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					                                     SOP 4.11: Waste Storage

    1.   Introduction......................................................................................1
    2.   Regulatory and contractual requirements ...........................................1
    3.   Staff qualifications.............................................................................1
    4.   Health and safety precautions ............................................................2
    5.   Equipment and supplies ....................................................................3
    6    Procedures for waste storage. ...........................................................3
    Attachment A: Notification form of HHW programs or program activities. .....5

1. Introduction
   RCRA requirements apply when hazardous waste (HW) lab packs or containers are filled, closed out, and
   placed into storage. For this SOP, lab packs, fiber drums, and metal drums will be referred to as

2. Regulatory and contractual requirements
   The storage of HW is governed by the requirements established in the Facility and state agency contract
   (Exhibit A); the state-contracted HW disposal company Hazardous Categorization Training Manual,
   OSHA 29 CFR 1910.178 and 1910.106 (d) and (e); Minn. Rules pt. 7045.0626, pt. 7045.0566, and pt.
   7045.0310, subd. 3, 7045.0205 through 7045.0320, 7510; Minn. Stat. § 299F.011; Minnesota Uniform
   Fire Code; and local building codes.

3. Staff qualifications
   3.1 Training
          3.1.1 The designated staff responsible for ensuring Facility HW storage compliance is the Facility

                  Manager. This Facility shall have a written training program that describes waste processing
                  relevant to job duties and shall include function-specific training, safety, regulatory, and
                  emergency procedures.

          3.1.2 Staff shall be trained within six months of hire or starting a new position at the facility, or be

                  supervised by trained staff until that time. Refresher training shall be conducted annually and
                  properly documented.

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         3.1.3 Staff shall review equipment manufacturer manuals prior to Facility operations to become

               familiar with design, function, and maintenance. Staff shall comply with safety requirements
               pertaining to equipment use and maintenance. Only trained staff shall be permitted to operate
               this equipment; see SOP 2.8 Powered Industrial Trucks with checklist and SOP 5.1
               Equipment Maintenance.

4. Health and safety precautions
   4.1 Safety requirements
         4.1.1 Staff shall follow safety requirements as outlined in this Facilities Emergency Contingency

               Plan and Health and Safety Plan. Staff shall also take precautions to prevent any impacts to
               the environment: see SOP 1.1 OSHA.

         4.1.2 No smoking, eating, or drinking is allowed in waste processing areas of this Facility.

         4.1.3 Routinely look for immediate dangers to nearby staff and property. Keep alert for suspicious

               activities or behaviors in accordance with the program’s DOT Security Plan; see SOP 4.15
               DOT Security Issues.

         4.1.4 Proper ergonomic techniques shall be used while processing waste; see SOP 2.11


   4.2 Personal protective equipment (PPE) requirements
         This Program may choose to implement a PPE policy by using engineered solutions appropriate to
         current environmental conditions and utilizing experienced staff judgment for unique conditions and
         situations. PPE shall be utilized if the potential for exposure remains after the institution of work
         practice controls; see SOP 2.4 Personal Protective Equipment. At a minimum, the following PPE
         shall be used when processing HW:
            Safety glasses with side shields, goggles, or equivalent eye protection
            Footwear with reinforced toe, toe caps or equivalent foot protection
            Nitrile gloves or equivalent hand protection
            Chemical splash apron, Tyvek coveralls, or equivalent body protection

   4.3 Medical monitoring requirements
         Engineering and work practice controls shall be utilized to minimize or eliminate exposures. Staff
         exposed to hazardous substances for 30 or more days per year shall receive medical monitoring
         examination annually per OSHA regulations. It is this Facility’s responsibility to set up procedures
         to continually verify that the medical monitoring program is meeting OSHA requirements and
         regulations; see SOP 2.13 Medical Monitoring Program.

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   4.4 Emergency response
         Only designated and trained emergency responders shall attend to incidents requiring assistance
         beyond the capabilities of Facility staff. This Facility shall make prior agreements with response
         teams to be used in emergencies; see SOP 2.10 HW Contingency Plan.

5. Equipment and supplies
   Facility processing and storage areas shall have staff access to:
       Equipment to assist in moving waste containers (e.g., moving cart, drum dolly, forklift).
       A spill kit; see SOP 2.6 Spill Response.
       A marked and serviced fire extinguisher. Local fire codes may require additional fire suppression
        equipment. Fire exits and extinguisher Facility areas shall be kept clear at all times.

6. Procedures for waste storage
   6.1 Storage building specifications—Local zoning and building fire codes may specify Facility
         construction materials (e.g., electrical fixtures, explosion-proof fixtures and wiring, HVAC systems,
         fire suppression equipment, grounding and bonding of flammable containers). Facility staff shall
         6.1.1 No material is stored in any manner that would impede access or exit from the Facility.

         6.1.2 State approval to operate is obtained from the State 30 days prior to operation; see

                Attachment A of this SOP.
         6.1.3 HW stored on site does not exceed the permitted maximum amounts (as stated in the State

                approval letter specific to this Facility).
         6.1.4 Facility storage areas have flooring impermeable to the type of waste stored.

         6.1.5 Facility storage areas do not have a floor drain that leads to a sewer or the environment.

         6.1.6 Buildings storing ignitable wastes are located at least 50 feet from the property line (this

                provision may be waived with the receipt of approval from the local fire marshal and local
                building officials).
         6.1.7 Secured Facility access.

         6.1.8 Overhead roofing protects HW containers from direct sunlight.

         6.1.9 Facility areas are marked with specific waste types of the containers stored.

         6.1.10 Storage areas include secondary containment (e.g., dike, berm, wall, curb, other device) large

                enough to contain 110% of the largest container (generally applicable to a 55-gallon drum).
         6.1.10 Storage areas include a dike, berm, wall, curb, or other device to segregate potential spills

                from incompatible HW (or wastes shall be stored and separated by a distance of at least 10

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   6.2 Waste container specifications
       6.2.1   To prevent reactions from incompatible chemicals, segregate HW containers while in the
               Facility storage area:

                   Flammables or pesticides                All flammable and combustible liquids and solids, and
                                                           any nonhazardous material that is chemically compatible
                                                           with flammables. Department of Agriculture chemicals,
                                                           poisons, and pesticides (that are not oxidizers), and any
                                                           nonhazardous materials chemically compatible with
                                                           pesticides may be stored in same area.

                   Bases                                   All corrosive liquids and solids that are alkaline, as well
                                                           as any nonhazardous materials that are chemically
                                                           compatible with bases.

                   Acids                                   All corrosive liquids and solids that are acidic, as well as
                                                           any nonhazardous materials that are chemically
                                                           compatible with acids.

                   Oxidizers                               All oxidizers, including organic peroxides.

                   Cyanides                                Store all cyanides away from acid wastes.

                   Dangerous when wet                      Store Dangerous When Wet wastes away from latex
                                                           paint or any water source.

                   * See HW Disposal State Contractor Manual for additional waste types.

       6.2.2   Containers placed into Facility storage areas shall have:
                     A unique number shall be assigned to each container and entered into the Facility log
                     One lab pack inventory sheet attached.
                     Be placed in rows with at least 24” of aisle space to facilitate inspection. Aisle space shall
                      be maintained in order to ensure the unobstructed movement of personnel and emergency
                     Proper grounding for bulked flammable wastes; for information on proper grounding, see
                      SOP 4.5 Waste Bulking, Attachment A.
                     Integrity protection, e.g. latex paint protected from freezing, 55-gallon drums not stacked
                      more than two high.
                     Secure closings.
                     Markings or labels attached, which are visible for inspection; see SOP 4.4 Waste

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Attachment A: Notification of New HHW Programs or
Program Activities
                                                     (Type or print)

1. Staffing
   A.   HHW operations contact person: ___________________________________________________________
        Phone: _______________________________________________________________________________
        Address: ______________________________________________________________________________
        Job responsibilities: _____________________________________________________________________
   B.   Education program contact person: _________________________________________________________
        Phone: _______________________________________________________________________________
        Address: ______________________________________________________________________________
        Job responsibilities: _____________________________________________________________________
   C.   Other county program staff: _______________________________________________________________
        Phone: _______________________________________________________________________________
        Address: ______________________________________________________________________________
        Job responsibilities: _____________________________________________________________________

2. Facility location
   D.   Facility location address: _________________________________________________________________
   E.   Facility EPA ID Number: _________________________________________________________________

3. Service area
   A.   Participating counties or regional area: ______________________________________________________
   B.   Cities (list those not included in Part 3A): ____________________________________________________
   C.   State: ________________________________________________________________________________

4. Facility operating hours
   A.   Facility type:      permanent local/satellite  permanent regional  single event
                            recurring event  mobile
   B.   Date(s) of operation: _____________________________________________________________________
   C.   Hours of operation: _____________________________________________________________________

5. On-site waste management
   A.   Briefly describe facility structure (if not a mobile unit), include size, construction materials, components (rest
        rooms, phone, water, etc.): _______________________________________________________________


   B.   List other program wastes accepted in addition to HHW (VSQG, Universal Waste, non-household pesticides,
        abandoned, or other) ____________________________________________________________________

   C.   Briefly describe storage methods and timeframes: _____________________________________________

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   D.   Briefly describe waste treatment/handling methods: ____________________________________________

   E.   Briefly describe waste transportation methods (if not transported by Contractor): ______________________


6. Contractor waste management
   A.   Transporter name: ______________________________________________________________________
        Address: ______________________________________________________________________________

   B.   Disposal contractor name ________________________________________________________________
        Address: ______________________________________________________________________________

7. Personnel safety training
   Indicate whether hazardous waste handling staff have received personnel training in accordance with Part A of
   Exhibit A and the Program’s Personnel Training Program. If staff are not trained in accordance with the Exhibit
   and Training Program, briefly describe hazardous materials and safety related training completed:

   Staff name or affiliation: _____________________________________________________________________

   (County or company): _______________________________________________________________________

                                                                    Training completed
                                                                    in accordance with
                                                                    Training Program
        ______________________________________________               Yes     No
        ______________________________________________               Yes     No
        ______________________________________________               Yes     No
        ______________________________________________               Yes     No

8. Safety and emergency procedures
   A.   Does County have a safety plan in accordance with Part B of Exhibit A for this facility?  Yes  No

   B.   Is the Facility-specific safety plan on-site and readily available?  Yes  No

   C.   List local emergency personnel notified of the operation:
        1.   Hospital ___________________________________________________________________________
        2.   Fire department ____________________________________________________________________
        3.   Police ____________________________________________________________________________
        4.   Other _____________________________________________________________________________

   D.   Have provisions been made to ensure personnel safety in accordance
        with Parts A and B of Exhibit A?  Yes  No

        If no, briefly describe safety provisions (eye wash, PPE, etc.): _____________________________________



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