Attachment 14-Hazardous Waste Management Plan 2014.pdf

HAZARDOUS WASTE MANAGEMENT PLAN

(HWMP)

FOR THE

FEDERAL LAW ENFORCEMENT

TRAINING CENTER

(FLETC)

Artesia, New Mexico

I. INTRODUCTION/SCOPE

The Federal Law Enforcement Training Center (FLETC) Office of Artesia Operations (OAO), Maintenance

Construction Branch (MCB), Environmental Services Office (ESO) provides this document to clarify and formalize the waste program, procedures, and intra‐facility responsibilities for maintaining safe and efficient accumulation, handling, documentation, transport and disposal of all hazardous and non‐ hazardous waste generated at the Main Campus and Range Complex, hereafter referred to as the

Facility.

The FLETC recognizes its responsibility to ensure that all campus activities involving hazardous materials and hazardous wastes are conducted in a manner that provides for the safety and security of employees, students, the general public and the environment. Furthermore, the Facility understands its obligation to conduct these operations in compliance with all applicable Federal, state and local regulations.

In order for the FLETC to fulfill these responsibilities and obligations, specific procedures have been developed. The guidelines detailed in this plan are designed to provide for the safe management of hazardous materials and hazardous wastes throughout the Facility.

The ESO provides this plan in an effort to achieve the following objectives:

Protect the environment by using sound principles of handling, treatment, storage and disposal of hazardous materials and waste.

Minimize the generation as well as the cost of handling and disposing of spent hazardous materials.

Ensure a safe and healthful work environment for employees, students and visitors

The proper management of hazardous materials and wastes at the Facility requires a partnership between the many groups involved. The specific functions and responsibilities of each are identified herein. Through the cooperative efforts of Facility staff and the use of the guidelines presented in this plan, these objectives can be fully accomplished.

FUNCTIONS AND RESPONSIBILITIES:

The management of hazardous chemical waste in a comprehensive campus setting is complex. The specific functions and responsibilities are delegated to various organizational and agency entities from the Director to individual staff members:

Individual Employees (Government, Contractor and otherwise)

The success of the Facility hazardous chemical management program requires that all administrative, facility support, instructors and other individuals who work with hazardous chemicals follow the guidelines presented in this plan. Individuals have a responsibility to:

Collect all hazardous wastes in accordance with established guidelines.

Identify all spent or surplus materials using available technical knowledge within the department or section.

Package and label all chemicals in accordance with established guidelines.

Consult with supervisors and/or the ESO regarding the safe handling and proper disposal of hazardous chemicals.

Supervisors

The primary responsibility of the supervisor or instructor is to ensure that the policies and guidelines established in this plan are strictly followed by personnel under their supervision. Generally the supervisors has responsibility for oversight of the chemical identification and labeling, waste accumulation, logging, and handling minor spill clean‐up, and housekeeping at the generation and accumulation areas

ESO

The ESO is responsible for the development and implementation of proper management practices for all hazardous chemical wastes and hazardous materials at the Facility. To fulfill this responsibility, the following functions are coordinated by ESO:

Develop and implement policies with regard to hazardous waste and material management.

Prepare applications for federal, state and local permits to properly generate and dispose of hazardous chemical waste and other applicable wastes.

Help ensure that FLETC policies and regulatory guidelines regarding the proper disposal of hazardous chemical waste are followed.

Prepare, submit and maintain records, reports and manifests as required by regulation.

Audit hazardous material management practices and disposal procedures for hazardous waste.

Operate Permitted, 180‐Day Hazardous Waste Storage Facilities for the Facility.

Develop and coordinate programs that minimize the generation of hazardous wastes.

Federal Law Enforcement Training Center, Artesia Area of Operations

Ultimately the Director of FLETC, OAO with the MCB – ESO are responsible for all Facility environmental.

The responsibility for ensuring safe work practices and adherence to established policies and guidelines is delegated through the normal chain of authority within the Facility and other partner organizations, to the directors, department heads, principal investigators, supervisors and ultimately each employee.

II. HAZARDOUS WASTE MANAGEMENT:

Each year the Facility manages approximately 40,000 pounds of hazardous waste and surplus chemicals collected from ranges, workplaces and stockrooms on campus.

The Facility generates and manages hazardous wastes at 14 established Satellite Accumulation Areas

(SAA). The hazardous waste generated are transferred by the ESO or other designated environmental service providers to one of two EPA Permitted 180‐Day HWSF’s located at the Main Campus, Building

24; and Range Complex, Building 70.

The Waste/Material Tracking form is prepared for each container received for disposal, and a container number is assigned to ensure that all waste is accounted for and disposed of properly. Ultimately all waste is shipped via commercial disposal contractor to either an Environmental Protection Agency (EPA) approved waste disposal facility, or certified recycle center for recovery.

Chemicals disposed of through commercial hazardous waste vendors are either incinerated, fuel‐ blended for energy recovery, or treated to meet EPA mandated standards prior to secure landfilling.

Biological, radiological and special waste are also collected, tracked and sent for proper disposal.

HAZARDOUS WASTE DEFINITION:

Hazardous Chemical Waste

The 1976 Resource Conservation and Recovery Act (RCRA), Part 261, Subpart C provides the definition of hazardous (chemical) waste for which EPA has issued regulations. Generally the identification of hazardous waste can be determined if the material is included in either of two categories ‐‐ it is either a characteristically hazardous waste or it is listed hazardous waste.

The waste is considered hazardous if due to its quantity, concentration, or physical and chemical characteristics may:

cause, or significantly contribute to, an increase in mortality or an increase in serious or incapacitating illness; or pose a substantial present or potential threat to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.

The disposal of regulated waste and other unwanted chemicals has become increasingly complicated.

The EPA and the New Mexico Environmental Division oversee the accumulation, treatment and disposal of regulated wastes in New Mexico. This section will provide a better understanding of materials that are regulated. Ideally the generator will use this information to assess processes with waste minimization in mind, and dispose of chemical waste in a manner consistent with legal requirements.

Characteristically Hazardous Waste

The Code of Federal Regulations (40 CFR 261.20 ‐ 261.24) and RCRA define the four fundamental characteristics of regulated hazardous waste as: ignitability, corrosivity, reactivity, and toxicity characteristics.

A waste demonstrating any of these characteristics is a hazardous waste whether it is listed or not

Ignitability ‐ Ignitable wastes are spent materials exhibiting one or more of the following characteristics:

Liquids that have a flash point less than 60°C (140°F) other than aqueous solutions containing less than 24% alcohol by volume.

Materials other than liquids that are capable, under standard temperature and pressure, of causing fire by friction, adsorption of moisture, or spontaneous chemical changes and, when ignited, burn so vigorously and persistently that they create a hazard.

An ignitable compressed gas, including those that form flammable mixtures with air.

Oxidizers that stimulate combustion of organic materials.

Examples ‐ most common organic solvents, gases such as hydrogen and hydrocarbons, and certain nitrate salts.

Corrosivity ‐ Corrosives are materials meeting one or more of the following criteria:

Aqueous solutions with a pH of less than or equal to 2 or greater than or equal to 12.5.

Liquid substances which corrode steel at a rate greater than 6.35 millimeters (0.250 inches) per year at a test temperature of 55°C (130°F).

Examples ‐ Most common laboratory acids and bases as well as some amines and solutions of certain metal salts (e.g., a 0.1M aqueous solution of ferric chloride has a pH of 2.0).

Reactivity ‐ Reactive materials are defined as materials meeting one or more of the following criteria:

Is normally unstable or reacts violently (without detonating).

Reacts violently with water.

Forms explosive mixtures with water..

Materials which, when mixed with water, generate toxic gases, vapors, or fumes dangerous to human health or the environment.

Contains cyanide or sulfide and generates toxic gases, vapors or fumes between pH 2 and 12.5.

Materials capable of detonation or explosive reaction when subjected to a strong initiating source or if heated in confinement.

Capable of detonation or explosive decomposition at standard temperature and pressure.

Examples ‐Alkali metals, peroxides, and cyanide and sulfide compounds.

Toxicity ‐ Toxicity is established through the Toxicity Characteristic Leaching Procedure (TCLP), which measures the tendency of certain toxic materials to be leached (extracted) from the waste material under conditions that the waste would be exposed to in a landfill. A waste demonstrates a TCLP characteristic if a representative sample taken according to prescribed EPA extraction procedure contains any of the following substances in excess of concentration limits.

Arsenic Barium

Benzene Cadmium

Carbon tetrachloride Chlordane

Chlorobenzene Chloroform

Chromium (hexavalent o‐Cresol m‐Cresol p‐Cresol

2,4‐Dichlorophenoxyacetic acid 1,4‐Dichlorobenzene

1,2‐Dichloroethane 1,1‐Dichloroethylene

2,4‐Dinitrotoluene Endrin

Heptachlor (and its epoxide) Hexachlorobenzene

Hexachlorobutadiene Hexachloroethane

Lead Lindane (hexachlorocyclohexane)

Mercury Methoxychlor

Methyl ethyl ketone Nitrobenzene

Pentachlorophenol Pyridine

Selenium Silver

Tetrachloroethylene Toxaphene (chlorinated camphene)

Trichloroethylene 2,4,5‐Trichlorophenol

2,4,6‐Trichlorophenol 2‐(2,4,5‐Trichlorophenoxy)propionic acid (Silvex)

Vinyl chloride

The levels at which these chemicals are regulated varies from 0.2 ppm to 400 ppm. These levels are very low. If a waste contains one or more of these components it should be considered to be hazardous waste unless TCLP analysis shows it to be below the regulatory limit.

The eight metals listed here are regulated in both their pure forms and as compounds (e.g. lead, lead paint, lead oxide, and tetraethyl lead are all regulated wastes).

Listed Hazardous Waste

In addition to characteristics waste, RCRA also lists (codes) certain specific waste materials as being regulated. These materials are listed in 40 CFR sections 261.31 (the F List), 261.32 (the K list), and 261.33

(the P and U Lists).

F List ‐ the F List addresses wastes from nonspecific sources (e.g., spent solvents) and is broken down into several subcategories (or codes). Five codes that are commonly applicable to laboratory wastes are:

F001 Code ‐ spent solvent mixtures and blends used for degreasing which contained, before use, a total of ten percent or more (by volume) of one or more of the following halogenated solvents:

o tetrachloroethylene o methylene chloride o trichloroethylene o 1,1,1‐trichloroethane o carbon tetrachloride o chlorinated fluorocarbons

F002 Code ‐ spent solvent mixtures and blends which contained, before use, a total of ten percent or more (by volume) of one or more of the following halogenated solvents:

o tetrachloroethylene o methylene chloride o trichloroethylene o 1,1,1‐trichloroethane o chlorobenzene o 1,1,2‐trichloro‐1,2,2‐trifluoroethane o ortho‐dichlorobenzene o trichlorofluoromethane o 1,1,2‐trichloroethane

F003 Code ‐ spent solvent mixtures and blends which contained, before use, a total of ten percent or more (by volume) of one or more of the following non‐halogenated solvents:

o xylene o acetone o ethyl acetate o ethyl benzene o methanolethyl ether o methyl isobutyl ketone o n‐butyl alcohol o cyclohexanone

F004 Code ‐ spent solvent mixtures and blends which contained, before use, a total of ten percent or more (by volume) of one or more of the following non‐halogenated solvents:

o cresols and cresylic acid o nitrobenzene

F005 Code ‐ spent solvent mixtures and blends which contained, before use, a total of ten percent or more (by volume) of one or more of the following non‐halogenated solvents:

o toluene o methyl ethyl ketone o carbon disulfide o isobutanol o pyridine o benzene o 2‐ethoxyethanol o 2‐nitropropane

K List ‐ this list contains waste from specific sources such as factories or industries. These definitions are generally not applicable to wastes generated at the Facility.

P List ‐ this list covers acutely hazardous wastes The criteria for this listing are as follows:

Small doses cause human mortality.

Oral LD50 = < 50 ppm by weight (mg/Kg).

Inhalation LC50 = < 2 mg/L.

Dermal LD50 = < 200 mg/Kg.

Examples ‐ nickel tetracarbonyl, phosphine, and osmium tetroxide.

U List ‐ This list addresses used and unused hazardous materials that are toxic.

Like the P list, this is applicable to many used and surplus chemicals that are disposed of by NMSU laboratories and research areas.

Examples ‐ aniline, benzene, and acetone.

Questions as to the determination of hazardous chemical waste beyond those covered here should be directed to the ESO at (575) 748‐8056.

Hazardous Biological (or Biohazardous) Wastes

Certain biological (or biohazardous) waste has been identified by the New Mexico Board of Health as waste which requires special handling to protect human health or the environment. It includes solid waste which if improperly treated or handled may serve to transmit an infectious disease(s). Biological waste is regulated by the New Mexico Environmental Division (NMED) and the New Mexico Department of Health. This waste is comprised of the following:

Microbiological

Waste

Microbiological waste includes discarded:

cultures and stocks of infectious agents and associated biologicals;

specimens from medical, pathological, pharmaceutical, research, clinical, commercial, and industrial laboratories;

live and attenuated vaccines, used disposable culture dishes; and used disposable devices used to transfer, inoculate, or mix cultures.

Animal Animal waste includes:

animal carcasses;

animal body parts;

whole blood, serum, plasma, and/or other blood components from animals; and bedding of animals intentionally exposed to pathogens.

Blood Products Human blood and blood products include:

human blood, serum, plasma, other blood components, and body fluids;

and disposable items contaminated with human blood or body fluids.

Pathological Pathological waste includes but is not limited to:

human materials including: body parts, tissues or fetuses, organs, and bulk blood and body fluids;

laboratory specimens of blood and tissue after completion of laboratory examination; and anatomical remains.

Sharps Sharps include the following, regardless of contamination:

hypodermic needles;

hypodermic syringes with attached needles;

scalpel blades;

razor blades, disposable razors, and disposable scissors used in surgery or other medical procedures; and glass Pasteur pipettes.

Sharps include but are not limited to the following, when contaminated, i.e. the presence or reasonably anticipated presence of blood, body fluids, or other infectious materials.

glass pipettes;

broken glassware;

specimen tubes;

blood culture bottles; and microscope slides.

Other Regulated, Non‐RCRA and Special Wastes

Allowable Wastewater Discharge Other regulated waste includes the wastewater discharged by the

Facility. The Artesia Water Treatment Facility allows the discharge of the following:

Rain waters recovered form Indoor Range Cleaning operations performed IWA ESO approved procedures.

Special landfill and other waste Special landfill wastes are wastes which are regulated by the New

Mexico Environmental Division. They are not considered hazardous by the EPA definition, but must be disposed of at a permitted landfill. Examples include: asbestos, soils contaminated by petroleum hydrocarbons, pesticides and used oil. See the accumulation section on special waste handling.

III. HAZARDOUS WASTE ACCUMULATION AREAS

The following section pertains to requirements for RCRA hazardous waste, i.e, waste that meet the

RCRA definition, however some of procedures are used for the other types of hazardous and regulated waste.

Under RCRA, a hazardous waste accumulation area is a designated area where the hazardous waste is held and is sequentially accumulated for more than 24 hours such as the Facility 180‐Day HWSF’s.

A satellite accumulation area (SAA) is similar to the above except that it is established for a processes that generate the same or similar waste on a regular, on‐going basis, i.e. not sporadic, must be at or near the point of generation and be the location where waste initially accumulates

(i.e. is not moved from one accumulation area to another) can only be used to accumulate up to 55 gallons of hazardous waste or 1 quart of extremely hazardous waste and must be under control of the operator of the waste generating process

While regulations allow hazardous waste to accumulate and/or be held up to 180 days at one of the two hazardous waste storage facilities. No duration is specified for a container in the process of being filled at a SAA; however a full waste container must be moved to a HWSF within 3 days. Containers holding waste for less than 24 hours and/or attached to a process, which are filled automatically, are not included in this definition.

Hazardous waste generated by a FLETC activity must be held at an accumulation area and remains the responsibility of the generator until the waste has been properly identified, inspected, and accepted by

ESO service providers.

Accumulation of hazardous waste containers in the classroom and/or shop is regulated by law. It is important as a generator of hazardous waste to follow the guidelines outlined below:

All wastes generated in a classroom or shop must be stored within the same classroom or shop.

Do not allow wastes generated in another classroom or shop area to be stored within your classroom or shop.

Do not accumulate more than 55 gallons of hazardous wastes, or 1 quart of acutely hazardous waste in any one location.

Ensure that all waste containers are tightly capped except when waste material is being introduced into them.

Generally satellite accumulation areas are established at locations near the waste generation activities for convenience and to lessen the risk of spillage by allowing transport of one large container rather than numerous small container loads to a HWSF. Multiple waste containers for multiple waste streams may be in use at a satellite accumulation area at the same time. However the 55 gallon hazardous waste and 1 quart acutely hazardous waste accumulation limits for each accumulation areas remains in effect.

Accumulation Area Requirements

All Facility hazardous waste generators (any activity, operation that produces hazardous waste) are required to provide information on the waste they produce and quantities. The ESO will inspect all collection sites and ensure the existence of appropriate conditions for safe chemical handling and collection prior to implementation of accumulation activities

The Facility will establish all satellite accumulation areas/points as follows:

Satellite accumulation areas will be located at or as near as reasonable to the generating activity or work place where the hazardous waste is generated.

The accumulation areas must be located such that accidental spills and discharge will not flow into sanitary or storm water run‐off systems. Secondary containment must be provided if the accumulation area cannot be isolated from the drain or run off area.

Indoor satellite accumulation locations will be designated with yellow and black safety tape and the area shall be identified with a sign specifying that it is a waste accumulation area and listing instructions for use and spillage. The containers will be placed within secondary containment pans or other support device as required.

Outdoor SAAs will use storage containers or lockers that provide controlled access and allow for the proper management of stored waste. Each SAA shall be identified with a sign specifying that it is a waste accumulation area and listing instructions for usage and spillage.

Information on the specific wastes that may be placed in the waste container along with cleanup and personal protective equipment will be posted at or near each waste container.

A SAA logbook will be provided for use with each container. The log will be used to maintain a record of each time that waste is added to the container. Each entry must include: Initials of person adding waste, waste volume (gallons or convenient measure), and addition date.

Entries shall also be made in the SAA logbook each time waste is remover and transferred to one of the 180‐Day HWSF to demonstrate control and document its ultimate disposal, and compliance with waste storage timeline restrictions.

Accumulation Area Management

Each designated accumulation location will have a primary and alternate manager appointed by the waste organization or activities supervisor. The names and phone numbers of the primary and alternate manager will be posted at the waste container in the accumulation area

The waste generator is responsible for the proper accumulation, maintenance, and housekeeping of their satellite accumulation areas. The waste generator and the accumulation monitor from each waste generating activity must ensure that:

Waste streams are not mixed. i.e. No waste other than the normal waste stream (approved for the container) is placed in the collection container.

The list of waste components is correct and complete for each waste container. An accurate log is maintained to minimize analytical costs associated with disposal.

All leaks, spills, and releases are recorded in the log, and reported to the ESO. Unless instructed otherwise, any release should be contained and cleaned up as soon as safely and quickly as possible. Small leaks or spills around the bungs or openings of containers will be absorbed with absorbent material or rags. The materials used to pick up the spill will be disposed of as a solid hazardous waste and will be properly characterized and disposed of.

Major leaks, releases, or spills sufficient to pose a threat to human health or the environment must be reported IAW the FLETC Emergency Procedures Handbook as summarized on the back cover of the SAA Logbook, and to the Facility ESO. The accumulation monitor must ensure that all major spills are reported immediately and the appropriate evacuation action is taken.

Waste containers are to be filled to not more than 90 percent of the rated capacity of the container. Fifty‐five gallon containers must have at least 5 inches of freeboard. This will allow sufficient free space to compensate for expansion due to heating. Small containers must maintain sufficient freeboard for transportation and liquid transfer. (Freeboard is the distance between the level of the liquid and the top of the container.)

Containers will be opened, handled, filled, emptied, and stored in a manner that avoids rupture or leakage. Funnels will be used when adding waste to containers. Funnels should fit securely in the container opening and must be compatible with the waste being entered. Funnels shall be removed from container after transfer of liquid is complete. Except when necessary to add or remove waste, containers must be kept closed.

Hazardous Waste Containers:

It is important to use the proper container when collecting hazardous waste in the SAA. A hazardous waste collected in the wrong container could pose a danger to laboratory personnel, ESO personnel and

FLETC property. Container holding waste must be clean, in good condition, not leaking, and compatible with the waste being stored. Numerous accidents can be traced to the placing of hazardous material in unwashed containers that previously held incompatible waste.

The ESO has established the following guidelines for collecting hazardous waste:

Use a separate screw‐top container for each hazardous chemical waste.

Use an appropriate container size to match the amount of waste generated.

All containers must be identified and appropriately labeled (see Labeling).

Containers holding waste must be in good condition, not leaking, and compatible with the waste being stored.

The container must always be closed during storage, except when it is necessary to add waste.

Hazardous waste must not be placed in unwashed containers that previously held an incompatible material (see compatibility chart ‐ appendices).

If container holding hazardous waste begins to leak, generator must transfer it to a container that is in good condition or manage the material to prevent potential for release

Incompatible materials and container holding incompatible materials must be segregated or protected by means of a partition, wall or other device.

Container should be kept at or near the site of generation and under control of the generator.

Properly identified with completed waste sheets before pickup is requested.

Filled to a safe level (not beyond the bottom of the neck of the container or a 5‐inch head space for 55 gallon drums).

All waste containers must:

o Be clearly labeled with the words "Hazardous Waste", or "Non‐hazardous/regulated

Waste", “Universal Waste” or “Recyclable Waste” as applicable for its contents and disposal criteria.

o Be clearly marked as to their contents. (i.e. Lead Contaminated Floor Sweepings, Solvent contaminated rags, etc.)

o Use the waste/material tracking form to list specific type and amount of chemical constituents for each waste container. This list should include all diluents (water, alcohol, etc.).

Note: Do not use Red bags, Sharps containers (Biohazard), or Asbestos bags for hazardous chemical waste collection.

Hazardous Waste Compatibility:

When more than one type of hazardous waste is being discarded at one time, the integrity of the chemical compatible groups must be maintained. Incompatible waste must be segregated. For example, flammable liquids and other organics must be segregated from acidic and caustic wastes. Never mix or pack together:

Acids with bases

Flammable or combustibles with oxidizers

Cyanides with other materials

Flammable with non‐flammable solvents

Resins with the hardeners or catalysts

Partial lists regarding chemical incompatibilities, shock‐sensitive compounds and potentially explosive combinations of some common reagents and common peroxide‐forming chemicals are provided in

Table 1.

Waste Segregation Guide

The following guidelines have been developed to assist in generating a well‐defined and segregated waste stream.

Collect inorganic substances separately and do not mix solids with liquids unless the generation of a process waste is involved.

Collect halogenated and non‐halogenated organic solvents in different containers.

Collect individual non‐halogenated organic solvents separately; however, when they must be mixed, clearly indicate each constituent and state its percentage composition in the mixture.

Do not mix metals in with organic solvents. Such a mixture cannot be incinerated because of the metal or landfilled because of the organic solvent.

Recycle vacuum pump oil and do not mix with organic solvents or other chemicals. Indicate on the label and on the tracking form as "pump oil contaminated with other chemicals."

Uncontaminated pump oil may be sent to the Vehicle Maintenance Facility (Building 12) for eventual recycling.

Segregation of non‐hazardous and hazardous chemical waste has several advantages: the prevention of unwanted or potentially dangerous reactions, the protection of ESO personnel from potentially unsafe working environments, the ease in handling and disposing of wastes and the reduction of disposal costs.

Acids, Mineral, Non-oxidizing

Acids, Mineral, Oxidizing 2 H Heat Generation

Acids, Organic G H 3 F Fire

Alcohols and Glycols

H

F

P 4 G Innocuous and non-flammable gas generation

Aldehydes

P

H F

P 5 GT Toxic Gas formation

Amides

GT 6 GF Flammable Gas formation

Amines, Aliphatic and Aromatic

GT

H 7 E Explosion

Azo Compounds, Diazo Compounds and Hydrazines

H G

H

GT

H G

H 8 P Violent Polymerization

Carbamates

G

H

GT

H 9 S Solubilization of toxic substance

Caustics

G 10 U May be hazardous, but Unknown

Cyanides

GF

GT

GF

GF G

Dithiocarbamates

H,F

GF

H,F

GF

H,GT

GF

GF

U

Esters

F

G H

Ethers

F

Fluorides, Inorganic

Hydrocarbons, Aromatic

Halogenated Organics

GT

H,F

GT

H

GT

H G

GF H

Isocyanates

G

H,F

GT

H G

H P

H P

H G

H,P G

G U

Ketones

F

G H H

Mercaptans and Other Organic Sulfides

GT

GF

H,F

GT

G H H H

Metals, Alkali and Alkaline Earth, Elemental

H,F

GF

H,F

GF

H,F

GF

H,F

GF

H,F

GF

GF

H

GF

H

GF

H

GF

H

GF

H

GF

H GF,H GT

GF

H

H E

GF

H

GF

H

Metals, Other Elemental & Alloys as Powders, Vapors, or Sponges

H

H E

GF

H

Metals, Other Elemental & Alloys as Sheets, Rods, Drops, etc.

H,F G

Metals and Metal Compounds, Toxic

S

S S

Nitrides

HF

H,F E

H

GF

H,E

GF

GF

H U

H G U

GF

H GF H

GF

H

GF

H U

GF

H

H E

Nitriles

H,GT

GF

H U

P S

Nitro Compounds, Organic

E

H,E

GF

H,E

Hydrocarbons, Aliphatic, Unsaturated

E

Hydrocarbons, Aliphatic, Saturated

Peroxides and Hydroperoxides, Organic

H G

H E

H F

H G

H

GT

H,F E

H,F

GT

H,E

GT H,F GT

H E H E

H,F

GT

H E

H G

H G

H,E

GF

H,P

GT

P

Phenols and Cresols

F

H G

H P

GF

H

H H

Organophosphates, Phosphothioates, Phosphodithioates

Sulfides, Inorganic

GT

GF

HF

H E H

Epoxides

P

H P

H P

P

H P

H P

H P U

H P

H P

H P

H P

H P

H P

H P U

Combustible and Flammable Materials, Miscellaneous

H G

H,F

GT

H,F G

H,F

GF

Explosives

E

H E

H E

H E

H E

H E

H E

H E

H E E E

H E

H E

H E

H E

Polymerizable Compounds

H

P H

P H

P H

P H

P H U

P H

P H

P H

P H

P H

P H

P H

P H

Oxidizing Agents, Strong

GT

H

GT

H F

H F

H,F

GT

H,F

GT

H E

H,F

GT

H,E

GT H,F GT

H F

H F

H F

H

GT

H,F

GT

H F

H,F

GT

H,F E

H,F E

H F

H,F E

H,F

GT

H E

H F

H F

H G

H F

H,F

GT

H,F

GT

H,F G

H,F G

H E

Reducing Agents, Strong

GF

H,F

GT

H

GF

H,F

GF

H,F

GF

H

GF

H G

H

GT H F

H,F E

H E

H

GF

H

GF

H

GF

H

GF

H E

H E

H

GF

H,GT

GF H

H

GF

H E

H,P

GF

Water and Mixtures Containing Water

H G

G

H

GF

H

GF S

H

GF

GT

GF

Water Reactive Substances <---EXTREMELY REACTIVE! DO NOT MIX WITH ANY CHEMICAL OR WASTE MATERIAL! EXTREMELY REACTIVE!--->

Table 1 EPA's Chemical Compatibility Chart EPA‐600/2‐80‐076 April 1980 A METHOD FOR DETERMINING THE COMPATIBILITY OF CHEMICAL MIXTURES Please Note: This chart is intended as an indication of some of the hazards that can be expected on mixing chemical wastes. Because of the differing activities of the thousands of compounds that may be encountered, it is not possible to make any chart definitive and all inclusive. It cannot be assumed to ensure compatibility of wastes because wastes are not classified as hazardous on the chart, nor do any blanks necessarily mean that the mixture cannot result in a hazard occurring. Detailed instructions as to hazards involved in handling and disposing of any given waste should be obtained from the originator of the waste.

Flammable Wastes

Drums used for the collection of flammable materials must be grounded and bonded to the waste container before emptying the waste container into the collection drum.

Empties and Container Residues:

Empty containers of waste can be discarded as solid waste if they are properly managed. The prescribed management for an empty container varies depending on the type of waste. RCRA regulation defines an empty container and mandates its decontamination prior to disposal as solid waste. These guidelines are provided to assist you in defining and managing empty containers.

A container of hazardous (non‐acute) waste is empty by regulation if:

All wastes have been removed using common practices for the type of container.

No more than one inch of residue remains on the container bottom.

If the container is o smaller than 110 gallons and no more than 3.0% residue by weight remains or o larger than 110 gallons and no more than 0.3% residue by weight remains in the container.

A container of acutely hazardous waste (see list of acutely hazardous materials) is empty if:

It has been triple rinsed with an appropriate solvent.

It has been cleaned by a method shown to be equivalent to triple rinsing.

The container has an inner liner which prevented contact between the container and the acutely hazardous waste.

Guidelines for

Handling

Residues

The residue in a RCRA "empty" container or liner is exempt from regulations (i.e., a RCRA "empty" container can be discarded as solid waste).

Rinsate from "triple rinse" procedures is hazardous waste and must be collected for proper disposal through ESO.

Empty containers that have been rinsed are solid waste and can be disposed of in the trash can.

When "triple rinsing" containers, use appropriate quantities of solvent to minimize the generation of large volumes of waste.

Compressed

Gas

Compressed gas cylinders are considered empty when the container pressure approaches atmospheric pressure.

Do not store cylinders for long periods without use.

If possible, purchase compressed gas only through local supplies who will allow for return of empty gas cylinders for reuse.

Small compressed gas cylinders (2 ‐ 3 lbs.) which have been emptied can be given to the ESO who will certify them as empty and for recycling them scrap metal.

Labeling:

Proper labeling of hazardous waste and material is essential for proper handling and disposal. In the workplace, labeling helps minimize the generation of unknown chemical substances and facilitates disposal by ESO personnel. When preparing chemicals for pickup, use the following guidelines for labeling:

Use the Waste/Material Tracking Form provided by ESO on all waste accumulation containers.

Use a permanent marker to mark out the wording on container or label (or remove label). However the original container labels must remain on chemicals which are surplus or have reached their manufacturer's expiration date because such chemicals have a potential for redistribution to other users.

Use proper chemical or common names in identifying chemical compounds.

Do not use chemical formulas, symbols or structural formulas to identify a material for the purpose of disposal.

List the active ingredients whenever a trade name or proprietary name must be used. This information is usually provided on the Safety Data Sheet (SDS) or by the chemical manufacturer.

IV. HAZARDOUS WASTE TRACKING, PICKUP AND DISPOSAL

TRACKING FORMS:

Each waste container picked up by ESO must be listed on the waste/material tracking form. The proper completion of this form is the most important component in the process of hazardous chemical management.

This form provides the basic information required by law for tracking all the chemical wastes managed at the 180‐Day Hazardous Waste Storage Facility and becomes a part of the "cradle to grave" concept of hazardous waste management as mandated by the EPA. Further, it provides a source of hazard information for ESO personnel responsible for managing your wastes as well as a source of identification of the chemicals in case of an accident either in transit or at the HWSF.

The following information is required on each form:

Indicate the quantity of each chemical in the container.

Indicated the common chemical name of each substance added to the container. Do not use formulas, symbols or structural formulas for the name.

If the compound is a mixture, properly list all components on the form and show approximate percentages.

Provide a contact name, department, building number, and phone number on the form.

All chemical containers picked up by ESO must be accompanied by a properly completed form(s).

An illustration of Waste/Material Tracking Form and completion instructions is presented in the appendices. The forms are available from ESO service providers by calling 478‐8056.

PACKAGING:

Good packaging is essential for the safe transportation of hazardous waste from the SAA to the

HWSF. Use the following procedures when packaging chemicals to be collected by ESO:

Boxes used in packaging hazardous waste must be sturdy enough to provide safe in transportation. Only compatible waste should be in the same package.

Liquids must be packaged in DOT approved boxes only.

Packing material such as newspaper, styrofoam, etc., may be used to prevent breakage

ESO can furnish boxes for chemical transportation if notified in advance.

Contact ESO with questions on packaging chemicals for disposal.

HAZARDOUS CHEMICAL PICKUP:

Whenever possible ESO service providers will provide prompt removal of unwanted hazardous chemicals. The successful attainment of this goal depends largely on the cooperation of personnel who use these chemicals. The following guidelines are provided to expedite the removal and proper disposal of hazardous waste:

Waste containers must be tightly closed at all times when not in use.

When waste containers are 75% full, complete the tracking form and call the ESO service providers office (746‐3327) for waste pick‐up.

ESO personnel will schedule your pick‐up on the next pickup unless there are special requirements.

Please provide notification of special circumstances, such as potentially explosive chemicals, extremely toxic chemicals, etc., at the time a request for service is initiated.

V. NON‐RCRA WASTE DISPOSAL PROCEDURES:

SHARPS – PACKAGING AND DISPOSAL:

To prevent injury to medical staff, custodial and ESO personnel, sharps must NOT be disposed of in the normal trash bin. Use the following guidelines for proper packaging and disposal of sharps:

Contain all sharps slated for disposal in special puncture‐proof (plastic, steel, etc, not cardboard) containers designed for this purpose.

Sterilize all sharps that may pose a potential biohazard to humans prior to scheduling with medical waste disposal service provider for pick up.

Sharps containers ready for disposal should be listed separately on the tracking form.

For additional information regarding the handling of sharps and related wastes, contact the Facility Safety Specialist at 746‐5713.

SPECIAL WASTE AND OTHER WASTE

Special wastes, such as motor oil, vehicle anti‐freeze, lead‐acid batteries and other regulated waste, will be stored by the generator in their respective accumulation areas.

Accumulation and disposal of special wastes which are recycled, reclaimed, treated, or require special disposal under Federal Regulations or New Mexico Landfill Regulations shall be managed

IAW applicable laws and regulations. Specific guidance for the management of special waste not already provided in this plan will be provided by the ESO in a separate policy or procedure.

A Waste Tracking Sheet must be completed for all special waste prior to removal to the 180‐Day hazardous waste storage facility by ESO service providers.

VI. CHEMICAL SPILL PROCEDURES:

GENERAL:

Accidental release of chemicals occasionally occurs as a result of spills, leaks, etc. When spills happen there is a potential for the development of harmful effects depending on the chemical involved and the associated hazards. Contingency planning can minimize potential problems and enhance personnel's ability to deal with routine spills effectively. The FLETC Emergency

Procedures Handbook provides response and reporting procedures for two chemical spill categories: 1) Immediately Dangerous to life or health; and 2) Minimal Hazard/Controlled.

PLANNING GUIDELINES:

Prior to commencing work, all personnel should be instructed on what to do in case of emergency. Such instruction or training should include at a minimum the following:

How to report a fire, injury, chemical spill or other emergency.

The location of emergency equipment such as safety showers and eyewashes.

The location of fire extinguishers and spill control equipment.

The locations of all available exits for evacuation.

Familiarization with the SAA Logbook and the summarization of emergency reporting procedures provided within.

Names and phone numbers of individuals responsible for the designated waste storage area. Such information should be posted on or near the storage areas entrance or container.

SPILL PLAN GUIDELINES:

Each work area where hazardous materials/waste is used should have a spill plan. Work processes should be assessed by the supervisor and be controlled and designed to minimize the possibility of an accidental release of hazardous substances.

SMALL SPILL GUIDE

The following are provided for your use in handling common small spills, i.e. Minimal

Hazard/Controlled. These are general guidelines; however, they should be customized to meet the needs of the individual process or operation:

Notify other personnel in the immediate area about the spill and if necessary, evacuate the area.

In case of injury or potential exposure, attend to victim(s) immediately and if necessary, request help.

Take appropriate steps to confine and limit the spill if this can be done without risk of injury or contamination.

Clean up spill using appropriate procedures. Dispose of spill clean‐up debris properly according to procedures outlined in this plan.

SPILL CONTROL AND CLEANUP MATERIALS:

Personnel working with hazardous materials/waste should be familiar with the properties

(physical, chemical and toxicological) of such substances prior to commencing work. The necessary safety equipment, protective clothing and spill control materials should be readily available in the work area. All areas in which hazardous substances are used should have spill kits to deal with the potential hazards of the substances being used.

A typical spill control kits might include:

Spill control pillows. These are commercially available and can be used to absorb solvents, acids, alkalis, but not hydrogen fluoride.

Inert absorbents such as vermiculite, clay, sand, kitty litter and oil‐dri.

Neutralizing agents for acid spills such as sodium carbonate and sodium bicarbonate.

Neutralizing agents for alkali spills such as sodium bisulfate or citric acid.

Plastic scoops and other equipment such as brooms, pails, bags, and dust pans, etc., as appropriate.

Appropriate warnings, barricade tapes and protection against slips or falls on wet floor during and after clean up episodes.

These items could easily be packaged in one or more 5‐gallon polyethylene buckets which can serve as a spill debris containers. For more information, call the ESO service providers at 746‐

3327.

FIRST AID GUIDE:

In case of injury or potential exposure, attend to victim(s) immediately as outlined below:

For spills affecting small portions of skin, immediately flush with flowing water for at least

15 minutes. If no visible burn exists, wash with warm water and soap, removing any jewelry

For spills on clothes, don't attempt to wipe the clothes. Quickly begin showering while removing all contaminated clothing, shoes and jewelry. It may be necessary to cut the clothes off in some instances to prevent contamination of the eyes.

Do not use creams, lotions or salves.

Avoid breathing the vapors of spilled substances.

Contaminated clothes should be discarded or laundered separately from other clothing.

For splashes into the eye, immediately flush with tepid potable water for at least 15 minutes. Hold the eyelids away from the eyeball, moving eye in all directions to wash thoroughly behind the eyelids. Use eyewash for this purpose.

In all cases, seek medical attention: Dial *9‐911 for emergency response.

SPILL CLEANUP GUIDE:

Spill cleanup procedures vary depending on the spill location, the spill amount and physical properties, the degree and type of toxicity and the level of training of individuals involved. The

Chemical Spill procedures in the FLETC Emergency Procedures Handbook give spill response for two chemical spill categories. The following are general guidelines for handling common small spills, i.e. not Immediately Dangerous to Life or Health:

Low flammability, This group includes inorganic acids (sulfuric, nitric) and bases

(sodium and potassium hydroxide). Absorption with an volatility, and

/or toxicity substances absorbent and appropriate disposal is recommended. The spilled substances may be neutralized with materials such as sodium bisulfate (for alkalis) and sodium carbonate or bicarbonate (for acids).

Flammable liquids

This category includes petroleum ether, hexane, pentane, diethyl ether, dimethoxyethane and tetrahydrofuran to mention a few.

Other personnel in the area should be alerted, all flames extinguished and any spark‐producing equipment turned off.

The spilled substance should be soaked up using absorbent material as quickly as possible. Spill debris should be sealed properly and disposed of through ESO.

Highly toxic substances

The ESO should be notified whenever a highly toxic substance spill occurs. Also, personnel in the area should be notified.

Consult the Safety Data Sheet (SDS) for appropriate or recommended cleanup procedures and consult with appropriate

EH&S staff for assistance and/or additional information.

Appropriate personal protective equipment such as gloves, goggles, protective clothing, aprons and if necessary, shoe coverings should be worn during any spill clean‐up event. Depending on the substance spilled, a respirator may be necessary. Individuals requiring the use of respirators must by regulation undergo special training and obtain medical clearance prior to respirator use.

Contact the Facility Safety Specialist 746‐5713 for more information.

GUIDE FOR LARGE CHEMICAL SPILLS:

In the event of a large chemical release (a volume which exceeds the capacity of a standard cleanup kit), a situation which may be immediately dangerous to life or health, or where the readily available personal protective equipment (PPE) is inadequate to ensure worker safety, the following measures must be followed:

Notify other personnel about the spill and evacuate the area. In case of injury or exposure, immediately attempt to remove or protect victim(s) immediately if this can be done without risk of injury or contamination, if need request help.

Move to a safe area and dial *9‐911 to report the emergency.

Call Security at (575) 748‐8136, inform the Security Officer that a 911 call has been made, and provide the following information:

o Name(s) of chemical substances involved o Building and room number, or location of spill o Type of incident (Spill, Fire, Explosions, Injuries etc.)

If the danger could or does involve the area beyond the spill or room, o pull fire alarm (or safety alarms if applicable).

o evacuate the building and secure entrances.

The Artesia Fire Department will respond to all 911 chemical emergencies at the FLETC.

GUIDE FOR CHEMICAL RELEASES TO THE ENVIRONMENT:

If hazardous or regulated materials are spilled outside of buildings or unintentionally released to the environment via a sewer or fume hood:

Contact ESO at 748‐8056 to determine if the chemical release is subject to special regulatory reporting requirements.

Be prepared to provide the o name of the chemical(s) involved, o quantities released, and o approximate time of the incident.

The ESO will contact the appropriate regulatory agencies and initiate reporting if necessary.

VII. UNKNOWNS:

All personnel must make every effort to provide an accurate description of all chemicals given to ESO for handling and disposal. Unknown chemicals will not be accepted by ESO since they cannot be handled or disposed of in a safe manner. Hazardous waste disposal companies will not accept unknowns without proper analysis and the analysis of a single sample can easily cost

$1,000 or more. It is the responsibility of the generator (individual or department) to accurately identify all chemical unknowns, either by knowledge or analysis.

GENERAL GUIDE FOR UNKNOWNS:

The process of identifying an unknown chemical can be tedious and paying for commercial analysis can be cost prohibitive. However, some activities can be done in the generator to help identify unknowns and also to prevent them from occurring in the first place. The following guidelines are provided to assist with the problem of unknown chemicals:

Determine from other personnel any information that may help to identify the chemical.

Exercise caution in opening chemical containers without labels especially if the cap is corroded or disfigured in any way. If unsure, seek assistance.

ORPHANED CHEMICALS ‐ 'LEFT OVERS' :

Chemicals of an unknown nature and sometimes of unknown origin, can present difficult handling and disposal problems. Such materials occur frequently, and more particularly in areas that have a high rate of personnel turnover.

Knowledge of materials used and the work that was being conducted by the departed worker might provide a clue as to the identity of the mixture. The identification of such compounds can be achieved in primarily the same way as unknown chemicals.

MINIMIZING 'UNKNOWNS AND LEFT OVERS'

The ESO offers the following suggestions to assist in reducing problems associated with unknown chemicals and orphan reaction mixtures:

Maintain labels on material containers. Replace defaced labels with new ones.

Institute a periodic review of material stock and rotate stock as new materials are purchased.

Maintain accurate records of materials in stock. This will help in the identification of any containers with missing labels.

Use a check‐out procedure that requires worker to sign for quantities taken for use in the performance of their work; and to track locations and quantities of dispensed material to ensure proper use, and minimize the potential for spills and unnecessary waste generation.

VIII. WASTE MINIMIZATION:

One of the primary goals of the 1976 Resource Conservation and Recovery Act (RCRA) was to reduce the generation of hazardous waste.