DRAFT 10/1/2018
PresbyterianCollege
HAZARDOUS WASTE MANAGEMENT PLAN
Document ID No. E-2
Issued: 1/30/2009
Please direct any questions or comments about the applicability of this document to Alan Urwick, Environment Health & Safety Coordinator.
Developed for PresbyterianCollege (all campuses) by:
Turning Bird Consulting, Ltd.
1205 Two Island Court, Suite 204
Mount Pleasant, SC 29466
ph.: 843-216-6833
12/07/01Page 1
Hazardous Waste Management Plan [Document ID No. E-2]Page 1
1/30/2009
TABLE OF CONTENTS
Abbreviations and Acronyms
1.0Purpose
2.1Main Campus
2.2The Branch Campuses
3.0Authority
4.0General Procedures
4.1Main Campus
4.2The Branch Campuses
5.0Laboratory, Classroom or Chemical Use Area Requirements
5.1Waste Determinations
5.2Unknown, Discarded and Unneeded Chemicals
5.3Containers, Compatibility and Storage
5.4Marking and/or Labeling Requirements
5.5Satellite Accumulation Areas
5.6Accumulation Limits
5.7Legal Disposal to the Sewer System
5.8Illegal Treatment or Disposal
5.9Training for Faculty and Staff
5.10Laboratory renovations, modifications and academic restructuring
6.0Central Storage Area (CSA) and Campus-wide Requirements
6.1Central Storage Facility/Area Requirements
6.2Disposal and Manifesting
7.0Hazardous Materials Registration Fees
8.0Emergency Response Equipment and Procedures
9.0Recordkeeping, Reporting, and Required Programs
9.1Recordkeeping
9.2Reporting
9.3Required Plans and Programs
Appendixes
Appendix A:Hazardous Waste Management for a CESQG Facility
Appendix B:Hazardous Waste Determination Form
Appendix C:RCRA P- and U-Listed Wastes
Appendix D:Peroxide Forming Compounds
Appendix E:Hazardous Waste Container Labels
Appendix F:Location of Satellite Accumulation Areas and Emergency Equipment
Appendix G:Hazardous Waste Container Storage Area Inspection Checklist
Appendix H:Hazardous Materials Registration Form
Appendix I:Standard Operating Procedures for Mercury Spills
Appendix J:Biennial Hazardous Waste Report
Turning Bird Consulting, Ltd.PC_LQG Master HWMgt Plan SC_TBC_011609
Hazardous Waste Management Plan [Document ID No. E-2]Page 1
1/30/2009
Abbreviations and Acronyms
BMP – Best Management Practices
CESQG – Conditionally Exempt Small Quantity Generator of hazardous haste is the least regulated generator class.
CFR – Code of Federal Regulations. Title 40 of the Code of Federal Regulations (40 CFR) contains all of the environmental protection regulations.
CHO – Chemical Hygiene Officer
CSA – Central Storage Area
DOT – Department of Transportation
EC – Emergency Coordinator
EPA – Environmental Protection Agency
EPA ID No. – EPA Identification Number
ERC – Emergency Response Coordinator
HAZWOPER – Hazardous Waste Operations and Emergency Response
HCW –Hazardous Chemical Waste
HW – Hazardous Waste
ID – Identification, as in EPA ID Number
Kg – Kilogram; one-kilogram equals 2.2 pounds
Lbs – Pounds
LDR –Land Disposal Restriction
LQG – Large Quantity Generator of Hazardous Waste is a fully regulated generator of hazardous waste.
SC DHEC – South Carolina Department of Environmental Protection
pH – Negative logarithm of the Hydrogen Ion concentration; A scale from 0 to 14 where 7 is neutral and lower numbers are successively more acidic (sweet), and higher numbers are more basic (sour).
ppb –Parts per billion, one-tenth of one percent is equivalent to one million parts per billion (0.1% equals 1,000,000 ppb).
RCRA – Resource Conservation and Recovery Act
SAA – Satellite Accumulation Area
SQG – Small Quantity Generator of hazardous waste is regulated to a much greater degree than the CESQG, but not regulated to the degree that a LQG.
TSDF – Treatment, Storage, or Disposal Facility
US EPA – United States Environmental Protection Agency
Turning Bird Consulting, Ltd.PC_LQG Master HWMgt Plan SC_TBC_011609
Hazardous Waste Management Plan [DocumentId. No. E-2]Page 1 of 16
1/3/2009
HAZARDOUS WASTE MANAGEMENT PLAN
1.0Purpose
PresbyterianCollegeis committed to operating its laboratories and classrooms in the safest manner possible, with concern for the individual and the protection of the environment in accordance with all applicable Federal and State statutes. The Hazardous Waste Management Plan, as outlined in the following sections, has been prepared to comply with applicable regulations promulgated by the United States Environmental Protection Agency (EPA) and the South Carolina Department of Health and Environmental Control (SC DHEC); and local ordinances enacted by Clinton, Laurens County, South Carolina.
2.0Scopes and Application
This program establishes the requirements that PresbyterianCollege faculty and staff must meet in order to manage the appropriate disposal of hazardous waste and excess chemicals in laboratories, classrooms, shops and chemical use areas located on the PresbyterianCollege campuses. This program describes the labeling and notification requirements, manifesting requirements, the general management of Satellite Accumulation Areas (SAAs) and Hazardous Waste (HW) storage areas; guidelines for disposal to the sanitary sewer, air and solid waste; applicable emergency procedures, prevention and response requirements; training and record keeping requirements.
2.1Main Campus
The PresbyterianCollegemain campus is considered a Large Quantity Generator (LQG) under the South Carolina Hazardous Waste Management Requirements[1] for LQGs. As such, the institution as a whole is allowed to generate, on a monthly basis:
More than 2200 pounds (1,000 kg) of non-acutely hazardous waste (D, F, K, or U waste codes),
More than 2.2 pounds (1 kg) of acutely hazardous waste (P waste codes), and
More than 220 pounds (100 kg) of acutely hazardous waste spill clean-up materials.
All hazardous waste generated on the main campus is managed and disposed of using the assigned EPA ID number ofSCD123456789, and may be accumulated on-site for a maximum of 90 days.
2.2The Branch Campuses
PresbyterianCollege currently does not have anyBranch Campuses.
3.0Authority
Title R61.79 of the South Carolina Code, Parts 260 through 270
Title 40 of the Code of Federal Regulations, Parts 260 through 270
4.0General Procedures
4.1Main Campus
PresbyterianCollege, and each of the individual laboratories, classrooms and chemical use areas located within the campus community, shall make every effort to maintain compliance with Large Quantity Generators standards (or Conditionally Exempt Small Quantity Generator standards, as appropriate). Any laboratory or work area generating hazardous waste must notify the Chemical Hygiene Officer, or the Environmental Health and Safety Coordinator, designate a Satellite Accumulation Area (SAA), and conform to the requirements stipulated by the South Carolina Department of Health and Environmental Control (SC DHEC) for LQGs.
The Collegewill remove all stored HW containers from the main campus at least once during each 90-day period using a licensed contractor. All HW will be managed according to local, state, and federal law and every effort will be made to reduce the potential long-term financial and legal liability to the institution. Furthermore, as an institution,PresbyterianCollegewill make every effort to reduce the quantity and/or toxicity of the hazardous waste it generates through chemical reuse, material substitution, modified process practices, or other pollution prevention activities where possible.
4.2The Branch Campuses
PresbyterianCollege currently does not have anyBranch Campuses..
5.0Laboratory, Classroom or Chemical Use Area Requirements
5.1Waste Determinations
Under the Resource Conservation and Recovery Act (RCRA, pronounced rick-rah), all hazardous materials destined for disposal must be considered hazardous wastes unless determined otherwise. Persons properly trained in the regulatory definitions of hazardous wastes must make all waste determinations. When knowledge of the hazard characteristics is indeterminate or unknown, waste analysis is required. Once a waste determination is made, the waste is managed as hazardous waste or discarded as a non-hazardous waste, as appropriate. All waste determinations must be maintained in writing for a minimum of three (3) years. Appendix B consists of a form useful for documentary purposes.
In order to conduct a waste determination all potentially hazardous constituents and reaction products must be considered. When in doubt, disposing of a regulatory agency-defined non-hazardous material as a hazardous waste is preferable to possibly releasing a potentially toxic pollutant into the environment. To manage hazardous wastes properly, the individuals responsible for laboratories, shops, and all other chemical use areas must identify and inventory their waste streams, and submit this information to theEnvironmental Health and Safety Coordinator. The EHS Coordinator will characterize the wastes, return the determination to the individual generator, and track the College’s hazardous waste generator status. This procedure is conducted by addressing the following steps:
Identify and Inventory Waste– Identify all waste streams generated within the lab or facility using knowledge of the process to determinethe waste that is generated. Examples include science lab experiment–week one (etc.), scheduled warehouse clean out, art project–one (etc.), or building renovation. These processes may yield, respectively, excess hazardous reagents, out-dated chemicals, spent paint solvents, or asbestos-containing materials. Once waste streams are identified, determine the volume or quantity of wastes generated each month.
Characterize the waste – Determine if the chemical waste is a RCRA-listed waste, or if it meets one of the characteristics of a hazardous waste and is not exempted or excluded under the rules. (See Appendix C.)
Hazardous waste includes chemicals and solutions with the following components or characteristics:
- All heavy metals and their salts (toxic);
- All sulfides, bisulfides and cyanides (reactive);
- All other toxic, reactive or oxidizing inorganics (toxic, reactive, or corrosive);
- All organic compounds except ethanol below 24% (toxic, ignitable, or corrosive);
- All gases not normally constituents of the earth’s atmosphere, and all flammable or oxidizing gases (toxic, ignitable, reactive, or corrosive)
Determine if a mixed chemical waste is hazardous or non-hazardous- If a RCRA-listed hazardous waste is mixed with a non-hazardous waste the resulting mixture will remain regulated as the listed waste regardless of quantity present in the mixture. (See Figure 1 below.)
If a characteristic hazardous waste is mixed with a non-hazardous waste, the resulting mixture will be regulated as hazardous only if the resulting mixture still exhibits the characteristic.
Determine and track generator status – Maintain a log of the process hazardous wastes. Information that should be included on this log include the following:
- For each waste: A description of the waste (e.g., waste solvents from labs); type of waste (hazardous waste or acutely hazardous waste), method of characterization (e.g., lab exercise date, generator knowledge); amount generated in the month; and amount accumulated in the month.
- Totals: Amount of all hazardous waste generated in the month; amount of all acutely hazardous wastes generated in the month; and the amount of all hazardous waste accumulated in the month.
5.2Unknown, Discarded and Unneeded Chemicals
Unidentified substances present a major problem for both storage and disposal. These chemicals can be removed by a Hazardous Waste transporter, but their disposal is much more expensive than disposing of known hazardous materials. Therefore, proper labeling and identification is important. “Unidentified or Unlabeled Chemicals” are those bottles without a label, containers labeled with only codes, generic process labels that do not specifically list the chemicals contained, and obviously mislabeled chemicals. Each of these chemicals must be “fingerprinted” for specific hazard classes before it may be removed from the premises by a licensed hazardous waste transporter.
Compounds that form peroxides, such as ethers (ethyl ether, and dioxane, but not “pet ether” or dioxins etc.), absorb and react with oxygen to form potentially explosive compounds with time. (See Appendix D.) Exposure to air and light accelerates these formations. Therefore, if your unlabeled liquid is partially or fully evaporated, and if crystals are present (or the liquid has become unclear), label the container as “Possible Peroxide” and handle as little as possible. These chemicals shall be brought to the attention of the hazardous waste transporter before any pickup is made.
Chemicals such as Picric Acid can become unstable if allowed to dehydrate. Due to the potential for friction or shock-sensitive explosion with these chemicals, do not move or attempt to open these bottles if the container appears old, crystalline or damaged in any way. Alkali metals are air reactive, and must be kept stored under kerosene. If the kerosene has evaporated exposing the metal sticks, dangerous concentrations of hydrogen, an explosively flammable gas, or a metal peroxide crust, a shock sensitive solid may have built up. These chemicals shall be brought to the attention of the hazardous waste transporter before any pickup is made.
Discarded and unneeded chemicals often represent unnecessary waste due to chemical mismanagement. Removal of unwanted chemicals and frequent evaluation of stored chemical containers are necessary to maintain chemical storage areas in a safe operating condition. To properly manage reagent chemicals on the PC campus, the laboratory instructor or manager shall:
Conduct a thorough laboratory cleanup and properly dispose of all unknowns, unwanted and unneeded chemicals.
Follow storage and labeling practices described in the PresbyterianCollegeChemical Hygiene Plan [Document ID No. S-2], to ensure that unknowns are not generated in the future.
Keep chemical stores to a minimum and review the annual inventory for unneeded chemicals that can be given to colleagues or placed into a re-use program before they have become useless or expired.
Borrow and share small amounts of rarely used chemicals with neighboring laboratories and when purchase is necessary, order the minimum practicable quantity.
5.3Containers, Compatibility and Storage
Waste chemicals must be stored in containers that are chemically compatible with the contents. Incompatible wastes must not be mixed together, nor can they be placed in an unrinsed container that contained an incompatible material. Acids cannot be mixed with bases, or flammables with oxidizing chemicals. Similarly, corrosives cannot be placed in metal containers, and Hydrofluoric Acid cannot be placed in glass containers.
Waste containers must be kept tightly closed when waste is not being added to and must be stored in such a way that they will not rupture or leak, e.g., temperature controlled environment, segregation from corrosive fumes, etc. All containers must be labeled appropriately and visibly according to the guidelines in Section 5.4.
All wastes must be stored indoors on a firm-working surface, and have secondary containment to prevent the release of hazardous waste to the environment. Containers shall be stored in a manner such that, in the event of a release, the contents will not enter the sanitary sewer or stormwater drains. All wastes must be placed in Department of Transportation (DOT) approved shipping containers before shipment off site.
5.4Marking and/or Labeling Requirements
5.4.1Containers
Each hazardous waste container must be properly marked or labeled. The marking or label must include the following information:
The words “Hazardous Waste,”
List of chemicals contained within the container and approximate percentages,
Hazards of the waste (e.g.: “flammable,” “combustible,” “corrosive,” “reactive,” “oxidizer,” “organic peroxide,” and “carcinogen”),
The date accumulation of hazardous waste was started in THAT container (the “Start Date”).
Preprinted labels are available from commercial vendors, although a laboratory-generated label is acceptable. (See Appendix E.) Fill in all applicable information, being sure to include all hazardous chemical constituents and the approximate concentration of each. The “Full Date” is added after the container is full.
5.4.2Satellite Accumulation Areas
In each area that initially generates hazardous waste; an SAA shall be demarcated and labeled as an SAA point of generation. This area is to contain accumulating hazardous wastes and hazardous materials that have been identified for disposal only. (Appendix F is an inventory of EHS equipment available in each laboratory at PresbyterianCollege, including the presence of one or more SAAs.)
5.5Satellite Accumulation Areas
Each SAA must be located at or near the point of generation and under the control of the laboratory manager or person directly responsible for the process generating the waste. SAAs may not contain accumulated hazardous wastes that are combined from several laboratory areas. Hazardous wastes may not be transported from one laboratory to another, in a common hallway, in an elevator or in a stairwell; except by authorized College personnel trained in hazardous waste management procedures.
Only one container per waste stream (a maximum of 55 gallons for a hazardous waste or one quart for an acutely hazardous waste) is allowed in each SAA. When the container is full, the “Full Date” must be completed on the label and the container must be removed from the SAA to the 90-day “Central Storage Area” (CSA) within 72 hours. Notification is made by calling the EHS Coordinator, has the waste picked up, the “Transfer Date” (abbreviated “Xfer Date” on the label in Appendix E) written on the label, and appropriately stored in the CSA. Containers must be stored by compatibilities on an impervious surface or in secondary containment to prevent access of spilled waste to the sanitary sewer.
5.6Accumulation Limits
Maximum Amount of Waste Stored in Satellite Accumulation Area / Allowable Amount of Waste Generated on Campus in Calendar Month / Amount of Waste Stored in Central Hazardous Waste Storage Area- 55 gallons of non-acute hazardous waste.
- 1 quart of acutely hazardous waste.
- Remove from the SAA within 72 hours of filling the container.
- Must be removed from the SAA for disposal within one year.
- More than2200 pounds (1000 kg) of hazardous waste
- More than 2.2 pounds (1 kg) of any one acutely hazardous waste
- More than 220 pounds (100 kg) of acutely hazardous waste spill cleanup
- More than 22 pounds (10 kg) of acutely hazardous waste from inner liners or paper bags
- There is no limit to the amount of waste that can be stored. Waste must be shipped off-site within 90-days of the “full date,” which is the date when the waste was marked “full” at the SAA.
For all hazardous wastes, a waste container must be removed from the CSA within 90days of the accumulation start date, which is the date the container was marked as full.
All containers within the CSA must be inspected weekly. Containers used for accumulation of hazardous wastes in SAAs must be removed at least once a year to prevent problems caused by container deterioration, to prevent excess accumulation of hazardous wastes, and to meet SC DHEC requirements.