Waste Logs and Waste Characterization

Appendix D Waste Logs and Waste Characterization Waste Generation and Disposal FAQ Sheet Summary of Hazardous Waste Generator Requirements EMS Waste Generation Log Example of a Completed EMS Waste Generation Log EMS Waste Disposal Log Example of a Completed Waste Disposal Log Waste Characterization Sheet (includes instructions for lab analysis and the Waste Profile form) EMS Waste Profile (form) Example of a Completed EMS Waste Profile (using sample SDS) Hazardous Waste s (sorted alphabetically by substance) Hazardous Waste s (sorted numerically by CAS number) Waste Hauling (flow chart)

EMS Manual Appendix D Waste FAQ Sheet Waste Generation and Disposal - Frequently Asked Questions (FAQ) What is a Waste? For practical purposes, a waste is anything the crew no longer needs and wants to throw away. Waste can be created by: Wear (e.g. lamp burns out or battery won't hold a charge) Damage (e.g. sat outside in the rain or ran into with a loader) Expired shelf life (e.g. outdate epoxy) Unwanted (e.g. sounded like a good product but doesn't work) By-product of a process (e.g. line flush) What EMS paperwork deals with waste? Three forms make up the EMS waste paperwork. Examples of completed forms are located in this Appendix. Waste Profile = Is this waste hazardous? Waste Generation Log = How much waste was created? Waste Disposal Log = Where did the waste go? The Waste Profile form is only used occasionally and instructions are provided in the Waste Characterization section of this Appendix. The Waste Generation Log is used to document that ODOT Maintenance yards are Conditionally Exempt Hazardous Waste Generators; so, all hazardous waste created at the yard or by the crew must be put on the log. The Waste Disposal Log documents that hazardous wastes are properly managed. ODOT Maintenance chooses to track the generation and disposal of universal wastes and three excluded wastes to show proper waste management and sustainability. What has to be included on the Waste Generation Log? Any hazardous waste, universal waste, and excluded waste created by Maintenance employees or Maintenance actions. Waste at tracked at the point of generation (where the waste was created). Hazardous waste must be tracked in pounds. Universal and excluded wastes may tracked in whatever units make sense (e.g. gallons or inches). Remember to write the units on the form. Hazardous waste Universal waste Excluded waste Examples of hazardous waste include Un-popped aerosol cans Hazardous epoxy Hazardous solvent Hazardous paint Anti-freeze that isn t recycled Non-alkaline batteries in trash Rechargeable and other non-alkaline batteries Mercury-containing lamps Fluorescent Mercury vapor Metal halide High-pressure sodium Waste pesticide (bulk; not aerosol) Mercury thermostats and switches Used oil Asphalt emulsion Used anti-freeze (recycled) Waste Generation and Disposal Version 1 February 1, 2009 Page 1 of 3

EMS Manual Appendix D Waste FAQ Sheet What is an excluded waste? Excluded wastes are solid wastes that may or may not be hazardous waste depending on how the waste was created. There are many excluded wastes. ODOT Maintenance primarily deals with three: used oil, used emulsion, and used anti-freeze. Excluded wastes do not have to be characterized, provided the BMPs in the EMS Manual are followed and the waste is recycled. What is a universal waste? Universal wastes are hazardous wastes that are produced by a variety of businesses. Universal waste regulations are more flexible than hazardous waste regulations. The goal of universal waste regulations is to reduce the amount of hazardous waste that ends up in landfills by encouraging recycling. There are four types of universal waste: Batteries (rechargeable) Pesticides (bulk) Mercury-containing thermostats and switches Mercury-containing lamps (e.g. fluorescent tubes, compact fluorescent bulbs, mercury vapor, metal halide, or high pressure sodium) What is a hazardous waste? A waste is considered hazardous if the waste 1) Has one of the four characteristics listed in the table below; OR 2) Contains chemicals listed on the state or federal list of hazardous wastes. And the waste has not been excluded from hazardous waste regulations and is not a universal waste. Listed chemicals have been combined into a table titled "Listed Hazardous Waste s" located in this Appendix. Listed wastes from manufacturing processes and radionuclides have not been included. Characteristics of hazardous waste Ignitability Corrosivity Reactivity Toxicity Description of waste Liquid with a flash point <140 F, an ignitable compressed gases, or oxidizers. Liquids with a ph <2.0 or >12.5 or something that will corrode steel (solid or liquid) Responds strongly to water, shock, heat, or pressure; gives off toxic gases; or is unstable or explosive Contain contaminants with a potential to leach into the ground, groundwater, or a waterbody at concentrations at or above allowable limits These compounds have serious health effects. Examples gasoline, petroleum-based solvent, enamel paint, paint thinner, and acetylene battery acid, caustic cleaners, and some degreasers Un-popped aerosol cans, lithiumsulfur batteries, unused explosives some resin catalysts, and ether organic pesticides, electronics, sludge, and poisons (e.g. for rats, mice, or ants) Waste Generation and Disposal Version 1 February 1, 2009 Page 2 of 3

EMS Manual Appendix D Waste FAQ Sheet What is a Conditionally Exempt Generator? There are three categories of hazardous waste generators: Conditionally Exempt Generator (CEG), Small quantity generator (SQG), and Large Quantity Generator (LQG). Generator status is determined by the amount of hazardous waste created each month in a calendar year and the amount of hazardous waste that is stored onsite. A facility is classified as a CEG if each calendar month the yard: Generates 2.2 pounds or less of acute hazardous wastes, or Generates 220 pounds or less of hazardous wastes, or Generates 220 pounds or less of spill cleanup debris containing hazardous wastes. CEGs are not allowed to store more than 2,200 pounds of hazardous waste onsite. CEGs have fewer requirements for managing hazardous waste than SQGs or LQGs. A summary of CEG and SQG generator requirements is located in Appendix D. A few ODOT yards may be classified as SQG. A Maintenance yard becomes a SQG if the amount of hazardous waste created in a month exceeds the CEG limits (even once) in a calendar year. Work with the Region HazMat Coordinator to meet SQG requirements if more than 220 pounds of hazardous waste is created in a month. For more information on hazardous waste generator requirements, refer to DEQ's Small Quantity Hazardous Waste Generator Handbook. The Handbook can be obtained from the DEQ web site http://www.deq.state.or.us/lq/hw/sqghandbook.htm What things have to be included on Waste Disposal Log? Any waste that is listed on the Waste Generation Log must be listed on the Waste Disposal Log when the waste leaves the yard. The Waste Disposal Log helps keep track of what happens to the waste (e.g. recycled or landfill). What is a Method of Disposal? The typical methods of waste disposal are listed below. Sewage treatment (including septic systems) and other specialized waste treatment methods are not typically part of the Waste Disposal Log so these methods are not discussed. Recycling is where waste is broken down into raw materials that are used to make new items. Common recyclables include aggregate (concrete), batteries, electronics, glass, green waste (brush), metals, paper, plastic, textiles (clothing), timber (wood), and tires. Available markets for recyclable waste vary around the State. DAS maintains a mandatory contract for some recyclables, such as electronic waste. Landfill disposal (e.g. the dump or trash) is where wastes are buried. In Oregon, DEQ regulates what landfills can and cannot bury. Some landfills are authorized to accept special wastes (e.g. hazardous waste). A list or DEQ permitted landfills and transfer stations is located in Appendix J. Incineration is where wastes are burned. At municipal incinerators, the heat generated from burning is converted to electrical power. Currently there is only one municipal incinerator in Oregon. Reuse is not a really a disposal method but a management strategy that involves using a product more than once. Products may be reused for the same function (e.g. washable rags) or reused for a different function (e.g. burning used oil for heat). Refer to the Disposal section of each procedure for disposal options. A list of permitted landfills and transfer station is located in Appendix J Permitted Landfills. For solid waste disposal look for a municipal landfill or transfer station (will say municipal in the class column). Waste Generation and Disposal Version 1 February 1, 2009 Page 3 of 3

COMPARISON OF HAZARDOUS WASTE GENERATOR REQUIREMENTS This page provides general guidelines for generators of hazardous waste. Generator Category Generator Requirements Small quantity generator Generates between 220 and 2,200 pounds of hazardous waste per month Accumulate waste onsite for no more than 180 days Identify all hazardous wastes Obtain DEQ/EPA hazardous waste identification number Properly package wastes Properly label and mark waste containers Placard waste for shipment Comply with DOT transport requirements Use a manifest Use a registered transporter Prepare modified contingency plans, emergency procedures and personnel training Meet preparedness and prevention requirements Keep records and retain for 3 years Prepare waste reduction plan Send hazardous wastes to a regulated hazardous waste facility Follow Land Disposal Restriction regulations and maintain records for 3 years Submit annual report to DEQ Pay DEQ generator fees Conditionally Exempt Generator Generates less than 2.2 pounds of acutely hazardous waste per calendar month Generates less than 220 pounds of hazardous waste per calendar month Never accumulate more than 2,200 pounds of hazardous waste onsite at any time Identify all hazardous wastes A hazardous waste ID number may be required by transporter Properly package wastes Properly label and mark waste containers Placard waste for shipment Comply with DOT transport requirements Use of a manifest is often required by transporter Recommend using a registered transporter No formal training requirements No preparedness and prevention requirements Recommend keeping records for 3 years No required waste reduction plan Send hazardous wastes to regulated hazardous waste facility, recycle wastes, or send waste to solid waste management facility Not subject to land disposal restrictions No required reports to DEQ No DEQ generator fees Comparison of Hazardous Waste Generator Requirements Version 2 February 1, 2009 Page 1 of 1

EMS WASTE GENERATION LOG Yard Year EPA Generator Number Use this document to track hazardous waste, universal waste, or excluded waste created at the yard or by Maintenance actions. A list of typical wastes is located on the back of this page. Do not include waste generated by the motoring public. Refer to the EMS Procedures, Appendix D Waste Paperwork, or Appendix E - Waste Cheat Sheet for additional information. Contact HazMat for help with lab analysis or other waste characterization questions. Hazardous waste must be recorded in pounds. A conversion chart is located in Appendix D or the weight may be estimated by using an 8 pound/gallon conversion factor. An empty aerosol can weighs about ¼ pound. Separate EMS Waste Generation Logs may be used at yards with multiple crews. However, the total weight of hazardous waste generated by all crews based at the facility will determine the yard s hazardous waste generation status. The goal is to stay under 220 pounds of hazardous waste generation each month. Type of Waste Method of Characterization Monthly Generation (include units of measurement) Name or Description Hazardous Universal Excluded Assumed hazardous Lab analysis Waste Profile Knowledge / Waste Sheet Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual Total Monthly Total Hazardous Waste Call Office of Maintenance if approaching 220 lbs. EMS Waste Generation Log Version 3 December 21, 2012

Hazardous waste Universal waste Excluded waste Examples of hazardous waste include Un-popped aerosol can and/or residue inside a can popper Unleaded fuel filter Solvent (many) Can popper filter Hazardous epoxy or paint (e.g. flash point less than 140 F or contains 10% or more of toluene, xylene, or methyl methacrylate) Propane and compressed gas cylinder not returned to a vendor Batteries (rechargeable and other non-alkaline) Mercury-containing lamps (examples listed below) Fluorescent Mercury vapor Metal halide High-pressure sodium Waste pesticide (e.g. outdated bulk pesticide or pesticide saturated absorbent) Mercury thermostats and switches Used oil Asphalt emulsion Used anti-freeze (recycled) Bad fuel that is recycled Unknown waste (bucket-o-gunk) Anti-freeze that isn t recycled Rechargeable battery or mercury-containing lamp thrown in the trash EMS Waste Generation Log Version 3 December 21, 2012

EXAMPLE - EMS WASTE GENERATION LOG Yard ODOT Maintenance Yard Year 2009 EPA Generator Number None Use this document to track hazardous waste, universal waste, or excluded waste created at the yard or by Maintenance actions. A list of typical wastes is located on the back of this page. Do not include waste generated by the motoring public. Refer to the EMS Procedures, Appendix D Waste Paperwork, or Appendix E - Waste Cheat Sheet for additional information. Contact HazMat for help with lab analysis or other waste characterization questions. Hazardous waste must be recorded in pounds. A conversion chart is located in Appendix D or the weight may be estimated by using an 8 pound/gallon conversion factor. An empty aerosol can weighs about ¼ pound. Separate EMS Waste Generation Logs may be used at yards with multiple crews. However, the total weight of hazardous waste generated by all crews based at the facility will determine the yard s hazardous waste generation status. The goal is to stay under 220 pounds of hazardous waste generation each month. Type of Waste Method of Characterization Monthly Generation (include units of measurement) Name or Description Hazardous Universal Excluded Assumed hazardous Lab analysis Waste Profile Knowledge / Waste Sheet Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual Total Used Oil x x 75 gal 120 gal 80 gal 50 gal 30 gal 30 gal 50 gal 50 gal 150 gal 70 gal 95 gal 80 gal 880 gal Aerosol cans x x 10 lbs 7 lbs 5 lbs 0.5 lb 5 lbs 5 lbs 1 lb 1.5 lb 2 lb 5 lb 10 lb 12 lb 64 lbs Fluorescent tubes x x 2 tubes 10 tubes 5 tubes 17 tubes Used anti-freeze x x 5 gal 25 gal 10 gal 1 gal 1 gal 3 gal 1 gal 6 gal 15 gal 5 gal 7 gal 15 gal 94 gal Solvent - parts washer x x 200 lbs 200 lbs Batteries (rechargeable) x x 12 pieces 24 pieces 36 pieces old epoxy tubes x x 2 lb 2 lbs unlabeled bucket x x 40 lbs 40 lbs paint with solvent x x 160 lbs 160 lbs Drained gasoline filter x x 1 lb 1 lb 1 lb 1 lb 1 lb 1 lb 1 lb 1 lb 1 lb 1 lb 1 lb 1lb 12 lb Monthly Total Hazardous Waste Call Office of Maintenance if approaching 220 lbs. 13 lbs 48 lbs 6 lbs 1.5 lb 206 lbs 6 lbs 162 lbs 2.5 lbs 3 lbs 6 lbs 11 lbs 13 lbs EMS Waste Generation Log Version 2 December 18, 2008 Page 1 of 2

Hazardous waste Universal waste Excluded waste Examples of hazardous waste include Un-popped aerosol cans Hazardous epoxy Hazardous solvent Hazardous paint Anti-freeze that isn t recycled Non-alkaline batteries in trash Batteries (rechargeable and other non-alkaline) Mercury-containing bulbs (examples listed below) Fluorescent Mercury vapor Metal halide High-pressure sodium Waste pesticide Mercury thermostats and switches Used oil Asphalt emulsion Used anti-freeze (recycled) EMS Waste Generation Log Version 2 December 18, 2008 Page 2 of 2

EMS WASTE DISPOSAL LOG Yard From To EPA Generator Number Use this form to document the disposal of hazardous universal, and excluded waste. All wastes listed on the Waste Generation Log should be listed on this form when the waste leaves the yard. The disposal of wastes not listed on the Waste Generation Log may also be tracked on this form, at the discretion of the TMM. Records of hazardous waste disposal should have both a manifest number and a certificate of disposal. Refer to the EMS Procedures, Appendix D Waste Paperwork, or Appendix E - Waste Cheat Sheet for additional information. Date of Disposal Description of Waste Quantity Method of Disposal (e.g. recycled, HazWaste incinerator, or landfill) Disposal Company Manifest or Receipt Number EMS Waste Disposal Log Version 3 December 21, 2012 Page 1 of 1

Example - EMS WASTE DISPOSAL LOG Yard ODOT MAINTENANCE YARD From 1/01/09 To 6/30/09 EPA Generator Number none Use this form to document the disposal of hazardous universal, and excluded waste. All wastes listed on the Waste Generation Log should be listed on this form when the waste leaves the yard. The disposal of wastes not listed on the Waste Generation Log may also be tracked on this form, at the discretion of the TMM. Records of hazardous waste disposal should have both a manifest number and a certificate of disposal. Refer to the EMS Procedures, Appendix D Waste Paperwork, or Appendix E - Waste Cheat Sheet for additional information. Date of Disposal Description of Waste Quantity Method of Disposal (e.g. recycled on-site, re-used, collected by vendor) Used Oil 200 gal Disposal Company Manifest or Receipt Number 3/25/09 Fuel for space heater Took to ODOT Brothers Maintenance yard None Solvent epoxy tubes 200 lbs 10 tubes Collected by HazWaste company 5/10/09 bucket unknown waste anti-freeze 5 gal (40 lbs) 50 gals Recycles the solvent and anti-freeze Incinerates other hazardous wastes Philip Services Corporation 123987 Aerosol cans 100 cans 6/15/2009 Can popper (recycle scrap metal) Took to ODOT The Dalles Maintenance yard None fluorescent tubes 12 tubes batteries 20 pieces 6/20/09 Recycled County Landfill (HazWaste collection day) None Gasoline fuel filters < 8 per month Various Drained and thrown in the trash Marion County Sanitation None EMS Waste Disposal Log Version 2 December 18, 2008 Page 1 of 1

EMS Manual Appendix D Waste Characterization Characterizing Waste - Overview Wastes created by ODOT are typically divided into the following types: Solid waste (e.g. trash, lumber, and scrap) Hazardous waste (e.g. un-popped aerosol cans and most solvents) Universal waste (e.g. rechargeable batteries and fluorescent tubes) Excluded waste (e.g. used oil and recycled anti-freeze) The Disposal Section of each Procedure provides information about the type of wastes that may be generated. If the waste type is not known, the waste must be characterized to determine how the waste should be managed. The waste type must be either known (e.g. written in the EMS Manual) or determined (e.g. use one of the characterization methods) before disposal. The EMS program provides three methods of waste characterization (to determine the waste type). 1. Assume the waste is hazardous waste (waste may NOT be assumed non-hazardous) 2. Have the waste analyzed by a laboratory for hazardous waste characteristics 3. Complete a Waste Profile using a MSDS or lab results Unknown wastes (e.g. unlabeled drum, mixed waste, or sludge) must be either tested or assumed hazardous since no MSDS is available. Known wastes (e.g. have the MSDS) may be characterized using any of the three methods. Method 1 Assume hazardous waste Pros: Easy (CANNOT assume a waste is non-hazardous) The method can be used for both known and unknown wastes Cons: May count more hazardous waste than actually create (may become a Small Quantity Generator) Disposal may be more expensive Waste must be collected by hazardous waste hauler or taken to licensed facility How to: Label waste container as hazardous waste Record hazardous waste generation on Waste Generation Log (check assumed) Have waste picked up by a hazardous waste hauler and record on Waste Disposal Log Method 2 Analyze by laboratory Pros: The method can be used for any waste. Can be used to look for specific chemicals Documents when a waste is non-hazardous. Cons: Expensive The results often need to be explained How to: Contact HazMat or the laboratory for assistance with sample collection. Note: ODOT lab contacts must be used for analysis. Analysis should be based on recommendations in Table 1. Contact Region HazMat for recommended analysis of wastes that are not listed in Table 1. Compare the lab results to Table 2. Contact HazMat or Office of Maintenance for help. If the concentrations are greater than the limits listed in Table 2, the waste is classified as a hazardous waste. Follow the disposal guidelines in the Procedure or contact Hazmat. Note: Double-check the units. Some labs are listing concentrations in ug/l. If concentrations are listed in ug/l, divide the number by 1000 to get mg/l (e.g. 410 ug/l = 0.41 mg/l). Waste Characterization Version 1 February 1, 2009 Page 1 of 5

EMS Manual Appendix D Waste Characterization TABLE 1 - Recommended Lab Analysis Waste Used solvents including biosolvents TCLP RCRA Metals TCLP BTEX Total Volatiles TCLP Volatiles Analysis TPH Gasoline TPH - Diesel Paint Filter Test Flash point X X X Parts washers sludge including hot water washers X X landfill may require landfill may require X Liquid or semi-solid paint or epoxy mixed with solvent X landfill may require X Wash rack sediment or catch basin sumps X X landfill may require landfill may require Used bead blast X Used antifreeze (if the waste is not recycled) X Used emulsion (if the waste is not managed as used oil) Used oil mixed with antifreeze X X X Used oil mixed with solvent X X X TABLE 2 Hazardous Waste Concentrations Characteristic Regulatory Limit Flashpoint <140 F Acetone 100,000 mg/l Volatile Organics Heavy Metals Benzene 0.5 mg/l Carbon tetratchloride 0.5 mg/l Chlorbenzene 100 mg/l 1,4 Dichlorobenzene 7.5 mg/l 1,2 Dichloroethane 0.5 mg/l 1,1 Dichloroethylene 0.7 mg/l Hexachlorobutadiene 0.5 mg/l Methyl ethyl ketone 200 mg/l Tetrachlorethylene or Tetrachloroethene 0.7 mg/l Trichloroethylene 0.5 mg/l Toluene 100,000 mg/l Xylene (total) 100,000 mg/l Vinyl chloride 0.2 mg/l Arsenic 5 mg/l Barium 100 mg/l Cadmium 1 mg/l Chromium 5 mg/l Lead 5 mg/l Mercury 0.2 mg/l Selenium 1 mg/l Silver 5 mg/l Waste Characterization Version 1 February 1, 2009 Page 2 of 5

EMS Manual Appendix D Waste Characterization Method 3 Complete a Waste Profile Form Pros: Identifies the code(s) for hazardous waste transport (if the waste is hazardous). Documents when a waste is non-hazardous. Can be completed with a MSDS or lab analysis Cons: Must be read carefully; can be confusing Can't be used to characterize unknown waste How to: A sample Waste Profile form and a sample MSDS are included in this Appendix. In this example, the crew wants to get rid of an old can of lacquer thinner. The MSDS is on file. The thinner has not been used to clean anything and has not been mixed with any other waste. Complete all boxes in the top section of the form, except the " Box." Check whether the Waste Profile is being completed using the MSDS or lab results. Question 1 2: Check the appropriate boxes. If the waste is an excluded or universal waste, the Waste Profile form does not have to be filled out. However, the waste has to be tracked on the Waste Generation and Waste Disposal Logs. In the example Question 1 - Lacquer thinner is not one of the three listed excluded wastes. The answer is "no." Question 2 - Lacquer thinner is not one of the four listed universal wastes. The answer is "no." Questions 3 7: Are any of the chemicals listed in these questions are listed on the MSDS or lab report? These questions contain the word "AND." Both the first part and one of the second parts of the question must be true for the answer to be "yes." The questions also contain an "OR" so either part a) or part b) may be true. The MSDS should list the hazardous substances and the chemical abstract numbers (CAS). A "CAS number" is a designation given to a specific chemical compound by the Chemical Abstract Service. Substance names can be confusing, so CAS numbers should be used to verify that the correct substance has been identified or to double check that the substance has not been listed under an alias or trade name. When the concentration is listed as a range (e.g. 7-10%), use the largest number. Lab results are often given in parts per million (ppm), milligrams per kilogram (mg/kg), and milligrams per liter (mg/l). All these terms mean the same thing. Some labs list concentrations in ug/l. If the concentrations are in ug/l, divide the number by 1000 to get mg/l (e.g. 410 ug/l = 0.41 mg/l). To convert concentrations to a age, divide the concentration by 10,000 (e.g. 20,000 ppm = 2% or 32,300 mg/l = 32.3%). In the example Question 3 The waste was not used as a degreaser, so the answer is "no." Note: Since the first half of the question was not true, there is no need to look at the second half of the question. Question 4 The waste is a solvent, however none of the substances listed in this question are listed on the MSDS. Therefore, the answer is "no." Question 5 The waste is a solvent. The waste contains both "Methanol" and "Methyl Isobutyl Ketone." The concentration of both substances is less than 100% (part a). However, "Toluene" and "Methyl Ethyl Ketone" are both listed in Question 7 and both have concentrations higher than 10% (part b), so the answer is "yes." Waste Characterization Version 1 February 1, 2009 Page 3 of 5

EMS Manual Appendix D Waste Characterization This has been determined to be a hazardous waste. The hazardous waste code "F003" has been identified. Complete the rest of the form to find any additional codes. Question 6 The waste is a solvent however, the substances listed in this question are not listed on the MSDS. The answer is "no." Question 7 The waste is a solvent and both "Toluene" and "Methyl Ethyl Ketone" have concentrations greater than 10% (part a) is "yes." The code "F005" has been identified. Note: All four of the substances listed on the MSDS have been identified. Questions 8-10: Compare the substances listed on the MSDS or lab report to the Listed Hazardous Waste s. Two versions of the Listed Hazardous Waste s have been included in this Appendix. One catalogs the substances alphabetically based on the primary chemical name. Formula numbers and some prefixes are ignored (e.g. n-butyl alcohol is listed with b words). The other catalogs the substances numerically by CAS number. Since ingredients can be listed by an alias name, searching by CAS number may provide results that are more accurate. In the example, Question 8 None of the substances on the Listed Hazardous Waste sheet have codes that start with a "P." The answer is "no." Question 9 All four substances on the MSDS have codes that start with a "U" and have concentrations higher than 10%. However, all the substances have been previously given hazardous waste codes (either F003 or F005). The answer is "no." Note: If the waste was not a solvent, the following waste codes would have been identified U220-OR Toluene; U154-OR Methanol; U159-OR Methyl Ethyl Ketone; and U161-OR Methyl Isobutyl Ketone. Question 10 - "Methyl Ethyl Ketone" has a code that starts with a "D" and the concentration is higher than regulatory limit (10% is greater than 0.02%). However, the substance has already been identified in Question 7. The answer is "no." Note: If Methyl Ethyl Ketone had not been identified in a previous question, for the "D035" would have been identified. Question 11-13: These are three part questions. The answer to all three parts (a, b, and c) must incorrect for the answer to be "No." Sometimes the answers are hard to find on the MSDS. To convert temperature from Celsius to Fahrenheit, first multiply by 1.8 then add 32 degrees. In the example, Question 11 - This waste is a liquid and the flash point is -5 C (or 23 F). Since the flash point is less than 140 F (part a) the answer is "yes." The code "D001" has been identified. Question 12 The ph is listed as N/A so assume is within a normal range. There is not indication that the waste will corrode steel. The answer is "no." Note: Corrosive wastes may have the word "acid" in the name. Question 13 - The chemical reactivity is listed as "stable" (part a). There is nothing in the MSDS that indicates the waste reacts violently with water (part b) or that the waste is explosive (part c). Also the waste is listed as "minimal" under reactivity. The answer is "no." Note: The words "unstable" or "highly reactive" in an MSDS are indicators of a reactive hazardous waste. Waste Characterization Version 1 February 1, 2009 Page 4 of 5

EMS Manual Appendix D Waste Characterization Summary: If the answer to question 1 or 2 is "yes" the waste is not hazardous, but the generation and disposal must be tracked on the waste logs. If the answer to any of questions 3-13 is "yes" the waste is a hazardous waste. Mark "yes" in the Box on the front of the form and list all the s that were discovered. Hazardous waste generation and disposal must be included on the Waste Generation and Disposal Logs. The s should be used on hazardous waste manifests and on the EMS Waste Logs. Make sure to label the containers as "hazardous waste." In the example, the waste is hazardous and has s of "F003, F005, and D001." If all questions were "no" the waste is non-hazardous and does not have to be tracked. Refer to the Disposal Section of the Procedure for disposal options. Keep a copy of the completed Waste Profile onsite, even if the waste is non-hazardous. The completed Waste Profile should be kept for at least 3 years after the product is no longer being used onsite. DEQ recommends keeping the forms for the life of the facility. The Waste Profile should be completed once for each waste unless there is a change in product (e.g. a different brand of solvent) or process (e.g. cleaning more or less frequently). Waste Characterization Version 1 February 1, 2009 Page 5 of 5

EMS WASTE PROFILE Name, Trade Name, or Waste Description List Components of Mixture (e.g. Dura Stripe Part A & Part B) Box (Answers the Question "Is this a Hazardous Waste?) No Yes - List s Use / Description (primary use) This Waste Profile was completed using the MSDS. This Waste Profile was completed using lab analysis. INSTRUCTIONS Complete this form using the MSDS or the results of lab testing to determine if a waste is classified as hazardous. Complete one profile for each waste. Additional information on characterizing waste is located in Appendix D of the EMS Manual. Answer ALL questions. If a MSDS is used to complete this form, the CAS numbers should be used to verify that the correct substance has been identified. "CAS numbers" are assigned by the Chemical Abstract Service. Each specific chemical compound is given a separate number. The CAS number will remain the same even when substances are listed by trade names. If the answer to any of the questions is "yes" the waste must be tracked on the EMS Waste Generation and Waste Disposal Logs. If the answer to any of questions 3-13 is "yes" the waste is considered hazardous; check "yes" in the Box (above). The amount of hazardous waste generated each month is used to determine the yard's hazardous waste generator status. For additional information on hazardous waste generator requirements, refer to Appendix D of the EMS Manual. If the answers to ALL questions are "no" the waste is non-hazardous; check "no" in the Box (above). Non-hazardous wastes may have disposal restrictions (e.g. liquids have to be in sealed containers). Non-hazardous wastes should be managed according to the options listed in the disposal section of the EMS Procedure for the product. Attach a copy of the MSDS(s) and/or laboratory results and file onsite. 1. 2. 3. 4. Waste Profile Questions Is this waste one of the excluded wastes below and is the waste managed according to the EMS Procedure? - Used oil - Asphalt emulsion or emulsion mixtures (e.g. diesel fuel and tack) - Used Anti-freeze Is this one of the universal wastes listed below and is the waste managed according to the EMS Procedure? - Batteries - Waste pesticides - Mercury-containing lamps - Mercury thermostats Is this waste a solvent, used as a degreaser, and does it contain a) 10% or greater of any of the substances below; or b) a total of 10% or greater of any of the substances listed in questions 4-8 and one of the substances listed below has the highest concentration. - Carbon tertrachloride (CAS # 56-23-5) - Chlorinated fluorocarbons - Methylene chloroide (CAS # 75-09-2) - Tetrachloroethylene (CAS # 127-18-4) - 1,1,1-Trichloroethane (CAS # 71-55-6) - Tricholorethylene (CAS # 79-01-6) Is this waste a solvent (not used as a degreaser) and does it contain a) 10% or greater of any of the substances below; or b) a total of 10% or greater of any of the substances listed in questions 4-8 and one of the substances listed below has the highest concentration. - Chlorobenzene (CAS # 108-90-7) - o-dichlorobenzene (CAS # 95-50-1) - Methylene chloroide (CAS # 75-09-2) - 1,1,1-Trichloroethane (CAS # 71-55-6) - 1,1,2-Trichloro-1,2,2-trifluoroethane (CAS # 76-13-1) - 1,1,2-Trichloroethane (CAS # 79-00-5) - Tetrachloroethylene (PCE or Perc) (CAS # 127-18-4) - Trichlorofluoromethane (CAS # 75-69-4) - Tricholorethylene (TCE) (CAS # 79-01-6) No Answers Yes. Check "no" in box and write "excluded". List item(s) below. stop here No Yes. Check "yes" in box and write "universal." List item below. stop here No Yes. Write "F001" in the box. List substance(s) below. No Yes. Write "F002" in the box. List substance(s) below. EMS Waste Profile Version 3 December 21, 2012 Page 1 of 2

List the "Name" from Page 1 (in case the pages become separated). 5. 6. 7. Is this waste a solvent and does it contain a) 100% of any of substances listed below; or b) one of these substances and 10% or greater of any of the substances listed in Question 4, 5, 7, or 8. - Acetone - n-butyl alcohol - Cyclohexane - Ethyl acetate - Ethyl benzene - Ethyl ether - Methanol - Methyl isobutyl ketone - Xylene (CAS # 67-64-1) (CAS # 71-36-3) (CAS # 108-94-1) (CAS # 141-78-6) (CAS # 100-41-4) (CAS # 60-29-7) (CAS # 67-56-1) (CAS # 108-10-1) (CAS # 1330-20-7) Is this waste a solvent and does it contain a) 10% or greater of any of the substances below; or b) a total of 10% or greater of any of the substances listed in questions 4-8 and that one of the substances listed below has the highest concentration. - Cresols/cresyllic acid - Nitobenzene (CAS # 1319-77-3) (CAS # 98-95-3) Is this waste a solvent and does it contain a) 10% or greater of any of the substances below; or b) a total of 10% or greater of any of the substances listed in questions 4-8 and that one of the substances listed below has the highest concentration. - Benzene - Carbon disulfide - 2-Ethoxyethanol - Isobutanol - Methyl ethyl ketone - 2-Nitropropane - Pyridine - Toluene (CAS # 71-43-2) (CAS # 75-15-0) (CAS # 110-80-5) (CAS # 78-83-1) (CAS # 78-93-3) (CAS # 79-46-9) (CAS # 110-86-1) (CAS # 108-88-3) 8. Does this waste contain 3% or more of any of substance on the Listed Hazardous Waste sheet that has a code number that starts with a "P"? (See EMS Appendix D) Note: Do not include substances that have already been listed (in questions 3-7). 9 Does this waste contain 10% or more of any of substance on the Listed Hazardous Waste sheet that has a code number that starts with a "U? Note: Do not include substances that have already been listed (in questions 3-8). 10. Does this waste contain more that the regulatory level of any substance on the Listed Hazardous Waste sheet that has a code number that starts with a "D"? Note: Do not include substances that have already been listed (in questions 3-9). No Yes. Write "F003" in the box. List substance(s) below. No Yes. Write "F004" in the box. List substance(s) below. No Yes. Write "F005" in the box. List substance(s) below. No Yes. Write the code in the box. List code, substance and below No Yes. Write the code in the box. List code, substance and below No. Yes. Write code in the box. List substances(s) below 11. Is this waste ignitable? a) a liquid with a flash point less than 140 F (60 C); or b) a solid or a gas that is capable of igniting at normal temperatures (can cause fire through friction, absorption of moisture, or spontaneous chemical change); or c) an oxidizer or ignitable compressed gas 12. Is this waste corrosive? a) a water-based liquid that has a ph equal to or less than 2; or b) a water-based liquid that has a ph equal to or greater than 12.5; or c) a liquid that corrodes steel 13. Is this waste reactive? a) normally unstable; or b) reacts violently with water; or c) capable of explosion or detonation The answers on this Waste Profile are True and Complete to the best of my ability. Name Signature Yard Position Date No Yes. Write "D001" in the box. List letter below. No Yes. Write "D002" in the box. List letter below. No Yes. Write "D003" in the box. List letter below. EMS Waste Profile Version 3 December 21, 2012 Page 2 of 2

Example of a Completed Waste Profile form *** Sample MATERIAL SAFETY DATA SHEET *** Product Name: LACQUER THINNER Product : TN0901440 Chemical Family: ORGANIC COATING Product Use: PROTECTIVE COATING Health: SERIOUS Fire: SERIOUS Reactivity: MINIMAL Whmis Class B: B2 Whmis Class D: D1A TDG Class: 3.2 TDG UN: 1263 SECTION I - MATERIAL IDENTIFICATION AND USE MANUFACTURER'S NAME : Quality Products, Inc. ADDRESS : 123 South Avenue Salem, Oregon EMERGENCY PHONE : 800-933-0000 DATE REVISED: January, 1996 INFORMATION PHONE : 503-993-1111 SECTION II - HAZARDOUS INGREDIENTS OF MATERIAL HAZARDOUS INGREDIENTS CONCENTRATION % CAS NUM. Toluene 40-70 108-88-3 Methanol 10-30 67-56-1 Methyl Isobutyl Ketone 7-13 108-10-1 Methyl Ethyl Ketone 7-13 78-93-3 SECTION III - PHYSICAL DATA FOR MATERIAL / CHEMICAL CHARACTERISTICS PHYSICAL STATE: Liquid ODOR: Ketone COLOR: Clear Liquid SPECIFIC GRAVITY: 0.825-0.875 SOLUBILITY IN WATER: 26.47/20c Pct VOLATILE/VOLUME: 100% VAPOR PRESSURE (mm): N/A VAPOR DENSITY (air=1): 3.10 EVAPORATION RATE (nbuac=1): 2.24 BOILING POINT (c): 64.60 FREEZING POINT (c): N/A ph: N/A COEFFICIENT OF WATER/OIL DISTRIBUTION: N/A SECTION IV - FIRE AND EXPLOSION HAZARD OF MATERIAL FLAMMABILITY: Yes, By Open flame, sparks, Excessive Heat, Smoking and other Sources of Ignition MEANS OF EXTINCTION: Dry Chemical, Carbon Dioxide, Foam, Water Fog. SPECIAL PROCEDURES: do not enter confined fire space without adequate protective clothing and an approved positive selfcontained breathing apparatus. Exclude air. Do not use water except as a fog. Use water to cool fire exposed containers. EXPLOSION: Vapor forms explosive mixture with air between upper and lower flammable limits. FLASH POINT (c) and METHOD: -5.00 AUTO IGNITION (c): N/A Upper Explosion Limit (% By Volume): 36.50 Lower Explosion Limit (% By Volume): 1.00 HAZARDOUS COMBUSTION PRODUCTS: Vapors may travel along ground and flashback along vapor trail. SENSITIVITY TO MECHANICAL IMPACT: None SENSITIVITY TO STATIC DISCHARGE: Yes. Example of a Completed EMS Waste Profile - Sample MSDS Page 1 of 2

Example of a Completed Waste Profile form *** Sample MATERIAL SAFETY DATA SHEET *** SECTION V - REACTIVITY DATA CHEMICAL STABILITY: Yes INCOMPATIBILITY WITH OTHER SUBSTANCES: Yes, with strong Oxidizing Agents, Mineral Acids. REACTIVITY AND UNDER WHAT CONDITIONS: Avoid excessive heat, open flame, spark and all ignition sources. HAZARDOUS DECOMPOSITION PRODUCTS: Carbon Monoxide and Carbon Dioxide when heated. SECTION VI HEALTH HAZARDS OF MATERIAL EXPOSURE LIMITS (TLV ppm): 100.00 IRRITANCY OF MATERIAL: Slight to moderate skin irritant SENSITIZATION: Not predicted to be a skin sensitizer. CARCINOGENICITY, REPRODUCTIVE EFFECTS, TERATOGENICITY and MUTAGENICITY: Chronic ingestion of methanol causes central nervous system and internal organ damage and could result in blindness and death. ROUTE OF ENTRY: Skin contact, Skin Absorption, Inhalation Acute, and Ingestion. EFFECTS OF ACUTE EXPOSURE TO MATERIAL: Direct contact with skin may cause defatting, drying and cracking. Contact with eyes may cause conjunctivitis, irritation, and inflammation of mucous membranes. Inhalation may cause irritation of eyes, nose, throat, and respiratory tract. Ingestion may cause irritation of mucous membranes of mouth and throat. EFFECTS OF CHRONIC EXPOSURE TO MATERIAL: Prolonged or repeated skin contact may cause defatting and drying resulting in irritation and possible dermatitis. Prolonged exposure to high vapor concentrations can cause headache, dizziness, nausea CNS depression and narcosis. Ingestion may cause nausea, vomiting, diarrhea. SECTION VII - FIRST AID MEASURES INHALATION: Remove to fresh air. If not breathing give artificial respiration. Obtain medical attention immediately. SKIN CONTACT: Flush with water and affected areas with mild soap and water. Remove contaminated clothing. EYE CONTACT: Flush eyes with water for at least 15 minutes holding eyelids open. Obtain medical attention immediately. INGESTION: Do not induce vomiting. Obtain medical attention immediately. ADDITIONAL INFORMATION: If ingested accidentally guard against aspiration of liquid into lungs producing chemical pneumonitis. Cardiac arrhythmia has been reported with solvent exposure. SECTION VIII - CONTROL MEASURES PERSONAL PROTECTIVE EQUIPMENT GLOVES: Impervious (vitron nitrile, PVC). EYES: Chemical safety goggles or full face shield. RESPIRATORY: Wear a CSA approved respirator. OTHER: Where the risk of skin exposure is higher, impervious clothing should be worn. A positive demand, self-contained or airline breathing apparatus for extremely high concentrations. ENGINEERING CONTROLS: Local and mechanical ventilation to maintain below LEL and TLV values. LEAK AND SPILL PROCEDURE: Eliminate all sources of ignition. Prevent from entering watercourses or sewers. Ventilate enclosed spaces. For large spills: Warn public of potential down wind explosion hazard due to flash back of flammable vapors. Contain by dyking. Recover product and collect contaminated soil or water for treatment and/or disposal. For small spills: Contain by applying sorbent. Collect waste sorbent and contaminated soil for disposal. Notify appropriate environmental agency. WASTE DISPOSAL: Reclaim or dispose of waste material in an approved incinerator or waste treatment disposal facility in accordance with applicable regulations by the environmental authority. HANDLING PROCEDURES AND EQUIPMENT: Flammable. Avoid breathing vapors and prolonged or repeated contact with skin. Launder contaminated clothing. Use good personal hygiene. Ground equipment. Use spark resistant tools. Avoid splash filling. STORAGE REQUIREMENT: Keep container closed. Store in a cool, dry, well-ventilated area, from heat and ignition sources. SPECIAL SHIPPING INFORMATION: Handle as flammable liquid. Example of a Completed EMS Waste Profile - Sample MSDS Page 2 of 2

Example of a Completed Waste Profile form EMS WASTE PROFILE Name, Trade Name, or Waste Description Lacquer Thinner List Components of Mixture (e.g. Dura Stripe Part A & Part B) NA This Waste Profile was completed using the MSDS. Box (Answers the Question "Is this a Hazardous Waste?") No Yes - List s F003, F005, D001 Use / Description (primary use) Solvent This Waste Profile was completed using lab analysis. INSTRUCTIONS Complete this form using the MSDS or the results of lab testing to determine if a waste is classified as hazardous. Complete one profile for each waste. Additional information on characterizing waste is located in Appendix D of the EMS Manual. Answer ALL questions. If a MSDS is used to complete this form, the CAS numbers should be used to verify that the correct substance has been identified. "CAS numbers" are assigned by the Chemical Abstract Service. Each specific chemical compound is given a separate number. The CAS number will remain the same even when substances are listed by trade names. If the answer to any of the questions is "yes" the waste must be tracked on the EMS Waste Generation and Waste Disposal Logs. If the answer to any of questions 3-13 is "yes" the waste is considered hazardous; check "yes" in the Box (above). The amount of hazardous waste generated each month is used to determine the yard's hazardous waste generator status. For additional information on hazardous waste generator requirements, refer to Appendix D of the EMS Manual. If the answers to ALL questions are "no" the waste is non-hazardous; check "no" in the Box (above). Non-hazardous wastes may have disposal restrictions (e.g. liquids have to be in sealed containers). Non-hazardous wastes should be managed according to the options listed in the disposal section of the EMS Procedure for the product. Attach a copy of the MSDS(s) and/or laboratory results and file onsite. 1. 2. 3. 4. Waste Profile Questions Is this waste one of the excluded wastes below and is the waste managed according to the EMS Procedure? - Used oil - Asphalt emulsion or emulsion mixtures (e.g. diesel fuel and tack) - Used Anti-freeze Is this one of the universal wastes listed below and is the waste managed according to the EMS Procedure? - Batteries - Waste pesticides - Mercury-containing lamps - Mercury thermostats Is this waste a solvent, used as a degreaser, and does it contain a) 10% or greater of any of the substances below; or b) a total of 10% or greater of any of the substances listed in questions 4-8 and one of the substances listed below has the highest concentration. - Carbon tertrachloride (CAS # 56-23-5) - Chlorinated fluorocarbons - Methylene chloroide (CAS # 75-09-2) - Tetrachloroethylene (CAS # 127-18-4) - 1,1,1-Trichloroethane (CAS # 71-55-6) - Tricholorethylene (CAS # 79-01-6) Is this waste a solvent (not used as a degreaser) and does it contain a) 10% or greater of any of the substances below; or b) a total of 10% or greater of any of the substances listed in questions 4-8 and one of the substances listed below has the highest concentration. - Chlorobenzene (CAS # 108-90-7) - o-dichlorobenzene (CAS # 95-50-1) - Methylene chloroide (CAS # 75-09-2) - 1,1,1-Trichloroethane (CAS # 71-55-6) - 1,1,2-Trichloro-1,2,2-trifluoroethane (CAS # 76-13-1) - 1,1,2-Trichloroethane (CAS # 79-00-5) - Tetrachloroethylene (PCE or Perc) (CAS # 127-18-4) - Trichlorofluoromethane (CAS # 75-69-4) - Tricholorethylene (TCE) (CAS # 79-01-6) No Answers Yes. Check "no" in box and write "excluded". List item(s) below. stop here No Yes. Check "yes" in box and write "universal." List item below. stop here No Yes. Write "F001" in the box. List substance(s) below. No Yes. Write "F002" in the box. List substance(s) below. EMS Waste Profile Version 2 February 1, 2009 Page 3 of 4

Example of a Completed Waste Profile form List the "Name" from Page 1 (in case the pages become separated). Lacquer Thinner 5. 6. 7. Is this waste a solvent and does it contain a) 100% of any of substances listed below; or b) one of these substances and 10% or greater of any of the substances listed in Question 4, 5, 7, or 8. - Acetone - n-butyl alcohol - Cyclohexane - Ethyl acetate - Ethyl benzene - Ethyl ether - Methanol - Methyl isobutyl ketone - Xylene (CAS # 67-64-1) (CAS # 71-36-3) (CAS # 108-94-1) (CAS # 141-78-6) (CAS # 100-41-4) (CAS # 60-29-7) (CAS # 67-56-1) (CAS # 108-10-1) (CAS # 1330-20-7) Is this waste a solvent and does it contain a) 10% or greater of any of the substances below; or b) a total of 10% or greater of any of the substances listed in questions 4-8 and that one of the substances listed below has the highest concentration. - Cresols/cresyllic acid - Nitobenzene (CAS # 1319-77-3) (CAS # 98-95-3) Is this waste a solvent and does it contain a) 10% or greater of any of the substances below; or b) a total of 10% or greater of any of the substances listed in questions 4-8 and that one of the substances listed below has the highest concentration. - Benzene - Carbon disulfide - 2-Ethoxyethanol - Isobutanol - Methyl ethyl ketone - 2-Nitropropane - Pyridine - Toluene (CAS # 71-43-2) (CAS # 75-15-0) (CAS # 110-80-5) (CAS # 78-83-1) (CAS # 78-93-3) (CAS # 79-46-9) (CAS # 110-86-1) (CAS # 108-88-3) 8. Does this waste contain 3% or more of any of substance on the Listed Hazardous Waste sheet that has a code number that starts with a "P"? (See EMS Appendix D) Note: Do not include substances that have already been listed (in questions 3-7). 9 Does this waste contain 10% or more of any of substance on the Listed Hazardous Waste sheet that has a code number that starts with a "U? Note: Do not include substances that have already been listed (in questions 3-8). 10. Does this waste contain more that the regulatory level of any substance on the Listed Hazardous Waste sheet that has a code number that starts with a "D"? Note: Do not include substances that have already been listed (in questions 3-9). No Yes. Write "F003" in the box. List substance(s) below. Methanol methyl Isobutyl ketone No Yes. Write "F004" in the box. List substance(s) below. No Yes. Write "F005" in the box. List substance(s) below. Toluene Methyl Ethyl Ketone No Yes. Write the code in the box. List code, substance and below No Yes. Write the code in the box. List code, substance and below No. Yes. Write code in the box. List substances(s) below 11. Is this waste ignitable? a) a liquid with a flash point less than 140 F (60 C); or b) a solid or a gas that is capable of igniting at normal temperatures (can cause fire through friction, absorption of moisture, or spontaneous chemical change); or c) an oxidizer or ignitable compressed gas 12. Is this waste corrosive? a) a water-based liquid that has a ph equal to or less than 2; or b) a water-based liquid that has a ph equal to or greater than 12.5; or c) a liquid that corrodes steel 13. Is this waste reactive? a) normally unstable; or b) reacts violently with water; or c) capable of explosion or detonation The answers on this Waste Profile are True and Complete to the best of my ability. Name Jon Smith Signature EMS Waste Profile Version 2 February 1, 2009 Page 4 of 4 No Yes. Write "D001" in the box. List letter below. -5C No Yes. Write "D002" in the box. List letter below. No Yes. Write "D003" in the box. List letter below. Yard ODOT MAITNENANCE YARD Position TMC Date 2/02/09