listed

2.1 Classification of the substance or mixture

system can be used to indicate information should be based upon the expected impact of a slug loading of a chemical or material upon the POTW. MSDSs or the National Fire Protection Association (NFPA) (from Table 2-4 or 2-5) applicable to each facility l Major materials of concern stored, used, or produced at the facility l Regular batch discharge schedule l Potential for spills l of slug risk m Status of IU-specific Slug Control Plan l Comments/observations. In the event of a slug, Table 2-5 helps POTW staff quickly locate the source of a slug based on chemicals of concern and sewer service area. The POTW can . then refer to the IU-specific slug potential data sheets (Tables 2-3 and 2-4) to obtain more detailed information. Efficient data collection and retrieval can facilitate slug identification procedures, thus accelerating

SECTION 2: Hazards identification

associated with a slug of,each chemical at a facility and can provide valuable information concerning appropriate control and cleanup techniques. POTW

Classifications

Scheme can be used to help determine the POTW hazard. The POTS should evaluate the HSDS information and

NFPA Ratings

to determine the applicability for slug control. If necessary, the POTS should seek the assistance of industry personnel and the local fire department in identifying IU sources and quantities and classifying chemicals by hazard code. IU representatives should have the HSDSs for many chemicals. The POTW inspector should also note all RCRA-listed or characteristic hazardous wastes that may be stored at the IU prior to

Disposal

such as pretreatment sludges. EPA recommends that POTWs summarize all of the IU data provided by the industrial users or obtained during inspections. Data areas (Section 2.3.4.2) l MATERIAL INVENTORY: Vpes, volumes, containers, etc. (Section 2.3.4.3) l SPILL AND LEAK PREVENTION EQUIPMENT AND OPERATIONS AND MAINTENANCE PROCEDURES: Definition of available equipment, plans to obtain equipment (Section 2.3.4.4) l EMERGENCY RESPONSE EQUIPMENT AND PROCEDURES: Inventory and location of equipment; and procedures (Section 2.3.4.5) l SLUG REPORTING: Description of procedures for notifying POTW (Section 2.3.4.6) l TRAINING PROGRAM: Assurances that the Plan is implemented by pro- viding for employee training (Section 2.3.4.7) l CERTIFICATION: A certification by a professional that the Plan is adequate to prevent and control slugs (Section 2.3.4.8). Two sample plans appear in Appendix D. 2.3.4.1 General Information An IU Slug Control Plar;c must include sufficient general information to enable the POTV to: (1) categorize and restrict the IU’s potential for a slug discharge; and (2) respond promptly and effectively in an emergency. General information should include a brief description of the IU, discharge practices, applicable pretreatment standards, and description of previous slugs and corrective actions. The information requested in the Industrial User Slug Potential Survey (Figure 2-2) is an outline o- f the kinds of infor-mation generally required in this element of a Slug Control Plan. 2-30 2.3.4.2 Facility Layout Flow Diagrams Each Plan should include detailed drawings of the facility showing the following: l General layout of the facility a Areas occupied by manufacturing or commercial activities; property boundaries, drainage of rainwater, and connections to the city’s sanitary sever and storm drains l Hazardous materials process and storage areas; waste handling, stolage, and treatment facilities l Loading and unloading areas l Direction of drainage from hazardous materials and waste handling, process,

Storage

and retrieval *Methods for conversion ifron weight measurements, whora volume is unknown) follov: For pur. Or nearly puce chemical liquids, the chemical’s specific gravity should be obtained from the chemical literature, such as the Handbook of Chemistry and Physics, or Lange’s Handbook of Chemistry Isoa rofarenca 11stj. The weight data can then be converted as follows: weight, pounds Volume, gallons = (rp*clfic gravity! 18.3454) Pot dilute aqueous mircturrs. the above formu:a c.n be us-d, wzth specific grrvity 0 1.0. Weights of solids t*.g., salts!, sludges, and/or complex chemical mixtures may not be convertible to a volume basis. In thasa cas.s, lnv*ntory volum*S should be estimated from tank size, bag or drum size and Count, and/or other n .,S”Ces of existing faclllti*s. 2-27 will aid in evaluating slug loading potential and tracking and identifying slug sources. This summary data can be stored in a computer database or a summary data table such as the one presented in Table 2-5. The data and retrieval system should incorporate: l A list of all industries within the POTW’s jurisdiction. l The Sewer Service Area for each Eacility. Industries may be assigned a sewer service area number based on geographic location. When a slug occurs in a specific area, the POTW can identify industries dis- charging to that location. l Chemical transportation, and and treatment areas l Floor drains, pipes, and channels which lead away from potential leak or spill areas [identify by coding footnotes, or narratives describing drainage patternsj l Flov diagram(s) shoving chemical and wastewater flow including piping and instrumentation, flow rates, tanks and capacities, treatment systems, and final destinations of flows. 2.3.4.3 Material Inventory The facility should provide sufficient data on all materials of concern used and stored at the facility. This may include those materials for which the POTV has established local limits (see Section 2.2.1). This information is useful in determining the origin of a slug, potential and appro- priate slug and process equipment, as well as built-in safeguards to prevent chemicals from being spilled such as secondary containment structures. Spill containment equipment consists of equipment or apparatus to keep a spill from spreading and to remove the spill. Examples of and Process Tanks: holding tanks, pumping equipment (compatible material); shell and bottom construction (compatible material); underground seepage protection; cathodic protection of underground tanks; liquid level sensing devices: overflow, temperature, pressure alarms; heating coils; collision protection support construction; secondary containment; diver- sionary structures in quench tanks - Drums: drum construction; areas; secondary containment; diversionary structures; collision protection; drum handling equipment; drip pans - Pipes, Valves, Fittings, Pumps, Electrical and Mechanical Equipment: seals ; valve stem packing; gaskets; cathodic protec- tion; vehicular traffic warning signs - Loading Stations: fill safeguards; curbs and drains: warning signs/improper disconnect protection; secondary containment - Alarm Systems: to detect unauthorized discharge flows, pH excursions, etc. l Equipment to Contain Spills: booms, barriers, sweeps, and fenders: surface collecting agents; absorbent materials; skimmers; oil/water separators; sumps; sewer plugs. Once spill potential reduction measures have been addressed, secondary containment systems should be considered. An IU which has the potential for a slug discharge should provide secondary containment systems, wherever possible, that will control the spread of a spill of toxic wastes or slug discharges of high-strength wastes at or near a potential spill source (e.g., tanks, processing equipment and piping). Several forms of secondary containment systems may be used including diking, diversion, holding tanks, or quick drainage. These pethods are described I)~lo:‘. 2-33 Diking is the most effective form of secondary containment for bulk chemical storage. Dikes can be constructed from concrete, cinder blocks, or earth. Bulk tanks and/or drum storage should be surrounded with an impervious dike that will hydrostatically and loading areas. It consists of an impervious curbed or below gradient pad that slopes into a drain that is connected to an impervious sump. Spilled volumes of liquid are collected in the impervious sump and then removed and appropriately treated, discharged, or disposed of. These structures should be used in areas where diking is impractical or unsafe. For example, chemicals which emit noxious fumes might be diverted to a closed tank in the event of a spill, rather than left in an open diked area. Diversionary structures can include quench tanks, which serve to simul- taneously collect and treat chemicals. Many industrial facilities possess process quench tanks to control runaway chemical reactions. Procedures The operation and maintenance proced\lLes designed to minimize spills -31 a facility are as important as the selection and installation of the 2-34 equipment. Many operation and maintenance procedures are common-sense, hovever , and should be adequately included in every Plan. For example, incom- patibility of materials with the container can result in leaks or explosion of the container. Elements of good housekeeping include neat and orderly of chemicals and prompt cleanup of spilled liquids or powders to prevent them from reaching the sewer collection system. An effective preventive mainte- nance should include periodic inspections and testing of equipment systems, appropriate adjustment, repair, or replacement of valves and other parts. Also, a security system to prevent accidental or intentional entry to the IU site would reduce the risk of vandalism, theft, sabotage, or other illegal use of the plant facility that could possibly cause a slug loading. Simple operating and maintenance procedures directed at eliminating spills and leaks include, but are not limited to, the following: l Inspect All Chemical Vessels, as Well as All Process Vessels and Fittings (Pumps, Valves, Piping): The items must be constructed of material compatible vith the chemicals passing through them. In particular, tanks and drums used to store corrosive chemicals should be constructed of stainless steel or of a corrosion resistant plastic. The plan should discuss all routine operation and maintenance (including housekeeping and replacement of worn-out equipment) performed to minimize spills. The frequency of inspections and monitoring for leaks or other conditions that could lead to spills should also be indicated. Any pumps or valves used to process these chemicals must possess corrosion-resistant seals and packings. Similarly, pumps or valves through which organic chemicals pass must Tanks, Process Vessels, and Piping. These must also meet compatibility and integrity requirements: All above ground vessels should be protected from vehicular damage through the use of truck guards. Underground vessels and pipes should be well marked and weight limits placed on roadways that may cross these underground vessels. All underground vessels should be cathodicly protected to prevent damage due to corrosion. Underground piping should be double-walled at vehicle crossings. l Equip Open Storage and Process Tanks with Liquid Level Control Devices, and Grounding Apparatus (where necessary): In addition, overflow alarms should be installed to warn personnel of tank over- fj lling. Similarly, temperature and pi-essut-e alarms should be installed on closed chemical procecsil:g equipment, to alert industr-y personnel to runaway reactions or other factors resulting in excessive 2-35 temperatures and pressures. Such extreme conditions can otherwise result in the automatic opening of relief valves, subsequently spilling the process vessel’s contents. Use Proper Drum Handling Equipment: The practice of scooping drums with the forks of a forktruck should be eliminated. Pallets should be used to aid handling and inspection. Oil dispensing racks should be provided with drip pans. Secure Loading/Unloading Pump Station Controls: In a manner to prevent the pumps from being turned on by unauthorized personnel. Warning signs or physical obstructions, such as crossing gates, should be used to prevent trucks from driving away while the loading hose is connected. Eliminate All Unnecessary Cross Connections: All unnecessary floor drains should be plugged, especially those in high-risk areas. Utilize Automatic Stormwater and/or Sewer Sampling Systems to Monitor These sampling systems can be tied into automatic shutoff will prohibit discharge from a plant effluent system. 2.3.4.5 Emergency Containers: Chemical spills must be con- tained and removed as soon as possible to prevent materials from spreading into other areas. Protective Clothing and Respiratouc: In Lesponding rr 311 emeKgenc , hazardous spill, employees shouid take

Response

time and reducing the damages incurred by each incident. 2.3.4 Requirements of IU Slug Control Plans This section outlines the recommended procedures and any time a slug has occurred, The general elements of IU Slug Control Plans are as follows: l GENERAL INFORMATION: IU Name and Address, IU Contact, Discharge Practices, Security Provisions and Employee Training (Section 2.3.4.1) l FACILITY LAYOUT FLOW DIAGRAMS: General layout including mapping of manufacturing, procedures. Descriptions of the material handled, the location of these materials, descriptions of containment, transfer and transport, as well as any additional comments should be provided as follows: l Materials - Both chemical and trade names should be listed in the inventory (OSHA MSDSs may be used). This information may help minimize confusion over the constituents of a compound and facilitate proper procedures to a slug. l Location in Plant - Knowing the location of (Rlj) materials will assist plant employees and emergency personnel in locating areas initially affected by a spill. l Maximum Volume/Container Volume - This information is useful in determining the potential impact of a slug. 2-31 l Container Description - The description should include the type of container (e.g., steel drum, fiberglass tank, etc.) and the presence of container attachments such as valves, pumps, transfer pipes, etc. The description of a container will help determine potential origins of a slug load. a Transfer and Transport Areas - The condition of containers and transfer equipment is useful in assessing the potential for accidental spills or slug discharges of high strength wastes and possible effects on the treatment plant. l Additional Comments - Additional comments should include information on the physical, chemical, and toxicological effects of each material, and special Equipment and Procedures Equipment Information that should appear in this section of the IU Plan includes an inventory of available IU emergency equipment and a detailed descrip- tion of emergency procedures. The emergency equipment inventory should also procedures should have access to the breathing apparatus and be adequately trained in the use of this equipment. l First Aid Kits: A well equipped first aid kit should be immediately available for use if necessary. The plan should indicate the location of the kit, and the items that it-contains. Items that are essential to a first aid kit include: antiseptic solutions and bandages for application of wounds; artificial respiration devices, and eyewashing solutions and cups. a Ventilation Equipment: Before entering an area where a potentially explosive spill has occurred, tests should be made for explosive atmosphere, the presence of toxic gases and oxygen deficiency. Whenever an adverse atmosphere is encountered, forced ventilation, such as powered explosion-proof ventilators, blowers, or fans, can be used to create safe conditions. Ventilation should be continued as long as recurrence of the

Contains

of an IU Slug Control Plan. As discussed in Section 2.3.1, notification requirements apply to all dischargers. In addition, POTWs should select from among the control measures described in this section and require medium- and high-risk facilities to implement appropriate control measures. POT’Js nay aiso require high-risk facilities to develop I!J Slug Cont.r-ol P1ar.c. ,:he~e necer sal- .’ 31 an5 shoruld I)e reviewed by the IU on a regular basis or -ihen changes In design.. construction. 2-28 service cfiemical kterials of Cancem Area Hazard Classificaticm Stored, Used or Batch Spill Sk3 Control Plan Irdum-ybm t&rnter F EC Ek NT Ra I Produced Discharges Potential Risk Status fhm-mts ABC Circuits 1 xx x X H,SO,,C&Cr,Ni,pH No High Hm Needs Plan Poor housekeeping and -t Will’s Ice 4 X x m,* YeS Ed. Med. Has Plan Plan needs to be rcviewfA cream plant by Ci ty for adequacy Fix-it 3 X Cu, Pb, Zn, acidic No Med. Md. Needs Plan Needs .saw inqxovenmt in Radiators tastes, ethylene househqing and under- !i!lYcol standing of waste disposal Railroad Ta~lk 4 X x m, @G ClheMls, YeS Med. Needs Plan Has an inopemtive oil/ Car Cleaning, nkethylene chloride, water separator and poor Inc. pesticides chemical storage practick ABC Rf2stauranr 1 X Fats, oil and grm No lAd Lm Does not Needs tobeadvisedof need plan ordinance rquiren-mts for oil and grease Pesticides 2 X Pesticides, fertilizers Yes Low Med. NeedsPlan thwashingofmixor Applicator application tanks mite, Inc. flcmchains in storage area --_ olenical Clzsiiica~ion F - Flaimthle N - Nxious/funirg F1 - Floatable E - Explosive T -Toxic S - Soluble C - Corrosive Ra - Rixiioactive Se - Settleable Fk - Reactive I - Inhibitdry to FQIW 2-29 operation, and maintenance at the facility warrant modification. A schedule for plan review and procedures for plan modification should also be described in the Plan. The Plan should also be reviewed when new conditions require changes in the emergency 110 percent of the capacity of the largest tank or the capacity of the largest tank plus water from a maximum 24 hour/l0 year rainfall event, whichever is greater. Accumulated rainwater from diked areas should be drained with a manually operated pump or siphon system. If a valve pipe has been installed through the dike wall, the drainage valve should be kept locked in the closed position when not in use. Flapper valves should not be used. Design of the dike should account for the containment of a spraying leak from the side of the tank. Where this design is not feasible, baffles could be installed at the top of the dike that would deflect potential leaks and cause them to drop within the containment area. Diversion of flow of potentially spilled material away from its naturally expected path can also be an effective means of secondary containment. Diversionary structures consist of curbs, sumps, and/or gutters which divert spilled material to a collection tank. A quick drainage system is frequently employed in small volume seals and packings which are dissolution-resistant. The IU should indicate in its Plan that appropriate materials of construction have been used, and are compatible with the chemicals being processed. a Inspect Foundations and Supports of Large the equipment location on the facility layout diagram and a physical description of each piece of equipment. A summary of the information that should appear in this part of the plan follows: Communication Equipment and Alarms: A communication system should be established for reporting emergencies and providing immediate emerg- ency instruction to facility personnel with the use of a telephone. intercom, radio, alarm, etc. Spill Containment and Control Equipment and Tools: Examples of this type of equipment include sorbent materials and dry chemicals ‘Jhich are often used for containing spills of small volumes. Spilled Material

Precautionary statements

that should be taken when handling these materials. A discussion should also be provided on the procedures to prevent contact between incompatible materials. Each facility must demonstrate that the following three compatibility aspects have been considered: (1) the construction of the container; (2) other mate- rials in the immediate vicinity; and (3) the surrounding environment. 2.3.4.4 Spill and Leak to ensure that as 2-36 much skin is covered as possible. Flameproof protective clothing sill not only prevent chemical burns, but will also protect skin during a fire. Other examples of protective clothing include: - Rubber Gloves - Apron - Goggles/Face Mask - Hard Hat. In addition, depending on the nature of the emergency, the use of self-contained breathing apparatus may be necessary. All employees involved in

Prevention

Equipment and Procedures This subsection is divided into a discussion of equipment and procedures. It provides information on the data an IU Slug Control Plan could contain. It also provides technical information that may be used to evaluate the adequacy of the equipment and procedures detailed in an IU Plan. The POTW’s review and evaluation of the IU Plans should use, but not be limited to the information provided here. Additional references, including those listed in Appendix E, should be reviewed and a thorough understanding of the IU operations should be achieved prior to evaluating the IU Plan. Existing and Proposed Spill and Containment Equipment required to control spills fal 1s into two categor ies : l Equipment to prevent spills l Equipment to contain spills. This section of the IU’s Slug Control Plan should identify all existing equipment and/or systems that the IU nas in place or plans to obtain to imple- ment the Plan. If equipment needs to be purchased, the expected purchase dates should be provided. 2-32 The Plan should describe current and projected inventories of both types of equipment. Equipment to prevent spills consists of appropriately selected chemical and con- tainment equipment are listed below: l Equipment to Prevent or Detect Spills - Chemical