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Introduction

As part of the charge to maintain employee safety and environmental health at the ¾ÅÉ«ÊÓƵ (¾ÅÉ«ÊÓƵ), the department of Environmental Health, Safety, Insurance & Risk Management (EH&S) has developed this Hazardous Waste Preparedness, Prevention, Contingency and Emergency Procedures Plan and Release Detection Response Levels (RDRL). 

This plan is in fulfillment of the U. S. Environmental Protection Agency's (EPA) Resource Conservation and Recovery Act (RCRA), parts 262.34 and 265, Subpart C, Florida Administrative Codes (FAC) 62-730 Hazardous Waste and 62-761.710 Recordkeeping.  These require small quantity generators (SQG) of regulated hazardous waste to develop a document that describes how the generator minimizes the possibility of fire, explosion or unplanned release of hazardous waste to the environment.  This Plan further describes the procedures to be taken in case of fire, unplanned release or tank discharge. 

Preparedness and Prevention 

As a SQG, ¾ÅÉ«ÊÓƵ generates between 100 and 1,000 kilograms (kg) of regulated hazardous waste per month and no more than 6,000 kg of regulated hazardous waste at any one time.  This waste is generated and accumulated in the Print Shop (bldg. #818), Physical Facilities Maintenance Shops (bldg. #5 & #6) , Biology Department (bldg. #4), College of Health (bldg. #39), Fine Arts Department (bldg. #45), Photo Lab (bldg. #45D), and the Chemistry, Physics and Engineering Departments (bldg. #50).  The enclosed maps show the location of these buildings relative to the campus community. 

The regulated waste streams generated in these areas include waste ink, toner, pads and cleaning solution from the Print Shop; oil based paint, organic solvents, brushes and rags from Physical Facilities, and lab pack materials from the College of Health, Chemistry, Physics, Engineering, and Biology Department teaching and research labs.  The latter primarily include poisons, reactives, corrosives, heavy metals and both halogenated and non-halogenated solvent waste. 

As an SQG, ¾ÅÉ«ÊÓƵ accumulates hazardous waste under the conditions necessary to qualify sites as satellite accumulation areas.  These conditions include: 

• Posting Accumulation Guidelines. 
• Accumulating less than 55 gallons of hazardous waste or 1 quart of acutely hazardous  waste. 
• Accumulating for less than 180 days from the date the container is filled and dating the  container once filled.
• Accumulating in or near the area of waste generation and under the control of the generator.
• Labeling all waste containers as hazardous waste and identifying the contents to ensure  that they are compatible with the waste. 
• Conducting weekly inspections of the accumulation areas for spills, leakage, container  labeling and integrity, and maintaining a weekly inspection log. 

Contingency

Several of ¾ÅÉ«ÊÓƵ's Environmental Health and Safety Programs address hazardous materials management.  These include the Chemical Hygiene Plan and the Hazardous Materials Management Program.  Facilities are designed and constructed to meet applicable fire, safety and building codes.  This includes fire alarms, sprinkler systems, and communications.  All regulated hazardous waste is accumulated in secured areas under the responsibility of a qualified supervisor (see Emergency Procedures section below).  Additional oversight is provided by EH&S and the University's Police Department who patrol all areas of the campus.  UPD officers have received training as required by the Occupational Safety & Health Administration's (OSHA) Hazardous Operations and Emergency Response (HAZWOPER) standard to be qualified as First Responders, Awareness Level. 

All areas where flammable materials are utilized contain an approved fire extinguisher rated for all classes of use.  These extinguishers are labeled and inspected on a monthly and annual basis. Waste accumulation areas are managed such that all container labels are visible during inspections and adequate aisle space is available for inspections and egress. 

All telephones in areas where hazardous materials are utilized are posted with the following emergency phone numbers: 

University Police Department, Information  620-2800 (Alternate Emergency Coordinator)      

EH&S / Emergency Coordinator Cell: 705-1580 Office: 620-2019 

Emergency Procedures

In general, University personnel are informed that emergency response is NOT part of their job responsibilities.  Upon discovery they are to leave the area, close the door behind them and immediately summon help through the UPD.  Communication is possible through the local telephone, radio or emergency phone.  UPD in turn contacts EH&S (Emergency Coordinator) and a decision is made on how to best handle the situation.   

Jacksonville Fire and Rescue (JFR) have been apprised of the hazardous materials on the campus of ¾ÅÉ«ÊÓƵ and the resources available on-site to handle unplanned releases.  In most cases they will be the responding party for hazardous materials incidents on the campus of ¾ÅÉ«ÊÓƵ.  

Several University personnel including the UPD, the Lab Manager’s of the Chemistry & Physics, Biology Departments, the Print Shop Manager and the Emergency Coordinator have received specialized training in the management of hazardous materials.  NO HAZARDOUS MATERIALS INCIDENT SHOULD BE HANDLED IN-HOUSE WITHOUT PRIOR CONSULTATION WITH ONE OF THESE PERSONNEL.   

Basic spill response measures include the following: 

• The immediate area should be evacuated while the identity and quantity of the material are evaluated.   
• If possible, ensure that the door to the area is closed and the fume hood is left on, if available.   
• If the spill threatens the health of building occupants, activate the fire alarms in the hallway to evacuate the building.   
• Personnel should then meet at a predetermined, common area for a head count.   A decision must be made by the trained supervisor, emergency coordinator and UPD as to the ability for in-house clean up or the need for outside assistance from JFR.  At a minimum, decision criteria must include the following: 
• The quantity of material lost 
• The physical state of the material and the resultant exposure route 
• The toxicity and effects of exposure 
• The ability to provide adequate protection and clean up supplies 

This information is available on the Material Safety Data Sheet (MSDS) for the substance of concern.  The emergency coordinator has other references as available.  If any doubt surrounds this decision, call JFR for assistance.  This call should include the following information: 

• The location, identity and quantity of the material lost. 
• The nature and extent of any injuries, exposures or fire  
• The identity of the caller and a phone number to call back for more information 
• If an in-house clean up is agreed to, the following procedures shall be utilized: 
• Review the MSDS and other references as necessary to determine the    recommended procedures for personal protection, handling and disposal. 
•  Personal protective equipment needs may include skin protection in the form of    chemical resistant gloves, coveralls or apron and shoe covers.  Other items    include respiratory protection in the form of air purifying and air supplying    devices.  However, no person should attempt to utilize this equipment unless    previously trained, fit tested, and medically qualified. 
• Clean-up supplies may include absorbent materials in the form of oil dry, kitty litter vermiculite, spill pillows, socks, booms, etc.  Additional items include brooms, shovels or scoops, mops, buckets, and towels. 
• The sorbent should be spread around a liquid spill to contain it and then placed on  top of the spill to soak it up.  The sorbent should be worked toward the center of the spill, carefully collected with the tools described above and placed into sealed   containers such as spill drums, plastic liners, etc. 
• Spills of dry materials such as powders should be cleaned up with a damp mop,   pillow, or similar material to control dusting. 
• All contaminated items such as gloves, towels, brooms, etc. should be disposed of  as hazardous waste unless decontaminated first.   
• Decontamination occurs by physical removal or chemical interaction.  However, in most cases detergent and warm water are the best materials.  Personnel involved in the clean-up should immediately wash or shower to remove potential contamination. 

In the event of a fire: 

• No attempt should be made to fight the fire unless it is sufficiently small to allow a quick dousing or unless previous training has been provided in fire extinguisher use.   
• If the fire is beyond control, evacuate the area immediately. If possible, ensure that the door is closed and the fume hood is on, if available. Activate the fire  alarms in the hallway, notify your supervisor and meet at the predetermined safe assembly area for your building. If you are unsure of where this area is, check  with your department head or building supervisor.   
• In the event of a release detected from an above ground storage tank by visual observation, odor detection or manual gauging: 
• The emergency procedures outlined above will be followed including emergency contact and basic spill response.  If an odor, visible sheen or free product is observed, an incident investigation will be conducted to determine the source of the release and the potential to stop the release.   
• An Incident Notification Form  will be submitted to the City of Jacksonville, Regulatory & Environmental Services Department, within 24 hours of an incident as described in FAC 62-761.450(2)(a) 1-7.  The Incident Notification Form (DEP Form # 62-761.900(6)) is available online at:  http://www.dep.state.fl.us/waste/categories/tanks/pages/rules.htm under Rule Forms # 6. Release detection inspections will be conducted monthly and a log will be kept by the Department of Physical Facilities to document the results of the inspections.   
• Reportable releases, under the requirements of the Emergency Planning and Community Right to Know Act (EPCRA), are made to the State Emergency Response Commission (SERC) at 850413-9911 or 800-320-0519 and the National Response Center (NRC) at 1-800-424-8802. Annual Tier II reports are provided to the SERC, the Local Emergency Planning Committee (LEPC) and JFR.  For more specific information on this and other emergencies, please consult the University's Emergency Management Plan.