21._ATTACHMENT17,_FLETC_Hazardous_Waste_Management_Plan.pdf

ATTACHMENT 17

HAZARDOUS WASTE MANAGEMENT PLAN

FEDERAL LAW ENFORCEMENT TRAINING CENTER

Homeland Security

PREPARED BY THE

ENVIRONMENTAL AND SAFETY DIVISION

Revised October 10, 2012

Table of Contents 10-10-12 ii

EXECUTIVE SUMMARY..................................................................................... ES-1

1.0 INTRODUCTION

1.1 Purpose…………………………………………………………………….. 1

1.2 Scope………………………………………………………………………. 1

1.3 Background………………………………………………………………… 1

1.4 Policy………………………………………………………………………. 1

1.5 Updates…………………………………………………………………….. 2

2.0 PROGRAM MANAGEMENT…………………………………………. 2

2.1 Environmental and Safety Office…………………………………………... 2

2.2 Hazardous Waste Coordinator (HWC)…………………………………….. 3

2.3 Procurement Division……………………………………………………… 4

2.4 Property Management Division……………………………………………. 4

2.5 Facilities Management Division…………………………………………… 4

2.6 Hazardous Waste Monitor (HWM)………………………………………... 5

2.7 Major Division and Partnering Organizations…………………………...… 5

3.0 WASTE CLASSIFICATION…………………………………………

3.1 Hazardous Waste Classification…………………………………………… 6

3.1.1 Hazardous Waste from Non-Specific Sources (F-listed)…………………... 9

3.1.2 Hazardous Waste from Specific Sources (K-listed)……………………….. 9

3.1.3 Acute Commercial Chemical Products (P-listed)………………………….. 9

3.1.4 Toxic Commercial Chemical Products (U-listed)………………………….. 9

3.2 Non-Hazardous Solid Waste……………………………………………….. 9

3.3 Universal Waste Classification…………………………………………….. 10

3.3.1 Batteries……………………………………………………………………. 10

3.3.2 Pesticides……………………………………………………………………11

3.3.3 Thermostats………………………………………………………………… 12

3.3.4 Mercury-Containing Lamps……………………………………………….. 13

3.4 Regulated Waste Classification……………………………………………. 13

3.4.1 Used Oil……………………………………………………………………. 14

4.0 WASTE ACCUMULATION PROCEDRUES…………………………. 14

4.1 Hazardous Waste Accumulation Site………………………………………. 14

4.1.1 General…………………………………………………………………….. 15

4.1.2 Storage Management………………………………………………………. 15

4.1.3 Container Management…………………………………………………….. 16

4.2 Hazardous Waste Satellite Accumulation Area……………………………. 24

4.2.1 General…………………………………………………………………….. 24

4.2.2 Container Management……………………………………………………. 24

4.3 Procedure for Establishing New Satellite Accumulation Areas…………… 25

4.4 Control of Unauthorized Entry into Accumulation Site…………………… 25

4.4.2 Signs……………………………………………………………………….. 25

4.5 Temporary Storage Procedures for Hazardous Waste……………………... 25

4.6 Universal Waste Accumulation……………………………………………. 26

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4.7 Used Oil Management Procedures………………………………………… 27

4.7.1 Container Management…………………………………………………… 27

5.0 FLETC WASTE ANALYSIS PLAN…………………………………… 27

5.1 Characterization Test………………………………………………………. 27

5.2 Unknown Waste……………………………………………………………. 28

5.3 Testing Services…………………………………………………………… 28

5.4 Disposal……………………………………………………………………. 28

6.0 WASTE DISPOSAL PROCEDURES…………………………………. 28

6.1 Hazardous Waste Transfer within the FLETC……………………………. 28

6.1.1 Stable Hazardous Waste…………………………………………………... 28

6.1.2 Unstable Hazardous Waste………………………………………………… 29

6.2 Handling Procedures for Hazardous Waste……………………………….. 29

6.2.1 Packaging………………………………………………………………….. 29

6.2.2 Marking…………………………………………………………………….. 29

6.2.3 Labeling……………………………………………………………………. 30

6.2.4 Shipping Papers……………………………………………………………. 30

6.2.5 Transportation…………………………………………………………….. 30

7.0 HAZARDOUS WASTE HANDLERS TRAINING……………………..30

7.1 Training Requirements…………………………………………………… 30

7.2 RCRA Training Program………………………………………………… 30

7.3 Site Specific Training…………………………………………………….. 31

8.2 Annexes……………………………………………………………………..32

9.0 HAZARDOUS WASTE MANAGEMENT……………………………. 32

9.1 Solvents……………………………………………………………………. 32

9.1.1 Solvent Management……………………………………………………… 32

9.1.2 Solvent Substitution……………………………………………………… 32

9.1.3 Solvent Reclaiming………………………………………………………… 32

9.1.4 Unlawful Disposal…………………………………………………………. 32

9.1.5 Solvent Requisitioning…………………………………………………….. 32

9.2 Expanded Ordnance……………………………………………………….. 32

9.2.1 Expended Ordnance Management………………………………………… 33

9.2.2 Unlawful Disposal…………………………………………………………. 33

9.3 Petroleum, Oil, and Lubricants (POLs)……………………………………. 33

9.3.1 POL Management…………………………………………………………. 33

9.3.2 Unlawful Disposal…………………………………………………………. 33

9.3.3 POL Contaminated Soils………………………………………………… 33

10.0 UNIVERSAL WASTE MANAGEMENT………………………………. 33

10.1 Batteries…………………………………………………………………… 33

10.2 Pesticides……………………………………………………………………34

10.3 Thermostats………………………………………………………………… 35

10.4 Mercury Lamps……………………………………………………………. 36

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11.0 WASTE MINIMIZATION……………………………………………… 36

11.1 Hazardous Materials……………………………………………………….. 37

11.2 Pollution Prevention Plan………………………………………………….. 37

12.0 MANIFESTING REQUIREMENTS…………………………………… 38

12.1 Hazardous Waste Manifests………………………………………………. 38

12.2 Exception Reporting………………………………………………………. 38

12.3 Record Keeping……………………………………………………………. 38

12.4 Signature Authority………………………………………………………… 38

Table 3-1 (EPA Toxic Hazardous Waste Numbers)……………………………….. 7 Table 4-1 (Hazardous Waste 90 Day Accumulation Inspection Form)………….. 18

Figure 4-1 (Waste Material Label)………………………………………………… 20 Figure 4-2 (Hazardous Waste Label)……………………………………………… 21 Figure 4-3 (Universal Waste Label)………………………………………………. 22 Figure 4-4 (Pending Analysis)……………………………………………………. 23

Appendix A (Definitions) Appendix B (References) Appendix C (Training Course Outline and Training Record) Appendix D (Hazardous Waste Training Record) Appendix E (List of Acronyms and Abbreviations)

Executive Summary 10-10-12

ES-1

EXECUTIVE SUMMARY

The purpose of the Hazardous Waste Management Plan (HWMP) is to establish the policy, procedures, and requirements concerning the generation, storage, transportation, and disposal of hazardous waste (HW) and universal waste at all Federal Law Enforcement Training Center (FLETC) Facilities.

The HWMP applies to FLETC, all partnering organizations, contractors, subcontractors, supported activities, and visitors to the facility.

The HWMP promulgates applicable requirements related to hazardous materials (HM), HW, and universal waste from procurement to disposal, including: identification of responsibilities, procedures, reporting requirements, security, storage, transportation, and training.

The HWMP defines the HW management process, identifies sources of information relevant to HW management, identifies waste generating activities, and establishes policy and procedures related to the generation, storage, transport, and disposal of HW generated at FLETC. It also defines the universal waste management process and identifies relevant requirements for universal waste at FLETC. Hazardous waste minimization is a goal of any HWMP and is addressed in accordance with Department of Homeland Security (DHS) directives.

The Plan describes reporting and other HW management interface requirements for activities at FLETC.

Section 2.0 identifies the responsibilities of FLETC Divisions, partnering organizations, and personnel with respect to the control and management of HW at FLETC.

Section 3.0 defines the classification of waste subject to policy, procedures and requirements of the HWMP.

Section 4.0 defines conditions which must be met for regulated HW and universal waste to be accumulated onsite. It also describes appropriate procedures and conditions for the storage of waste at the appropriate accumulation site.

Section 5.0 defines the chemical and physical information of any HW which must be determined before the waste can be transferred to the accumulation site.

Section 6.0 defines the procedures which shall be followed to properly dispose of HW and universal waste generated at FLETC.

Section 7.0 defines the training which shall be provided to personnel who handle HW and universal waste generated at FLETC.

Section 8.0 constitutes the FLETC Contingency Plan, designed to minimize hazards to

Executive Summary 10-10-12

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human health or the environment from fires, explosions, or any unplanned release of hazardous materials and/or HW constituents to air, soil, or surface water.

Section 9.0 describes the management of specific classes of HW, including solvents, expended ordnance, and Petroleum, Oil, and Lubricants (POLs) at FLETC.

Section 10.0 describes the management of universal waste consisting of batteries, pesticides, thermostats and lamps.

Section 11.0 constitutes the FLETC Waste Minimization Plan, designed to continuously reduce HW generation, in accordance with Homeland Security directives, by implementing procurement controls, seeking non-hazardous substitution, finding and developing markets for the waste as recyclable material, and total utilization of a hazardous material to eliminate the disposal of the remainder as a HW.

Section 12.0 describes the general requirements of the management and disposition of State and Federal hazardous waste through the use of a manifest.

Hazardous Waste Management Plan 10-10-12

1.0 INTRODUCTION

1.1 Purpose:

The Hazardous Waste Management Plan (HWMP) addresses the mandatory requirements promulgated by 40 CFR Parts 260 through 268, 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 Center (FLETC) sites.

The HWMP provides guidelines for safe handling of hazardous materials from point of generation where they become HW to 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, the FLETC Waste Analysis Plan, HW and universal waste disposal procedures, training, contingency plan measures, and the FLETC Waste Minimization Plan.)

1.1.1 Scope:

Unless otherwise specified, the HWMP applies to all partnering organizations assigned, attached, conducting training, or stationed at the FLETC facilities; all contractor and subcontractor activities providing services to or located at FLETC, and any person visiting or working within the defined property boundaries of the FLETC.

1.1.2 Background:

The primary function of the FLETC is to provide basic and advanced training to personnel from a total of eighty-two (82) Federal Law Enforcement organizations.

Specialized programs are also provided for state and local law enforcement personnel.

1.4 Policy

The HWMP defines the HW management process and identifies sources of information for use in conducting proper HW management. It is designed to protect the rights, safety, and health of FLETC personnel, contractors, the general public, and the natural environment by controlling the quantity, types, transport, storage, and disposal of HW.

Where practical, policy and procedures to reduce the use of HM and generation of HW are specified. This Manual also describes reporting and other HW program interface requirements for all activities located within the FLETC complex.

The following applicable regulations, industry standards, and Center Plans with respect to the classification, management, transport, storage, and disposal of HM and/or HW are hereby incorporated into the HWMP by reference, include:

• 40 CFR Parts 260 through 268, Environmental Protection Agency (EPA);

• 29 CFR 1910.1200, Occupational Safety and Health Administration (OSHA);

• 49 CFR Parts 100-180, Department of Transportation (DOT);

• NFPA 30, National Fire Protection Association (NFPA)

• FLETC Environmental Program Manual (January 2004).

1.5 Updates:

The HWMP shall be reviewed and updated on an annual basis.

2.0 PROGRAM MANAGEMENT

2.1 Environmental and Safety Division:

The Environmental and Safety (EVS) Division HW responsibilities are as follows:

• Serve as the FLETC HW Manager.

• Coordinate with Divisional/Branch Hazardous Waste Monitors (HWM) and interface with and provide guidance to shop supervisors as required by this instruction.

• Develop, implement, and monitor the FLETC HWMM including: Waste

Minimization; Waste Analysis; and Hazardous Waste Inspection.

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

• Coordinate all inspections of FLETC by EPA and State regulators.

• Coordinate contract agreements and compliance audits with HW contractors to ensure federal, state and local regulatory compliance.

• Assist Divisional/Branch HWM and shop supervisors in the management of HW activities in their appointed duties.

• Develop and publish 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 of HW managers/handlers.

• Authorize the establishment, closure, or change in status of HW generation/accumulation sites on the Center.

• Submit budget requirements for FLETC HW disposal costs.

• Supervise, direct, and assist the Hazardous Waste Coordinator (HWC) for all hazardous waste issues and management of the 90, 180, or 270-Day Accumulation Site.

• Respond to all spills and coordinate all spill clean-up for the Center.

• Certify all manifests and paperwork for all shipments of hazardous waste.

• Manifests shall only be signed by individuals granted signatory authority by the

Director, FLETC. The only personnel with signatory authority are ESD /Office Environmental Coordinators (ECs).

• Identify, train, and coordinate all hazardous waste handlers who might generate HW.

2.2 Hazardous Waste Coordinator (HWC):

The HWC is the only person authorized to transport HW within the Center. The HWC shall:

• Be responsible for the overall operation of the 90, 180, or 270-Day Accumulation

Sites.

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

• Conduct weekly inspections of the 90, 180, or 270-Day Accumulation Site utilizing

Hazardous Waste Site Inspection Form (see Section 4.1.2 and Table 4-1).

• Conduct daily inspections of the Satellite Accumulation Areas (SAAs) utilizing SAA

Inspection Checklist (Figure 2-1).

• Certify all contents, labeling, and documentation [Waste Information Document

(WID) (Figure 2-2)] for all HW transferred to the 90, 180, or 270-Day Accumulation Site.

• Pick up all waste from SAAs within four (4) hours of notification from the HWM or shop supervisor.

• Responsible for entering the EPA waste codes (see Figure 4-2) on the label of the container when container is picked up from the SAA, prior to being transferred to the 90, 180, 270-Day Accumulation Site. Ensure accumulation date is entered on label.

• Prior to transporting containers to the Accumulation Site, ensure that all containers are properly labeled, per Section 4.2.3.

• Deliver empty containers, lever-locking rings/drum funnels, and labels upon request of the HM/WM.

• Respond to all spills over one (1) gallon. Coordinate proper clean-up and disposal of material with ESD/Office.

• Responsible for all record keeping [WIDs (see Figure 2-2]

• Responsible for weighing all drums and documenting on label (see Figure 4-1), and assigning drum I.D. numbers and updating drum logs.

• Responsible for checking all construction/renovation debris dumpsters/roll-off’s on a daily basis to ensure no HW is being disposed of improperly.

2.3 Procurement Division:

The Procurement Division shall be responsible for:

• Coordinating all compliance issues with all onsite contractor/construction contractors generating waste.

• Coordinating with ESD/Office to ensure all onsite contractors/construction contractors are informed of the information contained in the HWMP.

• Ensuring Contracting Representatives conduct regular inspections of contractor sites to ensure compliance with the HWMP.

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

2.4 Property Management Division:

The Property Management Division will coordinate with the ESD/Office in the sale of recyclable hazardous waste materials (i.e., bullet waste, bullet brass, computer, monitors, etc.). Responsible for providing storage for this type of and other recyclable materials that would otherwise be considered HW.

2.5 Facilities Management Division:

The Facilities Management Division shall be responsible for:

• Coordinating all construction/renovation work through ESD/Office to ensure proper disposal and removal of waste generated by the Contractor.

• Ensuring that ESD/Office is informed of all new construction/renovation projects.

ESD/Office will be provided an allotted time during pre-construction meetings to ensure contractor is briefed on HW requirements and compliance issues.

• Supporting the ESD/Office in providing available equipment and personnel for onsite spill response.

2.6 Hazardous Waste Monitor (HWM):

The HWM shall be responsible for:

• Handling and storing waste in accordance with specific instructions provided on the

WID by ESD/Office.

• Maintaining documentation (WIDs, HWMP etc.) of all waste generated onsite, at the work center.

• Ensuring that SAAs are operated in compliance with Section 4.2.

• Coordinating with ESD/Office for establishment and location of new SAAs.

2.7 Major Division and Partnering Organizations:

The HW management responsibilities for the Director of each FLETC Division/Partnering Organizations are as follows:

• Identify all HW handlers. Ensure that individuals, groups, activities, or contractors, who are under the Directors’ authority, and handle, comply with this Plan.

• Appoint one HWM from each shop that generates waste. The HWM and shop supervisors shall serve as liaisons between the ESD/Office and the HWC.

• Ensure the HWM and shop supervisors are trained by the ESD/Office or a qualified trainer designated by the ESD/Office, in accordance with the requirements of Section 7.0, Hazardous Waste Handlers Training.

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

3.0 WASTE CLASSIFICATION:

This section defines the classifications of waste subject to policy, procedures, and requirements of the HWMM.

3.1 Hazardous Waste Classification:

A solid waste, which is not excluded from regulation as a HW as listed in either 40 CFR Parts 260 through 268, EPA, or State regulations, is a HW if it exhibits any of the characteristics of ignitability, corrosivity, reactivity, or toxicity.

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

• A liquid with a flash point of less than 140° Fahrenheit.

• A non-liquid which under normal conditions is capable of spontaneous and sustained combustion.

• An ignitable compressed gas as defined by 49 CFR 173.300.

• An oxidizer as defined in 49 CFR 173.151.

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

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

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

A solid waste is given an EPA waste number of D003 if it exhibits the characteristic of reactivity, including:

• Normally unstable and readily undergoes violent change without detonating.

• Reacts violently with water.

• Forms potentially explosive mixtures with water.

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

• 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.

• It is capable of detonation or explosive decomposition or reaction at standard temperature and pressure.

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

• 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.

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 Table 3-1.

Table 3-1. EPA Toxic Hazardous Waste Numbers

EPAHWN

CONTAMINANT

REGULATORY LEVEL

(mg/l)

D004

ARSENIC

5.0

D005

BARIUM

100.0

D018

BENZENE

0.5

D006

CADMIUM

1.0

D019

CARBON TETRACHLORIDE

D020

CHLORDANE

0.03

D021

CHLOROBENZENE

D022

CHLOROFORM

6.0

D007

CHROMIUM

D023 o-CRESOL

200.0

D024 m-CRESOL

D025 p-CRESOL

D026

CRESOL

D016

2,4-D

10.0

D027

1,4-DICHLOROBENZENE

7.5

D028

1,2-DICHLOROETHANE

D029

1,1-DICHLOROETHYLENE

0.7

D030

2,4-DINITROTOLUENE

0.13

D012

ENDRIN

0.02

D031

HEPTACHLOR

0.008

D032

HEXACHLOROBENZENE

0.13

D033

HEXACHLOROBUTADIENE

D034

HEXACHLOROETHANE

3.0

D008

LEAD

D013

LINDANE

0.4

D009

MERCURY

0.2

D014

METHOXYCHLOR

10.0

D035

METHYL ETHYL KETONE

D036

NITROBENZENE

2.0

D037

PENTACHLOROPHENOL

D038

PYRIDINE

D010

SELENIUM

D011

SILVER

D039

TETRACHLOROETHYLENE

0.7

D015

TOXAPHENE

D040

TRICHLOROETHYLENE

D041

2,4,5-TRICHLOROPHENOL

400.0

D042

2,4,6-TRICHLOROPHENOL

2.0

D017

2,4,5-TP (Silvex)

D043

VINYL CHLORIDE

0.2

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

3.1.2 Hazardous Wastes from Specific Sources (K-listed): HWs from specific sources are known as K-listed HWs. These HWs are generated by specific manufacturing operations. Refer to 40 CFR 261.32 for a specific listing.

3.1.3 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.

3.1.4 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.

3.2 Non-Hazardous Solid Waste:

The following solid wastes are NOT considered to be HWs:

• Household waste.

• 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.

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

• 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.

• 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.

• 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.

• 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:

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

o Hot-draining and crushing;

o Dismantling and hot-draining; and/or o Any other equivalent hot-draining method which will remove the oil.

3.3 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 thermostats, 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 thermostats, 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. .

3.3.1 Batteries:

• Batteries classified as universal waste:

o 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.

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

• Batteries not classified as universal waste:

o Spent lead-acid batteries that are managed under 40 CFR Part 266, Subpart G o Batteries that are not yet waste under 40 CFR, Part 261.

o 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.

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

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

3.3.2 Pesticides:

• Pesticides classified as universal waste:

o Stocks of a suspended and canceled pesticide that are part of a voluntary or mandatory recall under FIFRA Section 19(b), including, but not limited to those owned by the registrant responsible for conducting the recall; or o Stocks of a suspended or canceled pesticide, or a pesticide that is not in compliance with FIFRA, that are part of a voluntary recall by the registrant. It also includes stocks of other unused pesticide products that are collected and managed as part of a waste pesticide collection program.

• Pesticides not classified as universal waste:

o Pesticides not meeting the previously listed conditions. These pesticides must be managed in compliance with the hazardous waste regulations in 40 CFR, Parts 260-272.

o Pesticides that are not wastes under Part 261 including those that do not meet the requirements under Section (4).

o Pesticides that are not hazardous waste. A pesticide is a hazardous waste if it is listed in 40 CFR, Part 261, Subpart D or if it exhibits one or more of the characteristics identified in 40 CFR, Part 261, Subpart C.

• When a pesticide becomes a waste:

o A recalled pesticide becomes a waste on the first date on which both of the following conditions apply:

o The generator of the recalled pesticide agrees to participate in the recall.

o The person conducting the recall decides to discard (e.g., burn the pesticide for energy recovery).

o An unused pesticide product becomes a waste on the date the generator decides to discard it.

• Pesticides that are not wastes:

o Pesticides that are not wastes include unused pesticide products that the generator has not decided to discard (e.g., burn for energy recovery) and recalled pesticides previously described above, provided that the person conducting the recall:

o Has not made a decision to discard (e.g., burn for energy recovery) the pesticide. Until such a decision is made, the pesticide does not meet the definition of "solid waste" under 40 CFR 261.2; thus the pesticide is not a hazardous waste and is not subject to hazardous waste requirements, including this Part 273. This pesticide remains subject to the requirements of FIFRA; or o Has made a decision to use a management option that, under 40 CFR

261.2 does not cause the pesticide to be a solid waste (i.e., the selected option is use (other than use constituting disposal) or reuse (other than burning for energy recovery or reclamation). Such a pesticide is not a solid waste and therefore is not a hazardous waste, and is not subject to the hazardous waste requirements including Part 273. This pesticide, including a recalled pesticide that is exported to a foreign destination for use or reuse, remains subject to the requirements of FIFRA.

3.3.2 Thermostats:

• Thermostats classified as universal waste:

o All thermostats that contain metallic mercury in an ampule attached to a bimetal sensing element, and mercury-containing ampules that have been removed from these temperature control devices.

• Thermostats not classified as universal waste:

o Thermostats that are not yet wastes.

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

• Generation of waste thermostats:

o A used thermostat becomes a waste on the date it is discarded (e.g., sent for reclamation). An unused thermostat becomes a waste on the date the handler decides to discard it.

3.3.3 Mercury-Containing Lamps:

• Lamps classified as universal waste:

o Lamps must be managed in a way that prevents releases of any universal waste or component of a universal waste to the environment.

o Lamps must be contained in containers or packages that are structurally sound, adequate to prevent breakage.

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

• Lamps not classified as universal waste:

o Lamps that are not yet wastes under 40 CFR part 261 o Lamps that are not hazardous waste. A lamp is a hazardous waste if it exhibits one or more of the characteristics identified in part 261, subpart C of 40 CFR 273.

• Generation of waste Lamps:

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

• Small quantity handler of waste mercury-containing lamps means a waste mercury-containing lamp handler who does not accumulate more than 5,000 kilograms total of waste mercury-containing lamps at any time.

• Large quantity handler of waste mercury-containing lamps means a waste mercury-containing lamp handler who accumulates 5,000 kilograms or more total of waste mercury-containing lamps at any time. (Note: The designation as a large quantity handler of waste mercury-containing lamps is retained through the end of the calendar year.)

3.4 Regulated Waste Classification:

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.

3.4.1 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. Used oil that is required to be handled as a hazardous waste consists of the following:

• Mixtures of used oil and listed as hazardous waste;

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

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

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

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

4.0 WASTE ACCUMULATION PROCEDURES:

This section defines conditions which shall be met for regulated HWs and universal wastes to be accumulated onsite at FLETC. As a Large Quantity Generator (LQG) of HW, FLETC may accumulate HW onsite for 90 days or less without a permit, provided certain conditions are met. As a Small Quantity Handler (SQH) of universal waste, FLETC may accumulate universal waste onsite for up to one year. Note: The Artesia and Charleston facility are designated as a Small Quantity Generator (SQG) for HW. SQG are allowed by regulation to store waste on site for 180 days and 270 days if disposal facility is over 200 miles. The Artesia facility is a 270 accumulation site.

4.1 Hazardous Waste Accumulation Site:

A hazardous waste Accumulation Site is an area where HWs may be stored, temporarily, before being transported to a permitted, offsite waste disposal facility. The ESD/Office is assigned as the Site Manager for these facilities. The Site Manager shall ensure that the administration, storage management, container management, and inspections are conducted in accordance with this Manual.

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

• Glynco- GA6202932244

• Artesia- NMR000002964, NMR000006700 (two sites)

• Cheltenham- MDR000503847

• Charleston- SCR000762062

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

• Inspections shall be conducted at least weekly and recorded on the Hazardous Waste

Site Inspection Form, Table 4-1.

• Certified documents shall be maintained on file at the ESD/Office for three (3) years.

• Records of test results, inspections, waste analyses, and determinations shall be kept on file for three (3) years.

• A current copy of the HWMM shall be maintained at each HW Accumulation Site.

ESD/Office.

4.1.2 Storage Management: The following storage management procedures shall be followed at the HW Accumulation Site:

• Storage 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.

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

HW.

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

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

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

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

• Spill absorbent material and equipment shall be located at the Accumulation Site.

• HW containers shall be inspected weekly for container leaks or deterioration. Results shall be documented on Hazardous Waste Site Inspection Form (see Table 4-1).

• Storage areas shall make provisions for security (see Section 4.4). The storage area shall be a fenced and locked compound designed to prevent unknowing entry, and shall not be readily accessible by unauthorized personnel. Security and signs shall be provided in accordance with Section 4.4.2 of this Plan.

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

4.1.3 Container Management: The following container management procedures shall be followed at Accumulation Site at FLETC:

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

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

• HW containers shall be properly labeled as specified in Figures 4-1 and 4-2.

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

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

• Outdoors HW accumulation site shall be protected from the weather.

• Incompatible wastes should be segregated, including separate secondary containment.

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

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

• Spill absorbent material and equipment shall be located at the HW Accumulation

Site.

• HW containers shall be inspected weekly for container leaks or deterioration. Results shall be documented on Hazardous Waste Site Inspection Form (see Table 4-1).

• Storage areas shall make provisions for security (see Section 4.4). The storage area shall be a fenced and locked compound designed to prevent unknowing entry, and shall not be readily accessible by unauthorized personnel. Security and signs shall be provided in accordance with Section 4.4.2 of this Plan.

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

Table 4-1

HAZARDOUS WASTE 90-DAY ACCUMULATION SITE INSPECTION FORM

Weekly Inspection Log

Item to be Inspected Item to be Inspected

Results

Corrective Action(s)

Yes

No

Required

Date

Accomplished

STORAGE AREA

Warning signs present and legible

Secured and locked when not occupied

All security/night lights working properly

Clean and neat (trash, pine straw, leaves etc.)

removed

Adequate aisle space to allow for the unobstructed movement of personnel, fire protection equipment, spill control equipment and decontamination equipment

Weeds and grass properly trimmed and cut

Containment system has sufficient capacity

HAZARDOUS WASTE CONTAINERS

Incompatible wastes segregated in separate, secondary containment areas

Compatible with the waste stored in them

Good condition, with no visible signs of deterioration

No sign of leakage, odors, vapors, or fumes

All drum bungs, rings, and bolts tightly secured

Properly labeled with the words “Hazardous Waste”

Specific hazardous identification number of each component on container (EPA waste code)

Accumulation start date on container

Electrically grounded if highly flammable wastes

SPILL RESPONSE

Spill supplies and equipment readily available

Proper safety equipment readily available

Site-specific SPCC Plan on file

Appropriate fire extinguisher within 50 feet of the storage area (gauge in proper limits)

Alarm system/Communication device available

Emergency eyewash operational/tested

Overpack drums available

EQUIPMENT

Loading ramp inspected and operational

Forktruck inspected and operational

All MHE inspected and operational

Signature of Inspector

Location of Site Date

Figure 4-1. Waste Material Label

Figure 4-2. EPA ID NO. Label

Figure 4-3. Universal Waste Label

Figure 4-4. Pending Analysis

4.2 Hazardous Waste Satellite Accumulation Area:

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)].

4.2.1 General: The following general conditions shall be met at each SAA area at

FLETC:

• The SAA shall be near the point of generation.

• The SAA shall be under the control of the HWM of the waste generating work center.

• All SAA activities shall be placed under the direct control of the ESD/Office ECs.

• All SAA’s will be inspected on a daily basis. The HWC will inspect and record inspections on the SAA Inspection Checklist, see Figure 2-1.

• A copy of the Waste Information Document (WID) (see Figure 2-2) shall be maintained (by the HM/WM) at each satellite accumulation area.

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

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

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

• 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).

• 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.

• All containers shall be properly labeled, per the WID (see Figure 2-2), with a waste material label (see Figure 4-1). If the material is hazardous, then a hazardous waste label (see Figure 4-2) must be installed on the container in conjunction with the waste material label.

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

• The specific EPA Waste Number (see Figure 4-2), when specified by the WID, shall be marked on the container by the HWC.

• HW shall be segregated by waste stream and compatibility.

• HW containers shall be transferred (by the HWC) to the 90, 180 or 270-Day

Accumulation Site within three (3) days after accumulation start date is entered on container. Note: For the Cheltenham facility, the container must be moved the same day. The 72 hour transfer timeframe does not apply to Cheltenham (this is a state requirement).

4.3 Procedure for Establishing New Satellite Accumulation Areas:

Accumulation areas may be established where a new waste generating activity is identified. Prior to establishing any new SAA, the waste generating activity's HWM or shop supervisor shall contact the ESD/Office ECs for authorization and procedures for establishing the new satellite accumulation area.

4.4 Control of Unauthorized Entry into Accumulation Site:

4.4.1 Security: The following security measures shall be in effect for the Accumulation Site:

• The facility shall be surrounded by a fence,

• Entrances shall be locked when unmanned, and

• Lighting shall be provided for the fenced enclosure.

FLETC personnel shall immediately report apparent breaches of security at the Accumulation Site to the ESD/Office.

4.4.2 Signs: 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"

• 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 #)”

• A "No Smoking" sign will be posted on all four sides of the Accumulation Site.

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

4.5 Temporary Storage Procedures for Hazardous Waste:

The Accumulation Site is designed to be a temporary storage site for wastes. Wastes shall be picked up by a contractor and transported to the treatment, storage, and disposal facility (TSDF) on a regular basis to prevent unnecessary accumulation. 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 Site Inspection Checklist, see Table 4-1.

4.6 Universal Waste Accumulation:

Universal waste may accumulate onsite for not more than 1 year from the date that the universal waste is generated. Each handler must be able to demonstrate the length of time that the universal waste has been accumulated from the date it becomes a waste or is received.

The handler may make this demonstration by:

• Placing the universal waste label (Figure 4-3) on a container and marking or labeling the container with the earliest date that any universal waste in the container became a waste or was received.

• Marking or labeling the individual item of universal waste (e.g., each battery or thermostat) with the date it became a waste or was received.

• Maintaining an inventory system on-site that identifies the date the universal waste being accumulated became a waste or was received.

• Maintaining an inventory system onsite that identifies the earliest date any universal waste in a group of universal waste items, or a group of containers of universal waste, became a waste or was received.

• Placing the universal waste in a specific accumulation area and identifying the earliest date that any universal waste in the area became a waste or was received.

• Any other method which clearly demonstrates the length of time that the universal waste has been accumulated from the date it becomes a waste or is received.

4.7 Used Oil Management Procedures:

4.7.1 Container Management: 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. Containers used at used oil generators must be made of or lined with materials compatible with the used oil stored in them. The containers must be closed during storage, except when it is necessary to add or remove used oil, and handled in a safe manner. Secondary containment on tank systems at used oil generators must meet specific requirements including one or more of the following:

• A liner (external to the tank),

• A vault,

• A double-walled tank, or

• An equivalent approved device.

Tank ancillary equipment at used oil generators must also be provided with secondary containment. Tanks used for used oil treatment or storage at used oil generators must follow certain operating requirements such as spill and overfill prevention controls, and maintenance of sufficient freeboard to prevent overtopping.

5.0 FLETC WASTE ANALYSIS PLAN:

This section defines the chemical and physical information of any HW which shall be determined before the waste can be transferred to the 90, 180, or 270-Day Accumulation Site. In order to make the determination that a waste is hazardous, the generator may certify the waste is hazardous by generator knowledge or perform characterization tests to determine which HW characteristic(s) are exhibited.

5.1 Characterization Test:

A characterization test for waste from each continuous process shall be performed annually, or when changes occur in the process. Any new HW stream(s) shall be analyzed and profiled as it is generated.

Characterization testing shall be performed by the ESD/Office; however, all FLETC contractors (both construction and service) shall be responsible for conducting their own waste characterization and approved through the ESD/Office. Characterization testing is not required when the generator can certify, using generator knowledge, that the waste(s) is hazardous in accordance with the criteria established in 40 CFR Part 261. An example of the application of generator knowledge to make the HW determination would be:

spent acid with a pH less than or equal to 2 standard units.

Annual characterization testing, or when a process change occurs, shall be performed when a HW is believed to be, or known to be, hazardous by a characteristic of toxicity.

5.2 Unknown Wastes:

Unknown wastes are discovered at FLETC from time to time. Discovery of unidentified containers shall be immediately reported to the ESD ECs. The contents of these unidentified containers shall be analyzed to determine its waste characteristics for proper disposal. These containers shall be labeled (Figure 4-4) as unknown wastes until identified by analysis. Disposal of the wastes shall be made when analytical results become available. Unidentified containers shall be maintained at the 90, 180, or 270-Day Accumulation Site until disposal.

5.3 Testing Services:

The ESD/Office shall manage the testing services contract. When a container requires testing prior to disposal, the ESD/Office shall:

• Coordinate collection of samples

• Forward samples to the analytical laboratory

• Receive the analytical results and advise the HWC as to proper disposal by generation of a new WID.

5.4 Disposal:

When the waste analysis indicates material is hazardous, the container shall be processed through the 90, 180, or 270-Day Accumulation Site/HWC for disposal. The ESD/Office is responsible for maintaining all analytical results on file.

6.0 WASTE DISPOSAL PROCEDURES:

This section defines the procedures which shall be followed to properly dispose of HW.

6.1 Hazardous Waste Transfer Within the FLETC:

Transfer of HW within the FLETC complex shall only be performed by the HWC. The following procedures for HW transfer shall be followed.

6.1.1 Stable Hazardous Waste: When a HW can be safely transported, the HWC shall move the item to the 90, 180, or 270-Day Accumulation Site for shipment preparation.

• Transportation of HW shall be accomplished in strict accordance with all applicable

Federal, State, and local laws and regulations.

• HW shall not be transported on any public highway or road except by a licensed HW transporter using a Uniform HW Manifest. HW manifests shall only be signed by individuals granted signatory authority by the Director, FLETC. The only personnel with signatory authority are the ESD/Office ECs.

• HW shall not be transported onto FLETC from outside the Center.

• HW shall be properly secured to avoid spills during transport on the Center.

• Containers shall be in a safe-to-handle and non-leaking condition when offered for transportation.

• Incompatible waste shall not be transported on the same vehicle.

6.1.2 Unstable Hazardous Waste: When the HW cannot be safely transported, contact the ESD/Office to receive guidance for transferring the item. The ESD/Office shall determine and provide the proper procedures for either stabilizing or disposing the HW.