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- Empty Drums <br /> What is considered "empty" in California? <br /> Outside of California? <br /> Al - Ask suppliers if empty drums can be <br /> returned to them for refilling <br /> „6 <br /> 115 116 <br /> Waste Minimization/Pollution Agency Inspections & Internal EHS <br /> Prevention Assessments Findings - Waste <br /> States may require written waste minimization/pollution I Unlabeled or improperly labeled drums—Continues to <br /> prevention plans. be an issue <br /> Generator's Certification on hazardous waste manifest is I Container inspections weekly documentations—Missing <br /> certification that facility has waste minimization program weeks,not reading and answering questions carefully <br /> in place. I Improper waste storage(e.g.,containers not closed, <br /> Source reduction measures selected for implementation labels not visible,etc.) <br /> include: I Analytical data or profiles to verify a waste is non- <br /> - Employee training in spill prevention,housekeeping, hazardous <br /> operating procedures to reduce waste I 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 LAHT only:Employee training to observe for <br /> oil-water interface during tank water draws ,,, 18 <br /> 117 118 <br /> EHS Document System Waste Training <br /> ii Documents in the EHSDS: • What words must appear on the label of every container <br /> of hazardous waste throughout its existence? <br /> —SPCC Plan(and SWPPP, if applicable)in I What type of waste is mercury-containing equipment? <br /> Water Section ■ Can a non-Kinder Morgan employee sign a hazardous <br /> —Hazardous Waste Section includes guidance waste manifest? <br /> documents, RCRA contingency plan,waste i 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 /> 119 120 <br /> 20 <br />