B08_Attachment_No__05_-_SOP_Hazardous_Waste_Management.pdf

Golden Gate National Recreation Area

SUBJECT: HAZARDOUS WASTE MANAGEMENT

PROCEDURE NUMBER: 804 - REVISED

EFFECTIVE DA TE: NtJv'aAIB~ ~ 1}-0CJB

TABLE OF CONTENTS

Standard Operating

Procedures

TABLE OF CONTENTS ....................................................................................................................................... - I -

1. AUTHORITY .................................................................................................................................................. - 3 -

2. CONSEQUENCES OF NON COMPLIANCE ......................................................................................... - 3 -

3. INTRODUCTION ......................................................................................................................................... - 4 -

4. PURPOSE ....................................................................................................................................................... - 5 -

5. ROLES AND RESPONSIBILITIES ........................................................................................................ - 7 -

6. HAZARDOUS WASTE DEFINED .......................................................................................................... -8 -

6 .1 FEDERAL (RCRA) HAZARDOUS WASTE ............................................................... .. ... ...... . ..................... .... ..... - 8 -

6.2 NON- RCRA HAZARDOUS WASTE .... ..... ...... .. .. ........ .. ........................................... .. ........................ .............. - 10 -

6.3 EXTREMELY HAZARDOUS WASTE ..... .... ......................... .... ........ ............. ....... .... ......... .......... ................ ..... ... - 10 -

6.4 SPECIAL WASTE ... . .... .... ... .. . .......... ....... .. ................ . ..... ... ........ ....... .. ............ .... .. .... . .. .... .. ................ ......... .. ... - 11 -

6.5 UNIVERSAL WASTE .. .... .. .... . .. ........ . ... . .......... ... .... ...... ...... .. .. ... .. . .. ............... ... ... .......... ............ ....... .. .... .. ...... .. - 1 l -

6.6 RECYCLABLE HAZARDOUS WASTE ........... ... .......... ......... ............................... . ............ ................... ... ............. - 13 -

6.7 WASrE DETERMINATION .... ...... . ...... ..... .. .. : ................ .... ..... .. .. ........... ....... .... .. .... ... .. ..... ...... ... ...... ........ ..... .... - 13 -

7. GENERAL REQUIREMENTS ................................................................................................................ -14 -

8. EPA IDENTIFICATION NUMBERS ..................................................................................................... - 15 -

9. GENERATOR STATUS DETERMINATION ..................................................................................... - 16 -

10. ACCUMULATION SITE REQUIREMENTS .................................................................................... - 17 -

11. CONTAINMENT BUILDING REQUIREMENTS ........................................................................... - 19 -

12. SATELLITE ACCUMULATION SITE REQUIREMENTS ........................................................... - 20 -

13. ACCUMULATION TIME LIMITS ....................................................................................................... - 20 -

13.1 HAZARDOUS WASTE ... . ....... .. ..... .. .. ... ....... . ... ... ...... .... ... .. ..... . .. ....... .... .............. .... ... ........ .. ... : . .. .... ..... ... ......... -20 -

13.2 UNIVERSAL w ASTE . .. ................. ... . .... .... ..................... ... .. ....... ............. .. .... .. ... .... ... .... ........ .. ....... .. .... .. ... .... . - 2 1 -

14. ACCUMULATION QUANTITY LIMITS ........................................................................................... - 21 -

14.1 HAZARDOUS WASTE ........ . .. ... ..... ..... .. ...... ... ... ..... ..... . ....... ...... ...... ... ... .. .. .... ...... ... ......... .. ... .... ......... .. . .. ... . ..... -21 -

14.2 UNIVERSAL WASTE .. .. ........ .. ...... ... .............. ... ..... .. .. ....... ... .... ... .. ...... ........ ......... .. ........... .... .... ..... ... ....... . .. .. . - 21 -

100% DRAFT

15. LABELING REQUIREMENTS ............................................................................................................. - 21 -

15.1 HAZARDOUS WASTE ....... ......... ............. .................... ... ......................... .. ... .. .... . ............ .. .. ............ ............... -22 -

15.2 UNIVERSAL WASTE ............... ... ........ ... ...... ........... .. .... ...... ...... ....... .... ................................. .... .... ................. - 23 -

15.3 SPECIAL LABELING REQUIREMENTS .. ....................... ..... .. ..... .. .. ... .. .. .. ...... ..... ....... ................. ... ........ .......... - 24 -

16. CONTAINERS USE & MANAGEMENT ........................................................................................ - 24 -

16.1 HAZARDOUS WASTE CONTAINERS ........ ............. ....... .................... .. ........... ....... ..... ... .... .. ........................... - 24 -

16.2 UNIVERSAL WASTE CONTAINERS .............. ............. ....... ..... .... .. ........... ......... ... ... ... . .. .................. ... ... .......... - 26 -

17. REQUIREMENTS FOT INCOMPATIBLE WASTES .................................................................... - 27 -

18. MANAGEMENT OF EMPTY CONTAINERS .................................................................................. - 28 -

18.l EMPTY CONTAINER DEFINED .................. .... ..................... .......... ............ ............. .. .... .................... .............. - 28 -

18.2 MANAGEMENT REQUIREMENTS FOR "EMPTY" Cm.rrAINERS .... ......... ................. .... ............................ ...... - 31 -

18.3 PROVISIONS FOR SPECIAL CONTAINERS: COMPRESSED GAS CYLINDERS, AEROSOL CANS, AND CONTAlNERS

MADE OF ABSORPTIVE MATERIALS .. ....... ..... ........ ....... ......... ..... ..... .. ......... .. ......................... ...... . ....................... - 32 -

19. TRAINING REQUIREMENTS ............................................................................................................. - 32 -

20. RECORDS KEEPING REQUIREMENTS ..................................................................................... - 35 -

20.1 SHIPPING PAPERS .... .... .... ..... ............ ... ............ ..... . ... . ..................................................... .. ......... .......... .... ... - 35 -

20.2 WASTEANALYSIS .... .......... ...... ... ........... ............. ............ ........ .. ..................... .. ... .. .. .. ........................ .......... - 36-

20.3 HAZARDOUS WASTE ACCUMULATION LOG ......... ..... ................. ....... .. ........................................................ - 36 - 20-4 HAZARDOUS WASTE ACCUMULATION AREA WEEKLY INSPECTION LOG ......................................... .. ...... - 3 7 -

20.5 TRAINING .................................................. ..... ...... ..... ............... .. .. ...................... .. ........... ...... ...... ... .. ..... .. ... - 37 -

21. SPECIAL WASTE MANAGEMENT REQUIREMENTS .......................................................... - 37 -

2 1.l USED OIL ............... .. ............................................ .. .. ..... .......... ......... ... ................. ... .... .... ... . ............. ....... .... - 38 - 2 1.2 LEAD-ACID BATTERIES .... ..... .............................................................. ..... ............................ ...................... - 38 -

21.3 USED OIL, GASOLINE, AND DIESEL FILTERS .. ............................................................ .... ............ ..... .......... - 39 -

21.4 C HLOROFLUOROCARBONS AND HALON MANAGEMENT .... ..................................... .. ............ .. ................. .. - 40 - 2 1.5 TREATED WOOD WASTE .......... ..... ..... ... .. ........ ... ... ..... .... .... .. . ............ .... .. ... .... ......... .... .. ... ............. .. .. .......... - 43 -

22. TRANSPORTATION OF HAZARDOUS.WASTE .......................................................................... -45-

23. EMERGENCY RESPONSE PROCEDURES .................................................................................... - 47 -

23.1 EMERGENCY PROCEDURES FOR HAZARDOUS WASTE ACCUMULATION SITES ..... ..... .. ............. .... ......... .. . -47 -

23.2 EMERGENCY RESPONSE TO RELEASES OF UNIVERSAL W ASTE .......................... ... .. ... .... .... .. ........ ...... ....... - 4 9 -

24. AUDIT PROGRAM .................................................................................................................................. - 53 -

APPENDIX A - ROLES AND RESPONSIBILITIES ............................................................................ - 54 -

APPENDIX B - HAZARDOUS MATERIALS/WASTE INCOMPATIBILITY CHART ............... - 56 -

APPENDIX C - GOGA HAZARDOUS WASTE ACCUMULATION LOG ........................................ - 59 -

APPENDIX D - GOGA HAZARDOUS WASTE ACCUMULATION AREA WEEKLY

INSPECTION CHECKLIST .......................................................................................................................... - 60 -

APPENDIX E- GOGA HAZARDOUS WASTE INVENTORY ............................................................ - 61 -

APPENDIX F- GOGA HAZARDOUS WASTE AUDIT PROTOCOL ............................................... - 62 -

APPENDIX G -ABC OF HAZARDOUS WASTE MANAGEMENT ................................................. - 63-

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1. AUTHORI1Y

National Park Service (NPS) facilities, operations, and personnel are required to comply with all

Federal, State, and local laws and regulations pertaining to management of hazardous waste.

The following provide the regulatory framework for management of hazardous waste in the

Golden Gate National Recreation Area (GOGA):

/lii Resource Conservation and Recovery Act (RCRA), Subtitle C - (regulations found in 40 CFR Parts 260 -262, 265, 266, 268, 270, and 279);

/lii Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

- regulations found in 40 CFR Parts 300, 302, 311, 355, and 370);

II- Occupational Safety and Health Act (OSHA) - (regulations found in 29 CFR Parts 1910.120and1910.1200);

I> California Code of Regulations - (regulations found in Title 22, Division 4.5, Chapters 10-12, 15, 16, 18,23,and31);

,..... Executive order No. 12856, "Federal Compliance with Community Right-to-Know Laws and Pollution Prevention Requirements";

/Jo Department of Transportation Requirements (regulations found in 49 CFR Parts 171- 179);

/lo City and County of San Francisco Hazardous Materials Operations and Disclosure Ordinance (Article 21 );

/lii Marin County Code, Chapter 7.8.

2. CONSEQUENCES OF NON COMPLIANCE

As a result of the waiver of sovereign immunity contained in the Federal Facilities Compliance

Act of 1992, regulatory agencies can undertake civil and criminal enforcement actions in response to violations of the above statutes.

The National Park Service (NPS) is subject to civil penalties as an organization; however, individuals are potentially held personally liable and are subject to criminal prosecution. U.S .

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Environmental Protection Agency (EPA) may bring criminal charges against any individuals believed to have knowingly violated the law. Criminal penalties may include substantial fines and imprisonment. In addition to targeting the individual who was directly responsible, criminal prosecutions typically target upper management under assumption that management is responsible for its employee's actions. If a criminal action is taken against a Federal employee, the U.S. Department of the Interior's Solicitor's Office and the U.S. Department of Justice will not represent an individual so charged.

Because the NPS is the landowner, regulatory agencies can hold NPS civilly and criminally liable for the violations of non-NPS park users. NPS may also bear the expense of cleaning areas of contamination caused by non-NPS park users if NPS does not monitor their activities and ensure conformance to applicable laws and regulations. Therefore, the NPS managers are responsible for monitoring the actions of tenants, concessionaries, and special use groups.

3. INTRODUCTION

The Resource Conservation and Recovery Act (RCRA) is the primary regulatory driver for hazardous waste management in the United States. Passed in 1976 and amended twice in the early 1980's, it established the following goals:

11- To protect human health and the environment from the potential dangers of waste disposal;

11- To conserve energy and natural resources through waste minimization, recycling, and recovery; and

11- To ensure that wastes are managed in an environmentally sound manner.

This document serves as GOGA Hazardous Waste Management Standard Operating Procedures

(SOP) and was developed to meet the Federal and State laws and regulations.

The SOP is one of the elements comprising park's comprehensive Hazardous Waste

Management Program and is tailored to those facilities and operations that routinely generate hazardous waste in the park. The GOGA Hazardous Waste Management Plan

- 4 -and GOGA Hazardous Waste SOP are complementary and together make up the written park's program.

This SOP applies to GOGA hazardous waste accumulation and satellite accumulation sites (See

Figure I for a map of accumulation sites.) The SOP also applies to anyone who is involved in management and generation of Universal Waste.

4. PURPOSE

The purpose of this SOP is to ensure that all GOGA employees that routinely come into contact with hazardous waste know the proper management procedures to ensure regulatory compliance and safe practices. The SOP identifies roles and responsibilities and covers procedures for labeling, storage, transportation, inspections, training, emergency preparedness/response and records keeping associated with managing hazardous waste in the State of California.

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FIGURE I: GOGA Hazardous Waste Accumulation Sites

Marin County

· A.Stinson Beach ,&MulrWoods co Q

Legend .A Accumulation Site

£ Satellite Accumulation Site

GGNRA Managed Lands

0 1.550 3, 100 6.200 9.300 12,400 -~-==----c=:=====----Meters

Created by GGNRA Environmental Programs Office, 2007

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Aft. Cronkhite ,AFt. Barry

S F- B ay

Pieri ~Ft.Mason

San Francisco County

5. ROLES AND RESPONSIBILITIES

The following are the roles and responsibilities assigned to GOGA personnel in the following positions. See Appendix A for the names of GOGA personnel and their assigned responsibi Ii ties.

Superintendent: The Superintendent has the primary responsibility for ensuring that operations and facilities are in compliance with the laws and regulations affecting the management of hazardous waste. He/she is responsible for allocating staff and funding to compliance-related activities. The Superintendent is also responsible for ensuring that non-NPS Park users who generate hazardous waste are in full compliance with all applicable Federal, State, and local laws and regulations.

Park Hazardous Waste Coordinator: The Park Hazardous Waste Coordinator is responsib le for the overall implementation of the GOGA Hazardous Waste Management Program. He/she is responsible for revising and updating the program on an as needed basis. An alternate

Coordinator shall be designated to act in the absence of the Park Hazardous Waste Coordinator.

The alternate Coordinator shall be knowledgeable in all aspects of the hazardous waste program.

Emergency Coordinator: Each Hazardous Waste Accumulation and Satellite Accumulation

Areas shall designate in writing its own appropriate Area Emergency Coordinator who will be responsible for initial response to any type of emergencies.

Supervisors: Division Chiefs and all other supervisors shall be responsible for ensuring that all personnel within the area of their responsibility comply with the program.

Waste Accumulation Area Manager: Each Hazardous Waste Accumulation Area shall have a designated Hazardous Waste Accumulation Area Manager who will be responsible for day to day operations.

Satellite Accumulation Area Manager: If applicable, each area in the Park that generates hazardous waste sh all designate its own Satellite Accumulation Area Manager. The Satellite

- 7 -

Accumulation Area Manager shall be responsible for complying with regulations pertaining to

Satellite Accumulation Areas as outlined in this SOP.

GOGA Personnel: GOGA personnel shall deposit their hazardous waste at the nearest

Hazardous Waste Accumulation Area. Waste may not be left unless it is logged in by the

Storage Area Waste Manager or appropriate Maintenance Foremen. If unsure whether the waste is hazardous or not, contact GOGA Hazardous Waste Coordinator.

Non-NPS Users: Hazardous Waste generated by non-NPS users will not be accepted at the

Hazardous Waste Accumulation Areas. The users will be responsible for managing their own hazardous waste and complying will all applicable Federal, State, and local regulations. If ground disturbing activities are anticipated, the users will be notified of any potential environmental hazards through dig permit process. Users will be responsible for bearing the cost of any necessary sampling, worker protection, hazardous waste handling and disposal.

6. HAZARDOUS WASTE DEFINED

Under RCRA, GOGA is required to make a determination whether the waste it generates is hazardous. There are several categories of hazardous waste as defined by the Federal and State statues. Hazardous waste management practices depend on how the waste is classified and its final destination.

6.1 Federal (RCRA) Hazardous Waste

Listed RCRA Waste

Subpart D of 40 CFR 26 1 (Resource Conservation and Recovery Act) lists certain materials from specific and non specific sources and processes that are hazardous wastes by definition. This waste is often called "Federally Listed RCRA Waste". The list is broken down into four major categories as follows:

/$r "F" Waste - from non specific sources such as solvents, plating solutions, and chemical manufacturing processes(< 28 types of materials).

- 8 -

11- "K" Waste - from specific sources such as industrial processes (<l 00 types of materials).

Iii- "U" Waste - toxic discarded chemicals, off specification species, container and spill residues(< several IOOs materials) .

It- "P" Waste - meets definition of "U" waste and is Acutely Toxic Commercial

Chemicals

Each listed waste has an assigned EPA number. See Appendix Bin GOGA Hazardous Waste

Management Plan for listed RCRA wastes.

Characteristic Waste

Characteristic Waste is waste that exhibits the following characteristics: ignitability, corrosivity, reactivity, & toxicity as defined in Subpart C of 40 CFR 26 l .

Corrosivity - the waste is a characteristic corrosive (C) waste if the pH of a substance is less or equal to 2 or more than or equal to 12.5 .

Ignitability - the waste is a characteristic ignitable (I) waste is it can be ignited or will burn at certain conditions. The following are examples of ignitable waste: liquids with less than or equal to 24% alcohol in its mix and has a flash point of less than 140° F; flammable solids that can ignite through friction or contact with water, can com bust spontaneously or if ignited, extremely hard to extinguish; flammable gases; oxidizers which by yielding oxygen cause other materials to ignite.

Reactivity - the was te is a characteristic reactive (R) waste if it is unstable, reacts violently with water, is explosive, is capable of detonation, or has a potential to undergo violent change of state.

Toxicity - the waste is a characteristic toxic (T) waste if it is listed in Section 26 1.24 of 40 CFR.

An example of toxic waste is lead (at levels of more than 5 mg/Liter) and chloroform (at levels of 6 mg/Liter).

- 9 -

Wastes are presumed to be RCRA wastes unless determined otherwise (22 CCR § 66261.100

(b)). Any waste mixed with a listed waste is a RCRA hazardous waste.

6.2 Non-RCRA Hazardous Waste

Non-RCRA waste is presumed to be hazardous by the State of California even though it is not recognized as such by the Federal government and includes

II- California listed wastes (Appendix XII, 22 CCR Chapter 11);

~ Additional 20 inorganic and 18 organic constituents above certain threshold values

(Table lI and III in Article 3 of Title 22 CCR);

~ Containers that are "RCRA-empty" but not "Califomia-empty".1

See Appendix C in GOGA Hazardous Waste Management Plan for California listed wastes and additional inorganic and organic constituents.

6.3 Extremely Hazardous Waste

Extremely hazardous wastes are regulated by the State of California and are defined in 22 CCR §

66261.110 and § 66261 .11 3. According to State regulation a waste is extremely hazardous if it:

~ Has an Acute Oral Toxicity at LD 50 <=50 mg/kg.

II- Has an Acute Dermal Toxicity at LD50 <= 43 mg/kg.

~ Has an Acute Inhalation Toxicity at LC50 <= l 00 ppm.

~ Is listed as carcinogenic in Section 6661.24(a)(7) at a single or combined concentration

=> 0.1 % by weight.

~ Is water reactive.

ti- ls persistent and bioaccumulative.2

1 "RCRA-empty" is defined in 40 CFR 261.7. "California-empty" is defined in Title 22 CCR,§ 66261 .7.

2 For complete and detailed extremely hazardous waste regulation consult T itle 22 CCR,§ 66261. 11 0 and § 66261.1 13.

- l 0 -

6.4 Special Waste

Ao Subset ofNon-RCRA hazardous wastes and includes such materials as ash from burning a fossil fuel, auto shredder waste, sand from sandblasting etc.

Ao Generated in large volumes but pose less hazard.

IS- A generator must apply to California Department of Toxic Substance and Control

(DTSC) to receive an approval to manage hazardous waste as special waste.

Ji. Eligible to be managed at less stringent standards once approved by DTSC. 3

6.5 Universal Waste

Universal waste is a special subset of hazardous waste which is generated universally in large amounts and poses lower health risk to people and the environment. Universal waste is subject to special management provisions under RCRA (40 CFR 273). The provisions were issued to ease the burden of management and encourage recycling of such materials.

Under Federal standards there are currently four types of waste that are covered by the universal waste regulations: batteries, pesticides, Mercury-containing equipment, and lamps. California

Universal Waste Rule adopted in 2000 recognized additional wastes as universal wastes and includes consumer electronic devices, non-empty aerosol cans and Cathode Ray Tube materials.4

California does not recognize pesticides as universal waste; therefore, GOGA wiJI manage all waste pesticides as hazardous waste if they meet the definition.

Universal Waste Lamps

Universal waste lamps include but not limited to Fluorescent, High Intensity Discharge (HID), Mercury vapor, High pressure sodium, Metal halide, and Neon.

Mercury Containing Materials

Mercury containing materials include mercury-containing motor vehicle light switches, non automotive mercury switches, dental amalgam waste, mercury-containing gauges, mercury added novelties, counterweights and dampers, mercury-containing thermometers, mercury-

3 For complete special waste regulations consult Title 22 CCR, § 66261.120 - 122.

4 For complete California Universal Waste regulations consult Title 22 CCR Division 4.5 Chapter 23.

- 11 -containing medical devices, mercury-containing rubber flooring, and mercury gas flow regulators.

Consumer Electronic Devices

Consumer Electronic Devices (CED) include but not limited to computers, telephones, answering machines, radios, stereo equipment, tape players, recorders, CD players, phonographs, VCRs, calculators, and some appliances. CED considered hazardous due to the presence of various metals and other hazardous constituents.

Cathode Ray Tubes

Cathode Ray Tube (CRT) is a vacuum tube or a picture tube used to convert electrical signal into a visual image. "Picture tube" is a more common terminology used to refer to the CRT.

Computer monitors, television, some camcorders, and other electronic devices usually contain

CRTs. CRTs which are more than 4 inches in diameter are presumed to be hazardous unless proved otherwise. 5

Non-Empty Aerosol Cans

Aerosol cans are not hazardous waste when they have been completely emptied of their contents

(does not include cans that contained Federal (RCRA) waste). However, non - empty ones can be classified as hazardous waste if their contents are ignitable, corrosive, reactive, or toxic. Most of the aerosol cans contain flammable propellants which is a characteristic of ignitability.

Batteries

Universal waste batteries include all batteries except vehicle (cranking) spent lead-acid batteries.

Universal waste batteries are hazardous for corrosivity (alkaline or acidic electrolyte), heavy metals (lead, zinc, nickel, cadmium, mercury, silver, etc), and reactivity (unspent lithium batteries).

5 22 CCR Chapter 11 , Appendix X.

- 12 -

6.6 Recyclable Hazardous Waste

The State of California h~s an additional category of waste called Recyclable Hazardous Waste which presumed to be economically and technologically feasible to recycle. This category includes the following materials:

"' Acetone II- Methyl dichloride 11- Benzene ~ Methyl ethyl ketone

"' Butanol II- Mixed hydrocarbon solvents

"" Carbon Tetrachloride ~ Paint thinner ,,.... Chloroform II- Perchloroethylene

"' Ethanol II- Trichloroethane ,.,. Ethyl acetate ,.,. Toluene ~ Ethylene glycol Ao Xylenes

"' Freons II- Used Oil ,1- Hexanes ~ Lead acid batteries

"' Methanol

Within 365 days of the disposal ofrecyclable waste, DTSC may request the generator to provide a written explanation justifying why the recyclable hazardous waste was not recycled.6

6.7 Waste Determination

Each accumulation area is responsible for determining if the waste it generates is hazardous or not. Determination may be based on generator knowledge, commonly taken from a Material

Safety Data Sheet (MSDS). If a determination cannot be made using generator knowledge, contact Park Hazardous Waste Coordinator for further assistance.

A generator must know whether or not the waste is classified as hazardous because:

II-- Improper identification can result in health, safety and environmental problems.

ta- It is the Law: Federal and State regulations require any person who generates waste to determine if it is a hazardous waste as defined by the regulations.

6 For complete Recyclable Hazardous Waste regulations see Title 22 CCR Division 4.5 Chapter 16.

- 13 -

Ao Management of hazardous waste is subject to a number ofregulatory requirements.

Violations of these requirements can result in notices of violations and fines.

Information about the identity of the waste is essential.

If you encounter an unknown waste, contact GOGA Hazardous Waste Coordinator for further assistance.

7. GENERAL REQUIREMENTS

The following general requirements apply to all hazardous waste accumulation sites and their managers. The Section numbers refer to sections of thi s SOP that cover a particular topic.

Ao ID the waste present (Section 6)

Ao Possess an EPA ID Number (Section 8)

11- Package waste in Department of Transportation (DOT) containers (Section 16 ) fl' Follow accumulation time limits (Section 13)

Ao Designate an emergency coordinator and develop and implement contingency, hazard prevention and personnel training plans (Sections 23)

Ao Retain copies of all manifests, test results, and waste analysis for at least 3 years (Section 22) fl' Dispose of all waste at an EPA permitted Treatment, Storage, and Disposal facilities

Ao Never accumulate more than 13,200 lbs ( 6,000 kg) of hazardous waste or 2.2 lbs (I

kg) of acutely hazardous waste (Section 14)

Ao Follow requirements for accumulation & satellite accumulation areas (Sections 10 and 12) fl' Follow waste segregation requirements (Section 17)

Ao Follow labeling requirements (Section 15)

Ao Maintain an inventory (Section 20)

- 14 -

;1-- Conduct weekly inspections (Section 19) l"1 Maintain Training (Section 21)

8. EPA IDENTIFICATION NUMBERS

Both U.S. EPA and California DTSC issue EPA ID numbers to facilities generating hazardous waste. EPA ID number allows regulatory agencies to monitor and track each generator of hazardous waste. EPA ID numbers are site specific. For businesses that have several waste generation locations that are not contiguous, one EPA ID number is needed for each separate address. GOGA has seven EPA ID numbers for each of its current and forn1er hazardous waste accumulation sites which include

Ar Marin Headlands: CAL92 l l 92839;

l"1 Fort Mason: CAL141790195;

Ao Fort Miley: CAR000006494;

/lo Alcatraz: CAR000006 l 06;

Ao Stinson Beach: CAR00000976 l ;

ti- Muir Woods: CAR000009753; and

Ao Presidio: CA0000616094.

Permanent EPA ID numbers can only be used for routine waste generated by each site.7

For all other projects that have a potential for generating hazardous waste, a provisional ID number shall be obtained either from the DTSC or the U.S. EPA depending on the expected waste stream and its volume. If you are anticipating a need for an EPA ID number, contact

GOGA Hazardous Waste Coordinator as soon as possible.

No one shall obtain an EPA ID number prior to consulting with

GOGA Hazardous Waste Coordinator.

7 Routine means waste generated on a day to day basis by maintenance operations.

- 15 -

9. GENERATOR STATUS DETERMINATION

The determination of the generator's status is important since it determines the applicable of hazardous waste management requirements. The RCRA recognizes three categories of hazardous waste generators:

II- Large quantity generator (LQG): facilities generating more than 1,000 kg (2,200 lbs or approximately 275 gallons) of hazardous waste per calendar month or more than 1 kg

(2.2 lbs) of acutely hazardous waste. per calendar month.

/lo Small quantity generator (SQG): facilities generating between I 00 kg (220 lbs) and

1,000 kg (2,200 or approximately 275 gallons) of hazardous waste per month or accumulate less than 6,000 kg (13,200 lbs) of hazardous waste an any time.

/lo Conditionally exempt small quantity generators (CESQG): facilities generating less than I 00 kg (220 lbs or approximately 27 gallons) of hazardous waste per calendar month or less than 1 kg (2.2 lbs) of acutely hazardous waste per calendar month.

CESQG cannot accumulate more than 1,000 kg (2,200 lbs) of hazardous waste, I kg

(2.2 lbs) of acutely hazardous waste, or 100 kg (220 lbs) of any residue from the clean up of a spill of acute hazardous waste at any time.

LQGs have to comply with the strictest requirements. The analysis of past GOGA hazardous waste generation rates showed that the status of its accumulation sites varied from CESQG to

LQG. Currently, all GOGA accumulation sites meet the Federal CESQG status which the State of California does not recognize; and therefore, all hazardous waste accumulation sites within

GOGA are and will be managed as SQG unless they become LQG at any point in time.

GOGA shall strive to maintain its Small Quantity Generator Status.

- 16 -

10. ACCUMULATION SITE REQUIREMENTS

All accumulation areas shall be constructed and managed to include all of the following specifications:

A. Each site shall be secured from unauthorized entry by an enclosure that completely surrounds the accumulation area. The following GOGA personnel, excluding site workers, shall have access keys to the site: Presidio Fire Department, site specific emergency contact person and his back up, and GOGA Hazardous Waste Management

Coordinator.

B. Each containment building shall have signs, visible from at least 25 feet away, that state:

"DANGER - HAZARDOUS WASTE AREA - UNAUTHORIZED PERSONNEL

KEEP OUT" as well as "NO SMOKING".

C. Each containment building shall be labeled according to each hazard class of hazardous waste stored in the area such as "FLAMMABLE'', "CORROSIVES", "TOXIC", etc. If the containment building accumulates a combination of hazardous waste classes, either both or the predominant hazard shall be posted.

D. A sign listing the telephone numbers of people/organizations to call in case of an emergency such as a fire or a spill. In addition, the sign shall state the name of the site's · supervisor and his phone number. At a very minimum, the sign should state: "IN CASE

OF A SPILL OR EMERGENCY, IMMEDIATELY CONTACT PARK DISPATCH 561-

5505".

E. Spill contingency materials must be present in sufficient quantities to contain and manage all possibly emergencies such as small leaks and spills. At a minimum, the required spill contingency materials shall include: one empty 85 gallons Overpack drum, absorbent suitable for the type of waste handled, push broom, flat head shovel, and personal protective equipment such as dust masks, gloves, goggles, and Tyvek suits. Each area

- 17 -where spill contingency material is stored shall be labeled to its content such as "SPILL

KIT" or "SPILL ABSORBENT STORAGE'', and "SPILL CLEAN UP EQUIPMENT".

F. A portable or stationary eye-wash station capable of providing a continuous flow of water for at least 5 minutes. Each station shall be in the vicinity of a hazardous waste accumulation building.

G. Each container used to accumulate hazardous waste shall be labeled to its content.

H. Non - compatible wastes shall be segregated.

I. An up to date inventory shall be kept on site at all times.

J. Only DOT approved containers shall be used to accumulate hazardous waste.8

K. Each accumulation site shall be managed by personnel trained in hazardous waste management.

L. Each accumulation site shall be inspected by the site manager on a weekly basis and by

GOGA Hazardous Waste Coordinator an annual basis to ensure proper and safe management of hazardous waste.

M. Each area shall have a site business plan outlining procedures to follow in cases of emergency.

The following GOGA sites, due to the amount and the type of waste generated, shall be managed as Hazardous Waste Accumulation Areas: Marin Headlands, Fort Miley, and Fort Mason.

8 There wi ll be instances where non DOT containers can be used to accumulate hazardous waste such as universal waste.

- 18 -

11. CONTAINMENT BUILDING REQUIREMENTS

GOGA operates several containment buildings park wide. Under RCRA, at a very minimum, the containment building should have the following features9 l"1 Completely enclosed and self-supporting structure and is 2 hour fire-rated

/lo Secondary containment

II- Leak detection system & internal communication or alarm system capable of providing emergency instructions

Ao A device capable of summoning emergency assistance (must be immediately available on site)

Ao Portable fire extinguishers, spill control equipment, and decontamination equipment

/lo Automatic sprinklers or water at adequate volume and pressure on site l"1 Aisle space to allow unobstructed movement of personnel

/lo Certification by a qualified registered professional engineer (PE) that the building meets the requirements of Federal and State requirements.

Ao Each containment building shall have the following signs displayed at all times:

manufacturer's name, National Fire Prevention Association (NFPA) diamond, and all other applicable signage.

II- In addition to structural and engineering controls, specific work practices, outlined in this SOP, shall be followed to prevent releases and unsafe working conditions.

9 Every hazardous waste accumulation area within GOGA shall accumulate its waste in containment buildings that meet the requirements outlined in 40 CFR Parts 265 .30 through 265 . 3 7 and 265 . I I 00 through 265 .1102 as well as

22 CCR§ 66265 . 1100 through § 66265.1102 and 22 CCR§ 66265.30 through § 66265.3 7.

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12. SATELLITE ACCUMULATION SITE REQUIREMENTS

In addition to hazardous waste accumulation areas, there are areas throughout the park that qualify to be managed as Satellite Accumulation Areas. Satellite accumulation is the collection of hazardous waste in a container, not a tank, located at or near the point where the waste is generated. The container must be under the control of the operator of the waste generation process.

Within a Satellite Accumulation Area, a generator may accumulate up to 55 gallons of hazardous waste at the point of generation. If there are two incompatible waste streams, the generator is allowed to store up to 55 gallons of each waste stream. Within three days ofreaching the 55 gallons limit, waste must be transported to the nearest hazardous waste accumulation area. A generator can keep a satellite accumulation container on-site for a maximum of one year from the date the waste was first placed in the container. Additional requirements are provided in the fo llowing sections.

The following sites within GOGA due to the amount and the type of waste gen~rated shall be managed as Satellite Accumulation Areas: Stinson Beach, Muir Woods, and Fort Barry NIKE facility.

13. ACCUMULATION TIME LIMITS

There are certain requirements for how long hazardous waste can be accumulated on site.

13.1 Hazardous Waste

Each hazardous waste accumulation area shall accumulate hazardous waste for no more than 180 days. In those cases where the disposal faci lities located more than 200 miles away from

GOGA, the waste can be accumulated for up to 270 days.

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13.2 Universal Waste

Universal waste shall not be accumulated for more than 1 year. The disposal of universal waste shall be in sync with hazardous waste to minimize and eliminate the occurrences of the universal waste being accumulated for longer than 1 year.

Hazardous Waste Coordinator is responsible for making sure that the waste is not stored on site for more than 180 days or 270 days if applicable. Each Site Manager shall contact Hazardous

Waste Coordinator when the waste pick up is needed before the 180 days limit.

14. ACCUMULATION QUANTITY LIMITS

There are certain requirements for how much hazardous waste can be accumulated on site at anytime.

14.1 Hazardous Waste

Each hazardous waste accumulation site shall not accumulate more than 13,200 pounds of hazardous waste or 2.2 pounds of acutely hazardous waste. These quantity limits do not include universal waste. Each hazardous waste satellite accumulation area shall not accumulate more than 55 gallons of each waste stream.

14.2 Universal Waste

The quantity limits for universal waste include not accumulating more than 5,000 kilogram and not more than 35 kilogram of drained mercury.

15. LABELING REQUIREMENTS

The Resource Conservation and Recovery Act, Toxic Substances Control Act, and Title 22, California Code of Regulations established specific labeling/marking requirements for hazardous waste containers. All activities that generate and/or accumulate hazardous waste shall comply with all labeling requirements of the aforementioned laws and regulations.

- 2 l -

15.1 Hazardous Waste

Each hazardous waste container shall be labeled and marked in full compliance with the following. The original product's Material Safety Data Sheet is a conventional way to get the information needed to feel out the label. If further guidance is needed, please contact GOGA

Hazardous Waste Coordinator.

A. A hazardous waste label must be placed on the container as soon as the first drop of hazardous waste is placed in it.

B. All labels shall be completed using permanent ink that is not water soluble and will not readily fade i.e. sharpie & china marker.

C. Each hazardous waste label shall have the following information listed:

l. Common name which accurately identifies the content i.e. used oil.

2. Hazard Class i.e. flammable, combustible, etc.

3. Accumulation Start Date.

4. EPA ID number.

5. Site Address

6. Point of Contact

7. Physical state i.e. liquid, solid, etc.

The label has to be readable, legible, and visible for inspection.

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15.2 Universal Waste

A different set oflabeling/marking requirements apply to generators of universal waste. All universal waste labels shall have the accumulation start date and the point of contact. A generator shall mark each individual universal waste to identify the type of waste as specified below.

A. Universal waste batteries or a container in which the batteries are stored, shall be marked as "UNIVERSAL WASTE - BATTERIES", "WASTE BATTERIES", or "USED BATTERIES".

B. Universal waste lamps or a container in which the lamps are stored, shall be marked as "UNIVERSAL WASTE- LAMPS", "WASTE LAMPS", or

"USED LAMPS".

C. Each universal waste electronic device or container/pallet, shall be marked as "UNIVERSAL WASTE- ELECTRONIC DEVICE(S)" or

"UW - ELECTRONIC DEVICE (S)".

D. Each universal waste containing mercury (Hg) or a container in which the mercury waste is stored shall be marked as "UNIVERSAL WASTE - MERCURY

ELEMENTS"

E. Cathode Ray Tubes (CRT) or devices containing CRT, such as a television or a computer monitor, shall be labeled as ''UNIVERSAL WASTE - CRT".

F. Universal waste aerosol cans or a container in which cans are stored, shall be marked as "UNIVERSAL WASTE - AEROSOL CANS", "WASTE AEROSOL CANS", or" USED AEROSOL CANS".

03/30/2007

ACCUMULATION START DATE·---·--·- •... _ .

. John Smith fir· 415-777-7777

SHIPPER •....• _ --------------·-·--- ·· ·-·-- . --- ..•..

112 Fort Mason

ADDRESS

CITY, STATE, ZIP _Sa~ Francisco, CA 94123 ··--

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15.3 Special Labeling Requirements

A different set of labeling/marking regulations apply to generators of certain recyclable wastes.

All recyclable waste shall have the accumulation start date and the point of contact. A generator shall mark individual recyclable waste as specified below.

USED OIL/FUEL FILTERS

Used oil and fuel filters, or the containers in which the filters are stored, shall be marked as

"DRAINED USED OIL FILTERS".

USED LEAD-ACID BA TTRIES

Used lead-acid batteries, or a container/pallet in which the batteries are stored, shall be marked as "USED LEAD-ACID BATTERIES".

USED OIL

In addition to affixing a hazardous waste label per Section 17.1, used oil container has to be visibly marked as "USED OIL".

See Section 21.5 for labeling requirements of Treated Wood Waste.

16. CONTAINERS USE & MANAGEMENT

Containers used to accumulate hazardous waste are managed under 40 CFR Parts 264. 171 - 178 and 22 CCR Section 66265.170. The following provisions apply to containers use and management at all GOGA hazardous waste accumulation sites and hazardous waste satellite accumulation sites.

16.1 Hazardous Waste Containers

Container Has to Be in Good Condition

If a container holding hazardous waste is not in good condition (e.g. severe rusting, apparent structural defects) or if it begins to leak, Area Manager must transfer the hazardous waste form the defected container to a container that is in good condition or to an Overpack drum. When

- 24 -using an overpack drum, adhere to the following guidelines and contact GOGA Hazardous

Waste Coordinator for further guidance if needed.

Overpack containers are available in a variety of sizes and materials. Many hazardous wastes require a specific type of overpack container. Using the wrong container can lead to adverse personal and environmental impacts.

When overpacking leaking containers, it is necessary to place absorbent in the overpack drum. The absorbent material must be capable of soaking up all the liquid contents of the leaking container being overpacked.

Leaking containers of non-liquid hazardous waste (such as powders) may not need be overpacked with absorbent material. In most cases, it is sufficient to place the leaking container in an appropriate overpack drum.

f1,. Overpack containers must be labeled and marked in the same manner as all hazardous waste containers.

Container Has to Be Compatible with Waste

The Area Manager shall make sure that the container made of or lined with material which will not react with, and are otherwise compatible with, the hazardous waste to be stored, so that the ability of the container to contain the waste is not compromised. Consult original product' s

MSDS for compatibility guidelines. If more information is needed, contact GOGA Hazardous

Waste Coordinator.

Containers Holding Ignitable or Reactive Wastes

Precautions must be taken to prevent accidental ignition or reaction of these wastes by separating and protecting them from source of ignition or reaction including but not limited to open flames, smoking, cutting and welding, hot surfaces, frictional heat, sparks, spontaneous ignition, and radiant heat.

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Containers Must Be Closed and Handled Carefully

Containers holding hazardous waste must always be closed except when adding/removing the waste. Containers must be handled and stored in a manner which may not rupture the container and cause it to leak.

Containers Must Be Inspected Weekly

At least weekly, the Area Manager shall conduct a documented inspection of all containers (see

Section 20.4 for additional information).

Containers Must Have a Containment System

Container storage area must have a containment system. The containment system must be free of cracks or gaps and is sufficiently impervious to contain leaks, spills, and accumulated precipitation until the collected material is detected and removed. The base of the containment system must be sloped or must otherwise be designed and operated to drain and remove liquids resulting from leaks, spills, or precipitation. The containment system must have sufficient capacity to contain 10% of the volume of the containers or the volume of the largest container, whichever is greater. Spilled waste and/or accumulated precipitation must be removed immediately from the sump/collection area to prevent any potential overflows.

Pre-Transport Requirements

Before hazardous waste can be transported it has to be packed according to the Department of

Transportation (DOT) requirements as provided in 49 CFR, Subchapter C, Part 178. GOGA is contacting out the transportation and disposal of hazardous waste. The contractor, with GOGA

Hazardous Waste Coordinator oversight, shall meet all applicable DOT requirements.

16.2 Universal Waste Containers

Containers used to accumulate universal waste shall be kept closed, be structurally sound, compatible with waste stored, and lacking evidence of leakage or spillage.

The following containers are being used currently to accumulate universal waste:

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A- Universal waste batteries, used fuel and oil filters - A closed 5 gallons pail.

Ao Universal waste lamps - structurally sound cardboard box and/or 5 gallon pails.

Special Cases

Aerosol Cans - containers must be stored in a well ventilated area to avoid formation of an explosive atmosphere. Must be kept away from heat and open flames.

Universal Waste Lamps, Mercury Containing Materials, Consumer Electronic Devices, and

Cathode Ray Tubes - plastic airtight bag is required if signs of spillage, breakage, & damage are evident.

17. REQUIREMENTS FOT INCOMPATIBLE WASTES

One of the most important rules of any chemical storage, including hazardous waste, is to segregate incompatible chemicals which, if accidentally mixed, could cause fire, explosion, or generate toxic gases. Hazardous chemical reactions can occur from improper storage when incompatible materials mix because of accidental breakage, container failure, fires and earthquakes, mixing of gases or vapors from poorly closed containers, and mistakenly storing incompatibles together because of improperly labeled containers. Additionally, hazardous waste must not be placed in an unwashed container that previously held an incompatible waste/material .

Consult product's MSDS if you are unsure about waste's incompatibility. If more information is needed, contact GOGA Hazardous Waste Coordinator.

To minimize the accidents resulting from storing incompatible materials store each of the following groups of chemicals separately from one another, either in separate cabinets/containers or secondary containers: FLAMMABLE LIQUIDS, COMPRESSED GASES, ACIDS, BASES

LIQUID OXYDIZERS, AND VOLATILE POISONS.

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The U.S. Environmental Protection Agency (EPA), Office of Research and Development has developed a method for determining chemical compatibility (EPA-600/2-80-076, April 1980).

This method in a form of a chart can be used to determine compatibility between various groups of chemicals. The chemical compatibility chart can be found in Appendix B of the SOP. The chart should be used as a guiding reference only. Consult an MSDS for product specific information if needed.

18. MANAGEMENT OF EMPTY CONTAINERS

The U.S. EPA along with DTSC have developed and issued specific management requirements for the containers that used to hold hazardous waste and hazardous materials. Many properties throughout California have been contaminated because containers holding residual hazardous waste and materials were not managed properly.

The State of California has more stringent standards, which GOGA has to follow, for the management of empty containers than what the Federal government has promulgated. The specific State requirements can be found at Title 22, Section 66261.7. The specific Federal requirements can be found at 40 CFR, Part 261.7.

18.1 Empty Container Defined

According to both Federal and State provisions, a container is any portable device in which material can be stored, handled, treated, transported, recycled, or disposed of. The containers can be grossly divided into two categories: containers that have a capacity of more than 110 gallons (bulk containers) and those with a capacity of less than 110 gallons (non bulk containers). Most of the empty containers managed within GOGA are non bulk containers.

U.S. EPA Definition o{an Empty Container10

A container or an inner liner removed from a container that has held any hazardous waste, except a waste that is a compressed gas or that is identified as an acute hazardous waste is empty if:

10 For a full definition see 40 Code of Federal Regulations, Part 26 1.7.

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Ao All wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container, e.g., pouring, pumping, and aspirating, and no more than 2.5 centimeters (one inch) of residue remain on the bottom of the container or inner liner, or

Ao No more than 3 percent by weight of the total capacity of the…