2010 4.2


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2010 4.2

  2. 2. SECTION 4.2 USED OIL AND SOLVENTS STORAGE/DISPOSAL 4.2.1 Introduction Potential environmental liabilities associated with the storage of used lubricating oils and solvents are similar to those associated with the storage of gasoline and diesel fuel (see Section 4.1). In addition, used oils and solvents are waste products which require disposal. Given the potentially hazardous nature of these products, combined with limited disposal options and potentially high costs, proper storage and disposal of these products is extremely important. It should be noted that the procedures identified in this section for solvents are applicable to solvents mixed with paint, as well as waste paints. The storage and disposal of these products is often impacted by their classification relative to flammability and combustibility. Procedures and methods for classifying products as a "flammable liquid" or a "combustible liquid" are quite complicated and are described in detail in the national and provincial fire codes. However, in general terms, a flammable liquid has a flashpoint below 37.8 _C, while a combustible liquid has a flashpoint below 93.3 _C. In order to determine the flashpoint of the liquid you should consult a Material Safety Data Sheet (MSDS) for the product. MSDSs contain a great deal of information in addition to flashpoint (e.g., first aid data, storage requirements, personal protective equipment requirements, etc.). Provincial Occupational Health and Safety legislation requires that you have copies of MSDSs for all the
  3. 3. products which you use on the golf course (i.e., fuel, fertilizer, solvents, pesticides, etc.). MSDSs are available from the supplier of the product. Most petroleum-based solvents (e.g., varsol) are classified as combustible liquids. Lubricating oils are neither flammable nor combustible liquids. Did You Know . . . MSDS are available on line through the Canadian Centre for Occupational Health and Safety, a federally funded health and safety resource. Use the search box at this link: http://ccinfoweb.ccohs.ca/ for a free search across their Web Collections. Some of the records do require an annual subscription, a custom collection of MSDSs specific to your workplace can be ordered for a fee. 4.2.2 Regulatory Requirements A listing of regulatory contacts for waste oil and solvent storage and disposal issues is presented in Table 4.7. Specific regulatory requirements for the storage, handling and disposal of waste oils and solvents are as follows: 1. Storage of waste solvents which are classified as either flammable or combustible liquids is regulated by the fire code for the particular jurisdiction. Requirements for the storage of solvents in containers greater than 250 L (i.e., larger than a drum) are similar to those described in Section 4.1 for diesel and gasoline storage. Most courses however do not generate quantities which justify storage in large tanks and therefore would normally store waste solvents in drums or other smaller containers. Requirements for the storage of solvents in containers less than 250 L are summarized in Table 4.8. 2. Given that waste oils are neither flammable nor combustible materials, their storage is generally not regulated by the fire codes. The exception to this is in Alberta where the Alberta Fire Code provides specific requirements for waste oil storage tanks. Some provinces have created specific legislation and/or regulations addressing requirements for the storage of waste oil. Requirements addressed by this legislation include the following: • Storage volume thresholds above which the regulations apply • Setbacks from buildings, property lines and adjacent tanks • Construction materials • Attachments and piping • Corrosion protection
  4. 4. • Secondary containment • Inspection and monitoring • Recycling. A listing of the legislation which applies to the various provinces is presented in Table 4.9. Specific requirements contained in this legislation are also summarized in this table. 3. Spills and releases of waste oils and solvents are regulated in a similar manner to spills and releases associated with Fuel Storage tanks. As in the requirements for fuel storage, spills only have to be reported if they exceed certain minimum volumes. A summary of these minimum volumes, and a listing of the agencies to which the spill or release is to be reported, are presented in Table 4.6. It should be noted that the release or disposal of waste oils or solvents to a municipal sewer system would be classified as a release and hence, contravenes provincial legislation. 4. Provincial environmental legislation generally classifies particular wastes as being "hazardous", "special" or a "waste dangerous good". These types of wastes are particularly dangerous or toxic if they are released into the environment and hence, requirements for the disposal of these wastes are much more stringent than those associated with less dangerous wastes. This classification applies to waste solvents in all provinces and waste oils in most provinces. Table 4.10 summarizes the classifications of waste oils and solvents relative to the applicable legislation. 5. Provincial environmental legislation specifies that the waste generator is always responsible for impacts caused by the waste, regardless of the location of the waste. Therefore, the superintendent should always be aware of what waste disposal contractors are doing with their waste products, and should ensure that the waste is being disposed in accordance with the provincial legislation. Failure to do so could result in the course and/or the superintendent being held liable for problems which may result from incorrect disposal procedures.
  5. 5. Did You Know . . . Because environmental legislation says that the waste generator is always responsible for the waste, superintendents could be held responsible for impacts which it might create, even after they have turned it over to a recycler and/or disposal contractor. 6. Transportation of more than 5 L of hazardous waste, special waste and/or waste dangerous goods is regulated under the legislation identified in Table 4.9 and in provincial and federal Transportation of Dangerous Goods legislation. Superintendents will have to obtain waste generator numbers from the provincial environment ministries, and "manifest" waste shipments. "Manifesting" refers to documenting the chain of custody associated with the storage, transportation and disposal of these waste products, such that the location of the waste can always be identified. An example of a waste manifest is presented in Figure 4.6. 7. Most municipalities have enacted a sewer release bylaw, which restricts the types of substances which can be disposed into municipal storm and sanitary sewers. Sanitary sewers are connected to a sewage treatment plant and hence, standards for discharge to sanitary sewers are normally less stringent than those associated with discharges to storm sewers. Storm sewers normally discharge directly to surface water bodies (e.g., streams, rivers and lakes) and hence, have very strict standards associated with them. In any event, municipal bylaws would normally not permit the disposal of waste oils or solvents to either the storm or sanitary sewer systems. 4.2.3 Standard Operating Practices A. WASTE OIL STORAGE Storage of waste oil is best managed in either drums or dedicated ASTs or USTs. The decision on which way to proceed is based on the volume of oil which requires storage. If large volumes must be stored, then it is more practical to utilize a single dedicated tank. Otherwise the use of drums is probably easier from a handling perspective, and less expensive as a capital investment is not required.
  6. 6. Did You Know . . . In deciding how much waste oil requires storage, it is important to remember that some provincial legislation specifies storage limits beyond which special facilities must be constructed. Table 4.9 summarizes these limits. Construction of these facilities can be expensive, so it may be prudent to plan your oil changing schedule in order to limit the volume of waste oil which requires storage. If a dedicated waste oil AST or UST having a volume greater than 250 L is utilized, then the standard operating practices described for fuel storage tanks in Section 4.1 should be incorporated into the design, construction and operation of the waste oil tank. A number of manufactured waste oil ASTs have been developed. Illustrations of two types of these tanks are presented in Figure 4.7. As previously noted, superintendents may wish to utilize drums or other small containers for storage of waste oils. Standard drums have a capacity of 205 L (45 USG). Advantages of drums are the ease of transport and removal as well as less stringent regulatory requirements. In the event that waste oil is stored in drums or small containers, the following storage procedures should be implemented: 1. Containers should be stored in an upright position. 2. Container caps should be tightened. 3. Containers should be protected from the rain and snow, which enhance corrosion. 4. Some form of secondary containment (e.g., a berm or dyke) should be constructed and installed around the containers. 5. Contents of the container(s) should be clearly marked and identified. 6. Containers should not be in contact with the ground, as this enhances corrosion. An easy method of providing secondary containment is the use of drip pans for each drum. Figure 4.8 presents a diagram of a drip pan. Drip pans are easy to install and require no construction. B. WASTE SOLVENT STORAGE The development of "parts washers" has provided a cost-effective method of: • Minimizing handling requirements for solvents and thereby minimizing spills • Providing easy access to solvents for cleaning purposes.
  7. 7. In addition, their use facilitates the collection of waste solvents for recycling purposes. Figure 4.9 presents a diagram of a typical "parts washer". As shown in this figure, once the solvent becomes unsuitable for further cleaning, the "parts washer" can be removed from the drum, and the drum can be picked up by a recycling contractor. Storage procedures for waste solvent drums should be similar to those presented for waste oil containers in Section A above. In particular, it is very important to ensure that the contents of the drum are clearly labeled. C. WASTE OIL DISPOSAL The best method for the disposal of waste oil is to have it recycled at a waste oil re- refinery. A number of these facilities are located throughout the country. A number of contractors offer local waste oil pick-up services. It should be noted that in some provinces, vendors of lubricating oils must provide either collection depots or a collection service for waste oil. For a listing of the contractors in your area, you should contact the provincial Environmental Services Association. A listing of addresses, telephone numbers and facsimile numbers for the provincial associations is presented in Table 4.11. If you are located in Quebec, Manitoba, Alberta, BC or Saskatchewan you can contact NUOMAC for recycling information, see next page for details. In selecting a contractor, it is important to remember that the transporter and the re- refinery must be licensed in some provinces. Proofof this should be supplied by the contractor. A note of caution to the superintendent regarding liability: adequately investigate the contractors’ procedures and methods of disposal in terms of environmental compliance. Provincial environment ministry personnel and provincial Environmental Services Associations are good places to obtain references for contractors. Manifesting of waste oils is required in some provinces (see Section 4.2.2). However, it is recommended that waste manifests be completed for all waste oil shipments. Under no circumstances should waste oils be disposed into sewer systems or spread onto roads or parking areas for dust control purposes. The use of waste oils, particularly for dust control, has been carried out extensively in the past. However, the presence of high concentrations of heavy metals and non-biodegradable hydrocarbons in waste oil can result in the contamination of underlying soils.
  8. 8. Did You Know . . . On December 1st 2004 five non-profit associations from Quebec, Manitoba, Saskatchewan, Alberta and British Columbia responsible for for collecting used oil, used oil filters and used plastic containers extended their cooperation to form the National Used Oil Material Advisory Council (NUOMAC). NUOMAC coordinates the Canada-wide used oil recycling effort and encourage consistent national standards for this unique and successful industry-led stewardship recycling program. In 1988, the Canadian Petroleum Products Institute (CPPI) commissioned a task force on used oil materials recycling at the request of the Canadian Council of Ministers of the Environment (CCME). What developed is a government-approved, industry-led used oil materials recycling program model that has been acknowledged world-wide as working environmentally, economically and socio-economically. Under the program, a network of return collection points has been established. The program is funded not by a government tax, but by an Environmental Handling Charge (EHC) remitted by all wholesale suppliers (first sellers) on lubricating products including filters and plastic containers. The EHC is remitted to the association(s) in the province(s) in which the wholesaler does business. A Return Incentive (RI) is then paid to private sector collectors and processors to pick-up and deliver to government approved recycling facilities where the materials are processed into new products. For more information on NUOMAC visit their website at: www.usedoilrecycling.com NUOMAC has mapped all of the Return Collection Facilities for small quantities and the Collectors and Processors throughout each participating province. Simply visit the homepage (see above link), drag the pointer with your cursor over your province, then do the same for your region or type in your address and postal code and a lit of local options will appear. D. WASTE SOLVENT DISPOSAL The best method for the disposal of waste solvents is to have them recycled at a distillation facility. A limited number of these facilities are located throughout Canada and the United States. Care should be taken in utilizing facilities in the United States as some provincial legislation prohibits the export of hazardous waste out of country. Similarly some provinces may restrict the importation of hazardous wastes. As with waste oil disposal, a number of contractors offer local waste solvent pick-up services. For a listing of the contractors in your area, you should contact the provincial Environmental Services Association. Requirements for contractor and recycler licensing should be investigated as recommended for waste oil disposal.
  9. 9. Did You Know . . . Provincial Environmental Services Associations will have lists of contractors offering waste oil and solvent collection and disposal services. Addresses, phone numbers and facsimile numbers are presented in Table 4.11. Given that waste solvents are classified as hazardous wastes, manifesting of shipments is required. This is further discussed in Section E. Waste solvents can also be transported to hazardous waste treatment and disposal facilities located in Swan Hills, Alberta and throughout the United States for incineration. However, given the high costs associated with these facilities, along with the access to recycling facilities, there is no need to consider their use. Under no circumstances should waste solvents be released into sewer systems or spread onto the ground. Solvents contain very mobile, light hydrocarbons, which readily migrate into groundwater supplies. In addition, the light hydrocarbons contained in solvents (e.g., benzene, toluene, etc.) are very toxic and can create significant environmental liabilities should they migrate into useable water supplies. Finally it is important to note that waste solvents must not be mixed with waste oils or other substances as a means of changing their hazardous classification. This will result in the entire solution being deemed hazardous, and will increase disposal costs. E. TRANSPORTATION AND MANIFESTING As previously mentioned, all hazardous wastes, special wastes and waste dangerous goods must be classified in accordance with provincial or federal Transportation of Dangerous Goods (TDG) regulations prior to transportation. In addition, all applicable requirements of the TDG regulations in both the province in which the waste was generated, and the province in which the waste is being treated or disposed of, must be complied with. In particular, superintendents should remember the following: 1. Waste generators are responsible for ensuring that each waste shipment is properly classified, documented, labeled and placarded. While the transport and disposal contractors should do this for you, it is your responsibility to ensure that it is done. 2. Documents should accompany each shipment, and copies should be kept on file for two years. 3. Manifests should accompany each waste shipment, unless the transporter has a Permit for Equivalent Level of Safety from the province(s). These permits allow for the transportation of some wastes with reduced levels of documentation. In particular, waste oil transporters often have these. If the transporter has one of these permits it is still important to remember the following:
  10. 10. a) Signed copies of the permits must accompany the shipment. b) Permits do not exempt the shipment from all TDG regulations - only certain portions of them. c) No exemptions apply if there is not compliance with all aspects of the permit conditions. d) Records of shipments transported should be maintained on file. 4. Waste manifests consist of three parts: Part A: Completed by the waste generator (also referred to as the Consignor) Part B: Completed by the transporter (or carrier) Part C: Completed by the waste receiver (also referred to as the Consignee) There are six copies of the manifest which must be properly distributed to ensure the proper tracking of the waste (and compliance with provincial and federal regulations). Copies must be sent to the applicable regulators. A copy of a waste manifest is presented in Figure 4.6. Instructions on completing the manifest are presented in Figure 4.10. A summary of the responsibilities of the generator, transporter and receiver relative to the waste manifests is presented in Figure 4.11. 5. For non-hazardous (or equivalent) wastes, manifests are not required. However, it is still a good idea to use them. Of course, distribution to regulators is not required in this case. As a minimum, truck tickets or waybills should be retained on file. Plain English, Eh! While TDG regulations and terminology (e.g., consignor, consignee, manifests, etc.) are a bit confusing, their purpose is simply to ensure that all interested parties know what has happened to a dangerous good or waste product.
  11. 11. 4.2.4 Colleague Example
  12. 12. Figure 4.6 Waste Management
  13. 13. Figure 4.7 Typical Waste Oil ASTs
  14. 14. Figure 4.8 Typical Drip Pan
  15. 15. Figure 4.9 Typical Solvent Parts Washer
  16. 16. Figure 4.10 Instructions for Completing the Waste Manifest The Waste Management must be completed and submitted for all wastes that have been classified as hazardous wastes and which must be transported, unless otherwise exempted (see specific waste information sheet). The following is a guide for the completion of Part A. The Consignor (Waste Generator); Box numbers refer to the sample manifest form contained on the previous page. The Consignor is responsible for completing Boxes 1-32 and for ensuring that Section B is completed by the Carrier. Box 1: Generator Number Boxes 2-3: Company Name and Facility Address Boxes 4-7: Shipping Site Address or Legal Description Identify the specific legal description or address of the location where the WDG was generated. In most cases, this is the same as Boxes 2 & 3. However, if the waste was generated at a wellsite connected to a gas plant, the name and address of the plant should appear in Boxes 2 & 3 and the legal description of the wellsite should be identified in Boxes 4 through 7. Boxes 8-14: Consignee’s (Receiver’s) Company Name, Receiver Number and Address Box 8: Name of company that is receiving the WDG Box 8: Provincial I.D. number of the receiving company Box 10: Mailing address of the receiving company Box 11-14: Address of the consignee’s receiving/storage/disposal facility Boxes 15-24: Waste Information Box 15: Physical state (gas, liquid or solid) Box 16: TDGR Proper name as indicated in Schedule II, List II of TDGR Box 17: Only required in Ontario and Quebec Box 18: Product Identification Number 9PIN), as indicated in TDGR Schedule II, List II. The word “Waste” must appear before the shipping name. Box 19: Quantity shipped – use kilograms of litres units of measure Box 20: Units – identify kilograms or litres. Box 21: TDGR Classification, as indicated in Schedule II, List II of TDGR Box 22: TDGR Packing Group, as indicated in Schedule II, List II of TDGR Box 23: Number of packages
  17. 17. Box 24: Package code as per following: Package Type Package Code Number Drum 01 Tank 02 Bulk 03 Carton 04 Bag 05 Roll-off (container or chassis) 06 Other 07 Box 25: Special Handling Emergency Instructions. Special requirements or instructions for handling the waste. If there is not enough room to fully complete securely attach a complete set of instructions to the manifest and indicate in small box called “Attached” Boxes 26-28: Date, Time and Schedule Arrival Date Box 29: Only required in Quebec Boxes 30-32: Consignor’s Certification Box 30: Consignor’s printed name Box 31: Consignor’s signature Box 32: Consignor’s business phone number
  18. 18. Figure 4.11 Summary of Responsibilities of Waste Generators, Transporters and Receivers THE WASTE GENERATOR MUST: 1. Ensure the facility has a consignor number and is approved under the authority of the provincial or federal government. 2. Complete Part A of the manifest. 3. Contract the services of a licensed transporter (carrier). Ensure the carrier is registered with the provincial or federal government. 4. Consign the waste to an approved facility. Ensure the facility has a consignee number and is approved by the provincial or federal government. 5. Sign all copies of the manifest and ensure the form is also signed by the carrier. 6. Retain Copy #2 on file for two years. 7. Send Copy #1 to the provincial or federal government. THE WASTE GENERATOR MUST: 1. Ensure provincial approval as a carrier. 2. Ensure all wastes are properly identified and manifested. 3. Sign the manifest prior to transport. 4. Complete Part B of the manifest. 5. Retain Copy #4 on file for two years. THE WASTE GENERATOR MUST: 1. Ensure provincial approval as a carrier. 2. Only accept wastes with a signed manifest. 3. Complete Part C of the manifest. 4. Send Copy #3 to the provincial or federal government. 5. Return Copy # 4 to carrier. 6. Retain Copy # 5 on file for two years. 7. Send Copy #6 to generator (consignor).