|Submission Date||July 18, 2017|
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Campus Safety Officer
See Hazardous Waste Plan
See Hazardous Waste plan
Hazardous Waste plan:
Saint Joseph’s College
HAZARDOUS WASTE MANAGEMENT PLAN
I. Purpose of Hazardous Waste Management Program
This document describes how the Saint Joseph’s College (“Saint Joseph’s” or the “College”) handles hazardous wastes and complies with applicable federal and state requirements. This program applies to “hazardous waste” as defined under federal and state law, but does not address medical waste or “universal waste.” The College has adopted a separate Universal Waste Management Plan.
Saint Joseph’s College will manage its hazardous waste to maintain its status as a Small Quantity Generator “PLUS” as defined in the Department of Environmental Protection’s (“DEP’s”) Chapter 850 rules (Ch. 850 § 3(A)(5), and the state and federal rules it incorporates. These rules specify limited requirements for those who generate less than 100 kg. per calendar month and do not store more than 600 kgs of non-acutely hazardous waste at any one time (acute hazardous wastes have different quantity thresholds).
Saint Joseph’s College’s policy is to comply with all applicable hazardous waste requirements. This policy is intended to guide the actions of its employees in complying with those requirements. The College has registered for an EPA generator identification number as required by Maine DEP rules for a Small Quantity Generator Plus.
This document should be reviewed and updated annually in October by the Safety Committee Chair, Facilities Chemical Officer and the Director of Facilities Management (S.O.) whenever regulations change.
Appendix A: Emergency Response Personnel, Roles and Lines of Authority describes personnel responsibilities, lines of authority and identifies emergency coordinators as they relate to hazardous waste.
III. Hazardous Waste Determination
The Chemical Hygiene Officer, the Waste Storage Officer and the Safety Committee Chair are responsible for decisions on whether wastes generated at Saint Joseph’s facilities must be considered as hazardous waste. Hazardous waste identification will be conducted in accordance to the DEP’s Chapter 850 rules and those promulgated by the U.S. Environmental Protection Agency’s ("EPA’s”) rules, found in 40 C.F.R. Part 261.
However, the College cannot effectively determine whether wastes are hazardous unless personnel understand that wastes must be identified and brought to the attention of the appropriate person trained in hazardous waste determinations. As a result, there should be a regular reminder to all personnel who may generate or encounter wastes that they must be alert to the question of whether a waste, particularly new wastes, might be hazardous wastes so that they are identified for a hazardous waste determination.
Hazardous waste determinations may be made by knowledge of the waste and how it was generated, or by testing by trained personnel at the College or by an independent laboratory. If it is possible that a waste may be hazardous waste but no final determination has yet been made, the waste shall be managed as a hazardous waste until a final determination has been made.
When the waste determination is made, the College must determine whether the waste is incompatible with other wastes (e.g., it may react violently, give off gases, etc.). As noted below, those wastes must be stored separately.
IV. Hazardous Waste Generation & Storage
A. The following processes and locations have been identified as sources of hazardous waste:
Classroom #8 Environmental/Marine Science Lab – waste generated by experiments.
Classroom #7 Chemistry Lab – waste generated by experiments.
Classroom # 9 Biology Lab – waste generated by experiments.
Classroom # 10 Histology Lab – waste generated by experiments.
B. Proper handling of hazardous waste generated in the above listed labs is the responsibility of the Chemical Hygiene Officer.
C. Waste Handling.
Wastes must be stored only in containers of 55 gallon size or less.
Wastes must be labeled with a permissible DOT label, description, waste code, and a date when the container is full.
Once a container is full at a satellite accumulation area, it must be relocated to the long-term storage area within 72 hours. At the end of each semester, all hazardous waste satellite accumulation areas will be closed and wastes transferred to a long-term storage area.
Wastes must be stored in secondary containment to prevent any spills, and no incompatible wastes may be stored on the same secondary containment.
Hazardous waste is stored no longer than 180 days after a container is filled.
Each container will also be clearly marked as “Hazardous Waste.”
Hazardous waste is stored at the College only in locations that meet hazardous waste requirements.
Satellite Accumulation Areas.
Environmental/Marine Science Lab
Long Term Storage Area. Long-term hazardous storage is located in the basement of Xavier Hall.
Daily Inspections of all hazardous waste areas, Long Term Storage and Satellite Accumulation Sites, are required during “business days.” Inspection checklists are enclosed as Appendix B and C respectively. Missing a daily inspection is a violation of hazardous waste rules.
F. Storage limitations. Saint Joseph’s College is subject to special rules for SQG “Plus” generators because it generates less than 100 kg per calendar month and does not store more than 600 kgs of non-acutely hazardous waste at any one time (acute hazardous wastes have different quantity thresholds). IF THESE LIMITS ARE EXCEEDED, ADDITIONAL REQUIREMENTS IMMEDIATELY APPLY. BECAUSE THE COLLEGE DOES NOT MEET THESE REQUIREMENTS, THE COLLEGE MUST NEVER EXCEED THESE GENERATION OR STORAGE RATES. IF IT APPEARS THAT THE COLLEGE MAY EXCEED THESE LIMITS, IMMEDIATELY CONTACT MANAGEMENT AND MAKE ARRANGEMENTS TO AVOID EXCEEDING THESE LIMITES.
V. Hazardous Waste Treatment
Saint Joseph’s College will not conduct any treatment of hazardous wastes, with the exception noted below. As a general matter, mixing of a hazardous waste and other materials is prohibited.
Generators of laboratory hazardous waste who neutralize hazardous waste (which is solely hazardous by corrosivity characteristic) may do so in quantities less than 500 milliliters per treatment within their laboratory. However, the person conducting the treatment will need to ensure that the waste is only hazardous for corrosivity and not for other hazardous waste characteristics, such as toxicity (including metals), ignitability, or reactivity.
VI. Hazardous Waste Disposal Prohibition
It is the policy of Saint Joseph’s College not to dispose of hazardous waste at any school facility by discharge, dumping, or placement on the ground. The College will manage any spills or leaks as described.
VII. Shipment Off-Site
The College will ship each 55-gallon container of waste off-site within 180 days of the date the drum becomes full.
An appropriately licensed hazardous waste transporter will ship hazardous waste off-site. Hazardous waste will be directed only to appropriately licensed hazardous waste treatment, storage, or disposal facilities. Saint Joseph’s College will ensure that hazardous waste is not shipped to facilities otherwise ineligible because of the land disposal restrictions found in DEP’s Chapter 852 rules or EPA’s land disposal restriction rules found at 40 C.F.R. Part 268.
Prior to shipping any hazardous waste off-site, Saint Joseph’s College will ensure that the hazardous waste is packaged and labeled in accordance with the requirements of the U.S. Department of Transportation, found at 49 C.F.R. Parts 173, 178, and 179.
In addition, because the College must ship wastes under these DOT rules, training is required under the DOT rules for those who ship hazardous waste.
Saint Joseph’s College will initiate and track manifests. DEP’s Chapter 857 rules apply to the College. In particular, a tracking system will enable the Safety Officer and the Chemical Hygiene Officer to react to the failure to receive a return of copy #3 of the hazardous waste manifest within the requisite 35-day period. The Safety Committee Chair and /or the Waste Storage Officer will initiate a tracking process, including making the notifications required by DEP rule.
VIII. “Clean Sweep” Program
Clean Sweep is a program designed to inspect all of the labs that generate hazardous waste in an effort to control any stray or old chemical waste unintentionally left in the labs. The Clean Sweep program will occur annually in May. The Chemical Hygiene Officer will conduct a thorough search of all labs. Any chemicals found will be identified and placed in long-term storage until they can be shipped off-site for treatment or disposal.
IX. Record keeping and Annual Reporting Requirements
Saint Joseph’s College will maintain hazardous waste manifests as specified in DEP’s Chapter 857 rules, including:
Maintain copy #3 of the hazardous waste manifest for three years after receipt; and
Maintain copy #8 of the hazardous waste manifest for three years or until receipt of copy #8
These aforementioned records shall be maintained past the minimum retention period if those documents are involved in the course of an enforcement action or as requested by the DEP or EPA.
Although recordkeeping and annual reporting are not required for small quantity plus generators, Saint Joseph’s College will maintain records as described under federal and state law for large quantity generators, including:
Any laboratory analysis results used in determining whether a material meets the definition of hazardous waste will be retained on-site for a period of not less than ten years.
Any individual who receives, reviews, and signs manifests will be trained to the DOT certification level.
X. Spill/Leak Reporting & Response
Please see the “Hazardous Spill Reporting” section of the Saint Joseph’s College Emergency Response Plan.
XI. Hazardous Waste Minimization Program
Although small quantity generators are not required to adopt a hazardous waste minimization program, the College has attempted to reduce its hazardous waste through substitution and education of those who may generate hazardous waste.
XII. Compliance Assessment
An audit for the Compliance of our Hazardous waste program to the applicable requirements of the law and regulations will be conducted every three years.
When the College ceases to generate hazardous waste, it must commence generator “closure” in accord with the procedures of DEP regulations, Ch. 851, section 11. However, if a satellite accumulation facility or longer term storage area is closed or moved, it would be prudent to conduct “closure” of each area at that time.
APPENDIX A – EMERGENCY RESPONSE PERSONNEL, ROLES AND LINES OF AUTHORITY
APPENDIX B - LONG TERM HAZARDOUS WASTE STORAGE AREA CHECKLIST
APPENDIX C - HAZARDOUS WASTE ACCUMULATION SITE CHECKLIST
All laboratory chemicals are kept on one list, available to all science faculty.
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