Environmental Requirements

Section J Attachment J-5 Environmental Requirements This page (blank)

2 ATTACHMENT J-5 GENERAL ENVIRONMENTAL REQUIREMENTS

1.0 General 1.1 Environmental requirements established in this document are for contracts issued for work on Strategic Petroleum Reserve (SPR) facilities, systems, and property owned in fee or rights-of-way.

1.2 Contractors and subcontractors will comply with these requirements. Both entities will be identified as “contractor” in this exhibit.

1.3 Following contract award, applicable environmental submittals are to be provided in accordance with the environmental section of the Preliminary Hazards Review (PHR) form (Attachment 1). Those that are applicable to this contract are checked on the PHR.

2.0 Contractor Responsibility 2.1 Environment The contractor will be responsible for all environmental aspects in the performance of this contract. The contractor must conduct activities in a manner that minimizes waste and the use of electricity, fuel, and water. The contractor will comply with all applicable federal, state, and local regulations, and the Management and Operations Contractor (M&O)(currently Fluor Federal Petroleum Operations, LLC (FFPO)) requirements, and shall prevent pollution, and continually strive toward improving work processes to minimize environmental impact and promote sustainability.

2.2 Conflicts of Requirements In the event of any conflicts between the requirements of this document, the contractor will apply the more stringent requirements unless its application would cause the contractor to violate federal, state, or local laws. In that event, the contractor will address the issue to the M&O Subcontract Manager’s Technical Representative (SMTR) for approval before proceeding with the activity.

2.3 Changes to Regulations The contractor will be aware of any applicable regulatory updates and implement changes, substantive or otherwise, necessary to meet those updates after receiving approval from the SMTR.

2.4 Environmental Competency All contract and subcontract employees performing work on an SPR site or right-of-way, whose work has the potential to cause significant environmental impact, must be deemed competent to perform that work to reduce the risk of impact. For example, personnel whose work could cause an oil spill must have the skill, knowledge, or experience to perform the work in a manner that will reduce the risk of a spill.

Activities that have, or have a potential for, significant environmental impact are identified in the summary of work of this contract. If any activities are identified as such, the Declaration of Environmental Competency box will be checked, and the contractor must provide proof of employee competency. Use form MR002E (Attachment 10) or other means described on the form to document competency, and provide the completed form or document(s) to the SMTR as specified on the PHR.

3.0 Environmental Permits The contractor is responsible for verifying with the SMTR that all applicable permits and permit notifications to outside regulatory agencies have been procured by M&O prior to mobilization. Permits or notifications may be required for activities that may release air pollutants, are conducted in wetlands, or involve water discharges.

J-5-3 Rev. 3 (05/17/2016) 4.0 Air Emissions 4.1 On-Site Burning No onsite burning of wastes will be allowed.

4.2 Volatile Materials The release of volatile organic compounds (VOCs) must be minimized. Containers holding volatile material (such as solvents, paints, and adhesives) will be designed for the material, opened only when material is being used, and maintained tightly closed when not in use.

4.3 Dust Control The loss of bulk materials such as sand and dirt will be monitored and controlled by the contractor. Dust generated by the contractor will be suppressed as practicable with water in heavy traffic areas to prevent a nuisance to site personnel and the public. Hard surfaced roads will be maintained free of earthen material spilled by the contractor.

4.4 Chlorofluorocarbon (CFC) Refrigerants, Halon, and Sulfur Hexafluoride Recovery All CFC refrigerants, Halon, and sulfur hexafluoride will be recovered by certified technicians with certified recovery equipment. The contractor must provide to the SMTR proof of EPA approved certification of personnel and equipment. All releases of these substances will be reported by the contractor to the SMTR in accordance with Section 6.7

Service records must be provided to the SMTR on work on appliances that contain 50 pounds or more of refrigerant.

5.0 Product Approval 5.1 Product Approval All products will be evaluated for approval by M&O before transport to and use on any SPR facility. The contractor will provide current SDSs of all products to be brought on site to the SMTR for approval at least 10 working days in advance of need. If under an emergency contract, the contractor will provide the SDSs to the SMTR as soon as possible and before the product is used.

The contractor can reduce review time and assure product approval by selecting environmentally approved products listed in the SPR Qualified Products List. This list is available from the SMTR. The contractor is strongly advised to consider these products before submitting a product for approval.

5.2 Aerosol Products Aerosol products are approved on a case-by-case basis. Those with a CFC or HCFC propellant will not be approved. All spent aerosol cans must be punctured prior to disposal. Contact the SMTR for use of the site’s can puncturer.

5.3 Polychlorinated Biphenyls (PCBs) and Chemically Treated Wood No products or equipment containing PCBs will be allowed on an SPR site. No creosote, pentachlorophenol (PCP), or chromated copper arsenate (CCA) treated wood will be used. Only copper quat or copper azole treated wood is approved for use. Plastic lumber may also be substituted for specific uses but must be approved by the SMTR.

5.4 Affirmative Procurement (AP) and Biobased Products Affirmative procurement and biobased products are specific items identified by EPA and the Department of Agriculture, respectively that must be considered for purchase instead of their conventional counterparts. If procurement of AP and biobased is required elsewhere in this contract document, the contractor will provide documentation, as specified in the PHR (Attachment 1), by completing form PP005. (Attachment 2)

6.0 Hazardous Material Handling 6.1 EPA and DOT Training If checked on the PHR (Attachment 1), the contractor will instruct his employees on spill prevention and proper hazardous material handling and transportation in accordance with EPA and DOT requirements, where applicable, and provide to the SMTR documentation of training for individuals working on SPR facilities. Documentation will include course titles, course duration, student rosters, names of instructors, and names of companies providing training.

6.2 Material Maintenance 4 All hazardous materials will be maintained in staging areas determined by the SMTR. Unless specified otherwise in this contract, the contractor will arrange to have all unused hazardous and non-hazardous materials that were brought on site removed from the site prior to final acceptance and payment by M&O. Handling of hazardous materials shall be in accordance with all applicable federal, state, and local laws and regulations.

Incompatible materials must be separated, and products must be maintained separately from wastes.

Workplaces and storage areas will be managed so that products, including crude oil and brine, will be contained and prevented from reaching the environment. Chemical materials (products and wastes) must be kept in covered secondary containment that does not accumulate storm water. Poly packs are recommended for containment of products and wastes.

6.3 Workplace Inspection On a weekly basis, the contractor will inspect SMTR assigned workplaces, product storage areas, and waste accumulation areas for leaks and spills. All releases will be reported to the SMTR in accordance with Sections 6.7. The contractor is responsible for restoring any area contaminated by a spill from materials stored or accumulated by the contractor.

6.4 Unused and Excess Material Unless otherwise directed by the SMTR, all unused and excess materials will remain in the custody of the contractor and removed from the site when no longer required.

6.5 Pesticides All pesticides, including insecticides, soil sterilants, herbicides, biocides, fungicides, and rodenticides will be applied in strict accordance with the manufacturer’s label and all applicable regulations and bulletins. A list of prospective pesticides, their current labels, and SDSs must be submitted to the SMTR to ensure they are on the SPR approved list. Those products not approved must be evaluated by M&O in accordance with Section 5.1.

The contractor will provide a copy of his current commercial state applicator’s license to the SMTR and, with each site visit, a record of application that includes the following:

a. Owner/operator name, address, and license number (for commercial application) b. Applicator name and address c. Applicator certification number, if certified d. Product/brand name e. EPA registration number f. Restricted/general use pesticide g. Application date including beginning time of application h. Type of application i. Target vegetation j. Location of application k. Size of area treated (acres, square feet, or minutes of spraying) l. Rate of application m. Total amount of product (concentrate) applied n. Applicator equipment o. Certification number of applicator equipment (if applicable) p. Weather conditions during application including temperature, wind direction and velocity. Chemicals should not be applied when weather conditions prevent control of drift/overspray.

J-5-5 Rev. 3 (05/17/2016) Waste materials, including empty containers, containment items, and disposable personal protective equipment will be disposed by the contractor in accordance with Section 7. Refer to PHR (Attachment 1) for pesticide contractor submittals.

6.6 Transportation Hazardous materials will be transported in accordance with DOT requirements only by hazardous material licensed commercial drivers.

Wastes generated on an SPR facility will be transported offsite only by contractors included in the SPR Qualified Disposers, Recyclers, and Transporters Recyclers List available from the SMTR.

6.7 Spills and Spill Reporting Any environmental contamination by hazardous materials, crude oil, and brine resulting from activities by the contractor will be reported immediately to the SMTR. Form CW001 (Attachment 3) will be submitted to the SMTR by the end of the work day.

The contractor must provide response based on spill conditions and contractor competency. The contractor will be responsible for immediate and proper containment, collection, removal, and disposal of spilled material and clean-up equipment in accordance with all applicable federal, state and local regulations and M&O procedures (procedures are available for review through the SMTR). The contractor will respond to small drips and seeps that can be controlled and cleaned by qualified field personnel in the area with appropriate equipment on hand. All larger spills will require M&O approval before initiating action. For spills too large for the contractor to control and where contracted response is needed, the contractor will immediately notify the SMTR so that M&O can implement the site’s Emergency Response Procedures. The contractor will be liable for all costs incurred by M&O and spill clean-up organizations for releases caused by the contractor.

6.8 Chemical Inventory On a quarterly basis, or upon contract completion (whichever comes first) the contractor will inventory chemical products brought on. The contractor will coordinate with the SMTR to complete the Contractor’s Chemical Inventory form CS001 (Attachment 4) in accordance with the directions. The SMTR will coordinate that the chemical inventory is completed and entered in ESS chemical inventory with section 3 of the Environmental Instructions Manual.

7.0 WASTE MANAGEMENT The following are types of wastes commonly generated on the SPR:

Waste Type Examples Non-hazardous trash, garbage, non-hazardous spill clean-up debris, regulated construction debris Reclaimable/recyclable paper, cardboard, oil filters, lubricating oil, batteries, scrap metal, concrete, uncontaminated soil, aluminum cans, plastics, metal Oil field exploration and contaminated crude oil and brine, biodegradable sorbents production (E&P) waste containing crude oil, not otherwise regulated

6 Hazardous spent petroleum based paint materials, spent solvents, cleaners, lab wastes, unpunctured aerosol cans Waste water wash water, rinse water, flush water, sanitary waste water, hydrostatic test water, containment water

7.1 Waste Management All wastes generated on an SPR site, either by SPR employees or contractors, are DOE wastes and shall be properly collected, contained, characterized, and disposed in accordance with all applicable federal, state, and local laws and regulations and M&O requirements.

The replacement of used lubricating oil, oil filters, and antifreeze in contractor equipment on an SPR site is strongly discouraged. The wastes must be characterized and transferred to M&O for disposal by M&O through a recycler. Contact the SMTR to arrange the transfer.

7.2 Waste Management Plan Prior to commencement of physical work, the contractor must submit a Waste Management Plan to the SMTR for review and approval. The contractor will use the plan outline in form HW007E (Attachment 5) for plan development. The plan will include, as a minimum, the applicable items covered in these general environmental requirements. Sections that are not applicable to contracted activities should be so noted. The plan shall be approved and signed by an official of the contractor’s company after approval by the M&O Waste Management Specialist. Review of the plan by M&O may require up to five working days. The SMTR will then direct the contractor to implement the approved plan.

The waste management plan shall be up-dated by the contractor, as needed, when the contractor changes work methodology, is awarded additional tasks, uses new products, or generates new wastes.

Where applicable, the following issues will be included in the waste management plan:

7.2.1 Training Refer to Section 6.1. Hazardous waste handlers must have annual waste handling training.

7.2.2 Discharges No materials will be discharged on the ground or disposed onsite or in site plumbing or drainage of any kind without prior approval from the SMTR.

7.2.3 Pollution Prevention/Waste Minimization The contractor must certify in the waste management plan that effort will be made to prevent pollution and minimize wastes from all activities.

The contractor will perform as much of the contracted work as possible offsite to minimize DOE/SPR waste generation and chemical inventory. All wastes generated by the contractor offsite are contractor's responsibility for management and disposal (hazardous wastes, generated off-site, will be manifested under contractor’s waste generator and transporter EPA identification numbers).

Waste minimization practices include but are not limited to the following:

1) Eliminate or reduce product need (source reduction) 2) use environmentally preferred alternatives 3) use all of the product in a container 4) procure only enough product to complete the task 5) reuse products (i.e. solvents) until they are completely spent 6) use recycled material or products manufactured with recycled material

All contractors conducting painting activities must refer to Attachment 6 for additional waste minimization practices.

7.2.4 Waste Characterization The contractor will provide the SMTR complete characterization of wastes through process knowledge and/or chemical testing in accordance with Section 4 of the SPR Environmental Instructions Manual (ASI5400.15) available from the SMTR. Waste determinations must be completed for each waste stream. SPR Waste J-5-7 Rev. 3 (05/17/2016) Characterization data is posted electronically in the ESS database. Coordinate with the M&O Waste Site ES&H Manager or Waste Management Specialist to determine if a waste characterization exists for the waste generated. This is discussed in section 7.2.5 of these environmental requirements.

Process knowledge can be used to characterize a waste that is an uncontaminated material of known composition such as a leftover product that cannot be used and is in the original container. The SDS of this product can usually provide sufficient information for characterization.

Chemical testing is required to characterize a waste where the concentrations of constituents are unknown or the waste is composed of more than one material. Examples are as follows: a product contaminated with another material, spill cleanup material, or an undefined mixture of products. Waste sampling and characterization will be coordinated with the site ES&H manager. Laboratory testing will be performed only by a M&O qualified laboratory (list available from the SMTR).

The following EPA approved waste testing procedures include, but may not be limited to:

1. Toxicity Characteristic Leaching Procedure (TCLP) - Scope of TCLP analysis will be determined by the nature of the waste.

2. Reactivity/Corrosivity/Ignitability (RCI) - These tests are required by landfills and are performed with TCLP to determine additional waste stream hazards.

3. Total Petroleum Hydrocarbon (TPH) - Performed on petroleum (crude oil and refined products) contaminated soils.

4. Benzene, toluene, ethylbenzene, xylenes (BTEX) - Usually performed on petroleum spill (crude oil and refined product) wastes.

5. Constituents for Used Oil Burned for Energy (UOBE) Recovery – A suite of tests is run to determine if used oil can be used as a fuel and not disposed as a waste. Note that in order for used refined oil to be used as fuel, it cannot be mixed with other wastes.

Waste water that has not come in contact with products will be tested for those parameters required by the site’s federal and state discharge permits. These permits are available from the SMTR or ES&H Manager.

A copy of analytical and QA/QC results must be submitted to the SMTR within 10 working days after sampling. The analytical data will be used to verify the waste characterization. In addition, a Waste Determination Form must be completed and submitted to the SMTR if the waste stream is not listed in the ESS database.(Section 7.2.5). The ES&H Manager and Waste Management Specialist will review results with consideration for the contractor’s disposal intentions. If additional information is required, the SMTR will notify the contractor.

7.2.5 Waste Determinations A waste determination is a description statement that is based on the waste characterization. The contractor is to provide the SMTR with a waste determination worksheet, (HW001E) for each waste generated, including supporting documentation needed to prepare the waste determination. An example of the waste determination worksheet is found in Attachment 7.

To reduce time and effort in developing waste determinations, the contractor may contact the site ES&H manager or NO Waste Management Specialist and inquire if a waste determination exists for the expected waste that the contractor will generate.

Upon approval of each final waste determination, the SMTR will provide a copy to the contractor for inclusion with the contractor’s approved waste management plan.

7.2.6 Waste Accumulation

Refer to the waste management criteria as listed in section 4 of the Environmental Instructions Manual (ASI5400.15)

All waste accumulation areas will be approved by the SMTR. The contractor will provide and manage containers for wastes. Containers will be marked and labeled in accordance with DOT requirements. All 8 containers will be covered to prevent stormwater intrusion and contamination. Municipal Solid Waste (MSW) containers must be maintained closed except when waste material is being added.

The contractor will accumulate and manage hazardous waste in DOT approved containers labeled with “Hazardous Waste” and a description of contents. The containers will be kept in locked and covered secondary containment that does not allow precipitation to collect around the waste containers. Poly packs are recommended for secondary containment. In the waste management plan, the contractor must provide a description of proposed secondary containment.

All waste containers must be accumulated in an area separate from stored products to prevent commingling of product and waste. Incompatible wastes must not be mixed or stored together. The contractor will maintain all containers closed except when wastes are being added.

If needed, small hazardous waste satellite accumulation areas (accumulation areas of convenience located near work sites) will be assigned to the contractor by the SMTR. The contractor is responsible for managing all waste accumulation areas in accordance with federal and state regulations and SPR policies.

7.2.7 Waste Inspections and Inventories Refer to the waste management criteria as listed in section 4 of the Environmental Instructions Manual (ASI5400.15)

As applicable, on a weekly basis, the contractor will inspect all waste accumulation areas for leaks and spills and document this on a Weekly Waste Inspection form HW003E (Attachment 8). The contractor will inventory all wastes with a Waste Inventory Report form HW005E (Attachment 9) and submit the form to the SMTR. The SMTR will coordinate to ensure the data on the Waste Inventory Form is input to the ESS database. Contact the site ES&H Manager or Waste Management Specialist for assistance, as needed. Both forms are available from the SMTR. Completed forms will be signed by the inspector and provided to the SMTR as specified in the Environmental Instructions Manual or the end of the contract, whichever comes first.

7.2.8 Spills and Spill Reporting for Wastes Refer to Section 6.7.

7.2.9 SPR Qualified Waste Disposers, Recyclers and Recyclers A contractor will not dispose, transport, or recycle any waste generated at an SPR facility unless the transporter, recycling facility, or disposal facility is approved by M&O and identified in the SPR Qualified Disposers, Recyclers, and Transporters Recyclers List. Contact the SMTR for a copy of the most current list.

If the contractor wishes to use a facility that is not on the approved list, the contractor shall submit a request to the SMTR in writing to obtain an evaluation and possible approval from M&O before the alternative can be used. Approval is not guaranteed and may require up to 60 calendar days for a disposer/recycler or 10 calendar days for a transporter.

7.2.10 Waste Shipping Documents All shipping documents for wastes generated on SPR property will be reviewed and signed by M&O personnel as arranged by the SMTR. There are no exceptions to this requirement. Shipping documents include, but are not limited to, hazardous waste manifests, Exploration and Production waste shipping control tickets, and shipping papers for nonhazardous municipal, industrial, and recycled wastes.

The contractor will notify the SMTR at least one week in advance of scheduled hazardous waste shipments so that the appropriate M&O signatory authority will be available during the pick up. A legible copy of the completed manifest must be provided to the SMTR after signing.

7.2.11 Waste Water Discharges Prior to discharge of any waters (including but not limited to stormwater, containment water, wash water, flush water, hydrostatic test water, and ground water from dewatering), the contractor must obtain permission from the SMTR through a written request. The contractor must be aware of and plan for these activities prior to work because such discharges may require specific discharge requests by M&O to the state in accordance with site permits, or a separate permitting action.

J-5-9 Rev. 3 (05/17/2016) Time required to receive state approval could result in contractor incurred delays if his work is not properly scheduled in anticipation of the request.

A waste determination must be completed for waste water that must be tested by an outside laboratory to determine its disposition.

If the contractor intends to discharge hydrostatic test water to the ground, he must provide the SMTR with written notice to discharge 30 days in advance of the activity.

8.0 GROUNDS RESTORATION In addition to requirements specified elsewhere, if appropriate, in the contract for excavation, backfill, and compaction (CSI Section 02222), backfilled and disturbed areas must be restored as close as possible to pre-construction condition after excavation, trenching, or demolition to control erosion in accordance with CSI 02458 (Seeding). If wetlands will be impacted, M&O must provide permit coverage prior to commencement of work, and wetlands restoration will be provided by the contractor in accordance with U. S. Corps of Engineers requirements.

9.0 ENVIRONMENTAL FORMS In order to document and track compliance with certain Environmental requirements, the completion of forms is required. The applicable forms are completed by the contractor and forwarded to the SMTR. Once the SMTR has reviewed the forms for accuracy and completeness, the forms are then submitted to the appropriate SPR Environmental personnel as noted in the List of Environmental Submittals section of the PHR (ATTACHMENT 1)

Environmental forms listed in Attachments 1 through 10 of Section J-5 are for reference only. Contractors must coordinate with the SMTRs to obtain the current form that will be used for compliance documentation.

The environmental forms are posted on the Environmental Functional Website at: https://myspr.spr.doe.gov/ENV/SitePages/Home.aspx

10 Listed below is an environmental form and attachment cross reference matrix.

Description Title Form ID No.

LIST OF ENVIRONMNETAL AAA9020.715 ATTACHMENT 1 SUBMITTALS (pages 3 and 4) AFFIRMATIVE ATTACHMENT 2 PROCUREMENT/BIOBASED PP005 CERTIFICATION SUBMITTAL CONTRACTOR’S SPILL REPORT ATTACHMENT 3 CW001 FORM

CONTACTOR’S CHEMICAL ATTACHMENT 4 CS001 INVENTORY

OUTLINE FOR WASTE ATTACHMENT 5 HW007E MANAGEMENT PLAN

ADDITIONAL PAINT WASTE ATTACHMENT 6 MINIMIZATION PRACTICES

WASTE DETERMINATION ATTACHMENT 7 HW001E WORKSHEET

ATTACHMENT 8 WEEKLY WASTE INSPECTION HW003E

ATTACHMENT 9 SPR WASTE INVENTORY HW005E

DECLARATION OF ATTACHMENT 10 MR002E ENVIRONMENTAL COMPETENCY

J-5-11 Rev. 3 (05/17/2016) ATTACHMENT 1 LIST OF ENVIRONMENTAL SUBMITTALS

12 LIST OF ENVIRONMENTAL SUBMITTALS (cont.)

J-5-13 Rev. 3 (05/17/2016) 14 LIST OF ENVIRONMENTAL SUBMITTALS (cont.)

J-5-15 Rev. 3 (05/17/2016) LIST OF ENVIRONMENTAL SUBMITTALS (cont.)

16 ATTACHMENT 2

J-5-17 Rev. 3 (05/17/2016) ATTACHMENT 3

J-5-18 Rev. 3 (05/17/2016) ATTACHMENT 4

J-5-19 Rev. 3 (05/17/2016) J-5-20 Rev. 3 (05/17/2016) ATTACHMENT 5

J-5-21 Rev. 3 (05/17/2016) J-5-22 Rev. 3 (05/17/2016) J-5-23 Rev. 3 (05/17/2016) ATTACHMENT 6

ADDITIONAL PAINT WASTE MINIMIZATION PRACTICES

Paint Mixing 1. Ensure paint equipment is in operable condition before mixing paint.

2. Use ground barrier to keep spillage and splash from ground contact, e.g., plywood, tarp, plastic sheeting, etc. Use of a cattle tub as a ground barrier can also act as secondary containment in case of accidental spillage.

3. For small jobs, place the paint can directly into the pot liner. Adding a small amount of thinner to the bottom of the pot prior allows the can to float on the thinner as the can becomes empty. The suction line then is able to remove all product from the can. Whenever possible also extend the suction line tubes in the paint pot so as to maximize the amount of paint removed from the pot. The remaining thinner can then be reused.

4. Wash thinner from the same model and color of paint can be reused as mix thinner by allowing the thinner to settle and filtering it through cheese cloth to insure it is free of contaminants. Refer to paint specifications for manufacturer consent.

5. Mix enough not to exceed pot life requirements to prevent potential waste generation due to unexpected work stoppage (weather, equipment failure, etc.).

6. Lengthen suction line to maximize product removal from the container.

7. Be aware of weather conditions and mix an appropriate amount of paint.

Cleanup 1. Clean lid groove of partially used containers to ensure tight reseal until next use.

2. Apply all mixed paint in accordance with the (1)”Spraying Out” definition at the end of this addendum.

3. Clean paint lines with used thinner on first flush of line.

4. Back flush paint lines to use less thinner for cleanup (conventional guns only).

5. Lubricate spray gun after every use to minimize down time while paint is in pot.

6. Utilize a shortest possible length for paint line to minimize cleanup thinner required.

7. Apply all possible material from pot liner or other rendering it (2) RCRA empty in accordance with the definition at the end of this addendum.

8. RCRA empty paint containers may be disposed of in the dumpster after adding sorbent to bind up any free liquid. Lids are to be removed.

9. Only RCRA Empty cans are allowed to be left open to the atmosphere for drying.

10. Tilt the pot as the paint level gets low to maximize product usage.

11. One painter may blow out his hose and gun into another painter’s pot to use as much paint as possible.

J-5-24 Rev. 3 (05/17/2016) Reuse solvent 1. Wash thinner from the same model and color of paint can be reused as mix thinner by allowing the thinner to settle and filtering it through cheese cloth to insure it is free of contaminants. Refer to paint specifications for manufacturer consent.

2. Used solvent may be utilized to clean surfaces and equipment.

3. Used solvent must be poured onto the rag and not onto the surface to be cleaned. In this manner the rags are not subject to RCRA hazardous waste regulations.

Minimize sandblast media 1. Ensure proper sand pot adjustment for each job.

2. Ensure proper media is utilized for each task.

(1)Spraying Out – Spraying out, brushing, and rolling are only allowed if there is a legitimate use of the paint, and it is applied as a protective coating or an enhancement to a protective coating. Spraying out, brushing, and rolling are never allowed on the ground, in the air, or on any articles which are to be disposed of, e.g., plastic sheeting, scrap lumber, etc. Spraying out, brushing, and rolling without a legitimate use of the paint is treatment as per 40 CFR 260.10. If the waste is treated, then according to 40 CFR 270.1(c), a permit is required.

(2)RCRA Empty – All possible material is removed by pouring, pumping, or suctioning, AND no more than 1 inch of residue remains on the bottom of container. OR No more than 3% (by weight) residue remains if container is less than 110 gallons “OR” 0.3% (by weight) if container is larger than 110 gallons. 40 CFR 261.7 (b)(1)

J-5-25 Rev. 3 (05/17/2016) ATTACHMENT 7

J-5-32 Rev. 3 (05/17/2016) J-5-33 Rev. 3 (05/17/2016)