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Industrial & Manufacturing Services Blog

Should I over pack that drum?

Posted by Rebecca McDaniel

By Amanda Mendonza, Technical Services Representative

Shipping chemical waste is a dangerous business. Beyond studying and utilizing the 49 CFR (aka the DOT regulations) the bare minimum expected is that the containers are in safe transportable condition.  Proper DOT packaging is achieved when hazardous materials are placed in a container that is rated for those hazard characteristics and closed properly. What if that DOT packaging is compromised or not-DOT shippable? These instances will require a DOT-approved overpack or salvage drum to remedy the situation. Note: the overpack drum must also be rated to transport the chemical contents in case there is a full breach of the original outer container.

Most of the time it is be pretty obvious when there is a problem with the “outer container:”

  • Is there no DOT rating?
  • Is the top missing?
  • Is one or both of the bungs missing or not seating properly?
  • Is there a puncture or hole in the drum (whether leaking or not)?
  • Is the bottom rotted out?
  • Has the drum been crushed (compactor incident)?
  • Is there a dent affecting the balance/stability?
  • Is the drum bulging?

There will be instances where overpacking a drum may not appear so obvious but is going to provide the safest, most compliant transportation:

  • Is the drum rusted such that the DOT rating is not visible?
  • Are the contents not compatible with the type of drum?
  • Is the drum “wet” (fiber drums)?
  • Is the drum discolored or unable to be handled due to severe chemical contamination?
  • Was the drum in a fire?

It is very important that hazardous materials be securely packaged at all costs necessary to maintain the safety of the personnel handling it, the fleet transporting it and the environment surrounding it.

Impact of Lead

Posted by Rebecca McDaniel

By Greg Rosinski, Chemist II

Anyone involved with household buildings prior to 1978 need to become mindful of the human health risks posed by the presence of lead. Lead was one of the primary ingredients in paint prior to 1978. Until lead became properly regulated by the EPA and other state agencies, the human health effects posed to site occupants were never considered. The following items are cautioned to contain lead:

  • Paint
  • Soil around the home absorbed from deteriorating paint chips.
  • Household dust from walking in contaminated soil.
  • Drinking water from lead soldered plumbing.
  • Old painted toys and furniture.
  • Food and liquids stored in lead crystal or lead-glazed pottery or porcelain.
  • Lead smelters or other industries that release lead into the air.
  • Hobbies that use lead, such as making pottery or stained glass, or refinishing furniture.

To prevent the exposure of lead, it is necessary to clean up any dust in a home, especially with families with young children. . Another method is to contact professional abatement companies that will come in, and safely remove lead paint from a home to eliminate and/or significantly decrease the exposure.

The effects on children if lead exposure is ignored include headaches, hearing problems, slowed growth, behavioral problems, and damage to the brain and nervous system. The effects on adults include reproductive problems, high blood pressure, nerve disorders, hypertension, and muscle and joint pain. For more information on the human health effects posed by lead as well as the corrective action measures to eliminate exposure in a residential building, please visit the EPA website (www.epa.gov).

Bill is the Next Step in Modernizing US Chemical Safety Regulations

Posted by Mark Campanale

Written By Matthew Bauer, Marketing Intern

On July 22, U.S. Representatives Bobby Rush (D-IL), chair of the Subcommittee on Commerce, Trade, and Consumer Protection, and Henry Waxman (D-CA), chair of the Committee on Energy and Commerce, introduced H.R. 5820, the Toxic Chemicals Safety Act.   The following is a brief summary of the key provisions of the Toxic Chemicals Safety Act of 2010:

  • Establishes a framework to ensure that all chemical substances to which the American people are exposed will be reviewed for safety and restricted where necessary to protect public health and the environment.
  • Requires the chemical industry to develop and provide to the U.S. Environmental Protection Agency essential data, and improves EPA’s authority to compel testing where necessary.
  • Ensures that non-confidential information submitted to EPA is shared with the public and that critical confidential information is shared among regulators, with states, and with workers in the chemical industry.
  • Creates incentives and a review process for safer alternatives to existing chemicals as well as a workforce education and training program in green chemistry.
  • Promotes research to advance understanding of children’s vulnerability to the harms of chemicals.
  • Encourages the reduction of the use of animals in chemical testing.

This bill is a step forward in the modernization of the nation’s chemical safety regulation; the last update being the 1976 Toxic Substances Control Act (TSCA.)  The current law is widely perceived as a flawed and out of date system.  Under the current TSCA, virtually none of the 80,000 chemicals on the market today are regulated, despite many known links to autism, asthma, reproductive disorders, and cancer.

The 2010 reforms ensure public safety by regulating the chemicals in consumer products.  Supporters of the bill believe stricter regulation will greatly benefit the day to day lives of every single American. 

Although many believe the current system needs revisions, many are opposed to the proposed bill. The American Chemistry Council (ACC,) the group that represents the leading companies in the $674 Billion Chemical industry had this to say about the bill: “The federal chemical regulatory system must ensure public safety, protect the ability of American business to innovate, and preserve American jobs. This bill will need more work to get us there.”   Those in the chemical industry worry the proposal will stifle innovation.  With this stricter law many chemical companies will be forced to shut down or downsize, which would result in a loss of jobs.  Stricter regulation of chemicals would have a significant impact on this very important sector of the U.S. economy. 

Supporters of the bill disagree with the opposition’s argument.  They believe stricter regulation will incentivize innovation.  New greener, cleaner, and safer chemical alternatives will need to be created in order to comply with the new regulation.  This increase in needed innovation would actually create more jobs and improve the state of the U.S economy. 

With such strong opposition, it will be very interesting to see whether the bill will make progress in the coming months.  No matter the outcome though, this proposal has initiated a very important conversation.

Bill is Next Step Toward Modernizing US Chemical Safety Regulations

Posted by Mark Campanale

Written By Matthew Bauer, Marketing Intern

On July 22, U.S. Representatives Bobby Rush (D-IL), chair of the Subcommittee on Commerce, Trade, and Consumer Protection, and Henry Waxman (D-CA), chair of the Committee on Energy and Commerce, introduced H.R. 5820, the Toxic Chemicals Safety Act.   The following is a brief summary of the key provisions of the Toxic Chemicals Safety Act of 2010:

  • Establishes a framework to ensure that all chemical substances to which the American people are exposed will be reviewed for safety and restricted where necessary to protect public health and the environment.
  • Requires the chemical industry to develop and provide to the U.S. Environmental Protection Agency essential data, and improves EPA’s authority to compel testing where necessary.
  • Ensures that non-confidential information submitted to EPA is shared with the public and that critical confidential information is shared among regulators, with states, and with workers in the chemical industry.
  • Creates incentives and a review process for safer alternatives to existing chemicals as well as a workforce education and training program in green chemistry.
  • Promotes research to advance understanding of children’s vulnerability to the harms of chemicals.
  • Encourages the reduction of the use of animals in chemical testing.

This bill is a step forward in the modernization of the nation’s chemical safety regulation; the last update being the 1976 Toxic Substances Control Act (TSCA.)  The current law is widely perceived as a flawed and out of date system.  Under the current TSCA, virtually none of the 80,000 chemicals on the market today are regulated, despite many known links to autism, asthma, reproductive disorders, and cancer.

The 2010 reforms ensure public safety by regulating the chemicals in consumer products.  Supporters of the bill believe stricter regulation will greatly benefit the day to day lives of every single American. 

Although many believe the current system needs revisions, many are opposed to the proposed bill. The American Chemistry Council (ACC,) the group that represents the leading companies in the $674 Billion Chemical industry had this to say about the bill: “The federal chemical regulatory system must ensure public safety, protect the ability of American business to innovate, and preserve American jobs. This bill will need more work to get us there.”   Those in the chemical industry worry the proposal will stifle innovation.  With this stricter law many chemical companies will be forced to shut down or downsize, which would result in a loss of jobs.  Stricter regulation of chemicals would have a significant impact on this very important sector of the U.S. economy. 

Supporters of the bill disagree with the opposition’s argument.  They believe stricter regulation will incentivize innovation.  New greener, cleaner, and safer chemical alternatives will need to be created in order to comply with the new regulation.  This increase in needed innovation would actually create more jobs and improve the state of the U.S economy. 

With such strong opposition, it will be very interesting to see whether the bill will make progress in the coming months.  No matter the outcome though, this proposal has initiated a very important conversation.

Oil Water Separator Maintenance

Posted by Rebecca McDaniel

Dave Williamson,  Industrial Account Manager

Oil water separators (OWS) can be costly to maintain and if not properly managed, can pollute surface and ground water which typically leads to costly violations. Have you taken steps to minimize the effects of your OWS on your budget and the environment?

Eliminate contaminants: Don't rely on the OWS to handle wash water from fuel, coolant, solvent, oil, or paint spills. Instead, clean up spills when and where they occur with dry methods.

Wash without detergents: Emulsifying cleaning compounds disperse oil in wash water and make OWSs ineffective—oil passes right through to the sewer. High pressure water or non-emulsifying cleaners are sufficient for most cleaning applications.

Minimize loading: Minimize the amount of solids and oils that enter your OWS. The less solids and oils that reach the OWS, the less frequently sludge and floating oil must be removed from the OWS and the better it will work. Also, minimize the amount of wash water reaching the OWS. Excessive water flow can flood an OWS, forcing wastewater through it too fast to allow separation; the result: oil and other contaminants pass right through to the sewer.

Reduce sludge build up in OWS: If possible eliminate storm water flow into the OWS using berms or curbs solids have less time to settle. Install additional grates and screens on drains. Use sloping pavement and sediment traps around drains

Set-up a maintenance schedule: A field service crew with a Cusco Vacuum Truck can perform this service by pumping the sludge and oil then pressure washing from the surface. The Vacuum Truck then removes the rinsates. For larger OWS a confined space entry may be required.

Trickledown Environmental Effects of a Gulf Coast Disaster

Posted by Rebecca McDaniel

By Brian Boissonneault, Industrial Account Manager


Once again, we are dealing with a disaster in the Gulf of Mexico. If you thought exposure to this incident was limited by geography, think again. The effects, whether direct or not, will be felt by businesses and communities across the nation. It has happened before.


In 2005 Hurricane Katrina wreaked havoc on the Gulf Coast with high winds, floods and lightning. The result of such a massive catastrophe left the area in ruins. This event claimed 1836 lives and caused $81 billion in damage. A large portion of that money was spent on environmental cleanup. The flood caused containment pools and wastewater treatment systems to flood. The winds dropped buildings onto hazardous materials storage areas and the lightning caused extended power outages to chemical manufacturers.


In the ensuing months large environmental companies deployed resources from all over the country to the Gulf Coast to help with the cleanup. This mass deployment left a large vacuum in its wake. Areas of the country otherwise unaffected by this or any other hurricane, had to deal with the side effects. Businesses within these communities had to deal with depleted resources from their environmental services providers, leaving them out compliance and without the assistance of their trusted advisor at times. The majority of the cleanup took months and there are still some activities going on today. The companies who responded to the gulf profited handsomely.


Fast-forward to today and we're seeing the same thing over again. However, the extent of the damage from the oil spill in the Gulf of Mexico looks to dwarf Katrina's environmental impact exponentially. The cleanup will likely be longer, more difficult and more costly. At the time of this blog entry, the source of the leak has yet to be shut off. Large environmental companies are once again sending all available resources to the area. Businesses far removed from the gulf coast will surely again experience service failures from their environmental services company as a indirect result of this spill.


There are a few things you can do to prepare yourself and your program for failures. Ask your environmental services provider what their response to the incident is and how it has affected your local resources. Ask them how they plan to deal with unscheduled events, such as spills, fires, etc. These questions can also be used to gauge the level of customer service between you and your provider. It may also be a great time to look at bringing on a backup vendor and having them trained and ready to go in the event of a service failure by your primary.


Disasters in the gulf, or anywhere, affect us all. You can take just a few steps to prepare for the tough road ahead. Be sure you are working with a service provider who is as invested in your environmental program as you are.

Petroleum Aboveground Storage Tank Cleaning Procedures

Posted by Rebecca McDaniel

By Craig Childres, Director of Business Development - Petroleum & Energy

Aboveground storage tanks are large steel cylinders that are used to store petroleum products. Periodically either due to regulatory inspections requirements, a change of product within the tank or needed repairs, petroleum aboveground storage tank requires cleaning. Cleaning of petroleum aboveground tank should be performed by highly trained crews with the necessary experience and certifications. Below is a general guide to cleaning AST's

For all daily site work, crews must be TWIC certified, be current with all trainings and maintain proper insurance. The crew should perform a daily on-site safety meeting covering all of the possible related safety issues. This meeting will be documented and a representative of the owner should participate. The crew needs to obtain the necessary work permits from the owner and go through the lock-out tag-out on the tank each day. The isolation of the piping and valves associated with the aboveground tank should have occurred and tank ventilation should be in place prior to the crew arriving at the site. The crew should verify that all blinds and blanks are in place and set up a safe and secure work area including a decontamination area. A site specific Health & Safety Plan (HASP) needs to be prepared followed and maintained at the work site.

The tank cleaning crew, consisting of a minimum of three people and all the proper equipment vacuum truck for product removal, support trucks, pressure washers confined space entry/rescue gear, supplied air (SCBA) system, and proper PPE will be needed. The crew will set up the confined space entry equipment around the tank using the front manway as the only entry and exit manway into the tank. An approved and properly calibrated air monitoring meter should be used to evaluate the atmosphere in the tank and the tank should be continuously vented throughout the cleaning process. The entrant crew will enter the tank and work the recoverable product with squeegee's to the vacuum truck hose placed in the center of the tank. Using the pressure washer, the entrant/crew will water wash the interior floor and wall usually to the first weld ring. Larger aboveground tanks are worked in quarters so as not to contaminate an area already cleaned. The vacuum truck will be used to remove the water rinse/sludge and to transport all wastes offsite for disposal/recycling. Once the tank is completely cleaned, a Gas Free/Safe for Hot work can be issued by a Certified Marine Chemist.

OSRO’s and Oil Spill Cleanup Methods

Posted by Rebecca McDaniel

By Craig Childres, Director of Business Development - Petroleum & Energy

When an oil spill occurs, the oil forms a thin slick that floats on the water. As the oil spreads, it thins out, provided the source of the leak has been stopped and will eventually becomes a sheen. The speed in which a cleanup crew, or OSRO (Oil Spill Response Organization) can reach a spill, along with other factors (tide/current, impacted shoreline, weather, etc.), determines what method(s) the OSRO may use to perform the cleanup.


Usually if the OSRO can reach the spill within the first few hours the best method is containment and skimming. Containment booms, made of heavy gauge plastic covering foam like material along with a weight skirt that trails under the water will keep the oil from spreading out. This makes it easier to skim oil from the surface, using portable skimmers or boats that remove the oil, but leave the water behind. The recovered oil is collected in tanks or vacuum trucks and hauled off site for recycling or disposal.


When oil is contained or near a shoreline it can also be collected by the use of sorbents. Sorbents are usually made of synthetic material that is hydrophobic (repels water) and olephillic (loves oil). These sorbets come in the form of pads, sheets, long tubes (socks or boom) or OSRO's can use snare or pom-poms. Snare is shredded polypropylene tied together and placed in sensitive areas affected by the spill to recover the oil.


When an oil spill reached quickly these are the easiest to clean up by one of these methods. Oil spill cleanup is generally a very dirty, hazardous and environmentally threatening process.

 


EPA Proposed Effluent Guidelines for Airport Deicing Waste

Posted by Rebecca McDaniel

By Brian Boissonneault, Industrial Account Manager

On August 28, 2009 the U.S. EPA issued a proposed rule regarding the effluent standards from airport deicing activities. Under this proposed rule, EPA is proposing technology-based effluent limitation guidelines (ELG) and New Source Performance Standards (NSPS) under the Clean Water Act (CWA). The ELGs would be incorporated into the NPDES permits issued by EPA, states and tribes. EPA expects that compliance with this regulation would reduce the discharge of deicing regulated pollutants by at lease 44.6 million pounds annually. The proposed guidelines would apply to primary commercial airports whose annual departures exceed 1000 and perform deicing operations. There may be others included in the regulation once it is announced.

The proposed rules would affect two pollutant sources: aircraft deicing fluid and airfield pavement deicers. Airports with more than 1,000 but less than 10,000 annual departures would be required to meet the standards for only airfield pavement deicers. Airports with annual departures in excess of 10,000 would need to meet both standards for airfield pavement deicers and aircraft deicing fluids.

After an exhaustive study of both effectiveness of pollution reduction methods and cost estimates for implementing measures to meet the new standards, EPA has proposed best available technologies (BAT) for managing both airfield pavement deicers and aircraft deicing fluids. These proposals may include changes, additions, or upgrades to the current programs employed at operating airports. The EPA has also proposed management standards for new sources of pollutants at new airports.

Elements to consider for compliance with the proposed regulations:

  • Annual Departures
  • Volume of aircraft deicing fluids used annually
  • Chemical composition of airfield pavement deicers
  • Type of collection system employed for aircraft deicing fluids
  • On-site Waste water treatment capabilities and efficiencies
  • Local pretreatment effluent standards before discharge to POTW
Triumvirate Environmental is ready to take you over this new hurdle. Contact a representative for help sorting through your compliance with the proposed regulation.

Catch Basin Maintenance

Posted by Rebecca McDaniel

Dave Williamson, Industrial Account Manager

Most industrial companies have a routine schedule for cleaning all oil/water separators but often forgotten is the maintenance on catch basins. A catch basin is a part of a storm drain or sewer system which is designed to trap debris so that it cannot enter the drainage pipes. Most municipal sewer and storm drainage systems use catch basins, and the design is basically the same all over the world, with a few small variations.


Catch basins have a wide sloping inlet which collects runoff, assuring that even when high volumes of water are being dumped into the system, there is minimal overflow. The inlet opens to a pipe which is covered with a grating. The grating traps large debris, preventing it from entering the piping. As water floods the catch basin, small particles which slip through the grate settle to the bottom. Drainage pipes are located above the bottom of this vertical pipe, ensuring that the water which flows into the drains is clear of sediment.


If the catch basin is not maintained, eventually the debris rises to the level of the outlet pipe which sends debris and sediment into the storm water system. It is generally recommended the catch basins are serviced annually to avoid any potential environmental issues. Most catch basins can be clean from surface level utilizing a Vactor Truck equipped with hard pipe to remove the debris and sediment. Surface level pressure washing may also be required. Please contact Triumvirate to set up a routine maintenance schedule.