CHAPTER 29 - Hazardous Waste Management

 

A. INTRODUCTION

1. This Chapter applies to all Smithsonian Institution (SI) facilities, laboratories, and projects that generate hazardous wastes and establishes policy for hazardous waste (HW) management by identifying the requirements necessary to ensure the protection of human health and the environment.

2. It is the policy of the SI to conduct work in an environmentally sustainable manner, practice pollution prevention (P2), comply with federal, state and local regulations, and continuously evaluate activities for the purpose of reducing potential environmental impacts and ecological footprints.

3. This Chapter focuses on Federal regulations that address the management of hazardous waste. State and local regulations, which are based on Federal regulations and which are often broader in scope and more stringent, are not addressed in this Chapter. Those individuals responsible for the management of HW in SI facilities must be familiar with the state and local regulations that affect their geographic location. Internet links to state HW management regulations are provided at the end of this Chapter.

 

B. CHAPTER-SPECIFIC ROLES AND RESPONSIBILITIES

1. Directors shall:

a. Ensure that a qualified responsible person is appointed to coordinate hazardous waste management in their facility.

b. Ensure adequate funding is provided for personnel, equipment, materials, training and monitoring required to comply with recognized best management practices for hazardous waste management within their facility.

c. Ensure that all facility activities comply with current Federal, State, and local hazardous waste management requirements.

2. Hazardous Waste Coordinators(HWC)shall:

a. Coordinate with facility supervisors to identify all hazardous waste (HW) generation points within the facility.

b. Develop facility protocols for the management of HW by developing and implementing the Hazardous Waste Management Plan (HWMP) in Attachment 3, and by utilizing the assistance of supervisors and OSHEM.

c. Ensure compliance with labeling, accumulation times and applicable container management standards in the Central Accumulation Area (CAA).

d. Establish procedures for timely removal of accumulated HW from the CAA.

e. Serve as the point-of-contact for all HW regulatory environmental inspections.

f. Maintain regulatory compliance documentation that records all HW activities related to the generation, storage, transportation, and disposal of HW.

g. Review and submit the annual or biennial HW report to the EPA and State environmental regulatory agency, as required, and ensure payment of appropriate Federal, State, and local fees related to HW generation.

h. Program and request budget for personnel, equipment, materials, training, and monitoring necessary to comply with HW management requirements.

i. Ensure that coordination occurs as appropriate with the Safety Coordinators in matters relating to the management of HW.

j. Ensure that facility hazardous chemical emergency spill and leak procedures are current, distributed throughout their facility and reviewed with staff on a regular basis.

k. Ensure that OSHEM is notified when there is a release or other event that impacts the environment or compliance status of the facility

3. Supervisors shall:

a. Assist the HWC by identifying hazardous waste generation points under their supervision, and approximate quantities generated, using the facility HWMP.

b. Complete and maintain the Regulated Waste ID Log form, HWMP-2 (Attachment 7). Provide copies of completed forms to the HWC.

c. Ensure the HWMP-2 form is updated whenever there is a change in processes or activities in areas under their authority.

d. Ensure that all employees handling hazardous waste are properly trained within six months of employment and yearly thereafter and that documentation of this training is maintained.

e. Ensure compliance with labeling, accumulation, and applicable container management standards prior to waste disposal.

f. Maintain weekly inspection records for any CAA under their supervision. Attachment 10 or Attachment 13 may be used, as appropriate.

g. Establish a procedure to ensure timely removal of accumulated HW from work areas in coordination with the HWC.

h. Ensure that all hazardous waste spills/incidents are immediately reported to OPS and the facility HWC.

i. Program and request budget for personnel, equipment, materials, training, and monitoring necessary to comply with HW management requirements.

4. Employees shall:

a. Immediately notify their supervisor of any incident involving the uncontrolled release or spill of a hazardous material.

b. Handle hazardous wastes only after appropriate training has been obtained.

c. Notify their supervisor of any activity or changes in work processes that may result in the generation of hazardous waste.

d. Ensure compliance with proper HW labeling, accumulation times, and applicable container management standards prior to waste disposal.

5. Office of Safety, Health, and Environmental Management (OSHEM) shall:

a. Develop directives and policy as needed to implement SI HW policy that governs HW management.

b. Assist with SI cooperation and compliance with Federal, State, and local agencies with regard to HW regulations by providing technical assistance to facilities and through the METR process.

c. Assist in resolving disputes with Federal, State, and local, regulatory agencies as required.

d. Coordinate the notification of appropriate US EPA Regional Administrators, and/or State and Local authorities in the event of incidents were reporting thresholds are exceeded.

e. Provide support to SI facilities by interpreting Federal, State, and local HW regulatory requirements and by uniformly applying SI policy as set forth in this Manual.

f. Provide training, training materials, compliance verification checklists, and guidelines in the area of hazardous waste management

g. Provide oversight to ensure that only properly permitted transporters are used for the offsite transport of HW and that the HW is disposed at a properly permitted treatment, storage, and disposal facility in accordance with Federal and State HW rules and regulations.

 

C. IDENTIFICATION OF HAZARDOUS WASTE

1. Waste with properties that make it dangerous or potentially harmful to human health or the environment is called Hazardous Waste (HW). Hazardous wastes can be liquids, solids, contained gases, or sludges. They can be the by-products of a production or testing process or simply discarded commercial chemical products. Hazardous wastes are regulated by the Resource Conservation and Recovery Act (RCRA) Subtitle C in the Code of Federal Regulations (40 CFR 260-279).

2. To determine if a waste is regulated by RCRA, a generator may either apply knowledge of the material and process that produces the waste, or test the waste using EPA approved test methods as specified in 40 CFR 262.11.

3. A RCRA regulated hazardous waste is a waste that: exhibits at least one of four characteristics-ignitability, corrosivity, reactivity, or toxicity; or appears on one of the four hazardous wastes lists-F-list, K-list, P-list, or U-list. See Attachment 2 for details on waste identification.

 

D. HAZARD CONTROLS

1. The basic controls for the management of hazardous wastes are pollution prevention/waste minimization and compliance with applicable regulations through the development of a Hazardous Waste Management Plan (HWMP).

2. Pollution Prevention/Waste Minimization.

a. SI policy is to reduce the quantity of HW requiring disposal by using the pollution prevention hierarchy of reduction, recycling, treatment, and disposal. The highest priority should be placed on reduction of HW generation at the source.

b. Federal and State regulations require all HW generators to certify (on each Uniform HW Manifest, EPA Form 8700-22) that a program exists to minimize the volume and toxicity of HW generated, insofar as economically feasible.

c. It is imperative that SI facilities strive to achieve continuous reduction of HW generation through pollution prevention initiatives, best management practices, and best demonstrated available technology.

3. Regulatory Requirements

a. SI facilities must comply with all Federal, State, and local regulatory requirements relating to HW. Compliance with all aspects of an EPA-approved State HW management program is deemed to be in compliance with all Federal requirements. However, if a State has a program that is not approved by the EPA, the SI facilities and tenants in that state must comply with both the State and Federal program requirements. Each facility is responsible for knowing and complying with their State and local HW regulations. State programs may be accessed at: http://www.epa.gov/epahome/state.htm

b. This Chapter addresses the federal regulations only. Attachment 1 provides a summary of the federal requirements for HW generators. Additionally, the link below provides access to a more comprehensive but user friendly reference guide for the federal HW generator regulations: http://www.epa.gov/epawaste/hazard/downloads/tool.pdf

4. Hazardous Waste Management Plans (HWMP)

a. A HWMP is a tool designed to be used to ensure minimal compliance with regulations and provide documentation that a facility has a program in place.

b. Each facility shall develop a HWMP that will identify and implement HW management activities required by RCRA and/or by authorized State HW programs.

(1) Individual operational units within each SI facility must provide input to the Hazardous Waste Coordinator for inclusion of their portion of the plan.

(2) The plan must be signed by the senior SI management official at each facility

(3) The HWMP must be provided to all personnel who accumulate, generate, transport, treat, store, or dispose of HW.

(4) The HWMP must be maintained to reflect current facility and tenant organization responsibilities and current regulatory requirements.

(5) It must be reviewed and updated whenever there are facility conditions or operations that affect HW accumulation, generation, transportation, treatment, storage, or disposal change.

c. A generic HWMP template has been provided in Attachment 3.

 

E. TRAINING

1. The HWC shall successfully complete a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility's compliance with applicable environmental regulations. This training shall include but not be limited to:

a. Identification of HW (40 CFR 261)

b. HW accumulation rules for packaging, labeling, and storage (40 CFR 262.34)

c. Manifest (262.20-.23) and Recordkeeping and Reporting requirements (40 CFR 262.40)

d. Implementation of Contingency/Spill Response Plans (40 CFR 265)

e. Personnel training (40 CFR 265)

f. A detailed description of the training requirements for HWC can be found in Attachment 3, HWMP Section 13.3.

2. Personnel handling HW shall be trained by a person trained in hazardous waste management procedures. The training must include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed. (40 CFR 265.16) 3. All personnel must receive training within 6 months of employment in a position that involves handling hazardous wastes, and must not work unsupervised until such training has been completed. Facility personnel must take part in an annual review of the training.

 

F. RECORDS AND REPORTS

1. Reporting and recordkeeping requirements may vary in different jurisdictions. Consult state and local regulatory agencies for more stringent reporting and recordkeeping requirements.

2. Federal reporting requirements include but are not limited to:

a. RCRA Subtitle C Site Identification Form

b. Uniform HW Manifests

c. Manifest Exception Reports

d. Biennial HW Reports

e. Land Disposal Restriction (LDR) Notification or Certification

f. Waste Profiles or Waste Analysis forms

g. Satellite and Central Accumulation Area inspection Forms

h. Contingency/Spill Response Plans

i. Employee training records

3. Further details concerning reporting and recordkeeping are found in Attachment 3, Section 14 of the HWMP.

 

G. REFERENCES

1. Resource Conservation and Recovery Act of 1976 (42 U. S. C. 6901 et seq.)

2. Federal Facility Compliance Act of 1992 (Public Law 102-386)

3. Hazardous Materials Transportation Act of 1975 (49 U. S. C. 5101 et seq.)

4. Smithsonian SD-419

5. Hazardous Waste Generator Regulations: A User-Friendly Reference Document Version 2: May 2007.