hwbdocuments.env.nm.gov Chemical...2014/11/24 · RCRA Part B Permit Application Table of Contents Section 1 - Executive summary

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JEC - 5 2014

District 1

RCRA Part B Permit Application

Submittal Date: November 24, 2014

6137 Edith Boulevard N.E. Albuquerque, NM 87107 505-349-5220

D IE©IEOVJE DEC - 8 2014

RCRA Part B Permit Application

Table of Contents Section 1 - Executive summary .................................................................................................. 1

1.1. General Description of ACTreatment ................................................................................ 1 1.2. General review of history and historical issues ................................................................. 1 1.3. Description of submittal package ...................................................................................... 1

Section 2 - Facility Description ................................................................................................... 2

2.1. Owner ................................................................................................................................ 2 2.2. Operator ............................................................................................................................ 2 2.3. Location ............................................................................................................................. 2 2.4. Facility Size & Type for Fees .............................................................................................. 6 2.5. Facility Design .................................................................................................................... 6 2.6. Site Operations .................................................................................................................. 7 2.7. Traffic pattern: volume, controls, and access .................................................................. 12 2.8. Security procedures and equipment ............................................................................... 12 2.9. Air Permits ....................................................................................................................... 13

Section 3 - General Inspection Schedule .................................................................................. 14

3.1. Intent: .............................................................................................................................. 14 3.2. Schedule: ......................................................................................................................... 14 3.3. Corrective Actions: ........................................................................................................... 14 3.4. Inspection Recordkeeping ............................................................................................... 14

Section 4 - Waste Analysis and Management ........................................................................... 15

4.1. Chemical and Physical Analyses of Hazardous Wastes .................................................... 15 4.2. Waste Analysis Plan (WAP) .............................................................................................. 15 4.3. Precautions for Prevention of Accidental Ignition or Reaction of Ignitable, Reactive or

Incompatible Wastes ....................................................................................................... 15 Section 5 - Description of Procedures, Structures or Equipment for Hazard Prevention ............. 18

5.1. Design and operation of facility ....................................................................................... 18 5.2. Prevention of Hazards during Unloading Operations ...................................................... 18 5.3. Prevention of Flooding and Run-Off from Waste Handling Areas ................................... 18 5.4. Prevention of Water Supply Contamination ................................................................... 19 5.5. Mitigation of Effects of Equipment Failures and/or Power Outage ................................ 19 5.6. Prevention of Undue Exposure of Personnel to Hazardous Waste ................................. 19 5.7. Prevention of Releases to the Atmosphere ..................................................................... 20

Section 6 - ACTreatment Facility Contingency Plan ................................................................... 21

6.1. Facility Identification and General Information .............................................................. 21 6.2. Type of Facility ................................................................................................................. 21 6.3. Copies of Contingency Plan ............................................................................................. 21 6.4. Arrangements with Local Authorities .............................................................................. 21 6.5. Amendment of Contingency Plan .................................................................................... 22

Section 7 - Personnel Training Program ................................................................................... 24

Section 8 - Seismic & 100-Year Flood Plain Compliance ............................................................ 25

Page i

8.1. Seismic Standard Compliance .......................................................................................... 25 8.2. 100-Year Flood Plain Compliance .................................................................................... 25

Section 9 - Closure Plan ........................................................................................................... 26

9.1. Background ...................................................................................................................... 26 9.2. Purpose ............................................................................................................................ 26 9.3. Estimated Expected Year of Closure & Closure Schedule ................................................ 26 9.4. Maximum Inventory of Wastes ....................................................................................... 26 9.5. Notification & Schedule of Closure .................................................................................. 27 9.6. Closure Activities ............................................................................................................. 27 9.7. Disposal or Decontamination of Equipment, Structures & Soils ..................................... 28 9.8. Soil Sampling During Closure ........................................................................................... 28 9.9. Certification of Closure .................................................................................................... 29 9.10. Certificate of Liability Insurance ...................................................................................... 29 9.11. Closure Cost Estimate and Proof of Financial Coverage .................................................. 29 9.12. Closure Plan Amendments .............................................................................................. 30 9.13. Survey Plat ....................................................................................................................... 31 9.14. Post-Closure Care and Use of Property ........................................................................... 31 9.15. Post-Closure Plan; Amendment of Plan ........................................................................... 31 9.16. Deed Restrictions and Post-Closure Notices ................................................................... 31 9.17. Certification of Completion of Post-Closure Care ........................................................... 31

Section 10 -Summary of Pre-Application Meeting ..................................................................... 32

10.1. Evidence of Public Notice: ............................................................................................... 32 10.2. Summary of public information meeting ........................................................................ 32 10.3. Attendees at public information meeting ....................................................................... 32 10.4. Comments received at public information meeting ........................................................ 32

Section 11 -Information requirements for Solid Waste Management Units (SWMUs) ................ 33

Section 12 -Groundwater monitoring requirements .................................................................. 34

Section 13 -Consideration under Other Federal Laws ................................................................ 35

13.1. National Historic Preservation Act of 1996 ..................................................................... 35 13.2. Endangered Species Act ................................................................................................... 35 13.3. Wild and Scenic Rivers Act ............................................................................................... 35 13.4. Coastal Zone Management Act ....................................................................................... 35 13.5. Fish and Wildlife Coordination Act .................................................................................. 35

Attachment 1 - EPA 8700 Site Identification ........................................................................ 36

Attachment 2 -

Attachment 3 -

Attachment 4 -

Attachment 5 -

Attachment 6 -

ACTreatment Maps, Drawings and Diagrams ............................................... 57

Justification of ACTreatment Fuels Consolidation Policy .............................. 62

Certificate of Liability Insurance .................................................................. 65

ACTreatment Pre-Application Public Meeting .............................................. 66

RCRA Part B Permit Regulatory "Crosswalk" ................................................ 79

List of Tables

Table 1- Secondary Containment and Storage Capacities ................................................ 7 Table 2 - Segregation of Incompatible Hazard Classes .................................................... 16

Page ii

Table 3 - ACTreatment Emergency Coordinators ............... Error! Bookmark not defined. Table 4 - Emergency Equipment at ACTreatment .............. Error! Bookmark not defined. Table 5- ACTreatment Facility Closure Cost Estimate ..................................................... 30 Table 6 - Estimated BTU Value (from water content) ..................................................... 63 Table 7 - BTU Values of Consolidated ACTreatment Fuels Waste ................................... 63 Table 8 - ACTreatment RCRA Part B Permit Application Regulatory "Crosswalk" ........... 79

Table of Figures

Figure 1- Letter to John Kieling dated 11/11/11 ............................................................... 4 Figure 2 - Letter from County of Bernalillo noting change of address for Lot 3 ................ 5 Figure 3- ACTreatment Facility Evacuation Routes ......................................................... 23 Figure 4 - EPA Form 8700 Site Identification ................................................................... 36 Figure 5 - General location map of ACTreatment Facility ............................................... 57 Figure 6 - ACTreatment Site Layout and Storage Areas .................................................. 58 Figure 7 -Topographic map of ACTreatment and Surrounding Area {6000 ft scale) ...... 59 Figure 8 -Topographic map of ACTreatment and Surrounding Area {200 ft scale) ........ 60 Figure 9 - Local Geology of ACTreatment ........................................................................ 61 Figure 10 - BTU Value versus Water Content .................................................................. 62 Figure 11 - Certificate of Liability Insurance .................................................................... 65 Figure 12 - Albuquerque Journal order confirmation ...................................................... 66 Figure 13 - Albuquerque Journal order mailing notice .................................................... 68 Figure 14 - Clear Channel Receipt/ Purchase Confirmation ........................................... 69 Figure 15 - Clear Channel broadcast information ............................................................ 70 Figure 16 - Photos of visible and accessible signage ....................................................... 71 Figure 17 - Copy of letter sent to the permitting agency and appropriate units of

State and local government ...................................................................................... 72 Figure 18 - Sign-in-sheet from the meeting ..................................................................... 73 Figure 19 - PowerPoint presentation given at the meeting ............................................ 74

Page iii

Section 1 - Executive summary

1.1. General Description of ACTreatment

Advanced Chemical Treatment, Inc. (ACTreatment) is located at 6137 Edith Boulevard N.E., Albuquerque, NM 87107 in Bernalillo County (EPA ID# NMD002208627). ACTreatment manages a treatment, storage and disposal facility for hazardous waste products and also acts as the City of Albuquerque's household hazardous waste collection depot. Services include:

• Solid waste consolidation • Liquid waste consolidation • Lab pack chemical consolidation • Universal/ E-Waste consolidation • Household hazardous waste management • Empty drum crushing

Wastes are sent for further recycling, incineration, landfill, wastewater treatment, transport, and/or disposal at a permitted TSDF.

1.2. General review of history and historical issues

The facility was originally constructed in 1983. In 1992, the southern half of the warehouse was built as an addition, along with the canopy on the west side of the building. The table below depicts the nature of activities from 1983 to present.

Period Facility Operator Land Owner Nature of Facility Activity 1983 to 1987 RCI Properties RCI Properties Vacant Land 1987 to 2011 Rinchem Company, Inc. RCI Properties 10 day transfer facility/Part B permitted

TSDF 2011 to Present Advanced Chemical RCI Properties 10 day transfer facility/Part B permitted

Treatment, Inc. TSDF

1.3. Description of submittal package

This renewal application includes the following:

• Part A, see Figure 4 - EPA Form 8700 Site Identification • Part B - Required forms for application and other information, included below • ACTreatment Facility Operations Manual - site specific SOPs as referenced in the

application • Waste Analysis Plan (WAP) - included in the ACTreatment Facility Operations

Manual

ACTreatment RCRA Part B Permit Application Page 1of82

Section 2 - Facility Description

Applicable Regulations - 49 CFR 270.14(b)(l)

2.1. Owner

The owner of the land upon which this facility is located is RCI Properties (Bill Moore),

located at 6133 Edith Boulevard NE, Albuquerque, NM. Operator

The facility operator is Advanced Chemical Treatment, Inc. (ACTreatment). The NMED

approved the permit modification for the transfer of the operator from Rinchem

Company, Inc. to Advanced Chemical Treatment, Inc. on October 7, 2011 for the

Rinchem Hazardous Waste Facility, now called Advanced Chemical Treatment, Inc.

(ACTreatment)

2.2. Location

The facility is located at 6137 Edith Boulevard N.E., Albuquerque, NM 87107 in

Bernalillo County. Note that EPA ID# NMD002208627is currently linked to 6133 Edith

Boulevard N.E., Albuquerque, NM 87107 and ACTreatment will keep the address of

6133 Edith Boulevard NE until the effective date of the permit renewal. At the time the

new permit becomes effective, the facility will have a new address of 6137 Edith

Boulevard NE and Rinchem will keep the 6133 Edith Boulevard NE address. Please refer

to Figure 1- Letter to John Kieling dated 11/11/11 for a copy of the letter referring to

the address and EPA ID# change. In addition, the Bernalillo County Zoning Department

authorized the address change and these letters are included as Figure 2 - Letter from

County of Bernalillo noting change of address for Lot 3.

The facility conducts its operations on a leased 3.08 acre property which it shares with

a sister company Advanced Chemical Transport, Inc. (ACT). ACTreatment operates on

1.75 acres which is leased by RCI Properties and ACT operates on 1.33 acres which is

leased by Riccobene. The entire site is zoned M-1 and is situated in an urban area

containing nearby commercial/light manufacturing facilities which are then bordered

by mainly residential areas. The immediately adjacent properties includes a scrap

metal recycler (to the northwest), an auto salvage yard (to the south), a provider of

cement products (to the west), and a provider of chemical products (to the east). See

Figure 5 - General location map of ACTreatment Facility and Figure 6 - ACTreatment

Site Layout and Storage Areas.

The nearest surface water features are unnamed storm water drainage channels

(generally dry, 0.3 miles to the east and west) that ultimately discharge into the Rio

Grande River (2.5 miles west of the facility). In addition, there are two ~1 acre storm

water infiltration basins (~200 feet north and adjacent to the south) which

collect/infiltrate urban runoff from the surrounding urban area (but not the facility).

The nearest residence is located ~0.1 miles southeast of the facility and there are

ACTreatment RCRA Part B Permit Application Page 2 of 82

"'67,000 residents within 1 mile. See Figure 7 -Topographic map of ACTreatment and

Surrounding Area (6000 ft scale) and Figure 8 -Topographic map of ACTreatment and

Surrounding Area (200 ft scale)


Figure 1- Letter to John Kieling dated 11/11/11

July 15, 2011

Rinchem

County of Bernalillo Zoning, Building & Planning Department

111 Union Square St SE Ste 100 Albuquerque, NM 87102

Office (505)314-0350 Fax (505)314-0480

Attn: Lisa Gorgone 6133 Edith Blvd Ne Albuquerque, NM 87107

Re: CHANGE OF ADDRESS

This letter is to serve notice of an address correction for: Lot 4A·l of Subdivision of Lot 4A Edith Land Company Cont 1.960 Ac Uniform Property Code: 101506131049110643

FROM:

6133 Edith Blvd NE Albuquerque NJ.\11 87107

TO:

6137 Edith Blvd NE Albuquerque NM 87107

Address changes occur for the Safety, Health and Welfare of the residents of Bernalillo County. Please update your records to show this change.

If you have any questions, please contact our Permit Specialist, Wendy Barker directly at (505) 314-0362 or [email protected].

Permit & plication Processing Manager


Figure 2 - Letter from County of Bernalillo noting change of address for Lot 3

July 15, 2011

Rinchem

County of Bernalillo Zoning, Building & Planning Department

111 Union Square St SE Ste 100 Albuquerque, NM 87102

Office (505)314-0350 Fax (505)314-0480

Attn: Lisa Gorgone 6133 Edith Blvd Ne Albuquerque, NM 87107

Re: CHANGE OF ADDRESS

This letter is to serve notice of an address correction for: Lot 3 Land Of Edith Land Co The Major Portion Of Tract 2 MRGCD Map 32 Uniform Property Code: 101506132848110644

FROM:

6137 Edith Blvd NE Albuquerque Nl\1187107

TO:

6133 Edith Blvd NE Albuquerque Nl\1187107

Address changes occur for the Safety, Health and Welfare of the residents of Bernalillo County. Please update your records to show this change.

If you have any questions, please contact our Permit Specialist, Wendy Barker directly at (505) 314-0362 or [email protected].


2.3. Facility Size & Type for Fees

The facility is categorized as a Small Quantity Generator. Wastes generated at the facility may come from spill clean-up, unused cleaning and maintenance products and samples from the laboratory.

All wastes generated at the facility will be characterized according to the Waste Analysis Plan included in the ACTreatment Facility Operations Manual. The facility no longer runs an at-risk program and all at-risk waste was transferred offsite in 2013.

2.4. Facility Design

The facility contains a single 25,000 ft 2 warehouse building which has been subdivided into six operating areas (A-F) for waste receiving, bulking and segregated waste storage. Rooms C and Dare divided by heat-based fire sensors that automatically close metal roll-up doors and the building is 4-hour fire rated. The warehouse building is constructed of concrete block and metal with concrete floors, steel I-beams frame and skylights. The southern portion of the warehouse has a covered loading dock with levelers and four (4), 10' x 10' overhead doors. Wall heights of the warehouse range from 11.5 to 16 feet and each room sealed with epoxy and the expansion joints in the floor are caulked to prevent possible contamination of the soil. Below is a description of each storage room which is designed to store hazardous waste for subsequent consolidation and transfer to off-site facilities (A-F):

• Room A

• Room B

• Room C

• Room D

• Room E

• Room F

Temperature controlled office space (engineered for hazardous waste storage if needed) Temperature controlled for flammable and other compatible lab packs Flammables, Empty Drums & Totes (DOT. Class 6 toxics) and DOT Class 4.3 (Dangerous When Wet) lab packs Flammables/Combustibles Non-Regulated Material, Caustics/Bases and also toxics (DO Class 6) Acids/Toxics/Oxidizers

All rooms have secondary containment provided by a 4" (approximate) curb or berm. In addition, the floor in all rooms is sloped away from the storage bays toward the aisles. Drum storage areas on the wall sides (but not the middle rack) of warehouses E & F have additional secondary containment. See Figure 3- ACTreatment Facility Evacuation Routes for facility layout.

The calculated containment capacities (and associated maximum theoretical storage capacities) are shown in Table 1 - Secondary Containment and Storage Capacities.

• Containment capacity (in gallons) is based on room size and curb height • Length and width are indicated in feet, curb height is indicated in inches. • Cubic feet converted to gallons using 7.48 gallon/ft3 • The actual curb height in all rooms is approximately 4". To be conservative, a 3"

curb height was used to calculate containment • Storage capacity based on requirement for 10% secondary containment capacity.


Table 1 indicates maximum hazardous materials storage capacities for individual warehouse areas. ACTreatment will limit storage of hazardous waste to a total of 150, 000 gallons. Provisions for separation of incompatible materials are discussed in 4.3.1. Segregation of Incompatibles and in Facility SOP 8 of the ACTreatment Facility Operations Manual.

Table 1 - Secondary Containment and Storage Capacities

Leftlth Width Hetpt Contatnrnent Mutmum Stonll• (ft) (ft) (Inch) Capacity fal) capacity (pl)

A 25 50 3 2337.5 23,37S

B 2S so 3 28,0SO 280,SOO

c 100 so 3 112,200 1,122,000

D 100 so 3 112,200 1,122,000

E 110 so 3 123,420 1,234,200

F 110 50 3 123,420 1,234,200

SOl,627.S S,016,27S

The facility also contains office space and a household hazardous waste drop-off center. In addition, there are paved parking/access ways and two small storm water collection/infiltration ponds. Vehicle access into the facility is either through a truck entrance or through an access way located on the north side of the facility.

(Applicable Regulations - 49 CFR 270.lS)

2.5. Site Operations

2.5.1. Receiving (ACT)

Trucks bearing waste from ACT are backed into one of the five loading bays, (sloped to a blind sump) in front of the truck loading dock. The truck loading dock is an elevated covered concrete dock that runs along the east face of the facility and is used to process arriving waste loads. The loading dock is equipped with spill containment features and is located under an automatic foam-based fire suppression system.

2.5.2. Storage (ACTreatment)

Once procesed for acceptance, containerized waste can be placed in one of six storage rooms within the facility segregated by waste type. Containers and palletized waste are placed in labeled storage positions on a tiered metal rack system or are stacked on the epoxy-coated floor (maximum of 3 high). Generally, wastes within the facility are placed along the outside walls and in the center. The individual storage positions are labeled with paint on the floor, are marked with overhead signs and/or have barcode labels. Empty containers may be placed along the south side (or in other areas where space is available) and empty drums may be accumulated within the facility paved parking area in preparation for transportation to off-site clients.


Refer to Facility SOP 8 of the ACTreatment Facility Operations Manual for additional information

2.5.3. Bulking and Processing (ACTreatment)

Approximately 75% of the waste throughput at the facility undergoes some form of repackaging or bulking. Liquid wastes may be extracted from drums/containers and some small containers are consolidated into larger containers. Solid wastes may be sorted and repackaged into roll-off containers. Lab packs may be repacked/transferred into larger packaging (e.g. a transfer of a container into a 55-gallon drum from a 5-gallon pail). In general, the following types of processing or wastemanagement activities are conducted (see individual Waste SOPs in the ACTreatment Facility Operations Manual for procedures for specific waste streams)

Waste oil:

Waste oil that can be recycled is consolidated at the facility into totes or tank trucks and then disposed of at a permitted used oil recycling facility. Common Waste Oils that are managed at the TSO include:

• Used Motor Oils • Industrial /Commercial lubricants • Other Automotive products • Dielectric fluids • Other oily waste that can be recycled as oil

Aerosols:

Aerosols are received at the facility and consolidated as hazardous or universal waste or processed by puncturing. Common aerosol cans that are managed at the TSO include:

• Spray Paints • Pesticides • Cleaners • Automotive products

• Medicines • Other consumer goods packaged in aerosol cans

Batteries:

Batteries are consolidated and segregated at the facility per DOT regulations. Common types of Battery wastes that are managed at the TSO include but are not limited to:

• Lead-acid batteries • Nickel-cadmium batteries • Alkaline batteries • Mercury containing batteries • Lithium batteries


Electronic waste:

Electronic wastes are consolidated or palletized in a manner to prevent breakage. Common types of Electronic wastes that are managed at the facility include:

• Computers • Monitors • Printers

Labpacks:

Labpacks segregated by DOT hazard class and consolidated for transportation and disposal. Common Labpacks that are managed at the facility include laboratory and industrial chemicals that are spent or expired.

Lamps:

Lamps are consolidated into containers in a manner to prevent breakage or crushed using an EPA compliant bulb crusher. Common types of lamps that are managed at the facility include:

• Fluorescent lamps • High pressure sodium lamps • HID lamps of various types

Landfill Liquids:

Common Liquids that are consolidated at the facility as non-hazardous include:

• Non RCRA regulated liquids • RCRA regulated liquids • Corrosive bases and acids • Other liquids that are accepted at the TSO that can legally be disposed of in a landfill

Landfill Solids:

Solids are consolidated, shredded or compacted into containers such as cubic yard boxes or roll-off containers. Common solids that are managed at the TSO include:

• Production trash • Other debris with or without contaminants • Lab trash • Filters and medias

Liquid Fuels:

Liquid fuels are consolidated into totes or tank trailers. Common Liquid Fuels that are managed at the facility include:

• Laboratory or Industrial Solvent wastes • Motor Fuels and lubricants • Automotive products

• Other organic liquids that have greater than 5000 BTU fuel value. • Additional information on evaluation of BTU values of combustible wastes is included

in Attachment 3 - Justification of ACTreatment Fuels Consolidation Policy


Low BTU Organic Liquids:

Low BTU organic liquids are consolidated into toes or tank trailers. Common Low BTU organic Liquids that are managed at the facility include:

• Laboratory or Industrial Solvent wastes • Water I Solvent Mixtures • HPLC wastes • Other organic liquids that have less than 5000 BTU fuel value.

Mercury:

Mercury wastes are consolidated into appropriate containers. Common Mercury Wastes that are managed at the facility include:

• Elemental mercury • Laboratory I Industrial chemicals that contain mercury or mercury compounds • Thermostats, thermometers and other devices that contain mercury • Mercury containing debris from spill cleanup

Solid Fuels:

Solid fuels are consolidated, shredded or compacted into cubic yard boxes or rolloff containers. Common Solid Fuels that are managed at the facility include:

• Laboratory or Industrial Solvent wipes, trash, and debris • Empty containers that once held flammable liquids • Carbon media • Other organic solids that may have greater than 5000 BTU fuel value

Drum-In-Drum-Out Waste (DIDO):

DIDO wastes are typically any wastes that may contain wastes that are not intended to be consolidated at the facility, or are not viable for consolidation due to the properties of the material. Common DIDO Wastes that are managed at the TSO include:

• Non-Pumpable Fuels • Lean waters with high water concentrations • Waste liquids packaged in small containers (vials, cartridges, devices)

• Wastes that may need additional processing at downstream TSDs • Wastes that have no current consolidation program, but are not restricted from

management at the TSO

2.5.4. 10-Day Transfer Facility (ACT)

ACT operates an outdoor 10-day transfer facility adjacent to the ACTreatment facility. Per the requirements in 40 CFR 263.12, manifested shipments of hazardous waste are stored in containers at this facility for 10 days or less during the normal course of transportation. The 10-day transfer facility is a separate business unit from ACTreatment and is used for wastes being transported by ACT to ACTreatment or other TSO facilities.

The 10-Day Tranter Facility generates traffic of approximately 8 vehicles per day. The vehicles enter/exit the transfer facility by way of Edith Blvd to a service road


(Rinchem Road) that leads to the facilty through an industrial neigborhood. Employee operated vehicles have access to the facilty via remote control operated automatic gate. Contract haulers and other non-employee vehicles must park on the service road and sign in at the front office to gain access to the 10-day yard.

Addiitonal informiion on facility traffic patterns is provided in Section 2.6. Traffic pattern: volume, controls, and access.

2.5.5. Household Hazardous Waste (ACT)

A portion of the facility loading dock is used by ACT employees as a permanent Household Hazardous Waste Collection Center (HHWCC). The Center is open to the public (City of Albuquerque residents) every Monday, Wednesday, Friday and Saturday for at least six (6) hours each day. Waste brought to the Collection Center is managed in a manner consistent with comparable wastes generated by commercial enterprises and regulated under the Resource Conservation and Recovery Act (RCRA). ACT provides the following services for HHW brought to the collection center:

• Receiving/collection/segregation; • Analysis for compatibility of unknowns; • Packaging/bulking, including labeling and manifesting; • Transportation in accordance with DOT and EPA regulations; • Management (recycling/reuse/reprocessing, treatment or disposal) of HHW at an EPA

permitted or equal facility; and • Disposal of non-hazardous wastes (empty containers, packaging materials, etc.) at the

City of Albuquerque's landfill, if not recyclable.

Paint related material is consolidated with compatible waste streams within the TSDF and shipped off-site for fuels consolidation.

The following waste streams are consolidated on the north loading dock and shipped offsite to permitted TSDFs.

• Aerosols (paint, pesticides, lubricants, oils) • Alkaline batteries • Corrosive acids (cleaners and descalers) • Corrosive bases (cleaners and disinfectants) • Flammable toxics (liquid pesticides and herbicides) • Fluorescent lights • Lead acid batteries • Mercury (thermometers, thermostats • NiCd batteries • Paint related material (flammable) • Solid oxidizers (pool chemicals) • Toxic solids (solid pesticides and herbicides)

• Used oil

The following waste categories are not accepted into the collection center:

• Radioactive wastes • Biomedical wastes


• Explosives/reactive wastes • Compressed gases (exclusive of aerosol cans)

ACT also provides a "Materials Reuse" area. Materials brought to the HHWCC and which appear to be usable, appear to be in the original container, have a complete label, are not restricted use or banned pesticides, or are not known to be carcinogenic materials are made available to the public free or charge. The material reuse is open to the public the same hours as the collection center.

2.6. Traffic pattern: volume, controls, and access

(Applicable Regulation - 49 CFR 270.14(b)(10))

There is only one street approach to the facility. This entrance is located 600 feet west of Edith Blvd. All the trucks accessing the facility approach from Edith Blvd. The trucks turn west onto a road and utility easement. This paved road is a private easement. The Access road surface is three inches of asphalt over a six inch gravel base course which translates into a load-bearing capacity of fifty 18,000-pound single-axle loads per day over twenty years. The trucks proceed on this easement until they reach the gate of the facility. See Figure 5 - General location map of ACTreatment Facility and Figure 6 - ACTreatment Site Layout and Storage Areas

A stop sign and a sign informing the drivers that they must report to the office before proceeding further is at the gate to the loading/unloading dock. After receiving permission from the office, the gate is opened and the driver is escorted to the dock.

After leaving the facility by way of the easement, the trucks stop at a stop sign that is located at the end of the easement immediately before turning onto Edith Blvd.

Various commercial motor vehicles are used to transport wastes. These vehicles can be tank, flat or van trailers or box vans. The maximum axle weight for any of these vehicles is 16,250 pounds and maximum gross weight is 80,000 pounds. Approximately 60 commercial vehicles per month enter and leave the facility.

The increase in storage capacity included in this permit application (compared to the previous permit) will increase traffic flow onto the access easement road by a maximum of 2 to 3 truckloads per day on average. The increase in vehicle traffic will have minimal impact on traffic in the area of the facility and in the adjacent industrial area. In-bound and outbound loads will be scheduled to minimize congestion

2.7. Security procedures and equipment

(Applicable Regulations - 49 CFR 264.14, 49 CFR 270.14(b))

Advanced Chemical Treatment, Inc. (ACTreatment) employs a number of measures to ensure adequate security in order to assure the protection of the facility from entry by unauthorized personnel, livestock and wildlife. ACTreatment employs the following security procedures:


2.7.1. Alarm System:

The facility has a security alarm system that is connected to each perimeter door, there are glass breaks sensors on windows, and motion detectors in office area. This security alarm system is monitored 24 hours a day by an outside security company. The alarm code is changed whenever an employee leaves the company.

2.7.2. Fence:

A fence encompasses the entire facility, including the 10-day transfer station managed by Advanced Chemical Transport, Inc. The fence is a chain link fence constructed with razor wire or barb wire along the top of the entire fence. The fence is in good repair and completely surrounds the active portion of the facility.

2.7.3. Gates:

All gates are kept' closed and locked during non-working hours. During working hours, the gates are kept closed when vehicles are not entering or exiting the facility. The main truck gate has a sign informing non-facility employees to check in with the office before entering. All critical locks are changed when an employee leaves the company or a key is lost.

2. 7 .4. Warning Signs:

A sign with the legend, "DANGER - UNAUTHORIZED PERSONS KEEP OUT" and "PELIGRO-PERSONAS SIN AUTORIZACION NO ENTRADA" is posted at each entrance to the active portion of the facility and at other locations in sufficient numbers to be seen from any approach to the active portion. The signs are legible from a distance of 25 feet.

2.7.5. Visitor/Contractor/Vendor Check-In:

All visitors, contractors, vendors, etc. are required to sign-in at the front office prior to entrance into the facility. Visitors, contractors and vendors are escorted during the course of their visit.

2.8. Air Permits

In the spring of 2013 Angela Lopez ([email protected]; 505-768-1962) with the City of Albuquerque visited the facility to review the fuel consolidation process. In August 2013, ACTreatment submitted an application for an air quality permit for this process. The permit application has been assigned to Paul Puckett ([email protected]; 505-767-5627) and as of the date of submission of this permit is still under review.


Section 3 - General Inspection Schedule

(Applicable Regulations 49 CFR 270.14(b)(S), 49 CFR 264.15 (b), 49 CFR 264.174)

3.1. Intent:

Advanced Chemical Treatment, Inc. (ACTreatment) personnel conducts regular inspections of all equipment and structures to prevent, detect, or respond to environmental or human health hazards.

3.2. Schedule:

The Operations Manager or his designee is responsible for carrying out and documenting the facility inspections in accordance with Facility SOP 17 in the ACTreatment Facility Operations Manual.

As described in Facility SOP 17, inspections are conducted on a daily, weekly, monthly and annual basis (the term daily refers to one operating day). Each inspection notes any repairs that are needed and assures that they are completed. If facility personnel cannot carry out the repairs, outside contractors will be brought in and repairs will continue to be indicated on applicable inspection reports until completion. The inspection logs are maintained as part of the facility's operating log for at least three years

3.3. Corrective Actions:

The inspections include checking for leaks, drum condition, safety and emergency equipment status and containment conditions, etc. Inspectors may also make any other observations concerning the facility they think are warranted. Inspectors will recommend and document any remedial action that is appropriate. If remedial action is required, the supervisor has been authorized to respond immediately to correct any noted deficiencies.

3.4. Inspection Recordkeeping

The inspection reports are maintained at the facility for a period of three years.


Section 4 - Waste Analysis and Management

4.1. Chemical and Physical Analyses of Hazardous Wastes

(Applicable Regulations §270.14(b)(2))

Advanced Chemical Treatment, Inc. will collect information such as chemical and physical characteristics of a waste to be accepted at the facility prior to the waste being shipped. This will include completion of a waste profile sheet, compiling generator knowledge and collection of a representative sample to generate laboratory analytical data (if generator knowledge is not sufficient), or some combination thereof. The purpose of this phase is to determine if the waste is acceptable by the facility based on comparison of the waste characteristics to permit, process, and regulatory constraints.

The analysis will be repeated as necessary to ensure that it is accurate and up to date. At a minimum, the analysis will be repeated when ACTreatment is notified, or has reason to believe, that the process or operation generating the hazardous waste has changed. In addition, the analysis may be repeated when the evaluation of incoming shipments indicates that the waste received at the facility does not match the waste designated on the accompanying manifest or profile.

Specific acceptance criteria and evaluation procedures for each type of waste collected at ACTreatment are indicated in the Waste Category Standard Operating Procedures (SOPs) included in the ACTreatment Facility Operations Manual. General procedures for hazardous waste analysis are included in the ACTreatment Waste Analysis Plan (WAP) also included in the ACTreatment Facility Operations Manual

4.2. Waste Analysis Plan (WAP)

The ACTreatment facility Waste Analysis Plan (WAP) is included in the ACTreatment Facility Operations Manual

4.3. Precautions for Prevention of Accidental Ignition or Reaction of Ignitable, Reactive or Incompatible Wastes

(Applicable Regulations §264.17, 270.14(b)(9))

The facility has a combination of building design and procedural measures to prevent accidental ignition or reaction of ignitable, reactive or incompatible wastes. The first precaution taken shall be to ensure that the hazardous waste received is what is described on the generator's profile and the manifest accompanying the waste so that it can be stored properly. The procedures to accomplish this are described in the waste category SOPS and the facility WAP included in the ACTreatment Facility Operations Manual

Containerized hazardous waste materials shall be stored only in closed DOT approved containers. These containers will not be opened unless sampling or repackaging is necessary. Procedures for handling containers as well as procedures for consolidation


are included in Facility SOPs and Waste Category SOPs in the ACTreatment Facility Operations Manual.

The storage areas for the waste containers are inside the building, as described in Section 2.4. Facility Design and in Section 4.3.1. Segregation of Incompatibles.

4.3.1. Segregation of Incompatibles

In order to decrease hazards caused by storing incompatible wastes, the building is designed to allow physical separation and secondary containment of incompatible materials. The storage portion of the facility is separated into six sections by stem walls and cinderblock walls. Each area has sloped floors to contain any material within that area should a spill or leak occur. There are also ramps in between the storage areas to keep any spilled or leaked waste within the storage area. Routine inspections of containers and container storage areas shall be conducted to allow site personnel to detect a spill or leak quickly and to identify potential problems before they occur.

Table 2 - Segregation of Incompatible Hazard Classes

DOT Hazard Room B Room C Room D Room E Room F Class

2.1 ../ ../ ../

2.2 ../ ../ ../ ../ ../

2.3 ../

3 ../ ../ ../

4.1 ../ ../ ../

4.2 ../ ../ ../

4.3 ../ ../ ../

5.1 ../

5.2 ../

6.1 ../ ../ ../ ../ ../

8 (acid) ../

8 (base) ../

9 ../ ../ ../ ../ ../

Non DOT ../ ../ ../ ../ ../

../=storage allowed

All storage containers holding hazardous waste that is incompatible with other wastes and materials (based on DOT Hazard Class) will separated and protected from these wastes and materials by cinderblock walls, stem walls and ramps between the storage areas. Specific storage areas for hazard classes are shown in talbe 2, above.


Consistent with 40 CFR 264.176, no reactive or ignitable wastes are stored within SO feet of the ACTreatment property line. Where necessary (where the ACTreatment storage warehouses are closer than SO feet from the property line) the SO foot distance is marked on the warehouse floor and no reactive or ignitable wastes are stored in the indicated areas.

Procedures for storage of hazardous wastes are included in Facility SOP 8 in the ACTreatment Facility Operations Manual.

4.3.2. Sources of Ignition

Sources of ignition shall be eliminated by several means. First, containers of flammable and combustible materials are stored in designated areas, away from electrical equipment. Second, electrical outlets are not located in the areas where these wastes are stored. The rooms are lit by sunlight coming through skylights in the roof, warehouses A & B are temperature controlled, otherwise there are no heating systems in the warehouse areas. Third, all wiring and electrical equipment used around the waste storage areas (such as in the temperature control rooms and on the docks) is explosion proof. The forklifts are designed and rated to prevent ignition of flammable vapors.

Smoking, and use of matches or lighters are not be permitted anywhere in the facility. "NO SMOKING" signs are posted at all entrances to the waste storage and handling areas, on facility perimeter fencing and other prominent places throughout the facility. Welding, cutting and other high temperature operations shall not be allowed near the vicinity of the waste storage and handling areas unless proper precautions and planning are done and the work is approved by compliance.

4.3.3. Required Aisle Space

An aisle space of no less than three feet is maintained to allow the unobstructed movement of personnel, fire protection equipment and spill control equipment. The arrangement of containers in the staging area shall always be configured to meet aisle space requirements.


Section 5 - Description of Procedures, Structures or Equipment for Hazard Prevention

(Applicable Regulations §264.30-37, §270.14(b)(8), §270.14(b)(8)(i), §270.14(b)(8)(ii), §270.14(b)(8)(iii), §270.14(b)(8)(iv), §270.14(b)(8)(v), §270.14(b)(8)(vi))

5.1. Design and operation of facility

The ACTreatment facility is designed, constructed, maintained, and operated in a manner that minimizes the possibility of a fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment.

• The facility has designated H-occupancy storage areas for storage of flammable materials and all storage rooms have secondary containment in sufficient quantity to minimize the likelihood of release to air, soil or surface waters in the unlikely event of a spill (as described in Section 2.4. Facility Design.

• Waste materials are stored in designated areas, based on their hazard class (as described in Section 4.3.1. Segregation of Incompatibles to minimize the likelihood of incompatibles reacting with each other

• As described in the ACTreatment Facility Operations Manual, waste containers are received, inspected, stored and managed as described in Facility and wastecategory-specific standard operating procedures (SOPs) in order to minimize the likelihood of an spills or releases

• A Contingency plan is in effect to ensure rapid response to any spills or releases (see Section 6 - ACTreatment Facility Contingency Plan) and regular inspections are conducted (as described in Section 3 - General Inspection Schedule) to ensure that all applicable facility safety systems are available and able to function as intended in the event of a spill or a release

5.2. Prevention of Hazards during Unloading Operations

Unloading hazards shall be reduced through procedures, structural features and equipment used at the facility. Containerized wastes shall be unloaded and loaded only at the truck dock which is equipped with mechanical dock levelers. All wastes that enter or leave the facility shall be handled over the sloped area of the loading dock. Small trucks shall drive over the berm onto the dock from the east side of the facility. Longer trucks shall back up to the dock, parking on the sloped and bermed concrete apron to the south. Both areas can contain a 1000-gallon spill.

The facility will maintain hand trucks and forklifts for hazardous waste container carrying. Forklifts will be operated as described in the ACT Powered Industrial Truck (PIT). Generally accepted practices for container handling will be used. In particular, loads will never be lifted higher than is necessary to minimize the risk of breakage should the load fall

5.3. Prevention of Flooding and Run-Off from Waste Handling Areas

Flooding of the hazardous waste storage building shall be prevented by the land under the building which is elevated five feet above the surrounding land. This allows any


rain that might land near the building to flow away from, instead of towards, the building. Also, the building's roof is sloped and is equipped with a gutter system which allows the rainwater to flow from the facility in a southwesterly direction into the catchment ponds.

Prevention of runoff from the waste handling areas shall be accomplished in several ways. The storage area for the hazardous waste is situated inside the building over sealed concrete floors that are sloped and bermed so in the event of a spill or other release the material is contained inside the building. All other waste handling areas such as the docks are paved with concrete which provide secondary containment.

S.4. Prevention of Water Supply Contamination

All the measures discussed in the section above will decrease the chance of contamination of water supply. All waste handling will be performed over concrete and any spills or leaks that do occur shall be cleaned up immediately. Also, the road around the building slopes to the west so that rainwater flows into the drainage ponds in the back of the building. This prevents the mixing of rainwater and any potential contamination from trucks at the dock.

S.S. Mitigation of Effects of Equipment Failures and/or Power Outage

Power outages and equipment failures do not create problems in the facility for the following reasons:

• The storage section of the facility is lighted only by skylights. The docks are equipped with explosion-proof electrical lighting. The forklifts are equipped with floodlights which allow for their safe use in the dark.

• In an emergency, pull stations will be operable since the electronic alarm system is battery powered. Verbal announcements will also be effective means of warning employees to evacuate.

• Emergency exit signs shall be self-illumination and visible without electric power.

S.6. Prevention of Undue Exposure of Personnel to Hazardous Waste

Training is the key to the prevention of employee exposure. All personnel at the facility shall be trained in procedures for properly performing facility operations including handling hazardous wastes and responding to emergency situations. Included in the training shall be instruction in the use of personal protection equipment and the location and use of safety showers and eyewash units which are located at strategic points throughout the warehouse. Additional information on the employee training program is included in Section 7 - Personnel Training Program.

Specific procedures for handling different waste categories are included in the ACTreatment Facility Operations Manual, however, in general:

• Engineering controls, such as working in well ventilated areas like the open loading dock areas, will be used wherever possible

• Work practices such as keeping containers closed, minimizing spills and releases, good housekeeping, etc. will be followed as described in waste category SOPs


• All employees shall be provided with protective equipment which includes, but is not limited to, eye protection, steeled-toed boots, respirators, protective overalls and chemically resistant aprons.

• At a minimum, employees and visitors shall be required to wear eye protection in the warehouse, on the docks and in the yard at all times.

• Respirator use will be consistent with requirements in the ACT Respiratory Protection Program (RPP)

Additional procedures for receiving, inspecting, storing and consolidating specific categories of hazardous waste are included in Facility and Waste Category Standard Operating Procedures in the ACTreatment Facility Operations Manual.

5. 7. Prevention of Releases to the Atmosphere

In addition to the precautions taken at ACTreatment to prevent releases, other ACT business units that transport waste to the ACTreatment facility implement additional preventive procedures before the hazardous waste is transported. Before loading the containers of waste at a generator's site, the containers are checked for soundness, proper closure and labeling, and compliance with U.S. Department of Transportation (DOT) standards. Any damaged containers that might leak or burst during transporting or unloading are be accepted for transportation.

All containers are inspected as they are received at the facility for proper labeling and closure and to ensure they are structurally sound. At the facility, all containers will be kept closed except as necessary for business activities such as inspection, sample collection, consolidation.

In the event of a leak or a spill, all liquids will be retained in the curbed, secondary containment within each room. Specific response procedures are described in the facility contingency plan, however releases to the atmosphere will be minimized through prompt response to any spills or releases in order to minimize quantities that could evaporate or be released to atmosphere.


Section 6 - ACTreatment Facility Contingency Plan

(Applicable Regulations §264.50-56, §270.14(b)(7))

ACTreatment has implemented a contingency plan designed to m1n1m1ze hazards from fires, explosions or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil or surface water at, and around Advanced Chemical Treatment's (ACTreatment) facility. The provisions of the plan shall be carried out immediately whenever there is a threat to human health or the environment, as described below.

The complete ACTreatment Facility Contingency Plan is included as Facility SOP 12 in the ACTreatment Facility Operations Manual.

6.1. Facility Identification and General Information

Advanced Chemical Treatment, Inc.

6137 Edith Boulevard N.E., Albuquerque, NM 87107

505-349-5220

6.2. Type of Facility

On-site storage and consolidation of hazardous waste in containers, tanks, roll-offs and similar containers.

6.3. Copies of Contingency Plan

A copy of the contingency plan and all revisions to the plan are:

• Maintained at the facility; and • Submitted to all local police departments, fire departments, hospitals and State

and local emergency response teams that may be called upon to provide emergency services.

6.4. Arrangements with Local Authorities

In the event of an emergency at the facility, appropriate local authorities have toured the facility and are familiar with the layout of the facility, properties of hazardous waste handled at the facility and associated hazards, places where facility personnel would normally be working, entrances to the facility and possible evacuation routes.

• Bernalillo County Fire Department shall assume primary emergency authority and will coordinate with the City of Albuquerque.

• Lovelace Women's Hospital has been notified and contracted with the facility and is familiar with the properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions, or releases at the facility.


6.5. Amendment of Contingency Plan

The complete ACTreatment Facility Contingency Plan is included as Facility SOP 12 in the ACTreatment Facility Operations Manual.

The contingency plan will be reviewed, and immediately amended, if necessary, whenever:

1. The facility permit is revised; 2. The plan fails in an emergency; 3. The facility changes-in its design, construction, operation, maintenance, or other

circumstances-in a way that materially increases the potential for fires, explosions, or releases of hazardous waste or hazardous waste constituents, or changes the response necessary in an emergency;

4. The list of Emergency Coordinators changes; or s. The list of emergency equipment changes.


Figure 3 - ACTreatment Facili ty Evacuation Routes

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Facility Evacuation Routes Advanced Chemical Treatment

6137 Edith Blvd. NE Albuquerque, NM 87107

October 10111, 2014

ES::oEmergency Shower F=Fire Extinguisher SP.,Splll Kit

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Scale: 1 inch equals 50 feet

ACTreatment RCRA Part B Permit Application

PS,.PuU Station fA"' first Aid Kit

Pnmary Evacuabon Roule

Secondary Evacuation Route ffi

Page 23 of 82

Section 7 - Personnel Training Program

Applicable Regulations §264.16, §270.14(b)(12))

The primary objective of the facility's training program is to instruct employees in the practices, procedures and rules regarding safe operation in accordance with applicable State and Federal regulations. The training program requires training in safety, proper transport and response to hazardous waste emergencies. These classes are conducted inhouse by an employee trained in hazardous waste management procedures and/or outside training providers. The instruction is in the form of classroom instruction and onthe-job training.

All new employees who manage hazardous waste shall complete the initial training courses within six months from their date of hire or from the date of transfer of job assignment. Personnel shall not work unsupervised in their positions until they have completed the training. Annually, all personnel who manage hazardous waste must participate in a minimum of eight hours of refresher/review of the initial training.

All TSD employees will receive initial OSHA HAZWOPER training as required under subpart (p) and subpart (q) of 29 CFR 1910.120 and annual refresher training, as described below, as well as DOT hazardous materials transport training. Courses which satisfy all or part of the training include, but are not limited to:

• Initial Facility Orientation • OSHA HAZWOPER Hazardous Material Technician (29 CFR 1910.120(q)(6)) • OSHA HAZWOPER TSD Worker (29 CFR 1910.120(p)(7)) • OSHA 8-hr HAZWOPER Refresher • DOT Hazardous Materials Transportation Training

The training shall consist of lectures, discussions, examinations and on-the-job training.

See ACTreatment Facility Operations Manual, Facility SOP 2 for more information on employee training


Section 8 - Seismic & 100-Vear Flood Plain Compliance

8.1. Seismic Standard Compliance

(Applicable Regulations §264.18(a), §270.14(b)(11) §270.14(b )( ll)(ii) , §270.14(b)(11)(ii)(A), §270.14(b )(ll)(ii)(B))

§270.14(b)( ll)(i),

Bernalillo County is listed in Appendix VI of the New Mexico Hazardous Waste management Regulations 20.4.1.500 NMAC, incorporating 40 CFR §264.18(a), The facility must demonstrate compliance with the seismic standard found in the New Mexico Hazardous Waste Management Regulations 20.4.1 NMAC.

No faults having had displacement in Holocene time are present within 3,000 feet of the Facility. Figure 9 - Local Geology of ACTreatment is a copy of the Section of a published geological map of Albuquerque and Bernalillo County entitled, "Geology of Albuquerque Basin" by Vincent C. Kelly, 1977. It shows the different stratigraphic units found in the Albuquerque basin. This map also shows the faults that are present in the basin. The Facility is identified on the map. As one can see, there is a fault within 3-4 miles of the Facility. This coincides with the type of geology found under the facility. The facility is located over alluvial deposits.

8.2. 100-Year Flood Plain Compliance

(Applicable Regulations §264.18(a), §270.14(b)(11) §270.14( b)( ll)(i), §270.14(b )( ll)(ii) , §270.14( b )( 1 l)(ii)(A), §270.14(b)( ll)(ii)(B ))

Using a Flood Insurance Rate Map of the city of Albuquerque, the facility is not located in an area subject to a 100-year flood. A copy of the map used for this determination is shown in Figure 7 -Topographic map of ACTreatment and Surrounding Area (6000 ft scale). The facility is identified on the map shows that the lot which encompasses the Facility touches the boundary for the 100-year flood plain but is not part of it. The nearest flood plain is an area of 100-year shallow flooding where depths are from one to three feet. Prior to construction, the land on which the building is located was elevated five feet above the surrounding land to alleviate any problems that could be caused by a flood. Even if a 100-year flood occurred, the building would be high enough above the nearby flood plain to prevent damage or water contamination. In this way, the possible hazard caused by bordering a 100-year flood plain is eliminated.


Section 9 - Closure Plan

9.1. Background

Location: 6137 Edith Boulevard N.E., Albuquerque, NM 87107

EPA ID No.: NMD002208627

This closure plan provides for the closure of the hazardous waste storage warehouse with a total storage capacity of 150,000 gallons of hazardous waste.

9.2. Purpose

The facility will be closed in accordance with the closure requirements of 40 CFR 264.110 through 40 CFR 264.115. Closure of the facility will be carried out in accordance with the steps outlined in this plan and applicable Federal and State regulations. An estimated closure schedule and closure cost estimate is attached. The closure plan and closure cost estimate, as part of the permit, will be kept on site. Copies of closure cost estimate financial assurance documentation will be provided upon final approval of this permit application, based on permit approval conditions.

During remediation, all hazardous wastes will be removed and any hazardous waste residues will be reduced to levels that are protective of human health and the environment (as determined by an evaluation from a New Mexico registered PE based on generally accepted professional practices), thereby achieving clean closure and eliminating the need for further maintenance and care. Upon completion of closure activities, the need for further maintenance will be eliminated.

The facility has developed this generalized closure plan for decontamination at the site. The closure plan includes the following:

• The estimated expected year of closure and a closure schedule. • An estimate of the maximum inventory of waste in storage at any time during the

active life of the facility for development of the closure cost estimate. • Notification procedures. • A description of how and when the facility will be finally closed. • Procedures for certification of closure activities by the facility and an independent

professional engineer. • Closure Performance Standard

9.3. Estimated Expected Year of Closure & Closure Schedule

There is no anticipated closure date at this time. At the time of closure, the facility will only perform a full closure and not a partial closure.

9.4. Maximum Inventory of Wastes

The maximum containerized hazardous waste inventory at the facility is 150,000 gallons. See Section 2.4. Facility Design for storage quantity limits. General storage guidelines are described in Facility SOP 8 of the ACTreatment Facility Operations Manual.


9.5. Notification & Schedule of Closure

The facility will notify the Department in writing of any intent to close the facility at least 45 days before the facility begins implementation of closure activities.

Within 90 days of receiving the final volume of hazardous wastes, the facility will remove all hazardous wastes from the site in accordance with the approved closure plan. The facility will complete closure activities in accordance with the approved closure plan and within 180 days after receiving the final volume of waste or upon NMED approval of the closure plan and procedures, whichever is later. NMED may approve a longer period if the facility demonstrates that:

• The activities necessary to remove wastes or close the facility will, of necessity, take longer than 90 or 180 days, respectively, to complete;

• The facility has the capacity to receive additional wastes; • There is likelihood that a person other than Advanced Chemical Treatment will

recommence operation at the site within one year; • Closure of the facility is incompatible with future use of the site. In this case, the

facility will take all steps necessary to prevent threats to human health and the environment.

The facility may petition the agency for an extension to the closure period to ensure that the facility has achieved clean closure levels that are protective of human health and the environment.

9.6. Closure Activities

Facility closure will be implemented in accordance with this plan and any subsequent modifications.

The container storage area within the warehouse is used to store/accumulate/consolidate containers of hazardous and non-hazardous wastes. At the beginning of closure, or before, the waste shall be removed and transported to disposal facilities using the same procedures and practices that are employed in the facility's day-to-day business. As described in the ACTreatment Facility Operations Manual

The secondary containment structure (concrete floor, curbing and collection trenches) will be inspected and decontaminated in accordance with the following general procedures. Unless otherwise specified, the decontaminated containment structure will be left in place at the time of closure.

• The containment area dike and slab area will be inspected by an independent Professional Engineer for the presence of cracks, fissures, missing seals, etc. If found, visible cracks or gaps in the containment shall be sealed prior to commencement of cleaning to prevent migration of rinsate outside of the containment area. In addition, if unsealed cracks are fully penetrating, the underlying soil will be sampled during closure as described below.

• The containment dike will be swept to remove loose debris, and then washed with a detergent- water solution and high-pressure spray and then triple rinsed. The


quantity of wash water will be kept to a minimum to reduce the amount required for treatment/disposal. Decontamination of the concrete will be repeated as necessary, until any contamination is reduced to acceptable levels (as determined by an evaluation from a New Mexico registered PE based on generally accepted professional practices)

• The decontamination wash water will be collected and evaluated for hazardous waste characteristics. Based on that evaluation, the rinsate will either be managed as a hazardous waste and transported for treatment/disposal at an appropriately permitted TSDF or characterized as non-hazardous and treated or disposed in accordance with applicable regulations.

• As described below, soil in potentially contaminated areas (such as under any unsealed, fully penetrating cracks) will be evaluated for contamination.

• As an alternative, the decontaminated concrete containment structure may also be demolished and transported offsite for recycling or disposal.

9.7. Disposal or Decontamination of Equipment, Structures & Soils

Equipment used for decontamination will be cleaned along with and within the respective secondary containment structures. Small consumable equipment (e.g. mops, rags, disposable PPE, etc.), which cannot be cleaned will be evaluated for hazardous waste characteristics. Based on the results of this evaluation, these wastes will then either be containerized, managed as a hazardous waste and disposed of at a permitted TSDF, or characterized as non-hazardous waste and treated or disposed in accordance with applicable regulations.

The facility does not anticipate that heavy equipment, such as cranes and backhoes, will come into contact with hazardous wastes. However, if necessary, heavy equipment will be cleaned by scraping, brushing and/or using a pressure washer with a nonphosphate detergent/water solution with tap water rinse. The wash/rinse water and any other wastes will be collected and evaluated for hazardous waste characteristics. Based on this evaluation, these wastes will then either be containerized and managed as a hazardous waste and disposed of at a permitted TSDF or characterized as nonhazardous waste and treated or disposed in accordance with applicable regulations.

9.8. Soil Sampling During Closure

During the closure process, all structures will be evaluated by a New Mexico registered PE to identify any cracks or gaps in concrete or asphalt or any other potential areas that would allow wastes to migrate to underlying soils.

Soil samples will be collected and evaluated as determined by an evaluation from a New Mexico registered PE based on generally accepted professional practices. In general soil samples will be collected from areas immediately beneath any cracks or gaps noted by the professional engineer

Where necessary, samples will be collected from native soils below the cracked or otherwise suspect areas using U.S. EPA's SW-846: Test Methods for Evaluating Solid Waste - Physical and Chemical Methods.


It is anticipated that soil samples will be analyzed for constituents representative of the toxicity characteristic waste codes listed in the facility permit (total voes, SVOCs and RCRA metals). Background samples will be collected for comparison.

Soil sample results will be compared to applicable closure criteria (as established by a New Mexico registered PE, based on generally accepted professional practice). If soil sample results indicate the presence of contamination above applicable closure criteria, the identification, characterization, and remediation of any contamination that may exist beneath the containment areas will be described in a work plan prepared by a New Mexico registered PE, based on generally accepted professional practice. The work plan will be submitted to the NMED for review and approval.

9.9. Certification of Closure

When closure is completed, both the facility owner and operator as well as a qualified independent Professional Engineer registered in New Mexico will submit to the NMED a formal certification that the facility has been closed in accordance with the approved closure plan. The certification will be sent by registered mail.

The closure certification will be presented in a Closure Certification Report, which will be prepared in accordance with applicable portions of 40 CFR 264.115. Information contained in the closure report will include a brief site history, site plan, closure field notes, description of decontamination procedures, photos, soil sampling locations, laboratory analytical reports, tabular summaries of analytical results, volume of wastes and/ or wash water removed and copies of waste manifests. Any deviations from the approved closure plan will also be documented in the report. The Closure Certification Report will be submitted within 60 days of completion of the closure activities.

9.10. Certificate of Liability Insurance

The Hazardous Waste Facility Certificate of Liability insurance is included in Figure 11 -Certificate of Liability Insurance. This certificate is issued by Endurance Specialty Insurance Company under policy number FEl-EIL-20469-00, issued and effective 10/17 /14.

9.11. Closure Cost Estimate and Proof of Financial Coverage

The following is the most recent closure cost estimate for Advanced Chemical Treatment, Inc. as required by 20.4.1.500 NMAC, incorporating 40 CFR 264.142. The cost estimate is based on hiring a third party to close the Facility at a point in the Facility's active life when the extent and manner of its operation would make closure most expensive.

The closure cost estimate is based on aggregate waste storage capacity as described in Section 2.4. Facility Design


Table 3- ACTreatment Facility Closure Cost Estimate

Description Quantity Units Cost per Total

Unit Cost Cost for removal[disPOSal[treatment of:

Maximum amount of waste at fadlity at any given time 150,000 gallons $ 1.81 $271,500

Wash water/residue generated from closure activities 1000 gallons $ 0.50 $500 Disposal of contaminated walls 10 cu.Yd. $ 35.00 $350

Disposal of contaminated concrete flooring or asphalt 10 CV· Yd. $ 35.00 $350 Disposal of contaminated soil 10 CV· Yd. $ 35.00 $350

Saml!:li!}g costs:

Soil (coring labor and analysis} 10 Soil Samples $ 500.00 $5,000 Waste profile samples from wash water residue 2 Water Samples $ 95.00 $190

Closure certification costs:

Inspection by NM Registered P.E $2,250 Preparation of closure report by NM Registered P.£ $2,250

other costs:

Labor costs for decontamination 4 people x 5 days x 8 hours hours $ 20.00 $3,200 Labor costs for sealing cracks, fissures, missing seals, etc 1 person x 4 hours hours $ 20.00 $80

Equipment rental costs (power washer, PPE, jade $1,500 hammer, hand tools, etc.}

Labor costs for Demo 3 peoplex5daysx8 hours hours $ 20.00 $2,400 Equipment rental costs (power washer, PPE, jade 5days Excavatorw/ $ 500.00 $2,500

hammer, hand tools, etc.) breaker $292,420

Proof of financial coverage will be provided upon approval of this permit application, based on the terms of approval.

9.12. Closure Plan Amendments

If an amendment needs to be made to this Closure Plan, the facility will submit a written notification to the NMED for a permit modification at least 60 days prior to the proposed change in facility design or operation, or no later than 60 days after an unexpected event has occurred which has affected the closure plan. If an unexpected event occurs during the final closure period, the facility will request a permit modification no later than 30 days after the unexpected event. It should therefore be noted that the Sampling Plan presented below is only an example, because as operations within the facility and testing procedures and requirements change, so shall the facility's sampling plan through Permit Modification, to reflect these changes.

A permit modification must be submitted whenever:

• Changes in operating plans or facility design affect the closure plan, or • There is a change in the expected year of closure, if applicable, or • In conducting closure activities, unexpected events require a modification of the

approved closure plan


9.13. Survey Plat

Not applicable to the facility.

9.14. Post-Closure Care and Use of Property


9.15. Post-Closure Plan; Amendment of Plan


9.16. Deed Restrictions and Post-Closure Notices


9.17. Certification of Completion of Post-Closure Care

Not applicable to the facility


Section 10 - Summary of Pre-Application Meeting

On Thursday, August 28, 2014, Advanced Chemical Treatment held a public meeting to provide information about the application and respond to citizen comments and questions.

10.1. Evidence of Public Notice:

• Newspaper Advertisement:

An order confirmaiton and a mailing notice from the Albuquerque Journal order are included in Attachment 4 - ACTreatment Pre-Application Public Meeting as Figure 12 - Albuquerque Journal order confirmation and Figure 13 - Albuquerque Journal order mailing notice

• Broadcast Media Announcement

A Receipt I Purchase Confirmation from Clear Channel as well as broadcast information are included in included in Attachment 4 - ACTreatment PreApplication Public Meeting as Figure 14 - Clear Channel Receipt I Purchase Confirmation and Figure 15 - Clear Channel broadcast information

• Visible and accessible sign in front of the facility

Photos of visible and accessible signage is included in Attachment 4 - ACTreatment Pre-Application Public Meeting asFigure 16 - Photos of visible and accessible signage

• Notice to the permitting agency and appropriate units of State and local government

An example of the letters sent to the Bernalilo County Environment Environmental Health Office, City of Albuquerque Environmental Health Department, Facility Mailing List as provided by the NMED and John Kieling, Chief, Hazardous Waste Bureau, New Mexico Environment Department in Attachment 4 - ACTreatment Pre-Application Public Meeting as Figure 17 - Copy of letter sent to the permitting agency and appropriate units of State and local government

10.2. Summary of public information meeting

• A copy of the PowerPoint presentation given at the meeting is included in Attachment 4 - ACTreatment Pre-Application Public Meeting as Figure 19 -PowerPoint presentation given at the meeting

10.3. Attendees at public information meeting

• A copy of sign-in-sheet from the meeting is included is included in Attachment 4 -ACTreatment Pre-Application Public Meeting as Figure 18 - Sign-in-sheet from the meeting.

10.4. Comments received at public information meeting

• No comments were received


Section 11 - Information requirements for Solid Waste Management Units (SWMUs)

Advanced Chemical Treatment does not operate a "regulated unit" as defined by 40 CFR 264.90(a)(2); which is 'a surface impoundment, waste pile, and land treatment unit or landfill that receives hazardous waste after July 26, 1982'.


Section 12 - Groundwater monitoring requirements

Groundwater monitoring requirements as required in 40 CFR §270.14(c) do not apply because Advanced Chemical Treatment does not operate a "regulated unit" as defined in Section 11 - Information requirements for Solid Waste Management Units (SWMUs).


Section 13 - Consideration under Other Federal Laws

(Applicable Regulations §270.3(a) - (f))

13.1. National Historic Preservation Act of 1996

This Act is not applicable to this facility since the property is not a designated site nor will existing operations affect any listed site.

13.2. Endangered Species Act

Continuing operations at this site will not affect any endangered species.

13.3. Wild and Scenic Rivers Act

Continuing operations at this site will not have a direct adverse impact any national wild and scenic river.

13.4. Coastal Zone Management Act

This act is not applicable since the facility is not located in a coastal zone.

13.5. Fish and Wildlife Coordination Act

This act is not applicable since operation of the facility will not result in the impoundment, diversion, or modification of any body of water.


Attachment 1 - EPA 8700 Site Identification

Figure 4 - EPA Form 8700 Site Identification

OMB# 2050--0024; Expires 12/31/2014

~ .'~1t'IJSr-'1J>,,., COMPLim;D

EQRMIQ: United States Environmental Protection Agency ; Qi The Appropriate RCRA SUBTITLE C SITE IDENTIFICATION FORM l~· State or Regional +,.;, PttO'"'"''.t.; Office.

1. Reason for Re11&on for Submittal: Submittal 0 To provide an Initial Notification (first time submitting site identification information I to obtain an EPA ID number

for this location)

MARK ALL 0 To provide a Subsequent Notification (to update site identification information for this location) BOX(ES) THAT [!I As a component of a First RCRA Hazardous Waste Part A Permit Application

APPLY 0 As a component of a Revised RCRA Hazardous Waste Part A Permit Application (Amendment# )

0 As a component of the Hazardous Waste Report (If marked, see sub-bullet below)

0 Site was a TSO facility and/or generator of ~1.000 kg of hazardous waste, >1 kg of acute hazardous waste, or >100 kg of acute hazardous waste spill cleanup in one or more months of the report year (or State equivalent LQG reaulations)

2. Site EPA ID EPA ID Number I NI MI 011 o I o I 2112 I o I 8 I/ 6 I 2 I 11 Number

3. Site Name Name: Advanced Chemical Treatment, Inc.

4. Site Location Street Address: 6133 Edith Boulevard NE Information

Cltv. Town or Villaae: Albuquerque Countv: Bernalillo

State: New Mexico I country: USA Zlo Code: 87107

5. Site Land Tyge WJ Private Ocountv noistrict nFederal nTribal nMunicipal nstate nother

8. NAICS Code(s) A. I 5 for the Site

I 6 I 2 I 21 1 I 1 I c. I 5 I 6 I 2 I 9/ 91 8 I (at least 5-dlgit

B. I 5 I 6 I 2 I 1 I 1 I 2 I D. I I I I I I I codes)

7. Site Malling Street or P.O. Box: 6133 Edith Boulevard NE Address

Cltv, Town, orVillaae:Albuquerque

state: New Mexico / Countrv: USA Zio Code: 87107

8. Site Contact First Name: Shawn IM1:B Last: Moudy Person Title: General Manager

Street or p .0. Box: 6133 Edith Boulevard NE

Cltv. Town or Vlllaae: Albuquerque

State: New Mexico I Countrv: USA Zip Code: 87107

Emall: [email protected]

Phone: 505-349-5222 I ext.: Fax: 505-349-5232

9. LagalOWner A. Name of Site's Legal owner: RCI Properties-Biii Moore Date Became

1986 Owner: and Operator

Owner Type: 0 Private D County D District D Federal 0Tribal 0Municipal Ostate D Other of the Site

Street or P.O. Box: 6133 Edith Boulevard NE

Citv. Town, or VIiiane: Albuquerque Phone:505-345-3655

State: New Mexico I Countrv: United States Zlo Code: 87107

B. Name of Site's Operator: Advanced Chemical Treatment, Inc. Date Became

10118111 0Derator: Operator 0 Private D County 0 District D Federal 0Tribal 0Municipal Ostate Oother Type:

EPA Form 8700-12, 8700-13 A/B, 8700-23 (Revised 12/2011) Page1 of-1_


Attachment 1 - EPA 8700 Site Identification, continued

EPA ID Number I N I MI D 11 0 I O I 2 11 2 I O I 8 I I 6 I 2 I 7 I OMB#: 2050-0024; Expires 12/31/2014

10. Type of Regulated Waste Activily (at your site) Mark "Yes" or "No" for all .5!!!!!!!! activities (as of the date submitting the fonn); complete any additional boxes as instructed.

A. Hazardous Waste Activities; Complete all parts 1-10.

1. Generator of Hazardous Waste If "Yes'', mark only one of the following - a, b, or c.

oa. LQG: Generates, in any calendar month. 1,000 kg/mo (2,200 lbs.Imo.) or more of hazardous waste; or Generates, in any calendar month, or accumulates at any time, more than 1 kg/mo (2.2 lbs.Imo) of acute hazardous waste; or Generates, in any calendar month, or accumulates at any time, more than 100 kg/mo (220 lbs.Imo) of acute hazardous spill cleanup material.

0b. SQG

oc. CESQG:

100 to 1,000 kg/mo (220 - 2,200 lbs.Imo) of nonacute hazardous waste. Less than 100 kg/mo (220 lbs.Imo) of non-acute hazardous waste.

If "Yes" above, indicate other generator activities in 2-4.

2. Short-Tenn Generator (generate from a short-term or one-time event and not from on-going processes). lf"Yes", provide an explanation in the Comments section.

YO N0 3. United States Importer of Hazardous Waste

yO N0 4. Mixed Waste (hazardous and radioactive) Generator

B. Universal Waste Activities; Complete all parts 1-2.

Large Quantily Handler of Universal Waste (you accumulate 5,000 kg or mont) (refer to your State 111gulations to detennine what is regulated]. Indicate lypes of universal waste managed at your site. If "Yes", mark all that apply.

a. Batteries 0 b. Pesticides 0 c. Mercury containing equipment 0 d. Lamps 0

e. Other (specify) D f. Other (specify) D g. Other (specify) D

YD N 0 2. Destination Facilily for Universal Waste Note: A hazardous waste permit may be required for this activity.

EPA Form 8700-12, 8700-13 A/B, 8700-23 (Revised 12/2011)


vD N0 5. Transporter of Hazardous Waste If "Yes'', mark all that apply.

D a. Transporter

D b. Transfer Facility (at your site)

v0 NO 6. Treater, Storer, or Disposer of Hazardous Waste Note: A hazardous waste Part B permit is required for these activities.

vD N0 7. Recycler of Hazardous Waste

vD N0 8. Exempt Boiler and/or Industrial Furnace If "Yes", mark all that apply. D a. Small Quantity On-site Burner

Exemption

D b. Smelting, Melting, and Refining Furnace Exemption

vD N0 9. Underground Injection Control

IJl D 10. Receives Hazardous Waste from Off-Y~ N site

C. Used 0 ii Activities; Complete all parts 1-4.

Y0 NO 1. Used Oil Transporter lf"Yes", mark all that apply.

D a. Transporter

0 b. Transfer Facility (at your site)

YO N 0 2. Used Oil Processor and/or Re-ntfiner If "Yes'', mark all that apply.

D a. Processor

D b. Re-refiner

YO N0 3. Off-Specification Used Oil Burner

YO Nr;71 4. Used Oil Fuel Marketer ~ If "Yes", mark all that apply.

Marketer Who Directs Shipment of OffSpecification Used Oil to OffSpecification Used Oil Burner Marketer Who First Claims the Used Oil Meets the Specifications

Page 2 of.±__

Page 37 of 82


EPA ID Number I NI Ml DI I O I O I 2 I I 2 I O I 8 I I 6 I 2 I 7 I OMB#: 2050-0024; Expires 12/31/2014

D. Eligible Academic Entities with Laboratories-Notification for opting into or withdrawing from managing laboratory hazardous wastes pursuant to 40 CFR Part 262 Subpart K

·:· You can ONLY Opt into Subpart Kif . you are at least one of the following: a college or university; a teaching hospital that is owned by or has a formal affiliation agreement with a college or university; or a non-profit research institute that is owned by or has a formal affiliation agreement with a college or university; AND . you have checked with your State to determine if 40 CFR Part 262 Subpart K is eftective in your state

Y[J~ 1. Opting into or currently operating under 40 CFR Part 262 Subpart K for the management of hazardous wastes in laboratories See the item-by-item instructions for definitions of types of eligible academic entities. Mark all that apply:

Oa College or University

Db Teaching Hospital that is owned by or has a formal written affiliation agreement with a college or university

De. Non-profit Institute that is owned by or has a formal written affiliation agreement with a college or university

YONO 2. Withdrawing from 40 CFR Part 262 Subpart K for the management of hazardous wastes in laboratories

11. Description of Hazardous Waste

A. Waste Codes for Federally Regulated Hazardous Wastes. Please list the waste codes of the Federal hazardous wastes handled at your site. List them in the order they are presented in the regulations (e.g .. 0001. 0003, F007. U112). Use an additional page if more spaces are needed.

REFER TO ATTACHED TABLE 1

~ ------- ·- -- --------

-~

B. Waste Codes for State-Regulated (i.e., non-Federal) Hazardous Wastes. Please list the waste codes of the State-Regulated hazardous wastes handled at your site. List them in the order they are presented in the regulations. Use an additional page if more spaces are needed.

REFER TO ATTACHED TABLE 2

EPA Form 8700-12, 8700-13 A/B, 8700-23 (Revised 12/2011) Page 3 of .1_



EPA ID Number I N I MI DI I O I O I 2 I] 2 I O I 8 I I 6 I 2 I 7 I OMB#: 2050-0024; Expires 12131/2014

12. Notification of Hazardous Secondarv Material IHSMl Activitv

Y0N0 Are you notifying under 40 CFR 260.42 that you will begin managing, are managing, or will stop managing hazardous secondary material under 40 CFR 261.2(a)(2)(ii), 40 CFR 261.4(a)(23), (24), or (25)?

lf"Yes'', you must fill out the Addendum to the Site Identification Form: Notification for Managing Hazardous Secondary Material. --

13. Comments

-·

------

··-~

·-----

·-

--

14. Certification. I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system. or those persons directly responsible for gathering the information. the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information. including the possibility of fines and imprisonment for knowing violations. For the RCRA Hazardous Waste Part A Permit Application, all owner(s) and operator(s) must sign (see 40 CFR 270.10(b) and 270.11 ).

Signature of legal owner, operator, or an Name and Official Title (type or print) Date Signed authorized representative (mmldd/yyyy)

Shawn Moudy, General Manager

Bill Moore, Property Owner RGI ProperliE ·-

EPA Form 8700-12, 8700-13 A/B, 8700-23 (Revised 1212011) Page 4 of _4_



TABLE 1: FEDERAL HAZARDOUS WASTE CODES ACCEPTED AT ADVANCED CHEMICAL

TREATMENT

EPA Hazardous Estimated Unit Process Number Annual Quantity of Waste

Of Waste Measure Codes DOOl 1,331 T SOl D002 500 T SOl D003 500 T SOl D004 25 T SOl D005 25 T SOl D006 25 T SOl D007 25 T SOl D008 25 T SOl D009 25 T SOl DOlO 25 T SOl DOll 25 T SOl D012 25 T SOl D013 25 T SOl

D014 25 T SOl D015 25 T SOl D016 25 T SOl D017 25 T SOl D018 25 T SOl D019 25 T SOl D020 25 T SOl D021 168 T SOl D022 34 T SOl D023 25 T SOl D024 25 T SOl

D025 25 T SOl D026 25 T SOl D027 25 T SOl D028 369 T SOl

D029 25 T SOl D030 25 T SOl D031 25 T SOl D032 25 T SOl D033 25 T SOl D034 25 T SOl D035 25 T SOl D036 25 T SOl

D037 25 T SOl

D038 25 T SOl D039 25 T SOl

D040 25 T SOl




Of Waste Measure Codes 0041 25 T 501 0042 25 T 501 0043 25 T 501 FOOl 1100 T 501 F002 1100 T 501 F003 1100 T 501 F004 500 T 501 FOOS 575 T 501 F006 25 T 501 F007 25 T 501 F008 25 T 501 F009 25 T 501 FOlO 25 T 501 FOll 25 T 501 F012 25 T 501 FOB 25 T 501 F014 25 T 501 F015 25 T 501 F016 25 T 501 F017 25 T 501 F018 25 T 501 F019 25 T 501 F020 25 T 501 F021 25 T 501 F022 25 T 501 F023 25 T 501 F024 25 T 501 F025 25 T 501 F026 25 T 501 F027 25 T 501 F028 25 T 501 F029 25 T 501 F030 25 T 501 F031 25 T 501 F032 25 T 501 F033 25 T 501 F034 25 T 501 F035 25 T 501 F036 25 T 501 F037 39 T 501 F038 25 T 501 F039 25 T 501 KOOl 25 T 501




Of Waste Measure Codes K002 25 T SOl K003 25 T SOl K004 25 T SOl KOOS 25 T SOl K006 25 T 501 K007 25 T 501 K008 25 T 501 K009 25 T 501 KOlO 25 T 501 KOll 25 T 501 K012 25 T SOl K013 25 T 501 K014 25 T 501 KOlS 25 T 501 K016 25 T 501 K017 25 T 501 K018 25 T SOl K019 25 T 501 K020 25 T 501 K021 25 T 501 K022 25 T 501 K023 25 T 501 K024 25 T 501 K025 25 T SOl K026 25 T 501 K027 25 T 501 K028 25 T SOl K029 25 T 501 K030 25 T SOl K031 25 T 501 K032 25 T 501 K033 25 T 501 K034 25 T 501 K035 25 T SOl K036 25 T 501 K037 25 T SOl K038 25 T 501 K039 25 T 501 K040 25 T SOl K041 25 T 501 K042 25 T 501 K043 25 T 501 K044 25 T 501




Of Waste Measure Codes K04S 2S T 501 K046 2S T 501 K047 2S T 501 K048 2S T 501 K049 2S T 501 KOSO 2S T 501 KOSl 2S T 501 KOS2 2S T 501 KOS3 2S T 501 K054 2S T 501 KOSS 2S T 501 K056 2S T 501 KOS7 2S T 501 KOSS 2S T 501 KOS9 2S T 501 K060 2S T 501 K061 2S T 501 K062 2S T 501 K063 2S T 501 K064 2S T 501 K06S 2S T 501 K066 2S T 501 K067 2S T 501 K068 2S T 501 K069 2S T 501 K070 2S T 501 K071 2S T 501 K072 2S T 501 K073 2S T 501 K074 2S T 501 K07S 2S T 501 K076 2S T 501 K077 2S T 501 K078 2S T 501 K079 2S T 501 KOSO 2S T 501 K081 2S T 501 K082 2S T 501 K083 2S T 501 K084 2S T 501 KOSS 2S T 501 K086 2S T 501 K087 2S T 501




Of Waste Measure Codes KOSS 25 T 501 K089 25 T 501 K090 25 T 501 K091 25 T 501 K092 25 T 501 K093 25 T 501 K094 25 T 501 K095 25 T 501 K096 25 T 501 K097 25 T 501 K098 25 T 501 K099 25 T 501 KlOO 25 T 501 KlOl 25 T 501 K102 25 T 501 K103 25 T 501 K104 25 T 501 K105 25 T 501 K106 25 T 501 K107 25 T 501 K108 25 T 501 K109 25 T 501 KllO 25 T 501 Klll 25 T 501 K112 25 T 501 Kll3 25 T 501 K114 25 T 501 K115 25 T 501 K116 25 T 501 K117 25 T 501 K118 25 T 501 K119 25 T 501 K120 25 T 501 K121 25 T 501 K122 25 T 501 K123 25 T 501 K124 25 T 501 K125 25 T 501 K126 25 T 501 K127 25 T 501 K128 25 T 501 K129 25 T 501 K130 25 T 501




Of Waste Measure Codes K131 25 T 501 K132 25 T 501 K133 25 T 501 K134 25 T 501 K135 25 T 501 K136 25 T 501 POOl 2 T 501 P002 2 T 501 P003 2 T 501 P004 2 T 501 POOS 2 T 501 P006 2 T 501 P007 2 T 501 P008 2 T 501 P009 2 T 501 POlO 2 T 501 POll 2 T 501 P012 2 T 501 P013 2 T 501 P014 2 T 501 POIS 2 T 501 P016 2 T 501 P017 2 T 501 P018 2 T 501 P019 2 T 501 P020 2 T 501 P021 2 T 501 P022 2 T 501 P023 2 T 501 P024 2 T 501 P025 2 T 501 P026 2 T 501 P027 2 T 501 P028 2 T 501 P029 2 T 501 P030 2 T 501 P031 2 T 501 P032 2 T 501 P033 2 T 501 P034 2 T 501 P035 2 T 501 P036 2 T 501 P037 2 T 501




Of Waste Measure Codes P038 2 T 501 P039 2 T 501 P040 2 T 501 P041 2 T 501 P042 2 T 501 P043 2 T 501 P044 2 T 501 P04S 2 T 501 P046 2 T 501 P047 2 T 501 P048 2 T 501 P049 2 T 501 POSO 2 T 501 POSl 2 T 501 POS2 2 T 501 P053 2 T 501 P054 2 T 501 POSS 2 T 501 P056 2 T 501 POS7 2 T 501 POSS 2 T 501 P059 2 T 501 P060 2 T 501 P061 2 T 501 P062 2 T 501 P063 2 T 501 P064 2 T 501

P065 2 T 501 P066 2 T 501 P067 2 T 501 P068 2 T 501 P069 2 T 501 P070 2 T 501 P071 2 T 501

P072 2 T 501 P073 2 T 501 P074 2 T 501 P07S 2 T 501 P076 2 T 501 P077 2 T 501 P078 2 T 501 P079 2 T 501 P080 2 T 501




Of Waste Measure Codes P081 2 T 501 P082 2 T 501 P083 2 T 501 P084 2 T 501 POSS 2 T 501 P086 2 T 501 P087 2 T 501 POSS 2 T 501 P089 2 T 501 P090 2 T 501 P091 2 T 501 P092 2 T 501 P093 2 T 501 P094 2 T 501 P095 2 T 501 P096 2 T 501 P097 2 T 501 P098 2 T 501 P099 2 T 501 PlOO 2 T 501 PlOl 2 T 501 P102 2 T 501 P103 2 T 501 P104 2 T 501 PlOS 2 T 501 P106 2 T 501 P107 2 T 501 P108 2 T 501 P109 2 T 501 PllO 2 T 501 Plll 2 T 501 Pll2 2 T 501 Pll3 2 T 501 Pll4 2 T 501 PllS 2 T 501 Pll6 2 T 501 P117 2 T 501 Pll8 2 T 501 Pll9 2 T 501 P120 2 T 501 P121 2 T 501 P122 2 T 501 P123 2 T 501



EPA Hazardous Estimated Unit Process

Number Annual Quantity of Waste Of Waste Measure Codes

UOOl 2 T 501 U002 2 T 501 U003 2 T 501 U004 2 T 501 uoos 2 T 501 U006 2 T 501

U007 2 T 501 U008 2 T 501 U009 2 T 501 U010 2 T 501

U011 2 T 501 U012 2 T 501 U013 2 T 501 U014 2 T 501 U015 2 T 501 U016 2 T 501 U017 2 T 501 U018 2 T 501 U019 2 T 501

U020 2 T 501 U021 2 T 501

U022 2 T 501 U023 2 T 501 U024 2 T 501 U025 2 T 501 U026 2 T 501 U027 2 T 501

U028 2 T 501 U029 2 T 501 U030 2 T 501

U031 2 T 501 U032 2 T 501 U033 2 T 501 U034 2 T 501

U035 2 T 501 U036 2 T 501

U037 2 T 501 U038 2 T 501

U039 2 T 501 U040 2 T 501

U041 2 T 501 U042 2 T 501

U043 2 T 501




Of Waste Measure Codes U044 2 T 501 U045 2 T 501 U046 2 T 501 U047 2 T 501 U048 2 T 501 U049 2 T 501 uoso 2 T 501 UOSl 2 T 501 U052 2 T 501 U053 2 T 501 U054 2 T 501 uoss 2 T 501 U056 2 T 501 U057 2 T 501 U058 2 T 501 U059 2 T 501 U060 2 T 501 U061 2 T 501 U062 2 T 501 U063 2 T 501 U064 2 T 501 U065 2 T 501 U066 2 T 501 U067 2 T 501 U068 2 T 501 U069 2 T 501 U070 2 T 501 U071 2 T 501 U072 2 T 501 U073 2 T 501 U074 2 T 501 U075 2 T 501 U076 2 T 501 U077 2 T 501 U078 2 T 501 U079 2 T 501 U080 2 T 501 U081 2 T 501 U082 2 T 501 U083 2 T 501 U084 2 T 501 U085 2 T 501 U086 2 T 501




Of Waste Measure Codes U087 2 T 501 U088 2 T 501 U089 2 T 501 U090 2 T 501 U091 2 T 501 U092 2 T 501 U093 2 T 501 U094 2 T 501 U095 2 T 501 U096 2 T 501 U097 2 T 501 U098 2 T 501 U099 2 T 501 UlOO 2 T 501 UlOl 2 T 501 U102 2 T 501 U103 2 T 501 U104 2 T 501 UlOS 2 T 501 U106 2 T 501 U107 2 T 501 U108 2 T 501 U109 2 T 501 UllO 2 T 501 Ulll 2 T 501 U112 2 T 501 U113 2 T 501 U114 2 T 501 UllS 2 T 501 U116 2 T 501 U117 2 T 501 U118 2 T 501 U119 2 T 501 U120 2 T 501

U121 2 T 501 U122 2 T 501 U123 2 T 501 U124 2 T 501 U125 2 T 501 U126 2 T 501 U127 2 T 501 U128 2 T 501

U129 2 T 501


Attachment 1- EPA 8700 Site Identification, continued


Of Waste Measure Codes U130 2 T 501 U131 2 T 501 U132 z T 501 U133 2 T 501 U134 z T 501 U135 2 T 501 U136 2 T 501 U137 z T 501 U138 2 T 501 U139 z T 501 U140 z T 501 U141 2 T 501 U142 z T 501 U143 2 T 501 U144 2 T 501 U145 z T 501 U146 z T 501 U147 z T 501 U148 z T 501 Ul49 z T 501 UlSO z T 501 UlSl z T 501 U152 2 T 501 U153 z T 501 U154 5 T 501 U155 z T 501 U156 2 T 501

U157 2 T 501 U158 2 T 501 U159 z T 501 U160 z T 501 U161 2 T 501 U162 2 T 501 U163 2 T 501 U164 z T 501 U165 2 T 501

Ul66 2 T 501 U167 2 T 501 U168 2 T 501 Ul69 z T 501

U170 z T 501 Ul71 2 T 501

U17Z 2 T 501




Of Waste Measure Codes U173 2 T SOl U174 2 T 501 U175 2 T 501 Ul76 2 T 501 U177 2 T 501 U178 2 T 501 U179 2 T SOl U180 2 T 501 U181 2 T 501 U182 2 T 501 U183 2 T SOl U184 2 T 501 U185 2 T 501 U186 2 T 501 U187 2 T 501 U188 2 T 501 U189 2 T 501 U190 2 T SOl U191 2 T 501 U192 2 T 501 U193 2 T 501 U194 2 T 501 U195 2 T 501 U196 2 T 501 U197 2 T SOl U198 2 T SOl U199 2 T 501 U200 2 T 501 U201 2 T 501 U202 2 T 501 U203 2 T 501 U204 2 T 501 U205 2 T 501 U206 2 T SOl U207 2 T 501 U208 2 T SOl U209 2 T 501 U210 2 T 501 U211 2 T 501 U212 2 T 501 U213 2 T SOl U214 2 T 501 U215 2 T SOl




Of Waste Measure Codes U216 2 T 501 U217 2 T 501 U218 2 T 501 U219 2 T 501 U220 2 T 501 U221 2 T 501 U222 2 T 501 U223 5 T 501 U224 2 T 501 U225 2 T 501 U226 2 T 501 U227 2 T 501 U228 2 T 501 U229 2 T 501 U230 2 T 501 U231 2 T 501 U232 2 T 501 U233 2 T 501 U234 2 T 501 U235 2 T 501 U236 2 T 501 U237 2 T 501 U238 2 T 501 U239 2 T 501 U240 2 T 501 U241 2 T 501 U242 2 T 501 U243 2 T 501 U244 2 T 501 U245 2 T 501 U246 2 T 501 U247 2 T 501 U248 2 T 501 U249 2 T 501


Attachment 1- EPA 8700 Site Identification, continued

TABLE 2: CALIFORNIA HAZARDOUS WASTE CODES ACCEPTED AT ADVANCED CHEMICAL

TREATMENT

California Corresponding Estimated Unit Process Hazardous EPA Hazardous Annual Quantity of Waste Waste Codes Waste Code(s) Of Waste Measure Codes 121 D002, D006 .41 T SOl 122 DOOl, D002 3.38 T 501 123 D002 1.18 T 501 131 NONE 16.7S T SOl 133 DOOl, D018, 2.42 T SOl

FOOS, FOOS 134 DOOl, D002, 14.21 T SOl

D006 13S DOOl, D004, 80.9S T 501

D007, D008, D011

141 DOOl, D002, 1.0S T SOl D007, D018, D03S, F003, U134

171 D007 2.S9 T 501 172 NONE .03 T 501 181 D001,D004, 28.3S T 501

F003, D006,

D007, D008, D009, 0011,

211 DOOl, D018, 6.48 T 501

D019, D022, D038, F002,

F003,FOOS 212 DOOl, D022, 272.29 T SOl

D028, F002, F003,FOOS

213 DOOl, D018, 6.70 T SOl D03S, F003, FOOS

214 DOOl, 0002, 28S.06 T 501 D011, D018, D022, D026, D03S, D038,

F002, F003, FOOS, U154

221 DOOl 82.12 T 501

223 NONE, 13.S9 T SOl 232 DOOl, D004, .20 T 501

P044



California Corresponding Estimated Unit Process Hazardous EPA Hazardous Annual Quantity of Waste Waste Codes Waste Code(s) Of Waste Measure Codes 261 NONE .10 T 501 271 0001, F003 1.09 T 501 272 0001, 003S .so T 501 291 0001, 003S 11.96 T 501 311 0001, 0018, 34.76 T 501

0022, 0038, F002, F003, FOOS

331 0001, 0002, 80.4S T 501 0004, ooos, 0006, 0007, 0008, 0010, 0011, 0018, 003S, F003, FOOS

343 0001, 0002, 40.12 T 501 0011, 003S, F002, F003, FOOS

3S2 0001, DOOS, 321.87 T 501 0006, 0007, 0008, 0011, 0018, 0022, 003S, 0038, F002, F003, FOOS

461 0001, 003S 3.37 T 501 Sll 0001, 0002, 16.68 T 501

0003, ooos, 0006, 0007, 0008, 0009,

0011, 0018, 0022, 0026, 003S, 0038, F002, F003, F004, FOOS, PlOS, U031, U107, U109, U123, U188

S12 NONE .73 T 501 S13 0001 21.02 T 501 SSl 0001, 0002, 33.38 T 501

0018, 0022, 003S, F002, F003, FOOS

611 NONE 1.S8 T 501 612 0001, 0002, 1.34 T 501



California Corresponding Estimated Unit Process Hazardous EPA Hazardous Annual Quantity of Waste Waste Codes Waste Code(s) Of Waste Measure Codes

F001,F003 725 0001, 0002, .05 T 501

0007, 0008, 0009, 0011

741 0001, 0018, 33.17 T 501 0021, 0022, 0028, 0038, 0039, F002, F003, FOOS

791 0001, 0002, 54.60 T 501 0004, 0006, F002,F003

792 0002, 0007, .04 T 501 0009, 0011


Attachment 2 - ACTreatment Maps, Drawings and Diagrams

Figure 5 - General location map of ACTreatment Facility

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' Academy Rd NE

"·~

•Aonl90fl*Y Blvd NE

Arroyo Del Oso NOl1h

Atldemy Esates East

Spa.n RdN

OMJna Rd N

Osuna Park Inc

• losGrtegos ; Rio Grande Natu'e

~ l t "'

~ I:' w Montgomery Hodgin E ~

0 ~ c.ni .. Slate Pm

~ f

I £' Man hew

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~ Heights Village Patio i \

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Heights ii Comanc:::MRdNE S!

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if.

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M«laul 8Nd NE Uw:aulSl.nJNE

C«onodo 8 Altufll

GENERAL LOCATION MAP OF THE FACILITY ADVANCED CHEMICAL TREATMENT

6137 EDITH BLVD NE, ALBUQUERQUE, NM October 101

h, 2014

... i

TSD FACILITY LOCATION (35°08' 39.79"- 106° 37' 43.27")

C8tldelaria Rd NE

Sombre Del Monte

lne:-11 I• · Edil ln


<: § ~

ffi

N

E9

THc Bayfield

-Nos:os- --------S~lplOCkO Farmington

I o O o

I Upper Bloomfield

ul<ll Fnmlan<!

·~ o I TsaLlel

I Foh

Dflll~ o Tollatchl ~ Cra1Ynpoont

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I I I

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0 0

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0 Taos

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0 Santa Fe

0

®

Ne w Me x ic o

Carrizozo 0

o Capitan

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Tularosa 0

0 Alamogordo

'l

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1 I I Bol

Cloyton o 11Rrta Bia I Natic I Gra~ I o I I I I

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0 0

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Note: No injection wells or withdrawal wells are shown because no wells are known to be used with Y. mile of the facility. Several wells have been abandoned because of the lowering of the water table. The information was obtained from well records in the Tate Engineers Office. This was also confirmed by a survey of the residential areas surrounding the facility site.

Page 57 of 82

Figure 6 - ACTreatment Site Layout and Storage Areas

I

··- ··- ·

Site ?tan and Waste Storage Advanced Chemical Transport


October 10th, 2014

·· - . -

on. 36 n.. so n. 120n. ,..._-== I Scale: 1 inch equals 60 feet

r··---.............. : i i f ~~ j i : ! i ... . ........ ...

'


-1

0

L .· - · · - . - ···- ··-,

D '

' ~ · · - .. - .. - ·· - .. ' I

Page 58 of 82

Figure 7-Topographic map of ACTreatment and Surrounding Area (6000 ft scale)

35'08W" 108"38'50"


,. ....... 106"38'10-

Topographic Map

109"37'30"

. ·· ·······~···· ..

-~ . ~ .

I·.

. . w;1r··· ;. ·uSTl . .

. -1· ·· ..... ·.

. .

········· .... ~1.: .. . At~queW.1 Aupat(2'3050J

1~s.ms Am.ID! A'olClfoge • Al Ho.n ....._lgl~•71UJ

·-· ·-· Cl • . ,, o ...... .... • ·· • ..

TOPOGRAPHIC MAP ADVANCED CHEMICAL TREATMENT

6137 EDITH BLVD NE, ALBUQUERQUE, NM

N

~ ~

~,-;;:·n I

SCALE: 1 INCH EOOM.S 6000 FEET

Page 59 of 82

Figure 8 - Topographic map of ACTreatment and Surrounding Area (200 ft scale)

(see back pocket)


Figure 9 - Local Geology of ACTreatment

("Geology of Albuquerque Basin" by Vincent C. Kelly, 1977, see back pocket)


1 ·

GEOLOGY OF~ ALBUQUERQUE BASIN by Vi ncenl C. Kelley, 197 7

3 4 0 2 5 10 1 ~i MIL ES Ci====:4==:r----.:F==i==:::i. -~--=::=:r--------------;_----·----· - · --------,.

SCALE I: 190,000

· GEOLOGIC MAF

EXPLANATION

I lr:r::l • Qo J·~~~:f·~. - . . ..... . Alluvium

Qa: Arroyos; Qfa: Fans

~ . . Alluvium Floodpla ins

Landslide

Qe

,..._ .. , ... , ... .. ... . ~.~'! ,'• -..

·.:·.o.e:a·;·_::, .~:1.:~ :5? :~

Eolian sand Qe: Blankets; Qed: Dunes

G Gravel terraces

G Caliche

~ Gravel pediments

G Ortiz pediment gravel and surface

Fanglomerate ranging from large boulders t o pebbles

r>~c~-~j Santa Fe Formation

. Ts: Undi vided: pink ish . light-olive-drab and wh i te sandstone,

gray and brown mudstone; arkose, conglomerate, and fan ·

glomerate. Tse : Ceja Member. " Upper buff" of Bryan anc

Mr.r:;:inn: arr1vi.i:.h .r;;:inrl r1nrl aP.hhlv r:nnalnmerare . Tsz : Zia

Attachment 3 - Justification of ACTreatment Fuels Consolidation Policy

As described in waste category SOPs in the ACTreatment Facility Operations Manual, ACTreatment will consolidate ignitable wastes having a BTU value of 5,000 BTU or greater (as certified by the . generator) . BTU values used for bulking are based on generator knowledge in as established in the waste profile .

ACTreatment uses water values to verify conformance with the customer profi le specification. In addition, in order to ensure that all wastes that are consolidated for fuels are> 5,000 BTU, ACTreatment has a policy of not bulking waste that are >50% water. Wastes are tested as described in the ACTreatment Facility Operations Manual and any wastes that are >50% water assigned to an appropriate alternate waste profile.

This approach is supported by data from the consolidated fuels waste generated by ACTreatment from the consolidated of customer wastes. The fuel values and water content of consolidated ignitable wastes generated by ACTreatment (from the consolidation of customer wastes) are measured upon receipt by the disposal facilities, as shown in Table 5 - BTU Values of Consolidated ACTreatment Fuels Waste and in Figure 10 - BTU Value versus Water ContentError! Reference source not found ..

Figure 10 - BTU Value versus Water Content

BTU Value versus %Water

• y = -131.64x+ 12788 10000 -P"-...:::::::-~~~~~~~~~~~~~~~~~~~~~~~--'RL2~=~0.~30,,,,_,_7 ~~~~~-

4000 +-~~~-,-~~~~,---~~~-,--~~~-.~~~~-,-~~~-.~~~~.,.-~~~-,

20 25 30 35 40 45 so 55

The trend line from these results (using linear regression) can be used to calculate an estimated BTU value, based on water content, as shown in Table 4 - Estimated BTU Value (from water content). This table shows that consolidated, ignitable waste from


60

Attachment 3 - Justification of ACTreatment Fuels Consolidation Policy, continued

ACTreatment with a water content of 50% will typically have a fuels value of approximately 6,200 BTU.

This supports the ACTreatment policy of only consolidating wastes for fuels that have less than 50% water and provides an almost 25% margin to account for customer wastes that may vary in initial BTU value .

Table 4 - Estimated BTU Value (from water content)

% Water Estimated Average BTU Value

10 11,471.6

20 10,155.2

30 8,838.8

40 7,522.4

50 6,206

60 4,889 .6

70 3,573.2

Table 5 - BTU Values of Consolidated ACTreatment Fuels Waste

DATE Manifest BTU Range BTU Midpoint %Water

10/26/2013 006118507FLE 8-lOK 9000 20

10/29/2013 006118509FLE 12-14K 13000 20

11/1/2013 006118510FLE 6-7K 7000 33.5

11/5/2013 006118516FLE 8-lOK 9000 23 .3

11/12/2013 006118522FLE 8-lOK 9000 29 .9

11/19/2013 006118528FLE 8-lOK 9000 25.4

11/22/2013 006118530FLE 14K+ 15000 20

12/3/2013 006118534FLE 8-lOK 9000 32

12/12/2013 006118541FLE 8K-10K 9000 29 .71

12/13/2013 006118545FLE 10K-12K 11000 31.92

12/16/2013 006118550FLE 5K-6K 6000 55.79

12/20/2013 006118555FLE 5-6K 6000 51.07

12/28/2013 006118559FLE 8-lOK 9000 20

1/3/2014 006118561FLE 8-lOK 9000 20.9

1/9/2014 006118563FLE 7-8K 8000 33

1/16/2014 006118570FLE 8K-10K 9000 33.4

1/31/2014 006118580FLE 6-7K 7000 29 .74

2/11/2014 006118590FLE 8-lOK 9000 30.44

2/25/2014 006118599FLE 6-7K 7000 39 .28

3/4/2014 006761201FLE 8-lOK 9000 29.29


Attachment 3 - Justification of ACTreatment Fuels Consolidation Policy, continued

DATE Manifest BTU Range BTU Midpoint %Water

3/13/2014 006761208FLE 8-lOK 9000 20.4

3/18/2014 006761216FLE 12-14K 13000 20

3/20/2014 006761222FLE 8-lOK 9000 25

3/24/2014 006761224FLE 8-lOK 9000 20

3/25/2014 006761227FLE 10-12K 11000 20

4/1/2014 006761235FLE 8-lOK 9000 42 .72 4/8/2014 006761241FLE 8-lOK 9000 20

4/11/2014 006761247FLE 7-8K 8000 27 .16

4/17 /2014 006761250FLE 8-lOK 9000 33.54

4/22/2014 006761254FLE 7-8K 8000 36.55

4/25/2014 006761263FLE 8-lOK 9000 21.69

4/29/2014 006761268FLE 8-lOK 9000 22.23

5/6/2014 006761275FLE 8-lOK 9000 31.14

5/20/2014 006761283FLE 10-12K 11000 20

5/27/2014 006761292FLE 8-lOK 9000 20

5/30/2014 006761303FLE 7-8K 8000 28.5

6/3/2014 006761307FLE 8-lOK 9000 20

6/6/2014 006761318FLE 8-lOK 9000 26.4

6/17/2014 006761332FLE 8-lOK 9000 23

6/20/2014 006761335FLE 14K+ 15000 20 6/24/2014 006761339FLE 8-lOK 9000 25.3

7/11/2014 006761367FLE 7-8K 8000 26

7/16/2014 006761371FLE 7-8K 8000 29

7/19/2014 006761379FLE 8-lOK 9000 29 .1

7 /22/2014 006761385FLE 8-lOK 9000 20

7 /25/2014 006761394FLE 8-lOK 9000 20.8

8/1/2014 006761408FLE 8-lOK 9000 30.8

8/5/2014 006761410FLE 8-lOK 9000 25.1

8/6/2014 006761412FLE 10-12K 11000 20

8/8/2014 006761420FLE 8-lOK 9000 26

8/12/2014 006761425FLE 14k+ 15000 20

8/15/2014 006761437FLE 8-lOK 9000 20

8/22/2014 006761442FLE 8-lOK 9000 26.6

8/22/2014 006761444FLE 8-lOK 9000 25

8/26/2014 006761446FLE 8-lOK 9000 22 .53

8/29/2014 006761453FLE 8-lOK 9000 20.46

11/15/2014 006118525FLE 8-lOK 9000 25.1


Attachment 4 - Certificate of Liability Insurance

Figure 11 - Certificate of Liability Insurance

New Me)(ico Environment Depart ment

Hazardous Waste Facility Certificate of Liability Insurance

Advanced Chemica l Transport, Inc.

1210 Elko Drive

Sunnyvale, CA 94089

For Hazardous Waste Facility

1. Admiral Insurance Company, (the "Insurer"), of 1000 Howard Blvd #300, Mt Laurel NJ 08054 hereby certifies

that it has issued liability insurance covering bodily injury and property damage to Advanced Chemical

Treatment, Inc. (the "insured"), of 6137 Edith Blvd . NE, Albuquerque, NM 87107 in connection with the insured's

obligation to demonstrate financial responsibility under 40 CFR 264.147 or 265.147 as adopted by New Mexico

Administrative Code Title 20 Environmental Protection Chapter 4 Hazardous Waste Part 1 Hazardous Waste

Management sub-part 500, as applicable. The coverage applies at EPAlO# NMD 002208627; Advanced Chemical

Treatment, Inc.: 6137 Edith Blvd. NE, Albuquerque, NM 87107 for "sudden and non sudden accidental

occurrences" . The limits of liability are $4,000,000/$8,000,000 ("each occurrence "and" annual aggregate "limits

of the Insurer's liability), exclusive of legal defense costs. The coverage is provided under policy number FEl-EIL-

20469-00, issued by 10-17-14.The effective date of said policy is 10-17-14.

2. The Insurer further certifies the following with respect to the insurance described in Paragraphl,

(a) Bankruptcy or insolvency of the insured shall not relieve the Insurer of its obligations under the policy.

(b) The Insurer is liable for the payment of amounts within any deductible applicable t o the policy, with a right of

reimbursement by the insured for any such payment made by the Insurer. This provision does not apply with

respect to that amount of any deductible for which coverage is demonstrated as specified in 40 CFR 264.147(f)

or 265.147{f).

(c) Whenever requested by the Secretary of the New Mexico Environmental Department or his/her designee, the

Insurer agrees to furnish to such individual assigned duplicate origina l of the policy and all endorsements.

(d) Cancellation of the insurance, whether by the insurer, the insured, a parent corporation providing insurance

coverage for its subsidiary, or by a firm having an insurable interest in and obtaining liability insurance on behalf

of the owner or operator of the hazardous waste management facility, will be effective only upon written notice

and only after the expiration of60 days after a copy of such written notice is received by the Regional

Administrator(s) of the EPA Region(s) in which the facility(ies) is (are) located.

(e) Any other termination of the insurance will be effective only upon written notice and only afterthe expiration of

thirty (30) days after a copy of such written notice is received by the Secretary of the New Mexico

Environmental Department or his/her designee in which the facility(ies) is (are) located.

I hereby certify that the wording of this instrument is identical to the wording specified in 40 CFR 264.151U) as

adopted by such regulation and the New Mexico Administrative Code Title 20 Environmental Protection Chapter

4 Hazardous Waste Part 1 Hazardous Waste Management sub-part 500, as applicable, was constituted on the

date first above written, and that the Insurer is licensed to transact the business of insurance, or eligible to

provide insurance as an excess or surplus lines insurer, in one or more States.

·v~ ~ (Signature of Authorized Representative of Insurer) Date top 1/z cJ If David Brereton

Program Manager, Freberg Environmental Inc.

Admiral Insurance Company

2000 South Colorado Blvd. Tower II #800 Denver CO 80222

~ ---==--1,Notary Signature) _ Sandy Spencer_My commission Expires ¥, .)'/ 4;.


Attachment 5 - ACTreatment Pre-Application Public Meeting

Figure 12 - Albuquerque Journal order confirmation

ALBUQUERQUE JOURNAL THE SUNDAY JOURNAL lQJ2J25 Albuquerque Publishing Company

7777 Jefferson N.E. Albuquerque. New Mexico 87109 P.O. Drawer J-T Albuquerque, New Mexico 87103

(505) 823-7777

Ad Proof I Order Confirmation

ADVANCED CHEMICAL TRANSPORT 6137 EDITH BLVD. NE ALBUQUERQUE NM 87107

Ordered By

Customer EMail

Tax Amount

Total Amount

Nichole Gwash

$80.50

$5.64

$86.14

Amount Due $86.14

Product Albuquerque Journal

Customer Phone 505-349-5220

PO Number

cwh ite

Order Taken by : cwhite

Payment Method

Payment Amount $0.00

Legal Notices

£S£JQ£t2Z

Account Number

1058149

Ad Order Number

0001161411

Ad Number 0001161411.()1 Ad Type APC-Legals

Ad Size : 1 .0 X 50 Li

Placement

Classification

Sort Text

NoniJovernment.QOO 1 PARTBRENEWALAPPLICATIONPUBLIC INFORMATIONMEETINGHAZARDOUS

<NONE> 7/21/2014, 7/22/2014, 7/2312014

Affidavits

0

7/1812014 4 :13:48PM

ACT PART B RENEWAL

APPUCUIOM PUBLIC INRlRMATION lllEETirtG

HazardoltS W;i~o Parmll Renewal 6131 Edlh Bl•d. ~E.. -'lbUC!Jtl\l'll, M1'111 07

Tlmday. A•1uot 28. 2011 5.-30-•::i~P~A

Whot I• It •bout?

The penrit rtnewa1 li>r M<ara<I Ch1mca1Treatn:.E!!ll.

Wh!I?

The p.i-ol lhe mooing is.,

~~~.!t~::::m":::;:,u~ 1>rcpostd hazaRbus~ultmai · ogemm .ai;il .. lncl.Jded In lht ce1111i11~l tJp~i;alion Sor Actr.Jrad Chelrica!Troatrr...,,.

tf )'OUhillllGIJ95.ion;, p&~ CU\~ur.:

Mfill<»dCh""'<il Triilrn>n~ Ann: Pu~b l:domr.On kilffting. 6137Etlth li!Yd., NE .. At;,,.1uo~ que. 1111147107 505-31g.=

tt you 'tiil netd splCli:lasliiiUr.l::li p~CXl"ll3~ ut 3l lo3!il 72 hr:T.Jffl prior 1o tht rnHling lo- m.;J(e 1'/Ufltl~t


Attachment 5 - ACTreatment Pre-Application Public Meeting, continued

ALBUQUERQUE JOURNAL Tiffi SUNDAY JOURNAL

2iiiiQ!§& Albuquerque Publishing Company £tQ!jiJ2S 7777 Jeffel!IOtl N.E. Albuquerque, Now Mexko 87109

P.O. Drawerl-T Albuquerque, New Mexico 87103

ACT PART B RENEWAL

APPUCA TION PUBLIC INFORMATION MEETING

Hazardous Waste Permit Renewal 6137 Elith Blvd N.E., Albucµiruqe, NM 87107

Thl!Sday, August 28, 2014 5:30-6:30 PM

WMt is it about?

The p&miit renewal fa Advarctd D'lemktil Tret:ilment.

Why?

The purpose of the meeting is lo solicl ~utstions from the community and inform the community on proposed hazarOOus waste management activities included in the r1W1ewal appMcation for Advanc&d Olemical Treatment.

If you nave questions, please contact us:

Advanced Chemical Treatmenl Attn; Public lnformaticin Meeting, 6137 Elith Blvd, N.E .. Albuquerquo, NM 67107 505-349-5220

If you wil need special assistance please contact us <it least 72 hours prior to the meeting lo malc.11 anangments.

Laam mora: The existing pennit can be found on the NMED Hazc:irdous Wasle Bureau. Website: http://www.nmenv.stabt.nm.usiHW Blrinperm.hlml Joom•I: JLlv 21. 22. 23, 2014

7/18/2014 4:13:48PM

(505) 82J-7777


Ad Proof I Order Confirmation

Account Number

1058149

Ad Order Number

0001161411

ADVANCED CHEMICAL TRANSPORT

2

Page 67 of 82

Attachment 5 - ACTreatment Pre-Application Publ ic Meeting, continued

Figure 13 - Albuquerque Journal order mailing notice

AFFIDAVIT OF PUBLICATION

STATE OF NEW MEXICO County of Bernalillo SS

Linda MacEachen, being duly sworn, declares and says that she is Classified Advertising Manager of The Albuquerque Journal, and that this newspaper is duly qualified to publish legal notices or advertisements within the meaning of Section 3, Chapter 167, Session Laws of 1937, and that payment therefore has been made of assessed as court cost; that the notice, copy of which is hereto attached,

was P)l,b~~ in - ap in the regular daily ;,~on, for -~ times, the first publication being on

the ,;Lt':=, y of , 2q_, and the suosj<{t consecutive publications on o/ dk3 20 ' .

Sworn and subscribed before me, a Notary Public, in and

J'j7th~<#~e · oandStateofNewMexico1~ C?(iL aay of ---------,- of 2Dl+'.-.

OFFICIAL SEAL

Sandra B. Gutierrez

4 -----r--.._ PRICEgz. .(cf ~,~..__

Statement to come at end of month.

ACCOUNT NUMBER __,f._~___,5"'-~~J'--)tL-1--f __ I



Figure 14 - Clear Channel Receipt / Purchase Confirmation

James M. Kapin

From:

Sent: To:

CC Research <[email protected]>

Tuesday, July 22, 2014 8:40 AM Nichole Gwash

Subject Clear Channel Broadcasting Inc. Customer Receipt/Purchase Confirmation

-This email is sent from an unmonitored email address. For any inquiries concerning this transactions, please contact [email protected]

Thank you for your order!

Order Information ~ '

Merchant: Clear Channel Broadcasting Inc.

Invoice Number: ONEW PO Number: 241

Bllll•g Iofor•atlo• ACT 94089 [email protected]

Shipping l•formatloo

Total: US $10. 70

MasterCard : , " :

Dateffime:

Transaction JD:

22-Jul-2014 9:39:58 MDT

6353397661



Figure 15 - Clear Channel broadcast information

Spot Times Spot rmes - Ac:tuar

Dale Range: tan 07l25'2014 lo0112&2014; Slalus: Venlied; Adverisefs:AdvancedChemK31 Treabnent NJbil: Inc.Ute Al; Repof1 Header. fill Page; Tme Foonat t."lal)' Toe;

Line No. Station Title

Advertiser. Advanced Chemical Tntament (1 spo~

Order No.: 129823 (1 spo~ ACT PUBLK: NOTICE 2014

Plinlcd: 07/25120H 09:58

ISCI Code

PDF created with pdfFactory trial version www.pd!fac!orv com


Status Actual...

Verilod Fri

Actual Oat Actual Tin

0712512014 61953

Pago1 Of1

Page 70 of 82

Attachments - ACTreatment Pre-Application Public Meeting, continued

Figure 16 - Photos of visible and accessible signage

NOTICE OF PART B RENEWAL APPLICATION PUBLIC INFORMATION MEETING Thursdav, August 28, 2014 • 5:30-6:30 P

6137 Edith Boulevard, N.E. - Albuquerque, HM 87107 Adv$1Clld~ffNtmttithr.<Uo~ly~~PMt.8ptorrrit,whl(hctret,,1 lw"*(pc(trumc.9mW'aft mMrA)iJOUOd~t~fotWtf\~...,~W.ntn.Aln.,.rtf!~VIW1W is~rvdltll'M.a; bOn 11~e1\powl~in. Thkrhcdingdc~lk-~

• Olltuucon1i;fJfo/,.._,.,,;,ntH:Wtlil.,plk_t1tlon

"SolJckqun"'°"'*MfllnfOlmQft~ fllftHtK~INuerddU11 lllNlt•~O(fM#ft • °"1ctfbf flH 11pit:Ortli"'1~PtW~.U


Attachment 5 - ACTreatment Pre-Appl ication Public Meeting, continued

Figure 17 - Copy of letter sent to the permitting agency and appropriate units of State and local government

Adv need Ctiemlcal TNatment

August 7, 2014

RE: Notice of Public Meeting; Renewal Application for Advanced Chemical Treatment, Inc. EPA ID# NMD002208627-1

To Whom It May Concern :

Advanced Chemical Treatment, Inc. (ACTreatment) will be holding a public information meeting prior to the submittal of a Class 3 Perm it Renewal. ACTreatment currently holds a Part B permit which offers a broad spectrum of environmentally sound management technologies for both hazardous and non-hazardous wastes. At our site, waste is consolidated for final disposition at reputable disposal facilities. This meeting will cover the following:

Discuss content of permit renewal application Solicit questions and inform attendees of the proposed hazardous waste management activities Describe the upcoming review process

Meeting Information Date: Thursday, August 28, 2014 Location: 6137 Edith Boulevard N.E., Albuquerque, NM 87107 Time: 5:30 PM to 6:30 PM

If you have questions or need special assistance to participate In this meeting, please contact us at least 72 hours before the meeting so that special arrangements can be made :

Advanced Chemical Treatment Attn: Public Information Meeting 6137 Edith Boulevard. N.E. Albuquerque, NM 87107 505-344-7985

Regards,

Shawn Moudy General Manager Advanced Chem lcal Treatment

6133Ed1th G'vd NE /1lbucuerque NM 87 '07 G JAIN (~CVi) '3,19 'i//O 'A\ (505) 3~9-'i/'.l1 Wf F,', fi www arlvancerlchen1rcal net

ACTreatment RCRA Part B Permit Appl ication Page 72 of 82

Attachment 5 - ACTreatment Pre-Application Publ ic Meeting, continued

Figure 18 - Sign-in-sheet from the meeting

ACT SIGN IN SHEET

Public Meeting - Renewal Application for Advanced Chemical Treatment. Inc

Thursday. August 28. 2014

6137 Edith Boulevard N.E .• Albuquerque. NM 87107

PAGE_or_


NOTICE OF PART B RENEWAL APPLICATION ACT PUBLIC INFORMATION MEETING Thursday, August 28, 2014 • 5:30-6:30 PM

1137Edllll~11.!.-AI ........ , •11107 ~Ownbln.m...,ln(.~haldl•hrt8pirrM.wtlkt1G99fll•bfoldJPl(lnllllaftiWlron

~sound~~,_b!Mh.,..,...and-.~ ...... M--...... -~-.... d~.11NpUtll:MdkpoMlfldtlltl.Thlr.m.tingwll=-lhew-&ig: . Ollc.-_,.,e#,,..,.,,,__.~ . ~ ...... IMJ/,.,.,.........-at1•,_,,.a4-----.. .....,.,__..atvftfm . Daaa.1•.-........ ,,....

6'/fW~~orM!tfli,_..,ouill'cnu.ll!#W~ .. -.Arcotw°"*'""--..•""'"'..:sos.J.ff..ll»

Page 73 of 82


Figure 19 - PowerPoint presentation given at the meeting

PowerPoint Presentation Handout Title

CT Hazardous Waste Permit

Renewal Application

Welcome!

• Introduction

Public lnrorrnalion Meeting August 28, 2014

- Pasquale Paduano - Operations Director

- Shawn Moudy - Genera/ Manger

- Bill Littleton - Operations Manager - Krista Harsono - Compliance Director

Restrooms & Exit

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Agenda

• Welcome and agenda

• Purpose of meeting and NMED requirements

• Property information and pictures

• Management activities

• Questions

• Close

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Purpose of Meeting

• Discuss permit renewal request to modify the storage capacity on-site from 55,000 gallons to 244,000 gallons.

• Solicit questions from the community and inform the community of content of renewal application.

!!.CJ. ----

NMED Requirements for Permit Renewal & Public Meeting

• The initial permit became effective 3/12/02.

• Renewal is required every 10 years.

• Public meeting is required for all RCRA part B renewal applications which qualify as a class 3 permit modification under 40 CFR 270.42. -ACTreatment is proposing to modify the facility's

capacity to 244,000 gallons

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Page 75 of 82



Property Details

2.43 acre facility

Warehouse

Office

Six waste Storage Rooms Loading/Unloading docks

Underground storage tank

Rainwater containment areas

Facility Permitted Areas

Room A - temperature controlled (unused at this lime) Room B - temperature controlled for or9i1nlc and Inorganic dlemlc:als Room C - flammables, empty drums & totes Room oHammables/combustlbles Room E - non-regulated m aterlal, caustics/basics Room Fadds/toxlcsfoxldlzers

A.CJ. ----

Room Size & Storage Capacity

Room I size

1125'x50' 25'x50' 100'x50' 100'x50'

-

110'x50' 110'x50' -'u:;:

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Storage Capacity 15,840 gal 15,840 gal 79,860 gal 73,900 gal 81,800 gal 81,800 gal 349,040 gal 244,000eal

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Page 76 of 82

Attachment 5 - ACTreatment Pre-Appl ication Public Meeting, continued


Permitted Areas

Room C RoomB

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Permitted Areas

Room C Room D

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Management Activities

• Solid waste consolidation

• Liquid waste consolidation

• Lab pack chemical consolidation

• Universal/ E-Waste consolidation

• Household hazardous waste collection site

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Page 77 of 82



Closing

• Chanse comes from modified quantity of waste to be manased on-site (from 55,000 sallons to 244,000 sallons). Which qualifies it as a Class 3 permit renewal.

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Questions?

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Page 78 of 82

Attachment 6 - RCRA Part B Permit Regulatory "Crosswalk"

Table 6 - ACTreatment RCRA Part 8 Permit Application Regulatory "Crosswalk"

Cltatlon(s) - Description of Requirement Section#

40 CFR:

§264 Subpart G Closure and post-closure 9

§264.1033 Process vent standards NA

§264.1052 Equipment leak air emission standards NA

§264.1053 Compressor standards NA

§264.1058 Standards for pumps, valves, pressure relief devices, flanges, NA and connections

§264.13(b) Development and implementation of a written waste analysis 4.2, WAP plan

§264.13(c) Off-site waste analysis requirements 4.2, WAP

§264.14 Security procedures and equipment 2.8

§264.lS(b) General inspection schedule 3

§264.16 Personnel training program 7

§264.17 Procedures to prevent accidental ignition, reaction of 4.3 ignitables, reaction of reactives, reaction of incompatibles, and documentation of compliance with 40 CFR §264.17 (general requirements for ignitable, reactive, or incompatible wastes)

§264.174 Inspections/containers 3

Storage of Ignitable and Reactive Waste within 50 feet of 4.3.1 §264.176 Property Line

§264.178 Closure of containment systems 9.6, 9.7

§264.18(a) Seismic considerations 8.1

§264.195 Overfill control inspections NA

§264.197 Closure and post-closure care/tanks NA NA

§264.226 Surface impoundment monitoring and inspection NA

§264.227 Surface impoundment emergency repairs NA

§264.228 Surface impoundments NA

§264.254 Waste pile monitoring and inspection NA

§264.258 Waste piles NA

§264.273 Land treatment and operating requirements NA

§264.280 Land treatment NA

§264.303 Landfill monitoring and inspection NA

§264.30-37 Preparedness and prevention : applicability, design and 5 operation, required equipment, test ing and maintenance of equipment, access to communications or alarm systems, required aisle space, and arrangements with local authorities

§264.310 Landfills NA

ACTreatment RCRA Pa rt B Permit Application Page 79 of 82

Attachment 6 - RCRA Part B Permit Regulatory "Crosswalk, continued


40 CFR:

§264.351 Incinerators NA

§264.50-56 Contingency plan and emergency procedures: applicability, 6 purpose/implementation of contingency plan, content of contingency plan, copies of contingency plan, amendment to contingency, emergency coordinator, and emergency procedures

§264.603 Requirements by the Secretary NA

§270.14(b)(l) General facility description 2

§270.14(b)(10) Traffic pattern: volume, controls, and access 2.7

§270.14(b){11) Facility/unit identificat ion and location information 8.1

§ 2 70.14(b)(11 )( i) Seismic standard applicability [40 CFR §264.18(a)] 8.1

§270.14(b )( 1 l){ii) Seismic standard requirements 8.1

§270.14(b )( ll)(ii)(A) No fault within 3,000 feet (ft) with displacement in Holocene 8.1 time

§270.14( b )( ll){ii)( B) If faults which have displacement in Holocene time are present 8.1 within 3,000 ft, no faults pass within 200 ft of portions of t he facility where treatment, storage, or disposal will be conducted

§270.14( b )( 1 l)(iii) 100-year floodplain standard 8.2

§270.14( b )( 1 l){iv)(A- Facilities located within the 100-year floodplain 8.2 C)

§270.14(b)(ll)(v) Compliance schedule for 40 CFR §264.18(b) 8.2

§270.14(b)(12) Personnel training program 7

§270.14(b)(13) Closure and post-closure plans 9

§270.14(b)(14) Deed restrictions/post-closure notices (40 CFR §264.119) 9.16

§270.14(b)(15) Closure cost estimate (40 CFR §264.142) NA, 9.11

§270.14(b)(16) Post-closure cost estimate (40 CFR §264.144) NA, 9.15

§270.14(b)(17) Liability insurance (40 CFR §264.147) 9.10

§270.14(b)(18) Proof of financial coverage (40 CFR §264.149-150) 9.11

§270.14(b)(19) Topographic map requ irements Figures 6 &7

§270.14(b)(19)(i) Map scale and date Figures 5,6,7 &8

§270.14( b )(19)(ii) 100-year floodplain area Figure 7

§270.14( b )(19)(iii) Surface waters Figure 6 &7

§270 .14(b )( 19)(iv) Surrounding land uses Figures 5,6,7 &8

§270.14(b)(19)(ix) Wells Figure 4

§270.14(b)(19)(v) Wind rose Figure 6




40 CFR: &7

§270.14( b )(19)(vi) Map orientation Figures 5,6,7 &8

§270.14(b )( 19)(vii) Legal boundaries Figure 5

§270.14(b)(19)(viii) Access control Figure 5

§270.14(b)(19)(x) Buildings Figure 5

§270.14(b)(19)(xi) Drainage barriers or flood control Figure 5 &7

§270.14(b )( 19)(xii) Location of operational units Figure 5

§270.14(b)(2) Chemical and physical analyses of hazardous waste 4.1

§270.14(b)(20) Considerations Under Federal Law NA

§270.14(b)(21) Notice of extension approval for land disposa l facilities NA

§270.14(b)(22) A summary of the pre-application meeting 10

§270.14(b)(3) Waste analysis plan 4.2, WAP

§270.14(b)(4) Security procedures and equipment 2.8

§270.14(b)(5) General inspection schedule 3

§270.14(b)(6) Request for waiver from preparedness and prevention NA requirements of 264 Subpart C

§270.14(b)(7) Contingency Plan Section 6

§270.14(b)(8) Description of preparedness and prevention 5

§270.14(b)(8)(i) Hazard prevention in unloading operations 5

§270.14(b)(8)(ii) Runoff prevention 5

§270.14( b )(8)(iii) Prevent contamination of water supplies 5

§270.14(b)(8)(iv) Mitigation of equipment failure and power outages 5

§270.14(b)(8)(v) Prevention of undue exposure of personnel to hazardous 5 waste Section 2.5 .7

§270.14(b)(8)(vi) Prevention of releases to the atmosphere 5

§270.14(b)(9) Prevention of accidental ignition or reaction of ignitable, 4.3 reactive, or incompatible wastes

§270.14(c) Groundwater monitoring requirements 12

§270.14(c)(3) Topographic map with points of compliance Figure 5 &7

§270.14(c)(3) Proposed location of groundwater monitoring wells NA

§270.14(c)(4) Description of plume of contamination that has entered the NA groundwater from a regulated unit at the time the application was submitted

§270 .14(c)(4)(i) Extent of plume indicated on topographic map NA

§270.14(c)(4)(ii) Identification of constituents and concentration NA




40 CFR:

§270.14(c)(5) Detailed plan and engineering report describing proposed NA groundwater monitoring program

§270 .14(c)(6) If no release detected at date of submitted, then submit NA following NA

§2 70.14( c)( 6)( i) List of proposed indicator parameters, waste constituents, and NA reaction products

§2 70.14( c)( 6)( ii) Proposed groundwater monitoring system 12

§270.14( c)( 6)( iii) Background values for each proposed monitoring parameter 12

§270.14(c)(6)(iv) Description of proposed groundwater sampling, analysis, and 12 statistic comparisons to be used

§270.14(c)(7) If a release is detected at the point of compliance, then NA corrective actions

§270.14(d) Information requirements for SWMUs 11

§270.14( d)( l)(i) Location of SWMUs on topographic map 11

§270.14( d)( l)(ii) Types of SWMUs 11

§270.14( d)( l)(iii) Dimensions and descriptions of SWMUs 11

§270.14(d)(l)(iv) Dates of SWM U operations 11

§270.14(d)(l)(v) Waste types managed at SWMUs 11

§270.14(d)(2) Information on releases from SWMUs 11

§270.14(d)(3) RCRA Facility Assessment sampling and analysis results 11

§270.15 Information requirements for containers 2.5

§270.3 Considerations under Federal law. 13

§270.3(a) Wild and Scenic Rivers Act 13 .1

§270.3(b) National Historic Preservation Act 13.2

§270.3(c) Endangered Species Act 13.3

§270.3(d) Coastal Zone Management 13.4

§270.3(e) Fish and Wildlife Coordination Act 13.5

§270.3(f) Executive Orders 13.6


ACTreatment Facility Operations Manual

Date: November 26, 2014

Albuquerque, NM 87107 505-349-5220

Received

JEC - 5 2014

District l

ACTreatment Facility Operations Manual

Table of Contents Facility SOP 1 - Facility Overview .............................................................................................. 1

1.1. Policy .................................................................................................................................. l 1.2. Purpose .............................................................................................................................. 1 1.3. Facility Description ............................................................................................................ 1 1.4. Responsibilities .................................................................................................................. 1 1.5. Operational Manual Organization ..................................................................................... 2 1.6. Updates and modification of ACTreatment Facility Operations Manual .......................... 2 1.7. ACTreatment Facility Operations Manual Change Log ...................................................... 3

Facility SOP 2 - ACTreatment Employee Training ....................................................................... 4

2.1. Initial Facility Orientation Course Contents ....................................................................... 4 2.2. OSHA HAZWOPER Hazardous Materials Technician/TSO Worker Course Contents ........ .4 2.3. OSHA 8-Hour Refresher Course Contents ......................................................................... 5 2.4. DOT Hazardous Materials Transportation Training Course Contents ............................... 5 2.5. Training Records ................................................................................................................ 5

Facility SOP 3 - Contractors and Contractor Training ................................................................. 6

Facility SOP 4 - Receiving of Waste Shipments .......................................................................... 8

4.1. Weigh Containers .............................................................................................................. 8 4.2. Perform QC Check .............................................................................................................. 8 4.3. Waste Storage .................................................................................................................... 9 4.4. Records Update ................................................................................................................. 9

Facility SOP 5 - Uniform Hazardous Waste Manifest Management .......................................... 12

5.1. Regulatory Requirements ................................................................................................ 12 5.2. Inspection Steps ............................................................................................................... 12 5.3. Discrepancy Management ............................................................................................... 13 5.4. Good Documentation Practices ....................................................................................... 14 5.5. Manifest Recordkeeping and Retention .......................................................................... 14

Facility SOP 6 - Shipment Unloading ....................................................................................... 16

6.1. Prepare Truck for Unloading ............................................................................................ 16 6.2. Dock Truck ....................................................................................................................... 16 6.3. Unloading the Trailer and Staging Waste ........................................................................ 17

Facility SOP 7 - Hazardous Materials/Waste Storage Requirements ......................................... 18

7.1. General ............................................................................................................................ 18 7 .2. Waste Storage Rules ........................................................................................................ 18 7.3. Waste Segregation ........................................................................................................... 18

Facility SOP 8 - Description of Procedures, Structures or Equipment for Hazard Prevention ..... 20

8.1. Design and operation of facility ....................................................................................... 20 8.2. Spill Prevention ................................................................................................................ 20 8.3. Prevention of Hazards during Unloading Operations ...................................................... 21 8.4. Prevention of Flooding and Run-Off from Waste Handling Areas ................................... 22 8.5. Prevention of Water Supply Contamination ................................................................... 22

Page i

ACTreatment Facility Operations Manual - Table of Contents

8.6. Mitigation of Effects of Equipment Failures and/or Power Outage ................................ 22 8.7. Prevention of Undue Exposure of Personnel to Hazardous Waste ................................. 22 8.8. Prevention of Releases to the Atmosphere ..................................................................... 23 8.9. Employee Training ........................................................................................................... 23

Facility SOP 9 - Compactor Operations ................................................................................... 24

9.1. Pre Operation Instructions .............................................................................................. 24 9.2. Operating lnstructions ..................................................................................................... 24 9.3. Container Replacement ................................................................................................... 24

Facility SOP 10 - Shredder Operations ...................................................................................... 25

10.1. Pre Operation Instructions .............................................................................................. 25 10.2. Operating lnstructions ..................................................................................................... 25 10.3. Container Replacement ................................................................................................... 25

Facility SOP 11 - ACTreatment Facility Contingency Plan ........................................................... 26

11.1. Facility Identification and General Information .............................................................. 26 11.2. Type of Facility ................................................................................................................. 26 11.3. Copies of Contingency Plan ............................................................................................. 26 11.4. Arrangements with Local Authorities .............................................................................. 26 11.5. Emergency Coordinators: ................................................................................................ 26 11.6. Implementation of the Contingency Plan ........................................................................ 27 11.7. Emergency Response Procedures .................................................................................... 28 11.8. Notification of Situations Which Could Threaten Human Health or the Environment

Outside of the Facility ...................................................................................................... 30 11.9. Following Attainment of Control ..................................................................................... 30 11.10. Prevention of Recurrence or Spreading of an Incident ................................................... 31 11.11. Emergency Equipment ..................................................................................................... 31 11.12. Required Reports ............................................................................................................. 32 11.13. Amendment of Contingency Plan .................................................................................... 33

Facility SOP 12 - Selection and Scheduling of Waste Shipments ................................................. 35

12.1. Request Drop Appointment from Final TSO .................................................................... 35 12.2. Generate Pick List ............................................................................................................ 35 12.3. Pick Waste ........................................................................................................................ 35 12.4. Consolidate I Stage Waste Locate to Staging Area ......................................................... 35 12.5. Manifest I LOR I Labels I Marking (SOOl00-1) ................................................................ 35 12.6. Piece Count ...................................................................................................................... 36 12.7. Load Waste per Shipment Loading SOP .......................................................................... 36 12.8. Manifest Signatures ......................................................................................................... 36 12.9. Placarding ........................................................................................................................ 36

Facility SOP 13 - Shipment Loading ........................................................................................... 37

13.1. Prepare Truck for Loading ............................................................................................... 37 13.2. Inspect the dock ............................................................................................................... 37 13.3. Dock Truck ....................................................................................................................... 37 13.4. Loading the Trailer ........................................................................................................... 38

Facility SOP 14 - TSO Labeling Requirements of Hazardous Waste ............................................. 39

14.1. General ............................................................................................................................ 39 14.2. Labels Required ............................................................................................................... 39

Facility SOP 15 - TSO PPE General Requirements ....................................................................... 42

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ACTreatment Facility Operations Manual -Table of Contents

15.1. General ............................................................................................................................ 42 15.2. Training ............................................................................................................................ 42 15.3. Hazard Assessment .......................................................................................................... 42 15.4. Categories ........................................................................................................................ 43 15.5. Cleaning & Maintenance ................................................................................................. 44 15.6. Personal Protective Equipment Assessment Form .......................................................... 44

Facility SOP 16 - TSO Facility Inspections .................................................................................. 49

16.1. General ............................................................................................................................ 49 16.2. Daily lnspections .............................................................................................................. 49 16.3. Weekly lnspections .......................................................................................................... 49 16.4. Monthly Inspections ........................................................................................................ 50 16.5. Annual Inspections .......................................................................................................... 50 16.6. Inspection Procedure ....................................................................................................... 50

Waste SOP 1 - Waste management SOP - Aerosols ...........••••••..........•••••.........•.••••.•.........•••••• SS

1.1. Safety- General ............................................................................................................... 55 1.2. Waste Description/ Qualification ................................................................................... 55 1.3. Quality Control ................................................................................................................. 55 1.4. Receiving .......................................................................................................................... 56 1.5. Storage ............................................................................................................................. 56 1.6. Processing ........................................................................................................................ 56

Waste SOP 2 - Battery Wastes (Universal Waste) ••••.••......•....••••••..........•••••......•...•••••...........•• S9

2.1. Safety- General ............................................................................................................... 59 2.2. Waste Description I Qualification ................................................................................... 59 2.3. Quality Control ................................................................................................................. 59 2.4. Receiving .......................................................................................................................... 60 2.5. Storage ............................................................................................................................. 60 2.6. Processing instructions .................................................................................................... 60

Waste SOP 3 - Electronic Wastes (Universal Waste) ••........••••••••.........••.•••...•....•.••••••........•••••• 63

3.1. Safety- General. .............................................................................................................. 63 3.2. Waste Description I Qualification ................................................................................... 63 3.3. Quality Control ................................................................................................................. 63 3.4. Receiving .......................................................................................................................... 64 3.5. Storage ............................................................................................................................. 64 3.6. Processing instructions .................................................................................................... 64

Waste SOP 4 - Labpack Consolidation ..••••••••.........••••••••...•.....••••••••.....••••••••....•.•••••••••..•.•••••••• 66


Waste SOPS - Lamp Wastes (Universal Waste) ••••••••••..••••••.••••••..•••••••••••.•••••••••••.•••.••••••••••••••• 71

5.1. Safety-General ............................................................................................................... 71 5.2. Waste Description I Qualification ................................................................................... 71 5.3. Quality Control ................................................................................................................. 71 5.4. Receiving .......................................................................................................................... 72

Page iii

ACTreatment Facility Operations Manual -Table of Contents

5.5. Storage ............................................................................................................................. 72 5.6. Processing instructions .................................................................................................... 72

Waste SOP 6 - Landfill Liquids ............................................................................................... 75

6.1. Safety- General. .............................................................................................................. 75 6.2. Waste Description I Qualification ................................................................................... 75 6.3. Quality Control ................................................................................................................. 75 6.4. Receiving .......................................................................................................................... 76 6.5. Storage ............................................................................................................................. 76 6.6. Processing instructions .................................................................................................... 76

Waste SOP 7 - Landfill Solids ..••••••••...........•.••••••.............•••••••.•........•..•••••••....•......••••••••......•.. 79

7.1. Safety-General ............................................................................................................... 79 7.2. Waste Description/ Qualification ................................................................................... 79 7.3. Quality Control ................................................................................................................. 79 7.4. Receiving .......................................................................................................................... 80 7.5. Storage ............................................................................................................................. 80 7 .6. Processing instructions .................................................................................................... 80

Waste SOP 8 - Liquid Fuels ..••••............•••••••.•...........•••••.••.........•••••••••••......•••.••••••.......••••••••••• 83


Waste SOP 9 - Low BTU organic Liquids .......•••••••.............•••••••••...........••••.•..........•••••••.•......... 88


Waste SOP 10 - Mercury Wastes ....•••••••••••......••••••••••••.......•••••••••••••...•...••••••••••...•...•••••••••••..... 93

10.1. Safety- General. .............................................................................................................. 93 10.2. Waste Description/ Qualification ................................................................................... 93 10.3. Quality Control ................................................................................................................. 93 10.4. Receiving .......................................................................................................................... 94 10.5. Storage ............................................................................................................................. 94 10.6. Processing instructions .................................................................................................... 94

Waste SOP 11 - Non-Consolidation Wastes (DIDO) •••••••........•••••••••.......•..••••••.........••••.•..•........ 97

11.1. _safety- General ............................................................................................................... 97 11.2. Waste Description I Qualification ................................................................................... 97 11.3. Quality Control ................................................................................................................. 97 11.4. Receiving .......................................................................................................................... 98 11.5. Storage ............................................................................................................................. 98 11.6. Processing instructions .................................................................................................... 98

Waste SOP 12 - Solid Fuels ..........•.•.•...........••••............••••••...........•••••..........••••••.......•••••••...... 100

12.1. Safety-General ............................................................................................................. 100

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ACTreatment Facility Operations Manual - Table of Contents

12.2. Waste Description/ Qualification ................................................................................. 100 12.3. Quality Control. .............................................................................................................. 100 12.4. Receiving ........................................................................................................................ 101 12.5. Storage ........................................................................................................................... 101 12.6. Processing instructions .................................................................................................. 101

Waste SOP 13 - Waste Oil ..................................................................................................... 104

13.1. Safety- General ............................................................................................................. 104 13.2. Waste Description I Qualification ................................................................................. 104 13.3. Quality Control ............................................................................................................... 104 13.4. Receiving ........................................................................................................................ 105 13.5. Storage ........................................................................................................................... 105 13.6. Processing instructions .................................................................................................. 105

Waste Analysis Program (WAP) .............................................................................................. 108

WAP Section 1- General Requirement of the WAP .................................................................. 108 WAP Section 2 - Waste Documentation, Review and Approval Process .................................. 108 WAP Section 3 - Physical Acceptance of Waste ........................................................................ 111 WAP Section 4 - Inspection and Sampling of Waste ................................................................. 112 WAP Section 5 - Waste Processing ........................................................................................... 116 WAP Section 6 - Waste Shipment ............................................................................................. 117 WAP Section 7 - Waste Sample Collection Methods ................................................................ 117 WAP Section 8 - Discrepancy Criteria For On-Site Waste Acceptance Evaluation .................... 119

Page v

Facility SOP 1 - Facility Overview

1.1. Policy

It is ACTreatment policy that no job is so important that we cannot take time to perform our work safely and in an environmentally conscientious manner. ACTreatment personnel must implement the applicable provisions of this document to ensure that employee safety is kept as a top priority.

1.2. Purpose

This manual is intended to provide guidance and instruction concerning ACTreatment operations. It is the responsibility of ACTreatment personnel to adhere to the guidelines presented in this manual.

1.3. Facility Description

Advanced Chemical Treatment, Inc. (ACTreatment) is located at 6137 Edith Boulevard N.E., Albuquerque, NM 87107 in Bernalillo County (EPA ID# NMD002208627). ACTreatment manages a treatment, storage and disposal facility for hazardous waste products and also acts as the City of Albuquerque's household hazardous waste collection depot. Services include:

• Solid waste consolidation • Liquid waste consolidation • Lab pack chemical consolidation • Universal/ E-Waste consolidation • Household hazardous waste management • Empty drum crushing

Wastes are sent for further recycling, incineration, landfill, wastewater treatment, transport, and/or disposal at a permitted TSDF.

1.4. Responsibilities

1.4.l. Executive Management -

Executive management has the ultimate responsibility for the implementation of this program at ACTreatment. Executive management has assigned responsibilities to the following individuals in order to implement and maintain this program.

1.4.2. General Manager

The General Manager will ensure that all elements of this plan are implemented and maintained.

1.4.3. TSDF Operations Manager

The TSDF Operations Manager is responsible for the following:

• Provide program oversight; • Ensure that no employees perform work outlined in this program without proper

training; • Coordinate and supervise required recordkeeping; • Provide training for each employee as required; • Complete a periodic evaluation of overall program; and

ACTreatment Operations Manual Page 1of119

• Coordinate required changes/improvements in the program.

1.4.4. Hazardous Waste Coordinator (HWC)

The Hazardous Waste Coordinator (HWC) coordinates waste consolidation and other waste management activities, including the following:

• Determining individual waste containers to be consolidated, based on waste profile and characteristics

• Modifying or updating list of containers identified for consolidation. • Reconciling consolidated containers in the WMSS in order to maintain an accurate

facility inventory

1.4.5. Employees

Employees are responsible for the following:

• Follow the procedures as outlined in this program; and • If any questions arise or you are unsure about performing any activity outlined in

this program, contact the TSDF Operations Manager.

1.5. Operational Manual Organization

This Facility Operations Manual consists of:

• Facility SOPS - Standard Operation Procedures (SOPs) that apply across the facility and describe standard practices for general operations

• Waste-specific SOPs - SOPs for specific types or categories of hazardous wastes • Waste Analysis Plan (WAP)

1.6. Updates and modification of ACTreatment Facility Operations Manual

This document will be modified or updated to address changes to applicable regulatory requirements, changes to business activities or otherwise as needed. All changes will be approved by ACTreatment Facility Manager and recorded in the document change log. The official version of this document will be maintained on ACT web site. Please refer to on-line version before placing reliance on printed versions.


1. 7. ACTreatment Facility Operations Manual Change Log

Date Description of Change Approved by

11/21/14 Document Creation SM


Facility SOP 2 - ACTreatment Employee Training

The primary objective of the facility's training program is to instruct employees in the practices, procedures and rules regarding safe operation in accordance with applicable State and Federal regulations. The training program requires training in safety, proper transport and response to hazardous waste emergencies. These classes are conducted inhouse by an employee trained in hazardous waste management procedures and/or outside training providers. The instruction is in the form of classroom instruction and onthe-job training.

All new employees who manage hazardous waste shall complete the initial training courses within six months from their date of hire or from the date of transfer of job assignment. Personnel shall not work unsupervised in their positions until they have completed the training. Annually, all personnel who manage hazardous waste must participate in a minimum of eight hours of refresher/review of the initial training.

All TSD employees will receive initial OSHA HAZWOPER training as required under subpart (p) and subpart (q) of 29 CFR 1910.120 and annual refresher training, as described below, as well as DOT hazardous materials transport training. Courses which satisfy all or part of the training include, but are not limited to:

• • • • •

Initial Facility Orientation OSHA HAZWOPER Hazardous Material Technician (29 CFR 1910.120(q)(6)) OSHA HAZWOPER TSO Worker (29 CFR 1910.120(p)(7)) OSHA 8-hr HAZWOPER Refresher DOT Hazardous Materials Transportation Training

The training shall consist of lectures, discussions, examinations and on-the-job training.

2.1.

• • • • • • • • • • •

2.2.

• • • • •

Initial Facility Orientation Course Contents

Discussion of Emergency Preparedness Plan for the Facility Hazard Identification and Discussion Storage and Segregation Contingency Plan and Emergency Procedures Facility Tour Identify Safety Features Identify Communications and Alarm Systems Discuss Evacuation Routes Standard Operating Procedures Review of Procedures to Perform Operations at Facility Safety Practices

OSHA HAZWOPER Hazardous Materials Technician/TSO Worker Course Contents

Emergency Response to Hazardous Materials Incidents, Characteristics of Hazardous Wastes/Materials, Information Resources Identification of Hazardous Waste Levels of Protection


• Chemical Protective Clothing • Response Operations: Safety Plans and Standard Operating Procedures • Response Operations: Size-up • Response Operations: Strategy and Tactics • Site Entry • Incident Control: Confinement and Containment • Direct-Reading Instruments • Response Organization/Incident Command • Level A Demonstration • Decontamination • Establish Incident Command for Transportation Incident • Organize for Transportation Incident • The training shall consist of lectures, discussions, exercises and examinations.

2.3. OSHA 8-Hour Refresher Course Contents

• Hazardous Waste Management and Regulations • Source of Information • Compatibility of Hazardous Wastes • Personal Protection • Principles of Safety • Emergency Procedures

2.4. DOT Hazardous Materials Transportation Training Course Contents

• General Awareness/Familiarization • Identification of Hazardous Materials • Packaging • Marking • Labeling • Shipping Papers • Placarding • Separation and Segregation • Safety • Hazardous Waste Transportation Issues

2.5. Training Records

The following records will be maintained at the facility:

• The job title for each position related to hazardous waste management and the name of the employee filling each job

• A written job description for each position • A written description of the type and amount of initial and refresher training for

each position • Training records on current employees will be kept until closure of the facility and

training records on former employees will be kept for at least three years from the date the employee last worked.


Facility SOP 3 - Contractors and Contractor Training

• When ACTreatment arranges to have employees of another employer (Contractors) perform work that involves activities that may put personnel at risk, ACTreatment must inform the Contractor that the workplace contains specific hazards and that the work to be done is permitted only if all workers have the proper training, equipment and work conditions to accomplish the task(s) in a safe manner.

• Contractors are required to understand and to comply with the policies and procedures stated in this manual, as well as, all regulations pertaining to their operations.

• The supervisor of the contractor must complete a Contractor Training Checklist (below) for each contractor to work on-site. This supervisor must use this checklist to determine the training requirements for the contractor working on-site.


ACT ACTreatment Contractor Safety Checklist

~contractor Name:

Contact Name & Information:

Anticipated Date of Hire:

Description of Job Duties:

Duration of Employment:

I certify that this employee is approved to work (Compliance Director):

Agency I Company Name

Position:

Attach documentation of all completed courses to this document and submit to the Compliance Director for approval.

EH&S Training Requirements Job Tasks Date Completed

40 Hour HAZWOPER or 8-Hr Refresher Certificate - Handling hazardous materials, wastes, must have current certificate within one year of date decontamination tasks, bulking, etc.

DOT Training Certificate - must have current certificate Packaging waste for transportation, within 3 years of date labeling containers or completing the

paperwork

Hazard Communication Handling hazardous materials

Hazardous Waste Awareness - must have current Handling hazardous wastes certificate within one year of date

tespiratory Protection - must have current certificate Contractors issued/using a respirator within one year of date

*Other: Job Specific

Job Specific

* Examples include, HHW, TSDF Orientation, etc.

Medical I Drul Testing & DOT Requirements Personnel Date Completed

HAZWOPER Physical Handling hazardous materials, wastes, decontamination tasks, bulking, etc.

DOT Physical DOT Drivers

*Drug Test All

Pulmonary Function Test Contractors issued/using a respirator

Respirator Fit Test Contractors issued/using a respirator

* If an employee is needed within 48 hours a drug screen is not required at the time of approval. If they will be working more than 16 hours, a drug screen is required within two business days.


Facility SOP 4 - Receiving of Waste Shipments

4.1. Weigh Containers

4.1.1. Zero Scale

1) Zeroing the scale resets the scale in order to get an accurate weight.

2) Zero the scale by making sure that there is no weight on the scale and pressing the

button on the scale that is labeled "Zero".

3) Wait for the display to stabilize and the scale is ready to weigh.

4.1.2. Place Container on Scale

1) Use a forklift to place the waste container on the scale.

2) Raise the load high enough to avoid bumping the scale sides when moving the load over the scale. This can cause damage or inaccuracy in the scale.

3) Set the load down slowly and carefully to avoid jarring the scale.

4.1.3. Record the weight

1) Allow the display weight to stabilize before recording the weight.

2) Record the weight on the QC form and the Inventory label.

4.2. Perform QC Check

4.2.1. Open the Container

1) The container must be opened to inspect the waste material.

2) Always open containers carefully and wear the appropriate personal protective equipment.

3) Waste containers may be under pressure, keep face away from container opening.

4.2.2. Inspect the Waste

1) Carefully inspect the waste per the parameters outlined in the appropriate waste

management SOP. Avoid touching the waste and wear appropriate personal protective equipment. Level D for Solids, Level C for liquids.

4.2.3. Sample the Waste (when required)

1) Follow the appropriate Waste Management SOP to determine if a sample and additional analysis is required for a particular waste.

2) For wastes that need to be sampled, use a drum thief, COLIWASA or other sampling tool

to retrieve the waste from the container. Never use your hands to sample waste.

4.2.4. Record the QC results

1) Record the QC results on the QC form and initial to identify who performed the QC

check.

2) Note any discrepancies on the QC form and notify the Inbound Coordinator of the

discrepancy.


4.3. Waste Storage

• In general wastes will be stored in the appropriate room in the warehouse based on the DOT shipping hazard class of the waste, as described in Facility SOP 8 -Trailer doors must be locked after hours while docked or staged and at all times during transportation, in accordance with applicable DOT regulations.

• Hazardous Materials/Waste Storage Requirements. • Specific storage requirements for individual types of hazardous wastes are

addressed in the waste category SOPs

4.4. Records Update

4.4.1. Records of wastes received at the facility, current inventory, wastes being shipped and similar records will be maintained in a waste-management software system (the WMSS) . ACTreatment currently uses "Enviroware" software from Contemporary Software as its WMSS. Examples and specific references below are for the "Enviroware" software. ("E-ware") The information in this document will be updated as needed if a different WMSS is used.

4.4.2. Weigh Screen

ACTreatme

1) From the Weigh Screen, search the document number associated with the manifest that is being received in the Document field . The Weigh screen will display the number of items per manifest line number (each manifest line will be a different page in this screen, use the record navigation buttons at the top of the screen to move from line to line).

Ill I ?

°""" ....... mln9 ... ~DoalmenKJM~ n.m ........ c;:onwroon ..... 'ffll.llM•lnd locllol\lllNl•arta.. ad ....... ~ID~NCAMmlCCOl&lngtofOll"tr*ltl

, ..._~ LMsr-3 .... -~ cm mm, ~ - ro--

Ill I ?

number in sequence with a dash {D63421-1) in the Container Serial #field.

Weigh Screen Enter We1ghWolume and Initial Item Placement

auery1he Items using tfte Envtroware Oocumenwne numbers. Then tnllf' '" common weights. VOlumtt and location In this lop area. CUck .cPopulatt> to populate each Item 1ccording lo your 1nb1es.

Document {063421

Location: .------.

TSDFROOU

Line: 1 )]

SptciftcGl'IYily:r-

Weight

Volume:.-------,,

Use this section to rr.;ew or adjust item information (such as weight. wlum11, dimensions, or location).

Populate

UM: r.-- r weight

UM:~ C.Volume r .Process WaBIB?

Inventory

ln\/enlory

. of 119

3) Enter the corrected weight from the QC form of the waste container in the Weight field.

?

We19h Sc reen Enter We19htNolume and lmtial Item Placement

Outrrlle ttms Ulklg ... !tMfewart t>ocun'lttM.Jtl• ~. T""9 MWlhecommon-wa. 'l'Olurnt• and IOClllonlnllll•too•n. Clkt~loDOCIUl .. MCtlittm<ICCOfdlnoloyour"*lts .

.....,, 7

--r--:::::-: Inventory

4) Enter the storage location from the QC form in the Location field . Adjust locations in the Move Screen if necessary.

\''1e1gh Sc reen Enter We1qhlNolume .ind Jmt1,1l llem Pl.1cement

Ou91ylll .. ms "*'ON !rMroWert DoameNUM nurnDerS. Thin enllrllec:ornmonw.lgtltl. wtumu Ind localloftll'ltitlOll..., ClldC~lopoputltt•KhiltmlCCOfClnQlortMl'IMlff.

UM:' r _.... .. r- r.v.....

r.Pnlel .. Wnlli'

Inventory

·"''

5) Use the QC form to double check the size and type of container in the corresponding fields. Correct if necessary.

We19h Screen Enter We19htrvolume ,md lnitrnl Item Placement

OUtty lit hmt utlfto ltt !n*OWn OoOJmtn&\Jnt numbtf1. 1btn tnlW"' common wtlOMt, volumlt C'ld IOCllOn lnllls top .... Cle*: .populllP to POCIUl8 1acn1tm ICCOldlng10 your1'*'91

ACTreatment Operations Manual

Inventory

Page 10 of 119

4.4.3. Accept Screen

1) Accept Waste

From the Accept Inventory screen, search the document number associated with the manifest that is being received in the Document field . The Accept Inventory screen will display the number of items per manifest line number (each manifest line will be a different page in this screen, use the record navigation buttons at the top of the screen to move from line to line) .

.. I oea..t __ i ..... _ · _____ ,,__1PrtktAfuia1

DocwftHC jDll421 AcctptlCt ( OJ..$Ol.Z014

lnv1:>ntory Items

2) Click on the Accept All button to populate the Accepted Date field. This will populate the date for all records associated with the Document number.

= --1

4.4.4. Discrepancies

1) The Inbound Coordinator will notify the generator/ generator representative of the discrepancy and will either:

• Determine alternate rout ing of the waste • Return the waste to the generator


Facility SOP 5 - Uniform Hazardous Waste Manifest Management

5.1. Regulatory Requirements

5.1.1. During receiving of hazardous waste, Manifest must undergo QC inspection to confirm that:

1) Generator information is correct

2) Transporter information is correct

3) The DOT Shipping Name, container descriptions and RCRA waste codes are correct

4) Quantities are correct

5) Generator certification is correct and readable (the date and date format is also correct)

6) Transporter Acknowledgement is correct and readable (the date and date format is also correct)

7) The Hazardous Waste Management codes are noted for each RCRA Hazardous Waste

8) The Designated Facility Operator Certification is complete and readable

5.2. Inspection Steps

5.2.1. All RCRA hazardous waste shipments must be documented on a Uniform Hazardous Waste Manifest

1) The Uniform Hazardous Waste Manifest is normally accompanied by a Land Disposal Restriction Notification Form, unless special conditions exist.

2) All printing on the Uniform Hazardous Waste Manifest must be legible

3) Changes on a Uniform Hazardous Waste Manifest must be done by making a single line and initial with the new information written above or below.

5.2.2. Section 1 - Generator ID number must be printed on the manifest

1) 12 space alphanumeric EPA Id number or

2) CESQG designation

5.2.3. Section 2 - Number of pages on document is complete

5.2.4. Section 3 - Emergency Response Phone must be completed

5.2.5. Section 4 - Manifest Tracking Number is included (this is normally pre-printed)

5.2.6. Section 5 - Generator Name and Mailing Address is complete

1) This section shall also include the Generators Phone number

5.2.7. Section 6 - Transporter 1 Company Name and USEPA ID Number is complete

5.2.8. Section 7 - Transporter 2 Company Name and USE PA ID Number is complete (if applicable)

1) Applicable only when the custody of the waste is transferred between company entities. Transferring between different employees within the same company does not require additional transporter identification.

ACTreatment Operations Manual Page 12 of 119

5.2.9. Section 8 - Designated Facility Name and Site Address is complete with 12 digit EPAID number and phone number

5.2.10. Section 9 - US DOT shipping description including 9a and 9b is completed and correct.

5.2.11. Section 10, 11 and 12 - For each line item, the container number/ type, quantity weight and Units are correct

1) The actual quantities and weights will be noted on the QC Forms which accompany the manifest to this Manifest QC inspection Process

5.2.12. Section 13 - All applicable Waste Codes are filled out correctly

5.2.13. Section 14 - Special Handling and Additional Information may contain additional descriptions for the hazardous waste in this section.

1) The ERG number for the waste is required

5.2.14. Section 15 - Generators/ Offerors Certification must be filled out including printed name, signature and date

5.2.15. Section 16 - International Shipments completed when applicable

5.2.16. Section 17 -Transporter Acknowledgement of Receipt of Materials is completed include print sign and date.

5.2.17. Section 18a - Discrepancies regarding quantities, types, residues, rejections are noted in this section when applicable.

5.2.18. Section 18b - Alternate Facilities or Generator shipments are noted in this section

5.2.19. Section 18c - Signature of Alternate Facilities or Generators and date accepted when applicable.

5.2.20. Section 19 - Applicable Hazardous Waste Management Codes are noted per manifest line item in this section.

5.2.21. Section 20 - The Designated Facility Owner or Operator must have the name, signature and date of the person accepting the waste.

5.3. Discrepancy Management

5.3.1. Discrepancies on manifest, when discovered will be immediately investigated. Documentation of the discrepancy and resolution (when required) will be filed within the shipment file.

5.3.2. Discrepancies must be reported to the Generator within 15 days of receipt of the Waste.

5.3.3. The Generator must be informed in writing of the discrepancy and resolution, if required.

5.3.4. Rejections when discovered will be immediately investigated and documentation of the resolution, including all associated manifests and other communications will be filed within the original outbound shipment file.


S.4. Good Documentation Practices

5.4.1. All handwritten parts must be legible, and in blue or black ink.

5.4.2. Any changes must be made by crossing out with a single line, initial and write the correct information above or below the correction.

1) Rule ofThumb - the original mistake must be visible after the correction.

2) Scratch outs are not allowed.

S.S. Manifest Recordkeeping and Retention

5.5.1. Regulatory Requirements

• The record retention policy is driven by applicable federal, state, and local regulatory requirements. These requirements are followed in order to maintain compliance with these regulatory standards and to provide adequate documentation for the TSD business. The following basic requirements must be met for Hazardous Waste Manifest record retention:

• Each shipment file will contain the required manifest copies and other TSD permit required documentation.

• Each manifest is retained for a period of three years. • Each manifest has a copy of the applicable LDR form attached. • Each inbound manifest will have the "DESIGNATED FACILITY TO GENERATOR" copy

mailed to the generator within 35 days. • Each outbound manifest will have the "DESIGNATED FACILITY TO GENERATOR" copy

attached to the "GENERATORS INITIAL COPY" or will have attached a record of the attempt to locate the "DESIGNATED FACILITY TO GENERATOR" copy of the manifest.

5.5.2. Inbound Manifests

• Once receipt of the shipment is acknowledged by the Hazardous Waste Coordinator, the inbound manifests, LDRs and support documents are filed together per each shipment.

• The "DESIGNATED FACILITY TO GENERATOR" copy of the manifest is scanned for electronic filing.

• The original "DESIGNATED FACILITY TO GENERATOR" copy is mailed to the generator within 35 days of the shipment date of the waste.

5.5.3. Outbound Manifests

• The Hazardous Waste Coordinator is responsible for management of the outbound manifest copies and return manifest from the downstream TSD.

• Each outbound shipment manifest, LDR and associated support documents will be filed per each waste shipment. The manifest copies in the file shall include at minimum the "GENERATORS INITIAL COPY", the LDR and the "DESIGNATED FACILITY TO GENERATOR" copy of the manifest to document receipt of the shipment at the downstream TSD. Other supporting documentation for the shipment will also be retained in the file.

• The original "DESIGNATED FACILITY TO GENERATOR" copy should be mailed within 35 days of the shipment date of the waste.


• Upon receipt of the "DESIGNATED FACILITY TO GENERATOR" copy of the manifest, the "DESIGNATED FACILITY TO GENERATOR" will be filed in the shipment fi le along with the "GENERATORS INITIAL COPY" .

• The "Manifest Returned" field in E-ware will be updated for each shipment when a "DESIGNATED FACILITY TO GENERATOR" manifest is received . This wi l l allow tracking of the return manifest process.

Document Lme Information

• The Manifest Returned Report in E-ware can be run to determine which outbound shipments are at risk for not receiving a manifest within the required 35 day timeframe .


Facility SOP 6 - Shipment Unloading

6.1. Prepare Truck for Unloading

6.1.1. Open trailer doors

1) Swing doors cannot be opened while the trailer is docked and must be opened prior to docking the truck.

2) A roll up door may be left down while the trailer is docked, but should be closed again prior to docking the truck.

6.1.2. Inspect the load

1) Ensure the load is secure and will not shift in an abrupt stop that may occur when the trailer bumps the dock.

2) If the trailer has a roll-up door, close the door after inspection prior to docking the truck.

6.1.3. Inspect the dock

1) Ensure the dock plate lip is down and will not collide with the truck when backed into the dock.

2) Make sure that wheel chocks are available.

3) Make sure the wheel chocks will not be run over while backing the truck to the dock.

4) Make sure the dock bumpers are in place and in good condition to avoid damage to the trailer.

6.2. Dock Truck

6.2.1. Back Truck to the Dock

1) The truck driver will back the truck to the dock space.

2) The dock spaces are tightly spaced. A spotter should be used to help guide the truck into the dock space squarely and safely.

3) The spotter will also guide the driver when distance to the dock is short to prevent a hard collision with the dock bumpers, which can cause damage to the trailer or the load.

6.2.2. Chock the wheels

1) The wheels of the truck must be chocked to prevent the truck from creeping away from the dock. Wheel chocking is the responsibility of the person who will be unloading the truck as it is his/her safety at stake!!

6.2.3. Set Dock Plate

1) The dock plate is set by pulling the chain, which releases the dock plate and allows the lip to extend on to the trailer.

2) Stand away from the dock plate lip and face the trailer when releasing the dock plate to ensure that you are clear of the moving lip.

3) Ensure no other personnel are near the lip when releasing the dock plate.


6.2.4. Inspect the trailer floor

1) Inspect the trailer floor for damage, holes and protrusions before starting the unloading process.

6.3. Unloading the Trailer and Staging Waste

6.3.1. Transporting Drums

1) Unload the trailer by using a forklift and/ or drum dolly to transport drums from the trailer to the sampling/ weighing station. Manual handling of drums may cause strains and sprains.

6.3.2. Staging Waste

1) Stage waste in warehouse after QC check and follow the procedures in Facility SOP 4 - to finalize waste receiving.

2) Keep aisles clear when staging waste.

3) Mark staged groups with corresponding staging identification signs.

4) Enter the date on the sign with a dry-erase marker.

6.3.3. Trailer doors must be locked after hours while docked or staged and at all times during transportation, in accordance with applicable DOT regulations.


Facility SOP 7 - Hazardous Materials/Waste Storage Requirements

7.1. General

Proper Storage of Hazardous materials and hazardous waste is a critical part of maintaining an operation that is safe for employees, the community and the environment. The prescribed storage requirements of this procedure help to control hazards in a pro-active manner and to minimize the risk of incidents at the TSD.

7 .2. Waste Storage Rules

• Hazardous Materials and Hazardous Wastes are to be stored in containers that are in good condition, and in acceptable DOT containers when required.

• Waste containers must be properly labeled per RCRA requirements and marked / labeled per DOT requirements when stored in ACTreatment facility.

• All containers must be stored in a manner to allow for proper inspection of the waste. Inspection includes looking for damage, leaks, proper labeling and proper markings. Refer to the Facility Inspections SOP for more detail on inspection requirements,

• Waste containers must be closed at all times when in the storage areas at ACTreatment. DOT approved pressure relief devices may be used in special circumstances to relieve pressure or vacuum when required for safe storage.

• Waste containers of 30 gallons or greater may only be stacked upon each other two high. Containers smaller than 30 gallons may only be stacked at a maximum of three high, only when weights of the containers do not pose a safety hazard.

• Containers may not be stored in a manner that blocks egress routes or safety equipment (fire extinguishers, safety showers, spill kits) in ACTreatment facility.

• Containers that are stored on the racks of the warehouse must be secured to prevent falling during handling or storage. Shrink wrap, banding, tape or overpacking may be used to secure containers for rack storage.

• Liquids are not allowed to be stored on the 3rd racking tier or higher in ACTreatment facility.

• All waste containers at the facility must be stored inside the warehouse where proper containment exists and are not allowed to be stored on the dock or in the parking area overnight (or when the facility is unattended). Dock areas may be used for staging only while the facility is attended.

• Flammable and reactive hazardous wastes may not be stored within 50 feet of ACTreatment property. "SO-foot lines" are marked in the facility to delineate the prohibited areas for storage of flammable or reactive hazardous wastes.

• All wastes must be segregated from other wastes that will react if accidentally commingled (see Section 7.3. of this document for segregation rules and table).

7 .3. Waste Segregation

7.3.1. The waste will be stored in the appropriate room in the warehouse based on the DOT shipping primary hazard class of the waste.

7.3.2. The table below illustrates acceptable waste storage at the TSD:


DOT Roome Roome RoomD RoomE Room F Hazard Class

2.1 ,/ ,/ ,/

2.2 ,/ ,/ ,/ ,/ ,/

2.3 ,/

3 ,/ ,/ ,/

4.1 ,/ ,/ ,/

4.2 ,/ ,/ ,/

4.3 ,/ ,/ ,/

5.1 ,/

5.2 ,/

6.1 ,/ ,/ ,/ ,/ ,/

8 (acid) ,/

8 (base) ,/

9 ,/ ,/ ,/ ,/ ,/

Non DOT ,/ ,/ ,/ ,/ ,/

./=storage allowed

7.3.3. Storage requirements for individual waste categories are indicated in the category-specific SOPs


Facility SOP 8 - Description of Procedures, Structures or Equipment for Hazard Prevention

8.1. Design and operation of facility

ACTreatment facility is designed, constructed, maintained, and operated in a manner that minimizes the possibility of a fire, explosion, or any unplanned sudden or nonsudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water which could threaten human health or the environment.

• The facility has designated H-occupancy storage areas for storage of flammable materials and all storage rooms have secondary containment in sufficient quantity to minimize the likelihood of release to air, soil or surface waters in the unlikely event of a spill as described in Section 2 of the ACTreatment RCRA Part B Permit Application

• Waste materials are stored in designated areas, based on their hazard class (as described in Section 5 of the ACTreatment RCRA Part B Permit Application and in Facility SOP 8 - Trailer doors must be locked after hours while docked or staged and at all times during transportation, in accordance with applicable DOT regulations.

• Hazardous Materials/Waste Storage Requirements to minimize the likelihood of incompatibles reacting with each other

• As described below, waste containers are received, inspected, stored and managed as described in general and waste-category-specific standard operating procedures (SOPs) in order to minimize the likelihood of an spills or releases

• A Contingency plan is in effect to ensure rapid response to any spills or releases see Facility SOP 9 - cility SOP 12 - ACTreatment Facility Contingency Plan and regular inspections are conducted (as described in Facility SOP 17 - TSD Facility Inspections to ensure that all applicable facility safety systems are available and able to function as intended in the event of a spill or a release

8.2. Spill Prevention

All hazardous wastes are to be managed in a way that prevents release. The following general requirements must be followed. They include:

8.2.1. Waste Container Management

1) All hazardous waste containers must be in good condition and compatible with the materials stored within.

2) All hazardous waste containers must be accessible and spacing between containers must provide sufficient access to perform periodic inspections and respond to releases.

3) Empty hazardous waste containers (drums) must have all markers and labels removed and the container marked with the word 'empty'.

4) Any spills on the exterior of the container must be cleaned immediately.

5) Flammable materials stored or dispensed from drums or totes must be grounded to prevent static spark.


6) Do not overfill waste drums when performing consolidations. 3"of headspace must remain at a minimum to allow for expansion due to temperature or pressure changes.

7) Non-conforming or damaged containers must be packed into a salvage drum or repackaged immediately when discovered.

8.2.2. Housekeeping

1) All hazardous wastes must be stored inside the warehouse or under cover if containerized in a bulk container;

2) All hazardous substance containers should be closed while in the storage areas. Open container processing is not allowed in the warehouse storage areas.

3) Use drip pans or other collection devices to contain drips or leaks while consolidating to other containers or equipment;

4) Immediately clean up and properly manage all small spills or leaks;

5) Inspect equipment and hazardous waste storage areas daily to ensure leaks or spills are not occurring per the Facility and Waste Inspection procedure;

6) Keep all work areas and hazardous waste storage areas clean and in good general condition.

8.2.3. Secondary Containment

1) Store and handle all hazardous wastes above the concrete areas ofthe TSO facility or over appropriate secondary containment. The TSO facility is designed as secondary containment.

2) Secondary containment should be inspected daily per the Facility and Waste Inspection procedure, and any spills identified in secondary containment must be immediately cleaned up and removed.

8.2.4. Marking and Labeling

1) Ensure all hazardous wastes are properly marked and labeled in accordance with all federal, state and local regulations. See SOP TSO Labeling Requirements for specific instructions and requirements for waste container labeling.

2) Waste containers that are delivered to the facility without proper labeling must be corrected before receiving and storing the waste.

8.3. Prevention of Hazards during Unloading Operations

Unloading hazards shall be reduced through procedures, structural features and equipment used at the facility. Containerized wastes shall be unloaded and loaded only at the truck dock which is equipped with mechanical dock levelers. All wastes that enter or leave the facility shall be handled over the sloped area of the loading dock. Small trucks shall drive over the berm onto the dock from the east side of the facility. Longer trucks shall back up to the dock, parking on the sloped and bermed concrete apron to the south. Both areas can contain a 1000-gallon spill.

The facility will maintain hand trucks and forklifts for hazardous waste container carrying. Forklifts will be operated as described in the ACT Powered Industrial Truck (PIT). Generally accepted practices for container handling will be used. In particular,


loads will never be lifted higher than is necessary to minimize the risk of breakage should the load fall

8.4. Prevention of Flooding and Run-Off from Waste Handling Areas

Flooding of the hazardous waste storage building shall be prevented by the land under the building which is elevated five feet above the surrounding land. This allows any rain that might land near the building to flow away from, instead of towards, the building. Also, the building's roof is sloped and is equipped with a gutter system which allows the rainwater to flow from the facility in a southwesterly direction into the catchment ponds.

Prevention of runoff from the waste handling areas shall be accomplished in several ways. The storage area for the hazardous waste is situated inside the building over sealed concrete floors that are sloped and bermed so in the event of a spill or other release the material is contained inside the building. All other waste handling areas such as the docks are paved with concrete which provide secondary containment.

8.5. Prevention of Water Supply Contamination

All the measures discussed in the section above will decrease the chance of contamination of water supply. All waste handling will be performed over concrete and any spills or leaks that do occur shall be cleaned up immediately. Also, the road around the building slopes to the west so that rainwater flows into the drainage ponds in the back of the building. This prevents the mixing of rainwater and any potential contamination from trucks at the dock.

8.6. Mitigation of Effects of Equipment Failures and/or Power Outage

Power outages and equipment failures do not create problems in the facility for the following reasons:

• The storage section of the facility is lighted only by skylights. The docks are equipped with explosion-proof electrical lighting. The forklifts are equipped with floodlights which allow for their safe use in the dark.

• In an emergency, pull stations will be operable since the electronic alarm system is battery powered. Verbal announcements will also be effective means of warning employees to evacuate.

• Emergency exit signs shall be self-illumination and visible without electric power.

8.7. Prevention of Undue Exposure of Personnel to Hazardous Waste

Training is the key to the prevention of employee exposure. All personnel at the facility shall be trained in procedures for properly performing facility operations including handling hazardous wastes and responding to emergency situations. Included in the training shall be instruction in the use of personal protection equipment and the location and use of safety showers and eyewash units which are located at strategic points throughout the warehouse. Additional information on the employee training program is included in Facility SOP 2 - ACTreatment Employee Training

Specific procedures for handling different waste categories are included below in Waste Category SOPs, however, in general:


• Engineering controls, such as working in well ventilated areas like the open loading dock areas, will be used wherever possible

• Work practices such as keeping containers closed, minimizing spills and releases, good housekeeping, etc. will be followed as described in waste category SOPS

• All employees shall be provided with protective equipment which includes, but is not limited to, eye protection, steeled-toed boots, respirators, protective overalls and chemically resistant aprons.

• At a minimum, employees and visitors shall be required to wear eye protection in the warehouse, on the docks and in the yard at all times.

• Respirator use will be consistent with requirements in the ACT Respiratory Protection Program (RPP)

Additional procedures for receiving, inspecting, storing and consolidating specific categories of hazardous waste are included in Facility SOPs.

8.8. Prevention of Releases to the Atmosphere

Other ACT Companies that transport waste to ACTreatment facility implement additional preventive procedures before the hazardous waste is transported to the facility. Before loading the containers of waste at a generator's site, the containers are checked for soundness, proper closure and labeling, and compliance with U.S. Department of Transportation (DOT) standards. Any damaged containers that might leak or burst during transporting or unloading are be accepted for transportation.

All containers are inspected as they are received at the facility for proper labeling and closure and to ensure they are structurally sound. At the facility, all containers will be kept closed except as necessary for business activities such as inspection, sample collection, consolidation.

In the event of a leak or a spill, all liquids will be retained in the curbed, secondary containment within each room. Specific response procedures are described in the facility contingency plan, however releases to the atmosphere will be minimized through prompt response to any spills or releases in order to minimize quantities that could evaporate or be released to atmosphere.

8.9. Employee Training

All employees must receive periodic training on the proper handling of hazardous wastes; spill prevention practices, and emergency response procedures. Training must include a review of this spill prevention and emergency response plan, and a review of location and use of emergency response equipment. Training requirements per this procedure and RCRA regulation are covered in initial HAZWOPER training, annual HAZWOPER refresher training as well as monthly safety meetings and other required training. See Facility SOP 2 - ACTreatment Employee Training.


Facility SOP 9 - Compactor Operations

9.1. Pre Operation Instructions

9.1.1. During use stay clear of all moving parts of the compactor. Entanglement into the equipment will cause serious injury or death.

9.1.2. Only authorized and trained personnel should operate this compactor. This compactor is equipped with a key operated locking system. The keys to this equipment must be controlled, and should only be in the possession of authorized personnel.

9.1.3. Do not remove access covers except for servicing. This equipment has been identified as Confined Space Entry. To access inside the compactor you must follow the Confined Space Entry SOP. All hazardous energy of this equipment must be properly isolated and de-energized before servicing this equipment. Only qualified personnel are allowed access to service the equipment.

9.1.4. Acess doors on the compactor must be secured in place when unit is operating.

9.1.5. Normal operation as well as all maintenance and repairs will be subject to the requirements of the ACTreatment "Lockout/Tagout" (LOTO) program

9.1.6. Before operating the compactor, make sure that the ratchets and claws (or chains) are securely attached to the receiver container. If unsafe conditions exist contact the TSO Operations Manager.

9.2. Operating Instructions

9.2.1. Operating keys will be issued to qualified personnel whose job requires frequent use of the compactor. To obtain the operating key contact the TSO Operations Manager.

9.2.2. Place the waste designated for compaction into the compactor receiving compartment. For best operating performance of this equipment do not over fill the receiving compartment.

9.2.3. Insert the operating key into the key switch. Turn the key/switch to the left (counter-clockwise) and depress for 1 to 2 seconds, then release. The unit will make one complete cycle, and then stop. Repeat, if necessary, after the compactor has completed its cycle.

9.2.4. Do not lend or give your key to any unauthorized person.

9.2.5. In Case of an Emergency, push the large red button to stop the equipment (Estop). The Emergency Stop Pushbutton, when depressed, will stop all powered operation of the compactor. NOTE: The compactor will not operate with the "E" Stop button depressed.

9.3. Container Replacement

9.3.1. Contact the Hazardous Waste Coordinator when the container pressure gauge has reached the posted level to indicate that the receiving container is full.

9.3.2. The Hazardous Waste Coordinator will arrange for replacement and shipment of the full container.


Facility SOP 10 - Shredder Operations

10.1. Pre Operation Instructions

10.1.1. During use stay clear of all moving parts of the shredder. Entanglement into the equipment will cause serious injury or death.

10.1.2. Only authorized and trained personnel should operate the shredder. The shredder is equipped with an interlock system. Bypassing or modifying the interlock system is strictly prohibited.

10.1.3. Do not remove access covers except for servicing. This equipment has been identified as Confined Space Entry. To access inside the shredder you must follow the Confined Space Entry SOP. All hazardous energy of this equipment must be properly isolated and de-energized before servicing this equipment. Only qualified personnel are allowed access to service the equipment.

10.1.4. All access doors, guards and hopper on the shredder body must always be secured in place when the unit is operating.

10.1.5. Before operating the shredder, make sure that the receiving container is secure and will not move. An unsecure receiving container can create a safety hazard. If unsafe conditions exist contact the TSD Operations Manager.

10.1.6. Normal operation as well as all maintenance and repairs will be subject to the requirements of the ACTreatment "Lockout/Tag Out" (LOTO) program

10.1.7. Never attempt to use your hands or tools to release a jammed shredder. If the shredder jams, contact the TSD Operations Manager.

10.2. Operating Instructions

10.2.1. Start the shredder prior to introducing waste into the hopper.

10.2.2. Place the waste designated for shredding into the hopper. For best operating performance of this equipment do not over fill the hopper, which can result in jamming of the equipment.

10.2.3. Look to see that the shredded material is flowing out from the shredder body.

10.2.4. In Case of an Emergency, push the large red button to stop the equipment (Estop). The Emergency Stop Pushbutton, when depressed, will stop all powered operation of the compactor. NOTE: The compactor will not operate with the "E" Stop button depressed.

10.3. Container Replacement

10.3.1. Contact the Hazardous Waste Coordinator when the receiving container is full. The Hazardous Waste Coordinator will arrange for replacement and shipment of the full container.


Facility SOP 11 - ACTreatment Facility Contingency Plan

(Applicable Regulations §264.50-56, §270.14(b)(7))

This contingency plan is designed to minimize hazards from fires, explosions or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil or surface water at, and around Advanced Chemical Treatment's (ACTreatment) facility. The provisions of the plan shall be carried out immediately whenever there is a threat to human health or the environment, as described below.

11.1. Facility Identification and General Information

Advanced Chemical Treatment, Inc.

6137 Edith Boulevard N.E., Albuquerque, NM 87107

505-349-5220

11.2. Type of Facility

On-site storage and consolidation of hazardous waste in containers, tanks, roll-offs and similar containers.

11.3. Copies of Contingency Plan

A copy of the contingency plan and all revisions to the plan are:

• Maintained at the facility; and • Submitted to all local police departments, fire departments, hospitals and State

and local emergency response teams that may be called upon to provide emergency services.

11.4. Arrangements with Local Authorities

In the event of an emergency at the facility, appropriate local authorities have toured the facility and are familiar with the layout of the facility; properties of hazardous waste handled at the facility and associated hazards, places where facility personnel would normally be working, entrances to the facility and possible evacuation routes.

• Bernalillo County Fire Department shall assume primary emergency authority and will coordinate with the City of Albuquerque.

• Lovelace Women's Hospital has been notified and contracted with the facility and is familiar with the properties of hazardous waste handled at the facility and the types of injuries or illnesses which could result from fires, explosions, or releases at the facility.

11.5. Emergency Coordinators:

At all times, there will be at least one employee either on the facility premises or on call (i.e., available to respond to an emergency by reaching the facility within a short period of time) with the responsibility for coordinating all emergency response measures. Designated Emergency Coordinators are listed in Table 3, below. Emergency Coordinators are thoroughly familiar with all aspects of the facility's contingency plan, all operations and activities at the facility, the location and characteristics of waste handled the location of all records within the facility, and the facility layout. In


addition, Emergency Coordinators have the authority to commit the resources needed to carry out the contingency plan.

Table 1 - ACTreatment Emergency Coordinators

Emergency Coordinator Home Address Cell# Work#

Shawn Moudy 4504 Beresford Ln NW 408-470-0195 505-349-5221x450

Albuquerque, NM 87120

Bill Littleton - 1st Alternate 5520 Delhi NE 505-273-1256 505-349-5223

Albuquerque, NM 87111

Kris Gwash - 2nd Alternate 3708 Trinidad St Ne 505-379-9582 505-349-5224 Albuquerque NM 87111

All designated Emergency Coordinators are management personnel and are responsible for hazardous waste management at the site. The Emergency Coordinators are thoroughly familiar with all aspects of the contingency plan, all operations and activities at the facility, the location and characteristics of waste handled the location of all records within the facility, and the facility layout.

All designated Emergency Coordinators receive extensive training, including Bloodborne Pathogens, CPR/FA/AED, DOT Dangerous Goods, Emergency Action Plan, Emergency Contingency Plan, Hazard Communication, Personal Protective Equipment and Respiratory Protection as well as initial 40-hr HAZWOPER training and annual refresher training.

11.6. Implementation of the Contingency Plan

The Contingency Plan will be implemented if an incident might threaten human health or the environment. The Emergency Coordinator has full authority to make this decision. Depending upon the degree of seriousness, the following potential emergencies might call for the implementation of the contingency plan:

11.6.1. Spills

• A spill of hazardous waste from containers or tanks which can be contained on-site but where the potential exists for groundwater pollution.

• A spill of any stored hazardous waste from containers or tanks which cannot be contained on-site resulting in off-site soil contamination and/or ground or surface water pollution.

11.6.2. Fires

• A fire which could cause the release of toxic fumes from hazardous waste. • A fire which, if it spreads, could ignite materials at other locations at the site or

cause heat-induced explosions. • A fire which could spread to off-site areas.

11.6.3. Explosions

• An imminent danger exists that an explosion involving hazardous waste could occur, resulting in a safety hazard due to flying fragments or shock waves.


• An imminent danger exists that an explosion could ignite other hazardous waste at the facility.

• An imminent danger exists that an explosion involving hazardous waste could result in the release of toxic material.

• An explosion has occurred, resulting in significant damage to the facility, uncontrolled fire, personal injury, release of hazardous materials to the environment or other serious consequences

11.7. Emergency Response Procedures

11.7.1. Immediately Upon Discovery of an Emergency

An employee discovering a spill, fire, or an imminent danger of explosion involving hazardous waste that is not easily controllable with equipment and materials at hand must contact the Emergency Coordinator. The Emergency Coordinator will immediately respond and assess the situation.

If the emergency can be controlled without evacuating the facility, emergency crew members will be contacted to respond to the incident. If the Emergency Coordinator determines that the incident requires evacuation of the facility, he will immediately activate the internal alarm. (NOTE: All ACTreatment employees are instructed to activate the internal alarm system if the incident is an obvious immediate threat to fellow employees or the environment.)

The Emergency Coordinator will concurrently assess the situation by identifying the character, exact source, amount and extent of any released material. They will also make an assessment of possible threats to human health and the environment.

If the incident could threaten the environment or human health outside the property, the Emergency Coordinator will contact the Bernalillo County Fire Department (9-1-1) and Lovelace Women's Hospital if any injury that requires medical attention has occurred.

The Emergency Coordinator will take all necessary measures to contain the hazard within the facility property, and to prevent its spread to other nearby properties, with the assistance of emergency personnel assigned by the various parties contacted.

11.7.2. Tank and Container Spills

1. Determine source of spill. 2. Identify the waste material spilled and determine the hazards involved in terms of

potential for fire, hazardous gas release, corrosion, explosion, and water pollution. 3. Evacuate all endangered or unnecessary personnel. In case of the release of toxic or

flammable gases, determine if off-site evacuation is advisable. Remove nearby wastes that may be incompatible with the spilled material.

4. Contact the Bernalillo County Fire Department (9-1-1) as needed s. All spill response personnel are to wear appropriate protective equipment, including

respirators and/or SCBA's as needed, and are to stay upwind of the spill to the extent that is possible.

6. Contain the spill to the smallest area possible. 7. Place absorbent material on a liquid spill.


8. If the spill is from a leaking or damaged container, immediately over pack into an appropriate container.

9. If this spill is from a tank, dike around the tank with absorbent material. 10. If the spillage is due to the tank being ruptured, immediately empty the tank. 11. After the spill is contained, treat the spill with neutralizing agents to lessen risks of

fire, corrosion, explosion, or other hazards. Apply non-reactive sorbent materials. 12. Decontaminate area affected by spill by removal of spilled and sorbent materials and

contaminated soil. 13. Clean up, restore, or replace spill response equipment and return it to its original

location.

11.7.3. Tank & Drum Storage Fire

1. If the fire cannot be readily controlled with available equipment, the area will be immediately evacuated.

2. Determine what is on fire by location, drum label, inventory, or other means. 3. Determine if persons are endangered by the fire or if the fire could spread to other

wastes 4. Evacuate all endangered persons. In case of release of toxic gases or where there is

potential for explosion, determine if off-site evacuation is advisable. s. Define the limits of the fire. 6. Estimate the potential dangers due to location with respect to other wastes in the

immediate vicinity. 7. Call the local Bernalillo County Fire Department (911) if they may be needed. 8. Responding firefighters will wear full protective clothing and breathing apparatus as is

appropriate. 9. Firefighting should be done at a maximum allowable distance staying upwind and from

a protected location, if possible. 10. Small fires such as a single drum fire can be approached with portable extinguishers,

dirt, or sand to extinguish flames by smothering. 11. All large fires will require support from the Bernalillo County Fire Department. 12. Extra caution is to be taken with containerized material fires for signs of rupture or

explosion due to heat releasing hot liquids, flammable vapors, or poisonous gases. 13. After fire, clean up affected areas. 14. Run-off from water used in firefighting should be treated as a hazardous waste and

disposed of properly. 15. Clean up all firefighting equipment and return it to its original location in a state of

readiness.

11.7.4. Evacuation

Facility personnel are instructed to immediately stop activities and proceed to the nearest exit and assemble at the designated staging area. If the nearest exit is blocked (by a release of hazardous waste or fire), personnel must use the next nearest available exit. A diagram of available exit routes is located at each work area. See Figure 1- ACTreatment Facility Evacuation Routes.

All employees hearing the alarm must close down their equipment and proceed to the staging area to await further instructions. A designated employee will conduct a roll call for all employees who reported to the staging area.


The following actions shall be taken when a site evacuation is ordered:

1. The Emergency Coordinator will pull the alarm and announce the evacuation by shouting.

2. Each individual shall determine which route he or she will take depending on the location of the incident and his or her location at the time the alarm is sounded.

3. All personnel and visitors shall quickly leave the Facility in a safe manner. Visitor contacts shall direct visitors off-site.

4. Personnel shall re-group at the intersection of the road easement and Edith Boulevard. East of the Facility.

s. A person designated by the Emergency Coordinator will initiate a head count of all the people at the regroup area. This information shall be given to the Emergency Coordinator.

6. Refer to Figure 1- ACTreatment Facility Evacuation Routes

11.8. Notification of Situations Which Could Threaten Human Health or the Environment Outside of the Facility

If the Facility has had a release, fire or explosion which could threaten human health or the environment outside the Facility, the Emergency Coordinator shall immediately inform the appropriate local authorities if her/his assessment indicates that evacuation of local areas may be advisable. She/he shall also be available to help appropriate officials decide whether the local areas should be evacuated.

The Emergency Coordinator shall immediately inform either the government official designated as the on-scene coordinator for the facility's geographical area or the Nation Response Center if the Facility has had a release of a reportable quantity, fire or explosion which could threaten human health or the environment outside the Facility. The report shall include:

1. Name and telephone number of reporter; 2. Name and address of the Facility; 3. Time and type of incident; 4. Name and quantity of material(s) involved, to the extent known; s. The extent of injuries, if any; and 6. The possible hazards to human health or the environment outside the Facility.

11.9. Following Attainment of Control

The Emergency Coordinator will make sure that cleanup and restoration have progressed to the point of not jeopardizing the health and safety of the employees before discontinuing emergency operations.

Immediately after an emergency, the Emergency Coordinator will provide for treating, storing, or disposing of recovered waste, contaminated soil or surface water, or any other material that results from a release, fire, or explosion at the facility (unless ACTreatment can demonstrate, in accordance with 40 CFR §261.3(c) or (d) that the recovered material is not a hazardous waste). For all hazardous waste, ACTreatment becomes a generator of the waste and will manage it in accordance with all applicable requirements of 40 CFR parts 262, 263, and 264.


The Emergency Coordinator will ensure that all emergency equipment is restored to full operational status by emergency personnel following any incidents or emergencies

The Emergency Coordinator will investigate the cause of the emergency and will take steps to prevent a recurrence of such or similar incidents. This will be documented on an Incident Report form.

11.10. Prevention of Recurrence or Spreading of an Incident

During an emergency, the Emergency Coordinator shall take reasonable measures necessary to ensure that a release, fire, or explosion does not occur, recur or spread to other hazardous waste at the facility. Procedures that shall be carried out, when necessary, shall include:

1. Stopping processes or operations; 2. Collecting and containing released wastes; 3. Isolating or removing containers; 4. Inspecting for any leaks or cracks in containers; and s. Ventilation of the building.

11.11. Emergency Equipment

The table below lists the emergency equipment maintained at the facility including the equipment's location, physical description of each item on the list and a brief outline of its capabilities. This list must be kept up to date.

Table 2 - Emergency Equipment at ACTreatment

Equipment capabilities LOCATION

Fire Control

Fire extinguishers ABC fires Fire extinguishers are located within 50 feet of all flammable materials storage areas in the warehouse and also on each forklift.

Dry pipe foam Foam sprinkler system Under roof of the warehouse (all rooms)

Sprinkler Double fireman's Warehouse rooms for extra foam injection if hookup necessary

Personal Protective Equipment

Protective eyeglasses or goggles Protect eyes from Office for visitors, employees keep own glasses splashes

Face shields Protect eyes and face In PPE storage area.

SCBA's 30-minute air supply In Technician Office Area/Room A.

Aprons, chemical resistant Protect skin and In PPE storage area. clothing

Gloves, assorted chemical and Protect skin from Part of Hazmat spill cart inventory located physical damage resistant splashes within the warehouse in PPE storage area

Protective coveralls Protect skin and Part of Hazmat spill cart inventory located clothing from within the warehouse in PPE storage area hazardous waste

Boot shields Protect skin from Part of Hazmat spill cart inventory located


Equipment capabilities LOCATION splashes within the warehouse in PPE storage area

Spill Control

Absorbent Spill containment Part of the Hazmat spill cart inventory located in Room E of Warehouse

Forklift Moving containers and Warehouse area heavy equipment

Salvage drums Over packing of South side of the warehouse and on the dock damaged drums area.

Plastic (polyethylene) Containment of Part of the Hazmat spill cart inventory located hazardous spills in Room E of Warehouse

Shovels Used in cleaning up Part of the Hazmat spill cart inventory located debris within the warehouse or in Front or Back Dock

Area

Broom Used in cleaning up Part of the Hazmat spill cart inventory located debris within the warehouse or in Front or Back Dock

Area

Duct tape Used for temporary Part of the Hazmat spill cart inventory located plugging of leaks within the warehouse Front or Back Dock Area

Emergency Decontamination & First Aid

Emergency shower/eyewash Decontamination of There is 1 shower/eyewash in every room stations skin, eyes, and/or throughout the warehouse (with the exception

clothing of Technician Office Area/Room A.

First Aid station First aid medical Located within the office area/Room A. supplies

Emergency Communication & Alarm System

Pull stations Activates alarm, Front office, front dock connected to outside monitoring system

Horns To alert personnel of Placed throughout the warehouse an emergency

11.12. Required Reports

The time, date, and details of any incident that requires implementing the contingency plan will be recorded in the facility operating record. Within 15 calendar days after the incident, a written report on the incident will be submitted to the Secretary, New Mexico Environment Department (NMED). The report shall include the following:

1. Name, address and telephone number of the owner/operator; 2. Name, address and telephone number of the Facility; 3. Date, time and type of incident (e.g., release, fire);


4. Name and quantity of material(s) involved; 5. The extent of injuries, if any; 6. An assessment of actual or potential hazards to human health or the environment,

where this is applicable; and 7. The estimated quantity and disposition of recovered material that resulted from the

incident.

11.13. Amendment of Contingency Plan

This contingency plan will be reviewed, and immediately amended, if necessary, whenever:

1. The facility permit is revised; 2. The plan fails in an emergency; 3. The facility changes-in its design, construction, operation, maintenance, or other

circumstances-in a way that materially increases the potential for fires, explosions, or releases of hazardous waste or hazardous waste constituents, or changes the response necessary in an emergency;

4. The list of Emergency Coordinators changes; or 5. The list of emergency equipment changes.


Figure 1- ACTreatment Facility Evacuation Routes

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Facility Evacuation Routes Advanced Chemical Treatment


October 10th. 2014

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EB . Jge 34 of 119

Facility SOP 12 - Selection and Scheduling of Waste Shipments

12.1. Request Drop Appointment from Final TSO

12.1.1. The Hazardous Waste Coordinator will request an appointment for delivery of the waste to the destination TSO. Destination TSO appointment procedures will vary from site to site.

12.1.2. Once the appointment is set, the Hazardous Waste Coordinator will schedule the timing for selection, picking and consolidation of wastes for shipment.

12.2. Generate Pick List

12.2.1. The Hazardous Waste Coordinator will generate a pick list of waste containers for shipment or consolidation/ shipment.

12.2.2. The Pick List is selected by generating an inventory report in the WMSS and filtering for process code in the WMSS. Using the process codes will ensure that properly routed wastes will be picked by warehouse personnel.

12.3. Pick Waste

12.3.1. The Shipping Personnel will use the Pick List to locate the waste for consolidation/ shipment.

12.3.2. Any deviation from the Pick List must be approved by the TSDF Operations Manager.

12.4. Consolidate I Stage Waste Locate to Staging Area

12.4.1. After the waste is picked, it is delivered to either consolidation or staging area for pre shipment processing.

12.4.2. Consolidation wastes are consolidated to the bulk container for shipment. Each container is scanned to the WMSS bulk location that will be used to create the manifest.

12.4.3. Non-Consolidation wastes are delivered to the staging location for processing. Each container is scanned to the WMSS staging location for processing to the manifest.

12.5. Manifest I LOR I Labels I Marking (SOOl00-1)

12.5.1. The Hazardous Waste Coordinator will generate manifests, LOR labels and marking instructions in the WMSS and hand off to Shipping Personnel.

12.5.2. The Hazardous Waste Coordinator will submit a copy of the manifest to the destination TSO.

12.5.3. Shipping Personnel will Label and mark the containers according to the manifest number and sequence of drums on the manifest.

12.5.4. The manifest number and drum sequence number are used to create the drum number as shown below:

ACTreatment Facility Operations Manual Page 35 of 119

Manifest Document Manifest Drum Drum Number Number Sequence

S01234 1 S01234-1

2 S01234-2

3 S01234-3

4 S01234-2

5 S01234-3 II II

For manifest lines with multiple drums, the numbers of drums per line are still in the sequence. For example, if manifest line 1 has three drums, they will be numbered S01234-1, S01234-2 and S01234-3. Manifest line two will start with S01234-4

12.6. Piece Count

12.6.1. Shipping personnel responsible for the shipment will perform a piece count using the manifest to check that all containers are staged for loading.

12.7. Load Waste per Shipment Loading SOP

12.7.1. Shipping personnel will load the truck per the Shipment Loading SOP and the trailer will be staged for shipment.

12.8. Manifest Signatures

12.8.1. The Hazardous Waste Coordinator will sign the manifest/ LDR as the generator representative.

12.8.2. When custody of the load is transferred to the OTR truck driver, the driver will sign as Transporter 1 on the manifest.

12.9. Placarding

12.9.1. Placards for the load will be given to the driver of the load and placarding instructions will be provided.

ACTreatment Facility Operations Manual Page 36of119

Facility SOP 13 - Shipment Loading

13.1. Prepare Truck for Loading

13.l.l. Open trailer doors

1) Swing doors cannot be opened while the trailer is docked and must be opened prior to docking the truck.

2) A roll up door may be left down while the trailer is docked, but should be closed again prior to docking the truck.

13.2. Inspect the dock

13.2.l. Ensure the dock plate lip is down and will not collide with the truck when backed into the dock.

13.2.2. Make sure that wheel chocks are available.

13.2.3. Make sure the wheel chocks will not be run over while backing the truck to the dock.

13.2.4. Make sure the dock bumpers are in place and in good condition to avoid damage to the trailer.

13.3. Dock Truck

13.3.l. Back Truck to the Dock

1) The truck driver will back the truck to the dock space.

2) The dock spaces are tightly spaced. A spotter should be used to help guide the truck into the dock space squarely and safely.

3) The spotter will also guide the driver when distance to the dock is short to prevent a hard collision with the dock bumpers, which can cause damage to the trailer or the load.

13.3.2. Chock the wheels

1) The wheels of the truck must be chocked to prevent the truck from creeping away from the dock. Wheel chocking is the responsibility of the person who will be loading the truck as it is his/her safety at stake!!

13.3.3. Set Dock Plate

1) The dock plate is set by pulling the chain, which releases the dock plate and allows the lip to extend on to the trailer.

2) Stand away from the dock plate lip and face the trailer when releasing the dock plate to ensure that you are clear ofthe moving lip.

3) Ensure no other personnel are near the lip when releasing the dock plate. Stand away from the dock plate lip and face the trailer when releasing the dock plate to ensure that you are clear of the moving lip.

4) Ensure no other personnel are near the lip when releasing the dock plate.


13.3.4. Inspect the trailer floor

1) Inspect the trailer floor for damage, holes and protrusions before starting the unloading process.

13.3.5. Staging Waste

1) Stage the waste in warehouse or on the dock (for waste that will be loaded the same day) after outbound QC check.

2) Keep aisles clear when staging waste.

3) Mark staged groups with corresponding staging id signs and enter the date on the sign with a dry-erase marker.

4) Inspect each container and match the container to a line item on the pick sheet.

5) Escalate discrepancies to the Waste Coordinator immediately when discovered.

13.4. Loading the Trailer

13.4.1. Transporting Drums to the Trailer

1) Load the trailer by using a forklift and I or drum dolly to transport drums to the trailer from the staging area or directly from the waste location. Manual handling of drums may cause strains and sprains.

2) Perform a piece count to ensure that all items are represented on the manifest for the shipment.

13.4.2. Secure the Load

1) Secure the load using load bars and or load straps.

2) The driver of the truck is ultimately responsible for the load. Ensure that the driver has had an opportunity to inspect the load and agrees that the load is secured properly.

13.4.3. Offer Placards

1) The shipper is responsible for providing placards to the driver of the truck that is carrying the load. Refer to 49 CFR Subpart F Part 172 for placarding requirements for hazardous material shipments.

13.4.4. Weighing the load

1) Any weight overages will be corrected by removing waste from the trailer immediately prior to transporting the load to the destination (removal of waste will require correction of the manifest).

2) Once overages (if any) are corrected, the load is released for transportation to the destination.

13.4.5. Trailer doors must be locked after hours while docked or staged and at all times during transportation, in accordance with applicable DOT regulations.


Facility SOP 14 - TSO Labeling Requirements of Hazardous Waste

14.1. General

Specific labeling is required by both RCRA regulation, DOT regulation and by TSO standard practices. All containers that are received or generated at the TSO are required to be properly labeled per all standards.

14.2. Labels Required

14.2.1. RCRA Hazardous Waste

1) The Environmental Protection Agency requires containers that hold hazardous waste at the TSO facility to be appropriately labeled. The following information must be included on the label:

• The words "HAZARDOUS WASTE" • Composition and physical state of the waste • Statement or statements which call attention to the particular hazardous

properties of the waste (e.g. flammable, reactive, corrosive, toxic, etc.) • The accumulation start date • The name, address and telephone number of the generator

2) Yellow RCRA hazardous waste label completely filled out (generator name, address, telephone number, EPA ID#, RCRA and state waste codes, manifest#, accumulation start date, contents, physical state, hazard properties and DOT shipping name. Labels are placed on the upper 1/3 of the drum.

3) An example of acceptable hazardous waste labels for containers at the TSO

HAZARDOUS WASTE

STATE AND FEDERAL LAW PROHIBIT IMPROPER DISPOSAL IF FOUND, CONTACT THE NEAREST POUCE OR PUBUC SAF!rrV NJTHORfTY, THE U.S. ENVIRONMENTAL PROTECTION NJ&Cf

OR THE CAl.JFORNIA DEPNITMENT Of' TOXIC SUBSTANCES CONTROL GENERATOR INFOAMAllON:

________ PHONE ___ _

_______ STAlE_llP ___ _

CA ACQJMUV.TlON ---WASTE NO. STARTo.1£ ---

PHYSICAi. STATE: I KAZAAOOUS ~ D FlAMMAIU 0 SOUO 0 UOUIO 0 COAAOSM 0 AEACTMTV 0 OTHER ---

O TOXJC

[---0.0.T. PADPCR 9IPPHl KAME' ND UN OR NANO. WfTH PAUOC

HANDLE WITH CARE! .,..,._...,

14.2.2. Universal Waste

1) Universal Wastes do not require a manifest under 40 CFR Part 262 but are regulated by US DOT as a hazardous material because they meet the criteria for one or more hazard classes specified in 49 CFR 173.2. Under these regulations the package must be


identified as a universal waste. In addition, ifthe universal waste is a US DOT hazardous material, the shipping documents must include the US DOT proper shipping name.

2) An example of acceptable universal waste labels for containers at the TSD

GENERATOR INFORMATION (OptiOnal)

SHIPPER ________ _

ADDRESS ________ _

CITY, STATE. ZIP _______ _

CONTENTS _______ _

14.2.3. DOT Hazard Identificat ion Label

1) Labeling requirements establish clear and accurate communication about the material in a package and hazardous materials packages prepared for transport in commerce must be labeled according to the requirements of 49 CFR. This means that each package must have the specific hazard labels displayed on the package as it is received and before it goes into transportation.

2) Examples of DOT required labels:

3) Bulk containers

Bulk Labels will be affixed on two opposing sides of bulk hazardous waste that will be carried in a transport vehicle ... i.e. totes, super sacks, cubic yard boxes, etc . Labeling will consist of 10 x 10 placards on each side with the appropriate UN number across the middle or two 10 x 10 placards as well as Orange Placards with appropriate UN number.

ACTreatment Facility Operations Manua l Page 40 of 119

3077 4) Bulk Labels {10 x 10) are placed on two opposites sides of the container (which are

orientated with pallet slots for forklift) .

14.2.4. Inventory Tracking Label

1) All wastes received at the TSO will have an Inventory Tracking Label placed on it for inventory tracking upon receipt/ acceptance:

llllll Ill Ill llllDlll 011111111111 llR 065121-1 . r

Generator Malaria Inc. Racelved Date

26.SEP·14

Common MIXED FLAIVMABLE LIQUIDS WASTE <10% HALO( Name

DOT RO, UN1993, Was10 Flamm11bl11 llqulds, n.o.s . (tcETONE, TOLUENE), 3, PGll (0001)

Profile ACT0072 Manifest 007170466FLE Line I ROOMD ;

i

Process FUELS LIQ >5000 B" Wnshl 2 12,741 ,0001,0022.f002,F-003.f005 Codes

'

·' 1111111111111111111111 '

" 065121-1 r

:i


Facility SOP 15 - TSO PPE General Requirements

15.1. General

Personal Protective Equipment (PPE) use at ACTreatment is a critical part of maintaining an operation that is safe for employees while performing hazardous waste operations. When work is conducted where employees are potentially exposed to physical and chemical hazards in the workplace that cannot be adequately controlled or eliminated using engineering or administrative controls, PPE will be used.

All PPE use will be consistent with applicable OSHA regulations including (but not limited to):

• 29 CFR 1910.132 "Personal Protective Equipment - General Requirements" • 29 CFR 1910.134 "Respiratory Protection" • 29 CFR 1910. 120 "Hazal'dous waste operations and emergency response"

(HAZWOPER) • 29 CFR 1910.95 "Occupational Noise Exposure"

15.2. Training

Prior to conducting work requiring the use of personal protective equipment (PPE), employees must be trained to know:

• When PPE is necessary; • What type is necessary; • How it is to be worn; • What its limitations are; and, • Proper care, maintenance, useful life, and disposal.

15.2.1. Employees must demonstrate an understanding of the training and the ability to use the PPE properly before they are allowed to perform work requiring the use of the equipment.

15.2.2. Employees are prohibited from performing work without donning appropriate PPE to protect themselves from the hazards they will encounter in the course of that work.

15.2.3. If the supervisor or Project Lead has reason to believe an employee does not have the understanding or skill required, the employer must be retrained. Circumstances where retraining may be required include:

• Changes in the workplace or changes in the types of PPE to be used, which would render previous training obsolete;

• The type of PPE changes; or Inadequacies in an affected employee's knowledge or use of the assigned PPE, which indicates that the employee has not retained the necessary understanding or skills.

15.2.4. Signing of the Training Verification Form found in Appendix K certifies that the employee has received and understands these written PPE requirements.

15.3. Hazard Assessment

In order to assess the need for PPE, the Operations Manager identifies specific jobs where exposures occur or could occur. This is accomplished by completing a PPE


Assessment Form (see below) to document what hazards exist or may exist. The PPE Assessment Form documents the hazards that are present or likely to be present. Use of this form will enable the proper selection of PPE. After the appropriate PPE has been selected, it must be properly fitted to each affected employee.

The Operations Manager (or person completing the PPE Assessment Form) must notify the employee(s) of the appropriate PPE required for the job and the reason for the PPE selection. In addition, this person must sign and date the form and have each employee who will be engaged in in the project sign and date the form.

15.4. Categories

PPE to protect the body against contact with known or anticipated chemical hazards has been divided into four categories.

15.4.1. Level A

To be selected when the greatest level of skin, respiratory, and eye protection is required. The following constitute Level A equipment:

Positive pressure, full face-piece self-contained breathing apparatus (SCBA), or positive pressure supplied air respirator with escape SCBA, approved by the National Institute for Occupational Safety and Health (NIOSH)

• Totally-encapsulating chemical-protective suit • Coveralls (as needed) • Long underwear (as needed) • Gloves, outer, chemical-resistant • Gloves, inner, chemical-resistant • Boots, chemical-resistant, steel toe and shank • Hard hat, under suit (as needed) • Disposable protective suit, gloves and boots (depending on suit construction, may

be worn over totally-encapsulating suit)

15.4.2. Level B

The highest level of respiratory protection is necessary but a lesser level of skin protection is needed. The following constitute Level B equipment:

• Positive pressure, full-face piece self-contained breathing apparatus (SCBA), or positive pressure supplied air respirator with escape SCBA (NIOSH approved)

• Hooded chemical-resistant clothing (overalls and long-sleeved jacket; coveralls; one or two piece chemical-splash suit; disposable chemical-resistant overalls)

• Coveralls (as needed) • Gloves, outer, chemical-resistant • Gloves, inner, chemical-resistant • Boots, outer, chemical-resistant steel toe and shank • Boot-covers, outer, chemical-resistant, disposable (as needed) • Hard hat (as needed) • Face shield (as needed)


15.4.3. Level C

The concentration(s) and type(s) of airborne substance(s) is known and the criteria for using air purifying respirators are met. The following constitute Level C equipment:

• Full-face or half-mask, air purifying respirators (NIOSH approved) • Hooded chemical-resistant clothing (overalls; two-piece chemical-splash suit;

disposable chemical-resistant overalls) • Coveralls or company uniform (as needed) • Gloves, outer, chemical-resistant • Gloves, inner, chemical-resistant • Boots (outer), chemical-resistant steel toe and shank (as needed) • Boot-covers, outer, chemical-resistant, disposable (as needed) • Hard hat (as needed) • Escape mask (as needed) • Face shield (as needed)

15.4.4. Leve I D

The lowest level of protection and the most common level of PPE used by ACT. This is a work uniform affording minimal protection: used for nuisance contamination only. The following constitute Level D equipment:

• Body protection which can include coveralls, company uniform or laboratory coat • Gloves (as needed) • Boots/shoes, chemical-resistant steel toe and shank • Boots, outer, chemical-resistant, disposable) (as needed) • Safety glasses or chemical splash goggles (as needed) • Hard hat (as needed) • Escape mask (as needed) • Face shield (as needed)

15.5. Cleaning & Maintenance

PPE must be kept clean and properly maintained by the employee to whom it is assigned! Cleaning is particularly important for eye and face protection where dirty or fogged lenses could impair vision. PPE is to be inspected, cleaned, and maintained by employees at regular intervals as part of their normal job duties so that the PPE provides the requisite protection.

Supervisors are responsible for ensuring compliance with cleaning responsibilities by employees. If PPE is for general use, the Operations Manager has responsibility for cleaning and maintenance. If a piece of PPE is in need of repair or replacement it is the responsibility of the employee to bring it to the immediate attention of his or her supervisor or the Operations Manager.

It is against work rules to use PPE that is in disrepair or not able to perform its intended function. Contaminated PPE that cannot be decontaminated is disposed of in a manner that protects employees from exposure to hazards.

15.6. Personal Protective Equipment Assessment Form

See over


A~T \ PERSONAL PROTECTIVE EQUIPMENT ASSESSMENT FORM

Advanced Chemicol Trea'imcnt

JILLLYU::S

The ACTreatment Operations Manager or designee shall assess the workplace to determine if hazards are present, or likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the ACTreatment Operations Manager or designee shall select, and require affected employees to use PPE that will protect the employee from the hazards identified.

The ACTreatment Operations Manager or designee shall verify that the required workplace hazard assessment has been performed and that this Form identifies the workplace evaluated; the person certifying that the evaluation has been performed and the date of the hazard assessment. 45 El I.I.I 5333§§ 0 IS !LY

Personal Protective Equipment includes protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers. PPE shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.

Name: I Date:

Description of Task: I IJJJ:SZStLt

Check the box for each hazard: I Description of hazard(s): Controls in place: Identify required PPE:

Chemical Exposure I Yes D Owork in fume hoods Osafety glasses

High Heat/Cold I Yes D 0Enclosure/guarding Osafety goggles

Dust or Flying Debris I Yes D Oshielding (bystanders) 0Face shield

Impact I Yes D Osafe Work Practices Owelding helmet

UV Light I Yes D Ooust collection system Ocutting goggles

Radiation I Yes D Oather: Dot her: ii JC.tib I

Check the box for each hazard: I Description of hazard(s): Controls in place: Identify required PPE:

Impact I Yes D Ocanopy Oclass G hard hat

Electrical Shock I Yes D Doe-Energize Oclass E hard hat

Entanglement I Yes D 0Hair secured Oclass C hard hat

Other: I Yes D Oother: Awareness 0Bump cap/welding cap

Personal Protective Equipment Assessment Form Page 1of4

A~T { {

PERSONAL PROTEC1 IVE EQUIPMENT ASSESSMENT FORM Advoo::ed Chemical Tr'eo,mcnt

UihlBLJ_

Check the box for each hazard: Description of hazard(s}: Controls in place: Identify required PPE:

Chemical Exposure I Yes D Osubstitution Owork boots

High Heat/Cold I Yes D 0Mechanical device used Osteel-toed shoes/boots

Impact/Compression I Yes D 0Housekeeping Oslip-resistant shoes

Puncture I Yes D 01solation/grounding 0Puncture-resist shoes

Explosive/Flam. atmos. I Yes D Osafe Work Practices 0Non-conductive

Slippery/Wet Surfaces I Yes D 0Appropriate clothing 0Metatarsal protection

Electrical I Yes D Oather: ventilation Oshin guards

Other: ~ IYesD Oother: Dot her:

t!•No cz", RQs ~~y incfude the following: work with chemicals, abrasion/cut hazards during demolition and renovation, woodworking, hot or cold otjec:ts/rnatertlills medical facilities, lab research, animal areas, radioactive arid biological mciltel"ials.


Chemical Exposure I Yes D Osubstitution ~Chemical-resistant gloves

High Heat or Cold I Yes D D De-Energize 0Thermal-protective gloves

Cuts or Abrasion I Yes D OElimination Ocut-resistant gloves

Puncture I Yes D 0Avoidance 0Leather gloves

Electrical Shock I Yes D Oother: Ovoltage-rated-Class:

Radiation I Yes D Oother: Awareness 0Latex/nylon exam gloves

Vibration/grip I Yes D Oather: 0Anti-vibration gloves

Bloodborne Pathogens I Yes D P UJZLLUJ.C::ZU.i


Chemical Exposure I Yes D 0Reduce time exposed 0Lab coat

Extreme Heat/Cold I Yes D 0Guards/barriers 0Apron: PVC

Radiation I Yes D Osubstitution 0Flame-retardant

Personal Protective Equipment Assessment Form Page 2 of 4

I ~

\ \ ACT PERSONAL PROTECTIVE EQUIPMENT ASSESSMENT FORM Advanced Chemical Treotmcnf

Impact

Cut/ Abrasion/Puncture

Electrical Arc

Pushing/pulling/lifting .JLIEiblii.U.

Check the box for each hazard: I Description of hazard(s):

Chemicals I Yes D

Particulates I Yes D

Confined space work I Yes D

Welding/cutting fumes I Yes D

Other ~ IYesD

D De-Energize Ocoveralls

0Mechanical devices Ovest

Oother: 0Tyvek suit

Dot her: Dot her:

Controls in place: Identify required PPE:

0Fume hood 0Half-face

0Local exhaust ventilation 0Full-face

01ncrease air flow DscBA

OFiltration 0PAPR

Owork outside 0Dust mask

I certify that the above inspection was performed to the best of my knowledge and ability, based on the hazards present on this date.

Name (please print): Date: Signature:

Title: Telephone:


(.,.._ 4'-T PERSONAL PROTEC11VE EQUIPMENT ASSESSMENT FORM Advanced Chemicol Tr'cotmcn1

I Description ~T~sk: I I

I CERTIFY THAT I HAVE REVIEWED AND UNDERSTAND THE ABOVE REQUIREMENTS REGADING THE USE OF PERSONAL PROTECTIVE EQUIPMENT.

Print Sign Print Sign


Facility SOP 16 - TSO Facility Inspections

16.1. General

Facility Inspections are a critical part of maintaining an operation that is safe for employees, the community and the environment. Scheduled inspections of the facility and wastes help to control hazards in a pro-active manner and to minimize the risk of incidents at the TSO. The following inspections are required at the ACT TSO:

• Daily inspection of container handling areas • Weekly inspection of container storage areas • Monthly inspection of the facility and safety equipment • Annual inspection of fire suppression I safety equipment

16.2. Daily Inspections

16.2.1. Daily inspection includes inspection of container handling areas for evidence of spills and/ or hazards that can result in spills. Areas that are to be inspected include:

• Dock areas • Dock sumps • Trailer parking and yard(including under trailers) • Processing areas for consolidation • Storage area aisle ways (to ensure unobstructed egress) • Inbound processing area (scales) • HHW processing area • Roll-off containment pads • Containment ponds • Fencing and gates for evidence of break ins

16.2.2. Each area is inspected for evidence of spills, safety hazards, proper housekeeping and availability of safety equipment.

16.2.3. A copy of the Daily Inspection Form is included below

16.3. Weekly Inspections

16.3.1. Weekly inspections will be conducted in all container storage areas ensure that there are no containers that are leaking, or are at risk of leaking. Items on the weekly inspection include:

• Inspection of all containers for proper labeling • Containers are in good condition • Evidence of pressure or vacuum in containers • Pallets are in good condition • Storage racks are in good condition • No flammable or reactive wastes stored within 50 feet of the property line • Safety showers and eyewashes are in good working condition and kept clear • No wastes are stored on the dock(s) overnight • Personal Protective Equipment is available and well stocked • Adequate Housekeeping


16.3.2. A copy of the Weekly Inspection Form is included below

16.4. Monthly Inspections

16.4.1. Monthly inspections will be conducted to ensure that in the event of an emergency, safety equipment will be available and in good working condition in the event of an emergency. Monthly inspections include:

• Self-Contained Breathing Apparatus (SCBA) pass alarm check and are completely charged

• Fire extinguishers are under the correct pressure and are in good condition • Spill Kits are in good condition and are well stocked • The Fire suppression system is in good condition and risers are kept clear • The facility floor is sealed and free of cracks • Portable emergency eyewash is serviced • Housekeeping is adequate • Any other hazards that may exist


16.5. Annual Inspections

16.5.1. Annual inspections are related to specific equipment that may require annual inspection and certification on an annual basis to ensure a safe environment for employees, the community and the environment. Annual inspections include:

• Fire doors • Fire suppression system • The facility roof • Parking area asphalt condition • Condition of Containment Areas


16.6. Inspection Procedure

16.6.1. Review the previous day inspection for deficiencies that may need correction or are still in process. If a deficiency is still in process, follow up daily to check progress and document on the form.

16.6.2. Perform the inspection using the inspection form. Note any deficiencies that are discovered. In the event the deficiency can be immediately corrected. Correct the deficiency and note on the form that the deficiency was immediately corrected.

16.6.3. Once complete, review the inspection with the TSD manager in order to develop a corrective action plan for any deficiencies that cannot be immediately corrected.

16.6.4. Sign and date the form

16.6.5. File the form according to the record retention procedure.

ACTreatment Facility Operations Manual Page SO of 119

ACT DAILY INSPECTION SHEET ;\d,u01c >d (h, ,,;~ul r,, ~ nl

Inspector: Signature:

Date: Time:

CRITERIA/OBSERVATIONS STATUS0

DATE AND NATURE OF

(A)/(U) REPAIRS/ REMEDIAL ACTION AND COMMENTS

Inspect each container storage area for evidence of spills, safety hazards, proper housekeeping and availability/accessibility of safety equipment:

• Dock areas

• Dock sumps

• Trailer parking and yard(including under trailers)

• Processing areas for consolidation

• Storage area aisle ways for egress

• Inbound processing area (scales)

• HHW processing area

• Roll-off containment pads

• Containment ponds

• Fencing and gates for evidence of break ins

*~=Acceptable,!!= Unacceptable

Notes/Comments:

I certify that the above recommended action has been taken on items mentioned above and/or defective items are now satisfactory.

Supervisor: Date:


ACT WEEKLY INSPECTION SHEET i"»'h""'<'d Cn -n;.(1!lr<·;;' <' "

"' Inspector: Signature:

Date: Time:

CRITERIA/OBSERVATIONS STATUS .

DATE AND NATURE OF REPAIRS/

(A)/(U) REMEDIAL ACTION AND COMMENTS

Inspect each container storage area for the following:

• All containers are properly labeled

• Containers are in good condition

• No evidence of pressure or vacuum in containers

• Pallets in use are in good condition

• Storage racks are in good condition

• No flammable or reactive wastes stored within 50 feet of the property line

• Safety showers and eyewashes are in good working condition and kept clear

• No wastes are stored on the dock(s) overnight

• Personal Protective Equipment is available and well stocked

• Housekeeping is adequate

""'"""', *~=Acceptable, Y. =Unacceptable

Notes/Comments:


Supervisor: Date:


ACT MONTHLY INSPECTION SHEET J',d«0'1:t•d(hc•-.,iJro1TnT' •1,·;11


Date: Time:

CRITERIA/OBSERVATIONS STATUS• DATE AND NATURE OF REPAIRS/


Inspect each container storage area for the following:

• Self-Contained Breathing Apparatus (SCBA) pass alarm check and are completely charged

• Fire extinguishers are under the correct pressure and are in good condition

• Spill Kits are in good condition and are well stocked

• The Fire suppression system is in good condition and risers are kept clear

• The facility floor is sealed and free of cracks

• Portable emergency eyewash is serviced

• Housekeeping is adequate

*~=Acceptable, Y. =Unacceptable

Notes/Comments:


Supervisor: Date:


ACT ANNUAL INSPECTION SHEET t.t»,0•11u•d (lh''ll/.nlT•c•<''r·• nl


Date: Time:

CRITERIA/OBSERVATIONS STATUS• DATE AND NATURE OF REPAIRS/


Ensure the following items are inspected/certified annually:

• Fire doors

• Fire suppression system

• The facility roof

• Parking area asphalt condition

• Condition of Containment Areas

*~=Acceptable, Y. = Unacceptable

Notes/Comments:


Supervisor: Date:


Waste SOP 1 - Aerosols

1.1. Safety - General

1.1.1. Aerosol wastes contain chemicals packaged under pressure. Improper handling of

aerosols can result in fire, explosion, projectile or chemical exposure. See section 1.6.6 of this SOP for additional safety warnings and safe work procedures.

1.2. Waste Description I Qualification

1.2.1. Aerosol cans (Aerosols) are defined as a dispenser that holds a substance under pressure and allows the substance to be released as a fine spray. Common aerosol cans that are managed at the TSD include:

• Spray Paints • Pesticides • Cleaners

Automotive products Medicines Other consumer goods packaged in aerosol cans

1.2.2. Aerosols may be received at the TSD as Hazardous Waste, Universal Waste or Household Hazardous Waste or Non-Hazardous waste. All Aerosols wastes that are qualified for this program must have the following properties:

The waste meets the definition of an Aerosol per this procedure • The waste is properly characterized • The waste contains chemical constituents and / or waste codes that are not

prohibited from management at the TSD

1.2.3. Aerosols eligible for consolidation are assigned the following process codes in the WMSS:

• FUELS AERO FUELS AERO UNIVERSAL

1.3. Quality Control

1.3.1. QC Parameters

Upon Receipt, waste that is intended for the program is physically checked and evaluation is performed to ensure that the description on the profile is accurate, and that the waste will meet the requirements for the outbound management program. QA/QC data that is generated upon receipt of the waste includes:

1.3.2. The containers meet the definition of an aerosol per this procedure and the profile

• The waste is contained in its original container • The waste is properly labeled and is identified • The container is in acceptable condition, compatible with the waste, has no

damage and is properly closed

1.3.3. QC Steps

Inspect the outside of the container for conditions that could be a safety hazard.


• Inspect the container for proper labeling Per RCRA and Department of Transportation Labels as required.

• Open the shipping container • Inspect the waste for the above QC parameters and Record the results of the QC

on the QC Form.


• Note any discrepancies on the QC Form. • Non-conforming wastes are quarantined until disposition can be determined by

notifying the generator. • Non-conforming waste disposition may include re-routing of the waste to a more

appropriate program or rejection of the waste back to the generator.

1.4. Receiving

1.4.1. Physical Receiving of Waste

• Label the waste with the TSO inventory label/ barcode for inventory tracking. • Once the waste has passed QC check, and can be received into the TSO, the waste

will be physically received into the warehouse, and the Operating record will be updated to reflect the status and location of the waste.

1.4.2. Operating Record Update

The operating record will be updated with the receiving information that is required for receipt of the waste.

• Weight of the waste • Disposition of the waste • Storage location of waste

1.5. Storage

1.5.1. Storage Parameters

• The storage parameters of the waste are determined by the chemical composition of the waste.

• Flammable Aerosol wastes must be stored in Room C or Room D, which are designated as flammable/ organic storage areas.

1.5.2. Aerosol wastes are stored in their original containers, as shipped to the TSD, unless

there is a discrepancy or safety issue, in which the container may be changed by TSD

personnel, in order to meet DOT requirements, or TSD requirements.

1.6. Processing

1.6.1. Packaging I Labeling

Aerosols will be consolidated into DOT shipping containers such as cubic yard boxes or drums. Each consolidated container must be immediately labeled per RCRA I DOT I TSD requirements and entered into the WMSS inventory for proper tracking.

1.6.2. Processing Method - Consolidation

Consolidating flammable waste has risk of fire, explosion or chemical exposure. All employees are required to wear the proper personal protective equipment and follow


the required safety procedures when performing consolidations. Failure to do so may cause fire, injury or death.

• Locate and stage the wastes selected for consolidation on the Pick List. Initial the Pick List when each item is pulled and staged;

• Don the required PPE for consolidation (level D); • Open the containers of material to be consolidated; • Transfer the waste to the receiving container. Aerosols will be processed into

larger containers by hand, taking care not to discharge aerosols during handling. • Repeat steps above until the container is completely loaded with consolidated

waste; and • Note any non-conformances or discrepancies on the Pick List as they arise. • Universal Waste aerosols and Hazardous Waste aerosols are managed downstream

as Hazardous Waste or Universal Waste as designated by the generator on the waste profile. HHW aerosols are managed as Non-RCRA waste.

1.6.3. Processing Method - Solvent Reclaim

• Aerosols may be processed into "Puncture and Reclaim" system which will allow the solvents I materials to be consolidated into a container for management as liquid fuels.


• Don the required PPE for consolidation (level D); • Open the shipping containers of material to be consolidated; • Transfer the waste to the receiving container. Follow all processing equipment

operating instruction and safety rules to prevent safety health and environmental hazards.

• Repeat steps above until the receiving container is completely loaded with consolidated waste; and

• Note any non-conformances or discrepancies on the Pick List as they arise.

1.6.4. Tracking of Data

Maintaining data is essential for compliance, safety and inventory management efficiency. Failure to adequately track the data associated with the wastes that are handled by the TSD can result in non-compliance, safety hazards and re-work.

• Scan each container using a data acquisition terminal (scanner) to the receiving container location after they are transferred to the consolidation container. This will ensure tracking of the waste to the new container.

• Initial that each container was loaded to the receiving container on the Pick List. • When the container is full, close and secure the container then remove the

container from the consolidation area. • Return the completed Pick List to the HWC to complete the consolidation process

in the WMSS. • Repeat steps above until the container is completely loaded with consolidated

waste. • Note any non-conformances or discrepancies on the Pick List as they arise.


1.6.5. Housekeeping

• Clean-up and contain debris and place clean-up material and sheeting in an open top drum for disposal as Non-Hazardous Waste.

• Empty containers need to be de-faced, labeled as "EMPTY" and dated then sent for recycling or disposal within one year.

1.6.6. Processing Safety

• Aerosol wastes can be flammable, corrosive or toxic, take care not to accidentally discharge aerosol waste during handling, which can create a fire, injury or environmental hazard.

• No spark generating tools or equipment is allowed in the processing area when consolidation is in progress

• Follow all safety rules for processing equipment when operating. • Manual handling of Aerosols can cause strains/ sprains. Use safe lifting techniques

and proper tools to help prevent injuries. • Level D PPE is required for all employees involved in consolidating waste to

provide cross contamination protection. The following Level D personal protective equipment is required at a minimum:

o Eye Protection o Disposable apron or Tyvek suit o Chemical protective gloves


Waste SOP 2 - Battery Wastes (Universal Waste)


2.1.1. The Hazardous Materials contained in Battery Wastes can injury or environmental

damage if not handled properly. See section 2.6.5 of this SOP for additional safety

warnings and safe work procedures.


•

• • • • •

2.2.1.

• • •

•

2.2.2.

• • • • •

Battery Wastes are defined as batteries that are no longer needed for service or have been spent. Battery wastes are typically shipped to and received by the TSO as universal waste. Many of the Battery wastes shipped to the TSO contain metals such as cadmium, nickel and lead which can be hazardous if released. Common types of Battery wastes that are managed at the TSO include but are not limited to: Lead-acid batteries Nickel-cadmium batteries Alkaline batteries Mercury containing batteries Lithium batteries

Battery Wastes may be received at the TSO as Hazardous Waste (if broken and

contains a hazardous constituent) or Non-Hazardous I Universal waste (if not broken

and intact). All Battery wastes that are qualified for this program must meet the following requirements:

The waste meets the definition of a battery eligible for management at the TSO The waste is properly characterized The waste is managed per the Universal Waste management rules set forth in 40 CFR Part 262. (Broken batteries are managed at the TSO as hazardous waste) Each container has been reviewed and approved for shipment to the TSO

Battery waste eligible for consolidation are assigned the following process codes in

the WMSS:

Univ Bat Lith Univ Bat NiCad Univ Bat Lead Univ Bat Alk Univ Bat Mere



Upon Receipt, waste that is intended for the program is physically checked and evaluation is performed to ensure that the description on the profile is accurate, and that the waste will meet the requirements for the outbound management program. Results are recorded on the Quality Assurance/Quality Control (QA/QC) Report that accompanies the manifest. QA/QC data that is generated upon receipt of the waste includes:

• The waste meet the definition of a Battery waste per this procedure and the profile • The waste is properly labeled and identified


• The container is in acceptable condition, compatible with the waste, has no damage and is properly closed

2.3.2. QC Steps

• Inspect the container for conditions that could be a safety hazard • Inspect the container for proper labeling Per RCRA and Department of

Transportation Labels as required • Batteries that are broken during transportation should be handled as described in

2.6.2, below. • Inspect the waste for the above QC parameters and Record the results of the QC

on the QC Form.





2.4. Receiving


• Label the waste with the TSO inventory label I barcode for inventory tracking • Once the waste has passed QC check, and can be received into the TSO, the waste





2.5. Storage

2.5.1. The storage parameters of the waste are determined by the chemical composition of the waste.

2.5.2. Corrosive Battery wastes must be stored in Room E (alkaline) or Room F (acid and all other batteries)

2.5.3. Other batteries which are Class 9 or non-DOT regulated wastes may be stored in any room

2.6. Processing instructions


• Battery wastes are consolidated into shipping containers that are acceptable to properly contain the Battery waste and prevent breakage. Each consolidated


container must be immediately labeled per RCRA I DOT I TSD requirements as Universal Waste and entered into the WMSS inventory for proper tracking.

• Universal wastes that are hazardous materials under 49 CFR 171 through 180 must comply with DOT labeling requirements


Consolidating Battery waste has risk of fire, chemical exposure and environmental contamination. All employees are required to wear the proper personal protective equipment and follow the required safety procedures when performing consolidations. Failure to do so may cause exposure, injury or illness.

• Dry batteries greater than 9 volts, all lithium batteries and wet cell batteries, should always be protected against short circuit or prevented from becoming oriented in a manner that allowed the creating of a circuit and packaged in a manner that prevents excessive movement. This will eliminate a short from occurring and the dangerous evolution of heat. This can be completed by taping all terminals or contacts with electrical tape or contact covers. When using tape to effectively insulate batteries, ensure that marking remain visible to aid in the identification of batteries downstream.

• Do not use metal drums to pack lead acid batteries. • Do not lay batteries on their side as leaking will occur. • Containers larger than 5-gallons in size must be secured to pallets for shipping.

NOTE: • Containers for Lithium, Lithium Ion and Magnesium batteries are limited to 5-

gallons in size (66 pound gross weight per container). • All batteries must be kept DRY. However, do not package batteries with

vermiculite, desiccant, or other packaging material. • All batteries must be segregated by DOT compatibility and packaged in accordance

with USDOT regulations. • Large batteries should be uniformly stacked, layered with insulation and secured or

banded onto their pallets. • Leaking batteries must be packaged as follows:

o Separate all free liquid from battery casing. This liquid should be placed in a poly lHl drum or other DOT container compatible with the battery liquid.

o Place the battery carcasses in a poly drum liner (4 mil thickness) and place in a poly 1H2 5



• Scan each container using a data acquisition terminal (scanner) after they are transferred to the consolidation container. This will ensure tracking of the waste to the new container.


container from the consolidation area.


• Return the completed Pick List to the HWC to complete the consolidation process in the WMSS.

• Repeat steps above until the receiving container is completely loaded with consolidated waste.


2.6.4. Housekeeping




• Battery wastes can cause fire if not properly packaged. Batteries are also toxic and harmful to the environment. Take care not to accidentally break Battery wastes during handling, which can create injury or environmental hazard.

• Use care when handling broken batteries to avoid chemical exposure injury • Consolidation of battery wastes may be done inside of the warehouse as there is

no intentional handling of open waste containers. • In the event of a broken battery is discovered:

o Move the container to a well-ventilated and contained area for processing. o Wear appropriate personal protective equipment, such as a respirator and leather

gloves to keep vapors or dust from being inhaled or contacting your skin. o Follow section 6.2.9 of this procedure for packaging instructions.

• Use care if opening Battery waste containers during consolidation. Inner containers can be damaged I broken during transportation.

• Level D PPE is normally required for all employees involved in consolidating waste to provide cross contamination protection. In the event of a broken battery, a higher level of protection may be required depending on the hazards associated with the broken battery. A Health and Safety evaluation is necessary prior to repackaging.


Waste SOP 3 - Electronic Wastes (Universal Waste)


3.1.1. The Hazardous Materials contained in Electronic Wastes can injury or environmental

damage if not handled properly. See section 3.6.5 of this SOP for additional safety

warnings and safe work procedures.


• Electronic Wastes are defined as electrical devices that are no longer needed for service or have been spent. Electronic wastes are typically shipped to and received by the TSD as universal waste. Many of the Electronic wastes shipped to the TSD contain metals such as cadmium, nickel, silver and lead which can be hazardous to health and environment if released. Common types of Electronic wastes that are managed at the TSD include but are not limited to:

• Computers • Monitors • Printers • Any other electronic equipment

3.2.1. Electronic Wastes may be received at the TSD as Universal waste. All Electronic

wastes that are qualified for this program must meet the following requirements:

• The waste meets the definition of Electronic waste per section 2.1 • The waste is properly characterized • The waste is managed per the Universal Waste management rules set forth in 40

CFR Part 262. • Each waste profile has been reviewed and approved for shipment to the TSD

3.2.2. Electronic waste eligible for consolidation are assigned the following process codes

in the WMSS:

• Univ E-Waste • Univ CPU's • Univ NonPCB Ballast




• The waste meet the definition of an Electronic waste per this procedure and the profile

• The waste is properly labeled and identified • The container is in acceptable condition, compatible with the waste, has no



""'""' 3.3.2.

• •

•

•

3.3.3.

• •

•

QC Steps

Inspect the container for conditions that could be a safety hazard Inspect the container for proper labeling Per RCRA and Department of Transportation Labels as required Items that are broken during transportation should be left in the container they arrived in, and the package should be sealed to prevent any material from spilling. Inspect the waste for the above QC parameters and Record the results of the QC on the QC Form.

Discrepancies

Note any discrepancies on the QC Form . Non-conforming wastes are quarantined until disposition can be determined by notifying the generator. Non-conforming waste disposition may include re-routing of the waste to a more appropriate program or rejection of the waste back to the generator.

3.4. Receiving


• Label the waste with the TSD inventory label/ barcode for inventory tracking. • Once the waste has passed QC check, and can be received into the TSD, the waste





3.5. Storage

3.5.1. Electronic wastes are normally shipped as Class 9 or non-DOT regulated and may be

stored in any room



• Electronic wastes are consolidated into shipping containers or are palletized in a manner that is acceptable to properly contain the waste and prevent breakage. Each consolidated container must be immediately labeled per RCRA I DOT I TSD requirements as Universal Waste and entered into the WMSS inventory for proper tracking.

o Palletizing is the most efficient way to prepare large quantities of waste electrical and electronic equipment for shipment.

o Smaller quantities can be packaged in boxes, small crates or as individual pieces

• Universal wastes that are hazardous materials under 49 CFR 171 through 180 must comply with DOT labeling requirements.


3.6.2. Processing Method - Shipment

• If shipping via a Bill of Lading, attach a universal waste label to the container. • Universal wastes that are hazardous materials under 49 CFR 171 through 180 must

comply with DOT labeling requirements.


Maintaining data is essential for compliance, safety and inventory management efficiency. Failure to adequately track the data associated with the wastes that are handled by the TSO can result in non-compliance, safety hazards and re-work.






3.6.4. Housekeeping




• Electronic waste can be toxic and harmful to the environment. Take care not to accidentally break Battery wastes during handling, which can create injury or environmental hazard.

• Use care when handling electronics to avoid injury • Consolidation of electronic wastes may be done inside of the warehouse as there is

no intentional handling of open waste containers. • Use care if opening Electronic waste containers during consolidation. Inner

containers can be damaged I broken during transportation. • Level D PPE is normally required for all employees involved in consolidating waste

to provide cross contamination protection.


Waste SOP 4 - Labpack Consolidation


4.1.1. The Hazardous Materials contained in Labpack drums can cause fire, injury, death or

environmental damage if not handled properly. See section 4.6.5 of this SOP for

additional safety warnings and safe work procedures.


• Labpacks are defined as a containerized chemical wastes that are packaged into a secondary container for transportation and disposal. Labpacks often contain more than one container of chemical, and are segregated by DOT hazard class and other hazard characteristics as defined by regulation and policy. Common Labpacks that are managed at the TSO include Laboratory and industrial chemicals that are spent or expired.

4.2.1. Labpacks may be received at the TSD as Hazardous Waste or Non-Hazardous waste. The hazards associated with Labpacks can vary, as they may be corrosive,

flammable, reactive and toxic All Labpacks that are qualified for this program must meet the following requirements:

• The waste is qualified for Labpack transportation and disposal per DOT and RCRA regulation

• Each inner container is adequately identified • Each drum contains inner containers that are compatible with each other per DOT,

RCRA regulation, chemical properties and final TSO requirements • Each drum has been reviewed and approved for shipment to the TSO

4.2.2. Labpacks eligible for consolidation are assigned the following process codes in the

WMSS:

• LP Non-Reactive • LP Reactive • LP Lithium




• The waste meet the definition of a Labpack per this procedure and the profile • The waste is properly labeled and identified • The container is in acceptable condition, compatible with the waste, has no


4.3.2. QC Steps

• Inspect the container for conditions that could be a safety hazard


• Inspect the container for proper labeling Per RCRA and Department of Transportation Labels as required

• Inspect the container for Labpack inventory attachments. For Labpacks that do not have the inventory attached, report to the TSO Operations Manager for retrieval of the inventory sheets from the profile documentation.

• Inspect the waste for the above QC parameters and Record the results of the QC on the QC Form.





4.4. Receiving







4.5. Storage

4.5.1. The storage parameters of the waste are determined by the chemical composition

of the waste.

4.5.2. Labpack waste will be stored as described in Facility SOP 7.3. Waste Segregation



• Labpacks are consolidated into DOT shipping containers. Each consolidated container must be immediately labeled per RCRA I DOT I TSO requirements and entered into the WMSS inventory for proper tracking.


Consolidating Labpack waste has risk of fire, explosion or chemical exposure. All employees are required to wear the proper personal protective equipment and follow the required safety procedures when performing consolidations. Failure to do so may cause fire, injury or death.


• Labpack activities will be conducted by employees with experience and training to perform Labpack tasks safely and effectively, referred to as Labpack Chemists

• Segregation of materials will be supervised by an experienced Labpack Chemist. Materials will be segregated based on hazard characteristics, chemical compatibility, liquid or solid, specific TSDF criteria, and DOT requirements.

• The Labpack Chemist(s) must be aware of materials that require special or specific attention. Examples of these types of materials are explosives, organic peroxides, self -reactive materials, reactive materials, mercury, controlled substance, poisoninhalation hazards, temperature sensitive, shock-sensitive materials, etc. Most of these materials require either special/specific packaging, dilution, specific TSDF requirements, separate profile, and in some cases manifested separately.

• After segregation, an inventory will be completed I consolidated on a lab pack inventory sheet per drum.

• All the requested information on the lab pack inventory sheet must be filled out completely.

o When listing the inventory on the lab pack inventory sheet, be very specific with chemical concentrations and percentages when listing the material (e.g. Nitric Acid 70% aqueous, or Butyllithium 1.0M solution in hexanes).

o Materials such as Pl H's, stenches, materials with water added should be placed in a zip lock bag or a sealable container prior to being placed into a drum or pail. This information should also be added to the lab pack inventory sheet as a special note or provision (e.g. mercaptoethanol, double bagged).

• Packing of the material should begin during or after a lab pack inventory sheet is completed. The appropriate container must be chosen based on hazard class, chemical compatibility, packing group, and special packaging requirements per DOT. For example, corrosive material should not be packed in metal containers based on chemical compatibility.

o Drum rating is important! ACT uses X or Y rated drums. Materials in DOT Packing Group II and Ill can be packed in Y-rated OR X-rated containers. However, materials in DOT Packing Group I can only be packed in X-rated containers.

o Some examples of Packing Group I materials are Poison-Inhalation Hazards (PIH), water-reactive materials, pyrophorics, cyanides, etc.

Once the proper container has been selected pour compatible absorbent into the bottom of the container as required by DOT, then add materials. Ensure that:

• All materials stand right side up • All containers are completely labeled • All containers are completely sealed • There is space between glass containers and layers so that compatible absorbent

can be poured into the gaps between glass to prevent breakage • After all the material is placed into a container, fill with compatible absorbent until

the drum is completely filled.

The project lead and/or field chemist will assign a drum number to each container and list the drum number on the lab pack inventory sheet accordingly.

• Leave a carbon copy of the lab pack inventory sheet with the container. All other carbon copies will be given to the project lead and/or field chemist for profiling.


The following items will be placed on each drum:

• •

DOT markings and labels Drum number

• Lab pack inventory sheet placed on the outside of the container inside the packaging slip (leave the packing slip open on one slide for modifications)








4.6.4. Housekeeping




• Labpack wastes can be flammable, reactive, corrosive and toxic. Take care not to accidentally release Labpack waste during handling, which can create a fire, injury or environmental hazard.

• Note - Every effort should be made to ensure that the Labpack Chemist(s) can be clearly seen by at least one other individual in case of an accidental spill/exposure during segregation and processing. ALWAYS LOOK OUT FOR ONE ANOTHER! Safety is our main priority.

• Consolidation of Labpack wastes may be done inside of the warehouse as there is no intentional handling of open waste containers. If a broken or open container is discovered, the container should be moved to a well-ventilated area for processing. Additional PPE will be necessary. Evaluate the hazard of the potentially released chemical for the appropriate PPE.

• Use care when opening Labpack containers during consolidation. Inner containers can be damaged I broken during transportation.

• Level D PPE is normally required for all employees involved in consolidating waste to provide cross contamination protection. In the event of a broken container, the following Level C personal protective equipment is required at a minimum:

o Air purifying respirator (full face)


o Disposable apron or Tyvek suit o Chemical protective gloves

Note - Many Labpacks contain chemicals with a high degree of hazard and higher levels of personal protection may be required depending on the nature of the hazard and circumstances.


Waste SOP 5 - Lamp Wastes (Universal Waste)


5.1.1. The Hazardous Materials contained in Lamps can injury or environmental damage if

not handled properly. See section 5.6.7 ofthis SOP for additional safety warnings

and safe work procedures.

5.2. Waste Description / Qualification

Lamp Wastes are defined as wastes that contain lamps of various types and are typically shipped to and received by the TSO as universal waste. Many of the lamps shipped to the TSO contain metals such as mercury and sodium, which can be hazardous if released. Common types of lamps that are managed at the TSO include:

• Fluorescent lamps • High pressure sodium lamps • HID lamps of various types

5.2.1. Lamp Wastes may be received at the TSD as Hazardous Waste (if broken and

contains a hazardous constituent) or Non-Hazardous I Universal waste (if not broken and intact). All Lamp wastes that are qualified for this program must meet the

following requirements:

• The waste meets the definition of a Lamp per the description in this procedure • The waste is properly characterized • The waste is managed per the Universal Waste management rules set forth in 40

CFR Part 262. • Each container has been reviewed and approved for shipment to the TSO

5.2.2. Lamp waste eligible for consolidation are assigned the following process codes in

the WMSS:

• Univ 4' Tubes

• Univ 8' Tubes

• Univ CFL's

• Univ U/Cir Tubes

• Univ HID's




• The waste meet the definition of a Lamp waste per this procedure and the profile • The waste is properly labeled and identified • The container is in acceptable condition, compatible with the waste, has no



5.3.2. QC Steps


Transportation Labels as required • Lamps that are broken during transportation should be left in the container they

arrived in, and the package should be sealed to prevent any material from spilling. • Inspect the waste for the above QC parameters and Record the results of the QC

on the QC Form.





S.4. Receiving


• Label the waste with the TSD inventory label I barcode for inventory tracking. • Once the waste has passed QC check, and can be received into the TSD, the waste





S.S. Storage


of the waste.

5.5.2. Lamp wastes must be stored in Room E or Room F, which are designated as areas

acceptable for Lamp wastes

5.5.3. Class 9 and non-DOT regulated wastes may be stored in any room

S.6. Processing instructions

5.6.1. Processing Location

• Lamp waste consolidation may take place in any of the rooms designated for storage of lamp wastes, or on the docks.


• Lamp wastes are consolidated into shipping containers that are acceptable to properly contain the Lamp waste and prevent breakage. Each consolidated


container must be immediately labeled per RCRA I DOT I TSD requirements as Universal Waste and entered into the WMSS inventory for proper tracking.

• Universal wastes that are hazardous materials under 49 CFR 171 through 180 must comply with DOT labeling requirements.


Consolidating Lamp waste has risk of chemical exposure and environmental contamination. All employees are required to wear the proper personal protective equipment and follow the required safety procedures when performing consolidations. Failure to do so may cause exposure, injury or illness.

• Lamp wastes may be consolidated individually by lamp, or by original shipping container into larger containers such as drums or cubic yard boxes.

• The following items will be placed on each drum: • DOT markings and labels • Drum number • Lab pack inventory sheet placed on the outside of the container inside the

packaging slip {leave the packing slip open on one slide for modifications)

5.6.4. Processing Method - Crushing

• Lamp wastes may be consolidated into a "Bulb Eater" system which will safely crush the bulbs into a drum which will be managed as hazardous waste.

• Broken fluorescent lamps or crushed lamps are to be managed as hazardous waste, and must be packaged and shipped per the requirements of 49 CFR 171 through 180 as hazardous materials.


• Don the required PPE for consolidation {level D); • Open the shipping containers of material to be consolidated; • Transfer the waste to the receiving container. Follow all processing equipment

operating instruction and safety rules to prevent safety health and environmental hazards.

• Repeat steps above until the receiving container is completely loaded with consolidated waste; and




• Scan each container using a data acquisition terminal (scanner) after they are transferred to the consolidation container. This will ensure tracking of the waste to the receiving container.



in the WMSS.


• Repeat steps above until the container is completely loaded with consolidated waste.


5.6.6. Housekeeping




• Lamp wastes can be toxic and harmful to the environment. Take care not to accidentally break Lamp waste during handling, which can create injury or environmental hazard.

• Many Lamp wastes have poor warning properties in the event of a release or contamination. Never rely on odor as a warning property for wastes which may contain mercury, as it has no odor.

• Use care when handling broken lamps to avoid injection injury • Consolidation of Lamp wastes may be done inside of the warehouse as there is no

intentional handling of open waste containers. • In the event of a broken lamp is discovered:

o Move the container to a well-ventilated and contained area for processing. o Wear appropriate personal protective equipment, such as a respirator and leather

gloves to keep bulb dust and glass from being inhaled or contacting your skin. o Carefully remove the larger pieces and place them in a secure closed container. o Collect the smaller pieces and dust. It is recommended that you use two stiff pieces

of paper such as index cards or a mercury spill kit. o Put all material into a sealed container. Pat the area with the sticky side of duct

tape, packing tape or masking tape. Wipe the area with a damp cloth. o Put all waste and materials used to clean up the bulb in a secure closed container

and label it "Universal Waste - broken lamp". Additional PPE may be necessary. Evaluate the hazard of the potentially released chemical for the appropriate PPE.

• Use care if opening Lamp waste containers during consolidation. Inner containers can be damaged/ broken during transportation.


o Air purifying respirator (full face) o Disposable apron or Tyvek suit o Chemical protective gloves


Waste SOP 6 - Landfill Liquids


6.1.1. Landfill Liquids can cause injury, death or environmental damage if not handled

properly. See section 6.5 of this SOP for additional safety warnings and safe work procedures.


6.2.1. Landfill Liquids are defined as a liquid material that is eligible for disposal by landfill, with additional treatment such as solidification or stabilization depending on the waste characteristics and regulatory rules. Common Landfill Liquids that are

managed at the TSD include:

• Non RCRA regulated low BTU liquids • RCRA regulated low BTU liquids • Corrosive bases and acids • Other liquids that are accepted at the TSD that can legally be disposed of in a

landfill

6.2.2. Landfill Liquids may be received at the TSD as RCRA Hazardous Waste or Non - RCRA waste. All Landfill Liquids that are qualified for this program must have the following properties:

• The waste is non-RCRA regulated or • The waste is RCRA regulated but authorized for Landfill per the downstream TSD

permit, either with or without additional treatment and the final TSD

6.2.3. Landfill Liquids eligible for consolidation are assigned the following process codes in

the WMSS:

• LF Liq Non-Haz

• LF Liq Acid

• LF Liq Base

• LF Liq RCRA




• The waste meets the description of the waste per the approved profile • The waste is properly labeled and is identified • The container is in acceptable condition, compatible with the waste, has no

damage and is properly closed • pH • Layers


• Color • % Water • Sludge

6.3.2. QC Steps


Transportation Labels as required • Open the container • Inspect the waste for the above physical QC parameters using a coliwasa or similar

sampling device and Record the results of the QC on the QC Form • Conduct a chemical analysis as needed (pH, % water) on a representative number

of containers using the "cube root" procedure, as described in WAP Section 4.2





6.4. Receiving







6.5. Storage


of the waste.

6.5.2. Landfill Liquid wastes must be stored in the appropriate warehouse room based on

the DOT hazard class and compatibility chart, when applicable.




• Landfill Liquids are consolidated into DOT shipping containers such as drums, totes or tank trucks. Each consolidated container must be immediately labeled per RCRA


/ DOT / TSO requirements and entered into the WMSS inventory for proper tracking.


Consolidating Landfill Liquid waste has risk of chemical exposure due to chemical contaminants and potential for dust. All employees are required to wear the proper personal protective equipment and follow the required safety procedures when performing consolidations. Failure to do so may cause injury or death.

• The HWC will provide a list of containers identified for consolidation. Only the containers on the list provided are allowed to be consolidated. Additions to the Pick List will require approval by the HWC or Operations Manager after review of the waste profile.

• Stage and prepare the receiving container(s) as needed. • Stage and prepare the containers designated for consolidation, but leave the

container openings closed / covered until consolidation to minimize emissions from the containers.


• Don the PPE required in Section 6.5.6; • Open the containers of material to be consolidated; • Transfer the waste to the receiving container; • Repeat steps above until the container is completely loaded with consolidated

waste; and • Note any non-conformances or discrepancies on the Pick List as they arise.



• Scan each container using a data acquisition terminal (scanner) to the bulk location after they are transferred to the consolidation container. This will ensure tracking of the waste to the new container.





6.6.4. Housekeeping





• Landfill Liquid waste can toxic or harmful. Take care not to accidentally release the waste during handling, which can create injury or environmental hazard. Keep the work area clean and free of spilled waste.

• Clean up small spill and drips immediately • Consolidation of Landfill Liquid wastes must be done outside of the warehouse, on

the docks to allow for proper ventilation • Follow all safety rules for processing equipment when operating • Manual handling of Landfill Liquid containers can cause strains I sprains. Use safe

lifting techniques and proper tools to help prevent injuries. • Level D PPE is required for all employees involved in consolidating waste to

provide cross contamination and exposure protection. The following Level D personal protective equipment is required at a minimum:


• When consolidating RCRA regulated Landfill Liquids or any other Landfill Liquids that may constitute a respiratory hazard, Level C protection is required:

o Full Face Air Purifying Respirator o Disposable apron or Tyvek suit o Chemical protective gloves


Waste SOP 7 - Landfill Solids

7 .1. Safety - General

7.1.1. Landfill Solids can cause injury, death or environmental damage if not handled

properly. See section 7.6.6 ofthis SOP for additional safety warnings and safe work procedures.

7 .2. Waste Description I Qualification

7.2.l. Landfill Solids are defined as a solid material that is eligible for disposal by landfill, either with additional treatment or without additional treatment, depending on the waste characteristics and regulatory rules. Common Landfill Solids that are managed at the TSD include:

• Debris with or without contaminants • Production trash • Lab trash • Filters and medias • Other solids that are generated but can legally be disposed of in a landfill

7.2.2. Landfill Solids may be received at the TSD as Hazardous Waste or Non-Hazardous waste. All Landfill Solids that are qualified for this program must have the following properties:

• The waste contains no free liquid • The waste is non-RCRA regulated • The waste is RCRA regulated but authorized for Landfill either with or without

additional treatment and the final TSD

7.2.3. Landfill Solids eligible for consolidation are assigned the following process codes in the WMSS:

• LF Solids RCRA • LF Solids NH

7 .3. Quality Control


Upon Receipt, waste that is intended for the program is physically checked to and evaluation is performed ensure that the description on the profile is accurate, and that the waste will meet the requirements for the outbound management program. Results are recorded on the Quality Assurance/Quality Control (QA/QC) Report that accompanies the manifest. QA/QC data that is generated upon receipt of the waste includes:

• The waste meet the definition of a Landfill Solid per this procedure • The waste meets the description of the waste per the approved profile • The waste is properly labeled and is identified • The container is in acceptable condition, compatible with the waste, has no



7 .3.2. QC Steps


Transportation Labels as required • Open the container • Inspect the waste for the above QC parameters and Record the results of the QC

on the QC Form.





7.4. Receiving


• Label the waste with the TSO inventory label I barcode for inventory tracking. • Once the waste has passed QC check, and can be received into the TSO, the waste





7 .5. Storage


ofthe waste.

7.5.2. Landfill Solids wastes must be stored in the appropriate warehouse room based on

the DOT hazard class and compatibility chart, when applicable.




• Landfill Solids consolidation is allowed at the back dock, south dock, north dock or other location where a receiving container can safely be placed in proximity of the operation.


• Landfill Solids are consolidated into DOT shipping containers such as cubic yard boxes or roll-off containers. Each consolidated container must be immediately


labeled per RCRA I DOT/ TSD requirements and entered into WMSS inventory for proper tracking.


Consolidating Landfill Solids waste has risk of chemical exposure due to chemical contaminants and potential for dust. All employees are required to wear the proper personal protective equipment and follow the required safety procedures when performing consolidations. Failure to do so may cause injury or death.




• Locate and stage the wastes selected for consolidation on the Pick List. Initial the Pick List when each item is pulled and staged

• Don the PPE required in Section 6.6.7. • Open the containers of material to be consolidated • Transfer the waste to the receiving container or equipment

o Landfill Solids may also be processed into compaction or shredding systems which will allow the materials to be consolidated into a container for efficient transportation of the waste.

• For compaction or shredding, the material must be transferred to the processing equipment using all applicable ACTreatment SOPs, processing equipment operating instruction, and safety rules to prevent safety health and environmental hazards.

• Repeat steps above until the container is completely loaded with consolidated waste


7 .6.4. Tracking of Data








7.6.5. Housekeeping




• Landfill Solids waste can toxic or harmful. Take care not to accidentally release the waste during handling, which can create injury or environmental hazard. Keep the work area clean and free of loose waste.

• Consolidation of Landfill Solids wastes must be done outside of the warehouse, on the docks to allow for proper ventilation

• Follow all safety rules and procedures for processing equipment when operating. • Never operate shredding or compaction equipment without all guards and

interlocks in place, and never bypass an interlock or guarding device, as it can result in serious injury or death. Always follow the SOP for the equipment!

• Manual handling of Landfill Solids can cause strains / sprains. Use safe lifting techniques and proper tools to help prevent injuries.

• Many Landfill Solids can be sharp, use tools instead of hands to move waste to the consolidation container.

• Level D PPE is required for all employees involved in consolidating waste to provide cross contamination protection. The following Level D personal protective equipment is required at a minimum:


• When consolidating RCRA regulated Landfill solids or any other Landfill Solids that may constitute a respiratory hazard, Level C protection is required:

o Full Face Air Purifying Respirator o Disposable apron or Tyvek suit o Chemical protective gloves

• Many Landfill Solids can be dusty. Use light water spray from pump sprayers to help minimize dust emissions.


Waste SOP 8 - Liquid Fuels


8.1.1. Liquid Fuels (Flammable Liquids) can cause fire, injury, death or environmental

damage if not handled properly. See section 8.6.5 of this SOP for additional safety warnings and safe work procedures.


8.2.1. Liquid Fuels are defined as a liquid material that has fuel value greater than 5000 BTU. Common Liquid Fuels that are managed at the TSD include:

• Laboratory or Industrial Solvent wastes • Motor Fuels and lubricants • Automotive products • Other organic liquids that may have greater than 5000 BTU fuel value.

8.2.2. Liquid Fuels may be received at the TSD as Hazardous Waste or Non-Hazardous waste. All Liquid Fuels that are qualified for this program must have the following properties:

• The waste is liquid • The waste is organic and/or petroleum based • The waste is not corrosive as defined in 40 CFR 261.22 • The waste has a minimum of 5000 BTU fuel value as certified by the generator • The waste has a water content below 40%

8.2.3. Flammable liquids eligible for consolidation are assigned the following process codes

in the WMSS:

• Fuels Liq >5000 • Fuels Liq >5000 halogens • Fuels Liq <SO Solid • Fuels Liq >50 Solid




• The waste meet the definition of a Liquid Fuel per this procedure and the profile • The container is in acceptable condition, compatible with the waste, has no

damage and is properly closed • The waste is properly labeled and is identified • pH • Layers • Color


• % Water • Sludge

8.3.2. QC Steps









8.4. Receiving







8.5. Storage

8.5.1. The storage parameters ofthe waste are determined by the chemical composition

of the waste.

8.5.2. Flammable Liquid wastes must be stored in Room C or Room D, which are

designated as flammable I organic storage areas.

8.5.3. Optional storage may be in tanks, if the TSD is equipped to do so.



• Liquid Fuels are consolidated into DOT shipping containers such as totes or tank trailers. Each consolidated container must be immediately labeled per RCRA I DOT /TSO requirements and entered into the WMSS inventory for proper tracking.



Consolidating flammable waste has risk of fire, explosion or chemical exposure. All employees are required to wear the proper personal protective equipment and follow the required safety procedures when performing consolidations. Failure to do so may cause fire, injury or death.

Liquid Fuel consolidation is only allowed at the south dock or other suitable location where a certified grounding system is in place.

• Liquid fuels consolidation must take place in a 24 hour period once consolidation into the receiving container has started. Note the start date I time and finish date I time on the consolidation form.


• Stage and prepare the receiving container(s) as needed. • Stage and prepare the containers designated for pumping, but leave the container

openings closed / covered until pumping to minimize emissions from the containers.

• Ground and bond containers as described in Section 8.6.5 • Locate and stage the wastes selected for consolidation on the Pick List. Initial the

Pick List when each item is pulled and staged; • Don the PPE required in Section 8.6.5; • Open the containers of material to be consolidated; • Transfer the waste to the receiving container; • Repeat steps above until the container is completely loaded with consolidated




• Scan each container using a data acquisition terminal (scanner) to the bulk location after they are transferred to the consolidation container. This will ensure tracking of the waste to the tanker load.





8.6.4. Housekeeping





• Liquid Fuel wastes can be flammable and toxic. Take care not to accidentally release liquid fuel waste during handling, which can create a fire, injury or environmental hazard.


• Consolidation of Liquid Fuel wastes must be done outside of the warehouse, on the south dock or other suitable location to allow for proper ventilation

• Follow all safety rules for processing equipment when operating. • Manual handling of liquid fuels can cause strains / sprains. Use safe lifting

techniques and proper tools to help prevent injuries. • Level C PPE is required for all employees involved in consolidating waste to provide

chemical splash protection and respiratory protection. The following Level C personal protective equipment is required at a minimum:

o Air purifying respirator (full face) o Splash apron o Solvent protective gloves

• Bonding and grounding is required when consolidating flammable liquids. Bonding and grounding prevents the buildup of static electricity that could cause a fire or explosion when pumping or pouring flammable liquids. Serious injury or death could occur from explosion if bonding and grounding procedures are not followed!

o Bonding is completed by attaching a bond wire from the dispensing container to the receiving container. This creates a path for the static electricity to flow.

o Grounding is completed by connecting the dispensing container to a common ground. The common ground is connected to an earth ground. This system provides an electrical pathway for the static electricity to follow and be dissipated by the ground.

o The work area for tanker loading is equipped with a certified ground, where containers and tank trailers may be grounded.

o To be effective, bonding and grounding connections should be metal to metal between the containers and the cables. To get a good connection all paint, dirt and rust must be removed from the spots where the cable clamps will be attached.

o See below for grounding rod illustrations.


Figure 2-TankerConnected to Grounding Rod

Figure 1 - Grounding Rod on South Dock

Figure 3- ContainerConnected to Grounding Reel


Waste SOP 9 - Low BTU organic Liquids


9.1.1. Low BTU organic Liquids (which are commonly flammable) can cause fire, injury,

death or environmental damage if not handled properly. See section 9.6.5 of this

SOP for additional safety warnings and safe work procedures.


9.2.1. Low BTU organic Liquids are defined as a liquid material that is organic, or has significant organic constituents and has fuel value less than 5000 BTU. Common Low BTU organic Liquids that are managed at the TSD include:

• Laboratory or Industrial Solvent wastes • Water I Solvent Mixtures • Some HPLC wastes • Other organic liquids that may have less than 5000 BTU fuel value.

9.2.2. Low BTU organic Liquids may be received at the TSD as Hazardous Waste or NonHazardous waste. All Low BTU organic Liquids that are qualified for this program must have the following properties:

• The waste is liquid • The waste is contains organic and/or petroleum based constituents • The waste is not corrosive as defined in 40 CFR 261.22 • The waste has less than 5000 BTU fuel value as certified by the generator

9.2.3. Low BTU organic Liquids eligible for consolidation are assigned the following process codes in the WMSS:

• FUELS LIQ 2500-5000 • FUELS LIQ 0-2500




• The waste meet the definition of a Liquid Fuel per this procedure and the profile • The waste is properly labeled and is identified • The container is in acceptable condition, compatible with the waste, has no

damage and is properly closed • pH • • •

Layers Color Sludge


9.3.2. QC Steps









9.4. Receiving


• Label the waste with the TSO inventory label I barcode for inventory tracking. • Once the waste has passed QC check, and can be received into the TSD, the waste





9.5. Storage

• The storage parameters of the waste are determined by the chemical composition of the waste.

• Low BTU organic Liquids wastes must be stored in Room C or Room D, which are designated as flammable I organic storage areas.



• Low BTU organic Liquids are consolidated into DOT shipping containers such as totes or tank trailers. Each consolidated container must be immediately labeled per RCRA / DOT / TSO requirements and entered into the WMSS inventory for proper tracking.


Consolidating Low BTU organic Liquids waste has risk of fire, explosion or chemical exposure. All employees are required to wear the proper personal protective


equipment and follow the required safety procedures when performing consolidations. Failure to do so may cause fire, injury or death.

Low BTU organic Liquids consolidation is only allowed at the south dock or other suitable location where a certified grounding system is in place.

• The HWC will provide a list of containers identified for consolidation (see appendix A for a sample Pick List). Only the containers on the list provided are allowed to be consolidated. Additions to the Pick List will require approval by the HWC or Operations Manager after review of the waste profile.

• Stage and prepare the receiving container(s) as needed. • Stage and prepare the containers designated for pumping, but leave the container

openings closed / covered until pumping to minimize emissions from the containers.

• Ground and bond containers as described in Section 9.6.5 • Locate and stage the wastes selected for consolidation on the Pick List. Initial the

Pick List when each item is pulled and staged; • Don the PPE required in Section 9.6.5; • Open the containers of material to be consolidated; • Transfer the waste to the receiving container; • Repeat steps above until the container is completely loaded with consolidated









9.6.4. Housekeeping





• Low BTU organic Liquids wastes can be flammable and toxic. Take care not to accidentally release liquid fuel waste during handling, which can create a fire, injury or environmental hazard.


• Consolidation of Low BTU organic Liquids wastes must be done outside of the warehouse, on the south dock or other suitable location to allow for proper ventilation

• Follow all safety rules for processing equipment when operating. • Manual handling of Low BTU organic Liquids can cause strains / sprains. Use safe

lifting techniques and proper tools to help prevent injuries. • Level C PPE is required for all employees involved in consolidating waste to provide

chemical splash protection and respiratory protection. The following Level C personal protective equipment is required at a minimum:

o Air purifying respirator (full face) o Splash apron o Solvent protective gloves

• Bonding and grounding is required when consolidating flammable liquids. Bonding and grounding prevents the buildup of static electricity that could cause a fire or explosion when pumping or pouring flammable liquids. Serious injury or death could occur from explosion if bonding and grounding procedures are not followed!

o Bonding is completed by attaching a bond wire from the dispensing container to the receiving container. This creates a path for the static electricity to flow.

o Grounding is completed by connecting the dispensing container to a common ground. The common ground is connected to an earth ground. This system provides an electrical pathway for the static electricity to follow and be dissipated by the ground.

o The work area for tanker loading is equipped with a certified ground, where containers and tank trailers may be grounded.

o To be effective, bonding and grounding connections should be metal to metal between the containers and the cables. To get a good connection all paint, dirt and rust must be removed from the spots where the cable clamps will be attached.

o See below for grounding rod illustrations.


Figure 2- TankerConnected to Grounding Rod

Figure 1- Grounding Rod on South Dock

Figure 3 - ContainerConnectedto Grounding Reel


Waste SOP 10 - Mercury Wastes

10.1. Safety- General

10.1.1. The Hazardous Materials contained in Mercury Waste containers can injury, death

or environmental damage if not handled properly. See section 10.6.5 of this SOP for

additional safety warnings and safe work procedures.


• Mercury Wastes are defined as wastes that may contain elemental mercury, mercury compounds or mercury debris. Mercury wastes are managed with specific processes due to the nature of mercury waste and the specific disposal technologies required. Common Mercury Wastes that are managed at the TSD include:

• Elemental mercury • Laboratory I Industrial chemicals that contain mercury or mercury compounds • Thermostats, thermometers and other devices that contain mercury • Mercury containing debris from spill cleanup

10.2.1. Mercury Wastes may be received at the TSD as Hazardous Waste or Non-Hazardous

(Universal) waste. Mercury wastes may be corrosive and toxic. All Mercury wastes

that are qualified for this program must meet the following requirements:

• The waste meets the definition of a Mercury Waste per this procedure • The waste is properly characterized • The waste contains chemical constituents and I or waste codes that are not

prohibited from management at the TSD • Each drum has been reviewed and approved for shipment to the TSD

10.2.2. Mercury waste eligible for consolidation are assigned the following process codes in

the WMSS:

• Mercury Elemental • Mercury Compounds • Mercury Debris




• The waste meet the definition of a Mercury waste per this procedure and the profile

• The waste is properly labeled and identified • The container is in acceptable condition, compatible with the waste, has no



10.3.2. QC Steps


Transportation Labels as required • Inspect the waste for the above QC parameters and record the results of the QC on

the QC Form.





10.4. Receiving







10.5. Storage


of the waste.

10.5.2. Mercury wastes must be stored in Room E or Room F, which are designated as areas

acceptable for storage of corrosive I toxic mercury wastes




• Mercury wastes are consolidated into DOT shipping containers. Each consolidated container must be immediately labeled per RCRA I DOT I TSD requirements and entered into the WMSS inventory for proper tracking.


Consolidating mercury waste has risk of chemical exposure and environmental contamination. All employees are required to wear the proper personal protective equipment and follow the required safety procedures when performing consolidations. Failure to do so may cause exposure, injury or illness.


• Segregation of materials will be supervised by a Labpack Chemist. Materials will be segregated based on hazard characteristics, chemical compatibility, liquid or solid, specific TSDF criteria, and DOT requirements.

• After segregation, an inventory will be completed / consolidated on an inventory sheet per drum.

• All the requested information on the lab pack inventory sheet must be filled out completely.

• Packing of the material should begin during or after a lab pack inventory sheet is completed. The appropriate container must be chosen based on hazard class, chemical compatibility, packing group, and special packaging requirements per DOT. For example, corrosive material should not be packed in metal containers based on chemical compatibility.

• Once the proper container has been selected pour compatible absorbent into the bottom of the container as required by DOT, then add materials. Ensure that:

• All materials stand right side up • All containers are completely labeled • All containers are completely sealed • There is space between glass containers and layers so that compatible absorbent

can be poured into the gaps between glass to prevent breakage • After all the material is placed into a container, fill with compatible absorbent until

the drum is completely filled. • The project lead and/or field chemist will assign a drum number to each container

and list the drum number on the lab pack inventory sheet accordingly. • Leave a carbon copy of the lab pack inventory sheet with the container. All other

carbon copies will be given to the Lab Pack Chemist. • The following items will be placed on each drum: • DOT markings and labels • Drum number • Lab pack inventory sheet placed on the outside of the container inside the

packaging slip (leave the packing slip open on one slide for modifications)



• Scan each container using a data acquisition terminal (scanner) to the WMSS after they are transferred to the consolidation container. This will ensure tracking of the waste to the new container.






10.6.4. Housekeeping




• Mercury wastes can be corrosive and toxic. Take care not to accidentally release Labpack waste during handling, which can create injury or environmental hazard.

• Note - Every possible effort should be made to ensure that the Labpack Chemist(s) can be clearly seen by at least one other individual in case of an accidental spill/exposure during segregation and processing. ALWAYS LOOK OUT FOR ONE ANOTHER! Safety is our main priority.

• Many Mercury wastes have poor warning properties in the event of a release or contamination. Never rely on odor as a warning property for Mercury waste, as it has no odor.

• Use care when handling broken thermometers to avoid injection injury • Consolidation of Mercury wastes may be done inside of the warehouse as there is

no intentional handling of open waste containers. In the event of a broken or open container is discovered, the container should be moved to a well-ventilated and contained area for processing. Additional PPE will be necessary. Evaluate the hazard of the potentially released chemical for the appropriate PPE.

• Use care when opening containers during consolidation. Inner containers can be damaged I broken during transportation.




Waste SOP 11 - Non-Consolidation Wastes (DIDO)


11.1.1. The Hazardous Materials contained in "Drum In, Drum Out" (DIDO) containers can cause injury, death or environmental damage if not handled properly. See section 11.6.3 of this SOP for additional safety warnings and safe work procedures.


DIDO wastes are defined as wastes cannot be consolidated at the TSD, or are not viable for consolidation due to the properties of the material. Common DIDO Wastes that are managed at the TSD include:

• Non-Pumpable Fuels • Lean waters with high water concentrations • Waste liquids packaged in small containers (vials, cartridges, devices) • Wastes that may need additional processing at downstream TSDs • Wastes that have no current consolidation program, but are not restricted from

management at the TSD

11.2.1. DIDO Wastes may be received at the TSO as Hazardous Waste or Non-Hazardous waste. All DIDO wastes that are qualified for this program must meet the following requirements:

• The waste meets the definition of an DIDO waste per this procedure • The waste is properly characterized • The waste contains chemical constituents and I or waste codes that are not

prohibited from management at the TSD • Each drum has been reviewed and approved for shipment to the TSD

11.2.2. DIDO waste eligible for consolidation are assigned the following process codes in the WMSS:

• DO NOT CONSOLIDATE




• The waste meet the definition of a DIDO waste per this procedure and the profile • The waste is properly labeled and identified • The container is in acceptable condition, compatible with the waste, has no


11.3.2. QC Steps




• Inspect the waste for the above QC parameters and record the results of the QC on the QC Form.





11.4. Receiving







11.5. Storage


of the waste.

11.5.2. Room B, C and D are designated for flammable and reactive wastes

11.5.3. Room E is designated for corrosive base wastes

11.5.4. Room F is designated for corrosive acid wastes and oxidizing wastes

11.5.5. Toxic, Class 9 and non-DOT regulated wastes may be stored in any room



• Each DIDO waste container must be labeled per RCRA I DOT I TSD requirements and entered into the WMSS inventory for proper tracking. The following labels are required to be on all containers in storage at all times:

• RCRA label or non RCRA label -as applicable • DOT Hazard class label - when required • TSD inventory label




• Scan each container into the storage location using a data acquisition terminal (scanner). This will ensure tracking of the waste to the correct storage location.

• If a container is moved from one location to another, ensure that the new location is entered into the WMSS either by scanner, or manually into the WMSS.


• DIDO wastes can have any hazard associated with hazardous materials. Handle containers carefully in order to not accidentally release waste during handling, which can create injury or environmental hazard.

• Level D PPE is normally required for all employees involved in handling DIDO waste to provide cross contamination protection. In the event of a release or damaged container, the protective equipment requirements may need to be re-evaluated and upgraded based on the hazard of the waste that is spilled or at risk.


Waste SOP 12 - Solid Fuels


12.1.1. Solid Fuels can cause fire, injury, death or environmental damage if not handled

properly. See section 12.6.6 of this SOP for additional safety warnings and safe work procedures.


12.2.1. Solid Fuels are defined as a solid material that has fuel value greater than 5000 BTU.

Common Solid Fuels that are managed at the TSD include:

• Laboratory or Industrial Solvent wipes • Empty containers that once held flammable liquids • Carbon media • Debris and Production Wastes • Other organic solids that may have greater than 5000 BTU fuel value.

12.2.2. Solid Fuels may be received at the TSD as Hazardous Waste or Non-Hazardous

waste. All Solid Fuels that are qualified for this program must have the following

properties:

• The waste contains no free liquid • The waste is organic and/or petroleum based, or is contaminated with organic

chemical • The waste has a minimum of 5000 BTU fuel value as certified by the generator

12.2.3. Flammable solids eligible for consolidation are assigned the following process codes

in the WMSS:

• Fuels Sol Non-Haz • Fuels RCRA Solid




• • •

• •

The waste meet the definition of a solid fuel per this procedure and the profile The waste is properly labeled and is identified The container is in acceptable condition, compatible with the waste, has no damage and is properly closed Layers Color

12.3.2. QC Steps




• Open the container • Inspect the waste for the above QC physical parameters and record the results of

the QC on the QC Form.





12.4. Receiving







12.5. Storage


of the waste.

12.5.2. Flammable Solid wastes must be stored in Room C or Room D, which are designated

as flammable I organic storage areas.




• Solid Fuels consolidation is allowed at the back dock, south dock, north dock or other location where a receiving container can safely be placed in proximity of the operation.


• Solid Fuels are consolidated into DOT shipping containers such as cubic yard boxes or roll-off containers. Each consolidated container must be immediately labeled per RCRA I DOT I TSD requirements and entered into the WMSS inventory for proper tracking.



Consolidating flammable waste has risk of fire, explosion or chemical exposure. All employees are required to wear the proper personal protective equipment and follow the required safety procedures when performing consolidations. Failure to do so may cause fire, injury or death.

• Solid fuels consolidation must take place in a 24 hour period once consolidation into the receiving container has started. Note the start date/ time and finish date I time on the consolidation form. The HWC will provide a list of containers identified for consolidation. Only the containers on the list provided are allowed to be consolidated. Additions to the Pick List will require approval by the HWC or Operations Manager after review of the waste profile.




• Don the PPE required in Section 12.6.6 • Open the containers of material to be consolidated; • Transfer the waste to the receiving container;

o Solid Fuels may be processed into compaction or shredding systems which will allow the materials to be consolidated into a container for efficient transportation of the waste.

• For shredding and compaction, the material must be transferred to the processing equipment using all applicable ACTreatment SOPs, processing equipment operating instruction, and safety rules to prevent safety health and environmental hazards.

• Repeat steps above until the container is completely loaded with consolidated waste; and














• Solid Fuel wastes can be flammable and toxic. Take care not to accidentally release solid fuel waste during handling, which can create a fire, injury or environmental hazard.


• Consolidation of Solid Fuel wastes must be done outside of the warehouse, on the docks to allow for proper ventilation.

• Follow all safety rules for processing equipment when operating. • Never operate shredding or compaction equipment without all guards and

interlocks in place, and never bypass an interlock or guarding device, as it can result in serious injury or death. Always follow the SOP for the equipment!

• Manual handling of solid fuels can cause strains I sprains. Use safe lifting techniques and proper tools to help prevent injuries.

• Many Solid Fuels can be sharp, use tools instead of hands to move waste to the consolidation container.

• Level C PPE is required for all employees involved in consolidating waste to provide cross contamination protection and respiratory protection. The following Level C personal protective equipment is required at a minimum:


• Many Solid Fuels can be dusty. Use light water spray from pump sprayers to help minimize dust emissions.


Waste SOP 13 - Waste Oil

13.1. Safety- General

13.1.1. Waste Oil and Oily waters can cause injury, death or environmental damage if not

handled properly. See section 13.6.5 of this SOP for additional safety warnings and

safe work procedures.


13.2.1. Waste Oils are defined as a liquid material that contains oil that can be recycled. Common Waste Oils that are managed at the TSD include:

• Used Motor Oils • Industrial I Commercial lubricants • Other Automotive products • Dielectric fluids • Other oily waste that can be recycled as oil

13.2.2. Waste Oils are received at the TSD as Non-Hazardous waste. All Waste Oils that are qualified for this program must have the following properties:

• The waste is liquid • The waste is oil based, or contains oil based contaminants (oily water) • The waste is not RCRA regulated as a listed or characteristic hazardous waste

13.2.3. Waste Oils eligible for consolidation are assigned the following process codes in the

WMSS:

• Recycle Used Oil • Recycle Oily Water




• The waste meet the definition of a Waste Oil per this procedure and the profile • The waste is properly labeled and is identified • The container is in acceptable condition, compatible with the waste, has no

damage and is properly closed • pH • Layers • Color • Sludge

13.3.2. QC Steps




• Open the container • Inspect the waste for the above physical QC parameters using a coliwasa or similar







13.4. Receiving







13.5. Storage


of the waste.

13.5.2. Waste Oils may be stored in any of the TSO Rooms.



• Waste Oils are consolidated into shipping containers such as totes or tank trucks. Each consolidated container must be immediately labeled per RCRA I DOT I TSD requirements and entered into the WMSS inventory for proper tracking.


Consolidating waste oil has risk of chemical exposure and other hazards. All employees are required to wear the proper personal protective equipment and follow the required safety procedures when performing consolidations. Failure to do so may cause injury or death.


•

• •

•

• • • •

•

The HWC will provide a list of containers identified for consolidation (see appendix A for a sample Pick List). Only the containers on the list provided are allowed to be consolidated. Additions to the Pick List will require approval by the HWC or Operations Manager after review of the waste profile. Stage and prepare the receiving container(s) as needed Stage and prepare the containers designated for pumping, but leave the container openings closed / covered until pumping to minimize emissions from the containers Locate and stage the wastes selected for consolidation on the Pick List. Initial the Pick List when each item is pulled and staged Don the PPE required in Section 12.6.5 Open the containers of material to be consolidated Transfer the waste to the consolidation container Repeat steps above until the container is completely loaded with consolidated waste and Note any non-conformances or discrepancies on the Pick List as they arise












• Waste Oil can be combustible and toxic. Take care not to accidentally release waste oil during handling, which can create injury, environmental hazard or slip hazard.


• Consolidation of Waste Oil must be done outside of the warehouse, on the south dock to allow for proper ventilation

• Follow all safety rules for processing equipment when operating.


• Manual handling of Waste Oil can cause strains I sprains. Use safe lifting techniques and proper tools to help prevent injuries.

• Level D PPE is required for all employees involved in consolidating waste to provide chemical splash protection and respiratory protection. The following Level D personal protective equipment is required at a minimum:

o Safety glasses o Splash apron o Solvent protective gloves


Waste Analysis Program (WAP)

WAP Section 1 - General Requirement of the WAP

1.1. ACTreatment will maintain a copy of this Waste Analysis Plan (WAP) at the facility as required by 40CFR§264.139(b)]

1.2. As needed, ACTreatment may request, as a Class 1 Permit Modification, changes to test methods contained within this WAP to ensure that test

methods are kept current. 1.3. ACTreatment will update the required waste analysis to ensure that the

information is accurate. 40CFR §264.13(a)(3)]

1.3.1. The update or re-analysis will occur whenever ACTreatment has reason to believe the process or operation generating the waste has changed. 40CFR §264.13(a)(i)]

1.3.2. The update or re-analysis will occur whenever the on-site acceptance inspection indicates that the hazardous waste received at the facility does not match the waste designated on the accompanying manifest. 40CFR §264.13(a)(3 )(ii)

1.3.3. At a minimum, the required analysis will be reviewed and/or updated annually. The review will include updating the brief description of the process which generates each waste for each generator sending waste to the facility. Documentation of the review, up-date, and/or re-analysis will be maintained in the operating record. 40CFR §264.13(b)(4), and 40CFR §264.73(b)(3)]

1.4. ACTreatment will maintain copies of all waste analysis results as part of the operating record. These records shall be kept until closure of the Facility. 40CFR§264.73(b)] The Facility shall maintain these records during the PostClosure Period also.

1.5. If a discrepancy is found, and cannot be resolved, then no further shipments of the waste stream from that Generator will be accepted at the Facility without repeating formal acceptance review of the waste through the Waste Review procedures.

WAP Section 2 - Waste Documentation, Review and Approval Process

2.1. Waste Profile

• • • •

The Waste Profile is defined as the accumulated data that is used to perform Waste Analysis at the TSDF. The data that is contained in the Waste Profile will include some or all of the following:

Waste Profile Form and associated data Laboratory analytical data Waste inspection and sampling data Any other data that may be required for acceptance, management and disposition of the waste


2.1.1. Generator Knowledge

Acceptable process knowledge may be used for the pre-acceptance evaluation. The Operating Record shall contain documentation that demonstrates that the information is current and sufficient to accurately identify the waste.

2.1.2. Analytical Data

Analytical data required for the Waste Review may either be provided by the generator or by Advanced Chemical Treatment (ACTreatment). ACTreatment will perform verifyification analysis if the facility has reason to believe that the analytical data provided by the generator is inadequate.

When analytical data provided by the generator is used to comply with the analytical requirements of the Waste Review process, on-site analytical methods and quality control and quality assurance (QC/QA) will be used to evaluate the acceptability of that data.

2.1.3. Waste Profile Form

The waste characterization data that is necessary to perform the Waste Review will be recorded on a Waste Profile Form and confirmed by the signature of an authorized representative of the generator. The generator is responsible for the hazardous waste determination per 40 CFR §262.11 and the Waste Profile Sheet will document this determination.

2.1.4. Waste Profile Data

• Each waste stream will be assigned a unique identification number that is provided by ACT.

• Generator Identification Information (Section A of current profile form) • The key waste stream identification data provided by the generator representative

will include:

o Generator EPA Identification number (when applicable) o Generator name, contact information and applicable address(es) o Generator contact person name and title o Name of the waste stream o A description of the process that is generating the waste o Applicable EPA Source and Form code o NAICS code

• The generator representative will provide the following Physical Characteristics information Physical Characteristics of the Waste (Section B of current profile form)

o Physical state o Color o Clarity o Phase Separation and Number of Layers (when applicable) o Odor o pH

o Specific Gravity o Flash Point


o BTU Value

• The generator representative will provide the following Chemical Characteristics information (Sections C, D, E of the current profile form):

o The Chemical Composition of the waste o RCRA regulated metals information o Other Components and Characteristics o Whether the chemical composition information based on Generator Knowledge or

Laboratory Analysis?

• Regulatory Information (RCRA Codes, NESHAP, TSCA, Universal, etc.[currently resides in section F])

o Applicable regulated characteristics and RCRA Waste Codes

• Shipping and Generation Information (Section F)

o Department of Transportation Shipping Information o Shipping container information o Shipping frequency information

• Special Handling Information

o Any special handling information that may have an impact on safe handling and disposal of the waste

• Generator Certification

The Generator representative will certify that:

"I hereby certify that all information in this and all the attached documents is complete and accurate, and that all known or suspected hazards have been disclosed. I further certify that any samples submitted with this profile are representative of the waste to be shipped and are taken in accordance with SW 846 or other approved procedures. I agree to notify Advanced Chemical Treatment in writing when the process generating this waste stream changes or when I have reason to believe the data contained herein is not complete and accurate."

2.2. Waste Review

Following completion and submittal of the Waste Profile form, the waste will be evaluated for management at the facility. This evaluation will ensure that receipt of the waste material will be in compliance with this Permit, and all applicable laws and regulations. This review will also ensure that the waste material can be adequately managed by the facility's treatment, storage and disposal capabilities and that the waste will be compatible with other wastes with which it will come into contact during consolidation, and with each container's construction materials that the waste will be placed in. This evaluation will include the following:

• • • •

Documentation of the waste stream Physical and Chemical Characteristics Review Permit compliance of the waste and proposed management Customer Requirements and special requests


• Management Capability including prohibitions, storage requirements, processing requirements, QA I QC requirements and Process Code assignment

• Downstream disposition of the waste and acceptance requirements • Transportation Requirements • Packaging Requirements • Management of By-Products

Documentation of this evaluation shall be maintained in the Operating Record.

2.3. Waste Profile Acceptance

ACTreatment will use the Waste Review process to evaluate the acceptability of the waste into the TSO. Approval of the waste will be acknowledged by the General Manager or his designee.

2.3.1. Documentation of Approval

• Approval of the waste stream will be documented in the Operating Record. An approved waste profile has a status designation of "A" in the operating record.

• Each waste stream approval will be valid for one year after approval into the TSO. • Any waste profile that is expired or nearing expiration may be accepted by Re

certification with a signature on the profile form by the generator of the waste, provided that no changes to the waste stream have occurred.

• If there are changes to the waste stream, a new profile must be submitted, reviewed and approved.

2.3.2. Unacceptable Waste Streams

If a waste stream is not acceptable, the generator will be notified of the unacceptability and the reasons for the un-acceptability.

2.3.3. Record Retention

Waste profile information and signed waste profile forms will be filed electronically at ACTreatment within the operating record according to Federal and State record retention requirements and per the record retention requirements in ACTreatment procedure.

WAP Section 3 - Physical Acceptance of Waste

3.1. Document Verification

The following procedures will be used to verify that each waste stream shipment has the appropriate documentation for acceptance.

3.1.1. Manifest

• A manifest will accompany each hazardous waste shipment (except universal waste shipments).

• The generator and transporter portions of the manifest shall be reviewed for completeness, date, and signature

3.1.2. LDR

• Waste shipment and pre-acceptance approval information that determine if the waste stream is subject to LDRs will be reviewed


• A verification will be made that the Waste Profile and the LDR notification are current for the waste shipment

• Other Shipping Documents: All other shipping documents will be reviewed

3.1.3. Identification of Discrepancies

The following items will be considered significant discrepancies in the document verification process:

• The weight of a bulk shipment varies with the weight indicated on the accompanying manifest by more than 10 percent

• The piece count of a shipment varies with the piece count indicated on the accompanying manifest

• Variations in the type of waste or waste constituents indicated on the accompanying manifest

• The information contained in the generator or transporter portions of the manifest is incomplete or inconsistent with that expected based on the information contained on the Waste Profile;

• The generator and transporter portion of the manifest is unsigned or not dated; • A Waste Profile is not on file for the waste stream • The notification/certification required for a waste subject to LDR has not been

submitted or the notification/certification is incomplete.

If any of the discrepancies listed above are identified, the shipment will not be processed or disposed of until the discrepancy is resolved. Wastes may be stored (provided that the wastes meet the requirements for storage) while the discrepancy is resolved. These wastes must be segregated.

3.1.4. Resolution and Documentation of Discrepancies

Discrepancies which are resolved shall be recorded in the operating record with a concise explanation of how the discrepancy was resolved to allow acceptance of the waste.

If the discrepancy is not resolved within 15 days after receiving the waste, ACTreatment must immediately submit to the Department a letter describing the discrepancy and attempts to reconcile it, and a copy of the manifest or shipping paper at issue.

If no resolution is possible, the shipment will be returned to the generator.

WAP Section 4 - Inspection and Sampling of Waste

Chemical sampling, analysis and evaluation is a critical part of maintaining compliance to regulation and the facility permit for proper management of hazardous waste. This procedure describes the steps and processes required to perform waste sampling, analysis and evaluation.

4.1. Physical Inspection Requirements

Site personnel will consult the QC form and other applicable waste characterization data to identify proper personal protective equipment for shipment inspection and sampling.


Using appropriate personal protective equipment, site personnel will inspect the contents of the shipment for visual conformity with the waste described on the hazardous waste manifest. The contents of every selected container per section 4.2 of this document will be visually inspected for color and appearance as described in the waste-category SOPs above.

4.2. Selection of Containers for Physical or Chemical Evaluation and Analysis

As described above in waste-category SOPs, where chemical analysis is required for liquid wastes (i.e. pH, water content), representative samples will be obtained from each shipment of a given waste profile. The minimum number of containers to be sampled from each shipment of a waste stream will be determined according to the cube root procedure, Method D 140-70 of the American Society for Testing and Materials (ASTM). That method states that the number of drums to be randomly selected for sampling should equal the cube root of the total number in the shipment, as follows:

#Drums #Drums Received Sampled

1 1

2-8 2

9-27 3

28-64 4

65 - 225 5

The hazardous waste containers to be sampled will be chosen at random by the person taking the samples. The sampling will take place in a well-ventilated area of the Facility, such as the dock, and samples will be collected as described in the Waste Analysis Program (WAP), below.

4.3. Chemical and Physical Evaluation and Analysis Descriptions

The following physical analyses and/or evaluations may be performed at ACTreatment as identified in the waste category SOPs:

Parameter Method Rationale EPA Method

Container Visual • Container compatibility with the waste N/A

• Condition will not create a safety hazard

• Properly closed

Color Visual • waste confirmation I identification N/A

Appearance Visual • waste confirmation I identification N/A

Layers Visual • waste confirmation I identification N/A

• management method confirmation

• processing methods

Sludge Resistance • waste confirmation I identification N/A




The following chemical analyses and/or evaluations may be performed at ACTreatment as identified in the waste category SOPs:

Parameter Method Rationale EPA Method pH Wide Range pH • waste confirmation I identification 9041

Analysis by • management method confirmation indicator strip • processing methods

• hazard identification % Water Karl Fischer • waste confirmation I identification 9000

Titration • management method confirmation


• hazard identification British Calorimetry • waste confirmation I identification Thermal • management method confirmation Units (BTU) • processing methods Chlorine Test Strip • waste confirmation I identification



• hazard identification Oxidizer Test Strip • waste confirmation I identification

• hazard identification

4.4. Chemical Analysis Methods

4.4.1. Wide Range pH Analysis

1. Log the sample number in the sample log.

N/A

N/A

2. Using Hydrion Plastic pH Indicator Strips 0.0 - 14.0 (or equivalent), immerse the colored tip of the pH strip in the test solution.

3. Remove the strip and immediately match to the color chart on the pH strip container. 4. The color match will indicate the wide range pH of the sample. 5. Record the pH on the sample log.

4.4.2. Karl Fischer Titration

1. Log the sample number in the sampling log. 2. Shake the sample vigorously for at least 30 seconds. 3. Open the sample bottle and insert the transfer pipette. Always use a new disposable

pipette for each sample to prevent cross-contamination of samples. 4. Squeeze the pipette bulb, insert the tip of the pipette into the fluid and release the

bulb to draw fluid into the pipette. 5. Hold the pipette with the bulb down and tip pointed up. Tap the bulb of the pipette to

allow the sample to fall down into the bulb. 6. Place the pipette into the cup on the titration scale with the bulb down, to prevent

spillage and close the wind break on the scale.


7. Press start on the KF Titration unit or on the attached keyboard. This will begin the sample conditioning process in the titration reaction vessel on the KF titration apparatus. The KF titration unit will chime when the reaction fluid is conditioned.

s. Press start on the KF Titration unit or the attached keyboard again to move to the sample analysis process.

9. The KF Titration unit will ask for a sample number. Type the sample number (dnumber) and verify the sample number is correct before proceeding to the next step. If you make a mistake, use the delete key on the keyboard to back up the cursor to correct mistakes. After verification that the sample number is correct, press the enter key on the keyboard to move to the next step.

10. Remove the white stopper from the top of the reaction vessel. Make sure to keep the stopper clean and dry.

11. Remove the pipette from the scale and agitate the fluid in the bulb of the pipette by gently shaking or flicking the pipette bulb.

12. While gently squeezing the bulb and watching for fluid to reach the tip of the pipette, allow one or two drops of fluid to fall into the reaction vessel of the KF Titration unit.

13. Return the sample to the scale and replace the stopper on the KF Titration reaction vessel.

14. Allow the scale to re-balance and determine the weight of the drops that were placed into the reaction vessel. An accurate weight of sample introduced into the vessel is critical for accurate results.

15. Enter the weight of the sample into the KF Titration unit and press Enter to start the titration process. Once the titration is complete, it will print the results on the printer and will also display the results on the screen of the KF Titration Unit.

16. Remove the sample pipette and squeeze the remaining sample back into the original sample jar. Discard the pipette into the appropriate waste container.

17. Repeat the steps above for multiple samples.

Notes:

• Calibrate the scale daily following the calibration instructions in the scale manual • Check the accuracy KF Titration Unit daily by performing the above steps on a

sample of known quantity of water (10% water in solvent) • The sample run time is affected by the quantity of sample introduced into the

reaction vessel. Use only one or two drops. • Record the test results on the sample log.

4.4.3. Calorimetry

Calorimetry is not performed at this time. In the future, if calorimetry is performed, the unit will be operated per manufacturer instructions.

4.4.4. Chlorine Test Strips

1. Log the sample number in the sample log. 2. Using La Motte Chlorine Test Papers (Code 4250-BJ), immerse one inch of the test strip

into the test solution and remove immediately. 3. Blot the strip with a paper towel and allow drying. 4. Compare the color of the strip to the color chart on the test strip container. 5. Record the test results on the sample log.


4.4.5. Oxidizer Test Strips

Oxidizer test strips are not used at this time. In the future, if oxidizer test strips are used, they will be used according to manufacturer instructions.

4.4.6. Resolution and Documentation of Discrepancies

If any discrepancies (as described below) are identified, the shipment will not be processed or disposed at the facility until the discrepancy is resolved. Wastes may be stored (provided that the wastes meet the requirements for storage) while the discrepancy is resolved. These wastes must be segregated.

• Discrepancies which are resolved shall be recorded in the Operating Record with a concise explanation of how the discrepancy was resolved to allow acceptance of the waste.

• If the discrepancy is not resolved within 15 days after receiving the waste, ACTreatment will immediately submit to the Department a letter describing the discrepancy and attempts to reconcile it, and a copy of the manifest or shipping paper at issue.

• If no resolution is possible, the shipment will be returned to the generator.

4.5. Waste Acceptance

If no discrepancies are identified, or following the resolution of any discrepancies, the following procedures will be used to accept waste shipments:

• The Waste Coordinator will note the Management Method Codes in section 19 of the manifest.

• Acknowledgement of Receipt will be carried out by the Waste Coordinator, by signing the manifest as the designated facility in section 20 of the Manifest.

4.5.1. Record Retention

Waste Acceptance information will be filed electronically at ACTreatment within the operating record according to Federal and State record retention requirements and per the record retention requirements in ACTreatment procedure

WAP Section 5 - Waste Processing

5.1. Identification and Selection of Management Processes (Each MP Documented

by SOP)

Management Processes are designated during the waste review process based on waste chemical and physical composition, customer management requirements and downstream TSD requirements. Management Processes are defined by procedures that include specific instruction on management of the waste through the TSO.

• Review of Processing Requirements - Each Management Process is reviewed prior to execution to ensure that the correct steps will be followed for management of the waste and to eliminate miss-processing of wastes.

• Selection of Wastes for processing - Wastes for processing are selected by the TSD process codes that are assigned during the waste review process.


• Pre Processing Inspection - The waste is inspected prior to processing to ensure that the waste conforms to the process code and is uniform with the downstream TSD requirements for proper disposal.

• Execution of Process - The waste is processed per the Management Process documented by the appropriate SOP.

• Post Processing Inspection - The waste is inspected post processing to ensure that it conforms to the waste profile at the downstream TSD.

• Post Processing Sampling (when required) - When required, the waste will be sampled and analyzed per downstream TSD requirements.

5.2. Documentation of Process

The management processes are documented in the operating record which is designed to track consolidation and processing for individual containers as well as consolidated wastes. Each individual drum is tracked to its destination whether it is individually handled wastes or consolidated containers.

5.3. Record Retention

Waste Processing information will be filed electronically or by hard copy at ACTreatment within the operating record according to Federal and State record retention requirements and per the record retention requirements in ACTreatment procedure

WAP Section 6 - Waste Shipment

During the waste shipment process, the following steps will be taken to ensure that the waste will be transported and disposed of as required by the permit, customer requirements and downstream TSD requirements. Steps to ensure acceptability at the downstream TSD include review of:

• Downstream Profile Review • Transportation Requirements • Packaging Requirements • Acceptance Criteria at Downstream Facilities • Record Retention

Waste Shipment information will be filed electronically or by hard copy at ACTreatment within the operating record according to Federal and State record retention requirements and per the record retention requirements in ACTreatment procedure

WAP Section 7 - Waste Sample Collection Methods

An important consideration in the development of a waste-specific characterization program is the methodologies employed with waste sampling. It is imperative that the sample be as representative of the waste stream as possible, since the reliability of all subsequent analytical and evaluation efforts will be limited by this factor. Procedures and general guidelines for obtaining representative samples of wastes from drums, bulk loads, tanks, and impoundments are discussed in the following sections.

A Sampling Log will be used as a tool by the analyst to document the waste sampling activities. The Sample Log shall be maintained as part of the Operating Record.

Sampling devices are schematically illustrated in SW-846.


Prior to taking a sample, the Waste Profile will be reviewed and safety procedures will be implemented.

7 .1. Drum Sampling

Drums or other approved waste containers are likely to contain materials of varying in form and consistency, such as liquids, sludge, or dry solids, all generated either separately and/or in mixtures. The sampling methodologies employed will generally depend upon the specific form and type of waste contained in a drum. Sampling must be representative of the material in the drums and account for any layering or stratification that may occur for any wastes having various liquid/liquid or liquid/solid phases. Containers will be sampled in such a manner as to obtain a vertical profile of the material, unless the physical properties prohibit penetration of the sampling devices.

7.1.1. Sampling Liquids in Drums:

• Liquids will be sampled using a clean glass or plastic "thief', coliwasa or similar sampling device.

• Sludge in drums range in consistency from slurries to near-solid materials. The sampling device employed will be dependent upon the consistency of the sludge material. Loose slurry material will be sampled using a thief, coliwasa or similar sampling device. A material which will not enter these samplers will need to be sampled by other means or the drum will be managed off spec as solid where sampling will not be required.

7.2. Sampling of Tanks

7.2.1. Bulk Flammable Waste Storage Tanks

The contents of the contaminated water storage tanks will typically be sampled from sample valves. Alternatively, samples may be taken from the top of the tanks using a thief, Coliwasa, weighted bottle, or sampling bailer.

7 .3. Bulk Tankers

Each tanker will be sampled via the manhole entrance port on the top of the tankers or through a sampling valve located on the bottom-rear of the tanker.

7.3.1. The tanker contents will be sampled using a pond sampler or dipper. If necessary, a weighted bottle or equivalent sampling device will be utilized.

7.3.2. In the process of collecting a sample from the sample valve, one to two gallons of the liquid will first be permitted to flow through the valve and properly disposed of before collecting the representative sample. This is done to ensure the valve orifice is free of particulates and/or contaminants that may have accumulated during transportation. This procedure also applies to oil/solvent wastes containing variable concentrations of settleable/suspended solids.

7.4. Decontamination of Sampling Equipment

When practical, disposable sampling equipment will be used and disposed of in the same container from which the sample was taken. All reusable equipment will be


washed, rinsed, and visually inspected for residues prior to the reuse of such equipment.

WAP Section 8 - Discrepancy Criteria For On-Site Waste Acceptance Evaluation

The criteria itemized below define respective discrepancies with regard to a comparison of analytical data from either Department requested sampling and/or on-site analysis with the information listed on a Waste Profile.

1. Any determination which identifies or characterizes the material as:

• • •

Pyrophoric/air reactive Explosive Shock Sensitive

• Radioactive, exhibiting a radiation reading greater than the limits in Part 11.C.6. of this Permit

• Infectious Wastes

• Compressed Gas

2. Any analytical result which leads to a change of characterization for the following parameters:

• Reaction with change in pH resulting in release of gas • lgnitability • Corrosivity • Free Liquids

3. Any analytical result which deviates from the values specified on the Waste Profile by an amount or percentage greater than the limits set below will be considered a discrepancy.

• pH > 2.0 units (negative log of Hydrogen ion concentration difference) for corrosive wastes

• Total water content greater than 40% for organic liquids intended to be consolidated for fuel blending

4. Any distinctly different characteristic for each of the following parameters:

• • • •

•

Color Number of Phases Physical State Volume percent sediment, aqueous liquid and organic liquid having a difference in excess of twenty-five percent (25 %) Significant difference in Odor
