Hazardous Waste Determination and Management Plan

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1 Hazardous Waste Determination and Management Plan Prepared By: Triumvirate Environmental Developed: November 2014 Updated: Program Approval Associate Vice President of Public Safety & Administrative Services Date

2 Table of Contents 1.0 Introduction Waste Determination Responsibility for Completing a Waste Determination Hazardous Waste Identification Process Is the Material a Solid Waste? Is the Waste Specifically Excluded from RCRA? Is the Waste a Listed Hazardous Waste? Does the Waste Exhibit a Characteristic of Hazardous Waste? Hazardous Waste Management Definitions Satellite Accumulation Area Inspections Main Accumulation Area Inspections Waste Disposal and Manifest Tracking Waste Disposal Hazardous Waste Manifests Hazardous Waste Manifest Mailing

3 1.0 Introduction (LACFA) is located at 84 Lyme Street in Old Lyme, Connecticut. is a four-year, nationally-accredited college offering Bachelor of Fine Arts degrees in Drawing, Illustration, Painting, and Sculpture. Its mission is to provide the best education in drawing, illustration, painting, and sculpture through study of the history, traditions, and principles of the fine arts and the liberal arts, thereby establishing a comprehensive foundation for the development of the artist LACFA is registered with the Connecticut Department of Energy and Environmental Protection (CTDEEP) as a Conditionally Exempt Small Quantity Generator (CESQG)of hazardous waste as outlined in the Connecticut regulations 22a-449(c)-102(a)(1). The Environmental Protection Agency (EPA) identification number assigned to the LACFA campus is As a CESQG of hazardous waste, the following is applicable to the LACFA site: Generates less than 100 kilograms (220 pounds) of hazardous waste per calendar month; and, Accumulates less than 1000 kilograms (2200 pounds) of hazardous waste at any one time; and, Generates less than one kilogram (2.2 pounds) of acute hazardous waste per calendar month; and, Accumulates less than one kilogram (2.2 pounds) of acute hazardous waste at any one time 3

4 2.0 Waste Determination All potentially hazardous wastes must be properly characterized at the time they become a waste, that is, when it has been determined that the material is no longer useful for the purpose for which it was intended, and/or is otherwise collecting onsite for no reason other than storage prior to ultimate disposal. Please refer to Appendix A on page 9 for the Hazardous Waste Determination Flow-Chart. 2.1 Responsibility for Completing a Waste Determination LACFA staff is responsible for completing a proper waste characterization on all solid waste to determine if the waste is hazardous. For all questions pertaining to the waste characterization process, staff has been trained to contact their department manager. The following information can be used to properly determine if the waste is hazardous: 1. Generator knowledge of processes and waste; 2. Laboratory testing of the waste; and/or 3. Safety Data Sheets (SDS) for the components of the wastes. For routinely generated waste streams, the waste determination is recorded on the waste profile. Waste profiles for all routinely generated wastes are kept within the facility department. 2.2 Hazardous Waste Identification Process The hazardous waste identification (HWID) process is the crucial first step in the hazardous waste management system. Correctly determining whether a waste meets the Resource Conservation Recovery Act (RCRA) definition of hazardous waste is essential to determining how the waste must be managed. The LACFA waste generator has responsibility for determining if a waste is a RCRA hazardous waste. The HWID process consists of four questions: 1. Is the material a solid waste? 2. Is the waste specifically excluded from RCRA? 3. Is the waste a listed hazardous waste? 4. Does the waste exhibit a characteristic of hazardous waste? The above steps are explained in further detail in the following sections Is the Material a Solid Waste? Before a material can be classified as a hazardous waste, it must first be a solid waste. Under the EPA s RCRA, the definition of a solid waste includes any discarded material (solid, liquid or gas) Is the Waste Specifically Excluded from RCRA? The EPA and CTDEEP exclude certain solid wastes from the definition of hazardous waste. If a material meets an exclusion from the definition of hazardous waste, it cannot be a hazardous waste, even if the material technically meets a listing or exhibits a characteristic. 4

5 The following wastes are excluded from hazardous waste regulations because they are regulated under separate, more specific regulations: radiological waste;, medical waste; domestic sewage; universal wastes (batteries, lamps); and industrial wastewater discharge Is the Waste a Listed Hazardous Waste? The next step in the HWID process is to determine if the waste is a listed hazardous waste per 40 CFR and 40 CFR 124. The Code of Federal Regulations lists the following as hazardous wastes federally classified wastes additional detail pertaining to these waste codes can be found in Appendix B: F-list This list identifies wastes from common manufacturing and industrial processes, such as solvents that have been used in cleaning or degreasing operations. Because the processes producing these wastes can occur in different sectors of industry, the F-listed wastes are known as wastes from non-specific sources. P and U list This list includes discarded commercial chemical products and specific commercial chemical products in an unused form. Some pesticides and some pharmaceutical products become hazardous waste when discarded. If your waste is on any of these lists, or a component of your waste is on any of these lists, it is hazardous. The appropriate waste code or codes should be assigned accordingly and the waste should be appropriately managed as a hazardous waste Does the Waste Exhibit a Characteristic of Hazardous Waste? Waste that have not been specifically listed may still be considered a hazardous waste if exhibits one of the four characteristics defined in 40 CFR Part 261 Subpart C - ignitability (D001), corrosivity (D002), reactivity (D003) and toxicity (D004 - D043). Ignitability - Ignitable wastes can create fires under certain conditions, are spontaneously combustible, or have a flash point less than 60 C (140 F). These wastes can also include ignitable compressed gases as well as oxidizers. Corrosivity - Corrosive wastes are acids or bases (ph less than or equal to 2, or greater than or equal to 12.5) that are capable of corroding metal containers, such as storage tanks, drums, and barrels. Battery acid is an example. Reactivity - Reactive wastes are unstable under "normal" conditions. They can cause explosions, toxic fumes, gases, or vapors when heated, compressed, or mixed with water. Examples include lithium-sulfur batteries and explosives. Toxicity - Toxic wastes are harmful or fatal when ingested or absorbed (e.g., containing mercury, lead, etc.). When toxic wastes are land disposed, contaminated liquid may leach from the waste and pollute ground water. These wastes and their regulatory threshold can be found in Appendix B. 5

6 If the waste that has been produced does not fall into one of the above categories and/or lists, it is most likely a non-hazardous waste. 3.0 Hazardous Waste Management Once a waste has been identified as a hazardous waste, the waste is required to be managed per EPA and CTDEEP hazardous waste regulations. 3.1 Definitions Satellite Accumulation Areas Collection containers at or near the point of generator of a hazardous waste. Conditionally Exempt Small Quantity Generator EPA regulations state that CESQG s may not generate more than 100 kilograms of hazardous waste per month, nor may they generate more than 1 kilogram of acutely hazardous waste per month. Small Quantity Generator EPA regulations state that SQG s may not produce more than 2,200 pounds of hazardous waste and/or 2.2 pounds of acutely hazardous waste in a given month. o Hazardous waste generator statuses for WMH properties are listed in section Satellite Accumulation Area Inspections EPA and CTDEEP regulations require all satellite accumulation areas to be managed following hazardous waste container management regulations. All hazardous waste containers at LACFA must be managed following the below 13 steps. The CTDEEP requires that SAA locations be managed according to the below guidelines. At the LACFA campus, Triumvirate Environmental will conduct inspections of satellite accumulation areas (40 CFR ). All satellite accumulation areas at LACFA will be inspected for the following: 1. Area must be under the control of the individual directly responsible for the process that generates the waste. 40CFR (c) 2. Satellite area must be at or near each specific point of generation where wastes initially accumulate. 40CFR (c) 3. The wastes must be generated as a result of a process occurring at the specific point of generation where the wastes are initially accumulated. 40CFR (c) 4. Only one container per waste stream may be in use at any one time. 40CFR (c) 5. Maximum capacity of containers is as follows: 55 gallons of hazardous waste and/or 1 quart of acutely hazardous waste. 40CFR (c) 6. When the container is filled or exceeds the storage limits, it shall be dated immediately and within 3 days, moved to the main storage area and come into compliance with all regulations pertaining to that area. 40CFR (c) 7. The surface underlying the containers shall be free of cracks, gaps, and sufficiently impervious to contain leaks. 40CFR (a) 8. Each container shall be marked with the following: a) The words Hazardous Waste b) The chemical names (e.g., acetone, toluene) c) The hazard associated with those chemicals (e.g., ignitable, toxic, dangerous when wet). 40CFR (c) 9. Containers must be in good condition. (Free of rust and/or structural damage). 40CFR (a) 10. Container must be compatible with waste inside. 40CFR Container must be closed during storage. 40CFR (a) 6

7 12. Containers must not be handled in a manner, which may cause it to rupture or cause it to leak. 40CFR Containers must be spaced so they can be inspected. 40CFR (c) 3.3 Main Accumulation Area Inspections The CTDEEP requires that main storage areas be inspected at least weekly (310 CMR ) for the below requirements. At the LACFA campus, Triumvirate Environmental will conduct documented weekly inspections of the main accumulation area. The main accumulation area at LACFA will be inspected for the following: 1. The area must be clearly marked with a clearly visible line or piece of tape on the floor, or by a fence. 2. A sign must be posted with the words HAZARDOUS WASTE in capital letters, one inch high. 3. The area must have appropriate security in place to prevent the unauthorized entry of persons. 4. The surface underlying all containers must be free of cracks, gaps and sufficiently impervious to contain leaks. 5. Each container must be marked with the words Hazardous Waste, the chemical names (e.g., acetone, toluene), the type of hazard associated with the chemical (e.g., ignitable, toxic, dangerous when wet), the date on which accumulation begins. 6. Containers must be in good condition. (Free of rust and/or structural damage) 7. Containers must be compatible with waste inside. 8. Containers must be closed during storage. 9. Containers must be spaced so they can be inspected. 10. Waste may be accumulated on site for no more than 180 days. 11. Containers must not be handled in a manner which may rupture the container or cause it to leak. 12. Aisle spacing for container storage shall meet the guidelines set forth in NFPA-30, chapter 4 (4 feet) and allow for the unobstructed movement of emergency equipment. 13. The area must be inspected for leaking and/or deterioration of containers and containment system, at least weekly. 14. A generator shall remedy all malfunctions, deteriorations, operator errors, and discharges which any inspection reveals. 15. A generator shall record every inspection in an inspection log or summary. 16. A generator shall keep the records of all inspection logs for 3 years. 17. Ignitable and reactive hazardous waste shall be located at least 50 feet from the facility property line. 18. Incompatible hazardous waste shall not be placed in the same container. 19. Hazardous waste shall not be placed in an unwashed container that previously held waste or material that is incompatible with the hazardous waste. 20. Containers holding hazardous waste that are incompatible with other wastes or materials stored nearby shall be separated by means of a dike, berm, wall or other device. 21. Markings and labels shall be placed on the sides of containers so they are clearly visible for inspection. 22. The area must have the following equipment: a. An internal communication or alarm system capable of providing immediate emergency instructions. b. A telephone or other instrument, immediately available at all areas of operations, capable of summoning emergency assistance. c. A portable fire extinguisher, fire control equipment, and spill control equipment and decontamination equipment. 7

8 d. Water, at an adequate volume and pressure, to supply water hoses or foam producing equipment, or automatic sprinkler system. e. Clear markings identifying all exits. MAA inspection records will be kept within the MAA for a period of three years. 4.0 Waste Disposal and Manifest Tracking 4.1 Waste Disposal LACFA is contracted with a licensed hazardous waste disposal contractor, Triumvirate Environmental, Inc. Through weekly inspections of the MAA, LACFA manages the full dates of hazardous waste as to assure all dated wastes are not kept on-site after 180 days per LACFA s internal policy. As necessary, LACFA contracts the licensed hazardous waste contractor to pick-up and dispose of hazardous waste following all local, state and federal hazardous waste regulations. 4.2 Hazardous Waste Manifests Only LACFA employees that have been trained on RCRA hazardous waste regulations and the Department of Transportation s Hazardous Materials regulation are able to sign hazardous waste manifests. All non-trained LACFA employees are not permitted to sign hazardous waste manifests. Training records are kept within the facility department training binder. The last three years worth of hazardous waste manifests are kept within the LACFA facilities office. 4.3 Hazardous Waste Manifest Mailing For all hazardous waste shipments, LACFA must submit a fully executed manifest photocopy of Copy 3 to the CTDEEP within 30 days of receiving it from the designated facility. All required manifest copies are mailed to the following address: Hazardous Waste Manifest Program Department of Energy & Environmental Protection 79 Elm Street Hartford, CT

9 Appendix A: RCRA HAZARDOUS WASTE DETERMINATION 9

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