*Job Specific Environmental and Safety Review for*: [Agricultural
Operations]{.underline}

2^nd^ version created on 8/17/03

 

Contacts:          Richard C. Sautkulis, Agricultural Op.
Supervisor/Bldg. Mgr.-B463
(x3386)                                                       

                        Ann Emrick, Work Control Manager (x5756)

##                         Bob Colichio, ES&H (x8440) 

                        Steve Ferrone, Environmental Compliance (x5531)

**Objective**: Because your work activities have been identified as
having significant potential to impact the environment and your safety,
this document has been designed to provide you with the job-specific
information that you must know to protect the environment and to protect
yourself.  You are still required to complete all the BNL training that
has been identified for your position.

 

Environmental Aspects: (*significant environmental aspects are
underlined*)

 Hazardous waste

[Industrial waste]{.underline}

Liquid discharges

Water consumption

[Chemical storage/ use (back-flow prevention)]{.underline}

[Storage and Transfer of Toxic and Hazardous Materials (Barn is a
Registered Article 12 Facility)]{.underline}

Power consumption

 

 

1)      What potential impacts to the environment are associated with
your activities?

 Care must be taken to handle raw material stocks, associated wastes
appropriately to ensure proper disposal.  Agricultural Operations staff
work with pesticides, herbicides, fertilizers and associated wastes. The
potential impacts include: potential air emissions are emitted (vented
through large duct connected to vented chemical storage cabinet and
mixing fume hood); liquid effluents - wastewater (to sanitary);
industrial wastes - solid waste (unused fertilizers/organics- plowed
into field, plant pots are reused, bottles and bags to trash); bulk
storage of hazardous solids within the barn (Bldg. 496) requiring a
SCDHS Article 12 Registration and subsequent inspections; and "Universal
Waste" generation (spent HO and VHO fluorescent light bulbs- shipped off
site).  Improper disposal of the universal wastes could be a source of
contamination.

* *

2)      What consequences may result if your operations were to impact
the environment?

 The potential environmental impacts include:

> •   *Universal waste mismanagement with potential to contaminate the
> environment and incur regulatory penalties.*

-   *Improper hazardous material storage could cause
    runoff/environmental contamination*

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-   *Improper discharges to the sanitary sewer system resulting in a
    violation of the BNL SPDES permit (Clean Water Act) and potentially
    polluting surface and ground waters.\
    *

-   *Illegal discharges of pesticides to the environment resulting in
    FIFRA violations and potential contamination of the ground,
    groundwater and surface waters.\
    *

-   *Removal of the back-flow prevention could result in contamination
    to the drinking water in violation of the Safe Drinking Water Act.*

 

3)      What benefits or positive effects would you notice with improved
environmental performance? 

## •         *Minimize adverse impacts to the environment* 

•         *Ensure compliance with regulatory requirements*

•        *Save money through pollution prevention, reduced disposal
costs, improved energy efficiency and elimination of environmental
violations that subject BNL to fines and or shutdown*

•         *Allay community concerns and restore their confidence*

*By knowing the requirements and adhering to them, we will not only
improve our environmental performance but also improve our relationships
with the regulators.  By using environmentally suitable alternatives, we
can also minimize our exposure to toxic chemicals.*

 

4)      What role and responsibility do you have for these potential
impacts and environmental performance?

 

We are required to have knowledge of:

*The regulatory requirements that affect the work being performed (we
follow the SBMS- subject areas, specifically hazardous/industrial waste,
pollution prevention, spill response, liquid effluents, drinking water
and storage/transport of hazardous materials, Storage of Toxic and
Hazardous Materials and the BNL Chemical Hygiene plan).  Lab Standard
and Hazardous Waste Generator training is required to ensure we
understand the regulations. Additionally, the NYSDEC requires
applicators of pesticides to ornamentals, shade trees, and turf
(Category #3A) to have a license under 6 NYCRR Part 325. In addition to
passing initial written examinations, there are refresher course
requirements.*

•         *A process for identifying non-compliance and implementing and
tracking corrective actions.  The Tier 1 inspection process is utilized
and the Tier 1 Team is notified in writing about any non-compliance that
the Agricultural Op. Supervisor is responsible to correct. If we notice
an environmental problem, we can report this to the ES&H team.  There is
also a Safety Hotline that we can call to report environmental or safety
violations.*

I must understand, be responsible and accountable for the impacts that
my actions have on the environment.  I am aware of my surroundings,
activities and procedures.  We utilize resources to protect and improve
the quality of the environment for future generations.

 

5)      What controls or procedures are implemented to reduce the
potential for emergency?

•         *Secondary containment and proper labeling of stored raw stock
and waste liquids*

•         *Tier 1 program and self-assessments*

•         *Process Assessment Project- agricultural process assessment
(PEP-067)*

•         *Posting of sinks, listing acceptable sink disposable
materials where appropriate*

•         *Relevant subject areas and ES&H standards*

•         *Relevant training.*

•         *Back-flow prevention devices*

•        *Hooded sink for pesticide mixing*

•        *Posting/securing area around fields during pesticide
applications, and notifying authorities as required by DEC pesticide
application rules.*

 

*6)     * How would you respond in an emergency to reduce the potential
for environmental impact and what actions could be taken to mitigate?

 

•         *Call spill response hotline -- x2222*

•         *Local Emergency Plan*

•         *In case of hood failure, stop operations in hood, lower sash,
contact Bldg. Manager*

•        *Utilize spill response materials as appropriate*

* *

7)      What pollution prevention and waste minimization techniques have
been or could be considered to reduce or eliminate the potential to
impact the environment?

 

*We follow integrated pest management techniques.  Pesticide rinse water
is reused as well as surplus fertilizers. Universal waste fluorescent
bulbs are properly dispose/recycled off-site.*

 

These are some of the pollution prevention ideas generated during the
process assessments:

•         *Replace fluorescent light bulbs with non-hazardous low
mercury content fluorescent bulbs or an alternate non-fluorescent
lighting system or handle the bulbs as universal wastes and recycle them
off-site.*

•         *Reuse spent sand filter material from the fish house as fill
in the fields*

•         *Segregate metal materials from other wastes and transfer to
the Central Shops Division chip bins for recycling*

Unfortunately, the triple-rinsed pesticide containers cannot be recycled
as per NYSDEC pesticide regulations due to the potential for the plastic
to be used in the food industry. Therefore, the triple rinsed containers
formerly containing pesticides, herbicides and other hazardous materials
must be disposed of and not recycled.

 

*8)     * Are there any key Environmental-specific Competency
Requirements (Experience, Education, Qualification) for this position?

* *

*This is outlined in the Job Training Assessment (JTA*) *and R2A2s. 
(Review if needed).*

 

9)      Does this work include potential for injury?  If so, what
controls are used as protection?

 

*Pesticide use carries a potential for injury.  The Pesticide
Applicators are required to be certified as per NYSDEC regulatory
requirements.  At least one member of the team is required to be
respirator trained to handle powdered pesticides. We follow the
instructions on the label.  Eye protection is used where splashing is
possible.*

* *

*Operation of farm equipment carries a potential for injury.  To control
this, protective equipment such as ear protection and eye protection is
made available to the staff.  A cell phone is available for use in the
field for reporting personal and environmental emergencies.  Forklift
training is required.*

* *

10)  Are there any additional controls that you can think of that would
assist in preventing environmental or safety hazards in your job?

 

 

 

 

I have read and understood the above document.

 

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Print Name
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Number

 

If you have questions about this document, please use the contacts
listed on page 1.  Please return the signed form to the Training
Coordinator.  Thank you for your time.