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IADA FAQ Chapter Eight

Hazardous Waste Laws and Regulations


Current Laws and Regulations

Several laws govern the generation and disposal of hazardous waste. These laws and their accompanying regulations were meant to regulate hazardous waste from the "cradle to grave". There are five sets of laws and regulations applicable to a small quantity generator (SQG) relative to disposal of a waste.

  1. Resource Conservation and Recovery Act (RCRA) Gives the Federal EPA the authority to regulate hazardous waste.
  2. Comprehensive Environmental Reclamation, Compensation and Liability Act (CERCLA) - Also known as "Superfund". Pays for cleanup of old waste sites.
  3. Department of Transportation (DOT) Regulations - Govern methods by which hazardous wastes are shipped.
  4. Illinois Special Waste Regulations - Govern the disposal of hazardous and many non-hazardous special wastes in Illinois
  5. Hazardous and Solid Waste Amendments of 1984 (HSWA) Expand the scope of RCRA in many ways, including the establishment of SQG regulations.

A small quantity generator (SQG) is defined as any business or generator that produces a sum of hazardous waste greater than 200 lbs. per month (approximately 1/2 of a 55 gallon drum) and less than 2200 lbs per month (approximately five 55 gallon drums). A large quantity generator is a business or generator that produces a sum of waste greater than 2200 lbs. per month.

Determining whether a hazardous waste is generated for the purpose of estimating the pounds of waste generated is not always easy. The following is a list of hazardous wastes generally procured by an automotive service department, but it is not all-inclusive. In general, if you have any questions as to the hazardous status of a waste, refer to the Material Safety Data Sheet for the product or contact the vendor or manufacturer.

  • degreasers
  • carburetor cleaners parts
  • solvents paint containing heavy metals
  • paint thinners
  • laquer thinners
  • cleaning residues
  • used motor oil; currently an "Illinois Special Waste"
  • batteries

It is important to remember that under CERCLA, anyone who has ever had anything to do with a particular hazardous waste site could be considered a Potential Responsible Party (PRP) and could be held responsible for all or part of the cleanup expense.

This could include not only the site`s operator, but also anyone who has ever transported material to the site or generated material that was sent to the site. It does not matter whether the past disposal practices were legal.

The majority of dealership service and bodyshop departments will generate less than 2200 lbs per month. Therefore, the following regulatory requirements will be specific to the SQG.

Notification Requirements: If a dealership determines that it is in fact a SQG, it must notify the United States Protection Agency (USEPA) and the Illinois Environmental Protection Agency (IEPA) of its activities . This is done by filling out USEPA form 8700-12, and mailing it to the IEPA. The SQG will also need to fill out an Illinois Generator I.D. Number Request Form. Both of these forms are available through the IEPA at 217/7826760.

Storage Requirements: A SQG may accumulate hazardous waste on-site for up to 180 days, or 270 days if the nearest licensed treatment, storage and disposal (TSD) facility is more than 200 miles away. The total quantity stored cannot exceed 13,200 lbs. When hazardous wastes are stored on-site, the following precautions must be taken:

  1. Hazardous wastes must be stored in containers that are in good condition and compatible with the waste being stored.
  2. Containers must be clearly labeled with the words "Hazardous Waste" and the date that the waste was first put into the container.
  3. Containers must be inspected by the generator at least weekly. If the container begins to leak, the contents must be immediately transferred to another container.
  4. Containers should be kept closed during storage, except when adding or removing waste.
  5. Incompatible wastes must not be placed in the same container.
  6. The owner/operator of the dealership must ensure that all employees are familiar with proper waste handling and emergency procedures. This is not as stringent a requirement as the formalized training requirements for large quantity generators. Instead, it requires that employees know where the telephone is, where the spill control material is, how to use a fire extinguisher, etc.
  7. If a fire or spill spreads beyond the property, the dealership must contact the National Response Center 800/424-8802.
  8. In general, fire safety standards must meet National Fire Protection Association Codes.

Transporters and Disposal Facilities: SQGs must use transporters and disposal facilities that have IEPA Identification numbers and are permitted to handle the type of waste generated.

Manifesting Requirements: A manifest is a one-page form with 5 carbon copies. It accompanies the hazardous waste shipment from its point of origin (the small quantity generator) to its is point of disposal (the TSD facility). Its purpose is to track the shipment from the "cradle to the grave" to insure that the shipment of hazardous waste reaches the intended destination. As the shipment makes its way to its final disposal point, carbon copies are torn off and either kept by the generators, transporters, and TDS's or sent to the IEPA according to the manifest instruction.

If waste is to be shipped out of state, the receiving state's manifest should be used. Always check with the environmental agency of the state receiving the waste to find out about any special requirement in that state.

Record-Keeping Requirements: The new SQG regulations require that generators keep their copies of each manifest for three years. HWRIC recommends that generators keep these copies indefinitely.

Above and beyond the minimum requirements, it is advisable for SQGs to keep well-organized records in every aspect of their hazardous waste activities, including:

  1. Written documentation of the procedure used to carry out quantity determination.
  2. A copy of the original notice of hazardous waste activity.
  3. A copy of the acknowledgment of receipt and number assignment received from the USEPA.
  4. Contracts with haulers and TSDs.
  5. Records that indicate compliance with storage requirements.
  6. Copies of all manifests for shipments that have been sent out.

It is also advisable to keep these records well organized and in a place that can be reached quickly should an inspection occur. Good record-keeping will make an inspection go much more smoothly than when records are incomplete and not well organized.

Illinois Special Waste Requirements: The state of Illinois has regulated quantities of hazardous waste down to 220 lbs. since 1979 through its special waste regulations. These regulations apply not only to hazardous wastes, but also to all "industrial process wastes", i.e., used motor oil.

The wastes that are defined as special waste by the State of Illinois, carry the same "cradle to grave" responsibility.

Anti-Freeze: The USEPA and IEPA do not classify used anti-freeze as hazardous waste. The IEPA has stated that it is permissible to dispose of anti-freeze in your local sanitary system, once permission is received in writing from the local sanitary district office.

To determine whether your local sanitary district accepts or prohibits the disposal of anti-freeze, you should contact the district office, or the IEPA Division of Water, Industrial Permit Section.

If your sanitary district prohibits the disposal of used anti-freeze into the system, check with your hazardous waste disposal company regarding the disposal or recycling of the anti-freeze.

What To Look For, Where To Find It:

There are three different types of firms that a dealership may consider:

  1. Transporter to pick up and haul the waste.
  2. Transfer and storage facility that takes a generator`s waste and combines it with other wastes of similar types to make shipments of a size suitable to take to a large disposal or recycling firm.
  3. TSD facilities that ultimately dispose or recycle the waste.
    It is advisable to deal with a disposal or recycling firm that offers services in all three areas.

Evaluating a Disposal or Recycling Facility:

Before selecting a disposer, a dealership should ask some basic questions and be sure that certain requirements are met:

  1. TSDs must have a hazardous waste I.D. number similar to the number received by the generator from the USEPA and IEPA. When shipping to out-of-state TSD facilities, generators should be sure to check permit requirements of the state receiving the waste.
  2. TSD facilities must be permitted to dispose of or treat the particular type of wastes received from the generator.
  3. Records of previous violations should be carefully examined. If a dealership has any questions or doubts concerning how its waste is being disposed of, it can contact the IEPA, as these records are open to public scrutiny. Most TSDs will have been cited for some violations at one time or another, but consistent or serious violations, or violations that continue to be unresolved may be a sign of trouble. It is also a good suggestion to talk to the IEPA personnel who actually conduct TSD inspections.
  4. TSD facilities must have the ability to pay for closure of the disposal site at the end of its useful life and must also have insurance to cover damages resulting from sudden accidents or chronic environmental leaks causing long term damage. Always ask to see proof of insurance and financial stability.


The most important point to remember is that a common-sense approach must be used in evaluating a TSD. Some facilities have operated with all appropriate permits in place, but have operated poorly and ended up being Superfund sites. Dealerships must evaluate their options carefully, and use only facilities that they feel are trustworthy. As the generator, you assume the "cradle to grave" liability and are ultimately responsible for the proper disposal of all waste your dealership generates.

GOOD HOUSEKEEPING PRACTICES

Why Are Good Housekeeping Practices Important?

The potential danger of a hazardous waste does not go away when it`s put into a container. Many chemical leaks and work-related injuries are due to improper or unsafe container management.

Accidents happen. Hazardous waste spills, fires and explosions can result in serious injuries, significant property damage, and expensive clean-up costs. It is your responsibility to minimize these accidents by following the basic good housekeeping practices in this guide.

What Is A Proper Waste Container?

Store hazardous and non-hazardous special wastes in containers that are in good condition and compatible with the waste being stored (i.e., strong acids should not be stored in unlined steel drums).

Keep incompatible wastes in separate areas to reduce the risk of a potentially dangerous reaction and accident. Incompatible wastes should not be placed in the same container. Mixing a spent acid (i.e., sulfuric acid) with a spent caustic material (i.e., sodium hydroxide) could result in dangerously high temperatures or a violent chemical reaction.

Keep storage containers closed except when adding or removing waste. This will help reduce the evaporation of some volatile gases and minimize the chance of spills, fires or explosions.

How Do I Design A Proper Storage Area?

Store containers on pallets so leaks can be detected early and the containers can be moved easily during an emergency.

Waste storage areas should have a diked, crack-free concrete floor or pad so if containers leak, the waste does not contaminate underlying or adjacent soils, sewers, or bodies of waters.

There should be sufficient aisle space (at least 30 inches) between the containers to allow for easy container inspection and easy movement of emergency and spill control equipment.

Protect the containers from the weather by storing the containers under a roof. This will reduce corrosion, infiltration of water through the bung holes, and the effects of weathering on labels and signs.

Why Should I Label Containers?

Label containers clearly so you know their contents at all times. For example, write the words "HAZARDOUS WASTE" on the label if that is what you are accumulating. Include an easily understood description of the waste and the hazards associated with the waste (i.e., "ignitable" or "toxic").

Record the date you begin accumulating hazardous waste and mark the date on the container when it is full. These steps will help you determine how much hazardous waste you generate in a calendar month. The amount of waste you generate determines what requirements you must meet.

When you transfer a waste (i.e., hazardous or non-hazardous special waste) to another container, make sure you put a label on the new container and remove the label from the old one (unless you will use it to hold the same type of wastes immediately after).

How Are Containers To Be Emptied And Disposed?

All waste containers may go to a solid waste landfill or a scrap metal dealer if you remove all the waste and residue from the container. Remove all wastes by triple rinsing the container with a solvent capable of dissolving any residue in the container.

IF YOU ARE UNABLE TO COMPLETELY EMPTY A WASTE CONTAINER,

YOU MUST SEND THE CONTAINER TO EITHER A SPECIAL WASTE

LANDFILL OR A HAZARDOUS WASTE LANDFILL.

To send a hazardous waste container to a special waste landfill you must:

  1. Remove all residue possible, leaving less than one inch of residue in the container or;
  2. Leave less than three percent of residue from the total capacity of the container (e.g.: three percent of a 55-gallon drum is 1.7 gallons).

    These containers can then be sent to a special waste landfill.

However, containers that stored hazardous waste and still contain stubborn waste residue must be sent to a hazardous waste landfill.

For more information about what types of wastes you may have at your business, please refer to IEPA Fact Sheet: "How to Determine What Types of Waste You Generate and What Are Your Responsibilities",

When Should I Conduct A Self-Inspection?

Inspect the containers every week. If a container begins to corrode or leak, immediately clean up the waste and transfer to another container.

How Should I Prepare For Emergencies?

Severe accidents can be minimized if you are prepared. Make arrangements with local authorities (police, fire departments, etc.) to familiarize them with the types of materials stored and the layout of the facility.

Designate an "emergency coordinator." This coordinator might be the owner, foreman, or main person in charge on each shift and should be "on call" at all times.

Post the name and number of the emergency coordinator, the location of fire extinguishers, spill control material, the fire alarm, and the telephone number of the fire department and the Illinois Emergency Management Agency (IEMA) next to the telephone.

The owner or operator of the facility should ensure all employees are familiar with proper waste handling and emergency procedures (i.e., what materials are hazardous, where the telephone is, where the spill control materials are, how to use the fire extinguisher, etc.).

What If An Accidental Spill Or Leak Occurs?

Clean up any chemical spills or leaks immediately so that you do not contaminate surface waters, groundwaters, soils, or sewer systems.

Call the Illinois Emergency Management Agency (IEMA) at their 24-hour emergency phone number (800/782-7860) to report any chemical spills or leaks.

Things To Remember?

Do not discard any waste into an open dump, ravine, gully, surface impoundment, or ditch. Your waste must go to a permitted landfill. Ask your hauler to supply proof of proper disposal of your trash.

Do not rinse or drain hazardous and non-hazardous special wastes into the sanitary or storm sewer, creek, ditch, septic system, or underground tank. Chemicals poured, spilled, or leaked into sewer systems can form explosive vapors in sewers or basements or disrupt municipal wastewater treatment plant operations. Discharges underground may poison private or public water supplies, while discharges to surface waters may kill fish, livestock, or other wildlife.

Hazardous and non-hazardous special wastes cannot be discarded into the dumpster, roll-off box, or trash cans that are used for general refuse. The wastes may catch fire or injure your waste hauler or workers at the landfill.

Don`t store hazardous wastes on site more than 90 days without consulting: What Types of Wastes Does Your Small Business Generate and What Are Your Responsibilities, found in the IEPA Small Business Series, Steps to Managing Wastes. You may also contact the Illinois Environmental Protection Agency Land Permit section at 217/524-3300 or:

1021 N. Grand Ave

P. 0. Box 19276

Springfield, IL 62794-9276

217/524-3300

 

 

WALKING AND WORKING SURFACES AISLES AND FLOORS

 

O.K.

 

ATTENTION

  1. Are all places of employment kept clean and orderly?
     
       
  • Are floors, aisles and passageways kept clean and dry and all spills of oil or grease cleaned up immediately?
     
       
  • Are floor holes, such as drains, covered?
     
       
  • Are all working surfaces, such as aisles and service bays free from clutter or obstruction?
     
       
  • Are storage lofts, balconies, etc., that are more than 4 feet above the floor protected with guard rails?
     
       
  • Are all lofts and balconies where people or machinery could be exposed to falling objects guarded with standard 4-inch toeboards?
     
       
  • Is the safety leg or hoist safety pin always positioned when using lifts?
     
       
  • When using a lift, is each vehicle checked for proper positioning just after wheels have left the floor?
     

STAIRS

  • Are there standard stair rails (34") on all stairways?
     
       
  • Are all stairways at least 22 inches wide?
     
       
  • Do stairs have at least a 7-foot overhead clearance?
     
       
  • Are stairs and surfaces maintained free of tripping and slipping hazards?
     

 

LADDERS

  • Have defective ladders (e.g. broken rungs, side rails, etc.) been removed from service for repair or destruction and tagged as "Dangerous Do Not Use"?
     
       
  • Is it prohibited to use the top of an ordinary step ladder as a step? (No Step Decal)
     
       
  • Do fixed ladders have at least 3 1/2 feet extensions at the top of the landing?
     
       
  • Do portable rung ladders have non-slip bases?
     

 

EXITS

  • Are all exits marked with an exit sign and illuminated by a reliable light source?
     
       
  • Is the lettering at least 6 inches high with the principal letter strokes at least 3/4 inch wide?
     
       
  • Is the direction of exits, when not immediately apparent, marked with visible signs?
     
       
  • Are doors or other passageways, that are neither exits nor access to an exit, and located where they may be mistaken for exits,
     
appropriately marked "Not An Exit", "To Basement",

"Storeroom", etc.?

     
       
  • Are exit doors side-hinged?
     
       
  • Are all doors that must be passed through to reach an exit, or way to an exit, always free to access with no possibility of a person being locked inside?
     
       
  • Are all exits always kept free of obstructions?
     

 

HEALTH AND ENVIRONMENTAL CONTROL

  • Are engines turned off except when using the tail pipe exhaust system.
     
       
  • Are the gas space heaters properly vented?
     
       
  • Are employees properly protected during dusty and noisy work processes?
     
       
  • Are solvent soaked, greasy, or oily rags and combustible materials disposed of in covered metal containers and emptied daily?
     
       
  • Is the battery charging area ventilated and designated as a NO SMOKING area?
     
 

HAZARDOUS MATERIALS FLAMMABLE

AND COMBUSTIBLE LIQUIDS

  • Is paint stored in approved UL or FM approved metal or wood cabinets or storage rooms?
     
       
  • Do storage rooms have explosion proof lights?
     
       
  • Is non-flammable solvent used in the parts cleaner?
     
       
  • Are bulk drums of flammable liquids grounded and bonded to containers during dispensing?
     
       
  • Is there never more than 1 day's supply of paint outside of approved storage cabinet or room?
     
       
  • Are all spills of flammable or combustible liquids cleaned up promptly?
     
       
  • Are storage racks and platforms posted with their load limit capacity?
     
       
  • Gasoline should never be used for cleaning purposes.
     
       

 

PAINT SPRAY OPERATIONS

  • Are portable lamps removed during spray operations?
     
       
  • Do solvents used for cleaning have high flash points? (Spray equipment may be cleaned with low flash point thinners, if done in properly ventilated area.)
     
       
  • Are fire control sprinkler heads kept clean?
     
       
  • Are NO SMOKING signs posted in the spray area, paint room, paint booth and paint storage area?
     
       
  • Is the spray area a least 30 feet from flame, sparks, electric motors or other ignition sources?
     
       
  • Is the spray area free of hot surfaces?
     
       
  • Are electric lamps in spray area enclosed and guarded?
     
       
  • Is the spray area kept clean of combustible residue?
     
       
  • Are spray booths constructed of metal, masonry, or substantial non-combustible material?
     
       
  • Are spray booth floors and baffles non-combustible and easily cleaned?
     
       
  • Do spray booths have explosion proof lights or are they lit through sealed clear panels?
     
       
  • Is mechanical ventilation on during spray operations?
     
       
  • Do booths have independent exhaust systems?
     
       
  • Is the electrical motor for exhaust fan placed outside booth or ducts?
     
       
  • Are belts and pulleys inside booth fully enclosed?
     
       
  • Is air exhausted from spray operation removed from the ventilation system?
     
       
  • Do ducts have access doors to allow cleanings?
     
       
  • Is make-up air heater located outside the spray booth?
     
       
  • Do over spray filters have pressure gauges to indicate need for filter replacement?
     
       
  • Do all drying spaces have adequate ventilation?
     
       
  • Is the spray area used for drying with portable heaters,or heat lamps, kept clean of over spray deposits?
     
       
  • Is the infra-red apparatus kept out of spray area during spraying operations?
     
       
  • Is the spray area completely ventilated before using drying apparatus?
     
       
  • Is spray booth ventilation system operated during drying process?
     
       
  • Is the electrical drying apparatus properly grounded?
     

 

PERSONAL PROTECTIVE EQUIPMENT

  • Is eye protection provided and used when using bench grinders, right angle grinders, etc.?
     
       
  • Are rubber gloves provided and worn when cleaning parts, handling body fillers, paint thinners, etc.?
     
       
  • Is hand and eye protection used when removing radiator caps to protect from steam and hot liquids?
     
       
  • Is a battery carrier strap used when removing or carrying batteries?
     
       
  • Are respirators provided and worn during dusty operations, paint spraying, etc.?
     
       
  • Is there a minimal respirator program when respirators are used?
     
       
  • Are ear plugs or muffs provided and worn during noisy conditions?
     
       
  • Are proper lifting techniques used to prevent back injuries?
     
       
  • Have employees received training on the "Right to Know" law?
     
       
  • Do employees receive any form of safety training?
     
       

 

SANITATION

  • Are restrooms and washrooms kept in clean and sanitary condition?
     
       
  • Are covered receptacles for waste food kept in a clean and sanitary condition?
     
       

MEDICAL AND FIRST AID

  • In the absence of a nearby clinic or hospital, is at least one employee on each shift currently qualified to render first aid? (Some states require first aid trained persons regardless of nearby clinics or hospitals.)
     
       
  • Are approved first aid supplies readily available, inspected and replenished?
     
       
  • Are emergency telephone numbers posted at each phone location?
     
       
  • Are extinguishers selected for type of materials in areas where they are to be used?
     
       
Class A Ordinary combustible-materials fires

Class B Flammable liquid, gas or grease fires

Class C Energized electrical-equipment fires

     
       
  • Are extinguishers fully charged and mounted in designated places?
     
       
  • Are extinguishers located along normal paths of travel?
     
       
  • Are extinguishers free from obstruction or blockage?
     
       
  • Are extinguishers not mounted too high? If less than 40 lbs., the top must be below 5 ft. above the floor, greater than 40 lbs., the top must be below 3 1/2 ft. above floor.
     
       
  • Have all extinguishers been serviced, maintained, and tagged at intervals not to exceed one year.
     
       
  • Are all extinguishers checked (by manager or designated employee) monthly to see if they are in place, or if they have been activated, etc.?
     
       
  • Have all extinguishers been hydrostatically tested according to schedules set for the type of extinguisher?
     

COMPRESSED AIR EQUIPMENT

  • Is compressed air which is used for cleaning reduced to 30 psi when dead ended? (Can be accomplished by using special nozzles or air pressure reducing valves.)
     
       
  • Are compressed air tanks drained regularly?
     
       
  • Do the relief valves operate properly?
     

 

MACHINE AND MACHINE GUARDING

  • Are all points of power transmission properly guarded? (e.g. belts and pulleys on motors, compressors, rotating shafts, sprockets and gears, etc.)
     
       
  • Are all pieces of equipment with an electric motor or any electrical connection effectively grounded?
     
       
  • Are all fan blades seven feet, or less, from the floor guarded in such a manner that there exists no openings greater than 1/2 inch?
     
       
  • Is all fixed machinery securely anchored to prevent movement?
     
       
  • Are sprockets and V-belt drives within reach of platforms and passageways, or less than seven feet from the floor completely closed?
     
       
  • Is the adjustable tongue on top side of grinder used and kept adjusted to within 1/4 inch of wheel?
     
       
  • Are spindle guards being used?
     
       
  • Are bench and pedestal grinders permanently mounted?
     
       
  • Are goggles or face shields always worn when grinding?
     

 

HAND AND PORTABLE POWER TOOLS

  • Have mushroomed heads on chisels, punches, etc. been replaced?
     
       
  • Have broken hammer handles been replaced?
     
       
  • Have worn or bent wrenches been replaced?
     
       
  • Have deteriorated air hoses been replaced?
     
       
  • Are portable abrasive wheels appropriately guarded (e.g., right angle grinders)?
     
       
  • Are jacks checked periodically to see if they are in good condition?
     
       
  • Are cars on jacks cribbed, blocked or secured at once?
     
       
  • Are support stands always used after the vehicle has been raised with a hydraulic jack?
     

WELDING, CUTTING, BRAZING

  • Are cylinders stored away from heat?
     
       
  • Are gas cylinders and oxygen cylinders separated by 20 feet or a barrier 5 feet high?
     
       
  • Are cylinders secured and stored where they cannot be knocked over?
     
       
  • Are cylinder protective caps in place when not in use?
     
       
  • Are the valves shut off when not in use?
     
       
  • Are flash shields provided to protect nearby workers from the welding flash?
     
       
  • Is ventilation, or are respirators provided when welding or cutting in confined spaces?
     
       
  • Is welding always conducted at a safe distance from flammable liquids?
     

ELECTRICAL WIRING

  • Have exposed wires, frayed cords, deteriorated insulation been repaired or replaced?
     
       
  • Are junction boxes, outlets, switches, etc., covered?
     
       
  • Are breaker switches identified as to their use?
     

 

GROUNDING

  • Is all metal, fixed quipment grounded?
     
       
  • Does all equipment connected by cord and plug have grounded connections?
     
       
  • Are appliances such as vacuums, polishers, vending machines, etc., grounded?
     
       
  • Do all hand and power tools have double insulation, or are they grounded?
     
       
  • Do all extension cords being used have a ground wire?
     
       
  • Are all plugs equipped with ground pins?
     

 

FLEXIBLE CORDS AND CABLES

  • Do flexible cords and cables not run through holes in wall or ceiling?
     
       
  • Are flexible cords and cables free from splices or tape?
     
       
  • Are flexible cords and cables fastened so that there is no direct pull on joints or terminal screws?
     
       
  • Are flexible cords and cables never substituted for fixed wiring?
     
       
  • Are flexible cords and cables not attached to building surfaces?
     
       

 

ASBESTOS

  • Do you minimize airborne asbestos by always using the "Wet Method" for brake and clutch repair; or, even better, do you use an enclosed cylinder/HEPA filter vacuum system?
     

DON’T WAIT UNTIL 1998

This fact sheet lists the basic upgrade requirements for existing USTs. Start planning your upgrade, closure or replacement as soon as possible!

DON’T WAIT...

Was your UST installed before December 22, 1988?

If the answer is "yes," by December 22, 1998, you must:

  • Upgrade the UST by adding spill, overfill and corrosion protection, or
  • Replace it with a new UST that has spill, overfill and corrosion protection, or
  • Properly close the old UST.

The information that follows will help you upgrade, replace or close USTs.

Remember the deadline: December 22, 1998.

 

SPILL PROTECTION

Spills often occur at the fill pipe when the delivery truck’s hose is disconnected. You must add spill protection by installing a "spill bucket." A spill bucket is a catchment basin sealed around the fill pipe and designed to catch spills from fuel delivery. Some spill buckets look like the one below:

 

If you and your delivery driver follow standard fuel delivery practices, nearly all spills and overfills can be prevented.

OVERFILL PROTECTION

Overfill equipment is designed to restrict or stop the flow of fuel during delivery before the tank reaches full capacity. Your UST needs to have one of the following overfill protection devices:

  • An automatic shutoff device, or
  • An overfill alarm, or
  • A ball float valve.

Overfill devices may look like these below:

CORROSION PROTECTION

Many older USTs leak because corrosion has damaged the metal and produced corrosion holes. You must protect your existing UST from external corrosion.

Some existing USTs already meet the corrosion protection requirements if they are made of noncorrodible materials (such as fiberglass) or their exteriors are heavily coated with noncorrodible material (such as ACT-100 tanks). Also steel tanks that have a corrosion-resistant coating and cathodic protection (such as sti-P3 tanks)meet the corrosion protection requirements.

If your tank is not one of these already protected from corrosion, you must add equipment that protects your existing tank from the damage of corrosion. You have three choices:

  • Add cathodic protection, or
  • Add tank interior lining, or
  • Combine cathodic protection and tank interior lining.

 

Cathodic Protection

There are two types of cathodic protection and both must be designed by corrosion experts. One type, sacrificial anodes, is commonly used with new steel tanks having corrosion-resistant coatings. For existing bare metal tanks, corrosion experts recommend another type called an "impressed current system." This system supplies a continuous underground electrical current that protects the UST from corrosion.

Tank Interior Lining

To protect a tank from corrosion, trained professionals must empty the tank, clean the interior to a white metal surface, check the soundness of the tank, make any necessary repairs, add a thick layer of noncorrodible material and conduct follow-up inspections.

Note: Flexible inner liners (bladders) that fit inside a tank do not meet the tank interior lining requirements.

 

PIPING

Existing piping must also be protected from corrosion. Piping made of (or enclosed in) noncorrodible material (such as fiberglass) meets the corrosion protection requirements. Existing metal piping must have cathodic protection, and new metal piping must have cathodic protection and a corrosion-resistant coating.

REPLACING USTs

Existing USTs can be replaced only by properly installing new USTs that have spill, overfill and corrosion protection. Don’t forget, all new and existing USTs must meet leak detection requirements.

 

CLOSING USTs

If USTs are not closed properly, they can leak and create problems. You need to notify the Office of the State Fire Marshall that you intend to close your UST. Then make sure only trained professionals safely and correctly close your UST.

 

Upgrade or Replace Early

  • As December 1998 nears, increased customer demand to upgrade, close, or replace USTs may result in higher charges for these services.
  • Early upgrading prevents leaks that would otherwise occur between now and December 1998.

 

 

DON’T LET 1998 ARRIVE BEFORE YOU ARE READY!

AREA HAZARD ASSESSMENT SURVEY

INSTRUCTIONS: Copy this form and keep the original for future hazard assessments. Conduct a walk-through survey of the areas in question using a copy of this form. It will assist you in determining what hazards are present or are likely to be present in the work area.

Date:________________________________________ Job Classification:___________________________
Area:________________________________________ Shift:   Dept:   Group:   Team:  
   
Job Name:___________________________________ Job Description:____________________________
Assessor:____________________________________  

 

AFFECTED PERSONAL AREA

 

 

ELECTRICAL HAZARDS

  Insulating Blankets
  Matting
  Covers
  Line Hose
  Electrical Gloves
  Electrical Sleeves

GUIDELINES FOR SELECTING PERSONAL PROTECTIVE EQUIPMENT (PPE)

NOTE: Personal Protective Equipment alone should not be relied upon to provide protection against hazards, but should be used in conjunction with guards, engineering controls and sound manufacturing practices.

 
  1. Familiarize yourself with the potential hazards in the area and the types of PPE that are available.
 
  • Consider the hazards associated with the environment (impact velocities, masses, projectable shape, radiation intensities, etc.).
 
  • Select PPE that ensures a greater level of protection than the minimum required to protect workers from the hazards.
 
  • Fit the worker with the PPE and give instructions on its use and care. It is very important that workers be made aware of all warning labels for, and limitations of their PPE.

GUIDELINES FOR TRAINING PERSONNEL ON PERSONAL PROTECTIVE EQUIPMENT (PPE)

NOTE: The employer shall provide training to each employee who is required to use Personal Protective Equipment. Each such employee shall be trained to know at least the following.

  When PPE is necessary.
  What PPE is necessary.
  How to properly don, doff, adjust and wear PPE.
  The limitations of the PPE.

EYE OR FACE HAZARDS MAY INCLUDE THE FOLLOWING:

  Flying Particle
  Molten Metal
  Liquid Chemical
  Acids or Caustic Liquids
  Chemical Gases or Vapors
  Light Radiation
Tasks that may cause eye hazards include: Working with acids and chemicals, chipping, grinding, lasers, furnace operations, sanding, welding, woodworking, etc.
PPE SOLUTION RECOMMENDATION: _________________________________________________

RESPIRATORY HAZARDS MAY INCLUDE CONTAMINATION FROM ANY OF THE FOLLOWING: (Name the contaminant and concentration)

  Lack of Oxygen
  Dust, Mists, Fumes
  Gases
  Vapors
Tasks that may cause respiratory hazards include: Working with acids and chemicals, grinding, welding, painting, confined space, mining, grain bin operations, etc.
PPE SOLUTION RECOMMENDATION: ___________________________________________

HEAD HAZARDS MAY INCLUDE ANY OF THE FOLLOWING:

  Impact
  Electrical Shock
  Falling Objects
  Chemical Splash
Tasks that may cause head hazards include: Working below other workers who are using tools and materials which could fall, working under machinery or processes which might cause materials or objects to fall, working with chemicals, working on energized electrical equipment, etc.
PPE SOLUTION RECOMMENDATION: __________________________________________________

FOOT HAZARDS MAY INCLUDE ANY OF THE FOLLOWING:

  Falling or Rolling Objects
  Objects Piercing the Sole
  Chemical Hazards
  Electrical Hazards
Tasks that may cause foot hazards include: Carrying and handling materials that could be dropped, manual handling and working with hazards, working around energized electrical equipment, working with chemicals. Slips, etc.
PPE SOLUTION RECOMMENDATION: _____________________________________________________

HAND HAZARDS MAY INCLUDE ANY OF THE FOLLOWING:

  Skin Absorbsion of Harmful Substance
  Cuts or Lacerations
  Abrasions
  Punctures
  Chemical
  Thermal Burns/Temperature Extremes
Tasks that may cause hand hazards include: Chemical handling, welding, handling sharp objects, handling hot objects, etc.
PPE SOLUTION RECOMMENDATION: ___________________________________________________

ELECTRICAL HAZARDS MAY INCLUDE ANY OF THE FOLLOWING:

  Energized Electrical Equipment
Tasks that may cause electrical hazards include: Lineman’s job, electrical maintenance, trenching operations, etc.
PPE SOLUTION RECOMMENDATION: ___________________________________________________