Attachment C-8 FD_FM 025-01 FLETC Hazardous Waste Management Plan - 508.pdf

DEPARTMENT OF HOMELAND SECURITY

FEDERAL LAW ENFORCEMENT TRAINING CENTERS

FLETC DIRECTIVE NO:

DIRECTIVE TITLE:

EFFECTIVE DATE:

025-01 (Formerly 025-001) FLETC Hazardous Waste Management Plan April 12, 2018

I. POLICY: Federal Law Enforcement Training Centers (FLETC) comply with all federal and applicable local regulations, industry standards, and FLETC plans with respect to the classification, management, transport, storage, and disposal of hazardous material and/or hazardous waste.

II. SCOPE: This directive is in effect at all FLETC locations and applies to FLETC staff, Partner Organization (PO) staff, and contractor or subcontractor personnel at all FLETC Training Delivery Points.

III. REFERENCES:

A. 40 CFR Parts 260 – 273 (Hazardous Waste).

B. 40 CFR Part 279 (Standards for the Management of Used Oil).

C. 29 CFR 1910.1200 (Hazard Communication).

D. 49 CFR Parts 100 – 180 (Hazardous Material and Oil Transportation).

E. 42 U.S. Code, Chapter 82, Subchapter III (Hazardous Waste Management).

F. Public Law 94-580, October 21, 1976, [Resource Conservation and Recovery Act

(RCRA)].

G. Department of Homeland Security (DHS) Directive 023-02 (Environmental

Compliance Program).

IV. CANCELLATION: None.

V. ADDITIONAL GUIDANCE: FLETC Manual 025-01 (Formerly 025-001), FLETC Hazardous Waste Management Plan.

VI. OFFICE OF PRIMARY INTEREST: Environmental and Safety Division, Mission and Readiness Support Directorate.

Signature on File Thomas J. Walters Director

Attachment C-8

Federal Law Enforcement Training Centers Charleston SC Contract Number: 70LCHS25RPFB00001

POST PUBLICATION

Revision History

FD/FM 025-01(Formerly 025-001)

Date Revision Request

By:

Summary of Revisions Revisions

Made By:

3/24/2021 Directives and Policies

Program (DPP)

DPP changed the directive numbers to be in compliance with the BRM/LOB numbers provided by CIO. And consistent with the numbering.

This directive was 025-001 - changed to 025-

C. Haney

Federal Law Enforcement Training Centers Charleston SC Contract Number: 70LCHS25RPFB00001

POST PUBLICATION

Revision History

FM 025-001

Date Revision Request

By:

Summary of Revisions Revisions

Made By:

7/11/19 Terri Mason, ESD, via email

Due to changes in federal regulations and State and FLETC personnel, I need to make minor changes to FLETC Directive 025-001, FLETC Hazardous Waste Management Plan.

The changes are as followed:

• Section V – Responsibilities – E – #3: Added an “a” after utilizing

• Section V – Responsibilities – E – #4: Deleted “at a minimum” and added “according to State regulations”

• Section V – Responsibilities – E – #4: Added an “a” after utilizing

• Attachments 1 and 9 – Added the word (Example) to both at the top right

• Attachment 13 (FLETC Glynco’s Hazardous Waste Contingency Plan) – Updated Exhibits 2, 4, 11 and 13 o Exhibit 2: Emergency Response Coordinator Contact List – Deleted Mark Harvison’s information o Exhibit 4: Emergency Reporting Form – Updated State personnel emails.

o Exhibit 11: GA EPD Contact List – Updated State personnel and phone numbers.

C. Haney

FLETC MANUAL 025-01 (Formerly 025-001)

HAZARDOUS WASTE MANAGEMENT PLAN

Supporting Publication to FLETC Directive 025-01 (Formerly 025-001) Hazardous Waste Management

April 2018

FLETC Manual 025-001

FLETC MANUAL 025-01 (Formerly 025-001)

TABLE OF CONTENTS

Page

I. Introduction II. Scope III. Forms IV. Definitions.....… V. Responsibilities

A. Environmental and Safety Division B. Procurement Division C. Assets and Logistics Management Division D. Facilities Management Division E. Hazardous Waste Manager/Handler F. Hazardous Waste Coordinator G. Divisions and Partner Organizations

VI. Procedures A. Hazardous Waste Classification B. Universal Waste Classification C. Used Oil Management D. Generator Classification E. Hazardous Waste Accumulation Area and Management F. Satellite Accumulation Area G. Specific Classes of Hazardous Waste Management H. FLETC Waste Analysis Plan I. Waste Disposal Procedures J. Hazardous Waste Training K. Waste Minimization L. Manifesting Requirements

M. Exception Reporting N. Record Keeping O. Signature Authority P. Contingency Plans

VII. Attachments A. Attachment #1 - Accumulation Site Inspection Form B. Attachment #2 - Waste Management Label C. Attachment #3 - EPA ID Label D. Attachment #4 - Universal Waste Label E. Attachment #5 - Pending Analysis Label F. Attachment #6 - Annual Review Log G. Attachment #7 - Training Course Outline H. Attachment #8 - Training Record I. Attachment #9 - SAA Inspection Checklist J. Attachment #10 - Waste Information Document K. Attachment #11 - List of Acronyms/Abbreviations L. Attachment #12 - Contaminants M. Attachment #13 - FLETC Glynco Facility Hazardous Waste Contingency

Plan N. Attachment #14 - FLETC Cheltenham Facility Hazardous Waste Contingency

Plan

I. INTRODUCTION:

A. This Hazardous Waste Management Plan (HWMP) addresses the mandatory requirements promulgated by 40 CFR Parts 260 through 268, United States Environmental Protection Agency (EPA) and State (Georgia, Maryland, New Mexico, and South Carolina) regulations for the management and disposal of hazardous waste (HW) at all Federal Law Enforcement Training Centers (FLETC). The HWMP provides guidelines for the safe handling of hazardous materials from point of generation to the point they become HW to their ultimate disposal. The HWMP promulgates applicable requirements related to HW and universal waste management, including responsibilities, HW and universal waste classification procedures, HW and universal waste accumulation procedures, FLETC Waste Analysis Plan, HW and universal waste disposal procedures, training, contingency plan measures, and FLETC Waste Minimization Plan.

B. This Manual also describes reporting and other HW program interface requirements for all activities located within FLETC’s complex.

C. The HWMP has a five-year review cycle and will be updated as needed.

II. SCOPE: Unless otherwise specified, the HWMP applies to all FLETC staff, Partner Organization (PO) staff, and contractor or subcontractor personnel at all FLETC Training Delivery Points.

III. FORMS: See Attachments.

IV. DEFINITIONS:

A. Acquisition - Acquiring, by contract with federal funds, supplies or services

(including construction) by, and for the use of, the federal government through purchase or lease, whether the supplies or services are already in existence or must be created, developed, demonstrated, and evaluated. Acquisition begins at the point when agency needs are established and includes the description of requirements to satisfy agency needs, solicitation, and selection of sources, award of contracts, contract financing, contract performance, contract administration, and those technical and management functions directly related to the process of fulfilling agency needs by contract.

B. Chemical - Any element, compound, or mixture of elements and/or compounds.

C. Chemical Manufacturer - An employer with a work place where chemicals are produced for use or distribution.

D. Combustible Liquid - Any liquid having a flashpoint at or above 100 degrees Fahrenheit. Where the term "combustible" is used it shall pertain only to those with flashpoints at or above 100 degrees and below 200 degrees Fahrenheit.

E. Conditionally Exempt Small Quantity Generator (CESQG) - A generator who generates 100 kilograms (220.46 lbs.) or less per month of HW in a calendar month.

See 40 CFR 261.5.

F. Consumer Product - A product or hazardous substance where the employer can demonstrate how it is used in the workplace in the same manner as normal consumer use and which results in a duration and frequency of exposure which is not greater than exposures experienced by consumers.

FLETC Manual 025-001 April 2018

G. Container - Any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical.

H. Corrosive - A liquid or solid that causes visible destruction or irreversible alterations of human skin tissue at the site of contact or, in the case of leakage from its packaging, a liquid that has a severe corrosion rate on steel. Acids have a pH of 6.9 to 1 and bases have a pH of 7.1 to 14; 7 is neutral.

I. Designated Facility - a treatment, storage, or disposal facility that is permitted and designated to receive a specific HW shipment manifested by the generator.

J. Discharge or HW Discharge - the accidental or intentional spilling, leaking, pumping, pouring, emitting, emptying, or dumping of HW on land or into waters.

K. DOT - The U.S. Department of Transportation.

L. Employee - A worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers who encounter hazardous chemicals only in non-routine, isolated instances are not included.

M. Employer – An entity engaged in a business where chemicals are either used, distributed, or produced for use or distribution, including a contractor or subcontractor.

N. EPA Identification Number - The number assigned by the EPA to each HW generator, transporter, or facility.

O. EPA HW Number - The number assigned to each HW listed in 40 CFR 261.

P. EPA - The U.S. Environmental Protection Agency.

Q. Excess Hazardous Materials (EHM) - Ready for issue hazardous material, classified as hazardous material, and no longer needed by the activity having custody of the material.

R. Explosive - A chemical that causes a sudden, almost instantaneous, release of pressure, gas, and heat when subjected to sudden shock, pressure or high temperature.

S. Exposure or Exposed - When an employee contacts a hazardous chemical in the course of employment through any route or entry (inhalation, ingestion, absorption, injection). Includes potential (e.g. accidental or possible) exposures.

T. Flammable Solid - A solid material, other than one classed as an explosive, which is liable to cause fire through friction, absorption of moisture, spontaneous chemical change or retained heat from manufacturing or processing, or which can be ignited readily and when ignited can burn so vigorously and persistently as to create a serious hazard.

U. Flammable Liquid - A liquid with a flash point less than 100 degrees Fahrenheit.

V. Flash Point (fp) - The minimum temperature at which a substance gives off flammable vapors which, in contact with a spark or flame, will ignite.

W. Generating Activity (or HW Generating Activity) - any shop, laboratory, or process where waste or HW is generated.

X. Generator - any entity or individual whose actions or processes produces HW identified or listed in 40 CFR 261 or whose actions cause a HW to become subject to those regulations.

Y. Hazard Warnings - Any words, pictures, symbols, or combination thereof appearing on a label, or other appropriate form of warning, which conveys the hazards of the chemicals in a container, including target organ effects.

Z. Hazard Communication (HAZCOM) - A phrase and acronym derived from 29 CFR 1910.1200, the OSHA Hazard Communication Standard, that, when used as a noun or adjective, means a requirement related to the standard. The performance elements of the standard involve the following: a list of hazardous chemicals, Safety Data Sheets (SDSs), labels, other forms of warning, personnel training, non-routine tasks, contractor employers and employees, personnel accessibility to a list of chemicals and SDSs, and a HAZCOM program plan.

AA. Hazardous Chemical - Any chemical that is a physical hazard or health hazard per 29 CFR 1910.1200(c), and with some exceptions as specified in the Community Right to Know Law of 1986 (Superfund Amendments and Reauthorization Act (SARA), Title III). See hazardous material.

BB. Hazardous Waste (HW) - In general, this includes hazardous material (HM) which have no further use and exhibit characteristics of ignitability, corrosiveness, reactivity, and/or toxicity, or are defined as such in federal and state HW regulations. HW may also be known as a Regulated Substance.

CC. Hazardous Material (HM) - Any substance or material, including a hazardous substance, which, because of its quantity, concentration, or physical, chemical or infectious characteristics, may pose a hazard to human health or the environment. As a minimum, includes all material regulated by Title 49 CFR 173.2, Title 29 CFR 1910.1200, Title 40 CFR 261. HM at FLETC may also be termed a Regulated Substance.

DD. Hazardous Substance - Hazardous materials and hazardous wastes.

Hazardous Substance at FLETC may also be known as a Regulated Substance (RS).

EE. Hazardous Waste Minimization (HAZMIN) - Consists of three parts:

1. Avoiding HW generation by minimizing and controlling HM acquisition and use, and by applying best management, engineering and equipment to FLETC processes and procedures.

2. Recycling HW to return it to a ready-for-use state.

3. Treating HW to reduce the volume or to reduce it to a non-hazardous state.

FF. HW Management - the systematic control of the generation, collection, source separation, storage, transportation, processing, treatment, recovery, and disposal of

HW.

GG. Label - Any written, printed, or graphic material, displayed on, or affixed to, containers of hazardous materials or waste.

HH. Large Quantity Generator (LQG) - A generator who generates 1,000 kilograms (2,204 lbs.) or more of HW in a calendar month. See 40 CFR 262.34(a).

II. Manifest - the document originated and signed by the generator which contains the information specified by 40 CFR 262 Subpart B.

JJ. Marking – a descriptive name, identification number, instructions, cautions, weight, specification, or UN marks, or combinations thereof, required by 49 CFR 171.8 on outer packaging of hazardous materials.

KK. Originator - Anyone producing a hazardous or industrial waste.

LL. OSHA – U.S. Occupational Safety and Health Administration.

MM.Oxidizer - A substance that readily yields oxygen to stimulate the combustion of organic matter.

NN. Ozone Depleting Substance (ODS) - Chlorofluorocarbons and halons that have been linked to the depletion of the Earth's ozone layer. These include, but may not be limited to: 1,1,1 Trichloroethane (methyl chloroform); Freon 11 (Trichlorofluoro-methane); Freon 12 (Dichlorodifluoromethane); Freon 13 (Chlorotrifluoromethane); Freon 22 (Chlorodifluoromethane); Freon 113 (Trichlorotrifluoroethane); Freon 114 (Dichlorotetrafluoroethane); Freon 115 (Chloropentafluoroethane); Freon 500 (Dichlorodifluoromethane/Difluoroethane); Freon 502 (Chlorodifluoromethane/ Chloropenta-fluoroethane); Halon 1211 (Bromo-chlorodifluoromethane); Halon 1301 (Bromotrifluoromethane): Halon 2402 (Dibromotetrafluoro-ethane); Methylene Chloride.

OO. Pesticide - Pesticides are insecticides, herbicides (including desiccants, defoliants and growth regulators), rodenticides, acaricides, avicides (bird control materials), nematocides, fungicides, algicides, molluscicides and repellents, and attractants; or any combination thereof; or any other material used for the purpose of controlling, preventing or mitigating pest organisms.

PP. Purchase/Procurement - See acquisition.

QQ. Safety Data Sheets (SDS) - Written or printed information concerning a hazardous chemical which is prepared on OSHA Form 174 or equivalent. The SDS must be used by manufacturers, suppliers or other responsible party to communicate to users the chemical, physical and hazardous properties, and safety procedures for their product.

RR. Small Quantity Generator (SQG) - A generator who generates more than 100 kilograms (220.46 lbs.), but less than 1,000 kilograms (2,204 lbs.) of HW in a calendar month. See 40 CFR 262.34(d).

SS. Universal Waste (UW) -Waste which the EPA has specifically identified in order to reduce the amount going to landfills/incinerators, including: batteries, recalled and unused pesticides, mercury-containing equipment, and mercury lamps.

TT. Very Small Quantity Generator (VSQG) - see Conditionally Exempt Small Quantity Generator (CESQG)

UU. Waste Information Document (WID) - The WID is the central recording and permitting document for all regulated substance disposal transactions. It includes directions for handling, disposal, and transportation and contains authorizing and certifying signatures. FLETC WIDs may be found on the ESD MOSS site under Public Documents/Hazardous Waste Program.

VV. Work Area - A room or defined space in a workplace, indoors or outdoors, where hazardous chemicals are produced or used and where employees are present.

WW.Workplace - An establishment, job site or project, at one geographical location, containing one or more work areas. Title 29, Code of Federal Regulations (CFR), 1992 rev, Part 1910 General Industry Standards.

V. RESPONSIBILITIES:

A. Environmental and Safety Division (ESD)/Environmental and Safety

Office (ESO): The ESD/ESO are responsible for:

1. Designating individuals to serve as Hazardous Waste Manager (HWM);

2. Coordinating with Divisional/Branch Hazardous Waste Coordinators

(HWC) and/or Hazardous Waste Handlers (HWH), and interfacing with and providing guidance to shop supervisors as required by this instruction;

3. Developing, implementing, and monitoring the FLETC HWMP including: Waste Minimization, Waste Analysis, and Hazardous Waste Inspections;

4. Coordinating the submittal of all permit applications, manifests, audits, checklists, reports, plans, and payments of fees and fines as required by EPA and State regulators;

5. Coordinating all inspections by EPA and State regulators and notifying ESD with inspection results. Coordinating contract agreements and compliance audits with HW contractors (if applicable) to ensure federal, state and local regulatory compliance;

6. Assisting Division/Branch HWC and shop supervisors in the management of HW activities in their appointed duties;

7. Developing and publishing guidance for all activities and individuals handling or managing HW. Guidance shall pertain to classification of HW, safety precautions, packaging, labeling, storage, transportation, disposal requirements, and other responsibilities;

8. Authorizing the establishment, closure, or change in status of HW accumulation sites on the Centers;

April 2018

9. Submitting budget requirements for FLETC HW disposal costs;

10. Supervising, directing, and assisting the HWCs for all hazardous waste issues and management of Accumulation Sites and Satellite Accumulation Areas (SAAs);

11. Responding to all spills and coordinating all spill clean-up for the location and making all appropriate notifications when required. Notifying ESD of any regulatory notifications;

12. Reviewing, certifying, and signing all manifests and paperwork for all shipments of FLETC hazardous waste. Manifests will only be signed by individuals granted signatory authority by the ESD Division Chief/Site Director. The only personnel with signatory authority are those identified as HWMs who have completed and are current with the required training as specified by 40 CFR part 262 and 49 CFR 172-173;

and

13. Insuring through oversight that all individuals exposed to hazardous waste activities receive the appropriate training and protective equipment.

B. Procurement Division (PRO): PRO is responsible for:

1. Coordinating compliance issues with onsite contractors generating waste;

2. Coordinating with ESD/ESO to ensure onsite contractors are informed about the information contained in the HWMP;

3. Ensuring Contracting Officer Representatives (COR’s) conduct regular inspections of contractor sites to ensure compliance with the HWMP; and

4. Coordinating with ESD/ESO to provide HWMP training of all contractor personnel who generate, handle, and store HW.

C. Assets and Logistics Management Division (ALM): ALM is responsible for:

1. Coordinating with ESD/ESO for the sale or disposition of recyclable hazardous waste materials (i.e., bullet waste, bullet brass, computers, monitors, etc.);

2. Providing storage and handling of recyclable materials that would otherwise be considered HW. Wastes to be recycled may be held on site for up to one year; and

3. Furnishing ESD/ESO a copy of all Certificates of Recycling as evidence that a hazardous material has been recycled.

D. Facilities Management Division (FMD): FMD is responsible for:

1. Coordinating all construction/renovation work through HWM(s) to ensure proper disposal and removal of waste generated by the Contractor;

2. Ensuring the HWM(s) are informed of all new construction/renovation projects. HWM(s) will be provided an allotted time during pre-construction meetings to ensure contractors are briefed on HW requirements and compliance issues; and

FLETC Manual 025-001 April 2018

3. Supporting the HWM(s) in providing available equipment and personnel for onsite spill response.

E. Hazardous Waste Manager (HWM)/Hazardous Waste Handler (HWH):

These individuals are the only persons authorized to transport HW within the Center.

This individual may be government staff or contractor personnel. The HWM and HWH may be the same individual. The HWM/HWH is responsible for:

1. The overall operation of FLETC Accumulation Sites;

2. Ensuring transportation of HW within the Center is accomplished in strict accordance with all federal, state, and local laws and regulations;

3. Conducting weekly inspections of Accumulation Sites utilizing a Hazardous Waste Accumulation Site Inspection Form (see Attachment 1);

4. Conducting weekly inspections, according to State regulations, of Satellite Accumulation Areas (SAAs) utilizing SAA Inspection Checklist (Attachment 9) unless a contract vehicle is in-place at FLETC utilizing a contracted personnel, which may stipulate more stringent requirements;

5. Certifying all contents, markings, labeling, and documentation [Waste Information Document (WID) (Attachment 10)] for all HW transferred to the Accumulation Site;

6. Picking up HW waste from SAAs within three consecutive days of notification from the HWC or shop supervisor;

7. Entering the EPA waste codes (see Attachment 3) is on the label of the container when a container is placed in the SAA and ensuring the date is entered on the label at the time it is placed in the accumulation area;

8. Prior to transporting containers off Center, ensuring that all HW is properly packaged, labeled, and marked, per 40 CFR 262, Subpart C;

9. Delivering empty containers, lever-locking rings/drum funnels, and labels upon request of the HWC;

10. Responding to all spills over one (1) gallon. Coordinating clean-up and disposal of material with ESD/ESO;

11. Reporting and recordkeeping, per 40 CFR 262, Subpart D and to include WIDs (see Attachment 10);

12. Weighing all drums and documenting on labels (see Attachment 2), assigning drum I.D. numbers, and updating drum logs; and

13. Inspecting all construction/renovation debris dumpsters/roll-offs on an as needed basis to ensure no HW is being disposed of improperly.

F. Hazardous Waste Coordinator (HWC)/ Shop Supervisors: The HWC/ Shop Supervisors are responsible for:

1. Handling and storing all waste in accordance with specific instructions provided on the WID by the HWM;

2. Maintaining documentation (Profiles, WIDs, analytical data, etc.) of all waste generated within their respective areas;

3. Ensuring that SAAs are operated in compliance with Section VI.F of this document;

4. Coordinating with the HWM(s) for establishment and location of new SAAs;

5. Notifying the HWM/HWH when 55 gallons of HW is accumulated at an SAA; and

6. Ensuring the date is entered on the label at the time 55 gallons of HW has been accumulated at the SAA.

G. Divisions and Partner Organizations (POs): Divisions and POs are responsible for:

1. Identifying all HWCs for their respective areas if applicable. Ensuring that individuals, groups, activities, or contractors under their authority comply with this Plan;

2. Appointing one HWC from each shop/area that generates waste. The HWC and shop supervisor shall serve as liaisons between the organization and the

ESD/ESO;

3. Ensuring the HWC and shop supervisor are trained by the ESD/ESO, or a qualified trainer approved by the ESD/ESO, in accordance with the requirements of Section VI.J, Hazardous Waste Handlers Training; and

4. Implementing procedures to reduce costs associated with HW management and disposal options, including recycling/reuse and waste minimization.

VI. PROCEDURES:

A. Hazardous Waste Classification. This section defines the classifications of waste subject to policy, procedures, and requirements of the HWMP. Hazardous Waste Classification: A solid waste, that is not excluded from regulation as a HW as listed in either 40 CFR Parts 260 through 268 or State regulations, and exhibits any of the characteristics of ignitability, corrosivity, reactivity, or toxicity.

1. Characteristic D001: A solid waste is given an EPA Hazardous Waste Number D001 if it exhibits the characteristic of ignitability, including:

a. A liquid, other than an aqueous solution containing less than 24 percent alcohol by volume, with a flash point of less than 140° Fahrenheit.

b. A non-liquid which under normal conditions is capable causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard.

c. An ignitable compressed gas as defined by 40 CFR 261.21(a)(3).

d. An oxidizer as defined in 40 CFR 261.21(a)(4).

2. Characteristic D002: A solid waste is given an EPA waste number of D002 if it exhibits the characteristic of corrosivity, including:

a. An aqueous solution with a pH less than or equal to 2 or greater than or equal to 12.5 standard units.

b. A liquid which corrodes steel at a rate greater than 1/4 inch per year at a test temperature of 130° Fahrenheit.

c. A solid waste that exhibits the characteristic of corrosivity.

3. Characteristic D003: A solid waste is given an EPA waste number of

D003 if it exhibits the characteristic of reactivity, including:

a. Normally unstable and readily undergoes violent change without detonating.

b. Reacts violently with water.

c. Forms potentially explosive mixtures with water.

d. When mixed with water, generates toxic gases, vapors or fumes.

e. Cyanide or sulfide bearing wastes which, when exposed to pH conditions between 2 and 12.5 standard units, can generate toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment.

f. It is capable of detonation or explosive reaction if subjected to a strong initiating source or if heated under confinement.

g. It is readily capable of detonation or explosive decomposition at standard temperature and pressure.

h. It is a forbidden explosive as defined in 49 CFR 173.51, or a Class A explosive as defined in 49 CFR 173.53, or a Class B explosive as defined in 49 CFR 173.88.

4. EPA Waste Designation by Toxicity Characteristic Leaching Procedure (TCLP): A solid waste is given an EPA waste number if it exhibits toxicity characteristics as determined by Toxicity Characteristic Leaching Procedure (TCLP) testing of a representative sample of the waste at a concentration greater than or equal to the respective, regulated level of any of the contaminates listed in Attachment 12.

5. Hazardous Wastes from Non-Specific Sources (F-listed): HWs from nonspecific sources are known as F-listed wastes. These HWs are generated from common manufacturing and industrial processes. Refer to 40 CFR 261.31 for a specific listing.

April 2018

6. Hazardous Wastes from Specific Sources (K-listed): HWs from specific sources are known as K-listed HWs. These HWs are generated by specific sectors of industry and manufacturing processes. Refer to 40 CFR 261.32 for a specific listing.

7. Acute Commercial Chemical Products (P-listed): Discarded or intended to be discarded commercial chemical products, manufacturing chemical intermediates or off-specification chemical products, residue remaining in the containers, or contaminated soil, water, or other debris resulting from the cleanup of a spill, that have the major ingredient listed in 40 CFR 261.33(e) are known as P-listed HWs. These HWs are identified as acute HW and carry the associated EPA hazardous waste number.

8. Toxic Commercial Chemical Products (U-listed): Discarded or intended to be discarded commercial chemical products, manufacturing chemical intermediates or off-specification chemical products, residue remaining in the containers, or contaminated soil, water, or other debris resulting from the cleanup of a spill, that have the major ingredient listed in 40 CFR 261.33(f) are known as U-listed HWs. These HWs are identified as toxic HW and carry the associated hazardous waste number.

9. Non-Hazardous Solid Waste: The following solid wastes are NOT considered to be HW:

a. Household waste.

b. Fly Ash waste, bottom ash waste, and flue gas emission control waste generated primarily from the combustion of coal or other fossil fuels except for facilities that burn HW.

c. Drilling fluids, produced waters, and other wastes affiliated with the explorations, development, or production of crude oil, natural gas, or geothermal energy.

d. Solid waste which consists of discarded arsenical-treated wood or wood products which fail the test for Toxicity Characteristics for EPAHWN D004 through D017 and which is not a HW for any other reason if the waste is generated by persons who utilized the arsenical-treated wood and wood products for those materials intended end use.

e. Petroleum contaminated media and debris that fail the test for Toxicity Characteristic (Hazardous Waste Codes D018 through D043 only) and are required to meet the corrective action regulations under 40 CFR Part 280.

f. Used chlorofluorocarbon refrigerants from totally enclosed heat transfer equipment, including mobile air-conditioning systems, mobile refrigeration, and commercial and industrial air conditioning and refrigeration systems that use chlorofluorocarbons as the heat transfer fluid in a refrigeration cycle, provided that the refrigerant is reclaimed for further use.

g. Non-terne plated used oil filters that are not mixed with a listed HW if these oil filters have been gravity hot-drained using one of the following methods:

1) Puncturing the filter anti-drain back valve or the filter dome end and hot-draining;

2) Hot-draining and crushing;

3) Dismantling and hot-draining; and/or

4) Any other equivalent hot-draining method which will remove the oil.

B. Universal Waste Classification: The regulations for universal waste can be found in 40 CFR Part 273. These regulations, finalized in 1995 by the EPA, are less stringent management standards for batteries, recalled and unused pesticides, mercury-containing equipment, and lamps (i.e., fluorescent, mercury vapor, high pressure sodium, etc.). These standards are designed to reduce the amount of waste batteries, recalled and unused pesticides, mercury-containing equipment, and lamps sent to municipal waste landfills/incinerators. These wastes have been classified as universal waste. The definitions and applicability of these wastes are described in the following sections.

Universal Wastes may be accumulated for one year.

1. Batteries: Batteries classified as universal waste:

a. Any device consisting of one or more electrically connected electrochemical cells which are designed to receive, store, and deliver electric energy.

The term battery also includes an intact, unbroken battery from which the electrolyte has been removed.

b. Spent lead-acid batteries which are not managed in 40 CFR Part 266, Subpart G.

2. Batteries not Classified as Universal Waste:

a. Spent lead-acid batteries that are managed under 40 CFR Part 266, Subpart G.

b. Batteries that are not yet waste under 40 CFR, Part 261.

c. Batteries that are not hazardous waste. A battery is a hazardous waste if it exhibits one or more of the characteristics identified in 40 CFR Part 261, Subpart C.

3. Generation of Waste Batteries:

a. A used battery becomes a waste on the date it is discarded (e.g., when sent for reclamation).

b. An unused battery becomes a waste on the date the handler decides to discard it.

c. Batteries determined as discarded shall have ends taped to prevent possible fire hazard/ignition from electrical residual current prior to being placed in receptacle.

FLETC Manual 025-001 April 2018

4. Management of Waste Batteries: All batteries are to be collected for recycling. No battery (no matter what type) is to be thrown into the regular trash (domestic trash). All batteries will be recycled. There are two methods for collecting, storing, and recycling used batteries in the work centers:

a. First method:

1) At the request of the ESD/ESO, a battery storage container (6 gallon fiberboard drum) will be delivered to the work center for the collection and storage of used batteries. These containers will be properly labeled (Attachment 4) by the HWC.

2) Employees will tape (using any type of tape) each end of the battery before placing into battery container.

3) Employees will ensure container is closed at all times except when placing batteries into the container.

4) Once the container is full, contact the ESD/ESO for pick-up.

The HWM/HWC will pick up the full container and replace it with an empty container.

b. Second method: For small generation of batteries (one or two at a time) the following procedure may be used:

1) Tape each end of battery.

2) Place battery/batteries in a guard mail/regular envelope and send to ESD/ESO or the respective HWM/HWC.

c. All large type batteries (i.e., car, forklift, golf cart, etc.) will be turned into the prospective FLETC motor vehicle facilities (i.e., garage, motor pool, vehicle maintenance, etc.). Contact the ESD/ESO to coordinate pick-up of large batteries. All large used batteries must be stored in corrosive lockers and must be labeled (Attachment 4) with accumulation date posted on label.

5. Mercury-Containing Equipment: A device or part of a device (including thermostats, but excluding batteries and lamps) that contains elemental mercury integral to its function.

6. Mercury-Containing Equipment not Classified as Universal Waste:

a. Mercury-containing equipment that are not yet wastes.

b. Mercury-containing equipment that are not hazardous waste.

Mercury-containing equipment is a hazardous waste if it exhibits one or more of the characteristics identified in 40 CFR Part 261, Subpart C.

c. Equipment and devices from which the mercury-containing components have been removed.

7. Generation of Waste Mercury-Containing Equipment: Used mercury-containing equipment becomes a waste on the date it is discarded (e.g., sent for reclamation). An unused mercury-containing equipment becomes a waste on the date the handler decides to discard it.

FLETC Manual 025-001 April 2018

8. Management of Thermostats: Facility maintenance personnel (government and contractor) should manage thermostats in a way that prevents releases of any mercury to the environment. The management of waste thermostats is as follows:

a. SAA’s are established at each FLETC facility by the ESD/ESO for the storage of universal waste thermostats.

b. Glynco - Bldg. 210.

c. Artesia - 270 Day Storage Area (Main Campus).

d. Cheltenham - Bldg. 53, 90-Day Central Accumulation Site.

e. Charleston - Waste Accumulation Site.

f. The containers must be closed, structurally sound, compatible with the contents of the thermostat, and show no evidence of leakage, spillage, or damage that could cause leakage.

g. Maintenance personnel may remove mercury-containing ampules from universal waste thermostats provided the handler removes the ampules in a manner designed to prevent breakage of the ampules.

i. Remove ampules only over or in a containment device (e.g., tray or pan sufficient to collect and contain any mercury released from an ampule in case of breakage).

j. Ensures that a mercury clean-up system is readily available to immediately transfer any mercury resulting from spills or leaks from broken ampules, from the containment device to a container that meets the requirements of 40 CFR 262.34.

k. Transfer any mercury resulting from spills or leaks from broken ampules from the containment device to a container that meets the requirements of 40

CFR 262.34.

l. Ensure that the area in which ampules are removed is well ventilated and monitored to ensure compliance with applicable OSHA exposure levels for mercury.

m. Ensure that employees removing ampules are thoroughly familiar with proper waste mercury handling and emergency procedures, including transfer of mercury from containment devices to appropriate containers.

n. Store removed ampules in closed, non-leaking containers that are in good condition.

o. Pack removed ampules in the container with packing materials adequate to prevent breakage during storage, handling, and transportation.

p. All containers of universal waste thermostats must be labeled (Attachment 4) with accumulation date posted on label.

9. Lamps: Lamps classified as universal waste:

a. Must be cleaned and placed in a container that will prevent release of the pieces to the environment.

b. Must be contained in containers or packages that are structurally sound, adequate to prevent breakage.

c. Containers and packages must remain closed and must lack evidence of leakage, spillage or damage.

10. Lamps not Classified as Universal Waste:

a. Lamps that are not yet wastes under 40 CFR part 261.

b. Lamps that are not hazardous waste.

c. A lamp is a hazardous waste if it exhibits one or more of the characteristics identified in part 40 CFR 261, subpart C.

11. Generation of Waste Lamps: A used lamp becomes a waste on the date it is discarded (e.g., sent for reclamation). An unused lamp becomes a waste on the date the handler decides to discard it.

a. A handler [e.g., small quantity handler (SQH) or large quantity handler (LQH)] of waste lamps must manage waste lamps in a way that prevents releases of any waste lamps or a component of a waste lamp.

b. Small quantity handler of universal waste means a universal waste handler who does not accumulate 5,000 kilograms or more of universal waste (batteries, pesticides, mercury-containing equipment, or lamps, calculated collectively) at any time.

c. Large quantity handler of universal waste means a universal waste handler who accumulates 5,000 kilograms or more total of universal waste (batteries, pesticides, mercury-containing equipment, or lamps, calculated collectively) at any time.

This designation as a large quantity handler of universal waste is retained through the end of the calendar year in which the 5,000 kilogram limit is met or exceeded.

12. Management of Lamps: FLETC facility maintenance personnel (government and contractor) must manage lamps in a way that prevents breakage or release to the environment. The management of waste lamps is as follows:

a. All universal waste lamps will be recycled by placing used lamps into lamp containers (provided by the HWC) at the following FLETC locations:

1) Glynco - Bldg. 210.

2) Artesia - 270 Day Storage Area (Main Campus).

3) Cheltenham - Bldg. 53, 90-Day Central Accumulation Site.

4) Charleston - Waste Accumulation Site.

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b. Personnel may also contact the ESD/ESO for delivery and pick-up of bulk containers for large quantity generation of lamps. Pick-up of bulk containers will be accomplished by the HWM/HWC.

c. All containers of waste lamps must be labeled (Attachment 4) with accumulation date posted on label.

C. Used Oil Management: Used oil is a regulated waste. Regulated wastes are those solid wastes that either are not characterized as a hazardous waste, but due to their characteristics, may not be disposed of as a normal municipal refuse; and/or might be characterized as a hazardous waste, but due to specific exemptions in the regulations require special handling.

1. Used Oil: May be handled as a hazardous waste or according to specific used oil requirements as outlined in 40 CFR 279. Depending on the constituents of the used oil, facilities are required to handle used oil as a hazardous waste or according to the specific used oil requirements outlined in 40 CFR 279.10.

2. Used Oil as Hazardous Waste: Used oil that is required to be handled as a hazardous waste consists of the following:

a. Mixtures of used oil and listed as hazardous waste;

b. Used oil containing more than 1,000 ppm total halogens;

c. Used metalworking oils/fluids containing chlorinated paraffins if processed through a tolling agreement;

d. Used oil contaminated with CFCs removed from refrigeration units where the CFCs are destined for reclamation; and

e. Mixtures of used oil and hazardous waste if the resultant mixture exhibits characteristics of a hazardous waste.

3. Used Oil Management/Containment Procedures:

f. The words "USED OIL" must be clearly marked on containers and aboveground tanks that store used oil and on fill pipes that transfer used oil into underground storage facilities.

g. Containers utilized as used oil generators must be made of or lined with materials compatible with the used oil stored in them.

h. Containers must be closed during storage, except when it is necessary to add or remove used oil, and handled in a safe manner.

i. Secondary containment on tank systems at used oil generators must meet specific requirements including one or more of the following:

1) A liner (external to the tank),

2) A vault,

3) A double-walled tank, or

4) An equivalent approved device.

FLETC Manual 025-001 April 2018

j. Tank ancillary equipment at used oil generators must also be provided with secondary containment.

k. Tanks used for used oil treatment or storage at used oil generators must follow certain operating requirements such as:

1) Spill and overfill prevention controls.

2) Maintenance of sufficient freeboard to prevent overtopping.

D. Generator Classification: This section defines facility classifications applicable to FLETC facilities and accumulation conditions which shall be met for regulated HW and universal wastes to be accumulated onsite.

1. Large Quantity Generator (LQG): Large Quantity Generator (LQG) of HW may accumulate HW onsite for 90 days or less without a permit, provided certain conditions are met. The facilities at Glynco and Cheltenham are classified as large quantity generators.

2. Small Quantity Generator (SQG): are allowed by regulation to accumulate waste on site for 180 days and 270 days if the disposal facility is over 200 miles away. The Artesia, NM facility is designated as a SQG and a 270-day accumulation site.

3. Very Small Quantity Generator: These facilities are exempt from the requirements of the regulation and are allowed to accumulate hazardous waste for one year. The Charleston, SC facility is “exempt” from regulation.

4. Universal Waste Handler: FLETC sites may accumulate universal waste onsite for no longer than one year from the date the universal waste is generated.

E. Hazardous Waste Accumulation Sites & Management: A hazardous waste accumulation site is an area where HWs may be accumulated, temporarily, before being transported to a permitted, offsite waste disposal facility. The HWMs are assigned as the program manager for these facilities. The HWMs shall ensure that the administration, storage management, container management, and inspections are conducted in accordance with this Manual. The Accumulation Site is designed to be a temporary storage site for wastes. Wastes shall be picked up by a contractor and transported to a treatment, storage, and disposal facility (TSDF) within the site’s regulated allotted time to prevent from being out of compliance. If this storage period cannot be met for some reason (e.g., waiting for analysis results), this information shall be indicated on the Hazardous Waste Accumulation Site Inspection Checklist.

1. Generator EPA ID Number: Pursuant to 40 CFR Part 262.34 and state regulations, the following EPA Numbers have been assigned to each FLETC facility authorized to operate HW Accumulations:

a. Glynco, GA - GA6202932244.

b. Artesia, NM - NMR000002964, NMR000006700 (two sites).

c. Cheltenham, MD - MDR000503847.

d. Charleston, SC - Exempt.

2. General Conditions: The following general conditions shall be met for HW Accumulation Sites at FLETC facilities:

a. Inspections shall be conducted at least weekly and recorded on the Hazardous Waste Accumulation Site Inspection Form, Attachment 1.

b. Certified documents shall be maintained on file at the environmental office for the life of the Center.

c. Records of test results, inspections, waste analyses, and determinations shall be kept on file for the life of the Center.

d. A current copy of the HWMP shall be maintained at each HW Accumulation Site.

3. Storage/Container Management: The following storage/container management procedures shall be followed at all HW Accumulation Area(s)/Site(s):

a. Accumulation areas for containers of HW shall have a containment system with sufficient capacity to contain 10 percent of the volume of all containers, or 110% of the volume of the largest container, whichever is greater.

b. Inside storage of 55-gallon HW drums shall be within a structure designed to store HW.

c. Incompatible wastes shall be segregated, including separate secondary containment.

d. Storage areas shall be provided with adequate ventilation and lighting.

e. Storage areas shall not be located near any drainage system.

f. Storage areas shall have proper fire and safety equipment. An appropriate fire extinguisher shall be maintained within 50 feet of the waste storage area.

g. Spill absorbent material and equipment shall be located at the

Accumulation Site.

h. HW containers shall be inspected weekly for container leaks or deterioration. Results shall be documented on Hazardous Waste Accumulation Site Inspection Form (see Attachment 1).

i. HW containers shall be in good condition and shall be compatible with the waste stored in them.

j. HW containers shall be kept closed except when waste materials are being added or removed.

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k. HW containers shall be properly labeled/marked as indicated in Attachments 2 and 3.

l. Manufacturer’s recommendation for properly closing containers shall be retained at the Accumulation Site.

m. The storage areas are either a fenced and locked compound, a surface impoundment or a secured building designed to prevent unknown entry, and shall not be readily accessible by unauthorized personnel. Security and signs are provided in accordance with the requirements below.

n. Storage areas shall maintain adequate aisle space to allow for the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment.

o. The accumulation start date shall be marked on the container. The accumulation start date is the date that the container is considered "FULL."

p. The specific hazardous identification number of each component, when specified, shall be marked on the container by the HWM.

q. Outdoor HW accumulation site shall be protected from the weather.

4. Security of Accumulation Area: The following security measures shall be in effect for the Accumulation Site:

a. The facility shall be surrounded by a fence,

b. Entrances shall be locked when unmanned, and

c. Lighting shall be provided for the fenced enclosure.

d. FLETC personnel shall immediately report apparent breaches of security at the Accumulation Site to the ESD/ESO or the site HWM.

5. Signage for Accumulation Area:

a. The following signs shall be posted at the 90, 180, or 270-Day

Accumulation Site: A sign, of appropriate size, with the following wording, shall be posted at the entrance:

"CAUTION

HAZARDOUS WASTE ACCUMULATION SITE

AUTHORIZED PERSONNEL ONLY"

b. An 18 x 24-inch, or larger, sign which defines who to notify in case of a spill or emergency. At a minimum, the sign should state:

“IN CASE OF SPILL OR EMERGENCY,

IMMEDIATELY CONTACT SECURITY

(TELEPHONE #)”

c. A “No Smoking” sign will be posted on all four sides of the Accumulation Site.

d. All signs shall be legible from a distance of not less than 25 feet.

F. Satellite Accumulation Area (SAA): HW generators may accumulate up to

55 gallons of HW, or up to one quart of Acutely HW, in containers at or near any point of initial generation [e.g., satellite accumulation area (SAA)].

1. General: The following general conditions shall be met at each SAA area at FLETC:

a. The SAA shall be near the point of generation.

b. The SAA shall be under the control of the HWC of the waste generating work center.

c. All SAA activities shall be placed under the supervision of the

ESD/ESO. This may be delegated to the resident environmental professional at a site.

d. All SAA’s will be inspected on a weekly basis. The HWC will inspect and record inspections on the SAA Inspection Checklist, see Attachment 9.

e. A copy of the Waste Information Document (WID) (see

Attachment 10) shall be maintained, by the HWC, at each satellite accumulation area.

2. SAA Container Management: The following container management procedures shall be followed at each SAA at FLETC:

a. HW containers shall be in good condition and shall be compatible with the waste stored in them.

b. HW containers shall be labeled or marked clearly with the words

“Hazardous Waste,” while waste is being accumulated in them at the SAA.

c. HW containers shall be kept closed (more than finger tight), except when waste materials are being added or removed.

d. Lever-locking rings or drum funnels may be utilized on all open-top drums that contain solid type waste; this does not apply to liquid waste. Rings must be secured by using shower hooks (except when waste materials are being added or removed).

e. Prior to transporting container to the 90, 180, or 270-Day Accumulation Site, lever-locking rings/funnels must be removed and a DOT approved ring and bolt assembly must be installed in accordance manufacturer’s recommendation.

f. All containers shall be properly labeled and marked, per the WID

(see Attachment 10), with a waste material label (see Attachment 2). If the material is hazardous, then a hazardous waste label (see Attachment 3) must be installed on the container in conjunction with the waste material label.

FLETC Manual 025-001 April 2018

g. The accumulation start date shall be marked on the container, when the container is considered "FULL" or 55 gallons is exceeded for that SAA.

h. The specific EPA Waste Number (see Attachment 3), when…