Caustic Soda (Sodium Hydroxide)

Gulf of Mexico Shelf Region Waste Management Procedures Caustic Soda (Sodium Hydroxide) Before you begin

Description Water-based caustic (basic) solutions. Example: drilling mud additives.

Category If used downhole:  E & P exempt If used for other facility maintenance purposes or if unused:  It is hazardous waste if it has a pH of 2 or less or 12.5 or greater, and is being discarded  It is non-hazardous if pH is greater than 2 and less than 12.5

Analysis If Used:  Confirm pH. This can be done onsite with litmus paper If Unused:  No laboratory analysis required  Use MSDS to determine pH

Accumulation  Fluids that have been downhole may be discharged if permit conditions are met. Caustic should not come in contact with aluminum.  Hazardous waste must be stored in closed container, compatible with the product (original container may be used, if in good condition).

Waste  Minimize wasteful practices (i.e., overuse or excessive usage, return Red excess purchases to vendor). ucti  Return to manufacturer or find new user before declaring any unused on product to be a waste.

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Before you begin, (continued)

Disposal If used downhole:  May be discharged through the drilling fluids discharge under the NPDES permit— provided it causes no sheen.  May be used at another location.  May be disposed of at a state permitted E&P Waste facility

If used for other facility maintenance purposes but NOT DOWNHOLE:  It is hazardous waste if it has a pH of 2 or less or 12.5 or greater, and is being discarded: It must be disposed of at a state approved hazardous waste facility  It is non-hazardous if pH is greater than 2 and less than 12.5 1. May be used at another location. 2. It must be disposed of at a state approved non-hazardous waste disposal (or treatment) facility If unused:  Return to vendor or find new user before declaring any unused product to be a waste.

Recordkeeping Hazardous:  Complete entry in Hazardous Cargo Section [Section I] of the Apache Shipping Manifest (See example) prior to transportation:  Maintain a copy of manifest offshore and at shore base facilities while shipping papers are active. Send original manifest with shipment.  Retain records for three years.

 Complete all of Uniform Hazardous Waste Manifest, EPA Form 8700-22, for hazardous waste.  Maintain copy of EPA Form 8700-22 on site for three years.  Retain records for three years.  Maintain a copy of manifest offshore and at shore base facilities while shipping papers are active. Send original manifest with shipment.  Retain records for three years.

Non-Hazardous:  Complete entry in Hazardous Cargo Section [Section I] of the Apache Shipping Manifest (See example) prior to transportation.  Maintain a copy of manifest offshore and at shore base facilities while shipping papers are active. Send original manifest with shipment.  Retain records for three years.  Complete E&P Waste Shipping Control Ticket, UIC-28.  Retain records for three years.

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1. Call or FAX Dock/Base to schedule shipment.

2. Package Sodium Hydroxide as follows: a. Non-bulk packaging 1. Bag, woven plastic: 5H1, 5H2, or 5H3 2. Bag, plastic film: 5H4 3. Bag, textile: 5L1, 5L2, or 5L3 4. Bag, paper, multiwall, water resistant: 5M2

3. Mark Package: a. "Sodium Hydroxide, Solid, 8, UN 1823, PGII" b. If container holds more than 1000 lbs., the letters (Reportable Quantity) “RQ” shall be entered either before or after the words Sodium Hydroxide: Either “RQ, Sodium Hydroxide, Solid, 8, UN 1823, PGII” or “Sodium Hydroxide, Solid, RQ, 8, UN 1823, PGII”. The letters “RQ” are not needed if the container holds less than 1000 lbs. c. Stencil Container-"Apache" and the generator's location (i.e. Eugene Island 128)

4. Label Package: a. “Corrosive” label. b. For packages having a volume over 64 cubic feet (478 gallons) and for portable tanks of less than 1000 gallons: place labels on at least two ends (other than the bottom) or two sides.

5. Prepare manifest (See Example): a. Complete entry in Hazardous Materials Section [Section I] of the Apache Shipping Manifest (See example).

6. Placard Vehicle/Vessel: a. For cargoes of more than 1000 pounds: "Corrosive" Placard with UN number 2795 and the number 8 in bottom corner. b. For cargoes less than 1000 pounds: No Placard required on transport vehicle. c. Cargo or portable tanks shall be placarded as above on opposing sides if capacity is between 119 and 999 gallons and on all four sides if 1000 gallons or more. d. See attached placard

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Load cargo in accordance with the following shipping limitations:

AIR RESTRICTIONS (49 CFR 172.101)

Passenger Aircraft 35 pounds (15 kg)

Cargo Aircraft 110 pounds (50 kg)

WATER RESTRICTIONS (49 CFR 172.101)

Cargo and Passenger Vessels Must be stowed either on deck or under deck, however under deck should be used if available.

Other Requirements None

8. Include MSDS with shipment.

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