Appendix D 

SOUTHERN LNG AND EEC’S PROJECT-WIDE SPILL PLAN, 

WASTE MANAGEMENT PLAN, 

AND CONTAINER MANAGEMENT POLICY 
ELBA III PROJECT ELBA III TERMINAL EXPANSION 

ELBA EXPRESS PIPELINE 

D-1 

SOUTHERN NATURAL’S /ELBA EXPRESS COMPANY 

• SPILL PLAN & FORM, Pages 1 - 6 

• WASTE MANAGEMENT PLAN, Pages 7 - 11 

• CONTAINER MANAGEMENT POLICY, Page 12 

SPILL PLAN 

PREVENTATIVE MEASURES

The spill prevention and control methods listed in this section are based on approved spill control 

plans that Southern has used successfully in the past. This plan is comprehensive in that it 

addresses actions used to prevent spills in addition to specifying actions that will be taken should 

any spills occur, including emergency notification procedures. The Project's on-site EI’s are 

responsible for ensuring that contractors implement and maintain spill control measures. 

Training 

The Contractor will instruct personnel on the operation and maintenance of equipment to prevent the 

accidental discharge or spill of fuel, oil, and lubricants. Personnel will also be made aware of the 

pollution control laws, rules, and regulations applicable to their work. 

Spill prevention briefings with the construction crew will be scheduled and conducted by the EI to 

insure adequate understanding of spill prevention measures. These briefings will highlight: 

• precautionary measures to prevent spills; 

• sources of spills, such as equipment failure or malfunction; 

• standard operating procedures in case of a spill; 

• equipment, materials, and supplies available for clean-up of a spill; and 

• a list of known spill events. 

Equipment Inspection/Maintenance 

The Contractor will inspect and maintain equipment that must be fueled and/or lubricated 

according to a strict schedule. The Contractor will submit to Southern for approval written 

documentation of the methods used and work performed. 

All containers, valves, pipelines, and hoses will be examined regularly to assess their general 

condition. The examination will identify any signs of deterioration that could cause a spill and 

signs of leaks, such as accumulated fluids. All leaks will be promptly corrected and/or repaired. 

Refueling Operations 

The Contractor will insure that equipment is refueled and lubricated within the ROW and at least 100 

feet away from all waterbodies and wetlands with the following exceptions: 

• areas such as rugged terrain or steep slopes where movement of equipment to refueling stations 

would cause excessive disturbance to the ROW; 
ELBA III PROJECT ELBA III TERMINAL EXPANSION 

ELBA EXPRESS PIPELINE 

D-2 

• areas where removing equipment from a wetland for servicing would increase adverse impacts to 

the wetland; 

• when specialized refueling equipment (i.e., low ground weight buggies with a special mounted 

fuel tank within secondary containment) for refueling equipment in lengthy wetlands; 

• sites where moving equipment to refueling stations from pre-fabricated equipment pads is 

impracticable or where there is a barrier from the waterbody/wetland (i.e., road or railroad); 

• locations where the waterbody or wetland is located adjacent to a road crossing (from which the 

equipment can be serviced); and 

• refueling of immobile equipment including, but not limited to, bending and boring machines, air 

compressors, padding machines, and hydro-test fill pumps. 

In these areas, auxiliary fuel tanks will be used to reduce the frequency of refueling operations and in 

no case will refueling take place within 200 feet of any known potable water wells. 

The Contractor will assure that all refueling is done pursuant to the following conditions: 

• Impact minimization measures and equipment will be sufficient to prevent discharged fluids 

from leaving the ROW or reaching wetlands or waterbodies, and be readily available for use. 

These will include some combination of the following: 

a. dikes, berms or retaining walls sufficiently impervious to contain spilled oil; 

b. sorbent and barrier materials in quantities determined by the Contractor to be 

sufficient to capture the largest reasonably foreseeable spill; 

c. drums or containers suitable for holding and transporting contaminated materials; 

d. curbing; 

e. culverts, gutters, or other drainage systems; 

f. weirs, booms, or other barriers; 

g. spill diversion or retention ponds; and 

h. sumps and collection systems. 

• All spills will be cleaned up immediately. Containment equipment will not be used for storing 

contaminated material. 

Storage 

Storage containment areas will not have drains, unless such drains lead to a containment area or 

vessel where the entire spill can be recovered. 

Personnel Support 

Prior to construction, the ROW inspector or agent shall identify and prepare a written inventory of 

water wells within 200 feet of the construction site. The construction ROW agent will notify the 

authorities of all potable water supply intakes located within three miles downstream of any 

crossings a minimum of one week prior to construction. 

SPILL RESPONSE MEASURES 

Containment is the immediate priority in the case of a spill. A spill will be contained on Southern's 

property or ROW, if possible. Clean up procedures will begin immediately after a spill is contained. 

In no case will containment equipment be used to store contaminated material. 

In case of a spill, the Contractor or utility inspector (who ever sees it first) will notify the EI, 

construction supervisors, and Division contacts immediately. The following contacts are currently 

assigned to the Project and are subject to change: 
ELBA III PROJECT ELBA III TERMINAL EXPANSION 

ELBA EXPRESS PIPELINE 

D-3 

Elba III Terminal Expansion Project

SNG - Project Environmental Coordinator – 

Jason M. Goldstein 205-325-3879 (wk) 205-873-0701 (cell) 

SNG - Environmental Compliance Dept. – 

Tim McKellar 205-325-7684 (wk) 205-907-4843 (cell) 

National Response Center: 800.424.8802 

Georgia Emergency Response Center Toll free at: 1-800-241-4113

Elba Express Pipeline

EEC – Project Environmental Coordinator – 

 Stephen Weems 205-521-6084 (wk) 205-937-5674 (cell) 

EEC – Environmental Compliance Dept. – 

 Kelley Beavers 205-325-3784 (wk) 205-936-2364 (cell) 

EEC – Savannah Locations Contact 

 Mike Prestage – 912-748-2945 

National Response Center: 800-424-8802 

Georgia Response Center: 800-241-4113 

Emergency Response Contractors: 

Ferguson-Harbour, Atlanta, GA: 800-235-3224 

Moran Environmental Recovery, Savannah, GA: 912-232-3224 

If a spill enters a body of water, the Contractor will immediately take samples upstream and 

downstream from point of entry and refrigerate samples. If advised, additional analysis will be 

completed and/or additional samples will be gathered. 

If the EI determines that a spill is small enough such that the construction crew can safely handle it, 

the crew will use construction equipment to containerize all spilled material, contaminated soil, and 

sorbent material in a manner consistent with the spilled materials' characterization. 

If the EI determines that a spill cannot be adequately excavated and disposed of by the construction 

crew alone, the Contractor will contact waste containment specialists. The EI will ensure that all 

excavated wastes are transported to a disposal facility licensed to accept such wastes. Wastes will 

not be transported to a company facility unless the Division Compliance Specialist approves it in 

writing. 

• The Contractor will prepare a Construction Site Spill Report form to be given to the EI that 

includes: 

a. the date, time and location of the occurrence; 

b. a description of the material spilled; 

c. the quantity spilled; 

d. the circumstances that caused the spill; 

e. a list of waterbodies affected or potentially affected by the spill; 

f. a statement verifying whether a sheen is present; 

g. the size of the affected area; 

h. an estimate of the depth that the material has reached in water or on soil; 

i. a determination of whether the spill will migrate off of Southern's property or the 

ROW; 

j. a determination of whether the spill is under control; 
ELBA III PROJECT ELBA III TERMINAL EXPANSION 

ELBA EXPRESS PIPELINE 

D-4 

k. a statement verifying that clean-up has begun and a description of the methods 

being used to clean up the spill; and 

l. the names of the people observing the spill (with their affiliations). 

 

• The EI will assure that the Contractor notifies the appropriate agencies if it is determined that a 

spill exceeds reportable quantity thresholds. 

• The National Response Center (1-800-424-8802) will be notified immediately if spills occur 

above threshold levels (Clean Water Act, 40 CFR 110.10) into surface waters and/or wetlands. 

SUGGESTED SPILL EQUIPMENT LIST 

The Contractor's choice of impact minimization measures and equipment will be tailored to meet 

the characteristics of the affected terrain as well as the types and amounts of material that could 

potentially be spilled. 

Terrestrial Construction 

General equipment that Southern will use for spill containment and cleanup on terrestrial areas 

includes: 

• absorbents (pillows, socks, and wipe sheets) for containment and pick up of spilled liquids; 

• commercially available spill kits (or the functional equivalent thereof) that are prepackaged, selfcontained spill kits containing a variety of absorbents for small to large spills; 

• structures such as gutters, culverts, and dikes for immediate spill containment; 

• shovels, backhoes, etc., for excavating contaminated materials; 

• sumps and collection systems; and 

• drums, barrels, and temporary storage bags to clean up and transport contaminated materials. 

Fuels and Lubricating Oil Storage 

The Contractor will implement special measures to prevent spills in areas where trucks carrying fuel 

and where oil barrels are loaded. Containment equipment will be kept close to tanks and barrels to 

minimize spill response time, and will include absorbent pads or mats. The quantity and capabilities 

of the mats will be sufficient to capture the largest foreseeable spill, given ROW characteristics and 

crankcase and other fuel vessel capacities. 

Routine Refueling and Maintenance 

Absorbent pads and mats will be placed on the ground beneath equipment before refueling and 

maintenance. Equipment that will be stored on site for routine refueling and maintenance includes 

small sorbent kits (or their functional equivalent). 

Equipment Failure 

Kits with the capacity of absorbing up to five gallons of liquid can fit beneath the operator's seat on 

construction equipment for use in an equipment failure. 
ELBA III PROJECT ELBA III TERMINAL EXPANSION 

ELBA EXPRESS PIPELINE 

D-5 

Waterbody and Wetland Crossings 

For each wetland and waterbody crossed, the equipment listed below will be available in addition to 

that needed for terrestrial construction. This equipment will be stored close to the water or wetland 

to minimize response time, and will include: 

• oil containment booms and the related equipment needed for rapid deployment, and 

equipment to remove oils from water, such as oleophilic and hydrophobic absorbent booms and 

mats, and/or mechanical skimmers.
D-6 

SOUTHERN LNG COMPANY – ELBA III TERMINAL EXPANSION PROJECT

SPILL REPORT FORM

IT IS MANDATORY THAT YOU COMPLETE ALL BLANKS & FILL IN ANY BLANKS THAT DO 

NOT APPLY WITH “N/A” 

Name: ______________________________ 

Date/Time: ______________________________ 

LOCATION 

MP/St.#: _____________________________ 

Tract ID: _____________________________ 

Weather:_____________________________ GroundCond.:_________________________________ 

Nearest Wetland:______________________Wetland ID/Dir/Dist:_______________________________ 

Nearest Waterbody:____________________WaterbodyName/Dir/Dist:_____________________ 

• Spills in Wetlands/Waterbody CALL Nation Response Center Within 1 hour!!!!! (See Contacts at bottom 

of page)

• If spill is hazardous material or dangerous to the environment call MS Responses Center & Emergency 

Contractor 

SUBSTANCE SPILLED / RELEASE 

Check All That Applies: Diesel:_________ Oil:_______________ Transmission:_____________ 

 Gasoline:_______ Hydraulic:__________ Other:___________________ 

CAUSE OF SPILL / RELEASE 

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________ 

RECEIVING MEDIUM (WATER, LAND, PAVED SURFACE, ETC. ... 

GIVE SPECIFIC INFO WHERE APPLICABLE) 

______________________________________________________________________

______________________________________________________________________ 

REMEDIATION DESCRIPTION (WHAT WAS DONE) 

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________ 

DISPOSAL 

Container Type: Bag: [ ] Barrel: [ ] Drum: [ ] Other: [ ] 

Disposal Location: Yard: [ ] Other: [ ] If Other: ____________________ 

NOTIFICATION 

Spill Reported To: ______________________________ 

Reported Date/Time:_____________________________ 

SNG – Project Environmental Coordinator – 

Jason M. Goldstein (205) 325-3879 wk, (205) 873-0701 cell 

SNG – Environmental Compliance Dept. – Tim McKellar (205) 325-7684 wk, (205)-907-4843 cell 

SLNG – Emergency Coordinator – Garnasia Bogus (912) 944-3819 wk, (912) 507-6322 cell, (912) 966-2739 

National Response Center: 800.424.8802 

Georgia Emergency Response Center 

Toll free at: 1-800-241-4113 
D-7 

ELBA EXPRESS COMPANY – ELBA EXPRESS PIPELINE PROJECT

SPILL REPORT FORM

IT IS MANDATORY THAT YOU COMPLETE ALL BLANKS & FILL IN ANY BLANKS THAT 

DO NOT APPLY WITH “N/A” 

Name: ______________________________ 

Date/Time: ______________________________ 

LOCATION 

MP/St.#: _____________________________ 

Tract ID: _____________________________ 

Weather:_____________________________ GroundCond.:_________________________________ 

Nearest Wetland:______________________Wetland ID/Dir/Dist:_______________________________ 

Nearest Waterbody:____________________WaterbodyName/Dir/Dist:_____________________ 

• Spills in Wetlands/Waterbody CALL Nation Response Center Within 1 hour!!!!! (See Contacts at bottom 

of page)

• If spill is hazardous material or dangerous to the environment call MS Responses Center & Emergency 

Contractor 

SUBSTANCE SPILLED / RELEASE 

Check All That Applies: Diesel:_________ Oil:_______________ Transmission:_____________ 

 Gasoline:_______ Hydraulic:__________ Other:___________________ 

CAUSE OF SPILL / RELEASE 

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________ 

RECEIVING MEDIUM (WATER, LAND, PAVED SURFACE, ETC. ... 

GIVE SPECIFIC INFO WHERE APPLICABLE) 

______________________________________________________________________________

______________________________________________________________ 

REMEDIATION DESCRIPTION (WHAT WAS DONE) 

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________ 

DISPOSAL 

Container Type: Bag: [ ] Barrel: [ ] Drum: [ ] Other: [ ] 

Disposal Location: Yard: [ ] Other: [ ] If Other: ____________________ 

NOTIFICATION 

Spill Reported To: ______________________________ 

Reported Date/Time:_____________________________ 

EEC – Project Environmental Coordinator – Stephen Weems 205.521.6084 wk 205.937.5674 cell 

EEC – Environmental Compliance Dept. – Kelley Beavers 205.325.3784 wk 205-936.2364 cell 

EEC – Savannah Locations Contact – Mike Prestage – 912-748-2945 

National Response Center: 800.424.8802 

Georgia Response Center: 800.241.4113 

Emergency Response Contractors: Ferguson-Harbour, Atlanta, GA: 800.235.3224 

Moran Environmental Recovery, Savannah, GA: 912.232.3224 
ELBA III PROJECT ELBA III TERMINAL EXPANSION 

ELBA EXPRESS PIPELINE 

D-8 

 The following information is to be used as a Contractor’s guidance tool when generating wastes 

on a project and to assist the Contractor in developing a waste management plan, which must be 

submitted to the company before the project begins. 

Waste Identification and Characterization 

Identifying Wastes 

Wastes may be grouped into four categories, each requiring different forms of disposal: 

hazardous waste, non-hazardous waste, special waste, and universal waste. 

• Hazardous wastes - Wastes that meet one of the criteria of ignitable, corrosive, 

reactive, toxic, or is specifically listed as hazardous waste by regulation. These 

wastes require special handling and disposal. 

• Non-hazardous wastes - Wastes that do not fall into the other categories. This 

includes general trash. 

• Special wastes - Wastes that do not meet the criteria for hazardous wastes, but 

may present special hazards or require special handling. Examples of special 

wastes are asbestos, polychlorinated biphenyls (“PCBs”), radioactive waste, and 

naturally occurring radioactive material (“NORM”). It’s important to note that 

some states have their own classification of special wastes. 

• Universal wastes - To reduce the amount of hazardous waste in municipal solid 

waste streams, the Environmental Protection Agency (“EPA”) and many states 

recognize batteries, thermostats and lamps, e.g., fluorescent light bulbs, as 

“universal” and thus allow easier handling of these wastes. 

Waste Characterization 

The Environmental Inspector (“EI”) shall coordinate with the Field Environmental 

Representative and/or Compressor Station personnel to determine if existing waste 

profiles exist for wastes generated during construction. These locations maintain waste 

profiles that list the characterization results of various wastes. If the classification of a 

waste is unknown, the waste must be characterized using test results or knowledge of the 

process generating the waste to determine the proper handling requirements for that 

waste. The EI shall coordinate with the Field Environmental Representative and 

Contractor to determine the type of waste and the party responsible for proper disposal. 

The information below is used to characterize a waste.

• Source of the waste. 

• Material Safety Data Sheets (“MSDS”) for materials comprising the waste. 

• Laboratory results from waste testing, as applicable. 

Contact the Field Environmental Representative for waste characterization and sampling 

instructions if no existing waste profile exists. 

WASTE MANAGEMENT 
ELBA III PROJECT ELBA III TERMINAL EXPANSION 

ELBA EXPRESS PIPELINE 

D-9 

Prior to waste characterization a number of general guidelines shall also be adhered to 

when handling or storing wastes. 

• Ensure that the Contractor’s Environmental Guidelines in the contract are 

followed. 

• Ensure that the Contractor provides a list to the Company and EI of all hazardous 

materials or potential contaminants that are to be used or stored on the project 

site. 

• DO NOT bury any wastes. This includes stumps, rocks, or boulders unless 

approved by the Company or EI per the FERC’s (Southern’s) Plan and 

Procedures found in the Environmental Compliance Manual. 

• Never mix any waste awaiting characterization with other wastes. 

• Never ship any waste unless it has been characterized. 

• Never ship any hazardous waste from the job site to a compressor station without 

prior approval from the Field Environmental Representative and compressor 

station. 

• Ship wastes along with the required manifests only to company-approved 

facilities. 

• Never ship drums of waste to a compressor station without prior approval from 

the Field Environmental Representative and the compressor station. 

Waste Types 

Hazardous Waste 

Common wastes include, but are not limited to: pipeline sludge, spent pigs, sandblast 

abrasive (depending on type and use), MEK, paint thinner, and solvents. 

The following procedures apply to storage of waste determined to be hazardous for all 

classes of generators: 

• Store hazardous wastes using the Department of Transportation (“DOT”) 

approved containers, a frac tank (bulk liquid wastes), a covered steel roll-off 

container with a poly-liner (bulk solid wastes like contaminated soil), or on a 

thick poly-liner and provide the area with a poly-liner cover and temporary 

containment berm (bulk solid wastes). 

• When using DOT-approved containers, be sure the containers are kept closed or 

sealed (except when waste is being added), maintained in good condition (not 

damaged, leaking or corroded) and store compatible substances that will not react 

with the hazardous waste. For example, store acidic wastes in plastic or plasticlined containers rather than steel containers. 
ELBA III PROJECT ELBA III TERMINAL EXPANSION 

ELBA EXPRESS PIPELINE 

D-10 

• Label hazardous waste containers (drums, tanks, roll-off containers) with a 

hazardous waste label as soon as any hazardous waste is placed into the 

container. Use a waterproof pen to complete the following information on the 

label: 

o Generator name, address, and phone number. 

o Generator EPA identification number. 

o Description of waste (contact the Field Environmental Representative to 

obtain a waste description). 

o The 4-digit EPA waste code (the Field Environmental Representative 

will provide EPA waste codes). 

o Accumulation date (the date the waste was added to the container, if not 

from satellite storage, or the date it was brought to the waste storage area 

from a satellite accumulation area). 

• Label waste piles with a weatherproof sign identifying the waste and the date the 

waste pile was started. Waste piles are to be placed on poly-liner, covered to 

protect them from weather, and surround with barricade tape. 

• Store hazardous waste in a designated hazardous waste storage area (or in a 

designated satellite accumulation area at a minimum of 20 feet from the edge of 

the Certificated ROW edge) that is covered or protected from the weather; has an 

impermeable floor, surrounded by curbing or use spill pallets; and is more than 

50 feet away from the SNG facility property line if ignitable or reactive 

hazardous waste is stored in the area. 

Manage the hazardous waste storage areas as follows:

• Identify as hazardous and non-hazardous waste appropriately. 

• Arrange the containers by waste type, keeping similar hazardous wastes together. 

• Separate any incompatible waste by a dike, berm, wall, or other containment 

device. 

• Turn containers so labels may be read easily and ensure that enough isle space is 

left between drums to inspect for leaks and to gain access to respond to spills or 

fire. 

• Handle waste containers carefully to prevent rupture or leaks, and protect 

containers from extreme temperatures. 

• Large Quantity Generators and in some states Small Quantity Generators must 

have a contingency plan, make weekly inspections of hazardous wastes, and 

provide specific training to personnel. 

• Hazardous waste can only be disposed at approved facilities. Contact the Field 

Environmental Representative for a list of approved facilities. 
ELBA III PROJECT ELBA III TERMINAL EXPANSION 

ELBA EXPRESS PIPELINE 

D-11 

Non-Hazardous Waste 

Common wastes include, but are not limited to: oily rock/soil, oily rags, sandblast 

abrasive (depending on type and use), and general trash/garbage. 

• Turn containers so labels may be read easily. 

• Non-hazardous waste is waste that has not been found to be hazardous through 

testing or by generator knowledge but has special transportation and disposal 

requirements, which may include State permitting and approvals. 

• Store non-hazardous wastes using one of the following methods: 

o In DOT-approved containers. 

o In a frac tank (bulk liquid wastes). 

o In a covered steel roll-off container with a poly-liner (e.g., bulk solid 

wastes like contaminated soil or used sandblasting abrasive). 

o On a thick poly-liner and provide the area with a poly-liner cover and 

temporary containment berm (bulk solid wastes). 

• When using DOT-approved containers, be sure the containers are: 

o Kept closed or sealed (except when waste is being added). 

o In good condition (not damaged, leaking or corroded). 

• Label non-hazardous waste containers (drums, tanks, roll-off containers) with a 

non-hazardous waste label identifying the contents as soon as waste is placed into 

the container. 

• Store non-hazardous waste segregated from hazardous waste storage or satellite 

accumulation areas. 

• Non-hazardous waste can only be disposed at approved facilities. Contact the 

Field Environmental Representative for a list of approved facilities. 

Some States allow sandblast sand to be left in the ditch if sandblasting bare pipe only. 

Contact the Project Environmental Coordinator to verify if this type of activity may 

occur. 

Special Wastes (Asbestos) 

Check with the Project Environmental Coordinator to determine if there are any 

additional state-specific requirements that may apply. 

• If the Contractor subcontracts the handling of Asbestos Containing Material 

(ACM) to a Certified Asbestos Abatement Contractor, Southern will need to 

retain copies of the Abatement Contractors Certification, Competent Person and 

other personnel’s Training Documentation, and Physicians letter allowing those 

persons to perform ACM work. Southern will also require a copy of the ACM 

Disposal Manifests for Company records. 

OR 
ELBA III PROJECT ELBA III TERMINAL EXPANSION 

ELBA EXPRESS PIPELINE 

D-12 

• The Contractor will follow their Asbestos Management Plan which has been 

submitted to Southern’s ES&H Department and has been verified by the 

Company’s Safety Department. 

Universal Waste 

Common wastes include, but are not limited to: batteries, thermostats, and fluorescent 

light bulbs. 

• If any universal waste is generated during construction, contact the Field 

Environmental Representative for storage and disposal instructions. 
ELBA III PROJECT ELBA III TERMINAL EXPANSION 

ELBA EXPRESS PIPELINE 

D-13 

Container Management Policy 

Applicability: This policy applies to all containers used to: 

1. Accumulate non-hazardous, non-regulated waste. 

2. Accumulate hazardous waste (RCRA). 

3. Accumulate hazardous substances (SARA/CERCLA) or toxic substances (TSCA). 

4. Store products of 1 gallon container size or larger. 

All containers used to accumulate non-hazardous, non-regulated waste and store products

must be: 

1. Marked or labeled clearly to identify their content. 

2. Maintained in good condition to prevent leaks or spills. 

3. Placed in an area that is protected from weather (i.e., tarps, tents, covers, inside trailer 

size containers). 

4. Arranged so that there is sufficient aisle space between containers. 

5. Placed inside secondary containment at a minimum of 110% storage capacity 

regardless of product quantity. 

All containers used to accumulate hazardous waste, hazardous substances or toxic substances

(regardless of size or quantity) must be: 

1. Marked or labeled clearly to identify their content in accordance with the appropriate 

regulations. 

2. Maintained in good condition to prevent leaks or spills. 

3. Placed inside impervious secondary containment. 

4. Placed at least 20 feet from the edge of the Certificated ROW. 

5. Closed and secure at all times except when removing or adding materials. 

6. Arranged so that there is sufficient aisle space between containers. 

7. Placed in an area that is protected from the weather. 

8. Placed inside portable containment when permanent containment is not feasible. 

9. Inspected weekly at a minimum or at frequency in accordance with the appropriate 

regulations. 

NOTE: Containers used to accumulate hazardous waste must be marked or labeled with 

the words “Hazardous Waste” and an accumulation start date. 

All empty 55 gallon drums must be: 

1. Maintained in good condition. 

2. Marked or labeled as being “Empty.” (all old labels should be removed or erased). 

3. Stored on their sides, off of the ground and protected from the weather (where 

feasible). 

4. Crushed and properly disposed if not to be reused within six months.