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Presbyterian College

HAZARDOUS WASTE MANAGEMENT PLAN

Document ID No. E-2

Issued: 1/30/2009

Please direct any questions or comments about the applicability of this document to Alan Urwick, Environment Health & Safety Coordinator.

Developed for Presbyterian College (all campuses) by:

Turning Bird Consulting, Ltd.1205 Two Island Court, Suite 204Mount Pleasant, SC 29466ph.: 843-216-6833

Hazardous Waste Management Plan [Document ID No. E-2] Page i1/30/2009

TABLE OF CONTENTSAbbreviations and Acronyms......................................................................................... iii

1.0 Purpose...............................................................................................................12.1 Main Campus......................................................................................................12.2 The Branch Campuses........................................................................................1

3.0 Authority..............................................................................................................2

4.0 General Procedures............................................................................................24.1 Main Campus......................................................................................................24.2 The Branch Campuses........................................................................................2

5.0 Laboratory, Classroom or Chemical Use Area Requirements.............................25.1 Waste Determinations.........................................................................................25.2 Unknown, Discarded and Unneeded Chemicals.................................................45.3 Containers, Compatibility and Storage................................................................55.4 Marking and/or Labeling Requirements...............................................................55.5 Satellite Accumulation Areas...............................................................................65.6 Accumulation Limits............................................................................................65.7 Legal Disposal to the Sewer System...................................................................75.8 Illegal Treatment or Disposal...............................................................................85.9 Training for Faculty and Staff..............................................................................85.10 Laboratory renovations, modifications and academic restructuring.....................8

6.0 Central Storage Area (CSA) and Campus-wide Requirements...........................86.1 Central Storage Facility/Area Requirements.......................................................86.2 Disposal and Manifesting....................................................................................9

7.0 Hazardous Materials Registration Fees............................................................11

8.0 Emergency Response Equipment and Procedures...........................................12

9.0 Recordkeeping, Reporting, and Required Programs.........................................139.1 Recordkeeping..................................................................................................139.2 Reporting...........................................................................................................149.3 Required Plans and Programs..........................................................................15

Turning Bird Consulting, Ltd. document.docx

Hazardous Waste Management Plan [Document ID No. E-2] Page ii1/30/2009

AppendixesAppendix A: Hazardous Waste Management for a CESQG Facility

Appendix B: Hazardous Waste Determination Form

Appendix C: RCRA P- and U-Listed Wastes

Appendix D: Peroxide Forming Compounds

Appendix E: Hazardous Waste Container Labels

Appendix F: Location of Satellite Accumulation Areas and Emergency Equipment

Appendix G: Hazardous Waste Container Storage Area Inspection Checklist

Appendix H: Hazardous Materials Registration Form

Appendix I: Standard Operating Procedures for Mercury Spills

Appendix J: Biennial Hazardous Waste Report


Hazardous Waste Management Plan [Document ID No. E-2] Page iii1/30/2009

Abbreviations and Acronyms

BMP – Best Management PracticesCESQG – Conditionally Exempt Small Quantity Generator of hazardous haste

is the least regulated generator class.CFR – Code of Federal Regulations. Title 40 of the Code of Federal

Regulations (40 CFR) contains all of the environmental protection regulations.

CHO – Chemical Hygiene OfficerCSA – Central Storage AreaDOT – Department of TransportationEC – Emergency CoordinatorEPA – Environmental Protection AgencyEPA ID No. – EPA Identification NumberERC – Emergency Response CoordinatorHAZWOPER – Hazardous Waste Operations and Emergency ResponseHCW – Hazardous Chemical WasteHW – Hazardous WasteID – Identification, as in EPA ID NumberKg – Kilogram; one-kilogram equals 2.2 poundsLbs – PoundsLDR – Land Disposal RestrictionLQG – Large Quantity Generator of Hazardous Waste is a fully regulated

generator of hazardous waste.SC DHEC – South Carolina Department of Environmental ProtectionpH – Negative logarithm of the Hydrogen Ion concentration; A scale from

0 to 14 where 7 is neutral and lower numbers are successively more acidic (sweet), and higher numbers are more basic (sour).

ppb – Parts per billion, one-tenth of one percent is equivalent to one million parts per billion (0.1% equals 1,000,000 ppb).

RCRA – Resource Conservation and Recovery ActSAA – Satellite Accumulation AreaSQG – Small Quantity Generator of hazardous waste is regulated to a

much greater degree than the CESQG, but not regulated to the degree that a LQG.


Hazardous Waste Management Plan [Document ID No. E-2] Page iv1/30/2009

TSDF – Treatment, Storage, or Disposal FacilityUS EPA – United States Environmental Protection Agency


Hazardous Waste Management Plan [Document Id. No. E-2] Page 1 of 161/3/2009

HAZARDOUS WASTE MANAGEMENT PLAN

1.0 PurposePresbyterian College is committed to operating its laboratories and classrooms in the safest manner possible, with concern for the individual and the protection of the environment in accordance with all applicable Federal and State statutes. The Hazardous Waste Management Plan, as outlined in the following sections, has been prepared to comply with applicable regulations promulgated by the United States Environmental Protection Agency (EPA) and the South Carolina Department of Health and Environmental Control (SC DHEC); and local ordinances enacted by Clinton, Laurens County, South Carolina.

2.0 Scopes and ApplicationThis program establishes the requirements that Presbyterian College faculty and staff must meet in order to manage the appropriate disposal of hazardous waste and excess chemicals in laboratories, classrooms, shops and chemical use areas located on the Presbyterian College campuses. This program describes the labeling and notification requirements, manifesting requirements, the general management of Satellite Accumulation Areas (SAAs) and Hazardous Waste (HW) storage areas; guidelines for disposal to the sanitary sewer, air and solid waste; applicable emergency procedures, prevention and response requirements; training and record keeping requirements.

2.1 Main CampusThe Presbyterian College main campus is considered a Large Quantity Generator (LQG) under the South Carolina Hazardous Waste Management Requirements1 for LQGs. As such, the institution as a whole is allowed to generate, on a monthly basis:

More than 2200 pounds (1,000 kg) of non-acutely hazardous waste (D, F, K, or U waste codes),

More than 2.2 pounds (1 kg) of acutely hazardous waste (P waste codes), and

More than 220 pounds (100 kg) of acutely hazardous waste spill clean-up materials.

All hazardous waste generated on the main campus is managed and disposed of using the assigned EPA ID number of SCD123456789, and may be accumulated on-site for a maximum of 90 days.

1 Information taken from SC DHEC R6.79-262.34



2.2 The Branch CampusesPresbyterian College currently does not have any Branch Campuses.

3.0 AuthorityTitle R61.79 of the South Carolina Code, Parts 260 through 270Title 40 of the Code of Federal Regulations, Parts 260 through 270

4.0 General Procedures

4.1 Main CampusPresbyterian College, and each of the individual laboratories, classrooms and chemical use areas located within the campus community, shall make every effort to maintain compliance with Large Quantity Generators standards (or Conditionally Exempt Small Quantity Generator standards, as appropriate). Any laboratory or work area generating hazardous waste must notify the Chemical Hygiene Officer, or the Environmental Health and Safety Coordinator, designate a Satellite Accumulation Area (SAA), and conform to the requirements stipulated by the South Carolina Department of Health and Environmental Control (SC DHEC) for LQGs.The College will remove all stored HW containers from the main campus at least once during each 90-day period using a licensed contractor. All HW will be managed according to local, state, and federal law and every effort will be made to reduce the potential long-term financial and legal liability to the institution. Furthermore, as an institution, Presbyterian College will make every effort to reduce the quantity and/or toxicity of the hazardous waste it generates through chemical reuse, material substitution, modified process practices, or other pollution prevention activities where possible.

4.2 The Branch CampusesPresbyterian College currently does not have any Branch Campuses..

5.0 Laboratory, Classroom or Chemical Use Area Requirements

5.1 Waste DeterminationsUnder the Resource Conservation and Recovery Act (RCRA, pronounced rick-rah), all hazardous materials destined for disposal must be considered hazardous wastes unless determined otherwise. Persons properly trained in the regulatory definitions of hazardous wastes must make all waste determinations. When knowledge of the hazard characteristics is indeterminate or unknown, waste analysis is required. Once a waste determination is made, the waste is managed as hazardous waste or



discarded as a non-hazardous waste, as appropriate. All waste determinations must be maintained in writing for a minimum of three (3) years. Appendix B consists of a form useful for documentary purposes.In order to conduct a waste determination all potentially hazardous constituents and reaction products must be considered. When in doubt, disposing of a regulatory agency-defined non-hazardous material as a hazardous waste is preferable to possibly releasing a potentially toxic pollutant into the environment. To manage hazardous wastes properly, the individuals responsible for laboratories, shops, and all other chemical use areas must identify and inventory their waste streams, and submit this information to the Environmental Health and Safety Coordinator. The EHS Coordinator will characterize the wastes, return the determination to the individual generator, and track the College’s hazardous waste generator status. This procedure is conducted by addressing the following steps:

Identify and Inventory Waste – Identify all waste streams generated within the lab or facility using knowledge of the process to determine the waste that is generated. Examples include science lab experiment–week one (etc.), scheduled warehouse clean out, art project–one (etc.), or building renovation. These processes may yield, respectively, excess hazardous reagents, out-dated chemicals, spent paint solvents, or asbestos-containing materials. Once waste streams are identified, determine the volume or quantity of wastes generated each month.

Characterize the waste – Determine if the chemical waste is a RCRA-listed waste, or if it meets one of the characteristics of a hazardous waste and is not exempted or excluded under the rules. (See Appendix C.)Hazardous waste includes chemicals and solutions with the following components or characteristics:

All heavy metals and their salts (toxic); All sulfides, bisulfides and cyanides (reactive); All other toxic, reactive or oxidizing inorganics (toxic,

reactive, or corrosive); All organic compounds except ethanol below 24% (toxic,

ignitable, or corrosive); All gases not normally constituents of the earth’s

atmosphere, and all flammable or oxidizing gases (toxic, ignitable, reactive, or corrosive)

Determine if a mixed chemical waste is hazardous or non-hazardous - If a RCRA-listed hazardous waste is mixed with a non-hazardous waste the resulting mixture will remain regulated as the



listed waste regardless of quantity present in the mixture. (See Figure 1 below.)If a characteristic hazardous waste is mixed with a non-hazardous waste, the resulting mixture will be regulated as hazardous only if the resulting mixture still exhibits the characteristic.

Determine and track generator status – Maintain a log of the process hazardous wastes. Information that should be included on this log include the following:

For each waste : A description of the waste (e.g., waste solvents from labs); type of waste (hazardous waste or acutely hazardous waste), method of characterization (e.g., lab exercise date, generator knowledge); amount generated in the month; and amount accumulated in the month.

Totals : Amount of all hazardous waste generated in the month; amount of all acutely hazardous wastes generated in the month; and the amount of all hazardous waste accumulated in the month.

5.2 Unknown, Discarded and Unneeded ChemicalsUnidentified substances present a major problem for both storage and disposal. These chemicals can be removed by a Hazardous Waste transporter, but their disposal is much more expensive than disposing of known hazardous materials. Therefore, proper labeling and identification is important. “Unidentified or Unlabeled Chemicals” are those bottles without a label, containers labeled with only codes, generic process labels that do not specifically list the chemicals contained, and obviously mislabeled chemicals. Each of these chemicals must be “fingerprinted” for specific hazard classes before it may be removed from the premises by a licensed hazardous waste transporter.Compounds that form peroxides, such as ethers (ethyl ether, and dioxane, but not “pet ether” or dioxins etc.), absorb and react with oxygen to form potentially explosive compounds with time. (See Appendix D.) Exposure to air and light accelerates these formations. Therefore, if your unlabeled liquid is partially or fully evaporated, and if crystals are present (or the liquid has become unclear), label the container as “Possible Peroxide” and handle as little as possible. These chemicals shall be brought to the attention of the hazardous waste transporter before any pickup is made.


ANY AMOUNT OF Non-Hazardous Wastes

Any amount of listed hazardous waste

LISTED HAZARDOUS WASTE=+


Chemicals such as Picric Acid can become unstable if allowed to dehydrate. Due to the potential for friction or shock-sensitive explosion with these chemicals, do not move or attempt to open these bottles if the container appears old, crystalline or damaged in any way. Alkali metals are air reactive, and must be kept stored under kerosene. If the kerosene has evaporated exposing the metal sticks, dangerous concentrations of hydrogen, an explosively flammable gas, or a metal peroxide crust, a shock sensitive solid may have built up. These chemicals shall be brought to the attention of the hazardous waste transporter before any pickup is made.Discarded and unneeded chemicals often represent unnecessary waste due to chemical mismanagement. Removal of unwanted chemicals and frequent evaluation of stored chemical containers are necessary to maintain chemical storage areas in a safe operating condition. To properly manage reagent chemicals on the PC campus, the laboratory instructor or manager shall:

Conduct a thorough laboratory cleanup and properly dispose of all unknowns, unwanted and unneeded chemicals.

Follow storage and labeling practices described in the Presbyterian College Chemical Hygiene Plan [Document ID No. S-2], to ensure that unknowns are not generated in the future.

Keep chemical stores to a minimum and review the annual inventory for unneeded chemicals that can be given to colleagues or placed into a re-use program before they have become useless or expired.

Borrow and share small amounts of rarely used chemicals with neighboring laboratories and when purchase is necessary, order the minimum practicable quantity.

5.3 Containers, Compatibility and StorageWaste chemicals must be stored in containers that are chemically compatible with the contents. Incompatible wastes must not be mixed together, nor can they be placed in an unrinsed container that contained an incompatible material. Acids cannot be mixed with bases, or flammables with oxidizing chemicals. Similarly, corrosives cannot be placed in metal containers, and Hydrofluoric Acid cannot be placed in glass containers. Waste containers must be kept tightly closed when waste is not being added to and must be stored in such a way that they will not rupture or leak, e.g., temperature controlled environment, segregation from corrosive fumes, etc. All containers must be labeled appropriately and visibly according to the guidelines in Section 5.4.All wastes must be stored indoors on a firm-working surface, and have secondary containment to prevent the release of hazardous waste to the environment. Containers shall be stored in a manner such that, in the event of a release, the contents will not enter the sanitary sewer or stormwater



drains. All wastes must be placed in Department of Transportation (DOT) approved shipping containers before shipment off site.

5.4 Marking and/or Labeling Requirements5.4.1 Containers

Each hazardous waste container must be properly marked or labeled. The marking or label must include the following information:

The words “Hazardous Waste,” List of chemicals contained within the container and approximate

percentages, Hazards of the waste (e.g.: “flammable,” “combustible,”

“corrosive,” “reactive,” “oxidizer,” “organic peroxide,” and “carcinogen”),

The date accumulation of hazardous waste was started in THAT container (the “Start Date”).

Preprinted labels are available from commercial vendors, although a laboratory-generated label is acceptable. (See Appendix E.) Fill in all applicable information, being sure to include all hazardous chemical constituents and the approximate concentration of each. The “Full Date is added after the container is full.

5.4.2 Satellite Accumulation AreasIn each area that initially generates hazardous waste; an SAA shall be demarcated and labeled as an SAA point of generation. This area is to contain accumulating hazardous wastes and hazardous materials that have been identified for disposal only. (Appendix F is an inventory of EHS equipment available in each laboratory at Presbyterian College, including the presence of one or more SAAs.)

5.5 Satellite Accumulation AreasEach SAA must be located at or near the point of generation and under the control of the laboratory manager or person directly responsible for the process generating the waste. SAAs may not contain accumulated hazardous wastes that are combined from several laboratory areas. Hazardous wastes may not be transported from one laboratory to another, in a common hallway, in an elevator or in a stairwell; except by authorized College personnel trained in hazardous waste management procedures.Only one container per waste stream (a maximum of 55 gallons for a hazardous waste or one quart for an acutely hazardous waste) is allowed in each SAA. When the container is full, the “Full Date” must be completed on the label and the container must be removed from the SAA to the 90-day “Central Storage Area” (CSA) within 72 hours. Notification is made by



calling the EHS Coordinator, has the waste picked up, the “Transfer Date” (abbreviated “Xfer Date” on the label in Appendix E) written on the label, and appropriately stored in the CSA. Containers must be stored by compatibilities on an impervious surface or in secondary containment to prevent access of spilled waste to the sanitary sewer.

5.6 Accumulation Limits

Maximum Amount of Waste Stored in Satellite

Accumulation Area

Allowable Amount of Waste Generated on Campus in Calendar

Month

Amount of Waste Stored in Central Hazardous Waste Storage Area

55 gallons of non-acute hazardous waste.

1 quart of acutely hazardous waste.

Remove from the SAA within 72 hours of filling the container.

Must be removed from the SAA for disposal within one year.

As a Large Quantity generator, one or more of the following amounts are generated on campus: More than 2200

pounds (1000 kg) of hazardous waste

More than 2.2 pounds (1 kg) of any one acutely hazardous waste

More than 220 pounds (100 kg) of acutely hazardous waste spill cleanup

More than 22 pounds (10 kg) of acutely hazardous waste from inner liners or paper bags

There is no limit to the amount of waste that can be stored. Waste must be shipped off-site within 90-days of the “full date,” which is the date when the waste was marked “full” at the SAA.

For all hazardous wastes, a waste container must be removed from the CSA within 90 days of the accumulation start date, which is the date the container was marked as full.



All containers within the CSA must be inspected weekly. Containers used for accumulation of hazardous wastes in SAAs must be removed at least once a year to prevent problems caused by container deterioration, to prevent excess accumulation of hazardous wastes, and to meet SC DHEC requirements.

5.7 Legal Disposal to the Sewer SystemThe majority of chemical substances will be disposed of by transferring them to a company licensed to operate a treatment/storage/disposal facility (TSDF). Chemical substances cannot be flushed down the drain without issuance of a wastewater discharge permit. Chemical wastes cannot be dumped in storm water catch basins or floor drains.

5.7.1 Acids and BasesProvided that a material is not hazardous for any other reason than corrosivity (e.g. organic acids are ignitable), acidic or basic laboratory waste may be neutralized as long as it is part of the written experiment. The resulting neutral (pH 6.0-9.0) salt solution may be flushed down the drain.This neutralization process can only take place at the point of generation. It cannot be conducted in an accumulation container (such as a flask, beaker or chemical bottle). This step must be a part of the written, experimental procedure.

5.7.2 Inorganic CompoundsInorganic compounds that are not hazardous waste may be dissolved in water and flushed down the drain with copious amounts of cold water provided they do not contain heavy metals or toxic anions and provided they are not oxidizers or water reactive. In particular, the following chemicals may be flushed to the sanitary sewer:

Soluble, non-water reactive salts of sodium, potassium, magnesium, and calcium.

Soluble and non-water reactive chlorides, bromides, carbonates, bicarbonates, and sulfates.

Soluble and non-water reactive natural products such as sugars, and amino acids.

If these materials are in solid form, or if they are not soluble, they may be thrown into the regular trash.5.7.3 Chemicals Prohibited from Sink Discharges

Chemicals, which may not be flushed to the sewer or thrown into the regular trash, include, but are not limited to:



Arsenic, barium, copper, tin, lead, silver, iron, cobalt, nickel, cadmium, chromium, zinc, manganese, selenium, and mercury salts.

Fluorides, sulfides, bisulfides, cyanides, nitrites, peroxides, chlorates, perchlorates, and permanganates.

5.8 Illegal Treatment or DisposalWith the exception of the neutralization procedures noted in Section 5.7, emergency response cleanup-actions, and certain totally enclosed treatment units, the treatment of hazardous wastes is illegal without a permit from the South Carolina DEP. Adding additional steps to the end of an experiment for the sole purpose of reducing the volume or toxicity of a hazardous waste is interpreted as treatment and is illegal under hazardous waste rules.Once a chemical is no longer useful, a waste determination must be conducted. Because of the complexity of the regulations, waste determination questions should be directed to trained personnel.

5.9 Training for Faculty and StaffAll PC faculty and staff who generate or handle hazardous wastes will be trained in this Hazardous Waste Management Plan, the requirements of the state and federal laws and the management of their SAAs. A review of the initial training shall be repeated on an annual basis. Training given as part of the curriculum will satisfy this requirement.Written documentation of each training session, including a signature and date of the person trained, will be maintained for a minimum of three (3) years.

5.10 Laboratory renovations, modifications and academic restructuringFrom time to time, the use of a particular laboratory at PC is modified to meet the needs of new faculty members, an expanding department or academic curriculum. Similarly, as emeritus faculty members leave the College, their research spaces are reallocated to new department members. Invariably, chemicals and equipment are left behind, or are no longer needed and must be addressed. Before renovations can commence, it is imperative that the laboratory is thoroughly inspected and excess chemicals and hazardous waste removed from the area. Neutralizing all surfaces and thoroughly washing all surfaces with soap and water should decontaminate the room’s surfaces and storage areas. All excess chemicals and hazardous wastes shall be managed according to the requirements of this plan and the laboratory reassigned to the new faculty member in the best possible condition. This process is the responsibility of the Department Chair.



6.0 Central Storage Area (CSA) and Campus-wide Requirements

6.1 Central Storage Facility/Area RequirementsAll hazardous waste and unneeded hazardous materials containers shall be stored on an impervious surface. Indoor storage areas must be provided with secondary containment that can contain 10% of the total volume in storage or 100% of the largest container whichever is greater. Containers will be inspected weekly. See Appendix G for a container inspection protocol that serves as its own documentation.The CSA facility shall be clearly marked with the words, “Hazardous Waste,” maintained separate from all other areas. Access to the hazardous waste storage area is restricted to authorized personnel only.Each container or drum located in the CSA shall be marked or labeled with the words “Hazardous Waste,” list the date the container was marked full [or the date the one (1) year SAA storage limit expires], the date of transfer to the CSA, and the contents of the container in accordance with Section 5.4.When ignitable or reactive wastes are being handled, smoking and open flames will not be allowed. “No Smoking” signs must be posted around the working area. All potential sources of ignition or reaction will be removed or addressed before work with ignitable or reactive wastes commences. Grounding and bonding connections will be used when transferring flammable liquids from one container to another.

6.2 Disposal and Manifesting6.2.1 Disposal of Hazardous Wastes

Since wastes need to be removed from an LQG site before the “90-day” accumulation periods are reached, hazardous waste pickups at PC will be conducted before the end of each 90-day accumulation period and will be managed by a licensed HW transporter. To control costs associated with the disposal of hazardous waste, PC will seek to maintain a long-term service contract with an approved hazardous waste vendor. Decisions regarding the choice of vendor will not be based solely on price, but will take into account the potential long-term liability to the institution. Where possible, PC will allow licensed contractors to recycle hazardous wastes and materials (i.e., Mercury), allow for fuel blending opportunities, or allow elementary neutralization of simple corrosives (i.e., acids and bases) where no other hazard exists. All other hazardous wastes will be transported to a licensed hazardous waste facility for recycling, incineration, or chemical treatment before landfill disposal. At no time will hazardous wastes generated on the PC campus be shipped to foreign countries for disposal.



6.2.2 Facility Personnel TrainingThere shall be at least two employees of PC who receive DOT Hazardous Materials training, in addition to hazardous waste training, to ensure that Hazardous Waste manifests are completed properly. Only those individuals who have been trained are to sign hazardous waste manifests on behalf of the College. This training must be re-taken every three years.Copies of the training content and training certificates will be retained for a period of three (3) years.

6.2.3 LQG Waste Handler TrainingThe EPA and DEP require that persons handling waste at LQG sites be trained to ensure that they are thoroughly familiar with proper handling and emergency response procedures relevant to their responsibilities.Responsibilities may include any, or all, of the following:

Hazardous Waste Determinations Containers, Compatibility, Handling and Storage Container Inspections Accumulation Limits Labeling Requirements Disposal and Manifesting Spill Response Procedures

Training should be conducted at the time of initial assignment to duties, which require handling waste, or when chemicals that are SC DHEC and EPA regulated wastes are added to a process or work area.

6.2.4 Shipping ManifestsPC representatives shall ensure that the EPA required “Uniform Hazardous Waste Manifest” (EPA Forms 8700–22 and 8700–22A) is properly completed. Some states supply their own version of this manifest. South Carolina does not. If the destination state supplies its own version, their manifest must be used. State supplied manifests have eight-pages. If neither the destination state, nor the generator state supplies a manifest, a six-page manifest will be used.As an example, consider the distribution of the multiple copies of a destination state supplied manifest. PC will retain the last three copies (6-8). The remaining copies of the manifest shall be given to the transporter. The destination state copy (7) of the manifest must be transmitted to the destination state within ten days of the day the shipment begins. PC will file the generator copy (8). The generator state copy (6) need not be sent to the South Carolina DHEC.2

2 Nota Bene: South Carolina regulations require generators, who manifest hazardous waste to states that do not require their designated facilities to send signed copies to the generator state, to send



Of the first five copies of the manifest, the generator copy (3) must be transmitted to the generator within 35 days of the facility acceptance. The generator and destination states’ copies (1 and 2) must be transmitted by the receiving facility to the generator state, if necessary and the destination state within 14 days of facility acceptance. All copies received by PC from the HW transporter and receiving facility over the 35-day period will be maintained together in a readily accessible location. Copies 4 and 5 of the manifest are reserved for transfer of the waste shipment between additional transporters. It is recommended that a separate file be kept for each hazardous waste shipment. This file should include all manifest copies, the packing slips and the Land Disposal Restriction (LDR) documentation, as well as any foreign shipment information from the hazardous waste transporter.If PC has not received Copy 3 from the receiving facility within 35 days of shipment, they are to contact the receiving facility to reconcile the disposition of the shipment. If Copy 3 has not been received within 45 days of shipment, then an Exception Report must be submitted by Presbyterian College, to the South Carolina DEP and EPA. (See Section 8.2.2.)The hazardous waste transporter shall provide PC with the EPA required two-part manifest for wastes that are reclaimed or recycled according to the contractual agreement. All copies received by PC from the hazardous waste transporter will be maintained together at the Environmental Health and Safety Coordinator’s office.The hazardous waste transporter shall provide PC with a shipping form for waste oils. The generator copy must be transmitted to the generator within 35 days of the facility acceptance. All copies of the manifest received by PC from the hazardous waste transporter over the 35-day period will be maintained together at the Environmental Health and Safety Coordinator’s office.Manifests and accompanying documents must be retained for at least three years. Documents older than three years should be archived separately from the current files.

7.0 Hazardous Materials Registration FeesOn May 1, 2000 the Department of Transportation (DOT) expanded its hazardous materials registration program (49 CFR Part 107, Subpart G) to include those who offer or carry a shipment of hazardous materials (including hazardous wastes) that requires placarding. As a result, shippers

signed copies to the DEP. South Carolina generators manifesting waste to Alabama, Arkansas, Illinois, Louisiana, Michigan, Missouri, North Carolina, Texas and Wisconsin need to make a photocopy of the copy they receive from the designated facility and send it to DEP. Please ensure that these copies are legible.



of non-bulk packages became subject to the DOT's hazardous materials registration fee. All colleges and universities shipping hazardous waste off their campuses using a commercial transporter became responsible for registering annually, and submitting a fee of $2,000, or $250 if they qualified as a small business. Documentation of registration and payment is received in the form of a Hazardous Materials Registration Certificate, which must be kept for three years.DOT’s Research and Special Programs Administration (RSPA),3 since 1992, has used the fees from this registration program to fund the Hazardous Materials Emergency Preparedness (HMEP) grants program that supports hazardous materials emergency response planning and training activities by State and local governments. The registration program also allows the RSPA to gather information on hazardous materials movements throughout the US.In 2003 RSPA temporarily lowered the registration fee for the next six registration years. RSPA also set the fees for not-for-profit organizations, regardless of size, to the fee paid by small businesses. For the first three registration years the fee for small businesses has been set at $150. For the last three registration years the fee rises to $275. These six registration years run from 2003-2004 through 2008-2009Companies subject to these regulations must submit a complete and accurate registration statement on DOT Form F 5800.2 not later than June 30 for each registration year. A copy of the form for the 2005-2006 registration year is included in Appendix H. Copies of the most current year’s instruction brochure and registration form are available at the “Hazmat Registration” Internet site at http://hazmat.dot.gov/regs/register/register.htm. Fees are paid in advance of the registration year. Schools must register for prior years if (1) they engaged in activities that required registration during those years, and (2) they failed to register. The amount of the fees due for prior years is indicated above. A schedule of these fees is also attached in Appendix H.Each of the registration fees given above includes a $25 processing fee. An institution may register for up to three years at one time, but pays only one processing fee. Go to the “Hazmat Registration” site for additional information on the following:

Instructions for registering online.

3 In February 2005 the offices within the U.S. Department of Transportation’s Research and Special Programs Administration (RSPA) responsible for the safe transportation of hazardous materials were incorporated into the newly created Pipeline and Hazardous Materials Safety Administration (PHMSA). Hazardous Materials Certificates of Registration are now issued by PHMSA. Certificates issued by RSPA remain valid through their expiration date.



A complete list of the current U.S. Small Business Administration size standards.

Company Registration Look-Up HMEP Grants Program Information

8.0 Emergency Response Equipment and ProceduresAll faculty and staff are required to be trained in appropriate emergency procedures under both SC DHEC and Occupational Safety and Health Administration (OSHA) regulations. Emergency evacuation plans, fire extinguishers, spill control equipment, and the training to use them are all part of responsible waste management.Emergency Phone numbers including the number of the local fire department and Emergency Response Person shall be posted near each telephone. The locations of fire extinguishers, alarm systems (if present) and spill control equipment should also be posted and clearly marked.Each LQG site must always have at least one Emergency Response Coordinator (ERC) available to respond to emergencies. The designated ERCs are Ricky Hess, Supervisor of Maintenance, and Alan Urwick, Assistant Director of Facilities and Operations. The ERC is responsible for coordinating all emergency response measures, including calling the fire department in the event of a significant fire, ensuring that the flow of hazardous materials is contained in the event of a release, and ensuring that any contaminated materials or soils are removed. All ERCs are required to respond to an emergency and interface with external emergency response agencies and, must be trained in Incident Command procedures.Specific Emergency Response Procedures are located in the Presbyterian College Emergency Response Plan, [Document ID No. G-3]. (A response plan to an all too routine event is attached as Appendix I, “Standard Procedures for Mercury Spills.”) The Emergency Response Plan includes all of the required Hazardous Waste Contingency Plan components:

Facility Identification Information; Assignment of Emergency Coordinator Responsibilities; Contingencies that will require implementation the Plan; Emergency response procedures for those contingencies; Emergency equipment availability, location, and capability; Coordination agreements with local/regional emergency responders; Evacuation Plan—when, signals for, primary and alternate routes of; Required reporting—the incident, and attainment of compliance

(before resuming operations);



Amending the Plan upon changes in—the regulations, the facility, or the Emergency Coordinator.

9.0 Recordkeeping, Reporting, and Required Programs

9.1 Recordkeeping9.1.1 Shipping Manifests

Presbyterian College must keep a copy of the manifest for each shipment of hazardous waste. The manifest must contain the signature of a PC representative who has received DOT Hazardous Materials training within the past three years, the signature of the initial transporter to accept the hazardous waste, and the date the hazardous waste was accepted.A copy of each manifests must be kept for three years, or until the College receives a signed copy from the destination facility which received the waste. This signed copy must be retained as a record for at least three years from the date the waste was accepted by the initial transporter.

9.1.2 Waste DeterminationsThe College must keep records of the means by which waste were determined to be hazardous. (See Appendix B for a documentation form.) These include:

Matching generated waste with waste listed as a hazardous waste in the regulations,4

Testing to determine if the waste has one or more of the characteristics of a hazardous waste (ignitability, corrosivity, reactivity, or toxicity),

Applying generator knowledge of the hazardous characteristics (ignitability, corrosivity, reactivity, or toxicity) of the materials or processes used in generating the waste.9.1.3 Summary of Additional Records

The College must also keep the following records: Application for and receipt of assigned EPA Identification Numbers

for the main campus, the law campuses, and any non-contiguous, College -owned property that generates hazardous waste.

The log of generated hazardous waste used to determine generator status, see Section 5.1.

A copy of faculty and staff hazardous waste management training agenda and sign-in sheets, see Section 5.9

A copy of CSA facility personnel hazardous waste management training, see Section 6.2.2

4 See 40 CFR 261.



A copy of waste handler hazardous waste management training agenda and sign-in sheets, see Section 6.2.3

Copies of Hazardous Materials Registration Certificates for the past 3 years, see Section 7.

A copy of faculty and staff emergency response training agenda and sign-in sheets, see Section 8

Biennial Report, see Section 9.2.1 Exception Report, see Sections 9.2.2 and 6.2.4

9.2 Reporting9.2.1 Biennial Report

As a Large Quantity Generator of hazardous waste in South Carolina, Presbyterian College Main Campus must prepare and submit a Biennial Report of shipments of hazardous waste off-site to any treatment, storage or disposal facility. This report must be sent to the EPA by March 1 of each even numbered year.The Biennial Report form, EPA Form 8700–13, must cover generator activities during the previous, odd-numbered year, and must include the following information:

1. The EPA identification number, name, and address of the generator.

2. The calendar year covered by the report.3. The EPA identification number, name, and address for each off-site

treatment, storage, or disposal facility in the United States to which waste was shipped during the year.

4. The name and EPA identification number of each transporter used during the reporting year for shipments to a treatment, storage or disposal facility within the United States.

5. A description, EPA hazardous waste number, DOT hazard class, and quantity of each hazardous waste5 shipped off-site to a treatment, storage or disposal facility within the United States. This information must be listed by EPA identification number of each such off-site facility to which waste was shipped.

6. A description of the efforts undertaken during the year to reduce the volume and toxicity of waste generated.

7. A description of the changes in volume and toxicity of waste actually achieved during the year in comparison to previous years.

8. Certification of the Report signed by the College’s authorized representative.

The Biennial Report forms for 2007, EPA Form 8700–13A/B, is included in Appendix J.

5 This information may be found on the manifest for each shipment.



9.2.2 Exception ReportsIf PC has not received Copy 3 of the manifest from the receiving facility within 45 days of shipment, then an Exception Report must be submitted by the College, to the South Carolina DHEC and the EPA.The Exception Report must include a legible copy of the manifest for which the College does not have confirmation of delivery, and a cover letter signed by the College’s authorized representative explaining the efforts taken to locate the hazardous waste and the results of those efforts. The submission to EPA need only be a handwritten or typed note on the manifest itself, or on an attached sheet of paper, stating that the return copy was not received.

9.2.3 Quarterly HW ReportsSouth Carolina requires Large Quantity Generators to submit quarterly HW reports. The report forms are included in Appendix J along with the appropriate filing instructions.

The College must keep a copy of each Quarterly Report, each Biennial Report and Exception Report for a period of at least three years from the due date of the report.

9.3 Required Plans and ProgramsAs a Large Quantity Generator of Hazardous Wastes, Presbyterian College is required to develop and implement the following written plans:

Preparedness Prevention and Contingency Plan to meet SC DHEC requirements. (Note: This can be combined with the Hazardous Waste Contingency Plan and the Emergency Response Plan

Hazardous Waste Contingency Plan – The emergency response portion of which may be incorporated into EPA’s "One Plan," also known as the Integrated Contingency Plan (ICP)

A Waste Minimization Program (EPA)


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