COMMONWEALTH OF MASSACHUSETTS S.O.P.NO. ENV-01-03-1-000 MASSACHUSETTS DEPARTMENT OF TRANSPORTATION Page 1 of 5 HIGHWAY DIVISION STANDARD OPERATING PROCEDURES SUBJECT: Hazardous Waste Management at MassDOT DISTRIBUTION: Highway Facilities A EFFECTIVE: ISSUED: SUPERSEDES: ENV-01-03-1-000, AUTHORIZED:Signature on 11/23/10 11/23/10 Dated 8/13/10 original PURPOSE To ensure that Hazardous Waste is managed consistent with environmental regulations (reference 310 CMR 30). RESPONSIBILITY It is the responsibility of the District Maintenance Engineer or their designee to ensure that District maintenance facility personnel conduct facility Hazardous Waste Management consistent with the appropriate generator status (as defined below) and to conduct weekly inspections of Hazardous Waste accumulation areas where applicable. A copy of the Emergency Spill Response Plan For MassDOT Facilities must be available at all district maintenance facilities. The Environmental Management System Compliance Coordinator (ECC) is responsible for ensuring that inspections of each Hazardous Waste Accumulation Area occur on a regular basis, completing a regular inspection report for each facility, and maintaining records of the inspections. The ECC reports findings to the District Maintenance Engineer and to the EMS & Sustainability Unit Supervisor as necessary. The ECC is also responsible for maintaining a complete file of Very Small Quantity Generator, Small Quantity Generator, and Large Quantity Generator, generator registrations for the district and for maintaining manifests, waste profiles and land disposal restrictions for at least three years, or for the duration of any enforcement action by the Department of Environmental Protection (DEP). The ECC is responsible for arranging and/or overseeing the removal and disposal of the Hazardous Waste by a licensed transporter and disposal facility. POLICY For the purpose of this policy MassDOT Highway Division Facilities fall into one of four categories: (1) Not a Hazardous Waste Generator; (2) Very Small Quantity Generator; (3) Small Quantity Generator; (4) Large Quantity Generator. Accumulation Areas Hazardous Waste Accumulation Areas shall be set up in accordance with hazardous waste regulations at generating facilities. The following standards apply to all MassDOT Hazardous Waste Accumulation Areas:
COMMONWEALTH OF MASSACHUSETTS S.O.P.NO. ENV-01-03-1-000 MASSACHUSETTS DEPARTMENT OF TRANSPORTATION Page 2 of 5 HIGHWAY DIVISION STANDARD OPERATING PROCEDURES SUBJECT: Hazardous Waste Management at MassDOT DISTRIBUTION: Highway Facilities A EFFECTIVE: ISSUED: SUPERSEDES: ENV-01-03-1-000, AUTHORIZED:Signature on 11/23/10 11/23/10 Dated 8/13/10 original They will be located indoors, secured against unauthorized entry, separated from points of generation. Stand alone weatherproof storage units separated from main facility buildings are allowed; The accumulation area boundaries will be designated (using tape on floor or painted lines, cones, rope or other appropriate means; A HAZARDOUS WASTE sign (all capital letters, one-inch high) shall be prominently posted; If hazardous waste containers are not stored on spill pallets the floor surface shall be free from cracks or gaps and impervious to the Hazardous Wastes being stored; A minimum of 18 inches of aisle space around the drums shall be maintained; Single drums maybe stored along walls in an appropriate location; The Hazardous Waste Accumulation Area shall contain only Hazardous Waste and associated equipment. No virgin product and/or hazardous materials shall be stored in the Hazardous Waste Accumulation Area; Containers such as 55-gallon drums shall not be stacked unless separated by a pallet. Accumulation areas at SQGs and LQGs are inspected weekly by the designated facility personnel. A sample weekly inspection form is attached. The Weekly Hazardous Waste Inspection Form must be kept on file at the facility or at the ECC s discretion be submitted to the respective ECCs office where a file is maintained. Inspections forms shall be kept on file for one year. Generator Status - Time Limits and Quantity Limits The following accumulation limits shall not be exceeded: Very Small Quantity Generators (VSQGs) 2,200 pounds, 270 gallons/or five 55-gallon drums, at a rate of no more than 220 ponds per month or equivalent For Small Quantity Generators (SQGs) 13,200 pounds/or 1620 gallons or twenty-eight 55-gallon drums at a rate of no more than 220 ponds per month or equivalent For Large Quantity Generators (LQGs) No volume limit. No time limits for storage of hazardous waste apply to VSQGs. The time limit for the storage of hazardous waste at SQGs is as follows: 180 days from the date accumulation starts. The start date must be marked on the drum once accumulation starts. The time limit for the storage of hazardous waste at LQGs is as follows: 90 days from the date accumulation starts. The start date must be marked on the drum once accumulation starts.
COMMONWEALTH OF MASSACHUSETTS S.O.P.NO. ENV-01-03-1-000 MASSACHUSETTS DEPARTMENT OF TRANSPORTATION Page 3 of 5 HIGHWAY DIVISION STANDARD OPERATING PROCEDURES SUBJECT: Hazardous Waste Management at MassDOT DISTRIBUTION: Highway Facilities A EFFECTIVE: ISSUED: SUPERSEDES: ENV-01-03-1-000, AUTHORIZED:Signature on 11/23/10 11/23/10 Dated 8/13/10 original Satellite Accumulation Areas The following standards apply to Satellite Accumulation Areas operated at MassDOT Highway Maintenance Facilities: Up to 55 gallons of Hazardous Waste may be generated from a process at the location of the satellite accumulation; Storage time is 90 days (LQG) or 180 days (SQG) from the date the first 220 pounds (approximately one 55-gallon drum) has been accumulated; Only one container may be in use at one time in a satellite location; Each satellite accumulation area must be managed by the person who is directly responsible for the process producing the waste; The waste must be moved to the designated Accumulation Area within three days after the container is full; Hazardous Waste Containers The following standards apply to Hazardous Waste containers stored at MassDOT Highway Maintenance Facilities: All containers must be clearly labeled with the words HAZARDOUS WASTE, the name of the waste (i.e. waste oil, paint waste, waste gasoline); the type of hazard (i.e. toxic flammable, corrosive); and for LQGs and SQGs only, the date on which accumulation began; for satellite storage areas containers must be dated once they are full; All containers must be closed except when waste is being added or removed; Wastes of different types must be segregated and kept within the boundaries of accumulation area; Containers holding Ignitable or Reactive wastes must be kept at least 50 feet from the property line. Self Transporting Requirements The following standards apply for self-transporting any quantity of Hazardous Waste from MassDOT Highway Facilities:
COMMONWEALTH OF MASSACHUSETTS S.O.P.NO. ENV-01-03-1-000 MASSACHUSETTS DEPARTMENT OF TRANSPORTATION Page 4 of 5 HIGHWAY DIVISION STANDARD OPERATING PROCEDURES SUBJECT: Hazardous Waste Management at MassDOT DISTRIBUTION: Highway Facilities A EFFECTIVE: ISSUED: SUPERSEDES: ENV-01-03-1-000, AUTHORIZED:Signature on 11/23/10 11/23/10 Dated 8/13/10 original A copy of the VSQG Generator Registration Number must be present in the self-transporting vehicle.; Only VSQG can self transport to an SQG or LQG Only waste generated at the facility may be self-transported pursuant to this SOP; A maximum of 55 gallons of Hazardous Waste may be transported at one time; The container must be tightly sealed and labeled with HAZARDOUS WASTE, the name of the waste, and the hazard type; The container must be tightly secured to the vehicle; A two-part receipt must be used to track the origin and destination of all Hazardous Wastes. An example form is attached. Copies are also available from the District ECC; Notify the Department of Environmental Protection, State Police or National Response in the event of a spill; phone numbers are posted by facility phones; Federal Department of Transportation (USDOT) and Massachusetts Department of Public Safety requirements must be met. This includes the use of a USDOT shipping label for waste other than oil. Used Vehicle Filters Used oil, diesel and gasoline filters must be drained into a properly labeled hazardous waste container until the filter is free from flowing liquid. The liquid content from motor oil and diesel fuel filters must be drained into a designated waste oil drum. Gasoline, from gasoline filters, must be drained into a waste gasoline drum. Under no circumstances should the waste gasoline be mixed with waste oil. *Note: Prior to draining, used oil filters will be punctured from the top side, with a sharp device capable of penetrating the outer metal casing as well as penetrating an inner valve located inside the center of the filter. This will allow for trapped oil to completely drain out. Filters do not need to be drained for more than 24- hours. The drained filters must then be stored in a closeable drum, which has been designated and labeled for this purpose. The drum containing the used oil/diesel filters should be labeled as a non-hazardous waste. When the drums are filled with drained filters, the designated facility personnel shall notify the ECC and/or arrange for proper disposal/recycling. Cathode Ray Tubes Cathode ray tubes, televisions and computer monitors that are collected during roadside pickup activities shall be transported to a designated solid waste accumulation area. Do not attempt to dismantle cathode ray tubes; dangerous levels of high voltage are stored in cathode ray tubes for varying periods of time. Cathode Ray Tube Handling and Recycling Store and handle in a manner that minimizes breakage. The ECC shall track the accumulation of the cathode ray tubes and make arrangements for recycling at least on a yearly schedule or as necessary.
COMMONWEALTH OF MASSACHUSETTS S.O.P.NO. ENV-01-03-1-000 MASSACHUSETTS DEPARTMENT OF TRANSPORTATION Page 5 of 5 HIGHWAY DIVISION STANDARD OPERATING PROCEDURES SUBJECT: Hazardous Waste Management at MassDOT DISTRIBUTION: Highway Facilities A EFFECTIVE: ISSUED: SUPERSEDES: ENV-01-03-1-000, AUTHORIZED:Signature on 11/23/10 11/23/10 Dated 8/13/10 original Record Keeping Copies of Facility VSQG, SQG, or LQG Generator registration numbers shall be on file at each facility or available at district headquarters. A Hazardous Waste Accumulation Log shall be completed as part of the regular facility inspection as described in SOP 31 Performing Facility Environmental Compliance Inspections. Designated facility personnel shall complete Weekly Hazardous Waste Inspection Forms. A copy of the form shall be kept on file at the facility or at their discretion submitted to the Environmental Compliance Coordinator. The ECC shall ensure completion of a regular inspection report for each facility and maintain records of the inspection. Two-part receipts for self-transporting Hazardous Waste shall be used whenever a facility transports its waste to another MassDOT Highway Facility. The generating facility keeps the top half of the form for its records and the receiving facility keeps the bottom half for its records. Upon the request of the ECC, both the generating and receiving facilities must provide a copy of their paperwork for review. These receipts must be filed for at least three years or for the duration of any enforcement action by DEP. Hazardous Waste manifests shall be used any time a Hazardous Waste is removed by a licensed waste hauler. ECCs, Boston Environmental Services personnel, and properly trained district maintenance personnel, are the only MassDOT personnel authorized to sign manifests on behalf of the Department. The ECCs and/or Districts shall maintain manifests waste profiles and land disposal restrictions for at least three years or for the duration of any enforcement action by DEP. Emergency Response Procedures The following emergency response procedures apply to MassDOT Highway Facilities: An example of an Emergency Call Down Sheet is attached. These sheets shall be prominently posted near each telephone at the facility. Each facility shall maintain a copy of the Emergency Spill Response Plan For MassDOT Highway Facilities; A map showing the location of fire control equipment alarms, evacuation route, and directions to the nearest hospital shall be prominently posted at the facility (SQGs only); Adequate quantities of spill control equipment shall be readily available at each facility; Serviceable fire extinguishers shall be located in the vicinity of the hazardous waste accumulation area; An adequate supply and pressure of water, automatic sprinklers or water sprays or foam-producing equipment shall be available as required; An alarm or communication system that can provide emergency notification to employees; A telephone, two-way radio or other communication device that can summon police, fire or emergency response teams shall be immediately accessible from the hazardous waste accumulation area.
Massachusetts Department of Transportation Highway Facility RCRA Hazardous Waste Generator Emergency Response Plan Preparation Date: December 1, 2010
Massachusetts Department of Transportation Highway Facility RCRA Hazardous Waste Generator Emergency Response Plan Table of Contents 1. Emergency Coordinator......1 2. Emergency Contact List.......1 3. Available Spill Equipment and Resources... 2 3.1 Description of Emergency Resources at Hazardous Waste Facilities..2 3.2 Site-Specific Emergency Equipment List...2 4. Emergency Prevention Systems..3 4.1 Prevention of Fire, Explosion, or Chemical Reaction 3 4.2 Hazardous Waste Loading/Unloading Safety Procedures.3 4.3 Storm Water Pollution Prevention and Drainage Controls..3 4.4 Power Outage or Equipment failure.4 4.5 Protection of the Public and the Environment during Emergencies..4 4.6 Personnel Exposure Protection..4 5.0 Emergency Evacuation Procedures 5
1. Emergency Coordinator Each MassDOT facility which generates or accumulates hazardous wastes shall at all times have an emergency coordinator either on the facility premises, or, to the extent the facility's operations make this option appropriate, on call and available to respond to an emergency by reaching the facility within one hour. The emergency coordinator shall have the responsibility for coordinating all emergency response measures. This emergency coordinator shall 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. The coordinator shall have access to all parts of the facility. In addition, this individual shall have the authority to spend or use whatever is necessary to carry out the contingency plan. The Emergency Coordinator for MassDOT hazardous waste facilities is the District Maintenance Engineer for the district in which the facility is located. If the DME is unavailable, the alternates listed in Section 2.0 by order of ranking shall serve as the Emergency Coordinator. 2. Emergency Contact List In the event of a Hazardous Materials/Waste emergency, personnel shall contact the Emergency Coordinator immediately, or, in the case of fire, explosion, or other lifethreatening emergency, as soon as possible after notifying local fire, police, ambulance and/or other Emergency First-Responder groups. Notifying personnel should continue calling each person on the contact list until the emergency coordinator or an alternate is reached. Report to the Emergency Coordinator the location and nature of the incident, type and estimated volume of materials involved, environmental impacts, and the identity of any other emergency services contacted. Follow the instructions of the Emergency Coordinator, and report back any new developments on a frequent basis. [ Insert site/district specific contacts list here.]
3. Available Spill Equipment and Resources 3.1 Description of Emergency Resources at Hazardous Waste Facilities MassDOT facilities which generate and/or accumulate hazardous wastes have spill kits on premises, in close proximity to but outside the hazardous waste accumulation area. The spill kits contain an assortment of absorbent booms and pads, plastic bags, personal protective clothing (tyvek suits, gloves) for use in containing a small spill of hazardous waste material. Supplies of granular absorbents, drain blocker pads, neoprene rubber dikes, brooms, shovels, waste accumulation drums, and other spill containment and cleanup equipment are also available at each facility, or can otherwise be mobilized from a nearby facility. 3.2 Site-Specific Emergency Equipment List The specific Emergency Equipment available to facility personnel in the event of a hazardous waste emergency incident, is presented in Attachment 1. The list shall be kept up-to-date and include the location and a physical description of each item on the list, and a brief outline of its capabilities. Equipment locations may be depicted on the site-specific Facility Environmental Compliance Maps to assist personnel and responders. [The following table shall be completed by the ECC for each facility, and be updated annually or whenever there is a change in equipment or related information. The list can be extended as needed but must include at a minimum those items already listed] Emergency Equipment List MassDOT [Facility Name/ID] [as of Date] Equipment Type Location at Facility Use/Capabilities 1. Spill Kit 2. Fire Extinguisher 3. First Aid Kit 4. 5. 6. 7. 8. 9. 10.
4. Emergency Prevention Systems 4.1 Prevention of Fire, Explosion, or Chemical Reaction MassDOT maintenance facilities typically may generate and accumulate waste lubricating and hydraulic oils, diesel fuel, gasoline, and paint related materials, all of which are combustible or flammable. Hazardous wastes are accumulated either inside the facility maintenance garage on spill containment pallets (generally at VSQG facilities) in a designated location and separate from other materials, or; in an outdoor fire-rated hazardous waste shed with secondary containment and ventilation. To mitigate the potential for fire or explosion, MassDOT personnel must keep all waste containers tightly closed except when adding material to a waste container, strictly observe smoking bans, and ensure ignition sources such as welding torches are shut off when decanting hazardous waste materials. Non-hazardous oily rags and other absorbents are stored away from waste accumulation areas, in fire-resistant safety canisters which are emptied daily, to prevent spontaneous combustion. MassDOT facilities seldom if ever generate other hazardous waste materials that may be incompatible with the above routinely generated wastes. When special circumstance arise where a non-compatible waste is generated that may react with other waste materials (i.e. battery acid, alkaline materials, chlorine bleach, etc.) the material is moved to an isolated hazardous waste storage shed at the facility if available, self-transported to another facility for isolated storage subject to waste generator status, or immediately collected for transport to a TSD facility by a licensed waste hauler. 4.2 Hazardous Waste Loading/Unloading Safety Procedures During transfer of hazardous waste drums and other containers from garages to storage sheds, or from sheds to a TSD transport vehicle, all MassDOT and contractor personnel shall use proper drum lifting tools such as overhead drum clamps, drum lifting forks, drum dollies or other devices designed specifically for such purpose. Persons involved in container transfers should be outfitted with proper work attire including steel toe boots, work gloves, hard hat and eye protection. A spill kit or adequate supply of absorbent or containment materials should be near by in the event of a spill during transfer of containers. 4.3 Storm Water Pollution Prevention and Drainage Controls To prevent contamination of stormwater from hazardous wastes generated at MassDOT facilities, routine vehicle maintenance and repairs and other hazardous
waste generation activities are performed indoors whenever possible. When outdoor vehicle or equipment repairs are required, spill containment pads, buckets or other means to collect spillage must be employed. Hazardous waste containers are stored indoors and provided secondary containment in the event of a leaking container. Transfer of full hazardous waste containers from satellite accumulation areas to outdoor sheds, or from accumulation areas or sheds to a transport vehicle should only be performed in dry weather whenever possible. Hazardous waste accumulation sheds will be located as far from drainage structures or nearby receiving waters or wetlands as possible. Small Quantity Generator facilities which handle hazardous waste and which are not equipped with storm drains fitted with oil/grease traps will have readily available for deployment, drain-block pads made from Neoprene, latex, or other suitable material to seal off storm drains in the event of spill while transferring hazardous waste outdoors to or from accumulation areas. 4.4 Power Outage or Equipment failure Power outages would have no significant affect on routine MassDOT hazardous waste operations. Hazardous wastes at MassDOT facilities are not managed or processed via any mechanical equipment, therefore equipment failure has no bearing on MassDOT hazardous waste management. 4.5 Protection of the Public and the Environment during Emergencies MassDOT facilities are gated, and restricted from access by the general public. Hazardous wastes are stored at least 50 feet from the adjacent property boundaries as per state and federal requirements. Due to the limited volume and types of hazardous wastes generated and accumulated at MassDOT facilities, a hazardous waste emergency at the facility is unlikely to pose any threat to the general public. As indicated elsewhere in this plan, adequate spill containment materials, secondary containment, and fire/explosion-proof accumulation sheds are provided for the protection of the environment and public health and welfare. 4.6 Personnel Exposure Protection Persons engaged in Hazardous Waste operations, whether routine or emergency, shall wear appropriate Personal Protective Equipment suited to the nature of the work being performed and the hazardous waste being generated or handled. This includes work coveralls, work gloves, eye protection and where appropriate, protective rubber gloves for equipment repair activities. Activities involving transfers of hazardous wastes to or from containers, or spill cleanup shall also require the use of heavy duty rubber gloves or work gloves with surgical latex
gloves as liners; coveralls, tyvek, or other splash protection, eye protection (full face protection if skin irritant). In the event of a fire involving hazardous wastes, or spills of highly flammable wastes such as gasoline, MassDOT personnel should evacuate the area and notify the Fire Department, the Emergency Coordinator and other necessary emergency services immediately. 5.0 Emergency Evacuation Procedures Most MassDOT facilities engaged in hazardous waste activities are small to large, open vehicle garages with few personnel. If an emergency occurs that would require evacuation of the buildings or facility, persons discovering the emergency should alert others in the garage by yelling an appropriate warning (i.e. Fire ) contact emergency services, and then if safe to do so, attempt to determine if anyone else is in the building that may not have heard the alert, and evacuate as required. A plan of the facility, showing all exits shall be posted at various highly visible locations throughout the facility. A hazardous waste emergency at a maintenance facility located at the District Administrative Headquarters, may result in evacuation of the administration building or the entire property. In such cases, the general emergency evacuation plan for the building should be implemented, and attached to this plan for reference.
DISTRICT AREA FACILITY EMERGENCY CALL DOWN SHEET PRIMARY EMERGENCY COORDINATOR NAME: PHONE: CELL PAGER RADIO ID#: SECONDARY EMERGENCY COORDINATOR NAME: PHONE: CELL RADIO ID: ENVIRONMENTAL COMPLIANCE COORDINATOR NAME: PHONE: CELL RADIO ID#: daytime only SAFETY INSPECTOR NAME: PHONE: CELL RADIO ID#: LOCAL FIRE /POLICE DEPARTMENT STATE POLICE MADEP 1-888-304-1133 EPA NATIONAL RESPONSE CENTER 1-800-424-8802
HAZARDOUS WASTE SELF-TRANSPORT FORM HAZARDOUS WASTE RECEIPT Generating Facility/Depot copy Generating Facility/District Hazardous Waste Generator ID # Receiving Facility/District Hazardous Waste Generator ID # TYPE OF WASTE VOLUME SIGNATURE Delivering DATE SIGNATURE Receiving DATE KEEP THIS COPY FOR FACILITY FILES ----CUT HERE----------------------------------------------------------------------CUT HERE---- HAZARDOUS WASTE SELF-TRANSPORT FORM HAZARDOUS WASTE RECEIPT Receiving Facility/Depot copy Generating Facility/District Hazardous Waste Generator ID # Receiving Facility/District Hazardous Waste Generator ID # TYPE OF WASTE VOLUME SIGNATURE Delivering DATE SIGNATURE Receiving DATE KEEP THIS COPY FOR FACILITY FILES
WEEKLY HAZARDOUS WASTE STORAGE INSPECTION CHECKLIST FACILITY NAME INSPECTOR DATE 1. Are all hazardous wastes and waste oil stored within the designated accumulation area? yes no 2. Are the containers used to store haz waste in good condition? (Check for leaks, yes no corrosion, bulges, etc.) 3. Are containers labeled with the words Hazardous Waste, name of contents, hazard yes no associated with the waste, and for SQGs the accumulation start date? 4. Is the waste compatible with the container and/or its liner? yes no 5. Are all containers tightly closed? yes no 6. Is adequate aisle space maintained for container inspection? yes no 7. Are minor spills immediately cleaned up using appropriate absorbent material? yes no 8. Are waste oil drip pans and buckets immediately emptied into the waste oil drum? yes no 9. Are usable material and oils stored outside the hazardous waste storage area? yes no FOR ANY QUESTION ANSWERED WITH NO, EXPLAIN HERE: **NOTE: COMPLETE FORM EACH WEEK AND KEEP ALL COPIES ON FILE DISTRICT EMS COMPLIANCE COORDINATOR: PHONE: CELL: