HAZARDOUS WASTE OPERATION PLAN (TOXICS USE AND HAZARDOUS WASTE REDUCTION PLAN)

Transcription

1 HAZARDOUS WASTE OPERATION PLAN (TOXICS USE AND HAZARDOUS WASTE REDUCTION PLAN) CLACKAMAS COMMUNITY COLLEGE REFERENCE: 40 CFR, PART 265 SUBPART C DEQ/OAR July 1, 2012 Approved by ehscommittee Approved by CUDC Approved by Presidents Council Reviewed 9/2011 Originally Prepared 4/1998

2 Purpose The purpose of this program is to provide one source of written documentation for all elements required as hazardous waste records. In addition, this plan will inform interested persons, including college and contractor employees, about this college s compliance with Oregon Department of Environmental Quality (DEQ) and Environmental Protection Agency (EPA) requirements for small quantity generators of hazardous waste under the hazardous waste regulations for generators and OR-OSHA requirements OAR /H (q)(1),(2). This plan provides a written description of handling procedures for hazardous waste, accumulation requirements, waste reduction, emergency response, shipping protocol, and employee training. We encourage any suggestions that our employees have for improving our hazardous waste written plan, as we are committed to developing and maintaining an effective plan. We strive for clear understanding, safe behavior, and involvement in the plan from every level of the college. Administrative Duties Director of Campus Safety is responsible for developing the written Hazardous Waste Plan; for ensuring that our written plan is complete, kept up to date, and made available to applicable or required authorities; and for maintaining hazardous waste management records. Dean of Campus Services is the owner/operator of the college for the purpose of the hazardous waste plan and reports. Location of Plan Employees may review a copy of the hazardous waste written plan. It is located in Campus Safety Office, Barlow Hall 212a Employees can obtain a copy of the plan by contacting their supervisor or the Director of Campus Safety, extension 6451 College Hazardous Waste Generator Status The college is a small quantity generator when the college generates in one calendar month: generate more than 220 pounds but less than 2,200 pounds of hazardous wastes or

3 generate more than 220 pounds but less than 2,200 pounds of spill cleanup debris containing hazardous wastes or at any time accumulate more than 2,200 pounds of hazardous waste on-site We store hazardous waste for no more than the 180 days (270 days if transporting more than 200 miles) allowed under the regulations for our generator category. Accumulation limit for small quantity generator is 13,200 pounds. If we exceed this limit, a permit is required. We are not a permitted transportation, storage, and disposal facility. The college s EPA/DEQ identification number for Oregon City Campus: ORD Harmony Community Campus: N/A Wilsonville/OATC: ORD The college submits an annual report that documents our previous year s hazardous waste generation, accumulation, on-site recycling, or other management practices. Accumulation and Storage of Hazardous Waste At the college, certain activities are known to generate hazardous waste: Art/Theatre programs Automotive programs Apprenticeship programs Horticulture programs Manufacturing programs Nursing/EMT programs (Bio-Waste) PE/Health programs Campus Services operations Science programs Engineering/Water Quality Note: All Electronic waste is recycled under the college s Universal Waste Plan: example: Computer Monitors, Batteries As a generator of hazardous waste, this college can accumulate hazardous waste for 180(270 if transporting more than 200 miles) days before treatment or disposal. We also comply with the maximum accumulation amounts of 13,200 pounds. We handle wastes in a manner that prevents leaks, spills, fires, and explosions. It is the intent of this college to assure that accumulations of hazardous waste are monitored so that they comply with applicable regulations, are disposed of properly, and are evaluated for potential waste reduction initiatives.

4 We are careful about containers we select to store and ship hazardous wastes and we have appropriate containment devices available. We make sure that our hazardous waste storage containers meet the specifications of, and are marked, labeled, and placarded according to DEQ/EPA and Department of Transportation (DOT) requirements. All containers are marked with the words Hazardous Waste and must be marked with the date that the waste was fist put in the container; unless the container meets the requirements of satellite accumulation. Containers must be in good condition, handled carefully and replaced if leaking occurs. Containers cannot be used to store hazardous waste if the waste may cause the container to rupture, leak, corrode, or otherwise fail; and all containers holding hazardous waste must be CLOSED except when being filled or emptied. Containers must be inspected at least weekly for leaks and signs of corrosion. An inspection log will be kept. Waste Reduction An important component of controlling the generation of hazardous waste includes using good housekeeping practices. The college uses appropriate hazardous waste management practices, such as: Use and reuse of materials as much as possible. Recycling or reclaiming waste. Treating waste to reduce its hazards; under certain conditions Reducing the amount of waste generated. To reduce the amount of waste we generate, we: Do not mix hazardous wastes with non-hazardous wastes, since the entire contents then become subject to regulation. Avoid mixing several different hazardous wastes. Avoid spills or leaks of hazardous products because the materials used to clean up spills become hazardous wastes. Completely empty the original containers of hazardous products before they are disposed of. Avoid use of more hazardous products than needed. Substitute products that are less hazardous when available. Use waste/materials exchanges. Basic Emergency Response Plan Although we take every precaution to prevent spills of hazardous wastes, we are prepared should a spill occur. We have developed an Emergency Response Management Plan for the college as specified in 40 CFR 265 Subpart D. Our plan meets these requirements by providing a document that describes:

5 Who coordinates emergency activities? Posting certain information near telephones. Employee training in normal and emergency operations. Responses to fires, spills, explosions, or other unplanned releases. Our response plan applies to all work operations in at the college where employees may be exposed to potential discharge or spill situations involving hazardous waste under normal working conditions or during an emergency situation. This plan is designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned release of hazardous waste or hazardous waste constituents to air, soil, or surface water. The provisions of our plan are to be carried out immediately whenever there is a fire, explosion, or release of hazardous waste or hazardous waste constituents that could threaten human health or the environment. Coordination with Local Emergency Response Providers The college as attempted to make the following arrangements, as appropriate for the type of waste handled at the college and the potential need for the services of these organizations. (40 CFR (a)) Arrangements to familiarize police, fire departments, and emergency response teams with the layout of the college. Arrangements with emergency response contractors, and equipment suppliers The following information has been posted by hazardous material user departments telephones: Name and telephone number of the emergency coordinator(s). Location of fire extinguishers. Location of spill control material and fire alarms Telephone number of the fire department. Emergency Equipment

6 It is our policy to operate the college in a safe and responsible manner. We continually review our operations to minimize the possibility of a fire, explosion, or an accidental release of a hazardous waste or material. We have an emergency fire plan in place, and we routinely obtain a fire department inspection. To assist in effective handling of potential emergencies which could arise as a result of our hazardous material and waste operations, we have the following equipment: Immediately available telephone at the scene of operations. Two-way radio Fire control equipment, including Fire extinguishers Fire sprinkler systems Fire stand pipe systems Spill control equipment, including: Barlow Hall Rooms: 101,161,166a Non-aggressive fluids DeJardin Hall 182 Aggressive fluids, Non-aggressive fluids Pauling Center Rooms: 144, 163, 161, 165 Aggressive fluids Lewelling Building S/R Non-aggressive fluids Emergency Response Vehicle Aggressive fluids, Non-aggressive fluids Decontamination control equipment, including: Eye wash Showers This equipment is inspected regularly. The college has established procedures for regularly checking and maintaining our automatic sprinklers, fire extinguisher, fire alarms systems, and other emergency equipment. We regularly test and maintain to ensure that it will function properly in an emergency. At college facilities, we ensure that at all times our emergency equipment is readily accessible to the employees during operations involving hazardous waste materials. We also have established procedures to ensure that adequate aisle space is maintained to allow for the unobstructed movement of personnel and the transporting of equipment during an emergency. Emergency Coordination Clackamas Community College has an Emergency Response Management Plan (ICS) for coordination of any emergency situation on any of the campuses of the college

7 A designated Incident Commander is on the premises or on call at all times. Shipping Hazardous Waste The college documents shipments of hazardous wastes to treatment/disposal facilities. The Director of Campus Safety is responsible for coordinating shipments of hazardous wastes and to ensure that: Storing the waste properly before shipment. Tracking the amount of waste accumulated, (total of all hazardous waste generated during the course of a month/year). Finding and negotiating with a reputable, hazardous waste service provider and confirm that the service provider has a DEQ/EPA identification number and proper liability insurance as required by PUC. Coordinate or prepare hazardous waste manifest and any other appropriate shipping papers. Employee Training Supervisors either directly or through the Campus Safety Office will provide training to employees who are required handle hazardous material and training will be administered annually, or more if necessary. The Director of Campus Safety will coordinate training or train personnel who will handle hazardous waste according to 40 CFR (d)(5)(iii). Under this plan, employees are informed of proper waste handling and emergency procedures relevant to their responsibilities during normal college operations and emergencies. College personnel will complete the training program within two weeks after their assignment to the position requiring such training. College will maintain records for all training, describing the type and amount of basic training provided to fulfill the requirements. The Environmental Health and Safety Coordinator will keep training records on current personnel. Maintaining the Plan The Director of Campus Safety will monitor the effectiveness of this plan and make recommendations to improve the plan. Director of Campus Safety is responsible for: Conducting periodic site audits

8 Keeping records of all inspections and reports, including inspection logs, annual reports, shipping manifests, land disposal restriction certificates. If any, and exception reports for at least 3 years, 5 year for LDR s; DEQ believes it is in the best interest of the generator it retain waste management records for the life of the facility. Such records may limit future liability during cleanup or emergencies. Updating the plan as needed by incorporating any necessary changes resulting from major changes in the college s personnel, operation, or maintenance. Contact the Director of Campus Safety for more information, if needed at kurtn@clackamas.edu