[Sqg-program] how to deal with a drum allegedly containing just water

[Perrigan, Glen]

FYI...Good advice for sqg inspectors. A good example on enhanced
communication through the ESQG Program. Please read below=20

-----Original Message-----
From: traficanti_f [mailto:FrankTraficanti@colliergov.net]=20
Sent: Wednesday, July 09, 2003 5:24 PM
To: Emery, Charles; Tellado, Fred
Cc: Bayly, Karen; Briggs, Doris; WeinsteinBruce; nossier_m; =
cornelisse_m;
barr_c; Perrigan, Glen; Burt Mckee (E-mail); Barbara Kula (E-mail); =
Edith
Weigle (E-mail); Tim McMullen (E-mail)
Subject: RE: Collier Co. Inspections - Week of 6/23/03


Charles:
	On the contrary, thanks for the animated scenarios of potential
occurrences and liability issues.  You've depicted the many issues to be
considered in what one might consider initially to be an easy answer, =
but in
reality represents a huge liability.  Your mention of 'B PPE' will =
probably
give management their decision.  If only 'truth serum' could be =
administered
during the inspection...=20

Thanks,=09
Frank


-----Original Message-----
From: Emery, Charles [mailto:Charles.Emery@dep.state.fl.us]
Sent: Wednesday, July 09, 2003 9:39 AM
To: traficanti_f; Tellado, Fred
Cc: Bayly, Karen; Briggs, Doris; WeinsteinBruce; nossier_m; =
cornelisse_m;
barr_c; Perrigan, Glen; Burt Mckee (E-mail); Barbara Kula (E-mail); =
Edith
Weigle (E-mail); Tim McMullen (E-mail)
Subject: RE: Collier Co. Inspections - Week of 6/23/03


I don't know if Fred has answered this or not. We do not use coliwasa's
during our inspections. If sampling or opening of drums is required at a
particular site, I generally do it. I do not encourage or require my
inspectors to open drums.  Your last question needs to be answered =
before we
continue with how to deal with a drum allegedly containing just water.

How are you going to open the drum? Are you going to open it? The =
opening of
a drum is not just an ignitability or explosively issue but also a =
potential
reactive and toxic issue as well. You all, from a management point of =
view,
must make the decisions on how you wish to approach this type of =
situation. I
don't want to discourage you or prevent you from getting at the truth, =
but
once you make the decisions to open a drum you have crossed a line into =
an
area of safety that you must be  prepared for and concerned about. Are =
you
prepared? It may be easier to have the facility open the drum. If the is
facility's opens the drum and calls the material in the drum just water, =
I
will not allow the facility to just discharge it to the ground. I have =
been
there earlier in my tenure with this program where I allowed such =
activities
to occur and ended up having a pollutant mixed with the water being
discharged to the ground. Also it looks real bad if this activity is
occurring in a very populated area. Can you imagine a passer by seeing =
some
one discharging the contents of a 55-gallon drum to the ground. Our =
phones
would be ringing off the hook. Also once you agree with a facility that =
the
material appears to be water and you allow them to discharge it to the =
ground
you have condoned the activity. So if there is some sort of contaminates =
in
the water you have now condoned the discharging of that contaminate to =
the
ground at a site where the facility operator may not be the owner. You =
have
just set your self up for a real liability problem. Are you prepared for =
that
situation? I have allowed this to happen so even though I'm giving you =
advise
that would tend to indicate not to do I have done it. As an aside to =
this
conversation, this is why we tell facilities that empty open drums or
containers, etc left on site after the product has been used up is a
liability to the facility. Such containers if they have no future use =
should
be removed from the facility as soon as possible. If the facility wants =
to
keep such containers on site they should always store the container =
closed
and in a manner that does not allow rain water to enter into he =
container. If
you are some what confident that it is water you may allow the facility =
to
discharge it tot the ground, however please keep in mind all that I have =
just
discussed above. I now a days will encourage the facility to discharge =
the
water to their domestic waste water system or have them deliver it to =
their
waste water treatment facility or have the water taken off as industrial
water.

If I want to know what is in a drum I ask the facility to open the drum =
for
me. I will not accept an out right statement by the facility that the =
drum
contains water. If the facility agrees to open the drum, I usually =
considered
the various potentials that might occur during the opening process and
prepare for them, i.e. like not being right up on top of drum while they =
are
doing it, having a clear exit available if I perceive something is not
good(i.e. hissing, bad odor, pinging of the drum,etc) and using other =
common
sense factors ( the dude going to open the drum has a cigarette in his =
mouth,
the guy next to the drums just started to use his acetylene torch, or he =
is
using a metal grinder toll on something, etc). The opening of any =
container
without knowing what the contents are, is considered at a minimum to be =
a
level B PPE condition while using non-sparking tools. Once the drum is =
open,
I'm usually more interested in knowing if there is used oil in the drum =
and I
will use what ever is available to dip it into the drum to provided a
colorimetric view of the drums contents. The color of what you dip out
usually can give you a general idea of what might be in the drum (dark =
black
- used oil, red - transmission fluid/diesel fuel, diesel fuel has a
distinctive  odor, green-antifreeze, clear but evaporates quickly and =
has an
odor of gasoline probably means it is gasoline if no odor a solvent of =
some
type, clear and does not evaporate quickly  - mostly likely water, clear
doesn't evaporate quickly but has spots of oily material  - oily =
water/PCW
etc). If the facility opens the drum for you and you wish to use the =
Colawasi
tube go for it. The use of it will show you potential stratifications of =
the
contents of the drum and give a visual view of the material in question. =
What
will you do with the tube after use?=20

I'm sorry for the unusual length of this reply.

Charles



-----Original Message-----
From: traficanti_f [mailto:FrankTraficanti@colliergov.net]
Sent: Monday, July 07, 2003 4:25 PM
To: Tellado, Fred; traficanti_f
Cc: Emery, Charles; Bayly, Karen; Briggs, Doris; WeinsteinBruce; =
nossier_m;
cornelisse_m; barr_c
Subject: RE: Collier Co. Inspections - Week of 6/23/03


Ok, Fred thanks.
	By the way, do you ever use a coliwasa tube during your
inspections?...for example, when a business states that the drum(s) =
are/is
full of water.  Does the liability to explosions prevent or outweigh the
results? Frank

-----Original Message-----
From: Tellado, Fred [mailto:Fred.Tellado@dep.state.fl.us]
Sent: Wednesday, July 02, 2003 8:18 AM
To: FrankTraficanti@colliergov.net
Cc: Emery, Charles; Bayly, Karen; Briggs, Doris;
BruceWeinstein@colliergov.net; MusaNossier@colliergov.net;
MaryCornelisse@colliergov.net; ChristalBarr@colliergov.net
Subject: Collier Co. Inspections - Week of 6/23/03


Hi Frank;

No hazardous waste inspections were performed during the specified time
period.

Have a good day.

Fred