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
A Guide for Ship Scrappers:
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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
A Guide for Ship Scrappers:
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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
A Guide for Ship Scrappers:
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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
A Guide for Ship Scrappers:
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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
A Guide for Ship Scrappers:
Tips for Regulatory Compliance xiii Table of Contents
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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.
A Guide for Ship Scrappers:
Tips for Regulatory Compliance
1-2
Introduction
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Remember: This guide is not the final word on compliance responsibilities for your
ship scrapping operation.
A Guide for Ship Scrappers:
Tips for Regulatory Compliance 1-3 Introduction
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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
A Guide for Ship Scrappers:
Tips for Regulatory Compliance 2-1 Asbestos Removal and Disposal
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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?
A Guide for Ship Scrappers:
Tips for Regulatory Compliance 2-2 Asbestos Removal and Disposal
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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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Asbestos Removal and Disposal
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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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Tips for Regulatory Compliance 3-13 Disposal of PCBs
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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.
A Guide for Ship Scrappers: Sampling, Removal and
Tips for Regulatory Compliance 3-14 Disposal of PCBs
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CAUTION
CONTAINS
PCBs
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lit neatest U.S. E.PA Office
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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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Sampling, Removal and
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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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Tips for Regulatory Compliance 3-17 Disposal of PCBs
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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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3-18
Sampling, Removal and
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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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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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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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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 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.
A Guide for Ship Scrappers: Removal and Disposal of
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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.
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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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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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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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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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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.
A Guide for Ship Scrappers:
Tips for Regulatory Compliance 9-9 Resources
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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-
A Guide for Ship Scrappers:
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Resources
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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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Tips for Regulatory Compliance
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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.
A Guide for Ship Scrappers:
Tips for Regulatory Compliance 9-21 Resources
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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.
A Guide for Ship Scrappers:
Tips for Regulatory Compliance 9-22 Resources
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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
A Guide for Ship Scrappers:
Tips for Regulatory Compliance 9-23 Resources
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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 RegulationsDisposal 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
A Guide for Ship Scrappers:
Tips for Regulatory Compliance 9-24 Resources
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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:
A Guide for Ship Scrappers:
Tips for Regulatory Compliance 9-25 Resources
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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:
A Guide for Ship Scrappers:
Tips for Regulatory Compliance 9-26 Resources
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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/
A Guide for Ship Scrappers:
Tips for Regulatory Compliance 9-27 Resources
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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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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).
A Guide for Ship Scrappers:
Tips for Regulatory Compliance A-11 Appendix A
-------
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.
A Guide for Ship Scrappers:
Tips for Regulatory Compliance A-12 Appendix A
-------
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
A Guide for Ship Scrappers:
Tips for Regulatory Compliance A-13 Appendix A
-------
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)
A Guide for Ship Scrappers:
Tips for Regulatory Compliance A-14 Appendix A
-------
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
A Guide for Ship Scrappers:
Tips for Regulatory Compliance A-15 Appendix A
-------
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:
Tips for Regulatory Compliance A-16 Appendix A
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A Guide for Ship Scrappers:
Tips for Regulatory Compliance A-17 Appendix A
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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
-------
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
-------
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.
-------
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
-------
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
-------
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.
-------
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.
-------
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
-------
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)
-------
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.
-------
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.
-------
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
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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)
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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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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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WE WANT YOUR
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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