Hazardous Waste Training Plan. Supersedes: 02/15/16 (Rev.02) Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager

Transcription

1 Procedure No.: PA Page: 1 of 19 Port Arthur, TX. Reviewed: 02/18 Effective: 02/06/18 (Rev.03) Supersedes: 02/15/16 Preparer: Owner: Approver: EHS Team Member EHS Team Member EHS Manager Document Revision Change Table Revision Number Revision Description Revised By Revision Date 01 Changed Header and Footer VB 05/08 Reviewed No changes AH 02/12 02 Updated job titles and removed Appendix C AH 02/16 03 Reviewed no changes AH 02/18

2 Procedure No.: PA Page: 2 of 19 Port Arthur, TX. Reviewed: 02/18 Effective: 02/06/18 (Rev.03) Supersedes: 02/15/16 1. PURPOSE: The purpose of the hazardous waste training program is to provide facility employees with information and instruction needed to safely perform their duties as related to the management of hazardous waste. 2. DEFINITIONS: RCRA - Resource Conservation and Recovery Act OSHA - Occupational Safety and Health Act HAZWOPER - Hazardous Waste Operations, training requirements listed in 29 CFR, Port Arthur site refers to BASF TOTAL Petrochemicals. Employees and personnel are used interchangeably to include BASF employees and permanent contractors. 3. SCOPE: This training is required for all personnel who are involved in the management of hazardous wastes at the Port Arthur site. 4. PROCEDURE The objectives of the training program are to thoroughly train employees and contractors in the proper performance of their job duties as well as to ensure that all appropriate personnel are capable of effectively implementing emergency procedures in the event an incident should arise. Proper training will aid in the prevention of emergencies, or at least minimize the consequences through rapid and organized response. Hazardous waste management training is an important aspect of the total plant-training program and is incorporated into the facility's comprehensive basic training program. This provides employees associated with hazardous waste management activities sufficient knowledge of hazardous waste management concepts.

3 Procedure No.: PA Page: 3 of PROCEDURES cont d 4.1. Content of Training Program The Port Arthur site provides a training program for personnel that include a formalized training system. This system trains the operations staff in each area of operations by on-the-job training in conjunction with periodic testing. The training system is supplemented by specific training related to RCRA activities. The site accomplishes the comprehensive training program with instructor led training, on-the-job training and computer based training courses Instructor Led Training Instructor led training is an important part of the overall training program at the Port Arthur site that helps supplement the knowledge learned during the on-the-job training program. The training is an integral part of the existing safety and training programs that are provided to employees who are required to participate in such training as part of their particular job functions. [264.16(a)(1)]-Facility personnel must successfully complete training that teaches them to perform their duties in a way that ensures compliance with regulations for hazardous waste. All training will be completed within six months of job assignment. [264.16(a)(2)]- The site person(s) responsible for hazardous waste management training regularly attends outside seminars and/or conferences related to the management of hazardous waste to remain up to date on requirements. Hazardous waste management training concepts are also incorporated into the existing operations training program. The EHS Team Member or designee typically gives presentations on hazardous waste issues when needed. The basic hazardous waste training outline showing the pertinent topics and procedures that are presented in detail is provided in Section 6. [264.16(a)(3)]- The training program is designed so that personnel are able to respond effectively to emergencies. Included in the program are topics covering emergency procedures, emergency equipment, and emergency systems.

4 Procedure No.: PA Page: 4 of PROCEDURES cont d 4.1. Content of Training Program cont d Formal Training cont d [264.16(b)]- Upon initial hire or upon transfer or promotion of existing personnel to a new position with training requirements that differ from those of the previously held positions, those persons must be closely supervised by the area supervisor until they complete the required additional training. [264.16(c)]- refresher training sessions address parameters for automatic waste feed cut-off systems, alarm systems, response to spills, and response to fires and explosions. Training on shutdown of operations is conducted through the formal training system. The hazardous waste management portion of the training program is under the direction of the Environmental, Health and Safety Department who, through qualified personnel, present the necessary training during the overall operations training program. [264.16(d)(1)]- Job titles for persons involved in management of hazardous wastes at the site are listed in Section 7. and Appendix A of this plan. The name of the employee(s) currently filling the job will be kept on-site and updated as necessary. [264.16(d)(2)]- A written description for job titles listed in Section 7. are maintained in files of the Human Resource Department located on-site. [264.16(d)(3)]- A description of the training program is given in Section 4. of this plan. [264.16(d)(4)]- Records of training are kept in the Environmental, Health, and Safety Department or the Training Department, depending on training type. Section 4. of this plan details the record keeping procedure. [264.16(d)(2)]- A written description for job titles listed in Section 7. are maintained in files of the Human Resource Department located on-site. [264.16(d)(3)]- A description of the training program is given in Sections 3. and 6. of this plan.

5 Procedure No.: PA Page: 5 of PROCEDURES cont d 4.1. Content of Training Program cont d Formal Training cont d [264.16(d)(4)]- Records of training are kept in the Environmental, Health, and Safety Department or the Training Department, depending on training type. Section 8. of this plan details the recordkeeping procedure On-the-Job Training One of the most common and useful methods of operator training is onthe-job training (OJT). This type of training provides the advantage of "hands on" experience that is pertinent to normal daily operations of a unit. OJT with appropriate supervision is especially useful, because it provides for effective explanation of concepts of the systems operations and affords visual illustration of those concepts. The OJT program is utilized for employee orientation purposes as well as for new operational personnel and transferred employees. The training system provides for periodic testing in order to assess an employee's progress. The training is completed according to a specified schedule and the employee receives validation for completion of the program. This training is intended to provide compliance with the Process Safety Standard under OSHA found in 29CFR, Training in the area of hazardous waste for permitted facilities and Hazwoper requirements are outlined in the following section Training Program The overall site-training program is under the direction of the Learning and Development Coordinator. Specific training in the safety and environmental areas is provided by the EHS Department, who coordinate their specific training aspects into an overall comprehensive training program schedule. Incorporated into the existing safety and operation training programs is instruction that specifically details aspects of hazardous waste management practices, contingency plan implementation, and emergency response procedures.

6 Procedure No.: PA Page: 6 of PROCEDURES cont d 4.2. Training Program cont d All personnel involved with the management of wastes at the site will complete the initial environmental training program within six months after their date of employment. This also pertains to employees who have been promoted or transferred into hazardous waste management positions and who have not completed the necessary training as part of their previously held positions. Upon completion of the hazardous waste management-training portion, training records will be updated to reflect they have satisfactorily completed this training. All facility personnel managing hazardous waste will take part in an annual review of their initial and subsequent RCRA training, which will be updated as necessary to reflect current facility operations and procedures. This training includes items listed under 40CFR, Additional training provided to designated plant employees managing hazardous wastes includes the following items: Occupational Safety and Health Administration (OSHA) 29 CFR Section , Hazardous Waste Operations and Emergency Response (Hazwoper); OSHA Hazwoper 8-hour Refresher Training; Fire School Training; OSHA 29 CFR Section , Hazard Communication Training; and RCRA Refresher Training.

7 Procedure No.: PA Page: 7 of PROCEDURES cont d 4.3. Hazwoper Training Training requirements listed under 29CFR, , paragraphs (p) and (q) are followed to prepare employees for work in the area of plant operations. Paragraph (p) lists training to be given for workers directly involved in the treatment, storage, and disposal (TSD) facilities, which are subject to permitting under the Resource Conservation and Recovery Act (RCRA) of 1976 (not presently applicable to the operations at the Port Arthur site) Current Employees These employees shall be trained to at least a minimum level as specified under paragraph (q) for response to hazardous releases of material. Some employees will be trained to a higher level in order to perform duties that may be required in an emergency. In the course of their regular job functions, an employee will become familiar with his/her respective unit and will acquire knowledge to perform duties in a safe and healthful manner through formal and the on-job-training. refresher training will be given in the form of safety meetings and other appropriate formats that will be designed to cover pertinent material in the area of emergency response New Employees These employees will be given initial training in safety and environmental areas along with the formalized operator training prior to being assigned to a work unit. All new hires in the Operations Area will be given training equivalent to the Hazmat technician level specified in paragraph (q) either on-site or at a qualified off-site facility. New hires that can provide certification of completion of Hazmat training requirements are considered current. refresher training will be given in the form of safety meetings and such as specified for current employees Paragraph (Q) Hazardous Material Technician The object of training at this level is to be able to take offensive action to stop a release. These employees will receive 24 hours of training to meet the requirements of this paragraph. At the present time, initial training to meet paragraph (q) of the regulations is completed by an offsite contractor along with site-specific training conducted by site EHS personnel. Refresher training is conducted during regularly scheduled safety meetings.

8 Procedure No.: PA Page: 8 of PROCEDURES cont d 4.4. Paragraph (Q) cont d Incident Command (IC) Those persons that could reasonably be expected to perform in the role of incident commander will be trained to a level that will enable them to perform these duties should their services be required in an emergency. These people will be taken from the Group Leader level and above. IC training is usually given at off-site qualified facilities RCRA Hazardous Waste Training Program Outline I. HAZARDOUS WASTE MANAGEMENT OVERVIEW A. Definitions of Hazardous Wastes B. Hazardous Characteristics C. Specific Wastes Generated D. Record Keeping II. III. FACILITY POLICIES AND PROCEDURES A. Site Security B. RCRA Contingency Plan C. Personal Protective Equipment D. Testing and Maintenance of Emergency, Monitoring, Alarm, and Communication Systems E. Spill Response and Containment F. Communication Systems CONTAINER MANAGEMENT A. Waste Identification and Segregation B. Storage and Handling C. Labeling and Recordkeeping D. Inspection Requirements 4.6. Recordkeeping The Port Arthur site maintains documents and records pertaining to the employee's training requirements, including certification forms specifying hazardous waste management training. All records of training for current personnel will be kept on file at the site until closure. Records of former employees are kept for three years after the date the employee leaves the facility. Copies of training records for employees transferring within the company will accompany the employee.

9 Procedure No.: PA Page: 9 of RESPONSIBILITIES 5.1. Process Technicians This group is required to be trained per OSHA regulations found in 29 CFR, Part All of the technicians are to be trained per requirements in Paragraph (q) of the OSHA regulation. As such, they are will be able to perform containment operations in the event of a release of hazardous waste. They may also be able to take offensive action to stop the release. Training includes those items listed in section (p) of the regulation for clean up of spills of hazardous wastes. They must have knowledge in the selection and use of personal protective equipment. They must be familiar with the plant's Emergency Response Plan and be able to function within the Incident Command System for emergencies. Also in the plant's Emergency Response Plan is information on how to respond to the alarm system in case of an emergency. This includes all types of emergencies and is not limited to only those, which may involve a release of a hazardous waste. Specific RCRA training is required so that this group can perform activities included in the regulations. These activities include recognizing wastes that are considered hazardous wastes, proper labeling of drums which contain hazardous wastes, performing daily inspections on waste management units located within the operating areas, maintaining drums located at satellite accumulation areas, and reporting of any hazardous waste released to the environment to their supervisor. Certain process technicians belong to the plant's Emergency Response Team. These individuals attend annual fire training at an off-site training facility and take part in plant drills on a regular basis. They may also be asked to respond to offsite emergencies through mutual aid and to the Beaumont site Shift Supervisor Shift Supervisors at the Port Arthur site have the duty of supervising the operations team lead and technician groups. The Shift Supervisors must be trained to the same level as the operations technician group. They also are responsible for reporting of spills to other supervisors and the EHS Department, either during normal business hours or on the off-shifts. Shift Supervisors are automatically members of the Emergency Response Team and take part in offsite, annual fire training and onsite drills. They may also be asked to respond to offsite emergencies through mutual aid. The on-shift process Shift Supervisor may be the Incident Commander until relieved by a Qualified Designate.

10 Procedure No.: PA Page: 10 of RESPONSIBILITIES cont d 5.3. Operations Managers/Production Leaders The Operations Managers and Production Leaders must be familiar with the plant's Emergency Response Plan and be able to function in the Incident Command System during an emergency. They can serve as Incident Commander. Training in RCRA specific items is provided for such subjects as hazardous waste identification, inspection requirements, reporting of releases, and spill mitigation requirements Operations Director The Operations Director is currently listed as the senior most member of management who will act as Incident Commander during an emergency. As such, this person must know how to implement the plant's Emergency Response Plan during an emergency and is authorized to carry out all duties required of the position. Training in RCRA specific items is provided for such subjects as hazardous waste identification, inspection requirements, reporting of releases, and spill mitigation requirements Environmental, Health, and Safety Manager The EHS Manager must know how to implement the plant's Emergency Response Plan and function in the Incident Command System. The EHS Manager must be knowledgeable in the hazardous waste regulations and may train others in the regulations. The EHS Manager may also be required to report releases to the appropriate agencies 5.6. Environmental, Health, and Safety Team Member The EHS Team Member(s) must be knowledgeable in the hazardous waste regulations and may train others in the regulations. This person is also responsible for making sure that reports get filed to appropriate agencies as called for in the regulations. Reporting of releases to the appropriate agencies is also a part of the area of responsibility as well as filing of follow-up reports on releases Engineers The Operations Engineers must be familiar with the plant's Emergency Response Plan and be able to function in the Incident Command System during an emergency. They can serve as Incident Commander. Training in RCRA specific items is provided for such subjects as hazardous waste identification, inspection requirements, reporting of releases, and spill mitigation requirements Maintenance Coordinator/Technicians The Maintenance Coordinator is involved in matters pertaining to repairs and

11 Procedure No.: PA Page: 11 of 19 maintenance on plant equipment. As such, training in RCRA specific items is provided for such subjects as hazardous waste identification, inspection requirements, reporting of releases, and spill mitigation requirements. 5. RESPONSIBILITIES cont d 5.9. Other Personnel Detailed descriptions of hazardous waste management duties for each site job title is in Appendix A. 6. RELATED DOCUMENTS 40 CFR, PART (RCRA) 29 CFR, PART (HAZWOPER) Appendix A Employee Job Descriptions for Hazardous Waste Operations *Appendix B Job Titles and Personnel *Please contact the Environmental, Health, and Safety Department for a copy of Appendix B since this document has the potential to undergo numerous changes.

12 Appendix A Procedure No.: PA Page: 12 of 19 Port Arthur Site Employee Job Descriptions for Hazardous Waste Operations Job Title RCRA Duties Required Training Level Process Generates solid hazardous waste during Technician changing of filter media Generates liquid hazardous waste during sampling of product Generates liquid hazardous waste during changing of filter media Properly dispose of hazardous waste into the appropriate satellite accumulation area Transfer satellite storage area drums into a less than 90 day accumulation area Conduct periodic inspections of the satellite accumulation area(s) in the production areas May Participate on trained spill response team, after receiving proper training Operations May generates solid hazardous waste during Coordinator changing of filter media May generates liquid hazardous waste during sampling of product May generates liquid hazardous waste during changing of filter media Properly dispose of hazardous waste into the appropriate satellite accumulation area Transfer satellite storage area drums into a less than 90 day accumulation area Conduct periodic inspections of the satellite accumulation area(s) in the production areas May Participate on trained spill response team, after receiving proper training Maintenance Coordinator/ May work in areas where hazardous waste is generated, transferred, and/or stored Technicians May generate hazardous waste during maintenance activities May transfer waste into appropriate container for disposal Participate in daily, weekly, and monthly

13 Appendix A Procedure No.: PA Page: 13 of 19 Job Title RCRA Duties Required Training Level inspections of hazardous waste storage areas in their area of responsibility May participate on spill response team, after receiving proper training Security No exposure to hazardous waste None Supervisor Group Technology May prepare procedures that deal with handling Awareness & Project Manager Lead Infrastructure Analyst Maintenance Manager or disposal of hazardous wastes. No exposure to hazardous waste None Occasionally works in area where hazardous waste may be generated, transferred, and/or stored Audit area inspection records for hazardous waste storage area in their area of responsibility Engineers May generate solid hazardous waste during changing of filter media May generate liquid hazardous waste during sampling of product May generate liquid hazardous waste during changing of filter media Properly dispose of hazardous waste into the appropriate satellite accumulation area May transfer satellite storage area drums into a less than 90 day accumulation area May conduct periodic inspections of the satellite accumulation area(s) in the production areas Operations Manager/ Production Leaders May occasionally complete non-production related, non waste generating tasks in areas in which hazardous waste is generated, transferred, and/or stored May participate in daily, weekly, or monthly inspections of hazardous waste storage areas. TES Manager May occasionally complete non-production related, non waste generating tasks in areas in which hazardous waste is generated, transferred, and/or stored Awareness

14 Appendix A Procedure No.: PA Page: 14 of 19 Job Title RCRA Duties Required Training Level Accounting No exposure to hazardous waste None Manager Manager Human No exposure to hazardous waste None Resources Admin. Associate No exposure to hazardous waste None Application Owner No exposure to hazardous waste None Site Technical No exposure to hazardous waste Awareness Training Leader May assist in the preparation and presentation of Training Assistant No exposure to hazardous waste None Project Analyst No exposure to hazardous waste None Logistics No exposure to hazardous waste None Specialist Control Systems No exposure to hazardous waste None Coordinator Analytical May work in areas where hazardous waste is Systems generated, transferred, and/or stored Coordinator May generate hazardous waste during maintenance activities May transfer waste into appropriate container for disposal Instrument & No exposure to hazardous waste None Control Engineer Maintenance Team Lead May work in areas where hazardous waste is generated, transferred, and/or stored May generate hazardous waste during maintenance activities May transfer waste into appropriate container for disposal Participate in daily, weekly, and monthly inspections of hazardous waste storage areas in their area of responsibility May participate be a first responder to a spill Maintenance Tech Works in areas where hazardous waste is generated, transferred, and/or stored May generate hazardous waste during maintenance activities Properly transfer waste into appropriate container

15 Appendix A Procedure No.: PA Page: 15 of 19 Job Title RCRA Duties Required Training Level for disposal Participate in daily, weekly, and monthly inspections of hazardous waste storage areas in their area of responsibility May participate on spill response team, after receiving proper training Maintenance Tech (Routine Contractors) Works in areas where hazardous waste is generated, transferred, and/or stored May generate hazardous waste during maintenance activities Properly transfer waste into appropriate container for disposal Participate in daily, weekly, and monthly inspections of hazardous waste storage areas in their area of responsibility Optimization/ Controls Engineer Manager of Community & Government Affairs No exposure to hazardous waste None No exposure to hazardous waste May be called on to discuss issues related to hazardous wastes with employees and/or the community Awareness Site Manager/ Operations Director Will act as Incident Commander during an emergency. Must know how to implement the plant's Emergency Response Plan during an emergency Is authorized to carry out all duties required of the position. Trained in RCRA specific items for such subjects as hazardous waste identification, inspection requirements, reporting of releases, and spill mitigation requirements. Operations Shift Supervisors May occasionally complete non-production related, non waste generating tasks in areas in which hazardous waste is generated, transferred, and/or stored

16 Appendix A Procedure No.: PA Page: 16 of 19 Job Title RCRA Duties Required Training Level Participate in daily, weekly, monthly inspections of hazardous waste storage areas within their area of responsibility May participate on trained spill response team, after receiving proper training. HR Representative No exposure to hazardous waste May be called on to discuss issues related to hazardous wastes with employees and/or the community Awareness EHS Team Member Ensure compliance with all local, state and federal laws governing hazardous waste Ensure hazardous waste is properly profiled with BASF approved TSDF facilities Ensure hazardous waste is properly packaged, labeled and shipped Ensure hazardous waste is properly disposed of at BASF approved TSD facilities Ensure all hazardous wastes are properly identified and assigned a DOT proper shipping description Ensure all hazardous wastes are evaluated and EPA waste codes assigned Ensure all manifests and Land Disposal Restriction forms for shipments of waste are properly completed Retain appropriate records in accordance with BASF records Submit annual hazardous waste generator s report Track waste generation and cost monthly Permanent member of the waste minimization team Conducts annual RCRA training Attend annual Train the Trainer RCRA training Environmental, Act as Incident Commander for spill response

17 Appendix A Procedure No.: PA Page: 17 of 19 Job Title RCRA Duties Required Training Level Health, and Safety teams Manager Occasionally pass through areas where hazardous waste is generated, transferred, and/or stored Participate in annual RCRA training EHS Team Member May occasionally complete non-production related, non waste generating tasks in areas in which hazardous waste is generated, transferred, and/or stored Participate in daily, weekly, monthly inspections of hazardous waste storage areas within their area of responsibility May participate on trained spill response team, after receiving proper training. May conduct or assist with annual RCRA training May attend annual Train the Trainer RCRA training Heating Specialist May occasionally complete non-production related, non waste generating tasks in areas in which hazardous waste is generated, transferred, and/or stored Maintenance Planner Site Waste Coordinator (Veoila: In-Plant Services) May occasionally complete non-production related, non waste generating tasks in areas in which hazardous waste is generated, transferred, and/or stored Act as Hazardous Waste Coordinator for the site Ensure compliance with all local, state and federal laws governing hazardous waste Ensure hazardous waste is properly profiled with BASF approved TSDF facilities Ensure hazardous waste is properly packaged, labeled and shipped Ensure hazardous waste is properly disposed of at BASF approved TSD facilities Ensure all hazardous wastes are properly identified and assigned a DOT proper shipping description Ensure all hazardous wastes are evaluated and Awareness

18 Appendix A Procedure No.: PA Page: 18 of 19 Job Title RCRA Duties Required Training Level EPA waste codes assigned Ensure all manifests and Land Disposal Restriction forms for shipments of waste are properly completed Retain appropriate records in accordance with BASF records retention policy Properly complete and submit annual hazardous waste generator s report Track waste generation and cost monthly Permanent member of the waste minimization team May conduct or assist with annual RCRA training Attend annual Train the Trainer RCRA training

19