Environmental Health & Safety
Hazardous Waste Management Manual
October 1999
TABLE OF CONTENTS Section Page
I.
Introduction.........................................................................................................................
1
A.
Purpose..........................................................................................................................
1
B. Applicability ................................................................................................................. 1
II. Waste
Characterization
........................................................................................................ 4
A. General
........................................................................................................................... 4
B. Hazardous Waste Determination
Procedures
................................................................ 4
1. Solid Waste
.............................................................................................................. 5
2. Hazardous and
Miscellaneous Regulated Wastes
.................................................... 6
3. Empty Containers
................................................................................................... 7
C. Hazardous Waste
Minimization Requirements
............................................................. 8
III. Hazardous Waste Storage Procedures
............................................................................... 21
A. General Procedures
...................................................................................................... 21
B. Waste Storage
Containers
............................................................................................ 24
C. Labeling and
Marking
.................................................................................................. 24
D. Accumulation Time Limits
.......................................................................................... 25
E. Inspections
.................................................................................................................. 25
F. Record keeping and
Reporting
..................................................................................... 26
G. Training
........................................................................................................................ 26
IV. Hazardous Waste Pick-up Procedures
.............................................................................. 34
A. General Procedures
...................................................................................................... 34
B. Categorizing Hazardous Waste
.................................................................................... 34
C. Preparing Hazardous Waste Removal
Request ........................................................... 35
D. Satellite Accumulation Area
........................................................................................ 35
V. Hazardous Waste Shipping
Procedures
........................................................................ 39
A. General Procedures
...................................................................................................... 39
B. Labeling and Marking .................................................................................................. 39
C. Manifesting
.................................................................................................................. 39
D. Land Disposal
Restriction Certification
...................................................................... 40
E. Placarding
..................................................................................................................... 41
F. Record keeping and
Reporting
..................................................................................... 42
VI. Non-Routine
Activity Procedures
..................................................................................... 43
A. New Waste Streams
..................................................................................................... 43
B. Unlabeled
Containers
................................................................................................... 43
VII. Training Requirements
....................................................................................................... 46
A. Who Must be
Trained and How Often
....................................................................... 46
B. Scope of Mandatory
Training Requirements
.............................................................. 47
C. Training Required
by Other Laws
............................................................................... 47
D. Documentation and
Training Records
......................................................................... 48
Appendix A Hazardous Waste lists Appendix B Hazardous Waste
Incident Standard Operating Procedures (evacuation plans not included but can
be obtained from EH&S @ 656-2583 or 656-1770) Appendix C Hazardous Waste
Management Regulations (separate documents available from EH&S @ 656-2583
or 656-1770) Appendix D Hazardous Waste Storage Miscellaneous Information
LIST OF FIGURES
Figure II-1 Logic Diagram for Identifying Solid Wastes Figure II-2
Exclusions from the Definition of Solid Waste and Hazardous Waste Figure II-3
Logic Diagram for Determining When a Recycled Material is a Solid Waste Figure
II-4 Logic Diagram for Identifying Hazardous Waste Figure II-5 Logic Diagram
for Identifying if a Solid Waste is a Listed Hazardous Waste Figure II-6 Logic
Diagram for Identifying if a Solid Waste Exhibits the Characteristic of
Ignitability Figure II-7 Logic Diagram for Identifying if a Solid Waste
Exhibits the Characteristic of Corrosivity Table III-1 Environmental Protection
Agency Compatibility List
|
Figure II-8 |
Logic Diagram for Identifying
if a Solid Waste Exhibits the Characteristic of Reactivity |
|
Figure II-9 |
Logic Diagram for Identifying
if a Solid Waste Exhibits the Characteristic of Toxicity |
|
Figure II-10 |
Logic Diagram for Identifying
Miscellaneous Regulated Wastes |
|
Figure III-1 |
Map of Hazardous Waste
Accumulation Areas (to be inserted by departments as applicable) |
|
Figure III-2 |
Hazardous Waste Accumulation
Building Location |
|
Figure III-3 |
Hazardous Waste Label |
|
Figure III-4 |
Weekly Hazardous Waste
Inspection Form |
|
Figure IV-1 |
Hazardous Waste Removal
-Department Checklist |
|
Figure IV-2 |
Hazardous Waste Removal
Request |
|
Figure VI-1 |
Sample Out-for-Analysis Label
|
|
|
LIST OF TABLES |
Hazardous Waste Management Manual
I. INTRODUCTION
A. Purpose
This manual outlines the proper procedures for
managing hazardous waste at Clemson University, Clemson, South Carolina. This
document is intended to serve as a "how-to" manual for Clemson
employees, students and subcontractors involved with the handling of hazardous
waste. These procedures will be revised as necessary to reflect changes in
Clemson practices and environmental regulations.
A description of hazardous waste and hazardous waste
determination practices is provided in Section II. A discussion of hazardous
waste minimization is also provided.
Hazardous waste storage procedures are presented in
Section III. Section IV details the hazardous waste pick-up procedures. Section
V provides off-site shipping requirements for hazardous waste. Procedures for
addressing non-routine situations are detailed in Section VI. Section VII
outlines the required training for applicable personnel.
B.
Applicability
The
procedures contained in this hazardous waste management manual shall be
followed by all Clemson employees, students and subcontractor personnel
employed by Clemson. The Environmental Compliance Officer must approve any
deviation from the procedures defined in
this document in writing.
C. Regulatory Requirements
The Resource Conservation and Recovery Act of 1976
(RCRA) requires generators of hazardous waste to comply with the regulatory
requirements contained in Title 40 of the Code of Federal Regulations Part 262
(40 CFR Part 262). This Part requires generators to ensure and fully document
that the hazardous waste they produce is properly identified, managed on-site
for no more than 90 days and transported to a RCRA-permitted treatment, storage
or disposal (TSD) facility. These RCRA requirements are administered by the
South Carolina Department of Health and Environmental Control (SCDHEC) and
implemented under the South Carolina Hazardous Waste Management Regulations
(R.61-79.262).
All procedures defined in this manual are written for
compliance with the above regulations.
D.
Clemson University's Classification
The South Carolina Hazardous Waste Management
Regulations apply to the storage,
treatment, transportation and disposal of wastes that either are listed by the
Environmental
Protection Agency (EPA) or meet one or more of the characteristics of ignitability,
corrosivity,
reactivity or toxicity as defined in 40 CFR 261.
Under these regulations, Clemson University's main
campus is currently classified as a "Large
Quantity Generator" of hazardous waste. Within this limitation, Clemson
University personnel
are prohibited from:
� Treating a hazardous waste,
� Storing a hazardous waste at an accumulation point for
greater than ninety (90) days,
� Transporting hazardous waste away from the main
campus, and
� Negligent or otherwise unlawful waste disposal.
Clemson University provides its departments with a
single means for the lawful disposal of
hazardous waste. A state contract service is maintained without charge to the
generating
department. Those within Clemson University who have a potential for generating
hazardous
waste are responsible for four primary management activities:
� Hazardous
waste minimization
� Proper management of the waste material while it is
being generated
� Processing hazardous waste for removal.
� Obtaining the knowledge and putting that into practice
in the proper management of
CHEMICAL
EXCHANGE BETWEEN CLEMSON UNIVERSITY DEPARTMENTS IS ENCOURAGED UNDER THE
SUPERVISION OF THE ENVIRONMENTAL
COMPLIANCE
OFFICER.
SOME CHEMICALS ARE NOT REGULATED AS HAZARDOUS
SUBSTANCES BUT ARE, NONETHELESS, ENVIRONMENTALLY UNFRIENDLY AND IT IS CLEMSON
UNIVERSITY=S INTENT TO PROTECT THE ENVIRONMENT.
THE ENVIRONMENTAL COMPLIANCE OFFICER WILL MAKE ALL
FINAL DETERMINATIONS AS TO THE FINAL DISPOSITION OF ALL CHEMICAL AND BIOLOGICAL
SUBSTANCES THAT MAY BE HAZARDOUS.
II. WASTE CHARACTERIZATION
A. General
Any substance that no longer serves its intended
purpose and is destined for disposal should be evaluated by the generator to
determine if it meets the definition of a hazardous waste. Every possible
effort shall be made by the department to identify each waste stream. Unknowns
can be accepted by the Environmental Compliance Officer conditionally, but may
be returned to the generating department for chemical analysis if the hazardous
waste contractor cannot categorize the waste through on-site tests. DO NOT
GUESS AT THE IDENTITY OR "CREATE" A NAME FOR AN UNKNOWN! A wrongly identified waste, if released accidentally
to the environment, if exploding during disposal, or if causing the fouling of
an incinerator pollution control system, not only will harm life and property,
but could result in potential litigation. Likewise, the indiscriminate
discarding of unknown chemical substances can have equally serious
consequences.
NOTE:
All radioactive waste, including those radioactive wastes which meet the
definition
for a
hazardous waste, must be processed through Clemson University's program for
radioactive waste disposal.
The following sources shall be used to accurately
characterize a waste stream:
� Section II of this Manual,
� Material Safety Data Sheets (MSDS),
� Process Knowledge.
In the event that a waste chemical substance does not
meet the regulatory definition of a RCRA hazardous waste, yet the generator
recognizes unique hazardous characteristics which are not subject to other
regulatory requirements, the generator shall contact the Environmental Compliance
Officer (656-1770 or 656-2583) to determine if the waste substance should be
disposed as a hazardous waste. Many hazardous chemicals may not be RCRA
regulated but may be regulated by other laws and disposal restrictions.
B.
Hazardous Waste Determination Procedures
Waste
material, which may be a hazardous waste, is generated within three primary
activities at Clemson University. These activities include: � teaching� research
projects �
physical plant operations and
maintenance.
The
generators in these areas are responsible for properly characterizing the waste
generated
to determine if it is a hazardous waste. These activities generate three
general categories of
hazardous waste:
� off‑specification chemical stock,
� research effluent and residue,
� facility operations and maintenance waste (e.g., paint
related waste).
The
waste characterization process is defined in Figures II‑1 through II‑10.
These flow charts
guide the user through a systematic decision‑making
process for categorizing the wastes.
Note that a waste stream may belong to more than one category; therefore, follow
all of the
flow charts in order to properly characterize the waste. This process is discussed in more
detail in the following sections.
1. Solid
Waste
The first question to be answered when defining a
waste stream is: "Is this material a solid waste?" A solid waste is
any solid, semi‑solid, liquid or contained gaseous material that is
discarded or considered "inherently waste‑like"
(R.61‑79.261.2). Materials, which are solid wastes, are
identified in Figure II‑1.
Several types of materials are specifically excluded
from the definition of solid waste under R.61‑79.261.4.
These waste types are listed in Figure II‑2.
Some recycled materials are also exempt from the definition of a solid waste.
Some materials when recycled are solid wastes and others are not; these
materials are defined in Figure II‑3.
After reviewing Figures
II-1, II‑2 and II‑3
classify the waste stream as either a solid waste or not a solid waste. If it
is a solid waste, proceed to Section II.B.2. and determine if the waste is also
a hazardous waste or if other regulatory programs (such as the Toxic Substances
Control Act (TSCA) regulate it. If the material is not a solid waste, it may
still be a miscellaneous regulated waste; therefore, proceed to Section II.B.2.
2. Hazardous
and Miscellaneous Regulated Wastes
In order for a waste material to be a hazardous waste,
it must first meet the definition of a solid waste (Section II.B.1.). Figure
II-4 outlines the procedure for determining which solid wastes are also
hazardous wastes. There are two different ways a waste can be classified as a
hazardous waste. It can be a listed hazardous waste and/or it can be a
characteristic hazardous waste. Figure II‑5,
along with the tables in R.61‑79.261.31 through
261.33, define listed hazardous wastes. If a waste is included in any of these
lists, and in the case of U and P listed wastes it is un-used, it is a listed
hazardous waste. These lists are as follows:
� F‑listed waste from
operations that are not specific to a particular manufacturing operation (R.61‑79.261.31). Example: Spent halogenated solvents used
in degreasing.
� K‑listed waste from
specific manufacturing process (R.61‑79.261.32).
Example: Sludge from wood preserving.
� P‑listed acute
hazardous commercial chemical products (R.61‑79.261.33(e)).
� U‑listed toxic
commercial chemical products (R.61‑79.261.33(f)).
It is also necessary to determine if a waste is a
characteristic hazardous waste. The four hazardous waste characteristics are:
� ignitability,
� corrosivity,
� reactivity,
� toxicity
To determine if a solid waste exhibits the
characteristics of ignitability, follow Figure II‑6.
Use Figure II‑7 to determine if the waste exhibits the characteristics
of corrosivity, and Figures II‑8 and II‑9 to determine if the waste exhibits the
characteristics of reactivity and toxicity, respectively. If a waste exhibits
any of the above four characteristics, it is a characteristic hazardous waste.
A waste may be both a listed and a characteristic hazardous waste.
The generator of the waste must also determine if it
is regulated under TSCA or any other applicable federal or state laws or
regulations. A waste does not necessarily have to be defined as a solid waste
in order to belong in these categories. Use Figure II‑10 to determine if the waste belongs in these
additional waste categories.
3.
Empty Containers
Residues of hazardous waste remaining in a container
may not be subject to the requirements specified in this manual if the
container meets the regulatory definition of an empty container.
A container or an inner liner removed from a container
that has held a hazardous waste, except a compressed gas or acute hazardous
waste, is empty if:
� All wastes have been removed that can be removed using
common practices (e.g., pouring, pumping, aspirating), and
� No
material pours out of the container when held upside down or for Department of
Transportation
(DOT) recycling, no more than 2.5 cm (one inch) of residue remain on
the bottom of the container or inner liner, or
� No more than 3% by weight of the total capacity of the
container remains in the container or inner liner if the container is less than
or equal to 100 gallons, or
� No more than 0.3% by weight of the total capacity of
the container remains in the container or inner liner if the container is
greater than 100 gallons in size.
A container that has held a hazardous waste that is a
compressed gas is empty when the pressure in the container approaches
atmospheric pressure. However, it should be noted that releasing hazardous
waste from a compressed gas cylinder for the purpose of returning the cylinder
to atmospheric pressure is considered illegal discharge of a hazardous waste.
CAUTION! A container or an inner liner removed from a container
that has held a P-listed or acute
hazardous waste (as identified in
Appendix A) is not considered empty until:
� The
container or inner liner has been triple rinsed using a solvent capable of
removing the waste,
� The
container or inner liner has been cleaned by another method that has been shown
in the scientific literature, or by tests conducted by the generator, to
achieve equivalent removal, or
� In
the case of a container, the inner liner that prevented contact of the acute
hazardous waste with the container has been removed.
The rinsate generated when
cleaning hazardous material from an acute hazardous waste containers, should be
managed in accordance with the requirements specified in this manual unless it
can be determined, using the procedures outlined in this section, that the
material is not a hazardous waste. NORMALLY, ALL RINSATE FROM ACUTE HAZARDOUS
WASTE CONTAINERS IS AN ACUTE HAZARDOUS WASTE AND SHOULD BE COLLECTED AND MANAGED
ACCORDINGLY.
� For
disposal of empty containers into landfill at Clemson University see Appendix D
for guidance on defacing. Recycling should be investigated.
C. Hazardous Waste
Minimization Requirements
EPA defines waste
minimization as the reduction, to the most feasible extent, of hazardous waste
that is subsequently treated, stored and disposed of. Waste minimization
includes any source reduction or recycling activity undertaken by a generator
that results in either the reduction of the total volume or quantity of
hazardous waste, or the reduction of toxicity of hazardous waste, or both, so
long as the reduction is consistent with the goal of minimizing the present and
future threat to human health and the environment.
The main ideas behind waste
minimization are toxicity, volume reduction and material substitution. Toxicity
reduction means reducing the degree of hazard associated with the raw material
that, consequently, reduces the degree of hazard of the waste. Material
substitution means the use of lesser or even nontoxic materials.
The South Carolina Hazardous Waste Management Regulations and the ever rising costs for disposal, dictate that all possible efforts be taken to eliminate or reduce the generation of hazardous waste. Clemson University departments are responsible for assessing each source of hazardous waste within their operations and for establishing control measures to ensure that the least possible amount of wa