[Sqg-program] TIP FOR THE DAY...Management of Empty Containers and Potential Liabilities

[Perrigan, Glen]

The following is from Charles Emery from the DEP South District Office. =
He
has been working with Collier County Pollution Control  Dept. to enhance
their SQG Program. Charles offers some good advice on management of open
containers and potential liabilities that can and do occur. Thanks =
Charles
for the tip.=20

NOTE: If any of the DEP inspectors around the state have tips that they =
would
like to share, please pass them on. This information is very helpful.

I have often told facilities that empty drums are a liability, =
especially if
allowed to fill with rain water. Generally speaking we (DEP) do not =
allow
facilities to simply call materials in drums rain water and allow them =
to
kick the drums over and discharge them to the ground. Even if they =
contained
rained water the act of empting to the ground establishes a bad =
precedent,
may result in contamination to the site if in fact the drums did not all
contain rain water and may cause a liability issue to the regulatory =
entity
who might agree with the facility and allow for the discharge to the =
ground.

Having said all of this, Collier County handled a recent event where a
facility was discovered to  have had 31 fifty-five gallons drums on site =
of
which contained varying amounts of alleged water. The facility claimed =
rain
water and wanted to dump to the ground. We said no and asked the =
facility to
ship the material off site as industrial waste water.  After =
consolidation
the facility had eighteen full 55-gallon drums. They shipped the drums =
off
site at a cost of $3150 dollars.=20

The moral to the story is, "That empty containers are liabilities =
waiting to
happen. If you don't need a particular container get a rid of it =
properly. If
you want to keep a container you better manage it in a manner that =
doesn't
allow it to collect  rain water".=20

Charles

Charles Emery III
Environmental Manager
Hazardous Waste Program
South District Office - DEP
P.O. Box 2549  Fort Myers, FL 33902-2549
Telephone (239) 332-6975 Ext 150
FAX    (239) 332-6969
Internet  Charles.Emery@DEP.STATE.FL.US


Glen Perrigan
FDEP, Hazardous Waste Management Section
2600 Blair Stone Road  MS-4555
Tallahassee, Florida 32399-2400
Florida Department of Environmental Protection
850-245-8749 Fax:  850-412-0528
E-mail: glen.perrigan@dep.state.fl.us
Website:   www.dep.state.fl.us/waste