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 waste
is generated.
In anticipation of future hazardous waste minimization
audits by SCDHEC, each department should record any efforts undertaken for
hazardous waste reduction and submit the documentation to the Environmental
Compliance Officer on an annual basis. Waste reduction action is to be
implemented by an effective combination of the following methods:
� Non-hazardous
reagents shall be substituted for hazardous reagents where possible, to avoid
generating hazardous waste.
� Current
equipment that produces a hazardous waste stream and can be replaced by a new
technology that reduces or eliminates that waste stream shall be given high
priority in the selection and procurement of replacement equipment.
� No
greater quantity of a hazardous reagent shall be procured than will be
necessary to satisfy immediate planned usage. Unused chemical overstock
constitutes a large portion of hazardous waste generated at Clemson University.
� Any written agreement entered into by a department
with an industrial client, where hazardous reagents or samples are supplied for
specific research or experimental use on behalf of that client, shall include a
provision for return of the unused amounts to the client for appropriate
disposal.
� Any
agent of a department shall not accept donations of chemicals unless immediate
planned usage is confirmed for the entire amount.
� Chemical
reaction systems shall be preplanned and designed so that by‑products and effluent may be rendered non-hazardous in
the process, prior to reaching waste status.
� Upon
application of hazardous reagents such as paints, pesticides, etc., the entire
volume of material shall be applied or an additional area shall be identified
where any remaining excess can be properly applied at the same rate, so that
the entire amount can be depleted.
� Upon
termination of an employee or separation of a student, the exit process shall
include immediate collection of all chemical reagents and waste residues used
by or in the possession of that person. Prior to separation, the department is
responsible for documenting the identity of each chemical reagent collected.
The intent here is to ensure
that unused chemicals are returned to the department chemical stores and placed
on inventory for continued use, wherever possible. Also, this procedure can
help prevent the need for future analysis of "unknown" chemicals.
Until an effective chemical
stock management program is introduced throughout Clemson University, old
chemical stock will be a major portion of the waste stream. Some of this old
stock is hazardous waste. Other constituents of this old stock may not meet the
definition of hazardous waste. However, these wastes usually cannot be accepted
into local sanitary or solid waste landfills. In order that liabilities are
minimized, these chemical wastes are given to a hazardous waste disposer and
classified managed as non-RCRA regulated wastes. From a regulatory standpoint,
these unused chemicals are not hazardous wastes. From a cost standpoint, disposal
of these chemicals as wastes may cost as much as the disposal of hazardous
waste.
When a
department generates chemical wastes, old stock chemicals may not meet the
hazardous waste criteria and should be separated from those determined to be
hazardous waste. The hazardous wastes shall be fully managed as regulatory
requirements dictate. The other chemical wastes should be managed in a
practical way and recycled if possible. When pressed further by waste
minimization requirements, Clemson University may examine other options for
dealing with these other chemical wastes.
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
Wastes
Figure II-5 Logic Diagram for Determining if a
Solid Waste is a Listed Hazardous Waste
Figure II-6 Logic Diagram for Determining if a
Solid Waste Exhibits the Characteristics of Ignitability
Figure II-7 Logic Diagram for Determining if a
Solid Waste Exhibits the Characteristics of Corrosivity
Figure II-8 Logic Diagram or Determining if a Solid
Waste Exhibits the Characteristic of Reactivity
Figure II-9 Logic Diagram for Determining if a
Solid Waste Exhibits the Characteristic of Toxicity
Figure II-10 Logic Diagram for Identifying
Miscellaneous Regulated Wastes
III. HAZARDOUS WASTE STORAGE
PROCEDURES
A. General Procedures
Two types of hazardous
waste accumulation points are present at Clemson University's main campus:
� Accumulation Points
� Satellite Accumulation Points
A hazardous waste accumulation point is a location on-site at which hazardous
waste can
A
satellite accumulation point is a
location at or near the point of generation that is under the control of the
operator of the process generating the waste. No more than 55 gallons of
hazardous waste or one quart of acute hazardous waste can be accumulated at a
satellite accumulation point.
The
difference between a satellite accumulation point and an accumulation point are
the volume and the length of time
wastes may be accumulated. At a satellite accumulation point, up to 55 gallons
of hazardous waste or up to one quart of acute hazardous waste may be
accumulated for a reasonable amount of time. At an accumulation point, an
unlimited volume of waste may be accumulated in containers for up to 90 days.
If a facility has not been approved by the Environmental Compliance Officer to
maintain a hazardous waste accumulation point, then they are, by default,
satellite accumulation points and must stay in status with the volumes stated
above. The location of any Departmental Accumulation Points will be inserted as
necessary in Figure III-1. The location of the Central Hazardous Waste
Accumulation Building is depicted in Figure III‑2.
No hazardous waste shall be stored at an Accumulation Point at Clemson
University's main campus for greater than 90 days from the accumulation date on
the container.
Hazardous
waste must be kept in designated areas at all times. Wastes that are
accumulated in these areas must be managed in accordance with the procedures
specified below. The generator is responsible for ensuring compliance with
these procedures for his/her hazardous waste satellite accumulation point(s).
The Environmental Compliance Officer is responsible for managing the Central
Hazardous Waste Accumulation Building(s) in compliance with these procedures.
All hazardous
waste Accumulation Points must meet the following requirements:
� A
Hazardous Waste sign must be posted at each area. � The name and phone number of the accumulation point
supervisor and an alternate contact must be posted at each area. � The area should be used for hazardous waste
accumulation only. No raw materials or chemical stock should be stored in the
same area with hazardous waste. � Flammable
materials cabinet shall be used when possible for storage of ignitable
hazardous wastes. �
The area must be located at or near the
point of waste generation and must be under the control of the person
responsible for the waste‑generating process. � All containers will be appropriately labeled and segregated for
compatibility.
Access to the hazardous waste
accumulation points and building must never be blocked. The area shall be
quickly and easily accessible by emergency response personnel in the event of a
spill, leak or fire. Appropriate emergency response equipment shall be maintained
for each hazardous waste accumulation and satellite area. The accumulation
point supervisor is
Accumulation Building(s). Emergency equipment shall include the following:
� Fire
extinguisher, 20lb ABC type.
� Absorbent of the proper type and of sufficient amount
to absorb the volume present.
� Broom, bucket and mop.
� Telephone or other communication device.
� First aid kit.
� Safety shower and eye wash station as applicable.
� Coveralls, eye protection and gloves compatible with
wastes.
� Empty containers and bags compatible with cleanup
characteristics.
The accumulation
point shall be managed as follows:
� The person responsible for the area must meet the
Occupational Safety and Health Administration (OSHA) requirements for hazardous
waste training contained in 29 CFR 1910.120 and Department of Transportation
(DOT) HM-181/ HM-126F.
�
Waste shall be stored in approved
containers.
� Containers shall be kept closed except during waste
transfers.
� Inspections shall be conducted weekly (see Section
III.E).
� Incompatible materials shall not be combined into one
container. Containers of incompatible
� Containers shall be labeled with an approved hazardous
waste label before any waste is received (see Section III.B).
Satellite
accumulation points are subject to
the following requirements defined below:
� No more than 55 gallons total of hazardous waste or
one quart total of acute hazardous waste may be accumulated. See Appendix A for
a list of acute hazardous wastes.
� Containers with the excess must be dated as soon as 55
gallons of hazardous waste or one-quart total of acute hazardous waste or more
are accumulated. All subsequent containers will be dated upon initiation of the
first addition of waste until the site's status is returned to a Satellite
Accumulation point by the reduction of wastes at the site to meet the less than
55 gallons of hazardous or less than one quart of acutely toxic waste limit.
This should be accomplished within 3 days. In order to minimize the
establishment of new Accumulation Points, containers must be moved to an
established or central accumulation point within three days of the date the
storage volume limits are exceeded, unless permission to establish a new
Accumulation Point is obtained from the Environmental Compliance Officer.
In
order to minimize the risk of hazardous waste incidents and in order to comply
with published regulations, each site of hazardous waste generation will be
considered a satellite accumulation point unless designated otherwise by the
Environmental Compliance Officer. This will be particularly useful considering
the large number of laboratories generating hazardous waste on campus.
In spite of the flexibility allowed
in the regulations concerning volume limits at satellite accumulation points,
it will be Clemson University's procedure to pick up hazardous waste on demand.
This will also minimize the risk of potential hazardous waste incidents by not
allowing undue accumulation of waste.
B.
Waste Storage Containers
Hazardous waste shall be placed only in approved
hazardous waste containers. An approved hazardous waste container is made of or
lined with a material compatible with the waste. Empty containers, which
originally held the primary waste constituent or similar material, are
acceptable hazardous waste containers. The original container label must be
removed or defaced. An approved hazardous waste label with the appropriate
information shall be affixed to the container before any hazardous waste is received. (Container labeling
requirements are summarized in Section III.C)
The container must be in good condition without holes,
rust or dents. The container shall always be closed during storage, except when
waste is being added or removed. A hazardous waste container shall not be
opened, handled or stored in a manner that may rupture the container or cause
it to leak. Consideration should be given to doubly contain certain
particularly dangerous chemicals if storage conditions and limitations are not
ideal.
If drums are stacked in the Hazardous Waste
Accumulation Building, pallets shall be used to separate the containers, and
stacking and spacing shall meet applicable fire protection requirements. Aisle
spacing for container storage in the Hazardous Waste Accumulation Building
shall be such that each row of containers can be easily inspected for leakage
or damage.
C.
Labeling and Marking
An approved hazardous waste label (Figure III-3) shall
be affixed to each hazardous waste container prior to receiving any waste
material. The Environmental Compliance Officer is responsible for ensuring each
container is properly labeled before being picked up from a Satellite
Accumulation Point or an Accumulation Point and moved to the Central
Accumulation Point. However, the Generator or Accumulation Point Supervisor
responsible for the waste is responsible for ensuring each container in his/her
area is properly labeled before placing waste into the container or receiving
any waste into an Accumulation Point.
The following information shall be provided on each
hazardous waste label:
� HAZARDOUS
WASTE ‑Federal law prohibit improper disposal. If found,
contact the
waste acetone), including percentages of constituents
if more than one.
� Each container shall be appropriately labeled with EPA
Hazardous Waste Number
The labels shall be placed on the side of each
container in such a manner that they are clearly visible for inspection.
Up to 55
gallons total of hazardous waste or one quart total of acutely hazardous waste
may be collected in each satellite area. The accumulation point supervisor is
responsible for notifying the Environmental Compliance Officer as soon as 55
gallons of hazardous waste or one quart of acutely hazardous waste have been
collected (see Section IV). Each container that is stored in the Central
Hazardous Waste Accumulation Building or other at any other Accumulation Points
shall have the accumulation start date on the label.
D. Accumulation Time Limits
Up to 55 gallons total of hazardous waste or one quart
total of acutely hazardous waste may be collected in each Satellite
Accumulation area. Once 55 gallons of hazardous waste or one quart of acutely
hazardous waste has accumulated, the Generator shall date the container(s)
containing the excess waste. The container(s) must be moved to a designated
university Accumulation Point or picked up for off‑site disposal within three (3) days of declaration to
the Environmental Compliance Officer. Within 90 days of the accumulation start
date, the container must be shipped off-site for disposal at an approved RCRA
disposal facility. Hazardous waste may not be stored on‑site at a designated Accumulation Point for greater
than 90 days from the date it is first accumulated.
E.
Inspections
The
applicable accumulation point supervisor shall conduct weekly inspections of
the hazardous waste accumulation points and a copy kept on file at the site.
The Environmental Compliance Officer or his/her qualified designee shall
inspect the Central Hazardous Waste Accumulation Building(s). During the
inspection, the inspector shall check each item listed on Figure III‑4. The results of the inspection shall be documented on
this form. A copy of the form shall be sent to the Director of Environmental
Health and Safety and one copy retained on site for inspection.
If any
corrective action is required, the Accumulation Point Supervisor must comply
immediately. Once the problem has been corrected, the Accumulation Point
Supervisor is to date and initial a copy of the form and mail it to the
Environmental Compliance Officer. The Environmental Compliance Officer shall
maintain these records for three years.
F.
Record keeping and reporting
During
the weekly inspections of the departmental accumulation points and the Central
Hazardous Waste Accumulation Building(s), the current inventory of waste shall
be recorded (see Section IV). The Environmental Compliance Officer, for the purpose
of coordinating shipments of hazardous waste, shall use this inventory.
Within
30 days after the end of each calendar quarter, a written report must be
submitted by the Environmental Compliance Officer to SCDHEC summarizing the
hazardous waste activities for that quarter. In addition to general facility
information, the report must include the following information:
� Hazardous waste transporters used during the quarter to transport the
waste to a
All quarterly reports must be maintained at the facility for at least
three years from the date
G. Training
Personnel who handle or are occupationally exposed to
hazardous waste are required to be trained initially in the proper methods for
the management of hazardous waste and the implementation of the facility's
contingency plan. The training program must be directed by a person trained in
hazardous waste management. Personnel who are assigned to a position related to
hazardous waste management must complete training within six months of their
assignment. These personnel must not work in unsupervised positions until they
have successfully completed training. Refer to Section VII for details
regarding who must be trained and the scope of the required training.
Table III-1. Environmental Protection Agency (EPA)
Compatibility Table.
EPA has
published a list of potentially incompatible wastes, waste components and
materials along with the harmful consequences of mixing those materials
together. This list does not include every possible hazardous chemical
reaction, but should be used as a guide in packaging and storing these
materials. The list indicates the potential consequences of the mixing of a
Group A material with a Group B material.
For
example, mixing any Group 2-A waste, which include reactive metals and metal
hydrides, with a Group 2-B waste, which include the Group 1-A alkaline and the
Group 1-B acidic wastes, may produce a fire or explosion and the generation of
flammable hydrogen gas. Mixing a Group 3-A waste, which includes alcohol�
These
compatibility listings and packaging guides should not be the only information
used when packaging or accumulating waste chemicals. RCRA regulations require
that wastes should be adequately analyzed by TSD facilities so uncontrolled
substances or reactions do not occur. Payclose attention to any waste
characterization data you receive on material reactivity and compatibility.
There are also other sources of data that may be helpful in determining waste
compatibility. MSDS�
Group
1-A
Acetylene sludge
Alkaline caustic liquids
Alkaline cleaner
Alkaline corrosive liquids
Alkaline corrosive battery fluids
Caustic wastewater
Lime sludge and other corrosive alkalies
Lime wastewater
Lime and water
Spent caustic
Group
1-B
Acid sludge
Acid and water
Battery acid
Chemical cleaners
Electrolyte, acid
Etching acid liquid or solvent
Pickling liquor and other corrosive acids
Spent acid Spent mixed acid
Spent sulphuric acid
Potential
consequences: Heat generation; violent reaction.
Table III-1. EPA Compatibility Table (continued)
Group
2-A
Aluminum
Beryllium
Calcium
Lithium
Magnesium
Potassium
Sodium
Zinc powder
Other reactive
metals and metal hydrides
Group
2-B
Any
waste in Group 1-A or 1-B
Potential
consequences: Fire or explosion; generation of flammable hydrogen gas.
Group
3-A
Alcohol�
Water
Group
3-B
Any concentrated waste in Groups 1-A or 1-B
Calcium
Lithium
Metal Hydrides
Potassium
SO2Cl2, SOCl2, PCl3, CH2SiCl2
Other water-reactive waste
Potential consequences: Fire,
explosion, or heat generation; generation of flammable or toxic gases.
Group
4-A
Alcohol�
Halogenated hydrocarbons
Nitrated hydrocarbons
Unsaturated hydrocarbons
Other reactive organic compounds and
solvents
Group
4-B
Concentrated Group 1-A or 1-B wastes Group 2-A wastes
Potential consequences: Fire,
explosion or violent reaction.
Table III-1. EPA Compatibility Table (continued)
Group
5-A
Spent
cyanide and sulfide solutions
Group
5-B
Group
1-B wastes
Potential
consequences: Generation of toxic hydrogen cyanide or hydrogen sulfide gas.
Group
6-A
Chlorates Chlorine Chlorites
Chromic acid HypochloritesNitrates Nitric acid, fumingPerchlorates
PermanganatesPeroxides Other strong oxidizers
Group
6-B
Acetic
acid and other organic acids Concentrated mineral acids Group 2-A wastes Group
4-A wastes Other flammable and combustible wastes
Potential
consequences: Fire, explosion, or violent reaction.
Source: 40 CFR 264, Appendix V.
Figure III-1 Map of Hazardous Waste Accumulation
Points (to be inserted by department)
Figure III-2
Figure III-3
Figure III-4
IV. HAZARDOUS WASTE PICK‑UP PROCEDURES
A. General Procedures
When requesting a hazardous waste pick‑up the generator shall:
� Verify
that a correct hazardous waste determination has been conducted.
� Complete a Hazardous Waste Removal ‑Department Checklist (Figure IV‑1).
� Complete a Hazardous Waste Removal Request form
(Figure IV‑2) and submit it to the
Environmental Compliance Officer with a copy of the completed
Department Checklist.
� Follow up with the Environmental Compliance Officer to
ensure that the hazardous waste is removed from a satellite area within three
days of the accumulation start date and that no waste is accumulated on site
for greater than 90 days from the date it is generated.
The generator must initiate a request for a hazardous
waste pick-up. Usually when the total accumulated volume of waste in the
satellite area approaches 55 gallons of hazardous waste or one quart of acutely
hazardous waste. All accumulated waste must be removed from the satellite area
within three days of reaching these volume limits. However, it will be Clemson
University's procedure to pick up waste immediately after generation and upon
demand.
NO HAZARDOUS WASTE SHALL BE DISCARDED IN GENERAL
REFUSE, THROUGH WASTEWATER DRAINS, BY BURNING, BURIAL, SALE, GIVEAWAY, OR ANY
ROUTE OTHER THAN THAT PROVIDED BY CONTRACT WASTE DISPOSAL SERVICE THROUGH THE ENVIRONMENTAL
COMPLIANCE OFFICER.
CHEMICAL
EXCHANGE BETWEEN UNIVERSITY DEPARTMENTS IS ENCOURAGED
UNDER THE SUPERVISION OF THE ENVIRONMENTAL COMPLIANCE OFFICER.
B. Categorizing Hazardous Waste
The generator shall assign
an EPA hazardous waste code to each waste stream upon generation. The following
hazard codes shall be used to indicate the class or type of waste:
Ignitable Waste Corrosive Waste Reactive Waste
Toxicity
Characteristic Waste Acute Hazardous Waste Toxic Waste
Non RCRA regulated
D001-see Figure II-6 (and check the
F-list) D002-see Figure II-7 D003-see Figure II-8 See Figure II-9 (D-List) See
appendix A the P-List (also check F-List) See appendix A the U-List NR (all
waste hazardous materials not falling under an above category but destined for
disposal or
C.
Preparing Hazardous Waste Removal Request
The generator to request a hazardous waste pick-up
shall follow the following procedures:
� Complete
a Hazardous Waste Removal Request form.
� Obtain signature of the Department Head.
� Submit completed form to the Environmental Compliance
Officer.
� Append one copy to the Department Checklist and attach
paperwork to the associated
D.
Satellite Accumulation Point
Hazardous waste shall be
accumulated safely by the department until removed by the Environmental
Compliance Officer or contract hazardous waste service representative. Removal
will take place as soon as possible after notification is given to the
Environmental Compliance Officer but no later than within three days of the
accumulation start date for excess wastes.
Ignitable wastes shall be stored in accordance with
fire safety requirements for storage of flammables. Contact the University Fire
Department for information (656‑2323).
Corrosive wastes shall be stored in accordance with
procedures for storage of corrosive materials, with secondary containment
employed to prevent contamination or reaction from leakage.
Poisonous wastes shall be
stored in exhaust‑ventilated areas and double contained to prevent
leakage.
Reactive wastes shall be
isolated and reported to the Environmental Compliance Officer for immediate
removal or special handling by the contract hazardous waste service
representative.
Specific storage procedures
referenced above may be found in "Prudent Practices for Handling Hazardous Chemicals
in Laboratories". A copy of this
book, cited in 29 CFR 1910.1450, OSHA's laboratory standard for occupational
exposure to hazardous chemicals in laboratories, is kept at the office of
Environmental Health & Safety.
Figure IV-1
HAZARDOUS WASTE REMOVAL -DEPARTMENT CHECKLIST
(1) _____
Each potential waste substance is identified and its container marked with the
container contents.
(2) _____
The generator of the waste has confirmed that no further possible use of the
substance exists within the department or in other Clemson University
departments.
(3) _____
The waste is a hazardous waste according to the South Carolina Hazardous Waste
Management Regulations or after consultation with the Environmental Compliance
Officer is declared hazardous.
(4) _____ The waste is not
radioactive and does not contain PCBs.
(5)
_____ The waste has been screened and categorized according to hazard type.
(6) _____
A label with the words �labeling
and marking�verbiage
required) has been affixed to each container, complete with the chemical
name(s) and waste code(s).
(7) _____
A Hazardous Waste Removal Request form (Figure IV-2) has been prepared for each
existing hazard category.
(8) _____
Each request has been copied. One copy for department records directed through
the Faculty member responsible and/or Department Head, and the remaining copy
has been affixed to the waste group while awaiting pick-up.
(9) _____
Each group of hazardous waste is being temporarily stored in accordance with
safety requirements for that specific hazard category.
Figure IV-2
V. HAZARDOUS WASTE
SHIPPING PROCEDURES A. General Procedures
Pre‑transport regulations are designed to provide safe
transportation of a hazardous waste from origin to ultimate disposal. The pre‑transport regulations used by the Department of
Transportation (DOT) for transporting hazardous waste (49 CFR 172, 173, 178, and
179) were adopted by the South Carolina Public Service Commission and are
referenced in R.6179.262. These pre‑transport
regulations apply only to hazardous waste shipped off site.
B. Labeling and Marking
An approved hazardous waste
label (Figure III‑3) shall be affixed to each hazardous waste container
prior to off‑site shipment. Labeling requirements and marking
regulations are found in R.61‑79.262 and 49 CFR
172.101, Hazard Material Table. These regulations specify the following:
� containers must be labeled in accordance with the DOT
Hazardous Materials Table
(available
from the Environmental Compliance Officer); and
� containers must be marked with the following
information:
‑Proper chemical name
‑Percent of constituents if applicable
-EPA waste codes
-University Tracking I.D. number
-Accumulation Date
The Environmental
Compliance Officer is responsible for ensuring this information is provided
prior to off‑site shipment.
C. Manifesting
When hazardous waste is
shipped off-site for treatment or disposal, it must be accompanied by a
properly completed and signed Hazardous Waste Manifest. This form has multiple
copies for distribution as described in this section. The facility to which the
waste will be shipped will provide a copy of the blank manifest to Clemson
University. Blank manifests may also be obtained from SCDHEC. Emergency
response information for each waste shipped must accompany all manifest.
The Hazardous Waste
Manifest must be completed by Clemson University before offering any hazardous
wastes for shipment. To facilitate record keeping, the manifests are numbered
in sequential order and no numbers are skipped.
The information listed in
Item 11 of the Hazardous Waste Manifest (US DOT Description) must comply with
DOT requirements (49 CFR 172.101) for proper shipping name, hazard class and
identification number.
The quantity is to be
specified by a whole number only (Item 13) and includes the entire container.
The units for this quantity (Item 14) must also conform to DOT standards.
The EPA waste code number
for each waste listed in Item 11 must be identified in Item I.
As a generator of hazardous waste, Clemson University
is responsible for initiating the manifest with each shipment of waste. The
generator completes the sections of the manifest outlined above and signs and
dates the appropriate section of the manifest. At the time the waste is picked
up, the transporter signs and dates the manifest in the appropriate section
indicating that he has accepted the waste and agrees to deliver it to the
designated treatment, storage or disposal facility.
The generator must keep one copy of the manifest,
which has been signed by the generator and transporter for each shipment of
waste made to a hazardous waste facility. The original copy of the manifest
must accompany the waste shipment along with two additional copies. Once the
disposal facility receives the waste, the facility representative signs the
manifest and returns it to the generator. Clemson University must retain the
returned copy of the manifest signed by the receiving treatment, storage or
disposal facility for three years from the date of shipment. Copies of
manifests for shipments of hazardous waste sent out of South Carolina must be
submitted to SCDHEC within 45 days of receiving the returned copy of the
manifest from the disposal facility.
D.
Land Disposal Restriction Certification
Listed and characteristic hazardous wastes have been
evaluated by EPA to determine their suitability for land disposal. The result of
this evaluation is a treatment standard for each waste. Any waste meeting the
treatment standards may be land disposed without restriction in a RCRA land
disposal unit. If the treatment standard for a waste is not met, the waste
cannot be land disposed without prior treatment.
Information defining the restricted wastes and their
treatment standards is available from the Manager of Environmental Programs.
Whether the waste is restricted under the Land Disposal Restrictions 40 CFR
Part 268 will be determined by testing the waste or using knowledge of the
waste. At the time the waste is shipped for off‑site
disposal, a Notification and Certification Form must be completed in full and
must accompany the shipment. This form will identify the appropriate land disposal
treatment standards and whether or not these standards have been met.
All laboratory analyses used to determine if a waste
is subject to the land disposal restrictions will be conducted in accordance
with approved EPA test methods and procedures. For wastes with treatment
standards expressed as constituent concentrations in the waste extract (40 CFR
268.41), waste residues or an extract of such residues will be tested using the
toxicity characteristic leaching procedure (TCLP). For wastes with treatment
standards expressed as constituent concentrations in the waste (40 CFR 268.43),
waste residues will be tested using a total constituent analyses (TCA).
E.
Placarding
Clemson University is responsible for providing the
transporter with the proper placards when required to comply with DOT shipping
and labeling requirements. If more than 1,000 pounds of flammable and/or
combustible material are offered for shipment at one time, the placards for
flammable and/or combustible material must be provided. The appropriate
placards will be maintained at the facility or will be purchased by Clemson
University prior to shipping quantities requiring placarding. Placards must be
located on all sides of the motor vehicle.
F. Record keeping and Reporting
One copy of each manifest prepared for a hazardous waste
shipment must be kept at the
facility until the original signed copy
is returned from the disposal facility which received the waste. The copy
signed by Clemson University, the transporter and the receiving facility must
be maintained at the facility for three years from the date of shipment. If a
hand‑signedcopy is not returned from the disposal facility
within 35 days of the shipping date, Clemson University must contact the
transporter or the disposal facility to determine the status of the hazardous
waste.
If the completed manifest has not been
returned from the disposal facility within 45 days of the date the waste was
shipped from Clemson University, the Environmental Compliance Officer will
submit an Exception Report to SCDHEC. The report must contain a copy of the
manifest retained by Clemson University and a letter of explanation stating
what efforts have been made to locate the completed manifest and the results of
those efforts.
All manifests and exception reports
must be maintained at the facility for at least three years from the date the
report was filed or the waste shipment was made.
VI. NON‑ROUTINE ACTIVITY PROCEDURES
A. New Waste Streams
A new waste stream may be
generated in three ways:
� change in an existing process,
� implementation of a new process, or
� change in the regulations.
The generator, with the assistance of
the Environmental Compliance Officer, is responsible for reviewing any new
waste streams to determine if they will be subject to the hazardous waste
management regulations. If the new waste stream is not excluded from
regulation, analysis of a waste stream sample may be required. Laboratory work
may include analysis for the hazardous waste characteristics outlines in
Section II.
Knowledge of the process shall be
applied to determine analytical needs. Analytical data will be reviewed to
determine potential concerns of ignitability or reactivity during storage. The
generator is responsible for appropriately characterizing all new waste streams
generated in his area.
Professors, students and employees
shall notify the Environmental Compliance Officer if new waste streams are to
be generated.
B. Unlabeled Containers
The potential exists for containers of
unknown material to be discovered. Without knowledge of the container contents,
appropriate disposal options cannot be determined.
If an unidentified
container is discovered, the following steps shall be taken:
� Mark the container with the words "Awaiting
Administrative Determination" and date the
container. � Initiate a hazardous waste pickup. �
Immediately notify the Environmental Compliance Officer to arrange for the
container to be relocated to the
Hazardous Waste Accumulation Building.
If laboratory analysis is required to appropriately
characterize the waste material, a completed "Sample Out for
Analysis" label shall be affixed to the side of the container (Figure VI‑1).If the material is determined to be a hazardous
waste, label and date the container immediately, and properly dispose of the
material within 90 days.
Figure VI-1 Sample Out-for-Analysis Label
VII. TRAINING REQUIREMENTS
A. Who Must be Trained and How
Often
The regulatory framework which identifies who must be
trained may be circuitous, but must be complied with nevertheless. 40 CFR
265.16 and 40 CFR 264.16 require training for personnel at interim status and
permitted hazardous waste management treatment, storage and disposal (TSD)
facilities. Hazardous waste generators are instructed in 40 CFR 262.34(a)(4) to
comply with the requirements of 40 CFR 265.16 which is included in Appendix C
of this manual. Therefore, hazardous waste management training is required for
personnel who work at facilities which fit into any of the following
categories:
� Permitted hazardous waste TSD facilities,
� Interim status hazardous waste TSD facilities,
� Large quantity generators.
Persons who must be trained include those who are
involved with or are occupationally
exposed to hazardous waste. This may include (but is not limited to) persons
who perform any
of the following tasks:
� decide
which wastes are hazardous waste,
� add hazardous waste into accumulation containers at accumulation
points,
� remove hazardous waste from accumulation containers,
� transport hazardous waste to or from accumulation
points,
� transport hazardous waste to or from storage units,
� respond to spills, fires or explosions involving
hazardous waste,
� complete hazardous waste manifests, annual reports or
exception reports,
� inspect hazardous waste accumulation points and
storage facilities,
� operate or work at accumulation points,
� work at permitted or interim status TSD facilities,
� conduct any tasks involving occupational exposure to
or which require management of
hazardous waste.
The required training must be successfully completed
by all of the personnel described above. For new personnel, training must be
successfully completed within six months after assignment to the facility or to
a new position at the facility, whichever is later. Until that time, untrained
personnel must not perform any tasks involving hazardous waste management
unless they are supervised by trained personnel. Facility personnel may be
required to take part in an annual review of the entire training program. The
Environmental Compliance Officer will direct training of all applicable
facility personnel in hazardous waste management procedures. Included in this
training will be instruction in job specific hazardous waste management as well
as contingency plan implementation.
B. Scope of Mandatory Training Requirements
There are two general
components to the training requirements in 40 CFR 265.16; personnel must be
trained:
1.
1. How
to perform their duties in a way that ensures the facility's compliance with
the regulations; and
2.
2. How
to respond to emergencies involving hazardous waste.
EPA regulations published
in 40 CFR 265.16 regarding personnel training are presented in Appendix C of
this manual (separate document, copies available from EH&S).
C. Training Required by
Other Laws
Besides the required RCRA
training, other laws and regulations require training for many of the same
personnel who must receive RCRA training. For example, persons working at
permitted TSD facilities as well as hazardous substance emergency response
personnel are required to be trained in accordance with OSHA regulations
published in 29 CFR 1910.120. Personnel who work in areas in which hazardous
chemicals are present may be required to be trained in accordance with OSHA
regulations published in 29 CFR 1910.1200 or in accordance with substance
specific standards in 29 CFR 1910 Subpart Z. All employees who handle, prepare
for shipment, load, unload or drive a vehicle hauling DOT hazardous materials
must be trained in accordance with the DOT training requirements in 49 CFR
172.700-.704. These regulations require initial general awareness,
function-specific and safety training as well as recurrent training every three
years or when changes in the regulation occur. To ensure that Clemson
University personnel meet all of the training requirements specified by
environmental laws, the dean, director, department head or supervisor, with
guidance from the Environmental Compliance Officer, should determine the
necessary training required for associated employees.
D. Documentation and
Training Records
The following documents and
records must be maintained at Clemson University:
� The job title for each position at Clemson University
related to hazardous waste management including the name of the employee
filling the job. �
A written job description for each
position listed including the requisite skill, education or other qualifications,
and duties of personnel assigned to each position. � A written description of the type and amount of
introductory and continuing training that will be given to each person filling
the listed position. �
Records documenting that the required
training/job experience has been given to, and completed by applicable Clemson
University personnel.
Training records on current personnel must be kept
until closure of the facility. Training records on former employees must be
kept for at least three years from the date the employee last worked at the
facility. Personnel training records may accompany personnel transferred to a
different department within the university.
APPENDIX
A Hazardous Waste Lists
(Remove this page
and attach all current hazardous waste lists from SCDHEC regulation R.61-79
here)
APPENDIX B
CLEMSON UNIVERSITY HAZARDOUS WASTE INCIDENT
CONTINGENCY PLAN
APPENDIX B
CLEMSON UNIVERSITY HAZARDOUS WASTE INCIDENT
CONTINGENCY PLAN
Objective:
This
SOP defines general responsibilities of the first responding agencies of
Clemson University to a hazardous waste incident. It is intended to ensure safe
and professional action by those agencies who have responsibilities in
hazardous waste response situations.
Definition:
Hazardous
wastes will be as defined in R.61‑79.261
of the South Carolina Hazardous Waste Management Regulations as revised. A
hazardous waste incident may be defined as one of these wastes and/or certain
other wastes that may be leaking, spilled, burning, reacting or having a
release thereof, that may endanger life, property and/or the environment.
Notification
and Initial Responsibility:
It will
be the responsibility of the first on the scene recognizing a hazardous waste
incident to assess the degree of life, property, and/or environmental safety
hazard so that a preliminary determination can be made as to notification
and/or response by other agencies.
If the
first on the scene determines that a hazardous waste incident does exist, the
following University departments will be notified:
(1) Clemson University Fire
Department 656‑2211
(2) Clemson University Police
Department 656‑2222
(3) Environmental Health and Safety Department 656‑2583 EH&S Emergency Coordinators: Primary: W.
Robert Newberry IV, Brookwood Dr., Clemson SC 29631
Home Phone (864) 654-2628, Work Phone (864) 656-1804
Secondary: Philip D. Carroll Jr., 130 Mt. Bethel Rd., Pickens SC 29671
Home Phone (864) 868-7412, Work Phone
(864) 656-1770 First on Scene Procedures: The first on scene recognizing
a potential hazardous waste incident shall make a brief assessment to determine
if:
(A) The situation can be resolved by those available
with no danger to persons, property
|
and/or environment. |
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|
(B) A hazardous waste
incident exists. EVERY POTENTIAL HAZARDOUS WASTE |
INCIDENT |
SHALL |
BE |
REPORTED |
TO |
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|
ENVIRONMENTAL HEALTH AND
SAFETY, 656‑2583. |
|
|
|||||||||||||||
|
In Event of a Hazardous Waste
Incident: |
|
|
|||||||||||||||
|
The |
first |
on |
scene |
recognizing |
a |
hazardous |
waste |
incident |
shall |
be |
the |
on‑scene |
incident |
||||
commander. That person shall:
(1)
EVACUATE the premises by activating the nearest FIRE ALARM pull box and/or by
shouting for others to vacate.
(2)
NOTIFY the FIRE DEPARTMENT by FIRE ALARM pull box, and by telephoning 656‑2211, with information about the incident. Also,
NOTIFY the POLICE DEPARTMENT (656‑2222).
(3)
NOTIFY DEPARTMENT PERSONNEL who may assist with the emergency.
(4)
NOTIFY ENVIRONMENTAL HEALTH AND SAFETY by telephoning 656‑2583.
(5)
MEET AT THE FIRE DEPARTMENT COMMAND POST when it is established on site and
relinquish command to the CLEMSON UNIVERSITY FIRE DEPARTMENT.
THE CLEMSON UNIVERSITY FIRE DEPARTMENT HAS THE AUTHORITY TO ASSUME
COMMAND OF ANY HAZARDOUS MATERIALS INCIDENT (ACT. NO. 65 OF 1983, SECTION 6‑11‑1450). The Fire Department will proceed in accordance with CLEMSON UNIVERSITY FIRE DEPARTMENT STANDARD OPERATION PROCEDURES NO. 1021, 3‑5.2, RESPONSE TO HAZARDOUS MATERIALS INCIDENTS.
Environmental Health and Safety Department Responsibilities:
The Environmental Health and Safety Department shall designate the Environmental Affairs Coordinator as emergency coordinator in the event of a hazardous waste incident. That person shall serve as support to the incident commander.
At all times, there must be at least one employee either on the facility premises or on call (i.e., available to respond to an emergency by reaching the facility within a short period of time) with the responsibility for coordinating all emergency response measures. This emergency coordinator must be thoroughly familiar with all aspects of the facility's contingency plan, all operations and activities at the facility, the location and characteristics of waste handled, the location of all records within the facility, and the facility layout. In addition, this person must have the authority to commit the resources needed to carry out the contingency plan.
Emergency Procedures:
Whenever there is an imminent or actual emergency situation, the coordinator (or his/her designee when the emergency coordinator is on call) must immediately notify appropriate state or local agencies with designated response roles if their help is needed.
(1) Whenever there is
a release, fire or explosion, the emergency coordinator must immediately
identify the character, exact source, amount, and extent of area involved.
He/she may do this by observation or review of facility records or manifests,
and, if necessary, by chemical analysis.
(2)
Concurrently, the emergency coordinator must assess possible hazards to human
health or the environment that may result from the release, fire or explosion.
This assessment must consider both direct and indirect effects of the release,
fire or explosion (e.g., the effects of any toxic, irritating, or asphyxiating
gases that are generated, or the effects of any hazardous surface water run‑off from water or chemical agents used to control fire
and heat‑induced explosions).
(3)
If the emergency coordinator determines that the facility has had a
release, fire or explosion which could threaten human health or the
environment, outside the facility,
he/she must report his/her findings as follows:
(A)
If his/her assessment indicates that evacuation of local areas may be
advisable, he/she must immediately notify appropriate local authorities. He
must be available to help appropriate officials decide whether local areas
should be evacuated; and
(B)
He/she must immediately notify SCDHEC (using its 24 hour number 803‑253‑6488).The report
must include:
(i) Name and telephone number of reporter;
|
(ii) |
Name and address of facility;
|
|
(iii) |
Time and type of incident
(e.g., release, fire); |
|
(iv) |
Name and quantity of
material(s) involved, to the extent known; |
|
(v) |
The extent of injuries, if
any; and |
|
(vi) |
The possible hazards to human
health or the environment, outside the facility. |
(4)
During an
emergency, the emergency coordinator must take all reasonable measures
necessary to ensure that fires, explosions and releases do not occur, recur or
spread to other hazardous waste at the facility. These measures must include,
where applicable, stopping processes and operations, collecting and containing
release waste, and removing or isolating containers.
(5)
If the facility stops operations in response to a fire, explosion or release,
the emergency coordinator must monitor for leaks, pressure buildup, gas
generation or ruptures in valves, pipes or other equipment wherever this is
appropriate.
(6)
Immediately after an
emergency, the emergency coordinator must provide for treating, storing or
disposing of recovered waste, contaminated soil or surface water, or any other
material that results from a release, fire or explosion at the facility. Unless
the owner or operator can demonstrate, in accordance with South Carolina
Hazardous Waste Management Regulations R.61‑79.261.3(c)
or (d), that the recovered material is not a hazardous waste, the owner or
operator becomes a generator of hazardous waste and must manage it in
accordance with all applicable requirements of R.61‑79.262 Standards Applicable to Generators of Hazardous
Waste, R.61‑79.263 Standards Applicable to Transporters of
Hazardous Waste and R.61‑79.264. (amended
11/90)
(7) The emergency coordinator must ensure that, in the affected area(s) of the facility:
(A)
No waste that may be incompatible with the released material is treated, stored
or disposed of until cleanup procedures are completed; and
(B)
All emergency equipment listed in the contingency plan is cleaned and fit for
its intended use before operations are resumed.
(8)
The owner or operator must notify SCDHEC (803‑253‑6488), and appropriate state and
local
authorities, that the facility is in compliance with paragraph (7) of this
Section before operations are resumed in the affected area(s) of the facility.
(9)
The owner or operator must note in the operating record the time, date and
details of any incident that requires implementing the contingency plan. Within
15 days after the incident, he/she must submit a written report on the incident
to the department. The report must include:
(A)
Name, address, and telephone number of the owner or operator;
(B)
Name, address, and telephone number of the facility;
(C)
Date, time, and type of incident (e.g., fire, explosion);
(D)
Name and quantity of material(s) involved;
(E)
The extent of injuries, if any;
(F)
An assessment of actual or potential hazards to human health or the
environment, where this is applicable; and
(G)
Estimated quantity and disposition of recovered material that resulted from the
incident.
Evacuation
Plans: Entire campus plans are too
numerous for inclusion here in this document. Individual building plans,
including evacuation floor plans, are maintained and copies can be obtained at
no charge from: Environmental Health and Safety, Clemson University, Moorman
House, 208 N. Palmetto Blvd., Clemson SC., 29631-3012. (864) 656-2583, fax #
(864) 6567630. These plans must be obtained and the maps posted at each
Accumulation Point. These plans are needed by other regulations and may require
more extensive posting. For information on these contact the University Fire
Marshal at (864) 656-2323 and the Chemical Hygiene Officer at (864) 656-7554
for compliance with these other regulations.
List of Emergency and Spill Control
Equipment and Location: These lists are
maintained by the Clemson University Fire Departments Hazardous Materials
Response Team and Environmental health & Safety�
s Environmental Compliance Office. This list may be updated from the printing of this manual. Copies are kept current and available at the Office of Environmental Health and Safety, Clemson University, Moorman House, 208 N. Palmetto Blvd. (864) 656-2583 as well as at the University Fire Department (864) 656-2323. Copies may be obtained from the Environmental Compliance Officer at 656-1770.
The
department of Environmental Health and Safety�
s Environmental Compliance Group,
independently, for its waste operation at the Central Accumulation Point
Maintains the following equipment : At
its Dike location shown on map in Figure III-2 Vermiculite 20 bags Oil dry 2 bags
Aggressive fluids Spill kit Large for up to 65 gallons Non Aggressive fluids
Spill kit Large for up to 65 gallons Non Sparking Shovels (2) Drain Blockers 24�
X 24�
pads (2) Drain Plugs 4� (4) Portable Spill kit Aggressives
(on Truck) Broom and Dust pan (one also on truck) 85 gallon over pack drums (4)
Nitrile Gloves Coated Tyvex Coveralls Non Sparking bronze tool kit (on truck)
Barrel leak plug kit (on truck) First Aid kit (on truck) 20 # ABC Fire
extinguisher (on truck) Numerous plastic pans and contaniers of various sizes
for repackaging or over packing Full face respirators (individually assigned
during fit testing) Drum funnels and absorbent pads of assorted sizes Barrel
containment spill pans Spill controll pallets, plastic, numerous sizes
Waterproof tarps for above (6) One fork lift with numerous barrel handling
attachments Drum sampling pipettes (10) Portable pH meter and pH strips (on
truck) Mercury spill kits (2) One-non aggressive fluids Spill kit Large for up
to 65 gallons One aggressive fluid Spill kit Large for up to 65 gallons Nitrile
gloves- several cases One 30 gallon Hepa-filtered Vacuum One Flammable fluid
pump, electric Two flammable fluids pumps, Pneumatic One portable air
compressor Two Scott air pak�
-
SCBA�s Lab coats- three each Safety glasses-
20 pairs One fork lift with numerous barrel handling attachments First aid kit
Tool box with assorted tools Full-face respirators (individually issued at fit
testing) pH meter Spill containment pallets, numerous sizes
APPENDIX C
Hazardous Waste Management Regulations (Separate Documents)
For Copies of these documents to maintain a departmental library, contact Environmental Health and Safety at (864) 656-2583
APPENDIX C -Table of Contents
The following federal regulations (or parts thereof) concerning the management of hazardous waste are included in this appendix:
40 CFR 261 IDENTIFICATION AND LISTING OF HAZARDOUS WASTE
40 CFR 262 STANDARDS APPLICABLE TO GENERATORS OF HAZARDOUS WASTE
40 CFR 264 STANDARDS FOR OWNERS AND OPERATORS OF
264.16; HAZARDOUS WASTE TREATMENT, STORAGE, AND
SUBPART C,D & I DISPOSAL FACILITIES
40 CFR 265 INTERIM STATUS STANDARDS FOR OWNERS AND
265.15; OPERATORS OF HAZARDOUS WASTE TREATMENT,
SUBPART C,D & I STORAGE, AND DISPOSAL FACILITIES
40 CFR 279 STANDARDS FOR THE MANAGEMENT OF USED OIL
49 CFR 172.700-.704 DOT TRAINING REQUIREMENTS
29
CFR 1910.120 OSHA
HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE
APPENDIX D
Hazardous Waste Storage and other Miscellaneous
Information