TXO RELIABILITY AND MAINTENANCE GENERAL ENVIRONMENTAL AWARENESS Air, Waste and Water DOW CONFIDENTIAL - Do not share without permission 281947 Be sure

TXO RELIABILITY AND MAINTENANCE GENERAL

ENVIRONMENTAL AWARENESS

Air, Waste and Water

DOW CONFIDENTIAL - Do not share without permission

281947

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Overview

Historically Maintenance has been over looked in regards to environmental regulations.

Maintenance DOES have an impact on the environment.


Training Objective

This course is designed to inform maintenance of the permitting regulations, requirements and responsibilities.

This is a general overview and is not a substitute for the detailed training on a specific regulation in your maintenance area.


Individual Expectations

Contact your Health/Safety tech or Environmental tech or specialist BEFORE changes are made that could potentially affect an air, water or waste emission.

Always use management of change (MOC); ensure the right reviewers are listed.

Ask questions -- regulations are increasing, if something is questionable contact your Environmental tech or specialist immediately.


Why are we training?

We have multiple cases of violations of permit requirements: A few: A Safety Kleen machine was new to a maintenance shop

and was not permitted, nor were monthly inspections conducted.

Enclosed dry abrasive blasters did not meet the filtering velocity of the regulation. This was existing equipment that was not identified in the permit.

Quarterly visible emissions inspections on multiple combustion units were not conducted.

Unapproved paint purchased at local paint store was used in a facility.

These all resulted in Title V deviations.


Types of Permits

Permits: Air, Water, Waste Title V Permit O-02217

Pertains to air regulations Maintenance, Startup and Shutdown Permit

MSS 83839 Permit to conduct any type of painting, linings and

coatings on site within certain limits SPCC Plan -- Spill Pollution Countermeasure and

Control Pertains to water regulations

RCRA Permit -- Resource Conservation Recovery Act Pertains to waste management


Air

Title V Permits regulate air emissions. An air emission can be anything that creates a particulate

matter (silica, titanium dioxide etc.) or a Volatile Organic Compound (VOC) emission into the air Cold solvent cleaners (for example - Safety Kleen) Enclosed dry abrasive blasters *Outside dry abrasive blasting Fugitive monitoring Propylene or ethylene Combustion sources such as stationary

engines, boilers, flares, etc. *Any type of outside painting, lining

or coating*Must be reported to the environmental tech or specialist prior to the start of the job.


Maintenance, Startup and Shutdown Permit MSS 83839 regulates emissions from planned maintenance, startup and shutdown painting activities.Some special considerations Any type of outside painting, lining or coating excluding aerosol

cans. All painting work must be coordinated through MSA . Contractor company must be on the ASML. Approval of new paint and each job must occur through MSA

and Site Maintenance EHS ahead of time. At least 3 weeks notice to authorize.

Outside dry abrasive blasting. Usage of any dry abrasive blaster outside must be permitted

and approved by your environmental specialist PRIOR TO BEGINNING WORK.

Usage limitations per day apply. Regulates the hours when painting can be conducted.

Air


Water

SPCC Plan regulates oil/oil-like substance storage that can be discharged into navigable waters. Site Maintenance has one SPCC Plan.

What does this mean: All inventory must be documented within the plan if containers are

55 gallons or more. Depending on the containment, daily, weekly or monthly

inspections must occur. This includes equipment that uses oil like substances such as

transformers. Rain Water Discharge checklist must be conducted prior

to discharging water out of the dike. Water must not be held in a dike for longer than 24 hours. WHY? This containment is needed in the event a spill occurs.


Waste

RCRA regulates the disposal of solid and hazardous waste. Every day we generate waste from office

trash to oily rags. Waste requires a waste profile number (WPN). Preplanning is required before generating

waste. MSDS required.

Contact an Environmental tech or specialist for assistance.


Waste

If waste needs to be stored, it must be stored in a registered location to comply with RCRA and Dow rules.

Waste must be stored in one of the following: Non-hazardous container storage area (CSA). RCRA Satellite area – storage limit of 3 days for only 55 gallons. RCRA less than 90 day CSA – storage limit of 90 days. Universal Waste Storage Area is exclusively for UNWANTED

aerosol cans, light bulbs, batteries etc. IF one determines or references an

aerosol can as trash, waste, or empty a violation has occurred unless the can is in a satellite area or <90 day CSA. Maintenance DOES NOT make this determination. Maintenance only determines if the aerosol can is wanted or not.


SARA Reporting

SARA reporting Monthly CTT/MTL Task Targets any hazardous, non-hazardous

chemicals or oils. Environmental tech will ask each department

for additions or deletions of chemicals or oil each month

Storage and usage will be used for annual reporting which is reviewed by MPLs each year.

MSDS must be provided to capture information for environmental reporting


Management of Change (MOC) MOCs are required for changes, additions AND

removals from service. MOCs trigger the review of the permit requirements and

authorize various tasks that keep us in compliance with requirements including:

Inspection requirements and frequencies identified. Record retention identified. Monitoring requirements. Permit update. Unique numbers assigned to equipment. A CTT task downloaded into MTL.

Failure to comply with requirements could result in a violation/deviation.

For the purposes of environmental regulations temporary is defined as 6 months.


Consequences of Violation/Deviation

Failure to meet the Title V or MSS 83839 permit requirements can result in a deviation.

Failure to meet the requirements of SPCC or RCRA can result in a notice of violation (NOV).

Root cause investigations are conducted for deviations or violations against permit requirements.

A fine may be imposed. Permits may be revoked. Additional inspections may be triggered.


Conclusion

Maintenance has accountability for permitting and compliance. Equipment or any type of work that has the potential to create

an emission of particulate matter or a volatile organic compound (VOC) needs to be addressed. Example: garnet, sand silica, quartz, propylene, ethylene, natural

gasoline, diesel, benzene, refrigerants etc… Chemicals or oil being stored on site should be reported to

your environmental tech or specialist to comply with SARA and annual environmental reporting.

New waste streams should be requested ahead of time to allow time for processing.

Be familiar with your equipment and what makes it run (air, gas, diesel, etc.)

If you are in doubt, contact EHS.


Related documents

Site Maintenance Certified Spill Prevention Control & Countermeasure (SPCC) Plan

Paint Services Web Page- Contact your Dow sponsor

Approved Cleaning Solvents

http://mansvcadmin.intranet.dow.com/Services/Pai_Coat_Serv.htm

http://mansvcadmin.intranet.dow.com/Services/Pai_Coat_Serv.htm


Revision History

Revision history The following information documents at least the last 3 changes to this document, with all the changes listed for the last 6 months.

Date Revised By Changes

October 2012 Natalie Wisby Created Training

April 2013 Rivier/Wisby Updated for MyLearning

Documents

TXO RELIABILITY AND MAINTENANCE GENERAL ENVIRONMENTAL AWARENESS Air, Waste and Water DOW CONFIDENTIAL - Do not share without permission 281947 Be sure