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Hazardous Waste Management Guide

A. Explanation.

HBK AS-553, May 1992

1. USPS Commitment. The Postal Service is committed to a nationwide pollution prevention program designed to improve environmental quality and set a positive example for residents and private businesses in every community it serves. Hazardous waste management, a major component of that program, involves implementing practices to reduce or eliminate hazardous wastes before these wastes are generated and to ensure that hazardous wastes are handled in a way that will protect human health and the environment and meet all legal requirements.

2. Contents. This handbook provides the policies and procedures that postal managers need to develop and implement hazardous waste management activities. It indicates how to identify hazardous waste, sets quantifiable goals for minimizing that waste, and provides guidance on using the waste reduction planning process to achieve waste minimization goals. This handbook also explains what users, generators, transporters, treaters, storers, and disposers of hazardous waste must do to comply with federal, state, and postal regulations, including emergency response measures that must be taken at postal facilities.

3. Revisions. This handbook will be revised to modify pollution prevention policies and strategies as needed to reflect new legislation and regulations.

B. Distribution. 1. Initial. This document is being distributed directly to all Headquarters units and Headquarters field units, as

well as selected field offices.

2. Additional Copies. Organizations not included in the initial distribution or those requiring additional copies should order additional copies from their material distribution center (MDC) using Form 7380, MDC Supply Requisition. The checklists included in this handbook are not yet available at MDCs.

C. Comments and Questions. If you need further clarification of the policies and procedures outlined in this handbook, send your request to:

GENERAL MANAGER ENVIRONMENTAL MANAGEMENT DIVISION UNITED STATES POSTAL SERVICE 475 L'ENFANTPLZ SW RM 4130 WASHINGTON DC 20260-6423

D. Effective Date. These instructions are effective immediately.

Mitchell H . Gordon Senior Assistant Postmaster General Administrative Services Group

Hazardous Waste Management Guide Contents

Contents

Chapter 1-Introduction

110 General 111 Overview 112 Background

112.1 Importance of Hazardous Waste Management 112.2 Pollution Prevention Program

113 Policy 114 Scope 115 Objectives 116 KeyTerms 117 Use of Exhibits

120 Laws and Regulations 121 PrimaryLaws

121.1 Resource Conservation and Recovery Act of 1976 121.11 General 121.12 Enforcement 121.13 Penalties for Non-compliance

121.2 Comprehensive Environmental Response, Compensation, and Liability Act of 1980

121.3 Toxic Substances Control Act of 1976 122 Other Laws

122.1 Pollution Prevention Act of 1990 122.2 Clean Air Act Amendments of 1990 122.3 Clean Water Act 122.4 Marine Protection, Research, and Sanctuaries

Act 122.5 Occupational Safety and Health Act 122.6 Safe Drinking Water Act 122.7 Hazardous Materials Transportation Act

130 Responsibilities 131 General 132 Headquarters

132.1 Senior Assistant Postmaster General, Administrative Services Group

132.2 All Depmtments 132.3 Environmental Management Division,

Administrative Services Group 133 Regions 134 Divisions 135 Hazardous Waste Coordinators 136 Associate Offices, Stations, and Branches

Chapter 2-Hazardous Waste Identification and Facility Classifiation

210 Introduction

220 Definition of Hazardous Waste 221 General 222 Listed Wastes 223 Charactenstic Waste 224 Mixed Wastes 225 Excluded Waste

230 Identitying Postal Hazardous Waste 231 General 232 Chemical Identification 233 Unknown Substances 234 Hazardous Waste IIT the Ma11

240 Hazardous Waste Genmator Catogories 241 General 242 Conditionally Exempt Generators 243 Small Quantity Generators

243.1 General 243.2 Accumnlauon Time Limit 243.3 On-site Treatment

244 Large Quantlty Generators

Chapter 3-Recordkeeping and Reporting

310 Introduction

320 Notification

330 Manifests

340 Exception Reports

350 Biennial Reports 350.1 General 350.2 Recordkeeping

360 Toxic Emissions Reports

370 Personnel Qualifications and Records

380 Contingency Plans

390 Emergency Notifications

Handbook AS-553, May 1992 3


Chapter &Hazardous Waste Minimization Planning

530 Storage 531 General 532 Storaee Area Reauirements

410

420 421 422 423 424 425

430

440 441

442

443 444 445

450

460

470 47 1 412

Introduction

Waste-stream Assessment General Assessment Team Data Collection Identification of Candidate Waste Streams Facility Review and Waste-stream Analysis

Opportunities and Priorities

Waste Reduction Approaches Options 441.1 General 441.2 Source Reduction

441.21 General 441.22 Input Material Changes 441.23 Technology Changes 441.24 Good Operating Practices

441.3 Recycling Evaluation of Preliminary Waste Minimization Options Ranking of Waste Minimization Options Results and Option Rankings Final List

Feasibility Analyses

Facility-Specific Goals

Annual Review General Measurement

Chapter 5-Handling, Storage, Shipment, and Disposal

510 Introduction

520 Handling 521 General 522 Vehicle Maintenance and Equipment Repair Facilities 523 Printing Operations 524 Laboratories and Training Facilities 525 Preventive Maintenance

525.1 General 525.2 Specific Activities

526 Handling Unknown Substances

I

533 Container Storage Requirements 534 Satellite Accumulation 535 Maximum Storage Capacity 536 Tank Storage

540 Shipment 541 General 542 Standards Applicable to Transporters of Hazardous

Waste

550 Disposal 551 General 552 Specific Disposal Procedures

552.1 Waste Oil 552.2 Waste Paints 552.3 Used Batteries 552.4 Used Tires 552.5 Solvents and Degreasers 552.6 Printing Wastes 552.1 Laboratory Wastes 552.8 Asbestos

553 Standards Applicable to Owners and Operators of Treatment, Storage, and Disposal Facilities

554 Permits for Treatment, Storage, or Disposal of Hazardous Waste

Chapter 6-Emergency Planning and Procedures

610 Introduction

620 Contingency Plans

630 Required Equipment

640 Training

650 Other Measures 651 General 652 Required Aisle Space 653 Arrangements with Local Autboritles 654 Hazardous Waste Coordinator 655 Posted Information

660 Response Procedures

670 Remedial Response

680 Hazardous Waste Docket

4 Handbook AS-553, May1992


References

Glossary

Appendices Appendix A EPA ;te Hazardous Wastes Appendix B Hazardous Waste Characteristics Appendix C Typical Material Data Safety Sheet Appendix D Sample Contingency Plan Appendix E Hazardous Waste Report Forms Appendix F How to Get More Information about

Hazardous Waste

Exhibits

Chapter 1 112.1 Postal Service Benefits from Hazardous

Waste Minimization 1 I5 Chemicals Targeted for Reduction 121.11a Overview of RCRA Requirements 121.11b RCRA “Cradle-to-Grave’’ System for

121.12 Hazardous Waste Generator Inspection

121.2

Tracking Hazardous Waste

Checklist Relationship of CERCLA and RCRA

Chapter 2 223 224 231a

231b 231c 231d 241

Hazardous Waste Characteristics Potentially Incompatible Wastes Materials Used and Hazardous Waste That Might Be Generated at Typical Vehicle Maintenance and Equipment Repair Operations Postal Waste Descriptions RCRA Checklist Hazardous Waste Log Hazardous Waste Generator Requirements

Chapter 3 310a

310b 320 330a 330h 370

Chapter 4 410 422

424 425

441.22 472a 472b

Chapter 5 521 532

533

55 1

Chapter 6 620

670

Overview of Hazardous Waste Facility Requirements Hazardous Waste Regulatory Checklist Notification of Regulated Waste Activity Uniform Hazardous Waste Manifest Required Hazardous Waste Manifest Cycle Verification Sheet for Hazardous Waste Training

Cycle of Hazardous Waste Minimization Overview of Facility Hazardous Waste Assessment Waste Assessment Checklist Potential Location of Hazardous Waste in Postal Facilities USPS Hazardous Waste Shipping Report How to Measure Waste Minimization Worksheet for Recording Hazardous Waste Generation

Inventory Control Measures Hazardous Waste Drum Storage Area Inspection Checklist Typical Label for Hazardous Waste Container Approved Recycling Vendors, Haulers, and Landfills

Elements of Facility Emergency Response Plan Stages of Investigation and Cleanup Required by Federal Facilities Listed on the Federal Agency Hazardous Waste Compliance Docket


Hazardous Waste Management Guide 113

Chapter 1 Introduction

110 General 111 Overview This handbook is a guide for U.S. Postal Service managers to ensure the safe and environmentally sound management and disposal of hazardous and regulated substances. Hazardous wastes are

Introduction 4 Pnlll Itinn nravpntinn . .-.-....-..

quite common. If your operations use cleaning solvents, inks, oils, Daints. acids. alkalies. oesticides. or herbicides. vou mav he eener- + Laws and regulations , , ~ ~ . I - - D - ~ ~ ~, ,~~~~ ~~~~ king regulated hazardous waste. This handbook provides informa- + Responsibilities tion to assist you in identifying such hazardous waste. It outlines planning, program, and project requirements and explains postal policy regarding the use, generation, transportation, treatment, storage, and disposal of hazardous waste. The document provides guidance on complying with federal, state, local, and Postal Ser- vice regulations, and it establishes Postal Service performance standards.

112 Background 112.1 Importance of Hazardous Waste Management Hazardous waste management has become a critically important concem in recent years. Improper handling and disposal of hazardous wastes has damaged water supplies and threatened human health. The costs of waste disposal and liability are escalating. Landfilling of many hazardous wastes is now banned. There are few commercial hazardous waste disposal facilities, and their capacity is limited. Reducing the amount of hazardous waste generated by the Postal Service is the most economical and environmentally sound approach to meeting legal requirements (Exhibit 112.1). Waste minimization is not only economically feasible, it is the law. Lack of a hazardous waste program exposes the Postal Service to civil, criminal, and administrative penalties. Postal managers can be held personally liable by federal and state enforcement authorities for violation of hazardous waste laws. To protect the Postal Service and its employees, an integrated hazardous waste management program must be implemented with initiatives for reducing the use of hazardous waste.

112.2 Pollution Prevention Program Hazardous waste management is the third phase of the Postal Service pollution prevention program. The first phase-recycling- is covered in Handbook AS-550, Recycling Guide. The second phase-waste reduction-is covered in Handbook AS-552, Waste Reduction Guide. Forthcoming phases include stormwater management, underground storage tank management, and other programs.

113 Policy In performing its mission to provide prompt, reliable, and efficient postal services to all communities, the Postal Service will conduct its activities in a cost-effective manner that protects human health and the environment. In establishing postal regulations and prac-

Handbook AS-553, May 1992 @ 7

113 Hazardous Waste Management Guide

Hazardous Waste Minimization Benefits - Reduced hazardous waste

treatment, storage, and handling costs - Reduced generator/disposal fees and taxes - Avoidance of costly alternative treatment technologies - Reduced raw material and feedstock costs - Decreased regulatory reporting requirements and compliance costs

Lower operating and maintenance costs

exposure to chemicals

better management and production efficiencies - Reduced liability for environmental problems at both on-site and off-site treatment, storage, and disposal facilities

* Decreased employee risk from

* Overall reduced costs through

- Improved public image - Reduced impact on the environment

Exhibit 112.1, Postal Service Benefits from Hazardous Waste

Minimization

tices, the Postal Service will, as appropriate, follow the guidelines for environmental protection that are set forth in the Administra- tive Support Manual 550. The Postal Service’s highest priority in the area of hazardous waste management-as well as in waste reduction in general-is to minimize the amounts of potentially hazardous and toxic substances that it uses. Postal priorities for hazardous waste management are source reduction, recycling, energy conservation and recovery, waste treatment, and (as a last resort) waste disposal.

114 Scope The policies and guidelines in this handbook apply to all Postal Service managers, programs, projects, products, and services.

115 Objectives The focus of the hazardous waste management program is to investigate opportunities, identify options, and perform feasibility analyses to reduce the amounts of potentially hazardous and toxic materials used by the Postal Service. Substituting nonhazardous for hazardous wastes, recycling, reusing and recovering materials, and better housekeeping must become key management practices. In addition, hazardous waste must be handled in a way that will protect human health and the environment and meet all legal mandates. By implementing a strong hazardous waste management program, the Postal Service will reduce costs, paperwork, liability, and pollution, as well as create a cleaner, safer, and more efficient work environment. In particular, the program aims to develop realistic and safer alternatives to the use of toxic substances, with the goal of reducing hy one-third by 1994 and one-half by 1995 (relative to 1993 levels) the use of the 17 targeted chemicals listed in Exhibit 115.

116 KeyTerms Definitions of technical terms used in this handbook are found in the Glossary. The following terms are central to the discussion of hazardous waste management: a . Hazardous Waste. By-products of society that can pose a hazard

or potential hazard to human health or the environment when improperly managed. Federal regulations place hazardous wastes into two categories: (1) Characteristic Wastes. Wastes that are ignitable, corrosive,

reactive, or toxic. (2) Listed Wastes. Specific wastes that are included on any of

four lists included in the Resource Conservation and Re- covery Act (RCRA) regulations (see Appendix A).

b. Source Reduction. Any action taken before waste is generated

c . Toxic Substance. A substance that is harmful to living organ- isms-specifically, an asphyxiant, poison, mutagen (alters DNA), teratogen (causes birth defects), or carcinogen (causes cancer).

d . Unknown Substance. A substance of unknown composition or characteristics.

~~~ ~

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that reduces its volume and toxicity. ~ ~~

Handbook AS-553, May 1992

Hazardous Waste Management Guide 117

e. Waste. Any material discarded as worthless, defective, or of no further use that, when disposed of, may pose a threat to human health or the environment.

f. Waste Minimization. The reduction, to the extent feasible, of hazardous waste that is generated or subsequently treated, stored, or disposed. It includes any source reduction or recycling activity undertaken by a generator that results in ( I ) the reduction of total volume or quantity of hazardous waste; (2) the reduction of toxicity of hazardous waste; or (3) both, as long as the reduction is consistent with the goal of minimizing present and future threats to human health and the environment.

g. Waste Reduction. Any change in a process, operation, or activity that results in the economically efficient reduction in waste material per unit of production without reducing the value output of the process, operation, or activity.

h. Waste Stream. A specific type of waste leaving a facility or operation.

117 Use of Exhibits To meet postal waste minimization goals and comply with federal, state, and postal requirements pertaining to hazardous waste, all postal facilities and programs must carefully assess current practices. To aid in this assessment, several of the chapters in this handbook include checklists or worksheets for use by managers. For example, Exhibit 121.2 at the end of this chapter is a checklist that should help managers determine if their facilities comply with federal and state regulations.

Chemicals Targeted for Waste Minimization

1. Benzene

2. Cadmium and cadmium compounds

3. Carbon tetrachloride

4. Chloroform (trichloromethane)

5. Chromium and chromium compounds

6.

7. Lead and lead compounds 8. Mercury and mercury compounds

9. Methylene chloride (dichloromethane)

Cyanide compounds and hydrogen cyanide

10.

11.

12.

13.

14.

15.

16.

17.

Methyl ethyl ketone

Methyl isobutyl ketone

Nickel and nickel compounds

Tetrachloroethylene (perchloroethylene)

Toluene

1,l ,l-trichloroethane (methyl chloroform)

Trichloroethylene

Xylenes (all xylenes)

This list of chemicals is drawn from the Toxic Release Inventory (TRI), based on recommendations from EPA program managers.

Exhibit 115, Chemicals Targeted for Reduction



120 Laws and Regulations 121 Primary Laws 121.1 Resource Conservation and Recovery Act of 1976 .ll General The Resource Conservation and Recovery Act of 1976 (RCRA) addresses (1) dangers to human health and the environment posed by improper waste disposal and (2) conservation of valuable material and energy resources. Exhibit 121.11a briefly summarizes RCRA’s requirements; RCRA regulations can be found in Title 40 Part 260 et seq. of the Code of Federal Regulations. In particular, RCRA mandates a “cradle-to-grave” system that tracks hazardous waste from its origin through its ultimate disposal (Exhibit 121.1 1 b). Regulations adopted by the Postal Service to carry out that man- date extend to facilities and operations that generate, transport, store, treat, and dispose of hazardous waste. The Environmental Protection Agency (EPA) administers RCRA and requires that state programs he consistent with federal RCRA regulations. In some states, more stringent requirements have been added to address special problems within those states. For example, several states consider waste oils and PCBs as hazardous, whereas others do not. Other provisions of RCRA, as amended by the Hazardous and Solid Waste Amendments of 1984, address quality of landfills, surface waters, and underground storage tanks. These provisions have expanded requirements for groundwater monitoring and cleanup at permitted facilities. The result has been sweeping changes in the ways hazardous wastes must he managed certain wastes have been banned from land disposal; tighter controls have been placed on small quantity generators; and regulation of used oil and facilities inspections have gone into effect.

.12 Enforcement State agencies that administer hazardous waste programs are required to adequately enforce compliance. In 1991, there were approximately 48 states authorized by EPA to enforce some component of their own hazardous waste regulatory program. EPA and state and local health and environmental officials, upon presenting proper identification at any reasonable time, may enter and inspect any establishment-including any postal facility-where hazardous waste is being stored, handled, processed, disposed of, or treated to recover resources. Exhibit 121.12 at the end of this chapter is an example of a checklist used by hazardous waste inspectors. These officials may also: a. Obtain samples of waste from any authorized person. The in-

specting officer must provide the Postal Service a receipt de- scribing the sample taken and, when requested, a portion of each sample equal in volume or weight to the portion retained. If analysis of the sample is made, the Postal Service must be furnished promptly with the results of the analysis.

b. Stop and inspect any vehicle reasonably suspected of transporting hazardous waste when the investigator is accompanied by a uniformed police officer in a clearly marked vehicle.

c. Inspect and copy any records required to be kept under the hazardous waste control laws.

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10 @ Handbook AS-553, May 1992

121.13 -__ Hazardous Waste Management Guide

Generators

- Identification * Personnel training

Handling and storage - Labeling of waste Reporting requirements - Manifesting of waste - Disposal at an approved landfill

* Siting standards Emergency response

Treatment, Storage, and Disposal Facllities

Groundwater monitoring Container standards Tank standards Surface impoundment standards - Landfill standards Financial assurance Insurance Safety and health - Emergency response

Generators

Under RCRA, generators of hazardous waste are subject to requirements that ensure proper management of hazardous waste. Many RCRA requirements-such as personnel training, disposal only to a permitted treatment, storage, or disposal facility, and manifesting requirements-are investments that result in a significant minimization of future liabilities.

Treatment, Storage, and Disposal Facilltles

Treatment, storage, and disposal facilities have stringent operation and design criteria to prevent environmental releases. These facilities are required to adhere to regulations pertaining to groundwater monitoring, containers, tanks, surface impoundments, waste piles, and landfills. In addition, treatment, storage, and disposal facilities must meet certain financial requirements: financial assurance for closure and postclosure and liability coverage for injury and property damage.

Exhibit 121.11a, Overview of RCRA Requirements

d. Photograph any waste container and its label, vehicle, waste treatment process, waste disposal site, or violation found during the inspection (in compliance with federal, state, and local environmental regulations) complying with all reasonable secu- rity, safety, and sanitation measures specified by the operator.

Note: All records, reports, or information obtained by an inspection will be available to the public unless EPA and the Postal Service find that the information is entitled to the protection of confidentiality under Section 1905 of Title 18 of the US. Code.

.13 Penalties for Non-compliance Failure to comply with RCRA regulations can result in costly civil penalties. Moreover, postal managers, employees, and contractors who neglect or violate some provisions of the law are subject to significant individual criminal penalties, including fines and imprisonment. Specifically, Section 3008 of RCRA Subtitle C states


Hazardous Waste Management Guide 121.13 I

Treatment Facility

Postal Facility

Exhibit 121.11b, RCRA “Cradle-to-Grave” System for Tracking Hazardous Waste

that if any person knowingly transports, treats, stores, or disposes of any hazardous waste without a permit and commits a violation and knows at that time that he or she is placing another person in

conduct manifests an unjustified and inexcusable disregard for human life, then this person shall be subject to a maximum fine of $250,000 or imprisonment for not more than fifteen years, or both. In the case of a corporation, the maximum fine is $1 million. Under RCRA, persons liable for criminal penalties are those who knowingly: a. Transport any hazardous waste to a facility that does not have a

permit. b. Dispose of any hazardous waste without having obtained a

permit. c. Make any false statement or representation in any application,

label, manifest, record, report, permit, or other document file maintained or used for purposes of compliance.

~ imminent danger of death or serious bodily injury, and if this

~ ~~~~

12 Handbook AS-553, May 1992

122.6 .---.---____ ___- Hazardous Waste Management Guide

121.2 Comprehensive Environmental Response, Compensation, and Liability Act of 1980 The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA, or Superfund) provides for the cleanup of inactive and abandoned hazardous waste sites. As indicated in Exhibit 121.2, CERCLA has the same hasic objectives as RCRA; however, RCRA aims to avoid the creation of hazardous waste problems, whereas CERCLA addresses these problems once they exist. CERCLA imposes liability-on any or all parties responsible for the release of hazardous substances-for the costs of cleaning up those substances. Under CERCLA, the Postal Service remains responsible for the proper management of waste even after it leaves Postal Service property. The strict joint and several liability provisions established in CERCLA can lead to costly investigative and cleanup activities at waste disposal sites. These must be avoided.

121.3 Toxic Substances Control Act of 1976 The Toxic Substances Control Act of 1976 (TSCA) regulates the manufacture, use, and disposal of chemical substances. TSCA establishes a mechanism for pathering data to determine the potential health and environmental risks of chemicals and for using those data to support restrictions on the manufacture or use of those chemicals.

122 Other Laws 122.1 Pollution Prevention Act of 1990 The Pollution Prevention Act of 1990 establishes a national policy that pollution should he prevented or reduced at the source wben- ever feasible.

122.2 Clean Air Act Amendments of 1990 The Clean Air Act Amendments of 1990 require the prevention of releases to the atmosphere of hazardous and toxic agents. Al- though chlorofluorocarbons (CFCs) are not classified as hazardous waste, CFCs must he recovered or recycled and not vented to the atmosphere. See Handbook AS-55 1, Clean Air Act Compliance Guide (to be issued in spring 1992), for further information.

122.3 Clean Water Act The Clean Water Act regulates the discharge of hazardous pollut- ants into the nation’s surface waters.

122.4 Marine Protection, Research, and Sanctuaries Act The Marine Protection, Research, and Sanctuaries Act regulates waste disposal at sea.

122.5 Occupational Safety and Health Act The Occupational Safety and Health Act regulates hazards in the workplace, including worker exposure to hazardous substances.

122.6 Safe Drinking Water Act The Safe Drinking Water Act regulates contaminant levels in drinking water.

Protection of Human Health and the Envifonment from the Release of

Hazardous Substances

CERCLA Regulatory Program Ensuring Safe Management of Hazardous and Nonhazardous Waste

Exhibit 121.2, Relationship of CERCLA and RCRA


122.7 Hazardous Waste Management Guide

122.7 Hazardous Materials Transportation Act The Hazardous Materials Transportation Act regulates the transportation of hazardous materials.

130 Responsibilities 131 General The Postal Service is legally and socially responsible for safely managing the hazardous materials used in its operations and the waste it produces. As discussed in Chapter 2, all postal managers must determine which, if any, of the wastes they generate are hazardous, as well as the quantity of such wastes at their facilities. Managers involved with hazardous waste must comply with policies, regulations, and procedures identified in this handbook. Spe- cifically, postal managers at all organizational levels must: a. Develop and maintain a waste reduction program that places

highest priority on minimizing the use of potentially hazardous and toxic materials.

b. Encourage the purchase of recoverable materials that are less toxic substitutes for hazardous materials, where practicable.

c. Ensure that hazardous wastes are properly stored and labeled. d. Conduct, encourage, and promote the coordination of research

investigations, experiments, training, demonstrations, and stud- ies related to: (1) Protecting employee health. (2) Planning and financing waste management systems, in-

(3) Improving waste disposal methods and resource recovery. (4) Restricting the use of certain categories of chemical prod-

e. Become familiar with regulations pertinent to the operation of a facility for the treatment, storage, or disposal of hazardous waste and to the permitting process.

f. Periodically review waste disposal contractors and waste disposal facilities to ensure that each is complying with conditions of permits and regulations. Manifests must be obtained show- ing proper transportation and disposal of postal wastes.

g. Be knowledgeable of hazardous waste requirements for transporters and ensure that off-site shipments of hazardous waste are labeled, marked, and placarded according to US. Depart- ment of Transportation and EPA requirements, as described in this handbook.

h. For each facility that generates hazardous waste, designate an ad hoc hazardous waste coordinator to assist in the proper management of hazardous waste and to coordinate response measures in the event of a hazardous waste emergency (see section 135).

i

cluding resource recovery.

ucts.

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134 -_ Hazardous Waste Management Guide

132 Headquarters 132.1 Senior Assistant Postmaster General, Administrative Services Group The Senior Assistant Postmaster General, Administrative Services Group, is the Chief Environmental Officer for the Postal Service and is responsible for the overall development of plans, policies, and procedures to implement this program.

132.2 All Departments All departments must manage their respective functional areas to ensure compliance with hazardous waste laws and implement the intent of this bandhook.

132.3 Environmental Management Division, Administrative Services Group The Environmental Management Division, Administrative Ser- vices Group, is responsible for developing integrated environmental policies and methods for compliance with RCRA, CERCLA, TSCA, the Pollution Prevention Act of 1990, and other federal, state, and local environmental laws and regulations. This division also will serve as an information center and assist in developing an education program to provide information ahout pollution prevention and the importance of properly managing-and minimizing- hazardous wastes.

133 Regions The regional environmental steering committees must ensure management participation and compliance at all levels of the field organization and provide assistance to field division environmental coordinators. Regional environmental coordinators are responsible for program implementation, development, tracking, monitoring, and reporting: they must assess postal compliance with environmental laws and recommend processes or procedural corrections to deviations from the goal of providing safer, cleaner, more efficient, and cost-effective solutions to hazardous waste problems. Regions will provide comprehensive status reports to Head- quarters for a National Environmental Reporting and Database System (NERDS).

134 Divisions Each field division general manager is responsible for implementing the hazardous waste management program and designating a division environmental coordinator to assist each facility manager and hazardous waste coordinator in developing, tracking, monitoring, and reporting on hazardous waste minimization projects and programs. The division environmental coordinator is responsible for implementing sound environmental practices outlined in this handbook and for assisting functional managers regarding hazardous materials and waste. The division environmental coordinator should also compile and maintain an inventory of postal facilities and the chemicals specific to each. Field divisions must develop appropriate recordkeeping systems for waste management and minimization; must maintain manifests, biennial reports, contingency plans, employee training records, agency inspection reports,

Division Responsibilities Implement sound practices Maintain inventory of facilities and chemicals

Maintain documents Input data Submit reports

Develop recordkeeping systems ~~



permits, internal waste handling documents, material safety data sheets, and laboratory analyses; and must input data and submit status reports to regional coordinators.

135 Hazardous Waste Coordinators To assist the Postal Service in the proper management of hazardous waste, each facility that generates hazardous waste must designate a coordinator for the postal hazardous waste management program. This is an ad hoc responsibility. Working with the division environmental coordinator and facility manager, and as part of the waste assessment team, the hazardous waste coordinator must ensure that: a

b

C

d

e

f.

8

h

i.

The various operations and processes within the postal facility are surveyed to determine where chemicals are used. The sur- vey must consider the raw materials and equipment used to achieve the facility’s objectives. The hazardous waste coordinator should then identify where waste is generated and where it can be minimized. All waste streams are analyzed and quantified. The figures generated from the analyses will be used to satisfy the reporting requirements for compliance by field divisions, regions, postal headquarters, and outside agencies. Current waste handling procedures within the facility and departments are identified and the routine self-inspections are conducted at least monthly. Inspections facilitate proper lahel- ing and storage practices and assist the facility and division in the timely management of wastes. Process altematives are identified. Where possible, the coordinator should recommend to management the substitution of nonhazardous and environmentally benign materials. The field division environmental coordinator will endeavor to have equipment manufacturers, suppliers, and other vendors help identify other possible sources of waste reduction. Alternatives to landfilling of hazardous wastes-such as recycling, brokering usable products to other departments, chemical substitutions, and incineration-are identified. Empty drums must be considered for return to the manufacturer or sold to a drum recycler. Waste management vendors available to the division are identified and evaluated. Where possible, the division environmental coordinator will visit the facilities of vendors used for waste analysis, treatment, transportation, and disposal to ensure compliance with environmental laws and postal policies. Purchasing changes designed to reduce the generation of solid or hazardous waste are identified and recommended to management. Appropriate authorities are immediately notified in the event of a hazardous waste emergency and all necessary measures are taken to protect health, safety, and the environment. Hazardous waste reports are submitted to the division environmental coordinator.

Note; Additional waste assessment team responsibilities are discussed in section 422.


~

136 ---I


136 Associate Offices, Stations, and Branches Postmasters, station managers, and supervisors are responsible for forming waste reduction teams, establishing waste reduction programs and plans, and encouraging other participation. They are responsible for developing environmental awareness at their facilities, reducing hazardous and nonhazardous materials in their in- ventories, and ordering recyclable and recycled products.


Exhibit 121.12 (p. 1) Hazardous Waste Management Guide

Hazardous Waste Generator Inspection Checklist

Yes No

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~

_______

_ _ _ ~

_________

Exhibit 121.12 (p. I), Hazardous Waste Generator Inspection Checklist

Use this checklist to evaluate your operation and determine if your facility complies with regulations.

Generator Requirements

Hazardous 'Waste Determlnation

Generator has determined whether waste is nonhazardous, hazardous, or extremely hazardous

EPA ldentlficatlon Number

Generator has EPA identification number for manifesting wastes shipped off-site

Manifest

Generator shall complete producer-of-waste section of manifest and give to registered hazardous waste hauler when shipping waste off-site

Generator signs certification statement that he has a volume reduction program in place

Applicable sections accurately completed for all waste transported off-site, exceDt for waste transported by registered hauler with a manifest variance from'the appropriate siate agency

Codes of manifest available for review

Disposition of Waste

Hazardous waste taken only to state-permitted facility

Unnecessary generation of waste is avoided

Appropriate wastes are recycled

Acutely Hazardous Waste

Acutely hazardous waste not handled nor disposed of without permit

No deviation from approved handlingldisposal methods

Storage, Accumulation, and Handling Requirements

All waste is moved off-site to an approved facility within 90 days of commencing accumulation

Containers are in good condition

Containers are stored in a manner that prevents spills and escape from designated area


Exhibit 121.12 (p. 2) - ._"I__ Hazardous Waste Management Guide

~

Generator Requirements Yes No Drums and tanks inspected weekly

Hazardous waste storage area is secure to prevent unauthorized people from having access

Containers are labeled to indicate presence of hazardous waste, identify type of waste, and indicate date of start of accumulation

Stored waste does not cause corrosion, leakage, or premature failure of container

Ignitable or reactive wastes separated from sources of ignition

Wastes handled so as to prevent rupture, leaks, etc.

Means to StoD inflow for continuous feed

Discharge control equipment, monitoring equipment, and tank level inspected

Ignitable or reactive wastes treated, rendered, or mixed to be non-ignitable or non-reactive; protected from ignition or reaction; or tank used only for emergencies

Covered tanks storing ignitable or reactive wastes comply with buffer zone requirements

Uncovered tanks have 2 feet (60 centimeters) of freeboard, dikes, or other containment structures

Incompatibles are stored/protected in separate tanks and drums and stored in separate areas

I Wastes are segregated to promote recycling ! ! I I Pretransport Requirements I I

Waste is packaged, labeled, and placarded according to 49 CFR (DOT)

Each container of 110 gallons or less is marked properly

Training Employees receive training within six months after being hired

Employees trained to complete manifest properly

Employees trained on contingency plan and emergency procedures

Employees trained on proper waste handling

Employee training records are maintained

I ~ _ _ _ _ _ _ _

Exhibit 121.12 (p. 2), Hazardous Waste Generator Inspection Checklist


Exhibit 121.12 (p. 3) Hazardous Waste Management Guide _ll_.l_ll--_l-_ll_ -

~

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Submittal of biennial report Submittal of required reports to division environmental coordinator

I Generator Requirements Preparedness for and Prevention of Emergencles

Facility operated and maintained to minimize possibility of fire, explosion, or release of hazardous waste to the environment

Appropriate communicationlalarm systems

Appropriate firefighting, spill control, and decontamination equipment

Facility tests and maintains above equipment as necessary

Personnel have immediate access to communications or alarm systems

Adequate aisle space maintained

Contingency Plan and Emergency Procedures I Arrangements made with local authoritieslemergency response teams

Generator has prepared written contingency plan for site

Plan describes facility personnel action responses

Plan lists names, addresses, phone numbers of emergency coordinators, designates primary emergency coordinator, and lists others in order of assumption I of resDonsibilitv Plan lists all emergency equipment at the facility, location, physical description and capabilities

Plan includes an evacuation plan for facility personnel Copies of contingency plan submitted to police, fire department, hospital, local emergency response teams

Waste Minimization Plan

Spills and leaks are avoided in raw materials storage area, plant operations, and waste storage

Plant personnel are trained in waste minimization techniques

Facility is operated and maintained to reduce the amount of hazardous wastes discharged to the air, water, or land

Recordkeeping and Reporting Manifest, annual report, exception reports, employee training, and analytical test results retained by generator for at least three years

223 -l-l_.l--ll__ll__.l__l_l___ Hazardous Waste Management Guide

210

220

Introduction - All postal managers and contractors must determine if any of the wastes generated at postal facilities are hazardous and, if so, how much of these wastes they generate and store. In general, these determinations should be made during the development of facility- specific waste reductionplans, which are discussedin Chapter4 of this handbook, as well as in Handbook AS-552, Waste Reduction Guide. This chanter nrovides the definitions and guidelines that

kkxardous waste Ider1tificntior1 and Facility (7l"iication

Definition of hazardous waste I I I

will help managers determine if they are subject to hazardous waste regulations and reporting requirements.

@ Identifying postal waste Generator categories

Definition of Hazardous Waste

Chapter 2 Hazardous Waste ~d~~~~~~~~~~~~


221 General Postal managers must be familiar with the definition of hazardous waste, which may vary slightly from state to state. A waste is a material no longer used for its original intended purpose that is stockpiled for disposal. In plain language, waste is considered hazardous when it may cause or significantly contribute to an increase in serious illness or may pose a substantial hazard to human health, safety, or welfare or to the environment when improperly treated, stored, transported, used, disposed of, or otherwise managed. Under the Resource Conservation and Recovery Act (RCRA), waste is considered hazardous if it falls into either of the following categories: listed wastes and characteristic wastes.

222 Listed Wastes A waste may he considered hazardous if it appears on any one of the four lists of hazardous wastes contained in the RCRA regulations. These wastes have been listed because they exhibit one or more of the characteristics described below or contain any number of toxic constituents that have been shown to be harmful to human health and the environment. The RCRA regulations list hundreds of hazardous wastes, including wastes derived from nonspecific sources (so-called F Wastes), manufacturing process (K Wastes), and discarded chemical products (P and U Wastes). These lists can be found in the Code of Federal Regulations, Title 40, Part 261, Subpart D. Appendix A of this handbook contains a list of hazardous substances, including their identification numbers assigned under RCRA regulations. The acutely hazardous chemicals specifically targeted for reduction are listed in Exhibit 115 in Chap- ter 1. Although postal policy targets all hazardous substances for reduction, acutely hazardous wastes have priority for elimination or substitution by replacement of non-toxic materials.

223 Characteristic Waste Even though a waste does not appear on one of the hazardous wastes lists, it is considered a hazardous waste if it exhibits any one

21

Hazardous Waste Management Guide -_ 223 .- . of the following characteristics (graphically depicted in Exhibit I

Reactivity Toxlclty

I

Exhibit 223, Hazardous Waste Characteristics

C . 3 m mi o 12 U SPS \Nas f e s Oil

@ Solvents Batteries Pesticides and herbicides

Paint thinner and Degreasers @ Inks

@ Old paint

223): a. Ignitability. Easily catches fire, with a flash point of less than

140°F. b. Corrosivity. Easily corrodes materials or human tissue, very

acidic or alkaline (pH less than 2 or greater than 12.5). c. Reactivity. Explosive, reacts with water or acid, unstable. d. Toxicity. Causes local or systemic damages and may result in

adverse health effects in an organism-that is, an asphyxiant (such as carbon monoxide), poison (such as oil), mutagen (a chemical that alters DNA), teratogen (one that causes birth defects), or carcinogen (one that causes cancer).

Note: More detailed information on the specific characteristics of and criteria for identifying RCRA characteristic waste is located in Appendix B.

224 Mixed Wastes Mixing listed hazardous waste with other nonhazardous waste causes the entire waste to be classified as hazardous. In addition, managers should keep in mind that hazards can result from chemical reactions when incompatible materials are combined (for example, a toxic gas is formed when ammonia is combined with chlorine bleach). See Exhibit 224 for lists of potentially incompatible waste.

225 Excluded Waste Some states have determined that certain wastes-such as domestic sewage, fly ash and bottom ash, household hazardous waste, and discarded, untreated wood-are not subject to regulation as a hazardous waste. Postal managers should check with state environmental agencies to find out which wastes are excluded from regulation.

230 Identifying Postal Hazardous Waste 231 General

maintenance and equipment repair facilities, print shops, ~ ~ ~~~ Hazardous wastes can be found at postal laboratories, vehicle

groundskeeping operations, and elsewhere. Commonly found ex- amples are waste oil, solvents, cracked or leaking batteries, pesticides and herbicides that have expired and can no longer serve their intended function, inks, used paint thinner and degreasers, old paint, and hazardous materials spilled or recovered. Exhibits 231a and 231b describe hazardous wastes often found at postal vehicle maintenance and equipment repair facilities. Exhibit 231c at the end of this chapter is a multipurpose checklist that will enable managers at all postal facilities to identify RCRA solid and hazardous wastes. A hazardous waste log (shown in Exhibit 231d) should be used to list the names of hazardous chemicals as soon as they are identified, and the log should be updated as necessary. If questions arise as to whether or not a specific waste is hazardous, contact state regulatory officials for classification.


Exhibit 224 -_II.__-.__I_._____ .. Hazardous Waste Management Guide

This chart rovides broad groupings of chemicals that, when mixed, may react in an undesirable manner. demicals from one numerated group should not be mixed with chemicals from the same numerated group. For example, do not mix chemicals in group 2-A with chemicals in roup 2-B. These listings are not all inclusive. Specific chemical reactivity should be investigate 2 before using any chemical.

Heat generation or violent reactioi

1 -A

Acetylene sludge Alkaline caustic

Alkaline cleaner Alkaline corrosive

liquids Alkaline corrosive

battery fluid Caustic waste-

water Lime sludge and other corrosive aikalines

Lime wastewater Lime and water Spent caustic

liquids

1-8

Acid sludge Acid and water Battery acid Chemical cleaner! Electrolyte, acid Etching acid liquid or solvent

Pickling liquor anc other corrosive acids

Spent acid Spent mixed acid Spent sulfuric acic

Potential Consequences

Fire, explosion, or heat generation; generation of flammable toxic gases

2-A

Aluminum Beryllium Calcium Lithium Magnesium Potassium Sodium Zinc powder Other reactive

metals and metal hydrides

2-B

Any waste in Group 1 -A or 1-6

3-A

4lcohols Nater

3-8

\ny waste in Groups 1-A or 1-6

:alcium .ithium Aetal Hydrides 'otassium Ither water reactive wastes

Fire, explosion, or violent reaction

4-A

Alcohols Aldehydes Halogenated

hydrocarbons Nitrated

hydrocarbons Unsaturated

hydrocarbons Other reactive organic compounds and solvents

4-8

Concentrated Group 1 -A or 1-6 wastes

Group 2-A wastes

Generation of toxic hydrogen cyanide or hydrogen sulfide gas

5-A

Spent cyanide an( sulfide solutions

5-8

Group 1-6 wastes

Exhibit 224, Potentially Incompatible Wastes

Generation of toxic, explosive, andlor flammable gases

6-A

Chlorates Chlorines Chlorites Chromic acid Hypochlorites Nitrates Nitric acid, fuming Perchlorates Permaganates Peroxides Other strong

oxidizers

6-8

Acetic acid and other organic acids

Concentrated mineral acids

Group 2-A wastes Group 4-A wastes Other flammable

and combustible wastes


Exhibit 231a Hazardous Waste Management Guide _________.I..___. .I____."

Typical Material General Types of ProcesslOperation Materials Used Ingredient Waste Generated

Degreasing; engine, parts, and equipment cleaning

Rust removal

Paint preparation

Painting

Spray booth, spray guns, and brush cleaning

Paint removal

Tank cleanout

Installing lead-acid batteries

Degreasers (gunk), carburetor cleaners, engine cleaners, solvents, acidslalkalies, cleaning fluids

Naval jelly, strong acids, strong alkalies

Paint thinners, enamel reducers, white spirits, paint removers

Enamels, lacquers, epoxies, alkyds, acrylics, primers, solvents

Paint thinners, enamel reducers, solvents, white sDirits

Solvents, paint thinners, enamel reducers, white spirits

Solvents or cleaners to wash out tanks, residues

Used batteries of cars, trucks, and other vehicles

Petroleum distillates, aromatic hydrocarbons, mineral spirits, benzene, toluene, petroleum naphtha

Phosphoric acid, hydrochloric acid, hydrofluoric acid, sodium hydroxide

Alcohols, petroleum distillates, oxygenated solvents, mineral spirits, ketones

Acetone, toluene, benzene, petroleum distillates, epoxy ester resins, methylene chloride, xylene, VM&P naphtha, aromatic hydrocarbons, methyl isobutyl ketones

Ketones, alcohols, toluene, acetone, isopropyl alcohol, petroleum distillates, mineral spirits

Acetone, toluene, petroleum distillates, methanol, methylene chloride, isopropyl alcohol, mineral spirits, alcohols, ketones, other oxygenated solvents

Solvents, petroleum products in tanks

Lead dross

Acid/alkaline wastes Spent solvents Ignitable wastes Toxic wastes

Acid/alkaline wastes

Paint wastes Spent solvents Ignitable wastes Toxic wastes



Paint wastes Spent solvents Toxic wastes

Tank draws containing toxic residues

Acid/alkaline wastes Batteries (lead-acid)

Exhibit 231a, Materials Used and Hazardous Waste That Might Be Generated at Typical Vehicle Maintenance and Equipment Repair Operations


Exhibit 231b II_ _l_._._--.-.l__l__l_____


~~

Designations/ UNINA Waste Type Trade Names DOT Shipping Name Hazard Class ID Numbe

Strong Acld/Alkaiine Wastes

Ammonium Hydroxide

Hydrobromic Acid

Hydrochloric Acid

Hydrofluoric Acid

Nitric Acid

Phosphoric Acid

Potassium Hydroxae

Sodium Hydroxide

Sulfuric Acid Chromic Acid

Ethylene Dichloride'

Benzene' Toluene Ethyl Benzene Chlorobenzene'

Cresols1

Trichloroethylene'

Methyl Ethyl Ketone'

Chloroform' Carbon Tetrachloride'

Hexachloroethane' White Spirits, Varsoi

1 , I ,I-Trichioroethane

Ammon t.m hydrox.de. hrl,OH. Waste Ammonl,.m dyaroriae Corrosive Materia Sp.r Io1 hartsnorn, Aqua (containing not ess tnan 12% Ammonia but not more than 44% ammonia)

(containing less than 12% ORM-A ammonia)

more than 49% strength) Hydrobromic Acid, HBr Waste Hydrobromic Acid (not Corrosive Material

Hydrochloric Acid, HCI, Waste Hydrochloric Acid Corrosive Material Muriatic Acid Hydrofluoric Acid, HF, Waste Hydrofluoric Acid Corrosive Material Fluorohydric Acid Nitric Acid, HNO,. Aquafortis Waste Nitric Acid (over 40%) Oxidizer

(40% or less) Corrosive Material Phosphoric Acid, H PO, Waste Phosphoric Acid Corrosive Material Orthophosphoric AAd Potassium Hydroxide, KOH. Waste Potassium Hydroxide Corrosive Material Potassium Hydrate, Caustic Solution Dry Solid, Flake, Bead Corrosive Material Potash, Potassa or Granular Sodium Hydroxide, NaOH, Caustic Waste Sodium Hydroxide Corrosive Material Soda, Soda Lye, Sodium Hydrate Solution Dry Solid, Flake, Bead

or Granular Corrosive Material Sulfuric Acid, H,SO,, Oil of Vitriol Waste Sulfuric Acid Corrosive Material Chromic Acid Waste Chromic Acid Solution Corrosive Material

Spent Solvents and Ignitable or Toxic Wastes Containing:

Ethylene Dichloride, 1,2- Waste Ethylene Dichloride Flammable Liquid2 Dichloroethane Benzene Waste Benzene (benzol) Flammable Liquid Toluene Waste Toluene (toluol) Flammable Liquid Ethyl Benzene Waste Ethyl Benzene Flammable Liquid Chlorobenzene, Waste Chlorobenzene Flammable Liquid Monochlorobenzene. Phenylchloride 0-Cresol, m-Cresol. p-Cresol, Waste Cresol Corrosive Material (m,p)Gresol, (0,m.p)-Cresol TCE, Gematgene. Lanadin, Waste Trichloroethylene ORM-A Lethurin, Nialk, Perm-a-Chlor Methyl Ethyl Ketone, MEK, Methyl Waste Methyl Ethyl Ketone Acetone. Meetco. Butanone, Ethyl Methyl Ketone Chloroform Waste Chloroform ORM-A Perchloromethane Tetraform, Waste Carbon Tetrachloride ORM-A Carbona Halon 104 Hexachloroethane Waste Hexachloroethane ORM-A White Spirits, Mineral Spirits, Waste Naphtha Flammable Liquid Naphtha Aerothene TT, Chiorten, Waste 1 , I ,I-Trichloroethane ORM-A Chloroethane, Methyl Chloroform, Aloha T. Chlorotene

Flammable Liquid

Petroleum Distillates Petroleum Distillates Waste Petroleum Distillate Flammable Liquid Combustible Liquid3

(continued)

Exhibit 231b, Postal Waste Descriptions

NA2672

NA2672

UN1788

NA1789

UN1790

UN2031 NA1760 UN1805

UN1814 UN1813

UN1824

UN1823 UN1830 UN1755

UN1184

UN1114 UN1294 UN1175 UN1134

UN2076

UN1710

UN1193

UN1888 UN1846

NA9037 UN2553

UN2831

UN1268 UNl288


http://hydrox.de

232 Hazardous Waste Management Guide _.____lll__._l_̂ _ll---

Deslgnationsl UNINA Waste Type Trade Names DOT Shipping Name Hazard Class ID Number

I Palnt Wastes with Heavy Metals I Heavy Metal paints or Heavy Metal Paints I paint sludges with:

Lead' 1 Nickel' Hazardous Waste. Liquid or ORM-E Solid, NOS'

NA9189 I I Chromium' Other Wastes

Lead-Acid Batteries Lead-Acid Batteries I Lead Dross (containing 3% ORM-C or more free acid) NA1794 I I UsedOil NA1270 NA1270 I Various petroleum products Waste Petroleum Oil, NOS Combustible Liquid Waste Petroleum Oil. NOS Flammable Liquid

ignitable Wastes, NOS' Ignitable wastes

Hazardous Waste, NOS

Waste Flammable Liquid, NOS Flammable Liquid UN1993 Waste Combustible Liquid, NOS Combustible Liquid NA1993 Waste Flammable Solid, NOS Flammable Solid UN1325 Hazardous Waste, Liquid or ORM-E Solid, NOS I UN9189

Nore: These descriptions may change given variations in waste characteristics or conditions. The DOT shipping name, hazard class, and UNINA ID number do not necessarily correspond to RCRA hazardous waste categories. i Toxicity Characteristic Constituent. Any waste that results in a TCLP leachate containing a Toxicity Characteristic COnStitUent equal 10 or above regulatory levels is hazardous.

A flammable liquid has a flash point below 1 OO'F.

A combustible liquid has a flash point between 1 OO'F and 200°F. NOS-Not othewise specified.

Exhibit 231b, Postal Waste Descriptions (continued)

232 Chemical Identification A Material Safety Data Sheet (MSDS) is the best reference for information regarding a chemical located at your site. An example of an MSDS is provided in Appendix C. An MSDS contains the following information: a. Material Identification. This section identifies the manufacturer's

name, the manufacturer's address, an emergency telephone number for more information on the chemical, the chemical name and other names by which the chemical is known, the chemical formula, the trade name and other names by which the chemical is known, the chemical family, the Chemical Abstracts Service

~

~~

Registry Number, and the Department of Transportation (DOT) identification number.

b. Ingredients and Hazards. This section identifies the type and amount of each hazardous chemical in the chemical mixture; the threshold limit value, which is the maximum amount of gas, vapor, mist, or fumes in air, that is safe; and the permissible exposure limit, which is similar to the threshold limit value but is set by the Occupational Safety and Health Administration (OSHA) and is enforceable by law.


Exhibit 231d .- lll_


Exhibit 231d, Hazardous Waste Log Handbook AS-553, May 1992 27


c . Physical Data. This section identifies boiling point, vapor pressure, vapor density, solubility in water, specific gravity, percent volatility by volume, evaporation rate, and appearance and odor.

d. Fire and Explosion Data. This section identifies flash point, flammable limits, explosion limits, the best way to fight a fire that involves this chemical, and unusual fire and explosion hazards involving this chemical.

e . Reactivity Data. This section identifies a chemical’s stability, conditions to avoid regarding chemical stability, materials that are not compatible with this chemical, chemicals that are generated when the chemical purity decomposes due to age, hazardous reactions that can occur with other common chemicals, and chemicals that should not be mixed.

.f. Health Hazard Data. This section includes OSHA permissible exposure limit data, National Institute of Occupational Safety and Health (NIOSH) threshold limit value data, effects of over- exposure, and emergency first aid procedures.

g. Spill or Leak Procedures. This section identifies steps to be taken in case a material is released or spilled, including waste disposal methods.

h. Special Protection Information. This section identifies the types of respiratory protection recommended for handling this chemical, recommended eye protection, recommended skin protection, recommended additional protective equipment, and ven- tilation requirements.

i. Special Precautions. This section identifies precautions to be taken when handling and storing this chemical, as well as any other important information or precautions’not listed in other sections.

233 Unknown Substances When a material of unknown origin is discovered on a postal site, assume the material is hazardous until it can be determined otherwise. Use extreme caution. Try to identify the materials involved. Look for any labels identifying the contents of the container. The contents may be identified by name or by a “Listed Waste” number. Chapter 5 contains more detailed guidance on handling unknown substances. ~~

234 Hazardous Waste in the Mail ~~ ~

Some items transported in the mails may contain hazardous materials and may be subject to spills and leaks within mail processing areas. The Postal Service has hazardous waste policies for control- ling such releases and limiting the transportation of dangerous materials. (See Management Instruction MI-EL810-9-6, Haz- ardous Materials Spill or Leak Standard Operating Procedures. For further information, refer to Handbook EL-812, Employee AwarenesMazardous Materials and the Domestic Mail Manual.) General mail facilities use very limited amounts of hazardous substances in their operations and usually are not generators of hazardous wastes.


243.1 -- -__I__ - Hazardous Waste Management Guide

240 Hazardous Waste Generator Categories 241 General The Environmental Protection Agency and the appropriate state environmental management departments classify generators of hazardous waste into three categories according to the rate at which the facility generates hazardous wastes and how much it accumn- lates on-site. Each category has differentreporting and recordkeeping requirements, and every Postal Service facility must meet the requirements determined by its classification. This means that hazardous waste generated by laboratories, printing shops, vehicle maintenance and equipment repair facilities, training facilities, photoprocessing operations, and groundskeeping units must he measured to determine generator status. For the measurements to he meaningful, managers must know which wastes are classified as hazardous in their states. For example, if waste oil is considered hazardous, it must be measured along with other hazardous waste. Exhibit 241 summarizes the applicable requirements for each of the three generator categories.

242 Conditionally Exempt Generators Conditionally exempt generators, called very small quantity generators in some states, are facilities that generate no more than 100 kilograms (220 pounds) per month of hazardous waste, generate no more than 1 kilogram (2.2 pounds) per month of acutely hazardous wastes, and accumulate no more than 1,000 kilograms (2,200 pounds) of hazardous waste on their property. (There is no time limit for this accumulation as long as the 1,000 kilograms is not exceeded.) As a rule of thumb, a 55-gallon drum of hazardous waste is about 200 kilograms (440 pounds). This means that a postal facility is classified as conditionally exempt if it generates less than one-half of a 55-gallon drum per month or accumulates no more than five 55-gallon drums at any one time. As long as the Postal Service facility remains conditionally exempt, hazardous waste must he disposed of at a hazardous waste facility, or other facility approved by the state for industrial or municipal wastes, on the condition that the operating authority of the landfill accepts the waste. If hazardous waste management practices result in a postal facility losing its conditionally exempt status, all requirements for small generators must be met.

243 Small Quantity Generators 243.1 General Small quantity generators are facilities that generate between 100 kilograms and 1,000 kilograms (220 to 2200 pounds) per month of hazardous waste, generate no more than I kilogram (2.2 pounds) per month of acutely hazardous waste, and accumulate on-site no more than 6,000 kilograms (13,200 pounds) of hazardous waste. Most Postal Service facilities that use hazardous materials are categorized as small quantity generators. Postal facilities in this category should undertake efforts to minimize the amount of hazardous waste generated so that they can become conditionally exempt. However, as long as they remain small quantity generators, they must meet the following requirements.

Potential USPS Gerierators + Laboratories

Printing shop Vehicle maintenance facilities

Training facilities

Groundskeeping units

* Equipment repair facilities + Photoprocessing operations


Exhlbit 241 Hazardous Waste Management Guide

~~~ ~

Generator Classiilcation

Requlrement

~~

Conditionally Small Exempt Quantity

Large Quantity

21,000 kg/month >1 kg

Unlimited

Amount of acute waste (40 CFR 261 & 262)

Accumulation (40 CFR 261 & 262)

Storage time (40 CFR 261 & 262)

EPA ID No. (40 CFR 262)

Manifest (40 CFR 262)

Recordkeeping - manifest (262.40) - exception reports (262.42)

(manifest not returned)

0-100 kg/month 4 kg

100-1,000 kglmonth c1 kg

6,000 kg 1,000 kg

Unlimited 180 days unless >ZOO mile transport then 270 days \

Required

90 days

NIA

NIA

Required

Required Required

NIA NIA

3 years 60 days and send copy to EPA

3 years 35 days to contact TSD transDort and 45 days to E PA

-waste testing results - biennial report to

Personnel training

Emergency preparedness equipment & coordination (40 CFR 265, Subpart C)

Contingency plan and emergency procedures (40 CFR 265, Subpart D)

Container management (40 CFR 265, Subpart I)

Tank management (40 CFR 265, Subpart J) Land disposal notice and

EPA (262.41)

NIA NIA

NIA

NIA

3 years NIA

~~ ~ ~

3 years Required

Some (262.34)

Required

Required

Required

NIA SQG requirements and plans

Required

NIA

NIA

NIA

Required Required

SQG requirements

Required

Required

Required waste management plan (40 CFR 268.7)

Hazardous waste label

Accumulation date label

Should do

Should do

Required

Required

Required

Required

Exhibit 241, Hazardous Waste Generator Requirements


244 - Hazardous Waste Management Guide

243.2 Accumulation Time Limit Postal Service managers at facilities classified as small quantity generators must ship hazardous waste to EPA- or state-approved and -authorized Treatment, Storage, or Disposal Facilities (TSDF) so that such waste is not stored on Postal Service property for more than 180 days-except if the waste must be transported greater than 200 miles, in which case the waste may be stored up to 270 days. MaQagers of facilities that reach the 6,000-kilogram (1 3,200- pound) accumulation limit for total hazardous waste on site must immediately ship the waste to a TSDF. Containers and drums must be labeled and dated on thefirst day that any hazardous waste is placed in them. Wastes must not be transferred from one container to another to extend the allowable accumulation time. Postal Ser- vice managers should seek assistance from state environmental management authorities in locating an authorized transporter and facility for hazardous waste treatment or disposal.

243.3 On-site Treatment The small quantity generator may treat hazardous waste without a special permit if the treatment takes place within the 180-day or 270-day time limit for storage, if all container and tank storage requirements described in chapter 5 are followed, and if all necessary precautions are taken to prevent spills or accidents. The facility manager should discuss and clear on-site treatment of hazardous wastes with the state environmental management agency before start of operations to ensure that applicable regulations have been followed.

244 Large Quantity Generators Large generators are facilities that generate 1,000 kilograms or more (2,200 pounds) per month of hazardous wastes (or 1 kilogram per month of acutely hazardous waste). These facilities are not eligible for exemptions, and postal managers must abide by all requirements of the law. At the same time, these managers should make efforts to reduce the amount of hazardous waste generated so the facility becomes a small quantity generator.


Exhibit 231c (p. 1) Hazardous Waste Management Guide I__ l__.ll-.ll-.

Solid waste that has been exempted as RCRA waste?

Hazardous wastes that meet one of the four RCRA characteristics for hazardous waste (EP toxic, reactivity, ignitability, or corrosivity)?

Hazardous waste that is exempt because it is being reclaimed or recycled?

Do you know the types of RCRA hazardous wastes that have to be counted in your monthly accumulation total?

Have you counted:

~~

All wastes that have been stored on-site before treatment?

Wastes that are packaged for off-site transport?

Wastes going into a RCRA-regulated disposal or treatment facility?

Sludges or still bottoms removed from storage tanks?

Do you know which wastes you do not count'as RCRA hazardous wastes?

~

I Hazardous Waste Identification Checklist c

~

Residue left in storage tanks that are "empty"?

Recycled materials?

Waste that was already counted in the month and was recycled or treated on-site?

Use this checklist to help identify RCRA hazardous waste at your facility and compliance with RCRA requirements. I -

Question No

identifying RCRA Solid and Hazardous Wastes

Does your facility:

Generate RCRA solid wastes?

Generate RCRA hazardous or acutely hazardous wastes?

Qualify as a large quantity generator (over 2,200 pounds of RCRA waste generated per calendar month)?

Generate 2.2 pounds or more of acutely hazardous waste (RCRA "P" list wastes) per I calendar month? I Does your facility have:

Solid waste that has been excluded as RCRA waste?

Did you count:

Used oil that is recycled and has not mixed with other hazardous waste?

Lead-acid batteries sent off-site for recycling?

Residue in the bottom of product co

32

Exhibit 231c (p. l), RCRA Checklist


Exhibit 231c (p. 2) -..-l_....-..l...l.--..._ll II Hazardous Waste Management Guide

Question I Yes RCRA (3002) HSWA Hazardous Waste Minimization Requirements By signing the uniform nazardoJs waste manifest. nave yod implied a good faith effort" I to mlnimlze hazardous waste Droduction? As a generator, do you have a waste minimization program in place?'

Does the program identify waste minimization efforts and goals?

Are recvclable wastes beina recvcled either on-site or off-site?

Are spills and leaks avoided in raw material storage areas, facility operations, and waste storage areas?

Are your emolovees trained in waste minimization techniaues?

Is your business operated and maintained to reduce the amount of hazardous wastes discharged to the air, water, or land?

I RCRA Records I Does your facility submit a biennial waste report to EPA?

Does your facility have:

A desianated RCRA records coordinator?

Name: Finance #: Phvsical address:

I Files for hazardous waste records? I Monthly records of the hazardous waste produced?

Test to see whether wastes meet RCRA hazardous waste definitions?

An EPA waste generator identification number to use on the manifests of waste shipped off-site?

Do you maintain copies of fully completed uniform waste manifests for wastes shipped off-site?

I Do you have process flow charts or your various waste streams? I

RCRA Storage and Handling Are your wastes tracked from satellite storage areas to regular storage areas?

Are your wastes tracked from storage areas to on-site or off-site treatment or disposal?

Are safe orocedures followed in the movement of these wastes?

I Are emerclencv equiDment or SuDDlies handy to contain a serious accident? I Are your hazardous wastes segregated to promote reclaiming, recycling, and reuse?

If you accumulate hazardous waste on-site in a container, is the container:

A cOmDatible container for the waste?

I Clearly marked with the words "Hazardous Waste"? 1

Exhibit 231c (p. Z), RCRA Checklist Handbook AS-553, May 1992 33

Exhibit 231c (p. 3) Hazardous Waste Management Guide ____ l__..l_l_l_..l..-._. I._̂ I

Question

Dated with the day waste was first put in that container?

Kept in good condition, handled carefully, and replaced if leaking occurs?

Used to store hazardous waste if the waste may cause the container to rupture, leak, corrode, or otherwise fail?

Kept closed except when being filled or emptied?

InsDected for leaks or corrosion everv week?

Yes No

Placed as far as possible from the facility's property line to create a buffer zone if storing ignitable or reactive waste?

Used to store incompatible wastes that could react together to cause fires, leaks, or other releases?

Stored away from containers filled with an incompatible waste?

If the hazardous waste is stored in a tank, is the tank: Used to store hazardous waste if the waste may cause the tank to rupture, leak, corrode, or otherwise fail?

Inspected for leaks or corrosion every week?

Used to store incompatible wastes that could react together to cause fires, leaks, or other releases?

Kept covered: or, in uncovered tanks, left with at least two feet of freeboard (space at the top of the tank)?

Provided with waste feed cutoff or bypass systems to stop the flow in case of problems if the tank has equipment that allows the waste to flow into them continuously?

Monitoring or gauging systems inspected daily?

In compliance with the National Fire Protection Association's buffer zone requirements for tanks containing ignitable or reactive wastes?

Does your hazardous waste storage area have:

A solid base that will hold leaks, spills, and any rainfall until they can be discovered and removed?

~

t A drainage system to manage excess water?

A holding area large enough to contain a spill amounting to the volume of the largest container or 10 percent of the total volume of all containers, whichever is greater?

Is Your storaoe area reaularlv insDected?

~~

~~

Are your incompatible hazardous wastes segregated?

Are your ignitable and reactive hazardous wastes kept away from sources of ignitability and reactivity (e.g., smoking areas, open flames, welding, hot surfaces)?

Do you know what the RCRA time limits are for storing wastes on-site?

Do you ever store more than 2,200 pounds of hazardous waste on-site at any one time? I 34

Exhibit 231c (p. 3), RCRA Checklist


Exhibit 231c (p. 4) -__I 1111111-


Question

Emergency Contingency Plan and Employee Training Checklist Does your facility have an emergency plan in case of fire, explosion, spill, or leak?

Does your facility have a designated emergency coordinator and an alternate?

Yes

I Do vour emerclencv DreDarations include: I

Automatic sprinklers?

Spray equipment?

Telephone emergency numbers, fire extinguishers, and spill control materials located near all work areas?

1 A method for head counts on employees and the training of personnel in emergency orocedures and evacuation? I A National Resoonse Center INRC) notification Drocess? I

Procedures for employees who stay behind for the shutdown of facility operations and their evacuation?

Rescue and first aid duties?

If you have a spill or release, do you know that you may need to report it under the following federal laws:

Resource Conservation and Recoverv Act?

Hazardous Materials Transportation Act?

Clean Water Act (CWA)?

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)?

I SuDerfUnd Amendments Reauthorization Act (SARA). Title Ill? I Do you know what the reportable quantities are for hazardous materials and waste spills under the above regulations?

Should you report a fire, explosion, leak, or spill to:

NRC?

Local fire department?

Local emergency planning committee?

State emergency response commission?

Exhibit 231c (p. 4), RCRA Checklist Handbook AS-553, May 1992 35

Exhibit 231c (p. 5) Hazardous Waste Management Guide ___-

Question

Do you train your personnel before assignment to a hazardous waste area?

Is this training reviewed annually?

Is this training documented? Have local emergency personnel been notified of the types of hazardous wastes stored on-site?

Have local emergency personnel been notified of the location and quantities of hazardous waste on-site?

Have local emergency response organizations been a part of your emergency preparedness planning?

Have the following local emergency response organizations been contacted concerning your emergency preparedness plan:

Police department?

Fire department?

Emergency medical services and hospitals?

State emeroencv reswnse team?

I

Yes No

Does EPA define used oil as a hazardous waste?

Is used oil a hazardous waste if it is mixed with other wastes? Is used oil a hazardous waste if it exhibits the characteristics of a hazardous waste?

Does the state where Your business is located define used oil as a hazardous waste? ~

Did any of these emergency organizations decline to participate in your emergency preparedness plan?

Did vou document the refusal? I ~

1 Are your hazardous wastes handled so as not to damage public health or the environment? 1 I I

On-specification?

Off-specification?

I Used Oil Checklist

~ ~ ~

~ ~

1 Are you generating used oil that is: I I I

36



Hazardous Waste Management Guide Exhibit 231c (p. 6)

On-specification?

Off-specification?

Hazardous waste fuel? ~

Question

Have you developed safe housekeeping procedures to lessen spills and prevent accidents involving used oil?

Have you identified the used oil collection tanks on-site with a sign that includes warnings to orevent the introduction of anv additional hazardous contaminants?

Within your own garage, do you contaminate your used oil with chlorinated solvent cleaners, such as carburetor cleaners, brake cleaners, hand cleaners, parts cleaners, I floor cleaners. or metal cleaners? Has mixing other waste you have generated with used oil resulted in the used oil being classified as a hazardous substance?

Is water allowed to mix with used oil or get into collection tanks?

Do vou have a waste seareaation Dolicv? Do you store antifreeze, which is a hazardous waste, separately?

Do you accept used motor oil from the do-it-yourself oil changers to prevent environmental oollution?

__

If yes, do you inform do-it-yourself oil changers not to contaminate their used oil with paint, paint thinner, household chemicals, pesticides, gasoline, or other potential contaminants?

Do YOU acceDt used oil from other outside businesses?

- Are you recycling any used oil that is:

Are you recycling or reusing used oil: On-site?

I Off-site? If on-site, describe the method for recyclingheuse of the used oil.

If off-site, does an oil recycler collect your used oil?

Do you demand written statements or receipts from your used oil collector?

Do you keep files and records for every transaction to prove that oil generated on-site and collected from do-it-vourself oil chanaers in vour facility was shipped to a bona fide - . . I recycler? How does the recycler manage the used oil collected from you?

Does this used oil management practice satisfy all health and environmental regulations?

Must the first person claiming used oil to be classified as on-specification for burning DurDoses analvze the used oil to determine its wecification?

as fuel, must you analyze it to prove that it is on-specification?

Do you burn off-specification oil on-site?



Exhibit 231c (p. 7) Hazardous Waste Management Guide _._I__

Question

If yes, do you burn it in an oil-fired space heater?

Does this oil-fired space heater generate less than 500,000 Btu per hour?

Is this oil-fired space heater vented to ambient air?

Do you burn off-specification oil on-site in industrial furnaces and boilers?

If yes, did you notify the state with EPA Form 8700-12 or a written letter containing the notification form information?

Do you sell off-specification oil directly to a burner?

Does the burner to whom you sell used oil comply with the following recycler standards:

Notify EPA with EPA Form 8700-1 2 or a written letter containing the notification form information?

Invoice shipments?

Provide one-time certification from burner to generator that states the burner has notified EPA and will burn only in industrial devices or furnaces?

Keep this certification for three years?

Do you generate used oil that has 4,000 parts per million (ppm) or more total halogens?

If yes, have you:

Obtained an EPA identification number?

Completed a state hazardous waste manifest if transporting this type of oil off-site?

Met transport requirements (that is, packaging, labeling and marking, and placarding) per US. Department of Transportation requirements?

Met maximum accumulation and time requirements per EPA regulations?

Kept records and reported shipments?

If a discharge of hazardous waste fuel oil occurs during transporting, do you notify EPA and take appropriate action to protect human health and the environment?

Underground Storage Tanks Checklist Do you have a RCRA underground storage tank that holds RCRA-regulated materials and has 10 percent of its volume and pipes below ground level?

Do you have a tank that was taken out of service or is still in use after January 1, 1974?

Do you have underground tanks storing used oil (for example, automobile and truck used crankcase oil) or other petroleum products?

Do you have petroleum product underground storage tank systems?

If yes, have you notified designated state agencies of the presence of such tanks?

Do you have a newly installed underground storage tank system?

Do you know the technical requirements for underground storage tank systems?

1 Yes

Do you follow special requirements for pressurized delivery lines?

Have all new tanks been reported to local or state officials?

Exhibit 231c (p. 7), RCRA Checklist 38 Handbook AS-553, May 1992

Exhibit 231c (p. 8) -__ Hazardous Waste Management Guide

Question

Are your new underground storage tank systems aesigned and constructed to retain tneir structural integrity for their operating I fe, in accordance with natlonal consensus codes of pract ce and MI-AS-51 0-92-6?

Are all tanks and attached piping use0 to deliver the stored product protected from external corrosion?

Is cathodic protection mondorea and maintamed to ensdre that tne undergrodnd storage tank systems remain free of corrosion?

Were nationally recognized industry standards followed in pacing new Lnderground storage tank systems in service?

Did y o ~ certify that proper installation procedures were followed?

Did yo^ identify how the installation was accomplished?

Does your underground storage tan& have a method of leak detection in place?

Was your unoerground storage tank system instal.ed:

. . .

~ . .

-

.-

.

.-

. - .

~

-. Before 1965 or date unknown? I - 1965-1969? I 1970-1 974?

1975-1 979?

1980-1 988?

After December 22,1988?

Do your new or upgraded underground storage tank systems storing hazardous substances have secondary containment with interstitial monitoring?

I If no. is an alternate release detection method beino used? If yes, was it approved by the implementing agency?

Is there a method of corrective action available to clean up a release of the hazardous substances in your underground storage tank systems should one occur?

Do you follow proper tank filling practices to prevent releases caused by spills and overfills?

Do your new or upgraded underground storage tank systems use devices that prevent overfills and control or contain spills?

If your tanks were damaged in any way, were they repaired in accordance with nationally recognized industry codes?

Were any tests conducted to ensure quality repairs?

Have you taken an underground storage tank out of service?

Have you permanently closed any underground storage tank systems?

If yes, was the underground storage tank system removed from the ground?

If the underground storage tank was left in place, did you:

Remove all regulated substances and accumulated sludges?

Clean the tank?

Exhibit 231c (p. S), RCRA Checklist


Exhlblt 231c (p. 9) Hazardous Waste Management Guide

Question

Fill it with an inert substance?

Close it to all future outside access?

At the time of underground storage tank closure, did you ensure that a release had not occurred at the site?

- . I I . .. . .. t If a release has occurred, were corrective actions taken? .. Do you have a substandard existing u

Use this space to address additional concerns.

4Q @ Exhibit 231c (p. 9), RCRA Checklist


320 __ _I__ Hazardous Waste Management Guide

Chapter 3 Recordkeeping and Reporting

310 Introduction Accurate recordkeeping is essential to a successful hazardous waste management program. Complete and up-to-date records are necessary to comply with environmental regulations and to prepare reports that are required by state and federal authorities, as well as by internal postal regulations. This chapter describes standard reporting requirements and the types of records that managers must keep to meet those requirements. Postal management, including managers at conditionally exempt facilities, and contractors must be familiar with these requirements. Exhibit 310a summarizes the recordkeeping and reporting requirem

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