SOP 4.11: Waste Storage
Contents
1. Introduction 1
2. Regulatory and contractual requirements 1
3. Staff qualifications 1
4. Health and safety precautions 2
5. Equipment and supplies 3
6 Procedures for waste storage. 3
Attachment A: Notification form of HHW programs or program activities. 5
1. Introduction
RCRA requirements apply when hazardous waste (HW) lab packs or containers are filled, closed out, and placed into storage. For this SOP, lab packs, fiber drums, and metal drums will be referred to as “containers.”
2. Regulatory and contractual requirements
The storage of HW is governed by the requirements established in the Facility and state agency contract (Exhibit A); the state-contracted HW disposal company Hazardous Categorization Training Manual, OSHA 29 CFR 1910.178 and 1910.106 (d) and (e); Minn. Rules pt. 7045.0626, pt. 7045.0566, and pt. 7045.0310, subd. 3, 7045.0205 through 7045.0320, 7510; Minn. Stat. § 299F.011; Minnesota Uniform Fire Code; and local building codes.
3. Staff qualifications
3.1 Training
3.1.1 The designated staff responsible for ensuring Facility HW storage compliance is the Facility Manager. This Facility shall have a written training program that describes waste processing relevant to job duties and shall include function-specific training, safety, regulatory, and emergency procedures.
3.1.2 Staff shall be trained within six months of hire or starting a new position at the facility, or be supervised by trained staff until that time. Refresher training shall be conducted annually and properly documented.
3.1.3 Staff shall review equipment manufacturer manuals prior to Facility operations to become familiar with design, function, and maintenance. Staff shall comply with safety requirements pertaining to equipment use and maintenance. Only trained staff shall be permitted to operate this equipment; see SOP 2.8 Powered Industrial Trucks with checklist and SOP 5.1 Equipment Maintenance.
4. Health and safety precautions
4.1 Safety requirements
4.1.1 Staff shall follow safety requirements as outlined in this Facilities Emergency Contingency Plan and Health and Safety Plan. Staff shall also take precautions to prevent any impacts to the environment: see SOP 1.1 OSHA.
4.1.2 No smoking, eating, or drinking is allowed in waste processing areas of this Facility.
4.1.3 Routinely look for immediate dangers to nearby staff and property. Keep alert for suspicious activities or behaviors in accordance with the program’s DOT Security Plan; see SOP 4.15 DOT Security Issues.
4.1.4 Proper ergonomic techniques shall be used while processing waste; see SOP 2.11 Ergonomics.
4.2 Personal protective equipment (PPE) requirements
This Program may choose to implement a PPE policy by using engineered solutions appropriate to current environmental conditions and utilizing experienced staff judgment for unique conditions and situations. PPE shall be utilized if the potential for exposure remains after the institution of work practice controls; see SOP 2.4 Personal Protective Equipment. At a minimum, the following PPE shall be used when processing HW:
· Safety glasses with side shields, goggles, or equivalent eye protection
· Footwear with reinforced toe, toe caps or equivalent foot protection
· Nitrile gloves or equivalent hand protection
· Chemical splash apron, Tyvek coveralls, or equivalent body protection
4.3 Medical monitoring requirements
Engineering and work practice controls shall be utilized to minimize or eliminate exposures. Staff exposed to hazardous substances for 30 or more days per year shall receive medical monitoring examination annually per OSHA regulations. It is this Facility’s responsibility to set up procedures to continually verify that the medical monitoring program is meeting OSHA requirements and regulations; see SOP 2.13 Medical Monitoring Program.
4.4 Emergency response
Only designated and trained emergency responders shall attend to incidents requiring assistance beyond the capabilities of Facility staff. This Facility shall make prior agreements with response teams to be used in emergencies; see SOP 2.10 HW Contingency Plan.
5. Equipment and supplies
Facility processing and storage areas shall have staff access to:
· Equipment to assist in moving waste containers (e.g., moving cart, drum dolly, forklift).
· A spill kit; see SOP 2.6 Spill Response.
· A marked and serviced fire extinguisher. Local fire codes may require additional fire suppression equipment. Fire exits and extinguisher Facility areas shall be kept clear at all times.
6. Procedures for waste storage
6.1 Storage building specifications—Local zoning and building fire codes may specify Facility construction materials (e.g., electrical fixtures, explosion-proof fixtures and wiring, HVAC systems, fire suppression equipment, grounding and bonding of flammable containers). Facility staff shall ensure:
6.1.1 No material is stored in any manner that would impede access or exit from the Facility.
6.1.2 State approval to operate is obtained from the State 30 days prior to operation; see Attachment A of this SOP.
6.1.3 HW stored on site does not exceed the permitted maximum amounts (as stated in the State approval letter specific to this Facility).
6.1.4 Facility storage areas have flooring impermeable to the type of waste stored.
6.1.5 Facility storage areas do not have a floor drain that leads to a sewer or the environment.
6.1.6 Buildings storing ignitable wastes are located at least 50 feet from the property line (this provision may be waived with the receipt of approval from the local fire marshal and local building officials).
6.1.7 Secured Facility access.
6.1.8 Overhead roofing protects HW containers from direct sunlight.
6.1.9 Facility areas are marked with specific waste types of the containers stored.
6.1.10 Storage areas include secondary containment (e.g., dike, berm, wall, curb, other device) large enough to contain 110% of the largest container (generally applicable to a 55-gallon drum).
6.1.10 Storage areas include a dike, berm, wall, curb, or other device to segregate potential spills from incompatible HW (or wastes shall be stored and separated by a distance of at least 10 feet).
6.2 Waste container specifications
6.2.1 To prevent reactions from incompatible chemicals, segregate HW containers while in the Facility storage area:
Flammables or pesticides / All flammable and combustible liquids and solids, and any nonhazardous material that is chemically compatible with flammables. Department of Agriculture chemicals, poisons, and pesticides (that are not oxidizers), and any nonhazardous materials chemically compatible with pesticides may be stored in same area.Bases / All corrosive liquids and solids that are alkaline, as well as any nonhazardous materials that are chemically compatible with bases.
Acids / All corrosive liquids and solids that are acidic, as well as any nonhazardous materials that are chemically compatible with acids.
Oxidizers / All oxidizers, including organic peroxides.
Cyanides / Store all cyanides away from acid wastes.
Dangerous when wet / Store Dangerous When Wet wastes away from latex paint or any water source.
* See HW Disposal State Contractor Manual for additional waste types.
6.2.2 Containers placed into Facility storage areas shall have:
· A unique number shall be assigned to each container and entered into the Facility log book.
· One lab pack inventory sheet attached.
· Be placed in rows with at least 24” of aisle space to facilitate inspection. Aisle space shall be maintained in order to ensure the unobstructed movement of personnel and emergency equipment.
· Proper grounding for bulked flammable wastes; for information on proper grounding, see SOP 4.5 Waste Bulking, Attachment A.
· Integrity protection, e.g. latex paint protected from freezing, 55-gallon drums not stacked more than two high.
· Secure closings.
· Markings or labels attached, which are visible for inspection; see SOP 4.4 Waste Packaging.
Attachment A: Notification of New HHW Programs or Program Activities
(Type or print)
1. Staffing
A. HHW operations contact person:
Phone:
Address:
Job responsibilities:
B. Education program contact person:
Phone:
Address:
Job responsibilities:
C. Other county program staff:
Phone:
Address:
Job responsibilities:
2. Facility location
D. Facility location address:
E. Facility EPA ID Number:
3. Service area
A. Participating counties or regional area:
B. Cities (list those not included in Part 3A):
C. State:
4. Facility operating hours
A. Facility type: £ permanent local/satellite £ permanent regional £ single event
£ recurring event £ mobile
B. Date(s) of operation:
C. Hours of operation:
5. On-site waste management
A. Briefly describe facility structure (if not a mobile unit), include size, construction materials, components (rest rooms, phone, water, etc.):
B. List other program wastes accepted in addition to HHW (VSQG, Universal Waste, non-household pesticides, abandoned, or other)
C. Briefly describe storage methods and timeframes:
D. Briefly describe waste treatment/handling methods:
E. Briefly describe waste transportation methods (if not transported by Contractor):
6. Contractor waste management
A. Transporter name:
Address:
B. Disposal contractor name
Address:
7. Personnel safety training
Indicate whether hazardous waste handling staff have received personnel training in accordance with Part A of Exhibit A and the Program’s Personnel Training Program. If staff are not trained in accordance with the Exhibit and Training Program, briefly describe hazardous materials and safety related training completed:
Staff name or affiliation:
(County or company):
Training completed
in accordance with
Training Program
______£ Yes £ No ______£ Yes £ No ______£ Yes £ No ______£ Yes £ No
8. Safety and emergency procedures
A. Does County have a safety plan in accordance with Part B of Exhibit A for this facility? £ Yes £ No
B. Is the Facility-specific safety plan on-site and readily available? £ Yes £ No
C. List local emergency personnel notified of the operation:
1. Hospital
2. Fire department
3. Police
4. Other
D. Have provisions been made to ensure personnel safety in accordance
with Parts A and B of Exhibit A? £ Yes £ No
If no, briefly describe safety provisions (eye wash, PPE, etc.):
4.11 Waste Storage 5