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III <br /> Empty Drums <br /> What is considered "empty"" in California. <br /> ,, r Outside of California? <br /> _ �- "$'' " i Ask suppliers if empty drums can be <br /> f returned to them for refilling <br /> L <br /> 02110%2009,.. <br /> _ 116 <br /> Waste Minimization/Pollution Agency Inspections & Internal EHS <br /> Prevention Assessments Findings - Waste <br /> ■ States may require written waste minimization/pollution ■ Unlabeled or improperly labeled drums—Continues to <br /> prevention plans. be an issue <br /> i Generator's Certification on hazardous waste manifest is ■ Container inspections weekly documentations—Missing <br /> certification that facility has waste minimization program weeks,not reading and answering questions carefully <br /> in place. ■ Improper waste storage(e.g.,containers not closed, <br /> • Source reduction measures selected for implementation labels not visible,etc.) <br /> include: ■ Analytical data or profiles to verify a waste is non- <br /> -Employee training in sppill prevention,housekeeping, hazardous <br /> operating procedures to reduce waste r Land Disposal Restriction forms not completed,or <br /> —Sharing waste minimization practices with tank cleaning completed incorrectly <br /> contractors and inspectors <br /> —Daily walk-throughs to observe for leaks/spills <br /> —Carson and IAHT only:Employee training to observe for <br /> oil-water interface during tank water draws 116 <br /> EHS Document System Waste Training <br /> ■ Documents in the EHSDS: ■ What words must appear on the label of every container <br /> —SPCC Plan(and SWPPP,if applicable)in of hazardous waste throughout its existence? <br /> Water Section ■ What type of waste is mercury-containing equipment? <br /> ■ Can a non-Kinder Morgan employee sign a hazardous <br /> —Hazardous Waste Section includes guidance waste manifest? <br /> documents, RCRA contingency plan,waste ■ What amount of hazardous waste can be accumulated in <br /> minimization/pollution prevention documents, a satellite container? <br /> tiered permitting documents for wastewater <br /> treatment systems, hazardous waste report <br /> 9 120 <br /> 1 <br />