Engineering Procedure

SAEP-65 2 October 2017

Empty Container Management
Document Responsibility: Environmental Standards Committee

Contents
1 Overview ........................................................... 2
2 Scope ................................................................ 2
3 Applicable Documents ...................................... 2
4 Definitions ......................................................... 4
5 Instructions........................................................ 5
6 Responsibilities ............................................... 10
Revision Summary................................................. 13

Previous Issue: New Next Planned Update: 2 October 2020

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Contact: Khasawinah, Salim A. (khasawsa) on phone +966-13-8809429

©Saudi Aramco 2017. All rights reserved.

Document Responsibility: Environmental Standards Committee SAEP-65
Issue Date: 2 October 2017
Next Planned Update: 2 October 2020 Empty Container Management

1 Overview

This empty container management procedure requires proponents who use chemicals or
hydrocarbons contained in less than or equal to 275 gallons containers to comply with
Saudi Aramco Environmental Protection Policy (INT-5) and Implementation of
Hazardous Waste Code (GI-0430.001).

The objectives of this procedure is to:

 Fully utilize materials in containers;
 Minimize waste generation;
 Reduce material purchasing costs;
 Ensure proper treatment of wastewater and residuals generated from empty
containers cleaning activities;
 Prevent or minimize environmental and health impacts associated with the
inappropriate disposal of containers containing hazardous or acutely hazardous
materials or waste; and
 Reduce the Company’s legal liability due to illegal and / or improper disposal of
hazardous waste.

2 Scope

This procedure establishes the environmental instructions and responsibilities for the
management of empty 55-gallon drums (steel or plastic) and 275-gallon Intermediate
Bulk Containers (IBC) containing residues (heel) referred to in this document as
“Empty Container”. The procedure defines the responsibilities of all departments who
use materials contained in these containers. It also outlines the requirements for
efficient utilization of materials, waste minimization, proper management of empty
containers, and treatment of residual wastewater generated from empty containers
cleaning activities. This procedure excludes storage tanks and ISO Containers.

3 Applicable Documents

All referenced specifications, standards, codes, forms, drawings and similar material
shall be of the latest issue (including all revisions, addenda, and supplements) unless
stated otherwise.

3.1 Company Documents

Saudi Aramco Engineering Procedures

SAEP-302 Instructions for Obtaining a Waiver of a Mandatory
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Document Responsibility: Environmental Standards Committee SAEP-65
Issue Date: 2 October 2017
Next Planned Update: 2 October 2020 Empty Container Management

Saudi Aramco Engineering Requirement

SAEP-327 Management of Wastewater from Cleaning,
Flushing and Dewatering Pipelines and Vessels

Saudi Aramco Engineering Standards

SAES-A-104 Wastewater Treatment, Reuse, and Disposal
SAES-B-069 Emergency Eyewashes and Showers
SAES-M-006 Saudi Aramco Security and General Purpose Fencing
SAES-S-007 Solid Waste Landfill Requirements
SAES-S-010 Sanitary Sewers
SAES-S-020 Oily Water Drainage Systems
SAES-S-030 Storm Water Drainage Systems
SAES-S-040 Saudi Aramco Water Systems

Saudi Aramco General Instructions

GI-0002.716 Land Use Permit Procedures
GI-0151.006 Implementing the Saudi Aramco Sanitary Code –
SASC-S-02, Sanitary Wastewater and Sewerage
Systems
GI-0430.001 Implementing the Saudi Aramco Hazardous Waste
Code

Saudi Aramco Policies

INT-5 Saudi Aramco Environmental Protection Policy

3.2 Government Regulations

General Environmental Regulations for the Kingdom of Saudi Arabia
Royal Commission Environmental Regulations (RCER 2015)

3.3 Industry Standards

USEPA 40 CFR 261.7 Residues of Hazardous Waste in Empty Containers.
California Code of Regulations, Title 22,
Section 66261.7.

International Maritime Dangerous Goods (IMDG) Code

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Document Responsibility: Environmental Standards Committee SAEP-65
Issue Date: 2 October 2017
Next Planned Update: 2 October 2020 Empty Container Management

4 Definitions

Empty Container: The Empty Container definition was adopted from the State of
California Department of Toxic Substances Control standard, which requires the
generator to empty the container as much as reasonably possible. This definition shall
replace Saudi Aramco Hazardous Waste Code definition, which allows up to one inch
or 3% of the total weight of the container’s hazardous content to remain in the
container. It sets three standards to define an empty container, each standard is based
on the type of material held by the container:

Containers That Held Pourable Materials: For containers that held a material
that can be readily poured, all material must be removed by any practicable means
(including draining, pouring, pumping or aspirating) before the container can be
considered empty. In regards to draining, a container is empty when there is no
longer a continuous stream of material coming from the opening when the container
is held in any orientation.

Containers Holding Non-pourable Materials: For containers that previously held

materials that are non-pourable, no hazardous material shall remain in the container
that can feasibly be removed by physical methods, including scraping and chipping,
but not rinsing. This standard applies to materials that pour slowly or do not pour at
all from the container, including, but not limited to, viscous materials, solids which
have “caked up” inside the container, and non-pourable sludge.

Containers Holding Acute or Extremely Hazardous Materials: Containers

which previously held acute or extremely hazardous materials are considered empty
only if the container has been triple-rinsed using a solvent capable of removing the
material, steam cleaning, or cleaning by another method which is proven to achieve
equivalent removal to triple-rinsing.

ISO Containers: ISO or intermodal containers are used for the intermodal transport of
freight. They are manufactured according to specifications from the International
Organization for Standardization (ISO) and are suitable for multiple transportation
methods such as truck, rail, or ship.

Chaining: Within a steel drum cleaning process, the insertion of chains into the drum,
along with caustic, and tumbling the drum to remove remaining materials (i.e., heel)
from the drum interior.

Drum: A metal or plastic cylindrical container with either an open-head or a tight-head

(also known as bung-type top) used to hold liquid, solid, or gaseous commodities or
cargos which are in direct contact with the container interior.

Effluent: Wastewater discharges.

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Document Responsibility: Environmental Standards Committee SAEP-65
Issue Date: 2 October 2017
Next Planned Update: 2 October 2020 Empty Container Management

Heel: Any material remaining in a drum or container following unloading, delivery, or

discharge of the transported material. Heel may also be referred to as container residue,
residual materials, or residuals.

Intermediate Bulk Container (IBC or Tote): A completely enclosed storage vessel

used to hold liquid, solid, or gaseous commodities or material which are in direct
contact with the container interior.

Preflush: Within a drum or container cleaning process, a rinse, typically with hot
or cold water, performed at the beginning of the cleaning sequence to remove heel
(i.e., residual material) from the drum or container.

Pre-steam: Within a drum or container cleaning process, use of steam at the beginning
of the cleaning process to remove heel (i.e., residual material) from the drum, or container
interior.

5 Instructions

5.1 Waste Reduction

 The first-in, first-out inventory (FIFO) system shall be utilized at materials
storage facilities. Such system shall optimize chemical utilization and
minimize waste generation.
 Containers shall be emptied as designed using appropriate techniques.
Other methods, such as puncturing or damaging the containers, which could
cause spillage, shall not be used.
 55 gallon drums shall be emptied using pumps equipped with a non-return
valve. Using such pumps shall reduce 1–5 liters of heel (residue), equating
to 0.5–2.5% of the drum’s contents.
 The opening of the container shall be sealed or closed after each use.
Containers previously used for Volatile Organic Compounds (VOCs) shall
be sealed immediately after use to avoid volatilization of materials.
 Where feasible, any un-pumpable heels remaining at the bottom of the
container shall be recovered. Heel can be recovered by safely inverting the
container in any orientation and draining the content into another container
for further use.
 Chemicals shall be purchased in appropriate volumes and container sizes.
Ordering excess material shall always be avoided.
 It is recommended to purchase chemicals from suppliers who are willing to
accept return of used containers for refilling.
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Document Responsibility: Environmental Standards Committee SAEP-65
Issue Date: 2 October 2017
Next Planned Update: 2 October 2020 Empty Container Management

 Whenever possible, substitution of hazardous materials with non-hazardous

materials shall always be investigated.

5.2 Container Handling

 Hazardous materials shall be handled as per the company Construction
Safety Manual (CSM).
 Containers should be handled as if full, even if marked “empty”.
 Containers should be labelled to indicate their contents.
 Labels should be preferably stenciled with paint onto containers or labels
shall be used that are resistant to deterioration due to weather, etc., until the
containers are finally disposed of.
 Safety Data Sheets (SDS) and/or Chemical Hazard Bulletins (CHBs) shall be
provided for the specifically named products within the containers,
generic/read-across chemicals shall not be used.
 Close all bungholes and lids before containers are transported to prevent
spillage of contents.
 Basic training and knowledge shall be provided to personnel handling
containers so they are aware of handling hazards.
 Operators of forklifts and cranes shall be certified for the equipment they
use, and carry current proof of certification at all times.

5.3 Storage Requirements

 The container storage area shall be aboveground with impervious surface to
contain leaks or spills. Storage areas shall be curbed and coated or lined
with liquid-tight, chemical-resistant coatings or liners.
 The storage area shall be sloped downward to a collection sump pit.
 Containers of volatile chemicals shall be stored in shaded areas to avoid
excessive pressure build-up in the drums.
 Containers containing incompatible chemicals (e.g., acids and bases or
flammables and oxidants) shall be segregated. The storage area shall be
designed so that spills or leaks from incompatible materials drain to separate
collection sumps or low points.
 Inspect storage areas regularly for any cracks or leaks and repair as soon as
possible.

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Document Responsibility: Environmental Standards Committee SAEP-65
Issue Date: 2 October 2017
Next Planned Update: 2 October 2020 Empty Container Management

5.4 Spill Control and Handling

 An appropriate spill kit containing absorbent materials shall be located in the
container storage area.
 A leak-sealing kit (for temporarily seal leaking drums) shall be available at
delivery and handling areas and at other high-risk locations. Consider
establishing a ‘quarantine area’ where leaking containers can be placed safely.
 Any spillage from hazardous materials shall be contained for proper disposal
at an EPD-approved waste management facility.
 A detailed spill control plan (SPCC Spill Prevention Containment and
Countermeasure) shall be kept available at storage facilities.

5.5 Transport Requirements

 Prepare a waste manifest form for the containers having acutely
hazardous/hazardous materials using SAP-EH&S.
 Attached the Chemical Hazard Bulletin (CHB) of each material with the
manifest form.
 Containers shall be strapped and palletized.
 Containers shall be inspected before transportation to ensure they are not
leaking.
 Containers shall be transported by all around secured vehicle.
 Drivers shall always be in close proximity of the truck to prevent theft and to
take any action if an emergency occurs.
 Transportation of containers shall not take place in private vehicles.
 Vehicles transporting containers shall be appropriately placarded.
 For road safety, the transport vehicle shall not be overloaded with containers
beyond its intended capacity.
 Containers transported to contractors for cleaning shall be manifested using
SAP EH&S system.

5.6 Heel Recovery

 The heel remaining in the container shall be safely removed before cleaning
the container. Removal of heel shall significantly minimize water and
chemicals consumption used for cleaning containers.

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Document Responsibility: Environmental Standards Committee SAEP-65
Issue Date: 2 October 2017
Next Planned Update: 2 October 2020 Empty Container Management

 The heel recovery shall be conducted in a safe manner that reduces human
exposure to hazardous chemicals and prevents soil and groundwater
contamination.
 A qualified Hazardous Materials Advisor shall be consulted before
recovering hazardous materials from containers.
 Incompatible heel materials shall not be mixed in a single container.
 Highly reactive materials, and acutely hazardous materials shall not be
drained at Saudi Aramco facilities. These materials shall remain in their
containers for proper treatment and disposal at EPD approved waste
management facility or returned back to Procurement & Supply Chain
Management (P&SCM).
 The recovered heel shall either be used by the proponent, or treated and
disposed of at an EPD-approved waste management facility.

5.7 Cleaning Procedures

Containers Containing Hazardous Materials/Waste

1. Inspection: The containers shall be inspected to identify any remaining heel.
2. Pre-steaming: Containers shall be pre-steamed to enhance heel removal.
3. Caustic Washing: Empty containers shall be washed by spraying the
interior and exterior with hot caustic solution.
4. Rinsing: After caustic washing, containers shall be multiple-rinsed with
clean water.
5. Chaining: When the contents of a steel drum are difficult to remove using
only hot caustic, the facility may use a process called chaining in which
chains are inserted into the drum, along with caustic, and the drum is
tumbled to remove remaining materials. (Chaining is not applicable to
washing plastic drums). Drums may require a second chaining cycle.
Rusty drums are washed with a hydrochloric acid solution in the same
manner as caustic washing described above, followed by one or more
rinses.

Containers Containing Non-hazardous Materials/Waste

1. Inspection: The Containers shall be inspected to identify any remaining heel
2. Rinsing: Containers shall be single rinsed with clean water

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Document Responsibility: Environmental Standards Committee SAEP-65
Issue Date: 2 October 2017
Next Planned Update: 2 October 2020 Empty Container Management

5.8 Wastewater Treatment and Disposal

If containers cleaning activities are performed inside Saudi Aramco premises,

treatment and disposal of residual wastewater shall be in accordance with
SAES-A-104 and the Saudi Aramco Hazardous Waste Code. If there is no
adequate treatment facility, effluent wastewater shall be treated and disposed of
by an EPD approved drum cleaning contractor.

5.9 Personal Protective Equipment (PPE)

 Body: Coveralls or chemical resistant aprons shall be worn while transferring
chemicals and while cleaning Containers.
 Head Protection: A hardhat or helmet shall be worn while operating heavy
equipment (e.g., forklifts or cranes) or when working under anything that
could fall.
 Eye and Face Protection: Chemical goggles shall be worn while transferring
chemicals and while cleaning Containers.
 Hand Protection: The type of the gloves should be based on the job criteria
as follows:
o Leather gloves: For handling and moving Containers
o Chemical resistant gloves: For cleaning the Containers
o Cut resistant (Kevlar) gloves: While drums are being crushed
 Foot Protection: Chemical resistant boots shall be worn while transferring
chemicals and cleaning Containers.
 Hearing Protection: Ear protection such as earplugs shall be worn at work
sites where the noise level exceeds 85 dBA.
 Respiratory Protection: Respirators with the appropriate cartridges
shall be worn according to the SDS or CHB of the chemicals being handled.
A respirator program shall be in place that includes employee training,
respirator maintenance and cartridge change out schedule.
 The emergency eyewash and shower facilities shall comply with
SAES-B-069.

5.10 Training
 HAZCOM training shall be provided before any person handles, uses, or
disposes of hazardous materials.

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Document Responsibility: Environmental Standards Committee SAEP-65
Issue Date: 2 October 2017
Next Planned Update: 2 October 2020 Empty Container Management

 Hazard awareness and familiarization for all employees handling chemicals,

including minimum PPE requirements and how to wear PPE.
 Emergency Response Plan training shall be provided to hazardous materials
transporters.

6 Responsibilities

Title or
Action or Task
Organization

 Environmental Protection Department (EPD) shall be responsible for

the administration, coordination, and execution of the containers
cleaning contractor program. Duties include planning survey
schedules, setting up Survey Teams, conducting all meetings,
leading the on-site surveys, preparing the Final Reports, and tracking
follow-up actions and approving qualified contractors for container
cleaning services.
Environmental
Protection  EPD shall initially assess containers cleaning contractors and
Department approve them.
(EPD)
 EPD shall monitor the performance of the approved empty containers
cleaning contractors on an annual basis and suspend them if they
violate Saudi Aramco procedures or they fail to maintain valid
General Authority for Meteorology and Environmental Protection
(GAMEP) or Royal Commission (RC) permits.

 EPD shall submit the inspection report to the contracting department

if the contractor was found violating EPD requirements.

 Proponents shall exert all possible efforts to completely empty

Containers and IBCs at their facilities.

 Small quantity generators (less than 2000 drums or IBCs per year)
shall transport their empty containers to DPC-280 for cleaning.
Figure 1 describes the empty container process flow for small
Proponent quantity generators.

 Large quantity generators (more than 2000 drums and IBCs per year)
shall secure a contract with EPD approved container cleaning
contractor. The contractor shall coordinate with the proponent and
P&SCM before transporting clean containers to DPC-280. Figure 2
describes the empty container process flow for large quantity
generators.

Contracting  The Contracting Department is responsible for the procurement of

Department contracts and for administrative procedures as specified in the Saudi
Aramco Contracting Manual.

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Document Responsibility: Environmental Standards Committee SAEP-65
Issue Date: 2 October 2017
Next Planned Update: 2 October 2020 Empty Container Management

Title or
Action or Task
Organization
 Materials Logistics Department shall receive 55 gallon Empty
Containers and IBCs from small quantity generators at DPC-280
reclamation yard.
Materials  Materials Logistics Department shall transport Containers that require
Logistics cleaning to EPD approved Containers cleaning contractors.
Department
 P&SCM shall ensure that empty container cleaning contractors
return clean drums to DPC-280. Each Proponent and P&SCM are
responsible to verify the number of empty drums sent to container
cleaning contractors with the number received at DPC-280.
Loss Prevention  Advise on field safety precautions on request.
Department

 Shall be approved by the General Authority for Meteorology and

Used Environmental Protection (GAMEP) as hazardous waste transporter
Containers
Transporter  Shall submit to EPD a detailed Emergency Response Plan (ERP) for
review and approval.

 Shall be approved by GAMEP for hazardous waste management.

 Shall submit to EPD the empty containers cleaning process.
 The contractor shall clean Containers as described in 5.7 and return
them to Saudi Aramco.

 The contractor shall treat the effluent wastewater generated from

cleaning activities to levels that meet GAMEP or RC effluent
discharge regulations.

 No hazardous wastewater shall be discharged to evaporation ponds

prior to treatment.
Used
Containers  If the Containers are damaged and can no longer be reused, the
Cleaning contractor shall shred the Containers after notifying Materials Logistic
Contractors Department. If the Containers contained Hazardous waste,
Contractor shall shred and dispose them at hazardous waste landfill.

 If it is agreed upon in the contract, the facility undergoing an

inspection should furnish a technical liaison that is qualified to work
with the EPD inspection team. The contractor shall provide access
and logistical support to the team and allow them to inspect their
facilities, interview their employees, and review their documents as
requested by the inspection Team Leader.

 The Contractor shall address and resolve all of the survey team's
findings and provide status reports, as requested.

 The contractor shall maintain a current and valid PME license.

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Document Responsibility: Environmental Standards Committee SAEP-65
Issue Date: 2 October 2017
Next Planned Update: 2 October 2020 Empty Container Management

Figure 1 – Small Quantity Generators

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Document Responsibility: Environmental Standards Committee SAEP-65
Issue Date: 2 October 2017
Next Planned Update: 2 October 2020 Empty Container Management

Figure 2 – Large Quantity Generators

Revision Summary
2 October 2017 New Saudi Aramco Engineering Procedure developed by a multi-departmental taskforce led by
EPD to assess and streamline empty drum management practices.

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