2014 Caterpillar EH&S Conference -
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The 2014 Caterpillar EH&S Conference is being held in Denver, Colorado from may 5 through May 8
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2014 Caterpillar EH&S Conference -
- 1. Caterpillar Site Waste Characterization May 6, 2014 David Horowitz Slideshare: @dphorowitz Twitter @dphorowitz Youtube: dphorowitz 2014 Caterpillar EH&S Conference Denver, Colorado
- 2. Waste Characterization Takeaways ■ Three media – Evaluate all three ■ Permitting & Planning – We’ll provide some examples ■ Aren’t Always Obvious – Those hidden gems can be painful
- 3. Agenda ■ Media Streams – Air – Water – Waste – ……. Tanks!
- 4. Media Stream - Air
- 5. Media Stream – Air (Spray Booths) ■ 6H Applicability
- 6. Media Stream – Air (Spray Booths) Simple Notification Form
- 7. ■ R.I.C.E. – Reciprocating Internal Combustion Engines ■ NESHAPS = National Emission Standards for Hazardous Air Pollutants ■ HAPs = Hazardous air pollutants – Clean Air Act – Published in 40 CFR Parts 61 & 63 – Currently there are over 165 regulated source categories Media Stream – Air (Generators)
- 8. ■ Notifications ■ Emissions Limitations ■ Controls ■ Operating Limitations ■ Fuel Requirements ■ Performance Tests ■ Monitoring ■ Recordkeeping ■ Reporting Media Stream – Air (Generators)
- 9. ■ What qualifies as an emergency stationary RICE? – No limit on use during emergency situations – Maintenance checks/readiness testing limited to 100 hours/yr – 50 hours/year of non-emergency operation is allowable » Counts toward the 100 hours/year – No peak shaving or to generate income » Except for up to 15 hours/year for demand response ■ What qualifies as a limited use stationary RICE? – Less than 100 hours per year Media Stream – Air (Generators)
- 10. Media Stream – Air (Waste Oil Burning)
- 11. Media Stream – Air (Waste Oil Burning)
- 12. Media Stream – Air (Waste Oil Burning)
- 15. Normal Venting
- 17. Spill Containers
- 19. Interstice
- 20. Double Wall AST Remote Spill Box/Fill Fuel Dispenser Fuel Pump Interstitial Leak Detection Spill Kit Normal Vent Labels
- 21. Double Wall AST Dispenser Hose Bollards Secondary Tank Emergency Vent Primary Tank Emergency Vent Mechanical Gauge Preventive Limiting Barrier Concrete Pad 1.5-inches Nut
- 22. Dike Tank Integral Containment Rain Shield
- 23. Ideal Installation – Generator Tank
- 24. Observation Results ■ 200+ Tanks observed for tank integrity ■ One* with >75% wall thickness losses – Compared to existing standards ■ Most with regulatory, code compliance, operational issues – Vent heights & vent configuration/operation – No overfill protection / Level detection devices – Not UL 142 standard construction – No spill prevention devices – Improper protection from vehicular impact ■ Some with evident corrosion – Interior of double wall – External
- 25. Florida Leak Study ■ Florida has ~50,000 registered, active tanks at ~20,000 sites ■ 82% of the ASTs have secondary containment ■ 188 discharges from shop- fabricated ASTs (the type of tank that hospitals typically have)
- 26. Florida Leak Study ■ Top causes of failures from these ASTs (Accounting for 65% of the failures) were: – Overfills – Spills – Physical damage – Loose components
- 27. Media Stream - Water
- 28. Media Stream – Water (Wastewater)
- 29. ■ Wastewater Generation – Cleaning Operations ■ Discharge Wastewater – Sewer Authority » POTW – Tight Tank » Disposal – Septic System – Evaporation – Closed Loop – Stormwater Media Stream – Water (Wastewater)
- 30. Media Stream – Water (Stormwater)
- 31. Western States Wagner Equipment Milton- CAT Media Stream – Water (Stormwater)
- 32. ■ Most states are delegated to oversee program – 46 are delegated – States issue permits ■ Four states are not delegated – Massachusetts (Milton-CAT) – New Hampshire (Milton-CAT) – Idaho (Western States Eqpt.) – New Mexico (Wagner Equipment Co.) – EPA issues permits ■ Most sites likely not applicable Media Stream – Water (Stormwater)
- 33. Media Stream – Solid Waste
- 34. Media Stream – Solid Waste Waste Oil Paint Booth Filters Dirt from Vehicle Washing Oil Absorbent Material Oil Filters Aerosol Spray Cans Waste Light Bulbs Fuel Filters Waste Antifreeze Empty Containers Mercury Switches Cathode Ray Tubes Waste Paint/Solvent Vehicle Wash Water Vehicle Batteries Vehicle Air Bags
- 35. ■ Waste Determination/Characterization ■ Generator Status Determination ■ Waste Accumulation Areas ■ Container Accumulation Standards ■ Record keeping ■ Shipping ■ Inspections ■ Training Media Stream – Solid Waste
- 36. ■ Batteries ■ Mercury-containing thermostats ■ Lamps (including but not limited to fluorescent, neon and mercury vapor lamps) ■ Used electronics Media Stream – Solid Waste (Universal Waste)
- 37. ■ Store for less than one year ■ Store up to 5,000 kg (otherwise considered Large Quantity Handler) ■ Waste or outer package labeled “Universal Waste …” ■ Adequate aisle space ■ Managed to prevent damage / breakage ■ Contain broken or leaking waste Media Stream – Solid Waste (Universal Waste)
- 38. ■ Good condition ■ Not leaking (see above) ■ Labeled “Used Oil” ■ Secondary containment Media Stream – Solid Waste (Universal Waste)
- 39. Waste Characterization Takeaways ■ Three media – Evaluate all three ■ Permitting & Planning – We’ll provide some examples ■ Aren’t Always Obvious – Those hidden gems can be painful
- 40. Questions
- 41. ■ Store for less than one year ■ Store up to 5,000 kg (otherwise considered Large Quantity Handler) ■ Waste or outer package labeled “Universal Waste …” ■ Adequate aisle space ■ Managed to prevent damage / breakage ■ Contain broken or leaking waste Media Stream – Solid Waste (Universal Waste)
Editor's Notes
- Well – these are states that are NOT delegated in the SW program EPA issues the SW general permits for construction activities > 1 acre and for many industrial sites under the MSGP. The MS4 program was issued jointly by EPA and DEP – thus creating separate state and federal permits – providing equal regulatory and enforcement authority for both. Industrial Renew your MSGP Coverage Update your SWPPP September issuance January 2014 deadline
- Well – these are states that are NOT delegated in the SW program EPA issues the SW general permits for construction activities > 1 acre and for many industrial sites under the MSGP. The MS4 program was issued jointly by EPA and DEP – thus creating separate state and federal permits – providing equal regulatory and enforcement authority for both. Industrial Renew your MSGP Coverage Update your SWPPP September issuance January 2014 deadline
- Well – these are states that are NOT delegated in the SW program EPA issues the SW general permits for construction activities > 1 acre and for many industrial sites under the MSGP. The MS4 program was issued jointly by EPA and DEP – thus creating separate state and federal permits – providing equal regulatory and enforcement authority for both. Industrial Renew your MSGP Coverage Update your SWPPP September issuance January 2014 deadline