Reference_-_F_Hazardous_Waste_Disposal_Requirements_Report_10_30_22_v3f_3.pdf

Operation and Maintenance of Ohmsett Contract E17PC00014

Hazardous Waste Disposal Requirements Report

Prepared for:

BSEE Contracting Officer’s Representative (COR) Frank Jurado

BSEE Oil Preparedness Division 45600 Woodland Road

Sterling, VA 20166 Email: Frank.Jurado@bsee.gov

Phone: (571) 279-7896

Prepared by:

Applied Research Associates, Inc.

Ohmsett Facility P.O. Box 150

Leonardo, NJ 07737 www.ara.com

(732) 866-7183

Date: October 27, 2022 mailto:Frank.Jurado@bsee.gov http://www.ara.com/

Operation and Maintenance of Ohmsett Contract E17PC00014 i

Table of Contents

1. Requirement

2. Summary of Hazardous Waste Disposal Processes

2.1. Permitting

2.2. Oil Removal Service

2.3. Diatomaceous Earth Disposal

2.4. Sorbent Materials Disposal

2.5. Used Chemical Disposal

2.6. Wastewater Disposal

2.7. Hazard Communication, Safety Data Sheets, Labeling, Inventory, and Storage

2.7.1. Employee Training

2.7.2. Safety Data Sheets

2.7.3. Purchasing

2.7.4. Container Labels

2.7.5. Chemical Inventory

2.8. Department of Homeland Security Chemical Facility Anti-Terrorism Standards Status

Hazardous Waste Disposal Requirements Report

1. Requirement The Hazardous Waste Disposal Requirements Report, covering the period September 1, 2021, through August 31, 2022, includes a summary of the status of the following.

• Working with Naval Weapons Station Earle (NWSE) Environmental Department on all necessary permits for removing and disposing all hazardous and non-hazardous waste

• Planning for periodic removal service of used oil (as needed and in quantities over 100 gallons)

• Ensuring all storage of hazardous chemical by-products from the testing laboratory is done according to all applicable regulations

• Accounting for and labeling all hazardous chemical by-products, labeling and properly storing all hazardous chemicals used in the testing laboratory according to all applicable regulations

• Submitting Safety Data Sheets (SDS) to BSEE as necessary and ensuring SDS are organized and available for inspection in a single place at Ohmsett

2. Summary of Hazardous Waste Disposal Processes

2.1. Permitting

All permits are in place. ARA Ohmsett staff updated the New Jersey Pollutant Discharge Elimination System (NJPDES) Wastewater Discharge Permit and the New Jersey Community Right to Know (CRTK) program to reflect current contractor operation and point(s) of contact.

Permits are as follows.

• NJPDES Permit NJ0005762 for Surface Water Discharge N-2 Primary Licensed Operator: Allen Cannone Alternate Licensed Operator: Upon Rich Naples’ resignation, Joanne Letson and

Philip Sontag are pursuing N-2 licenses; New Jersey testing only occurs at specific times during the year.

The permit was issued July 1, 2022, and expires on June 30, 2027.

• CRTK Facility ID: 00000015137 CoMu 1331 (County/Municipality Codes: Monmouth County 13 and Middletown

Twp. 31) NAICS: 541712 (Research and Development Facility) POC: Tom Schmidt

2.2. Oil Removal Service

ARA selected Lorco Petroleum Services to remove oil contaminated liquid waste from the facility.

Removal services were performed both for general maintenance operations and as part of five-year tank maintenance and repair effort totaling 5,072 gallons of oily wastewater.

2.3. Diatomaceous Earth Disposal

Two types of used Diatomaceous Earth (DE) are generated at Ohmsett: (1) non-hazardous waste with <5% hydrocarbon content (by weight) and (2) hazardous waste with >5% hydrocarbon content. These materials are disposed of as follows.

1) <5% Content: This non-hazardous waste DE is generated as a byproduct from normal tank water filter operations. ARA contracted Republic Services/Waste Management for regular pickup of the DE for use as an I.D. 27 soil for daily cover material at landfills. Pickup and disposal are scheduled and occur routinely during the year.

2) >5% Content: This hazardous waste DE is typically generated only during dispersant or chemical herder testing; none of which has been produced during the reporting period.

ARA selected Veolia Environmental Services to provide a lined dumpster for collection and removal for incineration when necessary.

2.4. Sorbent Materials Disposal

Like DE, two types of waste sorbent materials are generated at Ohmsett: (1) non-hazardous waste material with <5% hydrocarbon content (by weight) and (2) hazardous waste material with >5% hydrocarbon content. These materials are disposed as follows.

1) <5% Content: This non-hazardous sorbent waste material is collected in the normal trash dumpster for landfill disposal in accordance with New Jersey Department of Environmental Protection (NJDEP) regulations through Republic Service/Waste Management.

2) >5% Content: This hazardous sorbent waste material is collected in 55-gallon drums and secured in the 90-day hazardous material storage cabinet for pickup and disposal by NWSE Environmental Department.

2.5. Used Chemical Disposal

All excess or waste chemicals from facility operations are collected in appropriate containers, stored in the 90-day hazardous material storage cabinet, and picked up for disposal by NWSE Environmental Department.

Laboratory chemical/solvent waste is collected in secondary containers located within the lab fume hood(s), transported to the 90-day hazardous material storage cabinet as necessary, and picked up for disposal by NWSE Environmental Department.

2.6. Wastewater Disposal

Routine and effective operations in the Ohmsett facility test tank require that the tank water level be maintained at 8 feet ± 5%. An inch of rain (or equivalent precipitation) in the open tank equates to approximately 1.3 inches of rise in the water level. This difference is due to the large amount of adjacent workspace and containment surfaces that drain to the tank. Evaporation rates from the tank surface are not sufficient to offset this rain accumulation. Significant periods of precipitation often result in a high water condition in the tank that is operationally unacceptable.

To counter this net gain in water level and allow the Ohmsett facility to continue to operate, it becomes necessary to periodically discharge water from the tank.

ARA uses two primary methods to discharge treated tank wastewater from Ohmsett. The primary method is through coordination and authorization from the Township of Middletown Sewer Authority (TOMSA) for sanitary sewer discharge. The secondary method is using the Ohmsett NJPDES Permit for Surface Water Discharge to Sandy Hook Bay. The bay discharge is used when the TOMSA resource is unavailable or when large quantities of water must be removed from the tank (e.g., preparing for the 2021–2022 tank refurbishment effort). In addition, rented fractionation tanks are utilized for excess water storage when discharge processes are being coordinated, allowing for the facility to remain operational during high water-level conditions.

These water discharge protocols and operational summaries are detailed in the concurrently submitted Other Disposal Requirements Report.

2.7. Hazard Communication, Safety Data Sheets, Labeling, Inventory, and Storage ARA updated the Ohmsett Health and Safety Plan (HASP) to reinvigorate an effective Hazardous Communication Program (HCP) that focuses on chemical safety guided by the OSHA Hazard Communication Standard. The standard mandates that employees have both a requirement and a right to know the identities and hazards of the chemicals they are potentially exposed to when working, and what protective measures should be implemented to prevent any adverse effects from occurring. The standard also requires chemical manufacturers to label each container of hazardous chemical product they produce with the names of the contained chemicals, the nature of the hazards, and the means of self-protection, or prepare and provide SDSs providing the same detailed information on the products for non-consumer items. Ohmsett obtains this information and supplies it to those employees who may be exposed to chemicals during daily duties.

Ohmsett will comply with the OSHA mandates by:

• Developing and maintaining a list of all hazardous chemicals in use in the workplace

• Evaluating the hazards of these chemicals

• Substituting less hazardous materials whenever possible

• Establishing proper work practices for using these chemicals

• Ensuring that every container of hazardous chemicals in the workplace is properly labeled

• Maintaining an SDS on each non-consumer hazardous chemical in use

• Having the SDS documents readily accessible in common directories

• Training employees on the hazards of all chemicals involved in their work effort, how to use them properly, where to find the SDSs, how to use them, and the employee's rights under the HCS

• Making the Ohmsett HCP available to all employees

• Never requiring employees to work with an unidentified hazardous substance

2.7.1. Employee Training

ARA will ensure all Ohmsett employees are trained on the HCP. This will include how to read container labels and SDSs before they are assigned a task involving the hazardous substance(s).

All new employees will be trained before they are assigned a task involving a hazardous substance and whenever any new chemical is introduced into the workplace. All training sessions will encourage questions and will focus on employee comprehension and understanding.

Specifically covered in the training sessions are:

• The details of this HCP, including an explanation of the labeling system, the SDSs, and how employees can obtain and use the hazard information

• Any operation in the work area where hazardous chemicals are present

• Methods and observations that can be used to detect the presence or release of a hazardous chemical in the work area

• The physical and health hazards of the chemicals in the work area

• The measures employees can take to protect themselves from these chemicals, including appropriate work practices, emergency procedures, and personal protective equipment to be used

2.7.2. Safety Data Sheets

ARA will ensure that SDSs are available for all chemicals in use at Ohmsett. These SDSs will always be accessible to employees and available for emergency operations. ARA will designate specific locations for directories, such as the laboratory or the filtration building. SDSs will be supplied to any employee immediately upon request when applicable. Requests for any missing SDSs will be included in the directories until they are received.

2.7.3. Purchasing

ARA will ensure that all vendors provide SDSs for all hazardous chemicals procured to support research and operations at Ohmsett. Copies of the SDSs will be reviewed by ARA and discussed as part of the Project Specific Safety Plan, as necessary. ARA will develop an effective mechanism for capturing all SDSs that are obtained and will ensure they are compiled in the directory.

2.7.4. Container Labels

Container labels provided by the chemical manufacturer, distributor, or importer must clearly identify the chemical(s) and list the necessary hazard warnings. The legible labels and any other forms of warning will not be removed or marked out. These hazard warnings and any instructions for use must be followed during storage and utilization of the product.

2.7.5. Chemical Inventory

ARA will prepare a baseline chemical inventory and file it in accordance with NSWE regulations.

ARA will also conduct periodic (not less than annually) inventories to keep the inventory list as current as possible, with emphasis on taking the broadest possible perspective when doing these surveys. The inventory will cover chemicals in all possible forms—liquids, solids, and gases. The inventory will be used to cross-check the SDS directories and ensure all SDS documents are present.

2.8. Department of Homeland Security Chemical Facility Anti-Terrorism Standards Status Chemical Facility Anti-Terrorism Standards (CFATS) is the national regulatory program focused specifically on security at high-risk chemical facilities. The Department of Homeland Security (DHS) manages the CFATS program by working with facilities to ensure they have security measures in place to reduce the risks associated with certain hazardous chemicals and prevent them from being exploited in a terrorist attack. Ohmsett staff have self-assessed the facility and determined that storage quantities of Chemicals of Interest (COI) are below triggering amounts for CFATS oversight.

2.8. Department of Homeland Security Chemical Facility Anti-Terrorism Standards Status