Ensure that Members of the Workforce complete the required training identified in ESH100.2.ENV.22 prior to performing the indicated work activity or fulfilling the indicated role. 

Note: See Sandia corporate procedure HR100.2.1, Identify and Complete Sandia Required Training for all Members of the Workforce.

Ensure that:

• Waste is managed through the Regulated Waste & Pollution Prevention Department.
• Waste management controls are implemented in technical work documents (TWDs), including training, waste minimization, pollution prevention, handling, storage, transportation, labeling, accumulation, and disposal.
• Members of the Workforce meet specific requirements for maintaining waste accumulation areas, including the allocation of resources to:
  • Correct identified deficiencies.
  • Identify unauthorized materials in areas and spaces for which you are responsible.
• 1-year storage limits are not exceeded.

• Maintain the Waste Management Program.
• Provide waste management assistance or technical answers to questions related to waste management to Members of the Workforce.
• Arrange for the disposal of approved waste streams.

• Incorporate waste minimization and pollution prevention practices into your technical work documents.
• Apply waste minimization and pollution prevention practices to waste generation, handling, labeling, and accumulation processes, whenever applicable.
• Follow the requirements in this document and the specifics of the associated technical work documents (TWDs), as applicable.
• Complete required training.
• Notify your manager concerning waste management issues in areas and spaces they are responsible for, including:
  • The steps taken to correct deficiencies.
  • Identification of unauthorized materials.
  • Waste accumulation quantities that are approaching the waste storage limits.
• Prepare technical work documents as described in ESH100.2.GEN.3, Develop and Use Technical Work Documents. Note: ESH100.2.GEN.3, Develop and Use Technical Work Documents, explains acceptable TWD formats for hazardous or radioactive materials.
• Develop a technical work document specific to your areas and spaces (e.g., Standard Operating Procedures) or adopt an existing document (e.g., Chemical Hygiene Plan [see ESH100.2.IH.4, Evaluate and Control Chemical Hazards]) suitable for hazardous waste management.
• Use the requirements of this procedure, the Primary Hazard Screening (PHS), and Hazard Analysis (HA) to identify important waste management steps to include in your TWD. Note: The Primary Hazard Screening and Hazard Analysis software tool evaluates work hazards and allows the generator to identify anticipated hazardous waste.
• Direct questions regarding hazardous waste handling, storage, transportation, processing, treatment, recovery, recycling, transfer, and disposal activities (including concerns as to whether this section applies to a specific activity) to the division ES&H team environmental compliance coordinator (ECC).

Follow Sandia’s waste management hierarchy:

1. Waste should be reduced or eliminated at the source.
2. If waste cannot be reduced or eliminated at the source, non-hazardous waste or material should be reused or recycled. The division ES&H team environmental compliance coordinator (ECC) should be consulted for details on applicable requirements.
3. If waste cannot be reduced or eliminated at the source, reused, or recycled, contact the division ES&H team ECC for additional help.

Note: Waste minimization and pollution prevention (P2) does not include regulated treatment processes that alter the physical, chemical, or biological characteristics or the volume of hazardous wastes.

• Integrate methods to minimize the generation of hazardous waste into your daily work operations.
• Evaluate process input to minimize waste:
  • Minimize introduction and use of chemicals. Note: Consider process or material modifications that could eliminate or reduce the quantity or toxicity of waste. These changes can often be justified when the cost of waste disposal is considered for the life of the project or process.
  • Identify the least toxic or hazardous material that meets the design or process requirement.
  • Have vendors provide chemicals and materials in reusable or returnable forms. The division ES&H team environmental compliance coordinator (ECC) should be consulted for details on applicable requirements.
• Evaluate process throughput to minimize waste: optimize processes to improve overall efficiency to reduce chemical use.
• Evaluate process output to minimize waste:
  • Decontaminate material and equipment for reuse.
  • Recycle and reuse chemicals. Notes:
    • Consult the division ES&H team ECC for details on applicable requirements.
    • Consider the Chemical Exchange Program (CEP) or consult the division ES&H team ECC before purchasing or disposing of unused chemicals.
• Document waste minimization efforts.

• Determine if potential waste material meets the definition of "hazardous waste.”  If it does not, the requirements of this section do not apply; however, other waste management requirements may apply.
• Until proven otherwise, regard the following as hazardous waste (for examples of hazardous waste, see the Guidance on Hazardous Waste Management at SNL):
  • All chemicals, including contained gases, liquids, and solids that are toxic, ignitable, corrosive, and/or reactive, unless a waste profile has been completed to determine that they are not hazardous.
  • Metals and waste contaminated with or containing these metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver, unless a waste profile has been completed to determine that they are not hazardous.
  • Any waste item that is contaminated with or that contains any of the above chemicals or metals, unless a waste profile has been completed to determine that it is not.
• If the waste is an unused commercial chemical product, determine if it is identified as an acute hazardous waste. If the waste is identified as an acute hazardous waste, pay close attention to its unique waste management requirements. Note:  A listing is available by generic name in 40 Code of Federal Regulations (CFR) 261.33(e).
• For excess or waste military munitions, follow requirements in Management of Excess or Waste Military Munitions.

Unless written approval is granted by the appropriate division ES&H team environmental compliance coordinator (ECC), do not do any of the following with material identified as hazardous waste:

• Treat, recycle, dilute, or volume-reduce the material.
• Discard the material into trash cans or dumpsters.
• Allow the material to enter sanitary sewers lines (see the Elementary Neutralization section) or storm drains via sinks, toilets, etc.
• Bury the material or release it to the ground, directly or indirectly.
• Allow the material to evaporate or disperse into the atmosphere.
• Remove the material from Sandia-controlled premises or Kirtland Air Force Base.
• Bring any material identified as hazardous waste onto Sandia-controlled premises, even if the material was generated on other Sandia-controlled premises.

Note: Management of used oil is regulated under 40 CFR Part 279 of the federal hazardous waste regulations. The regulations establish requirements for generators of used oil, as well as for burners, marketers, and processors of used oil fuel.

• Ensure that used oil to be recycled:
  • Is free of radioactive contamination.
  • Contains less than 2 ppm polychlorinated biphenyls (PCBs).
  • Is not mixed with a hazardous waste or hazardous constituent (e.g., antifreeze, brake fluid, kerosene, petroleum distillates, or solvents). Note: Used oil that is considered to exhibit a hazardous characteristic by its own nature and that has not been mixed with a hazardous waste must be recycled.
  • Does not exceed 1,000 ppm total halogens unless the generator has acceptable knowledge indicating the halogens are not due to solvents or other hazardous waste. If the oil contains halogens from refrigeration units or metalworking fluids, contact the appropriate division ES&H team environmental compliance coordinator (ECC) for assistance.
  • Meets all acceptance criteria imposed by the Hazardous Waste Management Facility (HWMF).
• If the used oil fails to meet any of the above criteria or if the history or the process that generated the used oil is uncertain, then manage and label the used oil as “hazardous waste,” unless a complete Resource Conservation and Recovery Act (RCRA) analysis is performed to prove otherwise. Contact the appropriate division ES&H team ECC for assistance about getting a RCRA analysis done.
• Submit used oil on a WDDR to the HWMF for recycling.

• Do not store used oil in units other than tanks or containers.
• Ensure that containers and above-ground tanks used to store used oil are in good condition (no severe rusting, apparent structural defects, or deterioration) and not leaking (no visible leaks).
• Ensure that storage containers and tanks adhere to all applicable spill prevention, control, and countermeasures (SPCC) requirements in ESH100.2.ENV.4, Manage Oil and Fuel Storage.

• Clearly label with the words “Used Oil” containers and aboveground tanks used to store used oil.
• Contact the appropriate division ES&H team environmental compliance coordinator (ECC) to obtain the proper label.
• Fill pipes used to transfer used oil to underground storage tanks must be labeled or marked clearly with the words “Used Oil.”  See ESH100.2.ENV.4, Manage Oil and Fuel Storage, for additional information.
• Use permanent or indelible ink on containers of used oil, especially those stored at outside locations. 
• Check labels periodically to ensure continued legibility.

• Safely segregate non-regulated broken or fragile glass from ordinary trash. 
• Place laboratory glassware (intact or broken) and empty glass containers in the glass boxes.
• Ensure that empty glass containers have a capacity of 5 gallons or less and meet the definition of “empty container” in the following table in this section.
• Do not place the following items in a glass box:
  • Glass containers not meeting the definition of “empty container” as described in Table 1, Common Wastes.
  • Incandescent light bulbs – these are to be managed as hazardous waste. See Table 1, Common Wastes, for additional information.
  • Fluorescent light bulbs, intact or broken. These may or may not be hazardous waste. See Table 1, Common Wastes, for additional information.
  • Non-glass items.
  • Any liquids.

Used aerosol cans that contain any amount of propellant or product must be managed as hazardous waste. At SNL/NM, if an aerosol can is empty of propellant and product, is no longer pressurized, and does not contain residue of an acute hazardous waste, it is considered an empty container and may be disposed of as regular trash.

• Do not spray out the remaining contents of an aerosol can for the sole purpose of emptying it.
• Never puncture an aerosol can.

Used batteries must be managed according to the following:

• Carbon-zinc and alkaline batteries, sizes AAA through D and 9-volt, are not hazardous waste and may be disposed of in the regular trash or recycled (contact the appropriate division ES&H team pollution prevention (P2) representative for additional details).
• Lead-acid batteries must be managed as a recyclable material unless they cannot be recycled because of damage. If damaged, manage batteries as hazardous waste. Otherwise, identify contents as a “Lead-Acid Battery.”  Label with a “Material for Recycle” label according to the requirements in the Labels section.
• All other batteries must be managed as hazardous waste, unless the waste profile process has been used to determine otherwise (e.g., 6-volt lantern batteries, Li-ion, NiCd, NiMH, and thermal).

Note: Battery terminals must be covered with non-conductive tape (such as electrical, masking, or duct tape) before depositing them in a hazardous waste primary container.

A container that held any chemical or hazardous waste, except a substance identified as an acute hazardous waste, is defined as an empty container if all the following criteria are met completely:

• All contents have been removed that can be removed using the practices commonly employed to remove material from that type of container, such as pumping, pouring, or aspirating.
• For containers less than or equal to 110 gallons, no more than 3% by weight of the total capacity of the container remains in the container.
• No more than 2.5 centimeters (one inch) of residue remains on the bottom of the container or inner liner.

Containers with a capacity of 5 gallons or less that meet the above criteria may be thrown in the trash. Empty containers with a capacity of greater than 5 gallons must be submitted for disposal on a waste description and disposal request (WDDR). Those containers must be marked with the words "Empty Container," the disposal request number, and line item numbers. For containers greater than 110 gallons, contact the appropriate division ES&H team ECC.

Note: Containers that held a substance identified as an acute hazardous waste must be regarded and managed as hazardous waste, even if they are empty according to these criteria.

All unbound, engineered nanoscale particle (UNP) bearing waste streams must be characterized and managed as either hazardous waste or as non-hazardous waste based on the requirements presented below and in ESH100.2.IH.16, Evaluate and Control Unbound Engineered Nanoscale Particles. Generators of UNP waste must:

• Package UNP-containing and UNP-contaminated wastes in sealed, impermeable bags or containers to prevent the release of UNP dust during handling and transportation. The bags, containers, and enclosures that are used for disposal of UNP waste must be labeled with the Labels section. UNP-bearing wastes must be placed in proper containers that are compatible with the contents, in good condition, and provide adequate containment to prevent the escape of the UNP.
• Label the primary and secondary waste container(s) with a “Hazardous Waste” or a “Solid Waste” label and a “Contains Unbound, Engineered Nanoscale Particles (UNP)” label.
• UNP-bearing waste must be segregated from other wastes during management and disposition.
• Submit a waste description and disposal request (WDDR) for pick-up and disposal of all nanoscale-bearing wastes, and be sure to mark the “contains nano material” box on the WDDR. No UNP-bearing waste can be disposed down the drain or in the regular trash or dumpster.

The following used Polaroid^® products may be disposed of in the regular trash:

• Processed prints (pictures)
• Used print backing
• Empty film cartridges containing batteries

Unused print film and all other waste Polaroid^® items must be managed as hazardous waste, unless the waste profile process has been used to determine otherwise.

Waste toner cartridges must be recycled, if possible. Follow the Pollution Prevention (P2) recycling process for recycling toner cartridges and other printer supplies. See P2 Recycling website for information on toner cartridge recycling, and contact the appropriate division ES&H team P2 representative for additional details.

Toner cartridges that cannot be recycled must be managed as hazardous waste, unless the waste profile process has been used to determine otherwise.

The term, "trace explosive contamination," is used to denote certain explosive-contaminated waste items that may be regarded and managed as hazardous waste only because the level of explosive contamination is such that it does not present an explosive safety hazard to handlers.

• For explosive waste to be regarded as trace explosive contaminated, all of the following criteria must be met:
• The estimated explosive concentration must be less than or equal to 1% by weight.
• The estimated total net explosive weight (NEW) must be less than or equal to 1 gram per primary container.
• The explosive substance must be distributed in such a manner and present in sub-critical diameter (listed in the LLNL Explosives Handbook) such that the explosives will not retain their explosive properties.
• The explosive substance is not a true primary explosive. (For the purpose of this definition, dry pentaerythritol tetranitrate [PETN], high melting-point explosive [HMX], research department explosive [RDX], cobalt-perchlorate [CP], and cis-bis-(5-nitrotetrazolato)tetraminecobalt(III) perchlorate [BNCP] are not considered true primary explosives and may be managed as trace explosive contaminated waste.)

Prepare and submit an approval request package to Sandia Site Office (SSO) according to the requirements stated in Table 2, Request Package Content, for materials that are currently in inventory and that will not have an identified disposal path when they become waste.

Note:  Because no action can be taken up front to prevent the material from becoming no-disposal-path (NDP) waste, this approval will focus on action requirements for future management of the waste.

Prior to generating waste with no disposal path, prepare and submit to SSO a request package that includes information shown in Table 2, Request Package Content.

Note:  The approval to generate a waste with no disposal path (NDP) is granted on a fiscal year basis; therefore, Members of the Workforce must review and resubmit the request every year that a waste with no disposal path is generated, unless a disposal path becomes available.

Provide a formal letter with the approval request package and transmit both to the SSO. The Regulated Waste and Nuclear Material Disposition Department must be the point of contact with the SSO.

Note:  Include a description of any problem in identifying programmatic ownership with the approval request package.

Review and renew the approval each fiscal year that the process continues. By October 1 of each year, if requested, provide an annual report to SSO documenting the steps taken to manage and find disposition for each no-disposal-path (NDP) waste that has been previously approved by SSO.

Note:  Progress made in locating a viable disposal path must be considered necessary for renewed approval to continue to generate waste with no identified path to disposal.

• Name of program that funds the project or process that will generate the waste (program/project manager's name).
• SNL contact, telephone number, and organization.
• Process that generates the waste and its location (technical area, building, or other appropriate location description).
• Scheduled start-up date.

• Waste that cannot be disposed of and the volume (annual volume and anticipated life-cycle volume) of waste that will be generated by the process.
• The NEPA document number(s) that address this operation and the generation and disposition of this waste.
• Summary of the documentation that comprises the authorization basis or authorization agreements for this facility and this operation, if applicable.
• Explanation of the waste characteristics and issues that prevent disposal of the waste (for example, it is a non-defense transuranic waste and there is no licensed disposal facility; the waste requires treatment before disposal, and there is no appropriate treatment facility). See examples of waste with no disposal path in Guidance on Hazardous Waste Management at SNL.

• Description of all activities and inquiries that have been made to determine whether a treatment/disposal path is available. Provide copies of pollution prevention opportunities or other waste minimization/pollution prevention studies performed for the waste stream. Indicate whether this waste is being addressed by national efforts to provide treatment and disposal options (for example, Mixed Low Level Waste Center of Excellence national procurements).
• Description of the consideration of alternatives to the process that generates the problem waste. Can the process be eliminated?  Can the raw materials used in the process be changed to preclude generating the problem waste?
• Estimate of the life cycle costs for storage and maintenance of the waste, and estimate ultimate disposal costs, if possible. Include a commitment from the generating program to support those costs until the waste is ultimately disposed of.

• Determine potential incompatibilities of waste. See one of the following:
  • Relevant material safety data sheet (MSDS).
  • Division ES&H team’s environmental compliance coordinator (ECC) for assistance.
  • 40 CFR 265, Appendix V, Examples of Potentially Incompatible Waste in the Reference section.
• Segregate incompatible wastes by placing them in separate containers.

• Physically segregate the explosive waste into the following waste categories:
  • Articles that contain explosives.
  • Bulk explosive substances.
  • Solid and liquid waste items that are contaminated with explosives.
• Further segregate dissimilar items within the same category by waste type:
  • Waste articles that contain explosives by identical type, such as RP-2 detonators.
  • Waste bulk substances by explosive type.
  • Waste solid items contaminated with explosives, such as wipes, from other explosive-contaminated solid items, such as filters.
  • Waste solvents contaminated with explosives by solvent type and explosive type.

When a corrosive hazardous waste is being generated, follow Resource Conservation and Recovery Act (RCRA)  requirements of 40 CFR 262.34(a) accumulation time prior to neutralization:

• Label as required by this procedure if the corrosive waste is stored in a container or tank prior to introduction into the elementary neutralization unit.
• The one-time Land Disposal Restriction (LDR) notification requirement of 40 CFR 268.7. Testing, tracking, and recordkeeping requirements for generators, treaters, and disposal facilities (a)(7).
• The records maintenance requirements of 40 CFR 268.7(a)(6).

Note: The one-time LDR notification describing such generation, subsequent exclusion from the definition of hazardous or solid waste or exemption from RCRA Subtitle C regulation, and the disposition of the waste, must be in the on-site file of the facility that performs the neutralization. Contact the appropriate division ES&H team environmental compliance coordinator (ECC) for LDR notification and recordkeeping requirements.

Neutralize waste before discharging it into the Albuquerque Bernalillo County Water Utility Authority (ABCWUA) sewer system.

Note:  If neutralized waste must be discharged to a sewer system other than the ABCWUA sewer system or be managed in any other way, additional Resource Conservation and Recovery Act (RCRA) requirements become applicable (for example, development of a waste analysis plan and submittal of a certification to the NMED). In addition, because a chemical waste is being generated, chemical waste requirements are applicable.

• Ensure that containers are able to withstand normal activities (i.e., storage, hand-carry, forklift handling, and truck transport) within the Sandia-controlled premises without leaking or sustaining damage.
• Place hazardous waste inside an appropriate container at the time it is generated.
• Use an appropriate container that is:
  • Chemically compatible with the waste.
  • In good condition and leak-free. Note: A container in good condition has no dents, creases, bulges, or corrosion that would compromise the integrity of the container. Minor dents and/or surface corrosion are acceptable. 
  • Closed, except to actively add or remove waste. Note: A closed container will not allow any waste to escape into the environment.
  • Free of external chemical contamination (i.e., all waste must be inside its container).
• Ensure that funnel equipment that drains hazardous waste into containers via tubing through an opening in a cap of the container has all vent holes sealed or capped off when the machine power switch is off. Note: The use of a funnel that attaches directly to the waste containers and to the tubing is considered a closed container regardless of the machine operating status.
• Contact the appropriate division ES&H team environmental compliance coordinator (ECC) for additional assistance (for container guidelines, see Guidance on Hazardous Waste Management at SNL).

When placing explosive waste in containers, comply with all compatibility and container requirements in MN471011, Sandia Explosives Safety Manual, and follow the following requirements:

• Place explosive waste inside antistatic primary containers, such as Velostat^TM bags or pillboxes.
• Place primary containers of explosive waste inside Sandia-approved explosive transportation (outer) containers, which must also comply with container requirements of MN471011, Sandia Explosives Safety Manual. Note: More than one primary container may be placed inside a transportation container, but only if all compatibility requirements are met.
• Contact the appropriate division ES&H team environmental compliance coordinator (ECC) for additional assistance (for container guidelines, see Guidance on Hazardous Waste Management at SNL).

• Order hazardous waste labels through just-in-time (JIT) or obtain them from your division ES&H team’s ECC.
• Obtain the following labels through your division ES&H team’s ECC:
  • Less-Than-90-Day Accumulation Area Start Date.
  • Material for Recycle.
  • Used Oil.
  • Solid Waste.
  • Lead for Re-Use.
  • Explosive Hazardous Waste.
  • UNP Waste.

Note: To see example labels, see Guidance on Hazardous Waste Management at SNL.

• Immediately apply a hazardous waste label (see Guidance on Hazardous Waste Management at SNL) when non-explosive hazardous waste is first placed inside a primary container.
• Complete each field on the label as follows. (Note: No date is required unless the container exceeds the satellite accumulation point (SAP) volume limit or is placed in a less-than-90-day accumulation area.)
  • Contents. Accurately describe the waste inside the primary container, including specific chemical names for all contaminants.
  • Owner name. Enter the name of the person who owns the waste.
  • Org. Enter the organization number of the person who generated the waste.
  • Phone. Enter the phone number of the person who generated the waste.
  • WDDR No. When the waste item is submitted for disposal, enter the waste description and disposal request number.
  • Line Item No. Enter the waste description and disposal request (WDDR) line item number that is applicable to the container.
• When primary containers of hazardous waste are placed in outer containers, at a minimum, mark or label the outer container with the words “Hazardous Waste.”
• Use permanent or indelible ink on containers of hazardous waste, especially those stored at outside SAP locations.
• Check labels periodically to ensure continued legibility.
• When a container exceeds the SAP waste-volume limits (see Limit SAP Volumes), immediately apply a date to the container identifying the day the SAP volume limit was exceeded.
• When a container is placed in a less-than-90-day accumulation area, complete the label’s “<90-Day Accumulation Start Date:” with the date that the container is first placed in the less-than-90-day accumulation area, and apply the label to the container.

Note: For assistance regarding labeling requirements for specific wastes, contact the appropriate division ES&H team’s ECC.

• Immediately apply an explosive waste label (see Guidance on Hazardous Waste Management at SNL) when explosive waste is first placed inside a primary container.
• Complete each field on the label as follows:
  • Contents (including explosive names and all contaminants). Accurately describe the waste inside the primary container, including the name(s) of the explosives present and all chemical contaminants.
  • UNO Classification of Waste. Enter the original or most appropriate United Nations Organization (UNO) hazard classification and compatibility group for the waste inside the primary container.
  • Note:  It is vital that the correct UNO hazard classification and compatibility group is assigned. Contact the appropriate division ES&H team explosives safety representative for assistance.
  • N.E.W. Enter the total net explosive weight (N.E.W.) present in the primary container.
  • Gross Quantity. Enter the total weight of the waste with unit of measure.
  • Owner’s Org. No. Enter the organization number of the person who owns the waste.
  • Phone No. Enter the phone number of the person who owns the waste.
  • Start Date. Enter the date when explosive waste is first placed in the container.
  • WDDR & Item No. When the waste is submitted for disposal, enter the number from the waste description and disposal request (WDDR) and the trackable unit (TU) number, as appropriate.

Place the following items in a clear plastic bag, seal the bag, write the waste profile on the bag (for example, WP-00ALLSANDIA-02), and deposit the bag in the regular trash:

• Cured epoxies/adhesives, stir sticks, wipes, mixing container, gloves, applicators, and empty packages (see examples in Guidance on Hazardous Waste Management at SNL).
• Minimal amounts of oils/greases on wipes, gloves, and the empty container (see examples in Guidance on Hazardous Waste Management at SNL).

Note: No date is required.

Contact the appropriate division ES&H team environmental compliance coordinator (ECC) for appropriate labels for the following types of materials (see labels in Guidance on Hazardous Waste Management at SNL):

• Material for Recycle: This label may be appropriate for specific fluorescent light bulbs, lead-acid batteries, scrap metal, and specific electronics and circuit boards.
• Used Oil: This label may be appropriate for used oil that has been determined to be acceptable for the Used Oil Program.
• Solid Waste: This label may be appropriate for solid waste that requires special handling.
• Lead for Re-Use: This label may be appropriate for lead items that will be re-used, such as lead bricks used for shielding. Note: Refer to ESH100.2.ENV.8, Manage Excess Metallic Lead, for further requirements.
• UNP:  This label may be appropriate for UNP-bearing wastes.

Accumulate waste only in one of the following areas:

• At a satellite accumulation point (SAP) as outlined in the SAP Management section.
• At less-than-90-day accumulation areas, as outlined in Less-Than-90-Day Accumulation Area section. Note:  In most instances, a SAP has fewer associated regulatory requirements as compared to a less-than-90-day accumulation area; however, the requirements for accumulating hazardous waste at a SAP are more restrictive in terms of allowable waste volume, location, and who is allowed to contribute waste.
• Consult the appropriate division ES&H team environmental compliance coordinator (ECC) for assistance in determining which option is better for accumulating and managing hazardous waste.

• Accumulate primary containers of hazardous waste at a Satellite Accumulation Point (SAP). Note: Every location where hazardous waste is initially accumulated is, at a minimum, a SAP and is subject to all requirements of this procedure, regardless of the type of hazardous waste being stored.
• Establish a less-than-90-day accumulation area to accept waste from other SAP location owners or generators, (see SAP Volume Limits section for volume distinction between an SAP and a less-than-90-day accumulation area).
• Ensure the SAP is:
  • Under the control of the owner or generator of the waste in storage at the SAP at all times.
  • Located at or near the point of waste generation (generally within the same room where the waste is generated). If this conflicts with any other requirement, contact the appropriate division ES&H team environmental compliance coordinator (ECC) for guidance.
  • Located at least 20 feet from security perimeter fences.
• Do not:
  • Accept waste from other waste owners or generators.
  • Establish a SAP without first obtaining approval from your division ES&H team ECC.
  • Submit waste to other waste owners or generators (unless the other one has a less-than-90-day accumulation area).
  • Transfer waste from one SAP to another SAP.
  • Combine waste from other SAPs.
  • Move waste out of the SAP (unless it is being placed in a less-than-90-day accumulation area) prior to pickup by personnel from the Hazardous Waste Management Facility (HWMF). If waste must be moved to facilitate pickup, the move must be coordinated with HWMF personnel so that the movement and pickup are concurrent.
• Because the size and boundaries of an SAP vary and depend upon an owner's or generator's waste type, container, and work area, contact the division ES&H team ECC for assistance when establishing an SAP.  

Note:  SAPs can vary in size from a single plastic bag on a workbench to several containers in a dedicated area or room.

• Limit the total volume of either liquid or solid hazardous and/or acute hazardous waste stored at satellite accumulation points (SAPs), as follows:
  • Hazardous waste accumulated at a SAP is limited to 55 gallons.
  • Acute hazardous waste accumulated at an SAP is limited to 1 quart.
• If the total volume of waste at an SAP exceeds either the 55-gallon or the 1-quart volume limit,
  • Mark the excess of the applicable limit with the date the volume limit was exceeded.
  • Remove the quantity in excess of the applicable limit within three calendar days by requesting a 3-day pickup. The request for a 3-day pickup must be initiated as soon as the volume limit is exceeded by completing the appropriate waste description and disposal request (WDDR) and checking the box for a "Volume Limit pickup."

Note:  Contact the division ES&H team environmental compliance coordinator (ECC) to ensure wastes are picked up within the required time.

• Maintain and operate less-than-90-day accumulation areas to minimize the possibility of fire, explosion, or any unplanned release of hazardous waste to air, soil, or surface water.
• Equip less-than-90-day accumulation areas with the following:
  • Internal communications or an alarm system capable of providing immediate emergency notification (voice or signal) to facility personnel.
  • A telephone, cellular telephone, or hand-held two-way radio capable of summoning emergency assistance from the SNL Emergency Operations Center (911, 844-0911, 284-0911, or 845-0911).
  • Portable fire extinguishers, fire control equipment, spill control equipment, and decontamination equipment.
  • Water at adequate volume and pressure to supply water hose streams, foam producing equipment, automatic sprinklers, or water spray systems.
• Test and maintain all communications or alarm systems, fire protection equipment, spill control equipment, and decontamination equipment, as required, to ensure proper operation during an emergency.
• Ensure that whenever hazardous waste is being handled, all personnel involved in the operation either have immediate access to an internal alarm or emergency communication device, directly or through visual or voice contact with another employee.
• Ensure that whenever there is just one employee present during operations, that employee has immediate access to a telephone, cellular telephone, or hand-held two-way radio capable of summoning external emergency assistance.
• Maintain aisle space to allow unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area during an emergency.

• Write a site-specific contingency plan in cooperation with the division ES&H team environmental compliance coordinator (ECC) that describes the actions personnel must take to mitigate an emergency resulting from fires, explosions, or any unplanned release of hazardous waste to air, soil, or surface water (see Guidance on Hazardous Waste Management at SNL for template).
• Carry out provisions of the site-specific contingency plan immediately in the event of a fire, explosion, or release of hazardous waste.
• Maintain site-specific and SNL site-wide contingency plans at the following locations:
  • The less-than-90-day accumulation area, and
  • The SNL/NM Emergency Operations Center (EOC).
• Review and amend, as necessary, each site-specific contingency plan, whenever one of the following is true:
  • Applicable regulations are revised.
  • The site-specific plan fails in an emergency.
  • The facility changes with respect to design, construction, maintenance, or operation in a way that increases the potential for fires, explosions, or releases of hazardous waste, or when the type of response that would be necessary in an emergency changes.
  • The list of emergency coordinators changes or your pager or telephone number change.
  • The list of emergency equipment changes.

Use the site-wide Training Plan for SNL/NM Less-Than-90-Day Accumulation Areas to document site-specific job assignments and completion of applicable training. Maintain the following information as part of the less-than-90-day accumulation area notebook at or near the accumulation area:

• The job title of each position at the accumulation area relating to hazardous waste management and the name of the person(s) filling each job.
• A written description for each job.
• A written description of the type and amount of both introductory and continuing training that will be given to each person filling each job position.
• Documentation verifying completion of the required training, including the required reading of the site-specific and SNL site-wide contingency plans.
• ENV416 (Training Attendance Sheet).
• Training Matrix Form.

Notes: 

• By signing the site-specific plan, Members of the Workforce acknowledge that they have also read and understood the site-wide contingency and training plans.  No other additional record is necessary; however, the site-specific contingency plan must reference these site-wide contingency and training plans for this condition to be valid.
• Destroy the notebook 5 years after the permit expires after a retention review (including long-term environmental stewardship) determines the information has no continuing value.

Place waste inside containers that are:

• Chemically compatible with the waste.
• In good condition and leak-free. A container in good condition has no dents, creases, bulges, or corrosion that would compromise the integrity of the container. Minor dents and/or surface corrosion are acceptable. If a container holding hazardous waste is not in good condition or if it begins to leak, the waste must be transferred to a container that is in good condition.
• Closed, except to actively add or remove waste. A closed container will not allow any waste to escape into the environment.
• Handled and stored in a manner that will not cause the container to rupture or leak.
• Free of external chemical contamination (in other words, all waste must be inside its container).
• Equipped with a cover and closure devices that form a continuous barrier over the container openings such that when the cover and closure devices are secured in the closed position there are no visible holes, gaps, or other open spaces into the interior of the container.
• Stored in manner that will allow container to be easily accessible and inspected.

• Mark containers clearly with:
  • Date upon which the container of hazardous waste was placed in the less-than-90-day accumulation area.
  • The words "hazardous waste."
• Ensure the required markings are visible for inspection (see Guidance on Hazardous Waste Management at SNL for markings).

Do not store hazardous waste at a less-than-90-day accumulation area for greater than 90 days.

Note:  A 30-day extension to the time limit is possible in special cases (such as when it is not feasible to remove the waste within 90 days). Make requests for the 30-day extension before the sixtieth day, or as soon as possible, by contacting the appropriate division ES&H team environmental compliance coordinator (ECC) (see Guidance on Hazardous Waste Management at SNL for timing).

• Be, at all times, either in the immediate vicinity of the accumulation area for which they are responsible or on call and able to reach the accumulation area within a short period of time.
• Be responsible for coordinating emergency response measures until the incident commander designated by the Emergency Operations Center (EOC) arrives and takes over.
• Be familiar with all aspects of the contingency plan, facility operations, waste locations, characteristics of the waste, location of records, and facility layout.
• Keep the contact information current in the contingency plan.

Note: The specific duties of the emergency coordinator are described in the Site-Wide Contingency Plan and in the site-specific addendum for each Accumulation Area.

• Inspect (at the time containers are accepted) the containers and their closure devices for visible cracks, holes, gaps, or other open spaces into the interior of the container when the closure devices are secured in the closed position.
• Inspect (at least weekly) accumulation areas where containers are stored. Look for leaks and for deterioration caused by corrosion or other factors.
• Include (at a minimum) in each inspection, the Criteria on the Less Than 90-day Hazardous or Mixed Waste Accumulation Unit Inspection form (latest addition). Use SA 2001-MWA (3-2010), Less Than 90-Day Hazardous or Mixed Waste Accumulation Unit Inspection Form (Word file/Acrobat file).
• Document the initial acceptance and the weekly inspection of containers (include date, time, signature, and notation of items on the Less Than 90-Day Hazardous or Mixed Waste Accumulation Unit Inspection Form (latest addition) and maintain the documentation at the accumulation area (see Guidance on Hazardous Waste Management at SNL for retention period).

• Make first efforts at repair of the defect no later than 24 hours after detection.
• Complete the repair as soon as possible and no later than five calendar days after detection.
• Note the repair in the accumulation area’s inspection log.

Maintain the following information as part of the less-than-90-day accumulation area notebook at or near the accumulation area:

• A copy of the approved site-specific contingency plan signed by all less-than-90-day accumulation area personnel.
• A copy of the Site-Wide Contingency Plan for Less-Than-90-Day Accumulation Areas at SNL/NM.
• Current inspections and those generated within the preceding 12 months within the accumulation area for review and auditing purposes.
• Inspections for the prior 3 years in department files and make them available for review or audit.
• Archive inspection records that are older than 3 years.
• When the accumulation area is vacated, a copy of the correspondence declaring all waste has been removed, a declaration that no future waste will be kept at this area, a history of any spills, that there is no visible contamination in the area, and the less-than-90-day accumulation area inhas been decommissioned and is officially closed.

• Request disposal of hazardous waste on or before either:
  • The day that the applicable volume limit is exceeded.
  • The date on which the generator's status or assignment changes such that the waste is no longer under your control.
• Request disposal of hazardous waste using a waste description and disposal request (WDDR).
  • Do not add any additional waste to any primary container that has been submitted for disposal.
  • Enter the WDDR number and line item number in the appropriate fields on the hazardous waste label for each container of waste submitted for disposal. Line item numbers can be determined by utilizing the WDDR report function.
• Provide all information necessary to enable Hazardous Waste Management Facility (HWMF) personnel to accurately characterize hazardous waste and ensure that safe handling and transportation methods/requirements are employed through ultimate disposition.
• Certify that the information provided on hazardous waste disposal request documentation is true and correct to the best of your knowledge and that they are ultimately responsible for the accuracy of that information.

• Identify the munitions, based upon descriptions in Table 3, Excess and Waste Military Munitions.
• Manage munitions according to the requirements in Table 3.

Provide and enter the following information into the Explosive Inventory System (EIS):

• Standard nomenclature.
• All applicable lot numbers.
• Federal supply class (FSC).
• National stock number (NSN).
• Department of Defense Ammunition Code (DoDAC) or Department of Defense Identification Code (DoDIC).
• Condition code.

Note: Consult the appropriate division ES&H team environmental compliance coordinator (ECC) or the explosive waste project leader for assistance.

Request explosive waste or excess and waste military munitions disposal by completing the process in the Explosives Inventory System (EIS) by following the steps in the Oracle EIS Users Manual.

Note: For waste explosive articles, review the constituents list to ensure that it accurately reflects the actual waste.

• No longer desired by the owning organization.
• Munitions can still be used for their intended purpose, which may include the following:
  • Use in the training of military personnel.
  • Use in the training of explosives and munitions emergency response specialists (including training in proper destruction of unused propellant or other munitions).
  • Use in research, development, testing, and evaluation of military munitions, weapons, or weapon systems.
  • On-range destruction of unexploded ordnance and munitions fragments during range clearance activities at active or inactive ranges.

Note: Use for intended purpose does not include the on-range burial of unexploded ordnance and contaminants.

• Identify and include these munitions in the Explosives Inventory System (EIS).
• Make excess military munitions available to other users by including them in the Resource Recovery and Disposition Account (RRDA) in EIS.
• Complete and submit a waste description and disposal request (WDDR).

• Abandoned by being disposed of, burned, detonated, incinerated, or treated prior to disposal.
• Removed from storage in a military magazine or other storage area for the purpose of being disposed of, burned, incinerated, or treated prior to disposal.
• Deteriorated or damaged (in other words, the integrity of the munition is compromised by cracks, leaks, or other damage) to the point that it cannot be put into serviceable condition and cannot reasonably be recycled or used for other purposes.
• Declared a solid waste by a military official.

• Immediately notify the explosive waste project leader.
• Immediately complete and submit a waste description and disposal request (WDDR).
• If safe to do so, immediately apply an EIS-generated explosive waste label to the waste military munition(s).

ENV216 (annually)
Required reading of the site-specific and SNL site-wide contingency plans.

Note: ECs and AECs must complete initial training prior to or no later than 6 months following assignment to the accumulation area. The EC or AEC cannot work unsupervised within the accumulation area until the initial training has been completed. Training must be repeated annually thereafter.

ENV316– RCRA (annually)
ENV416– RCRA (annually)
Required reading of the site-specific and SNL site-wide contingency plans.

• Acquire this training from the qualified accumulation area EC, AEC, owner, or the requestor’s environmental compliance coordinator (ECC).
• WSWs and inspectors must complete initial training prior to or no later than 6 months following assignment to the accumulation area. WSWs and inspectors cannot work unsupervised within the accumulation area until the initial training has been completed. Training must be repeated annually thereafter.

Administrative

Modified

Administrative

Modified

• Changed ESH100.2.IH.20 reference to ESH100.2.ENV.27; no title change. (Related Processes & Procedures)
• Replaced SAPLE link for subject matter expert with direct link to e-mail for improved usability.

Administrative

Modified

Updated the link to "Guidance on Hazardous Waste Management at SNL" throughout the document.

Administrative

Modified

Administrative

Modified

• Replaced "Regulated Waste and Nuclear Material Disposition Department" references with "Regulated Waste & Pollution Prevention Department" and updated the link where applicable.
• Corrected dictionary link to "hazardous waste."

Administrative

Modified

Updated all dictionary links to term identification numbers.

Administrative

Modified

Administrative

Modified

• Updated several links throughout the procedure including dictionary terms, training courses, and additional drivers.
• Relocated DOE prime contract driver to additional drivers so that a hyperlink could be added.
• Added a SA 2001-MWA under Forms, Links & Tools.

Administrative

Modified

• Updated SAPLE link for subject matter expert for system consistency.
• Un-Merged cells in requirements tables for system consistency.
• Relocated the change summary entries for 02/05/2010 and 02/10/2010 to be in the correct date order and corrected the formatting for the months to be 2 digits.

Administrative

Added

• Added website, "Environmental Compliance Coordinators," under "Forms, Links, and Tools."

Modified

• Put list of websites in alphabetical order.

Administrative

Modified

• Cleaned up HTML code for hyperlinks under "Forms, Links, and Tools."
• Updated hyperlink to SME.

Administrative

Modified

• Corrected link to electrical equipment in Requirements & Instructions.

Administrative

Modified

Information—from Include (at a minimum) in each inspection the questions on the Inspection Checklist. to Include (at a minimum) in each inspection, the Criteria on the Less Than 90-day Hazardous or Mixed Waste Accumulation Unit Inspection form (latest addition). Obtain the Inspection Form from the  Environmental Compliance Coordinator's (ECC) website. In Activity—Inspect Accumulation Areas.

Information—from Document the initial acceptance and the weekly inspection of containers (include date, time, signature, and notation of items on the checklist) and maintain the documentation at the accumulation area (see Guidance on Hazardous Waste Management at SNL for retention period). to Document the initial acceptance and the weekly inspection of containers (include date, time, signature, and notation of items on the Less Than 90-Day Hazardous or Mixed Waste Accumulation Unit Inspection Form (latest addition) and maintain the documentation at the accumulation area (see Guidance on Hazardous Waste Management at SNL for retention period). In Activity—Inspect Accumulation Areas.

Added

Added the following bullet: 

• Archive inspection records that are older than 3 years.  In Activity—Maintain Documents.

Administrative

Modified

Updated guidance link from Guidance on Managing Hazardous Waste at SNL to Guidance on Hazardous Waste Management at SNL.

Administrative

Modified

Updated guidance links from Guidance on Managing Hazardous Waste at SNL to Guidance on Hazardous Waste Management at SNL throughout the entire document.

Administrative

Modified

From:

• ENV216 (annually) Required reading of PLA-95-13, including site-specific addendum, and PLA-02-02.
• ENV316– RCRA (annually) ENV416– RCRA (annually) Required reading of PLA-95-13, including site-specific addendum, and PLA-02-02.

To:

• ENV216 (annually) Required reading of the site-specific and SNL site-wide contingency plans.
• ENV316– RCRA (annually) ENV416– RCRA (annually) Required reading of the site-specific and SNL site-wide contingency plans.

Reason for change

This change matches a similar correction updated just prior to the final transformation.