FLOWING IN THE RIGHT DIRECTION SECURE AND SAFE WASTESTREAM EG FLOWING IN THE RIGHT DIRECTION SECURE AND SAFE

ATTENTION PLEASE! You are about to loose direct control Your security could be in the hands of a stranger Will the end of your process be handled with care Your responsibility is your responsibility Everyone had better KNOW what is going to happen

WASTESTREAM DISPOSITION DECISIONS MAKING YOUR DECISION , A GOOD DECISION

That Becomes an open ended responsibility The NATURE of the BEAST A Highly Regulated Material Creates a Highly Regulated Process Yielding a Highly Regulated Product Leaving a Highly Regulated Residual That Becomes an open ended responsibility

ETHYLENE GLYCOL HOCH2-CH2OH

ETHYLENE GLYCOL GENERATION Ethylene oxide is made to reacts with water to form Ethylene glycol as shown below. (CH2)2O + H2O → (CH2OH)2 ΔH = −21.8 kcal Other byproducts are Diethylene glycol, Triethylene glycol and Tetra ethylene glycol

PROPERTIES OF ETHYLENE GLYCOL Boiling point at 101.3 kPa 197.60 °C Freezing point -13.00 °C Density at 20°C 1.1135 g/cm3 Heat of vaporization at 101.3 kPa 52.24 kJ/mol Heat of combustion 19.07 MJ/kg Critical temperature 372 °C Critical pressure 6515.73 kPa Critical volume 0.186 L/mol Flash point 111 °C Ignition temperature 410 °C

IT’S NOW EG HAZARD IDENTIFICATION ETHYLENE GLYCOL IS CONSIDERED TOXIC BY INGESTION IT’S SHIPPING pH MAY ALSO CLASSIFY IT AS CORROSIVE ENVIRONMENTAL HAZARD

REGULATIONS & LAWS GENERATOR APPLIED TWO CATEGORIES ENVIRONMENTAL HEALTH & SAFETY

CERCLA: COMPRESHENSIVE, ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT Passed in 1980. To require the responsible party to report any release of hazardous substances if the amount of release meets or exceeds that substance’s reportable quantity. To hold responsible party liable for clean up. Not following this regulation has penalties. Also known as superfund.

Superfund Amendments and Reauthorization Act (SARA) Passed in 1986 To reauthorize and expand the original CERCLA Superfund that expired in 1985. Administered by the EPA. Tasked DOT to create HAZWOPER requirements.

RCRA: RESOURCE CONSERVATION AND RECOVERY ACT (1976,1984) The RCRA gives the EPA the authority to control hazardous waste from “cradle to grave”, including the generation, transportation, treatment, storage and disposal of hazardous waste. It is used as a cradle to grave system for tracking and regulating hazardous wastes. Any facility that generates or stores more than 1000 kg of hazardous waste a month is a large quantity generator. Not complying with RCRA can result in penalties.

CRADLE-TO-GRAVE IN-PERPETUITY CREATES NEED FOR “ LIFE CYCLE’ THINKING

Life cycle thinking , assessment and analysis Processing of raw materials. Manufacturing. Transporation & Distribution. Use, Reuse & maintenance. Recycling. Disposal.

LIFE CYCLE

HEALTH AND SAFETY DESIGNATED HAZARDOUS SUBSTANCE UNDER SECTION 3(b) OF FEDERAL HAZARDOUS SUBSTANCES ACT; REQUIRES SPECIAL LABELING REMEMBER! EG BECOMES A TOXIC SOURCE UPON INGESTION AND MAY BE FATAL

TRANSPORT REGULATIONS EPA transporter requirements are in 40 CFR PART 263. Transporters must also comply with Department of Transportation requirements in 49 CFR, especially parts 171 through 179.

Transportation requirements for compliance. With new threats after 9/11 DOT is insisting on developing security plans for each chemical facility. Includes a security assessment to determine the risks and threats first and then develop a security plan. There should be emergency response plans in place. Employees should be given general awareness training and function specific training for handling and transportation haz materials.

PROCESS GENERATED ETHYLENE GLYCOL EG(ETHYLENE GLYCOL) IS THE RESIDUAL MATERIAL THAT BECOMES YOUR WASTESTREAM PROPER DISPOSITON OF THE EG IS AN ESSENTIAL TASK WITHIN YOUR OVERALL OPERATION

Plant Personnel Training & Record Keeping Proper hazwoper and haz comm. training for employees. Proper training for handling and transport of ethylene glycol and other chemicals. Train operators how to use MSDS, ERG, NIOSH, NFPA guides. DOT training for employees connected to transportation. Basic training on knowledge of epa regulations like RCRA, CERCLA and SARA. Record keeping of all training documents is another requirement. Usually kept for 3 years.

THE KNOWS to KNOW KNOW HOW…..INFORMED, FAMILIAR, NOT A GUESS KNOW WHERE…..CERTAINTY, DIRECT TRACABILITY KNOW WHEN…..RELIABILITY, COMMITMENT, TIMELY KNOW WHO…..NO PASS-OFF, TRUST, CREDENTIALED KNOW WHY…..SECURITY, CONFIDENCE

CONTRACTOR SELECTION FAMILIAR AND ATTENTIVE TO ALL REGULATIONS IN-PLACE “ROUTINE” PROTOCOLS AND PROCEDURES FOR EG HANDLING AND DISPOSITON PROVEN TRACK RECORD SPECIFC TO EG HANDLING AND UTILIZATION

Product Screening & Acceptance Procedure. Volume, frequency and availability of the stream. Availability of generators assay. Request pre shipment samples of the product. Lab analysis done to make sure material matches the assay generator provides us. Once the assays matches a trial load of the product is requested.

DOCUMENTS OF TRADE FULLY PERMITTED OPERATIONAL AND TRADE PLANS CREDENTIALED FOR ENVIRONMENTAL SERVICE FULLY PERMITTED OPERATIONAL AND TRADE PLANS LIABILITY INSURANCE WITH FORTUNE 500 ZERO CLAIM RECORD ENVIROMANTAL POLLUTION INSURANCE OF $10 MILLION

COASTLINE CHEMICAL TEN YEARS OF PROFESSIONAL EG HANDLING WITH A PROVEN TRACK RECORD. DIRECT USE OF EG IN OUR OWN ANTIFEEZE MANUGACTURING. DIRECT CONTROL AND ACCOUNTABILITY FOR THE ENTIRE PROCESS. STATE OF THE ART ENVIRONMENTAL AND HANDLING CONTROLS. INSPECTED AND APPROVED FACILITY. COASTLINE PARTNERS WITH BALCHEM IN A PLAN TO IMPROVE THE TOTAL SERVICE COMMITMENT THEY OFFER IN THE EO SUPPLY AND UTILIZATION CHAIN. IN HANDLING YOUR ETHYLENE GLCYOL, COASTLINE IS THE END USER, NOT A BROKER. YOU KNOW EXACTLY WHERE YOUR MATERIAL IS, WHAT IT IS BEING USED FOR.