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COLORADO SCHOOL OF MINES HAZARDOUS WASTE MANAGEMENT POLICIES AND PROCEDURES ADMINISTERED BY THE ENVIRONMENTAL HEALTH AND SAFETY DEPARTMENT Last Revision: January 21, 1999 SW-A-004060 ' \ 9..% , . V AUTHORIZATION TO IMPLEMENT In accordance with the Institutional Compliance Policy described in Part II of this document, I authorize the Environmental Health and Safety Director to implement these Policies and Procedures concerning management and disposal of hazardous waste. I Robert Moore Vice President Business Affairs 1 1 I1 7/98-BoblReportslReptl OOC TABLE OF CONTENTS e 1 . APPLICABLE REGULATIONS. ........................................................................... 1 . ............................................... A Colorado Hazardous Waste Regulation 6 CCR 7007-3 7 . B Regulations of the Federal Occupational Safety and Health Administration (OSHA) ................................................................................................ .............................................. : 2 . . ....................................... C Regulations of the U S Environmental Protection Agency 3 II. COMPLIANCE POLICY ...................................................................................... 3 111. RESPONSIBILITIES. ......................................................................................... 4 . ................................................................................................................ A The Institution 4 . ................................................ B The Environmental Health and Safety (EHS) Director 4 . .......................................................................................................... C Department Heads 5 . ............................................................................ D Faculty Supervisors of Laboratories 6 0 IV. PENALTIES AND ENFORCEMENT ................................................................. 7 . ........................................................ A Cooperation Wth Federal and State Authorities 8 . ........... B Delegation of Inspection and Enforcement Authority to Department Heads 8 . ................. C Delegation of Inspection and Enforcement Authority to EHS Personnel 8 . ........................................... D Investigation of Improper Waste Management Practices 9 . ............................................................ E Enforcement of Annual Training Requirement 9 V . WASTE MINIMIZATION ..................................................................................... 9 VI . PAYMENT FOR HAZARDOUS WASTE MANAGEMENT SERVICES .......... 10 VI1 . IDENTIFICATION OF REGULATED WASTE ................................................ 11 . .............................................................................. A Identification of Hazardous Waste 13 e VIII . DISPOSAL PROHIBITIONS ......................................................................... 13 . .... IX THE CENTRALIZED WASTE COLLECTION AND DISPOSAL SERVICE 14 3 Colorado School of Mines HAZARDOUS WASTE MANAGEMENT POLICIES AND PROCEDURES . ...................................................................................................................... A Collection 14 . .............................................................................................................. B Transportation 14 . .......................................................................................................................... C Storage 14 . ........................................................................................................................ D Disposal 15 X . MANAGEMENT OF WASTE IN LABORATORIES AND WORK AREAS ....... 15 . ................................................................................................. A Satellite Accumulation 15 . ........................................................................................................................ B Labeling 16 . ....................................................................................................... C Unidentified Waste 16 . ............................................................................................... D Consolidation of Waste 17 . ..................................................................................................................... E Containers 18 . ................................................................................... F Frequency of Waste Collection 18 . .......................................................................................... G Waste Compressed Gases 18 . ............................................................................... H Segregation of Waste Containers 18 . ...................................................................................................................... 1 Explosives 19 . .................................................. J Management of Highly Reactive or Toxic Materials 19 . .................................. .............. K Management of Chemicals with Limited Shelf Lives 19 . ..................................................................................................................... L Picric Acid 20 XI . TRAINING 20 . ..................................................................................... A Annual Training Requirement 20 . ............................................................................................................ B Training Outline 21 . ........................................................................................ C Training Notification Forms 21 ii Colorado School of Mines HAZARDOUS WASTE MANAGEMENT POLICIES AND PROCEDURES ...................................................................... D. Training of Hazardous Waste Workers 21 XII. MEDICAL SURVEILLANCE ........................................................................... 21 XIII. EMERGENCY PROCEDURES .................................................................... 21 XIV. GENERATOR STATUS ................................................................................ 22 XV. GENERATOR SITE BOUNDARY .................................................................. 22 XVI. GENERATOR IDE NTlF ICATION NU MBER: CO D982597320 ..................... 23 XVII. BIENNIAL REPORT .................................................................................... 23 iii 5 Colorado School of Mines HAZARDOUS WASTE MANAGEMENT POLICIES AND PROCEDURES APPENDICES A. Waste Minimization Plan B. Research Proposal Checklist C. Waste Water Discharge Permit D. Samples of "Container Identification Tags" and "Request for Chemical Recycling and Waste Disposal" Form E. Annotated Campus Map and Schematics of Chemical Management Facilities F. Sample Label for Waste Container G. Sample Notification of Denial of Services to Unauthorized Persons H. Training Outline @ I. Sample Notifications of Training Requirements J. Emergency Response Plan K. Emergency Information Poster L. Emergency Procedures and Contingency PladPreparedness and Prevention Plan M. Hazardous Material Discharge Notification Guidelines N. Job Descriptions 0. 1997 Biennial Report P. Hazardous Materials Management Facility Safety Orientation Poster iv 1 1 Colorado School of Mines HAZARDOUSWASTEMANAGEMENT POLICIES AND PROCEDURES 1. APPLICABLE REGULATIONS A. Colorado Hazardous Waste Regulation 6 CCR 1007-3 This regulation governs the management of hazardous waste that is produced by the Colorado School of Mines (CSM). The regulation is administered by the Colorado Department of Public Health and Environment (CDPHE), Hazardous Materials and Waste Management Division (HMWMD). Some important sections of the regulation which are significant in determining how hazardous waste must be managed by the School include the following: - Part 261 Identifies and classifies waste materials that are defined as "hazardous" or "acutely hazardous" wastes. - Part 262 Subparts B and C Describe use of the shipping manifest and describe packaging, labeling, marking and placarding requirements for shipment of hazardous waste. - Part 262.34 Allows the School to accumulate an unlimited quantity of hazardous waste on-site for up to 90 days without a permit. - Parts 262.34(a)(1) and 265 SubDart I Describe the use and management of hazardous waste containers and require a weekly inspection of container storage areas. - Part 262.34(a)(2).(3) Require that waste containers be labeled and bear the date when the accumulation period begins. - Part 262.34(d)(5)(C) Contains reporting and notification requirements in case of a fire, explosion or significant release of hazardous waste. - Part 262.40 Describes recordkeeping requirements. - Part 262.41 Describes requirements for submission of a "Biennial Report" to CDPHE. - Part 262.34(~)(1) Allows School personnel to accumulate waste at or near the point of generation ("satellite accumulation") provided that: The location of the waste is under control of the process operator. The waste is collected in containers that are used and managed in accordance with 265 Subpart I. Containers are labeled and the contents are identified. The locations of "satellite" accumulation sites and the location of the central accumulation site are identified in a contingency plan. The School conforms with requirements for personnel training, preparedness and 1 Colorado School of Mines HAZARDOUSWASTEMANAGEMENT POLICIES AND PROCEDURES prevention, and for emergency procedures and contingency planning detailed in 265.16, and 265 Subparts C and D. - Part 265.16 Describes requirements for personnel training and for maintenance of related documents and records including written job descriptions. - Part 265 SubDart C Describes requirements for "preparedness and prevention" which include the following provisions: Facility operations and maintenance. Required equipment. Testing and maintenance of equipment. -0 Access to communications or alarm systems. Required aisle space. Arrangements with local authorities. - Part 265 Subpart D Requires that the School implement a "Contingency Plan" which describes procedures for managing emergencies. Copies of the plan must be distributed to local emergency responders. A copy must also be maintained at the storage facility. Specific provisions of the Contingency Plan include the following: The Plan describes arrangements with local emergency responders. The Plan contains contact information for the emergency coordinator. The Plan includes a list of emergency equipment. The Plan includes an evacuation plan for the facility. - Part 265.55 Describes the duties of the "Emergency Coordinator." - Part 265.56 Describes emergency procedures and notification requirements. B. Regulations of the Federal Occupational Safety and Health Administration (OSHA) CSM is a public institution in the State of Colorado. Therefore, OSHA does not have direct regulatory authority over the School, however the School models its occupational safety program upon OSHA requirements in accordance with Governor's Executive Order D013889. In addition, the U.S. Environmental Protection Agency (E.P.A.) administers worker protection regulation 40 CFR Part 31 1. This regulation adopts the aforementioned OSHA regulation and makes the OSHA regulation applicable to state and local government employees who engage in hazardous waste operations and who would othetwise be exempt from OSHA regulation. Therefore, OSHA regulation CFR 1910 Part 120 entitled @ "Hazardous Waste Operations and Emergency Response" is applicable to the School in matters concerning hazardous waste operations. Important parts of OSHA regulation 29 CFR 1910 Part 120 2 Colorado School of Mines HAZARDOUS WASTE MANAGEMENT POLICIES AND PROCEDURES include the following: - Part 120(a)(l)(v), (a)(2)(iii)(B) and (a)M)(iii)(C) These regulations indicate that provisions in Part 120(p)(8) apply to School hazardous waste workers including students, and apply to emergency response operations which may be undertaken in the School's Hazardous Materials Management Facility (HMMF). In addition, provisions in Part 120(q) apply to members of the School's Chemical Spill Response Team and to operations of the Team. - Part 120(~)(8) Describes elements of a required "Emergency Response Plan" for hazardous waste workers in connection with operations of the Hazardous Materials Management Facility. The plan is similar to the Contingency Plan required in CDPHE regulation 6 CCR 1007-3 Part 265 Subpart D. The OSHA regulation indicates that duplicate plans are not required and that the Contingency Plan can be integrated into the OSHA prescribed Emergency Response Plan. Specific topics addressed by various subparagraphs of Part 120(p)(8) include the following: Training requirements for employees who respond to emergencies at the HMMF. The employer must certify that employees have received proper training. Site topography, layout and prevailing weather conditions. Incident reporting requirements. Review, rehearsal and amendment of the plan. Installation and use of an alarm system. C. Regulations of the U.S. Environmental Protection Agency - Superfund, Emergency Planning and Community Right-to-Know Programs, 40 CFR Parts 302 and 355 These contain requirements to report releases of hazardous waste to the environment and apply to School hazardous waste operations. Important reporting and notification requirements which pertain to releases of hazardous waste include the following: - Parts 302.4. 302.5 and 302.6 Identify "reportable quantities* of "hazardous substances," discuss how the reporting requirements apply to hazardous waste and describe reporting and written notification requirements. - Part 355.40 Identifies "reportable quantities" of "extremely hazardous substances" and describes reporting and notification procedures associated with a qualifying release of hazardous waste. II. COMPLIANCE POLICY , (The following policy was adopted by the CSM Board of Trustees in June 1992) The Colorado School of Mines is an academic institution devoted to the education and training of future 3 ~ Colorado School of Mines HAZARDOUS WASTE MANAGEMENT POLICIES AND PROCEDURES professionals in business, mining, industry, and government. That education must include appropriate professional training in related fields of environmental and occupational health and safety. It is incumbent upon the School to set an example for students by both word and action in providing an organizational model of an effective environmental and occupational health and safety program. Therefore, the School will integrate environmental health and safety functions into all institutional operations including teaching, research, physical plant maintenance, and internal administration. The School will pursue a prudent and reasonable course of risk management which is functionally effective and which optimizes the use of available resources. The School seeks to comply with federal, state, and local requirements pertaining to environmental protection, occupational health and safety, public safety, and building, fire and sanitation codes. The School will provide resources, training, facilities and services dedicated to this purpose. Environmental and occupational health and safety issues will be squarely confronted with the intention of administering such matters in a manner that reflects the highest ethical and professional standards. 111. RESPONSIBILITIES A. The Institution 0 The Institution provides resources to sustain the Hazardous Waste Management Program. Senior administrators assist in the acquisition and distribution of funds for this purpose, and act in support of the Environmental Health and Safety Compliance Policy. B. The Environmental Health and Safety (EHS) Director The Director provides the University with hazardous waste management services which are modeled upon federal and state regulations. Under the supervision of the Director, the EHS office performs the following waste management functions: Provide centralized chemical procurement and distribution services and facilities. Provide centralized hazardous waste collection, storage and disposal services and facilities. Integrate pollution prevention and waste minimization procedures into chemical procurement and waste management functions. Inform the School Administration concerning the status of the waste management program. Provide information, training and guidance to individual program participants. Contract with private consultants to accomplish waste packing, shipment and disposal. Maintain required records and plans. Submit required reports to regulatory agencies. Coordinate the on-campus transportation and storage of waste with local providers of emergency 4
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