   4-11
               Are the general pretreatment  standards for wastewater discharges met? ....   4-12
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              TABLE OF  CONTENTS (CONTINUED)
               Does the facility have a pretreatment permit from the POTW
                      for its wastewater discharges?	   4-13
               Are local POTW limits for wastewater discharges met?	   4-14
               Are monitoring and recordkeeping requirements met for
                      indirect wastewater discharges?	   4-14

               Meeting reporting requirements for indirect wastewater discharges	   4-15
               Does your facility pay a surcharge for discharges to the POTW?  	   4-16
   4.5   Wastewater Treatment and Waste Management	   4-16
         4.5.1  Treating Wastewater	   4-16
               Is an oil-water separator system used for wastewater treatment?  	   4-16
               Is evaporation used for treatment?	   4-17
         4.5.2  Storing Wastes in Tanks	   4-17
               Has the state UST program office been notified of any USTs on site?	   4-18
               Is leak detection conducted for tanks and piping?	   4-19
               Do USTs meet requirements for spill, overfill, and corrosion protection? ....   4-19
               Are ASTs inspected on a periodic basis to verify tank integrity?	   4-19
               Using secondary containment to prevent oil discharges	   4-20
         4.5.3  Managing Oil/Oily Wastes as Used Oil 	   4-20
               Preventing the mixing of used oil with hazardous waste	   4-22
               Are containers/tanks leak free and labeled "used oil"? 	   4-23
               Are used oil and fuel recycled or sent to a reclaimer?	   4-23
         4.5.4  Managing Oil/Oily Wastes as Hazardous Waste	   4-24
               Are oil/oily wastes hazardous?	   4-24
               If your facility generates hazardous waste, what is your
                      generator category?	   4-25
               If your facility is a CESQG, does it meet all applicable requirements?	   4-27
               If your facility is an SQG or LQG, does it meet all
                      applicable requirements?	   4-28
   4.6   Oil Spill Prevention, Response, and Recovery                               4-31
         4.6.1  Spill Prevention Planning	   4-32
               Does your facility have an SPCC plan? 	   4-32
               Does the SPCC plan include all the required information?	   4-32
         4.6.2  Spill Response Planning	   4-33
               Does your facility have a facility response plan (FRP)?	   4-35
               Was an existing response plan used or modified?	   4-36
               Was the FRP prepared and submitted by the deadline?  	   4-36
               Is the FRP maintained and updated? 	   4-37
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              TABLE OF CONTENTS (CONTINUED)
               Are appropriate FRP records maintained?	   4-38
               Are training and response drill requirements met?	   4-38
         4.6.3 Spill Notification and Recovery	   4-38
               Are oil spills reported as required?	   4-39
               Is all required information provided to the National Response Center?  	   4-40
               Is the facility prepared for an effective response to an oil spill?  	   4-40
               What oil recovery methods are used at the facility?	   4-42

5. OIL AND FUEL REMOVAL                                                           5-1
   5.1   Information About Oil and Fuel	    5-1
         What are oil and fuel?  	    5-1
         Where are oils and fuels found on a ship?	    5-2
         The potential dangers to workers during oil and fuel removal activities	    5-2
         What are the environmental impacts of oil spills?	    5-3
   5.2   Who Regulates Oil and Fuel Removal?                                       5-4
   5.3   Oil and Fuel Removal and Storage  	    5-4
         5.3.1 Removing Oil andFuel  	    5-4
               Have the locations and quantities of oil and fuel to be removed
                      from the ship been identified?	    5-5
               Has U.S. Coast Guard approval for removal activities been obtained?  	    5-5
               Are oils and fuels removed from the ship as thoroughly as practicable?	    5-5
               Is transfer operations equipment inspected prior to removal activities?  	    5-5
               Are booms immediately available to contain accidental discharges?	    5-5
         5.3.2 Cleaning Oil and Fuel Tanks/Compartments on Ships and Shore-Based
                      Storage Facilities	    5-6
               Are spaces cleaned after removal of oil and fuel?	    5-6
               How are confined or enclosed spaces determined to be safe for entry?	    5-7
               Are workers entering confined or enclosed spaces appropriately trained? ...    5-7
         5.3.3 Storing Wastes in Tanks	    5-8
               Has the state UST program office been notified of any USTs on site?	   5-9
               Is leak detection conducted for tanks and piping?	   5-9
               Do USTs meet requirements for spill, overfill, and corrosion protection? ....   5-10
               Are ASTs inspected on  a periodic basis to verify tank integrity?	   5-10
               Is secondary containment used to prevent oil discharges?	   5-11
         5.3.5 Managing Oil/Oily Wastes as Used Oil  	   5-11
               Is the mixing of used oil with hazardous waste prevented?  	   5-13
               Are all containers/tanks leak free and labeled "used oil"?  	   5-13
               Are used oil and fuel recycled or sent to a reclaimer?	   5-14
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            TABLE OF CONTENTS (CONTINUED)
        5.3.6 Managing Oil/Oily Wastes as Hazardous Waste	   5-15
             Are oil/oily wastes hazardous?	   5-15
             If your facility generates hazardous waste, what is your
                   generator category?	   5-16
             If your facility is a CESQG, does it meet all applicable requirements?	   5-18
             If your facility is an SQG or LQG, does it meet all applicable
                   requirements?	   5-19
   5.4   Oil Spill Prevention, Response, and Recovery	   5-22
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              TABLE OF CONTENTS (CONTINUED)
         5.4.1  Spill Prevention Planning	   5-22
               Does your facility have an SPCC plan? 	   5-22
               Does the SPCC plan include all the required information?	   5-23
         5.4.2  Spill Response Planning	   5-23
               Does your facility have a facility response plan (FRP)?	   5-25
               Was an existing response plan used or modified?	   5-26
               Was the FRP prepared and submitted by the deadline?  	   5-27
               Has the FRP been maintained and updated?  	   5-27
               Are appropriate FRP records maintained?	   5-28
               Are training and response drill requirements met?	   5-28
         5.4.3  Spill Notification and Recovery	   5-29
               Are oil spills reported as required?	   5-29
               Is all required information provided to the National Response Center?  	   5-30
               Is the facility prepared for an effective response to an oil spill?  	   5-30
               What oil recovery methods are used at the facility?	   5-32

6. PAINT REMOVAL AND DISPOSAL                                                    6-1
   6.1   Information About Paints and Paint Removal	    6-1
         What types of paints and coatings are found on ships? 	    6-1
         Methods used to remove paints and coatings 	    6-1
         The human health and environmental impacts associated
               with removing paints and coatings  	    6-2
   6.2   Who Regulates Paint Removal and Disposal Activities?	    6-2
   6.3   Paint Removal Activities 	    6-3
         Worker exposure limits	    6-3
         Have paints and coatings been tested to determine  if they are flammable?  	    6-3
         Highly flammable paints  and coatings must be removed prior to metal cutting	    6-4
         Have paints and coatings been tested to determine if they are toxic? 	    6-4
         Removing toxic paints and coatings in enclosed spaces	    6-4
         Measures used to protect worker health during paint removal activities	    6-4
         Air permit requirements	    6-6
   6.4   Managing and Disposing of Paint Removal Wastes 	    6-7
         Does your facility have a storm water permit?	    6-7
         Measures or controls used to prevent or minimize  storm water pollution	    6-8
         Are paint removal wastes hazardous?	    6-8
         If your facility generates  hazardous waste, what is  your generator category?  	   6-10
         If your facility is a CESQG, does it meet all applicable requirements?  	   6-11
         If your facility is an SQG or LQG, does it meet all applicable requirements?  	   6-13
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              TABLE OF CONTENTS  (CONTINUED)
7. METAL CUTTING AND METAL DISPOSAL                                           7-1
   7.1   Information About Metal Cutting and Metal Disposal                         7-1
         What is metal cutting?  	    7-1
         How are metals cut? 	    7-1
         What kinds of metal scrap are generated?  	    7-2
         Potential environmental impacts from metal cutting 	    7-3
         Worker health and safety concerns during metal cutting	    7-3
   7.2   Who Regulates Metal Cutting and Metal Disposal Activities?                 7-4
   7.3   Metal Cutting Practices and Procedures                                     7-5
         7.3.1  Testing Required Prior to Hot Work	    7-5
               Prior to any cutting activities, have preservative coatings on surfaces
                     been tested and removed if required?	    7-5
               Have work areas been tested and certified as "Safe for Hot Work"?  	    7-5
         7.3.2  Performing Metal Cutting	    7-7
               Do workers wear appropriate personal protective equipment
                     when metal cutting?	    7-7
               Equipment requirements when conducting gas or arc cutting	    7-7
               Air permit requirements	    7-8
               Is mechanical ventilation provided when metal cutting?	    7-8
               Is the proper mechanical  ventilation or respiratory protection used
                     when cutting certain metals?	    7-9
               Are hollow metal containers and structures cleaned, vented, or tested
                     before cutting?  	   7-10
               Fire prevention requirements	   7-10
         7.3.3  Managing Scrap Metal 	   7-11
               Is all scrap metal recycled?  	   7-11
               Is recyclable metal recovered using shredders and separators?	   7-11
               Is cable burning for copper recovery prohibited?	   7-12
               Is wastewater from metal cutting operations managed with bilge water? ....   7-12
               Does your facility have a storm water permit?  	   7-12
               Measures or controls used to prevent or minimize storm water pollution ....   7-13

8. REMOVAL AND DISPOSAL OF MISCELLANEOUS SHIP MACHINERY                      8-1
   8.1   Information About Miscellaneous Ship Machinery 	    8-1
         What is miscellaneous ship machinery and where is it found on a ship?  	    8-1
         When are components removed during scrapping?	    8-2
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             TABLE OF CONTENTS (CONTINUED)
         What are potential worker health and safety and environmental impacts from ship machinery
               removal and disposal?	    8-2
   8.2   Who Regulates the Removal and Disposal of Miscellaneous Ship Machinery?  8-2

   8.3   Ship Machinery Removal and Disposal Activities	   8-3
         Are worker health and safety requirements met?	    8-3
         Are asbestos requirements met during ship machinery removal?  	    8-3
         Are PCB requirements met during ship machinery removal? 	    8-3
         Are oils/fuels removed from ship machinery components handled as required?	    8-4
         Are paint removal and metal cutting requirements met during
               ship machinery removal? 	    8-4
         Is machinery recycled or sold for reuse?	    8-4
         Is recyclable metal recovered using shredder and separators?	   8-4
         Is cable burning for copper recovery prohibited?  	   8-5
         Does your facility have a storm water permit?	   8-5
         Measures or controls used to prevent or minimize storm water pollution	   8-5

9. RESOURCES  	   9-1
   9.1   Contact Information	   9-1
         9.1.1  EPA Headquarters and EPA Regional Offices	   9-1
         9.1.2  OSHA Headquarters and OSHA Regional Offices  	   9-2
         9.1.3  State  and Local Contacts  	   9-4
   9.2   Hotlines	   9-5
   9.3   Additional Contacts and  Resources	   9-6
         General Tools for Ship Scrapping Activities	   9-6
         Asbestos Removal and Disposal  	   9-7
         Sampling, Removal and Disposal of PCBs	   9-10
         Bilge and Ballast Water Removal	   9-11
         Oil and Fuel Removal 	  9-14
         Paint Removal and Disposal	   9-17
         Metal Cutting and Metal Disposal  	   9-17
         Removal and Disposal of Miscellaneous Ship Machinery 	   9-17
   9.4   Publications and Internet Sites  	   9-17
         General	   9-17
         Asbestos Removal and Disposal  	   9-18
         Sampling, Removal and Disposal of PCBs	   9-19
         Bilge and Ballast Water Removal	   9-20
         Fuel and Oil Removal 	  9-21
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            TABLE OF CONTENTS (CONTINUED)
        Paint Removal and Disposal	   9-22
        Metal Cutting and Metal Disposal  	   9-23
        Removal and Disposal of Miscellaneous Ship Machinery 	   9-23
APPENDIX A - WHY THIS GUIDE WAS DEVELOPED


   A.I  Overview of Ship Scrapping	   A-2
             The Ship Scrapping Industry	   A-2
             The Process of Ship Scrapping	   A-3

   A.2  The United States Ship Scrapping Program 	   A-5

   A.3  Regulating the Ship Scrapping Industry                                 A-9
             Identifying Compliance Issues for the Ship Scrapping Industry	   A-9
             Regulating Agencies  	   A-ll

APPENDIX B - List of Acronyms                                                B-l

APPENDIX C - Inspector Highlights                                    Not labeled
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                             1.  INTRODUCTION
                      What is ship scrapping? According to OSHA, ship
                      dismantling or breaking is "any breaking of a
                      vessel's structure for the purpose of scrapping the
                      vessel, including the removal of gear, equipment, or
                      any component of a vessel" (29 CFR 1915.4).
1.1.  THE GUIDE

lAlhat It Is; What It Does

   This guide is intended to provide the site supervisor of a ship scrapping facility with a good
   understanding of the most pertinent federal environmental and worker safety and health
   requirements affecting ship scrapping/ship breaking operations. (Specific state requirements are
   not included.) The document provides guidance with reference to specific regulations, tips in
   shadow boxes  •  , and regulatory inspector highlights denoted by check boxes  &T
   Organization of the Guide

   This guide is organized into 9 sections and 3 appendices. The document begins with a brief
   introduction and is then followed by a series of sections, each presenting key environmental and
   worker safety and health requirements for a major ship scrapping process. Each section was
   designed and developed to be used as independent guidance. These sections are as follows:

       •   Section 2. Asbestos Removal and Disposal
       •   Section 3. Sampling, Removal and Disposal of Poly chlorinated Bipheny Is
       •   Section 4. Bilge and Ballast Water Removal
       •   Section 5. Oil and Fuel Removal and Disposal
       •   Section 6. Paint Removal and Disposal
       •   Section 7. Metal Cutting and Metal Recycling
       •   Section 8. Removal and Disposal of Miscellaneous Ship Machinery

       Section 9. Resources identifies sources, such as general and process-specific contacts,
       hotlines, publications, and Internet sites, where additional information and/or assistance can be
       obtained on environmental and worker safety and health requirements.
A Guide for Ship Scrappers:
Tips for Regulatory Compliance
1-1
Introduction

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       Appendix A provides the user with an overview of the ship scrapping industry, the ship
       scrapping process, and the United States government ship scrapping program. It also includes
       a short summary of how the industry is regulated.

       Additional ship scrapping processes may be developed and added to the guide in the future.
       These processes might include:

       •  Removal and Disposal of Portable, Unfired Pressure  Vessels, Drums, and Containers
       •  Removal and Disposal ofNon-PCB Electrical Machinery
       •  Removal and Disposal of Batteries
       •  Removal and Disposal of Other Hazardous Materials

       Appendix B provides a list of acronyms.

       Appendix C contains summaries of Inspector Highlights noted in check boxes throughout
       sections of this guide.
       Using a Process-Based Approach

       Although most of the ship scrapping processes occur simultaneously during ship scrapping, it is
       useful to look at the requirements on a process-by-process basis. The idea is that you, as a site
       supervisor (or other key person at your ship scrapping facility), can examine any part of your
       facility, identify what process or processes are taking place, and quickly reference this guide for
       information on key environmental requirements, worker safety and health requirements, and
       management tips.

       Focus on Federal Requirements
       This guide presents overviews of majorfederal
       requirements only, and you are encouraged to
       review these requirements in detail by reading
       the relevant portions of the Code of Federal
       Regulations (CFR), which are cited throughout
       the guide. You should also be aware of all
       applicable state and local regulations (see box).
       If you have additional questions or need more
       information about a particular requirement, call
       the contacts or access the sources of information identified in Section 9. Resources.
         State/Local Requirements: The
         regulations discussed in this guide are
         federal EPA and OSHA requirements.
         Your state may have its own, stricter
         requirements. Be sure you know your
         state and/or local government
         environmental and worker safety and
         health requirements.
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       Remember: This guide is not the final word on compliance responsibilities for your
       ship scrapping operation.
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           2.  ASBESTOS REMOVAL AND  DISPOSAL

       During ship scrapping activities, the removal and disposal of asbestos is a primary
       environmental concern, as well as a health and safety concern for your workers. The following
       sections present background information on asbestos, discuss the effects of asbestos exposure,
       and describe some of the regulatory requirements with which your facility must comply.

2.1   INFORMATION ABOUT ASBESTOS
w
  This section provides background information on asbestos, including what it is, where it can be
  found on ships, how exposure can occur, and the dangers of exposure.

hat is asbestos?

  "Asbestos" refers to a group of minerals that occur naturally as masses of long silky fibers.
  There are three main types of asbestos fibers:

         Chrysotile fibers (white asbestos) are fine, silky flexible white fibers. They are pliable
         and cylindrical, and arranged in bundles. This was the most commonly used asbestos in
         the United States.

         Amosite fibers (brown asbestos) are straight, brittle fibers that are light grey to pale
         brown. This was the most commonly used asbestos in thermal system insulation.

         Crocidolite fibers (blue asbestos) are  straight blue fibers that are like tiny needles.

  There are three other types of asbestos fibers: anthopylite, tremolite, and actinolite.     Unlike
                                                                          most
                                                                          mineral
                                                                          s,
                                                                          which
                                                                          turn
                                                                          into
                                                                          dust
                                                                          particle
                                                                          s when
                                                                          crushed
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                                                                                   asbesto
                                                                                   s
                                                                                   breaks
                                                                                   up into
                                                                                   fine
                                                                                   fibers
                                                                                   that are
                                                                                   too
                                                                                   small to
                                                                                   be seen
                                                                                   by the
                                                                                   human
                                                                                   eye.

       Individual asbestos fibers are often mixed with a material that binds them together, forming what
       is commonly called asbestos-containing material (ACM).  There are two kinds of ACM: friable
       and non-friable.

       •      Friable ACM is any material containing more than 1% asbestos that, when dry, may
              be crumbled, pulverized, or reduced to powder by hand pressure.

              Non-friable ACM is any material containing more than 1% asbestos that, when dry,
              cannot be crumbled, pulverized, or reduced to powder by hand pressure.  Non-friable
              ACM is divided into two categories.

              S      Category I non-friable ACM includes asbestos-containing resilient floor
                     coverings, packings, and gaskets.

              S      Category II non-friable ACM includes all other non-friable ACM that is not
                     included in Category I.
               What is presumed asbestos containing material (PACM)? Thermal system
               insulation and surfacing material found in buildings, vessels, and vessel sections
               constructed no later than 1980 may be considered PACM.
lAlhy has asbestos been so widely used?
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       Asbestos was widely used in construction and industry due to its unique properties, and
       because there were few other available substances that combined the same qualities. Asbestos
       is resistant to abrasion and corrosion, inert to acid and alkaline solutions, and stable at high
       temperatures. It is strong yet flexible, non-combustible, conducts electricity poorly, and is an
       effective thermal insulator.

1AI here is asbestos found on a ship?

       Asbestos is found on ships in many types of materials, including, but not limited to:

       •   Bulkhead and pipe thermal insulation    •   Molded plastic products (e.g., switch
       •   Bulkhead fire shields/fireproofing           handles, clutch facings)
       •   Uptake space insulation                •   Sealing putty
       •   Exhaust duct insulation                 •   Packing in shafts and valves
       •   Electrical cable materials               •   Packing in electrical bulkhead penetrations
       •   Brake linings                          •   Asbestos arc chutes in circuit breakers
       •   Floor tiles and deck underlay           •   Pipe hanger inserts
       •   Steam, water, and vent flange gaskets   •   Weld shop protectors and burn covers,
       •   Adhesives and adhesive-like glues         blankets, and any fire fighting clothing or
           (e.g., mastics) and fillers                   equipment
           Sound damping                       •   Any other type of thermal insulating
                                                   material

       Caution!! ACM may be found underneath materials that do not contain asbestos.
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                                     Status of the Asbestos Ban

         There is a rather common misunderstanding about the status of the EPA 1989 ban on
         asbestos-containing products or uses.  Two years after EPA's ban, the U.S. Fifth Circuit
         Court of Appeals vacated much of EPA's rule in 1991 leaving only six asbestos-containing
         product categories (including corrugated paper, rollboard, commercial paper, specialty paper,
         flooring felt, and new uses of asbestos) still subject to the asbestos ban, In addition, several
         uses of ACM products remained banned, including the sprayed-on application of ACM (>1%
         asbestos) and the installation of certain types of asbestos-containing insulation. Besides
         the products and uses  listed above, EPA has no existing bans on other asbestos
         containing products or uses EPA does not track the manufacture, processing or
         distribution in commerce of asbestos-containing products. For further information, contact
         the TSCA Assistance Information Service at 202-554-1404, call your EPA Regional Asbestos
         Coordinator (see Section 9. Resources), or access http://www.epa.gov/asbestos and go to
         the "Helpful Information" button.
W
hat are the four classes of asbestos work?

   The Occupational Safety and Health Administration (OSHA) standard for asbestos specifies
   four classes of asbestos activities [29 CFR 1915.1001(b)].  These are:

   •       "Class F asbestos work means activities involving the removal of thermal system
          insulation (TSI) and sprayed-on or troweled-on or otherwise applied surfacing ACM
          or PACM.

   •       "Class D" asbestos work means activities involving the removal of ACM which is
          neither TSI or surfacing ACM.  This includes, but is not limited to, the removal of
          asbestos-containing wallboard, floor tile, and construction mastics.

          "Class UF' asbestos work means repair and maintenance operations where ACM
          (including TSI and surfacing ACM and PACM) is likely to be disturbed.

   •       "Class IV" asbestos work means maintenance and custodial activities during which
          employees contact, but so as not disturb ACM or PACM, and activities to clean up
          dust, waste, and debris resulting from Class I, n,  and in activities.
LJow can exposure to asbestos occur?
       As a site supervisor, you should be aware that you and your workers can be exposed to
       asbestos in several ways.  When ACM is deteriorated, crushed, or otherwise disturbed,
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       asbestos fibers break up into very fine fibers and are released to the environment by either
       dispersing in the air, floating on water or accumulating on the ground. Exposure to asbestos
       can occur by:

               Occupational exposure: Workers may be exposed to asbestos if working at facilities,
               including ships, which contain asbestos.  Because asbestos fibers are small and light,
               they can be suspended in the air for long periods and possibly inhaled by those working
               in these areas. Airborne asbestos fibers are small, odorless, and tasteless.  They range
               in size from 0.1 to 10 microns in length (a human hair is about 50 microns in diameter).
               The amount of asbestos a worker is exposed to will vary according to: (1) the
               concentration of fibers in the air; (2) duration of exposure; (3) the worker's breathing
               rate (workers doing manual labor breath faster); (4) weather conditions; and (5) the
               protective devices the worker wears. It is estimated that between 1940 and 1980, 27
               million Americans had significant occupational exposure to asbestos. People may also
               ingest asbestos if they eat in areas where there are asbestos fibers in the air.

               During ship scrapping, the most significant asbestos concerns for workers  arise when
               removing asbestos-bearing thermal insulation; handling of circuit breakers, cable, cable
               penetrations; and removing floor tiles (from asbestos in the mastic and in the tile).
               Additional concerns can arise from handling and removing gaskets with piping and
               electrical systems, as well as molded plastic parts.

       •       Paraoccupational exposure: Workers' families may inhale asbestos fibers released
               by their clothes that have been in contact with ACM.

               Neighborhood exposure:  People who live or work near asbestos- related operations
               may inhale asbestos fibers that have been released into the air by these operations.

lAlhat are the effects of exposure to asbestos?

       While scientists have not been able to determine a
                                                         Preventing exposure. Using controls
                                                         to prevent asbestos exposure is vital to
                                                         protecting the health of workers.
"safe" or threshold level for exposure to airborne
asbestos, EPA, OSHA, and the National Institute
for Occupational Safety and Health (NIOSH)
believe there is no known safe level of asbestos
exposure.

In short, some people exposed to asbestos develop asbestos-related health problems; some do
not.  Some known diseases caused from asbestos exposure include:  (1) asbestosis (scarring of
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       the lungs resulting in loss of lung function that often progresses to disability and to death), and
       (2) cancer, such as mesothelioma (cancer affecting the membranes lining the lungs and
       abdomen), lung cancer, or cancers of the esophagus, stomach, colon, and rectum.

       If inhaled, asbestos fibers can easily penetrate body tissues, and may be deposited and retained
       in the airways and lung tissue.  Because asbestos fibers remain in the body, each exposure
       increases the likelihood of developing an asbestos-related disease. Asbestos-related diseases
       may not appear until years after exposure.  Ingesting asbestos may be harmful, but the
       consequences of this type of exposure have not been clearly documented. Note: The risks of
       asbestos exposure are multiplied 10-fold or more if a worker smokes.

2.2   WHO REGULATES ASBESTOS REMOVAL AND DISPOSAL?

       Asbestos regulations are important to the ship scrapping industry because many ships being
       scrapped contain significant amounts of ACM. During ship scrapping activities, ACM must be
       properly removed and disposed of. Therefore, being aware of and complying with all
       applicable regulations for asbestos removal and disposal is important for your ship scrapping
       operation.  The process of removing and disposing of ACM is subject to various federal, state,
       and local environmental and safety and health requirements.

       •       EPA. EPA is responsible for developing and enforcing regulations necessary to protect
              human health and the environment. Asbestos is regulated by EPA under two laws: (1)
              the Clean Air Act (CAA), under the Asbestos National Emissions Standards for
              Hazardous Air Pollutants (NESHAP), and (2) the Toxic Substances Control Act
              (TSCA). Some of the requirements for asbestos removal and disposal under these
              laws include inspections; notifications; supervisor training; and the proper removal,
              transport and disposal  of asbestos.

              Specifically, the Asbestos NESHAP [40 CFR 61  Subpart M] is intended to minimize
              the release of asbestos fibers during demolition and renovation activities (including ship
              scrapping) through work practices. EPA has delegated authority to inspect and enforce
              the asbestos NESHAP regulations to most states.  Where the program has been
              delegated, the state agency may have requirements that are more stringent than the
              federal requirements. The  asbestos NESHAP requirements will be discussed in more
              detail in the following sections.

       •       OSHA.  OSHA is responsible for the health and safety of workers who may be
              exposed to asbestos in the work place. OSHA regulations covering asbestos exposure
              set a maximum  exposure limit and include provisions for engineering controls and
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              respirators, protective clothing, exposure monitoring, hygiene facilities and practices,
              warning signs, labeling, recordkeeping, and medical exams (29 CFR 1915.1001).
              Some of these requirements are discussed in more detail below.

2.3   ASBESTOS REMOVAL PRACTICES AND PROCEDURES

       As mentioned above, as the site supervisor, you should be familiar with EPA and OSHA
       regulations designed to minimize exposure to and release of asbestos. Some of these
       requirements are discussed below.
2.3.1  Worker Protection Practices

A re exposure assessments and monitoring conducted as required?
                                                      Tip: In addition to OSHA regulations,
                                                      air surveillance requirements for
                                                      sampling asbestos are often regulated
                                                      by state regulatory agencies.
      Your facility is required to perform air surveillance
      activities in work areas where asbestos is being
      removed, including meeting the general monitoring
      criteria, conducting initial exposure assessments,
      and performing daily and periodic monitoring.  The
      facility must inform workers of the monitoring
      results that represent each worker's asbestos exposure, and allow workers an opportunity to
      observe any monitoring of worker exposure to asbestos [29 CFR 1915.1001(f)].

      In addition, the facility must keep an accurate record of all measurements taken to monitor
      worker exposure to asbestos [29 CFR 1915.1001(n)(2)].

A re worker exposure limits met?

      Your facility must ensure that workers are not exposed to airborne asbestos concentrations in
      excess of either of the following limits, collectively referred to as permissible exposure limits
      (PELs):

             0.1 fiber per cubic centimeter (f/cc) of air averaged over an eight-hour work shift.  This
             PEL is called the time-weighted average (TWA) limit [29 CFR 1915.1001(c)(l)].

      •      1.0 f/cc of air averaged over a sampling period of 30 minutes. This PEL is called the
             excursion limit [29 CFR 1915.1001(c)(2)].
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lUIedical surveillance requirements
       Your facility is required to conduct medical surveillance for all workers who, for a combined
       total of 30 or more days per year, are performing asbestos removal work or are exposed at or
       above the permissible exposure limit. This includes medical examination and consultation prior
       to beginning work, at least annually, and upon termination of employment [29 CFR
       1915.1001(m)].

       The facility must establish and maintain an accurate record for each worker subject to medical
       surveillance.  These records must be maintained for the duration of the worker's employment,
       plus an additional 30 years [29 CFR 1915.1001(n)(3)].
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A re workers and supervisors trained  in asbestos removal?

       Worker training. Your facility must provide, at no cost, a
       training program for employees likely to be exposed to
       asbestos removal work during ship scrapping [29 CFR
       1915.1001 (k)(9)].  Training must be provided prior to or at
       the time of beginning work and at least once a year
       afterwards, and it must be conducted in a manner which the
       worker is able to understand.
Tip: Some facilities may
need to hire contractors for
training employees who
speak English as a second
language and may not be
fluent in English.
       For asbestos removal operations that require the use of critical barriers and/or negative
       pressure enclosures, the facility must provide training to workers that is equivalent in curriculum,
       training method, and length to the EPA Model Accreditation Plan asbestos abatement workers
       training found in 40 CFR 763, Subpart E, Appendix C.

                       An inspector may check to see that workers at your facility
                       received training  in a language that they understand.

       Supervisor training.  Your facility must have a supervisor on site overseeing all work in which
       regulated asbestos-containing material (RACM) is stripped, removed or otherwise handled.
       This is a requirement under the asbestos NESHAP regulations [40 CFR 61.145(c)(8)], as well
       as the OSHA shipyard industry standards [29 CFR 1915.1001(o)].

       According to the asbestos NESFLAP requirements, the supervisor must be trained in the
       provisions of the regulation and the means of complying with them. Training must include, at a
       minimum: applicability of regulations; notification requirements; material identification
       procedures; emission control procedures for removals; waste disposal practices; reporting and
       recordkeeping; and asbestos hazards and worker protection.

       Evidence of training must be posted and made available for inspection at the ship scrapping site
       [40 CFR 61.145(c)(8)]. Refresher training in the asbestos NESFLAP requirements is required
       for supervisors every 2 years.

       Training records. Your facility must maintain records for each worker and supervisor and
       document their completed training. These records must be maintained for one year past the last
       day of employment [29 CFR 1915.1001(n)(4)].

                       An inspector may check the training records for the workers and
                       supervisors listed on the daily work logs.
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Qo workers wear personal protective equipment as required?

       Your facility is required to ensure workers involved in asbestos removal and disposal are using
       approved respirators [29 CFR 1915.1001(h)].  Respirators appropriate for the work being
       conducted must be provided free of charge by the facility.

       In addition, your facility is required to provide and ensure the use of protective clothing, such as
       coveralls or similar full-body clothing, head coverings, gloves, and foot covering, during
       asbestos removal work.  In addition, wherever the possibility of eye irritation exists, face
       shields, vented goggles, or other appropriate protective equipment must be provided and worn
       [29 CFR 1915.1001(1)].

r\o workers use hygiene facilities and follow hygiene practices during
   asbestos removal work?

       Your facility must provide hygiene facilities for use by workers [29 CFR 1915.1001(j)].  These
       include:

       •       Decontamination areas and procedures: A decontamination area must be provided
              that is adjacent and connected to the regulated area for the decontamination of asbestos
              workers.  The decontamination area includes, in series, an equipment room, shower
              area, and clean room. Workers must enter and exit the regulated area through the
              decontamination area while following specific procedures.

       •       Lunch areas: The facility must provide lunch areas in which the airborne
              concentrations of asbestos are below the permissible exposure limits.

                      An inspector may check  the shower drains from the worker
                      showers to make sure they have filters.  Filters help remove lead
                      and asbestos from  the wastewater.

2.3.2. Asbestos Removal Activities

Is a supervisor present for all removal activities?

       During all work in which RACM is stripped, removed or otherwise handled, a supervisor must
       be  on site overseeing these activities. This is a requirement under the asbestos NESHAP
       regulations [40 CFR 61.145(c)(8)], as well as the OSHA shipyard industry standards [29 CFR
       1915.1001(o)].
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       As described in the OSHA shipyard industry regulation [29 CFR 1915.1001(o)], the
       supervisor (also commonly called the qualified person) must perform or supervise specific
       activities during asbestos removal work:

              Set up the regulated area, enclosure, or other containment; and ensure the integrity of
              the enclosure or containment.

       •      Set up procedures to control entry to and exit from the area and/or enclosure.

              Supervise all worker exposure monitoring and ensure that it is conducted appropriately.
       •      Ensure that employees working within the enclosure and/or using glove bags wear
              appropriate respirators and protective clothing.

       •      Ensure, through on site supervision, that workers set up, use, and remove engineering
              controls; use work practices; and use personal protective equipment.

       •      Verify that workers use the hygiene facilities and observe the decontamination
              procedures.

              Ensure through on site inspection that engineering controls are functioning properly and
              employees are using proper work practices.

              Ensure that notification requirements are met.

LJas a survey of asbestos-containing materials on the ship been conducted?

       A survey is basically a thorough inspection of the ship for the presence of asbestos, including
       friable ACM and Category I and Category H nonfriable ACM. [40 CFR 61.145(a)].  By
       conducting a survey of the ship for the presence of asbestos, your facility will determine
       whether it must meet the EPA asbestos NESHAP requirements 40 CFR 61, Subpart M during
       scrapping.

       What is RACM? Once ACM is identified, your facility must determine the total amount of
       ACM that is "regulated" under the asbestos NESFLAP. This material is referred to as
       regulated asbestos-containing material (RACM). RACM includes :
              Friable ACM;
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                                                       Common Practice. Ship scrappers
                                                       typically do not collect samples to be
                                                       analyzed for asbestos.  Instead, they
                                                       assume that all suspect material,
                                                       particularly any covering that is not
                                                       clearly fiberglass, is ACM.
           Category I nonfriable ACM that has
           become friable or that has been sanded,
           ground, cut, or abraded; or

           Category n nonfriable ACM that has a
           high probability of becoming or has
           become crumbled, pulverized, or reduced
           to powder by the forces expected to act on the material in the course of demolition or
           scrapping activities.

    How much RACM make the facility subject to the NESHAP regulations? Your facility is
    required to follow the asbestos NESHAP regulations if the combined amount of RACM on the
    ship is:

    •       At least 80 linear meters (260 linear feet) of RACM on pipes or at least 15 square
           meters (160 square feet) of RACM on other facility components; or

    •       At least one cubic meter (35 cubic feet) of RACM of facility components where the
           amount of RACM was previously removed from pipes and other facility components
           could not be measured before stripping [40 CFR 61.145(a)(l)].

    Note: If the combined amount of RACM is less than these amounts, then your facility only has
    to meet some of the notification requirements [40 CFR 61.145(a)(2)].

ow can asbestos be identified?

    While it is often possible to "suspect" that a material is asbestos or contains asbestos by looking
    at it (visual determination), actual determinations can only be made by instrumental analysis.
    Until your facility tests a product, it is best to assume that the material contains asbestos, unless
    the label or the manufacturer verifies that it does not.

    Your facility's qualified person (see Section 2.3.2, Regulated areas must be established and
    marked, for definition) will collect samples of suspect ACM for analysis. EPA requires (at a
    minimum) that  suspect samples be analyzed for asbestos content using polarized light
    microscopy (PLM). This technique determines both the percent and type of asbestos. EPA
    also recommends the use of the July 1993  Test Method (EPA/600/R-93/116), Method for the
    Determination of Asbestos in Bulk Building Materials, particularly when analyzing special
    case materials.
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        Tip:  EPA recommends that facilities use laboratories accredited by the National Institute of
        Standards and Technology (MIST) in its National Voluntary Laboratory Accreditation Program
        (NVLAP) to complete asbestos analysis. Contact NIST NVLAP for a current listing of
        accredited labs at 301-975-4016. Your facility can also obtain information about laboratories
        that test for asbestos by contacting your EPA Regional office.
H
as a notification been submitted?

    Your facility must submit a written notice of intent to scrap a ship (which is considered
    demolition) to the EPA Regional office and/or the delegated state/local pollution control agency
    [40CFR61.145(b)].
              This notice must be postmarked or delivered     _.._..        .     .   .
                                r                         Tip:  For ship scrapping, asbestos
              at least 10 working days before the date of
              any asbestos removal work  Because EPA
              and the delegated agencies currently receive
              over 90,000 notifications a year, the 10-day
                    .                   .                   starting date of the demolition.
              period is necessary to allow inspectors to
              prioritize and schedule inspections.
                                                       removal activities should begin on
                                                       the start date provided in the
                                                       notification. This date is not
                                                       always the same as the scheduled
              The notification should include, among other items, the scheduled starting and
              completion date of the ship scrapping (demolition); the scheduled starting and
              completion date of the asbestos removal
              work; the location of the site; the names of
              operators or asbestos removal contractors;
              methods of removal; and the approximate
              amount of RACM to be removed [40 CFR
              61.145(b)(4)].
                                                      Tip: Your facility must update the
                                                      notice when the amount of RACM
                                                      changes by at least ą 20 percent.
                       During an inspection, an inspector may verify that the notification
                       was submitted and that activities have been conducted according
                       to the notification.
lAlill RACM be removed before scrapping activities begin?
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       Your facility is required to remove all RACM
       from a ship being scrapped before any
       activities are carried out that would break up,
       dislodge or similarly disturb  the materials or
       preclude access to the materials for
       subsequent removal [40 CFR 61.145(c)(l)].
       All RACM to be removed must be:
        Too cold for wetting? If the temperature
        is below 0°C (32 °F) during removal
        activities, it is too cold for wetting and your
        facility must meet slightly different
        requirements during RACM removal.  See
        40 CFR 61.145(c)(7) for details.
              Adequately wet when removed and must remain wet until collected and contained for
              disposal (see below). RACM contained in leak-tight wrapping need not be wetted.

              Carefully lowered to the ground without dropping, throwing, sliding, or otherwise
              damaging or disturbing the material.

              Moved to the ground via leak-tight chutes or containers if removed more than 50 feet
              above the ground (and not removed as a unit or section).
                       An inspector may observe on site equipment and ask for verbal
                       explanations to determine whether the wetting and handling
                       requirements are being met.

 A re wet methods being used during RACM removal and disposal?

       When removing RACM, your facility is required to control visible emissions of asbestos to the
       outside air because no safe concentration of airborne asbestos has ever been established.

       Remember that the asbestos NESHAP relating to demolitions, including ship scrapping, is a
       work practice standard. This means that it does not place specific numerical emission
       limitations for asbestos fibers on asbestos removals and demolitions. Instead, it requires your
       facility to implement specific work practices to control asbestos emissions [40 CFR 61.145(c)].
       The primary method used to control asbestos emissions is to "adequately wet" RACM with a
       liquid or wetting agent prior to, during and after removal activities. [40 CFR 61.145(c)]. To
       "adequately wet" RACM means to sufficiently mix or penetrate the material with liquid to
       prevent the release of asbestos particulates. If you or your workers see visible emissions
       coming from RACM, then that material has not been adequately wetted.  However, the
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       absence of visible emissions is not sufficient evidence of being adequately wet (see 40 CFR
       61.141, Definitions).
                                    Tip to reduce airborne fibers.  A misting unit can be used
                                    to create a high level of humidity within a removal area. It is
                                    believed that fibers emitted into a saturated environment will
                                    absorb the wetting agent and fall  out of the air faster, thus
                                    reducing airborne asbestos fiber levels.
To meet the NESHAP
wetting provisions, your
workers must wet RACM
and keep it wet until it is
collected and contained for
disposal. Adequate wetting is
typically accomplished by
repeated spraying of the RACM with a liquid or a wetting agent, until it cannot absorb any
more. Wetting agents may be applied with garden sprayers or hoses.
                      An inspector may determine whether RACM has been adequately
                      wetted based on observations made during an inspection. These
                      observations may include, but are not limited to, the following:

                           Is there a water supply in place?

                           Is there visible dust (airborne or settled) or dry ACM debris in
                           the immediate vicinity of the operation? An inspector may
                           collect samples of such materials for analyses of their possible
                           asbestos content.
                           Does the RACM  inside the  bag (if transparent) appear wet?
                           Remember: ACM must be adequately wet when it is placed in
                           the bags or containers.  It is a violation  of the asbestos
                           NESHAP standards to put water in the  bottom of a bag, then
                           strip the asbestos material dry and let it fall into the water.
  "o remove units or sections with RACM
       During your scrapping activities, you can
       remove a component as a unit or in
       sections that contain RACM or are
       covered with, or coated with RACM.
       During the removal process, your workers
       must follow the procedures below to
       control asbestos emissions:
                                       Tip: Torch cutting cables with asbestos
                                       insulation inside (possibly as a wrapping or as a
                                       filler in between wires) is prohibited under the
                                       asbestos NESHAP unless the asbestos is first
                                       removed from the area to  be cut. Similarly,
                                       burning cables containing  asbestos to recover
                                       copper wire is also prohibited.
             Adequately wet all RACM exposed during cutting or disjoining; and
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              Carefully lower each unit or section to the floor and to the ground level without
              dropping, throwing, sliding, or otherwise damaging or disturbing the RACM    [40
                                                                                 CFR
                                                                                 61.145
       After removal, these units or sections must be wrapped in leak-tight wrapping or stripped of
       RACM [40 CFR 61.145(c)(4)]. If stripped, your workers must:

       •      Adequately wet the RACM during stripping; or

             Use a local exhaust ventilation and collection system designed and operated to capture
             the particulate asbestos materials produced by the stripping. The system must exhibit no
             visible emissions to the outside air.
                       Typically, an inspector will examine removed units or sections to
                       ensure that the RACM in these components is still intact.  This may
                       include looking at cut cables to see if any cables covered with
                       asbestos were cut by torch or burned, both of which are violations
                       of the asbestos NESHAP requirements. An inspector may also
                       want to know how the RACM on these units or sections will be
                       removed, if applicable.
Degula
ted areas must be established and marked
       According to OSHA requirements, your facility must establish
       a regulated area where asbestos removal work occurs.  The
       regulated area can include the area where asbestos work is
       conducted; any adjoining area where debris and waste from
       the asbestos work accumulates; and the work area within
       which airborne concentrations of asbestos exceed or can
       reasonably be expected to exceed the permissible exposure
       limits [29 CFR  1915.1001(b) and (e)].
                                                      Tip: Cable stripping areas
                                                      are usually treated as
                                                      regulated areas because
                                                      stripping produces fluff
                                                      which may contain
                                                      asbestos.
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       Each regulated area must meet the following requirements [29 CFR 1915.1001(e)(6)]:
                                                    Tip: Because many workers may not
                                                    be able to read or understand signs in
                                                    English, post signs in English and other
                                                    languages as appropriate.
Be clearly marked Regulated areas
must be marked in any manner that limits
the number of workers in the area, and
protects workers outside the area from
exposure to airborne asbestos [29 CFR
1915.1001 (k)(7)].
              Signs must be clearly displayed at all approaches to regulated areas and have the
              following OSFIA-approved wording.
                                            DANGER
                                           ASBESTOS
                            CANCER AND LUNG DISEASE HAZARD
                               AUTHORIZED PERSONNEL ONLY
              Limit access. Only authorized workers should have access to regulated areas.

              Use respirators. All workers entering and working in these areas must wear
              approved respirators. NOTE: All workers must be medically approved to wear
              respirators and be part of a respirator protection program.

              Prohibit certain activities. Workers are not allowed to eat, smoke, drink, or chew
              tobacco or gum in regulated areas.

              Qualified Person. Under the asbestos abatement requirements, your facility must
              have a qualified person supervise the work conducted in a regulated area (see below).
              Note: The asbestos NESFIAP regulation also requires your facility to have a person
              present during RACM removal activities that is trained in the asbestos NESFIAP
              requirements [40 CFR 61.165(c)(8)].

              Use decontamination area. Workers performing asbestos removal must enter and
              exit the regulated area through a three-stage decontamination area [29 CFR
 A re other engineering controls and work practices used to control asbestos
   emissions during removal?
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       In addition to the emission controls (e.g., wet methods, prompt clean up and disposal of
       RACM wastes) described above, asbestos removal work must be performed using control
       methods, such as vacuum cleaners equipped with high efficiency particulate air (HEPA) filters
       to collect all debris and dust containing ACM [29 CFR 1915.1001(g)(l)].

       In addition, to achieve compliance with OSHA permissible exposure limits, your facility must
       use control methods including, but not limited to:

              Local exhaust ventilation equipped with HEPA filter dust collection systems.

       •      Enclosure or isolation of those processes producing asbestos dust.

              Ventilation of the regulated area to move contaminated air away from the breathing
              zone of workers and toward a filtration or collection device equipped with a HEPA
              filter [29 CFR 1915.1001(g)(2)].

       To ensure that airborne asbestos does not migrate from the regulated area, your facility can also
       use critical barriers or another barrier or isolation method. A critical barrier is one or more
       layers of plastic sealed over all openings into a work area or any other physical barrier sufficient
       to prevent airborne asbestos in the work area from migrating to an adjacent area [29 CFR
       1915.1001(g)(4)]

       Additional control methods, which can be used alone or together, can control asbestos
       emissions [29 CFR 1915.1001(g)(5)]. These include, but are not limited to:

              Negative pressure enclosure systems.  In a negative pressure enclosure (NPE), air
              is changed at least 4 times per hour and is directed away from workers within the
              enclosure and towards a HEPA filtration or a collection device. The NPE is kept under
              negative pressure throughout the period of its use. There is also a requirement to
              maintain a minimum of-0.02 column inches of water pressure differential. This is
              normally accomplished with a manometer.

              Glove bag systems. A glove bag is a sealed compartment with attached inner gloves
              for the handling of ACM. Properly installed and used, glove bags provide a small work
              area enclosure and may be used to remove ACM from straight runs of piping and
              elbows and other connections.
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              Negative pressure glove bag systems .  These are similar to the glove bags
              described above, except a HEPA vacuum system or other device is attached to the
              bag. They may be used to remove ACM from piping.

              Negative pressure glove box systems . Glove boxes, which have rigid sides, are
              made from metal or another material which can withstand the weight of the ACM and
              water used during removal.  A HEPA filtration system is used to maintain the negative
              pressure in the box.  These systems can be used to remove ACM from pipe runs.

              Water spray process system. This process can be used for the removal of ACM and
              PACM from cold line piping.  This process can be used only if employees carrying out
              this process have completed a 40-hour separate training course in its use, in addition to
              training required for employees performing Class I work. For more detailed
              information on pertaining to control methods please refer to 29 CFR,  1915.1001
2.4   DISPOSAL PROCEDURES FOR ASBESTOS-CONTAINING WASTE
       MATERIAL

       Once you remove the ACM, you have to dispose of it. For demolition activities, asbestos-
       containing waste material (ACWM) is defined by EPA to mean any waste that contains or is
       contaminated with RACM (including equipment and clothing). Waste disposal procedures are
       specified in 40 CFR 61.150.

Is the ACWM properly contained?

       After wetting, your facility must seal all
       ACWM in leak-tight containers while
                                       Tip: Some facilities are implementing a new
        ^•11   ^ r/in/~rrT>/-I icr>/- \/ivi  T-I         po icy to et no regu ated materia s touch the
       still wet [40 CFR 61.15 0(a)( 1)1.  The           ^  * u  *      *  •       u •    i    ^
              L             \ ;\ 'i            ground. Asbestos containers are being placed
                                              on the ship, and then directly transported for
                                              disposal when they come off the ship.
containers can be plastic bags (6-mils
thick), cartons, drums, or cans.  For bulk
wastes that will not fit into containers
without additional breaking, your facility
must put these wastes into leak-tight wrapping. The wrapping should be sealed (e.g., with duct
tape) while adequately wet. If the ACWM is placed directly in trailers or roll-off boxes, the
trailers or boxes should first be lined with plastic sheeting. After the ACWM is loaded, the
trailer or roll-off box should be covered with a tarp while the ACWM is adequately wet.
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       In all cases, the ACWM should be wet when contained to prevent the release of asbestos
       fibers in case the container or wrapping is broken.
                     An inspector may check bags or other containers to determine if
                     the ACWM was kept adequately wet when packaging.  One way to
                     quickly check if this requirement has been met is to lift the bag.  A
                     bag with dry ACWM is light and fluffy and can generally be lifted
                     easily by one hand. A bag filled with well-wetted material is
                     substantially heavier and more dense. An inspector may also open
                     any bags to inspect them, most likely using a glove bag or other
                     emissions control method.  The inspector will then properly reseal
                     the bag,  or request that your workers do so. An inspector may also
                     observe trucks picking up asbestos wastes to see if the bags are
                     handled without bursting or dispersing asbestos to the atmosphere.
Is ACWM labeled?
       Your facility is required to place warning labels on all bags, containers, or wrapping materials
       containing ACWM [40 CFR 61.150(a)(l)]. These labels must be printed in letters of sufficient
       size and contrast so that they are easily visible and readable. The labels must have the wording
       specified by OSHA [29 CFR 1915.1001 (k)(8)]:
                                      DANGER
                           CONTAINS ASBESTOS FIBERS
                              AVOID CREATING DUST
                       CANCER AND LUNG DISEASE HAZARD
       Additionally, your facility must label those bags of ACWM destined to be transported offsite
       with the name of your facility (i.e., the waste generator) and the location of your facility [40
       CFR61.150(a)(l)].
 A re there visible emissions during disposal activities?
       Your facility must have no visible emissions to
       the outside air during the collection, packaging, or
       transporting of any ACWM, or your facility must
       use one of the emission control and waste
       treatment methods described in 40 CFR
          Tip: If emissions are visible during
          asbestos waste disposal activities,
          your facility is in violation of the
          asbestos NESHAP regulation.
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       61.150(a).  One such emission control method is adequately wetting the ACWM to ensure
       there are no visible emissions.

Is there visible material  on the ground that appears to be ACM?

       If there is material on the ground that appears to be ACM (such as white fluff), your facility may
       be in violation of the asbestos NESHAP regulation.

                      An inspector will be interested in any material that appears to be
                      ACM that is on the ground at your facility. The inspector may
                      sample and photograph suspected ACM, as well as the sources
                      (such as a nearby cable) that it may have come from.

A re waste shipment records included with ACWM shipments?

       All shipments of ACWM transported off the facility site must be accompanied by a waste
       shipment record (WSR). The WSR is a record of the movement and ultimate disposition of the
       asbestos waste.  Your facility, as a waste generator, must keep copies of all WSRs for at least
       2years[40CFR61.150(d)].

       If your facility does not receive a copy of the WSR signed by the disposal site operator within
       35 days, your facility must take actions to determine the status of the waste shipment.
       Additionally, if not received within 45 days, your facility must submit a written exception report
       to EPA or the delegated state regulatory agency. This report should include a copy of the
       WSR in question, as well as a cover letter explaining what your facility has done to locate the
       shipment and the results of the search.

                      An inspector may examine the WSRs to ensure that the records
                      are  complete, including all required signatures for each shipment.

Is ACWM transported to an appropriate disposal site?

       Your facility must send all ACWM to
       an active disposal site that receives
       ACWM or an EPA-approved site that
       converts RACM and ACWM into
Tip: The U.S. Department of Transportation does
not presently require placarding on transport
vehicles for hazardous materials (such as
asbestos wastes) which are classed as "Other
        ,  ,   f      ,  • , „,,.,  ^m        Regulated Material" [49 CFR 172.5001.
       asbestos-free material. While EPA          a              L             J
       does not license landfills for asbestos
       disposal, it has established asbestos
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       disposal requirements for active disposal sites under the asbestos NESHAP regulation [40
       CFR61.150(b)].

       State and/or local agencies usually require asbestos disposal sites to be approved or licensed.
       Your facility should check with your state or local agency for a list of approved or licensed
       asbestos disposal sites.

                       An inspector may check for consistency between the facility
                       ACWM logs and the disposal site records. Additionally,  the
                       inspector may check to see that the asbestos waste is placed in
                       the disposal site without dispersing asbestos to the atmosphere,
                       and that the site covers the asbestos waste daily.
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Is asbestos a hazardous waste?
       According to the federal hazardous
       waste regulations, asbestos is not
       regulated as a hazardous waste.
       However, states may or may not
       classify asbestos in the same manner.
       Some examples of state regulations are
       presented here:
Is asbestos hazardous? If asbestos is removed
from a ship and exhibits any hazardous waste
characteristics (e.g., toxicity), it is considered a
hazardous waste and is subject to RCRA Subtitle
C regulations found in 40 CFR 261-262.
               Texas: Texas adopted the federal definition of hazardous waste, and therefore, asbestos
               is not regulated as a hazardous waste.  However, discarded materials containing
               asbestos are considered special wastes in Texas. Facilities must follow the state's
               specific handling and disposal requirements for these special wastes disposed of in the
               United States.

               Virginia: Virginia also does not classify asbestos as a hazardous waste under its
               hazardous waste regulations.  However, asbestos is classified as a special waste under
               Virginia's solid waste regulations.  Similar to Texas, facilities must follow Virginia's
               special handling and disposal requirements for asbestos-containing wastes disposed of
               in the United States.

               California: Unlike the other two states, California considers asbestos to be a hazardous
               waste if its exceeds a specific concentration.
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       3. SAMPLING, REMOVAL AND DISPOSAL OF
          POLYCHLORINATED BlPHENYLS (PCBS)

      The sampling, removal, storage, and disposal of poly chlorinated biphenyls (PCBs) is a primary
      environmental concern, as well as a worker health and safety concern, for your facility during
      ship scrapping. As described below, PCBs are found throughout older vessels and it is likely
      your ship scrapping facility will be faced with managing large quantities of PCBs. The following
      sections present background information on PCBs, discuss the effects of exposure to PCBs,
      and describe some of the regulatory requirements with which your facility must comply.

3.1   INFORMATION ABOUT  PCBs
w
hat are PCBs?

  PCBs belong to a broad family of man-made organic chemicals known as chlorinated
  hydrocarbons.  They are basically mixtures of synthetic organic chemicals with the same basic
  chemical structure and similar physical properties. PCBs, which were domestically
  manufactured from 1929 until their manufacture was banned in 1979, can range in toxicity and
  vary in consistency from thin light-colored liquids to yellow or black waxy solids. While sold
  under the trade name "Arochlor," PCBs are known by many trade names. Common trade
  names for PCB dielectric fluids include, but are not limited to:
Aroclor
Aroclor B
Apirolio
Asbestol
Askarel*
Adkarel
Chlorextol
Chlorodiphenyl
Chlorinol
Clorphen
Clophen
Diaclor
Dk
Dykanol
EEC- 18
Elemex
Eucarel
Fenclor
Hyvol
Inclor
Inerteen
Kaneclor
Kennechlor
No-Flamol
Nepolin
Nonflammable Liquid
Phenoclor
Pydraul
Phyralene
Pyranol
Pyroclor
Saf-T-Kuhl
Santotherm FR
Santovac 1 and 2
Therminol

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         Askarel is the generic name used for nonflammable insulating liquid in transformers and capacitors.
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lAlhy were PCBs widely used?
       Due to their non-flammability, chemical stability, high boiling point and electrical insulating
       properties, PCBs were used in hundreds of industrial and commercial applications including
       electrical, heat transfer, and hydraulic equipment; as plasticizers in paints, plastics and rubber
       products; in pigments, dyes and carbonless copy paper; and many other applications. More
       than 1.5 billion pounds of PCBs were manufactured in the United States before production was
       stopped in 1979.
1AI here can PCBs be found on a ship?
       Although no longer commercially produced in the United States, PCBs are found in solid
       (waxy) and liquid (oily) forms in equipment and materials on ships being scrapped.  These
       equipment and materials which may contain PCBs in concentrations of at least 50 parts per
       million (ppm) include:
          Cable insulation
          Rubber and felt gaskets
          Thermal insulation material including
          fiberglass, felt, foam, and cork
          Transformers, capacitors, and
          electronic equipment with capacitors
          and transformers inside
          Voltage regulators,  switches, reclosers,
          bushings, and electromagnets
          Adhesives and tapes
LJow can exposure to PCBs occur?
        Oil including electrical equipment and
        motors, anchor windlasses, hydraulic
        systems, and leaks and spills
        Surface contamination of machinery and
        other solid surfaces
        Oil-based paint
        Caulking
        Rubber isolation mounts
        Foundation mounts
        Pipe hangers
        Light ballasts
        Any plasticizers
       PCBs can be ingested, inhaled, or absorbed through the skin. They circulate throughout the
       body and are stored in the body's fatty tissue. There are OSHA regulations governing
       exposure to PCBs in the workplace.
lAlhat are the dangers of exposure to PCBs?
       PCBs are toxic and persistent. They have been shown to cause a variety of adverse health
       effects, such as cancer in animals, as well as a number of serious noncancer health effects in
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       animals (e.g., effects on the immune system, reproductive system, nervous system, and
       endocrine system). Studies in humans provide supportive evidence for potential carcinogenic
       and non-carcinogenic effects of PCBs. The different health effects of PCBs may be
       interrelated, as alterations in one system may have significant implications for the other systems
       of the body.  In some cases, chloracne may occur in humans exposed to PCBs.  Severe cases
       of chloracne are painful and disfiguring, and may be persistent.

       It is very important to note that the composition of a PCB mixture changes following its release
       into the environment. The types of PCBs that bioaccumulate in fish and animals and bind to
       sediments tend to be the most carcinogenic components of PCB mixtures.  As a result, people
       who ingest PCB-contaminated fish or animal products and touch PCB-contaminated sediment
       may be exposed to PCB mixtures that are even more toxic than the PCB mixtures contacted by
       workers and released into the environment.

       EPA is also very concerned about the toxicity of the chemicals produced when PCBs are
       heated in fire-related incidents. The chemicals produced include polychlorinated dibenzofurans
       and polychlorinated dibenzo-p-dioxins, both of which are believed to be much more toxic than
       PCBs themselves.

3.2   WHO REGULATES PCBs?

              EPA. The Toxic Substances Control Act
                                                          Note: Some states may regulate
                                                          PCBs as hazardous wastes.
(TSCA) enacted in 1976  regulates commerce
and protects human health and the environment
by requiring testing of and establishing
restrictions on certain potentially hazardous chemicals, including PCBs. PCBs are
considered by EPA to be  an unreasonable risk to health and the environment.
Essentially, TSCA legislated true "cradle to grave" (i.e., from manufacture to disposal)
management of PCBs in the United States.

Under Section 6(e) of TSCA, EPA is required to control the manufacture, processing,
distribution in commerce,  use, and disposal of PCBs. The TSCA regulations detailing
the management requirements for PCBs are found in 40 CFR 761.  Part 761 provides
the definition, storage and disposal, cleanup policy, exemptions, general housekeeping,
and reporting requirements for PCBs. EPA published amendments to 40 CFR 761 in
the June 29,  1998 Federal Register [63 FR 35383-35474] which are broad and affect
the sampling, analysis, and disposal of PCBs. The new amendments were effective
August 28, 1998, and can be accessed at http://www.epa.gov/opptintr/pcb.
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             The regulations authorize the export for disposal of PCBs only at concentrations less
             than 50 ppm and imports are prohibited. A rulemaking exemption under TSCA
             Section 6 of TSCA would be required for imports or exports of PCB concentrations >
             50 ppm.

             Currently, EPA has regulatory authority for implementing the TSCA PCB regulations.
             However, several states have their own, more stringent programs.  To determine if your
             state regulates PCBs more stringently, your facility should contact the state
             environmental office.

       •      OSHA. OSHA is responsible for the health and safety of workers who may be
             exposed to PCBs in the work place, or in connection with their jobs. OSHA's
             regulations covering PCB exposure set a maximum exposure limit and include
             provisions for respirators, protective clothing, exposure monitoring, hygiene facilities
             and practices,  warning signs, labeling, recordkeeping, and medical exams. These
             requirements,  which are found in OSHA's Shipyard Industry standards (29 CFR 1915)
             and General Industry standards (29 CFR 1910), are described in more detail below.

3.3   SAMPLING, REMOVING AND MANAGING PCBs

3.3.1  Worker Protection Practices

LJow to meet worker protection limits

       Your facility must ensure that workers are protected from exposure to airborne PCB
       concentrations.  OSHA regulations governing exposure to PCBs in the workplace 29 CFR
       1915 (Subpart Z) include two time-weighted averages for chlorodiphenyl. These are:

       •      1.0 mg/m3 of workplace air over an 8-hour work shift for chlorodiphenyl containing 42
             percent chlorine.

       •      0.5 mg/m3 of workplace air over an 8-hour work shift for chlorodiphenyl containing 54
             percent chlorine.

       A worker's exposure to PCBs in any 8-hour work shift of a 40-hour week cannot exceed
       these concentrations.  Furthermore, employers are required to ensure a safe workplace under
       OSHA regulations.  If specific standards are not applicable, this general requirement for a safe
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       workplace applies.  Note: National Institute for Occupational Safety and Health (NIOSH)
       recommends a more stringent air standard for worker exposure of 1.0 mg/m3.

     workers wear personal  protective equipment as required?

       Your facility is required to ensure workers removing and disposing of liquid or solid PCB
       articles wear or use appropriate personal protective clothing or equipment. The regulation does
       not specify the type of clothing to use because this will vary from one removal and disposal
       scenario to the next. For example, for liquid PCBs, workers must wear PPE that protects
       against dermal contact with or inhalation of PCBs or materials containing PCBs. It is your
       facility's responsibility to determine what type of clothing/equipment is appropriate to protect
       workers handling the contaminated materials.  These may include, but are not limited to,
       coveralls or similar full-body clothing, head coverings, gloves, and foot covering; face shields;
       or vented goggles. This equipment/clothing must be disposed of as PCB remediation waste [40
       CFR761.61(a)(5)(v)].

       If required, workers must use approved respirators that are appropriate for the work being
       conducted.  These must be provided free of charge by the facility. Your facility is responsible
       for establishing an effective respiratory program and workers are responsible for wearing their
       respirators and complying with the program. An effective respirator program must cover the
       following factors: written standard operating procedures; selection; training; fit test; inspection,
       cleaning, maintenance, and storage; medical examination; work area surveillance; and program
       evaluation.

lUIedical surveillance requirements

       Your facility is required to conduct medical surveillance for all workers who, for a combined
       total of 30 or more days per year, are performing PCB removal work or are exposed at or
       above the exposure limit.  This includes medical examination and consultation prior to beginning
       work, at least annually, and upon termination of employment [29 CFR 1915].

A re workers trained in PCB removal and disposal?
       Your facility must provide, at no cost, a training program
       for all workers performing PCB removal work during ship
       scrapping. Training must be provided prior to or at the time
       of beginning work and at least once a year afterwards, and
Tip: Some facilities may
need to hire contractors for
training employees who
speak English as a second
language and may not be
fluent in English.
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       it must be conducted in a manner which the worker is able to understand.

                      An inspector may check to see that workers at your facility
                      received training in a language that they understand.

3.3.2  Sampling for PCBs on Ships

       EPA suspects that certain items, including some on ships, may contain PCBs at regulated
       concentrations of 50 ppm or greater.  When determining the concentration of PCBs in specific
       items, your facility can either: (1) make the same assumptions as EPA (PCB concentration > 50
       ppm) and dispose of these items according to PCB disposal requirements, or (2) conduct
       sampling of these items to determine the actual PCB concentration and dispose of them
       accordingly.

       EPA published amendments to 40 CFR 761 in the June 29, 1998 Federal Register
       [63FR3 53 84-3 5474] which affect the sampling, analysis, and disposal of PCBs. These new
       amendments were effective August 28, 1998. Note:  Technical and procedural amendments
       to this rule were published in the Federal Register [64FR33755] and became effective on
       June 24, 1999.
LJow is sampling for PCBs conducted?

       Using EPA's Interim Final Policy for PCB sampling

       Your ship scrapping facility may follow EPA's policy for determining whether PCBs are
       present and must be removed from a ship.  This policy, entitled Sampling Ships for PCBs
       Regulated for Disposal (Interim Final Policy, November 30, 1995), presents a sampling
       protocol, which is a statistically based random selection process, to analyze for the presence of
       PCBs in ship materials.

       The sampling policy presents two options for ship scrappers to remove PCBs from ships.  Ship
       scrappers may either:

       •      Remove all known liquid PCBs and non-liquid PCBs. No sampling or measurements
             are required for this removal; or
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       •       Sample the ship according to the policy (by three different stratum) and chemically
              analyze the samples to determine whether regulated concentrations of PCBs are
              present. Scrappers can opt either to: (a) sample all items in all classes of uses
              suspected of containing non-liquid PCBs; or (b) in place of this sampling approach,
              remove some classes of uses of non-liquid PCBs and sample all other classes.

       This policy is basically considered a best available practice and is self-implementing.  There are
       notification and recordkeeping requirements; however, no PCB disposal approval is required to
       carry out PCB removal procedures as part of a scrapping procedure.

                      An inspector may review the PCB sampling plans and laboratory
                      analysis results.
        Note: While this policy for sampling PCBs on ships has been used (and may still be
        used) by ship scrappers, the effectiveness of the sampling has been questioned and
        is under evaluation.  When evaluated by the U.S. Maritime Administration
        (MARAD) in 1997, the policy was found ineffective in revealing the most
        significant sources of PCBs or providing information that a scrapper needs to
        perform complete removal of PCBs. Additional problems were discovered with the
        method used for analyzing PCBs, including the appropriateness of the specified
        solvent and the effectiveness of the extraction procedure in recovering all PCBs.
        Your ship scrapping facility should check with your EPA regional office for
        guidance in sampling for PCBs.
Is the "assumption policy" no longer used when determining the PCB
 concentrations in electrical equipment that is being disposed of?

      Historically, many ship scrappers have operated by what is called the "assumption policy,"
      when determining whether liquid-filled electrical equipment contains regulated amounts of
      PCBs. Now, however, under the new PCB amendments, facilities can no longer use the
      assumption policy for PCB electrical equipment that is being disposed of (40 CFR 761.2).

      To be compliant, your facility can choose to either: (1) assume the equipment contains regulated
      concentrations of PCBs (>50ppm), or (2) can sample to determine the actual PCB
      concentration of the electrical equipment at the time of disposal or storage-for-disposal.
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                      An inspector may check to verify that all PCB items are being
                      identified and disposed of properly.  For example, the painted
                      canvas cover which is attached to fiberglass insulation may be a
                      source of PCBs.
 A re manifests used when sending samples for PCB analysis?

       If your facility does not have its own laboratory, it will most likely use an offsite laboratory for
       conducting PCB analysis. When transporting samples for PCB analysis, your facility is exempt
       from meeting the manifesting requirements if they are: (1) being stored and sent by your facility
       to the laboratory for testing, (2) stored by the laboratory prior to testing, and (3) returned to
       your facility by the laboratory after testing [40 CFR 761.65(I)(2)-(4)].
                An inspection team may conduct laboratory audits to verify that the
                laboratory is analyzing the PCB samples properly and that analytical
                results are accurate and reliable.
[Maintaining records of sampling and analysis results

       You must maintain the sampling and analysis results for all samples taken to verify the PCB
       concentration of items that have been removed from a ship.  The results should be listed two
       ways: by individual sample and by sampling scheme stage (that is, how the sample was selected
       in the sampling plan). Records for each individual sample include, but are not limited to:
          Unique identification number
          Type of material or item sampled
          Location where the sample was
          collected
          Date the sample was collected
    Name of the collector
    Amount of the sample collected
    Analytical method used
    PCB concentration in the sample
    Limits of quantitation for chemical analysis
3.3.3 Removal and Storage Requirements

lAlhat are PCB-containing materials and wastes called in the PCB
    regulations?

       You should be familiar with the various terms used in the PCB management regulations for
       PCB-containing materials and wastes.  As defined by EPA 40 CFR 761.3, these terms include:
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              PCB article is any manufactured article (other than a PCB container) that contains
              PCBs and whose surface(s) has been in direct contact with PCBs.

              PCB equipment is any manufactured item (other than a PCB container or PCB article
              container) which contains a PCB article or other PCB equipment. This includes
              electronic equipment and fluorescent light ballasts and fixtures.
           Ballast in fluorescent light fixtures may contain PCBs in small amounts - approximately 1.5
           ounces.  Because EPA banned the manufacture of PCBs in 1979, all light ballasts
           manufactured after 1979 should not contain PCBs and, until 1998, were required to be
           labeled as such ("No PCBs" notation). With this label, it is acceptable to treat ballast as
           unregulated for PCBs. However, without the label, it must be assumed to contain PCBs.
           Fluorescent light ballasts are regulated for disposal if they contain PCBs in concentrations
           of >50 ppm. Disposal options include the following:

           •   Fluorescent light ballasts containing PCB small capacitors that are intact and non-
              leaking can be disposed of as municipal solid waste in a state-approved solid waste
              landfill [40 CFR 761.50(b)(2)(i) and 40 CFR 761.60(b)(2)(ii)].

           •   Fluorescent light ballasts containing PCBs in the potting material are regulated for
              disposal as PCB bulk product waste in accordance with 40 CFR 761.62 [40 CFR
              PCB item is any PCB article, PCB article container, PCB container, PCB equipment,
              or anything that deliberately or unintentionally contains or has as a part any PCBs.

              PCB article container means any package, can, bottle, bag, barrel, drum, tank, or
              other device used to contain PCB articles or PCB equipment, and whose surface(s) has
              not been in direct contact with PCBs.

              PCB container means any package, can, bottle, bag, barrel, drum, tank, or other
              device that contains PCBs or PCB articles and whose surface(s) has been in direct
              contact with PCBs.

              PCB waste(s) means those PCBs and PCB items that are subject to the disposal
              requirements found in 40 CFR 761, Subpart D.

              PCB bulk product waste  refers to waste derived from manufactured products
              containing PCBs in a non-liquid state with a concentration of > 50 ppm PCBs at the
              time the waste is designated for disposal.
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              PCB remediation waste is waste (e.g., soil, rags, or other debris) containing PCBs at
              specified concentrations as a result of a spill, release, or other unauthorized disposal.

 Are storage-for-disposal requirements for certain PCBs and PCB items met?

       The storage of PCBs first became regulated in 1979, and the requirements have remained
       virtually unchanged. Typically, storage-for-disposal requirements apply to PCBs and PCB
       items designated for disposal that: (1) are known or assumed to have concentrations > 50 ppm,
       or (2) have concentrations less than 50 ppm as a result of dilution (materials were originally
       >50 ppm).

       To comply with storage requirements for PCBs, your facility has already or will do the
       following:

       •       Understand which PCBs and PCB items require storage and the various storage
              options which are available.

       •       Establish a proper storage facility for PCBs.

              Use proper containers for PCB storage.

       •       Manage PCB storage in accordance with marking, recordkeeping, and inspection
              requirements.

              Within the 1-year disposal time limit, remove from storage and dispose of PCBs and
              PCB items.

 LJas a  TSCA  identification number been obtained for storing PCBs?
       Your facility is required to have a TSCA
       identification (ID) number if it has a PCB
       storage-for-disposal area or stores PCB
       waste for more than 30 days.  To obtain a
       TSCA ID number, your facility must file
       EPA Form 7710-53 "Notification of PCB
       Activity," which can be obtained from the
       EPA Regional office or accessed at
Will a RCRA ID number work? Unless
otherwise directed by EPA, your facility can
use its valid RCRA ID number for storing
PCBs. Your facility must still notify EPA of
its PCB activity and then EPA can recognize
the RCRA ID number for PCB waste handling
activities.
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       http://www.epa.gov/opptintr/pcb/771053.pdf. Following notification, EPA will assign your
       facility a TSCA ID number.

       If your facility is considered a temporary storage facility (i.e., your facility does not have a
       storage-for-disposal area and stores for less than 30 days), an identification number is not
       required. Contact the facility's state regulatory agency to find out if the state has additional or
       more stringent requirements.
        Note: In addition to generators with on site PCB storage, TSCA ID numbers are also required
        for: transporters; commercial storers; and approved disposers; research and development
        treatability facilities; and scrap metal recovery ovens/smelters/high efficiency boilers.
establishing a PCB storage-for-disposal facility

       If your facility stores PCBs or PCB items for disposal, it must have a "PCB storage facility"
       which meets the following requirements 40 CFR 761.65(b):

       •      Adequate roof and walls to prevent rainwater from reaching PCBs and PCB items.
                                          Tip: Use Stock Tanks or Metal Boxes EPA allows
                                          flexibility in how to meet the "berming" criteria, such as
                                          using stock tanks or metal boxes. The berms of the
                                          tank or box must be constructed of smooth impervious
                                          materials and meet the height and volume requirements.
                                          The tank or box must not have any drains, seams, or
                                          other openings  that would allow liquids to flow from the
                                          containment area.
Adequate floor which has
continuous curbing with a
minimum 6-inch high curb.
The floor and curbing must
provide a containment
volume equal to at least
two times the internal
volume of the largest PCB
article or container stored
inside or 25 percent of the total internal volume of all PCB articles and containers
stored inside, whichever is greater.

Floors and curbing constructed of Portland cement, concrete, or a continuous, smooth,
non-porous surface which prevents or minimizes penetration of PCBs.

No drain valves, floor drains, expansion joints, sewer lines, or other openings that
would permit liquids to flow from the curbed area.
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             Not located at a site that is below the 100-year flood water elevation.

                       An inspector may examine PCB storage-for-disposal areas and
                       check the floor and curb for cracks, measure to verify that the curb
                       is at least 6 inches high, and check the capacity of the containment
                       storage area against the total volume of PCBs in storage.  He/she
                       may also determine the 100-year floodplain location with respect to
                       any storage area.  Many ship scrappers are located within the 100-
                       year floodplain and cannot have storage areas.

Qan an existing building or a portion of an existing building be used to
   properly store PCBs?

       Your facility is not required to construct a separate building for the proper storage of PCBs and
       PCB items. Your facility can use an existing structure to act as a PCB storage facility provided
       that it meets all the criteria noted above and listed in 40 CFR 761.65(b). In addition, your
       facility can designate an area within a building for PCB storage. This area must be clearly
       marked and segregated from other activities within the building.
Qtoring PCBs temporarily prior to disposal
       Your facility has two options for temporarily storing PCB items in areas other than your PCB
       storage facility. These options are referred to as "30-day temporary storage" and "pallet
       storage."
              Thirty-day temporary storage allows your facility to    T.  .,    .   .  .,.  ,
                  J   J    r    J      °       J        J      Tip: Keep in mind that
              store certain PCB items in an area that does not
              comply with the requirements for a PCB storage
              facility for up to 30 days from the date of their removal
the 30-day temporary
storage is included in the
total 1-year storage and
             from service for disposal [40 CFR 761.65(c)(l)].  A     disP°sal time limit-
             note must be attached to the PCB item or container
             indicating the date the item was removed from service.
             PCB items which can be stored under this option include:

             S     Non-leaking PCB articles and PCB equipment.

             S     Leaking PCB articles and PCB equipment if the PCB items are placed in a
                    non-leaking PCB container that contains sufficient sorbent materials to absorb
                    any liquid PCBs remaining in the PCB items.
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              S      PCB containers holding non-liquid PCBs, such as contaminated soil, rags, and
                     debris.

              S      PCB containers containing liquid PCBs at concentrations > 50 ppm, provided a
                     Spill Prevention, Control, and Countermeasures (SPCC) plan has been
                     prepared for the temporary storage area. In addition, the container must bear a
                     notation that indicates that the liquids in the drum do not exceed 500 ppm
                     PCBs.

              In all cases where PCBs of 50 ppm or greater are stored for disposal for more than 30
              days, a PCB storage facility is necessary. Liquid PCBs at concentrations of > 500 ppm
              may not be stored temporarily.
                                                             Tip: Your facility cannot use
                                                             pallet storage if it does not
                                                             have a PCB storage facility.
       •       Pallet storage allows your facility to temporarily
              store certain PCB items on pallets next to your
              PCB storage facility. However, pallet storage is
              only allowed when your PCB storage facility has
              unfilled storage space that is immediately available
              and is equal to 10 percent of the volume of the PCB items being stored on pallets [40
              CFR 761.65(c)(2)]. PCB items which can be stored on pallets include non-leaking
              and structurally undamaged PCB large, high-voltage capacitors and PCB-contaminated
              electrical equipment (known or assumed 50 to 500 ppm) that have been drained of
              free-flowing dielectric fluid.

Marking PCB items and PCB storage areas

       The large PCB mark must be used to mark all PCB items and areas where PCBs are being
       stored.  It is typically 6x6 inches, but may be reduced to 2  x 2 inches if space is limited. Each
       mark (see example) must have black letters and striping on a white or yellow background and
       be sufficiently durable.

       All PCB storage areas, including your PCB storage facility,  30-day temporary storage, and
       pallet storage, must be clearly marked [40 CFR 761.40(a)]. Marks must be placed on the
       exterior of the storage areas so that they can be  easily read by any person inspecting or
       servicing the storage areas.
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                       xxxxxxxxxxx
                                   CAUTION
                                        CONTAINS
                                    PCBs
                                     (Pdviiib injtsxj Bi|J ifcm>ib)
                            A :cKic enviroriJroi'U contaminant requiring
                           f.pfiMl tarrfling ird nifiprfi,-! In yficrdoiira uith
                          U.S. bnvircnmental Protector Agency Hegt aliens
                           43 TFR 701 — Fnr Disposal Informal inn ncrrsoi
                                  lit neatest U.S. E.PA Office
                             In case Df accident or spill, call toll tree the
                             11.5. Coasl G.i^rfl National Respnisfl Csntfif
                                       Ł00:424-6602
                              M>0 Con Met
                              Tel Ho.
                         xxxxxxxxxxx
       If the mark is still too big for the PCB item, a smaller mark (shown here) can be used. This
       mark is 1 inch by 2 inches, but can be reduced
       down to 0.4 inches by 0.8 inches, if necessary.
                       An inspector may check
                       each item in storage for
                       PCB marks.
                       CAUTION

                       PCBs
                    i AJyCl" 0 il&afel Sfl(.iWl}%j
                FOR PR:-?:! OISPSS*. INFORMATION

                    -*;HH;  ")ti K-K'.'i
 A re inspections of PCB storage areas conducted?

       Your facility must inspect all PCB articles and PCB containers in the PCB storage facility for
       leaks at least once every 30 days. If any leaking PCB articles or containers are found, they
       must be transferred immediately to properly marked non-leaking containers. Your facility must
       clean up any spilled or leaked materials immediately, and dispose of the PCB-contaminated
       materials and residues according to PCB disposal requirements [40 CFR 761.65(c)(5)].
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       Your facility must also inspect any PCB items stored adjacent to the PCB storage facility on
       pallets for leaks every week. Any leaking PCB items must be placed inside the storage area
       [40CFR761.65(c)(2)].

 A re appropriate PCB storage containers used for storage and shipment?

       Your facility must use containers for the storage of PCB s (known or assumed 50 ppm or
       greater) that comply with the U.S. Department of Transportation (DOT) Hazardous Materials
       Regulations at 49 CFR 171-180  Please note that the shipping container requirements
       listed in 40 CFR 761.65 (c)(6) are obsolete.  Your facility can obtain more information by
       contacting EPA or its state regulatory agency.

[Maintaining appropriate PCB storage practices and records

       You must manage PCB storage so that PCB articles and PCB containers can be located by the
       date they were removed from service for disposal. Therefore, all PCB articles and containers
       must be dated when they were removed from service for disposal, including 30-day temporary
       storage and pallet storage [40 CFR 761.65(c)(8)].

       You must also develop and maintain records that document it is following all of the PCB
       storage and disposal requirements [40 CFR 761.180(a)-(c)]. These records will form the basis
       for the required "Annual Records" to be prepared by the facility. Facilities which use or store at
       least one PCB transformer, 50 PCB large  capacitors, or 99.4 Ibs. of PCBs in containers must
       keep the following records:

       •     Annual records of all activities involving PCBs, including those PCBs in storage-for-
              disposal or those which have been disposed of during the year.  These records must
             include all manifests, certificates of disposal, records of inspections and cleanups.

       •     An Annual document log which includes specific and detailed information (dates,
             weights, etc.) on the PCBs stored and disposed of during the year. The written annual
              document log must include the name, address and EPA identification number of your
             facility, and the calendar year covered. The log also must include the following
             information for PCB articles, containers of PCBs, or PCB articles in containers at or
             generated at your facility:

             S   Unique identification number                    S  Total volume of container
             S   Container contents                           S  Date received at the facility
             S   PCB concentration (ppm)
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S   Date PCB waste in each container was
    removed from service for disposal
S   Date placed in transport for off-site storage or
    disposal
S   Date disposed of (if known)

       If using bulk storage of PCB s in containers or bulk tanks larger than 5 5-gallon drums, your
       facility must maintain records for each batch of PCBs added to the containers. These records
       must include the quantity of the batch and the date the batch was added. The records will also
       include the date, quantity, and method of disposition of any batch of PCBs removed from the
       container [40 CFR 761.65(c)(8)].

       The records and logs must be maintained for at least three years after the facility no longer
       stores PCB transformers, capacitors, or containers in the above quantities. All records must be
       available for inspection by EPA upon request. Although there is no requirement to do so,
       facilities should keep these records beyond the three-year period to show compliance and limit
       liability in future years.

DCBs stored onsite must be disposed of within one year

       All PCBs must be removed from storage and disposed of within one year [40 CFR 761.65(a)].
       The 1-year time starts the date the PCBs articles are removed from service for disposal or the
       first batch of PCBs is placed in the container for storage-for-disposal.
       Basically, this means that your facility (i.e., the generator) has nine months of the  1-year
       disposal timeframe to store PCBs and transport those PCBs to the disposal facility. The
       remaining three months are for the disposal facility to dispose of the waste.
                                                       Tip: A list of commercially permitted
                                                       PCB disposal companies can be found
                                                       at http://www.epa.gov/opptintr/pcb/
                                                       stordisp.html.
       If your facility delivers the PCB waste to a
       disposal facility later than 90 days before the end
       of the 1-year disposal deadline, your facility will
       be held liable if the disposal facility cannot
       dispose of the waste in time. On the other hand,
       if your facility delivers the waste with 90 days or
       more remaining in the 1-year deadline, then the disposal facility is responsible for disposing of
       the material before the deadline. The disposal facility will share in any liability if it does not
       dispose of the PCB waste within 90 days from the date it is received.

LJoware PCB liquids, items, and wastes disposed of?
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       Your facility must follow strict requirements for the disposal of PCB-containing or PCB-
       contaminated liquids, articles (e.g., transformers, capacitors, hydraulic machines, electrical
       equipment, fluorescent light ballasts), containers, spill material, bulk remediation wastes, and
       bulk product wastes. Depending on the item and its PCB concentration, the following kinds of
       disposal may be required in 40 CFR 761.60 through 40 CFR 761.62:
          Licensed incinerator
          High efficiency boiler
          Chemical waste landfill
                                                   Hazardous waste landfill
                                                   Municipal solid waste landfill
                                                   Non-municipal non-hazardous waste landfill
lAlhen disposing of electrical cables, are PCB materials in the cables
    separated from non-PCB materials?
       Your facility may use shredders and
       separators to recover recyclable
       metal that is intermixed with useless
       nonmetallic material  (see box). Some
       shredder feedstock contains
       hazardous materials, such as PCBs or
       asbestos, which can be difficult to
       contain and effectively separate from
       the metals during the shredding and
       separation process.
                                            Using Shredding for Recovery: Electrical cables,
                                            which range from approximately 15% to 75% copper
                                            by weight, are often shredded for recovery of the
                                            copper by recyclers specializing in this process.
                                            Shredders first reduce the parts to a gravel-like
                                            mixture of metal particles and nonmetal "fluff." After
                                            shredding, the metals can be separated from the
                                            fluff by several means, such as magnetic
                                            separators, air flotation separator columns, or
                                            shaker tables.
                                       Note: Many older vessels have electrical cables that
                                       contain asbestos.  A National Emission Standards for
                                       Hazardous Air Pollutants (NESHAP) notification may be
                                       required if cables contain asbestos. For information about
       While shredding no longer
       requires an approval under the
       PCB regulations, EPA may
       require a permit of shredding
       operations to ensure that
       hazards are properly controlled
       during shredding and separation
       and that the metals and fluff are properly managed thereafter (40 CFR 750). Your facility can
       contact EPA or your state regulatory agency for more information.

3.4   PCB SPILL REPORTING REQUIREMENTS

A re PCB spills  reported?
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       EPA has issued regulations controlling the disposal of PCBs, including both accidental and
       intentional releases of PCBs to the environment. In the event of improper disposal of PCBs in
       concentrations of 50 ppm or greater (or when material  with concentrations now less than 50
       ppm became that way through dilution), EPA has the authority under Section 17 of TSCA to
       compel persons to take action to rectify any damage or clean up the resulting contamination.
       EPA has established a nationwide policy
       for PCB spill cleanups that could affect ship
       scrapping facilities that have improperly
       disposed of PCBs [40 CFR 761.120].
       _, .    ,.   ,         -„  .      ^ r   A         concentrations of 50 ppm or greater.
       This policy became effective on May 4,
Definition of a Spill: A spill means both
intentional and unintentional spills, leaks, or
other uncontrolled discharges where the
release results in any quantity of PCBs with
       1987 and applies only to spills that occur
       after that date. Existing spills which
       occurred prior to May 4, 1987 are to be cleaned up in accordance with requirements
       established at the discretion of EPA.  The policy requires the cleanup to different levels,
       depending on the spill location, the potential for exposure to residual PCBs initially spilled, and
       the nature and size of the population potentially at risk of exposure.

       Spills of liquids containing any amount of PCBs are subject to TSCA regulations. Under the
       TSCA spill policy, your facility is required to report the following PCB spills to the appropriate
       EPA Regional Office of Pesticides and Toxic Substances in the shortest possible time after
       discovery, but in no case later than 24 hours after discovery:

       •       All PCB spills, 50 ppm or greater, which contaminate surface waters, sewers and
               sewer treatment plants, private or public drinking water sources, animal grazing lands,
               and vegetable gardens.

       •       All PCB spills, 50 ppm or greater, involving 1 Ib. or more pure PCBs (by weight) (e.g.,
               approximately 1 pound of Askarel).
        Other Reporting Requirements: Your facility may be required to report PCB spills under the
        Clean Water Act (CWA) and the Comprehensive Environmental, Response, Compensation and
        Liability Act (CERCLA).  Under the CERCLA National Contingency Plan, all spills involving 1
        pound or more of a PCB material must be reported to the National Response Center (NRC) at 1-
        800-424-8802. Check with your EPA regional office for more information on reporting PCB spills.
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        4.   BILGE AND BALLAST WATER REMOVAL

       An important activity during ship scrapping is the proper removal and disposal of wastewater,
       specifically bilge water and ballast water. The activities, if not conducted properly, may impact
       the environmental and present health and safety concerns for your workers.

4.1  INFORMATION ABOUT BILGE AND BALLAST WATER

       The following section describes bilge water and ballast water, where they are found on a ship,
       and the potential human health and environmental impacts if they are not managed properly
       during removal and disposal.

lAlhat is bilge water and where  is it found on a ship?

       Typically, government-owned ships received for scrapping have minimal bilge water onboard.
       Bilge water consists of stagnant, dirty water and other liquids, such as condensed steam, and
       valve and piping leaks, that are allowed to drain to the lowest inner part of a ship's hull (i.e., the
       bilge). Bilge water may also be found in onboard holding tanks, often referred to as oily waste
       holding tanks or slop tanks.

       Bilge water originates from many sources both when a ship is in operation and when a ship is
       being scrapped.  It may contain pollutants, such as oil and grease, inorganic salts, and metals
       (e.g., arsenic, copper, chromium, lead, and mercury). When a ship is in operatioa bilge water
       may originate from leaks and spills, steam condensate, and boiler blowdown.  This drainage
       may include small quantities of oils, fuels, lubricants, hydraulic fluid, antifreeze, solvents, and
       cleaning chemicals. During ship scrapping, bilge water is created through the accumulation of
       rain water (because the decks are open) and the collection of water from fire lines that leak, are
       left open or are used to wet down compartments. Additional bilge water may be generated
       during asbestos removal and metal cutting activities.

lAlhat is ballast water and where is it found on a ship?

       Ballast is typically water (e.g., port water, sea water) that is intentionally pumped into and
       carried in tanks to adjust a ship's draft, buoyancy, trim, and list, and to improve stability under
       various operating conditions.  There can be several kinds of ballast water onboard a ship during
       its operation, including:
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               Clean ballast.  Clean ballast is
               seawater that has been pumped
               into dedicated ballast tanks.
               Because these tanks are
               dedicated to ballasting
Types of Ballast: Ballast can consist of
materials other than water, such as mud or
concrete. Mud ballast usually refers to drilling
mud used in the petroleum drilling industry to
lubricate drill bits and  remove drilling debris.  This
type of ballast is typically treated with lubricants
               operations, the seawater is not        .       .   .  .....    _.  .        ..,,,.
                                                 and corrosion inhibitors. The term mud ballast
               mixed with fuel or oil. Clean        may a|so refer to concrete, rock, water, and other
               ballast water may contain           forms of locked-in ballast.
               pollutants, such as metals (e.g.,
               iron, copper, chromium) and
               chemical constituents. These can come from additives (e.g., flocculant chemicals that
               facilitate the separation of suspended silts) or from contact of the water with the piping
               systems and ballast tank coatings (e.g., epoxy coatings and rust inhibitors containing
               petroleum distillates).  The concentration of these pollutants is expected to increase the
               longer the water is in the clean ballast system.

               Compensated fuel ballast. During a ship's operation, compensated fuel ballast is
               seawater that is taken in by the ship to replace fuel as the fuel is used, thereby
               maintaining the ship's stability. The tanks are always full of fuel, seawater, or a
               combination of both. Depending on the seawater to fuel ratio at the time of scrapping,
               pollutants in compensated fuel ballast may include fuel, fuel additives (e.g., biocides
               added to control bacterial growth in the fuel oil), oil and grease, petroleum
               hydrocarbons and metals, which may result from leaching and corrosion of the fuel
               containment systems.

               Dirty ballast. Dirty ballast is created when seawater is pumped into empty fuel tanks
               for the purpose of increasing ship stability.  The seawater mixes with residual fuel
               producing "dirty" ballast.  Pollutants in dirty ballast may include residual fuel, fuel
               additives (e.g., biocides), oil and grease, petroleum hydrocarbons, and metals (e.g.,
               copper, nickel, silver, and zinc).
                Chromated ballast water: Sodium chromate may be added to ballast water to
                prevent algal growth at the time of vessel layup.
lAlhat are the potential impacts of bilge and ballast water discharges?

       During a ship's operation, bilge and ballast water are routinely discharged by ships operating in
       U.S. coastal waters on a daily basis as regulated by the U.S. Coast Guard (USCG).  The
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       criteria for a ship's discharge is 15 ppm total petroleum hydrocarbons (TPH). Through process
       knowledge, it is known that the presence of PCBs, oils, and Resource Conservation Recovery
       Act (RCRA) metals in regulated concentrations is not a standard occurrence. However, in the
       event that these pollutants are present at elevated concentrations in discharged bilge water and
       ballast water, there may be potential impacts to serious human health and environmental
       impacts. These are as described below:

       •      Bilge and ballast water may both contain metals which cannot be removed through
              treatment or environmental degradation.  Metals, if ingested, can cause various human
              health problems such as lead poisoning and cancer. Additionally,  consumption of
              contaminated seafood has resulted in exposure exceeding recommended safe levels.

              Bilge water may contain toxic organics, such as solvents and poly chlorinated biphenyls
              (PCBs), which can be cancer-causing and lead to other serious ailments, such as
              kidney and liver damage, anemia, and heart failure. Discharges of toxic organics can
              also result in the release of poisonous gas, which occurs most often when acidic wastes
              react with other wastes in the discharge.

       •      Bilge water may contain oils and fuels which can poison fish and other marine
              organisms.  Since these pollutants can float on the water's surface and be blown into
              the shoreline, they can physically cover plants and small animals thereby interfering with
              plant life cycles and the animal's respiration. Birds, fish,  and other animals are known
              to abandon nesting areas soiled by pollution.

              Ballast water has the potential to contain plants and animals, including
              microorganisms and pathogens, that are native to the location where the water was
              brought aboard.  When the ballast water is transported and discharged into another
              port or coastal area, the
              surviving organisms have the
              potential to impact the local
              ecosystem.  The invasion of
              nonindigenous aquatic species
              (see box)  is an environmental
              concern with ballast water
              discharges into U.S. harbors as
              it can cause significant changes
              to ecosystems, upset ecological
              balances,  and cause serious
  An Example of a Nonindigenous Aquatic
  Species - the Zebra Mussel.  The most
  infamous ballast water stowaway is the zebra
  mussel.  Originally from the Baltic Sea, and
  transferred commercially after the United States
  government lifted the Russian grain embargo in
  1981, it now flourishes in the Great Lakes.
  Since 1991,  the mussels have been altering the
  entire food web by removing vast amounts of
  basic food material from the ecosystem.
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              economic harm to U.S. marine, agricultural and recreational sectors.

       4.2   WHO REGULATES BILGE AND BALLAST WATER REMOVAL?

       Regulations governing the removal and disposal of bilge and ballast water and related activities
       (e.g., tank cleaning) are important for the protection of environment as they reduce the amount
       of pollutants released into the environment through wastewater and ensure proper management
       of wastes produced from wastewater treatment. Regulations also protect workers performing
       bilge and ballast removal activities (e.g., handling hazardous waste, performing tank cleaning in
       confined and enclosed spaces and dangerous atmospheres) during ship scrapping.

       •       EPA. EPA has regulatory oversight authority of bilge and ballast water discharges,
              under the following federal laws:

              S      Clean Water Act (CWA). The CWA regulations establish limits on the
                     pollutants that can be discharged by direct dischargers, including publicly-
                     owned treatment works (POTW), and indirect dischargers.

                     Direct dischargers. Direct dischargers are regulated under the National
                     Pollutant Discharge Elimination System (NPDES) program (40 CFR 122).
                     The NPDES program requires that all point source discharges to waters of the
                     United States are covered under an NPDES permit.  As of December 1999,
                     EPA has authorized 43 states and one territory to administer the NPDES
                     program.

                     Indirect Dischargers. If your facility is an indirect discharger, it discharges
                     wastewater into a sewer system that leads to a municipal treatment plant, also
                     known as a POTW.  The POTW typically is owned by the local municipality or
                     a regional board or sewer authority.  To address indirect discharges from
                     industries to POTWs, EPA established the National Pretreatment Program as a
                     component of the NPDES permitting program.  The National Pretreatment
                     Program is designed to reduce the level of pollutants discharged by industry and
                     others  into municipal sewer systems (which lead to POTWs), and thereby,
                     reduce the amount of pollutants released into the environment through
                     wastewater.  The program requires industrial and commercial dischargers to
                     treat or control pollutants in their wastewater prior to discharge to POTWs (40
                     CFR 403).
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                    Unlike other environmental programs that rely on federal or state governments
                    to implement and enforce specific requirements, the pretreatment program
                    places the majority of this responsibility on the POTWs. In authorized states,
                    certain POTWs are required to develop local pretreatment programs which are
                    then approved by the state. Of the 44 states/territories authorized to implement
                    state NPDES permit programs, 27 are authorized to approve local
                    pretreatment programs. In all other states and territories, the pretreatment
                    programs are approved by EPA.

                    Used oil management and  discharges of oil Used oil is regulated under the
                    Used Oil Management Standards (40 CFR 279). Under the CWA, the
                    discharge of oil in such quantities as may be harmful into navigable waters of
                    the United States and adjoining shorelines is prohibited  [CWA Section 31 l(b)].
                    EPA's Discharge of Oil regulation provides information regarding these
                    discharges (40 CFR Part 110) and the Oil Pollution Prevention regulation (40
                    CFR Part 112) requires certain facilities to prepare and implement Spill
                    Prevention, Control, and Countermeasures (SPCC) plans,  and/or Facility
                    Response Plans (FRPs). Waste or used oil that is hazardous must be managed
                    according to the RCRA hazardous waste regulations (40 CFR 261-270).

              S     Resource Conservation and Recovery Act (RCRA).  Under RCRA
                    Subtitle C regulations (40 CFR Parts 260-299), facilities that generate
                    hazardous waste must meet waste accumulation, manifesting, and
                    recordkeeping requirements.  Although RCRA is a federal statute, many states
                    implement the RCRA program. Currently, EPA has delegated its authority to
                    implement various provisions of RCRA to  47 of the 50  states and two U.S.
                    territories. Delegation has not been given to Alaska, Hawaii, or Iowa.

              OSHA.  OSHA regulations include general requirements that workers must follow
              when performing bilge and ballast water removal operations, such as the use of
              personal  protective equipment (PPE) (29 CFR 1915 Subpart I). In addition,
              depending on the work involved, workers may have to follow specific OSHA
              requirements, such as those for conducting confined and enclosed space activities (29
              CFR 1915 Subpart B).  These requirements will be presented in the following sections.

4.3   REMOVING BILGE AND BALLAST WATER

4.3.1  Removal Activities
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LJas the bilge and ballast water been tested?
       Your facility will most likely be required to determine pollutant concentrations in the bilge and
       ballast water prior to its discharge, either as a condition of its NPDES permit or as required by
       the POTW. Sampling may be conducted prior to removal of the water or after it has been
       transferred to a holding tank(s).  The pollutants to be tested for are specified in the permit or
       specified by the POTW. Wastewater, particularly ballast water, should be tested to determine
       the concentration of chromium.  This is due to the practice of adding sodium chromate to
       ballast water (and sometimes bilge water) to prevent algal growth during a ship's operation.
       Chromium may be present at a high concentration which will make the water a hazardous
       waste.
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Is transfer operations equipment inspected prior to removal activities?

       Your facility may use different kinds of transfer operations equipment, such as piping, valves,
       gauges, regulators, compressors, pumps, and other mechanical devices to transfer oil from the
       ship to onshore storage location. This equipment should be inspected regularly and repaired as
       necessary because of the high risk of spills during these operations.

                       An inspector may evaluate transfer operations equipment to verify
                       that all equipment is in proper working order and there is no
                       evidence of spills or leaks.

A re booms immediately available to contain accidental discharges?

       During scrapping, your facility is required to have immediately available certain types and
       lengths of boom to help contain any accidental discharges of oil or oil-containing wastewater
       and reduce the potential for impacts to surrounding biological resources.  This is an EPA
       requirement if your facility is subject to the SPCC rule (see Section 4.6). Under the SPCC rule,
       spill prevention procedures or controls, such as booms,  oil sorbents and barriers, can be used
       to reduce impacts to the environment in the event of a spill.

4.3.2 Cleaning Tanks/Compartments Onboard

       Following the removal of bilge and ballast water from the ship, the ship tanks and/or
       compartments may need to be cleaned to remove any residual oil or waste prior to additional
       ship scrapping activities (e.g., metal cutting).  If working inside spaces or areas, workers may
       be required to follow the OSHA requirements for confined and enclosed space work and
       dangerous atmospheres (29 CFR 1915 SubpartB).

 A re spaces cleaned after removal of bilge and ballast water?

       Depending on the kind of residues in a tank or compartment after bilge or ballast water
       removal, your facility may need to clean that space before any hot work can be performed.
       When cleaning spaces that contain or have last contained bulk quantities of liquids that are
       toxic, corrosive, or irritating, the facility must ensure that manual cleaning and other cold work is
       not performed until certain conditions are met [(29 CFR 1915.13) and (29 CFR 1915.14
       (Hotwork)].  These conditions include, but are not limited to, the following:

             Liquid residues of hazardous materials must be removed as thoroughly as practicable
             before workers start cleaning operations in the space.
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                                                   Who is a "competent person"?
                                                   A competent person is a person who is
                                                   capable of recognizing and evaluating worker
                                                   exposure to hazardous substances or to
                                                   other unsafe conditions and is capable of
                                                   specifying the necessary protection and
                                                   precautions to take to ensure worker safety.
                                                   Your facility may designate any person who
                                                   meets the requirements found in 29 CFR
                                                   1915.7 to be a competent person
                                                   responsible  for performing testing in certain
                                                   situations (29 CFR 1915.7).  The facility may
                                                   use a Marine Chemist, or in some cases, a
                                                   certified industrial hygienist to perform the
                                                   same activities as a competent person.
       Testing must be conducted by the
       facility's competent person to
       determine the concentration of
       flammable, combustible, toxic,
       corrosive, or irritant vapors within the
       space prior to the beginning of
       cleaning or cold work.

       Continuous ventilation must be
       provided at volumes and flow rates
       to ensure that these concentrations of
       vapors are within certain limits/levels,
       and testing must be conducted as
       often as necessary by the competent
       person during cleaning to assure that air concentrations stay within these limits/levels.

Following cleaning, tanks or other areas that have or have contained flammable liquids must be
certified by a marine chemist or a U.S. Coast Guard authorized person before any hot work
can be performed.
                        An inspector may review site records to verify that the proper
                        testing was conducted prior to and during the time that workers
                        conducted cleaning in these spaces.
 A re confined or enclosed spaces determined to be safe for entry?
       Prior to workers entering a
       specific confined or enclosed
       space, your facility's
       competent person must (1)
       visually inspect the space for
       the presence of solids, liquids
       or other contaminants, and (2)
       test the space, as appropriate,
       for:

       •      Oxygen content [29
              CFR 1915.12(a)]
                               A confined space is defined as a compartment of small
                               size and limited access such as a double bottom tank,
                               cofferdam, or other space which by its small size and
                               confined nature can readily create or aggravate a hazardous
                               exposure.

                               An enclosed space is defined as any space, other than a
                               confined space, which is enclosed by bulkheads and
                               overhead.  Enclosed spaces include cargo holds, tanks,
                               quarters, and machinery and boiler spaces.
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              Concentrations of flammable vapors or gases [29 CFR 1915.12(b)]
              Concentrations (air) of toxics, corrosives, or irritants  [29 CFR 1915.12(c)]

       If the tests demonstrate that the oxygen content and air concentrations are within the required
       limits, then workers may enter the space to work. If the tests show that it is not safe to enter a
       space, then certain measures must be taken (e.g., ventilation, re-testing, labeling the space to
       prevent entry or prevent entry without the required protection) for that space.
                       An inspector may review site records to verify that proper air
                       sampling was conducted prior to workers entering confined or
                       enclosed spaces.

 A re workers entering  confined or enclosed spaces appropriately trained?

       Your facility is required to train workers who enter confined or enclosed spaces or other areas
       with dangerous atmospheres to perform their work safely. OSHA requires training in hazard
       recognition and the use of personal protective equipment (PPE).  Your facility must provide
       workers entering these spaces with training before they are allowed to enter, and whenever
       there is a change in operation or in a worker's duties [29 CFR 1915.12(d)].

                       An inspector may review training records to verify  that workers have
                       the appropriate training to be working  in  confined  and enclosed
                       spaces.

4.4   DISCHARGING BILGE AND BALLAST WATER

       Your ship scrapping facility routinely manages the disposal of wastewater, including bilge water
       and ballast water, and where it discharges (e.g., directly to surface waters or indirectly to a
       POTW) will determine which discharge requirements apply. During ship scrapping, bilge water
       and ballast water are routinely transferred from the ship's tanks or bilges to onshore storage
       tanks, evaporation pits (ballast water only), or directly overboard.

       This onboard water must be tested to determine pollutant concentrations either prior to transfer
       onshore or prior to discharge.  Wastewater "treatment" may be required to remove certain
       pollutants (e.g., oils, fuels) prior to discharge.  Oily sludges, which are often produced from
       wastewater treatment (or that are removed from tanks bottoms and bilges), may require
       management as used oil or hazardous waste.

4.4.1  Direct Discharges
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Is wastewater discharged directly to waters of the United States?


       If your ship scrapping facility discharges wastewater directly into waters of the United States, it
       is a direct discharger and subject to the requirements of the NPDES permitting
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       program (40 CFR 122). The
       NPDES program controls direct
       discharges or "point source"
       discharges into navigable
       waters.  If your facility is not
       a direct discharger, refer to
       Section 4.4.2. Indirect
       Discharges.
                                 What is a point source? A point source is broadly
                                 defined as any discernable, confined, and discrete
                                 conveyance, including but not limited to any pipe, ditch,
                                 channel, tunnel, conduit, well, discrete fissure, container,
                                 rolling stock, concentrated animal feeding operations, or
                                 vessel or other floating craft, from which pollutants are or
                                 may be discharged (40 CFR 122.2).
Qoes your facility have an NPDES permit?
       As a direct discharger, you must apply for and obtain a permit under the NPDES program.
       Permits must be obtained from EPA or the authorized state or territory.
                                              Tip: Aside from needing a permit for your bilge
                                              water and wastewater discharges, your facility
                                              may also need an NPDES storm water permit for
                                              the storm water runoff from your facility.
As of December 1999, EPA has
authorized 43 states and one territory to
administer the NPDES program. Where
permit authority has not been delegated
to the state or territory, your facility
must apply for a permit directly from
EPA rather than the state authority. EPA has not delegated authority to the following states and
territories: Alaska, Arizona, District of Columbia, Idaho, Maine, Massachusetts, New
Hampshire, New Mexico, Pacific Territories, Puerto Rico, and the federal Tribal Lands.
       An NPDES permit typically includes effluent limits,
       sampling or monitoring requirements, and reporting
       requirements. In addition, it may contain other site-
       specific requirements, such as (1) construction
       schedules, (2) best management practices (BMPs),
       (3) additional monitoring for non-regulated
       pollutants, and (4) spill prevention plans.
                                                 Tip: For facilities in coastal areas,
                                                 states may include stricter permit
                                                 limits in order to meet the
                                                 requirements of the Coastal Zone
                                                 Management Act (CZMA). For more
                                                 information on these requirements,
                                                 contact your permitting agency.
                         An inspector may ask to see a copy of your facility's NPDES
                         permit covering wastewater discharges.
Qomplying with the effluent limits specified in the NPDES permit
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       An NPDES permit sets limits, often referred to as effluent limits, on the amount of pollutants
       that can be discharged to surface waters. These limits are based on either available wastewater
       treatment technology or on the specific water quality standards of the surface water.

       As part of the permit application, your facility may be required to analyze its wastewater for a
       variety of pollutants, including biochemical oxygen demand (BOD), chemical oxygen demand
       (COD), total organic carbon (TOC), total suspended solids (TSS), ammonia (as N),
       temperature, and pH.

Is wastewater monitoring conducted in accordance with the NPDES permit?
                                                         Removing oil from wastewater. To
                                                         reduce pollutant concentrations,
                                                         particularly oil, a facility may treat
                                                         wastewater using an oil-water
                                                         separator or some comparable
                                                         wastewater treatment technique (see
                                                         Section 4.5).
      Your ship scrapping facility typically will not have a
      continuous production of industrial wastewater.
      However, as a condition of your NPDES permit,
      your facility may be required to periodically monitor
      your wastewater, which may include the bilge and
      ballast water, to determine pollutant concentrations
      prior to discharge. The bilge and ballast water may
      be tested while still onboard in the ship's
      compartments of tanks or after being transferred to onshore storage tanks. The frequency and
      tests required will be specified in the permit. The results of the wastewater monitoring must be
      submitted as a report to the permitting agency.

      Sometimes the pollutant concentrations of the bilge and ballast water onboard a ship will be
      provided to the ship scrapping facility when the ship is received for scrapping. However, if this
      documentation is not provided, the facility will be required to test the water prior to discharge.

      Wastewater, particularly ballast water, should be tested to determine the concentration of
      chromium. This is due to the practice of adding sodium chromate to ballast water (and
      sometimes bilge water) to prevent algal growth during a ship's operation. Chromium may be
      present at a high concentration which will make the water a hazardous waste.

A re all monitoring records maintained as required by the  NPDES permit?

      It is extremely important for your facility to keep
       accurate records of wastewater monitoring
       activities.  The records generated under the
       NPDES program must include:
                                                     Tip: Compare the monitoring results to
                                                     verify that your facility meets the effluent
                                                     limits in its NPDES permit.
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                    The date, exact place, and time of sampling or measurements
                    The individual(s) who performed the sampling or measurements
             •      The date(s) analyses were performed
             •      The individual(s) who performed the analyses
                    The analytical techniques or methods used
                    The results of such analyses (e.g., bench sheets, instrument readouts, computer
                    disks, etc.) (40 CFR 122.41)

       NPDES permits require that all monitoring records be maintained at the facility for at least three
       years.  Note: Many states require these records to be maintained for at least Jive years.

                       During an inspection, the inspector may ask to see the facility's
                       wastewater monitoring records.

 A re additional NPDES reporting requirements met?

       While  some reporting requirements are facility-specific, there are several NPDES reporting
       requirements which apply to all facilities. In the case of the events described below, a facility
       must report to EPA or the authorized state regulatory agency within the required timeframe.
       These reporting requirements are as follows:
Event
Any noncompliance with your permit that may
endanger health or the environment
Other noncompliance
Any planned physical alterations or additions
to your facility
Any planned changes in your discharge that
may result in noncompliance
Reporting Time Frame
Within 24 hours of becoming aware of
violation; written submission within five days
At the time the facility's monitoring reports
are submitted
As soon as possible prior to alterations or
additions
In advance of changes
4.4.2 Indirect Discharges

Is wastewater discharged to a POTW?
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       As an indirect discharger, your facility
                                              What is pretreatment? The reduction of the
       must meet the requirements of the
       National Pretreatment Program (40
       CFR 403).  Under this program,
       industrial sources discharging
amount of pollutants, the elimination of pollutants,
or the alteration of the nature of pollutant
properties in wastewater prior to or in lieu of
discharging or otherwise introducing such
                    _,„„,,            ,       pollutants into a POTW [40 CFR 403.3(q)].
       wastewater to POTWs must control
       the amount of pollutants discharged
       and meet certain pollutant limits
       established by EPA, the state, and/or the local authority. The control of these pollutants may
       necessitate treatment of the wastewater prior to discharge to the POTW — therefore the term
       "pretreatment."

       There are three types of pretreatment requirements:

       •      General pretreatment standards. At a minimum, these federal general pretreatment
              standards apply to your ship scrapping facility's discharge to a POTW.

              Categorical pretreatment standards.  Currently, ship scrapping facilities are NOT
              subject to categorical standards. These standards establish numerical limits for specific
              categories of industrial sources on the discharge of particular toxic pollutants that could
              interfere with or pass through POTWs.

       •      Local limits. These are locally-established requirements for specific facilities which
              may also apply to your facility.

 A re general pretreatment standards for wastewater discharges met?

       In response to the potential problems caused by industrial wastewater, federally-required
       general pretreatment standards were developed to prevent the discharge of pollutants to the
       POTW that will:

       •      Interfere with the operation of the POTW
              Pass though the POTW untreated
              Create problems with disposal of sludge from the POTW
       •      Cause problems to sewer system or treatment plant workers from exposure to
              chemicals
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       Your facility, as an indirect discharger, must meet these general pretreatment standards.
       Basically, these standards include general and specific discharge prohibitions [40 CFR 403.5(a)
       and (b)] as described below.

              General prohibitions do not allow the discharge of any pollutant(s) to a POTW that
              causes pass through or interference.

              S       Pass through is a discharge which exits the POTW into waters of the United
                      States in quantities or concentrations which, alone or in conjunction with a
                      discharge(s) from other sources, is a cause of a violation of any requirement of
                      the POTW's NPDES permit.

              S       Interference is a discharge, which, alone or in conjunction with a discharge(s)
                      from other sources, both (1) inhibits or disrupts the POTW, its treatment
                      processes or operations, or its sludge processes, use, or disposal; and (2)
                      therefore is a cause  of a violation of any requirement of the POTW's NPDES
                      permit or prevents the use or disposal of sewage sludge.

       •      Specific prohibitions do not allow the discharge of certain types of wastes from all
              non-domestic sources, including the following:

              S       Discharges containing pollutants which create a fire or explosion hazard in the
                      POTW.

              S       Discharges containing pollutants causing corrosive structural damage to the
                      POTW, but in no case discharges with a pH lower than 5.0, unless the POTW
                      is specifically designed to handle such  discharges.

              S       Discharges containing pollutants in amounts causing obstruction to the flow in
                      the POTW resulting in interference.

              S       Discharges of any pollutants released at a flow rate and/or concentration which
                      will cause interference with the POTW.

              S       Discharges of heat in amounts which will inhibit biological activity in the POTW
                      resulting in interference, but in no case in such quantities that the temperature at
                      the POTW treatment plant exceeds above 104°F (40 °C) unless an alternative
                      temperature limit is approved.
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                        Contact your POTW. The primary enforcement authority for
                        pretreatment regulations is often the local POTW. To assure
                        compliance, your facility must contact its local POTW, even if it
                        has already contacted the state regulatory agency or EPA region.
                        Where the POTW local  limits are more stringent than federal
                        requirements, these local limits will replace the federal requirements.
              S     Discharges of petroleum oil, nonbiodegradable cutting oil, or products of
                    mineral oil origin in amounts that will cause interference or pass through.

              Local POTWs with approved pretreatment programs have responsibility for enforcing
              pretreatment requirements.

Qoes the facility have a pretreatment permit from the POTW for its
   wastewater discharges?

       In addition to the local limits, your POTW may require your facility to have a pretreatment
       permit for its wastewater discharges. This permit usually includes effluent limits, as well as
       monitoring, reporting, and recordkeeping requirements.  While a POTW is required by federal
       law to permit significant industrial users (SIUs),  it may also choose to issue permits to any of its
       industrial dischargers.

       Remember — even if a permit is not required, your facility will still need to get
       approval from the POTW for its industrial wastewater discharges to the POTW.

                       Prior to the inspection, the inspector may contact the POTW to
                       determine if a pretreatment permit is required for your facility.
                       During the inspection, the inspector may review the permit to
                       determine if your facility is in compliance with permit conditions.

A re local POTW limits for wastewater discharges met?

       Under the pretreatment program, a POTW can implement and enforce specific "local limits" for
       any or all of the industrial facilities from which it receives wastewater as part of its pretreatment
       program activities. Basically, these limits are designed to protect the POTW and its workers
       and to meet the POTW's own NPDES permit limits.
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       The POTW used by your ship scrapping facility may or may not have local limits. Prior to
       discharging to the POTW, your facility should contact the POTW to see if any pretreatment
       conditions or local limits apply to your wastewater discharges. Remember — even if your
       facility is not subject to the POTW's local limits, the general pretreatment standards
       do apply.

                       Prior to the inspection, the inspector may contact the POTW to
                       determine if any pretreatment conditions or local limits apply to
                       your facility. During the inspection, the inspector may review
                       facility records to determine if your facility is in compliance with
                       applicable pretreatment requirements,  including local limits.

 Are monitoring and  recordkeeping requirements met for indirect wastewater
   discharges?

       The monitoring and recordkeeping requirements applicable to your facility will be specified in its
       POTW pretreatment permit.  Your facility may be required to sample the bilge and ballast
       water prior to discharging to the POTW, either as a condition of the permit or as required by
       the POTW.

       Sampling or monitoring records must be maintained for all samples collected for at least three
       years.  These records, which should be available for review at any time, must include:

       •       Date, exact place, method, and time of sampling
              Individual(s) who performed the sampling
              Date(s) analyses were performed
       •       Individual(s) who performed the analyses
       •       Analytical techniques or methods used
              Results of such analyses [40 CFR 403.12(o)]

Meeting reporting requirements for indirect wastewater discharges

       The reporting requirements applicable to your facility will be specified in its wastewater
       discharge permit. In addition to these reporting requirements, there are some reporting
       requirements that apply to all indirect dischargers, even if they do not have a permit. These are
       presented below.

       •       Immediately notify the POTW or state of a discharge of wastewater that could cause
              problems to the POTW, including slug loading [40 CFR 403.12(f)].
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              Notify the POTW or state of substantial change in wastewater discharge prior to the
              change [40 CFR 403.12(j)].
              Notify the POTW, state hazardous waste        _.   . ,. .  ,    .  ,  .
                                                          Tip: A list of acutely hazardous
              authorities and EPA Regional Waste             wastes can be found in 40 CFR
                                                          261.30(d) and 40 CFR 261.33(e).
              Management Division Director of a discharge
              of hazardous waste.  This is a one-time
              notification required of those who discharge
              more than 15 kg of a hazardous substance in a month; or if the substance is acutely
              hazardous and any amount is discharged [40 CFR 403.12(p)].

              The written notification must include:

              S     Name of the listed hazardous waste as listed in 40 CFR 261.
              S     EPA hazardous waste number.
              S     Type of discharge.
              S     Certification that a program is in place to reduce the amount and toxicity of the
                    hazardous waste that is generated, to the degree that is economically feasible.

              If discharging more than 100 kg of hazardous waste in one month, the notification also
              must include:

              S     Identification of the hazardous waste constituents that are contained in the
                    waste.

              S     An estimate of the mass and concentration of the constituents in the waste
                    stream discharged during the month.

              S     An estimate of how much will be discharged in the next 12 months. If any new
                    substance is listed under RCRA and a facility discharges the substance,  the
                    facility must notify the authorities cited above within 90 days of the new
                    listing

Does your facility pay a surcharge for discharges to the POTW?

       Even if permits are not required, wastewater treatment by POTWs costs money and most
       POTWs charge according to the volume of wastewater treated. Many POTWs charge flat
       rates per unit flow and pollutants, regardless of concentration. Other POTWs may charge
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       extra if the waste load exceeds certain specified levels. This extra charge is called a surcharge.
       Surcharges are used for pollutants that typically can be treated at the wastewater treatment
       plant such as biochemical oxygen demand (BOD) and total suspended solids (TSS).

       A surcharge is defined as a charge that is based on the pounds of waste material in industrial
       wastewater in excess of a facility's "normal" levels.  The surcharge is levied in addition to the
       normal sewer service charge which is the regular charge for treating normal strength wastes and
       is generally based on volume alone. Because a surcharge typically is based on the pounds of
       waste above "normal," there is an economic incentive for facilities to reduce the strength of
       these wastes.

4.5   WASTEWATER TREATMENT AND WASTE MANAGEMENT

       Bilge and ballast water often contain concentrations of many pollutants, particularly oil and fuel,
       which must be reduced prior to wastewater discharge to a POTW or directly to surface waters.
       This reduction of pollutant concentrations is often required for your facility to meet permit
       and/or local limits. Wastewater treatment processes may produce waste oil and oily sludge.
       These materials may be stored in containers or holding tanks and depending on their properties,
       either: (1) managed as used oil or (2) managed and disposed of as hazardous waste. The
       effluent discharges from an oil-water separator typically contain the same constituents present in
       bilge water, but with lower concentrations of oil and grease and oil-soluble components.

4.5.1 Treating  Wastewater

Is an oil-water separator system used for wastewater treatment?

       "Treating" bilge and ballast water when still onboard a ship or stored in onshore tanks is
       typically accomplished using some type of oil-water separator system. While there are several
       types of oil-water separators available, it is important to install and use one that can remove any
       free, dispersed, and emulsified oils present in the wastewater.  Oily water from other sources at
       the facility, such as tank bottoms, can also be treated using an oil-water separator. The end
       products of this process generally include waste oils, oily sludge, and effluent discharges. The
       effluent discharges typically contain the same constituents as were present in the original
       wastewater, but with lower concentrations of oil and grease and oil-soluble components.
       Note: Although an oil-water separator should be used,  some ship scrapping facilities still
       decant liquids as a means of separation.
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     An Alternative to an Oil-Water Separator System. In addition to oil-water separation
     systems, there are other types of wastewater treatment systems available for use. For
     instance, a microbial treatment system can be used to degrade oil and fuel contaminants in
     bilge and ballast water.  One type of biological treatment system uses two tanks. Wastewater
     is pumped to the first tank where microbes are added to break down the petroleum
     contamination. The wastewater is pumped to a second tank where it is aerated to remove free
     oil.  Chlorine tablets  are added to kill the microbes, and the treated water can then be
     discharged to a sanitary sewer. This type of system can be placed near the dock area so that
     the bilge and ballast water can be pumped directly from the ships. If sized and operated
     properly, a microbial treatment system can eliminate the oil and fuel contaminants in
     wastewater, as well as other oily non-hazardous wastewater generated at the facility.
Is evaporation used for treatment?

       If not chromated, some facilities pump ballast water into an onsite evaporation pit for treatment.

4.5.2  Storing  Wastes  in Tanks

       While various types of containers may be used to store oil and fuel removed from a ship,
       facilities commonly use underground storage tanks (USTs) (40 CFR 280) or aboveground
       storage tanks (ASTs) [40 CFR 112.7(e)(2)].

       Underground Storage Tanks. An UST is a tank and any underground piping connected to
       the tank that has at least ten percent of its combined volume underground.  To protect human
       health and the environment
       from dangerous releases,
                      ,  ,              A Basic Checklist for USTs. EPA has a checklist that
       US 1 s must have leak             can he|p your facNity eva|uate its USTs Your facility can
                                       use the checklist to see how closely it meets the federal
                                       regulations for USTs (40 CFR 280). The checklist can also
                                       help your facility prepare for official inspections of USTs.
                                       The checklist can be accessed at http://www.epa.gov
                                       /swerustl/ cmplastc/cheklist.htm.
detection and spill, overfill, and
corrosion protection.  Other
UST requirements address
notification, installation,
corrective action, financial
responsibility, and
recordkeeping.

Tanks installed after 1988 need to comply with all UST requirements upon installation.  Tanks
installed before 1988 had until December 1998 to comply with spill, overfill, and corrosion
protection requirements, but these USTs should be in compliance with all requirements now.
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            Warning: Now that the December 22, 1998 deadline for all UST systems has
            passed, owners and operators of facilities that continue to operate UST systems
            not meeting the  federal requirements for leak detection, and spill, overfill, and
            corrosion protection are out of compliance. Besides posing a threat to human
            health and the environment, such operation can subject the owner/operator to
            considerable fines.
                                                            Note: USTs that store flammable
                                                            and combustible liquids must also
                                                            meet NFPA provisions for tank
                                                            storage and piping systems.
       Some USTs are not covered by federal regulations (e.g., tanks storing heating oil used on
       premises where it is stored; tanks on or above the floor of underground areas, such as
       basements or tunnels; emergency spill and overflow fill tanks); however, such USTs may be
       regulated by your state or local regulatory agency.

       For more information on USTs, visit EPA's Office of Underground Storage Tanks website at
       http://www.epa.gov/OUST/.  Check with the state and local regulatory agencies to find out if
       there are additional or more stringent state and/or local UST requirements.

       Aboveground Storage Tanks. ASTs, depending on
       their storage capacities, may  be subject to federal
       requirements under 40 CFR  112, as well as state and
       local requirements.  State  and local requirements
       typically incorporate standards established by
       organizations such as the National Fire Protection
       Association (NFPA) and the  American Petroleum
       Institute. For more information about the NFPA requirements, call the NFPA at 611'-71'0-
       3000 or access their website  at http://www.nfpa.org.

       Construction, design, and operation requirements for ASTs are typically governed by state and
       local fire marshals or environmental officers. In addition to consulting with your fire marshal,
       your facility should also check with your state regulatory agency for information on additional
       AST requirements.

LJas the state UST program office been  notified of any USTs on site?

       If your facility has onsite regulated UST systems, it is required to submit a notification form to
       the state UST program office. This form includes certification of compliance with federal
       requirements  for installation,  cathodic protection, release detection, and financial responsibility
       for UST systems installed after December 22, 1988. For more information on how to obtain
       and complete the form, call EPA's RCRA/UST,  Superfund, and Emergency Planning and
       Community Right-to-Know  Act (EPCRA) Hotline at 1-800-424-9346.
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                       An inspector may check with the state LIST program office to verify
                       that the number of USTs match the number reported on the
                       notification form(s) to the state.
Is leak detection conducted for tanks and piping?
       Facilities with federally regulated UST
       systems must conduct leak detection.
       The monthly monitoring methods that
       may be used to conduct leak
       detection of tanks include the
       following:
 Note: Facilities with USTs may use inventory
 control and tank tightness testing instead of one of
 the monthly monitoring methods for a maximum of
 10 years after the tank is installed or upgraded with
 corrosion protection (40 CFR 280.41).
       •   Automatic tank gauging
       •   Monitoring for vapors in soil
       •   Interstitial monitoring
       •   Groundwater monitoring
       •   Statistical inventory reconciliation
          Other methods approved by the regulatory authority.

       In addition, any pressurized piping must have: (1) monthly monitoring (as described above) or
       annual line testing, and (2) an automatic flow restrictor, an automatic shutoff device, or a
       continuous alarm system installed. Check with your state UST program office to determine
       which leak detection methods are acceptable in your state.

Qo USTs meet requirements for spill, overfill, and corrosion protection?

       Your facility must operate USTs to ensure that spills, overflows, and corrosion do not cause
       releases into the environment.  As of December 22, 1998, your facility was required to meet
       the federal requirements for spill, overfill, and corrosion protection for all of its UST systems
       see 40 CFR 280.

Are ASTs inspected on a periodic basis to verify tank integrity?

       ASTs must be inspected periodically for tank integrity [40 CFR 112.7(e)(2)(vi)]. Several
       techniques are available to test tank integrity such as:
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              X-ray or radiographic analysis to measure wall thickness and detect cracks and
              crevices in metal

       •      Ultrasonic analysis to measure shell metal thickness
              Hydrostatic testing to identify leaks caused by pressure

       •      Visual inspection to detect cracks, leaks, or holes

              Magnetic flux eddy current test used in conjunction with ultrasonic analysis to detect
              pitting.

       Your facility should check the outside of the tank for signs of deterioration, leaks that might
       cause a spill, and accumulated oil inside the diked areas. AST tank bottoms may be subject to
       extensive corrosion, which may go undetected during visual inspections.  A tank also may fail
       due to surface corrosion. Pitting creates a high potential for AST failure. Holes may form in
       rusty tanks causing the tank to leak. Your facility can prevent corrosion by taking measures
       appropriate for the type of tank installation and foundation (e.g.,  dielectric coatings, carefully
       engineered cathodic protection, and double-bottom tanks).

       Your facility should also examine the foundation and supports of each tank. If a tank sits on a
       foundation, check for large gaps between the foundation and the tank bottom and for crumbling
       or excessive cracking in a concrete foundation.  Assess whether a storage tank foundation
       provides adequate support for the tank.  If the tank sits directly on the ground,  check for large
       gaps between the ground surface and the tank bottom.

       All leaks should be documented and repaired immediately.

Msing secondary containment to prevent oil discharges

       For ASTs,  your facility is required to install appropriate containment and diversionary structures
       or equipment, such as dikes, berms, and retaining walls (40 CFR 112.7), to prevent discharges
       of oil from reaching navigable water, unless it can be clearly demonstrated that installation of
       such structures or equipment is not practicable. Impracticability  pertains primarily to those
       cases where severe space limitations or other physical constraints may preclude installation of
       structures or equipment to prevent  oil from reaching navigable water. Demonstrating
       impracticability on the basis of economic considerations is not acceptable.
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                         An inspector may verify that there are appropriate containment
                         and diversionary structures or equipment at the facility for all
                         ASTs.

4.5.3 Managing Oil/Oily Wastes as Used Oil

       Used oil is managed according to the Used Oil Management Standards (40 CFR 279). As a
       facility that handles used oil, your facility must follow certain good housekeeping practices.
       These management standards are common sense, good business practices designed to ensure
       the safe handling of used oil to maximize recycling and minimize disposal.  Note: Some states
       may have stricter disposal requirements. Contact your state regulatory agency to determine the
       used oil disposal requirements.

       As noted earlier, EPA defines used oil as "any oil that has been refined from crude oil or any
       synthetic oil that has been used and as a result of such use is contaminated by physical or
       chemical impurities."  A substance must meet each of the following three criteria to meet the
       definition of used oil:

       •      Origin. This criterion is focused on the oil's origin. Used oil must have been refined
              from crude oil or made from synthetic materials. Animal and vegetable oils are
              excluded from EPA's definition of used oil.

       •      Use.  This criterion is based on whether and how the oil is used.  Oils used as
              lubricants, hydraulic fluids, heat transfer fluids, buoyants, and for other  similar purposes
              are considered used oil. Unused oils, such as bottom  clean-out waste from virgin fuel
              oil storage tanks or virgin fuel oil recovered from a spill, do not meet EPA's definition
              of used oil because they have never been "used." EPA's definition also excludes
              products used as cleaning agents or used solely for their solvent properties, as well as
              certain petroleum-derived products like antifreeze and kerosene.

       •      Contaminants. To meet EPA's definition, used oil must be contaminated with either
              physical or chemical impurities as a result of being used. This includes  residues and
              contaminants generated from handling, storing, and processing used oil. Physical
              contaminants may include metal shavings, sawdust, or dirt.  Chemical contaminants
              could include solvents, halogenated volatile organics (i.e., halogens), or saltwater.

       Used oil and substances containing or covered with used oil are regulated according to the
       Used Oil Management Standards if they meet certain conditions. Otherwise, they are subject to
       being managed according to other regulations [40 CFR 279.10(b)].
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       The following are regulated as used oil:

       •      Used oil produced on a ship from normal shipboard operations is subject to regulation
              as a used oil when it is transported ashore.

              A mixture of used oil and a waste that is hazardous solely because it exhibits the
              characteristic of ignitability if the resultant mixture does not exhibit the characteristic of
              ignitability.

              Except as described in the bullet above, a mixture of used oil and a hazardous waste
              that solely exhibits one or more of the hazardous waste characteristics (e.g., ignitability,
              corrosivity, reactivity, or toxicity) if the resultant mixture does not exhibit any of the
              hazardous waste characteristics.

       •      Materials which contain or are otherwise contaminated with used oil that are recycled
              (e.g., burned for energy recovery). This includes the used oil drained or removed from
              these materials.

       The following are not regulated as used oil:

              Oils and oily wastes that do not meet the definition of used oil.

       •      A mixture of used oil and a hazardous waste that exhibits one or more of the hazardous
              waste characteristics (e.g., ignitability, corrosivity, reactivity, or toxicity) if the resultant
              mixture exhibits any hazardous waste characteristics. This mixture must be regulated as
              a hazardous waste

       •      A mixture of used oil and a listed hazardous waste. This includes used oil mixtures
              containing more than 1,000 ppm total halogens. (EPA presumes that the used oil has
              been mixed with a listed halogenated hazardous waste.) This mixture must be regulated
              as a hazardous waste.

              Materials which contain or are otherwise contaminated with used oil if the used oil has
              been properly drained or removed (i.e., there are no visible signs of free-flowing oil
              remaining on or in the materials)  from them. These materials are then not defined as
              used oil and therefore, are not regulated as used  oil.
preventing the mixing of used oil with hazardous waste
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                                           Tip: Avoid mixing used oil and hazardous waste.
                                           If used oil is mixed with hazardous waste, the entire
                                           volume will probably have to be managed as
                                           hazardous waste.  The safest practice is to never mix
                                           any other wastes with used oil.
    Hazardous waste fluids, such as
    used solvent, gasoline, or other
    hazardous substances, should not
    be mixed with used oil, or the
    entire volume maybe classified as
    hazardous waste. Basically, the
    following mixing rules apply:

           A mixture of used oil and a waste that is hazardous solely because it exhibits the
           characteristic of ignitability must be managed as a hazardous waste if the resultant
           mixture exhibits the characteristic of ignitability.

           A mixture of used oil and a hazardous waste that exhibits one or more of the hazardous
           waste characteristics (e.g., ignitability, corrosivity, reactivity, or toxicity) must be
           regulated as a hazardous waste if the resultant mixture exhibits any hazardous waste
           characteristics.

           A mixture of used oil and a listed hazardous waste must be regulated as a hazardous
           waste.  This includes used oil mixtures containing more than 1,000 ppm total halogens.
           (EPA presumes that the used oil has been mixed with a listed halogenated hazardous
           waste.)

    The safest practice is never to mix any other waste with used oil. However, if you have
    questions about which specific products may be mixed with used oil, call the RCRA/UST,
    Superfund, and EPCRA Hotline  at 1-800-424-9346.

re containers/tanks leak free and labeled "used  oil"?
    Your facility can store used oil in containers (e.g., 55-
    gallon steel drum) or tanks (e.g., underground or
    aboveground storage tanks). These containers and tanks
    must be leak free and labeled with the words "Used Oil."
    Some facilities have pipes that connect to a used oil
    storage tank. In this case, the piping should also be
    labeled with the words "Used Oil." No special labels are
    necessary, provided that the words "used oil" are visible at all times. Spray painting, crayon, or
    handwritten (preferably not in pencil) labels are okay.
                                                                labeling procedures apply to
                                                                any container storing such oil
                                                                (see Section 3).
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                          An inspector may inspect all oil storage containers or tanks to
                          verify that they are labeled properly and there is no evidence of
                          leaks or discharges of oil.
 A re used oil and fuel recycled or sent to a reclaimer?
       Recycling is the most environmentally protective and often the most economical approach to
       handling used oil. Your facility most likely sends used oil and fuel to a recycling center or
       reclaimer. The used oil management standards (40 CFR 279) include a recycling presumption,
       that is, an assumption that all used oil that is generated will be recycled. This is based on the
       fact that almost all used oil can be recycled. Facilities should maintain all records on their used
       oil storage and recycling activities.
       Your facility has two options for
       transporting used oil: (1) using a
       transporter or (2) self-transporting.
       Your facility must ensure that your used
                                        Tip: Check your transporter's qualifications to
                                        make sure they take your used oil to a reputable
                                        recycling center. Measure the level of oil in your
                                        tank before and after the transporter collects it to
        ...           ,              ,            be certain the oil collected matches the amount
       oil is transported to an approved            the transporter has reported.
       recycling center by transporters who
       have obtained EPA identification
       numbers. If self-transporting more than 55 gallons of used oil offsite to an approved recycling
       center, your facility is required to (1) have an EPA identification number and (2) be licensed as
       a used oil transporter.
       Another method of recycling used oil is burning       ..   .  ..  .   ..      ...      .  ,.
                           J   &               &       Used oil should never be disposed of in
                                                        sewers, drains, dumpsters, on the
                                                        ground, or used as dust suppressants.
for energy recovery. Your facility may burn the
used oil in an onsite heater which is used to heat
parts of the facility or heat hot water, or it either
has a transporter or takes its own oil to an
approved used oil burner. Used oil burned offsite may be used as fuel in industrial furnaces,
utility boilers, or hazardous waste incinerators.

Note: Though not the environmentally preferred method, nonhazardous sludge may be disposed
of in a solid waste landfill, which is also known as a municipal landfill (40 CFR 258), if it is not
sent to a recycling center. Your facility should contact its municipal solid waste landfill for more
information on industrial sludge disposal requirements.
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                        An inspector may track the shipments from your facility through the
                        reclaimers to verify that the shipments of fuel and oil do not
                        contain spent solvent or other hazardous waste liquids.

4.5.4  Managing Oil/Oily Wastes as Hazardous Waste

 A re oil/oily wastes hazardous?

       Oil and oily wastes from wastewater treatment or other sources may contain substances in
       concentrations which make them hazardous. If hazardous, they must be managed and disposed
       of according to the RCRA hazardous waste regulations (40 CFR 261-270).

       If your facility has determined that these oil/oily wastes are not classified as used oil, then it must
       test them to determine pollutant concentrations and evaluate if they are hazardous.  Tests may
       be conducted for various contaminants, including but not limited to: metals, such as lead,
       arsenic, chromium, and cadmium; polychlorinated biphenyls (PCBs); total halogenated volatile
       organics; and the flash point.

       To be considered "hazardous waste," materials must first meet EPA's definition of "solid
       waste."  Solid waste is discarded material, such as garbage, refuse, and sludge, and it can
       include solids, semisolids, liquids, or contained gaseous materials. Solid wastes that meet the
       following criteria are considered hazardous and subject to RCRA regulations 40 CFR 261:

       •      Listed waste. Waste is considered hazardous if it  appears on one of four lists of
              hazardous wastes published in 40 CFR 261 Subpart D.  Currently, more than 400
              wastes are listed. Wastes are listed as hazardous because they are known to be
              harmful to human health and the environment when  not properly managed. Even when
              properly managed, some listed wastes are  so dangerous that they are called "acutely
              hazardous wastes." Examples of acutely hazardous  wastes include wastes generated
              from some pesticides that can be fatal to humans even in low doses.

       •      Characteristic waste. If waste does not appear on one of the hazardous waste lists, it
              still might be considered hazardous if it demonstrates one or more of the following
              characteristics:

              S     Ignitable:  Ignitable wastes can create fire under certain conditions (e.g.,
                     temperature, pressure) or are spontaneously combustible (40 CFR 261.21).
                     Examples include certain used paints, degreasers, oils  and solvents.
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                     Corrosive: Corrosive wastes are acids or bases that are capable of corroding
                     metal, such as storage tanks, containers, drums, and barrels (40 CFR 261.22).
                     Examples include rust removers, acid or alkaline cleaning fluids, and battery
                     acid.

                     Reactive:  Reactive wastes are unstable and explode or produce toxic fumes,
                     gases, and vapors when mixed with water (40 CFR 261.23). Examples
                     include lithium-sulfide batteries and explosives.

                     Toxic: Toxic wastes are harmful or fatal when ingested or absorbed, or leach
                     toxic chemicals into the soil or groundwater when disposed of on land (40 CFR
                     261.24).  Examples include wastes that contain high concentrations of heavy
                     metals, such as cadmium, lead, or mercury.
                Determining toxicity: A facility can determine if its waste is toxic by having it tested
                using the Toxicity Characteristic Leaching Procedure (TCLP), or by process
                knowledge. TCLP can be done at a local certified laboratory.  It is designed to
                replicate the leaching process and other effects that occur when wastes are buried in
                a typical municipal landfill.  If the waste contains any of the regulated contaminants at
                concentrations equal to or greater than the regulatory levels, then the waste exhibits
                the toxicity characteristic. Process knowledge is detailed information on wastes
                obtained from existing published or documented waste analysis data or studies
                conducted on hazardous wastes generated by similar processes. For example, EPA's
                lists of hazardous wastes in 40 CFR 261 (as discussed above) can be used as
                process knowledge.
                       During an inspection, the inspector may ask the facility if it has
                       tested the oil and oily wastes to determine their pollutant
                       concentrations and if they are hazardous. He/she may ask to review
                       the test results.

If your facility generates hazardous waste, what is your generator category?

       Determining your generator category. Your facility's hazardous waste generator category is
       determined by the amount of hazardous waste that it generates each month (40 CFR 261).
       There are three federal categories of hazardous waste generators:

              Conditionally exempt small quantity generator (CESQG)  CESQGs generate
              <220 pounds (100 kg) of hazardous waste per month or <220 pounds of spill cleanup
              debris containing hazardous waste per month. CESQGs have no maximum on-site time
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              limits for storage, but cannot accumulate more than 2,200 Ibs. (1,000 kg) of
              hazardous waste onsite.  If a CESQG accumulates more than this amount, it becomes
              an SQG or LQG.

              Small quantity generator (SQG). SQGs generate >220 pounds (100 kg) and
              <2,200 pounds (1,000 kg) of hazardous waste per month or >220 pounds and
              <2,200 pounds of spill cleanup debris containing hazardous waste per month. SQGs
              may accumulate no more than 6,000 kg of hazardous waste in storage,  which may be
              stored on site for no more than 180 days (or no more than 270 days if the
              treatment/disposal facility is more than 200 miles away).  If an SQG accumulates more
              than the specified amount, it becomes an LQG.

              Large quantity generator (LQG). LQGs generate >2,200 pounds (1,000 kg) of
              hazardous waste per month or > 2,200 pounds of spill cleanup debris containing
              hazardous waste per month. LQGs may accumulate any amount of hazardous waste for
              no more than 90 days.
        Note: Facilities that generate 2.2 pounds or less of acutely hazardous wastes per month
        are classified as CESQGs, whereas facilities that generate more than 2.2 pounds of
        acutely hazardous wastes per month are classified as LQGs.
       Adding waste quantities. To determine which category applies to your facility, your facility
       must count all quantities of listed and characteristic hazardous wastes. These include wastes
       that are: (1) generated and collected at your facility prior to treatment or disposal; and (2)
       packaged and transported offsite.
       Many hazardous wastes are liquids
       and are measured in gallons, not
       pounds. To approximate the number
       of pounds of liquid your facility has,
       (because a gallon of water weighs 8.3
       pounds and many liquids have a
       density similar to water).
             Rough Guide
27 gallons (about half of a 55-gallon drum) of
waste with a density similar to water weighs
about 220 pounds (100 kg).
       multiply the number of gallons by 8.3        _„   „     ,        ...    .   ..   .  .,   .
           r J             °       J         -  270 gallons of waste with a density similar to
water weighs about 2,200 Ibs (1,000 kg).
       When adding up all the hazardous wastes generated, keep in mind that your facility does NOT
       have to count the following:
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              Wastes that are left on the bottom of containers that have been emptied by conventional
              means (i.e., pouring or pumping) and where no more than 2.5 cm (1 inch) of residue
              remains in the bottom of the container or no more than 3 percent by weight of the total
              capacity of the container remains in the container if the container is less than or equal to
              110 gallons in size.

       •      Residues in the bottom of storage tanks, if the residue is not removed (i.e., residues left
              in the bottom of the storage container are not counted as long as they are not removed
              when the tank is refilled).

       •      Wastes that are reclaimed continuously on site without storing the waste prior to
              reclamation.

              Wastes that have already counted once during the calendar month, and treated onsite
              or reclaimed in  some manner and used again.

       •      Wastes that are directly discharged to a municipal treatment plant or POTW without
              being stored or  accumulated first.

       •      Waste oil that meets the criteria for used oil and is to be managed and handled as used
              oil[40CFR279].

              Scrap metal that is recycled [40 CFR 261.6(a)(3)].

If your facility  is a CESQG, does  it meet all applicable requirements?

       As a CESQG, your facility's requirements are quite simple. There are three basic hazardous
       waste management requirements that apply to CESQGs:

       •      Identify all hazardous and acutely hazardous wastes [40 CFR 262.11]. For help in
              identifying hazardous wastes, call EPA or your state regulatory agency; a consultant; a
              licensed transporter; or the RCRA/UST, Superfund and EPCRA hotline at 703-412-
              9810 or 1-800-424-9346.

                              An inspector may review your facility's waste
                              determinations and any analytical data.

              Do not generate more than 220 Ibs. (or 100 kg) per month of hazardous waste or more
              than 2.2 Ibs. (1  kg) per month of acutely hazardous waste (this includes any wastes
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              your facility has shipped off site for disposal during that month); and never store more
              than 2,200 Ibs. (1,000 kg) of hazardous waste or 2.2 Ibs. of acutely hazardous waste
              for any period of time [40 CFR 261 and 262].

                               An inspector may evaluate the total volume of waste on site
                               at the time of the inspection and verify that it is within the
                               limits for your facility's generator category.

              Ensure proper disposal of your hazardous waste.  For CESQGs, proper treatment and
              disposal of hazardous wastes are fairly simple. It involves ensuring that the waste is
              shipped to one of the following facilities:

              -      A state or federally regulated hazardous waste management treatment, storage,
                     or disposal facility (if your facility's waste is hazardous).

              -      A facility permitted, licensed, or registered by a state to manage municipal or
                     industrial solid waste.

                     A facility that uses, reuses or legitimately recycles the waste (or treats the waste
                     prior to use, reuse, or recycling).

              Self-transporting hazardous waste.  CESQGs are allowed to transport their own
              wastes to the treatment or storage facility, unlike SQGs and LQGs which are required
              to use a licensed, certified transporter. While there are no specific RCRA requirements
              for CESQGs who transport their own wastes, Department of Transportation (DOT)
              requires all  transporters of hazardous waste to comply with all applicable DOT
              regulations. Specifically, DOT regulations require all transporters, including CESQGs,
              transporting hazardous waste that qualifies as DOT hazardous material to comply with
              EPA hazardous waste transporter requirements see 40 CFR 263.
              As a CESQG, your facility is
              not required by federal laws to
              train its employees on hazardous
              waste handling or emergency
              preparedness, however, it is
              strongly advised.
Keep in mind that employees responding to
releases of hazardous substances and
hazardous waste are required to be trained under
OSHA's Hazardous Waste Operations and
Emergency Response (HAZWOPER)
requirements see 29 CFR 1910.120.
       Your facility must comply with the above requirements to retain its CESQG status, and remain
       exempt from the more stringent hazardous waste regulations that apply to SQGs and LQGs.
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       Though not required, it is recommended that your facility follow the waste storage and handling
       requirements for SQGs to minimize the possibility of any leaks, spills, or other releases that
       potentially could cause economic hardship to your facility.  States may have more stringent
       and/or different requirements, so contact your state hazardous waste agency for these
       requirements.

If your facility is an SQG or LQG, does it meet all applicable requirements?

       If your facility determines, based on the amount of waste generated, that it is an SQG or LQG,
       it must comply with a variety of requirements covering the storage and handling, treatment, and
       disposal of the hazardous waste, from generation to final disposal.  These requirements include:

       •      Waste identification. As a generator, your facility must determine whether wastes are
              hazardous using the hazardous waste identification process [40 CFR 261]. For
              assistance, call EPA or your state regulatory agency; a consultant; a licensed
              transporter;  or the RCRA/UST, Superfund and EPCRA hotline at 703-412-9810 or
              1-800-424-9346.

                             An inspector may review your facility's waste determinations
                             and any analytical data.

              EPA identification number. An EPA hazardous waste generator identification
              number must be entered on all hazardous waste manifests [40 CFR 262.12]. For
              assistance in obtaining a hazardous waste generator identification number (EPA form
              8700-12 "Notification of Hazardous Waste Activity"), your facility may  contact EPA
              or the state regulatory agency.

              Accumulation and storage limits. Onsite accumulation (storage) limits are based on
              the total weight of hazardous waste that can be accumulated at any time  at your facility
              before it must be shipped offsite [40 CFR 262.34].

                              An inspector may evaluate the total volume of waste on site
                              at the time of the inspection and verify that it is within the
                              limits for your facility's generator category (e.g., SQG or
                              LQG).

              Container management. Your facility can store hazardous waste in 55-gallon drums,
              tanks, or other suitable containers, and it must comply with rules intended to protect
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             human health and the environment and reduce the likelihood of damages or injuries
             caused by leaks or spills [40 CFR 265].
                             An inspector may look at all hazardous waste on site noting
                             the size and type of containers, their condition, and whether
                             they are closed and protected from the weather. He/she may
                             check the labels on the containers for the words "hazardous
                             waste," and verify that the dates information is complete on
                             the label.  The  inspector may also check the containment for
                             cracks or leaks.
                                                    Keep in mind that employees
                                                    responding to releases of hazardous
                                                    substances and hazardous waste are
                                                    required to be trained under OSHA's
                                                    Hazardous Waste Operations and
                                                    Emergency Response (HAZWOPER)
                                                    requirements see 29 CFR 1910.120, in
                                                    addition to EPA's hazardous waste
                                                    management training.
Personnel training. Proper waste
handling can save your facility money in
waste treatment and disposal and in lost
time due to employee illness or accidents.
Your facility must train its employees on
the procedures for properly handling
hazardous waste, as well as on
emergency procedures [40 CFR
262.34(a)]. For LQGs, the training must
be formalized and be completed by
employees within six months of accepting a job involving the handling of hazardous
waste, and your facility is required to provide annual review of the initial training.
                             An inspector may check personnel records, including job
                             titles, to determine when hazardous waste duties were
                             assigned and if proper training was provided by your
                             facility.
             Contingency planning, emergency procedures, and accident prevention If an
             LQG, your facility is required to have a written contingency plan. If an SQG, your
             facility must have basic contingency procedures in place. Although a written
             contingency plan is not federally required for SQGs or CESQGs, it is strongly
             recommended. It is also important to check with your state and local authorities for any
             additional contingency plan or emergency preparedness requirements [40 CFR 262].
                             An inspector may review your facility's contingency plan or
                             basic contingency procedures, and ask about any incidents
                             requiring implementation of the plan or procedures.
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              Hazardous waste shipment labeling and placarding When your facility prepares
              hazardous wastes for shipment, it must put the wastes in properly labeled containers
              that are appropriate for transportation according to the DOT regulations (40 CFR
              262).

              Reporting and recordkeeping requirements Your facility is required to meet
              various reporting and recordkeeping requirements as part of your hazardous waste
              management activities. Reports include the following:

              S      Manifest form. The Uniform Hazardous Waste Manifest Form (EPA Form
                     8700-22) is a multi-copy shipping document that reports the contents of your
                     shipment, the transport company used, and the treatment/disposal facility
                     receiving the wastes (40 CFR 262.20). Your facility (i.e., the hazardous waste
                     generator), the transporter, and the treatment/disposal facility must each sign
                     this document and keep a copy. Your facility must keep the copy of the
                     manifest signed by all three parties on file for three years.

              S      Exception report. Exception reports document a missing return copy of the
                     hazardous waste manifest. Your facility must maintain copies of exception
                     reports for three years.

              S      Biennial report. If an LQG, your facility must submit a biennial report (EPA
                     8700-13 A) on March 1 of each even-numbered year to the appropriate EPA
                     or state regulatory agency (40 CFR 262.41). Some states impose this
                     requirement on SQGs. Your facility can obtain biennial report applications and
                     instructions from EPA or its state regulatory agency.

              S      Land disposal restriction notification. Land disposal restrictions (LDRs)
                     are regulations prohibiting the disposal of hazardous waste on land without prior
                     treatment of the waste (40 CFR 268).  Your facility is required to provide a
                     one-time notification about your wastes to the treatment or disposal facility
                     with the first shipment of waste offsite, and keep a copy in your files.

              In addition to these reports, your facility is required by EPA to keep certain records on
              file to show that good housekeeping practices and monitoring are being performed.
              EPA requires that records be kept on file at your facility for three years (40 CFR
              262.40). These records include:
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              S      Laboratory analyses and waste profile sheets for determining whether wastes
                     generated by your facility are hazardous.

              S      Copies of all hazardous waste manifests, land disposal restriction notification,
                     and exception reports.

              S      Copies of all Notification of Hazardous Activity forms submitted to and
                     received from the state or EPA.

              S      For LQGs only, copies of: (1) all personnel training plans and documentation
                     that indicate employees have completed the required training; (2) the facility's
                     contingency plan; and (3) the facility's biennial report.

                             An inspector will most likely review all records, including but
                             not limited to annual or biennial reports and manifests.

4.6   OIL SPILL PREVENTION, RESPONSE, AND RECOVERY

       Some of the most important activities during ship scrapping are: (1) preventing oil discharges,
       (2) being prepared to respond to spills, and (3) knowing how to respond to spills and recover
       spilled materials. EPA issued the Oil Pollution Prevention regulation (40 CFR 112) to prevent
       oil spills from reaching navigable waters of the United States or adjoining shorelines and to
       prepare facility personnel in responding to oil spills.  The regulation has two sets of
       requirements — the Spill Prevention Control and Countermeasures (SPCC) plan rule (an oil
       spill prevention program) and the Facility Response Plan (FRP) rule (an oil spill response
       program). Your facility may be subject to this regulation if it, among other things, produces,
       gathers, stores, transfers, or consumes oil.
4.6.1  Spill  Prevention  Planning

Qoes your facility have an SPCC plan?

       The intent of an SPCC plan is to prevent the discharge of oil from non-transportation-related
       fixed facilities (40 CFR 112). Your facility may be required to prepare and implement an
       SPCC plan if:
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              Due to its location, it could reasonably be expected to discharge oil into or upon the
              navigable waters of the United Stated or adjoining shorelines, AND

              It meets one of the following criteria regarding oil storage:
                     An aboveground storage capacity of
                     more than 660 gallons in a single
                     container.
                     A total aboveground storage capacity
                     of more than 1,320 gallons.
                     A total underground storage capacity
                     of more than 42,000 gallons.
Storage Capacity: Remember,
the requirements apply specifically
to your storage capacity.
regardless of whether the tanks
are completely filled.
       If subject to the SPCC requirements based on the above description, your facility is required to
       prepare an SPCC plan and follow the other provisions of the SPCC rule 40 CFR 112.3
       through 112.7.
         Tip: A sample SSPCC plan can be viewed at
         http://www.epa.gov/oilspill/sspcc/sampln.pdf.
Qoes the SPCC plan include all the required  information?
       Your facility's SPCC plan must be unique to your facility, but also must have certain elements
       common to all plans (40 CFR 112.7). Specifically, the SPCC plan must:

              Be certified by a registered professional engineer (PE)
              Be kept on site
       •      Have full management approval
              Conform with all SPCC requirements in 40 CFR 112.7
              Discuss  spill history
              Discuss  spill prediction
       •      Be reviewed every three years
       •      Be amended when a change is made at the facility  and recertified by a PE
              Include secondary containment or contingency plans
              Specify spill reporting
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                         An inspector may review the facility's SPCC plan to ensure that it
                         is certified by a registered professional engineer and that it is up-
                         to-date.

4.6.2 Spill Response Planning

       If subject to the SPCC requirements, your facility is required to conduct an initial screening to
       determine whether it is also required to develop a facility response plan (FRP). Under the FRP
       requirements, owners and operators of facilities that could cause "substantial harm" to the
       environment by discharging oil into navigable water bodies or adjoining shorelines must prepare
       FRPs for responding, to the maximum extent practicable, to the worst case discharge and to a
       substantial threat of such a discharge of oil [40 CFR 112.20 and 112.21, including Appendices
       A through F]. Facilities subject to the FRP requirements are referred to either as substantial
       harm facilities or significant and substantial harm facilities

       Substantial Harm Facilities

       If your facility is determined to be a substantial harm facility, it must prepare an FRP which is
       submitted to EPA for review. Your facility may be identified as posing a risk of substantial
       harm by one of two ways:

       •      Either through a self-determination process (EPA has established criteria located in 40
              CFR 112.20 to assist facilities in making the determination - see below),

       •      Or by a determination of the EPA Regional Administrator (RA).

       Self-Determination. Your facility has the potential to cause substantial harm if:

       •      Either the facility transfers oil over water to or from vessels and has a total  oil storage
              capacity, including both ASTs and USTs, greater than or equal to 42,000 gallons;

       •      Or the facility's total oil storage capacity, including both ASTs and USTs, is greater
              than or equal to one million gallons and one of the following is true:

              S      The facility does not have secondary containment for each aboveground
                     storage area sufficient to contain the capacity of the largest AST within each
                     storage area plus freeboard to allow for precipitation;
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               S      The facility is located at a distance such that a discharge could cause injury to
                      fish and wildlife and sensitive environments;

               S      The facility is located at a distance such that a discharge would shut down a
                      public drinking water intake; or

               S      The facility has had a reportable spill greater than or equal to  10,000 gallons
                      within the last five years [40 CFR 112.20 (f)(l)].

       EPA Determination. If a self-determination is not made, EPA's RA may determine whether
       your facility may cause substantial harm.  EPA's RA may consider factors similar to the self-
       selection criteria, as well as other factors, including the type of transfer operations at a facility,
       the facility's oil storage capacity, lack of secondary containment, proximity to environmentally
       sensitive areas or drinking water intakes, and/or the facility's spill history.  The EPA RA will
       notify your facility if EPA has determined that your facility poses a threat of substantial harm.

       Significant and Substantial Harm Facilities

       EPA is also required to identify a subset of substantial harm facilities that could cause
       significant and substantial harm to the environment upon a release of oil.   In addition to the
       criteria used to determine substantial harm, EPA bases its determination of significant and
       substantial harm on other factors such as the age of tanks, proximity to navigable water, and
       spill frequency. Facilities are notified by EPA in writing of their status as posing significant and
       substantial harm. If your facility is notified by EPA,  it must submit an FRP to EPA for review
       and approval. The RA will review the FRP and may inspect your facility for viability and
       compliance with the regulations before EPA approves the plan.

       If Your Facility  Does Not Meet the Criteria

       If your facility does not meet the "substantial harm" criteria, it does not have to prepare and
       submit an FRP. However, your facility must document this determination by completing the
       "Certification of the Applicability of the Substantial Harm Criteria Checklist," provided as 40
       CFR  112, Appendix C, Attachment C-H [40 CFR 112.20(e)]. This certification should be
       maintained with the facility's SPCC plan.
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Qoes your facility have a facility response plan (FRP)?

       If it has been determined, either through the self-selection process or by notification from the
       EPA RA, that your facility poses a threat of "substantial harm" to the environment, your facility
       must prepare and submit an FRP to the appropriate EPA regional office. FRPs must:
       •      Be consistent with the
              National Contingency
              Plan (NCP) and the
              Area Contingency Plans.
The NCP, also called the National Oil and Hazardous
Substances Pollution Contingency Plan, is the federal
plan for responding to both oil spills and hazardous
substance releases. See http://www.epa.gov/oilspill/ncp
for more information.
       •      Identify a qualified
              individual having full
              authority to implement removal actions, and require immediate communication between
              that person and the appropriate federal authorities and responders.

       •      Identify and ensure availability of resources to remove, to the maximum extent
              practicable, a worst-case discharge.

       •      Describe training, testing, unannounced drills, and response actions of persons at the
              facility.

       •      Be updated periodically.

       •      Be submitted for approval with each significant change.

       To assist your facility in preparing an FRP, EPA has prepared and included a "model facility
       response plan" see 40 CFR 112.2, Appendix F. The following is a list of key FRP elements:

       •      Emergency response action plan. This should be maintained as an easily accessible,
              stand-alone section of the overall plan.

       •      Facility name, type, location, owner, and operator information.

              Emergency notification, equipment, personnel, and evacuation information.

       •      Identification and evaluation of potential spill hazards and previous spills.
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              Identification of small, medium, and worst case discharge scenarios and response
              actions.

              Description of discharge detection procedures and equipment.

              Detailed implementation plan for containment and disposal.

              Facility and response self-inspection; training; exercises; and drills; and meeting logs.



              Diagrams of facility and surrounding layout, topography, and evacuation paths.

              Security measures including fences, lighting alarms, guards, emergency cutoff valves,
              and locks.

                        An inspector may evaluate FRP measures for their ability to
                        facilitate adequate response to a worst-case discharge of oil.

lAlas an existing  response plan  used or modified?


       EPA recognizes that many facilities may
       have existing response plans prepared to
           ,  ,,       •         ^r    r- -I-.          recognizes that many facilities have
       meet other requirements. Your facility         , *  .   . oori~~  ,      n,t.    .
                   n                    J         established SSPCC plans.  Although response
       does not need to prepare a separate FRP
       provided that your facility's original
       response plan:

       •       Satisfies the appropriate
               requirements and is equally as
               stringent;
Avoid Recreating the Wheel: EPA also
plans and prevention plans are different, and
should be maintained separately, some
sections of the plans may be the same. Under
OPA regulations, your facility is allowed to
reproduce or use those sections of the SSPCC
plan in your FRP.
       •      Includes all elements described in the model plan;
       •      Is cross-referenced appropriately; and
              Contains an action plan for use during a discharge.

lAlas the FRP prepared and submitted by the deadline?1
              The initial statutory deadline for "substantial harm facilities" either to submit FRPS or to stop handling,
              storing or transporting oil was February 18, 1993. EPA's regulatory deadline for "substantial harm facilities"
              and "significant and substantial harm facilities" to submit FRPs or stop handling, storing or transporting oil
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       The time that your facility has to prepare and submit a FRP will vary depending on several
       factors, including the following:

       •      Notification from EPA Regional Administrator:  If EPA notifies your facility that it
              is required to submit an FRP, then your facility must prepare and submit a plan within
              six (6) months.


              Newly Constructed Facilities: If your facility is newly constructed, it is required to
              submit the FRP prior to the start of operations. After sixty (60) days, your facility must
              make adjustments to the FRP to reflect changes that occur during the startup phase and
              resubmit the FRP.


              Planned Facility Changes: If your facility undergoes a planned change in design,
              construction, operation, or maintenance that places it in the designation of a substantial
              harm facility, then it must submit an FRP prior to the start of operations of the portion of
              the facility undergoing the changes.


              Unplanned Facility Changes: If your facility falls under the substantial harm facility
              designation because of an unplanned event or change in characteristics, then it must
              submit an FRP within six (6) months of
              the unplanned event.


Is the FRP maintained and updated?

       Your facility must periodically review your FRP
       to ensure consistency with the National Oil and
       Hazardous Substances Pollution Contingency
       Plan (NCP) and Area Contingency Plans
       (ACPs), and update it as appropriate [40 CFR
       112.20(g)]. Consequently, if your facility is
       required to prepare a FRP, it must review
       relevant portions of the NCP and the applicable
       ACPs annually and update its FRP as
          Area Contingency Plans (ACPs)
          include detailed information about
          resources (e.g., equipment and trained
          response personnel) available from the
          government agencies in the area.  They
          also describe the roles and
          responsibilities of each responding
          agency during a spill incident. Your
          facility can order copies of ACPs from
          the National Technical Information
          Service (NTIS)  by calling 1-800-553-
          6847. To obtain the NTIS ordering
          number for your area's ACP, first call
          the RCRA/UST, Superfund and EPCRA
          Hotline at 1-800-424-9346 or 703-412-
          9810.
              was August 30, 1994, the effective date of the FRP rule.
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       appropriate. Your facility must submit revised portions of the FRP within 60 days of each
       facility change that may materially affect (1) the response to a worst case discharge or (2) the
       implementation of the response plan.

 A re appropriate FRP records maintained?

       FRP requirements not applicable: If your facility determines that the response planning
       requirements  do not apply, then it must certify and maintain a record of this determination using
       40 CFR 112, Appendix C, Attachment C-II.

       FRP requirements applicable: If your facility is subject to the response planning
       requirements, it is required to maintain the FRP at the facility. Your facility is also required to
       maintain updates to the plan to reflect material changes to the facility and to log activities such
       as discharge prevention meetings, response training drills, and exercises. Your facility must
       keep the records of these activities for a period of five years.

 A re training and response drill requirements met?

       All facilities (i.e., "substantial harm" and "significant and substantial harm" facilities) subject to
       facility response planning requirements must address training and response drills (40 CFR
       112.21). FRPs  must include (1) information about self-inspection drills, exercises, and
       response training, including descriptions and logs of training and drill or exercise program; and
       (2) documentation of tank inspections, equipment inspections, response training meetings,
       response training sessions, and drills and exercises [40 CFR 112.20(h)(8)].  Consequently,
       FRPs may be revised based on evaluations  of the drills and exercises.

       Oil spill response training is an important element in EPA's oil spill prevention and preparedness
       efforts.  Because operator error is often the cause of an oil spill, training and briefings are
       critical for prevention of a spill as well  as response to a spill.  Training encourages up-to-date
       planning for the control of, and response
       to, an oil spill and also helps to sharpen
       operating and response skills, introduces
       the latest ideas and techniques, and
       promotes interaction with the emergency           '  T..O^^    .    ....   .
       F                              °   J             TASC Department Warehouse
                                                         3341Q 75th Avenue
                                                         Landover, MD 20785
                                                         FAX: (301) 386-5394
       ^r   Ł•  T*. -i      •   j ^  j   i          When requesting copies, please indicate the
       Your facility is also required to develop       .        .      ,.    .   ...  ..       .   ,.
                 J         n             r       document name(s)  and publication number(s).
       and implement a program of response
response organization and familiarity with
the facility's SPCC and FRP plans.
                                           PREP: The PREP guidelines booklet (USCG-
                                           X0191) and the Training Reference for Oil Spill
                                           Response (USCG-X0188) are available by mail
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                                                        Defining discharge. "Discharge"
                                                        means any spilling, leaking, pumping,
                                                        pouring, emitting, emptying or dumping
                                                        [CWA Section 311(a)(2)].
       drills and exercises, including evaluation procedures to test the effectiveness of your response
       plan.  A program that follows the National Preparedness for Response Exercise Program
       (PREP) will meet EPA's exercise requirements.  An alternative program can also be acceptable
       if approved by the EPA RA.

4.6.3 Spill Notification and Recovery

       Though not common, your ship scrapping facility may experience accidental discharges of bilge
       or ballast water, oil-water separator effluent, or oily sludge to U.S. waters or land while
       performing daily activities.
A re oil spills reported as required?

       Though not common, your ship scrapping facility
       may experience accidental discharges of oil to
       U.S. waters or land while performing daily
       activities. Your facility is required to report
       discharges of oil to navigable waters or adjoining
       shorelines in quantities that may be harmful to
       public health or welfare or the environment (40 CFR 110).  EPA has determined that
       discharges of oil in quantities that may be harmful include those that:

       •      Violate applicable water quality standards;

       •      Cause a film or "sheen" upon, or discoloration of, the surface of the water or adjoining
             shorelines; or

       •      Cause a sludge or emulsion to be deposited beneath the surface of the water or upon
             adjoining shorelines.

       If there is such a discharge from a ship or the onshore facility that may reach waters or
       adjoining shorelines or land areas that may threaten waterways, your facility owner or operator
       must:

       (1)    Call the National Response Center at 1-800-424-8802 or 703-412-9810
             (Washington, D.C. area);
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       (2)    Contact the nearest U.S. Coast Guard (USCG) or EPA regional office spill line;
              and

       (3)    Report the spill to the state regulatory agency where the spill occurred. Note:
              States and local government may have specific spill reporting requirements for facilities.
              For example, a facility may be required to report all spills meeting certain quantity
              thresholds, even if the spill does not leave a contained area within the facility. Check
              with your state and local regulatory agencies for their specific spill reporting
              requirements.

       In addition, the owner or operator of your facility must submit, in writing, certain information
       (including the SPCC Plan) to the EPA Regional Administrator within 60 days, if the release
       meets either of the following conditions: (1) either a single discharge of more than 1,000
       gallons of oil; or (2) two reportable spills/discharges of oil in harmful quantities, during any 12-
       month period, into or upon navigable waters, shorelines, etc.

       If your facility has an NPDES permit and the discharge causes your facility to be out of
       compliance with the permit requirements, then your facility must report the occurrence to your
       permitting agency within 24  hours of becoming aware of a violation, and provide a written
       submission within 5 days.

Is all required information provided to the National Response Center?

       When your facility contacts  the National Response Center (NRC),
       the center staff person will ask for the following information:

       •      Your name, location, organization, and telephone number.
       •      Name and address of the party responsible for the incident.
       •      Location, date and time of the incident.
       •      Source and cause of the release or spill.
       •      Type and quantity of material(s) released or spilled.
       •      Danger or threat posed by the release or spill.
       •      Number and types of injuries.
       •      Weather conditions at the incident location.
       •      Any other information that may help emergency personnel respond to the incident.

       The NRC records and maintains all spill reports in a computer database called the Emergency
       Response Notification System (ERNS), which is available to the public
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       (http://www.epa.gov/ERNS). The NRC relays the spill information to the EPA and USCG,
       depending on the location of the incident. Specifically, the NRC notifies representatives of
       EPA or the USCG, known as On-Scene Coordinators (OSCs).  The OSC is the federal
       official charged with directing a spill response through the Unified Command/Integrated
       Command System adopted by EPA and USCG. This intergovernmental coordinating system
       encourages, wherever possible, shared decision making by the federal lead response agency
       (EPA or USCG), the state(s) and the party responsible for the discharge/release.

Is the facility prepared for an effective response to an oil spill?

       The first and most immediate response to an oil spill is by your facility personnel. For this
       reason, facility response personnel must know the location, capabilities, and operating
       instructions of response equipment to attempt an effective oil recovery. For more information,
       visit EPA's Oil Program at http://www.epa.gov/oilspill/.

               SPCC/FRP regulated facilities (or substantial harm facilities): Within the SPCC-
               regulated community, facilities that may cause substantial harm to the environment or
               exclusive economic zone, based on the quantity and location of their oil storage, must
               prepare facility  response plans (FRPs) to ensure that these facilities have the capability
               to response to worst case scenario discharges (40 CFR 112.20-21).  FRPs greatly
               assist the facility and response agencies to expedite and coordinate cleanup efforts (see
               Section 4.6.2).

       •       Other SPCC-regulated facilities: It is recommended that all other facilities in the
               SPCC-regulated community be prepared to respond to a spill by identifying control and
               response measures in their SPCC plans. Every facility should have appropriate spill
               response equipment available  and easily accessible. A spill kit, which should be keep
               close at hand, should contain  absorbent pads and booms, disposal containers or bags,
               shovels, an emergency response guidebook, a fire extinguisher, and a portable pump.
               It is also recommended that facilities coordinate with local responders, other nearby
               facilities, and contractors before a spill occurs to ensure an efficient and effective
               response. Facility personnel, including seasonal employees, must participate in spill
               response, notification, and oil  recovery training courses. Being prepared to respond
               reduces the impact of a discharge on human health or the environment and minimizes
               cleanup costs and fines resulting from improper notification.

       •       First response: In the event of an oil spill, the response plan is immediately activated.
               The OSC will activate local, area, regional, or national plans depending on the nature of
               the spill and the response capability of the facility.
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               On-scene coordinators: The designated OSC from EPA or USCG is responsible for
               determining how to respond to the spill, i.e., determining the resources, both personnel
               and equipment needed.  The OSC does this based on his/her assessment of several
               factors, including the following: the magnitude and complexity of the spill; the availability
               of appropriate response equipment and trained personnel; and the ability of the
               responsible party, or local and/or state responders to respond to the spill.

               Although the OSC is responsible for coordinating federal efforts with local, state and
               regional response efforts, in practice the role of the OSC varies. Depending on the
               OSC's assessment, he/she may do the following: direct the response; direct the
               response in cooperation with  other parties; oversee that the response is conducted by
               other parties; provide limited or periodic oversight; or determine that a federal response
               is not needed.

               For example, small spills may be cleaned up by the facility (or responsible party) or by
               local  response agencies, while larger spills may require regional response efforts.  In
               either cases, the OSC is required to oversee and monitor the spill response to make
               sure that all appropriate actions to prevent threats to human health or the environmental
               are taken. If, however, a facility is handling a smaller spill adequately, the OSC may
               not go to the site.

               Oil recovery: For federal-led cleanups, the OSC, response teams, and a network of
               experienced agencies will decide on the most effective method of cleanup (see below).
               For potentially responsible party (PRP)-led cleanups, cleanup efforts are carefully and
               efficiently coordinated to protect response personnel, recreational areas, drinking water
               reservoirs, and wildlife from the  potentially catastrophic effects of an oil spill.
lAlhat oil  recovery methods are used at the facility?
       There are a number of advanced response methods available for controlling oil spills and
       recovering oil while minimizing their impacts on human health and the environment (see
       http://www.epa.gov/oilspill/oiltech.htm). The key to effectively combating spills is careful
       selection and proper use of equipment and materials best suited to the type of oil and the
       conditions at the spill site. Most spill response equipment and materials are greatly affected by
       such factors as conditions at sea, water currents, and wind.

       Some kinds of response methods include:
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              Mechanical containment or recovery is the primary line of defense against oil spills
              in the United States. Containment and recovery equipment include a variety of booms,
              barriers, and skimmers, as well as natural and synthetic sorbent materials.  Mechanical
              containment is used to capture and store the spilled oil until it can be disposed of
              properly.

              Chemical and biological methods can be used in conjunction with mechanical means
              for containing and cleaning up oil spills.  Dispersants and gelling agents are most useful in
              helping to keep oil from reaching shorelines and other sensitive habitats. Biological
              agents have the potential to assist recovery in sensitive areas such as shorelines,
              marshes, and wetlands. Research into these technologies continues to improve oil spill
              cleanup.

              Natural processes such as evaporation, oxidation, and biodegradation can start the
              cleanup process, but are generally too slow to provide adequate environmental
              recovery.

              Physical methods, such as wiping with sorbent materials, pressure washing, and
              raking and bulldozing, can be used to assist the natural processes.  Scare tactics are
              used to protect birds and animals by keeping them away from oil spill areas. Devices
              such as propane scare-cans, floating  dummies, and helium-filled balloons are often
              used, particularly to keep away birds.
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                      5. OIL AND FUEL REMOVAL

       Some ships sold for scrapping contain diesel fuel, fuel oil, natural and synthetic oils used as
       lubricants, and hydraulic oils. This section provides information about the various regulations
       that apply to the management of oil and fuel during the ship scrapping process.

5.1  INFORMATION ABOUT OIL AND FUEL

       This section provides background information on oil and fuel, including what they are, where
       they can be found on a ship, and the dangers of exposure to human health and the environment.
W
hat are oil and fuel?

   The term oil is interpreted by EPA to include crude oil; petroleum and petroleum-refined
   products (e.g., diesel fuel, gasoline, kerosene); and non-petroleum oils such as synthetic oils
   (e.g., silicone fluids), tung oils, and wood-derivative oils (e.g., resin/rosin oils), animal fats and
   oil, and edible and inedible seed oils from plants. The definition of oil under the Clean Water
   Act is "oil of any kind or in any form including, but not limited to, petroleum, fuel oil,
   sludge, oil refuse, and oil mixed with wastes other than dredged spoil" [CWA Section
       The most common refined petroleum products and their characteristics are as follows:

       •      Gasoline is a lightweight substance that flows easily, spreads quickly, and evaporates
              readily under temperate conditions. It is highly volatile and flammable, posing a risk of
              fire and explosion. Gasoline is more toxic than crude oil because of the high
              concentration of aromatics.

       •      Kerosene is a lightweight substance that flows easily, spreads rapidly, and evaporates
              quickly.  Although it disperses easily, kerosene persists in the environment.

       •      No. 2 Fuel Oil is a lightweight substance that flows easily, spreads rapidly, and
              disperses easily. It is neither volatile nor likely to form emulsions.

              No. 4 Fuel Oil is a medium weight substance that flows easily and is readily dispersed
              if treated promptly. It has a low volatility and moderate flash point.
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       •      No. 5 Fuel Oil (Bunker B) is a medium to heavyweight substance with a low volatility
              and moderate flash point.  Preheating may be required in cold climate. Dispersion is
              very difficult and potentially impossible.

              No. 6 Fuel Oil (Bunker  C) is a difficult to pump, heavyweight substance that requires
              preheating for use.  No. 6  Fuel Oil may be heavier than water. It is not likely to
              dissolve, and is likely to form tar balls, lumps, or emulsions.  No. 6 Fuel Oil is difficult
              or impossible to disperse.  It has a low volatility and moderate flash point and persists in
              the environment.

       •      Lubricating Oil is a medium weight substance that flows easily and disperses easily if
              treated promptly. It has a low volatility and moderate flash point and persists in the
              environment.

1AI here are oils and fuels found on a ship?

       Diesel fuel and fuel oil may be contained in various tanks throughout a ship, lubricating oil in
       engine sumps, drums of unused lubricating oil in ship storerooms or engineering spaces, and
       sludge in fuel and cargo tanks.  Oil, fuel, and sludge may also be found in the ship's machinery
       and piping system.

       Oil found on a ship may be defined by EPA as "used oil." Basically, EPA defines used oil as
       follows: Used oil is any oil that has been refined from crude oil or any synthetic oil that has been
       used and as a result of such use is  contaminated by physical or chemical impurities. Examples
       of used oil found on a ship may include spent lubricating fluids which have been removed from
       engine crankcases, transmissions,  and gearboxes; industrial oils such as compressor,  turbine,
       and bearing oil; metal working oil; and refrigeration oil. Note: Additional used oil may be
       generated from vehicles and machinery used at the ship scrapping facility.

The potential dangers to workers during oil and fuel removal activities

       The primary danger to workers due to the presence of oil and fuel on ships is that of fire.
       Beyond fire, the potential dangers to workers of handling oil and fuel decrease.  While some
       crude oils and high-end products are highly toxic and present hazards to workers, the types of
       oils and products (e.g., fuel  oil, hydraulic oil, lubricating oil) found on ships currently  provided
       for scrapping do not have toxic hazards above certain threshold limits, and therefore do not
       impose serious health threats to workers.
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       Be aware that exposure to oils or fuels that have certain toxic hazards, exposure can cause
       damage to the liver, lungs, kidneys, heart, and the nervous system. Exposure pathways include
       dermal contact, consumption through bioaccumulation in marine life, consumption through
       contaminated soil, inhalation of fumes or particles (particularly in confined spaces), and
       consumption of contaminated water.
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lAlhat are the environmental  impacts of oil spills?
       The severity of an oil spill's impact depends on a variety of factors, including the physical
       properties of the oil, whether oils are petroleum-based or non petroleum-based, and the natural
       actions of the receiving waters on the oil.  Each type of oil has distinct physical properties that
       affect the way it spreads and breaks down, the hazard it may pose to marine (and human life),
       and the likelihood that it will pose a threat to natural and manmade resources. The rate at which
       an oil spill spreads will determine its effect on the environment.  Most oils tend to spread
       horizontally into a smooth and slippery surface, called a "slick," on top of the water.

       Petroleum-based oils and non-petroleum oils can have both immediate and long-term adverse
       effects on the environment and can be dangerous or even deadly to wildlife. Light refined
       petroleum products, such as gasoline and kerosene, spread on water surfaces and penetrate
       porous soils quickly. Fire and toxic hazards are high, but the products evaporate quickly and
       leave little residue. Alternatively, heavier refined oil products may pose a lesser fire and toxic
       hazard and do not spread on water as readily. Heavier oils are more persistent, however, and
       may present a greater cleanup challenge. Many non-petroleum oils have similar physical
       properties as petroleum-based oils; for example, their solubility in water is limited, they both
       create  slicks on the surface of water, and they both form emulsions and sludges. In addition,
       non-petroleum oils tend to be persistent, remaining in the environment for long periods of time.

       Oil spills can harm the environment in several ways, including the physical damages that directly
       impact wildlife and their habitats, and the toxicity of the oil itself, which can poison exposed
       organisms. Spilled oil immediately begins to move and weather, breaking down and changing
       its physical and chemical properties. As these processes occur, the  oil threatens natural
       resources, birds,  and mammals,  as well as a wide range of subsurface marine organisms linked
       in a complex food chain. Some organisms may be seriously injured (acute effects) or killed
       (lethal effects) very  soon after contact with the oil in a spill, however; non-lethal toxic effects are
       more subtle and often longer lasting.

       •      Marine life on reefs and shorelines are at risk of being smothered by oil that washes
              ashore or of being slowly poisoned by long-term exposure to oil trapped in shallow
              water or on beaches. Many different types of marine habitats exist with varied
              sensitivities to the harmful effects of oil contamination and different abilities to
              recuperate from oil spills. In some areas, habitats and populations can recover quickly.
              Unfortunately, in other environments, recovery from persistent or stranded oil may take
              years.
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       •       Spilled oil can harm birds and mammals in many ways. When fur or feathers come into
              contact with oil, they get matted down. This matting causes fur and feathers to lose their
              insulating properties, placing animals at risk of freezing to death. As the complex
              structure of the feathers that allows birds to float becomes damaged, the risk of
              drowning increases for birds. Some species are susceptible to the toxic effects of
              inhaled oil. Oil vapors can cause damage to an animal's central nervous system, liver,
              and lungs. Animals are also at risk from ingesting oil, which can reduce the animal's
              ability to eat or digest its food by damaging cells in the intestinal tract. Some studies
              show that there can be long-term reproductive problems in animals that have been
              exposed to oil.

5.2  WHO REGULATES OIL AND FUEL REMOVAL?

       The management of oil and fuel is regulated because of the potential impacts of releases to the
       environment and the potential danger to those working with the substances.

       •       EPA.  Under the CWA, the discharge of oil in such quantities as may be harmful into
              navigable waters of the United States and adjoining shorelines is  prohibited [CWA
              Section 31 l(b)].  EPA's Discharge of Oil regulation provides information regarding
              these discharges (40 CFR Part 110) and the Oil Pollution Prevention regulation (40
              CFR Part 112) requires certain facilities to prepare and implement Spill Prevention,
              Control, and Countermeasures (SPCC) plans, and/or Facility Response plans (FRPs).
              Used oil is regulated under the Used Oil Management Standards (40 CFR 279).
              Waste or used oil that is hazardous must be managed according to the Resource
              Conservation Recovery Act (RCRA) hazardous waste regulations (40 CFR 261- 270).

              Coast Guard. If more than 250 gallons of fuel oil or lubricating oil are to be removed
              from the vessel, the U.S. Coast Guard Captain of the Port must be notified and Coast
              Guard approval obtained. Also, the Coast Guard has required procedures for pumping
              oil from a ship to the shore.

       •       OSHA.  OSFtA is responsible for ensuring that workers are not at risk or in danger
              when managing fuel and oil. OSFtA regulations include specific requirements or
              procedures for work that is conducted in spaces that contain or have contained
              combustible or flammable liquids or gases (29 CFR 1915). These and other worker
              safety requirements will be described in the following sections.

5.3   OIL AND FUEL REMOVAL AND STORAGE
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5.3.1  Removing Oil and Fuel

       This section highlights only a few of the requirements that apply to removing oil and fuel from
       ships. Please refer to the U.S. Coast Guard (USCG) regulations for additional information.
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LJave the locations and quantities of oil and fuel to be removed from the ship
   been identified?

       Your facility will most likely identify the locations and quantities of oil and fuel onboard during
       its initial survey of the ship. Note: Your facility may have received documentation of the
       locations and quantities of oil and fuel onboard when it obtained the ship for scrapping.

LJas U.S. Coast Guard approval for removal activities  been obtained?

       If more than 250 gallons of fuel oil or lubricating oil are to be removed from the ship, your
       facility is required to notify the USCG Captain and obtain approval from the Coast Guard prior
       to the removal activities.  If located at a port, the port must certify that there are adequate oil
       transfer facilities available, and the receiving facility must have oil spill cleanup and notification
       procedures, periodic inspections, and training.

A re oils  and fuels  removed from the  ship as thoroughly as practicable?

       The removal of oil and fuel is covered under USCG and OSHA regulations. Your facility must
       remove oil and fuel as thoroughly as practicable from the ship by draining or pumping the fluids
       in a manner that minimizes the potential for a release into the environment.

Is transfer operations equipment inspected  prior to removal activities?

       Your facility may use different kinds of transfer
                                                   Tip: Transfer operations must meet
                                                   specific U.S. Coast Guard requirements
                                                   in addition to inspection and repair.
                                                   Contact the USCG for more information.
      operations equipment, such as piping, valves,
      gauges, regulators, compressors, pumps, and
      other mechanical devices to transfer oil from the
      ship to onshore storage location. This
      equipment should be inspected regularly and
      repaired as necessary because of the high risk of spills during these operations. Oil and fuel
      may be transferred from the ship to storage tanks (aboveground or underground) onshore or
      directly to a transporter's truck.

                       An inspector may evaluate transfer operations equipment to verify
                       that all equipment is in proper working order and there is no
                       evidence of spills or leaks.

A re booms  immediately available to contain accidental discharges?
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       During scrapping, your facility is required to have immediately available certain types and
       lengths of boom to help contain any accidental discharges of oil or oil-containing wastewater
       and reduce the potential for impacts to surrounding biological resources.  This is an EPA
       requirement if your facility is subject to the SPCC rule.  Under the SPCC rule, spill prevention
       procedures or controls, such as booms, oil sorbents and barriers, can be used to reduce
       impacts to the environment in the event of a spill.
5.3.2 Cleaning Oil and Fuel Tanks/Compartments on Ships and
       Shore-Based Storage Facilities

A re spaces cleaned after removal of oil and fuel?

       Depending on the kind of oil or fuel in a tank or compartment, your facility may need to clean
       that space before any hot work can be performed. When cleaning spaces that contain or have
       last contained bulk quantities of combustible or flammable liquids or gases, the facility must
       ensure that manual cleaning and other cold work is not performed until certain conditions are
       met (29 CFR 1915.13).  These conditions include, but are not limited to, the following:

              Liquid residues must be removed as thoroughly as practicable before workers start
              cleaning operations in the  space [29  CFR 1915.13(b)(l)].
              Testing is conducted by the
              facility's competent person to
              determine the concentration of
              flammable, combustible, toxic,
              corrosive, or irritant vapors within
              the space prior to the beginning
              of cleaning.

              Continuous ventilation must be
              provided at volumes and flow
              rates to ensure that these
              concentrations of vapors are
              within certain limits/levels, and
              testing must be conducted as
              often as necessary by the competent person during cleaning to assure that air
              concentrations stay within these limits/levels [29 CFR 1915.13(b)(2)-(4)].
   Who is a "competent person"? A competent
   person is a person who is capable of recognizing
   and evaluating worker exposure to hazardous
   substances or to other unsafe conditions and is
   capable  of specifying the necessary protection
   and precautions to take to ensure worker safety.
   Your facility may designate any person who
   meets the requirements found in 29 CFR 1915.7
   to be a competent person responsible for
   performing testing in certain situations (29 CFR
   1915.7). The facility may use a Marine Chemist,
   or in some cases, a certified industrial hygienist
   to perform the same activities as a competent
   person.
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              The facility must promptly post signs that prohibit sources of ignition within or near a
              space that has contained flammable or combustible liquids or gases in bulk quantities:
              (1) at the entrance to those spaces; (2) in adjacent spaces; and (3) in an open area
              adjacent to those spaces [29 CFR 1915.13(b)(10)].

       Following cleaning, tanks or other areas that have or have contained flammable liquids must be
       certified by a marine chemist before any hot work can be performed (see Section 7.3.1).
                       An inspector may review site records to verify that the proper
                       testing was conducted prior to and during the time that workers
                       conducted cleaning in these spaces.
LJow are confined or enclosed spaces determined to be safe for entry?
       Prior to workers entering a
       specific confined or enclosed
       space, your facility's competent
       person must (1) visually
       inspect the space for the
       presence of solids, liquids or
       other contaminants, and (2)
       test the space, as appropriate,
       for:
A confined space is defined as a compartment of small
size and limited access such as a double bottom tank,
cofferdam, or other space which by its small size and
confined nature can readily create or aggravate a
hazardous exposure.
An enclosed space is defined as any space,  other than a
confined space, which is enclosed by bulkheads and
overhead. Enclosed spaces include cargo holds, tanks,
quarters, and machinery and boiler spaces.
              Oxygen content [29 CFR 1915.12(a)]
       •      Concentrations of flammable vapors or gases  [29 CFR 1915.12(b)]
       •      Concentrations (air) of toxics, corrosives, or irritants  [29 CFR 1915.12(c)]

       If the tests demonstrate that the oxygen content and air concentrations are within the required
       limits, then workers may enter the space to work.  If the tests show that it is not safe to enter a
       space, then certain measures must be taken (e.g., ventilation, re-testing, labeling the space to
       prevent entry or prevent entry without the required protection) for that space.

                       An inspector may review site records to verify that proper testing
                       was conducted prior to workers entering  confined or enclosed
                       spaces.

 A re workers entering confined or enclosed  spaces appropriately trained?
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       Your facility is required to train workers who enter confined or enclosed spaces or other areas
       with dangerous atmospheres to perform their work safely.  OSHA requires training in hazard
       recognition and the use of personal protective equipment (PPE). Your facility must provide
       workers entering these spaces with training before they are allowed to enter, and whenever
       there is a change in operation or in a worker's duties [29 CFR 1915.12(d)].
                        An inspector may review training records to verify that workers
                        have the appropriate training to be working  in confined and
                        enclosed spaces.
5.3.3 Storing Wastes in Tanks

       While various types of containers may be used to store oil and fuel removed from a ship,
       facilities commonly use underground storage tanks (USTs) (40 CFR 280) or aboveground
       storage tanks (ASTs) [40 CFR 112.7(e)(2)].
                                        A Basic Checklist for USTs. EPA has a  checklist that
                                        can help your facility evaluate its USTs. Your facility can
                                        use the checklist to see how closely it meets the federal
                                        regulations for USTs (40 CFR Part 280). The checklist
                                        can also help your facility prepare for official inspections
                                        of USTs. The checklist can be accessed at
                                        http://www.epa.gov/swerust1/cmplastc/cheklist.htm.
Underground Storage Tanks

A UST is a tank and any
underground piping connected to
the tank that has at least ten
percent of its combined volume
underground. To protect human
health and the environment from
dangerous releases, USTs must
have leak detection and spill,
overfill, and corrosion protection.  Other UST requirements address notification, installation,
corrective action, financial responsibility, and recordkeeping.

Tanks installed after 1988 need to comply with all UST requirements upon installation. Tanks
installed before  1988 had until December 1998 to comply with spill, overfill, and corrosion
protection requirements, but these USTs should be in compliance with all requirements now.
            Warning: Now that the December 22,1998 deadline for all UST systems has passed,
            owners and operators of facilities that continue to operate UST systems not meeting the
            federal requirements for leak detection, and spill, overfill, and corrosion protection are out
            of compliance. Besides posing a threat to human health and the environment, such
            operation can subject the owner/operator to considerable fines.
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       Some USTs are not covered by federal regulations (e.g., tanks storing heating oil used on
       premises where it is stored; tanks on or above the floor of underground areas, such as
       basements or tunnels; emergency spill and overflow fill tanks); however, such USTs may be
       regulated by your state or local regulatory agency.

       For more information on USTs, visit EPA's Office of Underground Storage Tanks website at
       http://www.epa.gov/OUST/.  Check with the state and local regulatory agencies to find out if
       there are additional or more stringent state and/or local UST requirements.
       Aboveground Storage Tanks                      	
                                                          Note: USTs that store flammable
       ASTs, depending on their storage capacities, may be      and combustible liquids must also
       subject to federal requirements (under 40 CFR 112),      meet NFPA Provisions for tank
            „          111-         ^      1        storage and piping systems.
       as well as state and local requirements.  State and      |
       local requirements typically incorporate standards
       established by organizations such as the National Fire
       Protection Association (NFPA) and the American Petroleum Institute. For more information
       about the NFPA requirements, call the NFPA at 617-770-3000 or access their website at
       http://www.nfpa.org.

       Construction, design, and operation requirements for ASTs are typically governed by state and
       local fire marshals or environmental officers.  In addition to consulting with your fire marshal,
       your facility should also check with your state regulatory agency for information on additional
       AST requirements.

LJas the state UST program office  been notified of any  USTs on site?

       If your facility has onsite regulated UST systems, it is required to submit a notification form to
       the state UST program office.  This form includes certification of compliance with federal
       requirements for installation, cathodic protection, release detection, and financial responsibility
       for UST systems installed after December 22, 1988.  For more information on how to obtain
       and complete the form, call EPA's RCRA/UST, Superfund, and EPCRA Hotline  at 1-800-
       424-9346

                       An inspector may check with the state UST program office to verify
                       that the number of USTs match the number reported on the
                       notification form(s) to the state.
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Is leak detection conducted for tanks and piping?
       Facilities with federally regulated
       UST systems must conduct leak
       detection.  The monthly monitoring
       methods that may be used to
       conduct leak detection of tanks
       include the following:
Note: Facilities with USTs may use inventory
control and tank tightness testing instead of one of
the monthly monitoring methods for a maximum of
10 years after the tank is installed or upgraded with
corrosion protection (40 CFR 280.41).
       •  Automatic tank gauging
       •  Monitoring for vapors in soil
       •  Interstitial monitoring
          Groundwater monitoring
       •  Statistical inventory reconciliation
       •  Other methods approved by the regulatory authority

       In addition, any pressurized piping must have: (1) monthly monitoring (as described above) or
       annual line testing, and (2) an automatic flow restrictor, an automatic shutoff device, or a
       continuous alarm system installed. Check with your state UST program office to determine
       which leak detection methods are acceptable in your state.

      USTs  meet requirements for spill, overfill,  and corrosion protection?

       Your facility must operate USTs to ensure that spills, overflows, and corrosion do not cause
       releases into the environment. As of December 22, 1998, your facility was required to meet
       the federal requirements  for spill, overfill, and corrosion protection for all of its UST systems
       see 40 CFR 280.
A re ASTs inspected on a periodic basis to verify tank integrity?

       ASTs must be inspected periodically for tank integrity [40 CFR 1 12.7(e)(2)(vi)].  Several
       techniques are available to test tank integrity such as:

              X-ray or radiographic analysis to measure wall thickness and detect cracks and
              crevices in metal
       •      Ultrasonic analysis to measure shell metal thickness
              Hydrostatic testing to identify leaks caused by pressure
              Visual inspection to detect cracks, leaks, or holes
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              Magnetic flux eddy current test used in conjunction with ultrasonic analysis to detect
              pitting

       Your facility should check the outside of the tank for signs of deterioration, leaks that might
       cause a spill, and accumulated oil inside the diked areas. AST tank bottoms may be subject to
       extensive corrosion, which may go undetected during visual inspections. A tank also may fail
       due to surface corrosion.  Pitting creates a high potential for AST failure. Holes may form in
       rusty tanks causing the tank to leak.  Your facility can prevent corrosion by taking measures
       appropriate for the type of tank installation and foundation (e.g., dielectric coatings, carefully
       engineered cathodic protection, and double-bottom tanks).

       Your facility should also examine the foundation and supports of each tank. If a tank sits on a
       foundation, check for large gaps between the foundation and the tank bottom and for crumbling
       or excessive cracking in a concrete foundation.  Assess whether a storage tank foundation
       provides adequate support for the tank.  If the tank sits directly on the ground, check for large
       gaps between the ground surface and the tank bottom.

       All leaks should be documented and repaired immediately.
Is secondary containment used to prevent oil discharges?

       For ASTs, your facility is required to install appropriate containment and diversionary structures
       or equipment, such as dikes, berms, and retaining walls (40 CFR 112.7), to prevent discharges
       of oil from reaching navigable water, unless it can be clearly demonstrated that installation of
       such structures or equipment is not practicable. Impracticability pertains primarily to those
       cases where severe space limitations or other physical constraints may preclude installation of
       structures or equipment to prevent oil from reaching navigable water.  Demonstrating
       impracticability on the basis of economic considerations is not acceptable.

                         An  inspector may verify that there are appropriate containment
                         and diversionary  structures or equipment at the facility for all
                         ASTs.

5.3.5 Managing Oil/Oily Wastes  as Used Oil

       Used oil is stored and managed according to the Used Oil Management Standards (40 CFR
       279). As a facility that handles used oil, your facility must follow certain good housekeeping
       practices. These management standards are common sense, good business practices designed
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       to ensure the safe handling of used oil to maximize recycling and minimize disposal. Note:
       Some states may have stricter disposal requirements. Contact your state regulatory agency to
       determine the used oil disposal requirements.

       As noted earlier, EPA defines used oil as "any oil that has been refined from crude oil or any
       synthetic oil that has been used and as a result of such use is contaminated by physical or
       chemical impurities."  A substance must meet each of the following three criteria to meet the
       definition of used oil:

       •       Origin.  This criterion is focused on the oil's origin. Used oil must have been refined
               from crude oil or made from synthetic materials.  Animal and vegetable oils are
               excluded from EPA's definition of used oil.

               Use. This criterion is based on whether and how the oil is used. Oils used as
               lubricants, hydraulic fluids, heat transfer fluids, buoyants, and for other similar purposes
               are considered used oil. Unused oils, such as bottom clean-out waste from virgin fuel
               oil storage tanks or virgin fuel oil recovered from a spill, do not meet EPA's definition
               of used oil because they have never been "used." EPA's definition also excludes
               products used as cleaning agents or used solely for their solvent properties, as well as
               certain petroleum-derived products like antifreeze and kerosene.

               Contaminants.  To meet EPA's definition, used oil must be contaminated with either
               physical or chemical impurities as a result of being used.  This includes residues and
               contaminants generated from handling, storing, and processing used oil. Physical
               contaminants may include metal shavings, sawdust, or dirt.  Chemical contaminants
               could include solvents, halogenated volatile organics (i.e., halogens), or saltwater.

       Used oil and substances containing or covered with used oil are regulated according to the
       Used Oil Management Standards if they meet certain conditions. Otherwise, they are subject to
       being managed according to other regulations [40 CFR 279.10(b)].

       The following are regulated as used oil:

               Used oil produced on a ship from normal shipboard operations is subject to regulation
               as a used oil when it is transported ashore.

               A mixture of used oil and a waste that is hazardous solely because it exhibits the
               characteristic of ignitability  if the resultant mixture does not exhibit the characteristic of
               ignitabilitv.
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               Except as described in the bullet above, a mixture of used oil and a hazardous waste
               that solely exhibits one or more of the hazardous waste characteristics (e.g., ignitability,
               corrosivity, reactivity, or toxicity) if the resultant mixture does not exhibit any of the
               hazardous waste characteristics.

       •       Materials which contain or are otherwise contaminated with used oil that are recycled
               (e.g., burned for energy recovery). This includes the used oil drained or removed from
               these materials.

       The following are not regulated as used oil:

               Oils and oily wastes that do not meet the definition of used oil.

       •       A mixture of used oil and a hazardous waste that exhibits one or more of the hazardous
               waste characteristics (e.g., ignitability, corrosivity, reactivity, or toxicity) if the resultant
               mixture exhibits any hazardous waste characteristics. This mixture must be regulated as
               a hazardous waste

       •       A mixture of used oil  and a listed hazardous waste. This includes used oil mixtures
               containing more than 1,000 ppm total halogens. (EPA presumes that the used oil has
               been mixed with a listed halogenated hazardous waste.) This mixture must be regulated
               as a hazardous waste.

               Materials which contain or are otherwise contaminated with used oil if the used oil has
               been properly drained or removed (i.e., there are no visible signs of free-flowing oil
               remaining on or in the materials) from them. These materials are then not defined as
               used oil and therefore, are not regulated as used oil.
Is the mixing of used oil with hazardous waste prevented?
       Hazardous waste fluids, such as
       used solvent, gasoline, or other
       hazardous substances, should not
       be mixed with used oil, or the
Tip: Avoid mixing used oil and hazardous waste.
If used oil is mixed with hazardous waste, the entire
volume will probably have to be managed as
hazardous waste.  The safest practice is to never mix
          ,.     ,         ,   ,    -c  i         any other wastes with used oil.
       entire volume maybe classified as
       hazardous waste. Basically, the
       following mixing rules apply:
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              A mixture of used oil and a waste that is hazardous solely because it exhibits the
              characteristic of ignitability must be managed as a hazardous waste if the resultant
              mixture exhibits the characteristic of ignitability.

              A mixture of used oil and a hazardous waste that exhibits one or more of the hazardous
              waste characteristics (e.g., ignitability, corrosivity, reactivity, or toxicity) must be
              regulated as a hazardous waste if the resultant mixture exhibits any hazardous waste
              characteristics.

              A mixture of used oil and a listed hazardous waste must be regulated  as a hazardous
              waste. This includes used oil mixtures containing more than 1,000 ppm total halogens.
              (EPA presumes that the used oil has been mixed with a listed halogenated hazardous
              waste.)

       The safest practice is never to mix any other waste with used oil.  However, if you have
       questions about which specific products may be mixed with used oil, call the RCRA/UST,
       Superfund, and EPCRA Hotline  at 1-800-424-9346.

   re all containers/tanks  leak free and labeled "used oil"?

       Your facility can store used oil in containers (e.g.,
                                                       Note: If oil contains >50 ppm of PCBs,
                                                       then the PCB labeling procedures
                                                       apply to any container storing such oil
                                                       (see Section 3).
55-gallon steel drum) or tanks (e.g., underground
or aboveground storage tanks). These containers
and tanks must be leak free and labeled with the
words "Used Oil." Some facilities havepipes
that connect to a used oil storage tank. In this
case, the piping should also be labeled with the words "Used Oil." No special labels are
necessary, provided that the words "used oil" are visible at all times.  Spray painting, crayon, or
handwritten (preferably not in pencil) labels are okay.

                 An inspector may inspect all oil storage containers or tanks to
                 verify that they are labeled properly and there is no evidence of
                 leaks or discharges of oil.
 A re used oil and fuel recycled or sent to a reclaimer?
       Your facility most likely sends used oil and fuel to a recycling center or reclaimer. The used oil
       management standards (40 CFR 279) include a recycling presumption, that is, an assumption
       that all used oil that is generated will be recycled.  This is based on the fact that almost all used
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       oil can be recycled. Recycling is the most environmentally protective and often the most
       economical approach to handling used oil. Facilities should maintain all records on their used oil
       storage and recycling activities.
       Your facility has two options for
       transporting used oil: (1) using a
       transporter or (2) self-transporting.
       Your facility must ensure that your used
       oil is transported to an approved
       recycling center by transporters who
       have obtained EPA identification
       numbers. If self-transporting more than 55 gallons of used oil offsite to an approved recycling
       center, your facility is required to (1) have an EPA identification number and (2) be licensed as
       a used oil transporter.
                                        Tip: Check your transporter's qualifications to
                                        make sure they take your used oil to a reputable
                                        recycling center. Measure the level of oil in your
                                        tank before and after the transporter collects it to
                                        be certain the oil collected matches the amount
                                        the transporter has reported.
       Another method of recycling used oil is burning
                                                       Used oil should never be disposed of in
                                                       sewers, drains, dumpsters, on the
                                                       ground, or used as dust suppressants.
for energy recovery. Your facility may burn the
used oil in an on site heater which is used to heat
parts of the facility or heat hot water, or it either
has a transporter or takes its own oil to an
approved used oil burner. Used oil burned offsite may be used as fuel in industrial furnaces,
utility boilers, or hazardous waste incinerators.

Note: Though not the environmentally preferred method, nonhazardous sludge may be disposed
of in a solid waste landfill, which is also known as a municipal landfill (40 CFR 258), if it is not
sent to a recycling center. Your facility should contact its municipal solid waste landfill for more
information on industrial sludge disposal requirements.

                  An inspector may track the shipments from your facility through the
                  reclaimers to verify that the shipments of fuel and oil do not
                  contain spent solvent or other hazardous waste liquids.
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5.3.6  Managing Oil/Oily Wastes as Hazardous Wastes

 A re oil/oily wastes hazardous?

       Oil and oily wastes may contain substances in concentrations which make them hazardous. If
       hazardous, they must be managed and disposed of according to the RCRA hazardous waste
       regulations (40 CFR 261-270).

       If your facility has determined that these oil/oily wastes are not classified as  used oil, then it must
       test them to determine pollutant concentrations and evaluate if they are hazardous. Tests may
       be conducted for various contaminants, including but not limited to: metals, such as lead,
       arsenic, chromium, and cadmium; polychlorinated biphenyls (PCBs); total halogenated volatile
       organics; and the flash point.

       To be considered "hazardous waste," materials must first meet EPA's definition of "solid
       waste."  Solid waste is discarded material, such as garbage, refuse, and sludge, and it can
       include solids, semisolids, liquids, or contained gaseous materials. Solid wastes that meet the
       following criteria are considered hazardous and subject to RCRA regulations (40 CFR Part
       261):

       •      Listed waste. Waste is considered hazardous if it appears on one of four lists of
              hazardous wastes published in 40 CFR 261 Subpart D.  Currently, more than 400
              wastes are listed. Wastes are listed as hazardous because they are known to be
              harmful to human health and the environment when not properly managed. Even when
              properly managed, some listed wastes are so dangerous that they are called "acutely
              hazardous wastes." Examples of acutely hazardous wastes include  wastes generated
              from some pesticides that can be fatal to humans even in low doses.

       •      Characteristic waste. If waste does not appear on one of the hazardous waste lists, it
              still might be considered hazardous if it demonstrates one or more of the following
              characteristics:

              S      Ignitable:  Ignitable wastes can create fire under certain conditions (e.g.,
                     temperature, pressure) or are spontaneously combustible (40 CFR 261.21).
                     Examples include certain used paints,  degreasers, oils and solvents.

              S      Corrosive: Corrosive wastes are acids or bases that are capable of corroding
                     metal, such as storage tanks, containers, drums, and barrels (40 CFR 261.22).
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                     Examples include rust removers, acid or alkaline cleaning fluids, and battery
                     acid.

                     Reactive:  Reactive wastes are unstable and explode or produce toxic fumes,
                     gases, and vapors when mixed with water (40 CFR 261.23). Examples
                     include lithium-sulfide batteries and explosives.

                     Toxic: Toxic wastes are harmful or fatal when ingested or absorbed, or leach
                     toxic chemicals into the soil or groundwater when disposed of on land (40 CFR
                     261.24).  Examples include wastes that contain high concentrations of heavy
                     metals, such as cadmium, lead, or mercury.
                Determining toxicity: A facility can determine if its waste is toxic by having it tested
                using the Toxicity Characteristic Leaching Procedure (TCLP), or by process
                knowledge. TCLP can be done at a local certified laboratory.  It is designed to
                replicate the leaching process and other effects that occur when wastes are buried in
                a typical municipal landfill.  If the waste contains any of the regulated contaminants at
                concentrations equal to or greater than the regulatory levels, then the waste exhibits
                the toxicity characteristic. Process knowledge is detailed information on wastes
                obtained from existing published or documented waste analysis data or studies
                conducted on hazardous wastes generated by similar processes. For example, EPA's
                lists of hazardous wastes in 40 CFR 261 (as discussed above) can be used as
                process knowledge.
If your facility generates hazardous waste, what is your generator category?

       Determining your generator category. Your facility's hazardous waste generator category is
       determined by the amount of hazardous waste that it generates each month (40 CFR 261).
       There are three federal categories of hazardous waste generators:

       •      Conditionally exempt small quantity generator (CESQG). CESQGs generate
              <220 pounds (100 kg) of hazardous waste per month or <220 pounds of spill cleanup
              debris containing hazardous waste per month. CESQGs have no maximum on-site time
              limits for storage, but cannot accumulate more than 2,200 Ibs. (1,000 kg) of
              hazardous waste onsite. If a CESQG accumulates more than this amount, it becomes
              an SQG or LQG.

              Small quantity generator (SQG). SQGs generate >220 pounds (100 kg) and
              <2,200 pounds (1,000 kg) of hazardous waste per month or >220 pounds and
              <2,200 pounds of spill  cleanup debris containing hazardous waste per month. SQGs
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              may accumulate no more than 6,000 kg of hazardous waste in storage, which may be
              stored on site for no more than 180 days (or no more than 270 days if the
              treatment/disposal facility is more than 200 miles away). If an SQG accumulates more
              than the specified amount, it becomes an LQG.

              Large quantity generator (LQG). LQGs generate >2,200 pounds (1,000 kg) of
              hazardous waste per month or > 2,200 pounds of spill cleanup debris containing
              hazardous waste per month. LQGs may accumulate any amount of hazardous waste for
              no more than 90 days.
           Facilities that generate 2.2 pounds or less of acutely hazardous wastes per month
           are classified as CESQGs, whereas facilities that generate more than 2.2 pounds
           of acutely hazardous wastes per month are classified as LQGs.
       Adding waste quantities. To determine which category applies to your facility, your facility
       must count all quantities of listed and characteristic hazardous wastes. These include wastes
       that are: (1) generated and collected at your facility prior to treatment or disposal; and (2)
       packaged and transported offsite.
       Many hazardous wastes are liquids and are
       measured in gallons, not pounds. To
       approximate the number of pounds of liquid
       your facility has, multiply the number of
       gallons by 8.3 (because a gallon of water
       weighs 8.3 pounds and many liquids have a
       density similar to water).
                    Rough Guide
         27 gallons (about half of a 55-gallon
         drum) of waste with a density similar to
         water weighs about 220 pounds (100 kg).
         270 gallons of waste with a density
         similar to water weighs about 2,200 Ibs
         (1,000kg).
       When adding up all the hazardous wastes generated, keep in mind that your facility does NOT
       have to count the following:

       •      Wastes that are left on the bottom of containers that have been emptied by conventional
              means (i.e., pouring or pumping) and where no more than 2.5 cm (1 inch) of residue
              remains in the bottom of the container or no more than 3 percent by weight of the total
              capacity of the container remains in the container if the container is less than or equal to
              110 gallons in size.

              Residues in the bottom of storage tanks, if the residue is not removed (i.e., residues left
              in the bottom of the storage container are not counted as long as they are not removed
              when the tank is refilled).
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              Wastes that are reclaimed continuously on site without storing the waste prior to
              reclamation.

       •       Wastes that have already counted once during the calendar month, and treated onsite
              or reclaimed in some manner and used again.

       •       Wastes that are directly discharged to a municipal treatment plant or POTW without
              being stored or accumulated first.

       •       Waste oil that meets the criteria for used oil and is to be managed and handled as used
              oil (40 CFR 279).

              Scrap  metal that is recycled [40 CFR 261.6(a)(3)].

If your facility  is a CESQG, does it meet all applicable requirements?

       As a CESQG, your facility's requirements are quite simple.  There are three basic hazardous
       waste management requirements that apply to CESQGs:

              Identify all hazardous and acutely hazardous wastes (40 CFR 262.11). For help in
              identifying hazardous wastes, call EPA or your state regulatory agency; a consultant; a
              licensed transporter; or the RCRA/UST, Superfund and EPCRA hotline at 703-412-
              9810 or  1-800-424-9346.

                              An inspector may review your facility's waste
                              determinations and any analytical data.

              Do not generate more than 220 Ibs. (or 100 kg) per month of hazardous waste or more
              than 2.2 Ibs.  (1 kg) per month of acutely  hazardous waste (this includes any wastes
              your facility  has shipped off site for disposal during that month); and never store more
              than 2,200 Ibs. (1,000 kg) of hazardous waste or 2.2 Ibs. of acutely hazardous waste
              for any period of time (40 CFR 261 and 262).

                              An inspector may evaluate the total volume of waste on site
                              at the time of the inspection and verify that it is within the
                              limits for your facility's generator category.
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              Ensure proper disposal of your hazardous waste.  For CESQGs, proper treatment and
              disposal of hazardous wastes are fairly simple. It involves ensuring that the waste is
              shipped to one of the following facilities:

                     A state or federally regulated hazardous waste management treatment, storage,
                     or disposal facility (if your facility's waste is hazardous).

              -      A facility permitted, licensed, or registered by a state to manage municipal or
                     industrial solid waste.

              -      A facility that uses, reuses or legitimately recycles the waste (or treats the waste
                     prior to use, reuse, or recycling).

              Self-transporting hazardous waste. CESQGs are allowed to transport their own
              wastes to the treatment or storage facility, unlike SQGs and LQGs which are required
              to use a licensed, certified transporter. While there are no specific RCRA requirements
              for CESQGs who transport their own wastes, Department of Transportation (DOT)
              requires all transporters of hazardous waste to comply with all applicable DOT
              regulations. Specifically, DOT regulations require all transporters, including CESQGs,
              transporting hazardous waste that qualifies as DOT hazardous material to comply with
              EPA hazardous waste transporter requirements see 40 CFR 263.

       •      As a CESQG, your facility is not required by federal laws to train its employees on
              hazardous waste handling or emergency preparedness, however, it is strongly advised.
              Keep in mind that your employees responding to releases of hazardous
              substances and hazardous waste are required  to be trained under OSHA's
              Hazardous Waste Operations and Emergency Response (HAZWOPER)
              requirements see 29 CFR 1910.120.

       Your facility must comply with the above requirements to retain its CESQG status, and remain
       exempt from the more stringent hazardous waste regulations that apply to SQGs and LQGs.
       Though not required, it is recommended that your facility follow the waste storage and handling
       requirements for SQGs to minimize the possibility of any leaks, spills, or other releases that
       potentially could cause economic hardship to your facility.  States may have more stringent
       and/or different requirements, so contact your state hazardous waste agency for these
       requirements.

If your facility is an SQG  or LQG, does it meet all applicable requirements?
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       If your facility determines, based on the amount of waste generated, that it is an SQG or LQG,
       it must comply with a variety of requirements covering the storage and handling, treatment, and
       disposal of the hazardous waste, from generation to final disposal. These requirements include:

             Waste identification. As a generator, your facility must determine whether wastes are
             hazardous using the hazardous waste identification process (40 CFR 261).  For
             assistance, call EPA or your state regulatory agency; a consultant; a licensed
             transporter; or the RCRA/UST,  Superfund and EPCRA hotline at 703-412-9810 or
             1-800-424-9346.

                              An inspector may review your facility's waste
                              determinations and any analytical data.

             EPA identification number.  An EPA hazardous waste generator identification
             number must be entered on all hazardous waste manifests (40 CFR 262.12). For
             assistance in obtaining a hazardous waste generator identification number (EPA form
             8700-12 "Notification of Hazardous Waste Activity"), your facility may contact EPA
             or the state regulatory agency.

             Accumulation and storage limits. Onsite accumulation (storage) limits are based on
             the total weight of hazardous waste that can be accumulated at any time at your facility
             before it must be shipped offsite (40 CFR 262.34).

                              An inspector may evaluate the total volume of waste on site
                              at the time of the inspection and verify that it is within the
                              limits for your facility's generator category (e.g., SQG  or
                              LQG).

             Container management. Your facility can store hazardous waste in 55-gallon drums,
             tanks, or other suitable containers, and it must comply with rules intended to protect
             human health and the environment and reduce the likelihood of damages or injuries
             caused by leaks or spills (40 CFR 265).

                              An inspector may look at all hazardous waste on site noting
                              the size and type of containers, their condition, and whether
                              they are closed and protected from the weather. He/she may
                              check the  labels on the containers for the words "hazardous
                              waste," and verify that the dates information is complete on
                              the label.  The inspector may also check the containment for
                              cracks or leaks.
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              Personnel training.
              Proper waste handling
              can save your facility
                        Keep in mind that employees who are responding to
                        releases of hazardous substances waste are also required
                        to be trained under OSHA's Hazardous Waste Operations
              monev in waste           anc' Emergency Response (HAZWOPER) requirements see
                                      29 CFR 1910.120, in addition to EPA's hazardous waste
                                      management training.
treatment and disposal
and in lost time due to
employee illness or
accidents. Your facility must train its employees on the procedures for properly
handling hazardous waste, as well as on emergency procedures [40 CFR 262.34(a)].
For LQGs, the training must be formalized and be completed by employees within six
months of accepting a job involving the handling of hazardous waste, and your facility is
required to provide annual review of the initial training.

                 An inspector may check personnel records to determine
                 when hazardous waste duties were assigned and if proper
                 training was provided by your facility.

Contingency planning, emergency procedures, and accident prevention. If an
LQG, your facility is  required to have a written  contingency plan.  If an SQG, your
facility must have basic contingency procedures in place.  Although a written
contingency plan is not federally required for SQGs or CESQGs, it is strongly
recommended.  It is also important to check with your state and local authorities for any
additional contingency plan or emergency preparedness requirements (40 CFR 262).

                 An inspector may review your facility's contingency plan or
                 basic contingency procedures, and ask about any incidents
                 requiring implementation of the plan or procedures.

Hazardous waste shipment labeling and placarding When your facility prepares
hazardous wastes for shipment, it must put the wastes in properly labeled containers
that are appropriate for transportation according to the DOT regulations (40 CFR
262).

Reporting and recordkeeping requirements. Your facility is required to meet
various reporting and recordkeeping requirements as part of your hazardous waste
management activities. Reports include the following:

S      Manifest form. The Uniform Hazardous Waste Manifest Form (EPA Form
       8700-22) is a multi-copy shipping document that reports the contents of your
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                      shipment, the transport company used, and the treatment/disposal facility
                      receiving the wastes (40 CFR 262.20).  Your facility (i.e., the hazardous waste
                      generator), the transporter, and the treatment/disposal facility must each sign
                      this document and keep a copy. Your facility must keep the copy of the
                      manifest signed by all three parties on file for three years.

              S      Exception report. Exception reports document a missing return copy of the
                      hazardous waste manifest.  Your facility must maintain copies of exception
                      reports for three years.

              S      Biennial report. If an LQG, your facility must submit a biennial report (EPA
                      8700-13 A) on March 1 of each even-numbered year to the appropriate EPA
                      or state regulatory agency (40 CFR 262.41). Some states impose this
                      requirement on SQGs. Your facility can obtain biennial report applications and
                      instructions from EPA or its state regulatory agency.

              S      Land disposal restriction notification Land disposal restrictions (LDRs)
                      are regulations prohibiting the disposal of hazardous waste on land without prior
                      treatment of the waste (40 CFR 268).  Your facility is required to provide a
                      one-time notification about your wastes to the treatment or disposal facility
                      with the first shipment of waste offsite, and keep a copy in your files.

              In addition to these reports, your facility is required by EPA to keep certain records on
              file to show that good housekeeping practices and monitoring are  being performed.
              EPA requires that records be kept on file at your facility for three years (40 CFR
              262.40). These records include:

              S      Laboratory analyses and waste profile sheets for determining whether wastes
                      generated by your facility are hazardous.

              S      Copies of all hazardous waste manifests, land disposal restriction notification,
                      and exception reports.

              S      Copies of all Notification of Hazardous Activity forms submitted to and
                      received from the state or EPA.

              S      For LQGs only, copies of: (1) all personnel training plans and documentation
                      that indicate employees have completed the required training; (2) the facility's
                      contingency plan; and (3) the facility's biennial report.
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                             An inspector will most likely review all records, including but
                             not limited to annual or biennial reports and manifests.
5.4   OIL SPILL PREVENTION, RESPONSE, AND RECOVERY

       Some of the most important activities during ship scrapping are: (1) preventing oil discharges,
       (2) being prepared to respond to spills, and (3) knowing how to respond to spills and recover
       spilled materials.  EPA issued the Oil Pollution Prevention regulation (40 CFR 112) to prevent
       oil spills from reaching navigable waters of the United States or adjoining shorelines and to
       prepare facility personnel in responding to oil spills. The regulation has two sets of
       requirements — the Spill Prevention, Control, and Countermeasures (SPCC) plan rule (an oil
       spill prevention program) and the Facility Response Plan (FRP) rule (an oil spill response
       program). Your facility may be subject to this regulation if it, among other things, produces,
       gathers, stores, transfers, or consumes oil.

5.4.1  Spill  Prevention Planning

Qoes your facility have an SPCC  plan?

       The intent of an SPCC plan is to prevent the discharge of oil from non-transportation-related
       fixed facilities (40 CFR 112). Your facility may be required to prepare and implement an
       SPCC plan if:

       (1)     Due to its location, it could reasonably be expected to discharge oil into or upon the
              navigable waters of the United Stated or adjoining shorelines, AND

       (2)     It meets one of the following criteria regarding oil storage:
                     An aboveground storage capacity of more than
                     660 gallons in a single container.

                     A total aboveground storage capacity of more than
                     1,320 gallons.

                     A total underground storage capacity of more than
                     42,000 gallons.
                          Storage Capacity:
                          Remember, the
                          requirements apply
                          specifically to your
                          storage capacity,
                          regardless of whether
                          the tanks are
                          completely filled.
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       If subject to the SPCC requirements based
       on the above description, your facility is
       required to prepare an SPCC plan and
       follow the other provisions of the SPCC
       rule 40 CFR 112.3 through 112.7.
Tip: A sample SSPCC plan can be viewed
at
http://www.epa.gov/oilspill/sspcc/sampln.pdf
Qoes the SPCC plan include all the required information?

       Your facility's SPCC plan must be unique to your facility, but also must have certain elements
       common to all plans (40 CFR 112.7). Specifically, the SPCC plan must:

              Be certified by a registered professional engineer (PE)
       •      Be kept on site
       •      Have full management approval
              Conform with all SPCC requirements in 40 CFR 112.7
              Discuss spill history
       •      Discuss spill prediction
       •      Be reviewed every three years
              Be amended when a change is made at the facility and recertified by a PE
              Include secondary containment or contingency plans
       •      Specify spill reporting

                       An inspector may review the facility's SPCC plan to ensure that it is
                       certified by a registered professional  engineer and that it is up-to-
                       date.

5.4.2 Spill  Response Planning

       If subject to the SPCC requirements, your facility is required to conduct an initial screening to
       determine whether it is also required to develop a facility response plan (FRP).  Under the FRP
       requirements, owners and operators of facilities that could cause "substantial harm" to the
       environment by discharging oil into navigable water bodies or adjoining shorelines must prepare
       FRPs for responding, to the maximum extent practicable, to the worst case discharge and to a
       substantial threat of such a discharge of oil (40 CFR 112.20 and 112.21, including Appendices
       A through F). Facilities subject to the FRP requirements are referred to either as substantial
       harm facilities or significant and substantial harm facilities
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       Substantial Harm Facilities

       If your facility is determined to be a substantial harm facility, it must prepare an FRP which is
       submitted to EPA for review. Your facility may be identified as posing a risk of substantial
       harm by one of two ways:

       •       Either through a self-determination process (EPA has established criteria located in 40
               CFR 112.20 to assist facilities in making the determination - see below),

       •       Or by a determination of the EPA Regional Administrator (RA).

       Self-Determination. Your facility has the potential to cause substantial harm if:

       •       Either the facility transfers oil over water to or from vessels and has a total oil storage
               capacity, including  both ASTs and USTs, greater than or equal to 42,000 gallons;

       •       Or the facility's total oil storage capacity, including both ASTs and USTs, is greater
               than or equal to one million gallons and one of the following is true:

               S      The facility does not have secondary containment for each aboveground
                     storage area sufficient to contain the capacity of the largest AST within each
                     storage area plus freeboard to allow for precipitation;

               S      The facility is located at a distance such that a discharge could cause injury to
                     fish and  wildlife and sensitive environments;

               S      The facility is located at a distance such that a discharge would shut down a
                     public drinking water intake; or
               S      The facility has had a reportable spill greater than or equal to 10,000 gallons
                     within the last five years [40 CFR 112.20 (f)(l)].

       EPA Determination. If a self-determination is not made, EPA's RA may determine whether
       your facility may cause substantial harm.  EPA's RA may consider factors similar to the self-
       selection criteria, as well as  other factors, including the type of transfer operations at a facility,
       the facility's oil storage capacity, lack of secondary containment, proximity to environmentally
       sensitive areas or drinking water intakes, and/or the facility's spill history. The EPA RA will
       notify your facility if EPA has determined that your facility poses a threat of substantial harm.

       Significant and Substantial Harm Facilities
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       EPA is also required to identify a subset of substantial harm facilities that could cause
       significant and substantial harm to the environment upon a release of oil.  In addition to the
       criteria used to determine substantial harm, EPA bases its determination of significant and
       substantial harm on other factors such as the age of tanks, proximity to navigable water, and
       spill frequency. Facilities are notified by EPA in writing of their status as posing significant and
       substantial harm.  If your facility is notified by EPA, it must submit an FRP to EPA for review
       and approval. The RA will review the FRP and may inspect your facility for viability and
       compliance with the regulations before EPA approves the plan.

       If Your Facility Does Not Meet the Criteria

       If your facility does not meet the "substantial harm" criteria, it does not have to prepare and
       submit an FRP. However, your facility must document this determination by completing the
       "Certification of the Applicability of the Substantial Harm Criteria Checklist," provided as 40
       CFR 112, Appendix C, Attachment C-H [40 CFR 112.20(e)].  This certification should be
       maintained with the facility's SPCC plan.

Qoes your facility have a facility  response plan (FRP)?

       If it has been determined, either through the self-selection process or by notification from the
       EPA RA, that your facility poses a threat of "substantial harm" to the environment, your facility
       must prepare and submit an FRP to the appropriate EPA Regional Office.

       FRPs must:
              Be consistent with the
              Plan (NCP) and the
              Area Contingency
              Plans.
The NCP, also called the National Oil and Hazardous
              M  .   .  „   .           Substances Pollution Contingency Plan, is the federal plan
              National  Contingency    for responding to both oN spN|s and hazardous substance
releases. See http://www.epa.gov/oilspill/ncp
for more information.
              Identify a qualified individual having full authority to implement removal actions, and
              require immediate communication between that person and the appropriate federal
              authorities and responders.

              Identify and ensure availability of resources to remove, to the maximum extent
              practicable, a worst-case discharge.
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       •      Describe training, testing, unannounced drills, and response actions of persons at the
              facility.

       •      Be updated periodically.

       •      Be submitted for approval with each significant change.

       To assist your facility in preparing an FRP, EPA has prepared and included a "model facility
       response plan" see 40 CFR 112.2, Appendix F. The following is a list of key FRP elements:

       •      Emergency response action plan. This should be maintained as an easily accessible,
              stand-alone section of the overall plan.

              Facility name, type, location, owner, and operator information.

       •      Emergency notification, equipment, personnel, and evacuation information.

              Identification and evaluation of potential spill hazards and previous spills.

       •      Identification of small,  medium, and worst case discharge scenarios and response
              actions.

       •      Description of discharge detection procedures and equipment.

              Detailed implementation plan for containment and disposal.

       •      Facility and response self-inspection; training; exercises; and drills; and meeting logs.

              Diagrams of facility and surrounding layout, topography, and evacuation paths.

       •      Security measures including fences, lighting alarms, guards, emergency cutoff valves,
              and locks.

                        An inspector may evaluate FRP measures for their ability to
                        facilitate adequate response to a worst-case  discharge of oil.
lAlas an existing response plan used or modified?
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                                           Avoid Recreating the Wheel: EPA also recognizes
                                           that many facilities have established SSPCC plans.
                                           Although response plans and prevention plans are
                                           different, and should be maintained separately, some
                                           sections of the plans may be the same. Under OPA
                                           regulations, your facility is allowed to reproduce or use
                                           those sections of the SSPCC plan in your FRP.
       EPA recognizes that many
       facilities may have existing
       response plans prepared to meet
       other requirements.  Your facility
       does not need to prepare a
       separate FRP provided that your
       facility's original response plan:        	

       (1)     Satisfies the appropriate requirements and is equally as stringent;
       (2)     Includes all elements described in the model plan;
       (3)     Is cross-referenced appropriately; and
       (4)     Contains an action plan for use during a discharge.

lAlas the FRP prepared and submitted  by the deadline?2
       The time that your facility has to prepare and submit a FRP will vary depending on several
       factors, including the following:

       •       Notification from EPA Regional Administrator:  If EPA notifies your facility that it
               is required to submit an FRP, then your facility must prepare and submit a plan within
               six (6) months.


       •       Newly Constructed Facilities: If your facility is newly constructed, it is required to
               submit the FRP prior to the start of operations. After sixty (60) days, your facility must
               make adjustments to the FRP to reflect changes that occur during the startup phase and
               resubmit the FRP.
               Planned Facility Changes: If your facility undergoes a planned change in design,
               construction, operation, or maintenance that places it in the designation of a substantial
               harm facility, then it must submit an FRP prior to the start of operations of the portion of
               the facility undergoing the changes.
               The initial statutory deadline for "substantial harm facilities" either to submit FRPS or to stop handling,
               storing or transporting oil was February 18, 1993. EPA's regulatory deadline for "substantial harm facilities"
               and "significant and substantial harm facilities" to submit FRPs or stop handling, storing or transporting oil
               was August 30, 1994, the effective date of the FRP rule.
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              Unplanned Facility Changes: If your facility falls under the substantial harm facility
              designation because of an unplanned event or change in characteristics, then it must
              submit an FRP within six (6) months of the unplanned event.
LJas the FRP been maintained and updated?
                                                        Area Contingency Plans (ACPs)
                                                        include detailed information about
                                                        resources (e.g., equipment and trained
                                                        response personnel) available from the
                                                        government agencies in the area. They
                                                        also describe the roles and
                                                        responsibilities of each responding
                                                        agency during a spill incident. Your
                                                        facility can order copies of ACPs from
                                                        the National Technical Information
                                                        Service (NTIS) by calling 1-800-553-
                                                        6847.  To  obtain the NTIS ordering
                                                        number for your area's ACP, first call
                                                        the RCRA/UST, Superfund and EPCRA
                                                        Hotline at  1-800-424-9346 or 703-412-
                                                        9810.
       Your facility must periodically review your FRP
       to ensure consistency with the National Oil and
       Hazardous Substances Pollution Contingency
       Plan (NCP) and Area Contingency Plans
       (ACPs), and update it as appropriate [40 CFR
       112.20(g)]. Consequently, if your facility is
       required to prepare a FRP, it must review
       relevant portions of the NCP and the applicable
       ACPs annually and update its FRP as
       appropriate. Your facility must submit revised
       portions of the FRP within 60 days of each facility
       change that may materially affect (1) the response
       to a worst case discharge or (2) the
       implementation of the response plan.

A re appropriate FRP records maintained?

       FRP requirements not applicable: If your facility determines that the response planning
       requirements do not apply, then it must certify and maintain a record of this determination using
       40 CFR 112, Appendix C, Attachment C-II.

       FRP requirements applicable: If your facility is subject to the response planning
       requirements, it is required to maintain the FRP at the facility. Your facility is also required to
       maintain updates to the plan to reflect material changes to the facility and to log activities such
       as discharge prevention meetings, response training drills, and exercises. Your facility must
       keep the records of these activities for a period of five years.

A re training and response drill requirements met?

       All facilities (i.e., "substantial harm" and "significant and substantial harm" facilities) subject to
       facility response planning requirements must address training and response drills (40 CFR
       112.21). FRPs must include (1) information about self-inspection drills, exercises, and
       response training, including descriptions and logs of training and drill or exercise program; and
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       (2) documentation of tank inspections, equipment inspections, response training meetings,
       response training sessions, and drills and exercises [40 CFR 112.20(h)(8)].  Consequently,
       FRPs may be revised based on evaluations of the drills and exercises.

       Oil spill response training is an important element in EPA's oil spill prevention and preparedness
       efforts.  Because operator error is often the cause of an oil spill, training and briefings are
       critical for prevention of a spill as well  as response to a spill. Training encourages up-to-date
       planning for the control of, and response to, an oil  spill and also helps to sharpen operating and
       response skills, introduces the latest ideas and techniques, and promotes interaction with the
       emergency response organization and familiarity with the facility's SPCC and FRP plans.
       Your facility is also required to develop
       and implement a program of response drills
       and exercises, including evaluation
       procedures to test the effectiveness of your
       response plan. A program that follows the
       National Preparedness for Response
       Exercise Program (PREP) will meet EPA's
       exercise requirements. An alternative
       program can also be acceptable if
       approved by the EPA RA.
                                           The PREP guidelines booklet (USCG-X0191)
                                           and the Training Reference for Oil Spill
                                           Response (USCG-X0188) are available by mail
                                           or fax:
                                                  TASC Department Warehouse
                                                  3341075th Avenue
                                                  Landover, MD 20785
                                                  FAX: (301) 386-5394
                                           When requesting copies, please indicate the
                                           document name(s) and publication number(s).
5.4.3 Spill Notification and  Recovery

 A re oil spills reported  as required?
                                                Defining discharge. "Discharge" means any
                                                spilling, leaking, pumping, pouring, emitting,
                                                emptying or dumping [CWA Section 311 (a)(2)].
Though not common, your ship
scrapping facility may experience
accidental discharges of oil to U.S.
waters or land while performing daily
activities.  Your facility is required to
report discharges of oil to navigable waters or adjoining shorelines in quantities that may be
harmful to public health or welfare or the environment (40 CFR 110). EPA has determined
that discharges of oil in quantities that may be harmful include those that:

•      Violate applicable water quality standards;

•      Cause a film or "sheen" upon, or discoloration of, the surface of the water or adjoining
       shorelines; or
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       •      Cause a sludge or emulsion to be deposited beneath the surface of the water or upon
              adjoining shorelines.

       If there is such a discharge from a ship or the onshore facility that may reach waters or
       adjoining shorelines or land areas that may threaten waterways, your facility owner or operator
       must:

       (1)    Call the National Response Center at 1-800-424-8802 or 703-412-9810
              (Washington, D.C. area);

       (2)    Contact the nearest U.S. Coast Guard (USCG) or EPA regional office spill line;
              and

       (3)    Report the spill to the  state regulatory agency where the spill occurred.  Note:
              States and local government may have specific spill reporting requirements for facilities.
              For example, a facility may be required to report all spills meeting certain quantity
              thresholds, even if the spill does not leave a contained area within the facility.  Check
              with your  state and local regulatory agencies for their specific spill reporting
              requirements.

       In addition, the owner or operator of your facility must submit, in writing, certain information
       (including the SPCC Plan) to the EPA Regional Administrator within 60 days, if the release
       meets either of the following conditions: (1) either a single discharge of more than  1,000
       gallons of oil; or (2) two reportable spills/discharges of oil in harmful quantities, during any 12-
       month period, into or upon navigable waters, shorelines, etc.

       If your facility has an NPDES permit and the discharge causes your facility to be out of
       compliance with the permit requirements, then your facility must report the occurrence to your
       permitting agency  within 24 hours of becoming aware of a violation, and provide a written
       submission within  5 days.

Is all required information provided to the National Response Center?

       When your facility contacts the National Response Center (NRC), the
       center staff person  will ask for the following information:

       •      Your name, location, organization, and telephone number.
       •      Name and address of the party responsible for the incident.
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       •      Date and time of the incident.
       •      Location of the incident.
       •      Source and cause of the release or spill.
       •      Types of material(s) released or spilled.
       •      Quantity of materials released or spilled.
       •      Danger or threat posed by the release or spill.
       •      Number and types of injuries.
       •      Weather conditions at the incident location.
       •      Any other information that may help emergency personnel respond to the incident.

       The NRC records  and maintains all spill reports in a computer database called the Emergency
       Response Notification System (ERNS), which is available to the public
       (http://www.epa.gov/ERNS). The NRC relays the spill information to the EPA and USCG,
       depending on the location of the incident. Specifically, the NRC notifies representatives of
       EPA or the USCG, known as On-Scene Coordinators (OSCs).  The OSC is the federal
       official charged with directing a spill response through the Unified Command/Integrated
       Command System adopted by EPA and USCG. This intergovernmental coordinating system
       encourages, wherever possible, shared decision making by the federal lead response agency
       (EPA or USCG), the state(s) and the party responsible for the discharge/release.

Is the facility prepared for an effective response to an oil spill?

       The first and most immediate response to an oil spill is by your facility personnel. For this
       reason, facility response personnel must know the location, capabilities,  and operating
       instructions of response equipment to attempt an effective oil recovery. For more information,
       visit EPA's Oil Program at http://www.epa.gov/oilspill/.

              SPCC/FRP regulated facilities (or substantial harm facilities): Within the SPCC-
              regulated community, facilities that may cause substantial harm to the environment or
              exclusive economic zone, based on the quantity and location of their oil  storage, must
              prepare facility response plans (FRPs) to ensure that these facilities have the capability
              to response to worst case scenario discharges (40 CFR 112.20-21).  FRPs greatly
              assist the facility and response agencies to expedite and coordinate cleanup efforts.

       •      Other SPCC-regulated facilities: It is recommended that all other facilities in the
              SPCC-regulated community be prepared to respond to a spill by identifying control and
              response measures in their SPCC plans. Every facility should have appropriate spill
              response equipment available and easily accessible. A spill kit, which should be keep
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               close at hand, should contain absorbent pads and booms, disposal containers or bags,
               shovels, an emergency response guidebook, a fire extinguisher, and a portable pump.
               It is also recommended that facilities coordinate with local responders, other nearby
               facilities, and contractors before a spill occurs to ensure an efficient and effective
               response. Facility personnel, including seasonal employees, must participate in spill
               response, notification, and oil recovery training courses.  Being prepared to respond
               reduces the impact of a discharge on human health or the environment and minimizes
               cleanup costs and fines resulting from improper notification.

               First response: In the event of an oil spill, the response plan is immediately activated.
               The OSC will activate local, area, regional, or national plans depending on the nature of
               the spill and the response capability of the facility.

               On-scene coordinators: The designated OSC from EPA or USCG is responsible for
               determining how to respond to the spill, i.e., determining the resources, both personnel
               and equipment needed. The OSC does this based on his/her assessment of several
               factors, including the following: the magnitude and complexity of the spill; the availability
               of appropriate response equipment and trained personnel; and the ability of the
               responsible party, or local and/or state responders to respond to the spill.

               Although the OSC is responsible for coordinating federal efforts with local, state and
               regional response  efforts, in practice the role of the OSC varies.  Depending on the
               OSC's assessment, he/she may do the following: direct the response; direct the
               response in cooperation with other parties; oversee that the response is conducted by
               other parties; provide limited or periodic oversight; or determine that a federal response
               is not needed.

               For example, small spills may be cleaned up by the facility (or responsible party) or by
               local response agencies, while larger spills may require regional response efforts. In
               either cases, the OSC is required to oversee and monitor the spill response to make
               sure that all appropriate actions to prevent threats to human health or the environmental
               are taken.  If, however, a facility is handling a smaller spill adequately, the OSC  may
               not go to the site.

               Oil  recovery: For federal-led cleanups, the OSC, response teams, and a network of
               experienced agencies will decide on the most effective method of cleanup (see below).
               For potentially responsible part (PRP)-led cleanups,  cleanup efforts are carefully and
               efficiently coordinated to protect response personnel, recreational areas, drinking water
               reservoirs, and wildlife from the potentially catastrophic effects of an oil spill.
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lAlhat oil  recovery methods are used at the facility?
       There are a number of advanced response methods available for controlling oil spills and
       recovering oil while minimizing their impacts on human health and the environment (see
       http://www.epa.gov/oilspill/oiltech.htm). The key to effectively combating spills is careful
       selection and proper use of equipment and materials best suited to the type of oil and the
       conditions at the spill site. Most spill response equipment and materials are greatly affected by
       such factors as conditions at sea, water currents, and wind.

       Some kinds of response methods include:

       •      Mechanical containment or  recovery  is the primary line of defense against oil spills
              in the United States. Containment and recovery equipment includes a variety of booms,
              barriers,  and skimmers, as well as natural and synthetic sorbent materials. Mechanical
              containment is used to capture  and store the spilled oil until it can be disposed of
              properly.

       •      Chemical and biological methods can be used in conjunction with mechanical means
              for containing and cleaning up oil spills. Dispersants and gelling agents are most useful in
              helping to keep oil from reaching shorelines and other sensitive habitats. Biological
              agents have the potential to assist recovery in sensitive areas such as shorelines,
              marshes, and wetlands. Research into these technologies continues to improve oil spill
              cleanup.

       •      Natural processes such as evaporation, oxidation, and biodegradation can start the
              cleanup process, but are generally too slow to provide adequate environmental
              recovery.

       •      Physical methods, such as wiping with sorbent materials, pressure washing, and
              raking and bulldozing, can be used to assist the natural processes. Scare tactics are
              used to protect birds and animals by keeping them away from oil spill areas. Devices
              such as propane scare-cans, floating dummies, and helium-filled balloons are often
              used, particularly to keep away birds.
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               6.  PAINT REMOVAL AND DISPOSAL

       This section will address the removal and disposal of paints and other preservative coatings
       prior to metal cutting. Please note that in the context of ship scrapping, the removal of paints
       prior to cutting may, in certain circumstances, not be necessary. However, in those situations
       where it is necessary, there are specific requirements that must be followed. In addition, the
       removal of paints generates waste that must be managed and disposed of according to the
       appropriate solid waste and/or hazardous waste regulations.

6.1   INFORMATION ABOUT PAINTS AND PAINT REMOVAL

lAlhat types of paint and coatings are found on ships?

       Paint and preservative coatings can be found on both interior and exterior surfaces of a ship.
       Particularly on older ships, paint may be flammable or may contain toxic compounds, such as
       polychlorinated biphenyls (PCBs), heavy metals (e.g., lead, barium, cadmium, chromium, and
       zinc), and pesticides. Lead compounds, such as red lead tetraoxide (Pb3O4) and lead
       chromate, have been used extensively in marine paint.  In general, metal-based paints, some
       containing as much as 30 percent heavy metals, were intended to protect ship surfaces from
       corrosion due to exposure to the elements. Other paints containing pesticides, such as tributyl
       tin and organotin, have been used on the hulls of ships to prevent the buildup of sea organisms
       (e.g., bacteria, protozoa, barnacles, and algae).

lUIethods used to remove paints and coatings

       Paints and coatings are typically removed using one of these three methods:

             Chemical stripping. Chemical stripping basically involves using solvents, such as
             methyl ethyl ketone and  1,1,1-trichloroethane, to remove the paint or coating.
             Solvents, which may be toxic or flammable, can be sprayed, wiped, or brushed on the
             surface and then removed, along with the paint or coating, using rags or wipes. Wastes
             generated from chemical stripping include contaminated or spent solvent, solvent
             residue or sludge, solvent-contaminated wipes/rags, and waste paint.

       •      Abrasive  blasting. Using this method, paints and coatings are removed by blasting a
             surface with abrasives, such as copper slag, coal slag, steel grit, mineral grit, and steel
             shot.  Blasting generates large amounts of dust, abrasive waste, and paint chips.
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       •       Mechanical removal.  This involves the use of power tools or flame to remove paints
              and coatings. The use of power tools, such as grinders, wire brushes, sanders, chipping
              hammers, needle guns, rotary peening tools, and other impact tools, generates waste
              such as dust and paint chips. Flame can also be used to remove certain paints or
              hardened preservative coatings, however, it should not be used on greasy or soft
              preservative coatings, or paints containing PCBs (see box).

The human health and environmental impacts associated with removing  paints
   and coatings
                                                  Tip: Paints containing PCBs cannot be
                                                  removed with a torch or flame.  This is
                                                  considered open burning and is prohibited.
                                                  Only non-thermal methods can be used to
                                                  remove paints containing PCBs.
       Chemicals and solvents used in stripping
       paints or coatings emit volatile organic
       compounds (VOCs) and hazardous air
       pollutants (HAPs) to the atmosphere. Other
       removal methods (e.g., mechanical removal,
       abrasive blasting) generate dust, particulate
       matter, and emissions containing lead and
       other contaminants.  These pollutants are hazardous to human health, potentially causing acute
       and chronic toxic effects in workers and possibly causing cancers.  For example, lead can
       cause poisoning and long-term damage to the central nervous system. Though they can be
       absorbed and ingested, the main pathway of concern for these pollutants is inhalation.

       Wastes (e.g., blasting residue, paint chips) generated from paint removal can have negative
       impacts on the environment if they are not properly contained and disposed of. If not contained
       by engineering controls, lead and other compounds from the waste may be discharged into
       nearby surface waters or may contaminate the soil at a facility.

6.2   WHO REGULATES PAINT REMOVAL  AND DISPOSAL ACTIVITIES?

       The activities associated with the removal and disposal of paint and other coatings are regulated
       because of their potential to release toxic pollutants, thereby potentially endangering both
       human health and the environment.
                                                    Note: If paint contains PCBs, it may be
                                                    regulated under the Toxic Substances
                                                    Control Act (TSCA) at 40 CFR 761.
              EPA.  EPA regulates paint removal and
              disposal activities through the Clean Air
              Act (CAA) and the Resource
              Conservation and Recovery Act
              (RCRA). Facilities that emit regulated
              amounts of air pollutants must obtain the appropriate permit and comply with all
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              emissions requirements (40 CFR 50-99). Under RCRA's hazardous waste regulations
              (40 CFR 261-270), facilities that generate hazardous waste (e.g., paint chips containing
              heavy metals, spent solvents) must meet accumulation, manifesting, and recordkeeping
              requirements. Some of these are discussed in more detail in the next section.

       •      OSHA.  OSHA is responsible for ensuring that workers are not at risk or in danger
              when conducting surface preparation activities.  OSHA regulations include specific
              requirements or procedures for surface preparation activities, specifically to protect the
              health of workers (29 CFR 1915).  These and other worker safety requirements are
              described in the following section.

6.3  PAINT REMOVAL ACTIVITIES

lAlorker exposure limits

       During paint removal activities, your facility must ensure that workers are not exposed to any
       listed contaminant in excess of the permissible exposure limit (PEL) (20 CFR 1915 (Subpart
       Z)).  For lead, which is commonly found in paint, the PEL is 50 //g/m3 of air averaged over an
       eight-hour work day. The action level is 30 //g/m3 of air, also based on an eight-hour work
       day.  The action level triggers several requirements such as exposure monitoring, medical
       surveillance, and training and education (29 CFR 1915.1025).

       Your facility can control a worker's exposure by using engineering controls, work practices,
       and/or administrative controls. However, if exposure cannot be reduced to or below the PEL
       through the use of such control or practices, your facility must provide personal protective
       equipment including, but not limited to, respiratory protection.

LJave paints and  coatings been tested  to  determine if they are flammable?
       Before cutting a surface covered by a paint or
       preservative coating, your facility is required to
       know the flammability of that coating. If not
Is it highly flammable? Paints and
preservative coatings are considered
to be highly flammable when
       ,            c  -I-.  ,        ,   ,       (            scrapings burn with extreme rapidity
       known, your facility s competent person (see         f2g ^ ~ 1Q15 53 „..
       Section 6.3, Measures used to protect worker's
       health during paint removal activities, for definition)
       must conduct a test to determine the coating's
       flammability  [29 CFR 1915.53(b)].
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                       An inspector may review your facility's records to verify that tests
                       were conducted to determine if coatings were flammable.
LJighly flammable paints and coatings must be removed prior to metal cutting

       When paints and hardened preservative coatings are determined to be highly flammable, they
       must be removed from the area to be heated (i.e., cut) to prevent ignition. In the case of ship
       scrapping, these coatings may be burned away under controlled conditions. As a precaution,
       your facility must have all/2 inch or larger tire hose with a fog nozzle, which has been uncoiled
       and placed under pressure, available for instant use in the immediate vicinity [29 CFR
       1915.53(c)].

                       An inspector may verify that highly flammable coatings have  been
                       removed prior to cutting.

LJave paints and coatings  been tested to determine if they are toxic?

       Your facility may conduct tests to determine whether paints and coatings are toxic. If it
       chooses not to conduct such tests, your facility should assume that all paints and coatings are
       toxic. If testing is used to determine the presence and concentrations of toxic metals, it should
       consist of, but is not limited to, collecting random and representative bulk samples of suspect
       coatings. Samples should be analyzed in accordance with the Test Methods for Evaluating
       Solid Waste,  Physical and Chemical Methods (SW-846, 3rd Edition, U.S. Environmental
       Protection Agency, 1986) for the appropriate metal.

Demoving toxic paints and coatings in enclosed spaces

       If surfaces in  an enclosed space are covered with toxic paints and preservative coatings and will
       be cut, your facility must take one of the following actions [29 CFR 1915.53(d)(l)]:

             Strip all toxic paints and coatings for a distance of at least 4 inches (10 centimeters)
             from the area to be heated (i.e., cut); or
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              Ensure that, during the cutting, workers are protected by approved air line respirators.
              This requirement is discussed in more detail in Section 7. Metal Cutting and Metal
              Disposal.

[Measures used to protect worker health  during paint removal activities

       There are several measures that can be used to safeguard the health of employees exposed to
       solvents and chemicals used to prepare surfaces for cutting. These measures are not required
       under OSHA regulations for ship scrapping (they are required for shipbuilding and ship repair),
       however, they can be implemented by your ship scrapping facility as best management
       practices.

       When using stripping techniques to remove paints:

       •      For chemical paint and preservative removers. Workers should be protected
              against all skin contact during handling and application of these removers. Additionally,
              workers should be protected against eye injury by goggles or face shields using
              approved personal protective equipment (PPE) (29 CFR 1915.33).  When using
              chemical paint and preservative removers which contain volatile or toxic solvents (e.g.,
              benzol, acetone, amyl acetate) or are flammable, your facility should follow the
              provisions described below.

       •      For toxic solvents. When toxic solvents (e.g., benzol, acetone, amyl acetate) are
              used, your facility can completely enclose the area to prevent the escape of vapor into
              the working space.  Either natural ventilation or mechanical exhaust ventilation can be
              used to remove the vapor at the source and dilute the concentration of vapors in the
              working space to a concentration that is safe (i.e., below the PEL) for the entire work
              period. Workers should be protected against toxic vapors from these solvents by
              wearing approved respiratory protective equipment.  They should also be protected
              against exposure of skin and eyes to contact with toxic solvents and their vapors by
              suitable clothing and equipment (29 CFR 1915.32). If flammable solvents are used,
              your facility should also use the protective measures described below.

              For flammable liquids. If flammable liquids, including flammable solvents or
              removers, are used to remove coatings, your facility should take additional precautions.
              For example, your facility should provide ventilation so that the concentration of vapors
              is below 10 percent of their lower explosive limit. This concentration should be
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              determined and monitored by your
              facility's competent person.
              Additionally, your facility should keep
              scrapings and rags soaked with
              flammable solvents in a covered metal
              container; use only explosion proof
              lights; and keep fire extinguishing
              equipment immediately available in the
              work area (29 CFR 1915.36).

       When using abrasive blasting to
       remove paints:
        Who is a "competent person"?
        A competent person is a person who is
        capable of recognizing and evaluating worker
        exposure to hazardous substances or to
        other unsafe conditions and is capable of
        specifying the  necessary protection and
        precautions to take to ensure worker safety.
        Your facility may designate any person who
        meets the requirements found in 29 CFR
        1915.7 to be a competent person
        responsible  for performing testing in certain
        situations (29 CFR 1915.7).  The facility may
        use a Marine Chemist, or in some cases, a
        certified industrial hygienist to perform the
        same activities as a competent person.
       •      Equipment. When blasting, your
              facility should use equipment (e.g.,
              hoses and fittings) that meets the following requirements. Hoses should be of a type to
              prevent shocks from static electricity.  Hose lengths should be joined by metal couplings
              secured to the outside of the hose to avoid erosion and weakening of the couplings.
              Nozzles shall be attached to the hose by fittings that will prevent the nozzle from
              disengaging by accident, and nozzle attachments should be metal and fit onto the hose
              externally. A dead-man control at the nozzle should either provide direct cutoff or
              signal the operator to cut off the flow.  Your facility should frequently inspect hoses and
              all fittings used for abrasive blasting to ensure timely replacement before an unsafe
              amount of wear has occurred.

       •      Worker PPE. Your facility should protect workers (referred to as abrasive blasters)
              conducting blasting in enclosed spaces by hoods and air-fed respirators or by positive-
              pressure air helmets.  Abrasive blasters working in the open could use filter-type
              respirators when synthetic abrasives containing less than 1 percent free silica are being
              used. Workers  other than blasters, including machine tenders and the  abrasive
              recovery team, should use eye and respiratory protective equipment in areas where
              unsafe concentrations of abrasive materials and dusts are present [29 CFR
              1915.34(c)].

       When using  mechanical removers  to remove paints:

       •      Power tools. To protect against eye injuries, workers using power tools should be
              required to wear goggles or face shields. Portable electric tools should be grounded,
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              and portable rotating tools should be adequately guarded to protect all workers from
              flying missiles [29 CFR 1915.34(a)].
              facility should not allow
              hardened preservative
              coatings to be removed by
Flame removal. Your         T.   .,     ,  ....  .          ,.      . .     ,.
                             Tip: If your facility burns away flammable coatings,
                             it is required to have a 1.5 inch (3.75 centimeter) or
                             larger fire hose with a fog nozzle, which has been
                             uncoiled and placed under pressure, immediately
a     •     ,    ,              available for instant use [29 CFR 1915.53(c)l.
name in enclosed spaces
              unless workers exposed to
              the fumes are protected by
              air line respirators. Additionally, workers performing this operation in the open air, and
              those exposed to the resulting fumes, should be protected by fume filter type respirators
              [29CFR1915.34(b)].

                       An inspector may review surface preparation activities at the
                       facility to verify that measures are being taken to protect worker
                       health.

 A ir permit requirements

       Ship scrapping activities, including surface preparation, will generate air pollutants subject to
       regulation under the Clean Air Act (CAA). Specifically, the use of solvents to strip coatings
       may result in the release of volatile organic compounds and hazardous air pollutants to the
       atmosphere. Because small quantities of solvent are used overall, these emissions are not likely
       to be of sufficient magnitude to have appreciable ambient air quality impacts. Likewise, the use
       of grit blasting medium would generate particulate matter, most of which would be larger than
       10 microns and, thus, not regulated under the CAA. The regulated portion of the parti culate
       matter (i.e., smaller than 10 microns) is not likely to cause ambient air quality impacts.

       If your facility emits regulated amounts of air pollutants, your facility must obtain the appropriate
       operating or preconstruction permit and comply with all emissions requirements set forth in that
       permit. Contact EPA or your state or local air pollution control authority for more information
       about air permit requirements.

                       If a permit has been issued by EPA or the state or local air
                       pollution control authority, an inspector may evaluate the facility for
                       compliance with the specific permit conditions.

6.4   MANAGING AND DISPOSING OF PAINT REMOVAL WASTES
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       The removal of paints and coatings, regardless of the process used, will generate wastes that
       must be managed and disposed of. Your facility must implement procedures to ensure that all
       wastes are contained and stored in a manner that will prevent their release into the environment.

Qoes your facility have a  storm water permit?

       Your facility may be required to obtain a  I
       ^T .    , _. „     „.  ,     -_,...       The term storm water includes storm water
       National Pollutant Discharge Elimination     mnoff snow me|t mnoff and surface mnoff and
       System (NPDES) permit for its storm       drainage [40 CFR 122.26(b)(13)].
       water discharges. Typically, storm        L^^^^^^^^^^^^^^^^^^^^^^^H
       water discharge associated with
       industrial activity must be covered by an NPDES permit. The term "storm water discharge
       associated with industrial activity" means any discharge from a conveyance which is used for
       collecting and conveying storm water and is directly related to storage areas at an industrial
       facility.  There are 11 categories of facilities considered to be engaged in industrial activity as
       defined in 40 CFR 122.26; one of which includes ship scrapping facilities. Contact EPA or
       your state regulatory agency for more information regarding NPDES storm water permitting
       requirements.

                  An inspector may review your facility storm water permit to ensure that
                  your facility is meeting all of the requirements of that permit.
[Measures or controls used to prevent or minimize storm water pollution

       If your facility is required to obtain an NPDES storm water permit, it will likely be required to
       prepare and implement a storm water pollution prevention plan (SWPPP). Each plan is facility-
       specific because every facility is unique in its source, type and volume of contaminated storm
       water discharges.  Regardless of the variations, all plans must include several common
       elements, such as a map and site-specific considerations. Additional elements include:

       •  Facility size and location
       •  A description of the volume of storm water and pollutants that could potentially be
          discharged
       •  Hydrogeology
       •  Environmental setting of each facility
       •  Predicted flow of storm water discharges
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          Climate
       As part of your plan, your facility must address how it will develop and use general and specific
       measures and controls (e.g., best management practices) to prevent or minimize pollution from
       storm water. One such measure may be to prevent storm water from coming in contact with
       wastes, including paint removal wastes.

       Additionally, your facility's SWPPP must address how the facility will complete the following
       activities: develop a pollution prevention (P2) team; train employees; conduct inspections and
       evaluations; test outfalls; and perform recordkeeping.
                       An inspector may review your facility's SWPPP to ensure that it
                       addresses all of the required elements. He/she may also review
                       the waste storage area to ensure that your facility is taking
                       appropriate measures to prevent storm water from coming into
                       contact with wastes, including paint removal wastes.
 A re paint removal wastes hazardous?

       If your facility prepares surfaces for cutting, it is most
       likely generating hazardous waste, which is regulated
       under the Resource Conservation and Recovery Act
       (RCRA). Wastes that may be hazardous include
       contaminated or spent solvents; solvents that have
       become contaminated or have deteriorated due to
       improper storage or handling; solvent residues and
       sludges; solvent-contaminated rags; abrasive residues;
       and paint chips.
               Tip: Paint waste that contains
               PCBs may also be regulated as a
               TSCA waste under 40 CFR 761.
               Some states regulate PCBs
               under their state RCRA programs
               and may have their own waste
               code for PCBs (even though there
               is no federal TSCA or RCRA
               waste code for PCBs).
       To be considered "hazardous waste," materials must first meet EPA's definition of "solid
       waste."  Solid waste is discarded material, such as garbage, refuse, and sludge, and it can
       include solids, semisolids, liquids, or contained gaseous materials.  Solid wastes that meet the
       following criteria are considered hazardous and subject to RCRA regulations 40 CFR Part 261:

       •      Listed waste. Waste is considered hazardous if it appears on one of four lists of
              hazardous wastes published in 40 CFR 261 Subpart D. Currently, more than 400
              wastes are listed. Wastes are listed as hazardous because they are known to be
              harmful to human health and the environment when not properly managed. Even when
              properly managed, some listed wastes are so dangerous that they are called "acutely
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              hazardous wastes." Examples of acutely hazardous wastes include wastes generated
              from some pesticides that can be fatal to humans even in low doses.

              Characteristic waste. If waste does not appear on one of the hazardous waste lists, it
              still might be considered hazardous if it demonstrates one or more of the following
              characteristics:

              S      Ignitable:  Ignitable wastes can create fire under certain conditions (e.g.,
                     temperature, pressure) or are spontaneously combustible (40 CFR 261.21).
                     Examples include certain used paints, degreasers, oils and solvents.

              S      Corrosive:  Corrosive wastes are acids or bases that are capable of corroding
                     metal, such as storage tanks, containers, drums, and barrels (40 CFR 261.22).
                     Examples include rust removers, acid or alkaline cleaning fluids, and battery
                     acid.

              S      Reactive: Reactive wastes are unstable and explode or produce toxic fumes,
                     gases, and vapors when mixed with water (40 CFR 261.23). Examples
                     include lithium-sulfide batteries and explosives.

              S      Toxic:  Toxic wastes are harmful or fatal when ingested or absorbed, or leach
                     toxic chemicals into the  soil or groundwater when disposed of on land (40 CFR
                     261.24).   Examples include wastes that contain high concentrations of heavy
                     metals, such as cadmium, lead, or mercury.
                Determining toxicity: A facility can determine if its waste is toxic by having it tested
                using the Toxicity Characteristic Leaching Procedure (TCLP), or by process
                knowledge.  TCLP can be done at a local certified laboratory.  It is designed to
                replicate the leaching process and other effects that occur when wastes are buried in
                a typical municipal landfill.  If the waste contains any of the regulated contaminants at
                concentrations equal to or greater than the regulatory levels, then the waste exhibits
                the toxicity characteristic. Process knowledge is detailed information on wastes
                obtained from existing published or documented waste analysis data or studies
                conducted on hazardous wastes generated by similar processes. For example, EPA's
                lists of hazardous wastes in 40 CFR Part 261 (as discussed above) can be used as
                process knowledge.
If your facility generates hazardous waste, what is your generator category?
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       Determining your generator category. Your facility's hazardous waste generator category is
       determined by the amount of hazardous waste that it generates each month (40 CFR 261).
       There are three federal categories of hazardous waste generators:

       •      Conditionally exempt small quantity generator (CESQG). CESQGs generate
              <220 pounds (100 kg) of hazardous waste per month or <220 pounds of spill cleanup
              debris containing hazardous waste per month. CESQGs have no maximum on-site time
              limits for storage, but cannot accumulate more than 2,200 Ibs. (1,000 kg) of
              hazardous waste onsite. If a CESQG accumulates more than this amount, it becomes
              an SQG or LQG.

              Small quantity generator (SQG). SQGs generate >220 pounds (100 kg) and
              <2,200 pounds (1,000 kg) of hazardous waste per month or  >220 pounds and
              <2,200 pounds of spill cleanup debris containing hazardous waste per month. SQGs
              may  accumulate no more than 6,000 kg of hazardous waste in storage, which may be
              stored on site for no more than 180 days (or no more than 270 days if the
              treatment/disposal facility is more than 200 miles away). If an SQG accumulates more
              than the specified amount, it becomes an LQG.

              Large quantity generator (LQG). LQGs generate >2,200 pounds (1,000 kg) of
              hazardous waste per month or > 2,200 pounds of spill cleanup debris containing
              hazardous waste per month. LQGs may accumulate any amount of hazardous waste for
              no more than 90 days.
          Facilities that generate 2.2 pounds or less of acutely hazardous wastes per month are
          classified as CESQGs, whereas facilities that generate more than 2.2 pounds of acutely
          hazardous wastes per month are classified as LQGs.
       Adding waste quantities.  To determine which category applies to your facility, your facility
       must count all quantities of listed and characteristic hazardous wastes. This includes wastes that
       are, during a one month period: (1)
       generated and collected at your facility
       prior to treatment or disposal; and (2)
       packaged and transported off site.
       are measured in gallons, not pounds.  To
       approximate the number of pounds of
            Rough Guide
27 gallons (about half of a 55-gallon drum) of
                                                  waste with a density similar to water weighs
                                                  about 220 pounds (100 kg).
       Many hazardous wastes are liquids and
270 gallons of waste with a density similar
to water weighs about 2,200 Ibs (1,000 kg).
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       liquid your facility has, multiply the number of gallons by 8.3 (because a gallon of water weighs
       8.3 pounds and many liquids have a density similar to water).

       When adding up all the hazardous wastes generated, keep in mind that your facility does NOT
       have to count the following:

       •      Wastes that are left on the bottom of containers that have been emptied by conventional
              means (i.e., pouring or pumping) and where no more than 2.5 cm (1 inch) of residue
              remains in the bottom of the container or no more than 3 percent by weight of the total
              capacity of the container remains in the container if the container is less than or equal to
              110 gallons in size.

              Residues in the bottom of storage tanks, if the residue is not removed (i.e., residues left
              in the bottom of the storage container are not counted as long as they are not removed
              when the tank is refilled).

              Wastes that are reclaimed continuously on site without storing the waste prior to
              reclamation.

       •      Wastes that have already  counted once during the calendar month, and treated on site
              or reclaimed in some manner and used again.

       •      Wastes that are directly discharged to a municipal treatment plant or POTW without
              being stored or accumulated first.

       •      Waste oil that meets the criteria for used oil and is to be managed and handled as used
              oil (40 CFR 279).

              Scrap metal that is recycled [40 CFR 261.6(a)(3)].

If your facility is a CESQG, does it meet all applicable requirements?

       As a CESQG, your facility's requirements are quite simple. There are three basic hazardous
       waste management requirements that apply to CESQGs:

       •      Identify all hazardous and acutely hazardous wastes (40 CFR 262.11).  For help in
              identifying hazardous wastes, call EPA or your state regulatory agency;  a consultant; a
              licensed transporter; or the RCRA/UST, Superfund and EPCRA hotline at  703-412-
              9810 or 1-800-424-9346.
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                               An inspector may review your facility's waste
                               determinations and any analytical data.
              Do not generate more than 220 Ibs. (or 100 kg) per month of hazardous waste or more
              than 2.2 Ibs. (1 kg) per month of acutely hazardous waste (this includes any wastes
              your facility has shipped off  site for disposal during that month); and never store more
              than 2,200 Ibs. (1,000 kg) of hazardous waste or 2.2 Ibs. of acutely hazardous waste
              for any period of time.

                               An inspector may evaluate the total volume of waste on site
                               at the time of the
                               inspection and verify that  it is within the limits for your
                               facility's  generator category.

              Ensure proper disposal of your hazardous waste.  For CESQGs, proper treatment and
              disposal of hazardous wastes are fairly simple. It involves ensuring that the waste is
              shipped to one of the following facilities:

              -      A state or federally regulated hazardous waste management treatment, storage,
                     or disposal facility (if your facility's waste is hazardous).

                     A facility permitted, licensed, or registered by a state to manage municipal or
                     industrial solid waste.

                     A facility that uses, reuses or legitimately recycles the waste (or treats the waste
                     prior to use, reuse, or recycling).

              Self-transporting hazardous waste.  CESQGs are allowed to transport their own
              wastes to the treatment or storage facility, unlike SQGs and LQGs which are required
              to use a licensed, certified transporter.  While there are no specific RCRA  requirements
              for CESQGs who transport their own wastes, DOT requires all transporters of
              hazardous waste to comply with all applicable DOT regulations.  Specifically, DOT
              regulations require all transporters, including CESQGs, transporting hazardous waste
              that qualifies as DOT hazardous material  to comply with EPA hazardous waste
              transporter requirements see 40 CFR 263.
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       As a CESQG, your facility is not
       required by federal laws to train its
       employees on hazardous waste handling
       or emergency preparedness, however, it
       is strongly advised.
   Tip: Keep in mind that your employees
   responding to releases of hazardous substances
   and hazardous wastes are required to be trained
   under OSHA's Hazardous Waste Operations and
   Emergency Response (HAZWOPER)
   requirements see 29 CFR 1910.120.
       Your facility must comply with the above
       requirements to retain its CESQG status, and remain exempt from the more stringent hazardous
       waste regulations that apply to SQGs and LQGs.  Though not required, it is recommended that
       your facility follow the waste storage and handling requirements for SQGs to minimize the
       possibility of any leaks, spills,  or other releases that potentially could cause economic hardship
       to your facility.  States may have more stringent and/or different requirements, so contact your
       state hazardous waste agency for these requirements.
If your facility is an SQG or LQG, does it meet all applicable requirements?

       If your facility determines, based on the amount of waste generated, that it is an SQG or LQG,
       it must comply with a variety of requirements covering the storage and handling, treatment, and
       disposal of the hazardous waste, from generation to final disposal. These requirements include:

       •       Waste identification. As a generator, your facility must determine whether wastes are
              hazardous using the hazardous waste identification process (40 CFR 261). For
              assistance, call EPA or your state regulatory agency; a consultant; a licensed
              transporter; or the RCRA/UST,  Superfund and EPCRA hotline at 703-412-9810 or
              1-800-424-9346.
                               An inspector may review your facility's waste
                               determinations and any analytical data.
              EPA identification number.  An EPA hazardous waste generator identification
              number must be entered on all hazardous waste manifests (40 CFR 262.12). For
              assistance in obtaining a hazardous waste generator identification number (EPA form
              8700-12 "Notification of Hazardous Waste Activity"), your facility may contact EPA
              or the state regulatory agency.
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             Accumulation and storage limits. Onsite accumulation (storage) limits are based on
             the total weight of hazardous waste that can be accumulated at any time at your facility
             before it must be shipped off site (40 CFR 262.34).
                             An inspector may evaluate the total volume of waste on site
                             at the time of the inspection and verify that it is within the
                             limits for your facility's generator category (e.g., SQG or
                             LQG).
              Container management. Your facility can store hazardous waste in 55-gallon drums,
              tanks, or other suitable containers, and it must comply with rules intended to protect
              human health and the environment and reduce the likelihood of damages or injuries
              caused by leaks or spills (40 CFR 265).
                             An inspector may look at all hazardous waste on site noting
                             the size and type of containers, their condition, and whether
                             they are closed and protected from the weather. He/she may
                             check the labels on the containers for the words "hazardous
                             waste," and verify that the date information is complete on
                             the label.  The inspector may also check the containment for
                             cracks or leaks.
             Personnel training. Proper waste
             handling can save your facility money in
             waste treatment and disposal and in lost
             time due to employee illness or accidents.
             Your facility must train its employees on the
             procedures for properly handling
             hazardous waste, as well as on emergency
             procedures [40 CFR262.34(a)].  For
             LQGs, the training must be formalized and
             be completed by employees within six
             months of accepting a job involving the handling of hazardous waste, and your facility is
             required to provide annual review of the initial training.
                              An inspector may check personnel records to determine
                              when hazardous waste duties were assigned and if proper
                              training was provided by your facility.
            Keep in mind that employees who are
            responding to releases of hazardous
            substances or waste are also required
            to be trained under OSHA's Hazardous
            Waste Operations and Emergency
            Response (HAZWOPER) requirements
            see 29 CFR 1910.120, in addition to
            EPA's hazardous waste management
            training.
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              Contingency planning, emergency procedures, and accident prevention If an
              LQG, your facility is required to have a written contingency plan. If an SQG, your
              facility must have basic contingency procedures in place. Although a written
              contingency plan is not federally required for SQGs or CESQGs, it is strongly
              recommended.  It is also important to check with your state and local authorities for any
              additional contingency plan or emergency preparedness requirements (40 CFR 262).

                              An inspector may review your facility's  contingency plan or
                              basic contingency procedures, and ask about any incidents
                              requiring implementation  of the plan or procedures.

              Hazardous waste shipment labeling and placarding  When your facility prepares
              hazardous wastes for shipment, it must put the wastes in properly labeled containers
              that are appropriate  for transportation according to the DOT regulations (40 CFR
              262).

              Reporting and recordkeeping requirements Your facility is required to meet
              various reporting and recordkeeping requirements as part of your hazardous waste
              management activities. Reports include the following:

              S      Manifest form. The Uniform Hazardous Waste Manifest Form (EPA Form
                     8700-22) is  a multi-copy shipping document that reports the contents of your
                     shipment, the transport company used, and the treatment/disposal facility
                     receiving the wastes (40 CFR 262.20).  Your facility (i.e.,  the hazardous waste
                     generator), the transporter, and the treatment/disposal facility must each sign
                     this document and keep a copy. Your facility must keep the copy of the
                     manifest signed by all three parties on file for three years.

              S      Exception report. Exception reports document a missing return copy of the
                     hazardous waste manifest.  Your facility must maintain  copies  of exception
                     reports for three years.

              S      Biennial report.  If an LQG, your facility must submit a biennial report (EPA
                     8700-13 A) on March 1 of each even-numbered year to the appropriate EPA
                     or state regulatory agency (40 CFR 262.41).  Some states  impose this
                     requirement on SQGs. Your facility can obtain biennial report applications and
                     instructions from EPA or its state regulatory agency.
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              S      Land disposal restriction notification  Land disposal restrictions (LDRs)
                     are regulations prohibiting the disposal of hazardous waste on land without prior
                     treatment of the waste (40 CFR 268). Your facility is required to provide a
                     one-time notification about your wastes to the treatment or disposal facility
                     with the first shipment of waste off site, and keep a copy in your files.

              In addition to these reports, your facility is required by EPA to keep certain records on
              file to show that good housekeeping practices and monitoring are being performed.
              EPA requires that records be kept on file at your facility for three years (40 CFR
              262.40). These records include:

              S      Laboratory analyses and waste profile sheets for determining whether wastes
                     generated by your facility are hazardous.

              S      Copies of all hazardous waste manifests, land disposal restriction notification,
                     and exception reports.

              S      Copies of all Notification of Hazardous Activity forms submitted to and
                     received from the state or EPA.
                     For LQGs only, copies of: (1) all personnel training plans and documentation
                     that indicate employees have completed the required training; (2) the facility's
                     contingency plan; and (3) the facility's biennial report.

                              An inspector will most likely review all records including, but
                              not limited to, annual or biennial reports and manifests.
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        7.  METAL CUTTING  AND METAL  DISPOSAL

       During ship scrapping, the activities of metal cutting and scrap metal management present
       environmental as well as worker health and safety concerns.  The following sections present
       background information on metal cutting,  regulatory requirements to be met during metal
       cutting, and management options for metal scrap disposal.

7.1   INFORMATION ABOUT METAL  CUTTING AND METAL DISPOSAL

       This section provides a brief introduction  to the metal cutting process and the tools used to
       perform cutting, a description of the kinds of scrap metal generated, and a summary of the
       environmental impacts and worker safety  concerns relating to metal cutting activities.
lAlhat is metal cutting?

       Metal cutting is the process of cutting a ship apart for the recovery of materials, including
       several grades and types of scrap metal (see below). During ship scrapping, the upper decks
       (i.e., the superstructure) and systems of the ship are cut first, followed by the main deck and
       lower decks. As large parts of the ship are cut away, they are lifted by crane to the ground
       where they are further cut into the shapes and sizes required by buyer (e.g., smelter, scrap
       metal broker). As cutting continues and the weight of the structure is reduced, the remaining
       hulk floats higher exposing lower regions of the hull for cutting. Finally, the remaining portion of
       the hull is pulled ashore and cut into sections.
H
ow are metals cut?

    The metals on ships are typically cut using a
    variety of torches and mechanical cutters.
    Some of these are described below.
                                                 While not as common as torches or cutters,
                                                 some facilities employ the use of detonation
                                                 charges to cut ship hulls.
             Oxygen-fuel torches.  An oxygen-
             fuel torch is the tool of choice for cutting steel. It burns a wide variety of fuel (e.g.,
             acetylene, propane, butane, fuel gas, natural gas) and uses either oxygen (liquid or
             compressed) or liquid air as the oxidizer and "cutting gas" that serves to burn (oxidize)
             iron along the cut line. Oxygen-fuel torches operate with a flame temperature of
             3,500°- 4,000°F and flame velocities of 290 - 425 feet per second. Dozens of
             different styles of torches and torch tops are available depending on the type and supply
             pressure of the fuel and oxidizer, the thickness of the metal to be cut, and the
             environment where the work is done.  The cutting speed of these torches ranges from
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              17 to 26 inches per minute depending on the steel thickness, fuel, oxidizer, and torch
              tip.
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              Electric arc or plasma arc torches. These torches generate temperatures high
              enough to liquefy almost any metal by the discharge of electric arcs. A cutting gas,
              often air, is used to blow away the molten metal. Manual electric arc torches are much
              slower than oxygen-fuel torches, cutting at rates of no more than 10 inches per minute.

              Shears. Large industrial shears can quickly reduce large metal parts to small
              dimensions suitable for a remelting furnace with less labor than torch or saw cutting.
              There are dozens of sizes of stationary and mobile shears available. Large shears have
              cutting rates measured in tens of feet per minute. The thickness, toughness, and
              dimensions of the metal to be sheared, the required cutting rate, and the product
              dimensions are important for selecting the proper kind of shears for the job.

              Saws. Several kinds of electric power metal cutting saws are available, including those
              with circular and reciprocating blades.  Saws can be used only on nonferrous metals
              (see below).
lAlhat kinds of metal scrap are generated?
       Ship scrapping generates several grades and kinds of scrap metal, commonly called scrap
       species, that are bought and sold in scrap materials markets. The scrap markets can be
       broadly classified as those dealing in ferrous scrap and nonferrous scrap.

       •       Ferrous scrap. Ferrous scrap from ships comes from forgings and castings, shell
               plating, framing, deck plating and beams, bulkheads, pillars and girders, miscellaneous
               hull steel, foundations, and steel superstructures. In addition, some structural steel outfit,
               hull attachments, doors and hatches, deck outfit, steward's outfit, hull engineering items,
               piping, and miscellaneous machinery are ferrous scrap. Of these sources, the largest
               proportion is co-called "carbon steel," described in the scrap trade as No. 1 heavy
               melting scrap.
              Nonferrous scrap. While there are
              many kinds of nonferrous scrap, one of
              particular interest is copper-yielding
              scrap (i.e., cuprous scrap). Cuprous
                      ,. ,  ,         ,     „   ,     .       ship, they return a large fraction of the
               scrap, which has a number of subspecies,           .         ,..  . ..  .
               .  ,  '  ,                         ,       revenue because of their high value.
               includes bronze, brass, and various other
               copper alloys.
Know the Value of Cuprous Scrap:
While copper and copper alloys
represent a small fraction of the total
weight of the metals recovered from a
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       To be marketable, scrap metal typically has to meet certain standards, such as quality and
       specific dimensions, which a buyer (e.g., a smelter or scrap metal broker) imposes on a seller
       (i.e., a ship scrapping facility).
           An Example of a Buyer-Imposed Standard:  No. 1 heavy melting scrap, a ferrous
           scrap metal species, is dimensionally limited by the buyer to the size of the scrap
           receiver box  for the smelting furnace.
potential environmental impacts from metal cutting

       Ship scrapping will generate air
       pollutants subject to regulation
       under the Clean Air Act.
       Specifically, torch cutting will
       and some or all of the following
       materials as participates:
       manganese, nickel, chromium, iron,
       aluminum, asbestos, and lead. It
New technology to reduce air emissions: The use of
new technology may reduce air emissions from metal
cutting operations. The employment of FireJetŽ
torches, lasers, water-jets, explosives, and shears may
             .  ,           .   r-r-            produce fewer emissions from ship cutting than
       generate large amounts of fumes       conventional torches. To the extent that cold cutting
(e.g., water-jet cutting) is used, fumes from heated
metals will be reduced or even eliminated. The FireJetŽ
Torch produces fewer emissions than conventional
       will also initiate small fires when oil
       or sludge is ignited by the torch.
       These fires are usually short-lived, but may generate some intense black smoke.  The cutting
       torches themselves generate oxides of nitrogen (NOx) and sulfur (SOx), and the process of
       combustion produces carbon dioxide and carbon monoxide. In spite of these releases, air
       pollutants from metal cutting are not likely to have a major air quality impact.

       The improper storage or disposal of scrap metal and other waste generated from metal cutting
       (e.g., filings, shavings) may result in soil and/or water contamination, primarily from lead and
       other compounds. Specifically, if metal scrap and waste are not protected from exposure to
       storm water, then metal wastes and contaminants from the scrap will be carried to surface
       waters and contribute to water contamination.
lAlorker health and safety concerns during metal cutting
       One worker safety issue during metal cutting is exposure to air contaminants, including metal
       fumes, particulates, and smoke. These contaminants can have acute and chronic toxic effects
       on workers. For example, exposure to lead can cause poisoning and long-term damage to the
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       central nervous system. Although ingestion, and in some cases, absorption of these
       contaminants are possible, inhalation is the main pathway of concern.
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       OSHA has exposure limits for various air contaminants that are considered toxic. If
       instantaneous monitoring is not feasible, the ceiling is a 15-minute time-weighted average
       exposure, which must not be exceeded at any time over a working day.  For example, there is
       such an instantaneous standard for manganese compounds and manganese fumes. In both
       cases, the limit is 5 milligrams per cubic meter (mg/m3).  For other contaminants, the exposure
       limit must not exceed a substance-specific, 8-hour time-weighted average in any 8-hour work
       shift of a 40-hour work week.

       Examples of the maximum exposure limits (8-hour time-weighted average) for air contaminants
       potentially generated from torch cutting include the following:

                     Chromium metal                             1 mg/m3
                     Nickel                                      1 mg/m3
                     Particulates not otherwise regulated           15 mg/m3

       Additionally, there are similar requirements that apply to occupational exposure to lead and
       cadmium. Lead and cadmium emissions may be generated during the torch cutting of metals
       containing these materials.  The permissible exposure limit for lead is 50 //g/m3 averaged over
       an 8-hour work day. The action level is 30
            3, also based on an 8-hour work day. The
       action level triggers several requirements such      Nt°te: °fHA is ""sideling more
                   &&            M                  stringent exposure limits for chromium,
       as exposure monitoring, medical surveillance,
       training, and education (29 CFR 1915.1025).
       The permissible exposure limit for cadmium is
       five //g/m3 averaged over an 8-hour workday.
       The action level is 2.5 //g/m3 of air, based on
       an 8-hour work day.
nickel, and manganese fumes, which are
released in large amounts during torch
cutting. The new limits being considered
                   .3
are as low as 0.5 //g/m  and will be
difficult to meet with existing cutting
technology and ventilation practices.
7.2   WHO REGULATES METAL CUTTING AND METAL DISPOSAL
       ACTIVITIES?

       Regulations governing metal cutting activities are important for the protection of the
       environment, as well as worker safety. These regulations are intended to (1) reduce the amount
       of pollutants released into the environment through air emissions, wastewater, and soil
       contamination, and (2) protect workers performing metal cutting activities.

              EPA.  EPA is responsible for developing and enforcing regulations necessary to protect
              human health and the environment. EPA has regulatory oversight authority of metal
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              cutting activities under the following federal laws. Some of the requirements for these
              regulations will be presented in the following section.
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             S      Under the Clean Air Act (CAA), air pollutants from ship scrapping facilities are
                    subject to regulation. If emitted in regulated quantities, facilities will be required
                    to obtain operating or preconstruction permits (40 CFR 50-99).

             S      Under the Resource Conservation and Recovery Act (RCRA) hazardous
                    waste regulations (40 CFR 261-270), facilities that generate hazardous waste
                    (e.g., scrap metal that is not recycled) must meet waste accumulation,
                    manifesting, and recordkeeping requirements.

             S      Regulations under the Clean Water Act (CWA) require certain facilities to limit
                    the amount of pollutants in their storm water discharges, and obtain a National
                    Pollutant Discharge Elimination System (NPDES) permit (40 CFR 122.26).
                    These facilities will be required to develop and implement storm water pollution
                    prevention plans to prevent storm water from coming into contact with potential
                    contaminants.

       •      OSHA. OSHA is responsible for the health and safety of workers who perform metal
             cutting operations. OSFEA's regulations 29  CFR 1910 and 1915 include provisions to
             be followed by employers and workers regarding personal protective equipment, tools
             and equipment, and hot work being performed in the open air, as well as confined and
             enclosed spaces. These worker safety requirements will be described in more detail in
             the following sections.

7.3   METAL CUTTING PRACTICES AND PROCEDURES

7.3.1  Testing Required  Prior  to Hot Work

prior to any cutting activities, have preservative coatings  on surfaces been
   tested and removed if  required?

       For any surface covered by a preservative coating whose flammability is not known, your
       facility's competent person must test this coating prior to the surface being cut [29 CFR
       1915.53(b)]. Under certain circumstances, your facility may be required to remove highly
       flammable or toxic coatings on surfaces to be cut. Please see Section 6. Paint Removal and
       Disposal for more information.

LJave work areas been tested and certified as "Safe for Hot Work"?
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       If your facility is conducting metal cutting with torches, commonly called burning, it is
       performing what is considered by OSHA to be "hot work" [29 CFR 1915.1 l(b)]. Depending
       on the type of area where torch cutting will be conducted, your facility may have to test those
       areas prior to any work beginning.
              Hot work requiring testing by a Marine
              Chemist or a U.S. Coast Guard
              authorized person. If hot work is to be
              performed in certain confined or enclosed
              spaces or other dangerous atmospheres,
              boundaries of those spaces, or pipelines, your
              facility cannot  start the work until those
              areas have been tested and certified by a
              Marine Chemist or a U.S. Coast Guard
              authorized person as  "Safe for Hot Work."
              This includes areas that are:
                                             A Marine Chemist is a person
                                             who has a current Marine Chemist
                                             Certificate issued by the National
                                             Fire Protection Association.

                                             A U.S. Coast Guard authorized
                                             person is someone who meets
                                             certain requirements (found in
                                             Appendix B of 29 CFR 1915,
                                             Subpart B) for tank, cargo, and
                                             miscellaneous vessels.
              S       Within, on, or immediately adjacent to spaces that contain or have contained
                      combustible or flammable liquids or gases;

              S       Within, on, or immediately adjacent to fuel tanks that contain or previously
                      contained fuel; and

              S       On pipelines, heating coils, pump fittings or other accessories connected to
                      spaces that contain or previously contained fuel.
                                                    What are hot work permits?  Hot work
                                                    permits allow cutting torches and saws to be
                                                    used to dismantle the ship. The hot work
                                                    permits do not deal with environmental
                                                    concerns such as cutting through lead or
                                                    PCBs present in painted surfaces.
If a certain area is determined to be
safe for hot work by the Marine
Chemist or U.S. Coast Guard
authorized person, a certificate,
commonly called a hot work permit,
will be issued by that person for that
specific work area. Your facility
must post this certificate in the
immediate vicinity of the area while metal cutting is in progress, and keep it on file for at
least three months from the completion date of the operation for which the certificate
was issued.
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              Hot work requiring
              testing by a competent
              person. Hot work
              cannot be performed in
              or on the spaces or
              adjacent spaces or other
              dangerous atmospheres
              listed below until they
              have been tested by a
              competent person and
              determined to contain      ^^^^^^^^^^^^^^^^^^^^^^^^™
              concentrations of
              flammable vapors or gases less than 10 percent of the lower explosive limit:
Who is a competent person? A competent person is a
person who is capable of recognizing and evaluating worker
exposure to hazardous substances or to other unsafe
conditions and is capable of specifying the necessary
protection and precautions to take to ensure worker safety.
Your facility may designate any person who  meets the
competent person requirements to be responsible for
performing testing in certain situations (29 CFR 1915.7).
The facility may use a Marine Chemist, or in some cases,
a certified industrial hygienist to perform the same activities
as a competent person.
              S      Dry cargo holds;
              S      Bilges;
              S      Engine room and certain boiler spaces;
              S      Vessels or vessel sections; and
              S      Landside confined and enclosed spaces or other dangerous atmospheres.

              If vapor concentrations are found to be equal to or greater than 10 percent of the lower
              explosive limit, an area will be labeled "Not Safe for Hot Work" and ventilated until the
              limits are met [29 CFR 1915.14(b)].

7.3.2 Performing Metal Cutting

r\o workers wear appropriate personal protective equipment when metal
   cutting?

       Your facility must ensure that all workers performing any type of metal cutting are wearing
       suitable eye protective equipment (29 CFR 1915.153), as well as appropriate hand and body
       protection (29 CFR 1915.157). Workers performing metal cutting must not wear clothing
       impregnated or covered in full or in part with flammable or combustible materials (e.g., grease
       or oil).
       Metal cutting at your facility may produce noise levels in
       excess of 100 decibels (dBA). If workers are subjected
       over a constant period of time to sound exceeding certain
       levels (29 CFR 1910.95), your facility must use feasible
                        For acoustic measurements
                        of effects on humans, sound
                        levels are denoted as dBA.
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       administrative or engineering controls to reduce the noise. If these controls fail to reduce the
       noise, then your facility must supply workers with personal protective equipment.

equipment requirements when conducting gas or arc cutting

       Your facility must comply with certain requirements when cutting with torches that burn gas.
       These requirements apply to transporting, moving, and storing compressed gas cylinders;
       placing cylinders; the treatment of cylinders; using fuel gas; fuel gas and oxygen manifolds;
       hoses; torches; and pressure regulators [29 CFR 1915.55].

       Additionally, your facility must comply with certain requirements when arc cutting. These
       requirements apply to manual electrode holders; welding cables and connectors; ground returns
       and machine grounding; operation instructions; and shielding (29 CFR 1915.56).

A ir permit requirements

       Ship scrapping activities, including metal cutting, will generate air pollutants subject to regulation
       under the Clean Air Act. Specifically, torch cutting will generate large amounts of fumes and
       paniculate matter, including paniculate matter with a particle size of less than 10 microns
       (PM10), and will initiate small fires when oil or sludge is ignited by the torch. These fires are
       usually short-lived, but may generate some intense black smoke.

       If your facility emits regulated amounts of air pollutants, it must obtain the appropriate operating
       or preconstruction permit and comply with all emissions requirements set forth in that permit.
       Contact EPA or your state or local air pollution control authority for more information about air
       permit requirements.
                        An inspector may investigate any open burning activities at the
                        facility. In addition, if a permit has been issued by EPA or the state
                        or local regulatory agency, the inspector may evaluate the facility
                        for compliance with the specific permit conditions.
Is mechanical ventilation provided when metal cutting?

       In Open Areas:
       In open areas, workers at your facility
       can normally perform general metal
       cutting without mechanical ventilation or
   Even in open areas, it is recommended that air
   sampling be conducted to ensure that there is no
   exposure to workers during metal cutting.
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       respiratory protective equipment, provided that (1) it is not done in confined or enclosed spaces
       and (2) metals containing or coated with toxic materials are not being cut [29 CFR 1915.51(f)].
       If, however, unusual physical or atmospheric conditions, such as confined spaces, result in the
       unsafe accumulation of contaminants, your facility must provide workers with suitable
       mechanical ventilation or respiratory protective equipment [29 CFR 1915.51(f)].

       Mechanical ventilation can consist of either a general mechanical ventilation system or a local
       exhaust system [29 CFR 1915.51(b)].

              General mechanical ventilation must have sufficient capacity and provide the
              number of air changes necessary to maintain fumes and smoke within safe limits.

              Local exhaust ventilation must have freely movable hoods that can be placed as
              close as practicable by the metal cutter to the work.  This system must have sufficient
              capacity and be arranged so as to remove fumes and smoke at the cutting site and keep
              the concentrations in the breathing zone within safe limits.
       In Confined Spaces:
       While not common, metal cutting may
       have to be performed in a confined
       space during scrapping activities. If this
       occurs, your facility must provide one
       ,.,„,.,     ...               or aggravate a hazardous exposure.
       kind of mechanical ventilation
What is a confined space? A confined space is
a compartment of small size and limited access
(e.g., double bottom tank, cofferdam) which by its
small size and confined nature can readily create
       described above and must provide the
       required means of access to the space
       for workers. There must be more than one way to access the confined space (unless the
       arrangement of the space makes this impractical), and if the ventilation ducts must pass through
       these means of access, they must be arranged so as to allow workers to freely pass through at
       least two of these means of access [29 CFR 1915.76(b)(l)-(2)].

       If sufficient ventilation is not possible without blocking the means of access, workers must use
       air line respirators and a worker outside of the confined space must maintain communication
       with those working within and aid them in an emergency [29 CFR 1915.51(c)].

                         An inspector may verify that appropriate mechanical ventilation is
                         provided for workers, if required, during metal cutting.
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Is the proper mechanical ventilation or respiratory protection used when
 cutting certain metals?

       Within Enclosed Spaces:
                                               What is an enclosed space?  An enclosed
                                               space is any space, other than a confined
                                               space, which is enclosed by bulkheads and
                                               overhead. This includes cargo holds, tanks,
                                               quarters, and machinery and boiler spaces.
While also not a common ship scrapping
activity, your workers may be required
to conduct metal cutting of certain
metals in enclosed spaces. These metals
may be described as containing or being
coated with toxic materials.  If cutting or
heating these metals in enclosed spaces,
your facility must provide workers with the appropriate kind of mechanical ventilation or
respiratory protection [29 CFR 1915.51(d)(l)-(2)] as presented below:

•      Workers must be provided with and use either general mechanical ventilation or
       local exhaust ventilation (described above) when cutting the following kinds of
       metals:
              S      Zinc-bearing base or filler metals or metals coated with zinc-bearing materials
              S      Lead based metals
              S      Cadmium-bearing filler materials
              S      Chromium-bearing metals or metals coated with chromium-bearing materials

              Workers must be provided with and use local exhaust ventilation or air line
              respirators  when cutting the following kinds of metals:
              S
              S

       In Open Air:
              Metals containing lead (other than as an impurity) or metals coated with lead-
              bearing materials
              Cadmium-bearing or cadmium-coated base materials
              Metals coated with mercury-bearing materials
       If your workers are cutting the same metals
       containing toxic materials described above in
       the open air, they must wear filter-type
       respirators [29 CFR 1915.51(d)(3)].
                                            Tip: Be sure to protect workers exposed to
                                            the smoke and fumes from these operations
                                            in the same manner as the worker(s)
                                            actually doing the work.
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       For Beryllium-Containing Base or Filler Metals:

       Your facility must provide workers with local exhaust ventilation and air line respirators
       regardless of whether this work is being performed in an enclosed space or in the open air
       [29CFR1915.51(d)(2)-(3)].

 A re hollow metal containers and structures cleaned, vented, or tested before
   cutting?

       For drums, containers, or hollow structures which have contained flammable substances, your
       facility must fill them with water or thoroughly clean them of such substances, and ventilate and
       test them prior to cutting. Your facility must provide a vent or opening in each drum, container,
       hollow structure, or jacketed vessel for the release of any pressure which may build up during
       heating.

       For structural voids such as skegs, bilge keels, fair waters, masts, booms, support stanchions,
       pipe stanchions or railings, your facility's competent person must inspect the object and, if
       necessary, test for the presence of flammable liquids or vapors and nonflammable liquids that
       could heat up and cause pressure (29 CFR 1915.54).
Cire prevention requirements
       Your facility must take the appropriate steps during metal cutting to prevent fires.  This can
       include moving objects to be cut to a safe location or taking all movable fire hazards away from
       the object to be cut.  If either of these is not possible, then your facility must take all steps
       possible to confine the heat, sparks, and slag, and to protect the immovable fire hazards from
       them [29 CFR 1915.52(a)(l)-(2)].

       The cutting of particular objects (e.g., tank shells, decks, overheads) may result in the direct
       penetration of sparks or heat transfer which can cause a fire in an adjacent compartment.  In
       these situations, the same precautions must be taken on the
       opposite side as are taken on the side where the cutting is being
       performed [29 CFR 1915.52(a)(3)].
       Additionally, your facility must eliminate the possibility of fire in       .    ,.
                 J  J         J                 t-      j              when they are
       confined spaces as a result of gas escaping through leaking or
       improperly closed torch valves. This can be done by positively
       shutting off the gas supply to the torch at some point outside the
          f   A       u       +u +   u •     +    A    u       +u      CFR1915.52(a)(4)].
       confined space whenever the torch is not used or whenever the
Tip: Open end fuel gas
and oxygen hoses must
be immediately removed
from confined spaces
disconnected from the
torch or other gas
consuming device [29
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       torch is left unattended for a substantial period of time (e.g., lunch hour). The torch and hose
       must be removed from the confined space overnight and at shift changes [29 CFR
       1915.52(a)(4)].

7.3.3  Managing Scrap Metal

Is all scrap metal recycled?

       If your facility recycles its "processed scrap metal," it does not have to manage this scrap
       according to the RCRA regulations [40 CFR 261.4 (a)(13)]. "Processed scrap metal"
       basically includes the hulls or other surfaces which are cut up during scrapping. Additionally, all
       other scrap metal (scrap metal that is not "processed scrap metal") onsite is classified by EPA
       as "hazardous waste that is recyclable," and if recycled, is not subject to RCRA regulations [40
       CFR261.6(a)(3)(ii)].
       Basically, this means that if your facility recycles
       all of its processed and other scrap metal, these
       materials are not subject to regulation under
       RCRA. Your facility can recycle scrap metal by
       selling it to a resmelting firm or scrap metal
       broker.
                Note: All scrap metal that is not
                recycled must be managed and
                disposed of according to the hazardous
                waste regulations (40 CFR 261-270).
Is recyclable metal recovered using shredders and separators?

       Recyclable metal that is intermixed with nonmetallic material can be recovered for reuse using
       shredders and separators.  For example, shipboard electric cables, when averaged over a
       whole ship, can range from 40% - 75% by weight copper. These cables are often shredded
       for the recovery of the copper by recyclers specializing in this process.
              Shredders. Shredders,
              of which hundreds of
              kinds are available,
              basically reduce the
              parts to a gravel-like
              mixture of metal
              particles and non-metal
              "fluff"
What is "fluff"?  Fluff is a term used in the recycling
trade for solid and liquid nonrecoverable nonmetallic
materials obtained during the ship scrapping process.
Fluff is  not salable. Because it may contain regulated
hazardous waste  (e.g., asbestos, PCBs, hydrocarbons),
must be managed and disposed of according to the
hazardous waste regulations (40 CFR 261-270).
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Metal Cutting and Metal Disposal

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              Separators. After shredding, the metals can then be separated from the fluff by several
              kinds of separators. These include, but are not limited to magnetic separators, air
              floatation separator columns, and shaker tables.

Is cable burning for copper recovery prohibited?

       For the recovery of copper wire, facilities burn cables to remove coverings. However, your
       facility should be aware that cable burning may be regulated by state or local open burning
       regulations. Additionally, cutting cable coverings containing PCBs and/or asbestos is
       considered open burning and is prohibited according to TSCA requirements (see Section 3.0)
       and asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP)
       requirements (see Section 2.0), respectively.

Is wastewater from metal cutting operations managed with bilge water?

       During metal cutting operations, water is used to extinguish small fires which may occur. Such
       water typically drains to the lower areas of the ship, commonly called bilge areas. All
       wastewater (i.e., bilge water) in these areas must be removed and disposed of according to the
       applicable regulations, as described in Section 4. Bilge and Ballast Water Removal.

Qoes your facility have a storm water permit?
       Your facility may be required to obtain a
       National Pollutant Discharge Elimination
       System (NPDES) permit for its storm
       water discharges.
The term "storm water" includes storm water
runoff, snow melt runoff, and surface runoff and
drainage [40 CFR 122.26(b)(13)].
       Typically, storm water discharge associated with industrial activity must be covered by an
       NPDES permit. The term "storm water discharge associated with industrial activity" means any
       discharge from a conveyance which is used for collecting and conveying storm water and is
       directly related to storage areas at an industrial facility. There are 11 categories of facilities
       considered to be engaged in industrial activity as defined in 40 CFR 122.26; one of which
       includes ship scrapping facilities. Contact EPA or your state regulatory agency for more
       information regarding NPDES storm water permitting requirements.

                       An inspector may review  your facility storm water permit to ensure
                       that your facility is meeting all of the requirements of that permit.

Measures or controls used to prevent or  minimize storm water pollution
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       If your facility is required to obtain an NPDES storm water permit, it will likely be required to
       prepare and implement a storm water pollution prevention plan (SWPPP). Each plan is facility-
       specific because every facility is unique in its source, type and volume of contaminated storm
       water discharges. Regardless of the variations, all plans must include several common
       elements, such as a map and site-specific considerations. Additional elements include:

              Facility size and location
              A description of the volume of storm water and pollutants that could potentially be
              discharged
       •      Hydrogeology
       •      Environmental setting of each facility
              Predicted flow of storm water discharges
       •      Climate

       As part of your plan, your facility must address how it will develop and use general and specific
       measures and controls (e.g., best management practices) to prevent or minimize pollution from
       storm water. One such measure may be to prevent storm water from coming in contact with
       wastes, including metal cutting wastes.

       Additionally, your facility's SWPPP must address how the facility will complete the following
       activities: develop  a pollution prevention (P2) team; train employees; conduct inspections and
       evaluations; test outfalls; and perform recordkeeping.

                        An inspector may review your facility's SWPPP to ensure that it
                        addresses all of the required elements.  He/she may also review
                        the waste storage area to ensure that your facility is taking
                        appropriate measures to prevent storm water from coming into
                        contact with wastes, including metal cutting wastes.
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                8.  REMOVAL AND DISPOSAL OF
              MISCELLANEOUS SHIP  MACHINERY

      During ship scrapping, there are many types of machinery that are removed from a ship. Some
      of this machinery may be sold for reuse or recycled as scrap. The following section presents
      background information on miscellaneous ship machinery, regulatory requirements applicable to
      the removal and disposal of this machinery, as well as options for recycling and reusing these
      components.

8.1   INFORMATION ABOUT MISCELLANEOUS SHIP MACHINERY
      This section provides a brief introduction to the kinds of miscellaneous ship machinery that are
      recovered during ship scrapping, and the possible environmental impacts and worker health and
      safety concerns during removal and disposal activities.

lAlhat is miscellaneous ship machinery and where is it found on a ship?

      Ship machinery consists of various components that are removed from a ship during the
      scrapping process.  These include, but not limited to, the following:
         Main propulsion; turbine drain and
         leakoff system
         Main reduction gears
         Main condenser
         Main air ejector
         Main circulating system
         Feed heaters
         Feed and condensate system
         Saltwater evaporator system
         Shafting, bearings, and stern tubes
         Propellers
         Miscellaneous shafting parts
         Lubrication oil system
         Miscellaneous engine oil tanks
         Cables/wires
         Fluff from wire/cable stripping
        Boilers including fuel oil burners and soot
        blowers
        Boiler draft system
        Air systems
        Automatic combustion system
        Stacks and uptakes
        Fuel oil service system
        Main steam piping
        Auxiliary stem piping
        Exhaust and escape piping
        Steam drain system
        Access systems
        Work shop, lifting, and handling gear
        Machinery space ventilation and fixtures
        Machinery space fixtures
        Miscellaneous instruments and gauges
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Tips for Regulatory Compliance
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    Removal and Disposal of
Miscellaneous Ship Machinery

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Tips for Regulatory Compliance             8-2               Miscellaneous Ship Machinery

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lAlhen are components removed during scrapping?
       Machinery components are typically removed throughout the scrapping process. During the
       preparation phase of scrapping, small articles and the propellers are removed which allows the
       hulk to be pulled into shallow water where scrapping usually takes place. As layers of the ship
       are cut, large reusable or recyclable components are removed as they become accessible.

lAlhat are potential worker health  and safety and environmental impacts from
    ship machinery removal and disposal?

       When removed from the ship, ship machinery components are typically handled in the shipyard,
       or what is commonly called the scrap yard. These components, which may be stripped of
       valuable materials and/or cut into smaller pieces, may contain or be contaminated with
       hazardous materials, including asbestos, polychlorinated biphenyls (PCBs), oils, and fuels.
       In the scrap yard, facilities should ensure that
       machinery components are being handled in
       such a manner as to prevent soil, surface water,
       and groundwater contamination. If improperly
       stored, residues and hazardous materials from
       ship machinery components may come in
       contact with rain water and cause soil and/or
       water contamination.
         Avoid lead contamination: Lead
         contamination of soil and groundwater has
         been found at ship scrapping facilities due
         to the improper handling and storage of
         ship components. Facilities should take
         extra measures to prevent this type of
         contamination from occurring at their site.
       Workers exposure to any hazardous materials in ship machinery may potentially have serious
       health effects. More information on specific impacts of asbestos, PCBs, and oils and fuels can
       be found in Sections 2, 3, and 5, respectively, of this guide.

8.2   WHO REGULATES THE REMOVAL AND DISPOSAL OF
       MISCELLANEOUS SHIP MACHINERY?

       Regulations governing the removal and disposal of miscellaneous ship machinery are important
       for the protection of the environment, as well as worker health and safety.  These regulations
       are intended to (1) reduce the amount of pollutants released into the environment through air
       emissions, wastewater, and soil contamination, and (2) protect workers performing machinery
       removal activities.

       •      EPA. EPA is responsible for developing and enforcing regulations necessary to protect
             human health and the environment. EPA has regulatory oversight authority of ship
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    Removal and Disposal of
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             machinery removal and disposal activities under the Clean Air Act (CAA), Resource
             Conservation and Recovery Act (RCRA), and the Clean Water Act (CWA). In
             addition, if ship machinery contains or is contaminated by PCBs, it or its components
             may be regulated under the Toxic Substances Control Act (TSCA). These
             requirements are described in more detail in this section and other sections of this guide.

       •      OSHA. OSHA is responsible for the health and safety of workers who perform ship
             machinery removal activities. OSHA regulations (29 CFR 1915) include provisions to
             control worker exposure to hazards encountered during ship machinery removal.
             These requirements are described in more detail in this section and other sections of this
             guide.

8.3   SHIP MACHINERY REMOVAL AND DISPOSAL ACTIVITIES

A re worker health and safety requirements met?

       Your facility must protect workers during ship machinery removal activities according to
       OSHA's Shipyard Industry standards (29 CFR 1915.1001) and General Industry standards
       (29 CFR 1910). These rules regulate general working conditions (e.g., housekeeping,
       illumination, first aid); the use of scaffolds, ladders, and other working surfaces; gear and
       equipment for rigging and materials handling; and tools and equipment. Additionally, if any
       machinery components contain or are covered with asbestos or PCBs, your facility must ensure
       that all workers are protected from exposure to these contaminants as required (see below).

A re asbestos requirements met during ship  machinery removal?

       Asbestos may be part of a machinery component or may be encountered by workers when
       removing and handling a machinery component. Regardless of its occurrence, your facility must
       comply with all applicable asbestos requirements, many of which are highlighted in Section  2.
       Asbestos Removal and Disposal.  For additional information on asbestos, please refer to the
       appropriate parts of Section 9. Resources.

A re PCB  requirements met during ship machinery removal?

       Like asbestos, PCBs may be found in a machinery component or may have contaminated a
       component.  For example, cable and chain anchor may contain PCB-laden materials. If found,
       your facility must comply with all applicable PCB requirements, many of which are highlighted
       in Section 3. Sampling, Removal, and Disposal of PolychlorinatedBiphenyls.  For
       additional information on PCBs, please refer to the appropriate parts of Section 9. Resources.
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A Guide for Ship Scrappers:                                      Removal and Disposal of
Tips for Regulatory Compliance             8-5               Miscellaneous Ship Machinery

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 A re oils/fuels removed from ship machinery components handled as required?

       Your facility may encounter for removal (1) machinery containing oils or fuels, or (2) machinery
       containing small compressors or engines which contain oils or fuels. Your facility must ensure
       that all oils/fuels found in machinery or machinery components are properly handled as
       described in Section 5. Oil and Fuel Removal. For additional information on oil removal,
       please refer to the appropriate parts of Section 9. Resources.

 A re paint removal and metal cutting requirements met during ship machinery
   removal?

       If paint removal and subsequent metal cutting are required to remove a machinery component,
       your facility must comply with all applicable requirements for these activities, some of which are
       presented in Section 6. Paint Removal and Disposal and Section 7. Metal Cutting and
       Metal Disposal. For additional information on these activities, please refer to the appropriate
       parts of Section 9. Resources.

Is machinery recycled or sold for reuse?

       Your facility may remove miscellaneous ship machinery that may be categorized as reusable or
       recyclable.
              Reuse. Reusable equipment and        _,.       , .       ,.     ,   .     .,  ,
                                                  Ship propulsion machinery that is certified
                                                  by a recognized organization, such as the
                                                  American Bureau of Shipping, can be
                                                  resold for use in other ships.
             components (e.g., compressors,
             electric motors) can be sold directly
             with little or no refurbishment by your
             facility. However, while there is a
             market for these components, it is
             presently not very active as many components recovered from ships are obsolete by
             current standards or can be obtained elsewhere either in better used condition or
             unused at a lower price.

             Recycle. A large portion of ship machinery is considered ferrous scrap, and can be
             sold to resmelters or recyclers.  In addition, some components, such as main
             generators, motors, and other electrical items, are high in copper content, making them
             intrinsically more valuable than merely ferrous materials.

Is recyclable metal recovered using  shredders and separators?
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       Recyclable metal that is intermixed with nonmetallic material can be recovered for reuse using
       shredders and separators.  For example, shipboard electric cables, when averaged over a
       whole ship, can range from 40% - 75% by weight copper. These cables are often shredded for
       the recovery of the copper by recyclers specializing in this process.

              Shredders. Shredders, of which hundreds of kinds are available, basically reduce the
              parts to a gravel-like mixture of metal particles and non-metal "fluff."

              Separators. After shredding, the metals can then be separated from the fluff by several
              kinds of separators. These include, but are not limited to magnetic separators, air
              floatation separator columns, and shaker tables.

Is cable burning for copper recovery prohibited?

       For the recovery of copper from electrical systems, facilities may burn cables to remove
       coverings. However, your facility should be aware that cable burning may be regulated by state
       or local open burning regulations. Additionally,  if these coverings contain PCBs and/or
       asbestos,  your facility is prohibited from burning the coverings according to TSCA
       requirements (see Section 3.0} and asbestos NESHAP requirements (see Section 2.0),
       respectively.

Qoes your facility have a storm water permit?

       Your facility may be required to obtain a
                                               The term "storm water" includes storm water
                                               runoff, snow melt runoff, and surface runoff and
                                               drainage [40 CFR 122.26(b)(13)].
National Pollutant Discharge Elimination
System (NPDES) permit for its storm
water discharges. Typically, storm
water discharge associated with
industrial activity must be covered by an NPDES permit.  The term "storm water discharge
associated with industrial activity" means any discharge from a conveyance which is used for
collecting and conveying storm water and is directly related to storage areas at an industrial
facility. There are 11 categories of facilities considered to be engaged in industrial activity as
defined in 40 CFR 122.26; one of which  includes ship scrapping facilities. Contact EPA or
your state regulatory agency for more information regarding NPDES storm water permitting
requirements.

                 An inspector may review your facility storm water permit to ensure
                 that your facility is meeting all of the requirements of that permit.
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Tips for Regulatory Compliance              8-7                Miscellaneous Ship Machinery

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[Measures or controls  used to prevent or minimize storm water pollution

       If your facility is required to obtain an NPDES storm water permit, it will likely be required to
       prepare and implement a storm water pollution prevention plan (SWPPP). Each plan is facility-
       specific because every facility is unique in its source, type and volume of contaminated storm
       water discharges.  Regardless of the variations, all plans must include several common
       elements, such as a map and site-specific considerations. Additional elements include:

              Facility size and location
       •      A description of the volume of storm water and pollutants that could potentially be
              discharged
              Hydrogeology
       •      Environmental setting of each facility
       •      Predicted flow of storm water discharges
       •      Climate

       As part of your plan, your facility must address how it will develop and use general and specific
       measures and controls (e.g., best management practices) to prevent or minimize pollution from
       storm water. One such measure may be to prevent storm water from coming in contact with
       wastes, including scrap metal and other wastes.

       Additionally, your facility's SWPPP must address how the facility will complete the following
       activities: develop a pollution prevention  (P2) team; train employees; conduct inspections and
       evaluations; test outfalls; and perform recordkeeping.

                       An inspector may review your facility's SWPPP to ensure that it
                       addresses all of the required elements. He/she may also review
                       the waste storage area to ensure that your facility is taking
                       appropriate measures to prevent storm water from coming into
                       contact with wastes, including scrap metal and other wastes.
A Guide for Ship Scrappers:                                        Removal and Disposal of
Tips for Regulatory Compliance              8-8                Miscellaneous Ship  Machinery

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                             9.  RESOURCES
9.1   CONTACT INFORMATION
9.1.1  EPA Headquarters and EPA Regional Offices

CPA Headquarters

      U.S. Environmental Protection Agency
      Attn: Federal Facilities Enforcement Office (2261 A)
       1200 Pennsylvania Ave. NW
      Washington, DC 20460
      Telephone: (202) 564-2461
      Fax: (202) 564-0069
      Website: http://www.epa.gov/fedfac/fflex.html

CPA Regional Offices
                              EPA Regional Office Information
          Region
          Address
   Telephone & Fax Numbers
          Web Address
             1
         (CT, MA,
        ME, NH, RI,
           VT)
Environmental Protection Agency
Region 1
One Congress Street Suite 1100
Boston, MA 02214-2023
Telephone: (617) 918-1111
Toll Free: (617)918-1809
Website: http://www.epa.gov/regionl/
        (NJ, NY, PR,
            VI)
Environmental Protection Agency
Region 2
290 Broadway
New York, NY 10007-1866
Telephone: (212) 637-3000
Fax: (212) 637-3526
Website: http://www.epa.gov/region2/
         (DC, DE,
        MD, PA, VA,
           WV)
Environmental Protection Agency
Region 3
1650 Arch Street
Philadelphia, PA 19103-2029
Telephone: (215) 814-5000
Toll free: (800) 438-2474
Fax: (215) 814-5103
Website: http://www.epa.gov/region3/
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                       Resources

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                                EPA Regional Office Information
           Region
           Address
    Telephone & Fax Numbers
          Web Address
         (AL, FL, GA,
         KY, MS, NC,
           SC, TN)
Environmental Protection Agency
Region 4
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, GA 30303-3104
Telephone: (404) 562-9900
Toll free: (800) 241-1754
Fax: (404) 562-8335
Website:http://www. epa.gov/region4/
         (IL, IN, MI,
        MN, OH, WI)
Environmental Protection Agency
Region 5
77 West Jackson Boulevard
Chicago, IL 60604-3507
Telephone: (312) 353-2000
Toll free: (800)621-8431
Fax:(312)353-1155
Website: http://www.epa.gov/region5/
              6
          (AR, LA,
        NM, OK, TX)
Environmental Protection Agency
Region 6
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
Telephone: (214) 665-2200
Toll free: (800) 887-6063
Fax: (214) 665-2146
Website:http://www. epa.gov/region6/
              7
         (IA, KS, MO,
             NE)
Environmental Protection Agency
Region 7
901 N. 5th Street
Kansas City, KS 66101
Telephone: (913) 551-7003
Toll free: (800) 223-0425
Fax: (913) 551-7467
Website: http://www.epa.gov/region7/
          (CO, MT,
         ND, SD, UT,
            WY)
Environmental Protection Agency
Region 8
999 18th Street Suite 500
Denver, CO 80202-2466
Telephone: (303) 312-6312
Toll free: (800) 227-8917
Fax:(303)312-7061
Website: http://www.epa.gov/region8/
         (AZ, CA, HI,
             NV)
Environmental Protection Agency
Region 9
75 Hawthorne Street
San Francisco, CA 94105
Telephone: (415) 744-1305
Fax: (415) 744-1070
Website: http://www.epa.gov/region9/
             10
         (AK, ID, OR,
            WA)
Environmental Protection Agency
Region 10
1200 6th Avenue
Seattle, WA 98101
Telephone: (206) 553-1200
Toll free: (800) 424-4372
Fax: (206) 553-6984
Website: http://www.epa.gov/regionlO/
9.1.2  OSHA Headquarters and OSHA Regional Offices
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                         Resources

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QSHA Headquarters
       U.S. Department of Labor
       Occupational Safety and Health Administration (OSHA)
       200 Constitution Avenue, N.W.
       Washington, D.C. 20210
       Telephone: 1-800-321-6742 (In case of emergency)
       Website: http://www.osha.gov
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QSHA Regional Offices
       OSHA regional offices as listed below can be contacted for additional information.  Additional
       contact information for area offices, which are located within each region, can be found at each
       regional office's website listed below or at http://spider.osha.gov/oshdir/. You may also visit
       OSHA's State Offices at the following website: http://www.osha.gov/oshdir/states.htm
                                OSHA Regional Office Information
         Region
          (Area
         Offices)
          Address
       Telephone & Fax Numbers
              Web Address
             1
         (CT, MA,
         ME, NH,
         RI, VT)
Occupational Safety and Health
Administration, Region 1
JFK Federal Building
Room E340
Boston, MA 02203
Telephone: (617) 565-9860
Fax: (617) 565-9827
Website: http://www.osha.gov/oshdir/r01.html
            2
         (NJ, NY,
         PR, VI)
Occupational Safety and Health
Administration, Region 2
201 Varick Street, Room 670
New York, NY 10014
Telephone: (212) 337-2378
Fax: (212) 337-2371
Website: http://www.osha.gov/oshdir/r02.html
         (DC, DE,
         MD, PA,
         VA, WV)
Occupational Safety and Health
Administration, Region 3
Gateway Building, Suite 2100
3535 Market Street
Philadelphia, PA 19104
Telephone: (215) 596-1201
Fax: (215) 596-4872
Website: http://www.osha.gov/oshdir/r03.html
            4
         (AL, FL,
         GA, KY,
         MS, NC,
         SC, TN)
Occupational Safety and Health
Administration, Region 4
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, GA 30303
Telephone: (404) 562-2300
Fax: (404) 562-2295
Website:
http://www.osha.gov/oshdir/r04.html
            5
          (IL, IN,
         MI, MN,
         OH, WI)
Occupational Safety and Health
Administration, Region 5
230 South Dearborn Street
Room 3244
Chicago, IL 60604
Telephone: (312) 353-2220
Fax: (312) 353-7774
Website: http://www.osha.gov/oshdir/r05.html
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                                Resources

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                                OSHA Regional Office Information
         Region
          (Area
         Offices)
         Address
       Telephone & Fax Numbers
              Web Address
            6
         (AR, LA,
         NM, OK,
           TX)
Occupational Safety and Health
Administration, Region 6
525 Griffin Street, Room 602
Dallas, TX 75202
Telephone: (214) 767-4731
Fax: (214) 767-4137
Website: http://www.osha.gov/oshdir/r06.html
            7
         (IA, KS,
         MO, NE)
Occupational Safety and Health
Administration, Region 7
City Center Square
1100 Main Street, Suite 800
Kansas City, MO 64105
Telephone: (816) 426-5861
Fax: (816) 426-2750
Website: http://www.osha.gov/oshdir/r07.html
         (CO, MT,
         ND, SD,
         UT, WY)
Occupational Safety and Health
Administration, Region 8
1999 Broadway, Suite 1690
Denver, CO 80202-5716
Telephone: (303) 844-1600
Fax: (303) 844-1616
Website: http://www.osha.gov/oshdir/r08.html
         (AZ, CA,
         HI, NV,
         and Guam
           and
         American
          Samoa)
Occupational Safety and Health
Administration, Region 9
71 Stevenson Street, Room 420
San Francisco, California 94105
Telephone:
(415) 975-4310
       (Main Public - 8 am - 4:30 pm Pacific)
(800) 475-4019
       (For Technical Assistance)
(800) 475-4020
       (For Complaints - Accidents/Fatalities)
(800) 475-4022
       (For Publication Requests)
Fax:(415)975-4319
Website: http://www.osha.gov/oshdir/r09.html
            10
         (AK, ID,
         OR, WA)
Occupational Safety and Health
Administration, Region 10
1111 Third Avenue, Suite 715
   Seattle, WA 98101-3212
Telephone: (206) 553-5930
Fax: (206) 553-6499
Website: http://www.osha.gov/oshdir/rlO.html
9.1.3  State and Local Contacts
Qtate Environmental Agencies
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                         9-5
                                Resources

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       Links to all state environmental agencies can be accessed at the Environmental Professional's
       Homepage at http://www.clay.net/.

Qtate Air Pollution Agencies: State and Territorial Air Pollution Administrators
   (STAPPA) and Association of Local Air Pollution Control Officials (ALAPCO)

       This website contains links to state government agency home pages and other state government
       resources and can be accessed at http://www.4cleanair.org/.
9.2   HOTLINES
       There are various sources your facility can contact to receive additional information and
       assistance regarding the requirements presented in this guide. Some of these hotlines and the
       related ship scrapping processes are listed below.
        For Help Relating to:
                    Call This Hotline:
       Asbestos Removal and
       Disposal
Asbestos Ombudsman Clearinghouse/Hotline
       Toll-free: (800) 368-5888
       Telephone: (703)305-5938 or 202-260-0490
       Fax: (703) 305-6462

       The Asbestos Ombudsman Clearinghouse/Hotline provides
       general information about asbestos to the public. Operated
       by EPA's Small Business Ombudsman's Office, it also
       assists small businesses in complying with EPA regulations.
       Asbestos Removal and
       Disposal

       Sampling, Removal and
       Disposal of PCBs

       Removal and Disposal of
       Misc. Ship Machinery
Toxic Substances Control Act (TSCA) Assistance
       Telephone: (202) 554-1404
       Fax: (202) 554-5603
       Email: tscahotline@epamail.epagov

       The EPA TSCA Hotline provides up-to-date technical
       assistance and information about programs implemented
       under TSCA. In addition, the Hotline provides a variety of
       documents, including Federal Register notices,  reports,
       informational brochures, and booklets. It can also provide
       referrals to specific sources of information. The  Hotline is
       a free service.
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        For Help Relating to:
                    Call This Hotline:
       Bilge and Ballast Water
       Removal

       Oil and Fuel Removal

       Removal and Disposal of
       Misc. Ship Machinery
EPA's Oil Spill Information Line
       To access the EPA's Oil Spill Program Information Line,
       call
       the RCRA/UST, Superfund and EPCRA Hotline (see
       below).

       To report an oil or hazardous substance release, call the
       National Response Center at (800) 424-8802 (see below).

       EPA's Oil Spill Program is designed to prevent oil spills, as
       well as prepare for and respond to any oil spill affecting the
       inland waters of the U.S.  The program is administered by
       EPA Headquarters and the 10 EPA Regions.
       Website: http://www.epagov/oilspill
       Bilge and Ballast
       Removal

       Oil and Fuel Removal

       Paint Removal and
       Disposal

       Removal and Disposal of
       Misc. Ship Machinery
RCRA/UST, Superfund and EPCRA Hotline
              Toll-free: (800) 424-9346
              Telephone: (703) 412-9810, (800)-535-7672 TDD
              line for the hearing-impaired, or (703) 412-3323
              TDD in the Washington DC area
              Fax: (703) 603-9234

This hotline provides information about the regulations and
programs implemented under RCRA, CERCLA (Superfund),
EPCRA/SARA Title III. This hotline also provides referrals for
documents related to these programs. Translation is available for
Spanish-speaking callers.
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For Help Relating to:
Bilge and Ballast
Removal

Oil and Fuel Removal

Removal and Disposal of
Misc. Ship Machinery














All processes

Call This Hotline:
National Response Center (NRC)
Toll-free: 1-800-424-8802
Telephone: 703-412-9810 (Washington, D.C. area)
Website: http://www.epa.gov/oilspill/NRC or
http://www.nrc.uscg.mil/

The National Response Center (NRC) is the federal
government's national communications center, which is
staffed 24 hours a day by U.S. Coast Guard officers and
marine science technicians. The NRC receives all reports
of releases involving hazardous substances and oil that
trigger the federal notification requirements under several
laws. It is the responsibility of the NRC staff to collect
available information on the size and nature of the release,
the facility or vessel involved, and the party(ies) responsible
for the release. The NRC relays the spill information to
the EPA and/or the U.S. Coast Guard (USCG), depending
on the location of the incident. The NRC records and
maintains all spill reports in a computer database called the
Emergency Response Notification System (ERNS), which
is available to the public.
OSHA Public Affairs
Telephone: 202-693-1999
9.3   ADDITIONAL CONTACTS AND RESOURCES

general Tools For Ship Scrapping Activities

       OSHA Expert Advisor Tools

              Hazard Awareness Advisor - (Public Test Version *)
              This is a powerful, interactive, expert software to identify hazards in General Industry
              workplaces. It can be accessed at http://www.osha.gov/oshasoft/hazexp.html. It is
              designed to help users, particularly small businesses, to identify and understand common
              occupational safety and health hazards in their work places. (*Note: Public Test
              Versions do not represent official OSHA policy).

              Once installed on your PC, it asks you about activities, practices, materials, equipment,
              and policies in your work places, and it asks follow-up questions based on your answers.
              From the users' answers, the Hazard Awareness Advisor draws inferences about the
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              hazards that are likely to be present.  It prepares a customized report that briefly
              describes the likely hazards and the OSHA standards which address those hazards.

              This Advisor is an introduction to hazard recognition. It is NOT able to identify ALL
              hazards. It is NOT a substitute for safety and health professionals. The system will NOT
              determine compliance with OSHA standards. It is intended for beginners not experts.

              SAFETY PAYS
              OSHAs "SAFETY PAYS" program is interactive software developed by OSHA to
              assist employers in assessing the impact of occupational injuries and illnesses (with Lost
              Work Days) on their profitability. It uses a company's profit margin, the AVERAGE
              costs of an injury or illness, and an indirect cost multiplier to project the amount of sales a
              company would need to generate in order to cover those costs. It  can be accessed at
              http://www.osha.gov/oshasoft/safetwb.html.

       OSHA Technical Advisor Tools

              Respiratory Protection Technical Advisor - (Public Test Version *)
              The purpose of this Advisor is to help you comply with the new OSHA respirator
              standard.  This  interactive online Advisor will instruct you on the proper selection of
              respiratory protection and the  development of change schedules for gas/vapor cartridges.
              It can be accessed at
              http://www.osha-slc.gov/SLTC/respiratory_advisor/change_schedule.html.  (*Note:
              Public Test Versions do not represent official OSHA policy).

 A sbestos Removal and Disposal

       EPA Asbestos Coordinators

       EPA has  asbestos coordinators, including TSCA and NESHAP coordinators, located in the
       regional offices. These coordinators (as of August 1999) are listed below.  For the most up-to-
       date listing, your facility should check EPA's asbestos website at
       http://www.epa.gov/asbestos/contacts.htm.
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                             EPA Asbestos Coordinator Information
         Region
TSCA Coordinator
   Information
NESHAP Coordinator
     Information
                    Jim Bryson
                           U.S. EPA, Region 1
                           One Congress Street
                           Suite 1100
                           Mailcode: CPT
                           Boston, MA 02214-2023
                           Telephone: (617) 918-1524
                           Fax: (617) 918-1505
                            Wayne Toland
                                   U.S. EPA, Region 1
                                   One Congress Street
                                   Suite 1100
                                   Mailcode: SEA
                                   Boston, MA 02214-2023
                                   Telephone: (617) 918-1852
                                   Fax:(617) 918-1810
                    Bob Fitzpatrick
                           U.S. EPA, Region 2
                           290 Broadway, 21st Floor
                           Mailcode: DECA/ACB
                           New York, NY 10007-1866
                           Telephone: (212) 637-4042
                           Fax: (212) 637-3998
                            Bob Fitzpatrick
                                   U.S. EPA, Region 2
                                   290 Broadway, 21st Floor
                                   Mailcode: DECA/ACB
                                   New York, NY 10007-1866
                                   Telephone: (212) 637-4042
                                   Fax: (212) 637-3998
                    Garry Sherman
                           U.S. EPA, Region 3
                           1650 Arch Street
                           Mailcode: 3WC32
                           Philadelphia, PA 19103
                           Telephone: (215) 814-5267
                           Fax:(215)814-3113
                            Garry Sherman
                                   U.S. EPA, Region 3
                                   1650 Arch Street
                                   Mailcode: 3WC32
                                   Philadelphia, PA 19103
                                   Telephone: (215) 814-5267
                                   Fax:(215)814-3113
                    Alfreda Freeman
                           U.S. EPA, Region 4
                           61 Forsyth Street SW
                           Mailcode: APTMD
                           Atlanta, GA 30303-8960
                           Telephone: (404) 562-8977
                           Fax: (404) 562-8972, 8973
                            Leia Richardson
                                   U.S. EPA, Region 4
                                   61 Forsyth Street SW
                                   Mailcode: 4APT-AEEB
                                   Atlanta, GA 30303-8960
                                   Telephone: (404) 562-9199
                                   Fax: (404) 562-9164
                    Phil King
                           U.S. EPA, Region 5
                           77 West Jackson Boulevard
                           Mailcode: DT-8 J
                           Chicago, IL 60604
                           Telephone: (312) 353-9062
                           Fax: (312) 353-4342
                            Rochelle  Marceillars
                                   U.S. EPA, Region 5
                                   77 West Jackson Boulevard
                                   Mailcode: AE-17 J
                                   Chicago, IL 60604
                                   Telephone: (312) 353-4370
                                   Fax:(312)353-8289
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                             EPA Asbestos Coordinator Information
         Region
        TSCA Coordinator
           Information
     NESHAP Coordinator
          Information
                    Neil Pflum
                           U.S. EPA, Region 6
                           1445 Ross Avenue Rm. 1200
                           Mailcode: 6T-ET
                           Dallas, TX 75202-2733
                           Telephone: (214) 655-2295
                           Fax: (214) 655-6762
                                    Elvia Evering
                                          U.S. EPA, Region 6
                                          1445 Ross Avenue Rm 1200
                                          Mailcode: 6EN-AT
                                          Dallas, TX 75202-2733
                                          Telephone: (214) 655-7575
                                          Fax: (214) 655-7446
                    Greg Crable
                           U.S. EPA, Region 7
                           901 N. 5th Street
                           Kansas City, KS 66101
                           Telephone: (913) 551-7391
                           Fax: (913) 551-7065
                                    Greg Crable
                                          U.S. EPA, Region 7
                                          901 N. 5th Street
                                          Kansas City, KS 66101
                                          Telephone: (913) 551-7391
                                          Fax: (913) 551-7065
                    Bob Vick
                           U.S. EPA, Region 8
                           999 18th Street, Suite 500
                           Mailcode: 8ENF-T
                           Denver, CO 80202-2466
                           Telephone: (303) 312-6204
                           Fax:(303)312-6409
                                    Bob Vick
                                          U.S. EPA, Region 8
                                          999 18th Street, Suite 500
                                          Mailcode: 8ENF-T
                                          Denver, CO 80202-2466
                                          Telephone: (303) 312-6204
                                          Fax: (303) 312-6409
                    Patricia Maravilla
                          U.S. EPA, Region 9
                          75 Hawthorne Street
                          Mailcode: CMD-4-2
                          San Francisco, CA 94105
                          Telephone: (415) 744-1122
                          Fax: (415) 744-1073
                                    Bob Trotter
                                          U.S. EPA, Region 9
                                          75 Hawthorne Street
                                          Mailcode: A-3-3
                                          San Francisco, CA 94105
                                          Telephone: (415) 744-1145
                                          Fax: (415) 744-1076
            10
Jayne Carlin
       U.S. EPA, Region 10
       1200 6th Avenue
       Mailcode: WCM-128
       Seattle, WA 98101
       Telephone: (206) 553-4762
       Fax: (206) 553-8509
Kathleen S. Johnson
       U.S. EPA, Region 10
       1200 6th Avenue
       Mailcode: OAQ-107
       Seattle, WA 98101
       Telephone:  (206) 553-1757
       Fax:(206)553-0110
       OSHA Expert Advisor Tool - The Asbestos Advisor 2.0
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       The Asbestos Advisor 2.0 is an interactive compliance assistance tool. It can be accessed at
       http://www.osha.gov/oshasoft/asbestos/. Once installed on your facility's computer, it can
       interview you (as the site supervisor) or your colleagues about buildings and worksites, and the
       kinds of tasks workers perform there. It will produce guidance on how the asbestos standard
       may apply to that work. Its guidance depends on your answers. This tool can provide general
       guidance, but may also be focused on a particular project. It provides pop-up definitions
       through "hypertext." Remember: This interactive expert program provides guidance, much as
       you would get from a pamphlet. It is NOT a substitute for the standards.

Campling, Removal and Disposal of PCBs

       EPA Regional PCB Coordinators

       Within each EPA Region, the EPA Regional Administrator has designated regional PCB
       coordinators to oversee the development of PCB efforts within each Region. A list of these
       coordinators, which is updated monthly, can be viewed at
       http://www.epa.gov/opptintr/pcb/coordin.htm.  The PCB coordinators, as of December 1999,
       are listed below.
                                EPA Regional PCB Coordinators
Region
1
2
3
4
Contact and
Kim Tisa
Abdi Mohamoud
Dave Greenlaw
John Brogard (Permits)
Ann Finnegan
Dan Kraft
Vivian Chin
Dorothy Zoledziowska
Scott Rice
Charlene Creamer
Stuart Perry
Craig Brown
Phone Number
(617) 918-1527
(617) 918-1858
(732) 906-6817
(212) 637-4162
(732) 906-6177
(732) 321-6669
(732) 906-6179
(732)906-6811
(304) 231-0501
(215) 814-2145
(404) 562-8980
(404) 562-8990
Fax Number
(617)918-0527
(732) 321-6788
(215)814-3114
(404) 562-8972
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                               EPA Regional PCB Coordinators
Region
5
6
7
8
9
10
Contact and Phone
Tony Martig
John Cornell
Priscilla Fonseca
Jean Greensley (Permit Writer)
Steve Johnson (Permit Writer)
Lou Roberts
Jim Sales (Permits)
Dave Phillippi
Gene Evans (Permit Writer)
James Callier (Permits)
Dan Bench
Francis Tran
Kim Le (Enforcement)
Max Weintraub
Christopher Rollins
Yosh Tokiwa
Dan Duncan
Cathy Massimino
Viccy Salazar
Number
(312)353-2291
(312) 886-6832
(312) 886-1334
(312)353-1171
(312) 886-1330
(214) 665-7579
(214) 665-6796
(913) 551-7395
(913) 551-7731
(913) 551-7646
(303) 312-6027
(303) 312-6036
(303) 312-6973
(415)744-1129
(415)744-1130
(415)744-1118
(206) 553-6693
(206) 553-4153
(206) 553-1060
Fax Number
(312)353-4788
(214) 665-7446
(913)551-7065
(303)312-6044
(303) 312-6409
(415) 744-1073
(206) 553-8509
Dilge and Ballast Water Removal
       EPA Headquarters and EPA Regional NPDES and Pretreatment
       Coordinators

       If your facility has questions regarding its NPDES permit requirements, contact the appropriate
       EPA permit regional contact. These contacts (as of October 1999) are listed below. For the
       most up-to-date listing, your facility should check EPA's website at
       http://www.epa.gov/owm/wm05000.htm#regions.

       In addition, EPA regional industrial pretreatment coordinators and state pretreatinent
       coordinators are available to assist you with questions regarding your pretreatment
       requirements. These coordinators (as of October 1999) are listed below.  For the most up-to-
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       date listing, your facility should check EPA's website at
       http://www.epa.gov/owm/permits/pretreat/ptregcon.htm.

       EPA Headquarters
       U.S. Environmental Protection Agency
       Pretreatment and Multimedia Branch
       Permits Division (MC4203)
       1200 Pennsylvania Avenue, NW
       Washington, DC 20460
       Telephone: (202) 260-1090
       Fax: (202) 260-1460
       Website: http://www.epa.gov/owm/
            EPA Regional NPDES Permit and Industrial Pretreatment Coordinators
         Regio
           n
  NPDES Permit Coordinator
          Information
                  Industrial Pretreatment Coordinator
                              Information
           1
Roger Janson
    617-918-1621
Fax: 617-918-1505
Justin (Jay) Pimpare
Joseph Canzano
                 U.S. EPA, Region 1
                 Water Quality Management Unit
                 One Congress Street Suite 1100
                 Boston, MA 02214-2023
                       (617) 918-1531
                       (617) 918-1763
                   Fax:(617)918-2064
U.S. EPA, Region 1
One Congress Street Suite 1100-CMU
Boston, MA 02214-2023
                 Walter Andrews
                   (212) 637-3880
                Fax: 212-637-3887
                 Virginia Wong
                 Phil Sweeney
                 Jacqueline Rios
                 Phil Sweeney         212-637-3873
                 Chief, Permits & Pretreatment
                 Section

                 U.S. EPA, Region 2
                 Water Programs Branch
                 290 Broadway, 21st Floor
                 New York, NY 10007
                       (212) 637-4241
                       (212) 637-3873
                       (212) 637-3859
                   Fax:(212)637-4211
                                  U.S. EPA, Region 2
                                  Water Compliance Branch
                                  290 Broadway, 20th Floor
                                  New York, NY 10007-1866
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             EPA Regional NPDES Permit and Industrial Pretreatment Coordinators
         Regio
           n
NPDES Permit Coordinator
        Information
Industrial Pretreatment Coordinator
            Information
                 Joseph Piotrowski     215-814-5730
                                  Fax: 215-814-2301

                 U.S. EPA, Region 3
                 Office for Watersheds
                 1650 Arch Street
                 Philadelphia, PA 19103
                                John Lovell
                                Steve Copeland
                        (215) 814-5790
                        (215) 814-5792
                   Fax: (215) 814-2302
                                U.S. EPA, Region 3
                                Office of Municipal Assistance
                                1650 Arch Street (3WP24)
                                Philadelphia, PA 19103-2029
                 Douglas Mundrick    404-562-9328
                                  Fax: 404-562-8692

                 U.S. EPA, Region 4
                 Surface Water Permits & Facilities
                 Branch
                 61 Forsyth Street SW
                 Atlanta, GA 30303-8960
                                Melinda Mallard Greene   (404) 562-9771
                                                   Fax: (404) 562-9729

                                U.S. EPA, Region 4
                                Atlanta Federal Center - 16th Floor
                                Water Permits & Enforcement Branch
                                61 Forsyth Street, SW
                                Atlanta, GA 30303-3415
                 Gene Chaiken
                 312-886-0120
              Fax: 312-886-7804
Matthew Gluckman
Cathy Scudieri
Carol Staniec
                 U.S. EPA, Region 5
                 NPDES Support & Technical
                    Assistance Branch
                 77 West Jackson Boulevard
                 Chicago, IL 60604-3507
    (312) 886-6089
    (312)353-2098
    (312) 886-1436
Fax: (312) 886-7804
                                U.S. EPA, Region 5
                                NPDES Support & Technical Assistance
                                Branch (WN-16J)
                                77 West Jackson Boulevard
                                Chicago, IL 60604-3507
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            EPA Regional NPDES Permit and Industrial Pretreatment Coordinators
        Regio
           n
  NPDES Permit Coordinator
          Information
Industrial Pretreatment Coordinator
            Information
           6
Jack V. Ferguson     214-665-7170
                Fax: 214-665-2191

U.S. EPA, Region 6
Permits Branch
1445 Ross Avenue
Dallas, TX 75202-2733
Lee Bohme
Mike Tillman
Al Hernandez
    (214) 665-7532
    (214) 665-7531
    (214) 665-7522
                                                             Fax: (214) 665-2191/665-6490

                                                  U.S. EPA, Region 6
                                                  NPDES Permits Branch (6WQ-PO)
                                                  1445 Ross Avenue
                                                  Dallas, TX 75202-2733

                                                  Bob Goodfellow         (214) 665-6632
                                                                     Fax: (214) 665-2168
                                                  U.S. EPA, Region 6
                                                  Water Enforcement Branch (6EN-WO)
                                                  1445 Ross Avenue
                                                  Dallas, Texas 75202-2733
                 Paul Marshall
                    913-551-7419
                Fax: 913-551-7765
Paul Marshall, P.E.
Mike Turvey
    (913) 551-7419
    (913) 551-7424
Fax:(913)551-7765
                 U.S. EPA, Region 7
                 NPDES, Facilities Management
                 Branch
                 726 Minnesota Avenue
                 Kansas City, KS 66101
                                 U.S. EPA, Region 7
                                 726 Minnesota Avenue
                                 Kansas City, KS 66101
                 Steve Tuber
                 Debrah Thomas
                    303-312-6260
                Fax: 303-312-7084

                    303-312-6373
                 Fax:303-312-7084
Curt McCormick
    (303) 312-6377
Fax: (303) 312-7084
                 U.S. EPA, Region 8
                 Water Program
                 999 18th Street, Suite 500
                 Denver, CO 80202-2413
U.S. EPA, Region 8
NPDES Branch (8P-W-P)
999 18th Street Suite 500
Denver, CO 80202-2466
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            EPA Regional NPDES Permit and Industrial Pretreatment Coordinators
        Regio
           n
  NPDES Permit Coordinator
          Information
                 Industrial Pretreatment Coordinator
                             Information
                 Terry Oda
                   415-744-2001
                Fax: 415-744-1235
                 U.S. EPA, Region 9
                 Standards and Permits Office
                 75 Hawthorne Street
                 San Francisco, CA 94105
                 Keith Silva              (415) 744-1907
                                    Fax: (415) 744-1235
                 U.S. EPA, Region 9
                 Clean Water Act Compliance Office
                 (WTR-7)
                 75 Hawthorne Street
                 San Francisco, CA 94105
          10
Bob Robichaud
   206-553-1448
Fax: 206-553-0165
                 U.S. EPA, Region 10
                 NPDES Permits Unit
                 1200 6th Avenue
                 Seattle, WA 98101
Sharon Wilson           (206)553-0325
           Fax: (206) 553-0165/553-1280

U.S. EPA, Region 10
NPDES Permits Unit (OW-130)
1200 6th Avenue
Seattle, WA 98101
Qil and Fuel Removal

       EPA Headquarters and EPA Regional SPCC/FRP Contacts and Spill Lines

       If your facility has questions regarding its SPCC/FRP requirements, contact the appropriate
       EPA regional contact. These contacts (as of October 1999) are listed below.  For the most up-
       to-date listings, your facility should check EPA's website at
       http://www.epa.gov/oilspill/sspcccont.htm.

       In the event of a discharge of oil, your facility should contact the appropriate EPA regional spill
       line listed below. For the most up-to-date listings, your facility should check EPA's website at
       http://www.epa.gov/oilspill/.
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       EPA Headquarters
       U.S. Environmental Protection Agency
       Director, Oil Program (5203 G)
       1200 Pennsylvania Avenue, NW
       Washington, DC 20460
       Telephone: (703) 603-8760

       U.S. Environmental Protection Agency
       Oil Spill Program
       1200 Pennsylvania Avenue, NW
       Washington, DC 20460
       Website: Http://www.epa.gov/oilspill

       U.S. Environmental Protection Agency
       Chemical Emergency Preparedness and Prevention Office
       1200 Pennsylvania Avenue, NW
       Washington, DC 20460
       Website: Http://www.epa.gov/swercepp
                      EPA Regional SPCC/FRP Contacts and Spill Lines
        Regio
           n
        SPCC/FRP Contact Information
 Spill Line
           1
SPCC/FRP Coordinator
c/o Emergency Response Section
U.S. EPA - Region I (HER)
1 Congress St., Suite 1100
Boston, MA 02114-2023
617-223-7265
                 SPCC Coordinator
                 U.S. EPA - Region II
                 2890 Woodbridge Ave.
                 Building 209, MS211
                 Edison, NJ 08837-3679
                                                     (732) 548-8730
                 SPCC Coordinator
                 U.S. EPA - Region III
                 1650 Arch St. (3HS32)
                 Philadelphia, PA 19103-2029
                                                     (215) 566-3255
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                      EPA Regional SPCC/FRP Contacts and Spill Lines
        Regio
           n
SPCC/FRP Contact Information
Spill Line
                 SPCC/FRP Coordinator
                 U.S. EPA - Region IV
                 61 Forsyth St.
                 Atlanta, GA 30365-3415
                                            (404) 562-8700
                 Oil Program Section Chief
                 U.S. EPA - Region V (SE5J)
                 77 W. Jackson Blvd.
                 Chicago, IL 60604-3590
                                            (312)353-2318
                 SPCC/FRP Coordinator
                 U.S. EPA - Region VI (6SF-RP)
                 1445 Ross Ave.
                 Dallas, TX 75202-2733
                                             (214) 665-222
                 Oil/SPCC Coordinator
                 U.S. EPA-Region VII
                 (SUPRER+R)
                 901 N. 5th Street.
                 Kansas City, KS 66101
                                            (913) 281-0991
                 Oil Program Coordinator
                 U.S. EPA - Region VIII (8EPR-SA)
                 999 18th St., Suite 500
                 Denver, CO 80202-2466
                                            (303)-293-1788
                 Oil Team/SPCC Coordinator
                 U.S. EPA - Region IX (SFD1-4)
                 75 Hawthorne St.
                 San Francisco, CA 94105
                                            (415) 744-2200
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                      EPA Regional SPCC/FRP Contacts and Spill Lines
        Regio
          n
        SPCC/FRP Contact Information
 Spill Line
          10
SPCC/FRP Coordinator
U.S. EPA-Region X
1200 6th Ave. (ECL-216)
Seattle, WA 98101

Alaska SPCC/FRP Coordinator
U.S. EPA - Alaska Operations Office
Federal Building/Room 537
222 West 7th Ave., #19
Anchorage, AK 99513-7588
(206) 553-1263
       EPA Regional Solid Waste and Hazardous Waste Programs

       For information about regional solid waste and hazardous waste programs, access
       http://www.epa.gov/epaoswer/osw/regi ons.htm#reg.
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Daint Removal and Disposal

      EPA Regional Solid Waste and Hazardous Waste Programs

      For information about regional solid waste and hazardous waste programs, access
      http://www.epa.gov/epaoswer/osw/regi ons.htm#reg.

      EPA Regional and State Water Programs

      For information about regional and state water programs, access
      http://www.epa.gov/ow/region.html.

Metal Cutting and Metal Disposal

      EPA Regional and State Water Programs

      For information about regional and state water programs, access
      http://www.epa.gov/ow/region.html.

Demoval and Disposal  of Miscellaneous Ship Machinery

      Please refer to the resources listed in the addition contacts and resource section in Section 9.3.

9.4  PUBLICATIONS AND INTERNET SITES

general

      Environmental Assessment of the Sale of National Defense Reserve Fleet Vessels for
      Scrapping.  The Maritime Administration, U.S. Department of Transportation. Report No.
      MA-ENV-820-96003. July 1997.

      Appendix A: The Legal Environment for Environmentally Compliant Ship
      Breaking/Recycling in the United States.  The Maritime Administration, U.S. Department of
      Transportation. Report No. MA-ENV-820-96003-A. July 1997.

      Appendix B: Substantive Law on Environmentally Compliant Ship Breaking/Recycling in
      the United States.  The Maritime Administration, U.S. Department of Transportation. Report
      No. MA-ENV-820-96003-B. July 1997.
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       Appendix C: Current and Advanced Technologies for the Ship Breaking/Recycling
       Industry.  The Maritime Administration, U.S. Department of Transportation.  Report No. MA-
       ENV-820-96003-C.  July 1997.

       Appendix D: Sampling and Analysis.  The Maritime Administration, U.S. Department of
       Transportation. Report No. MA-ENV-820-96003-D. July  1997.

       Appendix E: Survey of Ships and Materials.  The Maritime Administration, U.S. Department
       of Transportation. Report No. MA-ENV-820-96003-E. July 1997.

       Appendix F: The Markets, Cost and Benefits of Ship Breaking/Recycling in the United
       States.  The Maritime Administration, U.S. Department of Transportation. Report No. MA-
       ENV-820-96003-F. July 1997.

       Memo to Honorable John Glenn regarding ship scrapping. Prepared by U.S.  General
       Accounting Office, National Security and International Affairs Division. 1998

       Ship Scrapping Activities of the United States Government. The Subcommittee on Coast
       Guard and Maritime Transportation Hearing,  June 4,  1998.

       Report of the Interagency Panel on Ship Scrapping, April  1998.
       Http://www.denix.osd.mil/denix/Public/News/OSD/Ships/Final/fmal.html

       Multimedia Compliance Monitoring Investigation Protocol for the Ship Scrapping
       Industry, U.S. Environmental Protection Agency, National Enforcement Investigations Center,
       EPA-331/9-99-001, February 1999.

       The Yellow Book: Guide to Environmental Enforcement and Compliance at Federal
       Facilities, U.S. Environmental Protection Agency, Office of Enforcement and Compliance
       Assurance, EPA 315-B-98-011, February 1999.
 A sbestos Removal and Disposal
       A Guide to the Asbestos NESHAP, U.S. Environmental Protection Agency, Air and
       Radiation, EPA 340/1-90-015, Revised November 1990.

       Reporting and Recordkeeping Requirements for Waste Disposal - A Field Guide, U.S.
       Environmental Protection Agency, Air and Radiation, EPA 340/1-90-016, November 1990.
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      Asbestos/NESHAP Adequately Wet Guidance, U.S. Environmental Protection Agency, Air
      and Radiation, EPA 340/1-90-019, December 1990.

      Asbestos/NESHAP Regulated Asbestos Containing Materials Guidance, U.S.
      Environmental Protection Agency, Air and Radiation, EPA 340/1-90-018, December 1990.
      OSHA: Asbestos Standard for Construction (OSHA 3096), OSHA: Asbestos Standard for
      General Industry (OSHA 3095), and OSHA: Asbestos Standard for the Shipyard Employment
      Industry (OSHA 3145).

      Common Questions on the Asbestos NESHAP, U.S. Environmental Protection Agency, Air
      and Radiation, EPA 340/1-90-021, December 1990.

      Shipyard Industry, U.S. Department of Labor, Occupational Safety and Health
      Administration, OSHA 2268, 1998 (Revised).

      Multimedia Compliance Monitoring Investigation Protocol for the Ship Scrapping
      Industry, U.S. Environmental Protection Agency, National Enforcement Investigations Center,
      EPA-331/9-99-001, January 1999.

      OSHA Fact Sheet - Better Protection Against Asbestos in the Workplace (93-06), U.S.
      Department of Labor, Occupational Safety and Health Administration, 1/1/93.
      Http://www.osha-slc.gov/OshDoc/Fact_data/FSN093-06.html

      Inspection Procedures for Occupational Exposure to Asbestos Final Rule 29 CFR Parts
      1910.1001, 1926.1101, and 1915.1001, OSHA Directive CPL 2-2.63 (REVISED), U.S.
      Department of Labor,  Occupational Safety and Health Administration, 11/03/95.
      Http://www.osha-slc.gov/OshDoc/Directiv_data/CPL_2-2_63_REVISED_.html

      OSHA Web Site on Asbestos
      Http://www.osha-slc.gov/SLTC/asbestos/index.html

      Information on Asbestos
      Http://www.epa.gov/opptintr/asbestos/inforev.txt

      EPA Asbestos Materials Bans: Clarification, May 18, 1999
      Http://www.epa.gov/asbestos
Campling, Removal and Disposal of PCBs
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       EPA'sPCB Home Page.
       Http ://www. epa. gov/pcb/

       Office of Prevention, Pesticides and Toxic Substances Home Page
       Http://www.epa.gov/opptintr/

       1994 PCB Questions and Answers Manual
       Http://www. epa.gov/opptintr/pcb/manual.pdf

       Letter to MARAD from EPA, November 30, 1995. Includes Sampling Ships for PCBs
       Regulated for Disposal.
       EPA Fact Sheet. Final Rule: Amendments to the TSCA PCB Disposal Regulations
       Including Amendments to the PCB Notification and Manifesting Rule, June 1998. U.S.
       Environmental Protection Agency.
       Http://www.epa.gov/opptintr/pcb/pcbfs.pdf

       40 CFR Parts 750 and 761 - Disposal of Poly chlorinated Biphenyls (PCBs); Final Rule,
       Federal Register, June 29, 1998, Page 35383-35474.
       Http://www.epa.gov/opptintr/pcb/pcbdisp.txt
       Http ://www. epa.gov/opptintr/pcb/pcbdisp.pdf

       40 CFR 761 -Poly chlorinated Biphenyls (PCBs) Manufacturing, Processing,
       Distribution in Commerce, and Use Prohibition, Federal Register, July 1, 1998, Page
       495-637.
       Http ://www. epa.gov/opptintr/pcb/761 .txt or
       Http://www. epa.gov/opptintr/pcb/cfir3.pdf

       Technical and Procedural Amendments to TSCA Regulations—Disposal of
       Poly chlorinated Biphenyls (PCBs), Federal Register, June 24, 1999, Page 33755-33762.
       Http://www.epa.gov/opptintr/pcb/techcorr.txt or
       Http://www.epa.gov/opptintr/pcb/techcorrs.pdf

       1999 PCB Questions and Answers Manual - Part 1 of a 3-Part Document.
       Http://www.epa.gov/pcb/qaptl .pdf

       1999 PCB Questions and Answers Manual - Part 2 of a 3-P art Document.
       Http://www.epa.gov/pcb/qapt2.pdf
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        and Ballast Water Removal

       EPA's Office of Wastewater Management.
       Http://www. epa.gov/owm/

       Joint Service P2 Opportunity Handbook, Section 9. Wastewater.  Prepared by the Naval
       Facilities Engineering Service Center (NFESC), under the direction of the Office of the Chief of
       Naval Operations (CNO-N45) and the Naval Facilities Engineering Command (NAVFAC),
       the Air Force Center for Environmental Excellence (AFCEE), the Army Environmental Center
       (AEC), Headquarters Marine Corps (HQMC), the Defense Logistics Agency (DLA), and the
       Coast Guard (USCG).
       Http://enviro.nfesc.navy.mil/p21ibrary/section9.html

       Phase I.  Uniform National Discharge Standards for Vessels of The Armed Forces.
       Technical Development Document, Appendix A -Nature of Discharge Reports for
       Surface Vessel Bilgewater/Oil Water Separator Discharge; Clean Ballast; Compensated
       Fuel Ballast; and Dirty Ballast, U.S. Environmental Protection Agency, EPA 821-R-99-001.
       April 1999.
       Http://206.5.146.100/n45/doc/unds/fmrule/TDD/TDD.pdf

       Understanding Oil Spills and Oil Spill Response, U.S. Environmental Protection Agency,
       EPA 540-K-93-003, October 1993.

       Environmental Regulations and Technology: Managing Used Motor Oil, U.S.
       Environmental Protection Agency, EPA 625-R-94-010, December 1994.

       Oil Spill Program Compliance Assistance Guides, U.S. Environmental Protection Agency.
       Guides referenced include:
       S     Introduction and Background on the Oil Pollution Prevention Regulation
       S     Who's Who: Federal Agency Roles and Responsibilities for Oil Spill Prevention
             and Response
       S     What to Expect During an SPCC/FRP Inspection
       S     Facility Response Planning
       S     Sample SPCC Plan and Sample Containment Volume Calculations
       S     SPCC Requirements for Facilities Conducting Large Volume Transfer Operations
       S     Oil Spill Notification, Response, and Recovery
       Http://www. epa.gov/oilspill

       Office of Underground Storage Tanks Publications:
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       S     Financing Underground Storage Tank Work: Federal and State Assistance Programs,
             EPA-510-B-99-002, March 1999.
       S     Getting The Most Out Of Your Automatic Tank Gauging System,
             EPA-510-F-98-011, March 1998.
       S     List of Integrity Assessment Evaluations for Underground Storage Tanks -3rd Edition,
             January 22, 1999.
       S     List of Leak Detection Evaluations for UST Systems - 6th Edition, August 23, 1999.
       Http://www.epa.gov/swerustl/pubs/index.htm
Fuel and Oil Removal

       Understanding Oil Spills and Oil Spill Response., U.S. Environmental Protection Agency,
       EPA 540-K-93-003, October 1993.

       Environmental Regulations and Technology: Managing Used Motor Oil, U.S.
       Environmental Protection Agency, EPA 625-R-94-010, December 1994.

       Oil Spill Program Compliance Assistance Guides, U.S. Environmental Protection Agency.

       Guides referenced include:
       S     Introduction and Background on the Oil Pollution Prevention Regulation
       S      Who's Who: Federal Agency Roles and Responsibilities for Oil Spill Prevention
             and Response
       S      What to Expect During an SPCC/FRP Inspection
       S     Facility Response Planning
       S     Sample SPCC Plan and Sample Containment Volume Calculations
       S     SPCC Requirements for Facilities Conducting Large Volume Transfer Operations
       S     Oil Spill Notification, Response, and Recovery
       Http://www. epa.gov/oilspill

       U.S. Coast Guard - Marine Safety and Environmental Protection (Response Information)
       Http://www.uscg.mil/hq/g-m/nmc/response/index.htm

       EPA's Chemical Emergency Preparedness and Prevention Office
       Http ://www. epa. gov/swercepp

       Office of Underground Storage Tanks Publications:
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       S     Financing Underground Storage Tank Work: Federal and State Assistance Programs,
             EPA-510-B-99-002, March 1999.
       S     Getting The Most Out Of Your Automatic Tank Gauging System,
             EPA-510-F-98-011,  March 1998.
       S     List of Integrity Assessment Evaluations for Underground Storage Tanks -3rd Edition,
             January 22, 1999.
       S     List of Leak Detection Evaluations for UST Systems - 6th Edition, August 23, 1999.
       Http://www.epa.gov/swerustl/pubs/index.htm

       Tank Cleaning Process., OSHAweb document.
       Http://www. osha-slc.gov/SLTC/shipbuildingrepair/tankcleaning.html/

       Piskura, John R.  Oil and Hazardous Material Spills., Marine Environmental Engineering
       Handbook
Daint Removal and Disposal
       Profile of the Shipbuilding and Repair Industry., U. S. Environmental Protection Agency,
       EPA/310-R-97-008, November 1997.

       Draft Presumptive Maximum Achievable Control Technology for the Paint Stripping
       Operations Source Category. U.S. Environmental Protection Agency, Office of Air Quality
       Planning and Standards. January 1999.

       Bridges & Structures Q&A: Proposed Rulemaking Effort for OPPT's Bridges & Structures,
       Lead-based Paint Activities Rule: Frequently Asked Questions. U.S. Environmental Protection
       Agency.  June 1999.

       Pollution Prevention at Shipyards-A Northwest Industry Roundtable Report: Appendix
       C: Shipyard Best Management Practices.  Compiled by the Washington Department of
       Ecology.
       Http://www.pprc.org/pprc/sbap/shipyard

       The Paint and Coatings Resource Center
       Http://www.paintcenter.org

       EPA's Office of Wastewater Management.
       Http://www. epa.gov/owm/
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Metal Cutting and Disposal
      Appendix F: The Markets, Cost and Benefits of Ship Breaking/Recycling in the United
      States.  The Maritime Administration, U.S. Department of Transportation. Report No. MA-
      ENV-820-96003-F.  July 1997.

      Profile of the Shipbuilding and Repair Industry, U. S. Environmental Protection Agency,
      EPA/310-R-97-008, November 1997.

      International Scrap Directory, Worcester Park, Surrey, England: Metal Bulletin Books, Ltd.,
       1993.

      EPA's Office of Wastewater Management.
      Http://www. epa.gov/owm/

      The National Metal Finishing Center
      Http://www.nmfrc.org

Demoval and Disposal of Miscellaneous Ship Machinery

      Appendix F: The Markets, Cost and Benefits of Ship Breaking/Recycling in the United
      States.  The Maritime Administration, U.S. Department of Transportation. Report No. MA-
      ENV-820-96003-F.  July 1997.

      The Paint and Coatings Resource Center
      Http://www.paintcenter.org
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                                 APPENDIX A

              WHY THIS GUIDE WAS DEVELOPED

Decommendations of the Interagency Panel on Ship Scrapping

       This guide was developed in response to a recommendation in 1998 by the Interagency Panel
       on Ship Scrapping. This panel, which was formed in December 1997 by the Department of
       Defense, included representatives from EPA; the Defense Logistics Agency (DLA); and the
       Departments of State, Navy, Justice, Labor, and Transportation. The panel was convened in
       response to issues raised in a series in The Baltimore Sun newspaper about the poor
       environmental, health, and safety conditions in both domestic and overseas  scrapping facilities.

       The panel reviewed both domestic and international issues relating to the ship scrapping
       industry. These issues included, but were not limited to:

       •      U.S. Department of the Navy (Navy) and U.S. Maritime Administration (MARAD)
             programs for scrapping ships

       •      Processes and procedures in place for domestic as well as international  ship scrapping

             Information about the hazardous and toxic materials on scrapped ships

       •      Criteria used to evaluate contractor proposals and bids

             Oversight of ship scrapping contractor operations

       •      Export of non-liquid PCBs in vessels to be scrapped

       Based on this review, the panel developed a set of recommendations which were presented in
       the April 20, 1998 Report of the Interagency Panel on Ship Scrapping. The
       recommendations covered many aspects of the ship scrapping industry, including contracting
       improvements, performance bonds, data gathering and pilot projects, PCB  guidance, leveraging
       regulatory oversight, and international issues. The panel's report can be viewed in its entirety at
       http://www.denix.osd.mil/denix/Public/News/OSD/
       Ships/Final/fmal .html.
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       Under the category of leveraging regulatory oversight, the panel recommended that EPA and
       the Occupational Safety and Health Administration (OSHA), in conjunction with DLA, the
       Navy, and MARAD, develop this compliance guide.  The guide outlines the relevant
       environmental and occupational health and safety requirements applicable to ship scrapping.

fathering Stakeholder Input

       In the early stages of developing this guide, EPA requested input from various stakeholders,
       including ship scrappers and federal and state regulators,  regarding the scope, content, and
       format of the guide.  The following comments were provided:

       •       Stakeholders identified several processes that could be addressed in the guide because
              they pose the greatest challenges in compliance. These processes included PCB
              sampling and removal; asbestos identification and removal; contaminated wastewater;
              copper wire control procedures; and lead contamination (both at the site and by
              worker exposure).

              Stakeholders commented that they were not aware of any existing guidance, other than
              the regulations, for this industry. They currently obtain guidance from OSHA, EPA,
              state and local regulatory agencies, or the U.S.  Coast Guard (USCG) on an ad hoc
              basis.  Some noted that they rely on the regulations found in the CFR, while others are
              using information found on the Internet.

       •       Stakeholders identified training as a key requirement to enhance compliance.
              However, they noted that language is often a prominent obstacle when providing
              training because many workers are not fluent in English.

leading and Supporting Guide Development

       EPA's Federal Facilities Enforcement Office (FFEO) within the Office of Enforcement and
       Compliance Assurance and the Manufacturing, Energy and Transportation Division of EPA's
       Office of Compliance led the development of this compliance guide.  To assist in this process,
       EPA formed the Interagency Ship Scrapping Compliance Manual/Guide Workgroup, which
       included representatives from EPA, USCG, Navy, Defense Reutilization and Marketing
       Service (DRMS), OSHA, MARAD, National Enforcement Investigations Center (NEIC),
       National Oceanic and Atmospheric Administration (NOAA), and the DLA.

A.1   OVERVIEW OF SHIP SCRAPPING
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The Ship Scrapping Industry
       As part of the domestic ship scrapping industry, your facility is one of a small number of
       facilities that primarily dismantles or breaks ships, commonly called ship scrapping. Basically,
       when scrapping a ship, facilities are able to recover certain materials, mainly scrap steel, copper
       and other metals, that can be resold or recycled. Additionally, wastes are generated during
       scrapping that must be managed and disposed of according to the appropriate regulations.

       According to the North American Industry Classification System (NAICS) (see box below),
       facilities that conduct ship scrapping are classified in NAICS Code 48839 Other Support
       Activities for Water Transportation.  Previously, the Standard Industrial Classification (SIC)
       Code for facilities engaged in ship dismantling or ship breaking was 4499 Water
       Transportation Services, Not Elsewhere Classified.
                                 A New Industry Classification System
          In the United States, the NAICS replaces the SIC system. NAICS was developed jointly by
          the U.S., Canada, and Mexico to provide new comparability in statistics about business
          activity across North America. NAICS also provides for increased comparability with the
          International Standard Industrial Classification System (ISIC, Revision 3), developed and
          maintained by the United Nations. For more information on NAICS, access
          http://www.census.gov/epcd/www/naics.html.
       As mentioned above, the domestic ship scrapping industry has historically been and presently
       remains small. Currently, there are approximately four private ship scrappers in the United
       States, located in California, Maryland, Pennsylvania, and Texas, actively scrapping federal
       surplus ships.  The small size of this industry can partially be attributed to the risky nature of the
       work.  Ship scrapping is a labor-intensive industry with extremely high environmental and
       worker safety and health risks. Ship scrappers typically hire workers with a variety of skills
       and training, including welders, crane operators, forklift operators, sweepers, and loaders. At
       some facilities, it is common that supervisors are bilingual because some workers are not able
       to speak English

       Although ship scrapping can be done at a shipyard, it is more often conducted at less
       developed facilities.  Ship scrapping sites are typically less than 10 acres, are located in urban
       industrial  areas coincident with other industrial and maritime-related facilities, and require
       substantial electrical  services. Rail access to the sites is often available, although some
       scrapping is done in  areas serviced only by truck. Ship scrapping facilities usually work on one
       or two ships at a time, completing 2-3 ships per year.
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The Process of Ship Scrapping
       After removal from the fleet site, a ship is towed to the site where ship scrapping will occur.
       The ship is then scrapped while either moored, beached, or in drydock. Most ship scrapping is
       performed at slips, which are dredged openings in the bank of the ship channel.  Slips are
       generally 400 to 700 feet long and 100 to 120 feet wide at the entrance. A large winch at the
       head of the slip is used to drag the hull farther into the slip as work progresses.  The scrapping
       process usually occurs in a series of steps:

              Conduct a vessel survey. A diagram of all rooms, compartments, tanks, and storage
              areas is used (or prepared if not available) to identify areas that may contain hazardous
              materials, such as fuels, oils, asbestos, PCBs, and hazardous waste. Preliminary
              sampling of media is conducted, starting in the compartment that will be cut first.

       •      Remove fuels, oils, and other liquids.   The removal of fuels, oils, other liquids (e.g.,
              bilge and ballast water), and combustible materials from the ship generally occurs
              throughout the ship scrapping process. The U.S. Coast Guard requires booms around
              the ship to help contain any spills. Following removal activities, a marine chemist is
              contracted to certify that the ship is safe for workers or safe for hot work allowing the
              issuance of hot work permits. Hot work permits allow cutting torches and saws to be
              used to dismantle the ship.  During the ship scrapping process, water will continue to
              accumulate and will have to be removed.

       •      Remove equipment.  Fixtures, anchors, chains, and small equipment are removed
              initially. Large reusable components (e.g., engine parts) are removed as they become
              accessible. Reusable materials and equipment may be sold directly with little or no
              refurbishment by the scrapping facility. Propellers may also be removed so the hulk
              can be pulled into shallow water.

              Remove and dispose of asbestos and PCBs. Asbestos-containing material  (ACM)
              is removed from  cut lines so that large sections of the ship can be removed. The engine
              rooms usually contain the most asbestos and, therefore, take the longest for asbestos
              removal to be complete. PCB-containing materials that are accessible are removed, as
              well as PCB-containing materials from areas to be cut.  Some PCB-containing
              materials may be left in place on the room-sized pieces, only to be removed after the
              large piece is moved to shore.

              Prepare surfaces for cutting.  Following asbestos and PCB removal,  paint is
              removed, if required, from surfaces to be  cut.  The presence of hard-to-remove and
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              potentially toxic materials may require specific cut-line preparation, such as grit blasting.
              Cut metal. During the cutting phase, the upper decks and the superstructure and
              systems are first cut, followed by the main deck and lower decks. Metal cutting is
              typically done manually using oxygen-fuel cutting torches, but may be done with shears
              or saws (for nonferrous metals). Typically, as large parts of the ship are cut away, they
              are lifted by crane to the ground where they are cut to specific shapes and sizes
              required by the foundry or smelter to which the scrap is shipped. As cutting continues
              and the weight of the structure is reduced, the remaining hulk floats higher, exposing
              lower regions of the hull. Bilge water is sampled and discharged appropriately.
              Ultimately, the remaining portion of the hull is pulled ashore and cut.
              Recycle or dispose of materials  Scrap
              metals, including steel, aluminum, copper, copper
              nickel alloy, and lesser amounts of other metals,
              are sorted by grade and composition and sold to
              remelting firms or to scrap metal brokers.
              Valuable metals,  such as copper in electric cable,
              that are mixed with nonmetal material may be
              recovered using shredders and separators. The
              shredders produce a gravel-like mixture of metal
              particles and non-metal "fluff' (see box).  The
              metals are then separated from the fluff using
              magnetic separators, air flotation separator
              columns, or shaker tables.
                 What is "fluff"?  Fluff is a term
                 used in the recycling trade for
                 solid and liquid nonrecoverable,
                 nonmetallic materials obtained
                 during the ship scrapping
                 process.  Fluff is not salable.
                 Because it contains regulated
                 hazardous waste  (e.g.,
                 asbestos, PCBs,
                 hydrocarbons), it  must be
                 managed and disposed  of
                 according to the hazardous
                 waste regulations (40 CFR 261-
                 270).
              Other materials that are not recycled, including hazardous materials and other wastes,
              are disposed of according to applicable laws and regulations.

A.2  THE UNITED STATES SHIP SCRAPPING PROGRAM

       Currently, federal agencies have approximately 250 ships located throughout the United States
       awaiting scrapping or some other method of disposal (e.g., such as donating them to an
       organization or using them for experimental and training purposes).  The Navy and MARAD
       own the majority of these government ships.
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       Many of the vessels currently designated for scrapping were built in the 1940s, 1950s, and
       1960s using what was then state-of-the-art material in their construction. Many of these
       materials have since been classified as hazardous, including, but are not limited to, asbestos,
       PCBs, lead, chromates, mercury, and cadmium.  Recently, the U.S. Government ship
       scrapping program has come under criticism because some ship scrapping companies have
       violated environmental standards, worker health and safety regulations, and accepted ship
       scrapping practices.  Some instances of illegal dumping of asbestos, PCBs, oil, lead, and
       chromates, as well as dangerous working conditions, have been reported in the United States.

       MARAD is the U.S. Government disposal agent for surplus merchant-type ships of 1,500 tons
       or more.  To comply with the National Maritime Heritage Act (NMHA) of 1994, MARAD has
       to dispose of certain obsolete, surplus ships by September 30, 20013. In disposing of these
       ships, MARAD is required to maximize the financial return on the vessels to the United States,
       and comply with Section 510(1) of the Merchant Marine Act. To meet these objectives,
       MARAD is compelled to scrap the majority of these vessels because other alternatives, such as
       transferring the vessels for use as reefs or using the vessels for nontransportation uses,  are
       limited by MARAD's disposal authority.

       In the 1970s and early 1980s, the Navy scrapped hundreds of ships using private contractors.
       Navy ship scrapping was minimal throughout the 1980s because of the naval build up,  but
       increased in  1991 as part of military downsizing.  Historically, Navy ships have been sold for
       scrapping by its sales agent, the Defense Reutilization and Marketing Service (DRMS). As of
       May 1999, DRMS will no longer sell Navy ex-combatant ships for scrapping, but will,
       however, continue to administer the existing sales contracts for scrapping these ships. DRMS
       will continue to sell Navy service craft and boats for scrapping as appropriate.

       As of September 1999, the Navy had 63 ships designated for scrapping and MARAD
       reported having 113 ships available for scrapping.  Also, the U.S. Coast Guard (USCG) and
       NOAA reported having several ships available for  scrapping -14  and three, respectively.  The
       combined weight of the Navy and MARAD surplus ships is approximately  one million tons. If
       not scrapped, the storage, maintenance, and security of the surplus ships will cost the
       government approximately $58  million between fiscal years 1999 and 2003.  Some MARAD
       surplus ships are in very poor condition and may need repairs to  stay afloat. MARAD
       estimates that its  annual dry-docking and repair costs could be as high as $800,000 per ship.
       3 The date was changed from September 30, 1999, to September 30, 2001, by Section 1026 of the
National Defense Authorization Act of 1998, Public Law 105-85.
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       Scrapping Domestically Versus Internationally

       According to a 1997 MARAD study, the ship scrapping industry is a risky, highly speculative
       business, and domestic ship scrapping companies tend to be thinly capitalized.  Despite efforts
       by the Navy and MARAD to dispose of ships domestically, there appear to be only a few
       qualified domestic scrapping firms.

       In terms of international scrapping activity, the export of ships for scrapping from the United
       States to foreign countries has come under criticism in recent years.  The criticism mainly
       focuses on reports that some foreign  scrapping facilities are creating environmental problems
       due to the poor management of PCBs and other hazardous materials removed from ships, and
       they are risking the health and safety of their workers. In addition, foreign laws and regulations
       are viewed as poorly enforced.
       Historically, government-owned ships have
       been scrapped both domestically
       and overseas.  The Navy, as shown in Exhibit
       1, has relied mainly on the domestic industry to
       scrap its ships, while MARAD has relied
       primarily on overseas scrapping. The Navy has
       not sold any ships for overseas scrapping since
       1982. MARAD suspended overseas
       scrapping in 1994 in response to a 1993 EPA
       letter advising MARAD that exporting PCBs
       greater than 50 ppm for disposal was
       prohibited.
        Exhibit 1. Overseas Ship Scrapping by
                  Navy and MARAD
Timeframe
1970-1982
1983-1994
Since 1994
Number of ships scrapped
(% scrapped overseas)
Navy
533(10%)
35 (0%)
2 (0%)
MARAD
781 (38%)
213(>99%)
2 (0%)
        Source: April 20, 1998 Report of the Interagency
        Panel on Ship Scrapping
       Recognizing a need to reduce their backlog of surplus ships and the limitations of the domestic
       scrapping efforts, the Navy and MARAD each negotiated an agreement with EPA in 1997 to
       allow the export of ships for scrapping.  These agreements provided for:

       (1)    Removing all liquid PCBs prior to export.

       (2)    Removing all items containing solid PCBs that are readily removable when it does not
              affect the structural integrity of the ship prior to export.

       (3)    Notifying a country of a pending sale of a ship (which is being exported for scrapping
              from the United States) to one of its  ship scrapping companies.
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       Despite these agreements with EPA, the export of ships for scrapping was suspended by the
       Navy in December 1997 and MARAD in January 1998 because of continuing concerns about
       environmental pollution and worker health and safety, as well as potential impacts on the
       domestic ship scrapping industry.  These voluntary suspensions on ship exports are still in effect.

       Initiatives to Address Domestic Ship Scrapping Issues

       To improve the domestic ship scrapping process, the Navy and MARAD began instituting
       changes in their programs in 1996 to address management practices,  ship preparation
       processes, contracting processes, contractor oversight, and vessel exports.

       Changes to the Navy Program: According to the 1998 GAO report, the changes to the
       Navy's ship scrapping program included:

       •      Developing and implementing a two-step bid process requiring contractors to submit a
              technical proposal for approval before they can be considered viable candidates to
              place a financial bid for the surplus ships. The technical proposals are to consist of an
              environmental compliance plan, operational plan, business and management plan, and a
              safety and health plan.  A technical evaluation team will evaluate each plan and those
              contractors found to have  an acceptable proposal will be asked to submit a financial
              bid.

       •      Using quarterly progress reviews at each scrapping site to assess the contractor's
              progress and compliance with contract provisions, including environmental and safety
              requirements.

       •      Using a contractor rating system when deciding how closely to provide contract
              surveillance.

       •      Advertising and selling ships by lot and allowing contractors to remove the ships from
              government storage as they are ready to be scrapped.

              Holding periodic industry  workshops to inform contractors of what is expected of them
              in the scrapping of federal surplus ships and obtain feedback on their concerns and
              desires.

              Evaluating the potential for removing more hazardous materials before ships are
              advertised for sale.
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              Notifying state and local regulators where the ship scrapping will be performed after
              contracts are awarded.
                                                          Ensuring safe scrapping. Currently,
                                                          EPA is working with MARAD to
                                                          address issues related to permitting,
                                                          financial assurance, sampling of
                                                          potential PCB-containing materials
                                                          on vessels, and other issues to
                                                          ensure that, to the extent possible,
                                                          U.S. government vessels can be
                                                          safely scrapped in the domestic
                                                          market.
Changes to MARAD's program:  MARAD's
ship scrapping program is similar in material
respects, except that MARAD adopted a single
step bid process in which bidders are simultaneously
required to submit a bid and a technical compliance
plan.  Technical compliance plans consist of an
operations plan, a business plan, and an
environmental, health, and safety plan. MARAD
culls out all negative bids and reviews only the
technical compliance plans for those companies that
have provided positive bids.
       The Navy's 1999 Ship Disposal Project: On September 29, 1999, NAVSEA
       awarded 4 Indefinite Delivery, Indefinite Quantity (IDIQ) task order contracts for the disposal
       of conventionally-powered U.S. Navy warships that have been decommissioned and stricken
       from the Naval Vessel Register. These contracts represent the pilot phase of the Navy's Ship
       Disposal Project (SDP), a primary        	
       purpose of which is to obtain the cost
       data for dismantling ships in the United
       States, and to demonstrate
       environmentally-sound and cost-
       effective methods for dismantling the
       Navy's decommissioned vessels.
                                        "Disposal" includes the complete dismantling of
                                        the hull for recycling, and the proper removal and
                                        disposal of all hazardous materials that are part
                                        of the construction of these ships.
       These contracts are a significant departure from the sales contracting methodology previously
       used, under which purchasers paid the Government for the right to dismantle ships and to
       dispose of the hazardous wastes generated. The viability of ship dismantling under sales
       contracting depended on the metal value of the ship exceeding the costs of dismantling and
       hazardous waste disposal.  In contrast, the SDP contracts are cost plus incentive fee contracts
       with a performance incentive for environmental and safety compliance. Additionally, the SDP
       contractors will sell the scrap metal generated from dismantling the ships, and the proceeds will
       be credited to the cost of the contract.

       The contracts under this acquisition will provide the capability to scrap additional ships beyond
       the pilot phase. Based on the success of the pilot phase, the contract structure allows the Navy
       to compete additional task orders  among the current contract awardees for dismantling the
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                                      A-9
Appendix A

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       remaining inventory of decommissioned conventionally-powered cruisers, destroyers, frigates,
       and minesweepers that have been designated for scrapping. Additional information concerning
       the Ship Disposal Project can be found at http://www.contracts.hq.navsea.navy.mil/home.html.

A.3  REGULATING THE SHIP SCRAPPING INDUSTRY

Identifying Compliance Issues for the Ship Scrapping Industry

       In recent years, domestic ship scrappers have experienced difficulties in complying with various
       contractor performance provisions, including environmental and worker safety and health
       requirements. From 1991-1996, the Navy repossessed 20 of the 52 ships sold to domestic
       ship scrapping firms in North Carolina, Rhode Island, and California.  While changes in the
       economy contributed to these events, the repossessions were mainly the result of contractor
       performance issues and environmental and worker safety  and health compliance issues.

       Inspections conducted by EPA and OSHA have identified potential violations of applicable
       regulations and requirements.
                                                     As recommended by the Interagency
                                                     Panel on Ship Scrapping, EPA
                                                     developed the Multimedia Compliance
                                                     Monitoring Investigation Protocol for the
                                                     Ship Scrapping Industry (EPA-331/9-99-
                                                     001, February 1999) for conducting
                                                     environmental compliance inspections at
                                                     ship scrapping facilities.
EPA inspection findings  To develop a
protocol for conducting compliance
investigations at ship scrapping facilities
(see box), EPA and state health
inspectors participated in multimedia
compliance inspections of three ship
scrapping facilities from April 28-30,
1998.  These inspections, which were
intended to determine each facility's
compliance status, focused on PCB, asbestos, hazardous waste, storm water, and
SPCC plan requirements.

The following lists areas of potential problems or noncompliance found during the
inspections:

S      Improper waste management.  Several 55-gallon drums of mercury
       fluorescent bulbs were dated April 29, 1997.  If the drums contained more than
       100 kilograms of bulbs, they  are required to be disposed of within 180 or 270
       days depending on distance to a treatment/disposal facility.
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              S      Improper labeling.  Many containers of used oil stored onsite were not
                      marked with the words "Used Oil." Fuel tanks were not labeled.

              S      No plans/permits or failure to certify plans. Facilities were missing plans and
                      permits, including SPCC plans, NPDES permits, storm water permits, and
                      storm water pollution prevention plans. If the facilities did have the plans, they
                      were often out-of-date. One SPCC plan had not been signed by a registered
                      professional engineer.

              S      Lack of shower drain filters or leaking showers. Some shower drains used
                      by workers, did not appear to have filters.  These filters collect lead and
                      asbestos. One facility's shower water was leaking to the ground which may
                      add to lead contamination at the  site.

              S      Failure to understand requirements. One facility's operations manager did
                      not have any understanding of environmental requirements.

              S      Possible soil contamination. The soil throughout one facility may be
                      contaminated with lead and asbestos because the ground was covered with
                      pieces of cable, tiles, suspected ACM, metal, and paint chips. At another
                      facility, there were bulldozed piles at various locations potentially containing
                      hazardous materials (e.g., pieces of cable, suspected ACM).
                      Improper burnins of
                        ;,      ,              Cutting PCB-containing cable (or any material
                      cables.  Cables          contaminated with or containing PCBs) with a torch
                                              is considered open burning and is prohibited.
                                              Additionally, emissions from cable burning may be
                                              regulated by state or local laws.
appeared to have
been burned (i.e., cut
by torch) on sections
of a ship.
               OSHA inspection findings. While ship scrapping is a small industry, separate from
               the larger shipbuilding and ship repair industries, OSHA has inspected these ship
               scrapping operations and detected multiple violations of OSHA standards. For
               example, based on these inspections and other visits, a very common worker safety and
               health concern for this industry is insufficient worker training. Many ship scrapping
               facilities are deficient in providing overall worker training in areas, including, but not
               limited to, hazardous materials; personal protective equipment; proper storage, labeling,
               and marking of waste; and health and safety requirements in various work conditions
               (e.g., confined space, hot work, heights).
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Degulating Agencies
       Because ship scrapping is subject to federal, state, and local government rules and regulations
       for the protection of the environment and worker safety and health, your ship scrapping facility
       may be visited or inspected by representatives from various regulatory agencies. These can
       include, but are not limited to, EPA (including Headquarters, regional offices, and the National
       Enforcement Investigations Center (NEIC)), OSHA, DRMS, MARAD, state environmental
       regulatory offices, and state and local health departments.

       Environmental Protection  Agency (EPA)

       EPA has regulatory oversight with respect to the environmental aspects of domestic ship
       scrapping. Ship scrapping operations have become a concern for environmental regulators
       because they:

              Generate large amounts of waste, including asbestos and PCBs, that potentially pose
              significant environmental impacts if managed  poorly, and

       •      Have demonstrated difficulties in complying with the environmental regulations that are
              applicable to their operations.
       Your ship scrapping facility may be required to
       comply with various federal EPA laws and
       regulations. These include, but are not limited
       to:
Know your state regulations. State
regulations must be at least as strict as
the federal requirements.
              Air pollution control regulations under the Clean Air Act (CAA) (40 CFR 50-99),
              including the National Emission Standards for Hazardous Air Pollutants (NESHAP)(40
              CFR 61 SubpartM).

              Water pollution control regulations under the Clean Water Act (CWA), including the
              National Pollutant Discharge Elimination System (NPDES) and storm water permit
              requirements (40 CFR 122); pretreatment requirements (40 CFR 403); and
              requirements under EPA's Discharge of Oil regulation (40 CFR 110) and the Oil
              Pollution Prevention regulation (40 CFR 112).  As of December 1999, EPA had
              authorized 43 states and 1 territory to administer the NPDES permit.
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              Safe Drinking Water Act (SDWA) regulations, including Underground Injection
              Control (UIC) requirements and public water supply (PWS) requirements (40 CFR
              142 and 40 CFR 144-148).

              Solid and hazardous waste management requirements under the Resource Conservation
              and Recovery Act (RCRA), including land disposal restriction (LDR) requirements.
              RCRA provides a comprehensive program to protect human health and the
              environment from the improper management of hazardous waste. RCRA Subtitle C
              regulations establish a "cradle-to-grave" system governing hazardous waste from the
              point of generation to disposal (40 CFR 261-270). Used oil is regulated under the
              Used Oil Management Standards (40 CFR 279).  Although RCRA is a federal statute,
              many states implement the RCRA program.  Currently, EPA has delegated its authority
              to implement various provisions of RCRA to 47 of the 50 states and two U.S.
              territories.  Delegation has not been given to Alaska, Hawaii, or Iowa.

       •       Requirements for PCBs under the Toxic Substances Control Act (TSCA) regulations
              (40 CFR 761).

       •       Emergency Planning and Community Right-to-Know Act (EPCRA) regulations (40
              CFR 355 and 370).

       •       Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
              regulations (40 CFR 302).

       Occupational Safety and Health Administration (OSHA)

       OSHA's mission is to save lives, prevent injuries and protect the health of America's workers
       according to the rules and regulations of the Occupational Safety and Health Act (Act) of 1970.
       Under the Act, OSHA has promulgated standards that apply generally to all employers and
       standards that apply to specific industries.

       There are currently no geographical limitations to maritime jurisdiction on shore other than
       limitations of the Occupational Safety and Health Act itself. Employees performing maritime
       activities on shore, yard,  shipyard, vessels afloat, drydocks, or graving docks, are now covered
       by shipyard standards.

              General Industry Standards and the General Duty Clause  There  are General
              Industry Standards (29 CFR 1910) which apply to all employers, regardless of the type
              of industry. Additionally, because not every possible safety and health problem can be
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              covered by a workplace standard, the Occupational Safety and Health Act includes a
              "general duty" clause. This clause requires employers to furnish employment and a
              place of employment "free from recognized hazards that are causing or likely to cause
              death or serious physical harm" to employees.

              Shipyard Industry Standards.  To specifically address worker hazards at shipyards,
              OSHA developed safety and health standards called the Shipyard Industry standards
              (29 CFR 1915). Facilities affected by these standards include not only ship scrapping
              facilities, but also shipbuilding and ship repairing facilities, as they are all considered part
              of the shipyard industry. While some of the requirements in the Shipyard Industry
              standards apply to all three types of facilities, others apply only to shipbuilding and/or
              ship repair facilities.

              Because of this, ship scrappers must review the Shipyard Industry standards and
              become familiar with those that do apply to their facilities.  Some of these standards
              include, but are not limited to:

              S      Confined and enclosed spaces and other dangerous atmospheres (29 CFR
                      1915 SubpartB)

              S      Cutting and heating, including requirements for ventilation, fire prevention, and
                      working with preservative coatings (29 CFR 1915 Subpart D)

              S      Scaffolds or staging; ladders; access to vessels, dry docks, cargo spaces, and
                      confined spaces; and working surfaces (29 CFR 1915 Subpart E)

              S      General working conditions, such as housekeeping, illumination, utilities, health
                      and sanitation (29 CFR 1915 Subpart F)

              S      Gear and equipment for rigging and materials handling, including requirements
                      for inspections; ropes, chains, and slings; shackles and hook; chain falls and
                      pull-lifts; hoisting and hauling equipment; and operator qualifications (29 CFR
                      1915 Subpart G)

              S      Tools and equipment, such as hand tools, portable electric tools, abrasive
                      wheels, and internal combustion engines (29 CFR 1915 Subpart H)
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                     Personal protective equipment for the eyes, face, head, and body, including
                     respiratory protection, lifesaving equipment, personal fall arrest systems, and
                     positioning device systems (29 CFR 1915 Subpart I)
                                      Tip: Where a hazard is covered by both Shipyard Industry
Remember that hazards not
covered by the Shipyard            .  _     ..  .  .    ...     .  ..   0..     ....
                               and  General Industry standards, only the Shipyard Industry
Industry standards may be         ,   .   .  ....    .,  ..      ~OLJA •     *
      J             J           standard will be cited by an OSHA inspector.
covered by the General
Industry standards found in 29
CFR 1910.

•      Competent person.  Throughout many parts of the Shipyard Industry standards, tests
       and inspections are required to be performed by a marine chemist, a certified industrial
       hygienist, or some other "competent person." A competent person must be capable of
       recognizing and evaluating worker exposure to hazardous substances or to other unsafe
       conditions and specifying the necessary protection and precautions to take to ensure
       worker safety. Ship scrapping  facilities must have a person who meets the "competent
       person" requirements (found in 29 CFR 1915.7) for performing testing in certain
       situations.  The facility can also use a Marine Chemist to perform the same activities as
       a competent person. A Marine Chemist is a person who has a current Marine Chemist
       Certificate issued by the National Fire Protection Association.

•      State Safety and Health Programs. States administering their own occupational
       safety and health program through plans approved by OSHA [Section  18(b)] must
       adopt standards and enforce requirements that are at least as effective as federal
       requirements. Of the states with approved plans, only five (California, Minnesota,
       Oregon, Vermont, and Washington) include some coverage for workers at ship
       scrapping facilities. Otherwise, in all other states, these workers are subject to the
       federal OSHA requirements. For a more detailed summary of maritime coverage
       under particular state plans, see 29 CFR  1952 or access http://www.osha-
       slc.gov/fso.osp/index.

•      Maritime Advisory Committee Health Programs. Effective workplace
       management of safety and health issues greatly reduces worker deaths,  illnesses,
       injuries, and costs associated with them. According to The Maritime Advisory
       Committee for Occupational Safely and Health (MACOSH), all workplaces in the
       shipyard industry should have a safety and health program regardless of size or number
       of hazards [OSHA: Shipyard Industry (OSHA 2268) 1998 (Revised)].  The basic
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              elements listed below are essential for an effective workplace safety and health
              program:

              •      Employee Participation
              •      Training
                     Program Evaluation
              •      Recordkeeping
              •      Procedures for Multi-Employer Workplaces
              •      Management Commitment and Leadership
              •      Accident and Incident Investigation
              •      Hazard Identification, Assessment and Control

       These elements are performance-based and flexible enough to be adapted to workplace
       conditions, size and nature of hazards present. For more detailed information concerning these
       issues refer to OSHA: Shipyard Industry (OSHA 2268) publication.

       DRMS and MA RAD Contracts

       To monitor whether scrapping facilities
              ,•   ,,      •         r-,,  •          Historically, DRMS has been the Navy's sales
       are meeting the requirements or their              ,,   J'      ..    .   ,..    .'n „.-„,,.,,
                °      M                        agent for surp us ships. As of May 1999, DRMS
       current contracts, DRMS and MARAD
       may conduct unannounced environmental,
       safety, and health evaluations at the
       facilities. On occasion, daily on site
will no longer sell Navy ex-combatant ships for
scrapping, but will continue to administer the
existing sales contracts for scrapping these
       surveillance using either a naval engineer,
       industrial hygienist, or architect may also
       occur.  In addition, DRMS and MARAD may use a third-party (e.g., contractor) to conduct
       independent evaluations of scrapping operations.
A Guide for Ship Scrappers:
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A Guide for Ship Scrappers:
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                                 APPENDIX  B
                           LIST OF ACRONYMS
ACM
ACP
ACWM
AST
BOD
CAA
CERCLA
CESQG
CFR
COD
CWA
CZMA
DLA
DOT
DRMS
EPA
EPCRA
ERNS
FFEO
FRP
GAO
HAP
HAZWOPER
HEPA
IDIQ
LDR
LQG
MACOSH
MARAD
NAICS
NCP
NEIC
NESHAP
NFPA
Asbestos-containing material
Area contingency plan
Asbestos-containing waste material
Aboveground storage tank
Biochemical oxygen demand
Clean Air Act
Comprehensive Environmental Response, Compensation, and Liability Act
Conditionally exempt small quantity generator
Code of Federal Regulations
Chemical oxygen demand
Clean Water Act
Coastal Zone Management Act
Defense Logistics Agency
U.S. Department of Transportation
Defense Reutilization and Marketing Service
United States Environmental Protection Agency
Emergency Planning and Community Right-to-Know Act
Emergency Response Notification System
Federal Facilities Enforcement Office
Facility response plan
General Accounting Office
Hazardous air pollutant
Hazardous Waste Operations and Emergency Response
High efficiency particulate air
Indefinite Delivery Indefinite Quantity
Land disposal restriction
Large quantity generator
Maritime Advisory Committee for Occupational Safety and Health
United States Maritime Administration
North American Industrial Classification System
National Oil and Hazardous Substances Pollution Contingency Plan
National Enforcement Investigations Center
National Emission Standards for Hazardous Air Pollutants
National Fire Protection Association
A Guide for Ship Scrappers:
Tips for Regulatory Compliance
                                                       Appendix B

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                LIST OF ACRONYMS (CONTINUED)
NIOSH
NIST
NMHA
NOAA
NPDES
NPE
NRC
NVLAP
OC
OECA
OPA
OSC
OSHA
P2
PACM
PCB
PE
PEL
PLM
POTW
PPE
ppm
PREP
PWS
RA
RACM
RCRA
SDP
SDWA
SIC
SIU
SPCC
SQG
SWPPP
TOC
TSCA
TSI
TSS
TWA
National Institute for Occupational Safety and Health
National Institute of Standards and Technology
National Maritime Heritage Act
National Oceanic and Atmospheric Administration
National Pollutant Discharge Elimination System
Negative pressure enclosure
National Response Center
National Voluntary Laboratory Accreditation Program
Office of Compliance
Office of Enforcement and Compliance Assurance
Oil Pollution Act
On-Scene Coordinator
Occupational Safety and Health Administration
Pollution prevention
Presumed asbestos containing material
Polychlorinated biphenyl
Professional engineer
Permissible exposure limit
Polarized light microscopy
Publicly owned treatment works
Personal protective equipment
Parts per million
National Preparedness for Response Exercise Program
Public water supply
Regional Administrator
Regulated asbestos-containing material
Resource Conservation and Recovery Act
Ships Disposal Project
Safe Drinking Water Act
Standard Industrial Classification
Significant industrial user
Spill Prevention, Control, and Countermeasures
Small quantity generator
Storm water pollution prevention plan
Total organic carbon
Toxic Substances Control Act
Thermal system insulation
Total suspended solids
Time weighted average
A Guide for Ship Scrappers:
Tips for Regulatory Compliance
                                                       Appendix B

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             LIST OF ACRONYMS (CONTINUED)
UIC          Underground injection control
USCG        United States Coast Guard
UST          Underground storage tank
VOC         Volatile organic compound
WSR         Waste shipment record
A Guide for Ship Scrappers:
Tips for Regulatory Compliance                                     Appendix B

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A Guide for Ship Scrappers:
Tips for Regulatory Compliance                                                   Appendix B

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                               APPENDIX C

                     INSPECTOR HIGHLIGHTS
 This Appendix contains summaries of Inspector Highlights noted in check boxes throughout
 sections of this guide. These summaries contain important federal regulatory requirements
for each process that can be the target of federal or state inspectors when they visit your site.
You may want to laminate copies of the summaries for supervisors and individual workers or
  post the summaries at or near the job site as reminders of regulations and best practices.

 Disclaimer: The summaries in Appendix C provide guidance to assist you in understanding
your obligations under environmental laws; however, for a complete understanding of all legal
    requirements, you must refer to applicable federal and state statutes and regulations.
  Appendix C, as well as the guide itself, is a compliance assistance tool only, and it neither
   changes nor replaces any applicable legal requirements, nor does it create any rights or
                                benefits for anyone.

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          ASBESTOS REMOVAL AND DISPOSAL
 "Asbestos" - mineral fibers often mixed with other material to provide insulation for pipes, fireproofing, thermal
        insulation, etc. CAUTION: exposure to airborne-asbestos may cause health problems.
                             DANGER
                            ASBESTOS
                      Cancer and Lung Disease Hazard
                        Authorized Personnel Only
       (references are to pages in "A Guide for Ship Scrappers-Tips for Regulatory Compliance")

An inspector may

... check to see that workers at your facility received
training in a language that they understand, (pg 2-7)

... check the training records for the workers and
supervisors listed on the daily work logs, (pg 2-7)

... check the shower drains from the worker showers to
make sure they have filters. Filters help remove lead and
asbestos from the wastewater. (pg 2-8)

... check to verify that the notification of intent to scrap was
submitted and  that activities have been conducted according
to the notification, (pg 2-11)

... observe on-site equipment and ask for verbal
explanations to determine whether wetting and handling
requirements are being met. (pg 2-12)
Disclaimer: These summaries of Inspector Highlights provide guidance to assist you in understanding your
obligations under environmental laws; however, for a complete understanding of all legal requirements, you must
refer to applicable federal and state statutes and regulations. These summaries are a compliance assistance tool

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only, and they neither change nor replace any applicable legal requirements, nor do they create any rights or
benefits for anyone.
   ASBESTOS REMOVAL AND DISPOSAL - Continued
      (references are to pages in "A Guide for Ship Scrappers-Tips for Regulatory Compliance")
An inspector may

... check to determine whether regulated asbestos-
containing material has been  adequately wetted, (pg 2-12)

... examine removed units or sections to ensure that the
regulated asbestos-containing material in  these components
is  still intact.  This may include looking at cut cables to see if
any cables covered with asbestos were cut by torch or
burned, both of which are violations of the asbestos
requirements.  An inspector may also want to know how the
regulated asbestos-containing material on these units or
sections will be removed, if applicable, (pg 2-13)

... examine any material that appears to be asbestos-
containing material that is on the ground at your facility.
The inspector may sample and photograph suspected
asbestos-containing material, as well as the sources (such as
nearby cable) that it may have come from, (pg 2-13)

... examine the waste shipment records to ensure that the
records are complete, including all required signatures for
each shipment, (pg 2-18)

... check for consistency between the facility asbestos-
containing material waste logs and the disposal site records.
Additionally, the inspector may check to see that the
asbestos waste is placed in the disposal site without
dispersing asbestos to the atmosphere, and that the site
covers the asbestos waste daily, (pg 2-18)

Disclaimer: These summaries of Inspector Highlights provide guidance to assist you in understanding your
obligations under environmental laws; however, for a complete understanding of all legal requirements, you must
refer to applicable federal and state statutes and regulations. These summaries are a compliance assistance tool

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only, and they neither change nor replace any applicable legal requirements, nor do they create any rights or
benefits for anyone.
       SAMPLING. REMOVAL AND DISPOSAL OF
        POLYCHLORINATED BIPHENYLS (PCBs^
"PCBs" - man-made organic chemicals used in electrical, heat transfer, and hydraulic equipment; as plasticizers
in paints, plastics and rubber products, etc. CAUTION: toxic; may cause adverse health effects.
       (references are to pages in "A Guide for Ship Scrappers-Tips for Regulatory Compliance")

An inspector may

... check to see that workers at your facility received
training  in a language that they understand, (pg 3-5)

... review the PCB sampling plans and laboratory analysis
results for the ship, (pg 3-7)

... verify that all PCB items are being identified and
disposed of properly.  For example, the painted canvas cover
which is  attached to fiberglass insulation may be a source of
PCBs. (pg 3-7)

... conduct laboratory audits to verify that  the laboratory is
analyzing the PCB samples properly and that analytical
results are accurate and reliable, (pg 3-8)

... examine PCB storage-for-disposal areas and check the
floor and curb for cracks, measure to verify that the curb is
at least 6 inches high, and check the capacity of the
containment storage area against the total volume of PCBs
in storage. He/she may also determine the 100-year flood
plain location with respect to any storage area. Many ship
scrappers are located within the 100-year flood plain and
cannot have storage areas, (pg 3-11)

Disclaimer: These summaries of Inspector Highlights provide guidance to assist you in understanding your
obligations under environmental laws; however, for a complete understanding of all legal requirements, you must
refer to applicable federal and state statutes and regulations. These summaries are a compliance assistance tool
only, and they neither change nor replace any applicable legal requirements, nor do they create any rights or
benefits for anyone.

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        BTLGE AND BALLAST WATER REMOVAL
"Bilge Water" - "dirty" water in oily waste holding/slop tanks which may contain pollutants, such as oil and
grease, metals, etc. CAUTION: take precautions when entering confined spaces that contain bilge and ballast
water.
       (references are to pages in "A Guide for Ship Scrappers-Tips for Regulatory Compliance")

An inspector may

... check each item in storage for appropriate PCB marks
and labels, (pg 3-13)

... evaluate transfer operations equipment to verify that all
equipment is in proper working order and there is no
evidence of spills or leaks, (pg 4-6)

... review site records to verify that the proper testing was
conducted prior to and during the time that workers
conducted cleaning in bilge and ballast water spaces, (pg 4-
7)

... review site records to verify that proper air sampling was
conducted prior to workers entering confined or enclosed
spaces, (pg 4-8)

... review training records to verify that workers have the
appropriate training to be working in  confined and enclosed
spaces, (pg 4-8)

... ask to see a copy of your facility's discharge permit
covering wastewater discharges, (pg 4-9)

... ask to see your facility's wastewater  monitoring records.
(pg4-ll)
Disclaimer: These summaries of Inspector Highlights provide guidance to assist you in understanding your
obligations under environmental laws; however, for a complete understanding of all legal requirements, you must
refer to applicable federal and state statutes and regulations. These summaries are a compliance assistance tool
only, and they neither change nor replace any applicable legal requirements, nor do they create any rights or
benefits for anyone.

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  BTLGE AND BALLAST WATER REMOVAL- Continued
      (references are to pages in "A Guide for Ship Scrappers-Tips for Regulatory Compliance")

An inspector may

... prior to inspection, contact the publicly-owned treatment
works to determine  if a pretreatment permit is required for
your facility. During the inspection, the inspector may
review the permit to determine if your facility is in
compliance with permit conditions, (pg 4-14)

... verify that the number of underground storage tanks
match the number reported on the notification form(s) to the
state, (pg 4-19)

... verify that there are appropriate containment and
diversionary structures or equipment at the facility for all
above ground storage tanks, (pg 4-20)

... inspect all oil storage containers or tanks to verify that
they are labeled properly and there is no evidence of leaks
or discharges of oil.  (pg 4-23)

... track the shipments from your facility through the
reclaimers to verify  that the shipments of fuel and oil do not
contain spent solvent or other hazardous waste liquids, (pg
4-24)

... ask if you have tested the oil and oily wastes to determine
their pollutant concentrations and if they are hazardous.
He/she may ask to review the test results, (pg 4-25)
 Disclaimer: These summaries of Inspector Highlights provide guidance to assist you in understanding your
obligations under environmental laws; however, for a complete understanding of all legal requirements, you must
refer to applicable federal and state statutes and regulations. These summaries are a compliance assistance tool
only, and they neither change nor replace any applicable legal requirements, nor do they create any rights or
benefits for anyone.

-------
 BILGE AND BALLAST WATER REMOVAL - Continued
      (references are to pages in "A Guide for Ship Scrappers-Tips for Regulatory Compliance")

... review your facility's analytical data for hazardous waste
                   determinations, (pg 4-27)

An inspector may

... evaluate the total volume of waste on site at the time of
the inspection and verify that it is within the limits for your
facility's generator category, (pg 4-27)

... look at all hazardous waste on site noting the size and
type of containers, their condition, and whether they are
closed and protected from the weather. He/she may check
the labels  on the containers for the words "hazardous
waste," and verify that the dates/information is complete on
the label.  The inspector may also check the containment for
cracks or  leaks, (pg  4-29)

... check  personnel records, including job titles, to
determine when hazardous waste duties were assigned and if
proper training was provided to employees, (pg 4-30)

... review your facility's contingency plan or basic
contingency procedures, and ask about any incidents
requiring  implementation of the plan or procedures, (pg 4-
30)
Disclaimer: These summaries of Inspector Highlights provide guidance to assist you in understanding your
obligations under environmental laws; however, for a complete understanding of all legal requirements, you must
refer to applicable federal and state statutes and regulations. These summaries are a compliance assistance tool
only, and they neither change nor replace any applicable legal requirements, nor do they create any rights or
benefits for anyone.

-------
 BILGE AND BALLAST WATER REMOVAL - Continued
       (references are to pages in "A Guide for Ship Scrappers-Tips for Regulatory Compliance")

... review the facility's spill prevention plans to ensure that
they are certified by a registered professional engineer and
that they are  up to date, (pg 4-33)

... evaluate your facility's response plan measures for their
ability to facilitate adequate response to a worst-case
discharge of oil. (pg 4-36)
Disclaimer: These summaries of Inspector Highlights provide guidance to assist you in understanding your
obligations under environmental laws; however, for a complete understanding of all legal requirements, you must
refer to applicable federal and state statutes and regulations. These summaries are a compliance assistance tool

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only, and they neither change nor replace any applicable legal requirements, nor do they create any rights or
benefits for anyone.
                OIL AND FUEL REMOVAL
"Oil and fuel" - include petroleum, fuel oil, sludge, oil refuse, oil mixed with waste, etc.
CAUTION: Fire dangers!
      (references are to pages in "A Guide for Ship Scrappers-Tips for Regulatory Compliance")

An inspector may

... evaluate transfer operations equipment to verify that all
equipment is in proper working order and there is no
evidence of spills or leaks, (pg 5-5)

... review site records to verify that the proper testing was
conducted prior to and during the time that workers
conducted cleaning in oil and fuel compartments, (pg 5-7)

... review site records to verify that proper testing was
conducted prior to workers entering confined or enclosed
spaces, (pg 5-7)

... review training records to verify that workers have the
appropriate training to be working in confined and enclosed
spaces, (pg 5-7)

... check with the state underground storage tank program
office to verify that the number of underground storage
tanks match the number reported on the notification form(s)
to the state, (pg 5-9)

... verify that there are appropriate containment and
diversionary structures or equipment at the facility for all
above ground storage tanks, (pg 5-11)

Disclaimer: These summaries of Inspector Highlights provide guidance to assist you in understanding your
obligations under environmental laws; however, for a complete understanding of all legal requirements, you must

-------
refer to applicable federal and state statutes and regulations. These summaries are a compliance assistance tool
only, and they neither change nor replace any applicable legal requirements, nor do they create any rights or
benefits for anyone.

          OIL AND FUEL REMOVAL - Continued
      (references are to pages in "A Guide for Ship Scrappers-Tips for Regulatory Compliance")

An inspector may

... inspect all oil storage containers or tanks to verify that
they are labeled properly and there is no evidence of leaks
or discharges of oil. (pg 5-13)

... track the shipments from your facility through the
reclaimers  to verify that the  shipments of fuel and oil do not
contain spent solvent or other hazardous waste liquids, (pg-
5-14)

... review your facility's analytical date for hazardous waste
determinations, (pg 5-18)

... evaluate the total volume of waste on site at the time of
the inspection and verify that it is within the limits for your
facility's generator category, (pg 5-18)

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Disclaimer:  These summaries of Inspector Highlights provide guidance to assist you in understanding your
obligations under environmental laws; however, for a complete understanding of all legal requirements, you must
refer to applicable federal and state statutes and regulations. These summaries are a compliance assistance tool
only, and they neither change nor replace any applicable legal requirements, nor do they create any rights or
benefits for anyone.

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            PATNT REMOVAL AND DISPOSAL
"Paint" - you may find paint and preservative coatings on both interior and exterior surfaces of the ship.
CAUTION: paint may be flammable or contain toxic compounds and be harmful to you and the environment.
       (references are to pages in "A Guide for Ship Scrappers-Tips for Regulatory Compliance")

The inspector may

... review your facility's records to verify that tests were
conducted to determine if paints or other coatings were
flammable, (pg 6-3)

... verify that highly flammable coatings have been removed
prior to cutting, (pg 6-4)

... review surface preparation activities  at the facility to
verify that measures are being taken to protect worker
health, (pg 6-6)

... evaluate the facility for compliance with specific permit
conditions, if a permit has been issued by EPA or the state or
local air pollution control authority,  (pg  6-7)

... review your facility storm water permit to ensure that
your facility is meeting all of the requirements of that
permit.
(pg 6-7)

... review your facility's storm water pollution prevention
plan to ensure that it addresses all of the required elements.
He/she may also review the waste storage area to ensure that
your facility is taking appropriate measures to prevent
Disclaimer: These summaries of Inspector Highlights provide guidance to assist you in understanding your
obligations under environmental laws; however, for a complete understanding of all legal requirements, you must
refer to applicable federal and state statutes and regulations. These summaries are a compliance assistance tool
only, and they neither change nor replace any applicable legal requirements, nor do they create any rights or
benefits for anyone.
      PAINT REMOVAL AND DISPOSAL - Continued

-------
     (references are to pages in "A Guide for Ship Scrappers-Tips for Regulatory Compliance")
storm water from coming into contact with wastes, including
paint removal wastes, (pg 6-8)

The inspector may
... review your facility's  analytical date for hazardous waste
determinations, (pg 6-12)

... evaluate the total volume of waste on site at the time of
the inspection and verify  that it is within the limits for your
facility's generator category, (pg 6-12)

... look at all hazardous waste on site noting the size and
type of containers, their condition, and whether they are
closed and protected from the weather.  He/she may check
the labels on the containers for the words "hazardous
waste," and verify that the date/information is complete on
the label. The inspector may also check the containment for
cracks or leaks, (pg 6-13)

... check personnel records to determine when hazardous
waste duties were assigned and if proper training was
provided to employees, (pg 6-13)

... review your facility's  contingency plan or basic
contingency procedures,  and ask about any incidents
requiring implementation of the plan or procedures, (pg 6-
13)

... review all records including but not limited to, annual or
biennial reports and manifests, (pg 6-14)
Disclaimer: These summaries of Inspector Highlights provide guidance to assist you in understanding your
obligations under environmental laws; however, for a complete understanding of all legal requirements, you must
refer to applicable federal and state statutes and regulations. These summaries are a compliance assistance tool
only, and they neither change nor replace any applicable legal requirements, nor do they create any rights or
benefits for anyone.

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        METAL CTJTTTNG AND METAL DISPOSAL
"Metal Cutting" - metals on ships are cut using a variety of torches and mechanical cutters.
CAUTION: air pollutants, exposure to metal fumes, particulates, and smoke may be harmful to your health.
       (references are to pages in "A Guide for Ship Scrappers-Tips for Regulatory Compliance")

The inspector may

... investigate any open burning activities at the facility.  In
addition, if a permit has been issued by EPA or the state or
local regulatory agency, the inspector may evaluate the
facility for compliance with the specific permit conditions.
(pg 7-8)

... verify that appropriate mechanical ventilation is
provided for workers, if required, during metal cutting, (pg
7-9)

... review your facility storm water permit to ensure that
your facility is meeting all of the requirements of that
permit.
(pg 7-13)

... review your facility's storm water pollution prevention
plan  to ensure that it addresses all of the required elements.
He/she may also review the waste storage area to ensure that
your facility is taking appropriate measures to prevent
storm water from  coming into contact with wastes, including
metal cutting wastes, (pg 7-13)
Disclaimer: These summaries of Inspector Highlights provide guidance to you in understanding your obligations
under environmental laws; however, for a complete understanding of all legal requirements, you must refer to
applicable federal and state statutes and regulations. These summaries are a compliance assistance tool only, and

-------
they neither change nor replace any applicable legal requirements, nor do they create any rights or benefits for
anyone.

   REMOVAL AND DISPOSAL OF MISCELLANEOUS
                     SHIP MACHINERY
"Ship Machinery" - various types of machinery are sold for reuse or recycled as scrap.
CAUTION: protect yourself from exposure to contamination with hazardous materials, including asbestos, PCBs,
oils, and fumes.
       (references are to pages in "A Guide for Ship Scrappers-Tips for Regulatory Compliance")

The inspector may

... review your facility storm water  permit to ensure that
your facility is meeting all of the requirements of that
permit, (pg  8-5)

... review your facility's storm  water pollution prevention
plan to ensure that it addresses  all of the required elements.
He/she may also review the waste storage area to ensure that
your facility is taking appropriate measures to prevent
storm water from coming into contact with wastes, including
scrap metal and other wastes, (pg 8-6)

-------
Disclaimer:  These summaries of Inspector Highlights provide guidance to assist you in understanding your
obligations under environmental laws; however, for a complete understanding of all legal requirements, you must
refer to applicable federal and state statutes and regulations. These summaries are a compliance assistance tool
only, and they neither change nor replace any applicable legal requirements, nor do they create any rights or
benefits for anyone.

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                                              Survey

1. How did you learn about this guide?	
    Have you tried to read the guide on our website (www.epa.gov/oeca/fedfac/fflex.html)?      n Yes  n No
    Was it easily accessible?                                                              n Yes  n No

2.  How did this guide contribute to increasing environmental and worker safety and health benefits?
    n  Reduced waste by	
    n  Restored water quality by	
    n  Improved worker human health and safety by	
    n  Reduced emissions or other pollutants by	
    n  Other	
3.  What changes came about as a result of using this guide?
    n   Established new procedures or policies such as	
    n   Sustained or improved our compliance rate by	
    n  Eliminated practices that caused possible noncompliance by.
    n  Reduced personal injuries by	
    n  Created awareness by	
    n  Other 	
4. Are there additional ship scrapping topics you would like added to this guide in the future?
5. If the guide were ever to be rewritten, what would you do differently? Should the guide be provided in a
different language?	
6. Would you recommend this guide to other ship scrapping facilities or others involved in the industry?
                                                                              n Yes  n No n Maybe
Please explain your response:  	
7.  Would you be interested in participating in a forum with industry and regulatory representatives to
exchange ideas about the compliance needs of the ship scrapping industry and how best to meet those needs?
                                                                              n Yes  n No  n Maybe

Length:     n One day            n Two days        n Other 	
Location:    n Washington, DC     n Other	
8.   Your Name:  	  Title/Position:,
    Organization: 	  Facility Name:
    Address:	  Facility Location:
    Telephone:
    E-mail:	

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          INPUT!

You are invited to share with us
your opinions and thoughts
about this document, entitled A
Guide for Ship Scrappers: Tips
for Regulatory Compliance
(April 2000), by responding to
the following survey questions.
We would like to know how this
guide has helped you and if
there are additional topics you
would like to see added to the
guide in the future.

We look forward to hearing
from you. Please complete this
survey and mail it by September
29, 2000.
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