Presbyterian College
HAZARDOUS WASTE MANAGEMENT PLAN
Document ID No. E-2
Issued: 1/30/2009
Please direct any questions or comments about the applicability of this
document to Alan Urwick, Environment Health & Safety Coordinator.
Developed for Presbyterian College (all campuses) by:
Turning Bird Consulting, Ltd.
1205 Two Island Court, Suite 204
Mount Pleasant, SC 29466
ph.: 843-216-6833
Hazardous Waste Management Plan [Document ID No. E-2]
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TABLE OF CONTENTS
Abbreviations and Acronyms ........................................................................................ iii
1.0
2.1
2.2
Purpose .............................................................................................................. 1
Main Campus ..................................................................................................... 1
The Branch Campuses ...................................................................................... 1
3.0
Authority ............................................................................................................. 1
4.0
4.1
4.2
General Procedures ........................................................................................... 2
Main Campus ..................................................................................................... 2
The Branch Campuses ...................................................................................... 2
5.0
5.1
5.2
5.3
5.4
5.5
5.6
5.7
5.8
5.9
5.10
Laboratory, Classroom or Chemical Use Area Requirements ............................ 2
Waste Determinations ........................................................................................ 2
Unknown, Discarded and Unneeded Chemicals ................................................ 3
Containers, Compatibility and Storage ............................................................... 4
Marking and/or Labeling Requirements ............................................................. 5
Satellite Accumulation Areas.............................................................................. 5
Accumulation Limits ........................................................................................... 6
Legal Disposal to the Sewer System .................................................................. 6
Illegal Treatment or Disposal.............................................................................. 7
Training for Faculty and Staff ............................................................................. 7
Laboratory renovations, modifications and academic restructuring .................... 8
6.0
6.1
6.2
Central Storage Area (CSA) and Campus-wide Requirements .......................... 8
Central Storage Facility/Area Requirements ...................................................... 8
Disposal and Manifesting ................................................................................... 8
7.0
Hazardous Materials Registration Fees ........................................................... 10
8.0
Emergency Response Equipment and Procedures .......................................... 11
9.0
9.1
9.2
9.3
Recordkeeping, Reporting, and Required Programs ........................................ 12
Recordkeeping ................................................................................................. 12
Reporting.......................................................................................................... 13
Required Plans and Programs ......................................................................... 14
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Appendixes
Appendix A: Hazardous Waste Management for a CESQG Facility
Appendix B: Hazardous Waste Determination Form
Appendix C: RCRA P- and U-Listed Wastes
Appendix D: Peroxide Forming Compounds
Appendix E: Hazardous Waste Container Labels
Appendix F:
Location of Satellite Accumulation Areas and Emergency Equipment
Appendix G: Hazardous Waste Container Storage Area Inspection Checklist
Appendix H: Hazardous Materials Registration Form
Appendix I:
Standard Operating Procedures for Mercury Spills
Appendix J:
Biennial Hazardous Waste Report
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Abbreviations and Acronyms
BMP –
Best Management Practices
CESQG –
Conditionally Exempt Small Quantity Generator of hazardous haste is the least regulated
generator class.
CFR –
Code of Federal Regulations. Title 40 of the Code of Federal Regulations (40 CFR) contains
all of the environmental protection regulations.
CHO –
Chemical Hygiene Officer
CSA –
Central Storage Area
DOT –
Department of Transportation
EC –
Emergency Coordinator
EPA –
Environmental Protection Agency
EPA ID No. – EPA Identification Number
ERC –
Emergency Response Coordinator
HAZWOPER – Hazardous Waste Operations and Emergency Response
HCW –
Hazardous Chemical Waste
HW –
Hazardous Waste
ID –
Identification, as in EPA ID Number
Kg –
Kilogram; one-kilogram equals 2.2 pounds
Lbs –
Pounds
LDR –
Land Disposal Restriction
LQG –
Large Quantity Generator of Hazardous Waste is a fully regulated generator of hazardous
waste.
SC DHEC –
South Carolina Department of Environmental Protection
pH –
Negative logarithm of the Hydrogen Ion concentration; A scale from 0 to 14 where 7 is
neutral and lower numbers are successively more acidic (sweet), and higher numbers are more
basic (sour).
ppb –
Parts per billion, one-tenth of one percent is equivalent to one million parts per billion (0.1%
equals 1,000,000 ppb).
RCRA –
Resource Conservation and Recovery Act
SAA –
Satellite Accumulation Area
SQG –
Small Quantity Generator of hazardous waste is regulated to a much greater degree than the
CESQG, but not regulated to the degree that a LQG.
TSDF –
Treatment, Storage, or Disposal Facility
US EPA –
United States Environmental Protection Agency
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HAZARDOUS WASTE MANAGEMENT PLAN
1.0
Purpose
Presbyterian College is committed to operating its laboratories and classrooms in the safest manner
possible, with concern for the individual and the protection of the environment in accordance with
all applicable Federal and State statutes. The Hazardous Waste Management Plan, as outlined in the
following sections, has been prepared to comply with applicable regulations promulgated by the
United States Environmental Protection Agency (EPA) and the South Carolina Department of
Health and Environmental Control (SC DHEC); and local ordinances enacted by Clinton, Laurens
County, South Carolina.
2.0
Scopes and Application
This program establishes the requirements that Presbyterian College faculty and staff must meet in
order to manage the appropriate disposal of hazardous waste and excess chemicals in laboratories,
classrooms, shops and chemical use areas located on the Presbyterian College campuses. This
program describes the labeling and notification requirements, manifesting requirements, the general
management of Satellite Accumulation Areas (SAAs) and Hazardous Waste (HW) storage areas;
guidelines for disposal to the sanitary sewer, air and solid waste; applicable emergency procedures,
prevention and response requirements; training and record keeping requirements.
2.1
Main Campus
The Presbyterian College main campus is considered a Large Quantity Generator (LQG) under the
South Carolina Hazardous Waste Management Requirements1 for LQGs. As such, the institution as
a whole is allowed to generate, on a monthly basis:
 More than 2200 pounds (1,000 kg) of non-acutely hazardous waste (D, F, K, or U waste
codes),
 More than 2.2 pounds (1 kg) of acutely hazardous waste (P waste codes), and
 More than 220 pounds (100 kg) of acutely hazardous waste spill clean-up materials.
All hazardous waste generated on the main campus is managed and disposed of using the assigned
EPA ID number of SCD123456789, and may be accumulated on-site for a maximum of 90 days.
2.2
The Branch Campuses
Presbyterian College currently does not have any Branch Campuses.
3.0
Authority
Title R61.79 of the South Carolina Code, Parts 260 through 270
Title 40 of the Code of Federal Regulations, Parts 260 through 270
1
Information taken from SC DHEC R6.79-262.34
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4.0
General Procedures
4.1
Main Campus
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Presbyterian College, and each of the individual laboratories, classrooms and chemical use areas
located within the campus community, shall make every effort to maintain compliance with Large
Quantity Generators standards (or Conditionally Exempt Small Quantity Generator standards, as
appropriate). Any laboratory or work area generating hazardous waste must notify the Chemical
Hygiene Officer, or the Environmental Health and Safety Coordinator, designate a Satellite
Accumulation Area (SAA), and conform to the requirements stipulated by the South Carolina
Department of Health and Environmental Control (SC DHEC) for LQGs.
The College will remove all stored HW containers from the main campus at least once during each
90-day period using a licensed contractor. All HW will be managed according to local, state, and
federal law and every effort will be made to reduce the potential long-term financial and legal liability
to the institution. Furthermore, as an institution, Presbyterian College will make every effort to
reduce the quantity and/or toxicity of the hazardous waste it generates through chemical reuse,
material substitution, modified process practices, or other pollution prevention activities where
possible.
4.2
The Branch Campuses
Presbyterian College currently does not have any Branch Campuses..
5.0
Laboratory, Classroom or Chemical Use Area Requirements
5.1
Waste Determinations
Under the Resource Conservation and Recovery Act (RCRA, pronounced rick-rah), all hazardous
materials destined for disposal must be considered hazardous wastes unless determined otherwise.
Persons properly trained in the regulatory definitions of hazardous wastes must make all waste
determinations. When knowledge of the hazard characteristics is indeterminate or unknown, waste
analysis is required. Once a waste determination is made, the waste is managed as hazardous waste
or discarded as a non-hazardous waste, as appropriate. All waste determinations must be maintained
in writing for a minimum of three (3) years. Appendix B consists of a form useful for documentary
purposes.
In order to conduct a waste determination all potentially hazardous constituents and reaction
products must be considered. When in doubt, disposing of a regulatory agency-defined nonhazardous material as a hazardous waste is preferable to possibly releasing a potentially toxic
pollutant into the environment. To manage hazardous wastes properly, the individuals responsible
for laboratories, shops, and all other chemical use areas must identify and inventory their waste
streams, and submit this information to the Environmental Health and Safety Coordinator. The
EHS Coordinator will characterize the wastes, return the determination to the individual generator,
and track the College’s hazardous waste generator status. This procedure is conducted by addressing
the following steps:
 Identify and Inventory Waste – Identify all waste streams generated within the lab or
facility using knowledge of the process to determine the waste that is generated. Examples
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include science lab experiment–week one (etc.), scheduled warehouse clean out, art project–
one (etc.), or building renovation. These processes may yield, respectively, excess hazardous
reagents, out-dated chemicals, spent paint solvents, or asbestos-containing materials. Once
waste streams are identified, determine the volume or quantity of wastes generated each
month.
 Characterize the waste – Determine if the chemical waste is a RCRA-listed waste, or if it
meets one of the characteristics of a hazardous waste and is not exempted or excluded under
the rules. (See Appendix C.)
Hazardous waste includes chemicals and solutions with the following components or
characteristics:





All heavy metals and their salts (toxic);
All sulfides, bisulfides and cyanides (reactive);
All other toxic, reactive or oxidizing inorganics (toxic, reactive, or corrosive);
All organic compounds except ethanol below 24% (toxic, ignitable, or corrosive);
All gases not normally constituents of the earth’s atmosphere, and all flammable or
oxidizing gases (toxic, ignitable, reactive, or corrosive)
 Determine if a mixed chemical waste is hazardous or non-hazardous - If a RCRAlisted hazardous waste is mixed with a non-hazardous waste the resulting mixture will remain
regulated as the listed waste regardless of quantity present in the mixture. (See Figure 1
below.)
If a characteristic hazardous waste is mixed with a non-hazardous waste, the resulting
mixture will be regulated as hazardous only if the resulting mixture still exhibits the
characteristic.
 Determine and track generator status – Maintain a log of the process hazardous wastes.
Information that should be included on this log include the following:

For each waste: A description of the waste (e.g., waste solvents from labs); type of
waste (hazardous waste or acutely hazardous waste), method of characterization (e.g.,
lab exercise date, generator knowledge); amount generated in the month; and
amount accumulated in the month.

Totals: Amount of all hazardous waste generated in the month; amount of all
acutely hazardous wastes generated in the month; and the amount of all hazardous
waste accumulated in the month.
ANY AMOUNT OF
Non-Hazardous Wastes
5.2
+
Any amount of listed
hazardous waste
=
LISTED HAZARDOUS
WASTE
Unknown, Discarded and Unneeded Chemicals
Unidentified substances present a major problem for both storage and disposal. These chemicals
can be removed by a Hazardous Waste transporter, but their disposal is much more expensive than
disposing of known hazardous materials. Therefore, proper labeling and identification is important.
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“Unidentified or Unlabeled Chemicals” are those bottles without a label, containers labeled with
only codes, generic process labels that do not specifically list the chemicals contained, and obviously
mislabeled chemicals. Each of these chemicals must be “fingerprinted” for specific hazard classes
before it may be removed from the premises by a licensed hazardous waste transporter.
Compounds that form peroxides, such as ethers (ethyl ether, and dioxane, but not “pet ether” or
dioxins etc.), absorb and react with oxygen to form potentially explosive compounds with time. (See
Appendix D.) Exposure to air and light accelerates these formations. Therefore, if your unlabeled
liquid is partially or fully evaporated, and if crystals are present (or the liquid has become unclear),
label the container as “Possible Peroxide” and handle as little as possible. These chemicals shall be
brought to the attention of the hazardous waste transporter before any pickup is made.
Chemicals such as Picric Acid can become unstable if allowed to dehydrate. Due to the potential for
friction or shock-sensitive explosion with these chemicals, do not move or attempt to open these
bottles if the container appears old, crystalline or damaged in any way. Alkali metals are air reactive,
and must be kept stored under kerosene. If the kerosene has evaporated exposing the metal sticks,
dangerous concentrations of hydrogen, an explosively flammable gas, or a metal peroxide crust, a
shock sensitive solid may have built up. These chemicals shall be brought to the attention of the
hazardous waste transporter before any pickup is made.
Discarded and unneeded chemicals often represent unnecessary waste due to chemical
mismanagement. Removal of unwanted chemicals and frequent evaluation of stored chemical
containers are necessary to maintain chemical storage areas in a safe operating condition. To
properly manage reagent chemicals on the PC campus, the laboratory instructor or manager shall:
 Conduct a thorough laboratory cleanup and properly dispose of all unknowns, unwanted
and unneeded chemicals.
 Follow storage and labeling practices described in the Presbyterian College Chemical Hygiene
Plan [Document ID No. S-2], to ensure that unknowns are not generated in the future.
 Keep chemical stores to a minimum and review the annual inventory for unneeded
chemicals that can be given to colleagues or placed into a re-use program before they have
become useless or expired.
 Borrow and share small amounts of rarely used chemicals with neighboring laboratories and
when purchase is necessary, order the minimum practicable quantity.
5.3
Containers, Compatibility and Storage
Waste chemicals must be stored in containers that are chemically compatible with the contents.
Incompatible wastes must not be mixed together, nor can they be placed in an unrinsed container
that contained an incompatible material. Acids cannot be mixed with bases, or flammables with
oxidizing chemicals. Similarly, corrosives cannot be placed in metal containers, and Hydrofluoric
Acid cannot be placed in glass containers.
Waste containers must be kept tightly closed when waste is not being added to and must be stored
in such a way that they will not rupture or leak, e.g., temperature controlled environment,
segregation from corrosive fumes, etc. All containers must be labeled appropriately and visibly
according to the guidelines in Section 5.4.
All wastes must be stored indoors on a firm-working surface, and have secondary containment to
prevent the release of hazardous waste to the environment. Containers shall be stored in a manner
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such that, in the event of a release, the contents will not enter the sanitary sewer or stormwater
drains. All wastes must be placed in Department of Transportation (DOT) approved shipping
containers before shipment off site.
5.4
Marking and/or Labeling Requirements
5.4.1 Containers
Each hazardous waste container must be properly marked or labeled. The marking or label must
include the following information:
 The words “Hazardous Waste,”
 List of chemicals contained within the container and approximate percentages,
 Hazards of the waste (e.g.: “flammable,” “combustible,” “corrosive,” “reactive,” “oxidizer,”
“organic peroxide,” and “carcinogen”),
 The date accumulation of hazardous waste was started in THAT container (the “Start
Date”).
Preprinted labels are available from commercial vendors, although a laboratory-generated label is
acceptable. (See Appendix E.) Fill in all applicable information, being sure to include all hazardous
chemical constituents and the approximate concentration of each. The “Full Date is added after the
container is full.
5.4.2 Satellite Accumulation Areas
In each area that initially generates hazardous waste; an SAA shall be demarcated and labeled as an
SAA point of generation. This area is to contain accumulating hazardous wastes and hazardous
materials that have been identified for disposal only. (Appendix F is an inventory of EHS
equipment available in each laboratory at Presbyterian College, including the presence of one or
more SAAs.)
5.5
Satellite Accumulation Areas
Each SAA must be located at or near the point of generation and under the control of the
laboratory manager or person directly responsible for the process generating the waste. SAAs may
not contain accumulated hazardous wastes that are combined from several laboratory areas.
Hazardous wastes may not be transported from one laboratory to another, in a common hallway, in
an elevator or in a stairwell; except by authorized College personnel trained in hazardous waste
management procedures.
Only one container per waste stream (a maximum of 55 gallons for a hazardous waste or one quart
for an acutely hazardous waste) is allowed in each SAA. When the container is full, the “Full Date”
must be completed on the label and the container must be removed from the SAA to the 90-day
“Central Storage Area” (CSA) within 72 hours. Notification is made by calling the EHS
Coordinator, has the waste picked up, the “Transfer Date” (abbreviated “Xfer Date” on the label in
Appendix E) written on the label, and appropriately stored in the CSA. Containers must be stored
by compatibilities on an impervious surface or in secondary containment to prevent access of spilled
waste to the sanitary sewer.
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5.6
Accumulation Limits
Maximum Amount of
Waste Stored in Satellite
Accumulation Area




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55 gallons of non-acute
hazardous waste.
1 quart of acutely
hazardous waste.
Remove from the SAA
within 72 hours of filling
the container.
Must be removed from
the SAA for disposal
within one year.
Allowable Amount of
Waste Generated on
Campus in Calendar
Month
As a Large Quantity generator,
one or more of the following
amounts are generated on
campus:
 More than 2200 pounds
(1000 kg) of hazardous
waste
 More than 2.2 pounds (1
kg) of any one acutely
hazardous waste
 More than 220 pounds
(100 kg) of acutely
hazardous waste spill
cleanup
 More than 22 pounds (10
kg) of acutely hazardous
waste from inner liners or
paper bags
Amount of Waste Stored
in Central Hazardous
Waste Storage Area

There is no limit to the
amount of waste that can
be stored. Waste must be
shipped off-site within
90-days of the “full date,”
which is the date when
the waste was marked
“full” at the SAA.
For all hazardous wastes, a waste container must be removed from the CSA within 90 days of the
accumulation start date, which is the date the container was marked as full.
All containers within the CSA must be inspected weekly. Containers used for accumulation of
hazardous wastes in SAAs must be removed at least once a year to prevent problems caused by
container deterioration, to prevent excess accumulation of hazardous wastes, and to meet SC DHEC
requirements.
5.7
Legal Disposal to the Sewer System
The majority of chemical substances will be disposed of by transferring them to a company licensed
to operate a treatment/storage/disposal facility (TSDF). Chemical substances cannot be flushed
down the drain without issuance of a wastewater discharge permit. Chemical wastes cannot be
dumped in storm water catch basins or floor drains.
5.7.1 Acids and Bases
Provided that a material is not hazardous for any other reason than corrosivity (e.g. organic acids are
ignitable), acidic or basic laboratory waste may be neutralized as long as it is part of the written
experiment. The resulting neutral (pH 6.0-9.0) salt solution may be flushed down the drain.
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This neutralization process can only take place at the point of generation. It cannot be conducted in
an accumulation container (such as a flask, beaker or chemical bottle). This step must be a part of
the written, experimental procedure.
5.7.2 Inorganic Compounds
Inorganic compounds that are not hazardous waste may be dissolved in water and flushed down the
drain with copious amounts of cold water provided they do not contain heavy metals or toxic anions
and provided they are not oxidizers or water reactive. In particular, the following chemicals may be
flushed to the sanitary sewer:




Soluble, non-water reactive salts of sodium, potassium, magnesium, and calcium.
Soluble and non-water reactive chlorides, bromides, carbonates, bicarbonates, and sulfates.
Soluble and non-water reactive natural products such as sugars, and amino acids.
If these materials are in solid form, or if they are not soluble, they may be thrown into the
regular trash.
5.7.3 Chemicals Prohibited from Sink Discharges
Chemicals, which may not be flushed to the sewer or thrown into the regular trash, include, but are
not limited to:
 Arsenic, barium, copper, tin, lead, silver, iron, cobalt, nickel, cadmium, chromium, zinc,
manganese, selenium, and mercury salts.
 Fluorides, sulfides, bisulfides, cyanides, nitrites, peroxides, chlorates, perchlorates, and
permanganates.
5.8
Illegal Treatment or Disposal
With the exception of the neutralization procedures noted in Section 5.7, emergency response
cleanup-actions, and certain totally enclosed treatment units, the treatment of hazardous wastes is
illegal without a permit from the South Carolina DEP. Adding additional steps to the end of an
experiment for the sole purpose of reducing the volume or toxicity of a hazardous waste is
interpreted as treatment and is illegal under hazardous waste rules.
Once a chemical is no longer useful, a waste determination must be conducted. Because of the
complexity of the regulations, waste determination questions should be directed to trained
personnel.
5.9
Training for Faculty and Staff
All PC faculty and staff who generate or handle hazardous wastes will be trained in this Hazardous
Waste Management Plan, the requirements of the state and federal laws and the management of
their SAAs. A review of the initial training shall be repeated on an annual basis. Training given as
part of the curriculum will satisfy this requirement.
Written documentation of each training session, including a signature and date of the person trained,
will be maintained for a minimum of three (3) years.
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Laboratory renovations, modifications and academic restructuring
From time to time, the use of a particular laboratory at PC is modified to meet the needs of new
faculty members, an expanding department or academic curriculum. Similarly, as emeritus faculty
members leave the College, their research spaces are reallocated to new department members.
Invariably, chemicals and equipment are left behind, or are no longer needed and must be addressed.
Before renovations can commence, it is imperative that the laboratory is thoroughly inspected and
excess chemicals and hazardous waste removed from the area. Neutralizing all surfaces and
thoroughly washing all surfaces with soap and water should decontaminate the room’s surfaces and
storage areas. All excess chemicals and hazardous wastes shall be managed according to the
requirements of this plan and the laboratory reassigned to the new faculty member in the best
possible condition. This process is the responsibility of the Department Chair.
6.0
Central Storage Area (CSA) and Campus-wide Requirements
6.1
Central Storage Facility/Area Requirements
All hazardous waste and unneeded hazardous materials containers shall be stored on an impervious
surface. Indoor storage areas must be provided with secondary containment that can contain 10%
of the total volume in storage or 100% of the largest container whichever is greater. Containers will
be inspected weekly. See Appendix G for a container inspection protocol that serves as its own
documentation.
The CSA facility shall be clearly marked with the words, “Hazardous Waste,” maintained separate
from all other areas. Access to the hazardous waste storage area is restricted to authorized
personnel only.
Each container or drum located in the CSA shall be marked or labeled with the words “Hazardous
Waste,” list the date the container was marked full [or the date the one (1) year SAA storage limit
expires], the date of transfer to the CSA, and the contents of the container in accordance with
Section 5.4.
When ignitable or reactive wastes are being handled, smoking and open flames will not be allowed.
“No Smoking” signs must be posted around the working area. All potential sources of ignition or
reaction will be removed or addressed before work with ignitable or reactive wastes commences.
Grounding and bonding connections will be used when transferring flammable liquids from one
container to another.
6.2
Disposal and Manifesting
6.2.1 Disposal of Hazardous Wastes
Since wastes need to be removed from an LQG site before the “90-day” accumulation periods are
reached, hazardous waste pickups at PC will be conducted before the end of each 90-day
accumulation period and will be managed by a licensed HW transporter. To control costs associated
with the disposal of hazardous waste, PC will seek to maintain a long-term service contract with an
approved hazardous waste vendor. Decisions regarding the choice of vendor will not be based
solely on price, but will take into account the potential long-term liability to the institution. Where
possible, PC will allow licensed contractors to recycle hazardous wastes and materials (i.e., Mercury),
allow for fuel blending opportunities, or allow elementary neutralization of simple corrosives (i.e.,
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acids and bases) where no other hazard exists. All other hazardous wastes will be transported to a
licensed hazardous waste facility for recycling, incineration, or chemical treatment before landfill
disposal. At no time will hazardous wastes generated on the PC campus be shipped to foreign
countries for disposal.
6.2.2 Facility Personnel Training
There shall be at least two employees of PC who receive DOT Hazardous Materials training, in
addition to hazardous waste training, to ensure that Hazardous Waste manifests are completed
properly. Only those individuals who have been trained are to sign hazardous waste manifests on
behalf of the College. This training must be re-taken every three years.
Copies of the training content and training certificates will be retained for a period of three (3) years.
6.2.3 LQG Waste Handler Training
The EPA and DEP require that persons handling waste at LQG sites be trained to ensure that they
are thoroughly familiar with proper handling and emergency response procedures relevant to their
responsibilities.
Responsibilities may include any, or all, of the following:







Hazardous Waste Determinations
Containers, Compatibility, Handling and Storage
Container Inspections
Accumulation Limits
Labeling Requirements
Disposal and Manifesting
Spill Response Procedures
Training should be conducted at the time of initial assignment to duties, which require handling
waste, or when chemicals that are SC DHEC and EPA regulated wastes are added to a process or
work area.
6.2.4 Shipping Manifests
PC representatives shall ensure that the EPA required “Uniform Hazardous Waste Manifest” (EPA
Forms 8700–22 and 8700–22A) is properly completed. Some states supply their own version of this
manifest. South Carolina does not. If the destination state supplies its own version, their manifest
must be used. State supplied manifests have eight-pages. If neither the destination state, nor the
generator state supplies a manifest, a six-page manifest will be used.
As an example, consider the distribution of the multiple copies of a destination state supplied
manifest. PC will retain the last three copies (6-8). The remaining copies of the manifest shall be
given to the transporter. The destination state copy (7) of the manifest must be transmitted to the
destination state within ten days of the day the shipment begins. PC will file the generator copy (8).
The generator state copy (6) need not be sent to the South Carolina DHEC.2
Nota Bene: South Carolina regulations require generators, who manifest hazardous waste to states that do not require their
designated facilities to send signed copies to the generator state, to send signed copies to the DEP. South Carolina generators
manifesting waste to Alabama, Arkansas, Illinois, Louisiana, Michigan, Missouri, North Carolina, Texas and Wisconsin need to make a
photocopy of the copy they receive from the designated facility and send it to DEP. Please ensure that these copies are legible.
2
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Of the first five copies of the manifest, the generator copy (3) must be transmitted to the generator
within 35 days of the facility acceptance. The generator and destination states’ copies (1 and 2) must
be transmitted by the receiving facility to the generator state, if necessary and the destination state
within 14 days of facility acceptance. All copies received by PC from the HW transporter and
receiving facility over the 35-day period will be maintained together in a readily accessible location.
Copies 4 and 5 of the manifest are reserved for transfer of the waste shipment between additional
transporters. It is recommended that a separate file be kept for each hazardous waste shipment.
This file should include all manifest copies, the packing slips and the Land Disposal Restriction
(LDR) documentation, as well as any foreign shipment information from the hazardous waste
transporter.
If PC has not received Copy 3 from the receiving facility within 35 days of shipment, they are to
contact the receiving facility to reconcile the disposition of the shipment. If Copy 3 has not been
received within 45 days of shipment, then an Exception Report must be submitted by Presbyterian
College, to the South Carolina DEP and EPA. (See Section 8.2.2.)
The hazardous waste transporter shall provide PC with the EPA required two-part manifest for
wastes that are reclaimed or recycled according to the contractual agreement. All copies received by
PC from the hazardous waste transporter will be maintained together at the Environmental Health
and Safety Coordinator’s office.
The hazardous waste transporter shall provide PC with a shipping form for waste oils. The
generator copy must be transmitted to the generator within 35 days of the facility acceptance. All
copies of the manifest received by PC from the hazardous waste transporter over the 35-day period
will be maintained together at the Environmental Health and Safety Coordinator’s office.
Manifests and accompanying documents must be retained for at least three years. Documents older
than three years should be archived separately from the current files.
7.0
Hazardous Materials Registration Fees
On May 1, 2000 the Department of Transportation (DOT) expanded its hazardous materials
registration program (49 CFR Part 107, Subpart G) to include those who offer or carry a shipment
of hazardous materials (including hazardous wastes) that requires placarding. As a result, shippers of
non-bulk packages became subject to the DOT's hazardous materials registration fee. All colleges
and universities shipping hazardous waste off their campuses using a commercial transporter
became responsible for registering annually, and submitting a fee of $2,000, or $250 if they qualified
as a small business. Documentation of registration and payment is received in the form of a
Hazardous Materials Registration Certificate, which must be kept for three years.
DOT’s Research and Special Programs Administration (RSPA),3 since 1992, has used the fees from
this registration program to fund the Hazardous Materials Emergency Preparedness (HMEP) grants
program that supports hazardous materials emergency response planning and training activities by
State and local governments. The registration program also allows the RSPA to gather information
on hazardous materials movements throughout the US.
In February 2005 the offices within the U.S. Department of Transportation’s Research and Special Programs
Administration (RSPA) responsible for the safe transportation of hazardous materials were incorporated into the newly
created Pipeline and Hazardous Materials Safety Administration (PHMSA). Hazardous Materials Certificates of
Registration are now issued by PHMSA. Certificates issued by RSPA remain valid through their expiration date.
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In 2003 RSPA temporarily lowered the registration fee for the next six registration years. RSPA also
set the fees for not-for-profit organizations, regardless of size, to the fee paid by small businesses.
For the first three registration years the fee for small businesses has been set at $150. For the last
three registration years the fee rises to $275. These six registration years run from 2003-2004
through 2008-2009
Companies subject to these regulations must submit a complete and accurate registration statement
on DOT Form F 5800.2 not later than June 30 for each registration year. A copy of the form for
the 2005-2006 registration year is included in Appendix H. Copies of the most current year’s
instruction brochure and registration form are available at the “Hazmat Registration” Internet site at
http://hazmat.dot.gov/regs/register/register.htm. Fees are paid in advance of the registration year.
Schools must register for prior years if (1) they engaged in activities that required registration during
those years, and (2) they failed to register. The amount of the fees due for prior years is indicated
above. A schedule of these fees is also attached in Appendix H.
Each of the registration fees given above includes a $25 processing fee. An institution may register
for up to three years at one time, but pays only one processing fee. Go to the “Hazmat
Registration” site for additional information on the following:
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8.0
Instructions for registering online.
A complete list of the current U.S. Small Business Administration size standards.
Company Registration Look-Up
HMEP Grants Program Information
Emergency Response Equipment and Procedures
All faculty and staff are required to be trained in appropriate emergency procedures under both SC
DHEC and Occupational Safety and Health Administration (OSHA) regulations. Emergency
evacuation plans, fire extinguishers, spill control equipment, and the training to use them are all part
of responsible waste management.
Emergency Phone numbers including the number of the local fire department and Emergency
Response Person shall be posted near each telephone. The locations of fire extinguishers, alarm
systems (if present) and spill control equipment should also be posted and clearly marked.
Each LQG site must always have at least one Emergency Response Coordinator (ERC) available to
respond to emergencies. The designated ERCs are Ricky Hess, Supervisor of Maintenance, and
Alan Urwick, Assistant Director of Facilities and Operations. The ERC is responsible for
coordinating all emergency response measures, including calling the fire department in the event of a
significant fire, ensuring that the flow of hazardous materials is contained in the event of a release,
and ensuring that any contaminated materials or soils are removed. All ERCs are required to
respond to an emergency and interface with external emergency response agencies and, must be
trained in Incident Command procedures.
Specific Emergency Response Procedures are located in the Presbyterian College Emergency Response
Plan, [Document ID No. G-3]. (A response plan to an all too routine event is attached as
Appendix I, “Standard Procedures for Mercury Spills.”) The Emergency Response Plan
includes all of the required Hazardous Waste Contingency Plan components:
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Facility Identification Information;
Assignment of Emergency Coordinator Responsibilities;
Contingencies that will require implementation the Plan;
Emergency response procedures for those contingencies;
Emergency equipment availability, location, and capability;
Coordination agreements with local/regional emergency responders;
Evacuation Plan—when, signals for, primary and alternate routes of;
Required reporting—the incident, and attainment of compliance (before resuming
operations);
Amending the Plan upon changes in—the regulations, the facility, or the Emergency
Coordinator.
9.0
Recordkeeping, Reporting, and Required Programs
9.1
Recordkeeping
9.1.1 Shipping Manifests
Presbyterian College must keep a copy of the manifest for each shipment of hazardous waste. The
manifest must contain the signature of a PC representative who has received DOT Hazardous
Materials training within the past three years, the signature of the initial transporter to accept the
hazardous waste, and the date the hazardous waste was accepted.
A copy of each manifests must be kept for three years, or until the College receives a signed copy
from the destination facility which received the waste. This signed copy must be retained as a record
for at least three years from the date the waste was accepted by the initial transporter.
9.1.2 Waste Determinations
The College must keep records of the means by which waste were determined to be hazardous. (See
Appendix B for a documentation form.) These include:
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Matching generated waste with waste listed as a hazardous waste in the regulations,4
Testing to determine if the waste has one or more of the characteristics of a hazardous waste
(ignitability, corrosivity, reactivity, or toxicity),
Applying generator knowledge of the hazardous characteristics (ignitability, corrosivity,
reactivity, or toxicity) of the materials or processes used in generating the waste.
9.1.3 Summary of Additional Records
The College must also keep the following records:
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Application for and receipt of assigned EPA Identification Numbers for the main campus,
the law campuses, and any non-contiguous, College -owned property that generates
hazardous waste.
The log of generated hazardous waste used to determine generator status, see Section 5.1.
See 40 CFR 261.
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A copy of faculty and staff hazardous waste management training agenda and sign-in sheets,
see Section 5.9
A copy of CSA facility personnel hazardous waste management training, see Section 6.2.2
A copy of waste handler hazardous waste management training agenda and sign-in sheets,
see Section 6.2.3
Copies of Hazardous Materials Registration Certificates for the past 3 years, see Section 7.
A copy of faculty and staff emergency response training agenda and sign-in sheets, see
Section 8
Biennial Report, see Section 9.2.1
Exception Report, see Sections 9.2.2 and 6.2.4
Reporting
9.2.1 Biennial Report
As a Large Quantity Generator of hazardous waste in South Carolina, Presbyterian College Main
Campus must prepare and submit a Biennial Report of shipments of hazardous waste off-site to any
treatment, storage or disposal facility. This report must be sent to the EPA by March 1 of each even
numbered year.
The Biennial Report form, EPA Form 8700–13, must cover generator activities during the previous,
odd-numbered year, and must include the following information:
1. The EPA identification number, name, and address of the generator.
2. The calendar year covered by the report.
3. The EPA identification number, name, and address for each off-site treatment, storage, or
disposal facility in the United States to which waste was shipped during the year.
4. The name and EPA identification number of each transporter used during the reporting year
for shipments to a treatment, storage or disposal facility within the United States.
5. A description, EPA hazardous waste number, DOT hazard class, and quantity of each
hazardous waste5 shipped off-site to a treatment, storage or disposal facility within the
United States. This information must be listed by EPA identification number of each such
off-site facility to which waste was shipped.
6. A description of the efforts undertaken during the year to reduce the volume and toxicity of
waste generated.
7. A description of the changes in volume and toxicity of waste actually achieved during the
year in comparison to previous years.
8. Certification of the Report signed by the College’s authorized representative.
The Biennial Report forms for 2007, EPA Form 8700–13A/B, is included in Appendix J.
9.2.2 Exception Reports
If PC has not received Copy 3 of the manifest from the receiving facility within 45 days of shipment,
then an Exception Report must be submitted by the College, to the South Carolina DHEC and the
EPA.
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This information may be found on the manifest for each shipment.
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The Exception Report must include a legible copy of the manifest for which the College does not
have confirmation of delivery, and a cover letter signed by the College’s authorized representative
explaining the efforts taken to locate the hazardous waste and the results of those efforts. The
submission to EPA need only be a handwritten or typed note on the manifest itself, or on an
attached sheet of paper, stating that the return copy was not received.
9.2.3 Quarterly HW Reports
South Carolina requires Large Quantity Generators to submit quarterly HW reports. The report
forms are included in Appendix J along with the appropriate filing instructions.
The College must keep a copy of each Quarterly Report, each Biennial Report and Exception
Report for a period of at least three years from the due date of the report.
9.3
Required Plans and Programs
As a Large Quantity Generator of Hazardous Wastes, Presbyterian College is required to develop
and implement the following written plans:
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Preparedness Prevention and Contingency Plan to meet SC DHEC requirements. (Note:
This can be combined with the Hazardous Waste Contingency Plan and the Emergency
Response Plan
Hazardous Waste Contingency Plan – The emergency response portion of which may be
incorporated into EPA’s "One Plan," also known as the Integrated Contingency Plan (ICP)
A Waste Minimization Program (EPA)
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