COMMONWEALTH OF MASSACHUSETTS
MASSACHUSETTS DEPARTMENT OF TRANSPORTATION
HIGHWAY DIVISION
STANDARD OPERATING PROCEDURES
SUBJECT:
Hazardous Waste Management at MassDOT
Highway Facilities
EFFECTIVE:
11/23/10
ISSUED:
11/23/10
S.O.P.NO. ENV-01-03-1-000
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PURPOSE
To ensure that Hazardous Waste is managed consistent with environmental regulations (reference 310 CMR
30).
RESPONSIBILITY
It is the responsibility of the District Maintenance Engineer or their designee to ensure that District
maintenance facility personnel conduct facility Hazardous Waste Management consistent with the
appropriate generator status (as defined below) and to conduct weekly inspections of Hazardous Waste
accumulation areas where applicable. A copy of the Emergency Spill Response Plan For MassDOT
Facilities must be available at all district maintenance facilities.
The Environmental Management System Compliance Coordinator (ECC) is responsible for ensuring that
inspections of each Hazardous Waste Accumulation Area occur on a regular basis, completing a regular
inspection report for each facility, and maintaining records of the inspections. The ECC reports findings to
the District Maintenance Engineer and to the EMS & Sustainability Unit Supervisor as necessary. The ECC
is also responsible for maintaining a complete file of Very Small Quantity Generator, Small Quantity
Generator, and Large Quantity Generator, generator registrations for the district and for maintaining
manifests, waste profiles and land disposal restrictions for at least three years, or for the duration of any
enforcement action by the Department of Environmental Protection (DEP).
The ECC is responsible for arranging and/or overseeing the removal and disposal of the Hazardous Waste
by a licensed transporter and disposal facility.
POLICY
For the purpose of this policy MassDOT Highway Division Facilities fall into one of four categories: (1)
Not a Hazardous Waste Generator; (2) Very Small Quantity Generator; (3) Small Quantity Generator; (4)
Large Quantity Generator.
Accumulation Areas
Hazardous Waste Accumulation Areas shall be set up in accordance with hazardous waste regulations at
generating facilities. The following standards apply to all MassDOT Hazardous Waste Accumulation Areas:
COMMONWEALTH OF MASSACHUSETTS
MASSACHUSETTS DEPARTMENT OF TRANSPORTATION
HIGHWAY DIVISION
STANDARD OPERATING PROCEDURES
SUBJECT:
Hazardous Waste Management at MassDOT
Highway Facilities
EFFECTIVE:
11/23/10
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They will be located indoors, secured against unauthorized entry, separated from points of generation.
Stand alone weatherproof storage units separated from main facility buildings are allowed;
The accumulation area boundaries will be designated (using tape on floor or painted lines, cones, rope
or other appropriate means;
A HAZARDOUS WASTE sign (all capital letters, one-inch high) shall be prominently posted;
If hazardous waste containers are not stored on spill pallets the floor surface shall be free from cracks or
gaps and impervious to the Hazardous Wastes being stored;
A minimum of 18 inches of aisle space around the drums shall be maintained; Single drums maybe
stored along walls in an appropriate location;
The Hazardous Waste Accumulation Area shall contain only Hazardous Waste and associated
equipment. No virgin product and/or hazardous materials shall be stored in the Hazardous Waste
Accumulation Area;
Containers such as 55-gallon drums shall not be stacked unless separated by a pallet.
Accumulation areas at SQGs and LQGs are inspected weekly by the designated facility personnel. A sample
weekly inspection form is attached. The Weekly Hazardous Waste Inspection Form must be kept on file at
the facility or at the ECC’s discretion be submitted to the respective ECCs office where a file is maintained.
Inspections forms shall be kept on file for one year.
Generator Status - Time Limits and Quantity Limits
The following accumulation limits shall not be exceeded:
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Very Small Quantity Generators (VSQGs) – 2,200 pounds, 270 gallons/or five 55-gallon drums, at a
rate of no more than 220 ponds per month or equivalent
For Small Quantity Generators (SQGs) – 13,200 pounds/or 1620 gallons or twenty-eight 55-gallon
drums at a rate of no more than 220 ponds per month or equivalent
For Large Quantity Generators (LQGs) – No volume limit.
No time limits for storage of hazardous waste apply to VSQGs.
The time limit for the storage of hazardous waste at SQGs is as follows:
 180 days from the date accumulation starts. The start date must be marked on the drum once
accumulation starts.
The time limit for the storage of hazardous waste at LQGs is as follows:
 90 days from the date accumulation starts. The start date must be marked on the drum once
accumulation starts.
COMMONWEALTH OF MASSACHUSETTS
MASSACHUSETTS DEPARTMENT OF TRANSPORTATION
HIGHWAY DIVISION
STANDARD OPERATING PROCEDURES
SUBJECT:
Hazardous Waste Management at MassDOT
Highway Facilities
EFFECTIVE:
11/23/10
ISSUED:
11/23/10
S.O.P.NO. ENV-01-03-1-000
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Satellite Accumulation Areas
The following standards apply to Satellite Accumulation Areas operated at MassDOT Highway
Maintenance Facilities:
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Up to 55 gallons of Hazardous Waste may be generated from a process at the location of the satellite
accumulation;
Storage time is 90 days (LQG) or 180 days (SQG) from the date the first 220 pounds (approximately one
55-gallon drum) has been accumulated;
Only one container may be in use at one time in a satellite location;
Each satellite accumulation area must be managed by the person who is directly responsible for the
process producing the waste;
The waste must be moved to the designated Accumulation Area within three days after the container is full;
Hazardous Waste Containers
The following standards apply to Hazardous Waste containers stored at MassDOT Highway Maintenance
Facilities:
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All containers must be clearly labeled with the words HAZARDOUS WASTE, the name of the waste
(i.e. waste oil, paint waste, waste gasoline); the type of hazard (i.e. toxic flammable, corrosive); and for
LQGs and SQGs only, the date on which accumulation began; for satellite storage areas containers must
be dated once they are full;
All containers must be closed except when waste is being added or removed;
Wastes of different types must be segregated and kept within the boundaries of accumulation area;
Containers holding Ignitable or Reactive wastes must be kept at least 50 feet from the property line.
Self Transporting Requirements
The following standards apply for self-transporting any quantity of Hazardous Waste from MassDOT
Highway Facilities:
COMMONWEALTH OF MASSACHUSETTS
MASSACHUSETTS DEPARTMENT OF TRANSPORTATION
HIGHWAY DIVISION
STANDARD OPERATING PROCEDURES
SUBJECT:
Hazardous Waste Management at MassDOT
Highway Facilities
EFFECTIVE:
11/23/10
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A copy of the VSQG Generator Registration Number must be present in the self-transporting vehicle.;
Only VSQG can self transport to an SQG or LQG
Only waste generated at the facility may be self-transported pursuant to this SOP;
A maximum of 55 gallons of Hazardous Waste may be transported at one time;
The container must be tightly sealed and labeled with HAZARDOUS WASTE, the name of the waste,
and the hazard type;
The container must be tightly secured to the vehicle;
A two-part receipt must be used to track the origin and destination of all Hazardous Wastes. An example
form is attached. Copies are also available from the District ECC;
Notify the Department of Environmental Protection, State Police or National Response in the event of a
spill; phone numbers are posted by facility phones;
Federal Department of Transportation (USDOT) and Massachusetts Department of Public Safety
requirements must be met. This includes the use of a USDOT shipping label for waste other than oil.
Used Vehicle Filters
Used oil, diesel and gasoline filters must be drained into a properly labeled hazardous waste container until
the filter is free from flowing liquid. The liquid content from motor oil and diesel fuel filters must be
drained into a designated waste oil drum. Gasoline, from gasoline filters, must be drained into a waste
gasoline drum. Under no circumstances should the waste gasoline be mixed with waste oil.
*Note: Prior to draining, used oil filters will be punctured from the top side, with a sharp device capable of
penetrating the outer metal casing as well as penetrating an inner valve located inside the center of the filter.
This will allow for trapped oil to completely drain out. Filters do not need to be drained for more than 24hours.
The drained filters must then be stored in a closeable drum, which has been designated and labeled for this
purpose. The drum containing the used oil/diesel filters should be labeled as a non-hazardous waste. When
the drums are filled with drained filters, the designated facility personnel shall notify the ECC and/or
arrange for proper disposal/recycling.
Cathode Ray Tubes
Cathode ray tubes , televisions and computer monitors that are collected during roadside pickup activities
shall be transported to a designated solid waste accumulation area. Do not attempt to dismantle cathode ray
tubes; dangerous levels of high voltage are stored in cathode ray tubes for varying periods of time.
Cathode Ray Tube Handling and Recycling
Store and handle in a manner that minimizes breakage. The ECC shall track the accumulation of the
cathode ray tubes and make arrangements for recycling at least on a yearly schedule or as necessary.
COMMONWEALTH OF MASSACHUSETTS
MASSACHUSETTS DEPARTMENT OF TRANSPORTATION
HIGHWAY DIVISION
STANDARD OPERATING PROCEDURES
SUBJECT:
Hazardous Waste Management at MassDOT
Highway Facilities
EFFECTIVE:
11/23/10
ISSUED:
11/23/10
S.O.P.NO. ENV-01-03-1-000
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Record Keeping
 Copies of Facility VSQG, SQG, or LQG Generator registration numbers shall be on file at each facility
or available at district headquarters.
 A Hazardous Waste Accumulation Log shall be completed as part of the regular facility inspection as
described in SOP 31 Performing Facility Environmental Compliance Inspections.
 Designated facility personnel shall complete Weekly Hazardous Waste Inspection Forms. A copy of the
form shall be kept on file at the facility or at their discretion submitted to the Environmental Compliance
Coordinator.
 The ECC shall ensure completion of a regular inspection report for each facility and maintain records of
the inspection.
 Two-part receipts for self-transporting Hazardous Waste shall be used whenever a facility transports its
waste to another MassDOT Highway Facility. The generating facility keeps the top half of the form for
its records and the receiving facility keeps the bottom half for its records. Upon the request of the ECC,
both the generating and receiving facilities must provide a copy of their paperwork for review. These
receipts must be filed for at least three years or for the duration of any enforcement action by DEP.
 Hazardous Waste manifests shall be used any time a Hazardous Waste is removed by a licensed waste
hauler. ECCs, Boston Environmental Services personnel, and properly trained district maintenance
personnel, are the only MassDOT personnel authorized to sign manifests on behalf of the Department.
The ECCs and/or Districts shall maintain manifests waste profiles and land disposal restrictions for at
least three years or for the duration of any enforcement action by DEP.
Emergency Response Procedures
The following emergency response procedures apply to MassDOT Highway Facilities:
 An example of an Emergency Call Down Sheet is attached. These sheets shall be prominently posted
near each telephone at the facility. Each facility shall maintain a copy of the Emergency Spill Response
Plan For MassDOT Highway Facilities;
 A map showing the location of fire control equipment alarms, evacuation route, and directions to the
nearest hospital shall be prominently posted at the facility (SQGs only);
 Adequate quantities of spill control equipment shall be readily available at each facility;
 Serviceable fire extinguishers shall be located in the vicinity of the hazardous waste accumulation area;
 An adequate supply and pressure of water, automatic sprinklers or water sprays or foam-producing
equipment shall be available as required;
 An alarm or communication system that can provide emergency notification to employees;
 A telephone, two-way radio or other communication device that can summon police, fire or emergency
response teams shall be immediately accessible from the hazardous waste accumulation area.
Massachusetts Department of Transportation
Highway Facility
RCRA Hazardous Waste Generator
Emergency Response Plan
Preparation Date: December 1, 2010
Massachusetts Department of Transportation
Highway Facility
RCRA Hazardous Waste Generator
Emergency Response Plan
Table of Contents
1. Emergency Coordinator……….………………………………………………..……...1
2. Emergency Contact List…………………………...…………………………..………..1
3. Available Spill Equipment and Resources……………………………………..….…2
3.1 Description of Emergency Resources at Hazardous Waste Facilities…..2
3.2 Site-Specific Emergency Equipment List…………………………………...2
4. Emergency Prevention Systems………………………………………………………..3
4.1 Prevention of Fire, Explosion, or Chemical Reaction……………………3
4.2 Hazardous Waste Loading/Unloading Safety Procedures……………….3
4.3 Storm Water Pollution Prevention and Drainage Controls……………..3
4.4 Power Outage or Equipment failure……………………………………….4
4.5 Protection of the Public and the Environment during Emergencies…..4
4.6 Personnel Exposure Protection……………………………………………..4
5.0 Emergency Evacuation Procedures…………………………………………………5
1. Emergency Coordinator
Each MassDOT facility which generates or accumulates hazardous wastes shall at all
times have an emergency coordinator either on the facility premises, or, to the extent the
facility's operations make this option appropriate, on call and available to respond to an
emergency by reaching the facility within one hour. The emergency coordinator shall
have the responsibility for coordinating all emergency response measures. This
emergency coordinator shall be thoroughly familiar with all aspects of the facility's
contingency plan, all operations and activities at the facility, the location and
characteristics of waste handled, the location of all records within the facility, and the
facility layout. The coordinator shall have access to all parts of the facility. In addition,
this individual shall have the authority to spend or use whatever is necessary to carry out
the contingency plan.
The Emergency Coordinator for MassDOT hazardous waste facilities is the District
Maintenance Engineer for the district in which the facility is located. If the DME is
unavailable, the alternates listed in Section 2.0 by order of ranking shall serve as the
Emergency Coordinator.
2. Emergency Contact List
In the event of a Hazardous Materials/Waste emergency, personnel shall contact the
Emergency Coordinator immediately, or, in the case of fire, explosion, or other lifethreatening emergency, as soon as possible after notifying local fire, police, ambulance
and/or other Emergency “First-Responder” groups.
Notifying personnel should continue calling each person on the contact list until the
emergency coordinator or an alternate is reached. Report to the Emergency Coordinator
the location and nature of the incident, type and estimated volume of materials involved,
environmental impacts, and the identity of any other emergency services contacted.
Follow the instructions of the Emergency Coordinator, and report back any new
developments on a frequent basis.
[ Insert site/district specific contacts list here.]
3. Available Spill Equipment and Resources
3.1 Description of Emergency Resources at Hazardous Waste Facilities
MassDOT facilities which generate and/or accumulate hazardous wastes have
spill kits on premises, in close proximity to but outside the hazardous waste
accumulation area. The spill kits contain an assortment of absorbent booms and
pads, plastic bags, personal protective clothing (tyvek suits, gloves) for use in
containing a small spill of hazardous waste material. Supplies of granular
absorbents, drain blocker pads, neoprene rubber dikes, brooms, shovels, waste
accumulation drums, and other spill containment and cleanup equipment are also
available at each facility, or can otherwise be mobilized from a nearby facility.
3.2 Site-Specific Emergency Equipment List
The specific Emergency Equipment available to facility personnel in the event of
a hazardous waste emergency incident, is presented in Attachment 1. The list
shall be kept up-to-date and include the location and a physical description of
each item on the list, and a brief outline of its capabilities. Equipment locations
may be depicted on the site-specific Facility Environmental Compliance Maps to
assist personnel and responders.
[The following table shall be completed by the ECC for each facility, and be
updated annually or whenever there is a change in equipment or related
information. The list can be extended as needed but must include at a minimum
those items already listed]
Emergency Equipment List
MassDOT [Facility Name/ID]
[as of Date]
Equipment Type
1. Spill Kit
2. Fire Extinguisher
3. First Aid Kit
4.
5.
6.
7.
8.
9.
10.
Location at Facility
Use/Capabilities
4. Emergency Prevention Systems
4.1 Prevention of Fire, Explosion, or Chemical Reaction
MassDOT maintenance facilities typically may generate and accumulate waste
lubricating and hydraulic oils, diesel fuel, gasoline, and paint related materials, all
of which are combustible or flammable. Hazardous wastes are accumulated
either inside the facility maintenance garage on spill containment pallets
(generally at VSQG facilities) in a designated location and separate from other
materials, or; in an outdoor fire-rated hazardous waste shed with secondary
containment and ventilation.
To mitigate the potential for fire or explosion, MassDOT personnel must keep all
waste containers tightly closed except when adding material to a waste container,
strictly observe smoking bans, and ensure ignition sources such as welding
torches are shut off when decanting hazardous waste materials. Non-hazardous
oily rags and other absorbents are stored away from waste accumulation areas, in
fire-resistant safety canisters which are emptied daily, to prevent spontaneous
combustion.
MassDOT facilities seldom if ever generate other hazardous waste materials that
may be incompatible with the above routinely generated wastes. When special
circumstance arise where a non-compatible waste is generated that may react with
other waste materials (i.e. battery acid, alkaline materials, chlorine bleach, etc.)
the material is moved to an isolated hazardous waste storage shed at the facility if
available, self-transported to another facility for isolated storage subject to waste
generator status, or immediately collected for transport to a TSD facility by a
licensed waste hauler.
4.2 Hazardous Waste Loading/Unloading Safety Procedures
During transfer of hazardous waste drums and other containers from garages to
storage sheds, or from sheds to a TSD transport vehicle, all MassDOT and
contractor personnel shall use proper drum lifting tools such as overhead drum
clamps, drum lifting forks, drum dollies or other devices designed specifically for
such purpose. Persons involved in container transfers should be outfitted with
proper work attire including steel toe boots, work gloves, hard hat and eye
protection. A spill kit or adequate supply of absorbent or containment materials
should be near by in the event of a spill during transfer of containers.
4.3 Storm Water Pollution Prevention and Drainage Controls
To prevent contamination of stormwater from hazardous wastes generated at
MassDOT facilities, routine vehicle maintenance and repairs and other hazardous
waste generation activities are performed indoors whenever possible. When
outdoor vehicle or equipment repairs are required, spill containment pads, buckets
or other means to collect spillage must be employed.
Hazardous waste containers are stored indoors and provided secondary
containment in the event of a leaking container. Transfer of full hazardous waste
containers from satellite accumulation areas to outdoor sheds, or from
accumulation areas or sheds to a transport vehicle should only be performed in
dry weather whenever possible.
Hazardous waste accumulation sheds will be located as far from drainage
structures or nearby receiving waters or wetlands as possible. Small Quantity
Generator facilities which handle hazardous waste and which are not equipped
with storm drains fitted with oil/grease traps will have readily available for
deployment, drain-block pads made from Neoprene, latex, or other suitable
material to seal off storm drains in the event of spill while transferring hazardous
waste outdoors to or from accumulation areas.
4.4 Power Outage or Equipment failure
Power outages would have no significant affect on routine MassDOT hazardous
waste operations. Hazardous wastes at MassDOT facilities are not managed or
processed via any mechanical equipment, therefore equipment failure has no
bearing on MassDOT hazardous waste management.
4.5 Protection of the Public and the Environment during Emergencies
MassDOT facilities are gated, and restricted from access by the general public.
Hazardous wastes are stored at least 50 feet from the adjacent property boundaries
as per state and federal requirements. Due to the limited volume and types of
hazardous wastes generated and accumulated at MassDOT facilities, a hazardous
waste emergency at the facility is unlikely to pose any threat to the general public.
As indicated elsewhere in this plan, adequate spill containment materials,
secondary containment, and fire/explosion-proof accumulation sheds are provided
for the protection of the environment and public health and welfare.
4.6 Personnel Exposure Protection
Persons engaged in Hazardous Waste operations, whether routine or emergency,
shall wear appropriate Personal Protective Equipment suited to the nature of the
work being performed and the hazardous waste being generated or handled. This
includes work coveralls, work gloves, eye protection and where appropriate,
protective rubber gloves for equipment repair activities. Activities involving
transfers of hazardous wastes to or from containers, or spill cleanup shall also
require the use of heavy duty rubber gloves or work gloves with surgical latex
gloves as liners; coveralls, tyvek, or other splash protection, eye protection (full
face protection if skin irritant).
In the event of a fire involving hazardous wastes, or spills of highly flammable
wastes such as gasoline, MassDOT personnel should evacuate the area and notify
the Fire Department, the Emergency Coordinator and other necessary emergency
services immediately.
5.0 Emergency Evacuation Procedures
Most MassDOT facilities engaged in hazardous waste activities are small to large, open
vehicle garages with few personnel. If an emergency occurs that would require
evacuation of the buildings or facility, persons discovering the emergency should alert
others in the garage by yelling an appropriate warning (i.e. “Fire”) contact emergency
services, and then if safe to do so, attempt to determine if anyone else is in the building
that may not have heard the alert, and evacuate as required. A plan of the facility,
showing all exits shall be posted at various highly visible locations throughout the
facility.
A hazardous waste emergency at a maintenance facility located at the District
Administrative Headquarters, may result in evacuation of the administration building or
the entire property. In such cases, the general emergency evacuation plan for the building
should be implemented, and attached to this plan for reference.
DISTRICT____ AREA___
FACILITY EMERGENCY CALL DOWN SHEET
PRIMARY EMERGENCY COORDINATOR
NAME:
PHONE:
CELL
PAGER
RADIO ID#:
SECONDARY EMERGENCY COORDINATOR
NAME:
PHONE:
CELL
RADIO ID:
ENVIRONMENTAL COMPLIANCE COORDINATOR
NAME:
PHONE:
CELL
RADIO ID#:
daytime only
SAFETY INSPECTOR
NAME:
LOCAL FIRE /POLICE DEPARTMENT
STATE POLICE
MADEP
EPA NATIONAL RESPONSE CENTER
PHONE:
CELL
RADIO ID#:
1-888-304-1133
1-800-424-8802
HAZARDOUS WASTE SELF-TRANSPORT FORM
HAZARDOUS WASTE RECEIPT
Generating Facility/Depot copy
Generating Facility/District__________________________________
Hazardous Waste Generator ID #___________________________
Receiving Facility/District___________________________________
Hazardous Waste Generator ID #___________________________
TYPE OF WASTE_______________________VOLUME_________
SIGNATURE Delivering_________________________DATE___________
SIGNATURE Receiving_________________________DATE___________
KEEP THIS COPY FOR FACILITY FILES
----CUT HERE----------------------------------------------------------------------CUT HERE----
HAZARDOUS WASTE SELF-TRANSPORT FORM
HAZARDOUS WASTE RECEIPT
Receiving Facility/Depot copy
Generating Facility/District__________________________________
Hazardous Waste Generator ID #___________________________
Receiving Facility/District___________________________________
Hazardous Waste Generator ID #___________________________
TYPE OF WASTE_______________________VOLUME_________
SIGNATURE Delivering_________________________DATE___________
SIGNATURE Receiving_________________________DATE___________
KEEP THIS COPY FOR FACILITY FILES
WEEKLY HAZARDOUS WASTE STORAGE INSPECTION CHECKLIST
FACILITY NAME ______________________
INSPECTOR
______________________ DATE
_______________________
1. Are all hazardous wastes and waste oil stored within the designated accumulation area?
___yes___no
2. Are the containers used to store haz waste in good condition? (Check for leaks,
corrosion, bulges, etc.)
___yes___no
3. Are containers labeled with the words “Hazardous Waste”, name of contents, hazard
associated with the waste, and for SQGs the accumulation start date?
___yes___no
4. Is the waste compatible with the container and/or its liner?
___yes___no
5. Are all containers tightly closed?
___yes___no
6. Is adequate aisle space maintained for container inspection?
___yes___no
7. Are minor spills immediately cleaned up using appropriate absorbent material?
___yes___no
8. Are waste oil drip pans and buckets immediately emptied into the waste oil drum?
___yes___no
9. Are usable material and oils stored outside the hazardous waste storage area?
___yes___no
FOR ANY QUESTION ANSWERED WITH NO, EXPLAIN HERE:
_____________________________________________________
_____________________________________________________
_____________________________________________________
_____________________________________________________
**NOTE: COMPLETE FORM EACH WEEK AND KEEP
ALL COPIES ON FILE
DISTRICT EMS COMPLIANCE COORDINATOR:
PHONE:
CELL: