Haz Waste Compliance Handout - Rev 05.doc

FLETC HANDBOOK:

HAZARDOUS WASTE COMPLIANCE

Homeland Security

Presented by

Environmental Programs Branch (EVS)

Department of Homeland Security

(Revised 5/03/04)

TABLE OF CONTENTS

1. Introduction………………………………………………………...

2. Hazardous Waste Laws and Regulations……………………..

3. Hazardous Waste at Federal Facilities…………………………

4. Environment and Sanctions………………………………….….

5. Employee Exposure to Hazardous Materials or Waste….…..

6. Elements of Good Hazardous Waste Management.………...

6.1 Hazardous Waste Training Requirements…………..

6.2 Hazardous Waste Management Plan………………..

6.3 Satellite Accumulation Area Requirements………….

6.4 Leaks, Spills, and Contingency Procedures…………

6.5 Waste Information Documents………………………..

6.6 Container Labeling……………………………………..

6.7 Hazardous Waste Pickup……………………………..

6.8 Unused Hazardous Materials…………………………

6.9 Orphan Drums and Unidentified Wastes or Material.

6.10 When is an Empty Container Really Empty?

APPENDICES:

Appendix A: Acronyms Appendix B: Definitions Appendix C: Satellite

ATTCHMENTS:

Hazardous Waste Label Waste Material Label Universal Waste Label

1. Introduction: The Federal Law Enforcement Training Center (FLETC) generates hazardous and non-hazardous wastes as part of its activities training law enforcement officers in various skills. These wastes must be properly managed and disposed of in order to protect FLETC employees, students, contractors, partners and the public from their hazards. Proper management and disposal also protects the natural environment, including air, water, land, animals and plants, from the hazards of these wastes and materials.

EPA and state environmental regulations regarding hazardous waste management apply to many FLETC activities and facilities. Failure to comply with these requirements can result in risk to FLETC staff or students, damage to the environment, and/or violations of law and the subsequent, fees, fines, and penalties that can result from non-compliance.

FLETC is committed to compliance as part of the work we do in training students and operating effective training facilities. This manual is one of several tools FLETC uses to ensure it meets all applicable environmental requirements and protects both human health and the environment.

When working with environmental and safety laws and regulations, people frequently use acronyms and terms that have specific regulatory meanings. The acronyms and definitions for terms used in this manual have been included in Appendices A and B of this document for your ease and reference.

2. Hazardous Waste Laws and Regulations: Federal laws and regulations are intended to protect the environment and human health from hazardous chemicals. To achieve compliance, state and federal governments have implemented a number of regulatory programs. These laws and regulatory programs affect how FLETC employees do their jobs. FLETC tools like the FLETC Hazardous Waste Management Plan help ensure FLETC’s compliance with hazardous waste requirements. Failure to follow proper procedures and meet the requirements of these regulations may result in fines and/or jail terms for FLETC or FLETC employees.

The laws discussed in this course deal with three separate areas of concern:

Occupational Safety and Health - The Occupational Safety and Health Act (OSHA) of 1970 set requirements for worker safety and health.

Transportation of Chemicals - The Hazardous Materials Transportation Act of 1974 authorized the DOT to issue shipping, labeling, and marking regulations for use during transport of hazardous chemicals.

Environmental Protection - A number of laws have been passed to regulate various impacts on the environment, including waste management. These laws include:

· Clean Air - The Clean Air Act (CAA) of 1970 authorized the EPA to control hazardous air pollutants.

· Clean Water - The Clean Water Act (CWA) of 1977 allows the EPA to set water quality and effluent discharge standards for water pollutants.

· Hazardous Waste - The Resource Conservation and Recovery Act (RCRA) of 1976 sets standards for the management controls of hazardous waste (HW.) The Hazardous and Solid Waste Amendments (HSWA) of 1984 revised RCRA and mandated changes designed to protect the nation’s groundwater.

· Toxic Substances - The Toxic Substance Control Act (TSCA) of 1976 sets standards for the management and disposal of toxic substances, like asbestos and lead, and regulates chemicals used in commerce.

· Hazardous Substance Contamination - The Comprehensive Environmental Response Compensation and Liability Act (CERCLA) of 1980 (Superfund) requires reporting of hazardous substance disposal sites and areas made hazardous by old spills, including those on Federal property. It also regulates “Superfund” sites and requires federal facilities transferring property to assess potential for contamination.

· Community Right-to-Know and Emergency Planning - The Superfund Amendments and Reauthorization Act (SARA) of 1986 revised CERCLA and included a Community Right-to-Know provision as well as specific mandates to OSHA and DOT to address problems of HW management.

3. Hazardous Waste at Federal Facilities: Since 1965, Congress has been passing laws governing the management and disposal of solid waste, including hazardous waste in an attempt to resolve or prevent environmental problems. Federal law requires that Federal facilities comply with virtually all the same federal, state, and local pollution control requirements that apply to the private sector.

Federal Sovereign Immunity Waived: In 1992, Congress passed the Federal Facilities Compliance Act, which specifically waived sovereign immunity for Federal facilities regarding hazardous waste requirements, making these facilities not only subject to regulatory requirements, but also subject to fees, fines and penalties from state or EPA regulatory bodies.

All persons at Homeland Security installations must comply with Federal, State, and Local laws, regulations, and permit conditions concerning HW. The intent of Congress and the President is clear; Federal facilities will comply with all Federal, State, and Local HW requirements.

Presidential Executive Orders: Presidents often direct Federal facility compliance with various policies through Executive Orders (EO’s). There are several EO’s that pertain to hazardous waste and environmental requirements, including:

· Executive Order 12088, Federal Compliance with Pollution Control Standards: This executive policy concerns the daily business operations of the Federal Government and pollution control. It states that, “Each Executive agency is responsible for compliance with pollution control standards established in Federal environmental statutes, and must consult and cooperate with State and Local agencies concerning the prevention, control, and abatement of environmental pollution.”

· Executive Order 12856, Federal Compliance with Right-to-Know Law and Pollution Prevention Requirements: This executive order requires Federal agencies and facilities to comply with the same data tracking and reporting requirements that apply to segments of the private sector with regard to emergency planning and community right-to-know reporting requirements. It also requires Federal agencies and facilities to comply with pollution prevention requirements, including establishing pollution prevention plans and accomplishing a 50% reduction in the generation of toxic pollutants. It was revoked and replaced by EO 13101 (which set similar but more extensive requirements.)

· Executive Order 13148, Greening the Government through Leadership in Environmental Management: This EO (passed in April 2000) set dozens of goals and created dozens of requirements, including more specific requirements related to emergency planning and community right-to-know, pollution prevention and waste minimization, toxic chemical use/release reduction, and more.

4. Enforcement and Sanctions: Failure to comply with legal requirements and failure to follow Executive Branch policy, statements, and guidance documents concerning HW can have serious consequences for the Department of Homeland Security and responsible individuals. These consequences can include being exposed to enforcement actions and being subject to legal sanctions. Even though the Director is responsible for compliance, the employee, supervisor and/or manager can be prosecuted in cases of willful violations of environmental laws and regulations.

Enforcement of Hazardous Waste Requirements Who enforces hazardous waste requirements?

· Federal, State, and Local environmental regulatory agency inspectors and investigators enforce HW requirements.

· Whistle Blowers: Employees who turn in their employers for incidents involving non-compliance and violations of RCRA. Whistle blowers are protected from retaliation under Federal law. Any citizen can commence civil action for incidents involving non-compliance and violation of RCRA.

How often will a federal facility that generates hazardous waste be inspected by environmental regulatory agencies?

· EPA is mandated to inspect Federal facilities that fall into the “treatment, storage, and disposal facility” (TSDF) category at least once every 2 years. (A TSDF facility holds an EPA or state-issued “Part B” permit to treat hazardous waste, store hazardous waste for more than 90 days, or dispose of hazardous waste.)

· EPA inspects other hazardous waste-generating federal facilities once a year.

· State and local environmental regulatory agencies have their own schedules for inspections. State regulators often conduct unannounced inspections.

Sanctions What happens if I get caught out of compliance with a HW requirement?

· Non-compliance or violations of HW requirements may result in the regulatory agency taking one or more of the following actions: (1) issuance of a notice of violation, notice of non-compliance, or other regulatory letter; (2) issuance of a warning letter; (3) issuance of an administrative or consent order; (4) assessment of a fine or penalty; (5) conduct of a permit action; (6) civil action; and/or (7) criminal investigation.

The amount of monetary penalty sanctions for non-compliance with or violation of a RCRA requirement depends on the potential for harm, the extent of deviation from the requirement and the facility’s compliance record. Some examples of monetary penalties are:

· RCRA civil sanctions of up to $25,000 a day per violation and/or an injunction;

· RCRA criminal sanctions of up to $25,000 a day per violation and/or up to two years imprisonment per violation (for violations such as withholding or falsifying information);

· RCRA criminal sanctions of up to $50,000 a day per violation and/or up to five years imprisonment per violation (for violations such as willfully or negligently violating a RCRA requirement.)

5. Employee Exposure to Hazardous Materials or Wastes:

Employee Right-to-Know FLETC uses the Hazardous Substances Management System (HSMS) to ensure an accurate and current inventory of the hundreds of hazardous materials used at various locations around FLETC’s Glynco facilities. The Hazardous Materials Coordinator (HMC) is also responsible for maintaining Material Safety Data Sheets (MSDSs) for all hazardous materials used. The initial HSMS Program requirements included the creation and placement of MSDS books in each work group location so that employees would be ensured of access to information about the products they are required to work with. The work group is responsible for keeping the MSDS book updated with current MSDS’s on new materials as well as providing MSDS’s for new materials to the Hazardous Materials Coordinator for the FLETC’s master MSDS files.

Employee Monitoring The EVS periodically contracts with an Industrial Hygienist to monitor employee exposure to HM and HW in order to determine exposure levels and make recommendations as needed to control exposure. Based on work place exposure data, the Industrial Hygienist identifies personnel for inclusion in appropriate medical surveillance programs. Each supervisor must ensure that personnel who work with HM or HW are identified to the EVS for possible inclusion in the appropriate medical surveillance program.

Hazardous Material Exposure Each supervisor will ensure that any HM or HW exposure that results in medical treatment is reported to EVS.

Routine Workplace Hazardous Materials Inspections The supervisor will inspect the workplace to ensure hazardous materials are used safely and in accordance with the manufacturer’s guidelines and information on the MSDS.

6. Elements of Good Hazardous Waste Management:

There are several requirements and procedures put in place by FLETC that ensure compliance with the standards.

6.1 Hazardous Waste Training Requirements:

Per hazardous waste regulations, personnel who handle HW must receive:

· Initial training within six (6) months of assignment to waste handling duties.

· Refresher training annually.

· On-the-job training that teaches them to perform their duties in a way that ensures the facility’s compliance with the requirements set forth by hazardous waste regulations.

6.2 Hazardous Waste Management Plan is the official document used by FLETC personnel for the management of hazardous waste. It is periodically updated; employees should ensure that they are consulting the most current version when they use it. A current copy of it can be obtained from the EVS.

6.3 Satellite Accumulation Area Requirements:

A Satellite Accumulation Area (SAA) is a location where up to 55 gallons of HW or one quart of acutely hazardous waste (HW) of any single wastes stream is accumulated in containers at or near the point of generation. The purpose of SAA’s is to provide reasonable on-site accumulation of wastes at locations where it is generated instead of requiring the waste be constantly delivered to a centralized storage area. Once a drum is full, though, time limits start applying to that container. This is why the Hazardous Waste Coordinator must move the drum promptly to the 90-day storage area. Compliant satellite accumulation areas are not subject to the 90-day storage limitation. The requirements for management of a Satellite Accumulation Area (SAA) for HW, per the hazardous waste management plan are:

· The Hazardous Waste Monitor (HWM) for each work group location will periodically inspect his or her area to ensure that the SAA does not accumulate more than 55 gallons total of any single hazardous waste stream or more than one quart of an acutely hazardous waste stream.

· All HW containers must be made of or lined with material that is compatible with the waste and must be in good condition without leaks or apparent damage.

· The HW container must be kept closed except when it is necessary to add or remove waste. (FLETC has purchased special “open-top funnels” to make it easier in most locations to add waste to a drum. These funnels must be locked closed after each use in order to be in compliance with the closed requirement. For regular drums, the lever lock ring must be latched with shower curtain hook in place, or the ring and bolt in place and wrench tight.)

· The Hazardous Waste Coordinator will label the HW container with its proper description (this information is taken from the WID that identifies the waste material).

· Staging waste (selecting an on-going storage location) at a SAA shall be accomplished with consideration for appropriate storage requirements, including flammable requirements, compatible chemicals, etc.

· The HWM will ensure that all HW is properly collected, segregated and stored at any hazardous waste storage location. The HWC will ensure that containers are properly marked and labeled and that the markings and labels continue to be legible and accurate. Appendix C provides a checklist the HWM may want to use in periodically inspecting his or her own work area.

· The Hazardous Waste Coordinator (HWC) will conduct an inspection at least once a day of all SAA’s. The HWC will send the completed inspection checklist to EVS who will then forward the information to the work group location supervisor if there are any discrepancies that must be addressed. The supervisor will ensure that corrective action is taken on all discrepancies noted during the inspection.

6.4 Leaks, Spills and Contingency Procedures:

All spills of chemicals, hazardous materials and hazardous waste shall be reported to EVB immediately. Minor leaks and spills (less than one gallon) must be contained and cleaned up at once, using absorbing/neutralizing materials. Most shops have employees qualified to accomplish small cleanups. For assistance, work groups may contact the Hazardous Waste Coordinator, who will also conduct clean-ups.

Spill reporting and contingency procedures are located in the Integrated Contingency Plan (also known as “the One Plan”), which is distributed in most hazardous material and waste storage locations and can also be found on the FLETC local area network at:

6.5 Waste Information Documents:

Before any HW can be disposed of, it must have an appropriate and accurate Waste Information Document (WID). A WID is a profile document that is developed by FLETC’s EVS, using information obtained through testing and interviews of shop personnel for each waste stream at the FLETC. It includes directions for handling, packaging, and disposal of hazardous, non-hazardous and non-regulated wastes.

If a WID for a particular waste stream already exists, a copy of the WID must be located/obtained in order to ensure its directions are reviewed and followed. The Hazardous Materials Custodian for each work activity should keep WID’s on file for each and every waste stream generated at that activity’s location(s). When a new WID is needed or an existing WID needs to be updated, a copy of the current MSDS must accompany information sent to EVS with the request for a new or updated WID.

6.6 Container Labeling:

Hazardous Waste Coordinator shall ensure that hazardous waste containers are marked and labeled in accordance with the WID. All HW containers require a yellow waste material label be affixed. Proper liners are to be used for solid waste containers. Both container and liner labels must be identical and affixed prior to use. All HW also require HW label.

Prior to delivering the empty container for hazardous or other waste, the Hazardous Waste Coordinator shall affix the appropriate labels to the container as directed per the WID. The HWC shall complete the label in this order:

1. Description (VERBATIM PER THE W.I.D.);

2. WID number;

3. Hazardous Materials Custodian signature.

Prior to filling the container, the Hazardous Waste Monitor will check the labels to ensure they are correct and accurate.

6.7 Hazardous Waste Pickup:

When the SAA accumulates a maximum of 55 gallons of any hazardous waste stream or one quart of an acutely hazardous waste stream, the Hazardous Materials/Waste Monitor must notify the HWC or EVS for HW pickup. The HWC will enter the accumulation date part of the pick up process using an indelible marker and will ensure that it is entered prior to delivering the container to the 90-day storage area. He or she will also position new labels in a conspicuous area on the container; correct faded or marred markings prior to movement to the 90-day accumulation site; and ensure each container is positioned so that the labels are clearly visible.

The HWC will pick up and sign for the accumulated waste within 4 business hours of the transfer request.

6.8 Unused Hazardous Materials:

Unopened or unused HM which are no longer needed by a shop or organization are not automatically considered HW. This is true even when the documented shelf life has been exceeded. In the event a work center identifies hazardous materials that are surplus to its needs, it should contact the EVS who will evaluate the material and try to identify a use for it. Such materials will only be disposed of as a hazardous waste when all other options have been exhausted.

6.9 Orphan Drums and Unidentified Wastes or Materials:

When a Hazardous Materials/Waste Monitor finds an unmarked, unlabelled container that is not empty, but cannot identify its contents, he or she should contact EVS for assistance. EVS will conduct appropriate sampling to determine what the material is. Once identified, the EVS will make determination on proper disposition of material. If no uses are found, the material will be determined to be a waste and will be disposed of appropriately.

6.10 When is an Empty Container Really Empty?

A container of hazardous waste is considered empty ONLY if:

· All waste has been removed using the practices commonly employed to remove materials from the container (e.g., pouring, pumping, and aspirating);

· No more than 2.5 centimeters (one inch) of residue remain on the bottom of the container or inner liner;

· For containers that held a compressed gas hazardous waste, the container is empty when the pressure in the container approaches atmospheric pressure;

· For containers or inner liners removed from containers that held an acute hazardous waste, the container is empty if the container or liner has been triple rinsed using a solvent capable of removing the commercial chemical product.

NOTE: Although the above regulations meet the definition of “empty”, the FLETC policy is that no container is considered “empty” until they are wiped out or dried to the point that no “free liquids” can be released to the environment.

Appendix A Acronyms AUL - Authorized Use List

CERCLA - Comprehensive Environmental Response, Compensation, and

Liability Act (The Superfund Law)

CO - Carbon Monoxide

CFR - Code of Federal Regulations

DEP - Department of Environmental Protection

DOT - Department of Transportation

EPA - Environmental Protection Agency

EVS - Environmental and Safety Division

HM - Hazardous Material

HMC - Hazardous Materials Coordinator

HWM - Hazardous Waste Monitor

HSWA - Hazardous and Solid Waste Amendments (1984 RCRA Amendments)

HW - Hazardous Waste

HWC - Hazardous Waste Coordinator

Mg/m3 - Milligrams per Cubic Meter

MSDS - Material Safety Data Sheet

OSHA - Occupational Safety and Health Administration, PH - Potential of Hydrogen (a measure of acidity and alkalinity) ppm - Parts Per Million

RCRA - Resource Conservation and Recovery Act

SAA - Satellite Accumulation Area

SARA - Superfund Amendments and Reauthorization Act

TSCA - Toxic Substance Control Act

WID - Waste Information Document Appendix B

Definitions Acid: A chemical substance that has the ability through ionization to dissolve certain metals and form salts or react with bases or alkali to form salts. Acids are generally grouped as either organic or inorganic.

Acutely Hazardous Waste: Hazardous waste (HW) that has been identified in Title 40 of the Code of Federal Regulation (40 CFR), Part 261.31 by the Hazard Code “H” and in 40 CFR 261.33 (e) as the “P” list. Acutely hazardous wastes are hazardous wastes that have been found to be fatal to humans in low doses; or, in the absence of data on human toxicity, have been shown in studies to have an oral lethal dose (LD) 50 Toxicity (rat) of less than 50 milligrams per kilogram, an inhalation lethal concentration (LC) 50 Toxicity (rat) of less than 2 milligrams per liter, or a dermal LD 50 toxicity (rabbit) of less than 200 milligrams per kilogram; or is otherwise capable of causing or significantly contributing to an increase in serious irreversible, or incapacitating reversible, illness. (Example: If 100 rats were given a lethal dose (LD 50) of less than 50 milligrams per kilogram, 50% of the rats would die; if 100 rats inhaled a lethal concentration (LC 50) of less than 2 milligrams per liter, 50% of the rats would succumb).

Authorized Use List (AUL): A current inventory (for a particular FLETC work location) of all Hazardous Materials (HM), chemical substances, or components known or suspected to contain HM which have been authorized by Environmental and Safety Division for use at that FLETC location. Each HM on the list is assigned a unique identifier that relates it to a Material Safety Data Sheet (MSDS) with the same identifier. AULs are part of the Hazardous Substance Management System (HSMS).

Base: A compound with the ability through ionization to react (neutralize) with acids to form salts. The pH range of basic solutions is from 7.1 to 14. Bases are sometimes called “alkaline.”

Clean Water Act (CWA): Legislation that sets forth authorities, standards and processes for the protection and improvement of our nation’s water resources. Also known as the Federal Water Pollution Control Act. Various section address a variety of requirements, including water quality standards, wastewater discharges, wetlands protection, and enforcement authority.

Combustible Liquid: Per DOT standards, is a liquid that does not meet the definition of any other DOT hazard class, and having a flash point above 141°Fahrenheit (F) (60.5ْ Celsius (C)) and below 200ْF (93ْC). A flammable liquid with a flash point at or above 100ْF (38ْC) can be re-classed as a combustible liquid, if it does not meet any other hazard definition and is to be transported by vessel or aircraft, or if it is an intentionally heated elevated temperature material.

Concentration: The quantity of a substance per unit volume (in appropriate units). Examples: milligrams per cubic meter (mg/m3); parts per million (ppm); and fibers per cubic centimeter (fibers/cc).

Corrosive waste: A waste which (1) is aqueous and has a pH of less than or equal to 2 or equal to or greater than 12.5; or (2) is a liquid that corrodes steel at a rate greater than 6.35mm (0.250 inch) per year at a test temperature of 55OC (13OOF.). A waste which exhibits the characteristic of corrosivity is hazardous waste and has the Environmental Protection Agency (EPA) hazardous waste number D002.

Cradle-To-Grave: The tracking from the source, quantity, concentrations, and type of HW from the originator to final disposition.

Day-Can Container: A container used to hold waste material during working hours (and not overnight). Flammable material containers with self-closing lids are often used as day-can containers.

Department of Transportation (DOT): The Federal agency that is authorized to issue shipping, labeling, and marking regulations for use during transport of hazardous chemicals.

Environmental Protection Agency (EPA): The Federal agency that regulates environmental impacts and activities for the nation, including, but not limited to: hazardous air pollutants; water quality and effluent discharge standards; management and disposal of hazardous waste; pesticides; and spills of hazardous substances.

Extremely Hazardous Materials: Certain materials that are so highly flammable or dangerously toxic that special ordering and handling procedures are mandatory.

Flammable Liquid: Per DOT regulations, any liquid having a flash point (Closed Cup method) of not more than 141° Fahrenheit (F) (60.5ْ Celsius (C)), or any material in a liquid phase with a flash point at or above 100ْF (37.8ْC) that is intentionally heated and offered for transport at or above its flash point except under certain exceptions (see 49 CFR 173.120). There is also a definition for “ignitable waste” per EPA regulations (see below).

FLETC Hazardous Waste Coordinator (HWC): The person responsible for the operation of the 90-day accumulation site.

Hazardous Material (HM): Any material, which, because of its quantity, concentration, or physical, chemical or infectious characteristics, may pose a substantial hazard to human health and/or the environment. When used in reference to transportation, the term “hazardous material” means a material that poses a hazard when transported in commerce. Excluded from the FLETC definition of hazardous material are: (1) weapons; (2) medical and pharmaceutical supplies; (3) medical waste and infectious materials; (4) sewage and garbage; and (5) those radioactive materials which the Nuclear Regulatory Commission control. (These are regulated under other standards.)

Hazardous Materials Coordinator (HMC): The person who is responsible for the management of the FLETC Hazardous Substance Management System.

Hazardous Waste Monitor (HWM): The employee in each work location who is responsible for the management and oversight of HM and HW in their location, including coordination for the Hazardous Substance Management System (HSMS).

Hazardous Substance: A specific list of chemicals designated by EPA, which pose a threat to the environment when, discharged or spilled. Hazardous substances are regulated only when they are discharged above certain quantities (called reportable quantities). This term is used somewhat interchangeably with the term “hazardous material.”

Hazardous Substance Management System (HSMS): The computer-based inventory and management system used at FLETC to oversee the storage, use, management and disposal of hazardous materials and hazardous substances.

Hazardous Waste (HW): A solid, liquid or gaseous waste, which is included in specific lists of hazardous waste (in 40 CFR 261), or has the characteristic(s) of ignitability, corrosivity, reactivity, or toxicity as defined in 40 CFR 261.

Hazardous Waste Generator: Any person, by site, whose act or process produces HW identified or listed in 40 CFR 261, or whose act first causes a hazardous waste to become subject to regulation (40 CFR 260.10). (NOTE: This term is often used to refer to a facility producing hazardous waste in quantities greater than 1000 kg/mo [≈ 2205 lb/month] or any amount of acute waste but can refer to lower level generators as well.)

Hazardous Waste Management Plan: A plan designed to set forth written instructions for affected FLETC personnel on the proper management of hazardous waste. This plan is applicable to all Government, contractor, and partner organization personnel.

Hazardous Waste Minimization: The reduction, to the extent feasible, of any solid or HW that is generated at a facility or subsequently treated, stored, or disposed of.

Hazardous Waste Originator: Within the FLETC, a person, by site, who produces HW by act or process, is an originator. An originator would typically be a particular work group, department, branch, work center, or other organization.

Hazardous Waste Storage Site (90-Day): A designated location meeting specific physical requirements where HW is stored for up to 90 days prior to removal for disposal. Storage of HW longer than 90 days without a specific permit constitutes a violation.

Ignitable waste: A waste which is (1) liquid other than an aqueous solution containing less than 24% alcohol by volume with a closed cup flash point less than 60°C (140°F.); (2) a non-liquid and capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture, or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard; (3) an ignitable compressed gas; or (4) an oxidizer.

Irritant: A substance that upon immediate, prolonged, or repeated contact with normal living tissue will induce a local inflammatory reaction, which may be slight, moderate, or high (Also see sensitizer).

Material Safety Data Sheet (MSDS): A OSHA-required data sheet, which provides information on the ingredients, hazards and proper handling of a hazardous material or substance. Its informational contents are intended to enable employees working with the material to understand how to adequately protect themselves while using it. MSDSs include information on: hazardous ingredients, chemical properties, fire or explosive data, safe handling and use, and necessary information for emergency medical attention.

Non-Hazardous Waste: Any waste material that poses no hazard through disposal and is not regulated by either EPA or DOT requirements.

Non-Regulated Waste: Waste material determined to not be hazardous waste per the EPA standards in 40 CFR 261, but is still controlled, documented, and tracked (i.e., oily rags, empty aerosol cans, latex paint waste, etc).

Occupational Safety and Health Administration (OSHA): The agency assigned to regulate occupational safety and health for American workers. Created in 1970 when the Occupational Safety and Health Act was passed, which sets forth requirements for worker safety and health in the U.S.

Oxidizer: A compound that spontaneously evolves oxygen at room temperature or under slight heating. These chemicals can react vigorously when stored near or in contact with certain organic compounds. These materials provide oxygen when involved in a fire, making the fire more difficult to extinguish. (Storage areas for oxidizers should be well ventilated and kept as cool as possible).

Poison: A substance which when taken in small quantities or low concentrations by mouth, or is inhaled or absorbed through the skin, rapidly jeopardizes life by other than mechanical or physical action.

Reactive waste: A waste which: (1) is normally unstable and readily undergoes violent change without detonating; (2) reacts violently with water; (3) forms potentially explosive mixtures with water; (4) when mixed with water generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment; (5) is a cyanide or sulfide bearing material which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment; (6) is capable of detonation or explosive reaction if subjected to a strong initiating source, or is heated under confinement; or (7) is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.

Reclaimed: A material processed to recover a usable product or to regenerate a material.

Recycled: A material that is used, reused, or reclaimed.

Reused: A material that is employed as an ingredient in an industrial process to make a product or employed in a particular function or application as an effective substitute for a commercial product.

Satellite Accumulation Area (SAA): An area where a generator may accumulate as much as 55 gallons of HW or one quart of acutely HW in containers at or near the point of generation without regard to the 90-day storage limitation.

Sensitizer: An irritant that will cause hypersensitivity of normal living tissue, through an allergic or photodynamic process, the hypersensitivity of which becomes evident on its reapplication.

Site: Defined as a “geographic contiguous property in single ownership”. This definition is important since at a typical federal facility, anyone (host or partner organization) generating a HW affects the facility’s hazardous waste generator status. As the generator, the facility becomes the responsible for the wastes generated. The facility director assumes the legal responsibilities for compliance and liabilities, including fines and penalties.

Solid Waste: Any solid, liquid, semi-solid, or contained gaseous material resulting from industrial, commercial, mining, agricultural, or community activity which is discarded or is being accumulated, stored, or physically treated prior to being; has served its original intended use and is discarded; or is a manufacturing by-product and is sometimes discarded.

Spills: Any spilling, leaking, pumping, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment.

Solvent: A liquid chemical capable of dissolving another substance. Most solvents used at FLETC are organic (i.e., acetone, propanol, trichloroethane, etc.)

Toxic substance: A substance that demonstrates the potential to produce death, short- or long-term disease, or bodily injury to a person through ingestion, inhalation, or absorption.

Universal Waste: Any hazardous waste that is managed under the universal waste requirements of 40 CFR 273, including batteries, pesticides, thermostats, and lamps (such as fluorescent lamps).

Waste Information Document (WID): The WID is the profile document that is developed by FLETC’s Environmental and Safety Division, using information obtained through testing and interviews of shop personnel for each waste stream at the FLETC. It includes directions for handling, packaging, and disposal of hazardous, non-hazardous and non-regulated wastes.

Waste Stream: Wastes of a single kind generated at a particular location or from a particular process that share the same characteristics and contents with regard to hazardous waste identification.

Waste Stream Identification: The process of properly identifying, planning and handling the disposal of HW generated during the use of HM.

Appendix C Satellite Accumulation Area (SAA) Checklist

Proper containers

Containers in good condition

Closed with locking ring and bolts/bungs

Material segregated by waste stream

Material containerized according to WID

Less than 55 gallons hazardous waste (per waste stream)

Less than one quart acutely hazardous waste

Accumulation start date on label if 55 gallon limit reached

Label properly filled out with number and signature

Material properly described according to WID

Hazardous waste identified with hazardous waste label

Housekeeping

SAA located at or near any point where waste initially accumulates

Necessary WIDs on file

ATTACHMENTS