DSHW-2023-002257 - 0901a068811a6cce

Deq submit <[e-mail]>
Inspection Report - 7382399
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Darren Bauer <[e-mail]>Tue, Mar 7, 2023 at 11:07 AM
To: "[e-mail]" <[e-mail]>, "[e-mail]"
<[e-mail]>
Cc: Judith Moran <[e-mail]>, Deborah Ng <[e-mail]>, "[e-mail]"
<[e-mail]>, "[e-mail]" <[e-mail]>, "[e-mail]"
<[e-mail]>, Steve Rynders <[e-mail]>, "[e-mail]"
<[e-mail]>
Captain Schreiner,
As we’ve discussed in prior emails, several of items noted in the February 7, 2023 Inspection Report relate to the work
area in the northwest portion of Thatcher’s facility (which we refer to as the Northwest Storage Area or NWSA), which is
being used to carry out a work plan approved by DWMRC to address an accumulation of materials at the facility and
associated potential non-compliance with hazardous waste regulatory requirements that were identified in a 2019 audit of
the facility conducted by Thatcher’s contractor Stantec.
In December 2021, Thatcher and DWMRC entered into a Stipulation and Consent Order, SCO 2102006, pursuant to
which Thatcher is comprehensively addressing those matters identified in the 2019 audit. Pursuant to the SCO, Thatcher
prepared a detailed work plan (the “Phase 3 Material Management Plan” or “P3MMP”) to continue the characterization,
management, and disposition of the accumulation of materials identified in the 2019 audit, which was approved by
DWMRC in August 2022.
Attached are copies of the SCO and the P3MMP. While certain attributes of the NWSA do not meet the specific
requirements of the IFC noted in the Inspection Report, it is the only suitable place at the facility to undertake the work
necessary to address the requirements of the SCO. IFC 5001.3 permits the fire code official to approve a “performance-
based design alternative” plan in lieu of the specific requirements of IFC Chapters 50 through 67.
We believe that the P3MMP achieves the intent and requirements of IFC 5001.3 and have prepared the attached table
describing the portions of the P3MMP which address the 18 criteria to be considered in approving a performance based
alternative. Once you’ve had a chance to review this information, we’d like to meet with your team and DWMRC staff to
discuss the situation and chart a path forward that addresses the Fire Department’s concerns and allows the
implementation of the P3MMP to continue.
Please let us know your availability for a meeting.
Darren Bauer
Safety-Health-Environmental
State of Utah Mail - Inspection Report - 7382399
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DSHW-2023-002257
Thatcher Group, Inc.
801-924-3454
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3 attachments
Table__Thatcher IFC 5001.3 Compliance via Phase 3-v7.docx
66K
2022-08-15_Final Phase 3 Work Plan w Appendices-v1.pdf
9975K
Stipulation and Consent Order 12-10-2021__DSHW-2021-023302-v1.pdf
858K
State of Utah Mail - Inspection Report - 7382399
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A
Phase 3 Material Management Plan
Thatcher Company Inc.
1905 West Fortune Road, Salt Lake
City, Utah

August 15, 2022

Prepared for:

Thatcher Company, Inc.
1905 West Fortune Road,
Salt Lake City, Utah

Prepared by:

Stantec Consulting Services Inc.
2890 East Cottonwood Parkway
Suite 300
Salt Lake City, Utah

Phase 3 Material Management Plan

August 2022

4859-0509-4175\1
This document entitled Phase 3 Material Management Plan was prepared by Stantec Consulting Services
Inc. (“Stantec”) for the account of Thatcher Company, Inc. (Thatcher) and Thatcher Company, Inc. (the
“Client”). Any reliance on this document by any third party is strictly prohibited . The material in it reflects
Stantec’s professional judgment in light of the scope, schedule and other limitations stated in the document
and in the contract between Stantec and the Client. The opinions in the document are based on conditions
and information existing at the time the document was published and do not take into account any
subsequent changes. In preparing the document, Stantec did not verify information supplied to it by others.
Any use which a third party makes of this document is the responsibility of such third party . Such third
party agrees that Stantec shall not be responsible for costs or damages of any kind, if any, suffered by it
or any other third party as a result of decisions made or actions taken based on this document.

Prepared by
(signature)
Rich Pratt

Reviewed by
(signature)
Tom Fendler

Approved by
(signature)
Craig Thatcher
Chief Executive Officer
Thatcher Company, Inc.

Approved by
(signature)
Steven Rynders, PhD
VP R&D/Technical Services
Thatcher Company, Inc.

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Table of Contents
1.0 EXECUTIVE SUMMARY ................................................................................................ 1
2.0 INTRODUCTION ............................................................................................................ 3
2.1 BACKGROUND .............................................................................................................. 3
2.2 FACILITY DESCRIPTION .............................................................................................. 4
2.3 EMERGENCY RESPONSE ............................................................................................ 5
2.3.1 Incident (i.e., Leaking Containers) Management Programs ............................ 5
3.0 PROJECT DESCRIPTION ............................................................................................. 6
3.1 PHASE 3 MATERIALS MANAGEMENT PURPOSE ....................................................... 6
3.2 PHASE 3 MATERIAL MANAGEMENT OBJECTIVES .................................................... 6
4.0 REGULATORY REQUIREMENTS ................................................................................. 7
4.1 LARGE QUANTITY GENERATOR MATERIAL MANAGEMENT STANDARDS ............. 7
4.2 MATERIAL ANALYSIS AND DESIGNATION STANDARDS ........................................... 8
4.3 LEGITIMATE RECYCLING EVALUATIONS ................................................................... 9
5.0 RESPONSIBILITIES ...................................................................................................... 9
5.1 THATCHER .................................................................................................................... 9
5.2 FIELD SERVICES CONTRACTOR ...............................................................................10
5.3 ENVIRONMENTAL CONSULTANT ...............................................................................10
5.3.1 Electronic Files for DWMRC on SharePoint Site .......................................... 11
6.0 HEALTH AND SAFETY ................................................................................................11
6.1 CLEAN HARBORS MATERIAL MANAGEMENT HEALTH AND SAFETY .....................11
7.0 WASTE CHARACTERIZATION PROGRAM ................................................................12
7.1 APPLICATION OF GENERATOR KNOWLEDGE..........................................................12
7.1.1 Generator Knowledge Used for Characterization of Known Materials .......... 12
7.2 APPLICATION OF FIELD SCREENING AND ANALYSIS FOR MATERIAL
CHARACTERIZATION ..................................................................................................13
8.0 PHASE 3 MATERIAL INVENTORY AND MANAGEMENT ...........................................14
8.1 PHASE 3 BASELINE PRELIMINARY INVENTORY ......................................................15
8.2 INSPECTIONS ..............................................................................................................15
8.3 MANAGEMENT OF “CONTAINERS NOT IN GOOD CONDITION” ...............................15
8.4 PHASE 3 CONTAINER AREA REVIEW AND MANAGEMENT
DETERMINATIONS ......................................................................................................16
8.4.1 Area Disposition Review Forms and Spreadsheet ........................................ 17
8.5 DISPOSITION AND/OR DISPOSAL MATERIAL MANAGEMENT .................................17
8.5.1 Known Phase 3 Hazardous Secondary Materials Identified for
Disposition ................................................................................................... 18
8.5.1.1 Known Material Identified for Disposition (Use or Reuse (Recycling)) .......... 18
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8.5.2 Material Identified for Disposal ..................................................................... 19
8.5.2.1 Known Material Identified for Disposal ......................................................... 19
8.5.2.2 Unknown Material Identified for Disposal ..................................................... 19
8.5.3 Material Management Disposition Forms and Spreadsheets ........................ 20
8.5.3.1 Disposal Forms and Tracking Spreadsheets ................................................ 20
8.5.3.2 Disposition Tracking Spreadsheet ................................................................ 20
8.6 CONTAINER MANAGEMENT .......................................................................................20
8.6.1 Management of Containers Posing Imminent Threat .................................... 20
8.6.2 Management of Containers Spilled During Transport ................................... 20
8.6.3 Container Labeling ....................................................................................... 20
8.6.4 Container Repackaging ................................................................................ 21
8.6.5 Container handling ....................................................................................... 21
8.6.6 Empty Container Management ..................................................................... 21
8.7 WASTE STORAGE PROCEDURES .............................................................................22
8.8 WASTE DISPOSAL .......................................................................................................22
8.9 DECONTAMINATION PROCESS .................................................................................22
9.0 REPORTING .................................................................................................................23
9.1 MONTHLY REPORTING ...............................................................................................23
10.0 COMPLIANCE SCHEDULE ..........................................................................................23
10.1 COMPLIANCE SCHEDULE ..........................................................................................23
11.0 REFERENCES ..............................................................................................................25

LIST OF TABLES
Table 1 Buildings and Activities .................................................................................................. 4
Table 2 Field Screening, Sampling and Analyses Steps ...........................................................14

LIST OF FIGURES
Figure 1 Site Location Map
Figure 2 Site Map
Figure 3 Phase 3 Areas
Figure 4 Material Management Process Flow Diagram

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Appendices

Appendix A Thatcher Emergency Response Program (Hazardous Materials Emergency
Action Plan EHS-13) and Standard Operating Procedure (SOP) Environmental
Health and Safety (EHS-29)
Appendix B Solid and Hazardous Waste Management Plan
Appendix C Waste Analysis Plan
Appendix D P3MMP Distribution List
Appendix E Clean Harbors Health and Safety Plan
Appendix F 90-Day Hazardous Waste Storage and Phase 3 Areas Inspection Forms
Appendix G Area Disposition Review Form and Spreadsheet
Appendix H Field Screening Form
Appendix I Repackaging Form
Appendix J Container Tracking and Disposal Spreadsheets
Appendix K Disposition Tracking Spreadsheets
Appendix L Monthly Report

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Abbreviations

CCP Commercial Chemical Products
CFR Code of Federal Regulation
DOT Department of Transportation
DWMRC Division of Waste Management and Radiation Control
EHS Environmental Health and Safety
EPA Environmental Protection Agency
IDW Investigation-Derived Waste
LQG Large Quantity Generator
NWSA Northwest Storage Area
P3MMP Phase 3 Material Management Plan
PCBs Poly-chlorinated biphenyls
PPM Parts Per Million
POTW Publicly Owned Treatment Works
RCRA Resource Conservation and Recovery Act
SCO Stipulation and Consent Order
SDS Safety Data Sheet
SHWMP Solid and Hazardous Waste Management Plan
SOP Standard Operating Procedure
Stantec Stantec Consulting Services, Inc.
TCLP Toxicity Characteristic Leaching Procedure
Thatcher Thatcher Company, Inc.
UDEQ Utah Department of Environmental Quality
USHWA Utah Solid and Hazardous Waste Act
VOA Volatile Organic Analysis
WAP Waste Analysis Plan
WICP Waste Inventory and Characterization Plan

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Definitions

Commercial Chemical Products (CCP): means both listed commercial chemical products as defined in
40 C.F.R. § 261.33 / R315-261-33 and non-listed commercial chemical products which EPA defines as
including all types of unused commercial products, including off -specification species of the same, that
exhibit a characteristic of hazardous waste. See 50 Fed. Reg. 14219 (April 11, 1985).
Container not in Good Condition: includes leaking containers or containers with a structural integrity
issue that may cause the loss of containment due to corrosion, dents, etc.
Container Repackage: Container repackaging includes overpacking and/or transfer of materials to a
container in good condition.

Discarded Material: means and includes any material that is (i) abandoned by disposal, accumulated or
stored, but not recycled, before or in lieu of being abandoned by disposal, or sham recycled; (ii)
accumulated or stored before recycling in manner constituting disposal or, unless it is a commercial
chemical product, accumulated speculatively; or (iii) inherently waste-like.1
Discarded Spilled Material or Waste: means spilled or released Material or Waste not immediately
recovered. Hazardous Secondary Materials released to the environment and not immediately recovered
are Discarded Spilled Materials.2
Container Tracking and Disposal Spreadsheet: is the spreadsheet which will be used to (i) track area
containers, (ii) record the characterization and disposal of containers that are determined to be waste. The
container tracking and disposal spreadsheet will be used to record field screening data and laboratory
analytical results which are the basis for characterizing and profiling waste material for disposal.

Disposition: means the act of making Phase 3 determinations for either (i) use or reuse (recycling)
“disposition”, or (ii) disposal.
Hazardous Secondary Material: means a secondary material (e.g., spent material, by-product, or sludge)
that, when discarded, would be identified as a hazardous waste pursuant to Utah Admin. Code R315 -261.
Hazardous Waste: means when tested or classified based on generator’s knowledge, a solid waste that
(i) is not excluded under Utah Admin. Code R315- 261-4; and (ii) is listed as a hazardous waste under Utah
Admin. Code R315- 261-30 through 33, and/or exhibits any of the characteristics of a hazardous waste
under Utah Admin. Code R315- 261-20 through 24.
“Immediately” Related To Spill Response: means response measures are implemented without delay.

1 Utah Admin. Code R315-261-2(a)(2)(i).
2 Utah Admin. Code R315-260-43(a)(3).
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Newly Generated waste and Date: means any newly generated waste (e.g., investigation derived waste,
spill cleanup, environmental media (from spill cleanup), and/or personal protection equipment). The
container is dated with the date the material is accumulated (i.e., first generated).
Non-Hazardous Material/Waste: means those materials which are not a listed hazardous waste and do
not exhibit a characteristic of hazardous waste, either within containers not being discarded (non-hazardous
material) or being discarded (non-hazardous waste).
Non-Hazardous Secondary Material: means a secondary material that, when discarded, would not be
identified as a hazardous waste pursuant to Utah Admin. Code R315-261.
Material: means those substances discretely contained on-site, including active inventory, Hazardous
Secondary Material, recyclable material, and wastes (hazardous, or non-hazardous solid waste).
Phase 3 Accumulation Date: means the unique date that Thatcher first identifies each Phase 3 container
(e.g., container area review date P3MMP Section 8.4).
Phase 3 containers: means containers at the facility as of the date of the “Self-Disclosure Letter,”
November 26, 2019, that contain material that is not raw material, process intermediates,3 or products (not
including Thatcher’s active inventory CCP’s) and are being stored on-site for use or reuse (recycling) and,
as described in the Self-Disclosure Letter, for which Thatcher may not have historically maintained sufficient
information to document compliance with Resource Conservation and Recovery Act (RCRA) for the subset
of these materials that would be hazardous waste if “discarded” (i.e., disposed). Phase 3 containers may
include recyclable materials, non-hazardous material/solid waste, hazardous waste, universal waste,
and/or used oil.

Universal Waste: means hazardous waste (batteries, pesticides, mercury-containing equipment, lamps,
aerosol cans, and antifreeze) managed under Utah Admin. Code R315-273 standards for universal waste
management.

3 Materials generated from one process for another process.
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1.0 EXECUTIVE SUMMARY
Stantec Consulting Services Inc. (Stantec) conducted an environmental compliance audit in October 2019
at the Thatcher Company, Inc. (Thatcher) facility located at 1905 West Fortune Road, Salt Lake City, Utah
(the Facility or Site, see Figures 1 and 2). The audit was conducted to evaluate the Facility’s compliance
with state and federal solid and hazardous waste management requirements. Based upon the audit
findings, Thatcher, through its legal counsel Dorsey & Whitney LLP, submitted a self -disclosure letter dated
November 26, 2019 (the Disclosure Letter) to DWMRC, which identified instances of potential non-
compliance regarding the manner in which materials are stored on-site. Thatcher then met with the
regulatory agency to discuss the issues.

A Waste Inventory and Characterization Plan dated March 11, 2020 (WICP) was submitted to the DWMRC
which proposed to characterize and dispose of waste identified at the Facility in four phases:

• Phase 1 – laboratory chemicals;
• Phase 2 – an estimated 1,106 containers in the northwest storage area (NWSA) and an
estimated 200 containers directly east of the NWSA fence line;
• Phase 3 – an estimated 650 containers in various on-site storage areas; and
• Phase 4 – material management for continuous operation.

Thatcher completed Phase 1 of the project on April 10, 2020 and characterized/disposed of a total of 99
containers. Thatcher completed Phase 2 of the WICP on May 28, 2021 and characterized/disposed of
1,499 containers in and around the NWSA. Prior to pausing implementation of Phase 3 due to concerns
raised by the DWMRC, Thatcher characterized/disposed of 55 containers. Thatcher will resume
implementation of Phase 3 once it receives DWMRC approval of this Phase 3 Material Management Plan
(P3MMP).

A draft Stipulation and Consent Order (SCO) was agreed to between Thatcher and the DWMRC and was
provided for public comment. The approved SCO (number 2102006) is dated December 9, 2021. By letter
dated January 7, 2022, DWMRC granted Thatcher an extension to January 21, 2022 to submit the plan
and schedule required by paragraph 18.5 of the SCO. This P3MMP documents the plan and schedule
required by paragraph 18.5 of the SCO.

The primary objectives of P3MMP tasks to be completed at the Facility include:
• Demonstrate Phase 3 container material management compliance pursuant to the Utah Solid and
Hazardous Waste Act (the Act), Utah Code § 19-6-101, et seq., and the Utah Used Oil
Management Act (the Used Oil Act), Utah Code § 19-6-701.
• Maintain Phase 3 material management records for material handling (i.e., tracking material
movement and management practices), disposal, or continued storage for use or reuse
(recycling) with tracking to demonstrate compliance with RCRA legitimate recycling requirements.
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• Review the facility and evaluate the disposition of all Phase 3 containers.
• Ensure that all containers are in good condition with no leaks or defects (such as dents or
corrosion) that may compromise the integrity of the container and confirm that the construction of
all containers are compatible with the contents. Materials in Containers not in Good Condition
and/or materials in containers not compatible with the contents will be repackaged.
• Respond to leaks or spills immediately.
• Label all unlabeled Phase 3 containers.
• Make hazardous waste determinations pursuant to R315-262-11.
• Ship Phase 3 hazardous material designated for disposal within 90 days of the Phase 3
Accumulation Date or request, in writing, an extension of the 90-day time limit demonstrating that
the extension is necessary due to unforeseen, temporary, and uncontrollable circumstances .
• Complete the project within a “reasonably aggressive” project schedule estimated timeline (see
Section 10, Compliance Schedule).
• Use best management practices in the management of non-hazardous solid waste, hazardous
waste, universal waste, and/or used oil.
• Provide monthly status update reports to the DWMRC of progress completing Phase 3 activities.

Phase 3 materials in containers will be characterized following procedures set forth in Section 7, which
builds on the experiences gained during implementation of Phases 1 and 2 of the project. Management
options may include, as appropriate and in compliance with regulatory requ irements and paragraph 18.3
of the SCO, use/reuse (recycling) in the production process, and/or disposal. Thatcher has contracted
with Stantec to coordinate material analysis and characterization with Clean Harbors. The proposed
characterization methods include field screening, on -site laboratory analyses (Thatcher), and off-site
laboratory analysis, as detailed in the attached Waste Analysis Plan (WAP). The characterization program
is based on field screening data and pH for the categories as described in the WAP and Container Tracking
and Disposal Spreadsheets . When possible, generator knowledge will also be applied to characterize
known materials.

The characterization program is as follows.
• Field screening to categorize materials (oils, water, solvents, other) for sampling.
• Off-site lab pH confirmation.
• Laboratory analysis as detailed in the attached WAP.
• Category analyses as described in Table 2.

Thatcher will continue to inspect the 90-day hazardous waste storage and Phase 3 areas on a weekly
basis. Beginning on October 22, 2021, Thatcher observed all Phase 3 containers weekly to identify
Containers not in Good Condition. Weekly area inspections have been documented by area managers
and since initiating this inspection program four containers requiring repackaging have been identified and
managed. Weekly area monitoring and inspections will continue through Phase 3. Containers found to
be “Containers not in Good Condition” will be repackaged for storage on-site. Any container that is not in
good condition which contains material that exhibits a characteristic of, or is a listed hazardous waste, and
containers for which insufficient information is available to make a hazardous waste determination, shall
not be recycled or reworked and must be managed for disposal.
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Thatcher has designated 14 Phase 3 container management areas as shown on Figure 3. Thatcher
completed a Baseline Preliminary Inventory; as directed by the DWMRC, to provide assurance that the total
number of Phase 3 containers does not change as the project progresses. Material management decisions
can proceed concurrent with the area disposition review and inventory. Management decisions will include
use/reuse (recycling) in the production process, and/or disposal. A Facility -wide disposition area review will
be completed to gather information needed to facilitate efficient management decisions. Each Phase 3
container will be assigned a tracking number.

Once Phase 3 area disposition review is initiated, container management will be limited to the number of
containers requiring disposal that will fit into the NWSA secondary containment. Thatcher will manage
containers identified for disposition that will be left in the area or moved to another area for storage for use
and tracked on the disposition spreadsheets. Once assigned a date, Thatcher intends to manage containers
designated for disposal as non-hazardous, universal waste, and/or hazardous waste containers within the
90-day LQG storage time limit.

Thatcher will prepare and submit P3MMP reports to the DWMRC on or before the 15th day of each month
until P3MMMP is completed. The Phase 3 material management process will continue within 30 days of
receipt of DWMRC approval of this P3MMP.

2.0 INTRODUCTION
Stantec Consulting Services Inc. (Stantec) conducted an environmental compliance audit in October 2019
at the Thatcher Company, Inc. (Thatcher) facility located at 1905 West Fortune Road, Salt Lake City, Utah
(the Facility or Site, see Figures 1 and 2). The audit was conducted to evaluate the Site’s compliance with
state and federal solid and hazardous waste management requirements. Based upon the audit findings,
Thatcher, through its legal counsel Dorsey & Whitney LLP, submitted a self-disclosure letter dated
November 26, 2019 (the Disclosure Letter) to DWMRC, identifying instances of potential non -compliance
in the manner in which materials are stored on-site. Thatcher then met with the regulatory agency to
discuss the issues.
2.1 BACKGROUND
A Waste Inventory and Characterization Plan dated March 11, 2020 (WICP) was submitted to the DWMRC
which proposed to characterize and dispose of waste identified at the Facility in four phases:

• Phase 1 – laboratory chemicals;
• Phase 2 – an estimated 1,106 containers in the northwest storage area (NWSA) and an
estimated 200 containers directly east of the NWSA fence line;
• Phase 3 – 2,711 containers in various on-site storage areas (see Section 8.1); and
• Phase 4 – material management for continuous operation.
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Thatcher completed Phase 1 of the project on April 10, 2020 and characterized/disposed of a total of 99
containers. Thatcher completed Phase 2 of the WICP on May 28, 2021 and characterized/disposed of
1,499 containers in and around the NWSA. Prior to pausing implementation of Phase 3 due to concerns
raised by the DWMRC, Thatcher characterized/disposed of 70 containers. Thatcher will resume
implementation of Phase 3 once it receives DWMRC approval of this Phase 3 Material M anagement Plan
(P3MMP).

2.2 FACILITY DESCRIPTION
The Site is comprised of several parcels totaling approximately 30 acres. The Site is located within an
industrial area of Salt Lake City and is zoned M-1 for Light Manufacturing use. The Site is bordered by
Interstate-215 to the west, a large canal to the north, and California Avenue to the southeast. Fortune Road
transects the southern portion of the Site. Railroad tracks cross the southern and western portions of the
Site with railroad spurs entering the Site from the southeast and northwest corners of the property. The
Site is used for blending and repackaging of chemicals and consists of several buildings, material storage
areas, truck trailers used for storage, a large warehouse, office buildings, an above ground storage tank
farm, and wastewater treatment infrastructure. Thatcher uses over 30 chemicals (mostly inorganic basic
chemicals) to manufacture approximately 4,500 products for industries including agriculture, food and
dairy, water treatment, waste-water treatment, laundry, pharmaceutical, construction, mining, precious
metals, oil and gas, and power generation. The Site location is shown on Figure 1 and the Facility Map is
included as Figure 2. Buildings and activities are listed in Table 1 below.

Table 1 Buildings and Activities
Building Activity
1 Main Warehouse (Process Support)
2a Aluminum Sulfate Production
2b Ferric and Ferrous Sulfate Production
2c Anhydrous Chlorine Repackaging
3a Various Production Chemicals
3b Warehouse Storage (Process Support)
3c Sodium Thiocyanate Production
3 Outside Various combinations of hydrochloric acid products
4 Sodium Carbonate (Soda Ash) mixtures (i.e., compounding) Production
5 Container Wash Area
Water Treatment Containments
6 Food and Dairy - Oxidizer Repackaging and Various Production Chemicals
6A 6A - Warehouse
7 Pharmaceutical and Iodine Compounds Production
8 Batch processing from B12 Feed
Sulfite to thiosulfate
9 Production Tanks for Repackaging Alcohols, Glycols, and Various Chemicals
9A Warehouse (Process Support)
10 Ammonia for Ammonium Hydroxide
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Building Activity
Organic Process: Paraformaldehyde (PFA) is reacted w/ MEA to produce
monoethanolamine triazine (MEA-T)
11 Calcium Nitrates/Nitrites, Magnesium Nitrate, Sodium Nitrate
12 Sulfite Chemistry Area, Aluminum Chlorohydrate, Ammonium Bisulfite, Potassium
Sulfite
13 No Assigned Building/Activity
14 Truck Shop (Process Support)
15 Equipment Storage
16 Maintenance Shop (Process Support)
17 Laboratory (Process Support)
18 No Assigned Building/Activity
19 Tank Farm Area

Chemical products from vendors (raw materials) are stored on-site in railcars, tankers, tanks, and/or smaller
containers (i.e., totes or drums) for producing Thatcher products (i.e., product component chemicals).
Products are produced in designated process locations on-site. Excess product, off-specification (non-
conforming chemicals), and/or return material authorized chemicals are used for rework as product
component chemicals.

Site secondary containment consists of containment for storage tanks (tank farm secondary containments),
site containment for storage containers and process operations, and area sumps. The Site is self-contained
and is sloped toward the center of the Site. Self-containment includes asphalt and/or concrete surfaces
where materials and stormwater flow into area storm drains/sumps. The flow from the storm drains/sumps
is to the water treatment process in the Building-5 area where any pH adjustment, per the existing publicly
owned treatment works (POTW) permit, is completed prior to discharge to POTW.

Chemical production operations include raw materials storage with secondary containment, mixing and
holding tanks, reaction vessels, piping and transfer equipment, scrubbers, boilers, cooling towers, chillers,
dewatering filter presses, various water use treatment, and dust cartridge or bag collectors.
2.3 EMERGENCY RESPONSE
Thatcher maintains emergency plans in accordance with regulatory requirements and for the purpose of
contingency planning for the response in the event of an emergency.
2.3.1 Incident (i.e., Leaking Containers) Management Programs
Thatcher conducts weekly area monitoring and inspections. Observations from inspections are recorded
on inspection forms and historical inspection forms are archived at the Facility. Containers observed not
to be in good condition are addressed as necessary. Thatcher employees respond to incidents according
to the plan (see below) applicable to the materials released (i.e., haz ardous waste and/or hazardous
material), the materials Safety Data Sheet (SDS) and the training required to handle the material. The
Facility maintains the following emergency response program plans:
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• Emergency Response Program (hazardous materials Emergency Action Plan EHS-13) Appendix
A.
• Preparedness and Prevention Plan for management of 90-day and satellite accumulation
hazardous waste storage areas.
• Contingency Plan (hazardous waste).

These plans detail the emergency response and reporting necessary to meet regulatory requirements.
Thatcher’s record keeping and reporting guidelines include the following:
• Hazardous Materials – Thatcher Standard Operating Procedure (SOP) Environmental Health and
Safety (EHS-29) Appendix A.
• Hazardous Waste – Contingency Plan. Solid and Hazardous Waste Management Plan (SHWMP,
Appendix B) Sections 9.0 Contingency Plan and Emergency Procedures and 9.8 Emergency
Reporting Procedures.

Thatcher will direct all reasonable measures necessary to ensure that fires, explosions, and releases of
hazardous waste do not occur, recur, or spread. These measures may include:
• Stopping, controlling, or containing the source of the release;
• Containing the released materials to minimize spreading;
• Eliminating or controlling health and safety hazards;
• Collecting and containerizing released material;
• Reporting hazardous waste releases as required by R315-263-30; and
• Cleaning up and/or treating residual contamination in-place.
3.0 PROJECT DESCRIPTION
Following DWMRC approval of this P3MMP, Thatcher will continue with Phase 3 activities. This plan
details the methods and procedures to be followed to address Facility wide containers found outside of
the lab (Phase 1) and beyond the NWSA (Phase 2).
3.1 PHASE 3 MATERIALS MANAGEMENT PURPOSE
The purpose of Phase 3 of this project is to perform a facility-wide review, evaluate the status of all Phase
3 containers, identify available information regarding such containers , and make an appropriate
management decision for each container (i.e., disposal or continued storage for use or reuse (recycling)
with tracking to demonstrate compliance with Resource Conservation and Recovery Act (RCRA) legitimate
recycling requirements in compliance with Paragraph 18.3 of the SCO).
3.2 PHASE 3 MATERIAL MANAGEMENT OBJECTIVES
The primary objectives of P3MMP tasks to be completed at the Facility include:
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• Demonstrate Phase 3 container material management compliance pursuant to Utah Code § 19-
6-101, et seq., and the Used Oil Act, Utah Code § 19-6-701.
• Maintain Phase 3 material management records for material handling (i.e., tracking material
movement and management practices), disposal, or continued storage for use or reuse
(recycling) with tracking to demonstrate compliance with RCRA legitimate recycling requirements
and the provisions of the SCO.
• Review of the Facility to evaluate the disposition of all Phase 3 containers.
• Ensure that all containers are in good condition with no leaks or defects (such as dents or
corrosion) that may compromise the integrity of the container and to confirm that the construction
of all containers are compatible with the contents. Materials in Containers not in Good Condition
and/or materials in containers not compatible with the contents will be repackaged.
• Confirm that all materials containers have not exceeded their Department of Transportation
expiration dates.
• Respond to leaks or spills immediately.
• Label all unlabeled Phase 3 containers.
• Make hazardous waste determinations pursuant to R315-262-11.
• Ship Phase 3 hazardous material designated for disposal within 90 days of the Phase 3
Accumulation Date or request, in writing, an extension of the 90-day time limit demonstrating that
the extension is necessary due to unforeseen, temporary, and uncontrollable circumstances .
• Complete the project within a “reasonably aggressive” project schedule estimated timeline.
• Use best management practices in the management of non-hazardous solid waste and Utah
Administrative Code for hazardous waste, universal waste, and/or used oil.
• Provide monthly status update reports to the DWMRC of progress completing Phase 3 activities.

In addition to these objectives, a Waste Analysis Plan (WAP) is included in Appendix C, which details the
process for collecting material samples from containers requiring characterization, recording field data,
and performing laboratory analysis of material samples.
4.0 REGULATORY REQUIREMENTS
UDEQ’s DWMRC regulates hazardous waste management. Thatcher’s P3MMP shall be executed in
accordance with the SCO and Utah Admin. Code R315-261 through 268 and 273.
4.1 LARGE QUANTITY GENERATOR MATERIAL MANAGEMENT
STANDARDS
Thatcher’s SHWMP (Appendix B) provides for the Large Quantity Generator (LQG) material management
standards and includes the following:
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1. Introduction;
2. Description of generator status;
3. Waste analysis and designation with sampling and testing recommendations;
4. Waste container management;
5. Preparedness and Prevention Plan;
6. Satellite and universal waste accumulation areas;
7. Pre-transport and recordkeeping requirements;
8. Hazardous Waste Contingency Plan (required for an LQG);
9. Waste minimization guidelines; and
10. Personnel training.
4.2 MATERIAL ANALYSIS AND DESIGNATION STANDARDS
Containers in Phase 3 storage areas will be characterized in accordance with RCRA, statutory standards
and the regulations promulgated thereunder. Any business that generates a solid waste is required in
accordance with Utah Admin. Code R315-262-11 to make a hazardous waste determination for that
material. The generator is required to use the following steps to determine if the waste:

• Is excluded from regulation under Utah Admin. Code R315-261-4;
• Is listed as a hazardous waste under Utah Admin. Code R315-261-30 through 33;
• When tested, exhibits any of the characteristics of a hazardous waste under Utah
Admin. Code R315-261-20 through 24; and
• Can be is classified under Utah Admin. Code R315-262-11 based on generator’s
knowledge of the hazard characteristic of the waste.

Testing of process waste streams are generally referred to as “characteristic tests”. These analyses include
ignitability (flash point 140 degrees Fahrenheit [˚F] or below), corrosivity (pH less than or equal to 2.0 or
greater than or equal to 12.5), reactivity (unstable, water reactive, potentially explosive, can generate toxic
gases, etc.), and toxicity as determined by Toxicity Characteristic Leaching Procedure (TCLP).

If the waste is not excluded from regulation and is determined to be a hazardous waste, the generator must
refer to Utah Admin. Code R315-261, 264, 265, 266, 268, and 273 for possible exclusions or restrictions
pertaining to management of the specific waste. The Land Disposal Restrictions found in part 268 apply
to all wastes intended for landfill disposal and incineration (ash residues from incineration are land
disposed).

Based on the characterization, an appropriate management method (use, recycling, and/or disposal) will
be identified which complies with applicable legal requirements and is protective of human health and the
environment.

Thatcher’s SHWMP (Appendix B) includes a waste analysis and designation plan for Thatcher’s chemical
manufacturing processes. The waste analysis and designation standards are the same for P3MMP.
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4.3 LEGITIMATE RECYCLING EVALUATIONS
Thatcher will evaluate the legitimacy of materials for use or reuse (recycling) pursuant to Utah Admin.
Code R315-260-43. Disposition and disposal management methods are detailed in Section 8.5. The
following factors will be used in this legitimacy analysis.

1. The Hazardous Secondary Material must provide a useful contribution to the recycling process or
to a product or intermediate of the recycling process. The material provides a useful contribution if
it:
o Contributes a valuable ingredient to the product or intermediate;
o Replaces a catalyst or carrier in the recycling process;
o Is the source of a valuable constituent recovered in the recycling process;
o Is recovered or regenerated by the recycling process; or
o Is used as an effective substitute for a commercial product.
2. The recycling process must produce a valuable product or intermediate. The product or
intermediate is valuable if it is:
o Sold to a third party; or
o Is used by the recycler or generator as an effective substitute for a commercial product or
as an ingredient or intermediate in an industrial process.
3. The generator and the recycler must manage the Hazardous Secondary Material as a valuable
commodity when it is in their control.
4. The product of the recycling process does not contain significant concentrations of hazardous
constituents not found in analogous products, or at a significantly higher concentration than found
in analogous products, and does not exhibit a characteristic of hazardous waste not exhibited by
analogous products. This factor is not mandatory; it is not determinative of the analysis, but
it must be considered in the analysis.
5.0 RESPONSIBILITIES
The following subsections detail the responsibilities of the applicab le parties associated with
implementation of this P3MMP. A P3MMP distribution list is included in Appendix D. These responsibilities
are also included on Figure 4 Material Management Process Flow Diagram. Thatcher will inform Clean
Harbors that the requirements of this plan take precedence over Clean Harbors ’ standard operating
procedures (e.g., container labeling).
5.1 THATCHER
Thatcher will continue to act as the main point of contact and the lead on the project and will direct the
contractors during the Phase 3 activities. Thatcher’s P3MMP responsibilities include:
• Coordination with UDEQ DWMRC.
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• Section 6.0 Health and Safety.
• Providing facility staff, contractors, and equipment as necessary.
• Implementation and oversight.
• Section 7.0 Waste Characterization Program.
• Section 8.0 Material Inventory and Management.
• Section 9.0 Reporting.
• Section 10.0 Compliance Schedule.
• Signatures for profiles, manifests/bill of lading, etc.
5.2 FIELD SERVICES CONTRACTOR
A Field Services Contractor, Clean Harbors, was retained for field execution of Phase 1 and Phase 2 of
the WICP. During Phase 3 of the project, Clean Harbors will complete or provide assistance for the
following as directed by Thatcher:
• Section 6.0 Health and Safety.
• Adherence and execution.
• Training project management and operations personnel (i.e., safety, foreman, etc.). Training may
include the following:
o 40-Hour Hazardous Waste Operations and Emergency Response (HAZWOPER)
Training.
o Annual 8-Hour HAZWOPER Refresher [29 Code of Federal Regulations (C.F.R.)
1910.120(e)(8)].
o Department of Transportation (DOT).
• Additional training beyond the abovementioned required trainings may include, but not be limited
to:
o First Aid/Cardiopulmonary Resuscitation (CPR) Training (minimum of one on-site);
o HAZWOPER Supervisory 8-hour Training [29 C.F.R. 1910.120(e)(4)]; and
o Additional training specific to the job being performed (e.g., Fall Protection, Lock Out/Tag
Out, Hot Work, Confined Space, etc.).
• Assisting with Section 7.0, the Waste Characterization Program.
o Record keeping of sampling (i.e., related forms).
• Assisting with Section 8.0 Material Inventory and Management.
o Container handling and repackaging.
• Assisting with Section 9.0 Reporting.
• Profile approval and preparation of manifests/bill of lading, etc.
5.3 ENVIRONMENTAL CONSULTANT
An environmental consultant, Stantec, has been hired by Thatcher to prepare this P3MMP. Stantec will
periodically be on-site during implementation of this P3MMP to audit compliance with the plan and provide
technical support. Stantec will complete or provide assistance for the following as directed by Thatcher:
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• Section 6.0 Health and Safety.
• On-site area disposition review and inventory.
• Section 7.0 Waste Characterization Program recordkeeping and profiling.
• Section 8.0 Material Inventory and Management.
• Section 9.0 Reporting.
• Performance of P3MMP monthly inspections and record observations, as directed by Thatcher.
• Assisting with record management.
• As needed, provide technical support if advice is required to resolve field conditions which deviate
from those anticipated in this P3MMP.
5.3.1 Electronic Files for DWMRC on SharePoint Site
Stantec will provide DWMRC designated representative access to Thatcher’s DWMRC SharePoint data
sharing site and upload electronic files for DWMRC. P3MMP files on the SharePoint site include the
following:
• P3MMP Forms and spreadsheets.
• Hazardous waste manifest and Land Disposal Restriction (LDR) Forms.
• Hazardous waste profiles.
• Laboratory analytical reports
• Section 9.1 Monthly Reporting items.

DWMRC requested bill of lading for recyclable materials shipped elsewhere. Thatcher will not ship P3
materials offsite for recycling opting to dispose of recyclable materials which cannot be used at the
Facility.
6.0 HEALTH AND SAFETY
Clean Harbors’ field staff will perform P3MMP field tasks under a Site-specific health and safety plan
included in Appendix E which will include 1) task specific job hazard analysis; 2) hazard prevention and
control; 3) personal protective equipment; 4) hazard communication; and 5) safety data sheets. Thatcher
will perform tasks under Thatcher’s Health and Safety program. Stantec will perform tasks under Stantec’s
hazard recognition and control program. Site-specific health and safety will meet the requirements of
Occupational Health and Safety Administration (OSHA) regulations at 29 C.F.R. 1910.120. All field staff
will have the appropriate level of Hazardous Waste Operator Training for the P3MMP tasks they perform.
Thatcher will be responsible for health and safety oversight of all personnel at the Facility.
6.1 CLEAN HARBORS MATERIAL MANAGEMENT HEALTH AND SAFETY
Clean Harbors will provide sampling, container handling, and material management (off-site disposal)
support for the project. Clean Harbors will prepare job hazard analyses specific to each task which they
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will perform. The Health and Safety procedures are evergreen documents and will be updated daily during
tailgate meetings as necessary to reflect changed conditions.

Clean Harbors’ services may require the use of Level B (supplied air), C, and/or D personal protective
equipment as deemed necessary by a competent person.
7.0 WASTE CHARACTERIZATION PROGRAM
This section describes the processes which will be followed for Phase 3 characterization of known and
unknown materials in containers. Standard material analysis and designation as described in Section 4.2
Material Analysis and Designation will be used.
7.1 APPLICATION OF GENERATOR KNOWLEDGE
In 2019, Thatcher contracted with Stantec to provide regulatory support. A material inventory and
characterization team evaluated site operations and available information on material in storage to
evaluate the field monitoring, on-site, and off-site analyses necessary for material management under
health, safety, and/or statutory standards. This team consisted of Thatcher staff who are knowledgeable
of Facility processes and waste management practices, Stantec regulatory specialists, and Clean Harbors
field service specialists. Clean Harbors’ High Hazard Group was consulted as part of this process.

The types of chemicals used for production, produced product chemicals, and chemicals returned from
clients were evaluated. This evaluation included a preliminary review of the chemical production process
and laboratory operations. The following conclusions were made from the preliminary review:

• Hazardous waste was being generated at the laboratory.
• Materials from the chemical production process exhibiting only the characteristic of corrosivity
were neutralized and discharged under the discharge permit.
• No other hazardous wastes from the chemical production process were id entified.

Through generator knowledge it was determined that pesticides and herbicides (i.e., TCLP D-list pesticides
and herbicides) were not used, and poly-chlorinated biphenyls (PCBs) are not and historically have not
been used or stored on-site. On February 12, 2020, Mr. Craig Thatcher was contacted and confirmed that
pesticides and herbicides (i.e., TCLP D-list pesticides and herbicides) have not been on-site. Thatcher
staff members Mr. Dave Lindsey, environmental health and safety, and Tim Lawton, process engineer,
confirmed that PCBs were not on-site. Therefore, analyses for those analyte groups are not included in
the characterization program.

7.1.1 Generator Knowledge Used for Characterization of Known Materials
Generator knowledge used for characterization of known materials includes the following.
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• Container labels documented on P3MMP forms and/or spreadsheets.
• SDS
o If 100 percent of constituents are not identified, additional information will be obtained and
tracked in a SDS 100 percent composition spreadsheet included with Appendix G Area
Disposition Review Form and Spreadsheet.
• If an SDS is not available for the material, a Thatcher production record may be used for Thatcher
products.
7.2 APPLICATION OF FIELD SCREENING AND ANALYSIS FOR
MATERIAL CHARACTERIZATION
Materials in containers will be characterized under the standards described in Section 4.2 Material Analysis
and Designation. Management options may include use/reuse (recycling) in the production process, and/or
disposal.

Thatcher has contracted with Stantec to coordinate material analysis and designation (characterization)
with Clean Harbors based on Section 4.2 Material Analysis and Designation Standards. These standard
characterization methods include field screening and off-site laboratory analyses as detailed in the WAP
included in Appendix C.

The following is the characterization program developed by Thatcher’s project team. The characterization
program will include field screening and analyses (off-site labs). The characterization program is based on
field screening data and pH determinations for the categories as described in the WAP and Container
Tracking and Disposal Spreadsheets.

The characterization program is as follows:
• Field screening.
• Off-site lab pH confirmation.
• Category evaluation as described in Table 2.

Additional laboratory analysis will be performed as necessary, based upon field screening, to characterize
Phase 3 material.

The field screening, sampling, and analyses steps are detailed in Table 2.

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Table 2 Field Screening, Sampling and Analyses Steps
Step Descriptions Comments
Field Screening
Clean Harbors completes field screening, field
screening forms, enters the data on the Container
Tracking and Disposal Spreadsheet, and uploads
field forms to the SharePoint site.
Stantec completes a quality assurance review
of the forms and data entry.
Clean Harbors Sampling1 and Lab Analyses
Off-site: Samples are obtained for –
Analyses of:
1. pH,
2. TCLP RCRA 8 Metals and Underlying
Hazardous Constituent (UHC) Nickel,
3. Flash Point,
4. TCLP VOAs/Semi-VOAs and UHC methanol
(non-wastewater), and/or
5. UHC Total VOAs Methanol (wastewater) and
Xylene
6. Total sulfide or cyanide if detected from field
monitoring Yes (Y) or No (N)

If field screening for sulfide or cyanide is
negative, the samples are not analyzed for
these parameters.

1Chemtech-Ford Laboratories (CTF) analyzes pH and enters data in the Container Tracking and Disposal
Spreadsheets. Stantec completes a pH quality assurance review to ensure the correct category is
designated for CTF analyses determinations (i.e., P3MMP spreadsheet auto populates with a “Y” (Yes) in
the category column). This category is dependent on the following:
• Off-site lab pH analyses.
• Field screening parameters .
8.0 PHASE 3 MATERIAL INVENTORY AND MANAGEMENT
Thatcher is prepared to initiate the Phase 3 Inventory and Management following DWMRC approval of the
P3MMP. Container inspections have been completed weekly and a Baseline Preliminary Inventory was
performed during the preparation of this P3MMP.
A material inventory and management flow diagram is included in P3MMP Figure 4. This diagram
summarizes the P3MMP decision making process for Phase 3 containers.
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8.1 PHASE 3 BASELINE PRELIMINARY INVENTORY
DWMRC informed Thatcher that a Phase 3 inventory was required prior to continuing Phase 3 to provide
assurance that the total number of Phase 3 containers does not change as the project progresses. Phase
3 as initially started with Batch 1 and a total of 103 containers were inventoried, with 70 containers
disposed, and 33 containers identified as commercial chemical product for recycling. Thatcher dispersed
the 33 commercial chemical product containers to other areas. These containers are included in the
Baseline preliminary inventory and Phase 3 continuation. The term “batch” was applied to the first area
where container disposition management determinations were made prior to preparation of this plan.

Baseline preliminary inventory of containers in Phase 3 areas 1 through 14 (Figure 3) were numbered
as follows: Area (A), such as Area 1 (01), and container number (001) (e.g., A-01-001). Thatcher
inspected the 14 areas and completed the area’s baseline preliminary inventory. During the area’s
baseline preliminary inventory, labels w ere assigned to 1,003 containers and/or pallets (e.g., bags of
same materials). If it was determined that container area numbers were assigned to containers with
disposition numbers or materials not within the Phase 3 pre-November 2019 timeline they were
removed from the list; therefore, area numbers may not be consecutive.

Thatcher’s pre-existing trailer inventories (area 12) were used for trailer container inventory (1,177
containers); therefore, area numbers were not assigned and containers in trailers were not labeled
with assigned numbers. Containers on the disposition inventory (531 containers) have assigned
disposition numbers.

Total Phase 3 containers from the baseline inventory of the 14 areas (1,003), trailers (1,177), and
disposition list (531) is 2,711.
8.2 INSPECTIONS
The 90-day hazardous waste storage and Phase 3 areas are inspected on a weekly basis. Copies of blank
inspection forms are included in Appendix F. Completed copies of 90-day storage area inspection forms
are maintained by Thatcher.
8.3 MANAGEMENT OF “CONTAINERS NOT IN GOOD CONDITION”
Beginning on October 22, 2021, Thatcher observed all Phase 3 containers weekly to identify Containers
not in Good Condition. Weekly area inspections have been documented by area managers and since
initiating this inspection program, four containers requiring repackaging have been identified and
managed.

Regular area monitoring and inspections are ongoing and will continue through Phase 3; examples include
the following:
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• Weekly inspections of Phase 3 areas and maintenance of inspection records.
• Thatcher conducts regular work area inspections and addresses Containers not in Good
Condition as necessary.
• Employees that identify Containers not in Good Condition during daily operations follow company
container management and/or reporting guidelines (see Section 2.3 Emergency Response).
• Thatcher employees respond to incidents according to the plan applicable to the materials
released (i.e., hazardous waste and/or hazardous material) and training received.

During inspections, containers found to be Containers not in Good Condition will be repackaged prior to
moving the containers for storage in the NWSA and will be managed for disposal.

Thatcher immediately addresses (i.e., repackages per Section 8.6.4 Container Repackaging) any
containers that pose an imminent threat. Any spill or release of material (newly generated), including raw
materials or product, will be immediately cleaned up. If a spill is detected that is not immediately cleaned
up or is mixed with another material, soil, or precipitation/run-off, it is considered waste which will be
containerized for management as newly generated. Any container that is not in good condition which
contains material that exhibits a characteristic of, or is a listed hazardous waste, and containers for which
insufficient information is available to make a hazardous waste determination, shall not be recycled or
reworked and must be managed for disposal.

Containers with newly generated waste will be dated with the date the material is first placed in the
containers.
8.4 PHASE 3 CONTAINER AREA REVIEW AND MANAGEMENT
DETERMINATIONS
This section describes the processes which will be followed for the review of the Facility and inventory of
material containers during Phase 3 of the project. Thatcher has designated 14 Phase 3 container
management areas as shown on Figure 3. Material management decisions can proceed concurrent with
the area disposition review. Management decisions for Phase 3 containers will include use/reuse
(recycling) in the production process, and/or disposal. Facility-wide review will be completed to gather
information needed to facilitate efficient management decisions. The container area disposition review
will include Area 1 through Area 14 as shown in Figure 3. Thatcher knowledgeable staff will work with
Stantec to identify and track the containers with area disposition review forms and spreadsheets (see
Section 8.4.1). Each Phase 3 container will be assigned a tracking number. Containers observed not to
be in good condition will be immediately addressed as detailed in Section 8.2 Management of “Containers
not in Good Condition”. Container disposal is detailed in Section 8.8, Disposal Forms and Tracking
Spreadsheets, and the disposition process is detailed in Section 8.5.3.

A material inventory and management flow diagram is included in P3MMP Figure 4. This diagram
summarizes the P3MMP decision making process for Phase 3 containers.
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8.4.1 Area Disposition Review Forms and Spreadsheet
The Area Disposition Review Form will be used to track information collected during the disposition
process (disposal or disposition) and is included in Appendix G. Disposal numbering started with Batch
1 containers 1511-1542. The term “batch” was applied to the first area where container disposition
management determinations were made prior to preparation of this plan. The container numbering used
in the form and/or spreadsheets is as follows.
• Consecutive “by area” tracking numbers will be assigned to Phase 3 containers managed for
disposal or disposition.
▪ Phase 3 containers will be numbered as follows Area (A), such as Area 1 (01),
and container number (001) (e.g., A-01-001).
▪ Disposition (recycling) containers will have “(R)” added to the end of the number
(e.g., A-01-001 (R)).
Some containers with materials intended for recycling may have an existing disposition number which has
been tracked previously on a list maintained by Thatcher. These containers will be labeled as either
“Phase 3 Recyclable Material – CCP” or “Phase 3 Recyclable Material, Non-CCP Pending Approval from
the DWMRC” based on the contents of the container. These containers will be migrated to the disposition
spreadsheet, will receive a disposition number (e.g., A-01-001 (R))) and will be labeled for hazard type in
accordance with the Globally Harmonized System of classification and labeling of chemicals.
The Area Disposition Review Spreadsheet included in Appendix G is used to track area disposition review
determinations by each Area (disposal or disposition) for Phase 3 containers. A new Area Review
Disposition Spreadsheet will be started when transitioning to a new Area.

The Repackaging Form described in Section 8.5.3.1 will be used if containers require repacking for
movement (i.e., Containers not in Good Condition).
8.5 DISPOSITION AND/OR DISPOSAL MATERIAL MANAGEMENT
Area disposition review and container management will be limited to the number of containers requiring
disposal that will fit into the NWSA secondary containment (i.e., phased approach with an estimated
maximum of 50-containers in the NWSA at any one time). Thatcher knowledgeable staff will work with
Stantec to identify and track the containers. Each container not identified as “active inventory” designated
for disposition or disposal will be assigned a tracking number as described in Section 8.4.1. Container
condition and immediate action determinations will be addressed. Thatcher will manage containers
identified for disposition that will be left in the area or moved to another area for storage for use and tracked
on the disposition spreadsheets.

Clean Harbors will contain and cleanup any leaking or spilled material identified during movement from
the process or container storage area to the NWSA and will follow Thatcher emergency response plan
requirements. Container trailers will be moved to the NWSA by Thatcher and unloaded by Clean Harbors
and/or appropriately trained Thatcher staff. Clean Harbors and/or Thatcher will move repackaged
containers pending disposal to the area directly outside of the NWSA east fence line.
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The NWSA secondary containment is lined with high density poly-ethylene sheeting (HDPE), is open
sided, and has a roof that mostly covers the area. Storm water in the secondary containment is collected
for management. The area directly outside of the NWSA east fence line will be utilized for storage of
repackaged containers pending disposal which will provide room in the NWSA secondary containment to
accelerate the project schedule. Secondary containment for this area consists of asphalt and concrete
surfaces with storm water draining towards the facilities’ storm water treatment system. Once there is
sufficient room in the NWSA secondary containment area, disposition review and container management
will continue in order to meet “reasonably aggressive” project schedule objectives. When containers in
the NWSA are characterized and repackaged/overpacked (as necessary) they can be moved t o the east
of the NWSA fencing for temporary storage until a disposal shipment is arranged.

Containers will be labeled as detailed in Section 8.6.3, Container Labeling. Once assigned a date,
Thatcher intends to manage containers designated for disposal as universal waste, and/or hazardous
waste containers within 90 days of the Phase 3 Accumulation Date. If hazardous waste containers will
exceed the 90-day time limit, Thatcher will request in writing an extension of the 90-day limit, demonstrating
that the extension is necessary due to unforeseen, temporary, and uncontrollable circumstances . Use or
reuse (recycling) is summarized in Section 8.4.1. Used oil will be managed using Thatcher’s existing used
oil management practices. Universal waste will be managed in accordance with the requirements of R315-
273. A flow diagram detailing the material management process is included as Figure 4.

8.5.1 Known Phase 3 Hazardous Secondary Materials Identified for Disposition
Commercial Chemical Products are both listed commercial chemical products as defined in 40 C.F.R. §
261.33 / R315-261-33 and non-listed commercial chemical products which EPA defines as including all
types of unused commercial products, including off-specification species of the same, that exhibit a
characteristic of hazardous waste. See 50 Fed. Reg. 14219 (April 11, 1985).
8.5.1.1 Known Material Identified for Disposition (Use or Reuse (Recycling))
A “known material” identified for disposition is identified by label, SDS (Thatcher products or other
CCPs), and/or Thatcher tracking number (e.g., lot number, product number, etc.). Kn own Phase
3 CCPs shall be evaluated for use or reuse (recycling) within one year of the material’s Phase 3
Accumulation Date. Hazardous CCP containers not used within the one-year time period will be
transferred to the LQG storage area and disposed of with in 90 days.

Known non-CCP Phase 3 Hazardous Secondary Materials are not anticipated. If and when these
types of materials are identified Thatcher will provide the proposed recycling scenario information
to DWMRC. Non-CCP Phase 3 Hazardous Secondary Materials may only be recycled with the
express written authorization of DWMRC. Any non-CCP Phase 3 Hazardous Secondary Material
authorized for recycling, but not used within nine months of the Phase 3 Accumulation Date, will
be transferred to the LQG storage area and disposed of within 90 days. Section 4.3 legitimate
reuse/re-working scenarios will be provided for known non-CCP Hazardous Secondary Materials
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for DWMRC approval. While awaiting the DWMRC decision on the request to recycle non-CCP
Phase 3 Hazardous Secondary Materials, the containers will receive a disposition number;
however, the containers will be stored in the NWSA until approved for recycling. If the material is
not approved for recycling, it will be managed as hazardous waste and managed in accordance
with Section 8.5.3.1.

Known non-CCP Phase 3 Hazardous Secondary Materials recycling s cenario information will
include the following.
• Hazardous waste determination (i.e., would exhibit hazardous waste characteristics or be
a listed hazardous waste if disposed).
• Non-CCP hazardous secondary material is designated by Thatcher’s technical services
as “assigned in use” in the regular SharePoint disposition process. Thatcher Production
Planning creates an inventory under generic item number Disposition Material (DISP
MTRL) for approved rework disposition materials in the central Enterprise Resource
Planning (ERP) system Infor/M3 (software), assigning the Disposition number (DXXXX)
as the M3 Lot number. Production Planning and Technical Services will collaborate to add
“DISP MTRL” item by Lot (Disposition number) into finished goods batches to the M3 Bill
of Materials for that Manufacturing Order (MO).

Through basic functionality of the M3 ERP system, Lot tracing will provide historical usage
of these “DISP MTRL” items including the following data points: Lot number (Disposition
number), Item, date used, qty used, operator name that reported production, finished
product created, among others. This information is stored in the M3 database indefinitely
and can be accessed at any time.

8.5.2 Material Identified for Disposal
8.5.2.1 Known Material Identified for Disposal
A “known material” identified for disposal is identified by label, SDS (Thatcher products or other CCPs),
and/or Thatcher tracking number (e.g., lot number, product number, etc.). If information is not conclusive
for profiling the material for disposal, it will be managed as an unknown.
8.5.2.2 Unknown Material Identified for Disposal
An “unknown material” will be evaluated for disposal using the characterization process as detailed in
Section 7.0.
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8.5.3 Material Management Disposition Forms and Spreadsheets
8.5.3.1 Disposal Forms and Tracking Spreadsheets
Forms used to track container information include a Field Screening Form (Appendix H) and a
Repackaging Form (Appendix I). The Container Tracking and Disposal Spreadsheets are included in
Appendix J. This spreadsheet is used to track area containers, track sampling, characterization, profiling,
and disposal information. Stantec will upload the spreadsheet to the Thatcher UDEQ DWMRC SharePoint
site monthly when the monthly report is submitted. The process of field screening, sample collection and
analysis, and material characterization is detailed in the WAP (Appendix C).
8.5.3.2 Disposition Tracking Spreadsheet
The Disposition Tracking Spreadsheet is included in Appendix K. This spreadsheet is used to track Phase
3 container recycling (use, or reuse), or disposal determinations.
8.6 CONTAINER MANAGEMENT
The procedures proposed to physically manage the Phase 3 containers are detailed below.
8.6.1 Management of Containers Posing Imminent Threat
See Section 8.3 Management of Containers not in Good Condition.

8.6.2 Management of Containers Spilled During Transport
See Section 8.3 Management of Containers not in Good Condition.
8.6.3 Container Labeling
All containers will retain either the disposal number or the disposition (recycling) number assigned during
the area disposition review process as detailed in section 8.4.1. If a container is repackaged or
overpacked, the disposal or disposition number will be transferred to the new container. Containers with
unknown contents which require disposal will be labeled “hazardous waste” and “on test” with the inventory
date as the Phase 3 Accumulation Date, unless the actual accumulation date can be determined. If the
actual accumulation date is known, the container will be labeled with both the actual accumulation date
and the Phase 3 Accumulation Date.

Containers requiring disposal with known contents will be labeled as either hazardous or non-hazardous
waste. Containers designated for disposition (recycling or disposal) will be labeled with the Phase 3
Accumulation Date as the accumulation date unless a prior accumulation date c an be determined, in which
case both dates will be indicated on the label. In addition to the hazardous waste label, once any hazardous
characterization information is obtained, Department of Transportation (DOT) hazardous class labels will
be applied to the containers for identifying hazardous characteristics (e.g., DOT corrosive hazard class for
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RCRA characteristic of corrosivity). Containers will also be labeled as described above when material is
repackaged.

8.6.4 Container Repackaging
Container repackaging includes overpacking and/or transfer of materials to a container in good condition
by trained staff. Container condition will be inspected as described in Section 8.2. Containers will be closed
except when removing or adding material. Containers will be repackaged in areas with secondary
containment and will have spill response materials readily available. Temporary secondary containment
will be established (e.g., plastic sheeting with berms) in areas without secondary containment for
management of damaged/leaking containers. Containers will be overpacked by manual or mechanical
means. Transfer of materials from one container to another will be by manual methods (e.g., containers
emptied form one container to another using valves and funnels), or mechanical (pumps) means.

Non-sparking tools will be used for containers with ignitable materials and bonding and grounding will be
used when transferring material which could generate friction (e.g., pumping).

Container tracking numbers will be transferred to the new container(s). If contents from large containers
are repacked in smaller containers (e.g., 275-gallon tote to 55-gallon drums) an alphabetical character,
(e.g., 1543A and 1543B etc.) will be added to the number. If same material from small containers are
consolidated in larger containers (not bulked) (e.g., 5-gallon pails in 55-gallon drums), all small container
numbers will be tracked on the new larger container.

8.6.5 Container handling
Closed containers may be moved by manual (personnel and drum handling equipment) or mechanical
(forklift, drum handling equipment, transport vehicles) means. Manual drum handling equipment includes
cart, dolly, pallet, and/or pallet jack. Mechanical drum handling equipment includes drum mover
attachment and lifting devices. Loads will be secured on transport vehicles when necessary. Containers
designated for disposal will be moved to the NWSA secondary containment. Containers designated for
disposition will remain in the area or be moved to another area for management.

8.6.6 Empty Container Management
Containers will be: 1) emptied by using standard practices commonly employed for the material and
container type (e.g., pouring, pumping, and aspirating), and 2) Condition 1 must be met with one inch or
less of residue on the bottom (or 3% or 0.3%) and may not be RCRA empty if more can be poured out,
pumped out, or removed by aspirating - and in accordance with Utah Admin. Code R315-261-7:
• No more than 2.5 centimeters (one inch) of residue remains on the bottom of the container or inner
liner;
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• No more than 3 percent by weight of the total capacity of the container remains in the container
or inner liner if the container is less than or equal to 110 gallons in size ; or
• No more than 0.3 percent by weight of the total capacity of the container remains in the container
or inner liner if the container is greater than 110 gallons in size.
• Containers that have held acute hazardous wastes must be rinsed or cleaned per Utah Admin.
Code R315-261-7(b). Acute hazardous waste constituents can be determined by comparing
label/SDS constituents’ sole active ingredients, or hazardous waste from non -specific sources to
acute hazardous waste listed in Utah Admin. Code R315-261-31 or 261-33(e). Containers that
held acute hazardous waste will be rinsed with the proper rinsing agent (e.g., water for water-
soluble wastes and organic solvents for non-water-soluble wastes).
• Containers that have held acute hazardous waste will be rinsed with the appropriate reagent
before being discarded.

RCRA-empty small containers are discarded in the trash or managed as scrap metal when empty. Large
containers are recycled to the vendor, reused, managed as scrap metal, crushed, cut in half (plastic),
and/or thrown in the trash.
8.7 WASTE STORAGE PROCEDURES
Stantec, on behalf of Thatcher, developed a comprehensive SHWMP, dated August 31, 2020. The
SHWMP (Appendix B) was prepared in accordance with Utah Admin. Code R315, 262 through 265.
SHWMP Section 4.0 details preparedness and prevention for an LQG and describes practices for
hazardous waste storage areas management. Thatcher intends to comply with all the LQG requirements
for 90-day and satellite accumulation hazardous waste storage areas. This plan applies to the 90-day and
satellite accumulation hazardous waste storage areas located at the Facility. The area directly outside of
the NWSA east fence line will be utilized for storage of repackaged containers pending disposal which will
provide room in the NWSA secondary containment to accelerate the project schedule.
8.8 WASTE DISPOSAL
SHWMP Section 8.0 Pre-Transport Requirements and Record Keeping was prepared in compliance the
requirements of the hazardous waste regulations detailed in Ut ah Admin. Code 262-20 through 27, 30
through 35, and 40 through 44 for a LQG. Thatcher intends to comply with all the LQG requirements for
disposal in preparing hazardous waste for shipment off-site and for the proper maintenance of records
regarding these shipments.
8.9 DECONTAMINATION PROCESS
Newly generated investigation-derived wastes (IDW) generated during this work include used Personal
Protection Equipment, used disposable sampling equipment, paper shipping waste, and decontamination
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materials. Potential characteristic or listed hazardous waste decontamination materials will be
containerized, characterized, classified, and disposed of according to regulatory requirements.

All containers of potentially hazardous waste IDW generated pursuant to the P3MMP will be labeled to
identify their contents and left in safe locations at the site for eventual disposal (pending analyses). All IDW
wastes that did not contact sample materials or other site wastes will be handled as solid waste.
9.0 REPORTING
9.1 MONTHLY REPORTING
Thatcher will prepare and submit P3MMP reports to the DWMRC on or before the 15th day of each month
until P3MMP is completed. Reports will include a written project description and the following.
• Number of containers, by area, processed.
• Number of containers moved to the NWSA.
• Number of containers repackaged.
• Number of containers sampled and characterized.
• Number of containers disposed as hazardous waste and non-hazardous waste.
• Number of containers retained for reuse, container number, date.
• A copy of the inventory forms and spreadsheet created for the area.
• Inspection forms with description of cleanup of any leak or spill material identified during the
P3MMP process.

The monthly report format is included in Appendix L.
10.0 COMPLIANCE SCHEDULE
10.1 COMPLIANCE SCHEDULE
The Phase 3 material management process will continue within 30 days of receipt of DWMRC approval of
this P3MMP. The schedule for completing Phase 3 of this project will be dictated by the storage capacity
of the NWSA, which can accommodate containers as follows:
• Secondary containment approximately 50 containers, and
• Approximately 500 repackaged containers within the fenced area.

Thatcher anticipates that the initial area disposition review process for each area will take several days
(estimated 1.5-weeks) at the end of which a disposition management decision will have been made for
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4859-0509-4175\1
each Phase 3 container in the area. Once the area disposition review has been completed, the containers
will be processed in accordance with the disposition management decision made as detailed in Section
8.4.

Materials in containers will be sampled and characterized under the standards described in Section 4.2
Material Analysis and Designation and Section 7.2 Application of Field screening and Analysis for material
characterization (estimated 3-weeks). Management options may include use/reuse (recycling) in the
production process and/or disposal. Materials in Containers not in Good Condition, in containers not
compatible with the contents, or not meeting DOT standards will be repackaged. Containers will be labeled
as described above when material is repackaged. Repackaging and preparation for shipment is estimated
to require 4 weeks.

Analyses data and material/waste profile submission will be completed (estimated 1.5 weeks). Profile
approval is estimated at 2-weeks.

Thatcher’s “reasonably aggressive” compliance is based on the following. Thatcher estimates 12 weeks
(84 days)4 to process 50 containers for management in the NWSA, with 2,711 containers that must be
processed for management. DWMRC informed Thatcher on March 3, 2022 (via email) that the NWSA
area inside the fence line can be used for storage of repackaged containers . This will provide the capability
to process an estimated 50 containers every week. Therefore, the schedule for managing 2,711 containers
is 1 year 3 months.

Use or Reuse (Recycling) Schedule
Hazardous CCP containers not used within the one-year period from the Phase 3 Accumulation Date will
be transferred to the LQG storage area and disposed of within 90 days. For those Hazardous Secondary
Materials which are not CCPs and which have been approved, in writing, for recycling by DWMRC must
be used within 9 months of the material’s Phase 3 Accumulation Date. If not used within 9 month s, the
containers will be transferred to the LQG storage area and disposed of within 90 days.

4 This estimate includes six days of contingent time for unforeseen delay or unanticipated conditions.
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11.0 REFERENCES
Stantec Consulting Services, Inc, Waste Inventory and Characterization Work Plan. March 20, 2021

Utah Division of Waste Management and Radiation Control, Stipulation and Consent Order No. 2102006.
dated effective December 9, 2021

Utah Admin. Code R315-261 through 268 and 273.

Department of Transportation labeling 49 CFR part 172.

Occupational Safety and Health Administration standard 29 CFR 1910.1200.

Thatcher Phase 3 Materials Management Plan (to the P3MMP) – Response to Comments Letters. June
03, 2022 and August 15, 2022

FIGURES
NORTHWEST STORAGE AREA
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without notification. An re roductlon ma result In a loss of scale and or Information.
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1
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3
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Step 2: P3MMP Section 8.3 Management of Containers Not in Good
Condition - Evaluation (Thatcher and Stantec responsibility)
Is container damaged/ leaking?
Yes
Take immediate action.
1. Address spill or release - Record
keeping Section 2.3.1.
2. Repackage container - Record
Keeping "Repackage Form".
(Thatcher and/or Clean Harbors
responsibility)
Go to Step 5 for
Disposal
No
Step 3: Section 8.5 Disposition (Step 4) or Disposal (Step 5) Material
Management.
1. Use, reuse, or disposal - record keeping is the Material Management
Disposition Forms and Spreadsheets (8.5.3.1).
(Thatcher and Stantec responsibility)
Is container a "known material CCP or non-CCP" - Record keeping is label,
safety data sheet, and or Thatcher tracking number. (Thatcher and
Stantec responsibility)
Yes
Step 4: Section 8.5.1 Known
Commercial Chemical Products (CCP)
and Non-CCP - Evaluate for use or reuse
(recycling).
Can material be used or reused?
(Thatcher and Stantec responsibility)
Yes
Is container hazardous
CCP or non-CCP?
(Thatcher and Stantec
responsibility)
DWMRC approal for
use is required for
hazardous non-CCP.
Yes
Has container been used or
reused (recycled)
1. CCP within one year?
2. Non-CCP within 9-months?
(Thatcher and Stantec
responsibility)
Yes No further action
required.
No No go to Step 5 No No go to Step 5
Step 5: Section 8.4 Disposal and 8.4.2 Material Identified for Disposal
1. Known (8.5.2.1) or unknown material (8.5.2.2) identified for disposal.
1a. Evaluate/ characterize for disposal - Record keeping is the Disposal
Forms and Tracking Spreadsheets Section 8.5.3.1.
2. Responsibilies
a. Thatcher and/or Clean Harbors will move continers to the NWSA.
b. Clean Harbors container handling, repackaging, sampling, and related
forms.
c. Thatcher and Stantec recordkeeping management.
1. Use or Reuse
management tracked
on Disposition
spreadsheet.
2. Disposal go to Step
5.
FIGURE 4
Thatcher P3MMP Material Management Process Flow Diagram
Step 1: P3MMP Section 8.4 - Project team select storage area for material management from the 14 designated storage areas.
Inspect one storage area completely before moving on to additional storage area(s). Record keeping is the Area Disposition
Review Form and Spreadsheet Section 8.4.1 (Thatcher and Stantec responsibility).
Notes:
11. Phase 3 Container Numbers
a. Phase 3 containers will be numbered as follows Area (A), such as Area 1 (01), and container number (001) (e.g., A-01-001).
b. Disposition (recycling) containers will have “(R)” added to the end of the number (e.g., A-01-001 (R)).
2. P3MMP Section 8.2 Inspections: Areas are inspected weekly by Thatcher. Record keeping is the weekly inspection forms.
3. Monthly Reports Section 9.1: Thatcher and Stantec responsibility.
4. Records will be maintained on SharePoint by Stantec.
1The term “batch” was applied to the first area where container disposition management determinations were made prior to preparation of this plan.
Containers identified as known with the same contents are assigned the tracking number and an alphabetical character, e.g., A-01-001A and A-01-001B etc.

APPENDIX A
Thatcher Emergency Response Program (Hazardous Materials Emergency Action Plan EHS-
13) and Standard Operating Procedure (SOP) Environmental Health and Safety (EHS-29)

EMERGENCY RESPONSE PROGRAM PAGE: 2 of 28
(Emergency Action Plan (EAP) and Fire Prevention Plan) SOP: EHS-13
REV: 1

2.0 DEFINITIONS
2.1 California Code of Regulations (CCR)—the State of California code for regulatory compliance
that are equivalent or more stringent than the comparable Federal (OSHA) regulation.
2.2 CAL/OSHA—state of California’s Occupational Safety and Health administration. California is
one of many states with an OSHA approved State Plan.
2.3 Catastrophic Chemical Spill/Release—the emergency is beyond the ability of Thatcher
HazMat personnel and will only be controlled with the assistance of outside agency intervention.
The public will be affected.
2.4 CHEMTREC—The Chemical Transportation Emergency Center operated by the Chemical
Manufacturers Association in Washington D.C.
2.4.1 For domestic shipping (within the U.S.) call: 1-800-424-9300, Customer Number: 22106
2.4.2 For Canada call Canutec (613-996-6666), Customer number: 22106
2.4.3 For international (outside of the U.S.) call: 703-527-3887, Customer number: 22106
2.5 CHLOREP—the basic description of the chlorine industry's response procedure as set forth in
the document titled, "Chlorine Emergency Plan (CHLOREP)."
2.6 DOT—the United States Department of Transportation.
2.7 EMERGENCY—aAny incident involving a chemical which creates a potential or actual public
hazard.
2.8 ERT (Emergency Response Team)—a team consisting of a team leader and one or more
team assistants to handle the emergency. (HazMat team members are all 40 hour HAZWOPER
trained.)
2.9 EPA—the United States Environmental Protection Agency.
2.10 HazMat Refresher—eight (8) hour Hazardous material training once a year known as
HAZWOPER.
2.11 HAZWOPER—the required training course method for HazMat teams (29 CFR 1910.120).
2.12 International Fire Code (IFC)—Fire Code superseding 1997 Uniform Fire Code (UFC)—a new
version of this regulation was release in January 2012 and every three years afterwards.
2.13 Major Chemical Spill/Release—there is a strong possibility the chemical will leave the property
and a chance someone can be injured as a result of the incident. The public will be affected.
2.14 Minor Chemical Spill/Release—can be controlled by immediate personnel but a page is
conveyed to the Thatcher HazMat Team. This will allow the team to prepare, in the event the
condition becomes moderate. The public will not be affected.
2.15 Moderate Chemical Spill/Release—under the direction of the Plant Manager, the emergency
can be controlled on property. Thatcher HazMat Team members are required to respond in
order to contain the chemical, but injuries resulting from the incident are non-existent. The
public will not be affected.
2.16 NAC—Nevada Administrative Code.
2.17 Notification—the NRC shall be notified immediately when an unauthorized discharge becomes
reportable under state, federal, or local regulations.
2.18 NRC—National Response Center. The 800-424-8802 number may be called 24 hours a day
and the operator will submit a report to the various agencies. Calls to the Fire Department, and
State EPA will still need to be made.
EMERGENCY RESPONSE PROGRAM PAGE: 3 of 28
(Emergency Action Plan (EAP) and Fire Prevention Plan) SOP: EHS-13
REV: 1

2.19 OSHA—the Occupational Safety and Health Administration, as instituted by the OSH Act of
1970, which created the numerous federal laws which employers, must follow to ensure
employee safety.
2.20 Release of Hazardous Materials—hazardous materials shall not be released into a sewer,
storm drain, ditch, drainage canal, lake, river, or tidal waterway, or upon the ground, sidewalk,
street and highway, or into the atmosphere.
3.0 EMERGENCY ACTION PLAN (EAP) VS EMERGENCY RESPONSE PLAN (ERP)
3.1 EAP—an emergency action plan (EAP) is a written document required by OSHA standards 29
CFR 1910.38(a). The purpose of an EAP is to simplify and organize employer and employee
actions during workplace emergencies. Emergency Action Plans and proper employee training
(ensuring employees understand their roles and responsibilities within the plan) will result in
fewer and less severe employee injuries and less structural damage to the facility during
emergencies.
3.2 The EAP is designed to be the pre-planning phase of an incident/accident; it is the steps taken
by Thatcher Company to prepare for, and have a plan in place, to respond to all types of
accidents/incidents. This planning may include, but is not limited to
3.2.1 Creating an Emergency services—call list,
3.2.2 Creating and coordinating with List of hospitals and doctors,
3.2.3 Creating an Employee Call List (important phone numbers) 29 CFR 1910.38(c)(6),
3.2.4 Designating HazMat Team responsibilities,
3.2.5 Determining evacuation routes and practicing evacuation drills,
3.2.6 Determining Shutdown procedures for those who will remain behind during an incident
to properly shut down facility equipment and processes, and
3.2.7 Determining average employee responsibilities.
3.3 ERP—after an incident/accident has occurred, the first priority is always the preservation of life.
The second priority is the stabilization of the incident/accident. The actions taken to make a
situation better once the incident/accident has occurred are the response plan. The best way to
handle these incidents is to plan, train, and have designated responsibilities for them. These
responsibilities may be broken down into groups or individually and may include
3.3.1 Evacuating in an orderly manner to the primary or secondary evacuation point—as
directed
3.3.2 Performing assigned task (HazMat Team members only)
3.4 Activation of the Emergency Response Plan (ERP) will be at the discretion of those involved in
the incident (onsite personnel), anytime they feel outside help is needed 911 will be called.
3.5 As with all Thatcher Company Standard Operating Procedures (SOPs), this SOP must be
updated, or reviewed/validated at least annually for applicability. A new revision number will
indicate the SOP has been updated, or a separated review/validation sheet attached to the SOP
will indicate the SOP has been reviewed/validated on the date indicated on the form.
EMERGENCY RESPONSE PROGRAM PAGE: 4 of 28
(Emergency Action Plan (EAP) and Fire Prevention Plan) SOP: EHS-13
REV: 1

4.0 PRE-EMERGENCY PLANNING AND COORDINATION WITH LOCAL FIRE DEPARTMENTS,
EMERGENCY MEDICAL PERSONNEL, AND THE L.E.P.C.
4.1 Many State and local governments have programs in place to periodically complete local fire
department’s pre-incident inspections. Such inspections have been done to familiarize the fire
departments with the facility layout, its general operation, the different types of chemicals, and
their location around the facility. Any local fire department wishing to do so has an open
invitation for these inspections. Since Thatcher Company does not manage these entities we
cannot assume when they will accept the offer to train onsite; however, we anticipate training to
be offered at least annually. When training and coordination of this nature takes place, Thatcher
Company Personnel will take minutes from these meetings and maintain a record of the fact
emergency responders have seen this SOP and have knowledge of on-site capabilities and
expectations. Minutes need not be recorded on any special form but must be attached at the
end of this SOP. Topics of discussion, requirements, and recommendations from off-site
emergency responders will also be recorded
4.2 These pre-incident inspections are an essential part of Thatcher Company’s emergency
response plan. They allow Thatcher Company to work with fire fighters in an emergency to
preserve life and property. Together we will be able to respond efficiently and effectively to
emergencies and/or unauthorized releases (see EHS-29).
4.3 EMERGENCY RESPONSE: If OSHA considers a worksite response activity a "HAZWOPER
Emergency Response," then employers with employees at the site performing emergency
response must comply with HAZWOPER paragraph (q) and all other General Industry (29 CFR
1910) standards. The term "emergency response" has a very specific meaning and application
under HAZWOPER. Employers often apply this term to any activity requiring immediate
attention. However, under HAZWOPER this term applies specifically to response activities
where there is an uncontrolled release of a hazardous substance, as defined by HAZWOPER in
paragraph (a) (3), or where an uncontrolled release is likely. Thatcher Company HAZWOPER
trained employees (HazMat Team) are also trained in First Aid and CPR; as such, they are the
ONLY designated company personnel that can, and may, respond in an emergency situation—
all non-HazMat employees will evacuate the facility and are NOT authorized to assist in any
manner of medical duties.
4.4 In the event of an emergency or unauthorized release the Facility Incident Commander (FIC)
will take charge of the situation. The FIC for Thatcher Company will be the senior HazMat
(emergency response) team member onsite at the time of the incident.
4.5 Emergency Medical Teams—the medical facility handling any emergency situation for major
injuries involving one or more people will be the hospital listed in EHS-13F6. Any medical teams
responding to the facility will be advised of any potential hazards that still exist as well as
decontamination procedures that need to be followed.
4.6 Local Emergency Planning Community (LEPC)—a copy of this emergency response plan, a
map of the facility, and a copy of the hazardous materials inventory will be made available to the
LEPC upon request. Check your local regulations on this matter, many areas require the LEPC
be given this information, and other local groups such as the NDEP CAPP have access to this
information.
4.7 A complete list of chemicals is available through the onsite Hazardous Materials Identification
System (HMIS) and through Safety Data Sheets (SDS)—both are available upon request.
4.8 Important phone numbers and emergency numbers will be posted near all phones and on
employee information boards—the forms that may be posted are the forms associated with this
SOP (EHS-13F1, EHS-13F2, EHS-13F4, and EHS-13F6).
EMERGENCY RESPONSE PROGRAM PAGE: 5 of 28
(Emergency Action Plan (EAP) and Fire Prevention Plan) SOP: EHS-13
REV: 1

4.9 Employee responsibilities are broken down into two groups: first, those who are part of the
HazMat (emergency response team) and secondly, everyone else. Only HazMat team members
are permitted to respond to emergencies of any nature—all other employees evacuate to their
designated evacuation locations as specified in the SOP. HazMat Team members (members
listed in EHS-13F2) will act as incident command stricter as specified in section 11 of this SOP
until such times as they are relieved by local, state, or other governmental authorities.
4.10 Based on the type and nature of the chemicals used onsite, it is extremely unlikely that any
employee transported to an offsite emergency facility would be contaminated at a level high
enough to warrant decontamination of anyone other than the affected individual. A SDS of the
chemical of exposure will be made available to emergency responders upon request.
5.0 EMPLOYEE ALARM SYSTEM
5.1 General Alarm Requirements. An all employee alarm system will be designed according to the
following:
5.1.1 Does the employee alarm system appear to provide warning for necessary emergency
action as called for in the emergency action plan, or for reaction time for safe escape of
employees from the work-place or the immediate work area, or both?
5.1.2 Is the employee alarm capable of being perceived above ambient noise or light levels
by all employees in the affected portions of the work place?
5.1.3 Is the employee alarm distinctive and recognizable as a signal to evacuate the work
area or to perform actions designated under the emergency action plan?
5.1.4 Where a communication system also serves as the employee alarm system, do all
emergency messages have priority over all non-emergency messages?
5.1.5 Have procedures been established for sounding emergency alarms in the workplace?
For those facilities with ten (10) or fewer employees in a particular workplace, direct
voice communication is an acceptable procedure for sounding the alarm, provided all
employees can hear the alarm. Such work-places need not have a back-up system.
5.2 In addition to the requirements
5.2.1 Employees are properly trained.
5.2.2 Emergency telephone numbers are posted
5.2.3 Alarm system is maintained by trained personnel
5.3 Annual Alarm system testing will be performed and documented to ensure the system is
functioning and to find any areas of deficiency.
5.4 See EHS-13F13 for specific information on your facility’s alarm system and employee
notification procedures
6.0 EVACUATION PLANS
6.1 Emergency evacuation escape route plans are posted in key areas throughout the buildings
(usually near exit doors). All employees have been trained concerning these plans and should
also be familiar with the evacuation plans for the other buildings within the company.
6.2 Employee responsibilities are broken down into two groups: first, those who are part of the
HazMat (emergency response team) and secondly, everyone else. Only HazMat team members
are permitted to respond to emergencies of any nature—all other employees evacuate to their
designated evacuation locations as specified in the SOP.
6.3 All HazMat Team members are HAZWOPER trained to be able to respond to any release or
other emergency; they know how to use common emergency equipment.
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6.4 Employee Accountability Procedures after Evacuation 29 CFR 1910.38(c)(4).
6.4.1 In the event of an emergency, all occupants will promptly exit the building by the
nearest exit. Once clear of the building, go to the designated evacuation location and
immediately report to their supervisor. After evacuation, each supervisor (or designee)
is responsible for accounting for each employee assigned to that supervisor by rallying
at the designated evacuation location and conducting a head count. Each employee will
be accounted for by name.
6.4.2 Each employee is responsible for reporting to his or her supervisor so an accurate head
count can be made.
6.4.3 All supervisors are required to report their head count (by Name) to the Emergency
Plan Coordinator or designee.
6.5 Designated Evacuation Locations 29 CFR 1910.38(c)(2)
6.5.1 Primary Location (EHS-13F9).
6.5.2 Secondary Location (EHS-13F10).
6.5.3 Rescue or medical duties procedure—only HazMat Team members or emergency
personnel may be involved in medical and rescue activities. Other employees evacuate
their building to the primary or secondary evacuation location and wait for the all clean
before re-entering the facility.
6.5.4 Once the building is evacuated, no one is to re-enter the building for any reason.
Rescue personnel (if designated and properly trained) are excluded from this rule.
When the Fire Department or other responsible agency has notified us the building is
safe for re-entry, then, and only then, will personnel return to their workstations.
6.5.5 Training for employees who assist in evacuation will be limited to the HazMat Team.
Each HazMat Team member has been trained to assist in the safe and orderly
emergency evacuation of employees according to the requirements set forth in 29 CFR
1910.38(c) (5). Additionally, all HazMat Team member have been trained to the
requirements of 29 CFR 1910.120 (g) (HAZWOPER) and receive annual recertification
on this training as required by the OSHA regulation.
6.5.6 Employee training is provided to all employees when (a) the plan is initiated, (b) when
employee's required actions and responsibilities change, (c) there are any changes to
the plan, and (d) initially for new employees.
6.5.7 This training may include
6.5.7.1 Proper use of fire extinguishers and their location
6.5.7.2 Evacuation routes
6.5.7.3 Building shutdown procedures
6.5.7.4 Emergency escape procedures
6.5.7.5 Procedures to account for employees
6.5.7.6 Major workplace fire hazards
6.5.7.7 Fire prevention practices
6.5.7.8 Closing doors behind you
6.5.7.9 Means of reporting fire and other emergencies
6.5.7.10 Names and titles of emergency plan and fire protection coordinators
6.5.7.11 Alarm systems
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6.5.7.12 Proper housekeeping
6.5.7.13 Emergency and fire prevention plan availability
6.5.7.14 Hazard weather procedures
6.6 Annually this information may be reviewed during the bi-monthly safety meetings (i.e., refresher
training).
6.7 Hazard Weather Emergency Plan—when a hazardous weather alert is announced all
employees should immediately go to the closest tornado refuge area (where applicable). All
employees should stay in the tornado refuge area until given the all clear sign.
7.0 AUTHORITY TO EVACUATE THE PLANT
7.1 Any emergency that requires a decision to evacuate the plant must be cleared with the
company President. In his absence, the Plant Manager, Safety Manager, or the most senior
manager on-site will determine if evacuation is required. The decision to evacuate will be
communicated to senior management at the earliest convenience.
7.2 If an employee takes an emergency call from an off-site location, the following information
needs to be recorded:
7.2.1 A phone number where the person calling may be reached
7.2.2 The name of a contact person
7.2.3 The Company name and address (if applicable)
7.2.4 A brief description of the emergency
7.2.5 The appropriate Thatcher Company personnel to respond
7.2.6 Appropriate non-Thatcher Emergency Response Personnel (If applicable)
7.3 If evacuation is required outside of Thatcher Company property, personnel (highest ranking
person) will make an assignment to contact the adjacent businesses as listed in form EHS-
13F3.
8.0 EMERGENCY RECOGNITION
8.1 Thatcher Company believes providing employees with hazard recognition training that improves
safety awareness is the best way to bring common sense safety to our workplace.
8.2 Emergency recognition training educates employees about ways to identify workplace hazards,
recognize the harmful effects hazards can have on them, and learn how to minimize or
eliminate hazards by practicing safe work behaviors. This may include, but is not limited to
8.2.1 Housekeeping hazards
8.2.2 Fire
8.2.3 Flammable gas release
8.2.4 Toxic gas release
8.2.5 Medical
8.2.6 Other
8.2.7 Earthquake
8.2.8 Flood
8.2.9 Hurricane or other serious storm
8.2.10 Others not specifically listed
8.3 This training is part of the new employee safety orientation and may include annual refresher
training in the form of bi-monthly safety meetings.
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9.0 REPORTING AN EMERGENCY
9.1 All emergencies will be reported according to EHS-29. Reporting emergencies may also include
notifying others through manual pull box alarms, public address systems, radio, telephones, or
verbally.
9.2 On-site HazMat team member, who are First Aid and CPR certified, will be contacted to assess
if off-site emergency medical attention is needed. If off-site help is determined to be needed,
then the appropriate person(s) will be contacted (EHS-13F6).
9.3 It is the responsibility of the FIC to inform offsite emergency responders if decontamination
(decon 4 e) of employees is needed.
9.4 Fire 29 CFR 1910.38(c)(1).
9.4.1 All fires and emergencies will be reported by one of the following means.
9.4.1.1 Verbally to the FIC, if during standard work hours
9.4.1.2 By telephone, if after hours or on weekends
9.4.1.3 By the alarm system 24 hours a day
9.4.1.4 Public address system
9.4.1.5 The following numbers may be posted at all telephones having outside
lines:
9.4.1.5.1 FIRE
9.4.1.5.2 POLICE or SHERIFF
9.4.1.5.3 AMBULANCE
9.4.1.5.4 COMPANY NAME AND ADDRESS/LOCATION
9.4.2 It is anticipated the Fire Department responding will be from the city or county facility
nearest Thatcher Company property; however, this is only an assumption. Emergency
dispatchers (911) are always free to call whichever agency they feel best suited for the
task at hand.
9.5 Flammable Gas Release—will follow the guidelines set forth by the applicable Process Safety
Management (PSM). At minimum, employees should notify their immediate supervisor through
means such as a manual pull box alarms, public address systems, radio, or telephones.
9.6 Toxic Gas Release—will follow the guidelines set forth by the applicable PSM. At minimum,
employees should notify their immediate supervisor through means such as a manual pull box
alarms, public address systems, radio, or telephones.
9.7 Medical—will be reported according to the guidelines established in PS-11, employees should
also follow the guidelines set form in EHS-19. At minimum, employees should notify their
immediate supervisor through means such as a manual pull box alarms, public address
systems, radio, or telephones.
9.8 Earthquake—at minimum, employees should notify their immediate supervisor through means
such as a manual pull box alarms, public address systems, radio, or telephones.
9.9 Flood, where applicable—at minimum, employees should notify their immediate supervisor
through means such as a manual pull box alarms, public address systems, radio, or telephones.
9.10 Hurricane or other Serious Storm, where applicable—at minimum, employees should notify their
immediate supervisor through means such as a manual pull box alarms, public address
systems, radio, or telephones.
9.11 Others not specifically listed—at minimum, employees should notify their immediate supervisor
through means such as a manual pull box alarms, public address systems, radio, or telephones.
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9.12 Employees should use EHS-26 as a reference.
10.0 COMMUNICATION
10.1 The Supervisor will be likely to know of an emergency first. The Supervisor will notify the entire
facility through means such as a manual pull box alarms, public address systems, radio,
telephones, or verbally.
10.2 When paging using the overhead phone system—three random phone keys will be pushed on
the air to bring attention to the speaker. The person paging may state the chemical involved,
type of release, the location, and the severity or other details of the incident.
10.2.1 The Supervisor may designate a representative to speak on the paging system, if the
emergency requires his/her immediate attention.
10.3 For Laboratory and Office Staff Workers, press the “PAGE” button, press “00” for the entire
plant, then three random phone keys on the air to bring attention to the speaker.
10.4 Severity of emergency—The Chemical Spill/Release shall be categorized by the following, if
possible: Minor, Moderate, Major, or Catastrophic (Refer to 2.0 Definitions for details).
10.4.1 An example of a page: "HazMat team please report to the Alum area.”
10.4.2 In the event the PA system is not functioning, messengers must contact the HazMat
Team physically or by use of a megaphone. The Area Manager where the incident is
located will assign a messenger to summon the HazMat Team as needed.
10.5 Notifying required agencies.
10.5.1 A condition of Major or Catastrophic where the reportable quantity has been released
requires a 911 call; a call must also be made to the NRC and SERC (EHS-13F4).
10.5.2 The fire department is required to be notified when a chemical is released into the
environment (any RQ amount to ground). When a minor release has occurred, the non-
emergency fire department phone number will be used (EHS-13F4). The following is
an example of a required “Minor” release notification: "My name is (Designated Person),
from Thatcher Company at (give your location). I am making a required Non-
Emergency report for a chemical release. (Chemical Name) was released at (Time
AM/PM) on the (e.g., west end of the plant). The release has been contained and does
not require assistance from the Fire Department. There is no danger to employees or to
the public.
10.6 The designated person who contacts 911 or communicates with the outside ERT will need to
know the following information:
10.6.1 If anyone has been injured
10.6.2 The number of injured persons
10.6.3 The types of injuries
10.6.4 Name of the chemical
10.6.5 Source of the release, fire, or hazard
10.6.6 Immediate location of the release, fire, or hazard (Building #, address, etc.)
10.6.7 Current status of hazard
10.6.8 Possible hazards that may arise
10.6.9 Characteristics of the chemical (appearance, odors, etc.)
10.6.10 Evacuation information—how many and where have the evacuations been
implemented
10.6.11 Quantity of spill—Do not guess!
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10.7 The quantity of the release and other information given to the responding authorities must be
correct and substantiated. Explain to the Fire Department or other involved agencies an
evaluation is in process and a qualified chemist will inform you of the correct release quantity.
10.8 News Media
10.8.1 In the event of emergency, interested news personnel, (i.e., reporters, cameramen,
news crews, etc.) are to be directed to the Thatcher Company President. The Company
President may designate this duty of answering questions, and providing background to
another individual.
10.8.2 To ensure the safety of the news media, no media personnel are allowed on the
property until the Company President gives permission.
10.8.3 Once permission is granted, the Company President or his designated representative
will accompany the media personnel during the entire time they are on-site.
10.8.4 No employee may talk to the media until after they have received permission to do so
from the Company President. Violation of this principle may result in employee
discipline as described in EHS-09.
11.0 INCIDENT COMMAND STRUCTURE (ICS)
11.1 The ICS used during an emergency may consist of the following:
11.1.1 The senior most HazMat Team member on-site will act as the FIC until such time as the
local fire or police officials take over. Unless instructed otherwise the senior most
HazMat Team member will remain on-site even after properly relieved to ensure there
is a company representative on-site.
11.1.2 This person will also act as liaison between the company and offsite responders and
will ensure that company communications are communicated to offsite emergency
responders.
11.1.3 The FIC will be responsible for designating the roles of the other HazMat Team
members based upon the nature and degree of the incident.
11.2 Site Control
11.2.1 The purpose of site control is to minimize potential contamination of workers, protect
the public from the site's hazards, and prevent vandalism. Site control is especially
important in emergency situations.
11.2.2 Several site control procedures can be implemented to reduce worker and public
exposure to chemical, physical, biologic, and safety hazards.
11.2.2.1 Compile a site map
11.2.2.2 Prepare the site for subsequent activities
11.2.2.3 Establish work zones
11.2.2.4 Establish and strictly enforce decontamination procedures for both
personnel and equipment
11.2.2.5 Establish site security measures
11.2.2.6 Set up communication networks
11.2.2.7 Enforce safe work practices
11.3 The degree of site control depends on site characteristics such as the site size, nature, and
degree of the incident and the surrounding community. The appropriate sequence for
implementing these measures should be determined on a site specific basis. In many cases, it
will be necessary to implement several measures simultaneously.
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11.4 Site Map
11.4.1 A site map showing topographic features, prevailing wind direction, drainage, location of
buildings, Storage/Mix-tanks, and ponds is helpful in
11.4.1.1 Planning activities
11.4.1.2 Assigning personnel
11.4.1.3 Identifying access routes, evacuation routes, and problem areas
11.4.1.4 Identifying areas of the site that require use of personal protective
equipment
11.4.1.5 Supplementing the daily safety and health briefings of the field teams
11.4.2 The map should be prepared prior to site entry and updated throughout the course of
site operations to reflect
11.4.2.1 Accidents
11.4.2.2 Changes in site activities
11.4.2.3 Emergencies
11.4.2.4 Hazards not previously identified
11.4.2.5 New materials introduced on site
11.4.2.6 Vandalism
11.4.2.7 Weather conditions
11.4.3 Overlays can be used to help portray information without cluttering the map.
11.5 Site Work Zone
11.5.1 To reduce the accidental spread of hazardous substances by workers from the
contaminated area to the clean area, zones should be delineated on the site where
different types of operations will occur, and the flow of personnel among the zones
should be controlled.
11.5.2 The establishment of work zones will help ensure that
11.5.2.1 personnel are properly protected against the hazards present where they
are working,
11.5.2.2 work activities and contamination are confined to the appropriate areas,
and
11.5.2.3 Personnel can be located and evacuated in an emergency.
11.5.3 Contaminated area within the facility should be divided into as many different zones as
needed to meet operational and safety objectives. These zones may include
11.5.3.1 Exclusion Zone: the contaminated area
11.5.3.2 Contamination Reduction Zone (CRZ): the area where decontamination
takes place
11.5.3.3 Support Zone: the uncontaminated area where workers should not be
exposed to hazardous conditions
11.5.4 Outlining these three zones should be based on sampling and monitoring results and
on an evaluation of potential routes and amount of contaminant dispersion in the event
of a release. Movement of personnel and equipment among these zones should be
minimized and restricted to specific access.
11.5.5 Control Points to prevent cross-contamination from contaminated areas to clean areas
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should be established based on the degree and nature of the incident.
11.6 Exclusion Zone
11.6.1 The Exclusion Zone is the area where contamination does or could occur. The primary
activities performed in the Exclusion Zone are
11.6.1.1 Site characterization, such as mapping, photographing, and sampling.
11.6.1.2 Installation of wells for groundwater monitoring.
11.6.1.3 Cleanup work, such as drum movement, drum staging, and materials
bulking.
11.6.2 The outer boundary of the Exclusion Zone, called the Hotline, should be clearly marked
by lines, placards, hazard tape and/or signs; or enclosed by physical barriers, such as
chains, fences, or ropes. Access Control Points should be established at the periphery
of the Exclusion Zone to regulate the flow of personnel and equipment into and out of
the zone and to help verify proper procedures for entering and exiting are followed. If
feasible, separate entrances and exits should be established to separate personnel and
equipment movement into and out of the Exclusion Zone.
11.6.3 The Exclusion Zone can be subdivided into different areas of contamination based on
the known or expected type and degree of hazard or on the incompatibility of waste
streams. This allows more flexibility in safety requirements, operations,
decontamination procedures, and use of resources.
11.6.4 The personnel working in the Exclusion Zone may include the Field Team Leader, the
work parties, and specialized personnel such as heavy equipment operators. All
personnel within the Exclusion Zone should wear the level of protection required by the
Site Safety Plan. Within the zone, different levels of protection may be justified based
on the degree of hazard presented. The level of personal protection required in each
subarea should be specified.
11.6.5 The required level of protection in the Exclusion Zone may vary based on the degree
and nature of the incident. For example, a worker who collects samples from open
containers might require Level B protection, while one who performs walk-through
ambient air monitoring might only need Level C protection. When appropriate, different
levels of protection within the Exclusion Zone should be assigned to promote a more
flexible, effective, and less costly operation, while still maintaining a high degree of
safety.
11.7 Contamination Reduction Zone (CRZ)
11.7.1 The CRZ is the transition area between the contaminated area and the clean area. This
zone is designed to reduce the probability the clean Support Zone will become
contaminated or affected by other site hazards.
11.7.2 The distance between the Exclusion and Support Zones provided by the CRZ, together
with decontamination of workers and equipment, limits the physical transfer of
hazardous substances into clean areas.
11.7.3 The boundary between the CRZ and the Exclusion Zone is called the Hotline. The
degree of contamination in the CRZ decreases as one moves from the Hotline to the
Support Zone, due both to the distance and the decontamination procedures.
11.7.4 Decontamination procedures take place in a designated area within the CRZ called the
Contamination Reduction Corridor (CRC). They begin at the Hotline. At least two lines
of decontamination stations should be set up within the CRC: one for personnel and
one for heavy equipment. A large operation may require more than two lines. Access
into and out of the CRZ from the Exclusion Zone is through Access
11.8 Control Points: one each for personnel and equipment entrance, one each for personnel and
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equipment exit, if feasible.
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11.9 The boundary between the Support Zone and the CRZ, called the Contamination Control Line,
separates the possibly low contamination area from the clean Support Zone. Access to the CRZ
from the Support Zone is through two Access Control Points if feasible: one each for personnel
and equipment. Personnel entering the CRZ should be required to wear the personal protective
clothing and equipment prescribed for working in the CRZ. To reenter the Support Zone,
workers should remove any protective clothing and equipment worn in the CRZ, and leave
through the personnel exit Access Control Point.
11.10 The personnel stationed in the CRZ are usually the Site Safety Officer, a Personnel
Decontamination Station (PDS) Operator, and the emergency response personnel. Additional
personnel may assist the PDS Operator by conducting abbreviated decontamination procedures
for sample containers.
11.11 The CRZ must be well designed to facilitate
11.11.1 Decontamination of equipment, PDS operators, personnel, and samples.
11.11.2 Emergency response: transport for injured personnel (safety harness, stretcher), first-
aid equipment (such as bandages, blankets, eye wash, splints, and water), and
containment equipment (absorbent, fire extinguisher).
11.11.3 Equipment resupply: air tank changes, personal protective clothing and equipment
(such a booties and gloves), sampling equipment (such as bottles and glass rods), and
tools.
11.11.4 Sample packaging and preparation for onsite or offsite laboratories.
11.11.5 Worker temporary rest area: toilet facilities, bench, chair, liquids, and shade. Water and
other potable liquids should be clearly marked and stored properly to ensure all glasses
and cups are clean. Wash facilities should be located near drinking facilities to allow
employees to wash before drinking. Drinking, washing, and toilet facilities should be
located in a safe area where protective clothing can be removed. Facilities should be
cleaned and inspected regularly.
11.12 Appropriate protective measures should be taken by maintenance workers.
11.12.1 Drainage of water and other liquids that are used during decontamination.
11.12.2 Personnel within the CRZ should be required to maintain internal communications, line-
of-sight contact with work parties, work party monitoring (e.g., for air time left, fatigue,
heat stress, hypothermia), and site security.
11.13 Support Zone
11.13.1 The Support Zone is the location of the administrative and other support functions
needed to keep the operations in the Exclusion and CRZ running smoothly. Any
function that need not or cannot be performed in a hazardous or potentially hazardous
area is performed here. The Command Post Supervisor should be present in the
Support Zone. Other personnel present will depend on the functions being performed,
and may include the Project Team Leader and field team members who are preparing
to enter or who have returned from the Exclusion Zone.
11.13.2 Personnel may wear normal work clothes within this zone. Any potentially contaminated
clothing, equipment, and samples must remain in the CRZ until decontaminated.
11.13.3 Support Zone personnel are responsible for alerting the proper agency in the event of
an emergency. All emergency telephone numbers, change for the telephone (if
necessary), evacuation route maps, and vehicle keys should be kept in the Support
Zone.
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11.13.4 Support facilities are located in the Support Zone. Consider the following factors when
placing them.
11.13.4.1 Accessibility. Topography, open space available, locations of highways and
railroad tracks, and ease of access for emergency vehicles.
11.13.4.2 Resources. Adequate roads, power lines, telephones, shelter, and water.
11.13.4.3 Visibility. Line-of-sight to all activities in the Exclusion Zone.
11.13.4.4 Wind direction. Upwind of the Exclusion Zone, if possible.
11.13.4.5 Distance. As far from the Exclusion Zone as practicable.
11.14 The buddy system WILL be used during all emergency responses—HazMat Team Members
responding to the incident will work in pairs to mitigate the hazards involved. Specific roles may
include
11.14.1 Decontamination
11.14.2 Investigation
11.14.3 Liaison Officer
11.14.4 Service
11.14.5 Safety Officer
11.14.6 Those performing the hazard mitigation (strike team)
11.15 Emergency Response Team Organization
11.15.1 A current flowchart for the facility can be found in EHS-13F5.
11.16 The exact number of emergency responders (HazMat Team) will depend on the nature, type,
severity, and time of the incident.
12.0 MEDICAL AND FIRST AID
12.1 If an employee is injured, seek immediate medical attention by contacting your supervisor.
12.2 In non-emergency situations, the Supervisor must be notified immediately of an accident. In the
event of a serious injury, the Supervisor is to be contacted after medical attention has been
provided to the injured employee (i.e., 911 called).
12.2.1 The Supervisor and the injured employee must complete the "Accident Investigation"
report (EHS-06).
12.2.2 A non-emergency accident requires the Supervisor or Safety Manager to be notified
before a medical facility is visited. Workers Compensation has an approved Physician
list that is located in this SOP and on the Safety Manager’s door.
12.2.3 The injured employee is required to take a post-accident drug screen within 24 hours of
the injury.
12.3 Location of Emergency First Aid Kits
12.3.1 HazMat Team members are the only people authorized to administer first aid and use
the first aid kits. First Aid kits are generally located in the HazMat closet, and/or the lab
(if applicable). The HazMat first aid kits are under the supervision of the Safety Manger
(See EHS-19). Please verify the location of your closest first-aid kit.
12.3.2 An additional general use first aid kit is located in the dispatch office under the
supervision of the Plant Superintendent. This kit is for minor scrapes and cuts. (Branch
locations may differ—verify where your nearest first-aid kit is located).
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12.4 Chlorine Emergencies (see Pamphlet 63 from the Chlorine Institute: First Aid, Medical
Management/Surveillance and Occupational Hygiene Monitoring Practices for Chlorine,
Edition 8).
12.4.1 FIRST AID—first aid is the immediate temporary treatment given to an exposed
individual. Prompt action is essential. Reassurance to the individual will help to
alleviate anxiety. When indicated, medical assistance must be obtained as soon as
possible. Never give anything by mouth to an unconscious or convulsing person. If
chlorine has saturated an exposed individual’s clothes and/or skin, decontamination
should be done by removing affected clothing and showering as appropriate.
12.4.2 Responders should take the necessary precautions to protect themselves from any
exposure to chlorine while administering first aid and should move the victim from any
contaminated area as quickly as possible.
12.4.3 INHALATION—an individual with chlorine inhalation exposure should be evaluated for
adequate airway, breathing and circulation after the inhalation. If breathing has
apparently ceased, the victim should be given cardiopulmonary resuscitation (CPR)
immediately. If breathing has not ceased, the exposed individual should be placed in a
comfortable position. The person should sit in an upright position with the head and
trunk elevated to a 45-60 degree position (unless there is a medical
contraindication). Slow, deep breathing should be encouraged. Vital signs (respiratory
rate, pulse, and blood pressure) and oxygen saturation should be obtained if trained
personnel and equipment are available. Suitable equipment for the administration of
oxygen should be available either on site or at a nearby facility. Such equipment
should be periodically tested.
12.4.4 Historically, oxygen therapy, specifically humidified oxygen, has been considered the
primary treatment for chlorine inhalations. Humidified oxygen is preferred since the
humidity soothes the irritation to the mucous membranes caused by the chlorine.
Oxygen without the humidity can have a drying effect, thus potentially aggravating the
irritant symptoms. However, if humidified oxygen is not available, oxygen without the
humidity should not be withheld if oxygen therapy is indicated. With the advance in
technology, equipment (pulse oximeter) is now available which can quickly measure
the oxygen saturation in an indivi dual. This measurement may be helpful in
deciding whether supplemental oxygen is needed after a chlorine inhalation.
12.4.5 Oxygen therapy may not be necessary for all cases of chlorine inhalation. However, in
any case in which an individual with a chlorine inhalation continues to be symptomatic
after leaving the area of exposure, oxygen therapy is recommended unless it can
be determined it is not needed. The circumstances in which oxygen therapy is not
needed should be defined in advance by a physician, based on the clinical findings and
a case-by-case determination made by first aid providers specifically trained in this
area.
12.4.6 ADMINISTRATION OF OXYGEN—oxygen should be administered by first aid
providers trained in the use of the specific oxygen equipment under the guidance of a
licensed health care professional.
12.4.7 If a pulse oximeter is not available, oxygen therapy is recommended for any individual
who has inhaled chlorine and continues to be symptomatic after leaving the area of
exposure.
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12.4.8 If a pulse oximeter is available, the following findings comprise a base list of situations
in which oxygen therapy is generally indicated to be given by first aid providers after a
chlorine inhalation. Other criteria may be added to this list if specifically
recommended by a physician:
12.4.8.1 Sustained pulse-oximetry readings <92%; or
12.4.8.2 The individual is in obvious respiratory distress (including, but not limited
to rapid respirations, difficulty breathing, using accessory muscles for
respiration, continuous uncontrollable coughing, wheezing); or
12.4.8.3 The exposed individual is having “symptoms of concern”, such as
significant chest pain/tightness, extreme weakness, altered/declining
mental status, or the individual is diaphoretic (clammy/pale/sweating not
due to environmental conditions) etc., especially if these or other
significant symptoms occur with an individual with a past history of cardiac
problems or asthma; (NOTE: “symptoms of concern” generally do not
include the typical upper respiratory tract irritation symptoms which occur
with mild chlorine gas inhalations such as mild/moderate coughing, initial
difficulty “catching one’s breath”, mild/moderate shortness of breath,
irritated throat, runny nose, congestion, headache, and/or mild nausea).
12.4.9 NOTE: It is recommended a physician be consulted regarding any individual meeting
one or more of the above criteria in order to determine whether further evaluation
and/or treatment is indicated.
12.4.10 If oxygen therapy is indicated, it should be administered until the symptoms
resolve. Whenever oxygen is discontinued after symptoms resolve, the individual
should then be observed for 30–60 minutes while breathing room air. If significant
symptoms do not resolve within 60 minutes of oxygen therapy, or symptoms
return/worsen and/or the oxygen saturation (when pulse oximetry is available) falls
below 92%, it is recommended oxygen therapy be restarted (if it had been discontinued)
and further evaluation by a physician be provided.
12.5 Administration of Humidified Breathing Air—not all individuals who have inhaled chlorine require
oxygen therapy. It is recommended the circumstances in which oxygen therapy is not needed
should be defined in advance by a physician and a case-by-case determination made by first
aid providers specifically trained in this area.
12.6 In situations where it has been determined oxygen therapy is not needed, but the individual
with an inhalation exposure has irritant symptoms, humidified air may be provided for
symptomatic care. While breathing humidified air, the individual should be closely monitored for
30–60 minutes. If the individual continues to show no signs or symptoms for which oxygen
would be indicated, the humidified air can be stopped. Observation should continue for an
additional 30 minutes while the individual is breathing room air so as to ensure there is no
deterioration of the individual's condition. Oxygen therapy should be started at any time
during the above process if symptoms worsen to the point oxygen is indicated (12.4.8).
Further evaluation by a physician should be provided in any case in which oxygen therapy is
provided.
12.7 Symptomatic care—other symptomatic care measures, such as cool compresses to the face
and over-the-counter medications, may help to minimize symptoms. Over-the-counter
medications which may be helpful include
12.7.1 Irritated/sore throat—throat lozenges
12.7.2 Dry cough—dextromethorphan, guaifenesin
12.7.3 Headaches—acetaminophen, aspirin, ibuprofen
12.7.4 Upset stomach—antacids
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12.8 CONTACT WITH SKIN—if liquid chlorine has contaminated the skin or clothing, an emergency
shower should be used immediately and contaminated clothing should be removed under
the shower. Flush contaminated skin with copious amounts of tepid water for 15 minutes or
longer. Thermal burns, due to the cold temperature of liquid chlorine, may be more damaging
than any chemical reaction of chlorine and the skin. Exposure to gaseous chlorine can irritate
the skin. Do not attempt chemical neutralization or apply any salves or ointments to damaged
skin. Refer to a qualified health care provider if irritation persists after irrigation or if skin is
broken or blistered.
12.9 CONTACT WITH THE EYES—if the eyes have been irritated due to exposure to chlorine, they
should be flushed immediately with copious quantities of tepid water for at least 15 minutes.
12.9.1 Never attempt to neutralize with chemicals.
12.10 The eyelids should be held apart during this period to ensure contact of water with all
accessible tissue of the eyes and lids. Medical assistance must be obtained as soon as
possible. If such assistance is not immediately available, eye irrigation should be continued for
a second 15-minute period. Nothing but water should be applied unless ordered by a qualified
health care provider.
12.11 MEDICAL MANAGEMENT OF CHLORINE EXPOSURES (SUBSEQUENT TO FIRST AID)—the
following information is intended for general guidance only. Final determination of specific
medical intervention(s) should only be made by qualified medical personnel upon full
consideration of each patient’s overall medical condition. The Institute recommends that any
treatment be done in conjunction with a full medical assessment by qualified personnel.
12.12 GENERAL PRINCIPLES
12.12.1 All individuals who have developed symptoms as a result of an acute overexposure to
chlorine gas by inhalation should be placed under the supervision of qualified health
care personnel.
12.12.2 There is no known specific antidote for acute chlorine exposure. Prompt medical
assessment and supportive measures are necessary to obtain good therapeutic results.
12.12.3 If the individual is unconscious, take steps necessary to protect the airway from
obstruction.
12.12.4 Alleviate anxiety by communicating with the patient the various procedures
undertaken and elicit his/her cooperation, especially in breathing exercises.
12.12.5 Position the patient with the head and trunk elevated to a 45-60° position
(assuming there are no medical contraindications).
12.12.6 Encourage slow, regular respiration.
12.12.7 Oxygen therapy should be considered in all individuals who continue to be
symptomatic after a chlorine inhalation. If after medical evaluation it is determined an
individual does not need oxygen therapy, humidified air may be helpful an alleviating
some of the residual irritant respiratory symptoms.
12.13 THERAPY FOR SPECIFIC PHYSIOLOGICAL DISTURBANCES
12.13.1 Pulmonary Edema—once pulmonary edema has developed from acute chlorine
inhalation, the treatment is basically that of acute respiratory failure. This individual
should be under the care of a health care professional familiar with this disease
process in an intensive care setting. It should be noted there is inconclusive evidence
regarding the use of corticosteroids to prevent or alleviate pulmonary edema after an
acute chlorine inhalation.
12.13.2 Bronchospasm (Wheezing)—bronchodilators administered either by nebulization, or
subcutaneously, may be beneficial if patient is having bronchospasm (wheezing).
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12.13.3 Acute Anxiety—acute anxiety (fear and/or apprehension) by an employee exposed
to chlorine may occur. Reassurance is best accomplished without the use of
sedatives. Use of sedatives should only be considered by qualified medical
personnel following medical assessment and only employed under close supervision of
respiratory function to monitor progress.
12.13.4 Delayed Effects—after an acute exposure to chlorine, pulmonary function usually
returns to pre-exposure levels in 7 to 14 days, and complete recovery usually occurs.
Post-incident spirograms may be used for clinical follow-up. Cases of Reactive
Airways Dysfunction Syndrome (RADS), a chemical irritant-induced asthma, have been
reported after significant chlorine inhalation.
12.13.5 The inhalation of any irritating gas may lead to delayed reactions such as
pulmonary edema. Since physical exercise appears to have some relation with the
incidence of delayed reaction, it is recommended any patient who has had severe
inhalation exposure should be kept at rest for a period of observation. During the
period of observation, the avoidance of irritants (e.g., cigarette smoke, dust, etc.) is
recommended. The length of observation will depend on the clinical assessment of the
exposed individual. Observation may be required up to several days after exposure.
Excitement, apprehension and/or emotional distress may persist for some period of
time following a severe exposure.
13.0 FIRE SUPPRESSION PLAN (29 CFR 1910.157)
13.1 Responsibilities
13.1.1 Management is responsible for seeing fire-prevention procedures are established and
enforced; fire suppression systems are inspected regularly and maintained; supervisors
are trained to use fire extinguishers for incipient fires; and employees are trained to use
evacuation routes and procedures.
13.1.2 Supervisors are responsible for monitoring the use of flammable materials; training
employees in safe storage, use and handling of flammables; and ensuring storage
areas for flammables are maintained properly.
13.1.3 Employees are responsible for following company procedures for the safe storage, use
and handling of flammable materials, and reporting unsafe conditions to their immediate
supervisor.
13.2 Definitions
13.2.1 Fires are classified according to the type of fuel or material.
13.2.1.1 Class A—wood, paper and cloth
13.2.1.2 Class B—flammable gases, liquids and greases
13.2.1.3 Class C—fires in live electrical equipment, or involving materials near
electrically powered equipment
13.2.1.4 Class D—combustible metals such as magnesium, zirconium, potassium
and sodium
13.3 Ignition Sources—eliminate all non-essential ignition sources where flammable materials are
used or stored. For example
13.3.1 Keep sources of open flame (such as welding and cutting torches, furnaces, matches,
and heaters) away from operations involving flammables.
13.3.2 Do not cut or weld equipment containing flammable liquids unless the equipment has
been emptied and purged with a neutral gas such as nitrogen.
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13.3.3 Prohibit chemical ignition sources (such as DC motors, switches, and circuit breakers)
in areas where flammable materials are stored or handled.
13.3.4 Use only non-sparking tools in areas where flammables are stored or handled.
13.3.5 Eliminate the possibility of static sparks—caused by electron transfer between two
contacting surfaces—in flammable storage or handling areas.
13.4 Incompatible Materials (See EHS-16 For More Information)
13.4.1 Store materials such as oxidizers and organic peroxides, which produce large amounts
of oxygen when they decompose, in an area separate from flammable materials.
13.5 Fire Extinguishers
13.5.1 Portable fire extinguishers can be very effective for fighting fires in their incipient stages.
A person who is well-trained in fire-extinguisher use can save both lives and property.
Portable fire extinguishers must be available even when other firefighting measures are
available. For extinguishers to be effective in a fire situation, proper selection,
inspection, and maintenance are essential.
13.5.2 Fire Extinguishers are located throughout the facility for us in an emergency.
13.5.3 Make sure all fire extinguishers are placed in conspicuous locations, clearly visible, and
easily accessible.
13.5.4 Keep all fire extinguishers fully charged and operable, and in their proper locations at all
times.
13.6 Fire Safety Inspections And Housekeeping
13.6.1 Supervisors and safety committees are responsible for work site inspections to ensure
compliance with the company Fire Safety Program. These inspections should address
housekeeping issues, proper storage of chemicals, access to fire extinguishers, and
emergency evacuation routes.
13.7 Emergency Exits
13.7.1 Every exit must be clearly visible, or the path to it conspicuously identified in such a
manner that every occupant of the building will know the best way to get out of the
building in a fire or other emergency.
13.7.2 Exits must never be obstructed. Any door or passageway that is not an exit or path to
an exit must be identified with a sign that reads ‘Not An Exit’ or a sign that indicates its
actual use, such as storage closet, etc.
13.7.3 All exit signs must either be self-illuminating, or illuminated by a reliable external light
source.
13.8 Emergency Plan For Persons With Disabilities
13.8.1 First line supervisors are responsible for assisting persons with disabilities under their
supervision, and must choose an alternate to assume responsibility in the supervisor’s
absence. The supervisor, alternate and worker with the disability will be trained on
available escape routes. A list of persons with disabilities must be kept on file in the
(personnel, safety director’s office). Company visitors with disabilities will be assisted in
the same manner as employees.
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13.9 Fire Emergency Procedures
13.9.1 The person who discovers a fire should activate the nearest alarm, and notify his or her
supervisor and other building occupants.
13.9.2 You should only attempt to fight a fire if
13.9.2.1 The fire department has been notified
13.9.2.2 The fire is small and confined to its point of origin
13.9.2.3 You have an escape route available and can fight the fire with your back to
the exit
If you cannot answer yes to all of these conditions; immediately leave the area!
13.9.3 Be sure you have a proper, fully functioning fire extinguisher, and are trained on how to
use it before attempting to suppress a fire.
13.9.4 Leave your work area if you hear a fire alarm. Close all windows and doors, and turn off
any sources of fuel or points of ignition when you leave; evacuate the building and
move away from exits, and assemble in designated evacuation location in the company
evacuation plan. Remain outside until a competent authority says it is safe to re-enter
the building.
13.10 Fire Extinguisher Training
13.10.1 All new employees will receive orientation training on the proper use of fire
extinguishers. This may include watching a video, a PowerPoint presentation or a
verbal discussion.
13.10.2 Existing employees will be retrained annually on the safe use of fire extinguishers. This
training will consist of identifying and familiarization with the PASS acronym
13.10.2.1 P – Pull the pin
13.10.2.2 A – Aim
13.10.2.3 S – Squeeze the trigger
13.10.2.4 S – Sweep side to side
14.0 EVACUATION PROCEDURES
14.1 After the announcement (page) has been made to evacuate the working areas of the plant,
Supervisors will shut-down their operations. For areas with more involved shutdown
procedures, the Supervisor will follow the emergency shut-down SOP specific to their area, if
applicable.
14.2 The evacuation location will be determined by the HazMat team leadership. Once determined,
the location will be paged to all employees. Evacuation routes of Thatcher buildings are as
follows:
14.2.1 Primary evacuation location (EHS-13F9)
14.2.2 Secondary evacuation location (EHS-13F10)
14.3 Evacuation routes (preferred routes)
14.3.1 Each facility and building have specified unique (preferred) evacuation routes (map)
and they can be found in the forms associated with this SOP (EHS-13F14).
14.4 Upon notification of an emergency requiring an evacuation, all personnel should use the nearest
unobstructed exit and head to the primary evacuation location.
14.5 Supervisors will designate a roll call employee. This employee will gather the Area personnel in
the designated area and take roll as the employees assemble. The HazMat Team will be
notified of missing persons and enter into the plant for rescue after they have the appropriate
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Personal Protective Equipment (PPE).
14.6 The role sheet, pen and clip board, required for taking roll, are stored in the HazMat closet or in
the office.
14.6.1 Red Clip Boards are for day shift personnel (7:00 AM through 3:30 PM)
14.6.1.1 Every building has a designated person to take roll.
14.6.2 Blue Clip Boards are for swing shift personnel (3:30 PM through 7:00 AM)—Where
applicable
14.6.2.1 Every building has a designated person to take roll (generally this will be
the supervisor).
14.6.3 These sheets will be updated as required by the Safety Manager.
14.7 Any protective measures or containment efforts will be performed by the ERT. These operations
will continue until the problem is corrected or until outside agencies mandate (acquire) control.
14.8 The Office/Dispatch check-in (Scale house) will be responsible for any common carriers which
have signed in but have not yet entered into the facility. These drivers will be gathered in the
same manner as the area personnel are gathered.
14.9 The common carriers that have entered the facility will be the responsibility of the Supervisor
where he is loading; the Supervisor will include these drivers with their personnel.
14.10 All transportation vehicles will be checked for drivers in their sleeping berths. They will be
informed of the emergency, evacuated, and accounted for.
14.11 Evacuation Plans—emergency evacuation escape route plans are posted in key areas
throughout the facility. All employees shall be trained on primary and secondary evacuation
routes and locations.
14.12 Employee Accountability—in the event of an evacuation, all occupants shall promptly exit the
building via the nearest exit. Go to your designated evacuation location and report to your
supervisor. A role call will be complete to account for all employees, contractors, and visitors.
14.13 Building Re-Entry—once evacuated, no one shall re-enter the building(s), with the exception of
the HazMat (ERT) Team in searching for unaccounted personnel. Once the Fire Department or
other responsible agency has notified us the building is safe to re-enter; only then, shall
personnel be allowed to return to their areas of work.
14.14 Site Security and Control—in the case of an evacuation, site security shall be the responsibility
of the senior most HazMat Team member on-site. Any person who is not directly related to the
emergency at hand will not be allowed on Thatcher Company property for the duration of the
incident.
14.15 Contractor Responsibility—in the event of evacuation, the manager or designee is responsible
to account for all contractors on-site at that time. To accomplish this, contractors will sign-in and
out according to EHS-14. Once accounted for, contractors will be informed of the nature of the
incident and be instructed on when they may re-enter the facility.
15.0 LOCAL, STATE, AND NATIONAL EMERGENCY PHONE NUMBERS
15.1 A current list of these important phone numbers in maintained in EHS-13F4.
15.2 For chemical spills or releases involving quantities equal to or greater than reportable quantities,
the Plant Manager, Technical Director, or Safety Manger will assign a person to immediately
call the agencies listed in EHS-13F4.
15.2.1 The local Fire Department/Local Emergency Planning Committee (LEPC)
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15.2.2 National Response Center (NRC)
15.2.2.1 The National Response Center (NRC) is the sole federal point of contact for
RQ chemical spills and releases. The NRC operates 24 hours a day, 7
days a week, 365 days a year. A report will be generated and sent to the
local Fire Department and EPA automatically. The Fire Department and
EPA still require the notification from Thatcher Company even with the
generated NRC report.
15.2.3 EPA Contact
15.2.3.1 This may be a state agency or to a local EPA office—check your area for
applicability (EHS-13F4).
15.2.4 For accidental spill/release discharges into the sewer (POTW—Publically Owned
Treatment Works), Where applicable.
15.2.4.1 Within five (5) days of a spill/release discharge, a designated Thatcher
Company employee shall submit to the POTW manager a detailed written
report describing the cause of the discharge and the measures to be taken
to prevent future occurrences.
15.3 Qualified individuals in the lab and engineering departments will generate an estimate of the
hazardous material quantity that was released into the environment. If the amount meets or
exceeds the reportable quantity, the notification must be made to the proper authorities.
15.4 OSHA must be contacted by phone within 8-hours, if the following conditions are met. (Note: if
the Area OSHA office cannot be contacted, the 1-800-321-OSHA may be called.)
15.4.1 Death of any employee.
15.4.2 Inpatient hospitalization of three or more employees (Federal OSHA).
15.4.3 Arizona—employers must report to ADOSH all workplace accidents involving a fatality,
or involving the hospitalization of three or more employees. This report must be
made within eight (8) hours following the incident. To report an incident to ADOSH,
call [phone] or toll-free at [phone]. If you call outside of regular business
hours, please leave a message and someone will return your call as soon as possible.
15.4.4 California—CAL/OSHA must be contacted if one (1) person is hospitalized. (a) Every
employer shall report immediately by telephone or telegraph to the nearest District
Office of the Division of Occupational Safety and Health any serious injury or illness, or
death, of an employee occurring in a place of employment or in connection with any
employment. Immediately means as soon as practically possible but not longer than 8
hours after the employer knows or with diligent inquiry would have known of the death
or serious injury or illness. If the employer can demonstrate exigent circumstances
exist, the time frame for the report may be made no longer than 24 hours after the
incident. Title 8, California Administrative Code.
15.4.5 Florida—follow Federal guidelines listed in 15.4.
15.4.6 Idaho—follow Federal guidelines listed in 15.4.
15.4.7 Montana—follow Federal guidelines listed in 15.4.
15.4.8 Nevada—employers must report to NVOSHA all workplace accidents involving a fatality
of one or more employees, or involving hospitalization of three or more employees,
within eight (8) hours after learning of the accident. To report an incident to NVOSHA,
call [phone] (Southern Nevada) or [phone] (Northern Nevada).
15.4.9 New York—follow Federal guidelines listed in 15.4.
15.4.10 Utah—UOSH must be contacted if one (1) person is hospitalized.
15.4.11 Check local state regulation for federal OSHA variations.
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16.0 PERSONNEL TRAINING
16.1 All employees will have sufficient training to recognize an emergency should it arise. Training
through first responder level in accordance with OSHA standard 29 CFR 1910.12 (q) (6) (ii)
shall be given to all employees. All production employees shall receive training through the
hazardous materials specialist level, as defined by OSHA 29 CFR 1910.12 (q) (6) (iv). Through
training and hands-on experience, employees will be taught how to recognize potential hazards
and correct them (or at least minimize them) before they become emergencies. Engineering
controls have also been put into place to help prevent emergencies from happening. Ongoing
training may be given through bi-monthly meeting and semiannual drills.
16.2 All HazMat Team members have received training to the 40 hour HAZWOPER level (29 CFR
1910.120). All HazMat Team members also receive annual 8 hour refresher training as required
by the OSHA standard.
16.3 In addition, facility personnel will have annual refresher training of the current Emergency
Response Plan (ERP).
16.4 Only personnel with appropriate training will be allowed to respond to an emergency situation.
All plant employees will receive annual training on this SOP during a safety meeting. This
includes instructions of evacuation locations during an evacuation. Employees are trained on
the hazards of Chlorine, Sulfur Dioxide, and Ammonia gases. Information concerning SDS,
forms, placards, and safety are read and tested during this orientation meeting.
16.5 ERT (Emergency Response Team) members shall respond to chemical and other hazardous
plant emergencies. Before an employee can become a first responder, they must have the 40-
Hour HAZWOPER training followed by the annual 8-hour refresher courses to remain current.
Annual CPR and 3-year first aid certifications are required.
16.6 Thatcher Transportation Drivers and HazMat team members will be trained in the use of
Emergency Kits. Emergency Kits are designed to contain most leaks which may be
encountered in compressed gas shipping containers. They are designated
16.6.1 Kit A—for 150 lb. cylinders
16.6.2 Kit B—for ton containers
16.6.3 Kit C—for tank cars, and tank trucks
16.7 All trucks transporting these gases will carry the kits necessary for their shipment. Drivers using
any equipment, including the A, B, and C Kits, Fire Extinguishers, and respirators will be
reported to the Safety Manager. An incident investigation will follow any use of emergency
equipment.
16.8 The Supervisors are responsible of all safety equipment used in chemical gas leaks, spills, fires,
and other emergencies. Area fire extinguishers are checked bi-monthly and recorded on the
Safety Meeting notes
16.9 All employees will be trained on the facility evacuation plan during their new employee
orientation and annually thereafter. If for any reason the specifics of the EAP changes,
employees will receive training on these changes to the level of understanding. Additionally, if
an employee’s position changes within Thatcher Company they will receive training which
pertains to their new position.
16.10 At least once per year this plan will be tested in an evacuation drill. During these drill all alarms
systems will be tested.
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17.0 SAFE DISTANCES AND PLACES OF REFUGE (where applicable)
17.1 If the hazard is dependent on wind direction, as is the case with compressed gasses; use the
windsocks and observe the direction of the wind. When evacuating from a gas hazard, move
perpendicular to the wind (Wind sock).

17.2 The distance required for isolation and protective actions taken for a hazardous material release
is dependent on the nature of material released and size of spill. Please refer to the Emergency
Response Guidebook for specific distances. Minimum isolation distance is 50 feet and the
minimum evacuation distance is 150 feet; use this guideline until the Emergency Response
Guide (ERG) can be consulted, then implement the evacuation distance recommended by the
ERG.
17.3 Places of refuge within Thatcher Company do not exist as most hazards involved with a fire;
release or other emergency render the need to evacuate and not stay in a location near the
hazard.
17.4 In a severe incident requiring a lengthy amount of time for mitigation (clean-up) affected
employees will be sent home for the rest of their shift or as needed.
18.0 DECONTAMINATION, PPE, AND EMERGENCY EQUIPMENT
18.1 Decontamination will be performed by personnel appropriately attired in the PPE dictated by the
incident. Decontaminations procedures will only be performed by HazMat Team members who
are certified and have received proper training. However, the nature and characteristics of the
chemicals used at stored at Thatcher Company facilities are NOT those which require the
normal multi-stage HazMat clean-up and decontamination; as such, Thatcher Company will
more than likely use copious amounts of water spray to “decontaminate” personnel and
equipment.
18.2 Personnel and equipment need to go through decontamination whenever they are exposed to a
contaminated area. The decontamination area will be set up in a location that will minimize the
exposure contaminated equipment and employees. Water will be used to decontaminate
equipment and personnel. The contaminated water produced will be collected and disposed of
in accordance with all federal, state, and local laws governing such waste. Areas for
decontaminating may depend on the specific incident, but may take place where hoses and
water are available.
18.3 The level of PPE and the equipment used to contain the release will depend on the size and
type of leak (see EHS-08).
18.4 There is a generous supply of neutralizing agents kept in the warehouse to handle a spill of
chemical substances that would require neutralization.
19.0 OFF SITE EMERGENCIES WITH CHEMICALS SUPPLIED BY THATCHER COMPANY
19.1 Any carrier, customer, or civil authority having a chemical emergency can be put in contact with
an appropriate chemical emergency group by telephoning CHEMTREC telephone number (1-
800-424-9300) for the United States, or the CANUTEC telephone number (1-613-996-6666) for
Canada. These facilities are open 24-hours, 7-days a week, and are able to provide prompt
Move North or South if
the wind is from the east or west. Gas
Relea
se
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initial advice from pre-printed material to personnel at the scene.
19.2 Where expert advice or help at the scene appears necessary, CHEMTREC and CANUTEC
operate as Emergency Dispatch Agencies. In such cases, the Emergency Dispatcher will enter
the pertinent information on an appropriate dispatch report. This person will determine the
preferable chemical emergency group using the Location Guide.
19.3 At times, Thatcher Company may send company personnel to help clean a spill—when this
occurs, only personnel who have been HAZWOPER trained may be considered for offsite spill
management.
20.0 SHUT DOWN CHECKLIST
20.1 Procedures to be followed by employees who remain to operate critical plant operations before
they evacuate.
20.2 Employees may be required to operate fire extinguishers or shut down gas and/or electrical
systems and other special equipment that could be damaged if left operating or create
additional hazards to emergency responders (such as releasing hazardous materials) 29 CFR
1910.38(c)(3).
20.3 A full list of applicable equipment that may require lengthy shut-down procedures is maintained.
EHS-13F12 lists building and equipment that must be shut down before evacuation and the
person responsible for doing so.
21.0 CRITIQUE OF RESPONSE AND FOLLOW-UP
21.1 A critique of the response to the release will be performed no more than two weeks after the
date of the incident.
21.2 The critique will involve a written statement from all of the personnel directly involved in the
incident.
21.3 An analysis will be done on all other written reports to determine what could have been
improved upon in the response and what can be done in the future to prevent a similar incident
from happening again.
21.4 Additional training will be given in accordance with the results of the analysis to all of the
personnel affected by the incident.
21.5 Any engineering controls that can further reduce the likelihood of a similar accident from
happening again will be implemented.
21.6 A written record of incidents will be archived.
21.7 Any equipment deficiencies, such as a non-functioning alarm will be documented for repair.
Employees will be notified the alarm system or other equipment is non-functioning and down for
repair.
22.0 EMERGENCY PHONE NUMBERS
22.1 A current list of important phone numbers can be found in EHS-13F1.
22.2 A current list of the HazMat Emergency Response Team members and their phone numbers
can be found in EHS-13F2.
23.0 MANAGEMENT PLAN, SITE CONTACTS AND DOCUMENT CONTROL
23.1 Covered in EHS-13F15.
24.0 MAXIMUM INVENTORIES OF HHCs
24.1 A current list of maximum possible inventories of all chemicals stored on-site is located in the
Hazardous Materials Inventory Summary (HMIS) and is part of the Hazardous Materials
Management Plan (HMMP). The HMMP is updated at least annually and submitted to any
required local governing fire departments. It is the Plant Manager's responsibility to ensure
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REV: 1

these limits are not exceeded.
EMERGENCY RESPONSE PROGRAM PAGE: 28 of 28
(Emergency Action Plan (EAP) and Fire Prevention Plan) SOP: EHS-13
REV: 1

REVISION HISTORY

Rev Date
Author
Section Affected Change Description
0 09/21/2015
D. Bauer
All

Initial release.
This Document revised from SF-13.
1 APPROVALS
S. Cockcroft
All
24.0 Inventories
Update code references.
Add.

EMERGENCY RESPONSE PROGRAM
(Emergency Action Plan (EAP) and Fire Prevention Plan) SOP: EHS-13
REV: 1

REFERENCES
LIST OF EMERGENCY RESOURCES (Standard Operating Procedures)—the following list contains
Thatcher Company "Standard Operating Procedures” pertaining to different aspects of possible hazards
and/or contain elements of safety.
EHS-01 Lockout/Tagout Program
EHS-02 (SF-02) Confined Space Entry
EHS-08 (SF-08) Preparing and Suiting Up in a HazMat Situation Requiring Self-Containment
EHS-09 (SF-09) Disciplining and Documenting Safety and Conduct Violations
EHS-11 (SF-11) Hazard Communication
EHS-12 (SF-12) Respiratory Protection
EHS-14 Security Program
EHS-16 (SF-16) Storage of Incompatibles
EHS-19 (SF-19) Bloodborne Pathogen Program
EHS-26 Employee Injury and Illness Plan (IIPP)
EHS-29 (IH-01) Recording and Reporting Chemical Releases
EHS-47 (SF-25) Emergency Shutdown Procedures for SO2 and Ammonia Processes
EHS-49 (SF-18) Chlorine Room Emergency Shutdown Procedures
EHS-52 (MC-26) Solid and Liquid Waste Handling Procedure
EHS-70 (MBE-40) Reuse of DOT Packaging Containers
EHS-72 (HM-126) Hazardous Material Training and Certification
PS-01 Process Safety Management
PS-11 (SF-06) Accident/Incident Investigation

OSHA 29 CFR 1910
Nevada NAC Ref. 459
FORMS INDEX
FORMS
Forms listed as the generic numbering with site specific forms, using site annotation, being created
where applicable.

EHS-13F1 Emergency Phone Numbers
EHS-13F2 HazMat Emergency Response Team Members
EHS-13F3 Adjacent Business
EHS-13F4 Local, State, and National Emergency Phone Numbers
EHS-13F5 Emergency Response Team Organization Flow Chart
EHS-13F6 List of Doctors
EHS-13F7 Thatcher Company Map
EHS-13F8 Thatcher Company Evacuation Check-In Sheet
EHS-13F9 Primary Evacuation Location
EHS-13F10 Secondary Evacuation Location
EHS-13F11 Building Evacuation Exits, Extinguishers, SCBAs, Eyewash/Showers
EHS-13F12 Shut Down Operations (List of Buildings and Equipment that Must Be Shut Down Before
Evacuation and the Person Responsible for Doing So)
EHS-13F13 Thatcher Company Alarm System Information
EHS-13F14 Thatcher Company Evacuation Map (Preferred Routes)
EHS-13F15 Management Plan, Site Contacts and Document Control
EHS-13F16 Risk Assessment
LOGS
None

RECORDING AND REPORTING CHEMICAL RELEASES PAGE: 2 of 4
SOP: EHS-29
REV: 01

2.0 DEFINITIONS
2.1 Catastrophic Release—a major uncontrolled emission, fire, or explosion involving one or more
regulated substances that present imminent and substantial endangerment to public health and
the environment. All chemical spills or releases that cannot be immediately contained and can
have an unbridled effect upon coworkers, the public, and/or the environment.
2.2 Chemical Spill or Release—any gas, liquid, or solid chemical that has been released from
normal packaging containment, allowing it to be unintentionally released to the floor, ground,
drainage systems, or air.
2.3 Emergency Response Release—all chemical spill or release that will leave or have the
potential to leave Thatcher property thereby affecting the public.
2.4 Reportable Release—all chemical spills or releases that meet or exceed the reportable
quantity established by the Environmental Protection Agency (EPA). This includes chemical
spills or releases that cannot be contained in the immediate area or pose other health risks to
employees.
3.0 REGULATION REQUIREMENTS
3.1 Chemical spills and releases are regulated by several federal (including OSHA, EPA, DOT),
state, and local agencies (including the fire department). Their goal is to ensure companies do
not harm their employees, that employees do not carelessly hurt others, that the public is
protected from unknown harm, and the environment is safeguarded. To ensure compliance,
each spill or release must be carefully documented. All spills will be documented using the
steps and forms found in the Incident Investigation program (PS-11F1, 3, and 4) ensuring the
material and concentration of the chemical spilled or released is listed along with how it was
recovered and cleaned up.
3.2 Under 40 CFR 302.4 and 40 CFR 355 the federal government requires immediate notification of
a release for certain hazardous chemicals greater than the Reportable Quantity (RQ). Follow-up
reports are also required by the EPA as knowledge is gained throughout the release, the
Reportable Release Report (EHS-29-F2) will be used to record the contact information of the
regulatory agencies contacted.
3.3 Under state and local regulations the Fire Department, LEPC, and SERC must be immediately
notified upon a hazardous chemical release, except for amounts less than the reportable
quantities (RQ). The Reportable Release Report (EHS-29F2) will be used to record the contact
information of the regulatory agencies contacted.
3.4 The EHS Manager shall archive the Reportable Release Report (EHS-29F2) along with the
Incident Investigation Reports (PS-11F1, 3 and 4) for at least 5 years.
4.0 REPORTING AND DOCUMENTING REPORTABLE RELEASES AT THATCHER COMPANY
4.1 All chemicals spills or releases will be reported as soon as they happen.
4.1.1 The EHS Manager will be notified immediately to initiate the investigation.
4.1.2 The Area Supervisor will notify personnel to initiate chemical spill/release containment
and cleanup.
4.2 The EHS manager will ensure reportable spills have been thoroughly documented and
investigated by area managers and personnel involved. Limits of chemical release for key
materials handled by Thatcher personnel are noted in the Reportable Quantities (RQ) List
(EHS-29F1). For other chemical spills, the EHS Manager will provide exposure limits upon
request. All reportable releases must be recorded and corrected in accordance with 4.1.
4.2.1 In addition, the Area Supervisor must immediately notify the Operations Manager or the
acting Operations Manager on duty.
4.2.2 The Operations Manager shall take all precautions to protect other plant workers and
contain the chemical.
RECORDING AND REPORTING CHEMICAL RELEASES PAGE: 3 of 4
SOP: EHS-29
REV: 01

4.2.3 After the safety of plant workers has been secured, the Operations Manager shall in
turn notify the EHS Manager or the EHS VP.
4.2.4 Reportable releases or spills mandate notification of federal, state, or local agencies.
The EHS Manager shall make the required notifications and prepare written information
in accordance with appropriate government mandates. The Reportable Release Report
(EHS-29F2) must be filled out as soon as possible, preferably during the release or
directly after.
4.3 In case of an emergency response release the employee(s) at the release should do all they
can to SAFELY terminate and contain the release.
4.3.1 They should simultaneously notify key individuals on the Emergency Response list,
found in posted areas beginning with the Area Supervisor and then down the list as
appropriate to include owners, the HAZMAT team and the EHS Manager.
4.3.2 The EHS Manager will notify the appropriate agencies and will contact immediate
neighbors that may be affected. The Reportable Release Report (EHS-29F2) will be
used to document the agencies contacted and information given.
4.3.3 Employees associated with the spill or release will be required to properly document
events using the initial incident form (PS-11F1) as soon as the chemical spill or release
is contained.
4.4 For a catastrophic release or for fire, Thatcher Employees should immediately call 911 to report
the situation. They should also simultaneously perform all items in 4.3.
4.5 The Reportable Release Reports (EHS-29F2) will be filed by the EHS Manager. The EHS
Manager will then send a copy to Senior Management.
5.0 MEDIA COMMUNICATIONS AND EXTERNAL INFORMATION RELEASE
5.1 Except for an emergency report to 911, employees are not authorized to communicate
corporate information outside the company. Emergency communications will be coordinated by
the Company President through the EHS VP or Director.
RECORDING AND REPORTING CHEMICAL RELEASES PAGE: 4 of 4
SOP: EHS-29
REV: 01

REVISION HISTORY

Rev Date
Author
Section Affected Change Description
0 06/09/2016
D. Bauer / D.
Yocom
All Initial release. Document revised from IH-01.
1 APPROVALS
S. Poulos
D. Lindsey
2.0 Definitions
3.0 Regulations
4.0 Reporting
5.0 Media
Remove near miss.
Clarification of use of forms.
Clarification of use of forms and update position titles.
Update position titles.

RECORDING AND REPORTING CHEMICAL RELEASES
SOP: EHS-29
REV: 01

REFERENCES
40 CFR 68.3, Definitions of releases.
40 CFR 302.4, Designation of hazardous substances.
40 CFR 355, Emergency planning and notification.

FORMS INDEX
Forms and Logs listed as the generic numbering with site specific forms, using site annotation, being created
where applicable.

FORMS
EHS-29F1 Reportable Quantities
EHS-29F2 Reportable Release Report
LOGS
None

APPENDIX B
Solid and Hazardous Waste Management Plan

Thatcher Company, Inc.
Solid and Hazardous Waste
Management Plan
EPA ID No. UTD041307356

Prepared for:
Thatcher Company, Inc.
1900 Fortune Road
Salt Lake City, UT 84104

Prepared by:
Stantec Consulting Services Inc.
2890 E. Cottonwood Parkway,
#300
Salt Lake City, Utah 84121

August 31, 2020
Sign-off Sheet

This document entitled Thatcher Company, Inc., Solid and Hazardous Waste Management Plan
was prepared by Stantec Consulting Services Inc. (“Stantec”) for the account of Dorsey &
Whitney LLP (“Attorney”) and Thatcher Company Inc. (the “Client”). Any reliance on this
document by any third party is strictly prohibited. The material in it reflects Stantec’s professional
judgment in light of the scope, schedule and other limitations stated in the document and in the
contract between Stantec and the Client. The opinions in the document are based on
conditions and information existing at the time the document was published and do not take
into account any subsequent changes. In preparing the document, Stantec did not verify
information supplied to it by others. Any use which a third party makes of this document is the
responsibility of such third party. Such third party agrees that Stantec shall not be responsible for
costs or damages of any kind, if any, suffered by it or any other third party as a result of decisions
made or actions taken based on this document.

Prepared by
(signature)
Richard Pratt

Reviewed by
________________________________________
(signature)
Dan Heiser

Reviewed by
(signature)
Jen Cole

Thatcher Solid and Hazardous Waste Management Plan i

Table of Contents
LIST OF ACRONYMS AND ABBREVIATIONS ........................................................................... VIII
1.0 INTRODUCTION ............................................................................................................. 1
1.1 ENVIRONMENTAL PROTECTION AGENCY AND STATE HAZARDOUS WASTE
MANAGEMENT REGULATIONS ..................................................................................... 2
2.0 FACILITY HAZARDOUS AND UNIVERSAL WASTE GENERATOR STATUS ......................... 4
2.1 FACILITY HAZARDOUS WASTE GENERATOR STATUS .................................................... 4
2.2 FACILITY UNIVERSAL WASTE GENERATOR (HANDLER) STATUS .................................... 5
3.0 WASTE ANALYSIS AND DESIGNATION PLAN ................................................................ 6
3.1 GENERAL ADMINISTRATIVE WASTES ............................................................................. 7
3.1.1 Office and Lunchroom Wastes .................................................................. 7
3.1.2 Janitorial Products Including Aerosols and Waste from Their Use ........... 7
3.1.3 Industrial Lamp Bulbs .................................................................................. 7
3.1.4 Aerosol Paints, Cleaners, Lubricants, and Vent Filters .............................. 9
3.1.5 Spray Foam Insulation Aerosol Cans ........................................................10
3.1.6 Ni-Cad, Mercury, and Dry Lead Batteries ................................................10
3.1.7 Sealed Gel Lead Acid Batteries ...............................................................11
3.1.8 Carbon and Alkaline Batteries ..................................................................11
3.1.9 Lithium Batteries .........................................................................................11
3.1.10 Used Floor Dry or Sweeping Compound..................................................12
3.1.11 General Administrative Maintenance Wastes ........................................13
3.1.12 Pesticides ....................................................................................................13
3.1.13 Painting Wastes ..........................................................................................14
3.1.14 Sanitary Wastewater and Sludge .............................................................14
3.1.15 Warehouse Wastes ....................................................................................15
3.1.16 Safety-Health-Environment Department Wastes ....................................15
3.1.17 Fire Extinguisher Powder ............................................................................15
3.1.18 Used Computer Parts .................................................................................15
3.1.19 Waste Electrical Components ..................................................................16
3.1.20 Biohazard Waste ........................................................................................17
3.1.21 Empty Product Containers ........................................................................17
3.1.22 Unusable New Products ............................................................................18
3.1.23 Chlorinated Fluorocarbons/Refrigerant ...................................................18
3.1.24 Refrigeration Unit CFCs Oil Waste .............................................................18
3.1.25 Asbestos ......................................................................................................19
3.1.26 Non-leaking Light Ballasts and Small Capacitors ....................................19
3.1.27 Transformer Oil (No-PCB and PCB Oil)......................................................20
3.1.28 Mercury Waste ...........................................................................................20
3.2 VEHICLE, MOBILE EQUIPMENT, AND SHOP WASTE .....................................................21

Thatcher Solid and Hazardous Waste Management Plan ii

3.2.1 Used Oil and Used Oil Burner Ash .............................................................21
3.2.2 Used Oil, Air, Diesel Fuel, Gasoline, and Coolant Filters ..........................23
3.2.3 Used Grease ...............................................................................................23
3.2.4 Used Floor Dry .............................................................................................24
3.2.5 Used Rags, Wipes, Absorbent Pads, and Socks ......................................24
3.2.6 Used Engine Coolant (Glycol-Based Antifreeze) ....................................25
3.2.7 Water-Sediment/Sludges from Sumps ......................................................25
3.2.8 Aerosol Paints, Cleaners, Lubricants, and Vent Filters .............................26
3.2.9 Contaminated or Waste Diesel Fuel ........................................................26
3.2.10 Contaminated or Waste Gasoline and/or Kerosene ..............................26
3.2.11 Empty Product Containers ........................................................................27
3.2.12 Lead Acid Batteries ...................................................................................27
3.2.13 Scrap Metal Including Welding Rod and Cuttings .................................28
3.2.14 Compressed Gas Cylinders .......................................................................28
3.2.15 Cold Cutting Fluid ......................................................................................28
3.2.16 Machine Tool Fluids ....................................................................................29
3.2.17 Spent Solvent (Water and/or Hydrocarbon-Based), Sludge,
and/or Filters from Parts Washers or Bulk Solvent Use ..............................29
3.2.18 Hot Water Parts Washer Spent Filters, Water, Sludge, and
Skimmer Waste ...........................................................................................30
3.2.19 Used Desiccants .........................................................................................31
3.2.20 Ni-Cad, Mercury, Dry Lead Batteries, or Sealed Gel Lead Acid ............31
3.2.21 Lithium Batteries .........................................................................................32
3.2.22 Carbon and Alkaline Flashlight Batteries .................................................32
3.2.23 General Maintenance Wastes .................................................................32
3.2.24 Chlorinated Fluorocarbons/Refrigerant ...................................................32
3.2.25 Refrigeration Unit CFCs Oil Waste .............................................................32
3.2.26 Paint-Related Materials Including Blasting Grit .......................................32
3.2.27 Pressure Washing Wastes ..........................................................................32
3.2.28 Air Cooler Filters ..........................................................................................33
3.3 TIRE REPAIR (TRUCK SHOP) ..........................................................................................33
3.3.1 Tire Cleaner and Adhesive ........................................................................33
3.3.2 Tire and Wheel Balance Weights ..............................................................33
3.3.3 Tire Prep Solution ........................................................................................34
3.3.4 Tires ..............................................................................................................34
3.3.5 Used Floor Dry .............................................................................................34
3.3.6 Used Rags, Wipes, Absorbent Pads, and Socks ......................................34
3.3.7 Empty Product Containers ........................................................................34
3.4 EQUIPMENT PAINTING .................................................................................................34
3.4.1 Painting Wastes ..........................................................................................34
3.4.2 Used Blasting Grit and/or Paint Chips ......................................................35
3.4.3 Empty Product Containers ........................................................................35
3.4.4 Used Rags, Wipes, Drop Cloths, and Masking Material ..........................35

Thatcher Solid and Hazardous Waste Management Plan iii

3.4.5 Aerosol Paints, Cleaners, Lubricants, and Vent Filters .............................36
3.4.6 Lead Based Paint Removal Waste ...........................................................36
3.5 MAINTENANCE .............................................................................................................36
3.5.1 Used Lubricating and Hydraulic Oil ..........................................................36
3.5.2 Used Grease ...............................................................................................37
3.5.3 Used Rags, Wipes, Absorbent Pads, and Socks ......................................37
3.5.4 Waste Paints and Painting Wastes ...........................................................37
3.5.5 Sand Blast Grit ............................................................................................37
3.5.6 Scrap Metal Including Welding Rod and Cuttings .................................37
3.5.7 Spent Solvent (water and/or hydrocarbon-based), Sludge,
and/or Filters from Parts Washers or Bulk Solvent Use ..............................37
3.5.8 Industrial Lamp Bulbs .................................................................................37
3.5.9 Aerosol Paints, Cleaners, Lubricants, and Vent Filters .............................37
3.5.10 Cold Cutting Fluid ......................................................................................37
3.5.11 Used Floor Dry .............................................................................................37
3.5.12 Ni-Cad Batteries .........................................................................................37
3.5.13 Lithium Batteries .........................................................................................38
3.5.14 Carbon and Alkaline Batteries ..................................................................38
3.5.15 Sump Cleanouts .........................................................................................38
3.5.16 Tank and Vessel Cleanouts .......................................................................39
3.5.17 Used Rags, Wipes, Absorbent Pads, and Socks with Spray
Solvent Waste (Used on Instrumentation) ................................................40
3.5.18 Hot Water Parts Washer Spent Filters, Water, Sludge, and
Skimmer Waste ...........................................................................................40
3.5.19 Machine Tool Fluids ....................................................................................40
3.5.20 Lead Acid Batteries ...................................................................................40
3.6 LABORATORY ...............................................................................................................40
3.6.1 Used or Stored Excess Samples .................................................................41
3.6.2 Oil and Gas Industry Samples ...................................................................41
3.6.3 High Performance Liquid Chromatography Waste ................................41
3.6.4 Silver Nitrate Solution from Chloride Argentometric Analysis .................42
3.6.5 Chloroform Surfactant Titration.................................................................42
3.6.6 Dilute Metal Solutions ................................................................................43
3.6.7 Hydranal Solutions......................................................................................43
3.6.8 Lab Sink Drains and Neutralization Tank Wastewater Discharge ...........43
3.6.9 Unused Laboratory Chemicals .................................................................44
3.6.10 Laboratory Chemicals Desiccant and/or Activated Carbon Off
Gas Filters ....................................................................................................45
3.6.11 Makeup Air Filters .......................................................................................45
3.6.12 Water Purification Cartridges and Compressor Desiccant Filters ..........45
3.6.13 Miscellaneous Titration and/or pH Buffer Solutions .................................45
3.6.14 Contaminated Personal Protection Equipment (PPE), Floor
Sweepings, and/or Trash ...........................................................................46

Thatcher Solid and Hazardous Waste Management Plan iv

3.6.15 Hood Scrubber Solution.............................................................................46
3.6.16 Empty Reagent Containers .......................................................................47
3.6.17 Equipment Bulbs ........................................................................................47
3.6.18 Compressed Gas Cylinders .......................................................................47
3.6.19 Used Oil .......................................................................................................47
3.7 FUELING FACILITIES .......................................................................................................47
3.7.1 Collected Oil/Grease and Small Spills ......................................................47
3.7.2 Collected Diesel Fuel and Small Spills ......................................................47
3.7.3 Contaminated or Waste Gasoline and Small Spills .................................48
3.7.4 Collected Used Engine Coolant (Glycol-Based Antifreeze) and
small Spills ...................................................................................................48
3.7.5 Used Floor Dry .............................................................................................48
3.7.6 Used Rags, Wipes, Absorbent Pads, and Socks ......................................48
3.7.7 Fuel Filters ....................................................................................................48
3.7.8 Aerosol Paints, Cleaners, Lubricants, and Vent Filters .............................48
3.7.9 Oily Water, Used Oil, Sediment/Sludges from Sumps ..............................48
3.8 CHEMICAL MANUFACTURING ....................................................................................48
3.8.1 Scrubber Solutions ......................................................................................50
3.8.2 Filter Press Wash Water/Sludge or Used Filter Press Components ..........50
3.8.3 Filter Press Cake .........................................................................................51
3.8.4 Dust Collectors or Bag Filters .....................................................................51
3.8.5 Area Sumps ................................................................................................52
3.8.6 Boiler Blowdown .........................................................................................52
3.8.7 Boiler Chemical Cleaning .........................................................................53
3.8.8 Demineralization Water Treatment and Reverse Osmosis Filter
Cleaning Wash Water ...............................................................................53
3.8.9 Reverse Osmosis Water Filters ...................................................................54
3.8.10 Heat Exchanger, Cooling Tower, Chillers and/or Strainers
Pressure or Acid Wash Waste ....................................................................54
3.8.11 Sodium Hypochlorite Cooling Tower Bleed .............................................55
3.9 UTILITIES AND RAW MATERIALS ....................................................................................55
3.9.1 Area Sumps and Water Treatment Containments ..................................55
3.9.2 Container Wash Areas ..............................................................................56
3.9.3 Water Treatment Filter Press ......................................................................57
3.9.4 Water Treatment Filter Cake .....................................................................57
3.9.5 Oil Water Separators ..................................................................................57
3.9.6 Sodium Hydroxide Reagents Area Sumps ...............................................57
3.9.7 Antiscalant Area Sump .............................................................................58
3.9.8 Acid Area Sumps .......................................................................................58
3.9.9 Miscellaneous Reagent Area Sumps .......................................................58
3.9.10 Boiler Solution (Heat Transfer Solution) .....................................................58
3.10 SPILL CLEANUP .............................................................................................................59
3.10.1 Soils or Cleanup Material Contaminated with Oil and/or Grease ........59

Thatcher Solid and Hazardous Waste Management Plan v

3.10.2 Soils or Cleanup Materials Contaminated with Diesel Fuel ....................60
3.10.3 Soils or Cleanup Materials Contaminated with Gasoline and/or
Kerosene .....................................................................................................60
3.10.4 Soils or Cleanup Materials Contaminated with Alcohol .........................61
3.10.5 Soils or Cleanup Materials Contaminated with Oxidizer ........................61
3.10.6 Soils or Cleanup Materials Contaminated with Engine Coolant
or Heat Transfer Solution ............................................................................62
3.10.7 Soils or Cleanup Materials Contaminated with Used Non-Listed
Solvent ........................................................................................................62
3.10.8 Soils or Cleanup Materials Contaminated with Used Paint
Thinner or F-Listed Cleaning Solvent .........................................................62
3.10.9 Soils or Cleanup Materials Contaminated with Unused Paint,
Blended Commercial Formulations, or Chemical Mixtures ....................63
3.10.10 Soils or Cleanup Materials Contaminated with Acid ..............................63
3.10.11 Soils or Cleanup Materials Contaminated with Caustics and/or
Lime .............................................................................................................64
3.10.12 Soils or Cleanup Materials Contaminated with Antiscalant ...................64
3.10.13 Soils or Cleanup Materials Contaminated with a Pure Chemical .........64
4.0 ACCEPTABLE SOLID WASTE (TRASH) FOR OFF SITE DISPOSAL ................................... 66
4.1 GENERAL DESCRIPTION OF ACCEPTABLE SOLID WASTES..........................................66
4.2 FACILITY CONSTRUCTION WASTES ..............................................................................66
4.3 TRASH ...........................................................................................................................66
4.4 PROHIBITED AND HAZARDOUS WASTE .......................................................................66
5.0 CONTAINER MANAGEMENT PLAN ............................................................................. 68
5.1 TYPES OF CONTAINERS ................................................................................................68
5.1.1 Intermediate Bulk Containers (IBC) or Roll-Offs .......................................68
5.1.2 55-Gallon Open-Head Drums ...................................................................68
5.1.3 55-Gallon Closed-Top Drums ....................................................................69
5.1.4 Salvage Drums (Used for Overpacks) ......................................................69
5.1.5 Universal Waste Containers.......................................................................69
5.1.6 Totes and Tanks ..........................................................................................69
5.2 MANAGEMENT OF CONTAINERS ................................................................................70
5.3 CONTAINER INSPECTIONS ...........................................................................................71
5.4 STORAGE LIMITATIONS .................................................................................................71
5.5 IGNITABLE OR REACTIVE WASTES ................................................................................72
5.6 INCOMPATIBLE WASTES ...............................................................................................72
6.0 PREPAREDNESS AND PREVENTION PLAN .................................................................... 73
6.1 HAZARDOUS WASTE STORAGE AREAS MAINTENANCE AND NORMAL
OPERATION PROCEDURES ..........................................................................................74

Thatcher Solid and Hazardous Waste Management Plan vi

6.2 REQUIRED EQUIPMENT FOR OPERATION OF THE HAZARDOUS WASTE
STORAGE AREAS ..........................................................................................................76
6.3 ARRANGEMENTS WITH LOCAL AUTHORITIES ..............................................................79
7.0 HAZARDOUS WASTE SATELLITE AND UNIVERSAL WASTE ACCUMULATION
AREAS .......................................................................................................................... 80
8.0 PRE-TRANSPORT REQUIREMENTS AND RECORD KEEPING.......................................... 82
8.1 EPISODIC GENERATION REQUIREMENTS AND RECORD KEEPING .............................83
9.0 CONTINGENCY PLAN AND EMERGENCY PROCEDURES ............................................ 85
9.1 EMERGENCY COORDINATORS ...................................................................................85
9.2 EMERGENCY COORDINATOR ACTIONS .....................................................................86
9.3 EMERGENCY RESPONSE EQUIPMENT AND MATERIALS ..............................................89
9.4 EMERGENCY SPILL RESPONSE ACTIONS .....................................................................90
9.4.1 Emergency Spill Response Actions ...........................................................90
9.4.2 Internal Emergency Reporting ..................................................................91
9.5 EMERGENCY FIRE RESPONSE ACTIONS ......................................................................91
9.6 EMERGENCY EXPLOSION RESPONSE ACTIONS ..........................................................93
9.7 EVACUATION PLANS....................................................................................................93
9.8 EMERGENCY REPORTING PROCEDURES ....................................................................93
9.9 MANAGEMENT OF WASTES PRODUCED DURING AN INCIDENT RESPONSE .............96
9.10 COORDINATION WITH LOCAL AUTHORITIES ...............................................................96
9.10.1 Emergency Response Agency Waiver ....................................................97
9.11 AMENDMENT OF CONTINGENCY PLAN .....................................................................97
9.12 CONTINGENCY PLAN QUICK REFERENCE GUIDE ......................................................98
9.12.1 Emergency Coordinator Contact List ......................................................98
9.12.2 Emergency Communications ...................................................................98
9.12.3 Hazardous Waste Information ..................................................................98
9.12.4 Hazardous Waste Exposure ..................................................................... 100
9.12.5 Facility and Street Maps .......................................................................... 100
9.12.6 Hazardous Waste Quick Reference Guide Updates ............................ 101
10.0 PERSONNEL TRAINING ...............................................................................................102
10.1 INTRODUCTION .......................................................................................................... 102
10.2 HAZARDOUS WASTE MANAGEMENT JOB DESCRIPTIONS ........................................ 102
10.2.1 90-day Hazardous Waste Storage Areas Operator .............................. 103
10.2.2 Hazardous Waste Satellite Accumulation Operator ............................. 103
10.2.3 Hazardous Waste Shipper ....................................................................... 103
10.2.4 Universal Waste Operator ....................................................................... 103
10.3 TRAINING RECORD KEEPING ..................................................................................... 104
11.0 WASTE MINIMIZATION GUIDELINES ...........................................................................105

Thatcher Solid and Hazardous Waste Management Plan vii

11.1 MANAGEMENT SUPPORT ........................................................................................... 105
11.2 WASTE GENERATION ACCOUNTING ........................................................................ 105
11.3 ECONOMIC BENEFITS OF WASTE REDUCTION .......................................................... 106
11.4 WASTE MINIMIZATION ASSESSMENTS ......................................................................... 106
11.5 TECHNICAL WASTE MINIMIZATION INFORMATION ................................................... 107
11.6 IMPLEMENTATION OF WASTE REDUCTION APPROACH ........................................... 107
LIST OF TABLES
Table 2.1 - Small Quantity Universal Waste Handler .............................................................. 5
Table 3.1 Buildings and Activities ...........................................................................................48
Table 4.1 - Prohibited and Acceptable Waste List ...............................................................67
Table 6.1 - Hazardous Waste Storage Areas Phone Locations ...........................................77
Table 6.2 - Hazardous Waste Storage Areas Fire Extinguisher Locations ............................77
Table 6.3 - Hazardous Waste Storage Areas Spill Kit or Equipment Locations ...................78
Table 9.1 - Building 16 Hazardous Waste Information ..........................................................98
Table 9.2 - Laboratory Hazardous Waste Information .........................................................99
Table 9.3 - Process North West Storage Area Hazardous Waste Information .................. 100
LIST OF APPENDICES
APPENDIX A EMERGENCY CONTACT LIST ..................................................................... A.1
APPENDIX B CONTINGENCY PLAN MAPS ..................................................................... B.1
APPENDIX C HAZARDOUS WASTE MANAGEMENT PERSONNEL JOB TITLES .................. C.1

Thatcher Solid and Hazardous Waste Management Plan viii

List of Acronyms and Abbreviations
CFC Chlorinated Fluorocarbons
CESQG Conditionally Exempt Small Quantity Generator
CFR Code of Federal Regulations
CRT Cathode Ray Tubes
˚F Degrees Fahrenheit
DOT Department of Transportation
ENU Elementary Neutralization Unit
EPA Environmental Protection Agency
HID High-Intensity-Discharge
HP High-Pressure
IBC Intermediate Bulk Container
kg Kilogram
lbs Pounds
LDR Land Disposal Restriction
LQG Large Quantity Generator
mg/L Milligrams Per Liter
PCS Petroleum Contaminated Soil
PPE Personal Protective Equipment
PPM Parts Per Million
RCRA Resource Conservation and Recovery Act
SDS Safety Data Sheet
SHWMP Solid and Hazardous Waste Management Plan
SQG Small Quantity Generator
TC Toxicity Characteristic
TCLP Toxicity Characteristic Leaching Procedure
TOX Total Organic Halogens
TPH Total Petroleum Hydrocarbons
TSCA Toxic Substances Control Act
TSDF Treatment, Storage, and Disposal Facilities
UHWM Uniform Hazardous Waste Manifest
UAC Utah Administrative Code
VSQG Very Small Quantity Generator

Thatcher Solid and Hazardous Waste Management Plan ix

INTRODUCTION
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Thatcher Solid and Hazardous Waste Management Plan 1

1.0 INTRODUCTION
This Solid and Hazardous Waste Management Plan (SHWMP) presents information on the
generation, characterization, management, and disposal of the waste streams generated by
Thatcher Company, Inc. (Thatcher). This document represents the chemical manufacturing and
distribution facility plan for compliance with the federal and State of Utah solid and hazardous
waste management regulations applicable to chemical facility activities. Thatcher produces a
diversified range of products supporting industries such as oil/gas, water treatment, laundry,
pharmaceutical, and food/dairy. These products include mainly inorganic chemical
compounds, surfactants, concrete admixtures, disinfecting agents, soaps, and detergents. The
Thatcher’s facility is located at 1905 Fortune Road, Salt Lake City, Utah.
The complex nature of the hazardous waste regulations requires detailed planning, procedures,
and documentation. This document is intended for use by facility personnel familiar with and
responsible for the facility’s solid and hazardous waste management.
The following is a summary of material management practices in this plan:
• Acceptable non-hazardous solid wastes (trash) are disposed in trash containers on site
and transported for disposal off site at permitted county landfills/transfer stations.
Acceptable non-hazardous solid wastes with free liquids must be solidified/dried before
disposing in the trash.

• Hazardous wastes are disposed off site at permitted hazardous waste incineration and/or
landfill disposal facilities.

• Universal wastes are recycled off site at permitted universal waste handling facilities.

• Designated non-hazardous wastes are disposed off site at approved facilities.

• Used oil is recycled off site at approved facilities.

• Used coolant (antifreeze) is recycled on site or off site at approved facilities.

• Petroleum contaminated soils (PCS) are containerized and disposed of off site at
approved facilities.

• Recyclable materials may be recycled off site at approved facilities (e.g., electronics,
cardboard, aluminum, paper, ink cartridges).

• Sanitary wastewater is piped to the local Publicly Owned Treatment Works (POTW).

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Thatcher Solid and Hazardous Waste Management Plan 2

• Materials meeting the wastewater discharge permit parameters are treated and
discharge to the POTW under the permit number SLC-0001.

• Contractor wastes will comply with the Utah Hazardous Waste Regulations. When
needed, Thatcher will provide guidance to assist contractors in the proper management
of waste generated from each project. Ultimately, contractors are responsible for the
solid and hazardous wastes generated from contracted services as described in the
contract general terms and conditions. Potential wastes will be identified prior to
commencement of work. Acceptable non-hazardous solid wastes (trash) are disposed
off-site in permitted landfills. Acceptable non-hazardous solid wastes with free liquids
must be solidified/dried before disposing in the trash. Wastes may be approved by
Thatcher for management with Thatcher materials or wastes (i.e., used oil, non-hazardous
trash, and PCS).

• Waste minimization is practiced at the Thatcher facility, and materials are recycled when
possible and practical.
Any business that generates a waste is required by Title 40 of the Code of Federal Regulations
(CFR) Part 262.11 / Utah Administrative Code (UAC) R315-262-11 to determine if the waste is a
hazardous waste. Laboratory analyses of various process and waste streams have been used to
make the hazardous waste determinations for Thatcher, which are reported in this document.
Additional process and waste stream sampling is completed on an as-needed basis. The
original laboratory analytical results obtained from wastes sampled and analyzed for this plan
are located in the records archive of Thatcher’s Environmental Health and Safety Department.
Thatcher samples its waste streams as necessary to comply with the above regulations. Waste
streams were reviewed, inventoried, and identified for sampling in this report.
1.1 ENVIRONMENTAL PROTECTION AGENCY AND STATE
HAZARDOUS WASTE MANAGEMENT REGULATIONS
Utah's authorized version of the 1976 Federal Resource Conservation and Recovery Act (RCRA)
regulations are contained in the Utah Hazardous Waste Management Regulations. The
regulations are enforced in Utah by the Department of Environmental Quality (UDEQ), Division of
Waste Management and Radiation Control (DWMRC) located in Salt Lake City, Utah. The U.S.
Environmental Protection Agency (EPA), through its Region Eight office in Denver, Colorado, has
oversight and audit authority over the Utah program.

Federal government control of hazardous waste is derived from authority granted by the
Resource Conservation and Recovery Act (RCRA). The federal hazardous waste regulations
applicable to waste generators are found in 40 CFR Parts 260, 261, 262, 265, 266, 268, 273, 279,
and 280. The UDEQ, DWMRC regulations applicable to waste generators are found in Utah
Administrative Code (UAC) R315 - 260, 261, 262, 265, 266, 268, 273, 279, and 280.

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40 CFR Part 262/UAC R315-262 requires a waste generator to characterize its waste products to
determine if they are hazardous wastes. This requires a review of 40 CFR Part 261/UAC R315-261
to determine if the wastes are defined as solid wa stes (note: the regulatory definition of a solid
waste includes liquids and compressed gasses) and 40 CFR 261 Subpart D /UAC R315-261-(30-33
and 35) to determine if the solid wastes are specifically listed as hazardous wastes. If the wastes
are solid wastes and not specifically listed as hazardous wastes, the waste must then be
reviewed according to the methods set forth in Subpart C of 40 CFR Part 261/UAC R315-261-(20-
24). This testing is generally referred to as the "characteristic tests" (see Section 3.0).

FACILITY HAZARDOUS AND UNIVERSAL WASTE GENERATOR STATUS
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2.0 FACILITY HAZARDOUS AND UNIVERSAL WASTE
GENERATOR STATUS
2.1 FACILITY HAZARDOUS WASTE GENERATOR STATUS
Generators of hazardous wastes are classified and subsequently regulated dif ferently based on
the quantity of wastes generated on a monthly basis. The economic, legal, and practical
differences between generator classifications may be substantial. Generators are categorized
according to the amount of hazardous waste and acutely hazardous waste the facility
generates during a calendar month. The quantity limits apply to the total weight of hazardous
and acute hazardous wastes generated from all sources on site and may also include some
material designated for reuse or recycling unless specifically exempted, such as lead acid
batteries.
A fully regulated generator is a Large Quantity Generator (LQG) that generates more than 1,000
kilograms (kg) (2,200 pounds [lbs]) of hazardous waste, 1 kg (2.2 lbs) of acute hazardous waste,
or 100 kg (220 lbs) of acute hazardous waste cleanup residue per calendar month. A Small
Quantity Generator (SQG) generates between 100 kg and 1,000 kg (220 lbs and 2,200 lbs) of
hazardous waste, 1 kg (2.2 lbs) of acute hazardous waste or 100 kg (220 lbs) of ac ute cleanup
residue per calendar month. A Very Small Quantity Generator (VSQG) generates 100 kg or less
(less than 220 lbs) of hazardous waste, 1 kg (2.2 lbs) of acute waste, or 100 kg (220 lbs) of acute
cleanup residue per calendar month.
LQGs and SQGs have varying restrictions on handling, accumulation, and disposal of hazardous
wastes. They also have recordkeeping, reporting, employee training, emergency planning, and
emergency procedures requirements. VSQGs have few restrictions on handling and disposal of
hazardous waste.
Based on inspections and internal accounting, Thatcher is classified as an LQG. LQGs must
comply with parts of the federal and state hazardous waste regulations related to identification
of their wastes, use of proper containers, appropriate storage conditions, accurate markings
and labeling, use of hazardous waste manifests, emergency response, training, and proper
disposal of the wastes. The facility has recently updated its generator status with UDEQ and is in
the process of complying with all of these requirements. LQGs cannot store hazardous waste
onsite for more than 90 days.
This document describes the waste management activities at Thatcher and has been designed
to comply with the hazardous waste management regulations applicable to LQGs. Thatcher
has notified the EPA and the UDEQ regarding its waste generating activities and has been
assigned the following EPA Identification Number: UTD041307356.

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2.2 FACILITY UNIVERSAL WASTE GENERATOR (HANDLER) STATUS
Thatcher is a small quantity universal waste handler. A small quantity universal waste handler is
defined as a facility that does not accumulate more than 5,000 kilogram of universal waste
(batteries, pesticides, thermostats, lamps/bulbs, or mercury containing equipment calculated
collectively) at any one time.
Regulatory requirements for small quantity universal waste handlers are summarized in the
following in table.
Table 2.1 - Small Quantity Universal Waste Handler
Record
40 CFR
Regulatory
Citation/UAC
Small Quantity Handlers Retention Period
Notification to EPA
273.12 and 32 /
R315-273-
12and32
Not Required Not applicable
Universal waste
generator status
273.9 / R315-
273-9 11,000 lbs on site at any time
At minimum, have a record of
waste on site during calendar
year; recommend three years
Accumulation time
limits
273.15 and 35 /
R315-273-15 and
35
Method in place to
demonstrate the waste has
been accumulated no longer
than 12 months
At minimum, have a record while
waste is on site; recommend three
years
Employee Training
273.16 and 36 /
R315-273-16 and
36
Inform employees on proper
handling and emergency
procedures for the universal
wastes on site
No record required to be kept but
recommend keeping with other
employee waste training records
Off-site shipments
273.19 and 39 /
R315-273-19 and
39
Not required to keep records of
shipments but recommend
records be kept
Recommend three years

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3.0 WASTE ANALYSIS AND DESIGNATION PLAN
This section describes the chemical manufacturing processes with the associated waste streams.
Each waste stream is further detailed with its characteristics, classification, disposal requirements
and analysis (as required). Where applicable, the waste handling and shipping information is
also included.
Solid waste (40 CFR 261.2 / R315-261-2) will be characterized in accordance with the Resource
Conservation and Recovery Act (RCRA), the Utah Solid and Hazardous Waste Act (USHWA)
statutory standards, the Environmental Protection Agency (EPA), and UDEQ DWMRC regulations
promulgated thereunder. Any business that generates a solid waste is required by 40 CFR 262.11
/ R315-262-11 to determine if that material designated for management as a hazardous waste.
A hazardous waste is defined in 40 CFR Part 261 as part of waste analysis and designation. The
generator is required to use the following steps to determine if the waste:
• Is excluded from regulation under 40 CFR Part 261.4 / R315-261-4;
• Is listed as a hazardous waste under Subpart D of 40 CFR Part 261 / R315-261;
• When tested, exhibits any of the characteristics of a hazardous waste under Subpart C of
40 CFR 261 / UAC R315-261-(20-24); and
• Can be is classified under Subpart C of 40 CFR 261 / UAC R315-261 based on generator’s
knowledge of the hazard characteristic of the waste.
Testing of process waste streams is generally referred to as “characteristic testing.” These
analyses include: ignitability (flash point of 140 degrees Fahrenheit [˚F] or below), corrosivity (pH
less than or equal to 2.0 or greater than or equal to 12.5), reactivity (unstable, water reactive,
potentially explosive, can generate toxic gases, etc.); and Toxicity Characteristic (TC), Toxic
Characteristic Leaching Procedure (TCLP) Toxicity (a waste extraction process used to evaluate
waste content for 8 leachable metals, 25 organics, and selected pesticides and herbicides).
If the waste is not excluded from regulation and is determined to be a hazardous waste, the
generator must refer to 40 CFR parts 261, 264, 265, 266, 268, and 273 / R315 - 261, 264, 265, 266,
268, and 273 for possible exclusions or restrictions pertaining to management of the specific
waste. The Land Disposal Restrictions found in part 268 apply to all hazardous wastes intended
for landfill disposal and incineration (ash residues from incineration are land disposed).
Based on the characterization, an appropriate management method (use, recycling, and/or
disposal) will be identified which complies with applicable legal requirements and is protective of
human health and the environment.
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Non-hazardous wastes generated at the facility are disposed off site in permitted or approved
facilities. Hazardous wastes are stored at the designated LQG 90-day storage facility prior to
disposal off site. Each waste stream is characterized to determine classification and appropriate
management practice. The following sections document the waste analysis and designation
efforts made by Thatcher operations on all process and waste streams typically produced at the
property.
3.1 GENERAL ADMINISTRATIVE WASTES
Description: There are various wastes that are generally produced in all working locations of the
property including the administration buildings and the other chemical manufacturing areas.
These common, general wastes are described in this section.
3.1.1 Office and Lunchroom Wastes
Characteristics: Waste paper, metal, plastic, cardboard, wood, wrapping and packaging,
waste copier toner, waste laser printer toner/developers, hardened white-
out, hardened adhesives, food scraps and lunchroom trash.
Classification: Typically, non-hazardous solid waste, however, non-empty containers of
hazardous products may be hazardous wastes when disposed.
Disposal: Non-hazardous trash is discarded in the trash. Non-empty containers
should be disposed as required for the material characteristics.
Analyses: Not required, use product labels and Safety Data Sheets (SDSs) for
chemical products that are discarded.
3.1.2 Janitorial Products Including Aerosols and Waste from Their Use
Characteristics: Many janitorial products contain chemicals that may be hazardous. In
normal use, these products are either used consumptively or diluted in
water. See Section 3.1.4 for characterization and handling of aerosols.
Classification: Products used following instructions on labels do not constitute disposal,
and wastes from normal use of products are typically diluted enough to
not exhibit hazardous characteristics. Discarded, full-strength janitorial
products may exhibit hazardous characteristics of ignitability (D001),
corrosivity (D002), reactivity (D003), or TCLP toxicity (D004-D043).
Disposal: Non-hazardous wastes can be thrown in the trash or the sanitary
wastewater system as directed by the manufacturers' directions.
Discarded, unused products should be characterized by review of
product labeling or SDSs and containerized and disposed as appropriate.
Analyses: Not required; constituents can be determined from SDSs.
3.1.3 Industrial Lamp Bulbs
Characteristics: High-Pressure (HP) sodium High-Intensity-Discharge (HID), mercury vapor
HID, metal halide HID bulbs, fluorescent tubes, Compact Fluorescent
Lamps (CFL), Light-Emitting Diode (LED), and incandescent bulbs. It is
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Thatcher Solid and Hazardous Waste Management Plan 8

Thatcher policy to only use non-hazardous TCLP compliant HIDs or
fluorescent bulbs.
Classification: Some remnant “silver-tipped” fluorescent tubes/lamps on-site may have
been some of the first tubes/lamps manufactured with mercury below the
RCRA regulatory level and may be non-hazardous solid waste. Intact or
broken fluorescent tubes/lamps with the silver ends are typically TCLP
hazardous wastes for mercury (D009); HP sodium, mercury vapor, and
metal halide are TCLP toxic for mercury (D009) and lead (D008); CFL’s
may exceed the TCLP toxic level for mercury (D009); CFL’s and LED’s are
TCLP toxic for lead (D008), if not managed as universal waste under 40
CFR Part 273 / R315-273. Contact the Safety-Health-Environment
Department for classification of fluorescent tubes/lamps with silver ends.
The “silver-tipped” fluorescent tubes marked “TCLP Compliant,” “green-
tipped” fluorescent tubes, and incandescent bulbs are non-hazardous
solid waste. Philips HID bulbs marked “Alto” and other manufactures HID
bulbs marked “TCLP compliant” have passed a TCLP test and are non-
hazardous. Tubes and bulbs crusher filters are TCLP toxic for mercury
(D009).
Disposal: Non-hazardous Waste
Non-hazardous incandescent bulbs are placed in the trash and/or
recycled.
Hazardous Waste
Hazardous waste bulbs/tubes and /or broken bulbs/tubes are
accumulated in drums marked/labeled “Hazardous Waste Used Lamps”
prior to off-site management at an approved disposal facility.
Universal Waste
Fluorescent tubes, HP sodium, mercury vapor, metal halide lamps, CFL’s,
and LED’s are accumulated at the warehouse or other designated areas
in containers marked/labeled “Universal Waste Used lamps” prior to off-
site management at an approved universal waste management facility.
Analyses: Not required, if constituents can definitely be determined from SDSs. If
constituents cannot be determined from SDSs, apply generator
knowledge, use previous characterization information, and/or sample and
test for TCLP metals.
Waste Handling: Hazardous Waste
Broken bulbs/tubes hazardous wastes will be collected in drums having
properly completed EPA hazardous waste markings including the
accumulation start date when the drums are full. Containers are stored in
a designated area within the hazardous waste storage area or other
designated areas until they are shipped to a designated or a permitted
Treatment, Storage, and Disposal Facility (TSDF).
Universal Waste
Universal wastes are accumulated in original packaging or in an
approved container. Mark containers with a properly completed EPA
universal waste marking (sticker) including the date the waste is first put in
the container (accumulation start date). Containers are stored in a
designated area until they are shipped to a designated Universal Waste
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recycling facility (once per year). Universal waste cannot be stored on-site
for greater than 12 months.
Shipping: Container DOT Specification:
Hazardous Waste
UN/1A2.
Universal Waste
Original shipping container or other designation.
Waste Code:
Hazardous Waste: D008 and D009.
Universal Waste: Does not apply to universal waste.
Shipping Name: See waste profile.
3.1.4 Aerosol Paints, Cleaners, Lubricants, and Vent Filters
Characteristics: Aerosol paints, cleaners, lubricants, and vent filters may contain listed
chemicals. Additionally, material in aerosol cans may be ignitable (D001)
and/or reactive (D003). Vent filters contain carbon and adsorbed vapors.
It is company policy to minimize use of chlorinated and/or regulated
aerosol solvents.
Classification: Empty aerosol containers (approaching atmospheric pressure) are non-
hazardous, solid waste. Unused, discarded products are hazardous if they
contain a U- or P-listed chemical as the sole active ingredient or fail RCRA
characteristics. Non-empty aerosols (empty of product but still containing
propellant) may be hazardous due to characteristics of ignitability and/or
reactivity. Spent vent filters are listed hazardous waste and/or exhibit
hazardous waste characteristics.
Disposal: Aerosol products are sprayed onto surfaces then allowed to dry or wiped-
off with rags. Partially full potentially non-useable aerosol products are
collected to determine if the products are still usable or if they are
unusable or spent. All unusable or spent aerosol cans are emptied with a
can puncturing device (the satellite accumulation container under these
devices is under the management of a designated operator). Punctured
empty cans are thrown in the trash or recycled as scrap metal. Spent
vent filters are accumulated separately for disposal.
Analyses: Apply generator knowledge, use previous characterization information,
SDS, and/or sample and test aspirated liquids/solids for TCLP metals, F-
and D-list total volatiles, F- and D-list total semi-volatiles, and ignitability.
Waste Handling: Liquid hazardous wastes are collected in closed-top drums and spent vent
filters are collected in open-head drums having properly completed EPA
hazardous waste markings, including the date when the drum becomes
full or 55 gallons of the waste has accumulated. Drums containing
flammable liquids must be grounded when adding or removing waste.
Shipping: Container DOT Specification: Liquids UN/1A1 and vent filters UN/1A2
Waste Code(s): Varies with constituents.
Shipping Name: See waste profiles.
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3.1.5 Spray Foam Insulation Aerosol Cans
Characteristics: Insulating foam aerosol cans containing foam constituents. Additionally,
material in aerosol cans may be ignitable (D001) and/or reactive (D003).
Classification: RCRA-empty containers (approaching atmospheric pressure) are non-
hazardous, solid waste. Non-empty aerosols (empty of product but still
containing propellant) may be hazardous due to characteristics of
ignitability and/or reactivity.
Disposal: Aerosol products are used for their intended purpose. Partially full
potentially non-useable aerosol products are collected to determine if the
products are still usable or if they are unusable. All unusable insulating
foam aerosol cans are accumulated for disposal.
Analyses: Not required, constituents can be determined from SDS.
Waste Handling: Insulating foam aerosol cans hazardous wastes are collected in open-
head drums having properly completed EPA hazardous waste markings,
including the date when the drum becomes full or 55 gallons of the waste
has accumulated.
Shipping: Container DOT Specification: UN/1A2
Waste Code(s): Ignitability (D001) and reactivity (D003).
Shipping Name: See waste profile.
3.1.6 Ni-Cad, Mercury, and Dry Lead Batteries
Characteristics: NiCad batteries contain alkaline materials and cadmium. Dry lead (non-
lead acid) and mercury batteries contain lead and mercury respectively.
Classification: Recycled NiCad, dry lead, and mercury batteries are subject to the
Universal Waste management standards located in 40 CFR Part 273 /
R315-273. Discarded Ni-Cad batteries containing cadmium hazardous
waste characteristic (D006), mercury batteries containing hazardous
characteristic (D009), and dry lead batteries containing hazardous waste
characteristic (D008) are regulated for hazardous waste characteristics,
unless managed as universal wastes.
Disposal: Accumulated and recycled as Universal Wastes.
Analyses: Not required; constituents can be determined from SDSs.
Waste Handling: Handle batteries carefully to prevent damage. All batteries are placed in
plastic bags or terminals are taped to prevent terminals from contacting
and to prevent short circuits. Used Ni-Cad and mercury batteries are
collected and stored in plastic containers at designated locations on-site
and managed as universal waste. Universal waste cannot be stored on-
site for greater than 12 months. Universal Waste Batteries are collected in
containers marked with the words "Universal Waste Used Batteries (Ni-Cad,
Dry Lead, or Mercury Batteries Only)" or returned to the vendor for
recycling.
Shipping: Container DOT Specification: UN 1H2.
Waste Code: Not applicable to Universal Waste. Varies with hazardous
waste battery type: Ni-cad (D006), Mercury (D009) and Lead (D008).
Shipping Name: See waste profile.
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3.1.7 Sealed Gel Lead Acid Batteries
Characteristics: Sealed gel lead acid batteries contain lead and acid.
Classification: Undamaged non-leaking batteries are recyclable materials under 40 CFR
261.6 / R315-261-6 or universal waste under 40 CFR Part 273 / R315-273.
Damaged or leaking batteries are hazardous waste due to the
characteristics of lead (D008) and corrosivity (D002).
Disposal: Handle sealed gel lead acid batteries carefully to prevent damage and
potential acid spills. All batteries are place in plastic bags or terminals are
taped to prevent terminals from contacting and to prevent short circuits.
Recycled Batteries
Used batteries are stored in on-site specified locations (shops or
warehouse yards) prior to being returned to vendors for recycling when a
new battery is obtained.
Universal Waste
Batteries are handled as universal waste under 40 CFR Part 273 / R315-273
when a new battery is obtained. Used sealed gel lead acid batteries are
collected and stored in a plastic container, at the warehouse.
Hazardous Waste
Damaged leaking batteries are containerized and disposed as hazardous
waste. Each broken battery must be packaged in a separate plastic pail.
Analyses: Not required; constituents can be determined from SDSs.
Waste Handling: Hazardous Waste
Hazardous waste damaged or leaking batteries are collected in separate
plastic pails placed in plastic drums having properly completed EPA
hazardous waste markings, including the date when the drum becomes
full or 55 gallons of the waste has accumulated.
Universal Waste
Universal waste batteries are collected on-site in containers marked with
the words "Universal Waste Used Batteries (“Sealed Gel Lead Acid
Batteries Only"). Mark the universal waste container with the date the
waste is first put in the container. Universal waste cannot be stored on-site
for greater than 12 months.
Shipping: Container DOT Specification: UN/1H2.
Waste Code: Not applicable to universal waste. D008 (10 lbs) and D002
(100 lbs) for hazardous waste.
3.1.8 Carbon and Alkaline Batteries
Characteristics: Lamp and other miscellaneous batteries.
Classification: Rayovac zinc-carbon and alkaline batteries SDSs indicates waste batteries
are non-hazardous, solid wastes.
Disposal: Batteries are discarded in the trash.
Analyses: Not required; constituents can be determined from SDSs.
3.1.9 Lithium Batteries
Characteristics: Spent lithium ion batteries contain reactive and ignitable lithium.
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Classification: Recycled lithium batteries are subject to the Universal Waste
Management Standards located in 40 CFR Part 273 / R315-273. Discarded
lithium batteries containing reactive lithium are regulated for hazardous
waste characteristics of ignitability (D001) and reactivity (D003), unless
managed as universal wastes.
Disposal: Used lithium batteries are collected and stored in a plastic container, at
the designated location on-site and managed as universal or hazardous
waste. If disposed as a waste, they should be handled as hazardous
waste. Handle lithium batteries carefully to prevent damage. All batteries
are place in plastic bags or terminals are taped to prevent terminals from
contacting and to prevent short circuits.
Analyses: Not required; constituents can be determined from SDSs.
Waste Handling: Hazardous Waste
Hazardous wastes will be collected in drums having properly completed
EPA hazardous waste markings including the accumulation start date
when the drums are full. Containers are stored in a designated area within
the hazardous waste storage area or other designated areas until they
are shipped to a designated or a permitted Treatment, Storage, and
Disposal Facility (TSDF).
Universal Waste
Universal waste batteries are collected in containers marked with the
words "Universal Waste Used Batteries (Lithium Batteries Only)". Mark the
container with the date the waste is first put in the container. Universal
waste cannot be stored on-site for greater than 12 months. All batteries
are place in plastic bags or terminals are taped to prevent terminals from
contacting and to prevent short circuits.
Shipping: Container DOT Specification: UN/1A2 or UN/1H2.
Waste Code: D001 and D003 if disposed as hazardous waste. Not
applicable to universal waste.
Shipping Name: See waste profile.
3.1.10 Used Floor Dry or Sweeping Compound
Characteristics: Varies with wastes absorbed. Material may contain oil, TCLP toxicity
materials, or listed solvents or fuels. Listed solvents are typically not used at
the mine.
Classification: Normally non-hazardous solid waste; however, if contaminated with TCLP
toxicity materials or listed solvents or other hazardous materials, the floor
dry or sweeping compound may be regulated as a hazardous waste
when discarded.
Disposal: Non-draining (no free liquid) non-hazardous floor dry is routinely discarded
in the trash; however, large quantities generated from a spill cleanup are
containerized for characterization prior to disposal. Floor dry or sweeping
compound known to be contaminated with listed solvents or other
hazardous wastes should be segregated, containerized, and handled as
hazardous waste.
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Analyses: Normally not required except for characterization of potentially
contaminated floor dry. For spill cleanup waste characterization, review
of SDSs and/or testing may be required to determine regulatory status.
Waste Handling: Hazardous wastes are collected in open-head drums having properly
completed EPA hazardous waste markings, including the date when the
drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: UN/1A2.
Waste Code: Varies with waste analyses.
Shipping Name: See waste profile.
3.1.11 General Administrative Maintenance Wastes
Characteristics: Wastes produced from general maintenance of buildings including wood,
air filters, glass, pieces of metal, masonry, fiberglass and foam insulation
(except unused spray foam insulation aerosol cans), adhesives, yard care
products, hardware, and packaging.
Classification: Normally non-hazardous solid waste, however, if contaminated with F-
listed solvents or other hazardous materials, the wastes may be regulated
as a hazardous waste when discarded.
Disposal: Routinely discarded in the trash, however, wastes known to be
contaminated with F-listed solvents or other hazardous wastes should be
segregated, containerized, and handled as hazardous waste.
Analyses: Normally not required except for characterization of potentially
contaminated wastes. For contaminated waste characterization, review
of SDSs and/or testing may be required to determine regulatory status.
3.1.12 Pesticides
Characteristics: Small amounts of waste insecticides, herbicides, or rodenticides remaining
in RCRA empty containers. The facility only uses small amounts of these
materials.
Classification: Waste pesticides typically contain products that classify them as
hazardous waste. These materials are regulated by the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA) and RCRA. Recalled
pesticides and pesticides collected and managed as part of a waste
pesticide collection program are subject to the universal waste
management standards located in 40 CFR Part 273 / R315-273 if not
handled as hazardous waste.
Disposal: These products should be entirely used as intended whenever possible.
Unused waste pesticides should be handled as hazardous wastes
according to the manufacturers' recommendations. Pesticide containers
should be RCRA empty (see Section 3.1.21.) before being disposed in the
trash. Aerosol cans should be at atmospheric pressure when disposed.
Analyses: Not required, use manufacturer labels or SDSs.
Waste Handling: Hazardous wastes are collected in open-head lab pack drums having
properly completed EPA hazardous waste markings, including the date
when the drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: Various use SDS.
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Waste Code: Various use SDS.
Shipping Name: Various SDS.
3.1.13 Painting Wastes
Characteristics: Waste paint, thinners, paint brushes or rollers, masking material, rags,
wipes, and containers.
Classification: Latex (water-based) paint wastes are typically non-hazardous, solid
wastes. Oil-based painting related materials are typically hazardous
wastes. Most oil-based product reducers or thinners are hazardous due to
ignitability or listed solvent content. Spent reducers or thinners that
contain 10 percent or more of F-listed solvent prior to use are F-list solvent
hazardous waste. Oil-based paints may be hazardous due to ignitability
(D001), TCLP characteristic for lead (D008) or chromium content (D007).
Epoxy hardeners may be characteristic hazardous waste for corrosivity
(D002).
Disposal: Discard latex paints, containers, and painting wastes as solid wastes in the
trash after allowed to dry. Other waste paints, reducers, and thinners that
are either listed or have hazardous characteristics should be disposed as
hazardous waste at a RCRA-permitted facility. Epoxies should be
classified and disposed accordingly. Painting wastes (applicators, rags,
masking material, and empty containers) produced in the use of oil-
based paints may be hazardous if still wet when disposed.
Analyses: Apply generator knowledge; use previous characterization information,
SDS, and/or sample and test potentially hazardous painting wastes for
TCLP metals, F- and D-list total volatiles, F- and D-list total semi-volatiles
and ignitability.
Waste Handling: Solid hazardous wastes will be collected in open-head drums (UN/1A2).
Liquid hazardous wastes will be collected UN/1A1 drums. These drums will
have properly completed EPA hazardous waste markings, including the
date when the drum becomes full or 55 gallons of the waste has
accumulated.
Shipping: Container DOT Specification: UN/1A2 (solid) or UN/1A1 (liquid).
Waste Code: Varies with waste constituents.
Shipping Name: See waste profile.
3.1.14 Sanitary Wastewater and Sludge
Characteristics: Wastewater/sludge from toilets, sinks, eye wash stations, and showers.
Classification: Typically, non-hazardous. Listed hazardous wastes or materials that would
be a characteristic hazardous waste may render wastewater/sludge
hazardous and should not be disposed down toilets, sinks or showers.
Disposal: Sanitary wastewater is discharged through piping to the local publicly
owned treatment works.
Analyses: Not required.
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3.1.15 Warehouse Wastes
Characteristics: Unusable new products or materials that cannot be returned to the
vendors.
Classification: Inert parts and materials are typically non-hazardous solid waste.
Chemical products may be non-hazardous solid waste but may also be
listed hazardous wastes or characteristic hazardous wastes.
Disposal: Non-hazardous solid wastes are thrown in the trash. Chemical products
should be disposed according to typical operating practices or
according to SDS recommendations.
Analyses: Not required, follow label or SDS recommendations.
3.1.16 Safety-Health-Environment Department Wastes
Characteristics: Empty calibration gas cylinders, empty vials that contained sam ple
preservative chemicals, environmental analyses kits, and used Draeger
type sample or smoke tubes.
Classification: RCRA empty containers are solid waste. Used Draeger type sample or
smoke tubes may be non-hazardous solid waste but may also be listed
hazardous wastes or characteristic hazardous wastes.
Disposal: Non-hazardous solid wastes are thrown in the trash. Chemical products
should be disposed according to SDS recommendations.
Analyses: Not required, follow label or SDS recommendations.
3.1.17 Fire Extinguisher Powder
Characteristics: Dry-type fire extinguisher powder removed when servicing fire
extinguishers.
Classification: Non-hazardous material.
Disposal: Recycled back into extinguishers.
Analyses: Not required, follow SDSs for proper handling.
3.1.18 Used Computer Parts
Characteristics: Cathode Ray Tubes (CRTs) monitors, used computers, and circuit boards
(e-waste) contain TCLP metals. Electrical components include a variety of
electrical and electronic components for example, instrumentation
electronic components.
Classification: Varies with type and construction of component. Typically electrical
components are non-hazardous solid waste but could contain TCLP
metals such as mercury, silver, or lead.
Whole Used Circuit Boards
The scrap metal exemption applies to whole used circuit boards that
contain minor battery or mercury switch components and that are sent for
continued use, reuse, or recovery under 40 CFR 261.6 (a)(3)(ii) / R315-261-
6, RCRA Hotline fax back (14155), and (May 26, 1998, 63 FR 28556).
Used, Intact CRTs
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Used intact CRT monitors are not solid waste unless they are disposed
under 40 CFR 261.4 (a)(22) / R315-261-4.
Used, Broken CRTs
Used, broken CRT monitors are not solid waste provided that they meet
the requirements of 40 CFR Part 261.39 / R315-261-39. Documentation
must be on file from the recycling facility to show how recycling is
accomplished.
Hazardous Waste CRTs
CRT monitors waste is hazardous waste for lead (D008) if not recycled.
Disposal: Do not dispose recyclable e-waste in the trash. Material is accumulated
in containers for off site recycling. E-waste known to be contaminated
with hazardous wastes is segregated, containerized, and handled as
hazardous waste if not recycled.
Analysis Not required; constituents can be determined from SDSs.
Waste Handling: Recyclable Material:
Place used computer parts in cubic yard boxes on pallets and secure.
Label the boxed as “Used computer monitors and electronic equipment.”
Used, broken CRTs should be placed in boxes labeled, “Used cathode ray
tube(s)-contains leaded glass” and do not mix with other glass materials.”
Hazardous Waste:
Hazardous wastes will be collected in DOT specification cubic yard boxes.
These boxes will have properly completed EPA hazardous waste markings,
including the accumulation date when the box contains more than 7.4
cu. ft. (estimated 55-gallons) of waste.
Shipping: Container DOT Specification:
Recyclable Material:
Non-DOT specification containers may be used.
Hazardous Waste:
DOT specification cubic yard boxes.
Waste Code: CRTs - Lead (D008) and other various waste codes with
identified waste constituents.
Shipping Name: See waste profile.
3.1.19 Waste Electrical Components
Characteristics: Variety of unusable electrical and electronic components; for example,
instrumentation electronic components. Se e Section 3.1.18 for used
computer parts.
Classification: Varies with type and construction of component. Typically, non-
hazardous solid waste but could contain TCLP metals such as mercury,
silver, or lead. The scrap metal exemption applies to whole used circuit
boards that contain minor battery or mercury switch components and
that are sent for continued use, reuse, or recovery under 40 CFR 261.6
(a)(3)(ii) / R315-261-6, RCRA Hotline fax back (14155), and (May 26, 1998,
63 FR 28556). Documentation must be on file from the recycling facility to
show how recycling is accomplished.
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Disposal: Electrical components are accumulated for recycling or hazardous waste
disposal at approved facilities. Larger items such as motors are stored for
re-build, reuse, or resale.
Analyses: Not required for hardware that does not contain potentially toxic metals.
Components that are suspected of containing toxic metals should be
tested for TCLP metals before disposing.
3.1.20 Biohazard Waste
Characteristics: Biohazard waste from first aid operations and medical treatment.
Biohazard wastes include first aid waste containing blood.
Classification: Biohazard.
Disposal: Disposed off site at an approved incineration facility. Do not burn
biohazard waste on site or throw in the trash.
Waste Handling: Sharps are contained in rigid engineer-controlled containers. Non-sharps
biohazard wastes are contained in red biohazard bags. Sharps and non-
sharps biohazard waste containers should be placed in fiber barrels or
totes provided for these wastes. Biohazard containers are labeled with
biohazard labels.
Shipping: Container DOT Specification: UN/1G fiber drum or Non-DOT specification
tote (provided by the disposal facility).
Shipping Name: See waste profile.
3.1.21 Empty Product Containers
Characteristics: Empty containers previously holding ignitable materials may contain
explosive atmospheres. Use caution and ventilate.
Classification: Containers are empty and exempt from regulation (40 CFR 261.7 / R315-
261-7) when:
a. All products or waste have been removed that can be removed using
the practices commonly employed to remove materials from that
type of container, e.g., pouring, pumping, and aspirating, and
b. No more than 2.5 centimeters (one inch) of residue remain on the
bottom of the container or inner liner, or
c. No more than 3 percent by weight of the total capacity of the
container remains in the container or inner liner if the container is less
than or equal to 110 gallons in size, or
d. No more than 0.3 percent by weight of the total capacity of the
container remains in the container or inner liner if the container is
greater than 110 gallons in size.
e. Containers that have held compressed gases are empty when the
pressure in the container approaches atmospheric.
f. Containers that have held acute hazardous wastes must be rinsed or
cleaned per 261.7(b) / R315-261-7. Acute hazardous waste
constituents can be determined by comparing label/SDS constituents’
sole active ingredients, or hazardous waste from non-specific sources
to acute hazardous waste listed in 40 CFR 261.31, 261.32, or 261.33(e) /
R315-261-(31-33).
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Disposal: Small containers (<18 gallons) are discarded in the trash or managed as
scrap metal when empty. Large containers (>18 gallons) are recycled to
the vendor, reused, managed as scrap metal, crushed, cut in half
(plastic), and/or thrown in the trash. Containers that have held acute
hazardous waste will be rinsed with the appropriate reagent before being
discarded. The rinse reagent will be used in the same process as the
chemical if safe to do so or disposed.
Analyses: Not required.
3.1.22 Unusable New Products
Characteristics: Unusable new products or materials that cannot be returned to the
vendors.
Classification: Inert parts and materials are typically non-hazardous solid waste.
Chemical products may be non-hazardous solid waste but may also be
listed hazardous wastes or characteristic hazardous wastes.
Disposal: Non-hazardous wastes are thrown in the trash. Chemical products should
be disposed according to typical operating practices or according to SDS
recommendations.
Analyses: Not required, follow label or SDS recommendations.
3.1.23 Chlorinated Fluorocarbons/Refrigerant
Characteristics: Chlorinated Fluorocarbons (CFCs)/Refrigerants that are removed from
equipment air conditioning systems. See Section 3.2.25 for CFC
contaminated oil.
Classification: Excluded from regulation as solid waste under 40 CFR 261.2(e)(1)(ii) / R315-
261-2(e)(1)(ii) when recycled directly.
Disposal: This recyclable material is handled by certified employees or contractors
using a recovery unit.
Analyses: Not required.
3.1.24 Refrigeration Unit CFCs Oil Waste
Characteristic: Oil that comes in contact with CFCs during the normal use of the
refrigeration unit.
Classification: If total halogen is greater than 1,000 parts per million (ppm), then it is
treated as a hazardous waste unless it is sent to b e reclaimed for CFCs, 40
CFR 279.10(b)(ii)(B) / R315-279-10. If total halogen is less than 1,000 ppm,
then it can be managed as used oil.
Disposal: CFC work is conducted by certified technicians who may add new oil, but
they do not normally remove used oil. The facility has requested the
contractor to provide paperwork if they remove used oil with CFCs. If
greater than 1,000 ppm total halogen, ship to a facility that can reclaim
CFC from used oil or ship off as hazardous waste. If less than 1,000 ppm
total halogen, manage with used oil.
Analysis: Chlor-D-Tect test for total halogen content.
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3.1.25 Asbestos
Characteristics: Asbestos-containing waste containing greater than 1% by weight of
friable asbestos.
Classification: Solid waste requiring specialized handling practices under the Toxic
Substances Control Act (TSCA). Only properly certified employees or
contractors should handle asbestos.
Disposal: Disposed of off site at an approved landfill.
Analysis: Required to determine if suspect material is greater than 1% asbestos. A
trained asbestos inspector, as defined by EPA, must determine if material
is friable asbestos.
Waste Handling: Handling or removal must be performed by trained and/or certified
individuals (e.g., certified asbestos abatement technician). Double
bagged and placed into a double lined container. Containers are
labeled with one of the following warning labels: “Caution Contains
Asbestos Fibers Avoid Opening or Breaking Container Breathing Asbestos
Is Hazardous To Your Health”, “Caution Contains Asbestos Fibers Avoid
Creating Dust May Cause Serious Bodily Harm”, or “Danger Contains
Asbestos Fibers Avoid Creating Dust Cancer and Lung Disease Hazard.”
Check with receiving facility to determine proper shipping papers needed
for the facility (i.e. Clean Harbors requires a hazardous waste manifest).
Shipping: Container: Double lined container.
Waste Code: Not applicable.
Shipping Name: See waste profile.
3.1.26 Non-leaking Light Ballasts and Small Capacitors
Characteristics: Light ballasts and small capacitors removed from light fixtures.
Classification: If ballast and capacitors are labeled as non-Poly
Chlorinated Biphenyl (PCB), they are a non-hazardous solid waste. If the
ballasts or capacitors are labeled as containing PCB or have no labeling,
the facility is managing the waste as a Toxic Substances and Control Act
(TSCA) waste.
Disposal: Non-PCB ballasts and small capacitors can be thrown in the trash. PCB
containing ballasts and small capacitors should be containerized for
disposal at an approved TSCA facility.
Analysis: Not required; use labels on ballasts and small capacitors.
Waste Handling: TSCA PCB wastes are collected in open-head drums labeled with a PCB
marking. PCBs or PCB Items designated for disposal must be disposed of
within 1 year from the date it was determined to be a PCB waste and the
decision was made to dispose of it. This is the date of removal from service
and the point at which the 1-year time frame begins. Therefore, when the
drum is full or after 9 months, whichever is first, the drum should be shipped
for disposal to meet the 1-year disposal requirement. Waste must be
shipped using a hazardous waste manifest.
Shipping: Container DOT Specification: UN/1A2 (metal open-head drum).
Waste Code: Not applicable to TSCA waste.
Shipping Name: See waste profile.
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Reportable Quantity: PCBs (1 lb).
3.1.27 Transformer Oil (No-PCB and PCB Oil)
Characteristics: Empty transformers, large capacitors, oil drained from transformers during
maintenance, and leaking PCB light ballasts or small capacitors. PC B
containing equipment has not been identified on site. However, PCB
information is included if any PCB containing equipment is identified.
Classification: Past analyses indicate oil to be No-PCB and PCB. Any oil containing any
quantifiable level of PCBs (2 ppm) and oil-filled electrical equipment
containing > 50 ppm PCBs is regulated under TSCA. The TSCA cleanup
standards range from > 1 ppm in a residential or high occupancy area to
< 25 ppm in a low occupancy area. Spill cleanups originating from PCBs <
50 ppm are regulated under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), Superfund Amendments and
Reauthorization Act of 1986 (SARA) and State Department of
Environmental Quality (DEQ) requirements. The CERCLA SARA and/or
DEQ cleanup standards for PCBs are typically < 1 ppm. Therefore, empty
electrical equipment previously containing any detectable amount of
PCB should be managed at a company approved facility.
Disposal: No-PCB large capacitors are recycled by an approved remanufacturer.
Large capacitors, leaking light ballasts, and leaking small capacitors
containing PCB are disposed at a TSCA facility. No-PCB oil is handled as
used oil (see Section 3.2.1). PCB oil is disposed of as PCB at an approved
facility. Empty equipment previously containing no-PCB and/or PCB < 50
ppm is recycled at an approved remanufacturing facility.
Analyses: Not required unless the oil has not been previously analyzed or is
contaminated during maintenance with solvent or other materials. Oil
suspected of containing PCBs should be tested for PCBs before disposing.
Waste Handling: Liquid TSCA PCB wastes are collected in closed-top drums. Large
capacitors, leaking light ballasts, and leaking small capacitors containing
PCB are collected in open top drums. PCBs or PCB Items designated for
disposal must be disposed of within 1 year from the date it was
determined to be a PCB waste and the decision was made to dispose of
it. This is the date of removal from service and the point at which the 1-
year time frame begins. Therefore, when the drum is full or after 9 months
whichever is first the drum should be shipped for disposal to meet the 1-
year disposal requirement. The TSCA waste must be shipped using a
hazardous waste manifest.
Shipping: Container DOT Specification: Liquids UN/1A1 (metal closed-top drum) and
solids UN/1A2 (metal open-head drum) or 1H2 (plastic open-head drum).
Waste Code: Not applicable to TSCA waste.
Shipping Name: See waste profile.
3.1.28 Mercury Waste
Characteristics: Mercury in instruments (i.e. switches and testing equipment), thermostats,
and/or spills.
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Classification: Mercury thermostats and mercury containing equipment can be
managed as universal waste under 40 CFR Part 273 / R315-273 or as waste
mercury and contaminated debris D009 (mercury) hazardous waste if not
managed as universal waste.
Disposal: Universal Waste
Managed as universal waste if not managed as hazardous waste.
Hazardous Waste
Managed as hazardous waste (D009) if not managed as universal waste.
Analyses: Not required. Use generator knowledge as hazardous or universal waste
(thermostats or mercury containing equipment).
Waste Handling: Hazardous Waste
Accumulated in open top drums having properly completed EPA
hazardous waste markings, including the date when the drum becomes
full or 55 gallons of the waste has accumulated.
Universal Waste
Universal waste will be placed in an open top drum labeled as “Universal
Waste - Mercury Thermostats or Mercury Containing Equipment.” Mark
the container with the date the waste is first put in the container. Universal
waste cannot be stored on site for greater than 12 months.
Shipping: Container DOT Specification: UN/1A2 or 1H2 open-head drum.
Waste Code: Varies with waste analyses.
Shipping Name: See waste profile.
3.2 VEHICLE, MOBILE EQUIPMENT, AND SHOP WASTE
Description: Fleet equipment is serviced in the field or in the truck shop. Major equipment
repairs and preventative maintenance are completed at the Thatcher truck shop. Mobile lube
and utility trucks provide field lubrication and maintenance services.
3.2.1 Used Oil and Used Oil Burner Ash
Characteristics: Used lubricating oil and hydraulic oils, including brake and transmission
fluid, generated from vehicle and machinery with minor amounts of fuel
constituents and metals. It is facility policy to not mix used oil with solvents,
coolants, or other waste materials. Analyses have indicated that the oil
meets the criteria for specification used oil. Used oil burner ash may
contain metals.
Classification: Used Oil
Non-hazardous solid waste unless contaminated with degreasing solvent
or toxic metals. It is a facility policy that degreasing solvents are not to be
mixed with used oil. In addition, only non-chlorinated degreasing solvents
will be used. Wear of engine parts or hydraulic systems may contaminate
oil with metals resulting in oil classification as off-specification oil, if
recycled or as a hazardous waste, if disposed. Although used oil destined
for disposal or recycling is not listed as a hazardous waste, the EPA has
established standards for managing used oil (40 CFR Part 279). Used oil
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burned for energy recovery under these rules must be analyzed to show if
it meets used oil specifications.
Used Oil Burner Ash
Wear of engine parts or hydraulic systems may contaminate “used oil”
with metals resulting in ash containing metals. Ash with metals below TCLP
metals regulatory levels is non-hazardous solid waste and ach with metals
exceeding TCLP metals is hazardous waste.
Disposal: Used Oil
Used oil generated in the maintenance of mobile equipment is
vacuumed to the shop tank and/or collected in totes or drums and stored
in aboveground storage tanks within secondary containment. Used oil
from equipment that is maintained in the field is handled in a mobile tank
that is then brought to the designated shop where the oil from the mobile
tank is transferred to the stationary tank. Used oil is recycled off site at
approved facilities. Used oil is tested on a routine basis prior to on site or
off site recycling. A contractor picks up used oil for off site recycling for
energy recovery.
Used Oil Burner Ash
Non-hazardous solid waste ash is thrown in the trash. Hazardous waste ash
is accumulated in a satellite accumulation drum.
Analyses: Used Oil
Used oil shipped off site for recycling is tested for specifications (40 CFR
279.11 / R315-279-11).
Used Oil Burner Ash
Ash is analyzed for TCLP metals.
Waste Handling: Used Oil Off Site Recycling
The facility will not be a “Used Oil Marketer,” “Used Oil Processor/Re-
Refiner,” or a “Used Oil Transporter.” The facility’s procedures for used oil
management include the following: (1) We will not, nor will we allow any
“hazardous waste” to be mixed with our used oil; (2) We will only use a
pre-approved marketer/transporter having a valid EPA identification
number to transport our used oil; (3) We will not direct shipments of used
oil, and we will make no claim in regard to the used oil specification for
used oil recycled off site; (4) We will require that the transporter analyze
each shipment of used oil with Chlor-D-Tect ® test kits or the equivalent, to
verify that the total organic halogens (TOX) concentration is below 1,000
ppm before transportation. The results of this analysis will be provided to,
and retained by, the on site environmental personnel. If the analysis show
TOX in excess of 1,000 ppm, a sample will be collected and tested for
total volatiles and TCLP metals (standard turnaround) before the used oil is
transported off site for disposal; and, (5) We will use generator knowledge
and previous specification sample test results for used oil characterization.
Used Oil Burner Ash
Ash managed as hazardous wastes will be collected in open top drums
having properly completed EPA hazardous waste markings, including the
date when the drum becomes full or 55 gallons of the waste has
accumulated.
Shipping: Used Oil Burner Ash
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Hazardous Waste container DOT Specification: UN/1A2.
Waste Codes: Varies with waste analyses.
Shipping Name: See waste profile.
3.2.2 Used Oil, Air, Diesel Fuel, Gasoline, and Coolant Filters
Characteristics: Used oil filters contain used oil, dirt, and metal particles. Used coolant
filters contain coolant, dirt, and metal particles. Air filters contain dirt.
Diesel fuel filters contain diesel fuel, dirt, and metal particles. Gasoline
filters contain gasoline, dirt, and metal particles.
Classification: Used coolant and air filters are non-hazardous solid wastes. Used oil filters
are excluded from regulation as hazardous waste provided they are non-
terne plated, have not been mixed with a listed hazardous waste, and
have been punctured or dismantled, and gravity hot-drained (40 CFR
261.4 (b)(13) / R315-261-4 or crushed. Drained and/or crushed used diesel
fuel (diesel fuel > 140˚F) filters are non-hazardous solid waste. Used
gasoline/fuel filters are hazardous for ignitability (D001) and/or benzene
(D018). Drain and accumulate liquids in proper containers. Drained fuel
filter may be classified as scrap metal under 40 CFR 261.6 (a)(3)(ii) / R315-
261-6, under the June 3, 1998 RCRA online number: 14184 Regulatory
Status of Spent Metal Filters Under RCRA.
Disposal: Used oil filters are punctured on the filter dome end, then hot-drained for
at least 24 hours and/or crushed. Diesel and coolant filters are drained
and/or crushed. The diesel and used oil are combined with other used oil
generated on site and coolant is combined with coolant. Coolant is
collected in a separate bulk tank. Used oil and coolant filters that are
drained and/or crushed, and air filters are thrown in the trash. Gasoline
fuel filters are accumulated in hazardous waste containers or drained and
managed as scrap metal. Gasoline is used or accumulated and
managed under 3.2.10.
Analyses: None required as long as the above procedures are followed.
Waste Handling: Gasoline fuel filters managed as hazardous waste will be collected in
open-head drums having properly completed EPA hazardous waste
markings, including the date when the drum becomes full or 55 gallons of
the waste has accumulated.
Shipping: Container DOT Specification: UN/1A1.
Waste Codes: Gasoline fuel filters hazardous waste D001 and/or D018.
Shipping Name: See waste profile.
3.2.3 Used Grease
Characteristics: Vehicle and machinery greases that may contain regulated metals as
part of their formulation and/or from wear of metal parts. Wear of
mechanical parts on bearings may contaminate grease with metals. Use
of fuel or solvent for clean-up may contaminate the grease. Analyses of
this material have indicated that it is non-hazardous.
Classification: Non-hazardous solid waste unless contaminated with metals or
degreasing solvents. Metals in grease may produce a TCLP toxic
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hazardous waste. Any degreasing solvents mixed with grease may
produce an F-listed hazardous waste.
Disposal: Non-hazardous greasy rags and floor dry are discarded in drums labeled
trash. Larger quantities of used grease are disposed off site for recycling,
fuel blending, or incineration depending on waste analyses.
Analyses: Not required for unused or uncontaminated grease; constituents can be
determined from SDSs. For grease containing degreasing solvent or spill
cleanup waste, characterization review of SDS and/or testing may be
required to determine regulatory status. Test for TCLP metals and F- and
D-list total volatiles before shipping any previously uncharacterized grease
off site for disposal.
Waste Handling: Non-Hazardous Solid Waste:
Used grease is collected in open top drums having properly completed
markings.
Hazardous Waste:
Wastes are collected in open-head drums having properly completed
EPA hazardous waste markings, including the date when the drum
becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification:
Non-Hazardous Solid Waste:
Non-DOT specification containers may be used (i.e., the original grease
shipping containers if in good condition) or DOT specification containers
UN/1A2.
Hazardous Waste:
UN/1A2.
Waste Code: Varies with hazardous waste analyses.
Non-Hazardous Waste:
Mark the container with the wording “Used Grease.”
Hazardous Waste:
Shipping Name: See waste profile.
3.2.4 Used Floor Dry
Characterization and handling are the same as Section 3.1.10.
3.2.5 Used Rags, Wipes, Absorbent Pads, and Socks
Characteristics: Varies with use and materials absorbed. May contain oil, solvents, fuels,
and/or various substances.
Classification: Typically, non-hazardous solid waste. If wet with non-listed solvent, fuel,
used oil, or other regulated materials, the rags may be an ignitable (D001)
hazardous waste when discarded. If contaminated with listed degreasing
solvents, may be a (F002-F005) hazardous waste.
Disposal: Routinely generated non-hazardous rags, wipes, absorbent pads, and
socks that are not wet with oil, solvent, and/or fuel are discarded in the
trash barrels. Wet non-hazardous oily rags are drained, and petroleum
hydrocarbon products are accumulated with the used oil. Rags, wipes,
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absorbent pads, and socks that are wet with ignitable liquids or are known
to be contaminated with listed solvents or other hazardous materials
should be segregated, containerized, and handled as hazardous waste.
Analyses: Normally not required except for characterization of potentially
contaminated rags. For spill cleanup, waste characterization review of
SDS and/or testing may be required to determine regulatory status.
Waste Handling: Hazardous wastes are collected in open-head drums having properly
completed EPA hazardous waste markings, including the date when the
drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: UN/1A2.
Waste Code: Varies with waste analyses.
Shipping Name: See waste profile.
3.2.6 Used Engine Coolant (Glycol-Based Antifreeze)
Characteristics: Ethylene glycol and water (50:50 mix) drained from mobile eq uipment
may contain regulated metals and benzene. Ethylene glycol is toxic by
ingestion. Analyses of this material have indicated it is non-hazardous.
Classification: Non-hazardous solid waste unless contaminated with metals, fuels,
solvents, or other maintenance wastes. TCLP metal analyses of used
coolant from the facility were below hazardous waste regulatory levels. If
TCLP metals exceed hazardous waste regulatory levels, antifreeze would
be regulated as hazardous waste.
Disposal: Typically used consumptively or reused. Accumulated coolant is
collected in drums or tanks for recycling and recycled on site or off site
(by an approved facility). The approved contractor routinely tests and
evacuates the used antifreeze storage tank. Used coolant storage
containers including drums and tanks must be marked with the words
“Used Antifreeze.” Hazardous wastes should be segregated,
containerized, and handled as hazardous waste.
Analyses: Use coolant SDSs, apply generator knowledge, and/or sample initially
(and any time the process changes).
3.2.7 Water-Sediment/Sludges from Sumps
Characteristics: Water with dirt, detergent, and de minimis amounts of spilled fuel,
coolant, oil, grease, and solvents.
Classification: Typically, non-hazardous solid waste and used oil/grease.
Sediment/Sludge may contain hydrocarbons, characteristic hazardous
waste, and/or listed hazardous waste.
Disposal: Water and sediment in sumps is removed by a contractor with a vacuum
truck and managed according to classification. Absorbent booms may
be used. Absorbent booms are managed under 3.2.5 Absorbent Pads.
Petroleum Contaminated Soil (PCS) (non-hazardous) is containerized and
disposed at off site approved facilities. Solids/sludges that are wet with
ignitable liquids or are known to be contaminated with listed solvents or
other hazardous materials are segregated, containerized, and handled as
hazardous waste.
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Analyses: Not required for non-hazardous water and sediment. Apply generator
knowledge; use previous characterization and/or SDS information for
solids/sludge. Sample and test if necessary due to process or product
changes. Sample and test sludge for total petroleum hydrocarbons (TPH),
TCLP metals, total F- and D-list volatiles and/or semi-volatiles in order to
characterize. For spill cleanup waste characterization, a review of SDS
and/or testing may be required to determine regulatory status.
3.2.8 Aerosol Paints, Cleaners, Lubricants, and Vent Filters
Characterization and handling are the same as Section 3.1.4.
3.2.9 Contaminated or Waste Diesel Fuel
Characteristics: Diesel fuel resulting from servicing equipment and from spill cleanups.
Classification: Flash point of diesel fuel used at the facility is typically above 140˚F which
would not be RCRA ignitable. Diesel fuel mixed with used oil is regulated
as used oil, provided the resultant mixture does not exhibit the
characteristic of ignitability under 40 CFR Part 279.10 (b)(2)(iii) / R315-279-
10.
Disposal: Non-hazardous waste diesel fuel is collected in drip buckets and
combined in designated drums around the property. This is mixed with
used oil for recycling or energy recovery. PCS (non-hazardous diesel-
contaminated) is containerized and disposed at off site approved
facilities. Floor dry contaminated with adsorbed (no free liquid) diesel fuel
is thrown in the trash.
Analyses: Not required unless diesel fuel with a lower flash point is purchased and
disposed with used oil. Mixtures of diesel fuel and other materials to be
disposed off site will be tested for ignitability.
3.2.10 Contaminated or Waste Gasoline and/or Kerosene
Characteristics: Contaminated or off-specification waste gasoline from fueling vehicles or
from spills. Contaminated or off specification kerosene from use for
heating or from spills. Liquid waste must not be solidified for disposal.
Classification: Possible hazardous waste due to characteristics of ignitability (D001) and,
benzene (D018) if present in strong concentrations. Is exempt from
regulation as a hazardous waste under the Mixture Rule (40 CFR Part 261.3
(a)(2)(iii) / R315-261-3) if small concentrations are mixed with motor oil, or
other solid wastes and the resulting mixture no longer exhibits a
characteristic of hazardous waste. Also exempt from regulation if used as
a fuel such as burned for energy recovery.
Disposal: Liquid gasoline and kerosene disposed as a hazardous waste is shipped as
D001 and/or D018 hazardous waste if the discarded material exhibits the
characteristics. Exempt if used as a fuel. PCS (non-hazardous soil
contaminated with small amounts of gasoline) is containerized and
disposed at off site approved facilities. Solids/sludges that are wet with
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ignitable liquids are segregated, containerized, and handled as
hazardous waste.
Analyses: Apply generator knowledge; use previous characterization and/or SDS
information. Mixtures of gasoline, kerosene, and other materials to be
disposed off site will be tested for ignitability, TCLP benzene for solids
and/or total benzene for liquids. Mixtures of gasoline, kerosene, and other
materials that are recycled or used for energy recovery do not require
testing.
Waste Handling: Recyclable material or hazardous wastes will be collected in closed-top
drums. Hazardous waste containers will have properly completed EPA
hazardous waste markings, including the date when the drum becomes
full or 55 gallons of the waste has accumulated. Drums containing
flammable liquids must be grounded when adding or removing waste.
Shipping: Container DOT Specification: UN/1A1
Waste Code: D001 and/or D018 for hazardous waste and none if used as
a fuel.
Shipping Name: See waste profile.
3.2.11 Empty Product Containers
Characterization and handling are the same as Section 3.1.21.
3.2.12 Lead Acid Batteries
Characteristics: Vehicle and equipment batteries containing acid and lead.
Classification: Non-hazardous solid waste if recycled. Recycling requirements for lead-
acid batteries are found in 40 CFR 261.6 (a)(2) and (a)(3) / R315-261-6.
Damaged or leaking batteries are hazardous waste due to the
characteristics of lead (D008) and corrosivity (D002). If not recycled under
the recycling requirement above, recycled lead acid batteries are
subject to the Universal Waste Management Standards located in 40 CFR
Part 273 / R315-273.
Disposal: Handle lead acid batteries carefully to prevent damage and potential
acid spills. Damaged batteries may be costlier to recycle. Battery
terminals should be protected to prevent short circuits.
Recycled Batteries
Used batteries are stored in on-site specified locations (shops or
warehouse yards) prior to being returned to vendors for recycling when a
new battery is obtained.
Universal Waste
If not recycled under the recycling requirement above batteries are
handled as universal waste under 40 CFR Part 273 / R315-273 when a new
battery is obtained. Used lead acid batteries are collected and stored at
the warehouse.
Hazardous Waste
Damaged leaking batteries are containerized and disposed as hazardous
waste. Each broken battery must be packaged in a separate plastic pail.
Analyses: Not required; constituents can be determined from SDSs.
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Waste Handling: Hazardous Waste
Hazardous waste damaged or leaking batteries are collected in separate
plastic pails placed in plastic drums having properly completed EPA
hazardous waste markings, including the date when the drum becomes
full or 55 gallons of the waste has accumulated.
Universal Waste
Universal waste batteries are collected in containers marked with the
words "Universal Waste Used Batteries” (“Lead Acid Batteries Only"). Mark
the universal waste container with the date the waste is first put in the
container. Universal waste cannot be stored on-site for greater than 12
months.
Shipping: Container DOT Specification: UN/1H2.
Waste Code: Not applicable to universal waste. D008 (10 lbs) and D002
(100 lbs) for hazardous waste.
Shipping Name: See waste profile.
3.2.13 Scrap Metal Including Welding Rod and Cuttings
Characteristics: Pieces of metal scrap, used metal parts, and welding rod.
Classification: Recyclable material 40 CFR 261.6 / R315-261-6.
Disposal: Scrap metal is saved in recycling bins and/or specified locations and
picked up by a recycling contractor. Contractors routinely remove scrap
metal or used parts are returned to the vendor.
Analyses: Not required for recycled scrap metal.
3.2.14 Compressed Gas Cylinders
Characteristics: Typically, empty when disposed but may contain pressurized hazardous
materials if not empty.
Classification: Non-hazardous solid waste when empty. Reactive (D003) and/or
ignitable (D001) hazardous waste if still pressurized. Waste codes may
vary with constituents.
Disposal: Compressed gas vendors pick up large empty cylinders and refill them for
use. All gas cylinders not returned to vendors for use will be emptied to
atmospheric pressure before being thrown in the trash or recycled for
metal content (valves are removed or left open according to good
management practice). Mark empty cylinders with an “empty” sticker
and dispose in the trash (small disposable cylinders only) if empty. Non-
empty cylinders are recycled or disposed off site at a permitted facility.
Analyses: Not required; constituents can be determined from SDSs.
3.2.15 Cold Cutting Fluid
Characteristics: Used cold cutting fluid and metals from metal cutting saws. It is a good
management practice to not mix solvents, coolants, or other waste
materials with cutting fluid.
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Classification: Non-hazardous solid waste unless contaminated with metals or
degreasing solvents. Oil-based fluid is managed as used oil (see Section
3.2.1). Water-based fluid is typically non-hazardous solid waste but may
be hazardous if heavily contaminated with listed solvents or regulated
metals.
Disposal: Typically used consumptively. Excess oil-based fluid is mixed with used oil
for disposal (see Section 3.2.1). Acceptable non-hazardous solid wastes
with free liquids must be solidified/dried before disposing in the trash.
Hazardous waste water-based fluid is accumulated separately in drums
for off site disposal at permitted facilities.
Analyses: Not required for oil-based fluid unless there are process changes. Apply
generator knowledge, use previous characterization information, and SDS
for characterization of water-based fluid and/or sample and test for TCLP
metals and volatile organics (if identified by generator knowledge) to
verify characteristics. Once characterized, apply generator knowledge
and sample to re-characterize any time the process changes.
Waste Handling: Hazardous wastes are collected in closed-top drums having properly
completed EPA hazardous waste markings, including the date when the
drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: UN/1A1 (metal closed-top drum).
Waste Code: Varies with waste analyses.
Shipping Name: See waste profile.
3.2.16 Machine Tool Fluids
Characteristics: Machining fluids from cleaning out machine tool sumps.
Classification: Machining fluids used at the facility typically are not hazardous wastes.
Disposal: Typically, fluids are used consumptively but used oils removed from sumps
would be handled as used oil.
Analyses: Not required for oil-based fluid unless there are process changes. Apply
generator knowledge, use previous characterization information, and SDS
for characterization of water-based fluid and/or sample and test for TCLP
metals and volatile organics (if identified by generator knowledge) to
verify characteristics. Once characterized, apply generator knowledge
and sample to re-characterize any time the process changes.
3.2.17 Spent Solvent (Water and/or Hydrocarbon-Based), Sludge, and/or
Filters from Parts Washers or Bulk Solvent Use
Characteristics: Water-based and/or hydrocarbon-based spent solvent, sludge and filters
from bulk solvent use or parts washers. Typically spent solvents, sludge
and filters contain dirt, oil, and grease. Unused and/or spent solvent has a
flash point greater than 140˚F. Spent solvent, sludge and filters may also
contain metals from parts cleaning. If sludge is separated for disposal, it
will typically contain hydrocarbons. Do not mix F-listed solvent with solvent
from parts washers.
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Classification: Accumulated spent solvent, sludge, and/or filters not exceeding
hazardous waste regulatory limits are handled as non-hazardous solid
waste. These may be hazardous if mixed with listed solvents and/or
heavily contaminated with regulated metals. Accumulated spent
solvent, sludge, and/or filters exceeding hazardous waste regulatory limits
are handled as hazardous waste. If Safety Kleen solvent is being used,
Safety Kleen may include the plant parts washers in their continued use
program which is, when they service the washer, they reuse the solvent
from our washer to clean their drums at their facilities becoming the end
user. If Safety Kleen solvent exceeds hazardous waste reg ulatory limits and
is not used in Safety Kleen’s continued use program it must be handled as
hazardous waste.
Disposal: Non-hazardous cartridge type filters are drained and managed the same
as used oil filters (see Section 3.2.2) and non-hazardous cellulose filters are
drained and thrown in the trash. Non-hazardous combustible spent
solvent may be managed with used oil (see Section 3.2.1). Non-
hazardous sludge is containerized and managed as non-hazardous solid
waste for on or off site disposal. Spent solvent, sludge, and/or filters known
to be contaminated with listed solvents or other hazardous wastes, are
segregated, containerized, and handled as hazardous waste at
permitted facilities. Spent Safety Kleen solvent may be used by Safety
Kleen in their continued use program.
Analyses: Not required for unused solvent constituents (may be obtained from SDS).
Apply generator knowledge; use previous characterization information,
and SDS for characterization of filters and used solvent and/or sample and
test initially (and anytime the process changes) for TCLP metals and F- and
D-list volatile organics (if identified by generator knowledge) to verify
characteristics. Once characterized apply generator knowledge and
sample and re-characterize any time the process changes.
Waste Handling: Hazardous Waste
Hazardous waste liquids are collected in closed top drums, and filters
and/or sludges are collected in separate open head drums having
properly completed EPA hazardous waste markings, including the date
when the drum becomes full or 55 gallons of the waste has accumulated.
Safety Kleen Continued Use Program
Liquids are collected in open and/or closed top drums having properly
completed markings provided by Safety Kleen.
Shipping: Container DOT Specification: UN/1A2.
Waste Code: Varies with waste analyses.
Shipping Name: See waste profile.
3.2.18 Hot Water Parts Washer Spent Filters, Water, Sludge, and Skimmer
Waste
Characteristics: "Hot water parts washer" filters, water, sludge, and skimmer waste which
contains high pH detergent (before use) and may contain metals, oil,
grease, and solvents from parts cleaning. Detergent solutions typically
exhibit a neutral pH after use.
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Classification: Water, sludge, and skimmer (oil) waste are typically non-hazardous solid
wastes but may be hazardous if heavily contaminated with regulated
metals or listed solvents. Non-hazardous skimmer oil is managed as used
oil. Non-hazardous filters are handled the same as used oil filters.
Accumulated water, sludge, and/or filters exceeding hazardous waste
regulatory limits are handled as hazardous waste.
Disposal: Water and sludge are containerized, sampled, characterized, and
classified for disposal. Non-hazardous water and/or sediment/sludge is
transferred by a vacuum truck to the wash bay sump. Non-hazardous
skimmer oil is managed with use oil (see Section 3.2.1). Non-hazardous
cartridge type filters are drained and managed the same as used oil filters
(see Section 3.2.2) and non-hazardous cellulose filters are drained and
thrown in the trash. Hazardous waste water, sludge, and/or skimmer
waste is accumulated separately in drums for off site disposal at permitted
facilities.
Analyses: Apply generator knowledge, use previous characterization information,
and SDS for characterization of filters, water, sludge, and/or skimmer
waste and/or sample and test for TCLP metals and volatile organics (if
identified by generator knowledge) to verify characteristics. Once
characterized apply generator knowledge and sample to re-characterize
any time the process changes.
Waste Handling: Hazardous wastes are collected in open-head drums having properly
completed EPA hazardous waste markings, including the date when the
drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: UN/1A2.
Waste Code: Varies with waste analyses.
Shipping Name: See waste profile.
3.2.19 Used Desiccants
Characteristics: Used desiccant from various air drying systems.
Classification: Desiccant is typically non-hazardous solid waste.
Disposal: Dry non-hazardous waste is thrown in the trash.
Analyses: Not required for product; constituents can be determined from
labels/SDSs. Apply generator knowledge; use previous characterization
and/or SDS information. Sample and test if necessary due to process or
product change. Not required except for characterization of potentially
hazardous spent desiccant. Desiccant is typically tested for TCLP metals.
Once characterized apply generator knowledge and sample to re-
characterize any time the process changes.
3.2.20 Ni-Cad, Mercury, Dry Lead Batteries, or Sealed Gel Lead Acid
Characterization and handling are the same as Section 3.1.6.
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3.2.21 Lithium Batteries
Characterization and handling are the same as Section 3.1.9.
3.2.22 Carbon and Alkaline Flashlight Batteries
Characterization and handling are the same as Section 3.1.8.
3.2.23 General Maintenance Wastes
Characteristics: Waste paper, metal, plastic, cardboard, wood, wrapping and packaging,
RCRA empty containers and aluminum cans.
Classification: Typically, non-hazardous solid waste; however, non-empty containers of
hazardous products may be hazardous wastes when disposed. Scrap
metal is recyclable material under 40 CFR 261.6 (a)(3)(ii) / R315-261-6.
Disposal: Non-hazardous wastes are thrown in the trash. Recyclable materials are
accumulated for off site recycling. Non-empty containers (i.e., adhesive
and oil etc.) will be disposed as required for the material characteristics.
Analyses: Not required; use product labels and SDSs for chemical products that are
discarded.
3.2.24 Chlorinated Fluorocarbons/Refrigerant
Characterization and handling are the same as Section 3.1.23.
3.2.25 Refrigeration Unit CFCs Oil Waste
Characterization and handling are the same as Section 3.1.24.
3.2.26 Paint-Related Materials Including Blasting Grit
Characterization and handling are the same as Section 3.4.
3.2.27 Pressure Washing Wastes
Characteristics: Pressure washing overspray, oil, grease, and metals (water & chemical
additive; normally alkaline detergent). Undiluted product pH may be
corrosive.
Classification: Typically, non-hazardous solid waste but this wastewater may contain
listed or characteristic hazards according to generator knowledge. The
wastewater may be hazardous if heavily contaminated with regulated
metals, listed cleaning solvents, and/or characteristic cleaning solvents.
Unused, undiluted product additives or detergents may be hazardous
waste if discarded.
Disposal: Consult the SDS for disposal of unused or spilled pressure washing
chemicals. PCS (non-hazardous) is containerized and disposed at off site
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approved facilities. Wash water suspected of containing regulated
metals, listed cleaning solvents, and/or characteristic cleaning solvents is
containerized, sampled, and tested. Wash water failing for corrosivity only
is neutralized in containers and disposed in the water management
system. Hazardous waste wash water is disposed as hazardous waste off
site. Acceptable non-hazardous solid wastes with free liquids must be
solidified/dried before disposing in the trash.
Analysis: A change in the detergent formulation or product used requires a rev iew
of the SDS and pH testing. Not required except for characterization of
potentially contaminated wash water. For wash water containing
regulated metals, listed cleaning solvents, and/or characteristic cleaning
solvent waste characterization review of generator knowledge, SDS
and/or testing may be required to determine regulatory status. Test for pH
and TCLP metals before disposing of any previously uncharacterized wash
water.
3.2.28 Air Cooler Filters
Characteristics: Air filters contain dust from filtering outside and work area air.
Classification: Non-hazardous solid wastes.
Disposal: Air filters are thrown in the trash.
Analyses: None required.
3.3 TIRE REPAIR (TRUCK SHOP)
Description: Tire repair is conducted at the facility and involves use of adhesives and solvents.
Various wastes that are produced during tire repair are discussed below.
3.3.1 Tire Cleaner and Adhesive
Characteristics: Unused cleaners and adhesives from tire maintenance may be ignitable
and may contain toxic characteristic solvents. Used cleaners may contain
listed solvents.
Classification: Ignitable cleaners and/or cleaners containing toxic characteristic solvents
would be hazardous waste when discarded. Cleaners that contain 10
percent or more of F-listed solvent when spent are F-list solvent hazardous
waste. Review SDSs or labels for disposal requirements.
Disposal: Products are typically used consumptively with no waste. Unused
cleaners are typically hazardous due to ignitability or toxic characteristic
solvent content. Unused materials or used cleaners known to be
contaminated with listed solvents or other hazardous wastes should be
segregated, containerized, and handled as hazardous waste.
Analyses: Not required; constituents can be determined from SDSs.
3.3.2 Tire and Wheel Balance Weights
Characteristics: Lead weights.
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Classification: Recyclable material. Lead weights are hazardous waste for TCLP lead
(D008) if discarded.
Disposal: Accumulated used weights are recycled for use as weights and are not
disposed. Used weights are fully consumed.
Analyses: Not required.
3.3.3 Tire Prep Solution
Characteristics: Contains glycol and inert chemicals.
Classification: Typically used consumptively with no waste. Non-hazardous solid waste,
unless contaminated with listed solvents or other hazardous materials.
Disposal: Spills of tire life are absorbed and thrown in the trash.
Analyses: Not required; constituents can be determined from SDSs.
3.3.4 Tires
Characteristics: Chemically inert.
Classification: Non-hazardous solid waste.
Disposal: Tires are managed and disposed of off site by contractors.
Analyses: Not required.
3.3.5 Used Floor Dry
Characterization and handling are the same as Section 3.1.10.
3.3.6 Used Rags, Wipes, Absorbent Pads, and Socks
Characterization and handling are the same as Section 3.2.5.
3.3.7 Empty Product Containers
Characterization and handling are the same as Section 3.1.21.
3.4 EQUIPMENT PAINTING
Description: The facility will typically contract for sand blasting and painting of its larger
equipment and may also conduct its own small sand blasting and spray-painting jobs.
Equipment is cleaned and sand blasted to prepare it for painting. The painting process is
completed at the equipment location. Various paints, thinners, reducers, and hardeners are
used as required. Wastes consist of waste blasting grit, masking materials, empty paint cans,
rags, wipes, spent thinner, and minor amounts of waste paints.
3.4.1 Painting Wastes
Characterization and handling are the same as 3.1.13.
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3.4.2 Used Blasting Grit and/or Paint Chips
Characteristics: Used sand blasting grit at outdoor painting areas may contain metals
from the parts themselves and paint particles contained in the waste grit.
Analyses of this material have indicated that it is non-hazardous.
Classification: Typically, non-hazardous solid waste but may contain lead and cadmium
from paint particles in the waste. If the concentration of these metals is
high, the waste may fail TCLP metals and be a characteristic hazardous
waste. Samples obtained in the past indicate that none of the TCLP
regulatory levels for toxic metals were exceeded.
Disposal: Used non-hazardous blasting grit is typically left on the ground in the sand
blasting portion of the outdoor painting areas or it is collected by the
contractor for disposal in the trash or off site disposal. Used grit exhibiting
hazardous waste characteristics will be placed in drums and handled as
hazardous waste for disposal.
Analyses: Use paint SDSs, apply generator knowledge and/or sample initially (and
any time the process changes). Test for TCLP metals if metal content of
paint fraction or parts is uncertain.
3.4.3 Empty Product Containers
Characterization and handling are the same as 3.1.21.
3.4.4 Used Rags, Wipes, Drop Cloths, and Masking Material
Characteristics: Varies with use and materials absorbed. May be ignitable, contain
solvents, or characteristic metals.
Classification: Typically, non-hazardous solid waste, however, if waste is contaminated
with a listed solvent, the waste may be a listed hazardous waste. If
contaminated with paints, solvent blends, or other non-listed materials,
the waste may be a characteristic hazardous waste when discarded.
Waste that is wet with flammable paint or solvent when discarded may be
ignitable (D001). Waste that contains a strong concentration of paint
containing toxic metals such as cadmium or lead may be TCLP toxic for
these metals.
Disposal: Non-hazardous rags, wipes, drop cloths, and masking material can be
thrown in the trash. Wastes known to be contaminated with listed or TCLP
solvents or other hazardous wastes will be segregated, containerized, and
handled as hazardous waste.
Analyses: Normally not required except for characterization of potentially hazardous
rags, wipes and masking material. Review of SDS and/or testing may be
required to determine regulatory status.
Waste Handling: Hazardous wastes are collected in open-head drums having properly
completed EPA hazardous waste markings, including the date when the
drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: UN/1A2.
Waste Code: Varies with waste analyses.
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Shipping Name: See waste profile.
3.4.5 Aerosol Paints, Cleaners, Lubricants, and Vent Filters
Characterization and handling are the same as Section 3.1.4.
3.4.6 Lead Based Paint Removal Waste
Characteristics: Varies with removal process and materials used. May be ignitable; and
may contain solvents or characteristic metals in addition to lead (D008).
Classification: Hazardous waste D008 (lead). If waste is contaminated with listed solvent,
the waste is a listed hazardous waste. If contaminated with solvent
blends, or other non-listed materials, the waste may be a characteristic
hazardous waste when discarded. Waste that is wet with flammable
paint removal solvent when discarded may be ignitable (D001). Waste
that contains a strong concentration of paint containing other toxic
metals such as cadmium may include additional TCLP toxic metals.
Disposal: Lead based paint removal materials and paint chips are segregated,
containerized, and handled as hazardous waste.
Analyses: Review of SDS and/or testing may be required to determine regulatory
status. Apply generator knowledge; use previous characterization and/or
SDS information. Sample and test if necessary due to process or product
change. Lead based paint waste is typically tested for TCLP metals.
Sample and test for total F & D-list volatiles, total semi-volatiles and/or
ignitability (if identified by generator knowledge). Once characterized
apply generator knowledge and sample and re-characterize any time
the process changes.
Waste Handling: Lead based paint removal materials will be collected in drums having
properly completed EPA hazardous waste markings including the
accumulation start date when the drums are full and handled as follows:
Shipping: Container DOT Specification: UN/1A2.
Waste Code: Varies with waste analyses.
Shipping Name: See waste profile.
3.5 MAINTENANCE
Description: Maintenance of the chemical manufacturing equipment is conducted by the
maintenance department (maintenance and electrical shops). Various wastes that are
produced in these activities are discussed below.
3.5.1 Used Lubricating and Hydraulic Oil
Characterization and handling are the same as Section 3.2.1, except that any drums of used oil
from the field are brought to the work area designated used oil tank and transferred to it.
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3.5.2 Used Grease
Characterization and handling are the same as Section 3.2.3.
3.5.3 Used Rags, Wipes, Absorbent Pads, and Socks
Characterization and handling are the same as Section 3.2.5.
3.5.4 Waste Paints and Painting Wastes
Characterization and handling are the same as Section 3.1.13.
3.5.5 Sand Blast Grit
Characterization and handling are the same as Section 3.4.2.
3.5.6 Scrap Metal Including Welding Rod and Cuttings
Characterization and handling are the same as Section 3.2.13.
3.5.7 Spent Solvent (water and/or hydrocarbon-based), Sludge, and/or
Filters from Parts Washers or Bulk Solvent Use
Characterization and handling are the same as Section 3.2.17.
3.5.8 Industrial Lamp Bulbs
Characterization and handling are the same as Section 3.1.3.
3.5.9 Aerosol Paints, Cleaners, Lubricants, and Vent Filters
Characterization and handling are the same as Section 3.1.4.
3.5.10 Cold Cutting Fluid
Characterization and handling are the same as Section 3.2.15.
3.5.11 Used Floor Dry
Characterization and handling are the same as Section 3.1.10.
3.5.12 Ni-Cad Batteries
Characterization and handling are the same as Section 3.1.6.
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3.5.13 Lithium Batteries
Characterization and handling are the same as Section 3.1.9.
3.5.14 Carbon and Alkaline Batteries
Characterization and handling are the same as Section 3.1.8.
3.5.15 Sump Cleanouts
Characteristics: Occasional cleanout of process and floor sumps. Characteristics depend
on the location of the sump in the process and the presence of any spi lled
chemicals in the sump contents. Typical characteristics associated with
an area include floor wash water with de minimis amounts of spilled
equipment (pumps, compressors etc.) lube oil and process chemicals.
Classification: Recycled
Sump cleanouts that are recycled to the process from which the material
originated are excluded from RCRA solid waste under 40 CFR 261.4 (a)(8)
/ R315-261-4 (a)(8) and/or 40 CFR 261.2(e) / R315-261-2(e).
Elementary Neutralization Units
Elementary Neutralization Units (ENUs) are used for neutralizing wastes that
are hazardous only because they exhibit the corrosivity characteristic (40
CFR 260.10 / R315-260-10). They are exempted from permitting under 40
CFR 270.1(c)(2)(v) / R315-270-1(c)(2)(v). The requirements for 40 CFR Parts
264 and 265 / R315-264 and 265 do not apply [40 CFR 264.1(g)(6) / R315-
264-1(g)(6) and 265.1(c)(10) / R315-265-1(c)(10)]. The hazardous waste
corrosive characteristic is neutralized, and the waste classified as non-
hazardous solid waste by generator knowledge. Other spilled material
collected in sumps that is not recycled to the process circuit from which it
originated, ENU neutralized for the characteristic of corrosivity only will be
tested for hazardous waste characteristics before being recycled to the
process, ENU neutralized, or disposed.
Wastewater Permit
Materials treated and discharged to the POTW under the wastewater
discharge permit number SLC-0001 are excluded from regulation as a
solid waste (therefore not a hazardous waste) under 40 CFR 261.4 (a)(1)(ii)
/ R315-261-4 (a)(1)(ii).
Hazardous Waste
Sump cleanouts containing characteristic and/or listed hazardous waste
will be segregated, containerized, and handled as hazardous waste.
Disposal: Recycled to the process. Wash water failing for corrosivity only is
managed in an on site ENU. Treated waters are discharged under
wastewater discharge permit SLC-0001. Sump cleanouts containing
characteristic and/or listed hazardous waste will be segregated,
containerized, and handled as hazardous waste.
Analyses: Not required if material is recycled to the process from which the material
originated. The pH is monitored to ensure the corrosivity is neutralized
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when treating in an ENU. If the soil/sludge possibly contains metals and/or
F-listed solvents, sample and test initially (and anytime the process
changes) for TCLP metals and total F- and D-list volatile organics.

3.5.16 Tank and Vessel Cleanouts
Characteristics: Occasional cleanout of process tanks and vessels. Characteristics
depend on the location of the tank or vessel in the process and if any
cleaning reagents or materials are added to the tank contents to
conduct the cleanout.
Classification: Recycled
Tank cleanout materials that are not mixed with any ha zardous cleaning
reagents and that are recycled to the process from which the material
originated are excluded from RCRA solid waste under 40 CFR 261.4 (a)(8)
/ R315-261-4 (a)(8) and/or 40 CFR 261.2(e) / R315-261-2(e).
Elementary Neutralization Units
Elementary Neutralization Units (ENUs) are used for neutralizing wastes that
are hazardous only because they exhibit the corrosivity characteristic (40
CFR 260.10 / R315-260-10). They are exempted from permitting under 40
CFR 270.1(c)(2)(v) / R315-270-1(c)(2)(v). The requirements for 40 CFR Parts
264 and 265 / R315-264 and 265 do not apply [40 CFR 264.1(g)(6) / R315-
264-1(g)(6) and 265.1(c)(10) / R315-265-1(c)(10)]. The hazardous waste
corrosive characteristic is neutralized, and the waste classified as non-
hazardous solid waste by generator knowledge. Other spilled material
collected in sumps that is not recycled to the process circuit from which it
originated, ENU neutralized for the characteristic of corrosivity only will be
tested for hazardous waste characteristics before being recycled to the
process, ENU neutralized, or disposed.
Wastewater Permit
Materials treated and discharged to the POTW under the wastewater
discharge permit number SLC-0001 are excluded from regulation as a
solid waste (therefore not a hazardous waste) under 40 CFR 261.4 (a)(1)(ii)
/ R315-261-4 (a)(1)(ii).
Hazardous Waste
Sump cleanouts containing characteristic and/or listed hazardous waste
will be segregated, containerized, and handled as hazardous waste.
Disposal: Recycled to the process. Wash water failing for corrosivity only is
managed in an on site ENU. Treated waters are discharged under
wastewater discharge permit SLC-0001. Sump cleanouts containing
characteristic and/or listed hazardous waste will be segregated,
containerized, and handled as hazardous waste.
Analyses: Not required if material is recycled to the process from which the material
originated. The pH is monitored to ensure the corrosivity is neutralized
when treating in an ENU. If the soil/sludge possibly contains metals and/or
F-listed solvents, sample and test initially (and anytime the process
changes) for TCLP metals and total F- and D-list volatile organics.
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3.5.17 Used Rags, Wipes, Absorbent Pads, and Socks with Spray Solvent
Waste (Used on Instrumentation)
Characteristics: Waste rags, wipes, absorbent pads, and socks with solvent from using
spray solvent on instruments. It is facility policy to only use non-chlorinated
solvents. Small amounts of solvent used evaporate during use.
Classification: Typically, non-hazardous solid waste. If wet with non-listed solvent, fuel,
used oil, or other regulated materials, the rags may be an ignitable (D001)
hazardous waste when discarded. If contaminated with listed degreasing
solvents, may be a (F002-F005) hazardous waste.
Disposal: Routinely generated non-hazardous rags, wipes, absorbent pads, and
socks that are not wet with oil, solvent and/or fuel are thrown in the trash.
Wet non-hazardous oily rags are drained and petroleum hydrocarbon
products are accumulated with the used oil. Rags, wipes, absorbent
pads, and socks that are wet with ignitable liquids or are known to be
contaminated with listed solvents or other hazardous materials will be
segregated, containerized, and handled as hazardous waste.
Analyses: Normally not required except for characterization of potentially
contaminated rags. For spill cleanup waste characterization review of
SDS and/or testing may be required to determine regulatory status.
Waste Handling: Hazardous wastes are collected in open-head drums having properly
completed EPA hazardous waste markings, including the date when the
drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: UN/1A2.
Waste Code: Varies with waste analyses.
Shipping Name: See waste profile.
3.5.18 Hot Water Parts Washer Spent Filters, Water, Sludge, and Skimmer
Waste
Characterization and handling are the same as 3.2.18.
3.5.19 Machine Tool Fluids
Characterization and handling are the same as 3.2.16.
3.5.20 Lead Acid Batteries
Characterization and handling are the same as 3.2.12.
3.6 LABORATORY
Description: The laboratory conducts testing for the entire operation. The laboratory contains
facilities for sample preparation, assay, and wet chemistry testing. The laboratory waste streams
produced within the facility are:
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3.6.1 Used or Stored Excess Samples
Characteristics: Excess process samples not analyzed or research and development
samples which are recycled to the process as a component and samples
placed into storage for future analyses.
Classification: Samples placed into storage are not waste. Recycled samples are
excluded from RCRA solid waste under 40 CFR 261.2(e)(1)(i) / R315-261-
2(e)(1)(i) because the material is recycled as a raw material.
Disposal: Samples are used in the process or stored for analyses.
Analyses: Not required unless changes in laboratory processes occur that may
change the samples characteristics or if the samples are handled
differently.
3.6.2 Oil and Gas Industry Samples
Characteristics: Excess oil and gas industry samples containerized for sampling and
classification for management. Samples consist of oil, organics, water,
and/or metals.
Classification: Managed as used oil, non-hazard solid waste, or hazardous waste based
on generator knowledge or analyses.
Disposal: Used Oil
Characterization and handling same as Section 3.2.1.
Non-hazardous Waste or Hazardous Waste
Non-hazardous and hazardous wastes will be collected in drums having
properly completed markings: 1) non-hazardous; or, 2) EPA hazardous
waste markings including the accumulation start date when the satellite
accumulation drums are full). Containers are stored in a designated area
within the hazardous waste storage area or other designated areas until
they are shipped to a designated or a permitted or approved non-
hazardous waste facility or Treatment, Storage, and Disposal Facility
(TSDF).
Analyses: Sample and test initially (and anytime the process changes) for TCLP
metals and total F- and D-list volatile and semi-volatile organics.

3.6.3 High Performance Liquid Chromatography Waste
Characteristics: High Performance Liquid Chromatography solution (methanol and
acetonitrile).
Classification: Hazardous waste due to characteristic of ignitability (D001).
Disposal: Liquid methanol and acetonitrile collected in a hazardous waste satellite
accumulation container is disposed as a D001 hazardous waste.
Analyses: Apply generator knowledge; use previous characterization and/or SDS
information. Mixtures of methanol and other materials to be disposed off
site will be tested for RCRA hazardous waste characteristics.
Waste Handling: Hazardous wastes will be collected in closed-top drums. Hazardous waste
containers will have properly completed EPA hazardous waste markings,
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including the date when the drum becomes full or 55 gallons of the waste
has accumulated. Drums containing flammable liquids must be
grounded when adding or removing waste.
Shipping: Container DOT Specification: UN/1A2
Waste Code: D001.
Shipping Name: See waste profile.
3.6.4 Silver Nitrate Solution from Chloride Argentometric Analysis
Characteristics: Silver nitrate solutions left over from chloride argentometric analysis.
Classification: Silver nitrate solutions are hazardous waste for oxidizer (D001) and silver
(D011).
Disposal: Hazardous wastes are collected in a hazardous waste satellite
accumulation container and disposed as a D001 and D011 hazardous
waste.
Analyses: Use SDSs, apply generator knowledge and/or sample initially (and any
time the process changes). Test for TCLP metals if metals content of
solution is uncertain and other applicable RCRA hazardous waste
characteristics.
Waste Handling: Hazardous wastes will be collected in closed-top drums. Hazardous waste
containers will have properly completed EPA hazardous waste markings,
including the date when the drum becomes full or 55 gallons of the waste
has accumulated.
Shipping: Containers: Hazardous wastes are collected in compatible UN/1H1 or 1A1
drums.
Waste Code: Oxidizer (D001), silver (D011) and/or varies with waste
analyses.
Shipping Name: See waste profile.
3.6.5 Chloroform Surfactant Titration
Characteristics: Chloroform solutions left over titration.
Classification: Chloroform solutions are hazardous waste for chloroform (D022).
Disposal: Hazardous wastes are collected in a hazardous waste satellite
accumulation container and disposed as a D022 hazardous waste.
Analyses: Use SDSs, apply generator knowledge and/or sample initially (and any
time the process changes). Test for TCLP metals if metals content of
solution is uncertain and other applicable RCRA hazardous waste
characteristics.
Waste Handling: Hazardous wastes will be collected in closed-top drums. Hazardous waste
containers will have properly completed EPA hazardous waste markings,
including the date when the drum becomes full or 55 gallons of the waste
has accumulated.
Shipping: Containers: Hazardous wastes are collected in compatible UN/1H1 or 1A1
drums.
Waste Code: chloroform (D022) and/or varies with waste analyses.
Shipping Name: See waste profile.
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3.6.6 Dilute Metal Solutions
Characteristics: Dilute metal solutions not meeting wastewater discharge requirements.
Classification: Non-hazardous solid waste dilute metal solutions not meeting the
wastewater discharge requirements.
Disposal: Non-hazardous solid wastes are collected in accumulation containers for
off site management in an approved facility.
Analyses: Use SDSs, apply generator knowledge and/or sample initially (and any
time the process changes). Test for TCLP metals if metals content of
solution is uncertain and other applicable RCRA hazardous waste
characteristics.
Waste Handling: Non-hazardous wastes will be collected in closed-top drums. Containers
will have properly completed markings, including information identifying
the contents.
Shipping: Containers: Non-hazardous wastes are collected in compatible UN/1H1
or 1A1 drums.
Waste Code: None, unless identified from analyses.
Shipping Name: See waste profile.
3.6.7 Hydranal Solutions
Characteristics: Hydranal solutions not meeting wastewater discharge requirements.
Classification: Non-hazardous solid Hydranal solutions not meeting the wastewater
discharge requirements.
Disposal: Non-hazardous solid wastes are collected in accumulation containers for
off site management in an approved facility.
Analyses: Use SDSs, apply generator knowledge and/or sample initially (and any
time the process changes). Test for TCLP metals if metals content of
solution is uncertain and other applicable RCRA hazardous waste
characteristics.
Waste Handling: Non-hazardous wastes will be collected in closed-top drums. Containers
will have properly completed markings, including information identifying
the contents.
Shipping: Containers: Non-hazardous wastes are collected in compatible UN/1H1
or 1A1 drums.
Waste Code: None, unless identified from analyses.
Shipping Name: See waste profile.
3.6.8 Lab Sink Drains and Neutralization Tank Wastewater Discharge
Characteristics: Non-hazardous solid waste (i.e., liquid) and corrosive samples drain to the
lab neutralization tank from the sinks. Samples must not contain listed
hazardous waste or ignitable or oxidizer (D001), reactive (D003) or
characteristic waste in excess of TCLP levels.
Classification: Elementary Neutralization Units
Elementary Neutralization Units (ENUs) are used for neutralizing wastes that
are hazardous only because they exhibit the corrosivity characteristic (40
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CFR 260.10 / R315-260-10) (i.e., lab neutralization tank). They are
exempted from permitting under 40 CFR 270.1(c)(2)(v) / R315-270-
1(c)(2)(v). The requirements for 40 CFR Parts 264 and 265 / R315-264 and
265 do not apply [40 CFR 264.1(g)(6) / R315-264-1(g)(6) and 265.1(c)(10) /
R315-265-1(c)(10)]. The hazardous waste corrosive characteristic is
neutralized, and the waste classified as non-hazardous solid waste by
generator knowledge. Other material that is not ENU neutralized for the
characteristic of corrosivity only will be tested for hazardous waste
characteristics before being ENU neutralized (corrosivity D002 only) or
disposed.
Wastewater Permit
Materials treated and discharged to the POTW under the wastewater
discharge permit number SLC-0001 are excluded from regulation as a
solid waste (therefore not a hazardous waste) under 40 CFR 261.4 (a)(1)(ii)
/ R315-261-4 (a)(1)(ii).
Hazardous Waste
Samples containing characteristic (excluding corrosivity D002 only) and/or
listed hazardous waste will be segregated, containerized, and handled as
hazardous waste.
Disposal: Samples failing for corrosivity only are managed in an on site ENU.
Treated waters are discharged under wastewater discharge permit SLC-
0001. Samples containing characteristic (excluding corrosivity D002 only)
and/or listed hazardous waste will be segregated, containerized, and
handled as hazardous waste.
Analyses: The pH is monitored to ensure the corrosivity is neutralized when treating in
an ENU. If the samples possibly contain characteristic (excluding
corrosivity D002 only) and/or listed hazardous waste, sample and test
initially (and anytime the process changes) for TCLP characteristics and
/or total F- and D-list volatile or semi-volatile organics.
Waste Handling: Hazardous wastes will be collected in closed-top drums. Hazardous waste
containers will have properly completed EPA hazardous waste markings,
including the date when the drum becomes full or 55 gallons of the waste
has accumulated. Drums containing flammable liquids must be
grounded when adding or removing waste.
Shipping: Container DOT Specification: UN/1A1 or 1H1.
Waste Code: Varies with waste analyses.
Shipping Name: See waste profile.
3.6.9 Unused Laboratory Chemicals
Characteristics: Laboratory chemicals that have not been utilized and are in their original
containers.
Classification: If disposed as waste, will determine if the chemical is a listed or a
characteristic hazardous waste. Unused laboratory chemicals are
hazardous if they contain a U- or P-listed chemical as the sole active
ingredient or fail RCRA characteristics.
Disposal: If disposed, dispose off-site at an appropriate facility.
Analyses: Not required, determine material properties from SDSs.
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3.6.10 Laboratory Chemicals Desiccant and/or Activated Carbon Off Gas
Filters
Characteristics: Laboratory chemicals desiccant and/or activated carbon off gas filters
are used on various laboratory chemicals. Desiccant and/or activated
carbon filters may contain various laboratory chemical constituents.
Classification: If disposed as waste, determine if the filter material is a listed or a
characteristic hazardous waste. Desiccant and/or activated carbon
filters are hazardous if they contain a U- or P-listed chemical as the sole
active ingredient or fail RCRA characteristics.
Disposal: Non-hazardous solid wastes are thrown in the trash. Hazardous wastes are
segregated, containerized, and handled as hazardous waste.
Analyses: Not required, if material properties are determined from SDSs. If the filter
materials possibly contain metals and/or listed solvents, sample and test
initially (and anytime the process changes) for TCLP metals and total F-
and D-list volatile or semi-volatile organics.
3.6.11 Makeup Air Filters
Characteristics: Air filters contain dust from filtering outside.
Classification: Non-hazardous solid waste.
Disposal: Air filters are thrown in the trash.
Analyses: None required.
3.6.12 Water Purification Cartridges and Compressor Desiccant Filters
Characteristics: Cartridges and desiccant filters.
Classification: Non-hazardous solid waste.
Disposal: Thrown in the trash.
Analyses: Not required.
3.6.13 Miscellaneous Titration and/or pH Buffer Solutions
Characteristics: Titration solutions contain various chemicals. Various pH buffer solutions
are also used in the lab.
Classification: Most of the solutions are non-hazardous solid wastes. If solutions are
contaminated with TCLP Toxicity including metals (D009 mercury and
D011 Silver), ignitable or oxidizer liquids (D001), or listed solvents the
titration solutions may be regulated as a hazardous waste when
discarded.
Disposal: Non-hazardous solid waste solutions are poured into the sink drains.
Titration solutions known to be contaminated with TCLP Toxicity including
metals, ignitable liquid, or listed solvents or other hazardous wastes are
segregated, containerized, and handled as hazardous waste.
Analyses: Not required unless changes in laboratory processes occur that may
change the solution characteristics or if the solution is handled differently.
If disposed as waste, will determine if the material is a hazardous waste.
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Waste Handling: Hazardous wastes will be collected in closed-top drums. Hazardous waste
containers will have properly completed EPA hazardous waste markings,
including the date when the drum becomes full or 55 gallons of the waste
has accumulated. Drums containing flammable liquids must be
grounded when adding or removing waste.
Shipping: Container DOT Specification: UN/1A1 or 1H1.
Waste Code: Varies with waste analyses.
Shipping Name: See waste profile.
3.6.14 Contaminated Personal Protection Equipment (PPE), Floor
Sweepings, and/or Trash
Characteristics: Contaminated PPE, floor sweepings, and/or trash.
Classification: Typically, non-hazardous solid waste. If disposed as waste, determine if
the material is contaminated with a listed or a characteristic hazardous
waste.
Disposal: Non-hazardous solid waste it thrown in the trash. Hazardous wastes are
collected in a hazardous waste satellite accumulation container.
Analyses: Sample and test contaminated material initially (and anytime the process
changes) for TCLP metals and total F- and D-list volatile and semi-volatile
organics. These analytes are determined from known contaminants.
Waste Handling: Hazardous wastes are collected in open-head drums having properly
completed EPA hazardous waste markings, including the date when the
drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: UN/1A2.
Waste Code: Varies with waste analyses.
Shipping Name: See waste profile.
3.6.15 Hood Scrubber Solution
Characteristics: Caustic hood scrubber solution.
Classification: Elementary Neutralization Units
Elementary Neutralization Units (ENUs) are used for neutralizing wastes that
are hazardous only because they exhibit the corrosivity characteristic (40
CFR 260.10 / R315-260-10) (i.e., lab neutralization tank). They are
exempted from permitting under 40 CFR 270.1(c)(2)(v) / R315-270-
1(c)(2)(v). The requirements for 40 CFR Parts 264 and 265 / R315-264 and
265 do not apply [40 CFR 264.1(g)(6) / R315-264-1(g)(6) and 265.1(c)(10) /
R315-265-1(c)(10)]. The hazardous waste corrosive characteristic is
neutralized, and the waste classified as non-hazardous solid waste by
generator knowledge.
Wastewater Permit
Materials treated and discharged to the POTW under the wastewater
discharge permit number SLC-0001 are excluded from regulation as a
solid waste (therefore not a hazardous waste) under 40 CFR 261.4 (a)(1)(ii)
/ R315-261-4 (a)(1)(ii).
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Disposal: Caustic hood scrubber solutions failing for corrosivity only is managed in
an on site ENU. Treated waters are discharged under wastewater
discharge permit SLC-0001.
Analyses: The pH is monitored to ensure the corrosivity is neutralized when treating in
an ENU.
3.6.16 Empty Reagent Containers
Characterization and handling same as Section 3.1.21.
3.6.17 Equipment Bulbs
Characterization and handling same as 3.1.3.
3.6.18 Compressed Gas Cylinders
Characterization and handling same as Section 3.2.14.
3.6.19 Used Oil
Characterization and handling same as Section 3.2.1.
3.7 FUELING FACILITIES
Description: The processing operations at the facility require diesel fuel, gasoline, oils, greases,
antifreezes, and/or solvents for equipment operation and maintenance. Fueling facilities consist
of storage/dispensing facilities for fuels, lubricants, and coolant (glycol-based antifreeze).
Typical waste streams from these facilities are described below:
3.7.1 Collected Oil/Grease and Small Spills
This Includes used lubricating grease, oil and hydraulic oils, including brake and transmission fluid,
generated from vehicle and machinery with minor amounts of fuel constituents and metals. It is
facility policy to not mix used oil with solvents, coolants or other waste materials. Analyses have
indicated that the oil meets the criteria for specification used oil.

Collected oil characterization and handling are the same as 3.2.1.
Collected grease characterization and handling are the same as 3.2.3.
Small spills characterization and handling are the same as 3.14.1.
3.7.2 Collected Diesel Fuel and Small Spills
Diesel fuel collected within secondary containment features. The SDS flash point is reported to
be above 140˚F.

Collected diesel characterization and handling are the same as 3.2.9.
Small spills characterization and handling are the same as 3.14.2.
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3.7.3 Contaminated or Waste Gasoline and Small Spills
Collected gasoline characterization and handling are the same as 3.2.10.
Small spills characterization and handling are the same as 3.14.3.
3.7.4 Collected Used Engine Coolant (Glycol-Based Antifreeze) and small
Spills
Spilled, engine coolant (antifreeze) collected within secondary containment features.
Collected coolant characterization and handling are the same as 3.2.6.
Small spills characterization and handling are the same as 3.14.4.
3.7.5 Used Floor Dry
Characterization and handling are the same as Section 3.1.10.
3.7.6 Used Rags, Wipes, Absorbent Pads, and Socks
Characterization and handling are the same as Section 3.2.5.
3.7.7 Fuel Filters
Characterization and handling are the same as Section 3.2.2.
3.7.8 Aerosol Paints, Cleaners, Lubricants, and Vent Filters
Characterization and handling are the same as Section 3.1.4.
3.7.9 Oily Water, Used Oil, Sediment/Sludges from Sumps
Characterization and handling are the same as Section 3.2.7.

3.8 CHEMICAL MANUFACTURING
Description: Chemical manufacturing facility activities include various activities for production
of a diversified range of products. Buildings and activities are listed in Table 3.1 below.

Table 3.1 Buildings and Activities
Building Activity
1 Main Warehouse (Process Support)
2a Aluminum Sulfate Production
2b Ferric and Ferrous Sulfate Production
2c Anhydrous Chlorine Repackaging
3a Various Production Chemicals
3b Warehouse Storage (Process Support)
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Building Activity
3c Sodium Isocyanate Production
3 Outside Various combinations of hydrochloric acid products
4 Sodium Carbonate (Soda Ash) mixtures (i.e., compounding) Production
5 Oxidizer Repackaging
Container Wash Area
Water Treatment Containments
6 Food and Dairy - Various Production Chemicals
7 Pharmaceutical and Iodine Compounds Production
8 Batch processing from B12 Feed
Sulfite to thiosulfate
9 Production Tanks for Repackaging Alcohols, Glycols, and Various Chemicals
9A Warehouse (Process Support)
10 Ammonia for Ammonium Hydroxide
Organic Process: Paraformaldehyde (PFA) is reacted w/ MEA to produce
monoethanolamine triazine (MEA-T)
11 Calcium Nitrates/Nitrites, Magnesium Nitrate, Sodium Nitrate
12 Sulfite Chemistry Area, Aluminum Chlorate, Ammonium Bisulfite, Potassium
Sulfite
14 Truck Shop (Process Support)
15 None
16 Maintenance Shop (Process Support)
17 Laboratory (Process Support)
18 None
19 Tank Farm Area

Chemicals from vendors (raw materials) are stored on-site in railcars, tankers, tanks, and/or
smaller containers (i.e., totes or drums) for producing Thatcher products (i.e., product
component chemicals). Products are produced in designated process locations on-site. Excess
product, off-specification (non-conforming chemicals), and/or return material authorized
chemicals are used for rework as product component chemicals.

Site secondary containment consists of containment for storage tanks (tank farm secondary
containments) and site containment (for storage containers and process operations) and area
sumps. The Site is reportedly self-contained and is sloped toward the center of the Site. Self-
containment includes asphalt and/or concrete surfaces where materials would flow into area
sumps.

Chemical production operations include raw materials storage with secondary containment,
mixing and holding tanks, reaction vessels, piping and transfer equipment, scrubbers, boilers,
cooling towers, chillers, dewatering filter presses, various water use treatment, and dust cartridge
or bag collectors.

Typical waste streams from these facilities are described below:
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3.8.1 Scrubber Solutions
Characteristics: Acids or alkaline materials are neutralized.
Buildings: B2a, B2b, B2c, B3a, B10, and B11.
Classification: Recycled to the Process

Elementary Neutralization Units
Elementary Neutralization Units (ENUs) are used for neutralizing wastes that
are hazardous only because they exhibit the corrosivity characteristic (40
CFR 260.10 / R315-260-10). They are exempted from permitting under 40
CFR 270.1(c)(2)(v) / R315-270-1(c)(2)(v). The requirements for 40 CFR Parts
264 and 265 / R315-264 and 265 do not apply [40 CFR 264.1(g)(6) / R315-
264-1(g)(6) and 265.1(c)(10) / R315-265-1(c)(10)]. The hazardous waste
corrosive characteristic is neutralized, and the waste classified as non-
hazardous solid waste by generator knowledge.
Wastewater Permit
Materials treated and discharged to the POTW under the wastewater
discharge permit number SLC-0001 are excluded from regulation as a
solid waste (therefore not a hazardous waste) under 40 CFR 261.4 (a)(1)(ii)
/ R315-261-4 (a)(1)(ii).
Disposal: Recycled to the process. Wash water failing for corrosivity only is
managed in an on site ENU. Treated waters are discharged under
wastewater discharge permit SLC-0001
Analyses: The pH is monitored to ensure the corrosivity is neutralized.
3.8.2 Filter Press Wash Water/Sludge or Used Filter Press Components
Characteristics: Process sediment and solutions from processes. Filter press plates/cloth
may be rinsed and/or washed.
Buildings: B2a, B2b, B2c, B3a, B5, B8, and B11.
Classification: Wash water and sediment from filter press plates/cloth may contain
corrosive liquid or non-hazardous solid waste.
Recycled
Solutions are managed as products or returned to the process. Solutions
returned to the process are excluded from regulation as a solid waste
under 40 CFR 261.4 (a)(8) / R315-261-4 (a)(8) when recycled to the
process or under 40 CFR 261.2(e)(1)(i) / R315-261-2(e)(1)(i) because the
material is recycled as a raw material into the process.
Elementary Neutralization Units
Elementary Neutralization Units (ENUs) are used for neutralizing wastes that
are hazardous only because they exhibit the corrosivity characteristic (40
CFR 260.10 / R315-260-10). They are exempted from permitting under 40
CFR 270.1(c)(2)(v) / R315-270-1(c)(2)(v). The requirements for 40 CFR Parts
264 and 265 / R315-264 and 265 do not apply [40 CFR 264.1(g)(6) / R315-
264-1(g)(6) and 265.1(c)(10) / R315-265-1(c)(10)]. The hazardous waste
corrosive characteristic is neutralized, and the waste classified as non-
hazardous solid waste by generator knowledge.
Wastewater Permit
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Materials treated and discharged to the POTW under the wastewater
discharge permit number SLC-0001 are excluded from regulation as a
solid waste (therefore not a hazardous waste) under 40 CFR 261.4 (a)(1)(ii)
/ R315-261-4 (a)(1)(ii).
Disposal: Solutions are recycled to the process. Wash water and sediment flows to
the area sump. Wash water failing for corrosivity only is managed in an on
site ENU. Treated waters are discharged under wastewater discharge
permit SLC-0001. Sludge is disposed in roll-offs and an approved and
permitted disposal or agriculture facility. Unusable filter press components
may be rinsed before they are thrown in the trash.
Analyses: The pH is monitored to ensure the corrosivity is neutralized when treating in
an ENU. Sediment has been sampled, analyzed, and classified as non-
hazardous solid waste.
3.8.3 Filter Press Cake
Characteristics: Process sediment from the processes.
Buildings: B2a, B2b, B2c, B3a, B5, B8, and B11.
Classification: Filter press cake is a non-hazardous solid waste per generator knowledge.
Disposal: Sediment is disposed in roll-offs at an approved and permitted disposal or
agriculture facility.
Analyses: Sediment has been sampled, analyzed, and classified as non-hazardous
solid waste.
3.8.4 Dust Collectors or Bag Filters
Characteristics: Dust, cartridges, and/or bags from the various processes.
Buildings: B2c, B3a, B3c, B4, B6, B7, and B11.
Classification: Recycled
Dust returned to the process is excluded from regulation as a solid waste
under 40 CFR 261.2(e) / R315-261-2(e).
Non-hazardous Solid Waste
Cartridges and bags may be rinsed and managed as non-hazardous solid
waste by generator knowledge.
Hazardous Waste
Cartridges and bags that contain characteristic and/or listed hazardous
waste will be segregated, containerized, and handled as hazardous
waste.
Disposal: Dust is returned to the process for use. Non-hazardous solid waste
cartridges and bags are thrown in the trash. Cartridges and bags that
contain characteristic and/or listed hazardous waste will be segregated,
containerized, and handled as hazardous waste.
Analyses: Not required if material is recycled to the process from which the material
originated. If the cartridges and/or bags possibly contain metals and/or F-
listed solvents, sample and test initially (and anytime the process changes)
for TCLP metals and total F- and D-list volatile organics.
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3.8.5 Area Sumps
Characteristics: Characteristics depend on the location of the sump in the process and
the presence of any spilled chemicals in the sump contents. Typical
characteristics associated with an area include floor wash water with de
minimis amounts of spilled equipment (pumps, compressors etc.) lube oil
and process chemicals.
Classification: Recycled
Sump cleanouts that are recycled to the process from which the material
originated are excluded from RCRA solid waste under 40 CFR 261.4 (a)(8)
/ R315-261-4 (a)(8) and/or 40 CFR 261.2(e) / R315-261-2(e).
Elementary Neutralization Units
Elementary Neutralization Units (ENUs) are used for neutralizing wastes that
are hazardous only because they exhibit the corrosivity characteristic (40
CFR 260.10 / R315-260-10). They are exempted from permitting under 40
CFR 270.1(c)(2)(v) / R315-270-1(c)(2)(v). The requirements for 40 CFR Parts
264 and 265 / R315-264 and 265 do not apply [40 CFR 264.1(g)(6) / R315-
264-1(g)(6) and 265.1(c)(10) / R315-265-1(c)(10)]. The hazardous waste
corrosive characteristic is neutralized, and the waste classified as non-
hazardous solid waste by generator knowledge.
Spilled Material
Other spilled material collected in sumps that is not recycled to the
process circuit from which it originated, ENU neutralized for the
characteristic of corrosivity only will be tested for hazardous waste
characteristics before being recycled to the process, ENU neutralized, or
disposed.
Hazardous Waste
Sump cleanouts containing characteristic and/or listed hazardous waste
will be segregated, containerized, and handled as hazardous waste.
Wastewater Permit
Materials treated and discharged to the POTW under the wastewater
discharge permit number SLC-0001 are excluded from regulation as a
solid waste (therefore not a hazardous waste) under 40 CFR 261.4 (a)(1)(ii)
/ R315-261-4 (a)(1)(ii).
Disposal: Recycled to the process. Wash water failing for corrosivity only is
managed in an on site ENU. Treated waters are discharged under
wastewater discharge permit SLC-0001. Sump cleanouts containing
characteristic and/or listed hazardous waste will be segregated,
containerized, and handled as hazardous waste.
Analyses: Not required if material is recycled to the process from which the material
originated. The pH is monitored to ensure the corrosivity is neutralized
when treating in an ENU. If the soil/sludge possibly contains metals and/or
F-listed solvents, sample and test initially (and anytime the process
changes) for TCLP metals and total F- and D-list volatile organics.
3.8.6 Boiler Blowdown
Characteristics: Boiler water and scale. Scale from intake water may contain metals.
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Buildings: B11 and B7.
Classification: Non-hazardous solid waste.
Disposal: Water flows to the area sump which is pumped to the water treatment.
Wastewater Permit
Materials treated and discharged to the POTW under the wastewater
discharge permit number SLC-0001 are excluded from regulation as a
solid waste (therefore not a hazardous waste) under 40 CFR 261.4 (a)(1)(ii)
/ R315-261-4 (a)(1)(ii).
Analyses: Not required.
3.8.7 Boiler Chemical Cleaning
Characteristics: Water, cleaning chemicals, and scale. Scale from intake water may
contain metals.
Classification: The wastewater may be hazardous if heavily contaminated with
regulated metals, listed cleaning solvents, and/or characteristic cleaning
solvents. Cleaning waste must be sampled and tested for classification.
Disposal: Non-hazardous wash water is disposed in the area sump. Wash water
failing for corrosivity only is managed in an on site ENU. Hazardous waste
wastewater is disposed of as hazardous waste off site.
Analyses: For wash water containing regulated metals, listed cleaning solvents,
and/or characteristic cleaning solvent waste, characterization review of
generator knowledge, SDS, and/or testing may be required to determine
regulatory status. Test for pH and TCLP metals before disposing.
3.8.8 Demineralization Water Treatment and Reverse Osmosis Filter
Cleaning Wash Water
Characteristics: Anion, cation, and/or mixed bed resin used in demineralizer vessels that
has been exhausted and can no longer be regenerated in an efficient
manner. Resin or reverse osmosis filter cleaning chemicals and/or
backwash water. Sodium chloride (salt) may be used to regenerate the
resin. Rinsed filters.
Classification: Non-hazardous Solid Waste
Brine, wash water and/or scale is typically non-hazardous solid waste but
this wastewater and/or scale may contain listed or characteristic
hazardous waste according to generator knowledge.
Elementary Neutralization Units
Elementary Neutralization Units (ENUs) are used for neutralizing wastes that
are hazardous only because they exhibit the corrosivity characteristic (40
CFR 260.10 / R315-260-10). They are exempted from permitting under 40
CFR 270.1(c)(2)(v) / R315-270-1(c)(2)(v). The requirements for 40 CFR Parts
264 and 265 / R315-264 and 265 do not apply [40 CFR 264.1(g)(6) / R315-
264-1(g)(6) and 265.1(c)(10) / R315-265-1(c)(10)]. The hazardous waste
corrosive characteristic is neutralized, and the waste classified as non-
hazardous solid waste by generator knowledge.
Hazardous Waste
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The wastewater or sludge may be hazardous if heavily contaminated with
regulated metals, listed cleaning solvents, and/or characteristic cleaning
solvents.
Wastewater Permit
Materials treated and discharged to the POTW under the wastewater
discharge permit number SLC-0001 are excluded from regulation as a
solid waste (therefore not a hazardous waste) under 40 CFR 261.4 (a)(1)(ii)
/ R315-261-4 (a)(1)(ii).
Disposal: Wash water and sediment flows to the area sump. Wash water failing for
corrosivity only is managed in an on site ENU. Treated waters are
discharged under wastewater discharge permit SLC-0001. Used resins are
disposed of off site at approved facilities or managed by vendors. Sludge
containing characteristic and/or listed hazardous waste will be
segregated, containerized, and handled as hazardous waste.
Analyses: The pH is monitored to ensure the corrosivity is neutralized when treating in
an ENU. If the used resin and/or sediment possibly contains metals and/or
F-listed solvents, sample and test initially (and anytime the process
changes) for TCLP metals and total F- and D-list volatile organics.
3.8.9 Reverse Osmosis Water Filters
Characteristics: Rinsed cartridges filters.
Classification: Non-hazardous solid waste.
Disposal: Thrown in the trash.
Analyses: Not required.
3.8.10 Heat Exchanger, Cooling Tower, Chillers and/or Strainers Pressure or
Acid Wash Waste
Characteristics: Wash water and/or acid wash water. Heat exchanger, cooling tower,
and/or chillers are closed loop water systems. Building B12 cooling tower
process chemical bleed.
Classification: Building 12 Cooling Tower Bleed
Is managed under the wastewater permit.
Non-hazardous Solid Waste
Wash water and system water is typically non-hazardous solid waste.
Elementary Neutralization Units
Elementary Neutralization Units (ENUs) are used for neutralizing wastes that
are hazardous only because they exhibit the corrosivity characteristic (40
CFR 260.10 / R315-260-10). They are exempted from permitting under 40
CFR 270.1(c)(2)(v) / R315-270-1(c)(2)(v). The requirements for 40 CFR Parts
264 and 265 / R315-264 and 265 do not apply [40 CFR 264.1(g)(6) / R315-
264-1(g)(6) and 265.1(c)(10) / R315-265-1(c)(10)]. The hazardous waste
corrosive characteristic is neutralized, and the waste classified as non-
hazardous solid waste by generator knowledge.
Wastewater Permit
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Materials treated and discharged to the POTW under the wastewater
discharge permit number SLC-0001 are excluded from regulation as a
solid waste (therefore not a hazardous waste) under 40 CFR 261.4 (a)(1)(ii)
/ R315-261-4 (a)(1)(ii).
Hazardous Waste
The wash water and/or acid wastewater may be hazardous if heavily
contaminated with regulated metals, listed cleaning solvents, and/or
characteristic cleaning solvents.
Disposal: Wash water and sediment flows to the area sump. Wash water failing for
corrosivity only is managed in an on site ENU. Treated waters are
discharged under wastewater discharge permit SLC-0001. Wash water
and/or sludge containing characteristic and/or listed hazardous waste will
be segregated, containerized, and handled as hazardous waste.
Analyses: The pH is monitored to ensure the corrosivity is neutralized when treating in
an ENU. If the wash water and/or sediment possibly contains metals
and/or F-listed solvents, sample, and test initially (and anytime the process
changes) for TCLP metals and total F- and D-list volatile organics.
3.8.11 Sodium Hypochlorite Cooling Tower Bleed
Characteristics: Water, chlorine, and sodium hydroxide solutions from building 2C sodium
hypochlorite cooling tower bleed.
Classification: Recycled
Materials that are recycled to the process from which the material
originated are excluded from RCRA solid waste under 40 CFR 261.4 (a)(8)
/ R315-261-4 (a)(8) and/or 40 CFR 261.2(e) / R315-261-2(e).
Disposal: Recycled to the process.
Analyses: Not required if material is recycled to the process from which the material
originated

3.9 UTILITIES AND RAW MATERIALS
Description: Chemical manufacturing facility activities include various activities for production
of a diversified range of products. Chemicals from vendors (raw materials) are stored and
unloaded on-site. Containers include railcars, tankers, tanks, and/or smaller containers (i.e., totes
or drums) for producing Thatcher products (i.e., product component chemicals). Site secondary
containment consists of containment for storage tanks (tank farm secondary containments) and
site containment (for storage containers and process operations) and area sumps. The Site is
reportedly self-contained and is sloped toward the center of the Site or area sumps. Self-
containment includes asphalt and/or concrete surfaces where materials and stormwater would
flow into area sumps. Typical waste streams from these facilities are described below:
3.9.1 Area Sumps and Water Treatment Containments
Characteristics: Characteristics depend on the location of the sumps in the process (i.e.,
raw material storage areas, tank farms and/or general area sumps), the
presence of any spilled chemicals in the sump contents, and/or materials
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in the water treatment containments. Typical characteristics associated
with an area include stormwater, floor or area wash water, and/or
process water with de minimis amounts of spilled equipment (pumps,
compressors etc.) lube oil and process chemicals.
Classification: Storm Water Non-hazardous Solid Waste
Storm water used in the process is non-hazardous solid waste unless it
contains characteristic and/or listed hazardous waste.
Elementary Neutralization Units
Elementary Neutralization Units (ENUs) are used for neutralizing wastes that
are hazardous only because they exhibit the corrosivity characteristic (40
CFR 260.10 / R315-260-10). They are exempted from permitting under 40
CFR 270.1(c)(2)(v) / R315-270-1(c)(2)(v). The requirements for 40 CFR Parts
264 and 265 / R315-264 and 265 do not apply [40 CFR 264.1(g)(6) / R315-
264-1(g)(6) and 265.1(c)(10) / R315-265-1(c)(10)]. The hazardous waste
corrosive characteristic is neutralized, and the waste classified as non-
hazardous solid waste by generator knowledge.
Wastewater Permit
Materials treated and discharged to the POTW under the wastewater
discharge permit number SLC-0001 are excluded from regulation as a
solid waste (therefore not a hazardous waste) under 40 CFR 261.4 (a)(1)(ii)
/ R315-261-4 (a)(1)(ii).
Hazardous Waste
Sump or containment cleanouts containing characteristic and/or listed
hazardous waste will be segregated, containerized, and handled as
hazardous waste.
Disposal: Wash water failing for corrosivity only is managed in an on site ENU.
Treated waters are discharged under wastewater discharge permit SLC-
0001. Sump cleanouts containing characteristic and/or listed hazardous
waste will be segregated, containerized, and handled as hazardous
waste.
Analyses: Not required if material is recycled to the process from which the material
originated. The pH is monitored to ensure the corrosivity is neutralized
when treating in an ENU. If the soil/sludge possibly contains metals and/or
F-listed solvents, sample and test initially (and anytime the process
changes) for TCLP metals and total F- and D-list volatile organics.
3.9.2 Container Wash Areas
Characteristics: Characteristics depend on the container contents. Container wash
includes Building 5 and 6 (containers) and B2c (cylinders).
Classification: Elementary Neutralization Units
Elementary Neutralization Units (ENUs) are used for neutralizing wastes that
are hazardous only because they exhibit the corrosivity characteristic (40
CFR 260.10 / R315-260-10). They are exempted from permitting under 40
CFR 270.1(c)(2)(v) / R315-270-1(c)(2)(v). The requirements for 40 CFR Parts
264 and 265 / R315-264 and 265 do not apply [40 CFR 264.1(g)(6) / R315-
264-1(g)(6) and 265.1(c)(10) / R315-265-1(c)(10)]. The hazardous waste
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corrosive characteristic is neutralized, and the waste classified as non-
hazardous solid waste by generator knowledge.
Wastewater Permit
Materials treated and discharged to the POTW under the wastewater
discharge permit number SLC-0001 are excluded from regulation as a
solid waste (therefore not a hazardous waste) under 40 CFR 261.4 (a)(1)(ii)
/ R315-261-4 (a)(1)(ii).
Hazardous Waste
Sump cleanouts containing characteristic and/or listed hazardous waste
will be segregated, containerized, and handled as hazardous waste.
Disposal: Wash water failing for corrosivity only is managed in an on site ENU.
Treated waters are discharged under wastewater discharge permit SLC-
0001. Sump cleanouts containing characteristic and/or listed hazardous
waste will be segregated, containerized, and handled as hazardous
waste.
Analyses: Not required if material is recycled to the process from which the material
originated. The pH is monitored to ensure the corrosivity is neutralized
when treating in an ENU. If the soil/sludge possibly contains metals and/or
F-listed solvents, sample and test initially (and anytime the process
3.9.3 Water Treatment Filter Press
Characterization and handling are the same as Section 3.8.2.
3.9.4 Water Treatment Filter Cake
Characterization and handling are the same as Section 3.8.3.
3.9.5 Oil Water Separators
Characterization and handling are the same as Section 3.7.9.
Buildings: B7 and B16.
3.9.6 Sodium Hydroxide Reagents Area Sumps
Characteristics: Storm water and area wash water with de minimis amounts of spilled
liquid sodium hydroxide, hydraulic oil, and lubricating oil.
Classification: Water with de minimis amounts of reagents is non-hazardous solid waste,
not regulated as a solid waste under 40 CFR 261.2(e)(1)(i) and (ii) / R315-
261-2(e)(1)(i) and (ii) when recycled to the process, and/or excluded from
regulation as a solid waste under 40 CFR 261.4 (a)(8) / R315-261-4 (a)(8)
when recycled to the process.
Disposal: Recycled to the process.
Analyses: Not required for water with de minimis amounts of reagents. For spill
cleanup waste characterization, a review of SDS and/or testing may be
required to determine regulatory status.
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3.9.7 Antiscalant Area Sump
Characteristics: Storm water and area wash water with de minimis amounts of spilled
antiscalant, hydraulic oil, and lubricating oil.
Classification: Water with de minimis amounts of reagents is non-hazardous solid waste
and excluded from regulation as a solid waste under 40 CFR 261.4 (a)(8) /
R315-261-4 (a)(8).
Disposal: Recycled to the process.
Analyses: Not required.
3.9.8 Acid Area Sumps
Characteristics: Storm water and area wash water with de minimis amounts of spilled
hydrochloric acid, nitric acid, acetic acid, phosphoric acid, antiscalant,
hydraulic oil, and lubricating oil.
Classification: Water with de minimis amounts of reagents is non-hazardous solid waste.
Disposal: Recycled to the process.
Analyses: Not required for water with de minimis amounts of reagents. For spill
cleanup waste characterization, a review of SDS and/or testing may be
required to determine regulatory status.
3.9.9 Miscellaneous Reagent Area Sumps
Characteristics: Storm water and area wash water with de minimis amounts of spilled
reagents, hydraulic oil, and lubricating oil.
Classification: Water with de minimis amounts of reagents is non-hazardous solid waste.
If RCRA listed reagents are used, they must be reviewed on a case-by-
case basis; see Section 3.14.
Disposal: Reviewed and determined on a case-by-case basis.
Analyses: Not required for water with de minimis amounts of reagents. For spill
cleanup waste characterization, a review of SDS and/or testing may be
required to determine regulatory status.
3.9.10 Boiler Solution (Heat Transfer Solution)
Characteristics: Propylene glycol heat transfer solution used in various boilers may contain
regulated metals. Propylene glycol is toxic by ingestion.
Classification: Non-hazardous solid waste unless contaminated with metals. If solutions
are heavily contaminated with metals and metals exceed the TCLP
metals regulatory levels, solutions would be regulated as hazardous waste.
Disposal: Typically used consumptively or reused. Accumulated heat transfer
solution is collected in drums or tanks for recycling and recycled on site or
off site (by an approved facility). The approved contractor routinely tests
and evacuates the used antifreeze storage tank. Used heat transfer
solution storage containers including drums and tanks must be marked
with the words “Used Antifreeze.” Hazardous wastes should be
segregated, containerized, and handled as hazardous waste.
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Analyses: Use heat transfer solution SDSs, apply generator knowledge and/or
sample initially (and any time the process changes).

3.10 SPILL CLEANUP
Description: The cleanup of spilled materials produces waste streams consisting of the spilled
materials and soil or cleanup waste (adsorbents, rags, wash water, etc.) contaminated with the
spilled materials. Spilled material that is containerized and used for its intended purpose is not a
hazardous waste. According to the mixture rule, 40 CFR 261.3(a) / R315-261-3(a), contaminated
soil or cleanup waste resulting from the spill of a listed hazardous waste which is listed as a toxic
(T) or acute hazardous waste (H) [40 CFR 261.30/ R315-261-30] is itself a hazardous waste. Listed
hazardous waste includes commonly encountered F-list (F001-F005) spent solvents. F-list only
applies to solvent used for their solvent properties that dissolve or mobilize other constituents.
The F-list spent solvent must contain at least 10% of one or more of the F-list solvents before use.
Contaminated soil or cleanup waste resulting from the spill of a characteristic hazardous waste,
whether listed or not, would itself be a hazardous waste only if the soil or cleanup material also
exhibited the hazardous characteristic. The applicable hazardous characteristics are: ignitability
(I), corrosivity (C), reactivity (R), or toxicity characteristic (E) [40 CFR 261.20 - .24/ R315-261-20-24].
However, disposal of these materials will need to comply with the applicable land disposal
restriction (LDR) regulations [LDR regulations are found in 40 CFR Part 268/ R315-268]. Hazardous
waste cleanup wastes are containerized and handled as hazardous wastes.

Petroleum contaminated soils are containerized and disposed of off site at approved facilities.

The following spill waste streams may potentially be produced at the facility:
3.10.1 Soils or Cleanup Material Contaminated with Oil and/or Grease
Characteristics: Lubricating oil, hydraulic oil, used oil, grease and/or soil and cleanup
material.
Classification: Normally non-hazardous solid waste, however, if the oil/grease was
previously contaminated with F-listed solvents and/or heavily
contaminated with metals, the mixture would be regulated as an F-listed
and/or characteristic hazardous waste when discarded.
Disposal: Petroleum contaminated soils is containerized and disposed at off site
approved facilities. Non-draining absorbent cleanup material is routinely
discarded in the trash; however, large quantities generated from a spill
cleanup are containerized for characterization prior to disposal. Soil
contaminated with solvents or other hazardous materials will be
segregated, sampled, and containerized for testing before being sent to
a permitted facility.
Analyses: Apply generator knowledge; use previous characterization and/or SDS
information. Sample and test if necessary due to process or product
changes. Sample and test for TCLP metals, F- and D-list total volatiles and
F- and D-list semi-volatiles in order to characterize.
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3.10.2 Soils or Cleanup Materials Contaminated with Diesel Fuel
Characteristics: Diesel fuel contaminated soil or cleanup materials.
Classification: Flash point is typically above 140˚F for diesel fuel used at the facility, which
would not be RCRA ignitable.
Disposal: Petroleum contaminated soils is containerized and disposed at off site
approved facilities. Floor dry contaminated with adsorbed (no free liquid)
diesel fuel is thrown in the trash.
Analyses: Not required unless wet with lower flash point (<140˚F) diesel fuel. Mixtures
of lower flash point (<140˚F) diesel fuel and other materials will be tested
for ignitability.
3.10.3 Soils or Cleanup Materials Contaminated with Gasoline and/or
Kerosene
Characteristics: Contaminated or off-specification waste gasoline from fueling vehicles or
from spills. In addition, contaminated water and/or spills from the gasoline
storage tank and fuel pump. Contaminated or off specification kerosene
from use for heating or from spills. Liquid waste must not be solidified for
disposal.
Classification: Possible hazardous waste due to characteristics of ignitability (D001) and
benzene (D018) if present in strong concentrations. Exempt from
regulation if used as a fuel (such as burned for energy recovery).
Disposal: Small quantities of gasoline or kerosene (1%) may be mixed with used oil
for recycling or energy recovery. Liquid ga soline and kerosene disposed
as a hazardous waste is shipped as D001 and/or D018 hazardous waste if
the discarded material exhibits the characteristics. Exempt if used as a
fuel. Non-hazardous soil contaminated with small amounts of gasoline or
kerosene is containerized and disposed at off site approved facilities.
Solids/sludges that are wet with ignitable liquids are segregated,
containerized, and handled as hazardous waste.
Analyses: Apply generator knowledge; use previous characterization and/or SDS
information. Mixtures of gasoline, kerosene, and other materials to be
disposed off site will be tested for ignitability, TCLP benzene for solids
and/or total benzene for liquids. Mixtures of gasoline, kerosene, and other
materials that are recycled or used for energy recovery do not require
testing.
Waste Handling: Recyclable material or hazardous wastes will be collected in open-head
drums. Hazardous waste containers will have properly completed EPA
hazardous waste markings, including the date when the drum becomes
full or 55 gallons of the waste has accumulated. Drums containing
flammable liquids must be grounded when adding or removing waste.
Shipping: Container DOT Specification: UN/1A2
Waste Code: D001 and/or D018 for hazardous waste and none if used as
a fuel.
Shipping Name: See waste profile.
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3.10.4 Soils or Cleanup Materials Contaminated with Alcohol
Characteristics: Contaminated or off-specification waste alcohol from spills. Liquid waste
must not be solidified for disposal.
Classification: Possible hazardous waste due to characteristics of ignitability (D001) or
unused commercial chemical product sole active ingredient methanol
(U154) if present in strong concentrations.
Disposal: Liquid alcohol disposed as a hazardous waste is shipped as D001 or
methanol (U154) hazardous waste if the discarded material exhibits the
characteristics. Solids/sludges that are wet with ignitable liquids are
segregated, containerized, and handled as hazardous waste.
Analyses: Apply generator knowledge; use previous characterization and/or SDS
information. Mixtures of alcohol and other materials to be disposed off
site will be tested for ignitability.
Waste Handling: Hazardous wastes will be collected in closed-top drums. Hazardous waste
containers will have properly completed EPA hazardous waste markings,
including the date when the drum becomes full or 55 gallons of the waste
has accumulated. Drums containing flammable liquids must be
grounded when adding or removing waste.
Shipping: Container DOT Specification: UN/1A2
Waste Code: D001 or methanol (U154).
Shipping Name: See waste profile.
3.10.5 Soils or Cleanup Materials Contaminated with Oxidizer
Characteristics: Contaminated or off-specification waste oxidizer from spills. Liquid waste
must not be solidified for disposal.
Classification: Possible hazardous waste due to characteristics of oxidizer (D001) if
present in strong concentrations.
Disposal: Liquid oxidizer disposed as a hazardous waste is shipped as D001
hazardous waste if the discarded material exhibits the characteristic.
Solids/sludges that are wet with oxidizer liquids are segregated,
containerized, and handled as hazardous waste.
Analyses: Apply generator knowledge; use previous characterization and/or SDS
information. Mixtures of oxidizer and other materials to be disposed off site
will be tested for oxidizer.
Waste Handling: Hazardous wastes will be collected in closed-top drums. Hazardous waste
containers will have properly completed EPA hazardous waste markings,
including the date when the drum becomes full or 55 gallons of the waste
has accumulated. Drums containing flammable liquids must be
grounded when adding or removing waste.
Shipping: Container DOT Specification: UN/1A2, or 1H2.
Waste Code: D001.
Shipping Name: See waste profile.
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3.10.6 Soils or Cleanup Materials Contaminated with Engine Coolant or
Heat Transfer Solution
Characteristics: Glycol-based engine coolant, glycol-based heat transfer solution (boiler
propylene glycol) and/or water from closed loop cooling systems
equipment, boilers, soil, and cleanup materials. Cleanup materials may
contain regulated metals and/or benzene. Ethylene and/or propylene
glycol is toxic by ingestion.
Classification: Non-hazardous solid waste unless contaminated with metals, fuels,
solvents, or other maintenance wastes the mixture may be regulated as a
characteristic hazardous waste when discarded.
Disposal: Non-hazardous, non-draining materials are thrown in the trash. Glycol-
based coolant or heat transfer solution, known to be contaminated with
metals, fuels, solvents, or other maintenance wastes, is segregated,
containerized, sampled, and tested for classification. Hazardous wastes
are containerized and handled as hazardous waste.
Analyses: Not required except for characterization of potentially contaminated
glycol-based coolant or heat transfer solution. For spill cleanup waste
characterization, a review of the SDS and/or testing may be required to
determine regulatory status.
3.10.7 Soils or Cleanup Materials Contaminated with Used Non-Listed
Solvent
Characteristics: Used, spilled cleaning solvent mixed with soil or cleanup materials.
Classification: Typically, non-hazardous unless there is sufficient metal content in the
spilled solvent to fail TCLP toxicity for metals or if an F-listed solvent has
been mixed with the solvent.
Disposal: Acceptable non-hazardous solid wastes with free liquids must be
solidified/dried before disposing in the trash. Soil contaminated with listed
solvents or other hazardous materials will be segregated, sampled, and
containerized for testing before being sent to a RCRA-permitted facility.
Analyses: Sample and test for TCLP metals, flash point, and volatile organics.
Waste Handling: Hazardous wastes will be collected in open-head drums having properly
completed EPA hazardous waste markings, including the date when the
drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: UN/1A2.
Waste Code: Varies with waste constituents.
Shipping Name: See waste profile.
3.10.8 Soils or Cleanup Materials Contaminated with Used Paint Thinner or
F-Listed Cleaning Solvent
Characteristics: Used thinner or F-listed solvent mixed with soil or cleanup materials.
Classification: Most of these products will fall under one of the F-listed solvents (F001-
F005) when spent and discarded. Used solvent may also contain enough
metals to fail TCLP toxicity for metals and/or flash point.
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Disposal: Hazardous waste must be disposed at a RCRA-permitted facility.
Analyses: Sample and test for TCLP metals, flash point, and volatile organics.
Waste Handling: Hazardous wastes will be collected in open-head drums having properly
completed EPA hazardous waste markings, including the date when the
drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: UN/1A2.
Waste Code: Varies with waste constituents.
Shipping Name: See waste profile.
3.10.9 Soils or Cleanup Materials Contaminated with Unused Paint,
Blended Commercial Formulations, or Chemical Mixtures
Characteristics: Paint, commercial products, or chemical products consisting of blends of
chemicals mixed with soil or cleanup materials. Commercial formulations
may be characteristic hazardous waste (e.g. a commercial formulation of
paint thinner may be hazardous due to ignitability and/or toxicity
characteristics).
Classification: Typically, non-hazardous but may be hazardous by characteristic
depending on the chemical properties of the spilled material. Review the
SDS for the spilled material to see if it would be a hazardous waste under
any of the characteristics. If the concentration of a characteristic
hazardous waste is high enough in the soil or cleanup materials, the
mixture may exhibit the hazardous characteristic and be a hazardous
waste.
Disposal: Acceptable non-hazardous solid wastes with free liquids must be
solidified/dried before disposing in the trash. Mixtures exhibiting a
hazardous waste characteristic are disposed as hazardous waste.
Analyses: Not typically required if information on hazardous waste characteristics
can be obtained from SDSs. If SDS information indicates that the
contaminated soil may exhibit a hazardous characteristic, analyze the
mixture for that characteristic.
Waste Handling: Hazardous wastes will be collected in open-head drums having properly
completed EPA hazardous waste markings, including the date when the
drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: UN/1A2.
Waste Code: Varies with waste constituents.
Shipping Name: See waste profile.
3.10.10 Soils or Cleanup Materials Contaminated with Acid
Characteristics: Acid mixed with soil or cleanup materials.
Classification: Typically, not a hazardous waste at low acid concentrations. Recycled
reagents are excluded from regulation as a solid waste under 40 CFR
261.2(e)(1)(ii) / R315-261-2(e)(1)(ii). May be a corrosive hazardous waste
(D002) if saturated with acid and the mixture has a pH less than 2.0. Non-
hazardous solid waste after being neutralized according to SDS
recommendations.
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Disposal: Containerize liquid waste for use or disposal. Treat spills according to
directions in SDS. Dispose of non-liquid non-hazardous waste in the trash.
Analyses: Mixtures of acid and other materials that are recycled do not require
testing. Sample and test pH on free liquid waste if disposed.
Waste Handling: Hazardous wastes will be collected in open-head drums having properly
completed EPA hazardous waste markings, including the date when the
drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: UN/1H2.
Waste Code: D002 for hazardous waste.
Shipping Name: See waste profile.
3.10.11 Soils or Cleanup Materials Contaminated with Caustics and/or Lime
Characteristics: Caustic (sodium hydroxide), antiscalant (sodium hydroxide mixture), Trasar
Trac 101 (sodium nitrate used in the boiler), and/or lime reagents mixed
with soil or cleanup materials.
Classification: Typically, not a hazardous waste at low caustic/alkaline concentrations.
Recycled reagents are excluded from regulation as a solid waste under
40 CFR 261.2(e)(1)(ii) / R315-261-2(e)(1)(ii). May be a corrosive hazardous
waste (D002) if saturated with caustic and the mixture has a pH greater
than 12.5. Non-hazardous solid waste after being neutralized according to
SDS recommendations.
Disposal: Containerize liquid waste for use or disposal. Treat spills according to
directions in SDS. Dispose of non-liquid non-hazardous waste in the trash.
Analyses: Mixtures of caustic materials and other materials that are recycled do not
require testing. Sample and test pH on free liquid waste if disposed.
Waste Handling: Hazardous wastes will be collected in open-head drums having properly
completed EPA hazardous waste markings, including the date when the
drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: UN/1H2.
Waste Code: D002 for hazardous waste.
Shipping Name: See waste profile.
3.10.12 Soils or Cleanup Materials Contaminated with Antiscalant
Characteristics: Antiscalant (without acid or caustic constituents) mixed with soil or
cleanup materials.
Classification: Non-hazardous solid waste.
Disposal: Recycled to the process.
Analyses: Not required.
3.10.13 Soils or Cleanup Materials Contaminated with a Pure Chemical
Characteristics: Any pure chemical or a commercial formulation with one essentially pure
form chemical sole-active ingredient mixed with soil or cleanup materials.
Classification: May be a listed hazardous waste or be hazardous by characteristic
depending on the chemical properties of the spilled material. Review the
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SDS of the spilled material to see if it would be a hazardous waste under
any of the characteristics or listed hazardous waste constituents. Review
the hazardous waste listings in 40 CFR 261.33/ R315-261-33 to see if the
chemical is listed. If the spilled chemical is listed as a hazardous waste in
40 CFR 261.33/ R315-261-33, the mixture is also hazardous, unless it is listed
only for the characteristics of ignitability (I), corrosivity (C), or reactivity (R),
then the resulting mixture is hazardous only if it exhibits the characteristic.
Mixtures listed for other than characteristics of I, C, or R are hazardous
waste bearing the P or U hazardous waste number of the chemical.
Disposal: Acceptable non-hazardous solid wastes with free liquids must be
solidified/dried before disposing in the trash. Dispose of in a hazardous
waste disposal facility for mixtures with a listed hazardous waste or
mixtures exhibiting a hazardous waste characteristic.
Analyses: Not typically required if information on hazardous waste characteristics
can be obtained from SDSs. If SDS information indicates that the
contaminated soil may exhibit a hazardous characteristic, analyze the
mixture for that characteristic.
Waste Handling: Hazardous wastes will be collected in open-head drums having properly
completed EPA hazardous waste markings, including the date when the
drum becomes full or 55 gallons of the waste has accumulated.
Shipping: Container DOT Specification: UN/1A2.
Waste Code: Varies with constituents.
Shipping Name: See waste profile.
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4.0 ACCEPTABLE SOLID WASTE (TRASH) FOR OFF SITE
DISPOSAL
4.1 GENERAL DESCRIPTION OF ACCEPTABLE SOLID WASTES
All waste to be placed in the trash containers will be incidental to the industrial operation (see
Table 1). Examples of acceptable wastes include:
• Untreated wood wastes
• Paper products
• Drained and crushed oil filters
• Empty containers (x 3 rinse) crushed or cut
• Five-gallon empty containers or smaller with lids off
• Office and lunch room wastes
• Uncontaminated piping and liner material
Acceptable non-hazardous solid wastes (trash) are disposed in trash containers on site and
transported for disposal off site at permitted county landfills. Acceptable non-hazardous solid
wastes with free liquids must be solidified/dried before disposing in the trash.
4.2 FACILITY CONSTRUCTION WASTES
The construction of new facilities at the facility will generate some wastes. These wastes will
include wood, paper, and other non-salvageable metal products. The disposal of these wastes
will continue intermittently for the life of the facility site.
4.3 TRASH
The disposal of domestic waste will be minimal since no on site housing exists or is planned.
Therefore, the amount of domestic waste to be disposed will be generated by the employees
only during their working hours.
4.4 PROHIBITED AND HAZARDOUS WASTE
The following materials cannot be disposed in the off site landfill (see Table 1):
• Hazardous waste
• Batteries
• Liquid wastes
• Unpunctured aerosol cans
• Undrained oil filters
• Drums which are not empty and crushed
• Household hazardous wastes
• Highly putrescible wastes, including dead animals
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• Spent cleaning solvents
• Household wastes brought on site by employees

Table 4.1 - Prohibited and Acceptable Waste List
Prohibited Wastes Acceptable Wastes
Hazardous Wastes Paper Products
Liquids (Oil/Paint/Solvents/Antifreeze) Untreated Wood Pallets/Crates/Scrap
Unpunctured Aerosol Cans Scrap Metal/Plastic
Batteries Empty Cloth/Plastic Bags
Drums (Undrained/Uncrushed/Uncut) Empty Cut-in-Half Plastic Drums or Crushed Steel
Drums
Undrained Oil Filters Empty Metal/Plastic Buckets/Cans/Bottles (Lids off)
Contaminated Piping and Liner Office Wastes
Contaminated Soils (Lead/Hydrocarbons) Lunch Room Wastes
Dead Animals Oily Rags/Gloves
Spill Cleanup Materials (PPE/Soil/Debris) Clean Piping/Liner Materials
Sludges (Sewage/Sumps) Unsalvageable Parts
Grease (All types) Drained and Crushed Filters
Transformers/Capacitors Clean Construction (Concrete/Wood)
Explosives
Medical Wastes
Large Used Tires
Lamps

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5.0 CONTAINER MANAGEMENT PLAN
This Container Management Plan has been prepared in compliance with the requirements of
the federal hazardous waste regulation found in 40 CFR Part 262.15 / R315-262-15 and/or 262.17 /
R315-262-17, and Company guidelines. This plan applies to all containers used to hold
hazardous materials/wastes, non-hazardous materials/wastes, and universal wastes generated
at the facility. Containers shall be in good condition with no leaks, dents, corrosion, or any other
defect that may compromise the integrity of the container. Container construction will be
compatible with the contents.
5.1 TYPES OF CONTAINERS
The following descriptions are for approved types of containers to be used for accumulation
and temporary storage of hazardous wastes and hazardous materials. The Safety-Health-
Environment Department shall review and approve any containers not listed below to be used
for hazardous materials/wastes, non-hazardous materials/wastes, and universal wastes.
5.1.1 Intermediate Bulk Containers (IBC) or Roll-Offs
Roll-off containers are used to contain bulk quantities of non-liquid hazardous waste and non-
hazardous waste. IBC containers used to contain liquids, shall meet Department of
Transportation (DOT) United Nations (UN) specifications. Roll-offs will meet DOT non-sift proof
requirements. The construction material for the bulk containers will be compatible with the
characteristics of the wastes to be contained. This should be determined in consultation with
the Safety-Health-Environment Department. All bulk containers will be in good condition with no
damage or corrosion that would impair the ability of the bulk containers to contain the wastes.
The tops of roll-offs should incorporate a flexible sealing gasket or tarp in good condition.
5.1.2 55-Gallon Open-Head Drums
These containers are used to contain non-bulk quantities of non-liquid hazardous waste and
non-hazardous waste. Wastes shall be placed into clean, 55-gallon, open-head type drums
meeting DOT UN specification (e.g. steel drums 1A2/Y250 and plastic drums 1H2). The
construction material for the drums shall be compatible with the characteristics of the wastes to
be contained. This should be determined in consultation with the Safety-Health-Environment
Department. All drums shall be in good condition with no damage or corrosion that would
impair the ability of the drum to contain the wastes. The tops should incorporate a flexible
sealing gasket in good condition. The sealing rings should fit the drums and be able to seal the
drums tightly. Drums with side bungs should not be used.
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5.1.3 55-Gallon Closed-Top Drums
These containers are used to contain non-bulk quantities of liquid hazardous waste and non-
hazardous waste. Wastes shall be placed into clean, 55-gallon closed-top type drums meeting
DOT UN specification (e.g. 1A1/Y1.4/250). All drums shall be in good condition with no damage
or corrosion that would impair the ability of the drum to contain the wastes. The construction
material for the drums shall be compatible with the characteristics of the wastes to be
contained. This should be determined in consultation with the Safety-Health-Environment
Department. The tops should incorporate threaded bungs in good condition. The bungs should
fit the drums and be able to seal the drums tightly. Sufficient headspace (about 3 inches) should
be left in the container to provide for liquid expansion and contraction.
5.1.4 Salvage Drums (Used for Overpacks)
These containers are used for managing leaking or off-specification containers. Steel drums shall
meet DOT UN specification 1A2. Plastic drums shall meet DOT UN specification 1H2. The
construction material for the drums shall be compatible with the characteristics of the wastes to
be contained. This should be determined in consultation with the Safety-Health-Environment
Department. All drums shall be in good condition with no damage or corrosion that would
impair the ability of the drum to contain the wastes. The tops should incorporate a flexible
sealing gasket in good condition. The sealing rings should fit the drums and be able to seal the
drums tightly. Drums with side bungs should not be used.
5.1.5 Universal Waste Containers
These containers are used to contain universal wastes (e.g. "Batteries", "Lamps", or "mercury
containing equipment"). Universal wastes shall be contained in containers or packages that are
structurally sound, adequate to prevent breakage, and compatible with the contents. This
should be determined in consultation with the Safety-Health-Environment Department. All
containers shall be in good condition with no damage or corrosion that would impair the ability
of the container to contain the wastes.
5.1.6 Totes and Tanks
These containers are used to contain used oil and/or coolant (i.e., antifreeze). The construction
material for the containers shall be compatible with the characteristics of the wastes to be
contained. This should be determined in consultation with the Safety-Health-Environment
Department. All containers shall be in good condition with no damage or corrosion that would
impair the ability of the container to contain the wastes. Liquid waste shall be added with a
funnel to prevent spillage.
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5.2 MANAGEMENT OF CONTAINERS
a. All containers of hazardous materials/wastes, non-hazardous materials/wastes, and
universal wastes shall be closed during all times when wastes are not being added or
removed from the containers. IBCs shall be closed per container specific DOT closure
instructions. Roll-offs shall be closed by closing the door or covering the opening with a
tarp. Open top drums shall be closed by placing the lid and sealing ring on the drum.
The sealing ring bolt must face down and should be tightened sufficiently so that the
contents of the drum will not spill if the drum were to tip over. Only non-liquid wastes shall
be placed in open-head drums. All liquids shall be placed in closed-top drums with
bungs. Drums shall have their bungs turned in tight except when wastes are being
added or removed. Liquid waste shall be added with a funnel to prevent spillage.
b. All containers holding flammable wastes such as paints, paint-related material, and
solvents shall be grounded with a grounding wire attached to bare metal on the drum
before opening the container top to minimize the potential for sparking when adding
waste.
c. Only non-sparking bung wrenches and funnels shall be used for drums holding
flammable wastes.
d. Containers of hazardous materials/wastes, non-hazardous materials/wastes, and
universal wastes shall be handled carefully to prevent damaging the containers. Full
containers shall not be stacked or stored on their sides. Any damage caused to a
container of hazardous waste and/or universal waste shall immediately be reported to
management and an evaluation shall be made as to whether the container should be
overpacked or if the contents of the container should be transferred to a good
container. Any spilled hazardous waste should be immediately contained to minimize
contamination. Hazardous Waste Container Inspection Records shall be completed on
a weekly basis for all containers of hazardous waste in designated 90-day hazardous
waste storage areas.
e. Properly completed labels identifying the container contents shall be placed on the
upper 1/3 of each drum or container when the first waste is placed inside. Deteriorated
non-legible labels will be replaced.
f. Containers of unidentified waste that have not yet been characterized shall be marked
as determined by the Safety-Health-Environment Department.
g. Containers of hazardous waste shall be marked with a "Hazardous Waste" marking that
complies with 40 CFR 262.15 / R315-262-15. The accumulation start date shall be filled in
with the date and proper hazardous waste codes entered on the marking when the first
waste is added to the container, except for satellite accumulation container situations.
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The date is added to the container marking the day the satellite accumulation container
becomes full. The manifest document number shall be completed at the time the
container is shipped off site for disposal.
h. Containers of hazardous waste shall be marked with “hazard communication labels”
(e.g., hazard statement or pictogram consistent with the Occupational Safety and
Health Administration Hazard Communication Standard at 29 CFR 1910.1200 or DOT
hazard class label(s)) identifying the hazardous waste characteristics (i.e., ignitable,
corrosive, reactive, toxic).
i. Containers of incompatible hazard classes shall be separated by physical barriers or
enough distance to separate potential spills and prevent mixing of incompatible
materials.
j. Any drum to be disposed or reused should first be drained of all free liquid. All empty
drums should have bungs/lids on and should be stored on their sides. Drum to be used
for handling other non-hazardous wastes/materials or returned to vendors for refund
should be placed in designated areas. Drums that are damaged or are otherwise
intended to be disposed should be placed in the designated area prior to crushing
before being thrown in the trash. Drums may be managed as scrap metal.
5.3 CONTAINER INSPECTIONS
a. All containers of hazardous waste in designated 90-day hazardous waste storage areas
and/or designated hazardous waste satellite accumulation area shall be inspected at
least weekly, looking for proper labels, leaks, and deterioration caused by corrosion or
other factors. Hazardous Waste Container Inspection Records shall be completed on a
weekly basis for all containers of hazardous waste.
b. Containers shall be placed in designated satellite accumulation areas or the hazardous
waste storage area with sufficient space separating each container so that the inspector
can observe the top and all sides of each container of hazardous waste. All containers
shall be oriented such that all hazardous waste labels can be readily observed without
turning the containers.
c. Records of the inspections shall be maintained by the Safety-Health-Environment
Department.
5.4 STORAGE LIMITATIONS
Large Quantity Generators will not store hazardous waste onsite for more than 90 days, while
Small Quantity Generators will store hazardous waste on site for no more than 180 days (or 270
days if the facility is 200 miles or more from the TSDF). Very Small Quantity Generators and Small
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Quantity Generators will not store greater than 6,000 kg (13,200 lbs. or about 26 full drums) of
hazardous waste onsite.
5.5 IGNITABLE OR REACTIVE WASTES
a. 40 CFR 262.17(a)(1)(vi)(A) / R315-262-17(a)(1)(vi)(A) requires that ignitable or reactive
wastes should not be stored any closer than 50 feet from the property fence line.

b. Flammable and reactive wastes will be separated and protected from ignition sources
including smoking areas. “No Smoking” signs will be posted in the storage areas.

5.6 INCOMPATIBLE WASTES
a. Incompatible wastes (e.g., acids and bases, or organics and corrosives), shall not be
placed in the same containers. When there is any doubt as to the compatibility of a
waste to be added to a container, do not add the waste until after checking with the
Safety-Health-Environment Department.
b. Only new, reconditioned, or clean drums or containers shall be used for storage of
hazardous waste. In no case shall a drum or container that previously held an
incompatible material be used for storage of hazardous waste without first being
thoroughly cleaned and rinsate properly disposed. Contact the Safety-Health-
Environment Department for proper decontamination procedures.
c. Containers of hazardous waste that are incompatible with other hazard wastes being
stored nearby shall be separated by physical barriers (i.e., containment pallets) or
enough distance to separate potential leaking container spills and prevent mixing of
incompatible materials.
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6.0 PREPAREDNESS AND PREVENTION PLAN
This Preparedness and Prevention Plan has been prepared in compliance with the requirements
of the federal hazardous waste regulations found in 40 CFR Part 262 Subpart M (262.250-265) /
R315-262-250-265 Preparedness and prevention for an LQG and Company management
practice. Thatcher Company, Inc. (Thatcher) intends to comply with all the LQG requirements
for 90-day and satellite accumulation hazardous waste storage areas. This plan applies to the
90-day and satellite accumulation hazardous waste storage areas located at the facility:
90-Day Hazardous Waste Storage Areas
• The temporary 90-day hazardous waste storage area (drums and containers) located in
the north west storage area (NWSA), which also provides storage for non-hazardous
waste; and,
• The 90-day Lab hazardous waste storage area located outside on the east side of
Building 16 (maintenance shop) directly across from the west side of the lab.
• Other temporary 90-day hazardous waste storage areas may be established on a case-
by-case basis.
Satellite Accumulation Hazardous Waste Storage Areas
• The Lab storage area is located outside on the east side of the Building 16; and,
1.
• Building 16 aerosol puncturing area located on the north side of the Building.
The location of Hazardous Waste Generation and Satellite Accumulation Areas ar e shown on
Figure 1.
A boundary fence restricts access to most of the site including the NWSA. The NW SA and lab
storage areas also have separate fences to restrict access to the storage containers. Building 16
satellite accumulation container is maintained in the Building until full and then moved to the lab
storage area. Containers are stored on containment pallets in the lab area and/or on the
ground in the NWSA. Access to the 90-day hazardous waste storage areas is limited to
authorized personnel.
Signage with wording identifying the appropriate health and safety warnings (i.e. No Smoking)
will be posted around the 90-day hazardous waste storage area locations. Drums are to be
placed in these designated areas on wooden or containment pallets. Contain ment pallets will
be used to separate incompatible materials. Empty drums will be stored on their sides in
designated areas.
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6.1 HAZARDOUS WASTE STORAGE AREAS MAINTENANCE AND
NORMAL OPERATION PROCEDURES
The hazardous waste storage areas will be maintained and operated such as to minimize the
possibility of fire, explosion, or any other release of hazardous waste to the air, soil, or surface
water which could threaten human health or the environment. This will be accomplished in the
following ways:
a. To access the 90-day drum/container hazardous waste area, Thatcher personnel will be
given authorization from the Safety-Health-Environment Department and have a
portable radio and/or cellular phone on their persons.
b. All employees working in the hazardous waste storage areas shall be trained in the
proper handling of the wastes, appropriate personal protection measures, and
appropriate emergency response measures, relevant to their normal working
responsibilities.
c. All containers of hazardous waste shall be stored only in the designated area or
drum/container handling facility, which incorporate spill control measures.
d. All containers of hazardous waste shall be:
1. Properly labeled and marked with the words "HAZARDOUS WASTE", wording
identifying the contents, and labels identifying the hazardous waste
characteristics (e.g., ignitable, corrosive, reactive, toxic).

2. Placed on pallets and oriented so that their labels and markings are readily visible
to allow inspections of the containers and their labels.

3. Placed with sufficient aisle space and with aisle space maintained between lines
of drums in the drum/container handling facility such as to allow the
unobstructed movement of containers, spill control materials, and fire control
equipment; and

4. Each drum shall have a unique number identification to facilitate the recording
of inspection information.

e. All hazardous waste containers shall be of appropriate type and quality and shall be
tightly closed except for when wastes are being added or removed.
f. All workers shall extinguish any smoking materials or other open flames before entering
the drum/container handling facility.
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g. Containers of flammable hazardous waste shall be grounded with grounding wires
before being opened to add or remove wastes.
h. A grounding strap shall be attached to any drum containing flammable wastes before
opening.
i. Wastes shall be carried through the workplace to the hazardous waste storage container
in closed cans, buckets, or drums that are marked as to their contents and which would
prevent a spill if tipped or dropped.
j. Wastes shall be handled carefully when being transferred to the roll off and/or storage
drums/containers. Liquid wastes will always be added using the funnels or other
appropriate method.
k. Containers shall be handled carefully to prevent damage to them. Any damaged
container shall be evaluated as to its ability to satisfactorily contain the wastes and the
wastes shall be transferred to a new container if necessary. Alternatively, damaged
drums will be overpacked into open-head salvage drums.
l. Spill containment and cleanup materials shall be available at the waste storage areas
and/or warehouse areas and shall be used whenever there is a spill of hazardous waste.
m. Inspections of the 90-day hazardous waste storage areas shall be conducted weekly
and following any emergency response. Equipment shall be tested and maintained.
These inspections shall include observations and a record of the status of at least the
following:
1. Condition of all containers including their closure condition, labels, and any
damage or signs of corrosion or leakage. Items to be inspected will include the
number of containers in storage, how long they have been in storage, and any
observations of any problems or abnormal conditions with containers or other
storage area characteristics, noting which drum(s) had the problem(s).
2. Condition and availability of all tools, emergency response materials, including
monthly fire extinguisher inspections, and communications equipment.
3. Condition and completeness of all container labeling and marking. Particular
attention will apply to the accumulation dates and amounts of hazardous waste
stored.
4. The inspector will also note if there are any hazardous waste containers that have
been in storage for an extended time period (approaching the 90-day limit).
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n. Hazardous Waste Container Inspection Records shall be completed on a weekly basis for
all containers of hazardous waste. The written record of each inspection shall be
promptly delivered to the Safety-Health-Environment Department following each weekly
inspection. Inspection records shall be maintained by the Safety-Health-Environment
Department for a period of at least three years. Any abnormal conditions shall be
reported to the Safety-Health-Environment Department Vice President (VP) or their
designee in a timely manner. Any inspections noting leakage or potential leakage of
hazardous waste, or any other conditions that may result in danger to personnel or the
environment, shall be reported to the Safety-Health-Environment Department
immediately. The Safety-Health-Environment Department shall also note from the
inspection reports if storage times and/or amounts are nearing the allowable limits and
make the proper arrangements to dispose of the waste before these limits are
exceeded.

6.2 REQUIRED EQUIPMENT FOR OPERATION OF THE HAZARDOUS
WASTE STORAGE AREAS
The following materials and equipment are used in the hazardous waste storage areas; unless
none of the hazards posed by waste handled at the storage area could require a particular kind
of equipment:

a. 90-Day and Satellite Accumulation Hazardous Waste Storage Areas (drums and
containers).

b. Portable radios or telephones in proper working order which can be used to report
emergencies and allow the workers at the storage area to receive immed iate
emergency instruction. [262.252(a)(b), 262.254(b), and 262.261(e) / R315-262-(252(a)(b),
254(b), and 261(e)]

1. Emergency Communications - The following emergency communications
method is used for a hazardous waste emergency.

a) The supervisor or manager responsible for the area will notify the
Emergency Coordinator. See Appendix A Emergency Coordinators –
Contact List.

b) In the event of an imminent or actual emergency, the Area Supervisor will
notify all personnel and the Safety-Health-Environment Manager on site
by:

1) Paging using the overhead phone system—three random phone keys
will be pushed on the air to bring attention to the speaker. The person
paging may state the chemical involved, type of release, the
location, and the severity or other details of the incident.
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i. The Supervisor may designate a representative to speak on the
paging system, if the emergency requires his/her immediate
attention.

2) For Laboratory and Office Staff Workers, press the “PAGE” button,
press “00” for the entire plant, then three random phone keys on the
air to bring attention to the speaker.

c) After the announcement (page) has been made to evacuate the
working areas of the plant, Supervisors will shut-down their operations. For
areas with more involved shutdown procedures, the Supervisor will follow
the emergency shut-down SOP specific to their area, if applicable.

d) The evacuation location will be determined by the HazMat team
leadership. Once determined, the location will be paged to all
employees.

e) In the event that a partial or site wide evacuation is required, the
evacuation location will be determined by the HazMat team leadership.
Once determined, the location will be paged to all employees. The
“Page” will be accompanied by the order to evacuate as outlined in
Section 2.7 Evacuation Plans.

Table 6.1 - Hazardous Waste Storage Areas Phone Locations
Hazardous Waste
Storage Area (90-
Day NWSA)
Hazardous Waste
Storage Area (90-Day
Lab)
Lab Satellite
Accumulation
Storage Area
Maintenance
Satellite
Accumulation
Storage Area
Building 6 Building 17 Building 17 Building 16

c. Fire extinguishers, in working order and/or other fire equipment where available. These
are to extinguish fires involving the types of wastes stored in the area. [40 CFR 262.252(c)
and 262.261(e) / R315-(252(c), 261(e))]

Table 6.2 - Hazardous Waste Storage Areas Fire Extinguisher Locations
Hazardous Waste
Storage Area (90-
Day NWSA)
Hazardous Waste
Storage Area (90-Day
Lab)
Lab Satellite
Accumulation Storage
Area
Maintenance
Satellite
Accumulation
Storage Area
Immediate Area Within Building-17 Within Building-17 Within Building-16

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d. If large volumes of water are required to respond to a fire, this is available through the
site fire hydrants shown on Figure 1. [40 CFR 262.252(d) / R315-262-252(d)]
e. A labeled spill kit with response materials for the containment, absorption and cleanup of
wastes that are stored in the areas. The spill response materials also include suitable
personal protective equipment sufficient for two workers to respond to a significant spill
of the type of hazardous waste stored in the facility. [40 CFR 262.252(c) / /R315-262-
252(c)]
Table 6.3 - Hazardous Waste Storage Areas Spill Kit or Equipment Locations
Hazardous Waste
Storage Area (90-
Day NWSA)
Hazardous Waste
Storage Area (90-Day
Lab)
Lab Satellite
Accumulation Storage
Area
Maintenance Satellite
Accumulation
Storage Area
Immediate Area Within Building-17 Within Building-17 Within Building -16

f. Mobile equipment is available throughout the facility.

g. Additional PPE and chemical protective clothing are readily available at maintenance
stores.

h. Decontamination equipment is available on site and at maintenance stores.

i. Grounding straps and connectors to allow grounding of a container of flammable waste
before opening. [40 CFR 262.252(c) and 262.261(e) / R315-262-(252(c) and 261(e))]

j. Sufficient lighting to allow safe working conditions at all times wastes are being handled
in the waste storage area. If artificial lighting is not available, wastes will only be handled
in the storage area during daylight hours.

k. Appropriate tools for handling the containers of waste including non-sparking wrenches
and a non-sparking funnel. [40 CFR 262.252(c) / R315-262-252(c)]

l. At least one empty 55-gallon drum of the appropriate type (open head or bung) ready
to receive each type of waste stored in the area, and one empty, salvage drum to be
used to contain a leaking 55-gallon drum. [40 CFR 262.252(c) / R315-262-252(c)]

m. All facility communications or alarm systems, fire protection equipment, spill control
equipment, and decontamination equipment, where required, will be tested , and
maintained as necessary to assure its proper operation in time of emergency [40 CFR
262.253 / R315-262-253].

1. The communications equipment (handheld radios and cell phones) are tested
routinely through constant use at the property. Fire extinguishers are inspected
and tested regularly by the Environmental Safety and Health Department. Spill
control equipment at the hazardous waste storage facilities does not require
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testing but is maintained as necessary to be ready for use in an emergency.

2. Notify all personnel on site by Paging using the overhead phone system.

3. There are not any alarms related to hazardous waste generation or storage on-
site.

6.3 ARRANGEMENTS WITH LOCAL AUTHORITIES
See 9.0 Contingency Plan and Emergency Procedures Section 9.10 Coordination with Local
Authorities.

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7.0 HAZARDOUS WASTE SATELLITE AND UNIVERSAL WASTE
ACCUMULATION AREAS
In concert with the federal hazardous waste regulations in 40 CFR Parts 262.15 / R315-262-15 and
273 / R315-273, Thatcher has established one or more "satellite accumulation and/or universal
waste areas" at its facilities. These are intended to gradually accumulate hazardous wastes
and/or universal wastes in containers. Hazardous waste is accumulated in satellite
accumulation containers until they are full, at which time the containers are transferred to the
hazardous waste storage area. Universal wastes are accumulated in containers for no longer
than one year. The operation of the hazardous waste satellite accumulation and/or universal
wastes accumulation areas will be as follows:

a. Employees working with the hazardous and/or universal wastes will be trained in the
proper handling of the wastes and appropriate emergency response measures relevant
to their normal working responsibilities.

b. All satellite accumulation drums will be marked with the words "HAZARDOUS WASTE",
wording identifying the contents, and “hazard communication labels” (e.g., hazard
statement or pictogram consistent with the Occupational Safety and Health
Administration Hazard Communication Standard at 29 CFR 1910.1200 or DOT hazard
class label(s)) identifying the hazardous waste characteristics (i.e., ignitable, corrosive,
reactive, toxic).

c. All universal waste accumulation containers will be marked with the words "Universal
Waste" and the date the waste is first put in the containers. In addition, the container
shall be marked to identify the contents (e.g., "Batteries").

d. All accumulation containers will be located at or near the point of generation of the
wastes and will be under the control of the operator.

e. The accumulation containers will be located to be readily inspected on all sides and to
allow room for spill control and fire response (See section 5.3 for container inspection
procedures).

f. All accumulation containers will be oriented so that their labels and markings are readily
visible for inspection.

g. All accumulation containers will be closed except when wastes are being added or
removed.

h. Grounding straps will be connected to any accumulation drum containing flammable
wastes before opening.

i. Wastes will be handled carefully when being transferred to the accumulation drums or
containers. Liquid wastes should always be added using funnels. Any spillage will be
immediately cleaned up.
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j. When a 55-gallon or less hazardous waste satellite accumulation container is full, it should
be labeled with the appropriate EPA and/or DOT markings and labels. The
accumulation date on the EPA hazardous waste label (required on satellite
accumulation drums) should be filled in with the date that the drum became full.

k. Full satellite accumulation drums will be transferred to a hazardous waste storage area
within three days of becoming full.

l. Universal wastes are accumulated on-site for no longer than one year at which time the
containers are shipped to the universal waste management facility.

m. All outdoor accumulation drums may be placed on individual spill containment pallets to
control any spills or leakage.
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8.0 PRE-TRANSPORT REQUIREMENTS AND RECORD KEEPING
In compliance with 40 CFR 262 Subparts B, C, and D / R315-262-(20-27, 30-35, and 40-44), and
Company guidelines, the following requirements will be followed in preparing hazardous waste
for shipment off site and for the proper maintenance of records regarding these shipments.

a. Hazardous wastes will only be disposed in properly permitted, off site treatment, storage,
and disposal facilities (TSDF) that have been audited and approved by the Thatcher.

b. Chemical waste profiles, and profile samples as required for initial approval, will be
provided to the TSDF in advance of shipping the hazardous waste. The waste will not be
shipped until the TSDF replies with an approval.

c. Wastes will be packaged, labeled, and marked in compliance with applicable DOT
regulations and the requirements of the TSDF prior to shipping.

d. A Uniform Hazardous Waste Manifests (UHWM) prepared by hazardous waste disposal
vendors will be reviewed by the Safety-Health-Environment Department prior to the
shipping date.

e. The UHWM will be signed by the DOT 49 CFR trained Safety-Health-Environment
Department personnel and the transporter when the waste is shipped. The generator
copy of the UHWM will then be retained by the Safety-Health-Environment Department
and the rest of the copies will be given to the transporter.

f. The waste containers will be inspected to check for proper, non-leaking condition of the
containers, that all covers, bungs, and/or gaskets are tight and sealed, and that all
required markings and labels are present.

g. Prior to the shipment date, the appropriate, DOT-approved placards for the waste
shipment will be obtained to be offered to the transporter if the transporter does not
provide them.

h. Care will be taken to store hazardous waste on site for no more than 90-days for a LQG.

i. Copies of each manifest will be retained in facility records for at least 3 years.

j. Copies of all waste analyses or other determinations will be retained in facility records for
at least 3 years.

k. If a signed copy of a manifest is not received by an LQG, from a TSDF within 35 days of
shipping the waste, determine the status by contacting the transporter or TSDF. If a
signed copy of the manifest is not received from a TSDF within 45 days of shipping the
waste, a copy of the manifest with an explanation letter that the mine has not received
confirmation of delivery shall be sent to UDEQ.
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l. Biennial Reports shall be prepared and submitted by March 1 of each even numbered
year in compliance with instructions provided for the report form and UDEQ. Copies of
the Biennial Report shall be retained in mine records for at least 3 years.

m. Determine if the hazardous wastes are restricted from land disposal (40 CFR Part 268 /
R315-268). For each shipment of restricted hazardous wastes that do not meet treatment
standards, a written notification shall be made to the treatment and/or disposal facility.
For each shipment of restricted hazardous wastes that can be land disposed without
further treatment, a written notification and certification that the waste meets treatment
standards shall be made to the treatment and/or disposal facility (see 40 CFR Part 268.7 /
R315-268-7 for notification/certification content requirements).

n. Determine the underlying hazardous constituents (as defined in 40 CFR Part 268.2 / R315-
268-2) for all wastes exhibiting the characteristic of ignitability (D001) (other than high
TOC ignitable liquids), corrosivity (D002), reactivity (D003), and/or TCLP toxicity (D004-
D043). The disposal facility shall be notified of all underlying hazardous constituents for
these wastes.

o. Copies of all notices, certifications, demonstrations, waste analyses, and other
documents pursuant to the land disposal restrictions (40 CFR Part 268/ R315-268) shall be
retained for at least 3 years.
8.1 EPISODIC GENERATION REQUIREMENTS AND RECORD KEEPING
In compliance with 40 CFR 262 Subpart L/ R315-262-(30-33), the following requirements will be
followed for VSQG and SQG hazardous waste episodic generation.

a. Episodic generation applies to planned or unplanned activities that do not normally
occur during generation operations (i.e., maintenance or spills).

b. Episodic generation is limited to one episodic event per year unless a petition is granted
for additional events. EPA-approved episodic events do not count toward the facility’s
generator status.

c. A notification form (EPA using the RCRA Subtitle C Site Identification Form (8700-12)) must
be submitted to UDEQ/DSHW: 1) 30-days prior to a planned event; and 2) within 72-hours
by phone, via fax, or email for unplanned events.

Notification must include: the start date and end date of the episodic event and the
reason(s) for the event, types and estimated quantities of hazardous wastes expected to
be generated as a result of the episodic event, and identify a facility contact and
emergency coordinator with 24-hour telephone access to discuss the notification
submittal or respond to emergency.

d. Generated hazardous waste must be transported off-site within 60-days of generation.

e. A VSQG must obtain an EPA identification number if it doesn’t have one.
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f. Hazardous waste containers must be marked “Episodic Hazardous Waste” and the date
the waste was placed in the container, in addition to the standard hazardous waste
container marking requirements.

g. Records must be kept for 3 years and record keeping must include: 1) beginning and
end dates of the episodic event; 2) description of the episodic event, types, and
quantities of hazardous waste generated; 3) transporter name(s), description of
management and name of the hazardous waste disposal facility; and 4) approval letter
for petitioned additional episodic event.

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9.0 CONTINGENCY PLAN AND EMERGENCY PROCEDURES
In compliance with 40 CFR Part 262 Subpart M (262.260-265) / R315-262-(260-265) Contingency
Plan and Emergency Procedures and company policy, Thatcher Company, Inc. (Thatcher) has
developed the following Contingency Plan and Emergency Procedures for any accidents
involving hazardous waste at its facilities. This portion of the plan is designed to minimize hazards
to human health or the environment from fires, explosions or any unplanned sudden or non-
sudden release of hazardous waste or hazardous waste constituents to air, soil or surface water.
The Thatcher facilities have this Contingency Plan (hazardous waste) and an Emergency
Response Program (hazardous materials Emergency Action Plan and Emergency Response Plan)
in place. Thatcher employees respond to incidents according to the plan applicable to the
materials released (i.e., hazardous waste and/or hazardous material) and training received.
9.1 EMERGENCY COORDINATORS
a. An Emergency Coordinator chain-of-responsibility has been created at the facility to
coordinate all emergency response measures related to hazardous waste. The persons
listed are qualified to act as Emergency Coordinators with the knowledge, responsibility,
and authority for coordinating emergency response measures to be taken in the event
of an emergency involving hazardous wastes. This employee must be either present at
the facilities or on call (and able to report to the facility within a short per iod of time) with
the responsibility for coordinating all emergency response measures. The Emergency
Coordinator and/or Alternate will be thoroughly familiar with the contents of this
contingency plan. This person must have the authority to commit the re sources needed
to carry out the contingency plan. The Emergency Coordinator and/or Alternates are
listed in Appendix A - Emergency Coordinators Contact List..
*The supervisor or manager responsible for the area will notify the Emergency
Coordinator.
b. For emergencies involving hazardous waste, if the key individuals named above are not
immediately available or are in route to the facility, the following procedure will be used.

1. The first member of the Thatcher HazMat Emergency Response Team (HERT) to
arrive at the scene of an incident involving hazardous waste will communicate
with security and will help restrict access to the area of the incident until a more
senior member of the HERT or one of the persons named above arrives at the
scene of the incident.

c. The Emergency Coordinator and the alternate Emergency Coordinators are qualified to
act in this capacity due to their thorough familiarity with the following:
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1. Types of hazardous waste operations and activities at the facility;
2. Locations and characteristics of all hazardous wastes handled;
3. Locations of all records regarding hazardous wastes within the facility;
4. Layout of the facility, including all emergency equipment, manpower, and levels of
response training;
5. Appropriate evacuation procedures;
6. Safe and appropriate emergency response procedures;
7. Proper handling of hazardous wastes produced in response actions; and,
8. Selection and implementation of the proper decontamination procedures and
solutions used in response to hazardous conditions.
9.2 EMERGENCY COORDINATOR ACTIONS
a. If there is an imminent or actual emergency involving hazardous waste at the facility, the
Emergency Coordinator (or alternate) will:

1. Respond immediately when called out.

2. Activate emergency communications to notify all personnel in affected areas if
not already completed.

a) Paging using the overhead phone system—three random phone keys will
be pushed on the air to bring attention to the speaker. The person paging
may state the chemical involved, type of release, the location, and the
severity or other details of the incident.

b) The Supervisor may designate a representative to speak on the paging
system if the emergency requires his/her immediate attention.

c) For Laboratory and Office Staff Workers, press the “PAGE” button, press
“00” for the entire plant, then three random phone keys on the air to bring
attention to the speaker.

d) There are not any alarms related to hazardous waste generation or
storage on-site.

3. The Emergency Coordinator must decide if a situation is controllable by plant
personnel, onsite emergency response team, or if outside response is required
and will determine the need to implement provisions of the plan.
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4. Confirm that facility staff has begun the appropriate emergency response
actions, if not, assist in coordinating the appropriate response.

5. Establish security at the immediate location of the incident to prevent the entry of
unauthorized persons into the affected area.

6. Determine the character, source, amount, and extent of any released hazardous
waste or hazardous waste constituents by:

a) Observing from a safe distance the physical character of the released
waste or hazardous material (vapor, liquid, solid),
b) Weather patterns and wind direction at the time of the release.
c) Determining the source of the release through inspection or from firsthand
reports of observers,
d) Estimate the amount of material released by noting the size of the
container or tank and the location of the release point on the container
or tank, and
e) Noting the lateral extent of the obvious contamination by actual
presence of the material or from indirect evidence (smoke, stains, wetted
surfaces etc.).

7. Assess the possible hazards to human health and the environment that may result
from the release, fire or explosion including identification of:

a) Toxic or irritating vapors, smoke or fumes,
b) Toxic and/or corrosive liquids or solids,
c) Oxidizing materials,
d) Potential fuels,
e) Incompatible materials or chemicals, and
f) Soil and/or water contamination.

These hazard assessments will be conducted through identifying the materials
released by their locations within the facility or reading markings, labels, and/or
truck placards and then determining their hazardous characteristics by reviewing
DOT Emergency Response Guide (ERG) and/or SDS information, using health and
safety monitoring equipment, and/or using generator knowledge. SDSs are
available on Thatcher’s Thatchernet system and provide information for the main
hazardous chemicals and hazardous constituents of the waste streams produced
at the facility. Characterization analyses, waste profiles, and manifests for
hazardous waste streams produced at the available from the Safety-Health-
Environment Department.

8. Determine the need for the evacuation of persons not required for immediate
response actions and initiate any appropriate evacuation procedures.
Evacuation directions should consider possible effects of downwind transport of
airborne contaminants and downhill transport of liquids on persons exposed
during the evacuation. Should evacuation be necessary employees should
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Thatcher Solid and Hazardous Waste Management Plan 88

gather at designated assembly points unless instructed otherwise, and supervisors
will conduct an accounting of their respective personnel.

9. Notify appropriate state or local agencies with designated response roles if
needed. The Emergency Coordinator will designate a point-of contact to help
communicate with local, county, and state authorities if needed.

10. If the Emergency Coordinator determines that the incident could affect human
health or the environment outside the facility the emergency coordinator must
report findings. See section 2.8 Emergency Reporting Procedures, Number 1-
Reportable Incident Determination.

11. Determine if shutdown of certain processes or operations is necessary to reduce
hazards of release.

a) If the facility stops operations in response to a fire, explosion or release, the
emergency coordinator must monitor for leaks, pressure buildup, gas
generation, or ruptures in valves, pipes, or other equipment wherever
appropriate; and,

12. Direct all reasonable measures necessary to ensure that fires, explosions, and
releases of hazardous waste do not occur, recur, or spread. These measures may
include:

a) Stopping, controlling, or containing the source of the release,
b) Containing the released materials to minimize spreading,
c) Eliminating or controlling health and safety hazards,
d) Collecting and containerizing released material, and
e) Cleaning up and/or treating residual contamination in-place.

13. Provide for the proper handling of any hazardous wastes produced during the
incident itself and during any response actions taken.

14. Prevent placing any incompatible wastes or hazardous materials in contact with
the released waste.

15. Initiate internal reporting and notifications to outside agencies as required.

16. Ensure that emergency response equipment and materials are returned to
readiness and are in proper working condition after the response action and that
decontamination of the equipment has been completed, if necessary.

17. Record the time, date, of samples obtained and by whom, in addition to details
of any incident that requires implementing the Contingency Plan and any
internal and external notifications given.

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18. Thatcher must notify Utah Department of Environmental Quality (UDEQ) that
Thatcher facilities are in compliance with the following if the Contingen cy Plan
has been implemented:

a) The Emergency Coordinator ensured that incompatible waste recovered
from released material was not treated, stored, or disposed of improperly.
b) Cleanup was complete; and,
c) Response equipment was returned to service for use before operations
were resumed in affected areas.

19. The contingency plan must be reviewed, and immediately amended, if
necessary, whenever:

a) Applicable regulations are revised.
b) The plan fails in an emergency.
c) The facility changes in its design, construction, op eration, maintenance, or
other circumstances – in a way that materially increases the potential for
incidents.
d) The list of emergency coordinators changes; and,
e) The list of emergency equipment changes.

b. Following any hazardous waste emergency response action, the Emergency Coordinator
will conduct such investigations or evaluations as may be necessary to determine the
causes of the incident and how to prevent future incidents; assess the effectiveness of
the response actions and how they may be improved; and, determine if any changes to
the facility's emergency response procedures can be made to improve the quality of the
facility's emergency preparedness.

9.3 EMERGENCY RESPONSE EQUIPMENT AND MATERIALS
Emergency response equipment is available in the immediate work area to the employees who
have been trained in the response actions required for a release of hazardous waste and/or
hazardous material. The HazMat Emergency Response Team will be mobilized for response as
required.
a. The equipment and material to be used to respond to an incident involving hazardous
waste is in work areas, designated hazardous waste storage areas, and/or warehouse.
This equipment and material include the following:

1. Dry chemical fire extinguishers - to extinguish chemical fires
2. Splash goggles - to protect eyes from liquids and solids
3. Butyl or neoprene gloves - to protect hands from solids and liquids
4. Neoprene boots - to protect feet from solids and liquids
5. SCBA - to protect against inhalation of extremely hazardous substances
6. Shovel - to build containment features and clean up solid material
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7. Broom - to clean up solid material
8. Duct tape - to seal PPE, tailor or repair PPE, hold plastic sheeting, provide
temporary repairs of containers or equipment

b. Other items available for incident response, but located in the warehouse and or near
the hazardous waste storage areas include:

1. Overpack drum - used to overpack another drum or contain spill cleanup wastes
2. Tyvek and Saranex suits - for protection against hazardous solids (Tyvek) or liquids
(Saranex)
3. Paper towels - to help clean up liquids and assist with decontamination
4. Plastic garbage bags - to contain spent spill cleanup materials
5. Noncombustible absorbent material - to clean up spills of liquids
6. Face shields - to provide full-face splash protection
7. Plastic sheeting - to control evaporation of volatile chemicals, cover
contaminated surfaces, build decontamination areas, and protect clean
surfaces from contamination

c. Other spill response equipment and materials are available in other locations at the
facility to respond to spills of petroleum and chemicals. Emergency Spill Kits are provided
at locations throughout the facility for use by all emp loyees and contractors.
9.4 EMERGENCY SPILL RESPONSE ACTIONS
9.4.1 Emergency Spill Response Actions
a. In the event of a spill of hazardous waste or hazardous material, the hazardous spill
response and clean-up measures described in Thatcher’s Emergency Response Program
will be followed.

b. As a general rule, Thatcher employees only respond to very minor incidents if trained and
safe to do so, such as small incidental releases where the substance can be controlled at
the time of the release by employees in the immediate release area.

1. For small spills involving a container, the employees may be instructed to either
transfer the material to an approved container or overpack the container.

2. The HazMat Emergency Response Team will respond to incidents involving spills of
hazardous waste, fires, explosions, or any other incidents involving hazardous
waste.

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3. The first member of the HazMat Emergency Response Team to arrive at the scene
of an incident, involving hazardous waste will communicate with security and will
help restrict access to the area of the incident until a more senior member of the
HazMat Emergency Response Team or one of the emergency coordinators
arrives at the scene of the incident.

9.4.2 Internal Emergency Reporting
a. The Thatcher employee that first notices the spill or discharge shall notify the supervisor or
manager.
b. The Thatcher employee, supervisor, and/or manager shall:
1. Page using the overhead phone system—three random phone keys will be
pushed on the air to bring attention to the speaker. The person paging may state
the chemical involved, type of release, the location, and the severity or other
details of the incident.
a) The Supervisor may designate a representative to speak on the paging
system if the emergency requires his/her immediate attention.

2. For Laboratory and Office Staff Workers, press the “PAGE” button, press “00” for
the entire plant, then three random phone keys on the air to bring attention to
the speaker.

c. The following information must be provided to the Emergency Coordinator:
1. Name and location of the employee notifying the Emergency Coordinator,
2. The nature of the incident,
3. Any actions being taken by persons already on the scene of the incident, and
4. Any recommendations for further actions.
9.5 EMERGENCY FIRE RESPONSE ACTIONS
a. Personnel encountering a fire in their immediate workplace should:

1. Walk, do not run, to the nearest exit away from the fire.
2. Stay low and crawl in areas filled with smoke; and
3. Use handrails on stairways.
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b. In the event of a fire involving hazardous waste, the following response actions shall be
followed by the person discovering the fire:

1. Call for the response of all emergency personnel needed, and request radio
silence when necessary.
2. Notify other workers in the area and sound the fire alarm.
3. Notify the supervisor or manager by radio or phone and describe the location of
the fire and state your name.
4. Direct others away from the fire, and report to the posted evacuation assembly
point when necessary.
5. Confine the fire - close all doors and windows.
6. If the fire is small, and the person has had fire response training, an appropriate
fire extinguisher should be used only if the fire can be extinguished safely, and
there is an open exit available to escape if necessary.
7. If the fire is too large, evacuate the area and allow the Emergency Response
Team to respond.

c. Persons who find themselves in an area involved in a fire should aid emergency response
crews by:

1. Providing unobstructed access to and from the scene for emergency personnel
and equipment.
2. Providing any additional support requested by emergency personnel.
3. Shut-down equipment near the emergency site.
4. Account for personnel.
5. Remain calm and keep talking and noise to a minimum.
6. Listen for evacuation instructions.
7. Report to a safe area away from the fire and remain there for instructions; and
8. Do not return to the fire area until directed by personnel in charge.

d. The HazMat Emergency Response Team Incident Commander will coordinate the on-site
and/or off-site response to the fire according to Thatcher procedures.

e. The Supervisor will notify the Emergency Coordinator to assist with the fire response,
should hazardous substances be involved.

f. The Emergency Coordinator will determine if the fire involved hazardous waste or
hazardous materials that could release hazardous waste constituents. If so, the
procedures in this Contingency Plan will be followed.
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9.6 EMERGENCY EXPLOSION RESPONSE ACTIONS
a. The fire response actions of Section 9.5 of this document should be followed in the event
of an explosion.

b. If an explosion has not occurred, but an emergency incident has the potential to
develop into an explosion, the person in charge of responding to the incident shall:

1. Evacuate all employees to a safe location; and
2. Re-evaluate the necessary response actions considering the potential risk to the
health and safety of personnel and to facilities.
9.7 EVACUATION PLANS
Evacuation plans (EHS 13F11) have been developed for each building at the facility. When
instructed, personnel should walk, not run, to the nearest safe exit in their work area and
assemble at the posted designated evacuation assembly point as indicated in the evacuation
plans, unless otherwise instructed.
Emergency evacuation escape route plans are posted in key areas throughout the buildings
(usually near exit doors). All employees have been trained concerning these plans and should
also be familiar with the evacuation plans for the other buildings within the company. Only
HazMat team members are permitted to respond to emergencies of any nature, all other
employees evacuate to their designated evacuation locations as specified in the SOP.
9.8 EMERGENCY REPORTING PROCEDURES
To ensure that emergencies involving hazardous waste are properly handled and reported, the
following emergency reporting procedures shall be followed.
a. Persons who discover a release or potential release of hazardous waste should
immediately notify their immediate Supervisor or Manager. The immediate Supervisor or
Manager will immediately notify the Emergency Coordinator on-site or on call and
provide the following information:

1. Name and phone number of individual reporting.
2. Time and date of spill.
3. Location of spill - as specific as possible.
4. Description of the material and the amount of material spilled (if known).
5. Cause of spill.
6. Emergency action taken to minimize the threat to human health and the
environment
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7. Note if the released material is confined within property boundaries a nd/or if it
has reached a waterway, drainage, or pond.
8. Note the number of human and/or animal injuries/fatalities.

b. The Emergency Coordinator will determine if there has been a reportable incident, spill,
or discharge and complete applicable reporting.

1. In general, a reportable spill includes:

a) Hazardous chemicals equal to or in excess of the Federal “Reportable
Quantity” (RQ) under CERCLA and/or the Extremel y Hazardous
Substances (EHS) RQ under EPCRA.

1) CERCLA RQs are determined from 40 CFR 302.4 Appendix B
CERCLA RQ list.
2) EPCRA RQs are determined from 40 CFR Part 355 Appendix A.

b) One kilogram (2.2 lbs.) of acutely toxic hazardous waste (“P”-listed or “F”-
listed with hazard code “H”) or 100 kilograms (220 lbs.) of hazardous waste
or any non-permitted release that could threaten human health or the
environment must be reported to UDEQ.

Only Thatcher’s Plant Manager, Technical Director, Safety Manager or Emergency
Coordinator will assign a person to verbally notify the appropriate agencies, if any of the
above reporting requirements are met. If any of the above reporting requirements are
met, go to Number 2 below and follow the reporting requirements.
2. Reportable incident verbal notification:

a) Immediate notification requirements for reportable release that equal s or
exceeds the CERCLA RQ and/or EPCRA EHS RQ:

1) Facilities must immediately notify the National Response Center
(NRC), UDEQ, Salt Lake City Fire Department, which acts as the
Local Emergency Planning Committee (LEPC), and Utah
Department of Public Safety below.

b) One kilogram (2.2 lbs.) of acutely toxic hazardous waste (“P”-listed or “F”-
listed with hazard code “H”) or 100 kilograms (220 lbs.) of hazardous waste
or any non-permitted release that could threaten human health or the
environment must be reported to UDEQ:

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1) Facilities must as soon as possible, but not later than the end of the
first working day after the release, notify the UDEQ and provide
immediate notification to the Salt Lake City Fire Department
(LEPC) below.

3. Dial “8” to get an outside telephone line from onsite.

a) National Response Center 1-800-424-8802
b) Utah Department of Environmental Quality 1-801-536-4123
The State Emergency Response Commission (SERC)
and other UDEQ agencies are notified by UDEQ.
c) Salt Lake City Fire Department (LEPC) Emergency 911
d) Salt Lake City Fire Department (LEPC) Non-Emergency 1-801-596-5254
e) Utah Department of Public Safety 1-801-538-3702
4. The Emergency Coordinator shall provide the following information when
reporting a spill/release:

a) Company’s Name, phone number, address of the facility and hazardous
waste generator Identification Number: UTD041307356.
b) Name, title, and phone number of individual reporting.
c) Time, date, and type of incident (e.g., release, fire).
d) Name and quantity of materials involved.
e) Location of spill - as specific as possible including township and range,
section, and county in addition to the specific location on the site.
f) Description of the material and the amount of material spilled.
g) Cause of spill.
h) Emergency action taken to minimize the threat to human health and the
environment.
i) Description of any injuries or fatalities.
j) Evacuations necessary.
k) Environmental media the material was released to, if any; and
l) Clean up procedures taken.
5. Within 15 days of the spill, a written report will be prepared and submitted by the
emergency coordinator to the Division of Solid and Hazardous Waste, Utah State
Department of Environmental Quality that includes the above information. In
addition, the report must provide information on:

a) The extent of injuries, if any.
b) An assessment of actual or potential hazards to human health or the
environment, where this is applicable; and
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c) The estimated quantity and disposition of recovered material that resulted
from the incident.

6. The Emergency Coordinator shall determine if the incident requires the assistance
of an experienced hazardous waste spill response contractor.
9.9 MANAGEMENT OF WASTES PRODUCED DURING AN INCIDENT
RESPONSE
The wastes produced in a cleanup or response to an emergency incident involving hazardous
wastes or hazardous materials may themselves be hazardous wastes. For example, floor dry
used to absorb a spill of a listed solvent would be a hazardous waste mixture having the same
hazardous waste code as the spilled material. Waste is characterized, classified, and managed
at permitted or approved facilities.
9.10 COORDINATION WITH LOCAL AUTHORITIES
In compliance with federal hazardous waste regulations at 40 CFR 262.256 and 265.52(c), a
copy of the Hazardous Waste Contingency Plan and Hazardous Waste Preparedness and
Prevention Plan and an invitation to visit the facility has been sent to the local entities and
authorities listed in the section below that may be involved in an emergency situation. Thatcher
will coordinate with the following agencies to familiarize agency personnel with the types of
hazardous waste handled in the waste storage areas and the potential need for their services.
Thatcher has coordinated with the following local emergency response agencies to familiarize
them with the potential need for their services in the future to respond to a hazardous waste
incident:
• Salt Lake City Fire Department (LEPC)
• Salt Lake City Police Department
The following medical facilities will be notified of the hazards associated with various emergency
situations at the facilities and will be provided a copy of the Contingency Plan and Hazardous
Waste Preparedness and Prevention Plan.
• Intermountain Medical Center, 5121 Cottonwood St, Murray, UT, 1-801-507-6600
Personnel from the hospital and local ambulance services will be advised of materials handled
at the facility, the likely hazards involved. Safety Data Sheets and other technical references
pertaining to hazardous materials are available from facility for use by hospital personnel.

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The facility has contacted local police, fire, emergency response teams and hospitals and
provided them with copies of or portions of the Thatcher facilities Contingency Plan and
Hazardous Waste Preparedness and Prevention Plan and relevant background information in an
effort to familiarize them with the layout of the facilities, the properties of the hazardous wastes
handled at the facility, the associated hazards, entrances to and roads within the facility,
evacuation assembly areas. These local authorities are invited to visit the facility if they should so
desire. The arrangements with local authorities discussed above include provisions for
designating one authority as the primary emergency authority. If an emergency arises at
Thatcher, which cannot be controlled by plant personnel, the HazMat Emergency Response
Coordinator (HERC) will notify the appropriate authorities.
If a spill of hazardous material or hazardous waste cannot be contained, controlled, and
cleaned up by facility personnel or local authorities, the HazMat Emergency Response
Coordinator will call in a professional cleanup contractor.
Copies of letters sent to the Emergency Response agencies requesting their coordination in
response assistance to emergency situations are in the environmental files.
9.10.1 Emergency Response Agency Waiver
Thatcher has not applied for the waiver described below.
A facility possessing 24-hour response capabilities may seek a waiver from the authority having
jurisdiction (AHJ) over the fire code within the facility's state or locality as far as needing to make
arrangements with the local fire department as well as any other organization necessary to
respond to an emergency, provided that the waiver is documented in the operating record.
9.11 AMENDMENT OF CONTINGENCY PLAN
The Contingency Plan will be reviewed and amended according to the following.
a. Regulations are revised.
b. The plan fails in an emergency.
c. The emergency equipment list changes.
d. The emergency coordinator list changes.
e. The facility changes 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 as follows:
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1. Design or construction.
2. Operation, maintenance, or other circumstances.
9.12 CONTINGENCY PLAN QUICK REFERENCE GUIDE
This Contingency Plan Quick Reference Guide was developed per 40 CFR Part 262.262(b).
9.12.1 Emergency Coordinator Contact List
Emergency coordinator and alternates 7/24-hour emergency telephone number(s) are in
Appendix A.
9.12.2 Emergency Communications
Activate emergency communications to notify all personnel in effected areas if not already
completed.
a. Paging using the overhead phone system—three random phone keys will be pushed on
the air to bring attention to the speaker. The person paging may state the chemical
involved, type of release, the location, and the severity or other details of the incident.

b. The Supervisor may designate a representative to speak on the paging system, if the
emergency requires his/her immediate attention.

c. For Laboratory and Office Staff Workers, press the “PAGE” button, press “00” for the entire
plant, then three random phone keys on the air to bring attention to the speaker.

d. There are not any alarms related to hazardous waste generation or storage on-site.
9.12.3 Hazardous Waste Information
The following hazardous waste information tables include locations, general types/names, and
estimated maximum amount present at any one time.
Table 9.1 - Building 16 Hazardous Waste Information
Hazardous Waste
Descriptions Hazard
Estimated
Maximum
Amount
Location
Generated
Location
Accumulated
Aerosol Aspirator -Ignitable
-TCLP RCRA 8
metals
-TCLP volatiles or
semi-volatiles
55-gallons Building 16 Laboratory 90-
Day Storage
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Table 9.2 - Laboratory Hazardous Waste Information
Hazardous Waste
Descriptions Hazard
Estimated
Maximum
Amount
Location
Generated
Location
Accumulated
Mixed Organic Waste -Ignitable
-TCLP RCRA 8
metals
-TCLP volatiles or
semi-volatiles
55-gallons Laboratory-
Building 17
Laboratory
Satellite
Accumulation
Area

Full containers
are stored in the
Laboratory 90-
Day Storage
Area
Methanol/Acetonitrile -Ignitable 55-gallons Laboratory-
Building 17
Silver Nitrate -Corrosive Alkaline
-Silver
55-gallons Laboratory-
Building 17
Chloroform -Toxic 55-gallons Laboratory-
Building 17
Dilute Heavy Metal
Solutions
-TCLP RCRA 8
metals
55-gallons Laboratory-
Building 17
Hydrazine Waste 55-gallons Laboratory-
Building 17
Expired Analytical
Reagents
-Ignitable
-Corrosive Acid or
Alkaline
-TCLP RCRA 8
metals
-TCLP volatiles or
semi-volatiles
55-gallons Laboratory-
Building 17
Research and
Development
Accumulation
-Ignitable
-Corrosive Acid or
Alkaline
-TCLP RCRA 8
metals
-TCLP volatiles or
semi-volatiles
55-gallons Laboratory-
Building 17

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Table 9.3 - Process North West Storage Area Hazardous Waste Information
Hazardous Waste
Descriptions Hazard Estimated
Maximum Amount
Location
Generated
Location
Accumulated
Process Waste

Category 1 pH <2
or >12.5 (inorganic
or organic.
-Ignitable
-Corrosive Acid or
Alkaline
-TCLP RCRA 8 metals
-TCLP volatiles or semi-
volatiles
200 containers (55
to 275 gallons
each)
Process North West
Storage Area
Process Waste

Category 2: pH: >2
or <12.5
(Inorganic)
-TCLP RCRA 8 metals

400 containers (55
to 275 gallons
each)
Process Waste

Category 3: pH: >2
or <12.5 (Organic)
-Ignitable
-TCLP RCRA 8 metals
-TCLP volatiles or semi-
volatiles
400 containers (55
to 275 gallons
each)
Process Waste

Category 4:
Oxidizer, Peroxide,
Fluoride, Iodine,
Bromine, Chlorine,
Ammonia
(Inorganic or
Organic)
-Ignitable
-Corrosive Acid or
Alkaline
-TCLP RCRA 8 metals
-TCLP volatiles or semi-
volatiles
40 containers (55
to 275 gallons
each)
Process Waste

Category 5: Oil <
or >1000 ppm
Halogenated
Hydrocarbons.
-Ignitable
-TCLP RCRA 8 metals
-TCLP volatiles or semi-
volatiles
10 containers (55
to 275 gallons
each)

9.12.4 Hazardous Waste Exposure
Exposure to these hazardous wastes does not require unique or special treatment by medical
staff.
9.12.5 Facility and Street Maps
A facility map and a street map are included with the following information in Appendix B.

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a. Facility map access routes to:
1. Hazardous waste generation and accumulation locations; and,
2. Fire water supply locations (i.e., fire hydrant and flow rate).
b. Street map in relation to the following to understa nd the best route to the facility and
evacuate citizens and workers:
1. Surrounding businesses.
2. Schools; and,
3. Residential areas
9.12.6 Hazardous Waste Quick Reference Guide Updates
The Hazardous Waste Quick Reference Guide must be updated whenever the contingency
plan is amended. Amended documents must be submitted to the local emergency responders
identified in Section 9.10 Coordination with Local Authorities

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10.0 PERSONNEL TRAINING
10.1 INTRODUCTION
This section on training management details how the facility manages hazardous
materials/wastes, non-hazardous materials/wastes, and universal wastes training requirements
and training courses at the facility. It has been prepared in compliance with the requirements of
the federal hazardous waste regulation found in 40 CFR 262.17(a)(7) / R315-262-17(a)(7) LQG
Personnel Training and 273.16 / R315-273-16 universal waste small quantity handlers training.

The facility has instituted a personnel training program for those individuals whose job
descriptions require they handle or manage hazardous or universal waste(s), or who work at the
90-day hazardous waste storage areas. This training is offered to new hires within six months of
their initial employment at the facility, and annually thereafter to all applicable personnel. The
training summarizes the RCRA and DOT regulations, focusing in detail on areas directly related to
hazardous waste management and spill response measures at the facility. A representative of
the Safety-Health-Environment Department trained in hazardous waste management
procedures directs the training. The type and quantity of training given to each employee is
relevant to the employee’s hazardous waste management tasks commonly part of his/her
employment position. Training may be provided in separate areas as required (i.e., laboratory
waste management).

10.2 HAZARDOUS WASTE MANAGEMENT JOB DESCRIPTIONS
a. Employees’ names, general job titles, and hazardous waste management job
titles/descriptions are found in Appendix C. Supervisors, crew shifter, and/or other names
not listed in Appendix C are part of the facility operating records.

b. The following job descriptions are for the Facility’s employees who share in the
responsibility of managing the hazardous waste or are likely to handle hazardous waste
in an emergency situation at the facility site. The training requirements for these
individuals are also listed. A detailed list consisting of each employee name, job title,
and hazardous waste or hazardous materials job description/training is included in
Appendix C Hazardous Waste Management Personnel Job Titles. Training records are
kept in the Safety-Health-Environment Department Files.

c. As required in 40 CFR 262.17/ R315-262-17, 273.16/ R315-273-16 and/or 49 CFR 172.704,
initial training will include a class overview of RCRA and/or DOT requirements and this
manual. Yearly refresher training will include any changes or updates to this manual,
improvements to the RCRA management system, and a review of RCRA and/or DOT
requirements. Safety-Health-Environment Department personnel will predominantly
teach the initial training and yearly refresher courses.

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d. Operators will also receive training regarding response as described in the Spill
Prevention, Control, and Countermeasures Plan, Emergency Response Plan, Hazardous
Waste Contingency Plan, Emergency Preparedness and Prevention Plan and/or
Emergency responder training, in accordance with applicable OSHA regulations,
sufficient to enable the person to direct the evacuation, and/or appropriate response
resulting from an environmental emergency incident.

e. Required requisite skills, education, and qualifications required include classroom and on-
the-job training as follows:

1. 90-day Hazardous Waste Storage Areas Operator – 90-day storage hazardous
waste storage areas shipper, DOT Hazardous Materials Operator, and
DOT/RCRA/Emergency Response training;
2. Hazardous Waste Operator – Shipper, DOT Hazardous Materials Operator,
DOT/RCRA/Emergency Response training; and,
3. Satellite Accumulation and Universal Waste Operator – RCRA/Emergency
Response Training.
10.2.1 90-day Hazardous Waste Storage Areas Operator
Operators are in charge of ensuring the 90-day hazardous waste storage areas compliance with
this manual, training regulations, and emergency response duties. The operators respond to
emergency incidents according to the level of training received. The 90-day Hazardous Waste
Operator must ensure that the 90-day hazardous waste storage areas drum storage or bulk
storage containers are shipped off-site within each 90-day period, and that weekly inspections
are completed and documented.
10.2.2 Hazardous Waste Satellite Accumulation Operator
Operators overseeing an area that includes a hazardous waste satellite accumulation container
are responsible for complying with Section 7.0 (Hazardous Waste Satellite and Universal Waste
Accumulation Areas) of this manual [40 CFR 262.15 / R315-262-15] and emergency response
duties. The operators respond to emergency incidents according to the level of training
received.
10.2.3 Hazardous Waste Shipper
Individuals who have shipping responsibilities for hazardous wastes. As required in 49 CFR
172.704, initial training will include a class overview of DOT requirements, this manual, and
emergency response duties. The emergency response trained operators respond to emergency
incidents according to the level of training received.
10.2.4 Universal Waste Operator
Operators overseeing an area that includes a universal waste container are responsible for
complying with section 7.0 (Hazardous Waste Satellite and Universal Waste Accumulation Areas)
of this manual, and emergency response duties. The operators respond to emergency incidents
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according to the level of training received. As required in both 40 CFR 262.17(a)(7) / R315-262-
17(a)(7) and 40 CFR 273.16 / R315-276-16, initial training will include a class overview of the
Universal Waste requirements under RCRA and this manual.

10.3 TRAINING RECORD KEEPING
All hazardous waste training records will be kept for the life of the facility. These records are kept
in the Safety-Health-Environment Department files.

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11.0 WASTE MINIMIZATION GUIDELINES
The facility is committed to preventing or reducing pollution by avoiding unnecessary generation
of wastes and by participating in recycling efforts. The facility has implemented a waste
minimization program that addresses waste minimization efforts and opportunities for used oil,
non-hazardous petroleum related wastes, hazardous materials/wastes, non-hazardous
materials/wastes, universal wastes, and other solid wastes.
Waste minimization is achieved through source reduction and environmentally sound recycling.
Environmentally sound recycling includes use, reuse, or reclamation. The facility has
implemented these techniques to reduce the quantities of wastes. Examples of the facility’s
current waste minimization efforts include the following:
a. Source reduction through efficient and evolving operating practices, solvent substitution,
and inventory control of paints and solvents;
b. Environmentally sound recycling of aluminum, paper, cardboard, solvents, used oil,
antifreeze, lead acid batteries, fire extinguisher powder, scrap metal, e-waste, fuels,
and/or Chlorinated Fluorocarbons (CFCs)/Refrigerants and;
c. Product substitution of materials that may potentially generate a hazardous waste to
products that are environmentally sound, such as the elimination of chlorinated solvents
in all facilities; and,
d. Recycling of Universal Wastes, off site at permitted universal waste handling facilities.
11.1 MANAGEMENT SUPPORT
Minimizing the amount of hazardous waste generated is a crucial component of any effective
waste management program. The facility has an ongoing program of waste minimization.
Facility management will continue to support waste minimization efforts through one or more of
the following methods:
a. Issuing a formal written statement encouraging waste minimization,
b. Setting waste reduction goals,
c. Using preferred alternative products identified by the New Product Review form;
d. Making a commitment to implement waste minimization recommendations,
e. Designating waste minimization coordinator(s),
f. Publishing waste reduction success stories,
g. Implementing and employee incentive program, and/or
h. Training employees to recognize waste reduction opportunities.
11.2 WASTE GENERATION ACCOUNTING
The facility maintains a waste management system to track the types and quantities of wastes
produced as well as the types and amounts of hazardous constituents in wastes, including the
rates and dates they are generated. The data accumulated in this accounting system supports
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the facility's waste reduction efforts by providing information needed to identify waste
minimization opportunities. The waste management system also provides the data required to
describe the facility's waste minimization efforts; and results for LQG Biennial Reporting if required
in the future. A Biennial Report that is required for an LQG by regulation is required to be
submitted to ADEQ by March 1 of each even numbered year.
11.3 ECONOMIC BENEFITS OF WASTE REDUCTION
Reducing the quantity and toxicity of wastes makes good economic sense due to the high cost
of hazardous waste management and disposal. Significant cost savings can include:
• Reduced testing, transportation, and disposal costs,
• Reduced regulatory compliance costs,
• Reduced future liability costs, and
• Increased worker safety.
In many cases, implementation of proper waste management practices can significantly
reduce disposal costs. For example, a 55-gallon drum of waste oil can be recycled for less than
$50. However, if a chlorinated solvent were added to this drum, the waste may be re-classified
as a hazardous waste, increasing the disposal cost to as much as $800.
The facility will periodically determine the true costs associated with waste management and
cleanup, including the costs of regulatory compliance, paperwork and reporting, costs of
materials found in the waste stream, employee exposure and health care, transportation,
treatment, storage, disposal costs, and liability insurance. This will enable the facility to identify
where the greatest waste-reduction cost savings opportunities exist.
11.4 WASTE MINIMIZATION ASSESSMENTS
The facility will periodically conduct waste minimization assessments in order to identify where
materials can be prevented from becoming a waste or where new waste minimization
approaches can be effectively applied to a waste stream. Specific waste minimization
approaches to be considered for application include: source reduction, recycle/reuse, and
treatment. Some waste reduction examples include:
a. Input Changes (raw product substitution) - Example: Use of non-toxic grease instead of
grease containing toxic metals or volatile organic solvents. Also, replacing chlorinated
degreasing solvents with non-chlorinated solvents.

b. Operation Improvements - Examples: Chemical and/or physical property testing to
extend the useful life of a product such as motor oil or antifreeze.

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c. Maintenance Process Changes - Example: Oil or coolant reuse - During maintenance
and repair activities that require oil or coolant removal but not change-out, save the
material for reintroduction.

d. Administrative Controls - Example: Inventory control procedures and policies to ensure
products are used before new products are purchased and that damaged product
containers are properly repackaged and labeled for use.

e. Recycle/Reuse - Example: Recycling of solvents, used oil, antifreeze, lead acid batteries,
fire extinguisher powder, scrap metal, e-waste, fuels, and/or CFCs/Refrigerants.
11.5 TECHNICAL WASTE MINIMIZATION INFORMATION
The facility exchanges technical waste minimization information and success stories with other
company facilities. The facility also seeks out waste reduction information from other
companies, technical publications, trade or professional associations, consultants, universities, or
governmental agencies.
11.6 IMPLEMENTATION OF WASTE REDUCTION APPROACH
The facility strives to implement waste reduction approaches identified by waste minimization
assessments. Implemented waste reduction approaches are periodically evaluated by facility
personnel using one or more of the following criteria:
a. Waste reduction effectiveness,
b. Economic cost including effects on production and product quality,
c. Barriers or obstacles to implementation, and
d. Environmental impact and regulatory requirements.

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Appendix A EMERGENCY CONTACT LIST
Primary Emergency Coordinator Emergency Phone Number
Darren Bauer – VP Safety-Health-Environment
Department
801-888-6047
Alternates
Dave Johnson – Environmental Engineer 775-250-2930
Brandon Lowery – Safety-Health-Environment
Department TECHNICIAN
435-237-7245

APPENDIX B
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Thatcher Solid and Hazardous Waste Management Plan 1

Appendix B CONTINGENCY PLAN MAPS

2
© OpenStreetMap (and) contributors, CC-BY-SA
FOR:FIGURE:
JOB NUMBER:203721586 DRAWN BY:CCL CHECKED BY:JC APPROVED B Y:JC DATE: 5/15/2020
SITE VICINITY
Filepath: C:\Users\cclee\Desktop\7-11 AUTOCAD\_TOPO_.mxd
³2,000 0 2,000 4,0001,000
Feet
No warranty is made by Stantec Consulting Services Inc. as to the accuracy, reliability, or completeness of these data. Original data werecompiled from various sources. This information may not meet National Map Accuracy Standards. This product was developed electronically, and may be updated without notification. Any reproduction may result in a loss of scale and or information.
THATCHER COMPANY, INC.
2000 SOUTH COLORADO BOULEVARD, SUITE 2-300DENVER, COLORADO 80222
PHONE: [phone] FAX: [phone]
Legend
Airport
Commercial Corridor
Manufacturing
Open Space
Public Land
Residential
Transit Stations
SITE LOCATION
APPENDIX C
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Thatcher Solid and Hazardous Waste Management Plan 1

Appendix C HAZARDOUS WASTE MANAGEMENT PERSONNEL
JOB TITLES
General Job Title 1Name Hazardous Waste Management Personnel Job Titles
VP Safety-Health-
Environment
Departmentt
Darren Bauer 90-day Hazardous Waste Storage Areas Operators and/or
Emergency Responders

DOT Hazardous Materials/Wastes Shipper/Operator

Satellite 40 CFR 262. 15 / R315-262.15, Universal Waste40 CFR
273.16 / R315-273-16, and Hazardous Materials and Non-
Hazardous Materials/Wastes Management Training
Environmental
Engineer
Dave Johnson 90-day Hazardous Waste Storage Areas Operators and/or
Emergency Responders

DOT Hazardous Materials/Wastes Shipper/Operator

Satellite 40 CFR 262. 15 / R315-262.15, Universal Waste40 CFR
273.16 / R315-273-16, and Hazardous Materials and Non-
Hazardous Materials/Wastes Management Training
Safety-Health-
Environment
Department
TECHNICIAN
Brandon Lowery 90-day Hazardous Waste Storage Areas Operators and/or
Emergency Responders

DOT Hazardous Materials/Wastes Shipper/Operator

Satellite 40 CFR 262. 15 / R315-262.15, Universal Waste40 CFR
273.16 / R315-273-16, and Hazardous Materials and Non-
Hazardous Materials/Wastes Management Training
Lab Supervisor Management Satellite 40 CFR 262. 15 / R315-262.15, Universal Waste40 CFR
273.16 / R315-273-16, and Hazardous Materials and Non-
Hazardous Materials/Wastes Management Training
Lab Technicians Lab Technicians Satellite 40 CFR 262. 15 / R315-262.15, Universal Waste40 CFR
273.16 / R315-273-16, and Hazardous Materials and Non-
Hazardous Materials/Wastes Management Training
Maintenance Shop Management Satellite 40 CFR 262. 15 / R315-262.15, Universal Waste40 CFR
273.16 / R315-273-16, and Hazardous Materials and Non-
Hazardous Materials/Wastes Management Training
Truck Shop Management Satellite 40 CFR 262. 15 / R315-262.15, Universal Waste40 CFR
273.16 / R315-273-16, and Hazardous Materials and Non-
Hazardous Materials/Wastes Management Training
1Names not listed above are part of the facility operating records.

APPENDIX C
Waste Analysis Plan

4867-8198-7593\1

PHASE 3 WASTE ANALYSIS PLAN

July 2022
Prepared for:
THATCHER COMPANY, INC.
Prepared by:
STANTEC CONSULTING SERVICES INC.
2890 East Cottonwood Parkway, Suite 300
Salt Lake City, UT 84121
Project Number: 203722428

Phase 3 Waste Analysis Plan i

Table of Contents
1 INTRODUCTION ....................................................................................................... 1
2 FIELD SCREENING AND SAMPLING ..................................................................... 1
2.1 Air Monitoring ................................................................................................................................... 1
2.2 Liquid Sampling ............................................................................................................................... 1
2.3 Solid(s) Sampling ............................................................................................................................. 3
2.4 Sample Identification and Custody ................................................................................................ 4
2.5 Field Screening ................................................................................................................................. 4
3 LABORATORY ANALYSIS ...................................................................................... 6
3.1 Material Category Determination .................................................................................................... 8
3.2 OFF-SITE LABORATORIES ............................................................................................................. 9
3.2.1 CTF ............................................................................................................................................. 9
3.2.1.1 CTF Sample Dilution ............................................................................................................. 10
3.2.1.2 CTF QC Procedures .............................................................................................................. 10
3.2.2 ALLIANCE TECHNOLOGIES ................................................................................................... 11
4 CONCLUSION ........................................................................................................ 12

List of Tables
Table 2.1 Sample Bottles for Liquids ........................................................................................................ 2
Table 2.2 Sample Bottles for Solids .......................................................................................................... 3
Table 2.3 Field Screening Methods ........................................................................................................... 4
Table 3.1 Field Screening Data Purpose ................................................................................................... 7
Table 3.2 Potential Waste Categories and Laboratory Analysis ............................................................ 8
Table 3.3 CTF Analytical Methods ............................................................................................................. 9
Table 3.4 CTF PARCCS ............................................................................................................................. 11

Phase 3 Waste Analysis Plan ii

List of Attachments
Attachment 1 Clean Harbors Sampling Procedures
Attachment 2 Chain-of-Custody (COC)
Attachment 3 Field Screening Strip Instructions
Attachment 4 Chemtech-Ford Quality Manual
Attachment 5 Alliance QAPP

PHASE 3 WASTE ANALYSIS PLAN
Introduction
Phase 3 Waste Analysis Plan 1
4867-8198-7593\1
1 Introduction
This Phase 3 Waste Analysis Plan (P3WAP) has been prepared in accordance with Stipulation and
Consent Order number 2102006. This P3WAP details the procedures for field screening, sampling, and
laboratory analysis of Phase 3 materials at the Thatcher Company, Inc. (Thatcher) facility located at 1905
West Fortune Road, Salt Lake City, Utah (the Facility). This P3WAP will be used to characterize unknown
materials at the facility for off-site disposal.
2 Field Screening and Sampling
Prior to beginning Phases 1 and 2 of the Waste Inventory and Characterization Process (WICP) as
described in the WICP plan, Thatcher’s project team evaluated known chemicals which may be present at
each building based upon the raw materials and products used at the facility to manufacture goods for
sale. Known chemicals were used to identify chemicals used and potential exposure hazards to
personnel during the process of characterizing and disposing of unknown material. Based upon the known
chemicals and potential exposure hazards, a field monitoring and screening procedure was developed as
detailed below. Generator knowledge evaluations are detailed in the Phase 3 Material Management Plan
(P3MMP). Generator knowledge will be an important tool for identifying materials that are labeled and
known to the project team. Containers of known material will also be evaluated if the contents display
properties which differ from the Safety Data Sheet (SDS) suggesting that the material has been mixed with
an unknown material.
2.1 Air Monitoring
Air monitoring will be necessary prior to accessing containers with unknown materials in order to evaluate
personnel risks of exposure. While wearing the appropriate PPE, as detailed in a Site Specific Health and
Safety Plan, the technician will monitor valves, caps, and/or a slightly open (i.e., cracked) lid using a four-
gas meter. If readings are observed to be within acceptable limits, the technician will proceed with opening
the container for sampling and will measure the air quality inside the container. If the air measurements
are not within acceptable limits, the technician will allow the container to vent until acceptable air
measurements are obtained. Measurements from inside the container will be tracked on the Thatcher Field
Characterization Sheet and will be used for the sample characterization purposes. The Thatcher Field
Characterization Sheet is included in Appendix E of the P3MMP. Air monitoring measurements will include
oxygen (O2), lower explosive limit (LEL), carbon monoxide (CO), and hydro gen sulfide (H2S), and will be
recorded on a Field Screening Form which is included as an appendix to the P3MMP.
2.2 Liquid Sampling
Liquid and solid material samples will be collected once air monitoring is completed. Liquid samples are
typically collected from the opened container using either a composite liquid waste sampler (coliwasa),
standard drum thief, or a bailer. These sampling tools are preferred because they can collect sample
PHASE 3 WASTE ANALYSIS PLAN
Field Screening and Sampling
Phase 3 Waste Analysis Plan 2
4867-8198-7593\1
volume from the entire column of liquid which is most representative of the container contents. If a coliwasa
or standard drum thief is used, it will be inserted vertically into the container and through the liquid but will
not continue to the bottom of the container. The sample technician using a coliwasa will pull up the stopper,
remove the liquid column, and fill the sample containers (i.e., dispensing the full column into the container).
The sample technician using a standard drum thief will place their glove-protected thumb over the top
opening of the drum thief sealing the opening which will create a vacuum as the drum thief is extracted from
the container. Once removed, a liquid column will remain within the drum thief. Using the thumb to either
hold or release the vacuum, the technician will fill or partially fill containers. These coliwasa or standard
drum thief processes will be repeated until all sample containers have been filled. Bailers will be passed
through the liquid column similar to a coliwasa with the exception that the check ball will seal the bottom
opening of the bailer when the bailer’s downward motion ceases. Bailers can be used to fill containers by
either decanting liquids from the top or the check ball can be depressed to release liquids from the bottom
of the bailer. If the liquid is decanted from the top opening, the technician will use a glove-covered hand to
ensure that the liquid does not escape from the bottom of the bailer as the liquid column is decanted and
the hydraulic pressure is released from the check valve. In cases where small volumes of liquid are being
sampled, a stainless-steel dipper may be used. Decontamination procedures for re-usable sampling
equipment are detailed in the P3MMP.
Laboratory analysis of samples will be determined when field screening and field laboratory analytical data
are available, and the material category can be determined as detailed in P3MMP. Sample bottles for liquids
will be filled to allow for analytical methods (see Table 2.1 below) that are necessary to characterize the
material, including:
Table 2.1 Sample Bottles for Liquids
Analyses Sample Container(s)
Size Container
Type
Preservative
pH 8 Ounce (oz) Plastic None
TCLP RCRA 8 Metals and
UHC Nickel
1 Liter (L)
16 oz
Plastic
Plastic
None
Nitric Acid
Flash Point 16 oz Glass None
TCLP VOAs/Semi-VOAs
and UHC methanol
(nonwastewater)
Three (3) 40 ml vials
1 L
Two (2) 40 ml vials
Glass
Glass
Glass
None
None
None
PHASE 3 WASTE ANALYSIS PLAN
Field Screening and Sampling
Phase 3 Waste Analysis Plan 3
4867-8198-7593\1
UHC Total VOAs
Methanol(wastewater) and
Xylene
Three (3) 40 ml vials
Two (2) 40 ml vials
Glass
Glass
Hydrochloric Acid
None
Total Sulfide or Cyanide If
Detected from Field
Monitoring
8 oz
16 oz
Plastic
Plastic
Sodium Hydroxide and Zinc Acetate
Sodium Hydroxide
A detailed description of Clean Harbors ’ liquid and solid sampling procedures is included as Attachment
1.
2.3 Solid(s) Sampling
Solid(s) samples will be collected using hand shovels, spoons, hand augers, or a bucket. All reusable
equipment will be decontaminated prior to use as described in the P3MMP. Solid(s) sampling tools will be
used to collect solid material from multiple locations within the container. If the solid material appears to
be heterogeneous, the sample bottles will be filled using multiple grab aliquots which are approximately
equivalent to that material’s proportional content of the container. Sample bottles required for solid samples
are included in Table 2.2 below.

Table 2.2 Sample Bottles for Solids
Analyses Sample Container(s)
Size
Container
Type
Preservative
pH 2 oz Glass None
TCLP RCRA 8 Metals and UHC
Nickel 4 oz Glass None
Flash Point 16 oz Glass None
TCLP VOAs/Semi-VOAs and
UHC methanol (nonwastewater) Three (3) 4 oz Glass None
UHC Total VOAs Methanol
(wastewater) and Xylene
Two (2) 2 or 4 oz Glass None
Total Sulfide or Cyanide If
Detected from Field Monitoring 2 or 4 oz Glass None
PHASE 3 WASTE ANALYSIS PLAN
Field Screening and Sampling
Phase 3 Waste Analysis Plan 4
4867-8198-7593\1
2.4 Sample Identification and Custody
The outside of all sample bottles (liquid and solid) will be cleaned to limit the potential for cross
contamination and exposing personnel to contamination. Sample bottles will be labeled with the sample
identification (ID) (e.g., container number), date, and time. The sample ID will match the material container
that it was collected from. Phase 3 sample containers will be numbered as follows Area (A), Area 1 (01),
and container number from that area (001) (e.g., A-01-001). Samples for off-site laboratory analysis will be
recorded on a chain-of-custody (COC), which will document transfer in sample custody. Blank copies of
the COC sheets are included as Attachment 2.
2.5 Field Screening
Material will be collected from each container during sample collection for the purpose of field s creening.
Field screening will be conducted using paper test strips to evaluate the pH and screen for the presence of
iodine, bromine, chlorine, oxidizer, fluoride, hydrogen cyanide, ammonia, peroxide , and halogenated
hydrocarbons in oil. In general, test strips are intended for aqueous solutions and are colorimeter tests.
Field screening of solid material will be performed by dissolving the material in distilled water prior to
screening. In accordance with the manufacturer’s instructions, test strips are placed in a small quantity of
sample, a reagent is added if/as required, the test strips are removed, and the color change in the test
surface is compared to the color chart for that particular measurement. Some of the test strips are semi -
quantitative and some of the test strips indicate that an analyte is either present or not present.
All field screening test vessels will be cleaned and dried according to the manufacturer’s recommendations.
The instructions for the field screening test kits are included in Attachment 3. Details regarding field
screening methods are summarized in the table below:

Table 2.3 Field Screening Methods
Field
Monitoring
Parameters
Type Brand/Model Results Comments
pH(1) Litmus paper MQuant® pH Test
Strips 0-14 pH
Semi-quantitative
0 to 13
Intermediate range
indicators provide a
sensitivity of 0.3–0.5 pH
units and narrow range
strips provide a
sensitivity of 0.2–0.3 pH
units.

PHASE 3 WASTE ANALYSIS PLAN
Field Screening and Sampling
Phase 3 Waste Analysis Plan 5
4867-8198-7593\1
Field
Monitoring
Parameters
Type Brand/Model Results Comments
Iodine,
Bromine,
Chlorine
Litmus paper
Spilfyter Chemical
Classifier Strip Kit -
570001
Present or Not
Present
Oxidizer Litmus paper
Spilfyter Chemical
Classifier Strip Kit -
570001
Present or Not
Present
Four gradations of
present from Strong to
Weak
Fluoride Litmus paper
Spilfyter Chemical
Classifier Strip Kit -
570001
Present or Not
Present
Hydrogen
Cyanide
(HCN) ppm
and Contains
Cyanide
Litmus paper QUANTOFIX®
Cyanid
Semi-quantitative
1 to 30 mg/L
Dispose used test strips
as hazardous waste
Ammonia Litmus paper QUANTOFIX®
Ammonium
Semi-quantitative
10 to 400 mg/L
Dispose used test strips
as hazardous waste
Peroxide Litmus paper QUANTOFIX ®
Peroxide 100
Semi-quantitative
1 to 100 mg/L

Oils
Halogenated
Hydrocarbon
ppm (e.g., oils
(Chlor-
Dtect®))
Chlor-
Dtect®)
CHLOR-DE-TECT
1000 - Dexsil
Semi-quantitative
< 1,000 mg/L or
>1,000 mg/L
Special pre-disposal
instructions. Use
disposal ampule prior to
disposal
mg/L = milligrams per liter
(1) = pH is confirmed by laboratory analyses.
PHASE 3 WASTE ANALYSIS PLAN
Laboratory Analysis
Phase 3 Waste Analysis Plan 6
4867-8198-7593\1
The results of field screening are recorded on a unique field screening form for each container, and PDF
copies are loaded to the project SharePoint Site. A copy of the field screening form is included in Appendix
H of the P3MMP.
3 Laboratory Analysis
Field screening data will be used to determine the waste category (see Section 3.1 below) and the potential
health and safety risks for field personnel. The table below details if the field screening results are used for
health and safety or characterization purposes and if a positive screening result will necessitate laboratory
analysis:

PHASE 3 WASTE ANALYSIS PLAN
Laboratory Analysis
Phase 3 Waste Analysis Plan 7
4867-8198-7593\1
Table 3.1 Field Screening Data Purpose
Field Screening Parameters Health and
Safety
Characterization
and Disposal
Additional
Laboratory
Analyses Required
pH Yes Yes Confirmation
Iodine, Bromine, Chlorine Yes No No
Oxidizer Yes Yes Yes
Fluoride Yes Yes No
Volatile Organic Compounds (VOCs),
and Semi-Volatile Organic Compounds
(SVOCs) parts per million (ppm)
and,
lower explosive limit (LEL) %(2)
Yes Yes
TCLP volatile
organic analysis
(VOA), semi-volatile
organic analysis
SVOA, and Flash
Point (1)
Hydrogen Cyanide (HCN) ppm and
Contains Cyanide Yes Yes Confirmation (1)
Hydrogen Sulfide (H2S) % and
Contains Sulfide Yes Yes Confirmation (1)
Ammonia Yes Yes No
Peroxide Yes Yes Yes
Oils Halogenated Hydrocarbon ppm
(e.g., oils (Chlor-Dtect®))

Yes Yes
If >1,000 ppm then:
TCLP VOAs and
Semi-VOAs (1)
(1) If deemed necessary based upon results of field screening and/or on-site lab analyses
(2) LEL measurement obtained from air monitoring

PHASE 3 WASTE ANALYSIS PLAN
Laboratory Analysis
Phase 3 Waste Analysis Plan 8
4867-8198-7593\1
3.1 Material Category Determination
Container tracking and disposal spreadsheets (CTDS) used during Phases 1 and 2 of this project have
been updated to determine the waste category each material container is representative of, and the off-site
additional laboratory analysis necessary to characterize the material. The results of field screening are
entered into the CTDS. Additionally, all samples are initially analyzed by an off-site laboratory for pH which
is also entered into the CTDS. Based upon this data, algorithms within the CTDS automatically assign a
waste category for the material which is used to determine additional laboratory analysis required to
characterize and profile the waste. This same method will be used with the addition of Land Disposal
Restriction (LDR), 40 CFR Part 268.48/UAC R315 268-48 Universal Treatment Standard (UTS), Underlying
Hazardous Constituents (UHC). A flow diagram illustrating the material characterization process is included
as in the P3MMP Appendix J. Additional details regarding the waste characterization process and the CTDS
are detailed in the P3MMP. Potential waste categories and additional analysis include:

Table 3.2 Potential Waste Categories and Laboratory Analysis
Category Analyses1, 2, or 3 Comments
Category 1 pH: <2 or >12.5
(Corrosives
1
Category 2 pH: >2 and <12.5 1
Category 3 Oxidizer, Peroxide,
Fluoride, Iodine, Bromine,
Chlorine, Ammonia
1 and/or 2
Category 4: Oil < or >10003
ppm Halogenated
Hydrocarbons.
3 < 1000 ppm Halogenated Hydrocarbons is managed as
used oil.
11. pH, 2. TCLP RCRA 8 Metals and UHC Nickel, 3. Flash Point, 4. TCLP VOAs/Semi-VOAs and UHC methanol
(nonwastewater), 5. UHC Total VOAs Methanol (wastewater) and Xylene, 6. Total sulfide or cyanide if detected from
field monitoring Yes (Y) or No (N)
2If oxidizers are detected by field screening, oxidizer speciation will be performed by Alliance Technologies (see below).
If ammonia is detected by field screening, Chemtech-Ford (CTF) will analyze the material for ammonia and nitrate
concentrations.
3>1,000 ppm Halogenated Hydrocarbons: 1. TCLP RCRA 8 Metals and UHC Nickel, 2. Flash Point, 3. TCLP
VOAs/Semi-VOAs and UHC methanol (nonwastewater), 4. UHC Total VOAs Methanol (wastewater) and Xylene.
PHASE 3 WASTE ANALYSIS PLAN
Laboratory Analysis
Phase 3 Waste Analysis Plan 9
4867-8198-7593\1
3.2 OFF-SITE LABORATORIES
Thatcher proposes to use off-site laboratories CTF, located in Salt Lake City, Utah and Alliance
Technologies located in Monmouth, New Jersey. These laboratories were used to perform analytical
services for Phases 1 and 2 of the project and continued use will ensure continuity.
3.2.1 CTF
For each material container, a full set of sample bottles will be transferred from Thatcher to CTF. Enough
sample containers will be submitted per material container to provide sufficient sample volume to perform
all of the potential analytical methods for the above categories. Upon receipt of the samples, CTF will
perform laboratory analysis of pH and will subsequently update the CTDS. Once the CTDS is updated with
field data collected by Clean Harbors and CTF analysis of pH, the project will have the data required to
determine which additional off-site analyses are required to characterize the material. CTF will determine
the additional laboratory analysis required to characterize the material based upon the category assigned
to the material as detailed in Section 3.2 (above) and as summarized in the material characterization flow
chart included in the P3MMP Appendix J.
Proposed analytical methods to be provided by CTF are summarized below:
Table 3.3 CTF Analytical Methods
Analyte Analyses Method (Includes sample
preparation and cleanup)
pH SW-846 9045D
Flash Point SW-846-1010A
TCLP RCRA 8 Metals and UHC Metal Nickel SW-846 1311/3005B/6020B/7470A
TCLP Volatiles (VOA) and UHC methanol
(1nonwastewater),
SW-846 1311/8260D
Methanol SW-846 1311/8015
TCLP Semi-Volatiles (Semi-VOA) SW-846 1311/8270E
Total Volatile UHC Methanol (wastewater) SW-846 8015
Total Volatile UHC Xylene SW-846 8260D
PHASE 3 WASTE ANALYSIS PLAN
Laboratory Analysis
Phase 3 Waste Analysis Plan 10
4867-8198-7593\1
Total Cyanide SM 4500(CN)CE
Total Sulfide SM 4500(S2)D
Ammonia E350.1
Nitrate as N E353.2
SW-846 = US Environmental Protection Agency, Test Methods for Evaluating Solid Waste, Update VII
TCLP = toxicity leaching characteristic procedure
SM = Standard Methods
1Wastewater/Nonwastewater Definition: Wastewater (WW): Wastes that contain less than 1% by weight total
organic carbon (TOC) and less than 1% by weight total suspended solids (TSS).
3.2.1.1 CTF Sample Dilution
CTF informed Thatcher of the following:
• Complex sample matrices (e.g., oils, paints, soaps, alcohols, waxes etc.) necessitate
dilution before VOA/Semi-VOA analyses.
• Dilutions raise the Minimum Reporting Limit (MRL/ Practical Quantitation Limits (PQL))

These types of materials may also damage analyses equipment delaying analyses.

When the MRL is greater than the TCLP VOA/Semi-VOA regulatory level Thatcher assigns the
hazardous waste code (i.e., designates the material hazardous waste).

3.2.1.2 CTF QC Procedures
All of Thatcher’s Phase 3 samples will be submitted to CTF for analysis with Level 3 quality control
which includes reporting of:
• Surrogate recoveries.
• Method blanks 1:20 samples.
• Laboratory control samples1:20.
• Matrix spike and matrix spike duplicates 1:20 samples (Thatcher samples).
Precision, accuracy, representativeness, comparability, completeness, and sensitivity (PARCCS)
parameters are listed in Table 3.4.

PHASE 3 WASTE ANALYSIS PLAN
Laboratory Analysis
Phase 3 Waste Analysis Plan 11
4867-8198-7593\1
Table 3.4 CTF PARCCS
PARCCS Measure Comments
Accuracy: MS/MSD
and LCS/LCSD
70-130% DWMRC default control limits for the PARCC
parameters work for Metals but typical VOC and
SVOC LCS and MS/MSD control limits vary from
compound to compound.
Precision: MS/MSD
and LCS/LCSD
%RSD <25%
Comparability
between data
sets/split samples
The Comparability can be assessed from the
MS/MSD RPDs.
Completeness 100%
Sensitivity Less than the
regulatory or risk
action levels
Complex matrices, as are expected on this project
make it impossible to gather data less than
regulatory levels. When PQLs are greater than
regulatory levels, the Waste Code for those
parameters will be assigned to the Waste Profile.
A copy of the final chain-of-custody will be attached to the laboratory analytical report (Attachment 2). The
latest version of CTF’s Quality Manual is included in Attachment 4 which provides additional QC
procedures.
Data generated during sample analysis is maintained in the Laboratory Information Management System
(LIMS) which is CTF’s database. Both laboratory reports and electronic disk deliverables (EDDs) are
generated directly from the LIMS which ensures no discrepancies between the two report formats. The
EDD for this project will follow a format which matches the CTDS and CTF will populate the CTDS by
copying from the EDD and then pasting the data to the CTDS. CTF will provide an independent review of
all CTDS data entries to minimize errors. Lab reports will be maintained with the project files on the project
SharePoint site.
3.2.2 ALLIANCE TECHNOLOGIES
Samples of category 4 materials which are found to potentially be oxidizers , based on field screening
results, will also be submitted to the Alliance Technologies (Alliance) laboratory. These samples will be
further analyzed for oxidizer-specific analysis intended to speciate the type of oxidizer the material is
composed of. EPA methods for speciating oxidizers are not available so Alliance will use proprietary
PHASE 3 WASTE ANALYSIS PLAN
Conclusion
Phase 3 Waste Analysis Plan 12
4867-8198-7593\1
methods. All samples analyzed for oxidizer speciation will include analysis of active oxygen (AO)
concentration through titration methods.
Samples will also be evaluated for their elemental composition which will be used to assist with the
speciation of the type of oxidizer that is present. Solid samples will be analyzed for the presence of
elemental ions using inductively coupled plasma optical emission spectroscopy which reports results in
units of milligrams per kilogram. Liquid samples will be evaluated for elemental ions using energy
dispersive x-ray spectroscopy, x-ray diffraction. A copy of Alliance’s QAPP is included as Attachment 5.
4 Conclusion
This P3WAP details the procedures for field screening, sampling and laboratory analysis of Phase
3 materials at the Thatcher Facility. If material characterization procedures deviate from the processes
described in this WAP, the DWMRC will be informed of the new procedure and the reason for the variance.
Variances may be necessary in instances where an unanticipated material category is encountered.
PHASE 3 WASTE ANALYSIS PLAN
Phase 3 Waste Analysis Plan
4867-8198-7593\1

Attachment 1
Clean Harbors Sampling Procedures

SAMPLING PROCEDURES

COLLECTION EQUIPMENT
A variety of equipment should be available from a secure storage site for use by the CHES FS
PERSONNEL, as suggested below. Much of the equipment should be of the disposable type to minimize
cleaning, for QA and safety reasons. Additional items may be added as needed.
Solids Collection. Items for collecting samples of solids:
• Hand Shovels – Steel, stainless steel & plastic
• Stainless Steel / Plastic - Scoop / Spoon
• Hand Auger
• Stainless Steel / Plastic – Pan / Bucket

Liquid Collection. Items for collecting samples of liquids:
• Sample Rods and Contaminated Liquid Waste Samplers (Coliwasa) - disposable plastic
• Pipettes and Droppers - disposable plastic
• Bailers - disposable plastic and Teflon
• Stainless Steel or Polypropylene Dipper
Sample Jars and Containers:
An assortment should be readily available. To eliminate possible contamination or reaction of future
samples, new sample containers should be used each time, and each should be used only once. New
containers may be used out-of-box for information and disposal sampling activities. Glass containers
should have Plastic or Teflon-lined lids. Recommended sample containers to secure include:
At each container, the CHES FS team will perform various field tests and gather all the bottles needed to
support Stantec FTIR and AWAL.
• Solids / Soils: four 4oz jars plus one tall 16 oz jar
• Liquid/Part Liquid: one 4oz jar, one 250 mL plastic, one 16 oz tall glass, one 1L plastic, one 1L
amber, three unpreserved VOC vials.

SAMPLING PROCEDURES
This section describes how to collect various types of samples, CHES may alter these procedures, as
appropriate, on a case-by-case basis.
• Consult (SEE ATTACHED) JHA for KNOWN and UNKNOWN Sampling steps and Safety Procedures.
• Before commencing collection of samples, thoroughly evaluate the site Pre-sampling staging
area, sampling area and disposal staging area. Checking for any leakers, labels that may be
peeling off containers and to develop the sampling plan for the day’s activities.
SAMPLING PROCEDURES

SAMPLING PROCEDURES (Cont.)

• Record pertinent observations in Supervisor / Foreman field notes. Include a sketch, when
appropriate.
• Prepare all sampling equipment and sample containers properly prior to staging containers in
the Sampling / Repack Secondary containment. If possibly sample in the staging area and
following the day’s sampling plan discussed during the Safety Tail gate meeting at the beginning
of the shift following the pre-work inspection.
• Have absorbents handy to control spills.
• Place containers for receiving samples on a flat, stable surface.
• Collect samples and securely close containers as quickly as feasible.
• Where possible, record field observations at a safe on-site location rather than from the
sampling point itself.
• Due to potentially hazardous samples, be sure to clean the outside of the sampling containers
prior to packaging them for transportation.
• Label all sample containers with the date, time, sample ID and collector's initials that will match
the COC.
• Complete all chain-of-custody documents and record information in the field notes (JOB
STATEMENT DAILY).
• Sampling equipment that is reused should be decontaminated between samples. High or Low
pH sampling devices to be reused MUST only be reused on like pH or chemical compounds.

Drum or Container Sampling
1. Approach and open the drum or container only if it is possible to do so safely. Prior to opening the
container use a 4/5 gas PID meter to monitor the valve, lid, caps, etc… if all readings are safe, proceed
with opening the container for sampling, once open use 4/5 gas PID to get reading of the contents of the
drum and document on the Thatcher Field Characterization Sheet.
KNOWN CHEMICAL (PPE):
If the Container is a Known chemical but still requires sampling, review the SDS for Hazards and Proper
PPE (Suggested PPE QC Tyvek Suits, FFAPR with GME P100 cartridges, Nitrile Inner Gloves, Neoprene
Outer Gloves, Steel Toe Chemical Boots ALL Seams fully Taped Up.
UNKNOWN CHEMICAL (PPE):
If the Container is an Unknown chemical Minimum Suggested PPE SL Tyvek Suits, Full Face Suppled Air
Mask with SAR Bottle or SCBA, Nitrile Inner Gloves, Neoprene Outer Gloves, Steel Toe Chemical Boots
ALL Seams fully Taped Up.
SAMPLING PROCEDURES

Drum or Container Sampling (Cont.)
2. Select the sample container that is appropriate for the type of sample you will be obtaining. If Liquid
use one 4oz jar, one 250 mL plastic, one 16 oz tall glass, one 1L plastic, one 1L amber, three unpreserved
VOC vials, Volatile Organic Compounds (VOCs) are to be a parameter, use (3) three unpreserved VOC
vials, especially if the material is aqueous or of other nature that would allow easy volatilization. If the
material is VOC Solids or contaminated soil, use an four 4oz jars plus one tall 16 oz jar with a Teflon-lined
cap or Plastic Lid.
3. Select the appropriate sample rod or coliwasa for the chemical to be sampled. Slowly insert a sample
rod or coliwasa into the drum / container. Go to the bottom of the drum in order to obtain a
representative sample of all the layers that may be present.
4. If viscous materials are encountered, be careful about the possible breaking of the sampling Rod,
More than one attempt may be needed to retrieve a sample of all layers.
5. Using a gloved hand, cap the end of the rod with a thumb; then quickly withdraw the rod from the
drum.
6. Place the bottom end of the rod into a sample container and slowly release the thumb control to
allow the material in the sample rod to flow smoothly into the sample container. Put the sample
container nearby or atop the drum to lessen the chance of spillage.
7. Repeat the procedure until the desired amount of sample has been obtained. If VOCs are a
parameter, fill the sample container completely to the top to minimize volatilization of the sample.
8. Place the rod back into the Drum / Container momentarily and close the sample container
immediately.
9. Dispose of the rod,
• If acceptable to the disposal facility, break the rod and leave it in the drum;

Or

• Package it with other debris from the site, such as used PPE;
*** Bag PPE and sampling devices and place into a designated Drum, Flex Bin (Cubic Yard Box) or Roll
Off Box for Proper disposal. ***
10. Close the Drum / Container.
11. Label the sample container and the drum / container in a manner that allows them to be referenced
to each other. (i.e. Date, Time, Sample ID#) This is to be written with a Pint Marker on the TOP and Side
of each Drum / Container, also Place a Hazardous waste label on the Drum / Container as “PENDING
ANALYSIS” and a On Test Sticker Placed on the Drum / Container.
SAMPLING PROCEDURES

Drum or Container Sampling (Cont.)
12. Place the sample container in a shipping container (e.g., a cooler) for transportation along with a
COC Chain Of Custody.
13. Repeat this procedure for each drum / container to be sampled.

OTHER SAMPLING CONSIDERATIONS
VOC Vials
Samples that are to be tested for VOCs are to be collected in VOC vials to minimize loss of volatile
compounds. This is especially true with aqueous samples or other materials that may allow for easy loss
of VOCs.
To properly fill a VOC vial:
• The vial should be completely filled to prevent any volatilization.
• Extreme caution must be taken when filling the vial to avoid agitation or turbulence that may allow the
loss of VOCs.
• Gently pour the sample down the side of the vial to fill.
• Invert the vial and tap it gently to look for air bubbles. If bubbles are observed, repeat the procedure.
NOTE: If the material to be sampled has significant vapor pressure, such as a concentrated solvent, a
VOC vial is not recommended for use. Remember to only fill the sample container to approximately 90%
full.

Cooling
The most common preservative measure for emergency response sampling is to cool the samples with
ice packs or cold packs.
• Never use ice to cool materials that are known or suspected to be water reactive.
• Whenever possible, dilute aqueous samples should be cooled, especially in preparation for low- or
medium- level organic analysis and low-level inorganic analysis.
• VOC vials of dilute aqueous samples should also contain an appropriate preservative.
• All cyanide samples must be shipped on ice.

SAMPLING PROCEDURES

Cooling (Cont.)
• Concentrated waste samples generally do not need to be preserved, but it is nevertheless good
practice to cool them.

Field Testing:
• pH Test (0-14) - pH paper / Strips are used to estimate the pH of aqueous samples (and of water test
mixtures).
• Oxidizer Risk / Test - Spilfyter Chemical Classifier Strip to be used Light – Dark Blue= Present White=
Not Present
• Flouride Risk / Test - Spilfyter Chemical Classifier Strip to be used Yellow= Present Pink= Not Present
• Petroleum Product, Organic Solvent Risk / Test – Dark Blue= Present Light Blue= Not Present
• Iodine, Brome, Chlorine Risk – Violet= Present Peach= Not Present
• Peroxide Risk / Test – Quantofix (91312) Test Strip 1-100 mg/L H2O2
• Cyanide Risk / Test – Quantofix Vile / Strip (91318) Test Kit 1-30 mg/L CN
• Ammonium Risk / Test – Quantofix Vile / Strip (91315) Test Kit 10-400 mg/L NH4
• 4 / 5 Gas Meter - ALTAIR® 5X Multigas Detector (O2, CO, H2S, LEL) PID Varies on Meter we assign
(VOC, CN, SO2)

Lab Analysis – AWAL - American West Analytical Laboratories:
• pH (ALL SAMPLES)
• Cat 1 Corr Inorg: TCLP Dlist Metals
• Cat 1 Corr Org: Flash, TCLP Dlist (Met, SVOC, VOC)
• Cat 2 non Corr Inorg TCLP Dlist Metals
• Cat 3 non Corr Org: Flash, TCLP( Met, SVOC, VOC)
• Cat 4 Oxdz Etc Org: Flash, TCLP (Met, SVOC, VOC)
• Cat 4 Oxdizer Etc. Inorg: TCLP Dlist Metals
• Cat 5 Halo HC Flash, TCLP Dlist (Met, SVOC, VOC)
• Cyanide
• Sulfide

SAMPLING PROCEDURES

Cleaning Procedures
Clean Harbors normally acquires sample containers as needed from a contract laboratory that pre-
cleans them. All cleaning should be done outdoors in a well-ventilated area with in our containment
work area, using Level D protection at a minimum. After cleaning an item, handle and store it in a
manner that prevents contamination. Items should be wrapped in new aluminum foil or in a new
sealable plastic bag (i.e. Drum, bucket poly liner taped.
Glass Items
1. Wash with detergent (i.e. Dawn dish soap) and rinse with tap water.
2. Rinse with tap water.
3. Air or Rag dry
4. Package to prevent contamination.
Stainless Steel Equipment
1. Wash with detergent (i.e. Dawn dish soap) and rinse with tap water.
2. Rinse with tap water.
3. Air or Rag dry
4. Package to prevent contamination.
Plastic or Teflon
1. Wash with detergent (i.e. Dawn dish soap) and rinse with tap water.
2. Rinse with tap water.
3. Air or Rag dry
4. Package to prevent contamination.
Note: Plastic pipettes or droppers should not be cleaned due to the difficulty of cleaning and drying
them. Use only as new in box.
Soil or Sludge Sampling:
The type of soil / sludge sampling CHES will normally need to obtain is a surface grab sample at a spill
site, a composite sample of a soil pile, or confirmation sampling in an excavation. (rarely need to obtain
deep soil corings; so that aspect will not be discussed.)
1. Sample container with a sufficiently wide mouth to facilitate filling. It must be made of glass and have
a Teflon or aluminum-foil seal.
2. Use a clean Plastic / Teflon, stainless-steel scoop, spoon, or auger to gather the desired sample.
SAMPLING PROCEDURES

Soil or Sludge Sampling Cont.:
3. If the area is large or not visibly homogeneous, composite several samples within the contaminated
area.
4. The sample should be as free as possible of twigs, rocks, or other debris.
5. Sludges should be allowed to settle and liquid rise to the top to be strip test if needed a small amount
of distilled water will be added and mixed into get a enough liquid produced to conduct the onsite strip
testing.
5. If VOCs are intended to be a parameter, it is important to minimize their volatilization. Avoid
unnecessarily agitating or disturbing the soil sample. To minimize headspace volatilization, fill the
sample container as completely as possible.
6. Close, seal, and label the sample container.
7. Place it in a shipping container for transportation. Ice is not generally required for soil samples, but ice
may be used at the discretion of the sampler. However, to preserve their integrity all cyanide and VOC
samples must be cooled.

Composite Solid Sampling:
The aim of this procedure is to composite random samples of solids (e.g., soil, debris, hazardous
materials, scale, powder or fluff) drawn from containers that may or may have NOT been previously
liquid.
1. Survey the container.
2. Sample container with a sufficiently wide mouth to facilitate filling. It must be made of glass and have
a Teflon or aluminum-foil seal.
3. Use a clean Plastic / Teflon, stainless-steel scoop, spoon, or auger to gather the desired sample.
4. Solids should be put into a small test container (Glass or Plastic), a small amount of distilled water will
be added and mixed into get enough liquid produced to conduct the onsite strip testing.
5. The field-testing results will be Noted on the Field Characterization Sheet.
6. Pull sample and pack into sampling containers with NO head space, label and place the containers in
ice chest for lab analysis, add samples container count and sample ID# to the COC – Chain of Custody.

SAMPLING PROCEDURES

Container Management (Staging, repacking, over packing):

1. Inspect container (POLY Containers) for UN rating and expiration dates. Like all plastic packages, their
UN approval expires after 5 years so the date of manufacture is important to check. Note that in the
case of Nitric acid (>55%) and Hydrofluoric acid (>75%) the approval only lasts 2 years
Inspect Container (STEEL DRUMS): It is important to know that once a certified UN steel drum is
manufactured, it can be invalidated, but it never expires! What is critical is that the certification test
report is valid when the drums are manufactured. Though certification on the steel drum does not
expire, it can be deemed noncompliant if the components used in the drum are not as those specified in
the Closure Instructions from the original steel drum manufacturer, or the most recent re-manufacturer.

ALL CONTAINERS: Steel Drums, Poly Drums and Totes need to be inspected for expiration dates
(EXPIRED), dents, dings, gouges, cracking, rusting, missing seals, caps or bungs will require the contents
to be Repacked or Over Packed.
Dirty exterior of a container will require to be Cleaned, repacked or over packed.

OVER DRUMS:
Overdrums or Salvage Drums are used to contain drums that for various reasons are unsuitable to move.
This can include drums that are out of date, leaking or in bad condition (dented, rusted etc).
IBC’S
IBCs (Intermediate Bulk Containers) are a larger scale alternative to drums. They are typically used for
customers who produce large quantities of a waste stream.
Composite IBC’s are the most commonly used type of IBC. They are a plastic inner receptacle in a metal
cage outer. They fulfil a similar role to tight-head drums and are used for a broad range of waste
streams e.g., solvents and acids.
•The CHES will fills them through the cap at the top and discharges the contents through the drip cap at
the bottom
•IBC’s need to be tested every two and a half years to maintain their UN approval.
•An example of a UN code found on an IBC is shown in Example 2 below.

SAMPLING PROCEDURES

SAMPLING PROCEDURES

CONTAINER STAGING / REPACKING:
1. New set of containers are staged in rows that can be accessed by all sides for sampling and inspection.
2. NO more than 50 containers in the staging area at one given time.
3. Once the container has been inspected, sampled it will have a Hazardous Waste Label and a “On Test
label placed on the container “Pending analysis”
4. The container will have a Sample ID issued which will be unique to any other container.
5. The crew will place on a CHES Inventory form weather it is to be shipped or if it is to be Repacked or
Over Packed.

SAMPLING PROCEDURES

CONTAINER STAGING / REPACKING Cont.:
6. The Container will be taken into the Over Pack / Repack Secondary Containment and Repacked or
Over Packed. Most drums will be over packed and Most Totes (IBC’s) will be Repacked. IBC’s that are
Repacked based on the consistency of the material in the tote (i.e. Full Free Flowing liquids will be
pumped or drained into another IBC). (IBC’s that are Approx. ½ full or Less will be repacked into drums,
IBC’s with solids will be repacked into drums and they will retain the Sample ID number assigned to the
Original container, but a “S” will be added to the End for Heavy Sludge or Solids).
7. The repacked container will be updated on the CHES internal inventory sheet as to what size
container / containers and quantity of containers the original Sample ID Number was repacked into.
NOTE: All Repacking operations will be conducted in Level C (Unless the Chemical SDS or Field testing
and Monitoring require upgraded PPE.
8. Once the container is repacked or Over packed it will be staged in the Last section of the containment
Staged for disposal.
9. Once the results are back from the Lab, Stantec will then Assign the Container Sample ID a Waste
Profile number.
10. Once a waste profile number has been assigned to the container or containers the waste will be
scheduled for disposal, a manifest and labels will be printed.
11. The Crew will then Place the labels on the containers based on the Container size & profile number.
12. Inventory will be rechecked and confirmed then a truck will be scheduled to perform the T&D to
remove the waste from the Site.

EMPTY CONTAINER MANAGEMENT:
1. Empty containers from repack operations to be to RCRA empty standard with NO free liquids.
2. Drums and totes to be crushed or cut to minimize void space.
3. Crushed and Cut Drums and Totes to be placed into lined roll off container or containers with
absorbent spread on the bottom.
4. Crushed and Cut Drums and Totes to be disposed of on a Debris waste profile, the bin will be the
same used for PPE, Plastic, Sampling devices, etc…

PHASE 3 WASTE ANALYSIS PLAN
Phase 3 Waste Analysis Plan
4867-8198-7593\1

Attachment 2
Chain-of-Custody

CONTACT:
PROJECT:
PO Number:
INVOICE EMAIL ADDRESS:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Bottle type
Lot #
QC levels definition: QC1: none QC2: Batch QC, random
sample
QC3: 25% surcharge. Narrative plus Batch QC, your sample
selected
QC4: 40% surcharge. Add raw data
COMPANY:
CHAIN OF CUSTODY - SAMPLE SUBMITTAL FORM
* Expedited turnaround subject
to additional charge
UPS
HP
C
Headspace Present (VOC)
PHONE #:
ADDRESS:
Sample condition
CITY/STATE/ZIP:
EMAIL:
TESTS REQUESTED
Special Instructions:
Received by: [signature]
Customer Courier
Sampled by: [print]
Correct Containers
Sufficient Sample Volume
TIME
Received on Ice
Payment Terms are net 30 days OAC. 1.5% interest charge per month (18% per annum). Client agress to pay collection costs and attorney's fees.
Sampled by: [signature]
Received by: [signature]
Relinquished by: [signature]
Delivery Method
Date/Time
Date/Time
Date/TimeRelinquished by: [signature]
Relinquished by: [signature]
RUSH Due Date*:
CLIENT SAMPLE INFORMATIONLab Use Only
MATRIX
USPS
Received within Holding Time
Chemtech-Ford Courier
DATE
FedExTemperature Blank
temperature range of 0-6 C° may be rejected.
ON ICE NOT ON ICE Temp (C°):
Samples received outside the EPA recommended
E.

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Custody Seal
Container Intact
COC/Labels Agree
Walk-in
Date/Time
Date/Time
LOCATION / IDENTIFICATION
Received by: [signature]
QC Level
1 2 3 4
E.

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Date/Time
Chemtech-Ford Laboratories
9632 South 500 West
Sandy, UT 84070
Phone: [phone]
www.chemtechford.com
PHASE 3 WASTE ANALYSIS PLAN
Phase 3 Waste Analysis Plan
4867-8198-7593\1

Attachment 3
Field Screening Strip Instructions

Spilfyter ®CHEMICAL CLASSIFIER COLOR CHART
TEST 1
TEST 2
TEST 3
TEST 4
TEST 5
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®
1
2
3
4
5
1
2
3
4
5
ACID/BASERISK
OXIDIZERRISK
FLUORIDERISK
ORGANIC SOLVENTPETROLEUMDISTILLATE RISK
IODINE, BROMINECHLORINE RISK
DIRECTIONS
1) Keep Classifier dry until ready to use to avoid premature activation of the test strips. Avoid touching or contaminating test area on strip.
2) Fan Classifier in gas zone just above the level of solution to be tested. Observe test results.*
3) Dip Classifier vertically into solution (test end first).
4) Leave test strip in solution for 30 seconds, swishing if possible.
5) After removing test strip from solution IMMEDIATELY LAY FLAT on Color Chart.
• Classifier Strips are intended to be used for one wet testing procedure. Testing for vapors is considered a part of the single test.
* If Classifier is dipped or held in the incorrect position, bleeding from Test 1 may interfere with test #2, #4, and/or #5.
INTERFERENCES
Concentrated acidic solutions tend to totally destroy indicators impregnated in papers. Bleedingof the indicator dyes and extreme pH values are good evidence of indicator dye destruction. Inthe event of such a strong solution, dilution may be needed for an accurate analysis.
Heavy oils may saturate test papers and mask test colors.
Opaque solutions may mask colors.
Lightweight organic solvents may cause the blue indicator in test #4 to bleed. Volatile organicsmay vaporize before reading can be made.
Test #2 - Oxidizer test-strongly acidic, basic solutions, may cause false positives.
Test #3 - Fluoride test - Chlorates, Bromates and Sulfates result in a whitening of the test paper ifpresent in large quantities.
Test #5 - Free HNO2 (not nitrite ions) may cause false positives.
STABILITY AND STORAGE
Remove only as many strips as are required and reseal the container immediately after use. Do not touch test papers! Avoid exposing the strips to sunlight and moisture. Store the
container in a cool, dry place. Original color of test papers may vary. Expiration date dueto oxidizer test lifespan.
INTERPRETATION OF RESULTSTEST COLOR IDENTIFICATION
#1 ACID/BASE RISK Red (0)................................................... Strong Acid Orange (1,3).......................................... Moderately Acidic Yellow (5)............................................... Weak Acid Green (7)................................................ Neutral Dark Green (9,11).................................. Moderately Basic Dark Blue (13)........................................ Strong Base
(Useful for Aqueous Solutions only)
#2 OXIDIZER RISK White...................................................... Not Present Shades of Blue...................................... Present
#3 FLUORIDE RISK Pink......................................................... Not Present Yellow..................................................... Present (Any Shade)
#4 PETROLEUM Light Blue............................................... Not PresentPRODUCT, ORGANIC Dark Blue................................................ PresentSOLVENT RISK
#5 IODINE, BROMINE Peach...................................................... Not PresentCHLORINE RISK Violet....................................................... Present
LIMIT OF SENSITIVITY
Test #1 – 0-13 ph unitsTest #2 – 1 mg/l, Hydrogen PeroxideTest #3 – 20 mg/l, FluorideTest #4 – 10mg/l, GasolineTest #5 – 1 mg/l, Chlorine
PRESENT
PRESENT
PRESENT
PRESENT
STRONG WEAK
ACIDIC
STRONG WEAK
0 1 3 5
NOT PRESENT
NOT PRESENT
NOT PRESENT
NOT PRESENT
STRONGNEUTRAL WEAK
BASIC
7 9 11 13
STORE IN A COOL, DRY PLACE
© Copyright NPS Corporation 20031-800-558-5066 • 3303 Spirit Way • Green Bay, WI 54304 • www.spilfyter.com • Email: [e-mail]
INTERPRETATION OF RESULTS
TEST COLOR IDENTIFICATION
#1 ACID/BASE RISK Red (0)................................................... Strong Acid
Orange (1,3).......................................... Moderately Acidic
Yellow (5)............................................... Weak Acid
Green (7)................................................ Neutral
Dark Green (9,11).................................. Moderately Basic
Dark Blue (13)........................................ Strong Base
(Useful for Aqueous Solutions only)
#2 PETROLEUM Violet........................................................ Not Present
SOLVENT RISK Light to Dark Blue..................................... Present
#3 HYDROGEN White........................................................ Not Present
SULFIDE RISK Brown/Black............................................. Present
#4 NITRITE RISK White....................................................... Not Present
Blue/Violet................................................ Present

#5 NITRATE RISK White........................................................ Not Present
Light Pink.................................................. Present
#6 FLUORIDE RISK Pink.......................................................... Not Present
Yellow (Any Shade)................................... Present
TEST 1
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1
2
3
4
5
6
1
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4
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ACID/BASE
RISK
NITRITE RISK
HYDROGEN
SULFIDE RISK
ORGANIC SOLVENT
PETROLEUM RISK
NITRATE RISK
FLUORIDE RISK
ACID/BASE
RISK
NITRITE RISK
HYDROGEN
SULFIDE RISK
ORGANIC SOLVENT
PETROLEUM RISK
NITRATE RISK
FLUORIDE RISK
DIRECTIONS
1) Keep Classifier dry until ready to use to avoid premature activation of the test
strips. Avoid touching or contaminating test area on strip.
2) Fan Classifier in gas zone just above the level of solution to be tested.
Observe test results.*
3) Dip Classifier vertically into solution (test end first).
4) Leave test strip in solution for 30 seconds, swishing if possible.
5) After removing test strip from solution IMMEDIATELY LAY FLAT on Color Chart.
• Classifier Strips are intended to be used for one wet testing procedure. Testing
for vapors is considered a part of the single test.
* If Classifier is dipped or held in the incorrect position, bleeding from Test 1 may
interfere with test #2, #4, and/or #5.
INTERFERENCES
Concentrated acidic solutions tend to totally destroy indicators impregnated in papers. Bleeding
of the indicator dyes and extreme pH values are good evidence of indicator dye destruction. In
the event of such a strong solution, dilution may be needed for an accurate analysis.
Heavy oils may saturate test papers and mask test colors.
Opaque solutions may mask colors.
Lightweight organic solvents may cause the blue indicator in test #3 to bleed.
Fluoride Test (Test #6), Chlorates, bromates and sulfates result in a whitening of the test paper if
present in large quantities, Test #6 will give positive results in acidic solutions.
STABILITY AND STORAGE
Remove only as many strips as are required and reseal the container immediately after use.
Do not touch test papers! Avoid exposing the strips to sunlight and moisture. Store the container in a
cool, dry place. Original color of test papers may vary. Expiration date due
to oxidizer test lifespan.
PRESENT
PRESENT
PRESENT
PRESENT
NOT PRESENT
NOT PRESENT
NOT PRESENT
NOT PRESENT
NOT PRESENT
PRESENT
STRONG WEAK
ACIDIC
STRONG WEAK
0 3 5
STRONGNEUTRAL WEAK
BASIC
7 9 11 13
TEST 2
TEST 3
TEST 4
TEST 5
TEST 6
© Copyright NPS Corporation 20031-800-558-5066 • 3303 Spirit Way • Green Bay, WI 54304 • www.spilfyter.com • Email: [e-mail]
Spilfyter ®WASTEWATER CLASSIFIER COLOR CHART
LIMIT OF SENSITIVITY
Test #1 – 0-13 ph units
Test #2 – 10 ppm, Gasoline
Test #3 – 10 ppm, Hydrogen Sulfide
Test #4 – 1 ppm, Nitrate
Test #5 – 10 ppm, Nitrate
Test #6 – 20 ppm, Fluoride
STORE IN A COOL, DRY PLACE
5 mL
5
45 s
1 x CN ––1 5 CN ––2
MACHEREY-NAGEL GmbH & Co. KG · Neumann-Neander-Str. 6–8 · 52355 Düren · Germany
Tel.: [phone] · Fax: [phone] · [e-mail] · www.mn-net.com
MACHEREY-NAGEL GmbH & Co. KG · Neumann-Neander-Str. 6–8 · 52355 Düren · Deutschland
Tel.: [phone] · Fax: [phone] · [e-mail] · www.mn-net.com
Schweiz: MACHEREY-NAGEL AG · Hirsackerstr. 7 · 4702 Oensingen · Schweiz
Tel.: [phone] · Fax: [phone] · [e-mail]
Rev 2015-08 A007858 / 913 18 / 0851
me sofort wieder verschließen. Testfeld nicht berühren.
Zusatzhinweise:
Für erfolgreichen Test muss der pH-Wert der Probe < 10 liegen. Daher zu-
erst den pH-Wert der Probe bestimmen (z. B. mit pH-Fix 0–14 REF 921 10).
Bei pH-Wert > 10 Lösung tropfenweise mit verdünnter Schwefelsäure auf
pH 6–7 bringen.
Gebrauchsanweisung:
1. Messgefäß mit Prüfl ösung spülen und bis zur 5 mL Markierung füllen.
2. 1 Messlöel Cyanid-1 (Puermischung) zur Probe zugeben.
3. 5 Tropfen Cyanid-2 zur Probe zutropfen.
4. Probe kurz umschwenken.
5. Teststäbchen sofort in Probe eintauchen.
6. 45 s warten.
7. Flüssigkeitsüberschuss abschütteln.
8. Testfeld innerhalb von 10 s mit Farbskala vergleichen.
Störungen:
Es werden nur freie Cyanide bzw. durch Chlor zersetzbare Cyanidkom-
plexe erfaßt. Thiocyanate (SCN –) ergeben ab 1 mg/L eine ähnliche Verfär-
bung. Jodid und Bromid führen ab 5 mg/L zu einer Farbabschwächung bzw.
bei höheren Konzentrationen zum Ausbleiben einer Färbung. Sulfi d-Ionen
(S 2–) stören bis 20 mg/L nicht. Bei höheren Konzentrationen ist die Färbung
schwächer oder bleibt vollständig aus. Bei pH > 10 reicht die Kapazität des
zugesetzten Puers nicht mehr aus, um die Prüfl ösung auf einen optimalen
pH-Wert von 6–7 zu bringen. Durch tropfenweise Zugabe von verdünnter
Schwefelsäure sollte dann der pH-Wert auf 6–7 eingestellt werden.
Entsorgung:
Gebrauchte Teststäbchen zur Sondermüll-Entsorgung geben.
Lagerbedingungen:
Teststäbchen vor Sonnenlicht und Feuchtigkeit schützen. Dose kühl und
trocken aufbewahren (Lagertemperatur nicht über +30 °C).
Bei sachgemäßer Lagerung ist das Testkit bis zum aufgedruckten Verfalls-
datum haltbar.
mediately after removing a strip. Do not touch the test fi eld.
Additional indications:
To obtain correct results with this test, the pH value of the sample must be
< 10. Therefore, the pH value of the sample must be fi rst measured (for
example with pH-Fix 0–14, REF 921 10). If the solution has a pH value >
10, add some drops of diluted sulfuric acid to lower it to 6–7.
Instructions for use:
1. Rinse the measuring vessel with the test solution and fi ll it to the 5 mL
mark.
2. Add 1 spoon Cyanide-1 (buer solution) to the sample.
3. Add 5 drops Cyanide-2 to the sample.
4. Shake carefully.
5. Immediately dip the test strip into the sample.
6. Wait 45 seconds.
7. Shake o excess liquid.
8. Compare within 10 seconds with the color scale.
Interferences:
This test detects free cyanide and cyanide complexes which are decom-
posed by chlorine. Thiocyanates (SCN –) above 1 mg/L lead to a similar
coloration. Iodide and bromide in concentrations of 5 mg/L and above lead
to a fading of the color reaction, and in major concentrations may inhibit the
color reaction. Sulfi de ions (S 2–) up to 20 mg/L do not interfere. Higher con-
centrations also decrease or inhibit the color reaction. If the pH value of the
sample is > 10, then the capacity of the buer solution will not be suffi cient
to lower the pH to the optimal value of 6 –7. In this case, prior to the test, the
pH value of the sample should be adjusted to 6–7 by drop wise addition of
diluted sulfuric acid.
Disposal:
Dispose of used strips at an authorised hazardous waste collection point.
Storage:
Avoid exposing the strips to sunlight and moisture. Keep container cool and
dry (storage temperature not above +30 °C).
If correctly stored, the test kit may be used until the use-by-date printed on
the packaging.
5 mL
5
45 s
1 x CN ––1 5 CN ––2
QUANTOFIX ® Cyanide
Pack content:
1 aluminium container with 100 test strips
1 bottle Cyanide-1 1 measuring vessel with 5 mL mark
1 bottle Cyanide-2 1 small measuring spoon
Measuring range:
1–30 mg/L CN –
Color gradation:
0 · 1 · 3 · 10 · 30 mg/L CN –
Safety precautions:
Cyanide-2 contains chloramine T 1–5 % and pyridine 5–44 % CAS 127-65-1,
110-86-1. DANGER May cause allergy or asthma symptoms or breathing
diffi culties if inhaled. Avoid breathing dust. IF INHALED: If breathing is dif-
fi cult, remove to fresh air and keep at rest in a position comfortable for
breathing. If experiencing respiratory symptoms: Call a POISON CENTER
or doctor / physician.
General indications:
Remove only as many test strips as are required. Close the container im-
mediately after removing a strip. Do not touch the test fi eld.
Additional indications:
To obtain correct results with this test, the pH value of the sample must be
< 10. Therefore, the pH value of the sample must be fi rst measured (for
example with pH-Fix 0–14, REF 921 10). If the solution has a pH value >
10, add some drops of diluted sulfuric acid to lower it to 6–7.
Instructions for use:
1. Rinse the measuring vessel with the test solution and fi ll it to the 5 mL
mark.
2. Add 1 spoon Cyanide-1 (buer solution) to the sample.
3. Add 5 drops Cyanide-2 to the sample.
4. Shake carefully.
5. Immediately dip the test strip into the sample.
6. Wait 45 seconds.
7. Shake o excess liquid.
8. Compare within 10 seconds with the color scale.
Interferences:
This test detects free cyanide and cyanide complexes which are decom-
posed by chlorine. Thiocyanates (SCN –) above 1 mg/L lead to a similar
coloration. Iodide and bromide in concentrations of 5 mg/L and above lead
to a fading of the color reaction, and in major concentrations may inhibit the
color reaction. Sulfi de ions (S 2–) up to 20 mg/L do not interfere. Higher con-
centrations also decrease or inhibit the color reaction. If the pH value of the
sample is > 10, then the capacity of the buer solution will not be suffi cient
to lower the pH to the optimal value of 6 –7. In this case, prior to the test, the
pH value of the sample should be adjusted to 6–7 by drop wise addition of
diluted sulfuric acid.
Disposal:
Dispose of used strips at an authorised hazardous waste collection point.
Storage:
Avoid exposing the strips to sunlight and moisture. Keep container cool and
dry (storage temperature not above +30 °C).
If correctly stored, the test kit may be used until the use-by-date printed on
the packaging.
CTL SCIENTIFIC SUPPLY CORP. 1016-3 Grand Blvd. Deer Park, NY 11729
Tel: [phone]
web: www.ctlscientic.com
Manufacturer: Macherey-Nagel GMbH & CO. KG
Product data and ordering information
Type Semi-quantitative test strips
Presentation Tube of 100 test strips with reagents
Color reaction white to violet
Gradation 0 · 1 · 3 · 10 · 30 mg/l (ppm) CN–
REF 91318

5 mL
10
NH 4
+-1 5 s
MACHEREY-NAGEL GmbH & Co. KG · Neumann-Neander-Str. 6–8 · 52355 Düren · Germany
Tel.: [phone] · Fax: [phone] · [e-mail] · www.mn-net.com
MACHEREY-NAGEL GmbH & Co. KG · Neumann-Neander-Str. 6–8 · 52355 Düren · Deutschland
Tel.: [phone] · Fax: [phone] · [e-mail] · www.mn-net.com
Schweiz: MACHEREY-NAGEL AG · Hirsackerstr. 7 · 4702 Oensingen · Schweiz
Tel.: [phone] · Fax: [phone] · [e-mail]
men erleichtert. BEI BERÜHRUNG MIT DEN AUGEN: Einige Minuten lang vorsichtig mit Wasser ausspülen. Evtl. vorhandene Kontaktlinsen entfer -
nen, sofern leicht möglich. Weiter ausspülen. Für ausführliche Information
können Sie ein Sicherheitsdatenblatt anfordern (siehe www.mn-net.com/
MSDS).
Allgemeine Hinweise:
Stets nur notwendige Anzahl Teststäbchen entnehmen. Dose nach Entnah -
me sofort wieder verschließen. Testfeld nicht berühren.
Zusatzhinweise:
Die gelbe Färbung des ungebrauchten Testpapiers ist normal und kein Zei -
chen für eine Zersetzung der Reagenzien.
Gebrauchsanweisung:
1. Messgefäß mit spülen und bis zur 5 mL Markierung füllen.
2. 10 Tropfen NH 4+-1 (Natronlauge) zur Probe zutropfen.
3. Probe vorsichtig umschwenken.
4. Teststäbchen 5 s in Probe eintauchen.
5. Überschüssige Flüssigkeit abschütteln.
6. Teststäbchen mit Farbskala vergleichen.
Bei Anwesenheit von Ammonium-Ionen färbt sich das Testpapier orange.
Störungen:
Dieser Test ist vorgesehen für den Ammonium-Nachweis in
und Trinkwässern und in industriellen Abwässern, die kein Übermaß an
Störionen wie Härtebildner (Calcium, Magnesium), Eisen und Sulfidionen
enthalten.
Entsorgung:
Die gebrauchten Teststäbchen müssen als Sondermüll einer entsprechen -
den Abfallbehandlung zugeführt werden.
Lagerbedingungen:
Teststäbchen vor Sonnenlicht und Feuchtigkeit schützen. Dose kühl und
trocken aufbewahren (Lagertemperatur nicht über +30 °C).
Bei sachgemäßer Lagerung sind die Teststäbchen bis zum aufgedruckten
Verfallsdatum haltbar.
for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. For further information, please ask for safety data sheet
(see www.mn-net.com/MSDS).
General indications:
Remove only as many test strips as are required. Close the container im -
mediately after removing a strip. Do not touch the test field.
Additional indications:
The yellow colouration of the unused test fields is normal and does not
indicate any decomposition of the reagents.
Instructions for use:
1. Rinse the measuring vessel with the test solution and fill it to the 5 mL
mark.
2. Add 10 drops NH 4+-1 (sodium hydroxide solution) to the sample.
3. Shake carefully.
4. Dip the test strip into the test solution for 5 s.
5. Shake o excess liquid.
6. Compare with the color scale.
If ammonium ions are present, the test field turns orange.
Interferences:
This test is intended for the detection of ammonium in surface and drinking
water and in industrial waste water which do not contain high concentra -
tions of interfering ions, such as water hardeners (calcium, magnesium),
iron and sulfide ions.
Disposal:
The used test strips must be collected for special hazard waste treatment.
Storage:
Avoid exposing the strips to sunlight and moisture. Keep container cool and
dry (storage temperature not above +30 °C).
If correctly stored, the test strips may be used until the use-by-date printed
on the packaging.
5 mL
Rev 2014-04 A007792 / 913 15 / 0442
10
NH 4
+-1 5 s

QUANTOFIX® Ammonium
Pack content:
1 aluminium container with 100 test strips
2 bottles NH 4+-1
1 measuring vessel with 5 mL mark
Measuring range:
Visually
10–400 mg/L NH 4+ 10–350 mg/L NH 4+
Color gradation:
0 · 10 · 25 · 50 · 100 · 200 · 400 mg/L NH 4+
Safety precautions:
Reagent NH 4+-1 contains sodium hydroxide solution 32 % CAS 1310-
73-2. DANGER Causes severe skin burns and eye damage. Do not
breathe vapors. Wear protective gloves/eye protection. IF SWALLOWED:
rinse mouth. Do NOT induce vomiting. IF ON SKIN (or hair): Remove /
Take o immediately all contaminated clothing. Rinse skin with wa-
ter / shower. IF INHALED: Remove to fresh air and keep at rest in a posi-
tion comfortable for breathing. IF IN EYES: Rinse cautiously with water
for several minutes. Remove contact lenses, if present and easy to do.
Continue rinsing. For further information, please ask for safety data sheet
(see www.mn-net.com/MSDS).
General indications:
Remove only as many test strips as are required. Close the container im-
mediately after removing a strip. Do not touch the test field.
Additional indications:
The yellow colouration of the unused test fields is normal and does not
indicate any decomposition of the reagents.
Instructions for use:
1. Rinse the measuring vessel with the test solution and fill it to the 5 mL
mark.
2. Add 10 drops NH 4+-1 (sodium hydroxide solution) to the sample.
3. Shake carefully.
4. Dip the test strip into the test solution for 5 s.
5. Shake o excess liquid.
6. Compare with the color scale.
If ammonium ions are present, the test field turns orange.
Interferences:
This test is intended for the detection of ammonium in surface and drinking
water and in industrial waste water which do not contain high concentra-
tions of interfering ions, such as water hardeners (calcium, magnesium),
iron and sulfide ions.
Disposal:
The used test strips must be collected for special hazard waste treatment.
Storage:
Avoid exposing the strips to sunlight and moisture. Keep container cool and
dry (storage temperature not above +30 °C).
If correctly stored, the test strips may be used until the use-by-date printed
on the packaging.
CTL SCIENTIFIC SUPPLY CORP. 1016-3 Grand Blvd. Deer Park, NY 11729
Tel: [phone]
web: www.ctlscientic.com Manufacturer: Macherey-Nagel GMbH & CO. KG
Product data and ordering information
Type Semi-quantitative test strips
Presentation Tube of 100 test strips and reagents
Color reaction bright-yellow to orange
Gradation 0 · 10 · 25 · 50 · 100 · 200 · 400 mg/l (ppm) NH4+
REF 91315

QUANTOFIX® Peroxid 100
Beschreibung:
QUANTOFIX® Peroxid 100 sind Teststäbchen zum halbquantitativen Nachweis von Wasser -
2O2) und Peroxiden in Lösungen. Sie sind auch geeignet für die Rückstands -
analyse von Peroxiden in Dialysegeräten.
Inhalt:
1 Aluminiumdose mit 100 Teststäbchen
Messbereich:
Visuell *
1–100 mg/L H2O2 1–100 mg/L H2O2
Farbabstufungen:
0 · 1 · 3 · 10 · 30 · 100 mg/L H2O2* Zusammen mit dem QUANTOFIX
® Relax dürfen die Teststäbchen nicht im medizinischen
Bereich eingesetzt werden.
Reaktionsprinzip:
im Testfeld zu einem blaugefärbten Oxidationsprodukt.
Allgemeine Hinweise:
Stets nur notwendige Anzahl Teststäbchen entnehmen. Dose nach Entnahme sofort wieder
verschließen. Testfeld nicht berühren.
Zusätzliche Hinweise:
QUANTOFIX® Peroxid 100 eignet sich auch zum Nachweis von anderen organischen und
freien anorganischen Hydroperoxiden.
Zum Nachweis von Hydroperoxiden in organischen Lösemitteln wird das Testfeld nach dem
Verdunsten bzw. Eintrocknen des Lösemittels mit einem Tropfen Wasser befeuchtet.
Gebrauchsanweisung:
1. Teststäbchen 1 s in Probe eintauchen.
2. Flüssigkeitsüberschuss abschütteln.
3. 5 s warten.
Testpapier blau.
Wert ablesen, der der Verfärbung des Testfeldes am nächsten kommt (Ablesegenauig -
keit: ± 1/2 Farbfeld).
Verfärbungen oder Farbänderungen nach 1 Minute sind nicht mehr positiv zu bewerten.
Qualitätskontrolle:
mit einer Konzentration von 3 mg/L. Dazu stellt man sich zunächst eine Stammlösung von
500 mg/L H2O2liertem Wasser verdünnt. Anschließend werden 3 mL dieser Stammlösung in 500 mL destil -
liertem Wasser verdünnt (= 3 mg/L H2O2).
Die Messung mit den Teststäbchen sofort durchführen. Ergibt die Kontrolllösung auch nach
Wiederholung ein negatives Ergebnis, sind die restlichen unbenutzten Teststäbchen zu ent -
sorgen. Auch bei einer Negativkontrolle (Eintauchen in destilliertes Wasser) darf keine bläu -
liche Verfärbung eintreten. Als Ursache für beide Fehler kann das Verfallsdatum der Test -
die Teststäbchen wurden falsch gelagert.
Störungen:
Im Bereich von pH 2–9 ist die Reaktion unabhängig vom pH-Wert der zu prüfenden Lösung.
nekrats neredna tim sllafnebe trefeil tseT reD .nedrew tlletsegnie 7–5 Hp fua eruäsnenortiC
Oxidationsmitteln ein positives Ergebnis. Die Bestimmung wird durch die folgenden maxi -
malen Fremdionen-Konzentrationen nicht gestört:
3 mg/L: freies Chlor (Hypochlorit)
4 mg/L: Brom (Br2)
Hinweise:
Der Stopfen der Teststäbchendose enthält ein ungiftiges Trockenmittel. Sollte es einmal ver -
schluckt werden, reichlich Wasser nachtrinken.
Entsorgung:
Benutzte Teststäbchen in den Hausmüll geben.
Lagerbedingungen:
Teststäbchen vor Sonnenlicht und Feuchtigkeit schützen. Dose kühl und trocken aufbewah -
ren (Lagertemperatur nicht über +30 °C).
Bei sachgemäßer Lagerung sind die Teststäbchen bis zum aufgedruckten Verfallsdatum
haltbar.
QUANTOFIX ® Peroxide 100
Description:
QUANTOFIX ® Peroxide 100 are test strips for the semi-quantitative determination of hydro-
gen peroxide and peroxides in solutions. These test strips are also suitable for the determi-
nation of residual peroxide in dialysis equipment.
Pack content:
1 aluminum container with 100 test strips
Measuring range:
Visually *
1–100 mg/L H 2O 2 1–100 mg/L H 2O 2
Color gradation:
H L/gm 001 · 03 · 01 · 3 · 1 · 0 2O 2* Together with the QUANTOFIX ® Relax, these test strips may not be used for any medical
application.
Reaction principle:
Hydrogen peroxide reacts with peroxidase (POD) and the organic redox indicator in the test
to form a blue colored oxidations compound.
General indications:
Remove only as many test strips as are required. Close the container immediately after
removing a strip. Do not touch the test
Additional indications:
QUANTOFIX ® Peroxide 100 is also suitable for the detection of other organic and free inor-
ganic hydrogen peroxides.
When detecting hydroperoxides in organic solvents, moisten the test with 1 drop of
water after evaporation / drying of the solvent.
Instructions for use:
1. Dip the test strip into the test solution for 1s.
.s 5 tiaW.3
4. Compare test with the color scale. If hydrogen peroxide is present, the test
turns blue.
Take the value which matches closest with the colored test (reading accuracy: ± 1/2
colored of the scale).
.noitcaer evitisop a tneserper ton od etunim 1 retfa segnahc roloC
Quality control:
For the control of the functions of the test strips one uses a hydrogen peroxide solution
H L/gm 005 fo dradnats lortnoc a siht roF .L/gm 3 fo noitartnecnoc a htiw 2O 2 is prepared,
dellitsid fo Lm 0001 htiw detulid si noitulos edixorep negordyh % 03 eht fo Lm 5.1 yberehw
retaw dellitsid fo Lm 005 htiw detulid era noitulos lortnoc dradnats siht fo Lm 3 nehT .retaw
(= 3 mg/L H 2O 2). Now control the test strips immediately. Should the results still be negative
after a repeated control, than the remaining unused test strips should be properly disposed
of. Also with a negative control, whereby the test strips are dipped into distilled water, there
should be no blue coloration. The reasons for both failures can be, that the expiry date has
passed, the tubes was left open too long or improper storage, meaning not according to
instructions.
Interferences:
If the sample solution has a pH value of 2–9, the reaction will take place without interfer-
with citric acid to a pH of 5–7. The presence of other strong oxidants will also lead to false
positive results. The following ions interfere with the determination only when the concentra-
tions below are exceeded:
3 mg/L: free chlorine (hypochlorite)
4 mg/L: bromine (Br 2)
Special instructions:
The stopper of the tubes contains a harmless desiccant. Should this desiccant be swal-
lowed, then drink plenty of water.
Disposal:
Used test strips can be placed in the normal household waste.
Storage:
Avoid exposing the strips to sunlight and moisture. Keep container cool and dry (storage
temperature not above +30 °C).
If correctly stored, the test strips may be used until the use-by-date printed on the packag-
ing.
QUANTOFIX® WODA UTLENIONA
(PEROXID) 100
QUANTOFIX® Peroxid 100 to paski wskanikowe do półilociowego oznaczania H2O2 i nad-
tlenków w roztworach. Nadaje si równie do oznaczania pozostałoci nadtlenków w apa-
ratach do dializy.
Zawarto:
1 puszka aluminiowa zawiera 100 pasków testowych
Zakres pomiarowy:
Wizualny *
1–100 mg/L H2O2 1–100 mg/L H2O2
Odcienie kolorów:
0 · 1 · 3 · 10 · 30 · 100 mg/L H2O2* Te paski testowe nie mog by razem z QUANTOFIX
® Relax stosowane w dziedzinie me -
dycznej.
Zasada reakcji:
H2O2 reaguje z peroksydaz (POD) i organicznym wskanikiem redoks na papierku wsku
wskanikowym prowadzc do powstania niebieskiego produktu utlenienia.
Wskazówki ogólne:
Naley zawsze pobiera tylko potrzebn ilo pasków testowych. Po pobraniu pasków pusz-
k naley natychmiast szczelnie zamkn. Nie dotyka pól testowych.
Wskazówki dodatkowe:
QUANTOFIX® Peroxid 100 moe by równie uyty do wykrywania innych organicznych i
wolnych nieorganicznych nadtlenków wodoru.
Celem wykrycia nadtlenków wodoru w rozpuszczalnikach organicznych naley, po ulotnie-
niu si lub po zaschniciu rozpusz-czalnika, nawily pole testowe kropl wody.
Sposób uycia:
1. Paski testowe naley na 1 s zanurzy w próbce.
2. Strzsn nadmiar cieczy.
3. Odczeka 5 s.
4. Pole testowe porówna ze skal kolorów. W przypadku obecnoci nadtlenku wodoru pa-
pierek testowy zabarwia si na niebie-sko.
Odczyta warto, która jest najbardziej zbliona do zabarwienia pola testowego (do-
kładno odczytu: ± 1/2 barwnego pola).
Spłowienia lub zmiany zabarwienia wystpujce po upływie 1 minuty nie naley ju ocenia
pozytywnie.
Kontrola jakoci:
Do kontroli pasków uywa si roztworu nadtlenku wodoru w steniu 3 mg/L. W tym celu
przygotowuje si roztwór macierzysty 500 mg/L H2O2 - rozcieczajc 1,5 mL 30 % roztworu
nadtlenku wodoru 1000 mL wody destylowanej. Nastpnie 3 mL tego roztworu naley roz-
cieczy w 500 mL wody destylowanej (= 3 mg/L H2O2). Natychmiast przeprowadzi ana-
liz z uyciem pasków wskanikowych. Jeeli nie zachodzi odpowiednia reakcja barwna,
oznacza to, e paski s albo przeterminowane albo paski nie były poprawnie przechowywa -
ne. Podobne wnioski mona wycign przeprowadzajc tzw. kontrol negatywn. Zanurza -
jc pasek w wodzie destylowanej nie powinien on przyj niebieskiego zabarwienia.
Zakłócenia:
W zakresie pH 2–9 reakcja jest niezalena od wartoci pH badanego roztworu. Roztwory
silnie kwane naley zbuforowa octanem sodowym, natomiast roztwory alkaliczne nasta-
wi kwasem cytrynowym na warto pH 5–7. Równie przy uyciu innych, silnych utleniaczy
test ma wynik pozytywny. Nastpujce, maksymalne stenia jonów obcych nie zakłócaj
oznaczania:
3 mg/L: wolny chlor (podchloryn)
4 mg/L: brom (Br2)
Warunki przechowywania:
Paski testowe naley chroni przed wiatłem słonecznym i wilgoci. Puszk przechowywa
w miejscu chłodnym i suchym (w temperaturze nie przekraczajcej +30 °C).
Przy prawidłowym składowaniu laseczki testowe s przydatne do uytku do daty podanej
na opakowaniu.
Usawanie:
Uywany pasek testowy do odpadów komunalnych.
Wakazówka:
Korek pojemnika, w którym znajduj si paski, zawiera nieszkodliwy rodek osuszajcy. Je-
li dostanie si on do przewodu pokarmowego, naley wypi du ilo wody.
Zuyte paski mona wyrzuci do pojemnika na mieci.
1 s 5 s
Rev 09/2014 A007798 /913 12 /09420
CTL SCIENTIFIC SUPPLY CORP. 1016-3 Grand Boulevard Deer Park, NY 11729
Tel: [phone]
Manufacturer: Macherey-Nagel GMbH & CO. KG
Product data and ordering information
Type Semi-quantitative test strips
Presentation tube of 100 test strips
Color reaction white to blue
Gradation 0 · 1 · 3 · 10 · 30 · 100 mg/l (ppm) H2O2(limit of sensitivity for peracetic acid: 2 mg/l (ppm))
REF 91312
PHASE 3 WASTE ANALYSIS PLAN
Phase 3 Waste Analysis Plan
4867-8198-7593\1

Attachment 4
CTF Quality Manual

Chemtech-Ford, Inc.
9632 South 500 West
Sandy, UT 84070
[phone]
Vice President of Quality: Paul Ellingson
Quality Manager: Ron Fuller
Laboratory Director: Dave Gayer
Date of Issue: October 1, 2017
Controlled Copy #: QM-27
Dave Gayer, Laboratory Director
Paul Ellingson, Vice President
Ron Fuller, QA Officer
Quality Manual
This Quality Manual meets the requirements of ISO 17025, ISO 9001, and TNI. This
Quality Manual is confidential and assigned as outlined below.
Original Document: Quality Manager
Controlled Copy
Uncontrolled Copy
All employees have access to a controlled version through Quality Manager, or through
the Chemtech-Ford intranet. Printed copies are not considered controlled documents.
Companies whose Quality Systems are defined by this document are:
Chemtech-Ford Laboratories
9632 South 500 West
Sandy, UT 84070
801.262.7299
Timpview Analytical Laboratories
1384 West 130 South
Orem, UT 84058
801.229.2272
This Quality Manual has been approved for use by affiliate laboratories of Chemtech-
Ford, Inc.
Quality Manual
Only documents located on the intranet are controlled. All other forms
are uncontrolled.
Effective
Date:
10/01/2017
Rev:
27
Chemtech-Ford Laboratories Quality Manual Page No.
3 of 139
Prepared by: Ron Fuller Reviewed by: Paul Ellingson
Approved for
affiliate
laboratory use
Status: Active
Table of Contents
Introduction
1. Scope
2. Normative References
Reference List
Cross-references
3. Terms and Definitions
4. Management Requirements
4.1 Organization
4.2 Management System
4.3 Document Control
4.4 Review of Requests, Tenders, and Contracts
4.5 Sub-contracting of Tests and Calibrations
4.6 Purchasing Services and Supplies
4.7 Service to the Customer
4.8 Complaints
4.9 Control of Nonconforming Testing and Calibration work
4.10 Improvement
4.11 Corrective Action
4.12 Preventive Action
4.13 Control of Records
4.14 Internal Audits
4.15 Management Reviews
5. Technical Requirements
5.1 General
5.2 Personnel
5.3 Accommodation and Environmental Conditions
5.4 Test and Calibration Methods and Method Validation
5.5 Equipment
5.6 Measurement Traceability
5.7 Sampling
5.8 Handling of Test and Calibration Items
Quality Manual
Only documents located on the intranet are controlled. All other forms
are uncontrolled.
Effective
Date:
10/01/2017
Rev:
27
Chemtech-Ford Laboratories Quality Manual Page No.
4 of 139
Prepared by: Ron Fuller Reviewed by: Paul Ellingson
Approved for
affiliate
laboratory use
Status: Active
5.9 Assuring the Quality of Test and Calibration Results
5.10 Reporting the Results
Quality Manual
Only documents located on the intranet are controlled. All other forms
are uncontrolled.
Effective
Date:
10/01/2017
Rev:
27
Chemtech-Ford Laboratories Quality Manual Page No.
5 of 139
Prepared by: Ron Fuller Reviewed by: Paul Ellingson
Approved for
affiliate
laboratory use
Status: Active
Introduction
Purpose
This Quality Manual contains all the requirements that our laboratory uses to demonstrate
our quality management system, technical competence, and valid results.
Section 4 specifies how we demonstrate sound management and maintain client
satisfaction.
Section 5 specifies how we demonstrate technical competence in our laboratory.
In addition, this Quality Manual outlines how we meet:
ISO 17025
ISO 9001
TNI
All personnel are to take an active role in establishing, implementing, and maintaining
our quality management program. We do not separate quality from our daily business.
Quality is integrated into every facet of the decision-making process in the management
of our laboratory and the science that we practice.
It is the policy of Chemtech-Ford, Inc. and its employees to perform their duties in a
consistently legal and ethical manner. A professionally high level of ethical behavior is
characterized by, but not limited to, dealing honestly and forthrightly with all clients and
co-workers, maintaining data integrity, the open and timely treatment of inaccurate,
invalid, or misreported analytical data, and abiding by all pertinent rules, regulations,
company policies, and standard operating procedures.
Chemtech-Ford, Inc. encourages its employees to demonstrate consistently ethical and
professional behavior by implementing programs consonant with that purpose. These
programs, generally, include:
1) a thorough training program for new employees and continuing seminars throughout
employment which reflect Chemtech-Ford, Inc.'s commitment to integrity and quality
control and which present specific ways to honor that commitment
Quality Manual
Only documents located on the intranet are controlled. All other forms
are uncontrolled.
Effective
Date:
10/01/2017
Rev:
27
Chemtech-Ford Laboratories Quality Manual Page No.
6 of 139
Prepared by: Ron Fuller Reviewed by: Paul Ellingson
Approved for
affiliate
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2) a comprehensive documentation program for all facets of laboratory operation, which
allows ready reconstruction of any quality process
3) a program of continual evaluation, both internally and externally, with required levels
of quality acceptance
4) a management monitoring system which routinely evaluates the overall performance of
the laboratory.
This Quality Manual summarizes the policies and procedures employed by Chemtech-
Ford, Inc. It is the purpose of these policies and procedures to maintain the highest level
of integrity and ethical behavior in all aspects of laboratory work.
Distribution List
The approved version of this manual is available to all employees through Quality
Manager and/or Chemtech-Ford Laboratories intranet. All printed copies are
uncontrolled.
In the event that a controlled copy of this manual is necessary, the Quality Manager will
maintain a distribution list.
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1. Scope
This Quality Manual facilitates:
Recognition of technical competence for standardized methods, non-routine methods,
and laboratory-developed methods we perform
Inspection and product certification capabilities and/or services we provide
Total quality for our administrative and technical systems
Audits by clients, regulatory authorities and accreditation bodies
Meeting the requirements of ISO 17025, ISO 9001, and TNI
Client satisfaction
Chemtech-Ford Laboratories displays all Fields of Accreditation on our website.
2. Normative References
Reference List
ISO/IEC 17000, Conformity assessment – Vocabulary and general principles
VIM, International vocabulary of basic and general terms in metrology, issued by BIPM,
IEC, IFCC, ISO, IUPAC, IUPAP and OIML.
ISO 9001:2000 – Quality Management Systems – Fundamentals and vocabulary.
ISO/IEC 17025:2005 – General Requirements for the Competence of Testing and
Calibration Laboratories.
TNI Standard, Volume 1, 2009 NELAC Standard.
Cross-references
This manual is numerically aligned with the international standard ISO 17025.
Furthermore, each section cross-references the ISO 9001 standard.
For ease of use, each section starts with a brief summation of what the section addresses
and a listing of the quality terminology and key words.
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3. Terms and Definitions
For the purposes of this manual, the following documents and their corresponding
definitions apply: ISO/IEC 17000; ISO/IEC Guide 30; ISO Council Committee on
Conformity Assessment (CASCO); ISO 9000; ISO 5725-1; ISO 17025; TNI 2009
Standard; AOAC; and International Vocabulary of Basic and General Terms in
Metrology(VIM).
Accreditation – formal recognition of a laboratory by an independent science-based
organization that the laboratory is competent to perform specific tests.
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4.1 Organization
Section Synopsis
This section tells you our laboratory has:
1. Appointed a Quality Manager
2. Organized the workforce to achieve quality
3. Provided adequate resources to ensure quality
Key Words
Quality Manager
Organizational Chart
Authority
Resources
Confidential Information
Proprietary Rights
Responsibilities
Conflict of Interest
Cross-references
ISO 17025:2005 Section 4.1
ISO 9001:2000 Section 4.1, 5.1, 5.3, 5.4.1, 5.5.1, 5.5.2, 5.5.3, 6.1, 6.2.1, 6.2.2,
6.3.1, 7.1, 7.5.4
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4.1.1 Legal Identification / Registration
Chemtech-Ford, Inc.
9632 South 500 West.
Sandy, UT 84070
[phone]
[phone]
4.1.2 Laboratory Requirements
The work area of Chemtech-Ford, Inc has been organized to satisfy the needs of the
customer and regulatory authorities and to meet the international standards TNI, ISO
17025 and ISO 9001. Chemtech-Ford, Inc. is composed of the following work areas:
President/CEO/Vice Presidents
Lab Director
QA/QC Department
Customer Service Department
Receiving/Shipping Department
Organics Lab
Inorganics Lab
Microbiology Lab
Metals Lab
4.1.3 Scope of Management System
The management system covers activities all of the laboratory’s facilities. The fields of
activities include:
Environmental Sample Testing
Medical Device Testing
Nutraceutical Product Testing
Specialty Testing
The laboratory’s scope of tests is listed in the current Price List.
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4.1.5 Organization
A) Management and Technical Personnel
Policy:
The laboratory managerial and technical personnel, irrespective of other responsibilities,
have the necessary authority and resources needed to meet the mandates assigned to their
areas.
Details:
Responsibilities are detailed in 5.2.5
Departures from the organizational and management policies in this manual can only be
approved by a Vice President.
Departures from quality management system procedures can only be approved by a Vice
President or the Quality Manager.
Departures from test methods or technical standard operating procedures (SOPs) can only
be approved by the Quality Manager and/or the Laboratory Director.
See also section 5.2.
B) Conflict of Interest
Policy:
Management and personnel are to be free from any undue internal and external
commercial, financial and other pressures that may adversely affect the quality of their
work. The integrity of test results is the responsibility of all personnel. Management
ensures that employees are never instructed or forced to alter or falsify data. Chemtech-
Ford Laboratories performs annual data integrity training. A review of the undue
pressure policy is part of this training.
Details:
The following list provides some guidelines on how employees avoid conflict of interest
situations. Employees shall not:
falsify records, prepare fraudulent reports, or make false claims
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seek or use privileged or confidential company information, or data from any
customer, for any purpose beyond the scope of employment
conduct non-laboratory business on laboratory time, or use company facilities or
equipment to conduct outside interests in business, unless prior approval has been
obtained
solicit business on their own behalf (rather than the laboratory) from a customer
be employed by, or affiliated with, organizations whose products or services compete
with laboratory products or services
have employment that negatively affects or interferes with their performance of
laboratory duties
compete with the laboratory in the purchase, sale, or leasing of property or goods
allow association, family, or friends to influence business decisions to their benefit.
Decisions must be made on a strictly business basis, always in the best interest of the
laboratory
make any decision that provides gains or benefits to the employee and/or others
have personal financial dealings with an individual or company that does business
with the laboratory which might influence decisions made on the laboratory’s behalf
Firm adherence to this code of values forms the foundation of our credibility. Personnel
involved in dishonest activities are subject to a range of disciplinary action including
dismissal.
C) Customer Confidentiality
Policy:
It is the policy of our laboratory to protect the confidential information and proprietary
rights of our customer including the electronic storage and transmission of results.
Details and Procedures:
All employees sign a Confidentiality Agreement. The signed agreement is retained in
each employee’s Human Resources file.
Test results are only released to the customer. Release to someone other than the
customer requires the express permission of the customer, except when the situation
contravenes State or Federal Legislation and the results must be provided to the
appropriate agency. The release of test results to anyone other than the customer requires
the permission of management. Laboratory reports are reviewed for accuracy prior to
release.
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D) Operational Integrity
Policy:
The laboratory will avoid involvement in any activities that would diminish confidence in
its competence, impartiality, judgment, or operational integrity.
Details and Procedures:
To ensure confidence in laboratory operations a formal quality assurance program is
implemented. Technical competence is ensured through commercial performance testing
studies and data formatted in DOCs (Demonstration of Competency) reports. Impartiality
is assessed through audits and approvals. Judgment is ensured through the hiring of
qualified personnel and by continuously refining, upgrading, and improving his or her
skills. Operational integrity is reviewed by management on a regular basis at
management review meetings to ensure continued suitability and effectiveness of
laboratory policies and procedures. Any problems are acted on immediately through
corrective action procedures.
E) Organizational Structure
Policy:
The organization and management structure of the laboratory and the relationships
between management, technical operations, support services, and the quality management
system is defined through the aid of an organizational chart.
Details:
The most current organizational structure is contained within Quality Manager. The
organizational structure is reviewed at regular intervals (at least two times per calendar
year).
F) Responsibility and Authority
The responsibility, authority and interrelationships of all personnel who manage, perform
or verify work affecting the quality of the tests and/or calibrations is defined in section
5.2.5
G) Laboratory Supervision
Policy:
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Adequate supervision is provided in each area of the laboratory for all testing and
calibration personnel, including trainees, by persons familiar with the methods and
procedures.
Details:
Adequate supervision is ensured through designated supervisors as well as through
documentation such as this Quality Manual, test methods and SOPs. Initial and ongoing
training for regular personnel is required. The successful completion of analyses in the
commercial PT study program, and/or DOC studies are evidence of successful and
continued training.
H) Technical Management
Policy:
A technical manager is assigned to each major work area of the laboratory. They have
overall responsibility for the technical operations and the provision of resources needed
to ensure the required quality of laboratory operations.
Details:
While the technical manager may at times delegate duties to other personnel, the
technical manager is responsible for the work produced in his area of the laboratory, and
is accountable for any nonconforming activities.
I) Quality Manager
Policy:
The Quality Manager is appointed by the highest level of management. The Quality
Manager, who, irrespective of other duties and responsibilities, has defined responsibility
and authority for ensuring that the management system related to quality is implemented
and followed. The Quality Manager has direct access to the highest level of management
where decisions are taken on laboratory policy or resources.
Details:
This statement notifies all laboratory personnel that the Quality Manager is authorized by
senior management and the President to administer all activities relating to the Chemtech-
Ford Laboratories quality system. A formal announcement to the laboratory and
appropriate certification/regulatory authorities will be made if a change is made to the
person filling this position.
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J) Managerial Substitutions
Policy:
Deputies for key personnel are appointed to fulfill the key personnel’s duties in their
absence.
Details:
In the absence of the Lab Director, the Quality Manager or Deputy Lab Director will
assume his/her responsibilities.
In the absence of the Quality Manager, the Lab Director will assume his/her
responsibilities.
In the absence of the Laboratory Supervisor, the Lab Director, Deputy Lab Director
and/or Quality Manager will assume his/her responsibilities.
Management is responsible for ensuring that current and/or increased workload
requirements are met. This includes making adjustments as a result of employee absence.
Only fully trained employees are utilized to fulfill the duties of personnel who are absent.
Evidence of a DOC for each specific analysis must be recorded prior to allowing the
employee to perform any testing in the laboratory. If sufficient human resources are not
available, management will identify the best possible solution to meet operational
requirements.
K) Awareness
Policy:
Management ensures that its personnel are aware of the relevance and importance of their
activities and how they contribute to the achievement of the objectives of the
management system.
Details:
Supervisors review the details of each employee’s job description with the appropriate
employee and how the overall Quality Policy Statement (Section 4.2.2) relates to their
activities to achieve the objectives of the management system.
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4.1.6 Communication Processes
Policy:
Top management ensures that appropriate communication processes are established
within the laboratory and that communication takes place regarding the effectiveness of
the management system.
Details:
Management meetings are held regularly. Assignments and important communications
are made in this meeting. The appropriate manager communicates the assignment or
communication to their direct reports. These meetings are documented and follow-up
activities are recorded.
Revision History
Changes from Revision 26
Modified section 4.1.3 to include all of the facilities of the company rather than just the
main facility.
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4.2 Management System
Section Synopsis
This section tells you that our Management System (or Quality Management
System) is based on:
1. A well-defined quality policy statement
2. Say what you do through documentation
3. Do what you say following your documentation
4. Record what you did
Key Words
Establish, Implement, and Maintain
Policies, Systems, Processes, Programs, Procedures, Instructions
Communicate, Understand
Quality Policy Statement
Quality Manual
SOP
Test Method
Cross-references
ISO 17025:2005 Section 4.2
ISO 9001:2000 Section 4.1, 4.2.1, 4.2.2, 5.1, 5.3, 5.4.1, 5.4.2, 5.5.1, 5.5.2, 6.2.1,
7.1
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4.2.1 Policies and Procedures
Policy:
The Quality Management System is established, implemented, and maintained by
management. It is applicable to all the fields of testing and activities in which the
laboratory is involved and undertakes. All policies, systems, programs, procedures and
instructions are documented to the extent necessary to enable the laboratory to assure the
quality of results generated. These documents are communicated to, understood by,
available to, and implemented by the appropriate personnel.
Details:
The purpose of our Quality Management System is to ensure that all services and
products satisfy the customer’s requirements and have been designed, tested, and
delivered under controlled conditions.
The effectiveness of the Quality Management System is assessed in several ways:
by a program of planned internal audits, covering all aspects of the operation of the
quality management system
by regular management reviews of the suitability and effectiveness of the quality
management system
by analysis of potential and actual problems as shown by customer complaints and
supplier and subcontractor assessments
by other methods approved from time to time by the appropriate authority.
This Quality Manual and associated documents (including procedures) and records serve
as the quality plan for the laboratory. Other documents and records may include:
standard operating procedures (SOPs)
quality control plans in test methods
organizational charts
proposals
project management schemes
Equipment manuals
Reference methods
Regulations
Accreditation standards
Software
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4.2.2 Quality Policy Statement
Policy:
The policies and objectives for laboratory operations are documented in this Quality
Manual. The overall objectives are set out in the Quality Policy Statement and reviewed
during management review. The Quality Policy Statement is issued under the authority of
the Senior Management on the effective date.
Quality Policy Statement:
To ensure accurate and timely analytical services and to continuously meet or exceed the
stated or implied expectations of our customers through day-to-day interactions.
Effective Date: February 15, 2016
a) Management commitment to good professional practice and quality of services
provided to the customer: tests and calibrations are always carried out in accordance with
stated standardized methods and customers’ requirements. Requests to perform tests that
may jeopardize an objective result or have a low validity are rejected, or the laboratory’s
concerns are noted in the certificate of analysis.
b) Standards of service include:
 Customer Satisfaction
 Accuracy
Timeliness
Compliance with applicable standards and procedures
Excellence in the workplace is promoted by providing all employees with the knowledge,
training, and tools necessary to allow for the completion of accurate and timely work.
c) Purpose of management system related to quality: to manage our business by meeting
the needs of our customers and the requirements of the applicable standards and
procedures.
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d) Personnel: familiarize them with quality documentation and implement the policies
and procedures in their work.
e) Management is committed to complying with the applicable standards and regulations
(e.g. TNI, ISO, OGWDW etc.) and to continually improve the effectiveness of the
management system: the objective of this Quality Manual is to document the compliant
policies and associated procedures that are integrated into our daily activities. Continual
improvements are established, implemented, and locked into the management system.
Additional objectives include:
to establish the level of the laboratory’s performance
to make test method changes to improve performance
to participate in proficiency testing or quality evaluation programs with peer
laboratories
to ensure that all personnel are trained to a level of familiarity with the quality
management system appropriate to the individual’s degree of responsibility
to improve and validate laboratory methodologies by participation in method
validation collaborative tests
to establish and report on quality savings
4.2.3 Commitment to the Management System
Policy:
Top management is committed to the development and implementation of the
management system and continually improving its effectiveness.
Details:
The results of the management system are regularly reviewed during management review
(see Section 4.15) and continual improvements are made as outlined in Section 4.10 –
Improvements.
4.2.4 Communication of Requirements
Policy:
Top management communicates to the organization the importance of meeting customer
requirements as well as statutory and regulatory requirements.
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Details:
In general, the underlying message in all oral and written management communications
involves meeting the aforementioned requirements. Meeting customer requirements
ensures that ongoing business relationships secure the contracts that keep everyone
employed. Meeting statutory and regulatory requirements ensures that laboratory
operations will not be disrupted and the organization can continue to meet customer
needs.
4.2.5 Quality Manual
Policy:
This Quality Manual outlines the structure of the documentation used in the quality
management system. This Quality Manual makes reference to supporting procedures
including technical procedures and is maintained up to date.
Details:
This quality management system is structured in three tiers of documentation. The tiers
are as follows:
I. Quality Manual
II. Standard Operating Procedures and Test Methods
III. Records
For most customers, this Quality Manual and the associated documents form a general
Quality Plan. If necessary, specific Quality Plans will be prepared on a ‘per-customer’
basis. These Quality Plans will modify the general requirements stated in the Manual and
associated documents.
All of the above documents are controlled documents. Not all quality system documents
and procedures are maintained in this manual, rather some are referenced and located in
other documents. The following records and directive documents are contained or
referenced in the Quality Manual:
organizational chart (section 4.1.5.E)
identification of resources and management review (section 4.15.1)
job descriptions (section 5.2.4)
statistical techniques (section 5.9)
test reports (section 4.13.2 and 5.10)
identification of the laboratory’s approved signatures (section 5.10.2)
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laboratory’s scope of tests (section 4.1.3)
equipment inventory and records (sections 5.5.4 and 5.5.5)
calibration status indicators (section 5.5.8)
reference standards inventory (section 5.6.3)
verification records (section 5.9)
quality control plan / criteria for workmanship (section 5.4.1)
corrective action records (section 4.11)
preventive action records (section 4.12)
customer complaint records (section 4.8.1)
audit schedule and records (section 4.14.3)
procurement and subcontracting records (sections 4.6 and 4.5.4)
training records (section 5.2.5)
master list of documentation (section 4.3.2)
confidentiality agreements (section 4.1.5 C)
contract review (section 4.4.2)
validation of test methods (section 5.4.5)
facility floor plan (section 5.3.1)
4.2.6 Change Management
The roles and responsibilities for change management are outlined in QSP 4-2-6.
4.2.7 Technical Management and the Quality Manager
The roles and responsibilities for technical management and the Quality Manager are
outlined in section 5.2.5 of this manual.
Technical management ensures that section 5 of this manual is implemented and
maintained. The Quality Manager ensures that section 4 of this manual is implemented
and maintained.
4.2.8 Maintenance
Policy and Details:
Top management ensures that the integrity of the management system is maintained
when changes to the management system are planned and implemented.
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Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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4.3 Document Control
Section Synopsis
This section tells you that Document Control involves:
1. Writing good procedures
2. Getting them to the users
3. Keeping procedures good
Key Words
Controlled Document
Master List
Unique Identification
Revise
Revision Number
Effective Date
Review and Approval
Obsolete
Archive
Hand-written changes
Cross-references
ISO 17025:2005 Section 4.3
ISO 9001:2000 Section 4.2.1, 4.2.3, 4.2.4
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4.3.1 Policies and Procedures
Policy:
The SOP# QSP 4-3-1 is used to control all quality management system documents
(internally generated and from external sources). These include documents of external
origin, such as regulations, standards, other normative documents, test and/or calibration
methods, as well as drawings, specifications, instructions, and manuals.
Details:
Document means any information or instructions including policy statements,
procedures, specifications, charts, text books, posters, notices, memoranda, software,
drawings, and plans. These may be in various media, whether hard copy or electronic and
they may be digital, analog, photographic or written.
The documents to be controlled include:
Quality Manual
Standard Operating Procedures and test methods
Forms
Standards
Software manuals
Reference methods and manuals
Equipment manuals
Applicable regulations/statutes
The control of data related to testing and calibration is covered in section 5.4.7. The
control of records is covered in section 4.13.
4.3.2 Document Approval and Issue
4.3.2.1 Review / Approval / Master List
Policy and Details:
All documents issued to personnel in the laboratory as part of the quality management
system are reviewed and approved for use by authorized personnel prior to issue (i.e.,
reviewed by personnel knowledgeable in the documented activity and then approved by
management). A master list can be obtained by viewing the lists located on the Chemtech
Quality Manager and the SOP database for performance based methods, or intranet under
the SOP section. The categories are divided by folders. Each folder has a hyperlinked list
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of the SOPs. A listing of document revision is posted on the announcement area of the
Chemtech Document Archive tab. A revision history is maintained. Documents are
formally reviewed periodically to ensure their continuing suitability.
4.3.2.2 Availability and Obsolete Documents
Policy and Details:
The master list shows the current status of all controlled documents. The master list
document is organized with the following information:
Document Title
Effective Date
Revision Number
Method Reference (if applicable)
Date of last review
Controlled documents are approved before issue.
The SOP# QSP 4-3-1 for document control ensures that:
authorized editions of appropriate documents are available at all locations where
operations essential to the effective functioning of the laboratory are performed
documents are periodically reviewed and where necessary revised to ensure
continuing suitability and compliance with applicable requirements
invalid or obsolete documents are promptly removed from all points of issue or use to
assure against unintended use
obsolete documents retained for either legal or knowledge preservation purposes are
suitably marked (i.e., “INACTIVE" and dated) and/or archived appropriately.
4.3.2.3 Identification
Policy and Details:
All quality management system documentation is identified by:
date of issue and/or revision number
page numbering
total number of pages (e.g., page 5 of 5)
issuing authority (i.e., reviewer approval)
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4.3.3 Document Changes
4.3.3.1 Review / Approval
Policy:
Changes to documents are reviewed and approved by the same function (i.e., personnel or
position) that performed the original review.
Details:
Developments in policies and procedures require documents to be changed from time to
time. Changes to documents receive the same level of review and approval as the
originals.
The Quality Manual is reviewed annually by the Quality Manager. Records are kept of
this review.
Test methods and SOPs are reviewed on a biennial basis. Procedures for this are outlined
in SOP# QSP 4-3-1.
Obsolete documents are withdrawn, but are retained for archive purposes and clearly
labeled as obsolete.
4.3.3.2 Identification of Changes
Policy:
The nature of document changes is identified in the document.
Details:
As outlined in SOP# QSP 4-3-1.
In general, the nature of changes is identified in the document by changing the font color
to blue. Revision history is recorded at the end of the document.
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4.3.3.3 Amendments by Hand
Policy and Details:
Hand-written amendments to documents are permitted only by those personnel
authorized to do so (see section 4.1.5 A). Amendments are clearly marked, initialed, and
dated. A revised document is formally re-issued at the time of the annual review. For
further details refer to SOP# QSP 4-3-1.
4.3.3.4 Computerized Documents
Policy and Details:
The SOP# QSP 4-3-1 details how changes in documents maintained in computerized
systems are made and controlled.
Revision History
Changes from Revision 24
None
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4.4 Review of Requests, Tenders, and Contracts
Section Synopsis
This section tells you that you must:
1. Clearly understand customer requirements
Key Words
Requirements
Subcontractor
Request
Tender
Contract
Review
Cross-references
ISO 17025:2005 Section 4.4
ISO 9001:2000 Section 5.2, 6.1, 7.2.1, 7.2.2, 7.2.3
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4.4.1 Policies and Procedures
Policy:
Prior to the commencement of any services that fall within the scope of this Quality
System, Chemtech-Ford will ensure that the scope of the work is clearly defined and that
the objectives of the project can be met. In some cases, the requests are formalized
through a statement of work and signed contract. Other cases require less formalized
contracts. In all instances Chemtech-Ford formalizes a contract between the laboratory
and the client. The lab ensures that:
a) the customer requirements including the methods to be used are adequately defined,
documented and understood (see section 5.4.2)
b) the laboratory has the capability and resources to meet the requirements
c) the appropriate test method is selected and capable of meeting the customer’s
requirements (see section 5.4.2)
When practicable, any differences between the request or tender and the contract are
resolved before any work commences. Each contract must be acceptable by both the
laboratory and the customer.
Details:
The review of capability establishes that the laboratory possesses the necessary physical,
personnel, and information resources, and that the laboratory’s personnel have the skills
and expertise necessary for the performance of the tests in question. The review may also
encompass results of earlier participation in inter-laboratory comparisons or proficiency
testing and/or the running of trial test using samples or items of known value in order to
determine uncertainties of measurement, limits of detection, and confidence limits.
Some contracts are formalized through a bidding process, RFP etc. Some contracts are
less formal. When a formal process initiates the work, the specifications of the project
are agreed upon and programed into the LIMS. When appropriate contracts are signed by
necessary parties.
All work orders at Chemtech-Ford Laboratories are considered contracts between the lab
and the customer. After logging the sample(s) into the LIMS and after a login review is
performed by the lab, a login summary of requested analyses is submitted to the customer
for their review. The customer is informed of tests to be performed including test
method, subcontracted work, conditions of samples upon receipt and any other anomaly
that might have an adverse effect on the results of the analyses. The customer is
requested to review the work order for accuracy and note any discrepancies to the lab in a
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timely manner. If the customer does not reply in a timely manner, Chemtech-Ford
Laboratories proceeds with the work. For some analyses, the lab is required to start work
immediately (e.g. short holding times or rush analyses). The customer has the ability to
stop this work as needed.
The contract review ensures that each customer’s requirements are adequately defined
and documented in a timely manner. This should ensure that any order, once accepted,
can be completed without delay, and that the customer’s requirements including delivery
date, technical specification can be met.
Typical types of contracts include:
approved service quotations
confidentiality agreements
 non-disclosure agreements
 sample submission requests
 memorandum of agreement
 memorandum of understanding
 research proposals and contracts
 verbal orders (oral agreements)
 activity plans
4.4.2 Records of Review
Policy:
Records of request, tender and contract review, including significant changes, are
maintained. Records of pertinent discussions with a customer relating to the customer’s
requirements or the work during the period of execution of the contract are also
maintained.
Details:
Records of request is made by the client via chain-of-custody. Alternative requests may
also be made through other mechanisms (e.g. email). In the event that an alternative
mechanism besides the chain-of-custody is used for a request, such documentation is
retained. After samples have been entered into the LIMS and reviewed for correctness, a
summary of the requested work is sent to the client via email to verify the accuracy of
their request compared to Chemtech-Ford Laboratories interpretation of the request.
Chemtech-Ford Laboratories assumes that the request is accurate unless the client
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informs us otherwise. If there is a discrepancy, the change is noted and documented in
the LIMS or chain-of-custody.
Other work may demand more complex and formalized contract review. These contracts
are maintained by Chemtech-Ford Laboratories and the client. Formal contracts should
be stored in the project in LIMS. The LIMS project can be customized for most of the
project requirements such as pricing, analyte lists, reporting limits, QC limits, report
format, report recipients, etc.
When a formal contract is entered into between the lab and the client, the appropriate lab
member of management must sign the contract (usually the Vice President or their
designee). The person responsible for managing the project ensures that all of the aspects
of the project can be met. That person coordinates the project plan and execution of the
project with the appropriate laboratory staff. They also communicate any problems
meeting the client objectives to the client and will advise the lab how to proceed.
4.4.3 Review of Subcontracted Work
Policy:
Request, tender, and contract review also includes work that is subcontracted by the
laboratory.
Details:
Subcontractor laboratories are reviewed as described in section 4.5. Performance based
methods developed by Chemtech-Ford Laboratories are not subcontracted.
4.4.4 Notification of Customer
Policy and Details:
Customers are informed of deviations from the contract. This is typically communicated
to the customer prior to the performing the deviation.
4.4.5 Contract Amendment
Policy and Details:
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If a contract needs to be amended after the work has commenced, the same contract
review process is repeated and any amendments are communicated to all affected
personnel.
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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4.5 Subcontracting of Tests and Calibrations
Section Synopsis
This section tells you that we must:
1. Know what tests and calibrations need to be done by another laboratory
2. Check out the other laboratories
Key Words
Competence
Register of Subcontractors
Assessment
Cross-references
ISO 17025:2005 Section 4.5
ISO 9001:2000 Section 7.2.3, 7.4.1, 7.4.3, 8.2.4
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4.5.1 Subcontractor Competence
Policy:
Performance based methods developed by Chemtech-Ford Laboratories are not
subcontracted unless directed by the client. Work that must be subcontracted is done so
to a technically competent laboratory due to:
unforeseen circumstances
workload
project specifications/requirements
contracts requiring some extra technical expertise
Details:
The subcontracted laboratory demonstrates technical competence by possession or receipt
of one or more of the following:
recognized technical accreditation (e.g. TNI, ISO, EPA etc.)
satisfactory performance of appropriate quality control check samples, certified
reference material, in-house reference material or replicate analysis
audit of the subcontractor’s quality management system by our auditors
It is the responsibility of the Quality Manager to assess and approve the competence level
of subcontractor laboratories. The approved subcontract laboratories are maintained in
Quality Manager.
4.5.2 Customer Approval
Policy:
Customers are advised of work (or any portion thereof) that is being subcontracted to
another laboratory and their approval is obtained (preferably in writing).
Details:
Customers are advised of subcontracted work through the contracting process (see 4.4).
4.5.3 Assurance of Subcontractor Competence
Policy:
If the laboratory selects the subcontracted lab, then the laboratory is responsible to the
customer for the subcontractor’s work. Technical competence of subcontractor
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laboratories is demonstrated through various records including accreditation records from
the laboratories Accreditation Body. There may be circumstances where the customer
specifies which subcontractor is to be used. In such cases we may not be able to
demonstrate the competence of the subcontractor and therefore are not responsible for the
results.
Details:
Records of subcontractor competence can include, but are not limited to, the following:
accreditation certificates or documentation
registration certificates
check sample results
audit results
approval by the Quality Manager
approval by the client
4.5.4 Subcontractor Register
Policy:
A register of all subcontractors performing tests and calibrations is maintained in Quality
Manager or within the project records.
Details:
The approved register of subcontractors is maintained by the applicable Accreditation
Body or in the project records.
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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4.6 Purchasing Services and Supplies
Section Synopsis
This section tells you that we must:
1. Know what we want
2. Check out our suppliers
Key Words
Selection
Verify
Specifications
History
Cross-references
ISO 17025:2005 Section 4.6
ISO 9001:2000 Section 6.3.1, 7.4, 7.5.5, 8.2.4
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4.6.1 Policies and Procedures
Policy:
The SOP# QSP 4-6-1 is used to select and purchase services and supplies. The SOP#
QSP 4-6-1 is used for procurement, reception, and storage of supplies.
Details:
Consumable materials are stored according to the appropriate test method, SOP, or work
instruction.
4.6.2 Specifications
Policy:
Only services and supplies of the required quality are used. These quality requirements
are detailed in laboratory SOPs under the “Equipment and Supplies” and “Reagents and
Standards” sections and will identify the appropriate minimum specifications when
necessary.
Details:
Packing slips are checked against package content labels and matched with the Purchase
Order if accepted. Once accepted, the packing slip is dated and initialed as evidence of
compliance. Certificates of analysis (COA) are scanned and maintained on file in the
LIMS or other appropriate area after the COA is checked to ensure the received item
meets minimum specifications.
Chemicals are purchased with manufacturer’s certificates where possible. Uncertified
chemicals are purchased from ISO 9000 registered companies. Whatever the source, the
laboratory verifies the quality of the standards by comparing the new batch of standards
to the old. Due regard is paid to the manufacturer’s recommendations on storage and
shelf life.
Reagents are generally purchased from manufacturers who have a quality management
system based on ISO 9000. The grade of any reagent used (including water) is stated in
the method together with guidance on any particular precautions to be observed in its
preparation or use.
Where no independent assurance of the quality of procured goods or services is available
or the supplier’s evidence is insufficient the laboratory ensures that purchased goods and
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services comply with specified requirements. Where possible and practical the laboratory
ensures that goods are inspected, calibrated, or are otherwise in compliance with any
standard specification relevant to the calibrations or tests concerned.
4.6.3 Purchasing Documents
Policy:
Purchasing requests are recorded on the Purchase Order form and contain data describing
the product ordered. The Purchase Order is reviewed and approved for technical content
prior to release.
Details:
The description may include type, class, grade, precise identification, specifications,
drawings, inspection instructions, other technical data including approval of test results,
quality required and quality management system standard under which they were
produced.
The completion of the Purchase Order is the responsibility of the originator or supervisor.
Either reviews the Purchase Order for accuracy and approve the technical content prior to
release with their signature and the date.
4.6.4 Approved Suppliers
Policy:
Suppliers of critical services are evaluated and approved before use. An approved
supplier list is maintained.
Details:
Audits or tender evaluation is conducted to qualify suppliers of critical services prior to
use. The criteria for evaluation may include, but is not limited to the following:
references
accreditation
formal recognition
The records are maintained by purchasing personnel.
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Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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4.7 Service to the Customer
Section Synopsis
This section tells you that we must:
1. Facilitate clarification of the customer’s request
2. Give customer access to relevant testing area
3. Maintain customer contact
4. Inform customer of delays or deviations
5. Utilize customer surveys
Key Words
Clarification
Deviations
Delays
Customer Satisfaction Survey
Cross-references
ISO 17025:2005 Section 4.7
ISO 9001:2000 Section 6.1, 7.2.1, 7.2.3, 7.4.3, 7.5.1
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4.7.1 Service
Policy:
Customer requests are clarified for the customers or their representatives. Furthermore,
the customer or their representative will be afforded the right to monitor the performance
of the laboratory in relation to the work performed, provided that the laboratory ensures
confidentiality to other customers.
Details and Procedures:
Service to the customer includes:
Affording the customer or the customer’s representative reasonable access to relevant
areas of the laboratory for the witnessing of work performed for the customer; it is
understood that such access should not conflict with rules of confidentiality of work
for other customers or with safety.
Maintaining of open contacts. The customer values advice and guidance in technical
matters, and opinions and interpretations based on results. Contact with the customer,
especially in large assignments, should be maintained throughout the work. The
laboratory should inform the customer of any delays or major deviations in the
performance of the tests.
4.7.2 Feedback
Policy and Details:
The laboratory seeks feedback from the customer. Positive and negative feedback can be
obtained passively through ongoing communications with the customer (e.g., review of
test reports with customers) or actively through customer satisfaction surveys. The
feedback is used to improve the quality management system, testing activities, and
customer service.
One mechanism Chemtech-Ford Laboratories has established is a database that allows for
the entry of customer feedback (both positive and negative). The database categorizes
each item of feedback. When a laboratory representative receives feedback from a client
or other interested party, this should be reported in the database. When feedback requires
an action this is documented and assigned to the appropriate team member for review.
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Other mechanisms are in place to review customer feedback. During weekly
management meetings, customer feedback is reviewed (positive and negative).
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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4.8 Complaints
Section Synopsis
This section tells you that you must:
1. Maintain records of Complaints
2. Maintain records of Corrective Action
Key Words
Resolving
Investigation
Corrective Action
Follow-up Verification
Cross-references
ISO 17025:2005 Section 4.8
ISO 9001:2000 Section 7.2.3
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4.8.1 Policies and Procedures
Policy:
The SOP# QSP 4-8-1 is used for resolving complaints received from customers or other
parties. Records are maintained of all complaints and follow-up.
Details:
Records of complaints include the following information:
description of the complaint
investigation
corrective action (if necessary)
solution notes and date
follow-up verification
issuance level
See also section 4.11.
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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4.9 Control of Nonconforming Testing and Calibration Work
Section Synopsis
This section tells you that you must:
1. Stop testing when nonconforming work is identified
2. Determine what is causing nonconforming work
Key Words
Nonconforming
Root Cause
Cross-references
ISO 17025:2005 Section 4.9
ISO 9001:2000 Section 5.5.1, 7.4.3, 7.5.1, 8.2.4, 8.3, 8.5.3
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4.9.1 Procedures to Control Nonconforming Work
Policy:
The SOP# QSP 4-9-1 is used to control any aspect of testing and/or calibration work, or
the results of this work, when they do not conform with the test methods or the agreed
requirements of the customer.
Details:
The procedure ensures that:
Responsibilities and authorities for the management of nonconforming work are
designated and actions (including halting of work and withholding of test reports as
necessary) are defined and taken into consideration when nonconforming work is
identified
an evaluation of the significance of the nonconforming work is made
correction is taken immediately, together with any decision about the acceptability of
the nonconforming work
where necessary, the customer is notified and the work is recalled
the responsibility for authorizing the resumption of work is defined
Identification of nonconforming work or problems with the quality management system
or with testing activities can occur at various locations within the quality management
system and technical operations such as:
customer complaints
quality control
instrument calibration
checking of consumable materials
staff observations or supervision
test report checking
management reviews
internal or external audits
4.9.2 Root Cause Analysis
Policy:
Where evaluation indicates that nonconforming work could recur or that there is doubt
about the compliance of the laboratory’s operations with its own policies and procedures,
the corrective action procedures given in 4.11 are followed to identify the root cause(s) of
the problem and to eliminate this (these) cause(s). All notes, discoveries, and actions
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taken by participating personnel are to be reflected on the corrective action form. The
QM directs this process and retains all documentation within the appropriate files for
future reference. These corrective action documents will be stored for five years.
Details:
The SOP# QSP 4-11-1 outlines the recording of the root cause analysis for investigating
nonconforming work.
Situations warranting corrective action investigation include:
failure to comply with test method including all applicable procedures necessary to
ensure the integrity and representative nature of the sample
presentation of uncertain knowledge as to compliance with test methods including all
applicable procedures necessary to ensure the integrity and representative nature of
the sample
failure or suspected failure in method performance as demonstrated by results
provided by quality control samples
lack of relevant evidence provided by quality audit, proficiency testing, or customer
feedback
lack of relevant evidence provided by data validation
neglect to check the inherent property of the sample that compromises the testing
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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4.10 Improvements
Section Synopsis
This section tells you that you must:
1. Review procedures for improvements
2. Continually implement improvements
Key Words
Continually
Effectiveness
Analysis of data
Cross-references
ISO 17025:2005 Section 4.10
ISO 9001:2000 Section 6.1, 8.1, 8.2.1, 8.4, 8.5.1
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4.10.1 Policies and Procedures
Policy:
The laboratory continually improves the effectiveness of its management system through
the use of the quality policy, quality objectives, audit results, analysis of data, corrective
and preventive actions, and management review.
Details:
The laboratory has implemented a continual improvement philosophy within the
management system. Every employee in the laboratory is encouraged to suggest new
ideas for improving services, processes, systems, productivity, and the working
environment.
Opportunities for improvement of operations and processes are identified by managers on
a continual basis from ongoing feedback on operations and through management reviews.
Opportunities for improvement of services are identified by anyone within the
organization including Sales, and Marketing.
Inputs for improvement opportunities may be obtained from the following sources:
customer satisfaction surveys and any other customer feedback
market research and analysis
employees, suppliers, and other interested parties
internal and external audits of the management system
records of service nonconformities
data from process and service characteristics and their trends
Opportunities for improvement may also be identified on a special project basis. The
following are listed only as examples:
improving usefulness of bench space
reducing excessive inspection/testing
reducing excessive handling and storage
reducing test/calibration failures
Opportunities for improvement from daily feedback on operational performance (i.e.,
internal audits, customer feedback, test/calibration failures) are evaluated by the
Technical or Quality Manager. Typically, they are implemented through the corrective
and preventive action system.
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Opportunities for improvement from analysis of longer-term data and trends are
evaluated and implemented through the management review process. They are prioritized
with respect to their relevance for achieving quality objectives. When opportunities for
improvement are no longer supported by the current policy and objectives, management
will establish new quality objectives, and possibly change the policy. The process for this
evaluation is described in Section 4.15. Longer-term improvement projects are initiated
through the management review process, as well as the corrective and preventive action
system.
Service improvement opportunities are evaluated by management. They are implemented
through the supervisor of the laboratory who ensures that the improvements are validated
as outlined in Section 4.12 of this manual and appropriate level of quality control is
performed on an ongoing basis.
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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4.11 Corrective Action
Section Synopsis
This section tells you that you must:
1. Identify problems
2. Determine why the problem occurred
3. Fix the cause of the problem
4. Verify that your changes worked
Key Words
CAR
Root Cause
Monitor
Audit
Nonconforming work
Cross-references
ISO 17025:2005 Section 4.11
ISO 9001:2000 Section 5.5.1, 5.5.2, 8.1, 8.2.2, 8.2.3, 8.4, 8.5.2, 8.5.3
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4.11.1 General
Policy:
The SOP# QSP 4-11-1 is utilized for implementing corrective action when
nonconforming work or departures from policies and procedures in the quality
management system or technical operations have been identified. The procedure requires
that appropriate authority be designated for the implementation of corrective actions and
includes cause analysis, selection and implementation of corrective action, and
monitoring of actions.
Details:
Problems with the quality management system or technical operations of the laboratory
may be identified through a variety of activities, such as control of nonconforming work,
internal or external audits, management reviews, feed-back from customers, or staff
observations.
Corrective action investigations are documented and required changes to operational
procedures are implemented. The corrective action request (CAR), investigation and
resolution are recorded in the CAR database.
4.11.2 Cause Analysis
Policy:
Corrective action always begins with an investigation to determine root cause(s) of the
problem (see SOP# QSP 4-11-1).
Details:
Potential causes of the problem could include customer requirements, the samples,
sample specifications, methods and procedures (see 4.11.6), personnel skills and training,
consumable materials, or equipment and its calibration.
4.11.3 Selection and Implementation of Corrective Actions
Policy and Details:
After determining the cause(s) of the problem, potential corrective actions are identified.
The most likely action(s) (this includes practical and/or reasonable) are selected and
implemented to eliminate the problem and to prevent recurrence. It should be noted that
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any corrective actions taken to eliminate the cause(s) of nonconformities or other
departures are to a degree appropriate to address the magnitude of the problem and
commensurate with the risks encountered (Note – in plain language, this means
determine whether the benefit outweighs the cost). Controls are applied to prevent
recurrence. The laboratory documents and implements the required changes resulting
from corrective action investigations.
4.11.4 Monitoring of Corrective Action
Policy:
After implementing the corrective action(s), the laboratory monitors the results to ensure
that the actions taken have been effective in overcoming the problems originally
identified.
Details:
Monitoring is assigned to an appropriate individual such as the originator of the CAR or
the originator’s manager. Changes resulting from corrective action are documented.
4.11.5 Additional Audits
Policy:
Where the identification of nonconformities or departures casts doubts on compliance of
policies, procedures, regulations, international quality standards, the appropriate areas of
activity are promptly audited in accordance with section 4.14.
Details:
Special audits follow the implementation of corrective actions to confirm their
effectiveness. A special audit is only necessary when a serious issue or risk to the
business is identified. Special audits are carried out by trained and qualified personnel
who are [whenever resources permit] independent of the activity to be audited. See
section 4.14 for more details.
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4.11.6 Responsibility
Policy:
Analytical data routinely generated by the laboratory is evaluated to determine
acceptability, including precision and accuracy. Laboratory analyst and supervisors are
responsible for evaluating QC in comparison to acceptance criteria.
Details:
When data falls outside of the established control limits or acceptance limits for a given
method (as defined by the SOP), that information is evaluated and appropriate action
taken. If a problem is discovered that could merit corrective action, the person that
discovers the problem should discuss with the Quality Manager the need to initiate a
formal corrective action. All Chemtech-Ford Laboratories employees can recommend
corrective action. If it is determined that the problem merits corrective action, the
Quality Manager will initiate the corrective action.
Revision History
Changes from Revision 24
None
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4.12 Preventive Action
Section Synopsis
This section tells you that you must:
1. Identify potential problems
2. Determine why the problem could occur
3. Fix the cause of the potential problem
4. Verify that your changes worked
Key Words
PAR
Potential Nonconformity
Action Plan
Cross-references
ISO 17025:2005 Section 4.12
ISO 9001:2000 Section 4.2.4, 6.3.1, 8.4, 8.5.1, 8.5.2, 8.5.3
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4.12.1 Preventative Action Identification
Policy:
Opportunities for needed improvement and potential sources of nonconformities, either
technical or with the quality management system shall be identified. If action is required,
action plans are developed, implemented and monitored, to reduce the likelihood of
occurrence of such nonconformities and to take advantage of the improvement
opportunities.
Details:
Records of preventive action include the following information:
details of potential nonconformities
investigation
preventive action
follow-up verification
4.12.2 Preventive Action Plans
Policy:
The preventive action procedure includes the initiation of such actions and application of
controls to ensure that they are effective.
Details:
Preventive action may result from the review of operational procedures and analysis of
data. Analysis of data includes trend analysis, analysis of proficiency testing results, and
risk analysis.
Preventive actions can be designated and documented in the Corrective Action database
or in management meeting notes or other approved laboratory mechanism for
recording/monitoring preventive actions.
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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4.13 Control of Records
Section Synopsis
This section tells you that you must:
1. Identify the records to be kept
2. Keep identified records in a useful state
3. Destroy records when they are no longer needed
Key Words
Collection
Indexing
Access
Storage
Maintenance
Disposition
Legible
Traceable
Retrievable
Secure
Cross-references
ISO 17025:2005 Section 4.13
ISO 9001:2000 Section 4.2.4, 6.3, 6.4, 7.1, 7.5.1, 7.5.2, 7.5.3, 8.1, 8.2.2, 8.2.3,
8.2.4
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4.13.1 General
4.13.1.1 Procedures
Policy:
The SOP# QSP 4-13-1 is used to identify, collect, index, access, file, store, maintain,
protect, backup, and dispose quality and technical records. Quality records include
reports from internal audits and management reviews as well as corrective and preventive
action records.
Details:
Records are available to demonstrate conformance to requirements and effective
operation of the Quality Management System. Quality records from suppliers are also
controlled.
All records, including test reports, are safely stored and held secure (either electronically
or physically), and in confidence to the customer. Records are maintained in the
designated archival area for five (5) years.
4.13.1.2 Record Integrity
Policy:
All records are to be legible and shall be retained in such a way that they are readily
retrievable in facilities that provide a suitable environment to prevent damage or
deterioration and to prevent loss.
Details:
The retention times for records are generally set at five (5) years. Records may be in the
form of any type of media, such as hard copy or electronic media.
4.13.1.3 Record Security
Policy:
All records are held secure and in confidence.
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Details:
Access to records is secured through locked rooms, filing cabinets, passwords.
4.13.1.4 Record Backup
Policy:
The SOP# QSP 4-13-1 is followed to protect and backup data/records held on computers
at all times and to prevent unauthorized access to or amendment of data/records on
computers.
Details:
Data is password protected.
Backups ensure integrity and availability of data/information in the event of a
system/power failure.
4.13.2 Technical Records
4.13.2.1 Record Information
Policy:
Original observations, calculations, derived data and sufficient information to establish an
audit trail, calibration records, personnel records and a copy of each test report issued are
retained for five (5) years.
The records for each test or calibration shall contain sufficient information to facilitate, if
possible, identification of factors affecting the test uncertainty and to enable the test or
calibration to be repeated under conditions as close as possible to the original. The
records include the identity of personnel responsible for sampling, performing of each
test and/or calibration and checking of results.
Details:
Technical records are accumulations of data (see 5.4.7) and information that result from
carrying out tests and/or calibrations and which indicate whether specified quality or
process parameters are achieved. They may include forms, contracts, work sheets, work
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books, note books, instrument printouts, magnetic media, check sheets, work notes,
control graphs, test reports, calibration certificates, customer’s notes, papers and
feedback, and test reports to customers.
The records for each test contain sufficient information to permit its repetition. Records
include:
date of sampling
sample receipt
sample handling, storage, and disposal
identification of personnel
analyst proficiency
equipment identification and performance
calibration records
media performance, where appropriate
test organism batch # or lot #, where appropriate
results
reports (mailed, emailed, or faxed)
review
Note – the above records may be stored in separate locations. They are cross-referenced
for easy retrieval.
4.13.2.2 Recording
Policy:
Observations, data, and calculations are clearly and permanently recorded and
identifiable to the specific job at the time they are made.
Details:
Handwritten records must be legible and made with indelible ink immediately after an
observation, after data is collected and/or after calculations are made.
4.13.2.3 Corrections to Records
Policy:
Changes to test data are made so as not to obscure or delete the previous data entry.
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Details:
Mistakes are crossed out with a single line, initialed, dated and the correct value entered
alongside. Mistakes are not erased, made illegible, or deleted. All alterations to records
are signed or initialed by the person making the correction. In the case of computer-
collected data, similar measures are taken to avoid loss or change of original data.
4.13.2.4 Transfer of records
Policy:
Records will be maintained or transferred in the event that a laboratory transfers
ownership or goes out of business.
Details:
In the event that the laboratory changes ownership, all records will be transferred to the
new owners. The new owner(s) will then be given the responsibility of maintaining the
records.
If the laboratory goes out of business, all hard copy and electronic records will be
maintained by the ownership group at the time of the dissolution of the company for a
period of 5 years.
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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4.14 Internal Audits
Section Synopsis
This section tells you that:
1. Trained internal auditors examine your internal operations for quality
2. Auditors report the results to those in charge
3. You must correct any areas that need fixing
Key Words
Schedule
Elements
Independent
Nonconformity
CAR
Cross-references
ISO 17025:2005 Section 4.14
ISO 9001:2000 Section 8.1, 8.2.2, 8.2.3
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4.14.1 Internal Audit Program
Policy:
The internal audit program involves periodic audits conducted according to a
predetermined schedule for each year. Each year different aspects of the Quality System
are evaluated. The schedule is reviewed during the managerial review. All elements of
the management system including the testing activities are covered on a regular basis.
These audits are performed to verify operations continue to comply with the requirements
of this Quality Manual and are effective.
Details:
The tracking of internal audit results is maintained in Quality Manager. The frequency is
also maintained in Quality Manager. The Quality Manual, test procedures, and
laboratory results are verified for compliance. It is the responsibility of the Quality
Manager to plan and organize audits as required by the schedule and requested by
management. Audits are carried out by trained and qualified personnel who are [wherever
resources permit] independent of the activity to be audited. Personnel are not to audit
their own activities except when it can be demonstrated that an effective audit will be
carried out (see also 4.11.5). Audits are performed through the aid of a checklist prepared
in advance to minimize the possibility of overlooking any details during the audit. The
results of the internal audit are maintained and accessible.
Generally, the types of audits include:
quality management system
technical methods
products, services, and reports
4.14.2 Corrective Action
Policy:
When audit findings cast doubt on the effectiveness of the operations or on the
correctness or validity of test or calibration results, timely corrective action is taken and
customers are notified if investigations show that laboratory results may have been
affected.
Details:
Nonconformities that can be resolved easily are to be corrected immediately, ideally
during the audit. Records are made on the audit checklist. Nonconformities that require a
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more involved resolution are recorded on a CAR and resolved as described in section
4.11.
Corrective actions and customer notifications must be kept on record for each audit
deviation that casts doubt as described in this section.
4.14.3 Records and Management
Policy:
Records are made of the activity being audited, the audit findings, and corrective actions
that arise. Management ensures that corrective actions are discharged within an
appropriate and agreed timeline.
Details:
A report is prepared by the auditors and distributed to those audited and/or the area
manager/supervisor within an appropriate and agreed timeline. The audit report may
include the following sections, as appropriate:
audit objective and scope
area or section audited
personnel involved – auditors and auditees
date of audit
reference documents
observations including nonconformities and commendations
opening and closing meetings
recommendations
audit report distribution
The appropriate manager is responsible for ensuring that corrective actions are
sufficiently recorded. Follow-up is performed by the auditor and recorded when
corrective action is complete and deemed effective. The audit records are kept in the
laboratory.
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4.14.4 Follow-up Audits
Policy:
Follow-up audits are performed to verify and record the implementation and
effectiveness of the corrective action taken.
Details:
The follow-up audit is performed at a mutually acceptable time between the area
implementing corrective action and the auditor. This time is determined when the CAR is
issued.
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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4.15 Management Reviews
Section Synopsis
This section tells you that management must:
1. Periodically review technical competence and customer satisfaction
2. Keep records of reviews
3. Ensure follow-up is executed
4. Measure progress
Key Words
Supervisor Reports
Audit Reports
CAR / PAR
Proficiency Results
Customer Satisfaction Survey
Resources
Cross-references
ISO 17025:2005 Section 4.15
ISO 9001:2000 Section 5.1, 5.4.2, 5.6, 6.2.1, 7.1, 8.5.1
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4.15.1 Review of Quality Management System and Testing
Policy:
Top management periodically (at least annually) and in accordance with a predetermined
schedule and SOP# QSP 4-15-1, conduct a review of the laboratory’s quality
management system and testing and/or calibration activities to ensure their continuing
suitability and effectiveness and to introduce any necessary changes or improvements.
Details:
The review takes account of:
suitability of policies and procedures (including the Quality Policy outlined in this
manual)
reports from managerial and supervisory personnel
the outcome of recent internal audits
corrective and preventive actions
assessments by external bodies
results of inter-laboratory comparisons or proficiency tests
changes in the volume and type of work undertaken
feedback from customers, including complaints and customer satisfaction surveys
recommendations for improvement
other relevant factors, such as quality control activities, resources and personnel
training
A minimum period for conducting a management review is once a year. Results of the
review feed into the laboratory planning system and include goals, objectives and action
plans for the coming year.
A management review can be supplemented by consideration of related subjects at
regular management meetings.
4.15.2 Findings, Actions, and Records
Policy and Details:
Findings from management reviews and the actions that arise are recorded in the minutes
of the meeting. Management will ensure that the actions are discharged within an
appropriate and agreed upon timeline.
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Revision History
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Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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5.1 General
Section Synopsis
This section informs you that:
1. Many factors contribute to the correctness and reliability of tests and/or
calibrations
2. The laboratory must account for these factors
Key Words
Correctness
Reliability
Uncertainty
Cross-references
ISO 17025:2005 Section 5.1
ISO 9001:2000 Section 7.1, 7.5.1
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5.1.1 Correctness and Reliability
Policy and Details:
Correctness and reliability of the tests and/or calibrations performed have many
contributing factors including:
Human factors (see section 5.2)
Accommodation and environmental conditions (see section 5.3)
Test and calibration methods and method validation (see section 5.4)
Equipment (see section 5.5)
Measurement traceability (see section 5.6)
5.1.2 Measurement Uncertainty
Policy:
When developing test and calibration methods and procedures, total measurement
uncertainty must be accounted for in the training and qualification of personnel, and in
the selection and calibration of equipment.
Details:
The extent to which the factors contribute to total measurement uncertainty differs
between tests, matrices, methodologies.
See section 5.4.6 for more details.
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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5.2 Personnel
Section Synopsis
This section tells you that management:
1. Analyzes training needs
2. Provides training to employees for them to do their jobs
3. Qualifies people performing specific tasks
Key Words
Competence
Qualification
Authorize
Training Needs
Job Description
Registry of Skills
Cross-references
ISO 17025:2005 Section 5.2
ISO 9001:2000 Section 5.5.1, 6.2.1, 6.2.2, 7.5.1, 7.5.2
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5.2.1 Competence and Qualification
Policy:
Management ensures the competency of all employees including specific equipment
operators, those performing tests and/or calibrations, those evaluating results and signing
test reports. Appropriate supervision is provided for employees undergoing training.
Personnel performing specific tasks are qualified on the basis of appropriate education,
training, experience and/or demonstrated skills, as required.
In addition, personnel responsible for the opinions and interpretations included in test
reports also have:
Relevant knowledge of the technology used in the performance of analyses, materials,
products tested, or the way they are used or intended to be used and of the defects or
degradation that may occur during sampling, analysis, or use.
Knowledge of the general requirements expressed in the legislation and standards.
An understanding of the significance of deviations found with regard to the normal
use of the items, materials, or products concerned.
Details:
Management defines the minimum levels of qualification and experience necessary for
all posts within the laboratory. The educational and experience requirements for various
laboratory positions are listed in the following sections:
5.2.1.1 Laboratory Director – The minimum requirements for the technical director are:
Bachelor’s degree in the chemical, environmental, biological sciences, physical
sciences or engineering with at least twenty-four (24) college semester credit
hours in chemistry and at least two (2) years of experience in the environmental
analysis of representative inorganic and organic analytes for which the
Chemtech-Ford Laboratories seeks or maintains accreditation. A master’s or
doctoral degree in one of the above disciplines may be substituted for one (1)
year of experience.
For microbiological analyses the technical manager must have a minimum of an
associate’s degree with at least four (4) college semester credit hours in general
microbiology when the laboratory is engaged in microbiological analysis
limited to fecal coliform, total coliform, E. coli and standard plate count. In
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addition, the person shall have one (1) year of experience in microbiological
analyses.
If the laboratory maintains a scope beyond fecal coliform, total coliform, E. coli
and standard plate count, then the technical director must have a bachelor’s
degree in microbiology, biology, chemistry, environmental sciences, physical
sciences or engineering with a minimum of sixteen (16) college semester credit
hours in general microbiology and biology and at least two (2) years of
experience in the environmental analysis of representative analytes for which
the laboratory seeks or maintains accreditation. A master’s or doctoral degree
in one of the above disciplines may be substituted for one (1) year of
experience.
5.2.1.2 Quality Manager - The minimum requirements for the quality manager are:
Bachelor’s degree and 2 years of experience in environmental laboratory
analysis/operation or an associate’s degree and 4 years of experience in
environmental laboratory analysis/operation. Understanding of quality systems
including QA/QC. Understanding of laboratory operations. Strong
communication skills including to work with a variety of staff and management
5.2.1.3 Supervisor - The minimum requirements for a laboratory supervisor are:
A bachelor’s degree plus one-year work experience in a certified environmental
laboratory or in a laboratory that the prospective supervisor demonstrates as one
that substantially meets equivalent quality standards for a certified laboratory;
or
An associate’s degree in the biological, chemical, or physical sciences from an
institution of higher education, plus four years work experience in a certified
laboratory or in a laboratory that the prospective supervisor demonstrates as one
that substantially meets equivalent quality standards for a certified laboratory.
The supervisor must demonstrate competency to supervise testing in the areas
over which they supervise.
5.2.1.4 Technical Employees - The minimum requirements for technical laboratory
employees vary as to position and job requirements. The education requirements
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differ based on the job assignments. In general, the requirements are:
A bachelors degree in the biological, chemical, or physical sciences from an
institution of higher education; or
An associates degree in the biological, chemical, or physical sciences from an
institution of higher education; or
A high school degree.
Continued competence is monitored through the use of blind performance evaluation
samples and Demonstrations of Competency. Where this is not achieved, the need to
retrain personnel is considered. Where a method or technique is not in regular use,
verification of personnel performance before they undertake tests, may be necessary.
5.2.2 Training Policies and Procedures
Policy:
Management will formulate the goals with respect to the education and the skills of the
laboratory personnel. The training program is relevant to the present and anticipated tasks
of the laboratory. SOP# QSP 5-2-1 is utilized to identify training needs and providing the
necessary training for personnel.
Details:
The skills and knowledge are defined in the job description for each job function as
described in section 5.2.1. Management compares the job description to the skills and
knowledge of the new incumbent to determine the training needs.
5.2.2.1 QA Program - Chemtech-Ford, Inc. provides easy access to controlled copies of
this “quality assurance program” as written within this document for all employees
of this laboratory.
5.2.2.2 Training Files - Chemtech-Ford, Inc. maintains training files for all employees
involved with data generation and reduction. The training files contain the
following sub-files:
Job description (minimum qualifications, experience, and skills
defined).
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Analytical qualification documentation “Demonstrations of
Capability,” (DOC’s). DOCs are neither appropriate nor required
for the analyses of Odor, Color, and Paint Filter Test. Also
alternatively, duplicate checks of capability are performed for
Dissolved Oxygen, Flashpoint, and all microbiological analyses.
Training attendance sheets.
SOP reading documentation.
Certificates, degrees, etc.
Signed “Ethics Statement.”
Training in the laboratory must include all methods or parts of methods and techniques
that personnel are asked to perform. Minimally, the analyst must demonstrate
competency through observation by management and verification using replicate and/or
check samples. For technicians who perform only parts of the method, confirmation of
competency may be verified by observation only. Re-verification of all personnel must be
performed annually on all methods or techniques pertinent to their job description by use
of blind performance evaluation samples and/or Demonstrations of Competency tests.
5.2.3 Employees
Policy:
Competent permanent or contractual employees are employed in the laboratory. The
technical manager ensures that contractual, additional technical employees, and key
support personnel are supervised and work in accordance to the policies and procedures
of this Quality Manual.
Details:
Testing must be either performed or supervised by an experienced person qualified by the
experience and/or degree level requirements from section 5.2.1.
5.2.4 Job Descriptions
Policy:
Current job descriptions for managerial, technical and key support personnel involved in
tests and/or calibrations are maintained centrally in the administration area of the
laboratory.
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Details:
Minimum contents of job descriptions include:
The duty of performing tests.
The act of planning tests and evaluation of results.
The responsibility of developing and validating new methods as / when requested.
Expertise and experience.
Qualifications and training programs.
Managerial duties.
5.2.5 Key Personnel and Responsibilities
Policy:
Chemtech-Ford, Inc. complies with the managerial staff requirements as identified and
required by “Utah Rule R444-14-8.”
Details:
Key Personnel include the following listed positions:
5.2.5.1 Authority and Interrelationships – The laboratory has designated the following
lines of authority:
CEO
President – Reports to CEO
Executive Vice President reports to President
Vice President, Quality Manager, Laboratory Director report to Executive
Vice President
Deputy Lab Director report to Lab Director
Section Manager reports to Lab Director or Deputy Lab Director
Team Leader reports to Section Manager
Analysts & Technicians report to Team Leader
These lines of authority may have exceptions (e.g. there may not be a Team Leader and
the analyst/technician may report to a Section Manager. The organizational chart is
reviewed and updated (as needed) at least semi-annually (or more frequently as needed).
5.2.5.2 Laboratory Director - The Laboratory Director is responsible for the
administrative oversight and overall technical operation of the laboratory. The
laboratory director will:
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Define minimum qualifications, experience, and skills necessary for all
technical employees.
Ensure and document through an annual competency check that each
technical employee demonstrates initial and on-going proficiency for the
tests performed by that employee.
Review the Quality Managers audit findings and document such reviews.
Oversee laboratory technical and support staff.
Review and approve all new and existing analytical procedures.
Review and approve all deviations from normal analytical protocols.
Review external and internal quality control audits and all other relative
documentation/information.
Perform final review and approval of new laboratory projects including
reports and documents.
Nominate deputies in case of temporary absence. Unless otherwise
specified, the QM or deputy Lab Director will serve as acting laboratory
director in the director's absence.
Review laboratory resources and capabilities prior to accepting new non-
routine project work that may affect or adversely tax the present capacity of
the laboratory.
Ensure that subcontracted laboratories are capable and appropriately
certified for analytical work sent to them.
5.2.5.3 Quality Manager (QM) - The QM reports directly to the executive team. The QM
has the responsibility for the quality system and its implementation (See Section 6
of the QM). The Quality Assurance Officer will:
Have direct access to the highest level of management at which decisions
are taken on laboratory policy and resources, and to the laboratory director.
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Serve as the focal point for quality assurance and oversee and review quality
control data.
Have functions independent from laboratory operations for which he or she
has quality assurance oversight.
Have documented training or experience in quality assurance procedures
and be knowledgeable in the quality assurance requirements of Utah Rule
R444-14; also be knowledgeable in the quality systems.
Have knowledge of the approved methods used by the laboratory in order
to accurately evaluate laboratory performance.
Objectively evaluate data and objectively perform assessments without
undue influence.
Oversee all quality aspects of sample handling, testing, and report
generation.
Schedule, oversee, and be responsible for reviews of the entire technical
operation of the laboratory. This includes conducting annual technical
audits.
Arrange, when available, analytical participation in inter-laboratory
comparisons and proficiency testing programs. For purposes of qualifying
for and maintaining accreditation, the QM shall arrange for participation
in an external proficiency test program according to Utah Rule R-444-14
and as identified in the Quality Systems of NELAP.
Notify laboratory management of deficiencies in the quality system and
monitor corrective actions (ensure managers review all corrective actions
initiating from their areas of concern, using corrective action reports as
references during QA training meetings).
Serve as the back-up to the Laboratory Director in the absence of the
Laboratory Director.
5.2.5.4 Laboratory Area Supervisors - These managers are responsible for the day-to-
day operation of the laboratory. Their responsibilities include:
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Supervise all technical and non-technical employees.
Be responsible for the production and quality of all data reported by the
laboratory.
Review and approve analytical data generated within the area.
Develop and submit new methods and operating procedures for approval by
the Laboratory Director.
Evaluate instrument and personnel needs.
Ensure that all samples are accepted, analyzed, and reported in accordance
with laboratory SOPs.
5.2.5.5Technical Staff - Technical personnel, generally, are responsible for the routine
receipt, analysis and reporting of all laboratory samples. The technical staff will:
Report directly to the assigned supervisor.
Perform duties in accordance to laboratory policy and procedures.
Read, understand, and follow the Quality Manual and all appropriate SOPs.
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5.2.6 Laboratory Organizational Chart
The official organizational structure is contained in Quality Manager.
5.2.7 Staff Management Policies
Policy:
Management authorizes specific personnel to perform particular types of testing, to issue
test reports, to give opinions and interpretations and to operate particular types of
equipment. Records of the relevant competence, educational and professional
qualifications, training, skills and experience of all technical personnel and contracted
personnel are maintained. This information is readily available and includes the date on
which authorization and/or competence was confirmed and the criteria on which the
authorization is based and the confirming authority.
Details:
5.2.7.1 Confidentiality
Each employee shall read, understand, and acknowledge that the analytical work
performed in the laboratory demands a high degree of confidentiality. In a practical
sense, this has to do with the potential communication of laboratory procedures and
analytical results to clients, regulatory agencies, and other interested parties. All
employees should understand that analytical data legally belongs to the client
who contracted such work.
5.2.7.1.1 Telephone Correspondence
A request for analytical results via telephone should be verified by requesting
the name of the requestor (and as applicable the phone number, FAX number,
e-mail address, or mailing address) before releasing data. It should be clear that
the contracting client is the same as the client requesting the data. For any data
request from a client other than the contracting client, the contracting
client must approve its use by the requesting client before release. Such
permission must be documented (requestor, contracting client, date and time of
request, staff member taking request) and placed in the client data file.
5.2.7.1.2 E-mail and FAX Correspondence
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Similar guidelines to 5.2.7.1.1 apply to requests for results transmitted by e-
mail or FAX. Chemtech-Ford, Inc. will keep electronic records of e-mail/FAX
requests and reports for 5 years.
5.2.7.1.3 "In-Person" Requests
Similar guidelines to 5.2.7.1 apply to clients who appear at the laboratory in
person and request analytical data or other laboratory documentation. Copies
of such reports or documentation may be released only after determining that
the requestor is the contracting party, or has written permission from the
contracting party to release the data.
5.2.7.1.4 Statement of Confidentiality
Each employee shall sign a Confidentiality Agreement, which describes the
understanding of such laboratory confidentiality and acknowledges the
penalties for failing to follow established laboratory procedures regarding
confidentiality.
5.2.7.2 Improper, Unethical, and Illegal Actions
It is the policy of Chemtech-Ford, Inc. and its employees to perform their duties
in a consistently legal and ethical manner. A high level of ethical behavior is
characterized by, but not limited to, dealing honestly and forthrightly with all
clients and co-workers, maintaining data integrity, open and timely treatment of
inaccurate, invalid, or misreported analytical data, and abiding by all pertinent
rules, regulations, company policies, and standard operating procedures.
Deliberate violations of such behavior will result in disciplinary action up to and
including termination, the consequences of which could additionally lead to direct
liability and legal action against the responsible individual.
It is the responsibility of each Chemtech-Ford, Inc. employee to report any
observed violation of this policy. This observation may result from a visual or
studied review of protocol, generated data, or reported information. Laboratory
management will review the evidence of any such reported violation;
confirmation that such a violation occurred will result in severe disciplinary
action, up to and including termination and possible legal action.
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Serious violations of Chemtech-Ford, Inc.'s ethical policy include, but are not
limited to, the following:
Changing a reported value in the LIMS database without proper support of
documentation;
Intentionally misrepresenting data generated by instrument or calculation;
Recording invalid or otherwise altered data to make the analysis conform to
"expected" levels;
Recording invalid or otherwise altered data at someone else's suggestion or
insistence;
Recording invalid or otherwise altered data to satisfy quality assurance
acceptance criteria;
Manually integrating chromatographic data to satisfy quality assurance
acceptance criteria;
Withholding information that was noted during sample receipt or analysis;
Purposefully destroying a sample prior to the completion of analysis; and
Willfully circumventing the sample disposal Standard Operating Procedure.
Each Chemtech-Ford, Inc. employee is required to participate in a training session
within two weeks of employment. The training will include Chemtech-Ford’s
ethical policies, examples of unethical behaviors, and penalties for non-
compliance. The new employee will be required to sign an attestation statement
as a condition of employment which will again define Chemtech-Ford’s policies
and penalties.
Each year, or more frequently if needed, each Chemtech-Ford, Inc. employee is
required to attend ethical training to review company policies and penalties. At
the conclusion of the training, each employee will be required to sign an
attestation called an Ethical Attestation Statement that summarizes the
employee's ethical and legal responsibilities. This Statement acknowledges that
penalties exist for deliberately violating this policy.
In order to promote an atmosphere of integrity, management will reiterate at
routine staff meetings the importance of reporting discovered errors and the
insistence that such reporting will not necessarily result in personal punishment,
even though the company may suffer financially.
Furthermore, management will institute internal proficiency testing (blind and
double blind samples) where applicable; QC meetings whose emphasis is on
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appropriate and inappropriate laboratory technique and instrument/data
manipulation will be held routinely to address this topic.
5.2.7.2 Manual Integration
In keeping with Chemtech-Ford’s policy of producing data of the highest possible
quality, integrations performed in the laboratory must be generated by fully
calibrated instruments and not altered in an unsubstantiated manner.
Improper manual integrations performed for the purposes of meeting quality
control criteria or any other reason are not allowed. Such unsubstantiated
integrations are subject to possible disciplinary action by laboratory management.
If a manual integration is necessary, the integration produced after manual
integration shall both be labeled and present in the raw data package. The intent
is to demonstrate the results of the integration are appropriate and according to
good laboratory practices. It is recommended that a short explanation be provided
if an unusual integration has to be made (e.g. for unusual tailing due to matrix
effect).
All manual integrations are subject to strict scrutiny to ensure that they are
performed appropriately. Analysts are advised that they must be prepared at any
time to defend a manual integration. When there is a question to the validity of the
manual integration by the analyst, then they should discuss the integration with
their supervisor. Supervisors should regularly review the manual integrations of
employees.
Manual integrations are noted in the raw data package. Typically, these are
denoted by an “m” next to the integrated area or concentration.
5.2.7.3 Undue Pressure
An appropriate working atmosphere will be provided at Chemtech-Ford, Inc. so
that all employees will be free from any commercial, financial, or other undue
pressures, which might adversely affect the quality of their work.
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If a Chemtech-Ford, Inc. employee feels that his or her work has been affected
by undue pressure of any sort, the following recourses are available:
5.2.7.3.1 The employee may report the source of the pressure(s) affecting lab
performance to his or her supervisor, or to the laboratory director or
owner if the employee believes notifying the supervisor will be
ineffective or problematic; and/or
5.2.7.3.2 The employee may generate a Corrective Action Form. This form will
specify those requests, behaviors, or other pressures, which adversely
affect the quality of the employee's work. The form will then follow
normal review channels through the laboratory in order to be resolved.
5.2.7.4 Validation of Employee Qualifications
It is the responsibility of Chemtech-Ford, Inc. management to ensure that
all employees have demonstrated capability in the activities for which they
have been hired and are responsible. This includes verification that a
potential employee possesses all of the technical, organizational, and
communication skills prior to employment; and that, once hired, each
employee continues to upgrade his knowledge and skills.
Each new employee is required to read, sign, and understand a
comprehensive employment documents provided at time of employment.
These documents verify the position's required skills as well as educating
the employee in all aspects of the company's operations and policies. This
documents include, but are not limited to containing:
An attestation that all educational qualifications and technical and
communication skills requirements have been fulfilled and reviewed
by management.
A Confidentiality Agreement.
An Ethics Statement.
A Harassment Prevention Policy.
An attestation that the employee has read, acknowledged, and
understood the Chemtech-Ford, Inc. Quality Manual.
An attestation that the employee has read, understood, and agreed to
perform the most recent version(s) of the test method(s) for which
the employee is responsible.
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Demonstrations of Capability for all technical competencies
required.
An explanation of the Chemtech-Ford, Inc. Laboratory Information
Management System (LIMS) and its functions.
New employees are apprised of all laboratory security systems and the
Training Files to be kept by each employee.
Specialized training sessions will be routinely held to 1) review current
policies and procedures; 2) institute new policies and procedures; 3) review
particular technical skills, Quality Assurance topics, or corrective actions;
and 4) institute cross training. These training sessions/courses will be
documented in each employee's training file.
Prior to the initiation and acceptance of test results from an employee on
any test method, satisfactory demonstration of capability is required.
Following the completion of all capability demonstration work, the initial
analytical work of any new employee will be carefully reviewed for
accuracy, thoroughness, and timeliness by the laboratory supervisor.
Correct and accurate entry of data into the LIMS will also be monitored.
Once the supervisor is satisfied of the technical competency of the new
employee, a less rigorous review of the employee's skills and generated data
will be required.
Records are held in Quality Manager.
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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5.3 Accommodation and Environmental Conditions
Section Synopsis
This section tells you:
1. That laboratory facilities are suitable for attaining correct performance of tests
and calibrations
2. Critical environmental conditions are monitored, controlled and recorded
3. Incompatible activities are separated
4. Access to laboratories is controlled
5. Good housekeeping is practiced
Key Words
Incompatible activities
Prevent cross-contamination
Controlled access
Cross-references
ISO 17025:2005 Section 5.3
ISO 9001:2000 Section 6.3, 6.4, 7.1, 7.5.1, 7.5.2, 7.6, 8.2.3
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5.3.1 Facility
Policy:
Laboratory facilities shall be appropriate to allow for the proper performance of
analytical testing. This may include, but not limited to, energy sources, lighting, heating,
ventilation and any other environmental conditions.
Appropriate care is taken to ensure that the environment does not invalidate the results or
adversely affect the required quality of any measurement. The technical requirements for
accommodation and environmental conditions that can affect the results of tests and
calibrations are documented.
Details:
This section deals with the test areas in the laboratory and premises for support such as
sample receipt and storage. Central laboratory supplies and services, such as water
purification systems, air supply, vacuum source, and sample storage, are appropriate to
facilitate proper performance of tests.
5.3.2 Monitoring
Policy:
Critical environmental conditions are monitored, controlled and recorded as required by
the relevant specifications, methods, and procedures or where they may influence the
quality of the results. Tests and calibrations are stopped when the environmental
conditions jeopardize the results of the tests and/or calibrations.
Details:
Laboratories are ventilated to reduce the levels of contamination, lower humidity, and
control temperature. Laboratories’ test areas are air-conditioned and the temperature is
20-25 °C.
Bench tops and floors are made of impervious, smooth easily cleaned materials. There is
at least two linear meters workspace per analyst while working. Walls and ceilings are
made of materials that are smooth and easily cleaned.
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5.3.3 Separation of Incompatible Activities
Policy:
Effective separation between neighboring areas is made when the activities are
incompatible. Measures are taken to prevent cross-contamination.
Details:
Reference materials and certified reference materials must be kept separated from
samples (log-in and storage). Sample log-in and storage must be segregated, ideally in a
separate area from the testing laboratory, and include proper sanitation to exclude the
possibility of cross-contamination. Segregation of activities is achieved through time and
space allocations.
5.3.4 Controlled Access
Policy:
Access to and use of areas affecting quality of the tests is defined and controlled.
Details:
Access to the laboratory is restricted to authorized personnel only. The authorized
personnel are made aware of the following items:
the intended use of the area
the restrictions imposed on working within such areas
the reasons for imposing the restrictions
5.3.4.1 Sample Receiving - The sample receiving area is designed to be independent of the
other laboratory areas. The sample receiving area is designed with a convenient
access from the out-of-doors. This access is controlled allowing security of the
laboratory and sample storage. The sample receiving area may also be used for
preparing and shipping of containers to clients.
5.3.4.2 Volatiles Laboratory - The volatiles laboratory is located within a climate controlled
area away from the main laboratory in order to eliminate solvent cross-contamination
from other areas of the laboratory. As with the main laboratory, access to this building
is limited to authorized personnel only. All GC/MS volatiles work is performed in
this area.
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5.3.4.3 Inorganic Chemistry Laboratory - The inorganic chemistry laboratory occupies
the largest of the lab area within the building. The area consists of a centrally
located spacious rooms equipped with several large benches for analytical work.
Conventional wet techniques such as gravimetric, colorimetric, titrimetric are
performed here. Several fume hoods are located within the rooms to provide ease
of sample preparation.
5.3.4.4 Wet Chemistry Laboratory - This laboratory is adjacent to the inorganic chemistry
laboratory and contains the necessary equipment required to perform various wet
chemistries (e.g., BOD, COD, and TSS).
5.3.4.5 Metals Laboratory - The metals analysis laboratory contains all of the metals
analytical equipment. However, samples are prepared for metals analysis in the
inorganic laboratory, thus reducing the possibility of instrument contamination. The
metals laboratory is designed for ICP, ICP/MS, and Hg cold-vapor instrumentation.
5.3.4.6 GC and Semi-Volatile GC/MS Laboratory - The preparation lab contains standard
fume hoods and ample bench space for sample extraction. The GC and Semi-volatile
GC/MS instrument laboratory has several benches with GC and GC/MS
instrumentation and supplies.
5.3.4.7 Microbiology Laboratory - The microbiology laboratory is a separate room that is
climate-controlled with ample bench space on which to perform the required
analytical procedures. The laboratory contains its own supplies and storage facilities
for ease of analysis and for prevention of contamination.
5.3.4.8 Sample Storage - Samples remaining in the sample analysis stream are located
within their respective holding areas (refrigerators, etc.) until required analyses
have been complete. Additional post-analysis storage for metals-preserved sample
bottles is accomplished via storage shelves located within the metals laboratory.
All other inorganic/organic samples are kept for a maximum of three months
(following data reporting) in refrigerated storage throughout the laboratory.
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5.3.5 Good Housekeeping
Policy:
Measures are taken to ensure good housekeeping in the laboratory. Special procedures
are followed when necessary.
Details:
Controlled use of cleaning and pest control materials is exercised. The laboratory
complies with the local health and safety requirements.
Revision History
Changes from Revision 25
Section 5.4.5.3 Title edited for grammar.
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5.4 Test Methods and Method Validation
Section Synopsis
This section tells you:
1. Preference is given to the use of a standard method when selecting
procedures
2. All methods must be validated before use
3. Measurement uncertainty is estimated
4. Data is controlled
Key Words
Standard Methods
Laboratory-Developed Methods
Non-standardized Methods
Validation
Uncertainty of Measurement
Data Checks
Cross-references
ISO 17025:2005 Section 5.4
ISO 9001:2000 Section 4.2.1, 4.2.3, 6.1, 6.3, 6.4, 7.1, 7.2.1, 7.2.2, 7.3, 7.4.3,
7.5.1, 7.5.2, 7.6, 8.1, 8.2.3, 8.2.4
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5.4.1 General
Policy:
Methods and procedures used for all tests and/or calibrations are appropriate as per:
sampling, handling, transport, storage, and preparation of items to be tested and/or
calibrated
an estimation of the measurement of uncertainty as well as statistical techniques for
analysis of test and/or calibration data where appropriate
Instructions on the use and operation of all relevant equipment and on the handling and
preparation of items for testing and/or calibration are available. All instructions,
standards, manuals and reference data relevant to the work of the laboratory are
maintained current and readily available to personnel. Deviation from test and calibration
methods must be documented, technically justified, authorized, and accepted by the
customer.
Details:
There are SOPs for sample handling, storage, preparation of test items, QA/QC
procedures (media QC, incubation times and temperatures, equipment calibration and
maintenance, process control QC), and standards for approving / rejecting results. These
may be combined with or separate from the method. The content of an environmental
(TNI) test method should include:
Applicable Matrices
Detection Limit
Method Scope
Method Summary
Definitions
Interferences
Safety
Equipment and Supplies
Reagents and Standards
Sample Collection, Preservation, Shipment and Storage
Quality Control
Calibration and Standardization
Procedure
Calculations
Method Performance
Changes to the Approved Method
Data Assessment and Acceptance Criteria
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Corrective Action & Contingencies for Out of Control Data
Pollution Prevention and Waste Management
References
Editorial Changes to SOP
Appendices
International, national, or regional standards or other recognized specifications that
contain sufficient and concise information on how to perform the tests and/or calibrations
are not necessarily supplemented or rewritten as an internal procedure when they are
written in a way that can be used as published by laboratory staff. Consideration may
need to be given to providing additional documentation for optional steps in the method.
5.4.2 Selection of Methods
Policy:
Test and/or calibration methods, including methods for sampling, meet the needs of the
customer and are appropriate for the tests and/or calibrations it undertakes. Preference is
given to reference methods published as international, national, or regional standards.
The laboratory ensures that the latest edition of a standard is used unless it is not
appropriate or possible to do so. When necessary, the standard is supplemented with
additional details to ensure consistent application.
Details:
Methods that have been published either in international, national, or regional standards,
or by reputable technical organizations, or in relevant scientific texts or journals, or as
specified by the manufacturer are selected when the customer does not specify the
method to be used. Methods may be adopted from but are not limited to the following
sources: EPA, Standard Methods, USP, AOAC, FDA BAM, USDA FSIS & AMS,
APHA SMEDP, APHA, AWWA, WEF, NELAC, TNI, Compendium of Methods for the
Microbiological Examination of Foods, ISO, ICMSF, National Food Processors,
American Association of Cereal Chemists, Association of Dressing and Sauces, Health
Canada, Environmental Protection Agency, OIE, and ASTM.
The ability of the laboratory to achieve satisfactory performance against documented
performance characteristics is verified before samples are analyzed.
Laboratory-developed methods or methods adopted by the laboratory may also be used if
they are appropriate for the intended use and if they are validated. The customer is
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informed as to the method chosen. The laboratory confirms that it can properly operate
standardized methods before introducing the tests or calibrations. If the standardized
method changes, the confirmation is repeated.
The customer is informed when the method proposed by the customer is considered to be
inappropriate or out of date.
5.4.3 Laboratory-Developed Methods
Policy:
Introduction of test and calibration methods developed internally is a planned activity and
is assigned to qualified personnel equipped with adequate resources. Plans are updated as
development proceeds and ensures effective communication among all personnel
involved.
Details:
Methods developed in-house are validated and authorized before use. Where available,
Certified Reference Materials (CRMs) are used to determine any systemic bias, or where
possible results are compared with other techniques, preferably based on different
principles of analysis. As applicable, determination of uncertainty is part of this
validation process and is essential for ongoing quality control.
5.4.4 Non-Standard Methods
Policy:
Utilization of non-standard methods is subject to agreement with the customer and
includes a clear specification of the customer’s requirements and the purpose of the test.
The developed method is validated appropriately before use.
Details:
Discussion and agreement for the use of non-standard methods is recorded as part of
contract review procedures (see section 4.4).
All non-standard and new tests are validated for their intended purpose. Qualitative test
methods must be validated to demonstrate estimated sensitivity and specificity, relative
accuracy to official methods (if appropriate), positive and negative deviation, limit of
detection, matrix effect, repeatability, and reproducibility.
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Quantitative test methods are validated to demonstrate specificity, sensitivity, relative
accuracy, positive and negative deviation, repeatability, reproducibility, and limit of
determination.
For new methods where procedures are developing rapidly, especially for emergency
situations, it may be necessary to circumvent normal validation procedures. Minimally,
this must be a demonstrated recovery in replicate.
New test and/or calibration methods are documented prior to providing test and/or
calibration results to customers and contain at least the following information:
appropriate identification
scope
description of the type of item to be tested or calibrated
parameters or quantities to be determined
apparatus and equipment, including technical performance requirements
reference standards and reference materials required
environmental conditions required and any stabilization period needed
description of the procedure, including:
affixing identification marks, handling, transporting, storing and preparing of
items
ensuring checks are made before the work is started
checking that the equipment is working properly and, where required, calibrating
and adjusting the equipment before each use
listing method of recording the observations and results
indicating any safety measures to be observed
criteria and/or requirements for approval/rejection (quality control plan)
data to be recorded and method of analysis and presentation
uncertainty or procedure for estimating uncertainty
5.4.5 Validation of Methods
5.4.5.1 Performance Characteristics
Policy:
Validation of a method establishes, by systematic laboratory studies, that the performance
characteristics of the method meet the specifications related to the intended use of the test
results.
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Details:
The performance characteristics of a validation plan includes, as applicable:
selectivity and specificity
range
linearity
sensitivity
limit of detection
limit of quantitation
accuracy
precision
reporting limit
repeatability
reproducibility
recovery
confirmation techniques
criteria for the number of samples tested to validate method as per defined scope of
method
action levels where defined by regulation
quality control incorporating statistics as applicable
Performance characteristics that are selected take into account the intended use of the
method, whether for screening, confirmatory analysis, or quantitation.
The design, verification of the method and documentation procedures for validation are
planned and conducted by qualified personnel, equipped with adequate resources.
This section lists a few acceptable validation procedures. The choice of the procedure
depends on the extent of the deviation from the published method.
Validation of methodology is a value judgment in which the performance parameters of
the method are compared with the requirements for the test data. A prerequisite for a
valid method is that data produced by the method must attain a state of statistical control.
Such a state is obtained when the mean value of a large number of individual values tends
to approach a limiting value called the limiting mean.
Methods may be validated by one or more alternative procedures. Some of these
procedures are described below. Apparent differences can be analyzed statistically to
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confirm their significance. In all cases, the reasons for choosing one or more alternatives
must be documented.
analysis of standard reference materials (SRM) that are identical or almost identical to
the test samples
in the absence of suitable SRMs, analysis of reference materials that are similar in all
respect to the test samples; the use and validity of this reference material must be
documented
using an alternative method to measure the same parameter provides a very high level
of confidence if results are confirmed
recovery studies by the addition of a known concentration of the parameter of interest
to some of the replicates being measured
The parameters to be determined include:
the scope of the method and any known interference
detection limit
the range of concentration where the method is valid
precision and bias
Judgment is required to determine if some or all of the above is required. Requirements
will depend largely on the extent of deviation from the original method.
Developments in methodology and techniques require methods to be changed from time
to time. The difference in performance between revised and obsolete methods is
established so that it is possible to compare old and new data.
Where a change in method involves only minor adjustments, such as sample size, or
different reagents, the amended method is validated and the changes brought to the
attention of the accreditation body at the next accreditation audit. Where the proposed
change involves technology or methodology, the laboratory seeks the approval of the
accreditation body.
Records are kept on all validation activities. The records include any of the performance
characteristics chosen, reference procedures or guidance documents followed to validate
the method or custom validation procedure, and a final confirmation (memo to file) that
the method validation results are acceptable for continued use of the method. An example
statement would be “This serves as record that the validation of the XYZ Test Method
has been approved for use by [name and title of approver]”.
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5.4.5.2 Fit for Use
Policy:
The laboratory validates non-standardized methods, laboratory-designed/developed
methods, standardized methods used outside their intended range, and amplifications of
standard methods to confirm that the methods are fit for the intended use. The validation
is as extensive as is necessary to meet the needs in the given application or field of
application (may include procedures for sampling, handling, and transportation). The
laboratory records the results obtained, the procedure used for the validation, and a
statement as to whether the method is fit for the intended use.
Details and Procedure:
Validation records are kept as in section 5.4.5.1. Included in these records is the
validation procedure. The procedure used for the validation is likely to vary between
different methods. Therefore, the procedures included in the laboratory records are not as
detailed as a typical SOP, but are sufficient enough to re-create how the method was
validated.
The techniques used for the determination of the performance of a method, are one of, or
a combination of, the following:
calibration using reference standards or reference materials
comparison of results achieved with other methods
inter-laboratory comparisons
systematic assessment of the factors influencing the result
assessment of the uncertainty of the results based on scientific understanding of the
theoretical principles of the method and practical experience.
When changes are made in the validated non-standard method, the influence of such
changes carried out is documented and if appropriate a new validation is performed.
5.4.5.3 Customer’s Needs
Policy:
The range and accuracy of the values obtainable from validated methods (e.g., the
uncertainty of the results, detection limit, selectivity of the method, linearity, limit of
repeatability and/or reproducibility, robustness against external influences and/or cross-
sensitivity against interference from the matrix of the sample/test object) as assessed for
the intended use is relevant to the customer’s needs.
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Details:
Validation includes the specification of the requirements, determination of the
characteristics of the methods, the comparison of the requirements with the values of the
characteristics of the method, and a statement on the validity.
As method development proceeds, regular review is required to verify that the needs of
the customer are still being fulfilled. Changing requirements requiring modifications to
the development plan are approved and authorized.
Validation is always a balance between costs, risks, and technical possibilities.
5.4.6 Uncertainty of Measurement
5.4.6.1 Calibration
Policy:
Physical, chemical, and biological standards are calibrated or characterized by qualified
subcontractors.
Details and Procedures:
Repeatability and reproducibility data are components of measurement uncertainty and
are determined as a first step towards producing estimates of this parameter. The
uncertainty of measurement may be made available on the certificate of analysis or
calibration certificate from a subcontractor.
Note – in-house calibrations include procedures for uncertainty of measurement
estimates where practicable.
5.4.6.2 Testing
Policy:
The SOP# QSP 5-4-1 is utilized to estimate uncertainties of measurement in testing,
except when the test methods preclude such rigorous calculations. In certain cases, it is
not possible to undertake metrologically and statistically valid estimations of uncertainty
of measurement. In these cases, the laboratory attempts to identify all the components of
uncertainty and make the best possible estimation, and ensure that the form of reporting
does not give an exaggerated impression of accuracy. Reasonable estimation is based on
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knowledge of the performance of the method and on the measurement scope and makes
use of previous experience and validation data.
Details:
The degree of rigor needed in an estimation of uncertainty of measurement depends on
factors such as:
requirement of the test method
requirement by the customer
if there are narrow limits on which decisions on conformity to a specification are
based
In cases where a well-recognized test method specifies limits to the values of the major
sources of uncertainty of measurement and specifies the form of presentation of
calculated results, the laboratory is considered to have satisfied the estimation uncertainty
of measurement by following the reporting instructions (see section 5.10).
5.4.6.3 Uncertainty Components
Policy:
When estimating the uncertainty of measurement, all uncertainty components that are of
importance in the given situation are taken into account using accepted methods of
analysis.
Details:
Sources contributing to the uncertainty include, but are not necessarily limited to, the
reference standards and reference materials used, methods and equipment used, the
environmental conditions, the item being tested or calibrated and the operator.
The predicted long-term behavior of the tested and/or calibrated item is normally not
taken into account when estimating the measurement uncertainty.
For further information, see ISO 5725 and the Guide to Expression of Uncertainty in
Measurement.
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5.4.7 Control of Data
5.4.7.1 Calculations and Data Transfers
Policy:
Calculations and data transfers are subject to appropriate checks in a systematic manner.
Details:
Test data are approved through the following arrangements by the QM, supervisor, lab
director, peer etc.:
checks to determine accuracy of calculations, conversions, and data transfers
checks for transcription errors, omissions, and mistakes
checks to determine consistency with normal or expected values
For those analyses where manual data reduction is required, it is performed according to
the instructions provided in the test method or SOP.
5.4.7.2 Computers and Automated Equipment
Policy:
When computers or automated equipment are used for the acquisition, processing,
manipulation, recording, reporting, storage or retrieval of test or calibration data, the
laboratory ensures that:
computer software developed by the user is documented in sufficient detail and
suitably validated or otherwise checked as being adequate for use
procedures are established and implemented for protecting the integrity of data; such
procedures include, but are not be limited to, integrity and confidentiality of data
entry or collection, data storage, data transmission, and data processing (see section
4.13.1.4)
computers and automated equipment are maintained to ensure proper functioning and
are provided with the environmental and operating conditions necessary to maintain
the integrity of test and calibration data
data is securely maintained by preventing unauthorized access to, and unauthorized
amendment of, computer records
Details and Procedures:
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Data generated using computer software programs that are interfaced directly to
instruments incorporates all dilutions and calculations, thereby eliminating the need for
manual data reduction.
Commercially developed software in general use within its designed application range
may be considered sufficiently validated. Laboratory software configuration /
modifications are validated as outlined in SOP# QSP 5-5-1.
It is the stated goal of Chemtech-Ford Laboratories to meet the requirement for
Electronic records, electronic signatures, and handwritten signatures executed to
electronic records as defined by 21 CFR. Part 11 (Docket No. 92NO251) RIN0910-
AA29; Federal Register: March 20, 1997, Volume 62, Number 54), Rules and
Regulations, pages 13429-13466. Chemtech-Ford is not now fully compliant, but records
of compliance evaluation are maintained and can be inspected upon request.
For details of the requirement see:
http://www.fda.gov/ora/compliance_ref/part11/
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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5.5 Equipment
Section Synopsis
This section tells you to:
1. Identify information needs for accept / reject decisions
2. Install equipment capable of providing that information
3. Use the equipment in the proper environment
4. Periodically check the equipment calibration
Key Words
Required Equipment and Accuracy
Authorized Personnel
Unique Identification
Inventory
Maintenance
Procedures
Out of Service
Calibration Status
Re-verification
Checks
Correction Factors
Safeguards against Adjustment
Cross-references
ISO 17025:2005 Section 5.5
ISO 9001:2000 Section 4.2.1, 4.2.3, 5.1, 6.2.2, 6.3.1, 7.1, 7.4, 7.5.1, 7.5.2, 7.5.3,
7.6, 8.1, 8.2.3, 8.2.4
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5.5.1 Required Equipment
Policy:
The laboratory is furnished with all items for sampling, measurement and test equipment
required for the correct performance of the tests and/or calibrations (including sampling,
preparation of test and/or calibration items, processing and analysis of test and/or
calibration data). When equipment is used outside the laboratory’s permanent control, it
ensures that the requirements of this Quality Manual are met.
Details:
Equipment is used in an environment appropriate to its proper performance. All
equipment required by a test is described in each method, including the equipment’s
tolerances.
A current list of equipment is maintained in Quality Manager.
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5.5.2 Required Accuracy
Policy:
Equipment and software used for testing, calibration and sampling are capable of
achieving the accuracy required and comply with specifications relevant to the tests
and/or calibrations concerned. Calibration programs are established for key quantities or
values of the instruments where these properties have a significant effect on the results.
When received, equipment, including that used for sampling, is checked to establish that
it meets the laboratory’s specification requirements, complies with the relevant standard
specifications, and is checked and/or calibrated in accordance with section 5.6 before use.
Details:
The procedures for checking newly received equipment are as determined by
manufacturers’ specification and/or those determined by the laboratory during
procurement.
5.5.3 Authorized Personnel
Policy:
Equipment is operated by authorized personnel. Up-to-date instructions on the use and
maintenance of equipment (including any relevant manuals provided by the manufacturer
of the equipment) are readily available for use by the appropriate laboratory personnel.
Details:
Access to laboratory equipment is controlled to ensure that only authorized personnel use
equipment.
5.5.4 Unique Identification
Policy:
Each item of equipment used for testing and calibration is uniquely identified when
practicable.
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Details:
Measuring and testing equipment is uniquely identified. Typical identification includes
instrument type, make, model, serial number or other unique markings. Measuring and
testing equipment includes any instrument that could affect the quality of test results.
Components that can be interchanged between various instruments are tracked in
equipment logbooks but are not assigned individual identification.
5.5.5 Inventory and Maintenance Records
Policy:
Records are maintained for each item of equipment significant to the tests and/or
calibrations performed. The records include the following:
identity of the item of equipment (and its software)
manufacturer’s name, type identification, and serial number and/or other unique
identification
Date received (if available)
Date placed into service (if available)
checks that equipment complies with the specification (see section 5.5.2)
current location, where appropriate
the manufacturer’s instructions, if available, or reference to their location
dates, results and copies of reports and certificates of all calibrations, adjustments,
acceptance criteria, and due date of next calibration
maintenance carried out to date and the maintenance plan (includes calibration)
damage, malfunction, modification or repair to the equipment
Analysts initials
Details:
A database is used to capture the above inventory information. The above information
related to service and maintenance is kept in Quality Manager. Other information
recorded may include:
date received and date placed in service
condition when received (e.g., new, used, refurbished)
dates and results of calibration and/or verification and date of next calibration and/or
verification
performance history, where appropriate (e.g., response time, drift, noise level)
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5.5.6 Equipment Procedures
Policy:
The SOP# QSP 5-5-1 is utilized as an established plan for safe handling, transport,
storage, use and maintenance (including calibration) of measuring equipment, and
appropriate use of correction factors to ensure proper functioning and in order to prevent
contamination or deterioration.
Note – additional procedures may be necessary when measuring equipment is used
outside the permanent laboratory for tests, calibrations, or sampling (currently not
applicable at our laboratory).
Details and Procedures:
The procedures for each piece of measuring equipment are located in the appropriate
room where the equipment is located. These procedures detail any information for safe
handling, transport, storage, use, and maintenance of measuring equipment.
5.5.7 Out of Service Equipment
Policy:
Equipment that has either been subjected to overloading or mishandling, or gives suspect
results, or has been shown to be defective or outside specified limits, is taken out of
service, clearly marked, and appropriately stored until it has been repaired and shown by
calibration or test to perform correctly.
Details:
Routine testing work is completely discontinued on equipment that even shows minor
nonconformances. Not only do we do this for ethical reasons in support of our customer,
but minor nonconformances are often indicative of major breakdowns in expensive
equipment. These breakdowns need to be avoided wherever possible.
Out of service equipment is clearly marked as outlined in section 5.5.8.
The laboratory examines the effect of the defect or departure from specified limits on
previous test and/or calibrations and institutes the “Control of Nonconforming Work”
procedure as outlined in section 4.9.
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5.5.8 Calibration Status
Policy:
Equipment requiring calibration is labeled to indicate the calibration status and/or
operational status and the date when re-calibration is due when appropriate.
Details:
Calibration labels have a write-on surface and a pressure sensitive adhesive. The areas
that are filled out include the person who performed the calibration, the date it was
performed, the date it is due for re-calibration, and the equipment’s identification
number.
Measuring equipment that has failed calibration or is deemed out of service is labeled
with one of the following labels:
A piece of equipment that is not calibrated or checked is labeled with the following label:
5.5.9 Return to Service
Policy:
When equipment goes outside the direct control of the laboratory for a period, the
laboratory ensures that the function and calibration status of the equipment are checked
and validated and shown to be satisfactory before the equipment is returned to service.
Details and Procedures:
The procedures used to check and ensure that the function and calibration status of the
equipment are satisfactory before the equipment is returned to service are outlined in the
CALIBRATION VOID
DO NOT USE
CALIBRATION
BY DATE
DUE ID#
OUT OF SERVICE
DO NOT USE
FOR REFERENCE ONLY
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manufacturer’s equipment manual. Any additional quality control checks are outlined in
the “Quality Control Plan” section of the appropriate test method.
5.5.10 Periodic Checks
Policy:
When intermediate checks are needed to maintain confidence in the calibration status of
equipment, these checks are carried out periodically according to defined procedure.
Details and Procedures:
As stated in section 5.5.6, the procedures for each piece of measuring equipment are
available on the laboratory computer network. SOP# QSP 5-5-1 outlines a general
maintenance plan for equipment and includes various checks. Internal quality control
checks are specified in individual test methods that are located in the appropriate
laboratory areas thereby providing procedures for intermediate checks.
5.5.11 Correction Factors
Policy
Calibrations that give rise to a set of correction factors are updated along with all copies
of this data (e.g., in computer software).
Details and Procedures:
The updating of correction factors, including all copies, is assured by following the
appropriate test method or SOP. It is the responsibility of the QM to ensure that all copies
are updated.
5.5.12 Safeguards against Adjustments
Policy:
Test and calibration equipment, including hardware and software, are safeguarded from
adjustments that invalidate test and/or calibration results/status.
Details:
Safeguards against adjustment for laboratory equipment include:
detailed SOPs and manufacturer’s manuals on the operation of the equipment
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policies permitting only fully trained and competent personnel to operate equipment
access to the laboratory is restricted to authorized personnel
Safeguards against adjustment for software includes:
password protection for important files and packages
access to the laboratory is restricted to authorized personnel
An electronic audit trail is maintained on for the changes made in the LIMS software
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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5.6 Measurement Traceability
Section Synopsis
This section tells you:
1. Measurements are traceable to SI units (when applicable)
2.Reference Standards and Reference Materials are used
Key Words
Systemèm International
Reference Standard
Reference Material
Traceability
Cross-references
ISO 17025:2005 Section 5.6
ISO 9001:2000 Section 6.3.1, 7.1, 7.5.1, 7.6
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5.6.1 General
Policy:
Test and/or calibration equipment for subsidiary measurements (e.g., for environmental
conditions) having a significant effect on the accuracy or validity of the result of the test,
calibration, or sampling are calibrated before being put into service. All measurement and
test equipment having an effect on the accuracy or validity of tests is calibrated and/or
verified before being put into service. As mentioned in section 5.5, the SOP# QSP 5-5-1
outlines an established program for the maintenance of equipment and includes calibration.
Details:
The program includes a system for selecting, using, calibrating, checking, controlling, and
maintaining:
measurement standards
reference standards used as measurement standards
measuring and test equipment used to perform tests and calibrations
Procedures are documented where appropriate. All measurements that play a defining role
in testing accuracy are based directly or indirectly on reference standards, reference
materials, certified reference materials, or other standards or materials having appropriate
traceability.
Records are maintained in the LIMS for each standard. These records include, as applicable:
supplier, grade, lot number, and concentration
dates of preparation or verification
measurement of weights, volumes, time intervals, temperatures, and pressures and
related calculations
relevant processes (e.g., pH adjustment, sterilization)
verification results
identification of personnel involved
Reagents prepared in the laboratory are labelled to identify substance, strength, solvent
(where not water), and date of preparation and/or expiry. The person responsible for the
preparation of the reagent is identified either from the label or from records.]
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5.6.2 Specific Requirements
5.6.2.1 Calibration
Policy:
The program for calibration equipment is designed and operated to ensure that calibration
measurements are traceable to the System International (SI) units of measurement.
Details:
Traceability of measurement is assured by the use of calibration services from laboratories
that can demonstrate competence, measurement capability and traceability. The calibration
certificates issued by these laboratories show that there is a link to a primary standard or to a
natural constant realizing the SI unit by an unbroken chain of calibrations. The calibration
certificates contain the measurement results including the measurement uncertainty and/or a
statement of compliance with an identified metrological specification (see also section
5.10.4.2).
Calibration laboratories accredited to ISO 17025 are considered competent to provide the
appropriate calibration services.
Traceability to SI units of measurement may be achieved by reference to an appropriate
primary standard or by reference to a natural constant the value of which, in terms of the
relevant SI unit, is known.
The term “identified metrological specification” means that it must be clear from the
calibration certificate against which specification the measurements have been compared
with, by including the specification or by giving an unambiguous reference to the
specification.
When the terms “international standard” or “national standard” are used in connection with
traceability, it is assumed that these standards fulfil the properties of primary standards for
the realization of SI units.
Maintain certificates of all reference standards, measuring equipment, or certified reference
material used in ensuring traceability. Where traceability to national standards of
measurement is not applicable, the laboratory provides satisfactory evidence of correlation
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of results, for example by participation in a suitable program of inter-laboratory
comparisons or proficiency testing.
Reference standards, such as thermometers and weights, are traceable to a national or
international standard (e.g., NIST).
5.6.2.1.1 Instrument Performance Evaluation
5.6.2.1.1.1 General calibration of laboratory instruments falls into two categories: 1)
calibration which is conducted on a routine basis as part of the analytical
procedure prior to each use; and 2) periodic, scheduled calibration of
instruments and gauges against known standards to ensure the continuing
precision and accuracy of such instruments.
5.6.2.1.1.2 All instrumentation must be demonstrably calibrated and evaluated for
appropriateness before analysis is initiated. Divergence from acceptable
benchmark criteria requires correction before analyses may be performed.
The instrument performance evaluation material may be a standard spiked into
the solvent used for analysis, but it is not extracted as if it were a sample.
5.6.2.1.2 Calibration
5.6.2.1.2.1 Generally, as applicable to the method, calibration curves are established for
each parameter using known concentrations of standards. At least three
different concentrations in non-interfering matrices, that span the range of
expected sample values are analyzed and plotted. Generally, a correlation
coefficient of better than 0.995 constitutes an acceptable calibration.
5.6.2.1.2.2 Method-specific calibration requirements are included in individual SOPs. In
this case, the analytical method will take precedence.
5.6.2.1.3 Continuing Calibration
5.6.2.1.3.1 Prior to use each day, the initial calibration must be verified. Typically, one of
the mid-point calibration standards are analyzed and the results are compared
to the expected results. If the results fall within the method acceptance limits,
then analysis can proceed. If the results are not within the acceptance limits,
then the problem must be corrected prior to analysis of samples. Some
methods require that samples be bracketed by valid opening and closing
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calibration standards. When bracketing is required, only results between
valid calibration verification standards can be used.
5.6.2.1.3.2 Reportable analytical results are those within the calibration range of the
parameter. In general, values above the highest standard are not reported.
The lowest reportable value is the MRL. Instrumental calibration will be
verified either initially and during sample analysis or at a rate that the
established method requires. The continuing calibration (may be substituted
by the check standard) is made with standards independent from that used for
instrumental calibration. The calibration check must agree within established
limits with the calibration or the instrument is re-celebrated. Continuing
calibration standards must agree within established limits of calibration. If
not, the cause of the discrepancy is identified, corrected, and documented.
5.6.2.1.4 Initial Calibration Verification (ICV)
5.6.2.1.4.1 An ICV is a well-characterized material that is run, at a minimum, with each
calibration. The material, which is obtained from a documented second
source. In order to assess the performance of the method, the ICV is run in
the same manner as the other calibration standards. If the results are not
within acceptable limits, the source of the problem is evaluated. Continual
failure indicates there is a problem with the system, the ICV standard or the
calibration standards. Prior to analysis, the ICV must pass method criteria.
A calibration check solution or sample material should be analyzed at least
each day of analysis to demonstrate that calibration and standardization of
instrumentation is within acceptable limits.
5.6.2.1.5 Calibration Policy
5.6.2.1.5.1 The calibration policies and procedures set forth in this section apply to all
instruments requiring scheduled calibrations against traceable standards,
including: analytical and test equipment in the laboratory, flow rate (e.g.,
rotometers), volume (e.g., dry gas meters), temperature measurement
equipment, balances, weights, thermometers, pH meters, SRM’s, etc.
5.6.2.1.5.1.1 The standards used in the laboratory measurement system will be calibrated
against higher-level, primary standards having certified accuracy. NIST or
other equivalently-recognized standardization will certify these higher-level
standards.
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5.6.2.1.5.3 Calibration standard reagents purchased from commercial vendors will be
required to have a certificate of analysis. Whenever a certified, calibration
standard is available from NIST, commercial vendors will be required to
establish traceability of the certificate of analysis to the certified standard.
5.6.2.2 Testing
5.6.2.2.1 Uncertainty
Policy:
The requirements given in section 5.6.2.1 apply to measuring and test equipment with
measuring functions used, unless it has been established that the associated calibration
uncertainty contributes little to the total uncertainty of the test result. When this situation
arises, the laboratory ensures that equipment used can provide the accuracy of measurement
needed.
Details:
The extent to which the requirements in section 5.6.2.1 are followed depends on the relative
contribution of calibration uncertainty to the total uncertainty. If calibration is the dominant
factor, the requirements are strictly followed. If, however, calibration is not one of the major
contributors to the total uncertainty, other ways for providing confidence may be used, as
given in section 5.6.2.2.2.
5.6.2.2.2 Traceability
Policy:
Where traceability to SI units of measurement is not possible and/or not relevant, other
means for providing confidence in the results are applied such as:
the use of suitable reference materials certified to give a reliable characterization of the
material
mutual-consent standards or methods which are clearly specified and agreed upon by all
parties concerned
participation in a suitable program of inter-laboratory comparisons or proficiency testing
Details:
Reliable characterization involves an estimate of recovery.
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The laboratory participates in proficiency testing and/or check sample programs. The list of
programs is maintained by the Quality Manager.
5.6.3 Reference Standards and Reference Materials
5.6.3.1 Reference Standards
Policy:
The SOP# QSP 5-6-1 outlines the program for the calibration of reference standards.
Reference standards are obtained or calibrated by a body that can provide traceability as
described in section 5.6.2.1. Such reference standards of measurement held by the
laboratory are used for calibration only and for no other purpose, unless it can be shown that
their performance as reference standards would not be invalidated.
Details:
Reference standards are obtained from ISO certified vendors], if applicable.
5.6.3.2 Reference Materials
Policy:
Where possible, reference materials are traceable to SI units of measurement, or to certified
reference materials. Internal reference materials are checked as far as is technically and
economically practicable.
Details:
Reference materials, including calibration standards, used in chemical measurement are
prepared so that the point of measurement is similar or equivalent to that of the samples. The
matrix, prior to the addition of the analyte does not have a detectable concentration of the
analyte. Reagents used in the preparation of reference materials, including calibration
standards are of certified purity.
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5.6.3.3 Intermediate Checks
Policy:
Checks needed to maintain confidence in the calibration status of reference, primary,
transfer or working standards and reference materials are carried out according to defined
procedures and schedules.
Details and Procedures:
The control check standards used to verify the accuracy of all the other standards are
prepared independently from all the other standards used to establish the original calibration.
These control check standards are preferably prepared from a separate lot # or source. It is
the responsibility of the Quality Manager to establish and maintain the individual schedule
for each SOP and/or test method. In some cases, where the first two source standards agree
but the results are called into question, then it may be appropriate to obtain an additional
source for verifications.
5.6.3.4 Transport and Storage
Policy:
The SOP# QSP 5-6-1 outlines safe handling, transport, storage and use of reference
standards and reference materials in order to prevent contamination or deterioration and in
order to protect their integrity.
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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5.7 Sampling
Section Synopsis
This section tells you:
1. There must be a sampling plan and procedure
2. Appropriate records of sampling are kept
3. Deviations, additions, and exclusions from the plan or procedure are
recorded
Key Words
Sampling Plan and Procedure
Deviation, Addition, or Exclusion
Cross-references
ISO 17025:2005 Section 5.7
ISO 9001:2000 Section 4.2.4, 7.5.1
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5.7.1 Sampling Plan and Procedures
Chemtech-Ford, Inc. Does not currently perform sampling.
Revision History
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Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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5.8 Handling of Test and Calibration Items
Section Synopsis
This section tells you to:
1. Keep samples in good condition.
Key Words
Identification
Receipt
Protection
Cross-references
ISO 17025:2005 Section 5.8
ISO 9001:2000 Section 6.3, 6.4, 7.1, 7.4.3, 7.5, 8.2.4
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5.8.1 Procedures
Policy:
The SOP# QSP 5-8-1 outlines the procedures for the transportation, receipt, handling,
protection, storage, retention and/or disposal of test and/or calibration items, including all
provisions necessary to protect the integrity of the test or calibration item, and the interests
of the laboratory and the customer.
Details:
Samples, reagents, and standards are stored so as to ensure their integrity by preventing
against deterioration, contamination, and loss of identity. It is recognized that this is a
general statement, but details are elaborated upon in SOP# QSP 5-8-1.
5.8.2 Identification of Test and/or Calibration Items
Policy:
Test and/or calibration items are systematically identified as they arrive at the laboratory.
The identification is retained throughout the life of the item in the laboratory. The system is
designed and operated so as to ensure that items cannot be confused physically, or when
referred to in records or other documents. The system accommodates a sub-division of
groups of items and the transfer of items within and from the laboratory when appropriate.
Details:
Sample labelling indicates the unique identification and conforms to applicable legal
requirements. The laboratory has established and documents a system for appropriate chain-
of-custody.
5.8.3 Receipt
Policy:
Upon receipt of the test or calibration item, any abnormalities or departures from normal or
specified conditions, as described in the relevant test or calibration method, are recorded.
When there is any doubt as to the suitability of an item for test or calibration, or when an
item does not conform to the description provided, or the test or calibration required is not
specified in sufficient detail, the laboratory consults the customer for further instructions
before proceeding and keeps a record of the discussion.
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The Chemtech-Ford sample acceptance policy is detailed in document QSP 5-8-3.
Details:
Conform to applicable regulations or contractual arrangements. The condition of sample
may include or relate to damage, quantity, preparation, packaging, or temperature.
Preparation may include addition of chemical preservative, removal of moisture, isolation of
portion of sample to be tested, homogenization, or subsampling.
Procedures are in place to document that the elapsed time between sampling and testing
does not exceed test method specifications (holding time) once the sample is received in the
laboratory.
5.8.4 Protection
Policy:
The SOP# QSP 5-8-1 outlines the procedures and appropriate facilities for avoiding
deterioration, loss or damage to the test or calibration item during storage, handling and
preparation and testing; instructions provided with the item are followed. When items have
to be stored or conditioned under specified environmental conditions, these conditions are
maintained, monitored, and recorded. Where a test item is to be held secure (e.g., for reasons
of record, safety or value, or to enable complementary test and/or calibrations to be
performed later), the laboratory has arrangements for storage and security that protect the
condition and integrity of the secured item concerned.
Details:
A sampling procedure and information on storage and transport of samples, including all
information that may influence the test or calibration result, is provided to those responsible
for taking and transporting the samples.
The laboratory establishes whether the sample has received all necessary preparation or
whether the customer requires preparation to be undertaken or arranged by the laboratory.
Proper requirements for packaging, environmental conditions, and separation from
incompatible materials are observed. Where samples have to be stored or conditioned under
specific conditions, these conditions are maintained, monitored, and recorded, where
necessary.
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Where a sample, or portion of a sample, is to be held secure (e.g., for reasons of record,
safety, or value, or to enable check tests to be performed later), the laboratory has storage
and security arrangements that protect the condition and integrity of the sample.
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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5.9 Assuring the Quality of Test Results
Section Synopsis
This section tells you:
1. That results are monitored
2. There is a plan for monitoring
Key Words
Internal Quality Control
Statistical Techniques
Inter-laboratory Comparisons
Proficiency Testing
Certified Reference Materials
Secondary Reference Material
Replicates
Re-testing
Correlation
Cross-references
ISO 17025:2005 Section 5.9
ISO 9001:2000 Section 6.3, 6.4, 7.1, 7.2.1, 7.2.2, 7.3, 7.4.3, 7.5.1, 7.5.2, 7.5.3,
7.5.5, 8.1, 8.2.3, 8.2.4, 8.4
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5.9.1 Quality Control / Quality Assurance
Policy:
Quality control procedures are utilized to monitor the validity of test and/or calibration
results. These procedures are for each test method utilized in the laboratory. The resulting
data are recorded so that trends are detectable (and where practicable, statistical
techniques are applied to the reviewing of the results). This monitoring is planned and
reviewed and may include, but not limited to, the following:
regular use of certified reference materials and/or internal quality control using
secondary reference materials
participation in inter-laboratory comparisons or proficiency testing programs
replicate tests or calibrations using the same or different methods
re-testing or re-calibration of retained items
correlation of results for different characteristics of an item
Details:
The methods utilized from the above list will be appropriate for the type and volume of
the work undertaken. Records are maintained of assurance activities and any actions
taken.
As a guide, for routine analyses the level of internal quality control is typically 5% of the
sample throughput. For more complex procedures, 20% is not unusual and on occasions
even 50% may be required. For analyses performed infrequently, a full system validation
is performed on each occasion. This may typically involve the use of a reference material
containing a certified or known concentration of analyte, followed by replicate analyses
of the sample and spiked sample. For analyses undertaken more frequently, systematic
quality control procedures incorporating the use of control charts and check samples are
implemented. These procedures are documented in the "Quality Control Plan" of each
test method.
Proficiency testing helps to highlight not only repeatability and reproducibility
performance between laboratories, but also systematic errors such as bias. It is important
to monitor proficiency testing results as a means of checking quality assurance and take
action as necessary.
The QM maintains a list of all the current proficiency testing programs the laboratory
participates in, monitors the results, and notifies the appropriate personnel of both
problematic and successful results.
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Technical personnel use certified reference materials and reference materials to evaluate
test performance on a daily basis and include daily process control checks. These data are
used to evaluate the validity of the test results.
Replicate tests may be used if suitable reference material is available. These materials
and proficiency test materials are available for improving repeatability.
Re-testing of test items is performed occasionally at the discretion of the supervisor or
when test results seem anomalous.
5.9.1.1 Quality Control Procedures
The determination of precision and accuracy is an important analytical tool in
evaluating the quality of generated data. Precision is defined as the ability to
reproduce a value within defined limits. Accuracy is defined as producing the
correct answer. Different methods are employed to measure each of these
parameters.
5.9.1.1.1 Precision - Utilizing duplicate samples and comparing their respective results is
the primary method for the analysis of precision. However, it has no bearing on
accuracy. A result may be precise and inaccurate at the same time. One duplicate
sample is analyzed for each matrix type and method, and for each sample batch,
or for each sample batch containing 20 samples, whichever is less. The relative
percent difference (RPD) for each component is then calculated and compared to
the acceptance limits for the matrix and method.
5.9.1.1.2 Accuracy - Utilizing matrix-matched standards of known concentration and comparing them
to the analyte of interest is the primary method for measuring accuracy. Participation in
independent Performance Evaluation (PE) studies is also utilized to monitor accuracy of
data in the laboratory.
5.9.1.1.3 Reproducibility - The tracking of reproducibility ensures that analyses
performed at different times or by different individuals may be acceptably
reproduced. This demonstrates that the method, instrumentation, and
analytical technique are resilient enough to reproduce results within a specified
range over time.
5.9.1.2 Quality Control Samples
The quality control principles contained in this section will be implemented
consistently, dependent upon the type of analysis to be performed and any
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associated, specific requirements of such analysis. In addition, the analyst is to
use his/her best judgment to evaluate the use of additional QC bracketing
samples which have a difficult matrix, react differently, or have distinctive client
or reporting requirements. The additional QC can take the form of additional
spikes, standards, and/or SRM’s. Sufficient QC should be performed to insure
that the analyst has performed due diligence with regard to QC while analyzing
the sample.
5.9.1.2.1 Matrix Spike and Matrix Spike Duplicate - Matrix spikes are employed to
monitor recoveries and maintain extraction and/or concentration techniques at
acceptable levels. Compounds of interest are added to samples prior to
extraction and analysis. Compound recoveries and reproducibility are then
compared with tables of acceptance for each method. The established
acceptance ranges are contained in each method SOP.
5.9.1.2.1.1 This QC procedure provides information about the effect of the sample
matrix on the analyte in question. Generally, a ratio of one spike sample for
each ten samples for drinking water and for each twenty samples for RCRA
and wastewater analyzed must be maintained. In the event that an analytical
run will have less than ten samples one spike shall accompany the batch.
The method SOP should be consulted to determine the proper frequency.
Solutions used to fortify samples should, when possible, be made from a
source other than that from which the calibration standards are made.
Percent recovery of matrix spikes is determined using the following:
Percent Recovery = (SSR-SR)/SA x 100
Where:
SSR = Spiked Sample Result
SR = Sample Result
SA = Spike Added
5.9.1.2.1.2 Spike Recoveries - Percent spike recoveries range between +3 standard
deviations (SD) of the historical percent recoveries when method-specified
criteria are not available. It is recognized that this will not always be
achievable due to matrix effects. In that case, the data will be reported and
an explanation made concerning the problem.
5.9.1.2.1.3 Laboratory matrix spikes and matrix spike duplicates must be prepared
and analyzed for each ten samples for drinking water and for each twenty
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samples for RCRA and wastewater analyses. This procedure provides
information regarding the precision of an analysis. (These sample types are
not always possible due to the type of analysis, for example pH.) The
relative difference between duplicate measurements is assessed using the
following equation:
Relative Percent Difference (RPD) = |D1-D2|/ ((D1 + D2)/2) x 100
Where:
D1 = Sample Value
D2 = Duplicate Sample Value
5.9.1.2.2 Laboratory Control Spikes - Compounds of interest are added to reagent blank
samples prior to extraction and analysis, as required by each method SOP.
Compound recoveries and reproducibility are then compared with tables of
acceptance for each method.
5.9.1.2.3 Duplicates and Spike Duplicates - Both routine sample analysis and spiked
samples are run in duplicate at a prescribed frequency. The relative percent
difference between duplicate sample analysis or duplicate spike analysis must
range between + 2 standard deviations (SD) of historical relative percent
difference (RPD), when method-specified criteria are not available. It is
recognized that this will not always be achievable due to matrix effects. If a
matrix effect is confirmed, the data will be reported and an explanation
concerning the problem will be noted on the final report.
5.9.1.2.4 Surrogates - Surrogate spike compounds of interest are added to each sample
prior to extraction and analysis. Compound recoveries and reproducibility are
then compared with tables of acceptance for each method.
5.9.1.2.5 Method and Reagent Blanks - Method blanks must be prepared with each batch
of samples and analyzed to ensure that sample contamination has not occurred.
If blank analyses do not fall within acceptable limits, as noted in the method
specific SOP, a modification of method reagents or cleaning of glassware may
need to be implemented before further analysis is attempted. In addition to
method blanks, reagent blanks shall be prepared whenever the lot number of a
reagent used in the analysis has changed.
5.9.1.2.6 Internal Standards - Internal standards will be prepared from a solution
containing a known amount of analyte and will be traceable to a certified
reference solution. Internal standard levels spiked into the sample for analysis
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will be according to method SOP protocol. During analysis, internal standard
intensities will be monitored and compared to the intensities established in the
calibration blank. In general, intensities should be within 60 – 135% of the
original response in the calibration blank, or as otherwise specified in the method
SOP.
5.9.1.2.7 Quality Control Check Samples - Quality control check samples will be
prepared from a solution containing a known amount of analyte and will be
traceable to a certified reference solution. These solutions will be prepared
from a solution that is “second source” in difference from the calibration
standards/tuning standards. These solutions will be used to verify the stability
of the analytical curve established for the current analytical run.
5.9.1.2.7.1 After calibration and calibration verification, continued calibration
blanks (CCB) and continued calibration verification samples (CCV)
will typically be analyzed after every 10 samples and at the end of
every analytical run. Control limits during analysis of these solutions
will be subject to the QA protocol as defined by the method SOP.
5.9.1.2.7.2 Quality control check samples will be used to verify the efficacy of the sample
preparation procedure via the analyses of preparation blanks (PB) and
laboratory control samples (LCS) derived from a certified reagent
traceable to a certified reference material or solution. Laboratory
control samples must agree within + 2 standard deviations of the
historical data base or no greater than + 20 percent of the true value.
Where method specific ranges exist, they may be used.
5.9.1.2.8 Calibration Standards - Calibration Standards will be prepared from a
solution containing a known amount of analyte and will be traceable to a
certified reference solution. Calibration standards will be prepared from a
solution that is “second source;” that is, different from the continued
calibration verification (CCV) solution.
These solutions are to be utilized for the calibration/tuning of analytical
instruments at the beginning of an analytical run and to be used for tuning
frequency as required by the method SOP protocol. These solutions are also
used to evaluate method MDL’s and effective quantitative ranges (linearity).
When required, these samples will be analyzed as samples with control limits
as required by the method QA SOP protocol. Selection of appropriate
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formulae to reduce raw data to final results is included in the method analyte
SOP
5.9.1.3 Other Quality Control Measures
5.9.1.3.1 Control charts can be produced by analyte for the evaluation of QA/QC data.
The charts are produced by the LIMS software.
5.9.1.4 Out-of-Control Situations
On occasion, a quality control sample may fail; i.e., the recovery for one or more
specific analytes may lie outside the acceptable range (creating an "out-of-
control" situation). This failure may or may not affect the acceptability of the
analytical run and the quality of associated generated data. Quality control
guidelines, contained in Chemtech-Ford, Inc.'s Data Validation and Acceptance
Procedure, have been established to be used in the evaluation of out-of-control
data for each analytical SOP
5.9.2 Correction and Prevention
Policy and Details:
Quality control data are analyzed and, where they are found to be outside pre-defined
criteria, planned action is taken to correct and to prevent incorrect results from being
reported.
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
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5.10 Reporting of Results
Section Synopsis
This section tells you:
1. What needs to be on a report
2. How to handle amendments to reports
Key Words
Specific Information
Required Information
Interpretation
Opinion
Subcontractor
Electronic Transmission of Results
Format
Amendments
Cross-references
ISO 17025:2005 Section 5.10
ISO 9001:2000 Section 6.1, 6.3.1, 7.1, 7.2.1, 7.2.2, 7.4.3, 7.5.1,
7.5.4, 7.5.5, 8.2.4
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5.10.1 General
Policy:
The results of each test, or series of tests are reported accurately, clearly, unambiguously
and objectively, and in accordance with any specific instructions in the test methods.
The results are reported, normally in a test report and include all the information
requested by the customer and necessary for the interpretation of the test results and all
information required by the method used. This information may include what is outlined
in section 5.10.2, 5.10.3 and 5.10.4.
Details:
Test reports are issued as either hard copy or by electronic data transfer.
5.10.2 Test reports and certificates
Policy:
Test reports include the following information, as appropriate:
a title (e.g., “ Certificate of Analysis”)
name and address of laboratory, and location where tests were carried out if different
from the address of the laboratory
Unique identification of the test report, and on each page an identification in order to
ensure that the page is recognized as a part of the test report
name and address of the customer
identification of the method used
Description, condition, and unambiguous identification of the item(s) tested.
date of receipt of test items (where this is critical to the validity and application of
the results) and date(s) of performance of the analysis
reference to sampling procedures used by the laboratory or other bodies where these
are relevant to the validity or application of the results
test results with, where appropriate, units of measurement
the name(s), function(s) and signature(s) or equivalent of person(s) authorizing the
test report
where relevant, a statement to the effect that the results relate only to the items tested
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Details:
Signing authority for test reports is the responsibility of the Lab Director. Records for
individuals with signing authority for test reports are approved by the Quality Manager
and maintained by same.
Analytical reports include the individual page number and total number of report pages
(Page 3 of 16).
A statement is included specifying that the test report is not to be reproduced except in
full, without written approval of the laboratory. Data reported to the customer contains
the appropriate significant digits for each test method. Low level data are identified as
being below specified limits and are flagged with a ‘J’ flag indicating a value found
between the MDL and MRL.
5.10.3 Test Reports
5.10.3.1
Policy and Details:
In addition to the requirements listed in section 5.10.2, test reports include the following,
where necessary for the interpretation of results:
deviations from, additions to, or exclusions from the test method, and information on
specific test conditions, such as environmental conditions
where relevant, a statement of compliance/non-compliance with requirements and/or
specifications
where applicable, a statement on the estimated uncertainty of measurement of the test
result; information on uncertainty is needed in test reports when it is relevant to the
validity or application of the test results, when a customer’s instruction so requires, or
when uncertainty affects compliance to a specification limit
where appropriate and needed opinions and interpretations (see section 5.10.5)
additional information required by specific methods, customers, or groups of customers
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5.10.3.2
Policy and Details:
In addition to the requirements listed in sections 5.10.2 and 5.10.3.1, test reports containing
the results of sampling include the following, where necessary for the interpretation of test
results:
date of sampling
unambiguous identification of substance, matrix, material or product sampled (including
name of manufacturer and lot number as appropriate)
location of sampling
reference to sampling plan and procedures used
details of any environmental condition during sampling that may affect the interpretation
of the test results
any standard or other specification for the sampling method or procedure, and
deviations, additions to or exclusions from the specification concerned
5.10.4 Calibration Certificates
5.10.4.1
Policy:
The testing laboratory does not issue calibration certificates. However, the laboratory often
receives calibration services from a calibration laboratory and needs to be familiar with the
information on a calibration certificate.
Details:
In addition to the requirements listed in 5.10.2, the calibration certificate could include the
following, where necessary for the interpretation of calibration results:
the conditions (e.g., environmental) under which the calibrations were made that have an
influence on the measurement results
the uncertainty of measurement and/or a statement of compliance with an identified
metrological specification or clauses thereof
evidence that the measurements are traceable (see 5.6.2.1.1)
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5.10.4.2
Policy:
This section is not applicable to a testing laboratory.
5.10.4.3
Policy:
This section is not applicable to a testing laboratory.
5.10.4.4
Policy:
A calibration certificate (or calibration label) shall not contain any recommendation on the
calibration interval except where this has been agreed with the customer or it is to be used
by the laboratory itself.
5.10.5 Opinions and Interpretations
Policy:
When opinions and interpretations are included in the test report, the basis upon which the
opinions and interpretations have been made is documented. Opinions and interpretations
are clearly marked as such in the test report.
Note - Opinions and interpretations should not be confused with inspections and product
certifications as intended in ISO/IEC 17020 and ISO/IEC Guide 65.
Details:
Opinions and interpretations included in a test report may comprise, but not be limited to the
following:
opinion on conformity of the results with requirements
fulfilment of contractual requirements
recommendations on how to use the results
guidance to be used for improvements
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In many cases it is appropriate to communicate the opinions and interpretations by direct
dialogue with the customer.
5.10.6 Testing and Calibration Results Obtained from
Subcontractors
Policy and Details:
Test reports containing the results of tests performed by subcontractors are clearly identified
for the subcontracted results. The subcontractor reports the results either in writing or
electronically to our laboratory.
5.10.7 Electronic Transmission of Results
Policy:
In the case of transmission of test results by telephone, facsimile or other electronic or
electromagnetic means, the requirements of the policies and procedures of this Quality
Manual continue to apply (see also 5.2.7.1.2).
Details:
Signatures are recorded on file at the laboratory. Clients may request a hardcopy example of
signatures.
5.10.8 Format of Reports
Policy:
The format of reports is designed to accommodate each type of test carried out and to
minimize the possibility of misunderstanding or misuse.
Details:
The layout of the test report is such that the presentation of the test data facilitates ease of
assimilation by the reader.
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5.10.9 Amendments to Reports
Policy:
Material amendments to a test report after issue are made only in the form of a further
document, or data transfer, which includes the statement “Amended Report”. Such
amendments meet all the requirements in this Quality Manual.
Details:
When it is necessary to issue a complete new test report, it is uniquely identified and
contains a reference to the original that it replaces. A narrative accompanies the amended
report which details the changes in the report as well as justifications for the change.
Details for producing an amended report are located in document QSP-5-10-9.
Revision History
Changes from Revision 24
Revision 25 is a significant revision with numerous additions, deletions and corrections.
These are not all documented in the revision history, rather all persons on the distribution
list are required to read the entire document.
PHASE 3 WASTE ANALYSIS PLAN
Phase 3 Waste Analysis Plan
4867-8198-7593\1

Attachment 5
Alliance QAPP

Information for Work Plan / R20210400
Prepared for:
Stantec
Salt Lake City, UT

November 18, 2021

www.alliancetechgroup.com
[e-mail]
732.355.1234 (ph)

www.alliancetechgroup.com
9 Deer Park Drive ~ Suite B
Monmouth Jct., NJ 08852
[e-mail]

CONFIDENTIAL - R20210400 QAPP DOCUMENTATION.DOCX - THE ANALYTICAL DATA IN THIS REPORT ARE TO BE
USED FOR EXPLORATORY AND DEVELOPMENT STUDIES ONLY AND ARE NOT INTENDED FOR PRODUCT RELEASE
PG 2

Summary
Alliance Technologies is an FDA and DEA-registered laboratory. The lab was asked to perform the
following testing on a varity of samples provided by Stantec:

• ICP-OES
• Active Oxygen
• EDX analysis to determine approxiamte elemental composition
• X-Ray Diffraction (XRD) on solid samples for phase analysis

In-house methods were used for all sample analysis and are described in the Experimental
section.
Experimental
Analysis of Samples for Active Oxygen: Since the samples had an unknown amount of Active
Oxygen, the samples were “screened” by creating a 10% solution of the sample. Approximately
1g of each sample was placed in a 15 mL centrifuge tube and diluted to 10mL with DI water. The
solutions were then shaken to mix and allowed to sit at room temperazture overnight. The next
day, 1mL of the sample solutions was placed in a 15 mL centrifuge tube along with 1.0 mL 50% KI
and 1.0 mL of starch indicator. If the color of the solution did not change to a darker shade of
purple/black; the solution was not titrated and determined to have low/no Active Oxygen. If the
color of the solution changed, 0.5 mL increments of 0.1N sodium thiosulfate was added until the
solution was colorless.

For samples low in Active Oxygen, 5mL of the sample solution was placed into a 150mL beaker
along with 1.0 mL of 50% KI and 1.0 mL of starch indicator. The solution was diluted to ~60mL
with DI water. The solution was titrated with 0.025N sodium thiosulfate until the solution became
colorless.

www.alliancetechgroup.com
9 Deer Park Drive ~ Suite B
Monmouth Jct., NJ 08852
[e-mail]

CONFIDENTIAL - R20210400 QAPP DOCUMENTATION.DOCX - THE ANALYTICAL DATA IN THIS REPORT ARE TO BE
USED FOR EXPLORATORY AND DEVELOPMENT STUDIES ONLY AND ARE NOT INTENDED FOR PRODUCT RELEASE
PG 3
The final Active Oxygen was calculated from the amount of thiosulfate required to reach the
endpoint in the titration.

ICP-OES analysis: The samples were weighed into 15 place Teflon microwave digestion vessels.
To each tube, 8 mL of nitric acid was added. The samples were then digested using a Milestone
Ultrawave. Once the samples cooled, they were quantitatively transferred to 50 mL ICP tubes
and diluted to 25 mL using DI water. The solutions were then analyzed on an Agilent 710 ICP-OES
which was calibrated using a multi-point calibration curve created from NIST-traceable
standards.

XRD Analysis: The solid samples were ground into a fine powder using a mortar and pestle. The
powder was backfilled into the sample holder to allow for random orientation . Optimized
diffraction data was collected using a Philips PW1830 diffractometer system XRD patterns were
collected on a Philips PW1830 diffractometer system operating with the following parameters:
45kV Voltage and 35mA Current

Quality Control
The following documents are being supplied for a description of the Quality system used at
Alliance Technologies:

• 1M-04 Policy Manual – Describes the overall quality management system and quality
policy
• GE003-08 – Documentation and Data Handling

© Alliance Technologies, LLC 2021 - Reproduction of this report in its entirety is permitted. No portions of this report may be reproduced,
transmitted, or removed without the written permission of Alliance Technologies. All Rights Reserved.

APPENDIX D
P3MMP Distribution List

Phase 3 Material Management Plan Distribution List
Area Print Name Signature

APPENDIX E
Clean Harbors Health and Safety Plan

HEALTH AND SAFETY PLAN

Phase III Material Management Plan

Thatcher Group, Inc.

1905 Fortune Road
Salt Lake City, UT 84104

March 2022

Prepared by: Michael E. Sanders
Operations Manager
Clean Harbors
[e-mail]
801-673-5373

Page i
Table of Contents

1. Scope of Work……………………………………………………………………………………..…1
1.1. General…………………………………………………………………………………………..1
1.2. Scope and Applicability of the Health and Safety Plan……………………………………..1
2. Site Description……………………………………………………………………………………….1
3. Roles and Responsibilities…………………………………………………………………………..2
3.1. Responsibilities of Foreman/Supervisor……………………………………………………...2
3.2. Responsibilities of Health and Safety…………………………………………………………2
3.3. Responsibilities of Onsite Personnel……………………………………………………........3
4. Training and Medical Monitoring Requirements…………………………………………………..3
4.1. Training…………………………………………………………………………………………..3
4.2. Medical Monitoring Program…………………………………………………………………...4
5. Description of Field Work……………………………………………………………………………4
6. Physical Hazards……………………………………………………………………………………..4
6.1. Weather…………………………………………………………………………………………..4
7. Personal Protective Equipment……………………………………………………………………..5
7.1. Selection of Personal Protective Equipment…………………………………………………5
8. Illumination…………………………………………………………………………………………….5
9. Meteorological Monitoring…………………………………………………………………………...6
10. Standard Safe Work Practices……………………………………………………………………...6
10.1. General Rules of Conduct……………………………………………………………...6
10.2. Injury/Illness Reporting…………………………………………………………………7
11. Confined Spaces……………………………………………………………………………………..7
12. Air Monitoring…………………………………………………………………………………………7
13. Work Area Access……………………………………………………………………………………7
14. Decontamination……………………………………………………………………………………...7
15. Sanitation……………………………………………………………………………………………...8
16. Emergency Supplies…………………………………………………………………………………8
17. Emergency Information………………………………………………………………………………8
17.1. Site Resources…………………………………………………………………………..9
17.2. Emergency Procedures………………………………………………………………...9
18. Directions to Medical Facilities…………………………………………………………………….10
19. Authorized Changes to the Health and Safety Plan…………………………………………….10

Attachment A: Facility Map
Attachment B: Plan Acceptance Form
Attachment C: Directions to Rocky Mountain Care Clinic
Attachment D: Directions to University of Utah Hospital
Attachment E: Employee Acknowledgement

Page 1
1.0 Scope of Work

1.1 General

This HASP describes the procedures and protective measures that will support the work being
performed at the site. All Occupational Safety and Health Administration (OSHA) Regulation
requirements will be followed.

The purpose of this HASP is to provide site-specific safety information and procedures,
overview of site hazards, chemicals of concern, action levels, initial levels of personal protective
equipment to be used for various site activities, decontamination procedures, and emergency
resources and information.

In this document, Clean Harbors will establish procedures designed to meet the following goals:

1. Staff: A team consisting of 1 x Foreman/Supervisor, 1 x Operator and 2 x Technicians
providing support up to 40 hours/week, for the tasks outlined in the “Description of Field
Work” section of this document.
2. Incorporate Clean Harbors Online Services system capabilities for visibility into waste
volume tracking, generating regulatory reporting data and compliance inspections.
3. Provide Transportation and Disposal pricing for all waste streams.
4. Prepare and coordinate shipments of all waste streams into designated facilities.
Develop a partnership/program that is flexible enough to allow for contraction or expansion of
duties that mirrors Thatcher’s business fluctuations.

1.2 Scope and Applicability of the Health and Safety Plan

The provisions of this HASP are for all personnel working on site, who shall read this plan and
sign the accompanying plan acceptance form (Attachment A) before starting site activities. In
addition, personnel will operate in accordance with the most current requirements of Title 29
Code of Federal Regulations, Section 1910.120 (29 CFR 1910.120), Standards for Hazardous
Waste Operations and Emergency Response (HAZWOPER). These regulations include the
following provisions for employees: training, CFR 29 1910.120 (e); medical surveillance, CFR
29 1910.120(f); and personal protective equipment (PPE), CFR 29 1910.120(g).

Clean Harbors personnel are responsible for operating in accordance with all applicable
regulations of the company and Federal/State guidelines.

If there are any questions, please contact the Site Foreman/Supervisor or Health & Safety.

2.0 Site Description

Thatcher is in Salt Lake City, UT the facility produces various chemicals for commercial sale.
The area in which Clean Harbors will be conducting sampling and repacking is in the Northwest
corner of the plant. This area is barricaded off from the rest of the plant and only designated
personnel have access.

Page 2

3.0 Roles and Responsibilities

The Foreman/Supervisor is the primary entity to conduct the work at the Site.

If personnel involved in removal action activities believe that the removal action process is being
conducted in a manner inconsistent with the work plan or HASP, or in any other inconsistent
manner, all activities must cease.

3.1 Responsibilities of Foreman/Supervisor

The Site Foreman/Supervisor will direct the activities. The Foreman/Supervisor has the primary
responsibility for ensuring that all personnel are aware of:

 Names of personnel and alternates responsible for site safety and health.
 Safety, health, and other hazards present onsite.
 Use of personal protective equipment (PPE) and ensuring that the equipment is
available and in good working condition.
 Work practices by which the employee can reduce risks from hazards.
 Safe use of engineering controls and equipment onsite.
 Medical surveillance requirements, including recognition of symptoms which might
indicate exposure to hazards.
 Site control measures, decontamination procedures, site standard operating
procedures, and the contingency plan and responses to emergencies including the
necessary PPE.

The Foreman/Supervisor is also responsible for ensuring that all employees have received at
least 40 hours of health and safety instruction (off-Site), and three days of actual field
experience under the direct supervision of a trained experienced supervisor. Workers who may
be exposed to unique or special hazards shall be provided additional training.

The Foreman/Supervisor also monitors the performance of personnel to ensure that mandatory
health and safety procedures are being performed and corrects any practices that do not
comply with the HASP. Copies of the health and safety training certificates must be available
for review by the Foreman/Supervisor.

If unforeseen site conditions or emergencies occur, the Foreman/Supervisor shall ensure that
the medical surveillance program is implemented as required by CFR 29 1910.120. Additional
responsibilities may include:

 Consulting with the H & S and/or personnel.
 Preparation and submittal of any and all project reports – includes progress,
accident, incident, contractual, etc.
 Monitoring personnel decontamination to ensure that all personnel are complying
with the established decontamination procedures.

3.2 Responsibilities of Health & Safety

The responsibilities of H & S include:

 Ensures that a copy of the HASP is maintained on-Site during all field activities.
 Advise the team on all health and safety-related matters involved onsite.
Page 3
 Follow the safety program in the field, including the proper use of personal protective
and site monitoring equipment.
 Ensure that field personnel observe the appropriate work zones and decontamination
procedures.
 Report any safety violations to the Foreman/Supervisor and local Management.
 Conduct safety briefings during field activities.

H & S will approve this HASP and will address any changes that need to be made to this HASP.
H & S will also be a part of the morning tool box talk with the crew each day.

3.3 Responsibilities of onsite personnel

The responsibilities of onsite personnel include:

 All personnel going onsite must be thoroughly briefed on anticipated hazards and
trained on equipment to be worn, safety procedures to be followed, emergency
procedures, and communications.
 All personnel should avoid obvious vapor exposure, e.g., presence of strong and
irritating or nauseating odors.
 Personnel shall be familiar with the physical characteristics of site conditions
including:
o Wind direction in relation to contamination zones
o Accessibility to associates, equipment and vehicles
o Communication
o Operation zones
o Site access
o Nearest water sources
o Rally and/or Assembly Areas (in the event of an evacuation)
 The number of personnel and equipment in the contamination area must be kept to a
minimum, consistent with effective site operations.
 Procedures for leaving a contaminated area must be planned and implemented
before going onsite in accordance with the HASP.
 All visitors to the job site must comply with the HASP procedures. Personal
protection equipment may be modified for visitors depending on the situation.
Modifications must be approved by the H & S.

4.0 Training and Medical Monitoring Requirements

4.1 Training

Only authorized personnel with at least 40 hours of hazardous waste health and safety training
(e.g. HAZWOPPER) meeting the requirements of OSHA (CFR 29 1910.120). As applicable, all
personnel shall have the required annual HAZWOPER refresher training. All Site personnel will
document training.

Site-specific training in the use of equipment, as well as safety precautions, will be provided
during the pre-field safety meeting. The training will be repeated for any worker not present for
the initial training. H & S will be a part of daily, pre-shift tool box talks, which cover the Clean
Harbors Hazardous Work Permit. Safety meetings will be conducted monthly at the Clean
Harbors Facility to review various topics throughout the year. Written attendance and meeting
records of all safety meetings will be maintained at the local branch.

Page 4
4.2 Medical Monitoring Program

General Provisions

All personnel who enter hazardous waste/spill sites or have potential for exposure to hazardous
materials therein must participate in a Medical Monitoring Program. The program is conducted
by a medical professional. The purpose of the program is to identify any pre-existing illnesses
or problems that would put an employee at unusual risk from certain exposures or inhibit the
use of respirators, and to monitor and evaluate exposure-related events where workers are
involved in handling hazardous materials. Foreman/Supervisor may consult with the Health and
Safety Officer concerning the scope of work and known or anticipated chemical hazards
associated with the project.

5.0 Description of Field Work

Waste Handling
 Waste Collection of Phase III materials brought to repack area
 Sampling of Unknown Waste Streams
 Waste Identification/Characterization
 Pump/Transfer of Waste into proper shipping containers as needed

Reports/Administrative/Shipment Paperwork
 Manifesting, Generation and Record Keeping of all Shipment Paperwork
 Profile Management, Completion and Recertification
 Chain of Custody for Samples/Analytical
 Waste Minimization, Recycling and Volume Reduction
 Waste Stream Volume Reporting

Procurement
 Supply Management (Waste Containers, PPE, Sampling)

6.0 Physical Hazards

Personnel should be aware of and act to minimize dangers associated with physical hazards
typically encountered during onsite activities. These hazards include material handling, slippery
surfaces, lifting and drum handling. Personnel will walk at all times. Running should be avoided
as it greatly increases the probability of slips, trips, and falls.

6.1 Weather

During extreme weather conditions, the Foreman/Supervisor shall use his best judgment and
has the authority to stop fieldwork or dismiss workers for the day. Examples of conditions that
may warrant work stoppage include tornado warnings, high winds, hail, flooding, snow, cold
temps, and ice storms.

Page 5
7.0 Personal Protective Equipment

The level of employee protection for the work to be completed during site activities was
determined by researching site conditions, reviewing planned activities, and identifying Site-
specific physical and chemical hazards.

7.1 Selection of Personal Protective Equipment

It is important that specified PPE protect against known and suspected Site hazards. Protective
equipment is selected based on the types, concentrations, and routes of personal exposure that
may be encountered. In situations where the types of materials and possibilities of contact are
unknown or the hazards are not clearly identifiable, a more subjective determination must be
made of the PPE required, and greater emphasis is placed in experience and sound safety
practices. As discussed above, PPE for site workers will be based on Site history and on the
activities to be performed there.

The minimum level of PPE for set up/tare down, forklift operation and trailer loading will be Level
D.

Level D consists of the following:

 Work Uniform
 Inner gloves of Nitrile
 Outer gloves Cut/Impact Resistant Leather Gloves
 Safety glasses
 Hard Hat
 Steel Toe Leather Boots

The minimum level of PPE during repacking, characterization and sampling procedures will be
Level C.

Level C consists of the following:

 Poly-coated Tychem suit w/hood and booties
 Inner gloves of Nitrile
 Outer gloves, chemical resistant
 Head/eye protection of full-face respirator with lined air
 Steel-toed rubber boots

8.0 Illumination

Nighttime work activities are not anticipated. If nighttime (or low illumination levels) work is
planned, adequate illumination will be provided to allow for full illumination in the work area.

Page 6
9.0 Meteorological Monitoring

Onsite ambient weather conditions (temperature, wind speed and direction, and relative
humidity) may be monitored each day by the following methods; real-time internet weather
locations and the National Weather Service (if a local station can provide data relevant to the
Site).

Real time internet weather information will be monitored at
www.intellicast.com/LocalWeather/World/UnitedStates

Or with an appropriate weather app on the Foreman/Supervisors phone.

10.0 Standard Safe Work Practices

Standard safe work practices required onsite include:

 Eating, drinking, chewing gum or tobacco, smoking, or any other activity that
increases the probability of hand-to-mouth transfer and ingestion of material is
prohibited in any area designated as contaminated.
 Hands and face must be thoroughly washed upon leaving the work area.
 Whenever decontamination procedures for outer garments are in effect, the entire
body should be thoroughly washed as soon as practical after leaving the
contamination reduction zone.
 Contact with contaminated surfaces should be avoided. Whenever possible, do not
walk through puddles, leachate, or discolored surfaces or lean, sit, or place
equipment on drums, containers, or soil suspected of being contaminated.
 Medicine and alcohol can exacerbate the effects from exposure to toxic chemicals.
Prescribed drugs shall not be taken by personnel on cleanup or response operations
where the potential for absorption, inhalation, or ingestion of toxic substances exists,
unless specifically approved by a qualified physician. Consumption of alcoholic
beverages is prohibited.

10.1 General Rules of Conduct

The following general rules of conduct are required for anyone working on this project:

 Alcohol, firearms, narcotics, and other contraband items are not permitted on the
premises.
 Any violation of local, state, or federal laws, or conduct outside the generally
accepted moral standards of the community is prohibited.
 Willfully damaging or destroying property, or removing records is forbidden.
 Misappropriation or unauthorized alteration of any record is forbidden.
 Gambling in any form, selling tickets or articles, taking orders, soliciting
subscriptions, taking up collections, etc., is forbidden.
 Compliance with posted signs and notices is required.
 Boisterousness and noisy or offensive work habits, abusive language, or any oral,
written, symbolic, or other communication that tends to disrupt work or morale of
others is forbidden.
 Fighting or threatening bodily harm to another is forbidden.
 Defacing any property is forbidden.
Page 7
 Wearing shorts of any type and/or offensive logos, pictures, or phrases on clothing is
forbidden. Shirts, shoes, and pants, slacks, or coverall-type garments will be worn at
all times.
 People operating motor vehicles will obey all traffic regulations.

10.2 Injury/Illness Reporting

Clean Harbors will report any and all incidents to the appropriate Thatcher contact and local
Management. Appropriate actions will then be taken to ensure the employee or equipment is
taken care of immediately. A report will be generated and can be made available to Thatcher
upon request. An investigation of the incident will take place when it is warranted in a timely
manner. Once an investigation is completed, any and all mitigation procedures or retraining will
be implemented and relayed to the Thatcher contact.

11.0 Confined Spaces

No confined space entry is anticipated.

12.0 Air Monitoring

Air monitoring will be conducted during all characterization, sampling, transfer and repacking
procedures.

13.0 Work Area Access

Site visitors to the work area will be restricted to times when characterization, sampling, transfer
and repacking procedures are not taking place. If conversations need to be conducted during
these times, they can either be done outside of the work area, or work will be shut down and
containers sealed closed prior to access to the site.

If H & S believes that personnel are in danger or others may be in danger because of activities
being conducted, he/she has the authority to immediately suspend work and may instruct
personnel to evacuate the area. Examples of situations when this may happen are:

 Severe weather conditions such as thunder or lightening.
 Extreme winds.
 Site conditions have changed, for whatever reason, such that the HASP does not
adequately address the current situation.
 Safety precautions being used are inadequate for the situation.
 Personnel including the contractor, subcontractors, or visitors, are or may be exposed to
an immediate health hazard.

14.0 Decontamination

All personnel that come into contact with potentially contaminated soil or water will be
decontaminated to avoid cross contamination. Disposable equipment intended for one-time use
will not be decontaminated but will be packaged for appropriate disposal. Decontamination will
occur prior to and after each designated use of a piece of equipment or truck. Decontamination
procedures, based on Level C protection, will consist of the following:

 Brushing off heavily soiled boot covers and PPE.
 Rinsing off all PPE while still on person in potable water rinse.
 Disposing of gloves and other disposable PPE in a designated container.
Page 8
 Washing hands and face.
 Washing with non-phosphate detergent and potable water wash, using a brush if
necessary.

Equipment will be decontaminated in the pre-designated area on plastic sheeting or other
appropriate barrier or method, and clean bulky equipment will be stored on plastic sheeting in
uncontaminated areas.

15.0 Sanitation

Temporary sanitary facilities will be established or identified at the site for the duration of the
work and will be serviced at regular intervals. Workers will complete the following personal
hygiene procedures before leaving the work site:

 Toilet and hand washing facilities will be located on site or an alternate sanitary facility
and their specific location identified prior to beginning work activities.
 Potable drinking water will be on site for use by site personnel.
 Personal protective equipment shall be kept clean and in good repair. Safety devices,
including protective clothing worn by the employee, shall not be interchanged among the
employees until properly cleaned.
 All equipment leaving the site will be free of gross hazardous and non-hazardous waste
(i.e. mud and/or soil).

Eating, drinking, chewing gum or tobacco, and smoking - are prohibited within the work area.
 Sitting or kneeling should be avoided in areas of known or suspected areas of
contamination.
 Hands and face should be thoroughly washed when leaving the work area.
 Defective PPE should be repaired or replaced immediately.

16.0 Emergency Supplies

The following emergency and first-aid items will be at the site in a designated area during all
activities:
 A physician-approved, industrial first-aid kit with eyewash kit, one-way air valves for
CPR, latex gloves, and safety glasses.
 A 10lb (min.) ABC-type fire extinguisher. Technicians will be trained and informed on
the proper use of fire extinguishers.
 Potable water for drinking and washing.
 A spill-control kit containing absorbent materials and neutralizing agents.
 A plumbed eye and deluge shower is on site next to the entrance to the work area.
 Communications equipment immediately available to all employees. If cell phone
coverage is available, at least one cell phone will be onsite.

Page 9
17.0 Emergency Information

All hazardous waste site activities present a risk to onsite personnel. During routine operations,
risk is minimized by establishing good work practices, staying alert and using proper PPE.
Unpredictable events such as physical injury, chemical exposure, or fire may occur and must be
anticipated.

During the site briefing that will be held, workers will be reminded of the provisions of the
emergency response plan, communications systems, and evacuation routes.

Thatcher Emergency Contacts

Darren Bauer HR/EHS 801-888-6047
Dave Johnson 775-250-2930
Brandon Lowery 435-237-7245
Dave Lindsey EHS Manager 801-673-5532

Onsite Clean Harbor Emergency Contacts

TBD TBD TBD
Michael Sanders Operations Manager [phone]
Tim Armentrout Health and Safety Manager [phone]

If emergency contacts are not available, contact:

Ambulance Emergency Dispatch 911
Fire Fire Department 911
Police Police Department 911

17.1 Site Resources

First-aid equipment, telephones, restroom facilities, and water are available. Clean Harbors
personnel working onsite communication and first-aid equipment available at the work area at
all times.

17.2 Emergency Procedures

All personnel with current First Aid and CPR training will be identified during morning tool box
talks.

Emergency procedures are to be followed if any of the following situations develop onsite:

 Any member of the field crew is involved in an accident or experiences any adverse
effects or symptoms of exposure while onsite.
 A condition is discovered that suggests the existence of a situation more hazardous than
anticipated.

The following emergency procedures should be followed:

 Site work area entrance and exit routes will be planned and emergency escape routes
lined out.
 If any member of the field team experiences any effects or symptoms of exposure while
on the scene, the entire field crew will immediately halt work and act according.
Page 10
 For applicable site activities, wind indicators visible to all onsite personnel will be
provided by Foreman/Supervisor to indicate possible routes for upwind escape.
 Identifying any conditions that would suggest a situation more hazardous than
anticipated will result in the suspension of work until the situation has been evaluated
appropriate mitigating steps have been relayed to the field team.
 If an accident occurs, the Foreman/Supervisor is to contact local Management and
assist in complete an accident report form for submittal to the appropriate company
official.
 If a member of the field crew suffers a personal injury, the Foreman/Supervisor will
initiate Injury and Illness procedures.
 If a member of the field crew suffers a chemical exposure, the affected areas should be
flushed immediately with copious amounts of clean water via the onsite safety
eyewash/shower. While employee is being flushed in safety eyewash/shower, the
Foreman/Supervisor will initiate Injury and Illness procedures.

18.0 Directions to Hospital

The closest medical facilities:

Rocky Mountain Care Clinic
1820 South 4088 West
Salt Lake City, UT 84104
801-975-7799
801-746-4014 After Hours

University of Utah Hospital
50 Medical Drive North
Salt Lake City, UT 84132
801-581-2121

19.0 Authorized Changes to the Health and Safety Plan

Any changes to this Health and Safety Plan must be approved in writing by the Health and
Safety Manager and Operations Manager. The documentation will become part of the HASP.

Page 11

ATTACHMENT A

Facility Map with Evacuation Routes

Page 12
ATTACHMENT B

PLAN ACCEPATANCE FORM

Health and Safety Plan

INSTRUCTIONS: This form is to be completed by each person working or visiting at the project
work site during the proposed activities.

Project: Phase III Material Management Plan

I represent that I have read and understand the contents of the above plan and agree to perform
my work in accordance with it.

Signed:

Print Name:
Company:
Date:

Page 13
ATTACHMENT C

DIRECTIONS TO ROCKY MOUNTAIN CARE CLINIC FROM SITE:

Page 14
ATTACHMENT D

DIRECTIONS TO UNIVERSITY OF UTAH HOSPITAL

Page 15
ATTACHMENT E

EMPLOYEE ACKNOWLEDGEMENT

I acknowledge having received a briefing on this health and safety plan, and that I understand
the requirements of this plan, including the potential for random or for-cause drug and alcohol
testing. I further acknowledge that failure to follow the requirements of this plan may result in
removal from this Site.
Printed Name Company Signature Date

APPENDIX F
90-Day Hazardous Waste Storage and Phase 3 Areas Inspection Forms

APPENDIX G
Area Disposition Review Form and Spreadsheet

Phase 3 Thatcher Area Disposition Review Form
Container identification number:
Inventory Area:
GPS (Description of Area e.g., inside building location outside location):
Container Condition and Immediate Action Determination:
Labeled Yes (Y) or No (N) and description:
Not Labeled Y or N and description:
Container Location Description:
Container Information: Size Type Color Quantity
Material Generation Source:
Date of transfer from area to NWSA or disposition area:
Comments:
Review Form Date
(Accumulation Date):
1Disposition (Recycle or Disposal)
Label Date if Different from above:
1Containers will be labeled with the inventory date as the Phase 3 Accumulation Date, unless the actual accumulation date can be determined. If the actual
accumulation date is known, the container will be labeled with both the actual accumulation date and the Phase 3 Accumulation Date.
Spreadsheet Items To-Be-Determined: SDS, Hazard Determination, Hazardous Characteristics, CCP and Secondary Material Determinations, Repack and Comments
(Include: legitimate use/re-use/re-working scenario and DWMRC approval date).
Page _______ of _______
Phase 3 AREA DISPOSITION REVIEW SPREADSHEET
Area Disposition Review Spreadsheet
The Phase 3 area disposition review spreadsheet was prepared for tracking container
information as follows in Table 1.
Table 1 Area Disposition Review Spreadsheet
Column Description
A Introduction top of worksheet
A Location
A Area location/GPS
A Inventory date
Data Entry
A Description
B Labeled
C Unlabeled
D SDS
E Non-hazardous (NH) or Hazardous (H)
F Hazardous Characteristics
G Hazardous Determination
a. Generator Knowledge
b. Analyses
H Container size, type, and color
I Quantity
J - M Columns J through M Header - Disposition
J CCP Date
K CCP Tracking No. (Lot or Assigned)
L Secondary Material Date
M Secondary Material Tracking No.
N & O Columns N and O Header - Dispose
N Disposal Label Date
O Disposal No.
P Repack
Q Comment
Include: legitimate use/re-use/re-working scenario and DWMRC approval date
WICP #SDS Composition %Solid Liquid pH
Flash
Point
Specific
Gravity Density DOT Comments
1531 SDS
Ammonium
Phosphate 100 x 8 1.62 NA
1524 SDS Calcium Polysulfide Calcium Polysulfide 30 red 11.3-11.5 1.28 NA
Water 70
1517 SDS (4)Excel Final Oxy Sulfuric Acid 40-50 red 0.75 1.71 8 NA1760, Compounds, cleaning liquid, 8, PGII
Hydrogen Peroxide 5.0-10
Methanesulphonic Acid 5.0-10
ATMP Acid
.Aminotris(methylenephosphonic
acid),
[Bis(phosphonomethyl)amino]m
ethylphosphonic acid <1
Water 40-60
It is necessary to have 100% composition and document some general information for profiling the materail. Some previous P3 Batch 1 examples are provided below.
Phase 3 Thatcher Area Disposition Review Spreadsheet
Area No. 01
GPS
Review Date:
Description Labeled Unlabeled SDS
Non-Hazardous (NH)
Hazardous (H)
Hazardous
Characteristics
Hazard
Determination
a. Generator
Knowledge
b. Analyses
Container
Size
Type
Color Qty CCP Date
CCP Tracking
No. (Lot or
assigned)
Secondary
Material Date
Secondary
Material
Tracking No.
Disposal
Label
Date
Disposal
No.Repack
Comments
Include: legitimate use/
re-use/re-working
scenario and DWMRC
Approval Date
Disposition Disposition Dispose

APPENDIX H
Field Screening Form

Phase 3 Field Screening Form THATCHER COMPANY Nothwest Storage Area
Date Container
ID#
Material
Amount
Liq (L)
Solid (S)
Sludge (SL)
Material
Color
pH O2 %CO %
H2S
%VOC (ppm)LEL %HCN (PPM)
Iodine,
Bromine,
Chlorine Oxidizer Fluoride
Water
Miscibility/Temp
after test
Y or N Y or N Y or N
Contains
Cyanide
Contains
Sulfide Ammonia
Unif
orm Ununiform
% Free
Liquids
% Settled
Solids
% Total
Suspende
d Solids
Phases
Top
%/Color
Phases
Middle
%/Color
Phases
Bottom
%/Color
Y or N Y or N Y or N
Material is compatible with container type: Y or N
1Wastewater/Nonwastewater Definition: Wastewater (WW): Wastes that contain less than 1% by weight total organic carbon (TOC) and less than 1% by weight total
suspended solids (TSS).
Specific Gravity/Density: < 0.8 (Gasoline), 0.8-1.0 (Ethanol), 1.0 (Water), 1.0-1.2 (Antifreeze), >1.2 (Methylene Chloride)
Contents Description Comments (include container label description):
Other Comments:
Field Monitoring
Comments:
Peroxide: 0, 0-2, 2-5, 5-10, >10 or ppm ______
Viscosity (Centipoise): 1-100 (Water), 101-500 (Motor Oil), 501-10,000 (Molasses), > 10,000
Physical State: Solid without Free Liquid, Powder, Monolithic Solid, Liquid with No Solids, Liquid/Solid Mixture, Sludge, Gas/Aerosol
Halogenated
Hydrocarbon (PPM)
(e.g., oils (Chlor-
Dtect))
Container Information
[Type (metal (M),
plastic (P), fiber board
(F) or other]
Labeled Yes (Y) or No
(N)
If yes enter
information in
Comments Section
Size:
Color:
Type:
Field Monitoring: Circle Y (yes), N (no) or enter monitoring data.
Weather Conditions
and Temperature
1Underlying Hazardous
Constituent UHC: Circle
Wastewater/Nonwastewater
Determination
Wastewater
Nonwastewater
Page ___ of ___

APPENDIX I
Repackaging Form

Phase 3 Container Repackaging Form
Date:Container identification number:
Container Location:
Was the container number updated? If yes, list the updated number:
Container Information: Size Type Color
Comments:
Phase 3 Container Repackaging Form
Date:Container identification number:
Container Location:
Was the container number updated? If yes, list the updated number:
Container Information: Size Type Color
Comments:
Note: Form is set up for two containers per page.

APPENDIX J
Container Tracking and Disposal Spreadsheets

Category 1: pH: <2 or >12.5 (Corrosives)
Category 2: pH >2 and <12.5 Yes
Off-site lab analyses
1. pH,
2. TCLP RCRA 8 Metals and UHC Nickel,
3. Flash Point,
4. TCLP VOAs/Semi-VOAs and UHC methanol
(1nonwastewater),
5. UHC Total VOAs Methanol (wastewater) and
Xylene,
6. Total sulfide or cyanide if detected from field
monitoring
Data evaluation and material management
decision.
No
Category 3: 2Oxidizer, 2Peroxide, Fluoride,
Iodine, Bromine, Chlorine, 2Ammonia
Yes
Off-site lab analyses
1. pH,
2. TCLP RCRA 8 Metals and UHC Nickel,
3. Flash Point,
4. TCLP VOAs/Semi-VOAs and UHC methanol
(1nonwastewater),
5. UHC Total VOAs Methanol (wastewater) and
Xylene,
6. Total sulfide or cyanide if detected from field
monitoring
Data evaluation and material management
decision.
No
Category 4: Oil < or >1000 ppm
Halogenated Hydrocarbons.Yes
Field Screening CHLOR-DE-TECT 1000 - Dexsil (<
or >1000 ppm Halogenated Hydrocarbons)
1. <1000 managed as used oil
2. >1000 off-site analyses
Off-site lab analyses > 1000 ppm
1. TCLP RCRA 8 Metals and UHC Nickel
2. Flash Point
3. TCLP VOAs/Semi-VOAs UHC methanol
(nonwastewater),
4. UHC Total VOAs Methanol (wastewater)
and Xylene
Data evaluation and material management
decision.
1. Used oil
2. Hazardous Waste
FIGURE 3
Material Characterization Flow Diagram
1Wastewater/Nonwastewater Definition: Wastewater (WW): Wastes that contain less than 1% by weight total
organic carbon (TOC) and less than 1% by weight total suspended solids (TSS).
2If oxidizers are detected by field screening, oxidizer speciation will be performed by Alliance. If ammonia is
detected by field screening, Chemtech-Ford (CTF) will analyze the material for ammonia and nitrate
concentrations.
Start: Assign each container and sample a unique number starting with Area (A), Area 1 (01), and container
number (001) (e.g., A-01-001) and complete field monitoring.

P3MMP Container Tracking and Disposal Spreadsheets
The WICP spreadsheets have been updated for P3 MMP container tracking, accumulation date, sample
analyses tracking, characterization/classification (by analyses or Safety Data Sheet), recycling
designation, and disposal tracking. The P3MMP Container Tracking and Disposal Spreadsheets workbook
contains the following worksheets.
Table 1 Worksheet 1
• Worksheet 1. Container Tracking, Material Screening, Category Designation
Table 2 Worksheets 2 Through 5
• Worksheet 2. Category 1 pH: <2 or >12.5 (Corrosives)
• Worksheet 3. Category 2 pH: >2 or <12.5
• Worksheet 4. Category 3 Oxidizer, Peroxide, Fluoride, Iodine, Bromine, Chlorine, Ammonia
• Worksheet 5. Category 4: Oil < or >10003 ppm Halogenated Hydrocarbons
Table 3 Worksheets 6 Through 9
• Worksheet 6. Peroxide Liquids
• Worksheet 7. Peroxide Solids
• Worksheet 8. Ammonia Solids
• Worksheet 9. Oxidizer Solids

Table 1 P3MMP Disposal Spreadsheets (Worksheet 1)
Worksheet
1 Column
Headers Row 2
Descriptions Row 3
A through
D
Header:
Column A: Container Tracking and/or Sample Number, and Description
Column B: Analyze (A), Safety Data Sheet (S), or Recycle (R
Column C: 1Accumulation Date
Column D: Container Description - For unidentified material include a general description and for
material identified by Safety Data Sheet (SDS) include product name.
A Phase 3 containers will be numbered as follows Area (A), Area 1 (01), and container number (001)
(e.g., A-01-001). Container identification number is used to track the container management
and/or sampling/analyses, SDS, and/or recycling data. Containers designated for recycling are
tracked on the disposition spreadsheet.
B • “A” is entered for unidentified materials that required analyses.
• “S” is entered for known materials identified by product name and SDS.
• “R” is entered for materials designated for recycling.
C Containers will be labeled with the inventory date as the Phase 3 Accumulation Date unless the
actual accumulation date can be determined. If the actual ac cumulation date is known, the
container will be labeled with both the actual accumulation date and the Phase 3 Accumulation
Date.
D Container Description - For unknown material a general description is included and for material
identified by Safety Data Sheet (SDS) the product name is included.
E through
G
Header CTF Lab Data
E CTF Lab ID#
F CTF Lab Data Entry Personnel (Initial)
Worksheet
1 Column
Headers Row 2
Descriptions Row 3
G Lab pH
•The category is assigned based on the lab pH.
H through
N
Header: Field Screening Data (Clean Harbors enters screening data and Stantec completes QA)
Field screening data is used to make category determinations.
H Wastewater/Nonwastewater Determination: Wastewater (WW): Wastes that contain less than 1%
by weight total organic carbon (TOC) and less than 1% by weight total suspended solids (TSS).
Lab will make methanol analyses determination: TCLP UHC methanol (nonwastewater) or UHC
Total VOAs Methanol (wastewater).
I Field pH

J Oxidizer, Peroxide, Fluoride, Iodine, Bromine, Chlorine, Ammonia
Yes (Y) or No (N)
K Oil >1000 ppm HH. Yes (Y) or No (N)
< 1000 ppm Halogenated Hydrocarbons is managed as used oil
L Cyanide? Yes(Y) or No (N)
M Sulfide? Yes(Y) or No (N)
N VOC (ppm)
Columns O
through R
Header: Category Determinations Yes (Y) or No (N)
O Category 1: pH: <2 or >12.5 (Corrosives)
P Category 2: pH: >2 or <12.5
Q Category 3: Oxidizer, Peroxide, Fluoride, Iodine, Bromine, Chlorine, Ammonia
R Category 4: Oil < or >1000 ppm Halogenated Hydrocarbons.
Columns S
through U
Header: Characterization\Classification, Review\Determination, and Date.
S Hazardous Waste (HW))
T Non-Hazardous (NH)
U Date
Column V Header: Disposal Profile Number
V Green highlight is approved profile and un-highlighted is not approved.
Column W Header: Phase 3 Shipment
W Shipment Number and Manifest Number/Date
Containers are tracked by shipment, manifest, and profile numbers. The manifest line items
correlate to profile numbers assigned to the containers.
The P3MMP worksheets 2 through 5 are field screening and/or analyses data spreadsheets Table 2.
Spreadsheets are set up for analyses data entry. Stantec reviews the analyses and determines if the
material is a characteristic or listed hazardous waste and/or non-hazardous material. This information is
used to determine if there is an existing disposal profile of if a new profile is necessary. Disposal profiles
numbers are entered at the bottom of the worksheet for each container. The profile number is transferred
to worksheet 1 by Stantec after the profile is approved by the disposal facility.
Table 2 P3MMP Disposal Spreadsheets (Worksheets 2 Through 5 Analyses)
Worksheets
2 through 5
Category pH Flash
Point
(less
than or
greater
than
1400F
TCLP
RCRA 8
Metals
and
UHC
Nickel
TCLP Volatile
and Semi-
Volatile and UHC
methanol
(nonwastewater)
UHC Total
VOAs
Methanol
(wastewater)
and Xylene
Halogen
ated Oil
Content
< or
>1000
ppm
2 Category 1 pH
<2 or >12.5
(Corrosives)
-Acid
pH <2
-Basic
pH
>12.5
Yes Yes Yes Yes No
3 Category 2 pH
>2 or <12.5
>2 or
<12.5
Yes Yes Yes Yes No
4 Category 3
Oxidizer,
Peroxide,
Fluoride,
Iodine,
Bromine,
Chlorine,
Ammonia
-Acid
pH <2
-Basic
pH
>12.5
->2 or
<12.5
Yes Yes Yes Yes No
5 Category 4: Oil
< or >10003
ppm
Halogenated
Hydrocarbons.
-Acid
pH <2
-Basic
pH
>12.5
->2 or
<12.5
Yes Yes Yes or No1 Yes or No1 Yes
1Yes if Halogenated Oil Content >1000 ppm
The P3MMP worksheet 4 is Category 3 field monitoring and additional parameter worksheets 6 through 9
analyses data spreadsheets Table 3. Category 3 Worksheet 4 Field Monitoring and additional Category 3
field screening parameters (worksheets 6 through 9) identified by the characterization team are listed in
the following table. Unknown materials identified as containing oxidizers, peroxides, and/or ammonia will
be analyzed for additional characterization parameters, determinations, profiling, and disposal.
Table 3 Disposal Spreadsheets (Worksheets 6 through 9)
Category 3
Worksheet 4 Field
Monitoring
Additional Parameters Worksheets 6
through 9
Comments
Oxidizer and Peroxide Worksheet 6 Peroxide Liquids Active
Oxygen (AO)1 and/or Inductively
Coupled Plasma (ICP)
ICP is used to identify material
components for disposal profile
if AO is >10 ppm.
Worksheet 7 Peroxide Solids AO1, X-Ray
Diffraction (XRD) Qualitative analysis,
Energy Dispersive X-Ray (EDX) analysis
XRD Qualitative and EDX
analyses are used to identify
material components for
disposal profile.
Worksheet 8 Ammonia Solids AO1, EDX,
Ammonia mg/kg, Total Nitrate as N mg/L
Ammonia and nitrate
concentrations were evaluated
to determine oxidizing potential
Worksheet 9 Oxidizer Solids AO1, XRD
Qualitative, and EDX
Fluoride NA
Iodine NA
Bromine NA
Chlorine NA
Ammonia See Worksheet 8 above
1AO <10 ppm is not considered to have oxidizing potential. AO >10 ppm is managed as an oxidizer.
Materials with active oxygen was < 10 containing other oxidizing potential constituents (e.g., nitrate
compounds) were identified as oxidizers. An oxidizer yes or no column was added for making the oxidizer
determinations.
CTF Lab
pH Disposal Profile Number Phase3: Shipment
Container Tracking
and/or Sample
Number
Analyze (A),
SDS (S), or
Recycle (R)1Accumulaiton Date
Container
Description CTF Lab ID#
CTF Lab
Data Entry
Personnel
(Initial)Lab pH
2Wastewater? Yes
(Y) or No (N)Field pH
Oxidizer,
Peroxide,
Fluoride, Iodine,
Bromine,
Chlorine,
Ammonia
Yes (Y) or No (N)
Oil >1000
ppm HH.
Yes (Y) or
No (N)
Cyanide?
Yes(Y) or No
(N)
Sulfide?
Yes(Y) or
No (N)
VOC
(ppm)2. Cat 1 pH <2 or >12.5 (Corrosives)
3. Category 2: pH: >2 or
<12.5
4. Cat 3: Oxidizer, Peroxide,
Fluoride, Iodine, Bromine,
Chlorine, Ammonia 5. Category 4: Oil < or >1000 ppm
Halogenated Hydrocarbons
Hazardous Waste
(HW))
Non-Hazardous
(NH) Date
Green highlight is
approved profile and un-
highlighted is not
approved.
Shipment Number
and Manifest
Number/Date
A-01-001 N N N N
A-01-002 N N N N
A-01-003 N N N N
A-01-004 N N N N
A-01-005 N N N N
1. Container and Analyses Tracking
Characterization\Classification, Review\Determination, and
Date.
Notes
1. Phase 3 containers will be numbered as follows Area (A), Area 1 (01), and container number (001) (e.g., A-01-001) column A.
2. Stantec and Thatcher determine if containers require analyses (A), are characterized by safety data sheets (S), or are recyclable (R) in column B.
3. Clean Harbors enters the accumulation date column C, container description column D, and field monitoring data is entered in columns H-N.
4. Lab enters lab ID# column E, data entry personnel initial entry column F, and analyzes\enters pH in column H.
5. Data auto populates in the Category columns for identifying remaining off-site analyses.
6. Off-site analyses is entered in Category worksheets (i.e., xls lab data).
7. Characterization\Classification Review\Determination (Hazardous Waste (HW) or Non-Hazardous (NH)) and Date.
8. Disposal Profile Number - Green highlight is approved profile and un-highlighted is not approved.
9. Phase 3 Shipment - Shipment Number and Manifest Number/Date
1Containers will be labeled with the inventory date as the Phase 3 Accumulation Date unless the actual accumulation date can be determined. If the actual accumulation date is known, the container will be labeled with both the actual accumulation date and the Phase 3 Accumulation Date.
Category Determinations
Category 1 pH <2 or >12.5 (Corrosives), Category 2 pH >2 and <12.5, Category 3 Oxidizer, Peroxide, Fluoride, Iodine, Bromine, Chlorine,
Ammonia Analyses: 1. pH, 2. TCLP RCRA 8 Metals and UHC Nickel, 3. Flash Point, 4. TCLP VOAs/Semi-VOAs, UHC methanol
(nonwastewater), 5. UHC Total VOAs Methanol (wastewater) and Xylene, 6. Total sulfide or cyanide if detected from field monitoring Yes
(Y) or No (N)
Category 4 Oil < or >1000 ppm Halogenated Hydrocarbons Analyses: 1. TCLP RCRA 8 Metals and UHC Nickel, 2. Flash Point, 3. TCLP
VOAs/Semi-VOAs UHC methanol (nonwastewater), 4. UHC Total VOAs Methanol (wastewater) and Xylene.
Column A: Container Tracking and/or Sample Number
Column B: Analyze (A), Safety Data Sheet (S), or Recycle (R
Column C: 1Accumulation Date
Column D: Container Description - For unknown material include a general
description and for material identified by Safety Data Sheet (SDS) include
product name.CTF Lab Data
Field Screening Data (Clean Harbors enters screening data and Stantec completes QA)
2Wastewater/Nonwastewater Definition: Wastewater (WW): Wastes that contain less than 1% by
weight total organic carbon (TOC) and less than 1% by weight total suspended solids (TSS).
Lab methanol analyses determination: TCLP UHC methanol (nonwastewater) or UHC Total VOAs
Methanol (wastewater).
2. Cat 1-<2 or >12.5 Corrosive
A-01-001 A-01-002 A-01-003
Analyses
RCRA Waste
Code Reg Limit
Off-site Lab
1. pH <2 (Corrosive Acid)D002
2. pH >12.5 (Corrosive Base)D002
4. Flash Point (less than or greater than 140 deg F)D001 140
A-01-001 A-01-002 A-01-003
Reg Level Reg Level Reg Level
1. TCLP Analyses - RCRA 8 Metals
RCRA Waste
Code Reg Limit
a. Arsenic (ppm; mg/L)D004 5.0
b. Barium (ppm; mg/L)D005 100.0
c. Cadmium (ppm; mg/L)D006 1.0
d. Chromium (ppm; mg/L)D007 5.0
e. Lead (ppm; mg/L)D008 5.0
f. Mercury (ppm; mg/L)D009 0.2
g. Selenium (ppm; mg/L)D010 1.0
h. Silver (ppm; mg/L)D011 5.0
I. UHC Nickel UHC 11.0
2. Total sulfide or cyanide if detected from
field monitoring*
a. Cyanide (ppm; mg/L)
b. Sulfide (ppm; mg/L)
*Note: If cyanide or sulfide are present in a sample container, a D003 waste code determination will be necessary.
Sample/ Container Number:
Sample/ Container Number:
2. Cat 1-<2 or >12.5 Organic
A-01-001 A-01-002 A-01-003
1. TCLP Analyses - Volatile Constituent for
Organic Samples and UHC Methanol
(Nonwastewater)
RCRA TC Waste
Code TCLP Limit Reg Level Reg Level Reg Level
Benzene D018 0.5
Carbon Tetrachloride D019 0.5
Chlorobenzene D021 100
Chloroform D022 6
1,2-Dichloroethane D028 0.5
1,1-Dichloroethylene D029 0.7
Methyl Ethyl Ketone (2-Butanone)D035 200
Tetrachloroethylene (Perchloroethylene)D039 0.7
Trichloroethylene D040 0.5
Vinyl Chloride D043 0.2
1P or 1,4-Dichlorobenzene D027 7.5
Methanol (UHC Nonwastewater)UHC 0.75
1. UHC Total VOAs Methanol (wastewater)
and Xylene Mg/L
Methanol (wastewater)UHC 5.6
Xylene (Nonwastewater)UHC 30
Xylene (wastewater)UHC 0.32
1543 1544 1545
1. TCLP Analyses - Semi-Volatile Constituent
for Organic Samples
RCRA TC Waste
Code TCLP Level Reg Level Reg Level Reg Level
O-Cresol (2-Methylphenol)D023 200
M-Cresol (3&4-Methylphenol)D024 200
P-Cresol (3&4-Methylphenol)D025 200
Cresol (*Total O-M-P Cresol D026 200
2,4-Dinitrotoluene D030 0.13
Hexachlorobenzene D032 0.13
Hexachloro-1,3-Butadiene D033 0.5
Hexachloroethane D034 3
Nitrobenzene D036 2
Pentachlorophenol D037 100
Pyridine D038 5
2,4,5-Trichlorophenol D041 400
2,4,6-Trichlorophenol D042 2
Sample/ Container Number:
Sample/ Container Number:
3. Cat 2 pH>2or<12.5
1540 1541 A-01-001 A-01-002
Analyses
RCRA Waste
Code
Off-site Lab
1. pH >2 and <12.5 4.5 3
2. Flash Point (less than or greater than 140 deg F)D001 140 >158 >158
1540 1541 A-01-001 A-01-002
Reg
Level
Reg
Level Reg Level Reg Level
1. TCLP Analyses - RCRA 8 Metals
RCRA Waste
Code Reg Limit
a. Arsenic (ppm; mg/L)D004 5.0 < 0.200 < 0.200
b. Barium (ppm; mg/L)D005 100.0 < 3.00 < 3.00
c. Cadmium (ppm; mg/L)D006 1.0 < 0.0350 < 0.0350
d. Chromium (ppm; mg/L)D007 5.0 < 2.00 < 2.00
e. Lead (ppm; mg/L)D008 5.0 < 2.00 < 2.00
f. Mercury (ppm; mg/L)D009 0.2 < 0.100 < 0.0100
g. Selenium (ppm; mg/L)D010 1.0 < 0.100 < 0.100
h. Silver (ppm; mg/L)D011 5.0 < 0.100 < 0.100
i. UHC Nickel UHC 11.0
2. Total sulfide or cyanide if detected from field monitoring*
a. Cyanide (ppm; mg/L)
b. Sulfide (ppm; mg/L)
*Note: If cyanide or sulfide are present in a sample container, a D003 waste code determination will be necessary.
1540 1541 A-01-001 A-01-002
1. TCLP Analyses - Volatile Constituent for Organic Samples and
UHC Methanol (Nonwastewater)
RCRA TC Waste
Code TCLP Limit
Reg
Level
Reg
Level Reg Level Reg Level
Benzene D018 0.5 < 10.0 < 1.00
Carbon Tetrachloride D019 0.5 < 20.0 < 2.00
Chlorobenzene D021 100 < 20.0 < 2.00
Chloroform D022 6 < 20.0 < 2.00
1,2-Dichloroethane D028 0.5 < 20.0 < 2.00
1,1-Dichloroethylene D029 0.7 < 20.0 < 2.00
Methyl Ethyl Ketone (2-Butanone)D035 200 < 100 < 10.0
Tetrachloroethylene (Perchloroethylene)D039 0.7 < 20.0 < 2.00
Trichloroethylene D040 0.5 < 20.0 < 2.00
Vinyl Chloride D043 0.2 < 10.0 < 1.00
1P or 1,4-Dichlorobenzene D027 7.5 < 20.0 < 2.00
Methanol (UHC Nonwastewater)UHC 0.75
1. UHC Total VOAs Methanol (wastewater) and Xylene Mg/L
Methanol (wastewater)UHC 5.6
Xylene (Nonwastewater)UHC 30
Xylene (wastewater)UHC 0.32
Sample/ Container Number:
Sample/ Container Number:
Sample/ Container Number:
3. Cat 3 pH>2or<12.5 Organic
1540 1541 A-01-001 A-01-002
1. TCLP Analyses - Semi-Volatile Constituent for Organic
Samples
RCRA TC Waste
Code TCLP Level
Reg
Level
Reg
Level Reg Level Reg Level
O-Cresol (2-Methylphenol)D023 200 < 10.0 < 10.0
M-Cresol (3&4-Methylphenol)D024 200 < 10.0 < 10.0
P-Cresol (3&4-Methylphenol)D025 200 < 10.0 < 10.0
Cresol (*Total O-M-P Cresol D026 200
2,4-Dinitrotoluene D030 0.13 < 10.0 < 10.0
Hexachlorobenzene D032 0.13 < 10.0 < 10.0
Hexachloro-1,3-Butadiene D033 0.5 < 10.0 < 10.0
Hexachloroethane D034 3 < 10.0 < 10.0
Nitrobenzene D036 2 < 10.0 < 10.0
Pentachlorophenol D037 100 < 10.0 < 10.0
Pyridine D038 5 < 10.0 < 10.0
2,4,5-Trichlorophenol D041 400 < 10.0 < 10.0
2,4,6-Trichlorophenol D042 2 < 10.0 < 10.0
Sample/ Container Number:
4. Cat 3 Oxidizers Etc
1542 A-01-001 A-01-002
Analyses
RCRA
Waste Code
Off-site Lab
1. pH <2 (Corrosive Acid)D002 < 1.00
2. pH >12.5 (Corrosive Base)D002 < 1.00
3. pH >2 and <12.5 < 1.00
4. Characterization of Sample Container*:
a. Oxidizer Y/N
b. Peroxide Y/N
c. Fluoride Y/N
d. Iodine Y/N
e. Bromine Y/N
f. Chlorine Y/N
g. Ammonia Y/N Y
5. Flash Point (less than or greater than 140 deg F)D001 140 N/A
*Note: If sample contains any material type described by a - g, above, then a waste code determination will be necessary.
1542 A-01-001 A-01-002
Reg Level Reg Level Reg Level
1. TCLP Analyses - RCRA 8 Metals
RCRA
Waste Code Reg Limit
a. Arsenic (ppm; mg/L)D004 5.0 < 0.200
b. Barium (ppm; mg/L)D005 100.0 < 3.00
c. Cadmium (ppm; mg/L)D006 1.0 < 0.0350
d. Chromium (ppm; mg/L)D007 5.0 26.50
e. Lead (ppm; mg/L)D008 5.0 < 2.00
f. Mercury (ppm; mg/L)D009 0.2 0.02
g. Selenium (ppm; mg/L)D010 1.0 < 0.100
h. Silver (ppm; mg/L)D011 5.0 < 0.100
i. UHC Nickel UHC 11.0
2. Total sulfide or cyanide if detected from field
monitoring*
a. Cyanide (ppm; mg/L)
b. Sulfide (ppm; mg/L)
*Note: If cyanide or sulfide are present in a sample container, a D003 waste code determination will be necessary.
Sample/ Container Number:
Sample/ Container Number:
Regulatory Analyses - Enter Sample Date Range Here
4. Cat 4 Oxidizers Etc Organic
1542 A-01-001 A-01-002
1. TCLP Analyses - Volatile Constituent for Organic
Samples and UHC Methanol (Nonwastewater)
RCRA TC
Waste Code TCLP Limit Reg Level Reg Level Reg Level
Benzene D018 0.5 < 1.00
Carbon Tetrachloride D019 0.5 < 2.00
Chlorobenzene D021 100 < 2.00
Chloroform D022 6 < 2.00
1,2-Dichloroethane D028 0.5 < 2.00
1,1-Dichloroethylene D029 0.7 < 2.00
Methyl Ethyl Ketone (2-Butanone)D035 200 < 10.0
Tetrachloroethylene (Perchloroethylene)D039 0.7 < 2.00
Trichloroethylene D040 0.5 < 2.00
Vinyl Chloride D043 0.2 < 1.00
1P or 1,4-Dichlorobenzene D027 7.5 < 2.00
Methanol (UHC Nonwastewater)UHC 0.75
1. UHC Total VOAs Methanol (wastewater) and
Xylene Mg/L
Methanol (wastewater)UHC 5.6
Xylene (Nonwastewater)UHC 30
Xylene (wastewater)UHC 0.32
1542 A-01-001 A-01-002
1. TCLP Analyses - Semi-Volatile Constituent for
Organic Samples
RCRA TC
Waste Code TCLP Level Reg Level Reg Level Reg Level
O-Cresol (2-Methylphenol)D023 200 < 40.0
M-Cresol (3&4-Methylphenol)D024 200 < 40.0
P-Cresol (3&4-Methylphenol)D025 200 < 40.0
Cresol (*Total O-M-P Cresol D026 200
2,4-Dinitrotoluene D030 0.13 < 40.0
Hexachlorobenzene D032 0.13 < 40.0
Hexachloro-1,3-Butadiene D033 0.5 < 40.0
Hexachloroethane D034 3 < 40.0
Nitrobenzene D036 2 < 40.0
Pentachlorophenol D037 100 < 40.0
Pyridine D038 5 < 40.0
2,4,5-Trichlorophenol D041 400 < 40.0
2,4,6-Trichlorophenol D042 2 < 40.0
1. Ammonia and Nitrate Analyses
RCRA
Waste Code
Reporting
Limit (ppm)
a. Ammonia as N
b. Nitrate/Nitrite as N
Sample/ Container Number:
Regulatory Analyses - Enter Sample Date Range Here
Regulatory Analyses - Enter Sample Date Range Here
Sample/ Container Number:
5. Cat 4 Oil Halogenated HCs
A-01-001 A-01-002
Analyses
RCRA Waste
Code Reg Limit
Off-site Lab
1. pH <2 (Corrosive Acid)D002 Y/N
2. pH >12.5 (Corrosive Base)D002 Y/N
3. pH >2 and <12.5 Y/N
4. Halogenated Oil Content >1000 ppm 1000
5. Flash Point (less than or greater than 140 deg F)D001 140
A-01-001 A-01-002
Reg Level Reg Level
1. TCLP Analyses - RCRA 8 Metals
RCRA Waste
Code Reg Limit
a. Arsenic (ppm; mg/L)D004 5.0
b. Barium (ppm; mg/L)D005 100.0
c. Cadmium (ppm; mg/L)D006 1.0
d. Chromium (ppm; mg/L)D007 5.0
e. Lead (ppm; mg/L)D008 5.0
f. Mercury (ppm; mg/L)D009 0.2
g. Selenium (ppm; mg/L)D010 1.0
h. Silver (ppm; mg/L)D011 5.0
i. UHC Nickel UHC 11.0
A-01-001 A-01-002
1. TCLP Analyses - Volatile Constituent for Organic Samples and UHC
Methanol (Nonwastewater)
RCRA TC Waste
Code TCLP Limit Reg Level Reg Level
Benzene D018 0.5
Carbon Tetrachloride D019 0.5
Chlorobenzene D021 100
Chloroform D022 6
1,2-Dichloroethane D028 0.5
1,1-Dichloroethylene D029 0.7
Methyl Ethyl Ketone (2-Butanone)D035 200
Tetrachloroethylene (Perchloroethylene)D039 0.7
Trichloroethylene D040 0.5
Vinyl Chloride D043 0.2
Methanol (UHC Nonwastewater)UHC 0.75
1. UHC Total VOAs Methanol (wastewater) and Xylene Mg/L
Methanol (wastewater)UHC 5.6
Xylene (Nonwastewater)UHC 30
Xylene (wastewater)UHC 0.32
Sample/ Container Number:
Sample/ Container Number:
Sample/ Container Number:
5. Cat 5 Oil Halogenated HCs
A-01-001 A-01-002
1. TCLP Analyses - Semi-Volatile Constituent for Organic Samples
RCRA TC Waste
Code TCLP Level Reg Level Reg Level
O-Cresol (2-Methylphenol)D023 200
M-Cresol (3&4-Methylphenol)D024 200
P-Cresol (3&4-Methylphenol)D025 200
Cresol (*Total O-M-P Cresol (Cresylic Acid) D026 200
1P or 1,4-Dichlorobenzene D027 7.5
2,4-Dinitrotoluene D030 0.13
Hexachlorobenzene D032 0.13
Hexachloro-1,3-Butadiene D033 0.5
Hexachloroethane D034 3
Nitrobenzene D036 2
Pentachlorophenol D037 100
Pyridine D038 5
2,4,5-Trichlorophenol D041 400
2,4,6-Trichlorophenol D032 2
Sample/ Container Number:
6. Peroxide Liquids Sample/
Container Number:
pH
Active Oxygen (ppm)
Oxidizer (Y/N)
ICP Analyses < D.L.mg/Kg
Ag (Silver)NA
Al (Aluminum)
As (Arsenic)
Au (Gold)
B (Boron)
Ba (Barium)
Be (Beryllium)
Bi (Bismuth)
Ca (Calcium)
Cd (Cadmium)
Co (Cobalt)
Cr
Cu (Copper)
Fe (Iron)
Ga (Gallium)
Hg (Mercury)
K (Potassium)
Li (Lithium)
Mg (Magnesium)
Mn (Manganese)
Mo (Molybdenum)
Na (Sodium)
Ni (Nickel)
P (Phosphorus)
Pb (Lead)
Pd (Palladium)
Pt (Platinum)
S (Sulfur)
Sb (Antimony)
Se (Selenium)
Si (Silicon)
Sn (Tin)
Sr (Strontium)
Th (Thorium)
Ti (Titanium)
Tl (Thallium)
U (Uranium)
V (Vanadium)
W (Tungsten)
Zn (Zinc)
Zr (Zirconium)
7. PeroxideSolids Sample/
Container Number:
pH
Active Oxygen (ppm)
XRD Qualitative
Oxidizer (Y/N)
EDX Analyses %%%
Al (Aluminum)
C (Carbon)
Ca (Calcium)
Cl (Chorine)
Cu (Copper)
Fe (Iron)
I (Iodine)
K (Potassium)
Mg (Magnesium)
N (Nitrogen)
Na (Sodium)
O (Oxygen)
P (Phosphorus)
S (Sulfur)
Si (Silicon)
Ti (Titanium)
Note: "-" indicates that the lab analysis sheet did not provide a value for the analyte.
8. AmmoniaSolids Sample/
Container Number:
pH
Active Oxygen (ppm)
Ammonia (mg/Kg)
Total Nitrate as N (mg/L)
XRD Qualitative
Oxidizer (Y/N)
EDX Analyses %%
Al (Aluminum)
C (Carbon)
Ca (Calcium)
Cl (Chorine)
Fe (Iron)
K (Potassium)
Mg (Magnesium)
Na (Sodium)
O (Oxygen)
P (Phosphorus)
S (Sulfur)
Si (Silicon)
Ti (Titanium)
Note: "-" indicates that the lab analysis sheet did not provide a value for the analyte.
9. Oxidizer Solids Sample/
Container Number:
pH
Active Oxygen (ppm)
XRD Qualitative
Oxidizer (Y/N)
EDX Analyses %%%%%
Al (Aluminum)
C (Carbon)
Ca (Calcium)
Cl (Chlorine)
Fe (Iron)
I (Iodine)
K (Potassium)
Mg (Magnesium)
Na (Sodium)
O (Oxygen)
S (Sulfur)
Si (Silicon)
Note: "-" indicates that the lab analysis sheet did not provide a value for the analyte.
1. 698 requires review with Thatcher to determine identification (i.e., lab and or process knowlegde).

APPENDIX K
Disposition Tracking Spreadsheets

PHASE 3 DISPOSITION SPREADSHEET
Thatcher’s disposition spreadsheets have been updated for P3MMP container use or reuse (recycling) or
disposal tracking as follows in Table 1.
Table 1 Disposition Spreadsheet
Worksheet
Column
Description
A "Disposition ID" is used for tracking each container.
-Each container is labeled with the tracking number.
B "Branch Location" UT
C “Date container added to the system”
-This date will auto populate for tracking P3 CCPs and secondary material (not CCP).
D "Flow Status "
Management Status:
-Assigned In Use
-Complete
-Okay to Sell "As Is"
-Pending
-Samples Needed
-Waiting on Final Assignment
-Waiting on Lab Results
E “Labeled As”
F “Safety Data Sheet (SDS) Y (Yes) N (No)”
If column E has a product name an SDS is typically available.
G “Product Number (PNUM)”
H “Quantity”
I “Quantity Used”
J “Quantity Remaining”
K “Location In Warehouse”
L “Batch # (Batch Lot #) to Use In”
M, N, and O
M.“Container Size”
N.“Unit of Measure”
O.“Container Type” (e.g., tote, drum)
P “Liquid, Solid, or Sludge (Semi-solid material)”
Q
“Control Equipment Sludge”
RCRA defined "sludge" (i.e., air pollution control or other pollution control whether it is a
solid, semi-solid, or liquid)
R “Lot #”
-Lot # that this batch originated from
S “Reason for Disposition”
T
“Commercial Chemical Product: Yes (Y) No (N)”
Examples of CCPs include:
-Excess material from processing.
-Returned materials.
-Off-spec materials (those which would have otherwise been a CCP if they had met
specifications)
U “Final Disposition Determination Date of CPP”
V
“Secondary Material: Yes (Y) No (N)”
Examples of secondary materials include:
-Scrubber Material
-Baghouse Material
-Rinse Water
W “Final Disposition Date of Secondary Material”
X “Non-Hazardous, Hazardous Determinations”
Y “Comments”
Z “Created By”
AA “Lab Tests Completed By”
AB “Lab Recommendation Notes”
AC “Lab Assignment”
AD “Products to Use in Rework”
AE “Retest Date”
AF “Disposal Determination Date (Generation Date)”
AG “Tech Services VP Decision”
AH “Tech Services VP Notes”
AI “Item Type (Program Auto Generated Column)”
AJ “Path (Program Auto Generated Column)”
Phase 3 Thatcher Disposition Spreadsheet
Disposition ID
Branch
Location
Date Container
Added to System Flow Status Labeled As
Safety Data Sheet
(SDS) Y (Yes) N (No)PNUM Quantity
Quantity
Used
Quantity
Remaining
Location in
Warehouse
Batch# to
Use In
Phase 3 Thatcher Disposition Spreadsheet
Container Size Unit of Measure
Container
Type
Liquid, Solid, or
Sludge (Semi-solid
material)
Air Pollution
Control Equipment
Sludge (solid, semi-
solid, or liquid)Lot#
Reason for
Disposition
Commercial Chemical
Product (CPP): Yes (Y) or
No (N)
Final Disposition
Determination Date
of CPP
Secondary
Material: Yes (Y) or
No (N)
Phase 3 Thatcher Disposition Spreadsheet
Final Disposition Date
of Secondary Material
Non-Hazardous,
Hazardous
Determinations Comments Created By
Lab Tests Completed
By Lab Recommendation Notes Lab Assignment
Products to use in
Rework Retest Date
Phase 3 Thatcher Disposition Spreadsheet
Disposal
Determination
Date (Generation
Date)
Tech Services
VP Decision
Tech Services VP
Notes Item Type Path

APPENDIX L
Monthly Report

Thatcher P3MMP Monthly Report Date:
Area Date
Number of Containers
Processed
Number of Containers
Repackaged Trailer Number
0 0
P3MMP monthly reports will include the following on the SharePoint site.
1. Written Projec Description.
2. A copy of the inventory forms and spreadsheet created for the area.
3. Description of cleanup of any leak or spill material identified during the P3MICMP process.
Items 1 and 2 will be included in the written project description on Thatchers letterhead with the certification.
Thatcher P3MMP Monthly Report
Area Disposition Review Monthly Data
Totals =
From Area Date
Number of Containers
Moved to NWSA
Number of Containers
Repackaged
Number of
Containers Sampled
and Characterized
Number of
Hazardous
Waste
Containers
Disposed
Number of Non-
Hazardous
Waste
Containers
Disposed
0 0 0 0 0
Thatcher P3MMP Monthly Report
NWSA Monthly Data
Totals =
Date of
Retained
Container Container Number
Number of Containers
Retained for Reuse
0Totals =
Thatcher P3MMP Monthly Report
Use/Reuse (Recycling) Monthly Data

DSHW-2021-023302 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL

Douglas J. Hansen
Director

December 10, 2021

Craig N. Thatcher, President CERTIFIED MAIL
Thatcher Company, Inc. RETURN RECEIPT REQUESTED
1900 Fortune Road 7003 2260 2353 4886
Salt Lake City, UT 84104

RE: Final Signed Stipulation and Consent Order No. 2102006
UTD041307356

Dear Mr. Thatcher:

Please find enclosed a final signed original of Stipulation and Consent Order No. 2102006 for your records.
The effective date of the Stipulation and Consent Order is the date signed by the Director.

If you have any questions, please call Judy Moran at [phone].

Sincerely,

Douglas J. Hansen, Director
Division of Waste Management and Radiation Control

DJH/JAM/kd

Enclosure: Signed Original of Stipulation and Consent Order No. 2102006

c: Angela C. Dunn, MD, MPH, Health Officer, Salt Lake County Health Dept.
Dorothy Adams, Deputy Director, Salt Lake County Health Dept.
Ron Lund, Environmental Health Director, Salt Lake County Health Dept.
Annette Maxwell, USEPA, Region VIII (ENF)
Connie Nakahara, Assistant Attorney General, Office of Utah Attorney General
Ben Machlis, Outside Counsel for Thatcher Company (Email)
Darren Bauer, VP of Safety-Health Environmental, Thatcher Company (Email)
Carlee Christoffersen, Admin. Manager, Div. of Waste Management and Radiation Control, UDEQ
---oo000---
In the Matter of:
THATCHERCOMPANY, INC.
EPA ID UTDO4I3O7356
STIPULATION AND CONSENT
ORDER
No.2102006
---oo0oo---
This STIPULATTON AND coNsENT ORDER C'CONSENT ORDER") is issued by the Dhector of
the Division of Waste Management and Radiation Control ("Director") pursuant to the Utah Solid and
Hazardous waste Act (the "Act"), utah code $ 19-6-101 , et seq.,
^nd,
the utah used oil Management
Act (the "Used oil Act"), utah code $ l9-6-701, er seq., and stipulared ro by Thatcher company, Inc.
("Thatcher").
DET'INITIONS
For purposes of this CONSENT ORDER, terms used herein have the meaning provided for in the Act,
and the regulations implementing the Act, utah Admin. code R 315-260 through 26g (the.,Rules").
JURISDICTION
1. The Director has jurisdiction over the subject matter of this CONSENT ORDER pursuant to
Utah Code $$ 19-6-107 and 19-6-112 and l9-6-705(2)(c). Thatcher stipulates to and will not
challenge issuance of this CONSENT ORDER or the Director's jurisdiction to enter and enforce
this ORDER.
FINDINGS
2. Thatcher is a corporation registered to conduct business in the State ofutah, engaged in the
manufacture and sale of chemical products.
3. Thatcher is a "person" as defined in Utah Code $ 19-1-103(4) and is subject to all applicable
provisions of the Act and the Rules.
4. Thatcher generates and stores solid and hazardous waste, as defined in the Rules, at rts
approximately 3o-acre facility located at 1905 West Fortune Road, Salt Lake City, Salt Lake
County, Utah (hereinafter referred to as the "facility").
5. On August 18, 1980, Thatcher initially notified as a very small quantity generator of hazardous
waste D002 and obtained a U.S. Environmental Protection Agency ("EpA") identification
number. Thatcher changed its generator status to a large quantity generator on May 21,2001 but
did not specify any waste codes. On June 14,2013, Thatcher changed its generator status back
to a very small quantity generator for waste code D002.
Paee 1of9
On January 14, 2014, pursuant to Utah Code gg l9-6-107(2Xd) and 19-6- 109, duly authorized
representatives ofthe Director conducted an inspection ofthe Thatcher facility.r Division
representatives documented:
6 . I . At the time of the inspection, Thatcher blended and repackaged industrial chemicals
generating 4,500 different chemical products by blending about 20 to 30 chemicals.
See 2014Inspection Report at 2.
6.2. "[W]henever a chemical/product is blended inconectly or when spilled[,] the resultltant]
materials are re-blended into other chemicals/products." 1d.
6.3. "Baghouse dusts [were] also re-blended." .Id.
6.4. Thatcher generated "small amounts" ofused oil during maintenance ofgearboxes. 1d.
6.5. Thatcher generated "small amounts" of "various" laboratory wastes. 1d.
On November 14,2019, Thatcher "received draft results ofa voluntary, third-party
environmental compliance audit of their Salt Lake City facility" (',Draft Audit,').2
On November 26,2019, Thatcher emailed a letter to Division staff regarding "Self-Disclosure
under the utah Department of Environmental Quality Self-Evaluation Act" ("self-Disclosure
Letter") to "voluntarily disclose to the Utah Department of Environmental Quality [] instances of
potential non-compliance with laws, regulations, and other requirements relating to the
management of solid and hazardous waste identified in a voluntary third party audit, pursuant to
the Utah Environmental Self-Evaluation Act[]."3 Thatcher's Self-Disclosure Letter siated that:
8. 1 . The Thatcher Draft Audit determined "tie amount of hazardous waste exceeds the
threshold for the site to be considered a Large Quantity Generator[]."
,See Self-Disclosure Letter at !l I.l .
8.2. The Thatcher Draft Audit determined that Thatcher stored certain large quantity
generator amounts of haz ardous waste beyond the 90-day storage period. Id.atlll.
8.3. The Thatcher Draft Audit determined that "the waste analyses, designation, and
associated recordkeeping ofthese materials was insufficient, and that hazardous waste
satellite accumulation containers did not include appropriate labeling." Id. atfll.l.
' See SQG/CESQG Compliance Evaluation lnspection Report ("2014 Inspection Repo* ) (DSHV/-2014-00261).
2 Se€ Self-Disclosure Letter fiom Ben Machlis to Deborah Ng. (November 26, 2019).
3 Thatcher's Self-Disclosure Letter was addressed and submitted by email to Deborah Ng, Urah Division Waste Management
and Radiation Control (Divisiou), Hazardous Waste Section Manager on November 26,2019. By email dated November 27,
20t9, Ms. Ng requested the letter be resubmitted by mail to Mr. Ty Howard, Division Director and by reply email to Ms. Ng
that same day counsel for Thatcher confirmed that the Self-Disclosure Letter had been re-addressed and mailed to Mr.
Howard with a copy to Ms. Ng. The parties have been unable to locate haxdcopies mailed to Mr. Howard and Ms. Ng. In
February 2021, the Director formally acknowledged receipt of Thatcher's Self-Disclosure Letter ad&essed to Ms. Ns.
6.
7.
8.
Page 2 of9
8.4. The Thatcher Draft Audit "identified a substantial amount of materials that were being
stored for rework and recycling" that have insufficient documentation to determine ifthe
"materials" are hazardous waste and meet applicable recycling requirements. Thatcher
stated that "[s]uch material may qualiS as being 'speculatively accumulated' ..." Id. atn
r.z-
8.5. Thatcher had not updated its EPA ID generator status to a large quantity generator
although a Thatcher auditor determined the "facility likely qualifies as [a] [Large
Quantif Generatorl." Id. atll.3.
8.6. The Thatcher Draft Audit identified universal waste management issues, including
"[s]ome containers ofused oil were improperly marked, aerosol cans were not properly
disposed of, and storage time limits were not observ ed;' Id. atll.4.
8.7. Thatcher maintained that the Draft Audit issues "fall[] within the requirements of Utah
DEQ's Audit Policy;' Id. at ffi II.1 - II.8.
9. The Director has not taken a position whether the "potential instances ofnon-compliance"
acknowledged in the Thatcher Self-Disclosure Letter qualifu for a waiver of civil penalties as
specified in the Environmental Self-Evaluation Act, Utah Code $ l9-7-109.
I 0. On March 13,2020, Thatcher updated its EPA ID generator status to a large quantity generator
forwastecodes: D001,D002,D003,D004,D005,D006,D008,D009,D010,DOil.D018.
D035, and D039.
I l. On March 23,2020, Thatcher submitted for Division review and approval a draft.,Waste
lnventory and Characterization Plan" (the "WICP') (DSHW-2020-006313), dated March I l,
2020, that proposed an approach to addressing Thatcher's waste issues identified in the Self-
Disclosure Letter in four phases:
o Phase I - laboratory chemicals;o Phase 2 - an estimated 1,106 containers in the northwest storage area ('NWSA") and an
estimated 200 containers directly east of the NWSA fence line;. Phase 3 - an estimated 650 containers in various onsite storage areas; andr Phase 4 - material management for continuous operation.
See WICP at 6.
12. On April 3,2020, on behalf of Thatcher, Clean Harbors Environmental Services requested the
Director issue a "temporary emergency license [or permit] for onsite treatment of l0 potentially
unstable, hazardous waste containers of [] Hexene (1x100m1), Diethyl Ether (1x4L),
Tetrahydrofiiran (lx4L),1,4 Dioxane (4x100m1), Styrene (lxll,), Acrylonitrile (1x250m1), [and]
Page 3 of 9
tJ.
t4.
2,4 Dinitrophenylhydrazine (lx100g).'{ The Emergency Permit Request stated "[t]he material in
question has been deemed expired or unstable for transport and disposal and will require
treatment prior to shipment."
On April 7,2O2O, the Director issued Emergency permit #UT-010-2020 (DSI{W-2020405287)
to Thatcher to treat 10 potentially unstable containers ofhazardous waste onsite.
The Thatcher Company Hazard Project After-Action Report, dated, Apil23,2020
(DSHW-2020-006633), stated in addition to treatment of the unstable hazardous waste
containers identified in the Emergency Permit Request (DSHW-2020-005606), clean Harbors
treated onsite three additional containers ofunstable compounds: Tehahydrofuran (lxl00rnl),
1,4, Dioxane (lxl0Oml), and Benzoyl Peroxide (lx50g).
Between January - March, 2021, pursuant to Utah Code $$ 19-6-107(2Xd) and 19-6-109,
authorized representatives ofthe Director inspected Thatcher's facility to evaluate compliance
with utah Admin. code R3l5-262-17 and other applicable Rules. Based on observations from
the inspections, on January 29,2021, the Director issued a Notice of Immediate Action Required
(DSHW-2021-001342) to Thatcher requiring certain actions to be taken. In letters dated
February 1,2021,February 5,2021, and March 1,2021, Thatcher provided the responses
required by the Notice of Immediate Action Required. The Division has not yet issued an
inspection report or other documentation of its findings from the inspection.
Thatcher has been implementing the WICP and completed Phase I of the WICp on April 10,
2020. During Phase l, Thatcher characterized a total of 99 containers, 75 of which were
characterized and disposed ofas hazardous waste. The remaining 24 containers were determined
to be non-hazardous. Thatcher completed Phase 2 of the wICP on May 28,2021. During phase
2, Thatcher characterized 1,093 containers in the NWSA. 687 of those containers were
characterized and disposed ofas hazardous waste, and the remaining 406 containers were
identified as non-hazardous. Another 412 containers which were staged next to the NWSA were
also processed in Phase 2,279 of which were characterized and disposed ofas hazardous waste
and 133 were determined to be non-hazardous. Prior to pausing implementation ofphase 3 due
to concerns raised by the Division, Thatcher characterized 55 containers, 40 of which were
characterized and disposed ofas hazardous waste. The remaining 15 containers were identified
as non-hazardous.5 Thatcher will resume implementation of Phase 3 once it receives Division
approval ofthe work plan to be submitted pursuant to tf 18.5.
" See Letter from Jason J. Widows, Clean Harbon Environmental Services, to Ty Howard ("Emergency Permit Request')
(DSHW-2020-005606) (dated April l, 2020).
5 NTD: When Thatcher submitted the letter to the Division on March l, Thatcher indicated that it had inventoried 352 phase
3 containers. This included containers that were located dircctly outside ofthe NWSA; however, in the WICp. those
containers were included in the universe ofPhase 2 containers. This summary will conect the designation ofthese containers
as Phas€ 2 containers instead ofPhase 3 containers.
15.
16.
Page 4 of9
STIPULATION AND CONSENT ORDER
17 . This CONSENT ORDER has been negotiated in good faith and the parties now wish to resolve
the issues identified in the Self-Disclosure Letter and provide for the continued implementation
of the work necessary to address those issues without administrative orjudicial proceedings.
18. The parties hereby stipulate that Thatcher shall manage its hazardous waste without a permit as
follows:
18.1. With respect to all hazardous waste generated at the facility, except as specifically
provided for in !Jfl 18.2 - 18.4 of this CONSENT ORDER, Thatcher shall comply with
all applicable provisions of the Act and its implementing Rules. Nothing in this
CONSENT ORDER authorizes Thatcher to violate or suspend any other state, federal, or
local rule, license, permit, or other mandate.
18.2. Labeling Phase 3 WICP containers:
18.2.1. Thatcher shall label each container storing hazardous material or unknown
material with the actual accumulation date. If the accumulation date is unknown,
Thatcher shall label the container with the "Phase 3 Accumulation Date" which is
the unique date that Thatcher first identifies each Phase 3 container.
18.2.2. On or before the Phase 3 Accumulation Date, Thatcher shall label each hazardous
material and unknown material Phase 3 container with the words "hazardous
waste" and the hazard, ifknown. Thatcher may add a label to containers with
Phase 3 unknown material indicating the designation of hazardous waste
confi rmation is pending.
18.3. Recycling ofknown, Phase 3 material:
18.3.1. Thatcher shall limit the reuse ofPhase 3 material to material stored in containers
in good condition with labels clearly identiffing the chemical contents of the
container. This material may be referenced as ,.known phase 3 material.',
18.3.2. Within in one year of each container's Phase 3 Accumulation Date, at its
discretion and upon proper documentation of legitimate recycling, Thatcher may
reuse known Phase 3 hazardous secondary materials which are commercial
chemical products.
18.3.3. IfThatcher desires to reuse known Phase 3 hazardous secondary materials which
are not commercial chemical oroducts:
Page 5 of9
18.3.3.1 . Thatcher shall request in writing that the Director pre-approve types of
anticipated Phase 3 hazardous secondary materials which are not
commercial chemical products that may be considered for reuse. At a
minimum, Thatcher's request shall include the legitimate recycling criteria
set forth in the Phase 3 work plan in tf 18.5.
18.3.3.2. Upon the Director's written pre-approval to reuse types of material as
specified in !f 18.3.3.1 and upon proper documentation of legitimate
recycling, Thatcher may reuse Phase 3 hazardous secondary materials
which are not commercial chemical products, within nine months of the
Phase 3 Accumulation Date.
18.3.4. Thatcher shall document legitimate recycling in ffi 18.3.2 and 18.3.3 in
accordance with the procedures described in the Phase 3 work plan approved by
the Director in writing as required in !{ 18.5, which shall include detailed criteria
of all information that will be tracked to document the legitimacy of the recycling.
18.4. Unless stored for legitimate recycling in accordance with,lf fl 18.3.2 or 18.3.3.2, Thatcher
may store Phase 3 containers containing hazardous waste for no more than 90 days from
the Phase 3 Accumulation Date. Upon written request, the Director may extend the
hazardous waste storage time in writing upon a demonstration that an extension is
necessary due to unforeseen, temporary, and uncontrollable circumstances.
18.5. On or before 30 days from the effective date of this CONSENT ORDER Thatcher shall
submit to the Director, for review and written approval, a plan and schedule for
completing Phase 3 of the WICP and to assess the immediate risk from uncharacterized
WICP material and anv need for interim measures.
18.5. I . On or before l5 days from the receipt of the plan described in fl 18.5 the Director
will either approve the plan in writing or provide comments to Thatcher.
18.5.1.1. The parties shall meet to discuss and resolve differences regarding the
assessment of onsite risk and the plan to complete phase 3 . If the parties
fail to timely resolve differences, pursuant to Utah Code g l9-6-107, upon
reasonable consideration ofthe potential risk, the Director may separately
order Thatcher to assess and manage the risk from onsite waste
accumulation.
18.5.1 .2. Thatcher shall implement the plan and schedule in fl I 8.5 as approved by
the Director in writing or as separately ordered.
18.6. On or before the 15h day of each month until Phase 3 of the WICP is completed,
Thatcher shall submit a monthly report to the Director surffnarizing its progress,
including the number of containers sampled, the number ofcontainers overpacked,
description ofany discharge of unknown Phase 3 material and the response, and the
number of containers disposed of as hazardous waste and nonhazardous waste.
Page 6 of 9
18.7. To address Utah Code $ 19-7-109(2Xd) and prevent reoccuffence ofthe potential
violations, on or before 90 days from the effective date of this CONSENT ORDE&
Thatcher shall submit to the Director, for review and written approval, a plan outlining
reasonable steps to identiff, characterize, and manage its material, including future
unusable, expired, or discarded chemicals, laboratory reagents, spont solvents, spilled
chemical product, universal waste, used oil, and other discarded material at the facility
and a recordkeeping process to retain inforrnation regarding the chemical traits when
designated as hazardous secondary materials or discarded material. At a minimum, this
plan shall adopt the sirme management procedures as provided in the Phase 3 work plan
required in fl 18.5.
18.7. l . On or before 45 days from the receipt of the plan described in !f I 8.7 the Director
will either approve the plan in writing or provide comments to Thatcher.
18.7.2. The parties shall meet to discuss and resolve differences regarding the plan.
18.'7.3. For a minimum of four years from the date the Director approves the plan,
Thatcher shall comply with the future management plan described in fl 18.7 as
approved by the Director in writing.
18.8. On or before 180 days from the effective date of this CONSENT ORDER, Thatcher shall
submit to the Director, for review and written approval, a plan to evaluate the need to
investigate and conduct corective action at the facility in accordance with Utah Admin.
Code R3l5-263-31 and potentially R3l5-101.
18.8.1. On or before 45 days from the receipt of the plan described in tf 18.8 the Director
will either approve the plan in writing or provide comments to Thatcher.
18.8.2. The parties shall meet to discuss and resolve differences regarding the assessment
of onsite risk. If the parties fail to timely resolve differences, pusuant to Utah
Code $ 19-6-107, upon reasonable consideration ofthe potential risk, the Director
may separately order Thatcher to assess and manage the risk from onsite waste
accumulation.
18.8.3. Thatcher shall comply with the corrective action plan described in !i 18.8 as
approved by the Director in writing.
18.9. All submittals required under this CONSENT ORDER shall be signed by a duly
authorized represetrtative of Thatcher stating, "I certifr under penalty of law that this
document and any and all attachments were prepared under my direction or supervision
according to 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 ofmy knowledge and belief, true, accurate, and
Page 7 of9
19.
20.
complete. I am aware that there are significant penalties for submiuing false information,
including the possibility of fine and imprisonment for knowing violations."
Thatcher agrees to pay for the time reasonably spent by Division staffto review the various plans
and schedules of compliance specified in lJtl 18.5-18.8. Stafftime will be reimbursable at a rate
of $ 1 10 per hour, up to a maximum of I 50 hours. The Division shall send an invoice quarterly,
which invoice shall include sufficient information for Thatcher to determine that the time spent is
reasonable for the review conducted. Thatcher shall pay any undisputed amount invoiced within
60 days of receiving the invoice.
The Director agrees not to bring a separate enforcement action or impose penalties for the
following issues related to wICP Phase 1,2, or 3 hazardous waste stored in good containers and
specifically disclosed in Thatcher's Self-Disclosure Letrer: (i) for failure to timely make
hazardous waste determinations pursuant to R315-262-11; (ii) for storing hazardous waste in lieu
of disposal prrsuant to R3l5-261-2(bX3); and (iii) for failing to comply with the 90-day
accumulation time limit pursuant to R3l5-262-17(a) so long as the material was processed
during Phase 1,2, or 3 of the WICP or is addressed in accordance with this CONSENT ORDER.
The Director further agrees not to bring an enforcement action or impose penalties for the
following additional issues specifically disclosed in Thatcher's self-Disclosure Letter: (i) up
until November 30. 2019, for failure to properly label satellite accumulation conrainers furiuunt
to R315-262-15; (ii) for failure to update and notify as a large quantity generator pursuant to
R3l5-262-18; (iii) up until November 30, 2019, for failure to use best management practices in
managing its universal waste; and (iv) for failure to report in 2019 pursuant to R3l5-262-lg.
Except as specifically set forth in this CONSENT ORDER, including rhis paragraph, this
CONSENT ORDER does not resolve any potential liability for alleged violations of the Act or
the Rules applicable to a large quantity generator, management of hazardous waste in satellite
accumulation storage areas, or related to the discharge of hazardous waste arising from the
Division's inspection of the facility or other times. The Division does not waive its authority to
issue a notice ofviolation, order, or to take otler actions, including seeking penalties relating to
such alleged violations and rhatcher does not waive any right to dispute or contest any such
alleged violations.
EFFECT OF CONSENT ORDER
For the purpose of this CONSENT oRDER, the parties agree and stipulate to the above stated
facts and findings. The obligations in this cONSENT oRDER apply to and are binding upon
the Division of waste Management and Radiation control and upon Thatcher company, Inc. and
any ofThatcher's successors, assigns, or other entities or persons otherwise bound by law
The stipulations contained herein are for the purposes of settlement and shall not be considered
admissions by any party and shall not be used by any person related or unrelated to this
CONSENT ORDER for purposes other than determining the basis of this CONSENT ORDER.
Nothing contained herein shall be deemed to constitute a waiver by the State of Utah of its right
to initiate enforcement action, including civil penalties, against Thatcher for willfully,
knowingly, recklessly, or criminally violating the Act or the Rules; in the event of future non-
compliance with this cONSENT ORDER, with the Act or with the Rules; nor shall the state of
21.
Page 8 of9
L).
24.
Utah be precluded in any way from taking appropriate action should such a situation arise again
at the Thatcher facility. However, entry into this CONSENT ORDER shall relieve Thatcher of
all liability for civil violations which did arise or could have arisen prior to the Effective Date for
matters specifically addressed in this CONSENT ORDER.
EFFECTIVE DATE
This CONSENT ORDER shall become effective upon the date of execution by the Director.
PUBLIC PARTICIPATION
This GoNSENT ORDER shall be subject to public notice and comment for a period of at least
30 days ("Comment Period") in accordance with Utah Admin. Code R3l5-124-34. The Drrecror
reserves the right to withdraw or withhold its consent ifany comment received during the
Comment Period discloses facts or consideration indicating the CONSENT ORDER is
inappropriate, improper, or inadequate.
SIGNATORY
25. The undersigned representative ofthe Thatcher Company, Inc. certifies he is authorized to enter
into this CONSENT ORDER and to execute and legally bind Thatcher Company, Inc.
Pursuant to the utah Solid and Hazardous waste Act (the AcO, utah code $ l9-6-l0l , et seq.,
the parties hereto mutually agree and consent to STIPULATION AND CONSENT ORDER 21 02006 as
evidenced below:
THATCHER COMPANY, INC.THE STATE OF UTAH
DryISION OF WASTE MANAGEMENT
ANDRADIATION CONTROL
Craig N. Thatcher, President
Date: ll /'?{1aaa1-----------=.1-
Douglas J. Hansen, Director
out, tLlqIzozt
Page 9 of 9
4882-7189-0771\7
Thatcher Plan to Address IFC Section 5001.3
IFC Provision Explanation of Relevant Thatcher P3MMP Provisions
5001.3.1 Objective.
The objective of
Section 5001.3 is to
protect people and
property from the
consequences of
unauthorized discharge,
fires or explosions
involving hazardous
materials.
This is a general statement not requiring a specific action. However, the overall purpose of Thatcher’s Phase 3 Material
Management Plan (“P3MMP” or “the Plan”)—in conjunction with Phases 1, 2, and 4—is to obtain compliance, and
maintain compliance going forward, with relevant legal environmental health and safety requirements, including but not
limited to the Utah Solid and Hazardous Waste Act. See P3MMP § 1.
While the contents of many Phase 3 containers is known, the contents of other containers is currently unknown. See
P3MMP §§ 1, 7, 8. A key component of the P3MMP is to characterize all waste on-site and determine how to either
safely dispose of it or safely reuse it, as appropriate. See P3MMP §§ 3.1–3.2 (project purpose), § 7 (characterization
process), § 8 (management decisions process); § 4.2 (explaining that, based on the characterization, an appropriate
management method (disposal or reuse) will be identified which “complies with applicable legal requirements and is
protective of human health and the environment”). The Plan contains detailed procedures for this characterization, waste
handling, and disposition process, managing containers based on a Baseline Preliminary Inventory already conducted.
Further, inspections of container and storage areas have been and are being conducted on a weekly basis to ensure
containers are in good condition and appropriately labelled. See P3MMP §§ 1, 2.3.1, 8.2–8.3. Thatcher also conducts
regular work area inspections during daily operations and promptly and appropriately addresses Containers not in Good
Condition. See P3MMP § 8.3. Any containers found to be Containers not in Good Condition are addressed promptly. See
P3MMP §§ 1, 2.3.1, 8.3. Further, as a part of these procedures, containers will be brought in phases from where they
currently are on-site to the NWSA secondary containment area for disposition review and container management. See
P3MMP § 8.5. The NWSA site is the only on-site location for these activities because it is separated from daily operations,
secure, and has been outfitted with a secondary containment system requested by the Division of Water Quality. See
P3MMP § 8.5. Moreover, the north side of the property is abutted by a large canal that acts as an additional space buffer
between the property and any neighbors. See P3MMP § 2.2. Thus, the P3MMP is designed comprehensively to achieve
what IFC 5001.3.1 is designed to achieve—protection of people and property from potential threats from hazardous waste
that may be on-site—during the implementation of the P3MMP.
5001.3.2 Functional
statements.
Performance-based
design alternatives are
based on the following
functional statements:
The P3MMP specific provisions to prevent and address discharges, fires, or explosions are listed in rows below.
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1. Provide
safeguards to
minimize the risk of
unwanted releases,
fires or explosions
involving
hazardous
materials.
2. Provide
safeguards to
minimize the
consequences of an
unsafe condition
involving
hazardous materials
during normal
operations and in
the event of an
abnormal condition.
5001.3.3 Performance
requirements. Where
safeguards, systems,
documentation, written
plans or procedures,
audits, process hazards
analysis, mitigation
measures, engineering
controls or construction
features are required by
Sections 5001.3.3.1
through 5001.3.3.18,
the details of the design
alternative shall be
subject to approval by
the fire code official.
This is a general statement explaining that the fire code official’s approval will be needed, but not requiring any other
specific action at this time.
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The details of actions
granting the use of the
design alternatives shall
be recorded and entered
in the files of the
jurisdiction.
5001.3.3.1 Properties
of hazardous
materials. The
physical- and health-
hazard properties of
hazardous materials on-
site shall be known and
shall be made readily
available to employees,
neighbors and the fire
code official.
See explanation for 5001.3.1, above.
The P3MMP outlines the extensive tracking that will take place to track area containers, sampling, characterization,
profiling, disposal, and disposition information. See P3MMP § 8.5.3 (describing forms in Appendices H, I, J, K); see also
§ 8.4.1 (describing the Area Disposition Review Form in Appendix G). The Container Tracking and Disposal
Spreadsheets (which are included in Appendix J), will be upload to the Thatcher UDEQ DWMRC SharePoint site monthly
when the monthly report is submitted.
As explained in the P3MMP Sections 1 and 9.1, Thatcher will prepare and submit P3MMP reports to the DWMRC on or
before the 15th of each month until completed. These reports will include “a written project description” and information
about the number of containers processed by area, moved to the NWSA, repackaged, sampled and characterized, disposed
of, retained, and a copy of inventory forms and inspection forms. See P3MMP § 9.1.

5001.3.3.2 Reliability
of equipment and
operations. Equipment
and operations
involving hazardous
materials shall be
designed, installed and
maintained to ensure
that they reliably
operate as intended.
The P3MMP details how hazardous waste is to be safely handled, stored, sampled, and otherwise managed on-site,
including but not limited to in the NWSA. To ensure that equipment is in good, safe working condition and operations
are otherwise in-order and in-compliance, the P3MMP provides for conducting weekly inspections of container and
storage areas, regular work area inspections during daily operations, monthly reporting, and additional as-needed
reporting. The P3MMP also includes limiting access to the NWSA and only allowing trained employees and qualified
contractors (Stantec and Clean Harbors) to be on-site and handling the containers and equipment. Further details are as
follows:
• See P3MMP § 1 Executive Summary — Explains that “Thatcher will continue to inspect the 90-day hazardous waste
storage and Phase 3 areas on a weekly basis” and will observe “all Phase 3 containers weekly to identify Containers
not in Good Condition,” and area managers will document the weekly area inspections. Containers will be inspected
for their condition and managed appropriately, in accordance with the sections cited below.
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• See P3MMP § 2.3.1 — Explains that “Thatcher conducts weekly area monitoring and inspections. Observations from
inspections are recorded on inspection forms and historical inspection forms are archived at the Facility. Containers
observed not to be in good condition are addressed as necessary.”
• See P3MMP § 8:
o § 8.2 (Inspections) — Explains that “The 90-day hazardous waste storage and Phase 3 areas are inspected on a
weekly basis” and inspections are documented in forms “maintained by Thatcher.”
o § 8.3 (Management of ‘Containers Not in Good Condition’) — Describes how there are “regular area monitoring
and inspections,” including but not limited to: “weekly inspections of Phase 3 areas and maintenance of inspection
records”; “regular work area inspections” which result in addressing containers found to be “Not in Good
Condition”; identification of “Containers Not in Good Condition during daily operations” and following
“container management and/or reporting guidelines.” Moreover, “[d]uring inspections, containers found to be
Containers not in Good Condition will be repackaged prior to moving the containers for storage in the NWSA
and will be managed for disposal.”
o § 8.4 (Phase 3 Container Area Review and Management), 8.5 (Disposition and/or Disposal Material
Management), 8.6.4 (Container Repackaging) — Describes how only “knowledgeable staff” and “trained staff”
and qualified contractors (e.g., Stantec, Clean Harbors) will handle the containers, and all information will be
carefully tracked;
• See App’x A § 16 (Thatcher Emergency Response Program) (describing personnel training)
• See App’x B (Solid and Hazardous Waste Management Plan), particularly but not limited to:
o App’x B § 5.2(d) — Requires that “Hazardous Waste Container Inspection Records shall be completed on a
weekly basis for all containers of hazardous waste in designated 90-day hazardous waste storage areas.”
o App’x B § 5.3(a) Container Management Plan, Container Inspections — Requires weekly inspection of
containers of hazardous waste in the 90-day hazardous waste storage areas and/or designated hazardous waste
satellite accumulation areas to check for leaks, deterioration, and labelling condition.
o App’x B § 6 Preparedness and Prevention Plan
 § 6.1(m) — Explains that “Inspections of the 90-day hazardous waste storage areas shall be conducted
weekly and following any emergency response. Equipment shall be tested and maintained.”
 § 6.2(m) Required Equipment for Operation of the Hazardous Waste Storage Areas — Explains that “All
facility communications or alarm systems, fire protection equipment, spill control equipment, and
decontamination equipment, where required, will be tested, and maintained as necessary to assure its
proper operation in time of emergency.”
5001.3.3.3 Prevention
of unintentional
The P3MMP details protocols designed to minimize the risk of unintentional reactions and releases, including through
regular inspections to promptly find and address containers that are not in good condition, separate materials known to
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reaction or release.
Safeguards shall be
provided to minimize
the risk of an
unintentional reaction
or release that could
endanger people or
property.
be incompatible, ensure that containers are closed with limited temporary exceptions, and that site access and container
handling is done only by trained staff and qualified contractors, as detailed below. The P3MMP also minimizes risk to
people and property as a whole through its selection of the NWSA as the on-site location for disposition review and
container management because it has secondary containment and other appropriate lining/draining and security/fencing
features. See P3MMP § 8.5. Moreover, the north side of the property is abutted by a large canal that acts as an additional
space buffer between the property and any neighbors. See P3MMP § 2.2.
• See row above, describing extensive inspections to comply with IFC § 5001.3.3.2, including references to and quotes
from P3MMP §§ 2.3.1, 8.2, 8.3, 8.4, 8.6.
• See P3MMP § 2.3.1 — Describes how the facility maintains and follows the emergency response programs in
Appendix A and Appendix B, and explaining that “Thatcher will direct all reasonable measures necessary to ensure
that fires, explosions, and releases of hazardous waste do not occur, recur, or spread,” including but not limited to:
“Stopping, controlling, or containing the source of the release; Containing the released materials to minimize
spreading; Eliminating or controlling health and safety hazards; Collecting and containerizing released material;
Reporting hazardous waste releases as required by R315-263-30; and Cleaning up and/or treating residual
contamination in-place.”
• See App’x A Thatcher Emergency Response Program (Hazardous Materials Emergency Action Plan EHS-13),
particularly but not limited to:
o § 13.4 (Fire Suppression Plan, Incompatible Materials) — Includes requirement to “Store materials such as
oxidizers and organic peroxides, which produce large amount of oxygen when they decompose, in an area
separate from flammable materials.”
• See App’x B (Solid and Hazardous Waste Management Plan), particularly but not limited to:
o App’x B § 5 Container Management Plan
 App’x B § 5.2(a), (d), (e), (g), (h), (i) — Requires that: all containers be “closed,” labelled, and “handled
carefully to prevent damag[e]”; any damage to containers of hazardous waste “shall be immediately
reported” and addressed accordingly; and “containers of incompatible hazard classes shall be separated by
physical barriers or enough distance to separate potential spills and prevent mixing.”
 App’x B § 5.6 (Incompatible Wastes) — Instructs that: (a) “Incompatible wastes…shall not be placed in the
same containers”; and (b) “only new, reconditioned, or clean drums or containers shall be used for storage
of hazardous waste;” and (c) “Containers of hazardous waste that are incompatible with other hazard wastes
being stored nearby shall be separated by physical barriers (i.e., containment pallets) or enough distance to
separate potential leaking container spills and prevent mixing of incompatible materials.”
 App’x B § 5.3(a), (b) (Container Inspections) — Requires weekly inspection of containers of hazardous
waste in the 90-day hazardous waste storage areas and/or designated hazardous waste satellite accumulation
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areas to check for leaks, deterioration, and labelling condition, and also requires that the containers be stored
“with sufficient space separating each container” so as to allow inspection.
o App’x B § 6 Preparedness and Prevention Plan.
 Section 6 applies specifically to the NWSA 90-day hazardous and non-hazardous waste storage area, as
well as the 90-day lab hazardous waste storage area outside the Building 16 Maintenance Shop, and other
temporary 90-day hazardous waste storage areas that may be established as necessary, and two other
satellite accumulation hazardous waste storage areas. Section 6 describes how access to the hazardous waste
storage areas is restricted, thus minimizing the risk of releases, reactions, or fires caused by untrained
persons. Specifically, a “boundary fence restricts access to most of the site including the NWSA,” and
additional fences restrict access to the containers in the NWSA. See App’x B § 6.0. Access is also limited
to certain personnel with relevant hazardous waste safety training. See App’x B 6.1(a), (b).
 Further, health and safety warning signs are posted in the hazardous waste storage areas. See App’x B § 6.0.
Proper labelling shall also be affixed to and visible on all hazardous waste containers. See App’x B
§ 6.1(d)(1), (2), (4). Risk of spills and reactions is further reduced by requiring that hazardous waste
containers be of “appropriate quality” and “tightly closed,” see App’x B § 6.1(e), and stored only in
designated areas with spill control measures, id. at § 6.1(c), and that lines of drums or containers of
hazardous waste be stored with sufficient space between aisles to “allow the unobstructed movement of
containers, spill control materials, and fire control equipment.” See id. § 6.1(d)(3). Likewise, wastes being
carried or transported “through the workplace to the hazardous waste storage container” must be done so
in “closed” containers that prevent spills if tipped or dropped, and such containers must be “handled
carefully” to prevent spills and to “prevent damage.” See id. § 6.1(i), (j), (k).
 Spill and reaction risk is further reduced through regular weekly inspections of container conditions and
spill response equipment conditions, and any problems are reported immediately and dealt with. See id.
§ 6.1(m), (n).
o App’x B § 7.0, Hazardous Waste Satellite and Universal Waste Accumulation Areas — Minimizes risk of spills
or unintentional reactions by requiring that: employees with access be appropriately trained; “Hazardous
Waste” labels be affixed to and visible on containers as relevant; accumulation containers be stored in a way
that allows inspection and spill control and fire response; containers be “closed”; “grounding straps” be
connected where relevant; and wastes be handled “carefully” during transfer.
5001.3.3.4 Spill
mitigation. Spill
containment systems or
means to render a spill
harmless to people or
The P3MMP details protocols to discover and immediately address, contain, and render harmless any spills. As noted
above, the P3MMP provides for regular inspections and immediate reporting and addressing of any adverse conditions
and spills. The P3MMP is designed to minimize risk to people and property as a whole through its selection of the NWSA
as the on-site location for disposition review and container management because it has secondary containment described
as follows:
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property shall be
provided where a spill
is determined to be a
plausible event and
where such an event
would endanger people
or property.
“The NWSA secondary containment is lined with high density poly-ethylene sheeting, is open-sided, and
has a roof that mostly covers the area. Storm water in the secondary containment is collected for
management. The area directly outside of the NWSA east fence line will be utilized for storage of
repackaged containers pending disposal which will provide room in the NWSA secondary containment to
accelerate the project schedule. Secondary containment for this area consists of asphalt and concrete
surfaces with storm water draining towards and other appropriate lining/draining and appropriate
security/fencing.”
See P3MMP § 8.5. Further, the north side of the property is abutted by a large canal that acts as an additional space buffer
between the NWSA and neighboring or public uses. See P3MMP § 2.2.
Specific spill-containment and spill response actions detailed in the P3MMP include:
• See P3MMP § 2.3 (Emergency Response) — Describes how the facility maintains and follows the emergency
response programs in Appendix A and Appendix B to deal with spills and leaking containers, and explains that
“Thatcher will direct all reasonable measures necessary to ensure that fires, explosions, and releases of hazardous
waste do not occur, recur, or spread,” including but not limited to: “Stopping, controlling, or containing the source of
the release; Containing the released materials to minimize spreading; Eliminating or controlling health and safety
hazards; Collecting and containerizing released material; Reporting hazardous waste releases as required by R315-
263-30; and Cleaning up and/or treating residual contamination in-place.”
• See P3MMP §§ 8.5, 8.6.4, 8.6.5 — Describes the use of secondary containment for container disposition and
management, container repackaging, container handling.
• See P3MMP § 8.5 Disposition and/or Disposal Material Management — Explains that “Clean Harbors will contain
and cleanup any leaking or spilled material identified during movement from the process or container storage area
to the NWSA and will follow Thatcher emergency response plan requirements.”
• See generally App’x A Thatcher Emergency Response Program (Hazardous Materials Emergency Action Plan EHS-
13) — Provides a detailed emergency response and spill response program and protocols, in addition to employee
training, and reporting protocols.
• See App’x B (Solid and Hazardous Waste Management Plan), particularly but not limited to:
o App’x B § 5.2(d) — Instructs that “Any spilled hazardous waste should be immediately contained to minimize
contamination.”
o App’x B § 6.1(b), (c) (Hazardous Waste Storage Areas Maintenance and Normal Operating Procedures) —
Requires that hazardous waste container areas “incorporate spill control measures,” and that employees with
access be appropriately trained in the use of such response measures.
o App’x B § 6.2 — Requires that certain working equipment be maintained in hazardous waste areas that can be
used to deal with emergencies, including communication equipment to report and receive instructions on
8
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emergencies, fire extinguishers, water, spill kit, PPE, decontamination equipment, grounding straps, and an
extra drum ready to receive waste.
o App’x B § 7.0 (Hazardous Waste Satellite and Universal Waste Accumulation Areas) — Advises that outdoor
accumulation drums be “placed on individual spill containment pallets to control any spills or leakage.”
o App’x B § 9 (Contingency Plan and Emergency Procedures) — Details how Thatcher addresses any accidents
involving hazardous waste at its facilities. “This portion of the plan is designed to minimize hazards to human
health or the environment from fires, explosions or any unplanned sudden or nonsudden release of hazardous
waste or hazardous waste constituents to air, soil or surface water.”
 App’x B § 9.2 — Details how the Emergency Coordinator will restrict access to the applicable area,
activate emergency communications, coordinate staff’s emergency response actions, assess the character,
source and extent of the release and possible hazards to human health and the environment in and outside
of the facility, notify appropriate government agencies, determine if evacuation is needed, determine if
shutdown procedures should be initiated, direct measures to prevent or minimize spread of fires and
releases, and conduct appropriate investigations and reporting post-incident.
 App’x B § 9.3(b)(1) — Provides that an “overpack drum” should be available for incident response, to
overpack another drum or contain spill cleanup wastes.
 App’x B § 9.3(b)(7) — Provides that “plastic sheeting” should be available for incident response, “to
control evaporation of volatile chemicals, cover contaminated surfaces, build decontamination areas, and
protect clean surfaces from contamination.
 App’x B § 9.3(a), (b) — Lists many other types of equipment that should be available to be used to respond
to incidents involving hazardous waste, such as fire extinguishers and PPE.
5001.3.3.5 Ignition
hazards. Safeguards
shall be provided to
minimize the risk of
exposing combustible
hazardous materials to
unintended sources of
ignition.
The P3MMP includes detailed protocols designed to avoid and/or minimize the risk of exposing combustible hazardous
materials to ignition, and thereby avoid and/or minimize the risk of fire. Moreover, regular inspections are conducted, as
described above, to identify and respond to any containers not in good condition, thereby further reducing the risk of
fires.
• See P3MMP § 2.3 (Emergency Response) — Describes how the facility maintains and follows the emergency
response programs in Appendix A and Appendix B.
• See P3MMP § 8.6.4 — Requires that in the hazardous waste storage areas, “Non-sparking tools will be used for
containers with ignitable materials and bonding and grounding will be used when transferring material which could
generate friction (e.g., pumping).”
• See App’x A Thatcher Emergency Response Program (Hazardous Materials Emergency Action Plan EHS-13),
particularly but not limited to:
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o App’x A § 13.3 (Fire Suppression Plan, Ignition Sources) — Requires the elimination of “non-essential ignition
sources where flammable materials are used or stored.”
o App’x A § 13.4 (Fire Suppression Plan, Incompatible Materials) — Includes requirement to “Store materials
such as oxidizers and organic peroxides, which produce large amounts of oxygen when they decompose, in an
area separate from flammable materials.”
• See App’x B (Solid and Hazardous Waste Management Plan), particularly but not limited to:
o App’x B § 3.1.21 — Instructs to “use caution and ventilate” when emptying containers previously holding
ignitable materials.
o App’x B § 5.2(b) — Requires that “All containers holding flammable wastes... shall be grounded….”
o App’x B § 5.2(c) — Requires that “Only non-sparking bung wrenches and funnels shall be used for drums
holding flammable wastes.”
o App’x B § 5.5 (Ignitable or Reactive Wastes) — Instructs that “flammable and reactive wastes will be separated
and protected from ignition sources.”
o App’x B § 6.1(f) Preparedness and Prevention Plan — Has requirement to “extinguish smoking materials or
other open flames…”
5001.3.3.6 Protection
of hazardous
materials. Safeguards
shall be provided to
minimize the risk of
exposing hazardous
materials to a fire or
physical damage
whereby such exposure
could endanger or lead
to the endangerment of
people or property.
The P3MMP includes detailed protocols designed to avoid and/or minimize the risk of exposing combustible hazardous
materials to fire or damage, as detailed below. Further, as noted above, the P3MMP is designed to minimize risk to people
and property as a whole through its selection of the NWSA as the on-site location for disposition review and container
management because it has a secondary containment and is buffered to the north by a large canal, and is secured by
fencing. Moreover, regular inspections are conducted, as described above, to identify and address any Containers not in
Good Condition, thereby further reducing the risk of fires.
• See P3MMP § 2.3 (Emergency Response) — Describes how the facility maintains and follows the emergency
response programs in Appendix A and Appendix B.
• See P3MMP § 8.6.4 — Requires that in the hazardous waste storage areas, “[n]on-sparking tools will be used for
containers with ignitable materials and bonding and grounding will be used when transferring material which could
generate friction (e.g., pumping).”
• See App’x A Thatcher Emergency Response Program (Hazardous Materials Emergency Action Plan EHS-13),
particularly but not limited to:
o App’x A § 13.3 (Fire Suppression Plan, Ignition Sources) — Requires the elimination of “non-essential ignition
sources where flammable materials are used or stored.”
o App’x A § 13.4 (Fire Suppression Plan, Incompatible Materials) — Has requirement to “Store materials such as
oxidizers and organic peroxides, which produce large amounts of oxygen when they decompose, in an area
separate from flammable materials.”
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• See App’x B (Solid and Hazardous Waste Management Plan), particularly but not limited to:
o App’x B § 3.1.21 — Instructs to “use caution and ventilate” when emptying containers previously holding
ignitable materials.
o App’x B § 5.2(b) — Requires that “[a]ll containers holding flammable wastes... shall be grounded….”
o App’x B § 5.2(c) — Requires that “[o]nly non-sparking bung wrenches and funnels shall be used for drums
holding flammable wastes.”
o App’x B § 5.5 (Ignitable or Reactive Wastes) — Instructs that “flammable and reactive wastes will be separated
and protected from ignition sources.”
o App’x B § 6.1(f) — Requires that “All workers shall extinguish any smoking materials or other open flames
before entering the drum/container handling facility.”
5001.3.3.7 Exposure
hazards. Safeguards
shall be provided to
minimize the risk of
and limit damage from
a fire or explosion
involving explosive
hazardous materials
whereby such fire or
explosion could
endanger or lead to the
endangerment of
people or property.
In addition to the detailed protocols designed to avoid fires and explosions, as described in the prior two rows, the P3MMP
also includes detailed protocols to respond to and limit damage from fires or explosions, should one occur. Further, as
noted above, the P3MMP is designed to minimize risk to people and property as a whole through its selection of the
NWSA as the on-site location for disposition review and container management because it has a secondary containment
and is buffered to the north by a large canal, and is secured by fencing. Regular inspections are conducted, as described
above, to identify and respond to any containers not in good condition, thereby further reducing the risk of fires. Moreover,
explosive materials have not been encountered, and are not expected to be encountered, during the Phase 3 process.
• See P3MMP § 2.3 (Emergency Response) — Describes how the facility maintains and follows the emergency
response programs in Appendix A and Appendix B.
• See P3MMP § 8.6.4 — Requires that in the hazardous waste storage areas, “[n]on-sparking tools will be used for
containers with ignitable materials and bonding and grounding will be used when transferring material which could
generate friction (e.g., pumping).”
• See App’x A Thatcher Emergency Response Program (Hazardous Materials Emergency Action Plan EHS-13),
particularly but not limited to:
o App’x § 13 (Fire Suppression Plan)
o App’x A § 11 (Incident Command Structures)
o App’x A § 4 (Pre-Emergency Planning and Coordination with Local Fire Departments, Emergency Medical
Personnel, and the LEPC)
o App’x A § 14 (Evacuation Procedures)
• See App’x B (Thatcher Solid and Hazardous Waste Management Plan), particularly but not limited to:
o App’x B § 5.2(b) — Requires that “[a]ll containers holding flammable wastes... shall be grounded….”
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o App’x B § 5.2(c) — Requires that “[o]nly non-sparking bung wrenches and funnels shall be used for drums
holding flammable wastes.”
o App’x B § 5.5 (Ignitable or Reactive Wastes) — Instructs that “flammable and reactive wastes will be separated
and protected from ignition sources.”
o App’x B § 6.2(c) (Preparedness and Prevention Plan) — Requires working fire extinguishers and fire equipment
in the hazardous waste storage areas.
o App’x B § 9 Contingency Plan and Emergency Procedures
 App’x B § 9.3 (Contingency Plan and Emergency Procedures) — Details how Thatcher addresses any
accidents involving hazardous waste at its facilities. “This portion of the plan is designed to minimize hazards
to human health or the environment from fires, explosions or any unplanned sudden or nonsudden release of
hazardous waste or hazardous waste constituents to air, soil or surface water.” Among other things, this plan
details how the Emergency Coordinator will direct measures to prevent or minimize spread of fires and
releases. App’x B § 9.3(a), (b) also lists many other types of equipment that should be available to be used to
respond to incidents involving hazardous waste, such as fire extinguishers and PPE.
 App’x B § 9.5 (Emergency Fire Response Actions) — Details how staff should respond if they encounter a
fire, including one involving hazardous waste, and instructs that the person should notify emergency response
personnel and other employees, confine the fire, extinguish if small, evacuate if large, and aid emergency
response personnel.
 App’x B § 9.6 (Emergency Explosion Response Action) — Directs that the fire protocols under § 9.5 should
be followed.
 App’x B § 9.7 — Provides additional Evacuation Plans
 App’x B § 9.8 — Details further Emergency Reporting Procedures.
 App’x B § 9.9 — Details Management of Waste Produced During an Incident Response.
 App’x B § 9.10 — Instructs on Coordination with Local Authorities in emergency response actions.
5001.3.3.8 Detection
of gas or vapor
release. Where a
release of hazardous
materials gas or vapor
would cause immediate
harm to persons or
property, means of
mitigating the
dangerous effects of a
As noted above, the P3MMP is designed to minimize risks to people and property as a whole through its selection of the
NWSA as the on-site location for disposition review and container management because it has a secondary containment,
is ventilated with open-sides, and is abutted by a large canal that acts as an additional space buffer between the NWSA
and neighboring or public uses. See P3MMP § 2.2.
Additional details in the P3MMP to minimize risks of and/or harms from hazardous gas or vapor are as follows:
• See App’x A (Thatcher Emergency Response Program, EHS-13), particularly but not limited to:
o § 9.5 Flammable Gas Release reporting
o § 9.6 Toxic Gas Release reporting
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release shall be
provided.
o § 12.4, 12.8, 12.12, 12.13.5 — Provides instruction on medical care for exposure to chlorine gas.
o § 16.6–16.8 — Provides for emergency kits and training to contain leaks that “may be encountered in
compressed gas shipping containers.”
o § 17 — Provides instruction on consideration of wind pattern when dealing with evacuation from gas hazard.
• See App’x B § 9 (Thatcher Solid and Hazardous Waste Management Plan, Contingency Plan and Emergency
Procedures), particularly but not limited to:
o App’x B § 9.3(a)(5) — Lists that equipment is available for use in emergency responses to “protect against
inhalation of extremely hazardous substance.
o App’x B § 9.3 (b)(7) — Lists that available for incident response is “plastic sheeting – to control evaporation”
of VOCs.
• See App’x C § 2.1 (Waste Analysis Plan) — Describes procedures for conducing air monitoring prior to accessing
containers.
• See App’x E § 12 (Clean Harbors Health and Safety Plan) — Provides for air Monitoring during characterization,
sampling, transfer, repacking.
5001.3.3.9 Reliable
power source. Where a
power supply is relied
on to prevent or control
an emergency condition
that could endanger
people or property, the
power supply shall be
from a reliable source.
The NWSA 90-day storage secondary containment area is not reliant on power supply to prevent or control emergency
conditions. To the extent that power and lighting are needed to allow safe working conditions in handling waste and in
providing emergency response actions, power and lighting are addressed in Appendix A, Thatcher’s Emergency Response
Program and Appendix B, Thatcher’s Solid and Hazardous Waste Management Plan, as follows:
• See App’x A Thatcher Emergency Response Program (Hazardous Materials Emergency Action Plan EHS-13),
particularly but not limited to:
o § 11.13.4.2 (Instructing that, when placing support facilities in relation to an emergency response, there must be
consideration of the adequacy or resources, including power lines).
• See App’x B § 6.2(j) (Thatcher Solid and Hazardous Waste Management Plan) — Requires that in hazardous waste
storage areas there must be “sufficient lighting to allow safe working conditions at all times wastes are being handled,”
and if such light is not available then only handle wastes in daylight.
5001.3.3.10
Ventilation. Where
ventilation is necessary
to limit the risk of
creating an emergency
condition resulting
from normal or
The NWSA 90-day storage secondary containment area has ample ventilation by virtue of the fact that, although it has a
roof, it is “open-sided.” See P3MMP § 8.5 (describing the NWSA). As an additional precaution, Thatcher’s Solid and
Hazardous Waste Management Plan instructs personnel to “use caution and ventilate” when emptying containers
previously holding ignitable materials. See App’x B § 3.1.21 (Thatcher Solid and Hazardous Waste Management Plan).
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abnormal operations,
means of ventilation
shall be provided.
5001.3.3.11 Process
hazard analyses.
Process hazard analyses
shall be conducted to
ensure reasonably the
protection of people
and property from
dangerous conditions
involving hazardous
materials.
The overall purposes of the P3MMP are to address the potential hazards identified in Thatcher’s 2019 audit of the facility
relating to accumulated materials at the facility, and to come into, and remain in, compliance with applicable legal
requirements relating to the management of solid and hazardous waste, and to ensure the protection of human health and
the environment by addressing and mitigating any dangerous conditions that may exist on the site as a result of those
materials. This is explained in further detail in P3MMP Section 7.1. Following the 2019 evaluation, Thatcher, in
consultation with DWMRC, developed and implemented the Phase 1, 2, and 3 Plans to properly manage, characterize,
and dispose of or recycle the process wastes and stored wastes.
The P3MMP also addresses the possibility that newly generated waste materials may result from the process of
implementing the P3MMP, and it provides that newly generated waste materials as a result of a spill “will be immediately
cleaned up.” See P3MMP § 8.3. Further, “[n]ewly generated investigation-derived wastes (IDW) generated during this
work,” which includes “used Personal Protection Equipment, used disposable sampling equipment, paper shipping waste,
and decontamination materials,” will be “containerized, characterized, classified, and disposed of according to regulatory
requirements” if such materials are “potential characteristic or listed hazardous waste,” and “[a]ll containers of potentially
hazardous waste IDW generated pursuant to the P3MMP will be labeled to identify their contents and left in safe locations
at the site for eventual disposal (pending analyses).” See P3MMP § 8.9.
In addition, as the P3MMP explains in Section 4.3, Thatcher’s Solid and Hazardous Waste Management Plan (App’x B)
includes a Waste Analysis and Designation Plan (App’x B § 3), which “standards are the same for the” P3MMP. The
P3MMP also contains a detailed Waste Analysis Plan (Appendix C) that details the characterization methods, including
field screening and off-site laboratory analyses that will be employed by Thatcher’s qualified contractors, Stantec and
Clean Harbors.
5001.3.3.12 Prestartup
safety review. Written
documentation of
prestart-up safety
review procedures shall
be developed and
enforced to ensure that
operations are initiated
in a safe manner. The
The overall purpose of the P3MMP (and earlier phases) is, in effect, to be a prestart-up review that provides a roadmap
for implementing the characterization, management, and disposition of Phase 3 containers, and to come into, and remain
in, compliance with applicable safety, health, and environmental legal requirements and ensure the protection of human
health and the environment. The P3MMP details the procedures that will be used to safely undertake the field monitoring,
and on-site and off-site analyses that may be necessary for material management under health, safety, and/or statutory
standards. Further, Section 6 summarizes Clean Harbors’ health and safety plan and explains that all field staff will have
appropriate training, and Appendix E contains Clean Harbors’ site-specific health and safety plan. Where the P3MMP
necessitates revisions, Thatcher will coordinate with DWMRC personnel, as well as affected site employees, to make
such requisite updates.
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process of developing
and updating such
procedures shall
involve the
participation of affected
employees.
5001.3.3.13 Operating
and emergency
procedures. Written
documentation of
operating procedures
and procedures for
emergency shut down
shall be developed and
enforced to ensure that
operations are
conducted in a safe
manner. The process of
developing and
updating such
procedures shall
involve the
participation of affected
employees.
The P3MMP is in effect a comprehensive documentation of the operating procedures that Thatcher, Stantec, and Clean
Harbors will use to safely manage, analyze, characterize, handle, and propely dispose of or reuse, if appropriate, the
wastes that are on-site.
The P3MMP also contains comprehensive emergency response procedures, which includes shutdown as necessary, as
detailed below:
• See P3MMP § 2.3 (Emergency Response) — Describes how the facility maintains and follows the emergency
response programs in Appendix A and Appendix B, and explains that “Thatcher will direct all reasonable measures
necessary to ensure that fires, explosions, and releases of hazardous waste do not occur, recur, or spread.”
• See App’x A Thatcher Emergency Response Program (Hazardous Materials Emergency Action Plan EHS-13),
particularly but not limited to:
o App’x A § 20 Shut Down Checklist
o App’x A § 6.5.7 — Explains that employee training may include building shutdown procedures.
o App’x A § 14.1 — Provides for shutdown by supervisors during plant evacuation.
• See App’x B (Thatcher Solid and Hazardous Waste Management Plan),
o App’x B § 6.2(c) — Provides for shutdown by supervisors during plant evacuation.
o App’x B § 9.2(a)(11) — Instructs that the Emergency Coordinator will determine if shutdown is necessary.
o App’x B § 9.5(c) — Instructing that persons in an area involved in a fire should shut down equipment nearby.
The P3MMP Appendix B also provides for the possibility that operating and emergency procedures may require updating,
and involves participation of affected employees as follows:
o App’x B § 9.2(b) — Requires that post-incident, the Emergency Coordinator must conduct appropriate
investigations to “assess the effectiveness of the response actions and how they may be improved; and determine
if any changes to the facility’s response procedures can be made to improve the quality of the facility’s
emergency preparedness.”
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o App’x B § 9.11 (Amendment of Contingency Plan) — Requires the Contingency Plan to be reviewed and
amended if regulations are revised, the plan fails in an emergency, the emergency equipment changes, the
emergency coordinator changes, the facility changes in a way that materially increases the potential for fires,
explosions, or releases … or changes the response necessary in an emergency….”
5001.3.3.14
Management of
change. A written plan
for management of
change shall be
developed and
enforced. The process
of developing and
updating the plan shall
involve the
participation of affected
employees.
The P3MMP contemplates that changes in personnel and operating conditions may arise and provides protocols to address
such situations as detailed below. In addition, the P3MMP as a whole is designed to address unknown and changing on-
site conditions and hazards, and provides the analysis, prioritization, and decision-making framework to manage this.
• See App’x A Thatcher Emergency Response Program (Hazardous Materials Emergency Action Plan EHS-13),
particularly but not limited to:
o App’x A § 6.5.6 and §16.9 — Provides for employee training when an employee’s responsibilities change or
there are changes to the emergency action plan.
• See App’x B (Thatcher Solid and Hazardous Waste Management Plan), particularly but not limited to:
o App’x B § 9.2(a)(19), (b) — Instructs that the emergency contingency plan must be reviewed and amended after
any response action and also if the facility changes design, operations, equipment, emergency coordinators, or
otherwise changes “in a way that materially increases the potential for incidents.”
o App’x B § 9.11 (Amendment of Contingency Plan) — Requires the Contingency Plan to be reviewed and
amended if regulations are revised, the plan fails in an emergency, the emergency equipment changes, the
emergency coordinator changes, the facility changes in a way that materially increases the potential for fires,
explosions, or releases … or changes the response necessary in an emergency….”
5001.3.3.15
Emergency plan. A
written emergency plan
shall be developed to
ensure that proper
actions are taken in the
event of an emergency,
and the plan shall be
followed if an
emergency condition
occurs. The process of
developing and
updating the plan shall
The P3MMP contains comprehensive emergency response procedures to ensure that proper actions are taken in the event
of an emergency, as detailed below:
• See P3MMP § 2.3 (Emergency Response) — Describes how the facility maintains and follows the emergency
response programs in Appendix A and Appendix B to deal with spills and leaking containers, and explains that
“Thatcher will direct all reasonable measures necessary to ensure that fires, explosions, and releases of hazardous
waste do not occur, recur, or spread,” including but not limited to: “Stopping, controlling, or containing the source of
the release; Containing the released materials to minimize spreading; Eliminating or controlling health and safety
hazards; Collecting and containerizing released material; Reporting hazardous waste releases as required by R315-
263-30; and Cleaning up and/or treating residual contamination in-place.”.
• See App’x A Thatcher Emergency Response Program (Hazardous Materials Emergency Action Plan EHS-13) and
Standard Operating Procedure (SOP) Environmental Health and Safety (EHS-29)
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involve the
participation of affected
employees.
o The EHS-13 plan includes detailed protocols for: pre-emergency planning and coordination with local fire
departments, emergency medical personnel, and the LEPC; employee alarm systems and employee training;
evacuation plans; recognition of emergencies and related employee training; reporting an emergency internally
and externally, with specific requirements for different types of emergencies; emergency communications
internally and externally; incident command structures and site control and security; medical and first aid for
different types of emergencies and exposures; a fire suppression plan and related employee training;
evacuation procedures; overall personnel training for emergencies and safe operations; decontamination, PPE,
and emergency equipment, a shutdown checklist; availability of emergency phone numbers; critique of a
response after one has occurred and appropriate follow-up.
o The EHS-29 plan provides additional procedures for documenting and reporting chemical spills and releases.
• See App’x B (Thatcher Solid and Hazardous Waste Management Plan), particularly but not limited to:
o App’x B § 6.2 — Requires that certain working equipment be maintained in hazardous waste areas that can
be used to deal with emergencies (e.g., communication equipment to report and receive instructions on
emergencies, fire extinguishers, water, spill kit, PPE, decontamination equipment, grounding straps, extra
drum ready to receive waste).
o App’x B § 9 (Contingency Plan and Emergency Procedures) — Details how Thatcher will address accidents
involving hazardous waste at its facilities in order to “minimize hazards to human health or the environment
from fires, explosions or any unplanned sudden or nonsudden release of hazardous waste or hazardous waste
constituents to air, soil or surface water.”
 App’x B § 9.2 — Details how the Emergency Coordinator will restrict access to the applicable area,
activate emergency communications, coordinate staff’s emergency response actions, assess the character,
source and extent of the release and possible hazards to human health and the environment in and outside
of the facility, notify appropriate government agencies, determine if evacuation is needed, determine if
shutdown procedures should be initiated, direct measures to prevent or minimize spread of fires and
releases, and conduct appropriate investigations and reporting post-incident.
 App’x B § 9.3 —Lists the equipment that will be available for incident response, such as an “overpack
drum,” “plastic sheeting” “to control evaporation of volatile chemicals, cover contaminated surfaces, build
decontamination areas, and protect clean surfaces from contamination,” fire extinguishers, and PPE.
 App’x B § 9.5 Emergency Fire Response Actions — Details how staff should respond if they encounter a
fire, including one involving hazardous waste, and instructs that the person should notify emergency
response personnel and other employees, confine the fire, extinguish if small, evacuate if large, aid
emergency response personnel.
 App’x B § 9.6 Emergency Explosion Response Action — Directs that the fire protocols under § 9.5 should
be followed.
 App’x B § 9.7 — Provides additional Evacuation Plans
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 App’s B § 9.8 — Details further Emergency Reporting Procedures.
 App’x B § 9.9 — Details Management of Waste Produced During an Incident Response.
 App’x B § 9.10 — Instructs on Coordination with Local Authorities in emergency response actions.
The P3MMP also provides for the possibility that operating and emergency procedures may require updating, and
involves participation of affected employees as follows:
o App’x B § 9.2(b) — Requires that post-incident, the Emergency Coordinator must conduct appropriate
investigations to “assess the effectiveness of the response actions and how they may be improved; and
determine if any changes to the facility’s response procedures can be made to improve the quality of the
facility’s emergency preparedness.”
o App’x B § 9.11 (Amendment of Contingency Plan) — Requires the Contingency Plan to be reviewed and
amended if regulations are revised, the plan fails in an emergency, the emergency equipment changes, the
emergency coordinator changes, the facility changes in a way that materially increases the potential for fires,
explosions, or releases … or changes the response necessary in an emergency….”
5001.3.3.16 Accident
procedures. Written
procedures for
investigation and
documentation of
accidents shall be
developed, and
accidents shall be
investigated and
documented in
accordance with these
procedures.
The P3MMP contains comprehensive procedures to investigate and document accidents, both ensure that proper actions
are taken in the event of an emergency, and to assess accident responses or emergency responses and make appropriate
changes, as detailed below:
• See P3MMP § 2.3 (Emergency Response) — Describes how the facility maintains and follows the emergency
response programs in Appendix A and Appendix B to deal with spills and leaking containers, and explaining that
“Thatcher will direct all reasonable measures necessary to ensure that fires, explosions, and releases of hazardous
waste do not occur, recur, or spread.”
• See App’x A Thatcher Emergency Response Program (Hazardous Materials Emergency Action Plan EHS-13) and
Standard Operating Procedure (SOP) Environmental Health and Safety (EHS-29):
o The EHS-13 plan includes detailed protocols for accident investigation and documentation, including but not
limited to: employee alarm systems and employee training; evacuation plans; recognition of emergencies and
related employee training; reporting an emergency internally and externally, with specific requirements for
different types of emergencies; emergency communications internally and externally; and critiquing a
response after one has occurred and appropriate follow-up.
o The EHS-29 plan provides additional procedures for documenting and reporting chemical spills and releases
both internally and externally.
• See App’x B (Thatcher Solid and Hazardous Waste Management Plan), particularly but not limited to:
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o App’x B § 9.2 (Contingency Plan and Emergency Procedures) — Details how the Emergency Coordinator will
restrict access to the applicable area, activate emergency communications, coordinate staff’s emergency
response actions, assess the character, source and extent of the release and possible hazards to human health
and the environment in and outside of the facility, notify appropriate government agencies, determine if
evacuation is needed, determine if shutdown procedures should be initiated, direct measures to prevent or
minimize spread of fires and releases. See App’x B § 9.2
o App’x B § 9.2(b) — Requires that post-incident, the Emergency Coordinator must conduct appropriate
investigations to “assess the effectiveness of the response actions and how they may be improved; and
determine if any changes to the facility’s response procedures can be made to improve the quality of the
facility’s emergency preparedness.”
5001.3.3.17
Consequence analysis.
Where an accidental
release of hazardous
materials could
endanger people or
property, either on or
off-site, an analysis of
the expected
consequences of a
plausible release shall
be performed and
utilized in the analysis
and selection of active
and passive hazard
mitigation controls.
The overall purpose and effect of the 2019 analysis and subsequent development of the Phase 1, 2, and 3 plans was to:
analyze Thatcher’s site operations, site processes, and materials; assess the condition of containers on-site and the
character of their contents; assess the possibility and consequences of a possible release; and, based on that information,
make determinations on how to handle such wastes, implement operational procedures to avoid release and spills, and
create emergency response actions if a spill were to occur. The P3MMP is an operating procedure and framework for
conducting consequence analyses and selecting appropriate hazard mitigation controls through its materials waste
characterization and analysis provisions and waste disposition and management decision-making protocols.
Moreover, the NWSA was designated as the area for disposition review and container management, as it is the best-
equipped area to address and mitigate the consequences of a spill if one were to occur. The NWSA has secondary
containment and other appropriate lining/draining and security/fencing features. See P3MMP § 8.5. The north side of the
property is abutted by a large canal that acts as an additional space buffer between the property and neighboring or public
uses. See P3MMP § 2.2. Moreover, the NWSA has ample ventilation by virtue of the fact that, although it has a roof, it
is “open-sided.” See P3MMP § 8.5 (describing the NWSA).
As noted above, the P3MMP provides detailed procedures to safely undertake the field monitoring, and on-site and off-
site analyses and to make materials management determinations pursuant to health, safety, and/or statutory standards.
While the overall purpose of the P3MMP and its detailed operating procedures is to avoid releases, it also provides robust
spill response and emergency response procedures, as detailed in prior rows.
5001.3.3.18 Safety
audits. Safety audits
shall be conducted on a
periodic basis to verify
compliance with the
The P3MMP contains a number of provisions, from employee training to regular reviews and inspections of the facility,
to ensure the protocols of the Plan are being followed and to ensure that containers and related equipment are in good
working conditions. To ensure that containers, storage areas, and equipment are in good, safe working condition and
operations are otherwise in-order and in-compliance, the Plan provides for conducting regular weekly inspections of
storage areas and containers, daily inspection, monthly public reporting, and additional as-needed reporting. See P3MMP
§§ 1, 8.0–8.3. The Plan also includes limiting access to the NWSA and only allows access for trained employees and
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requirements of this
section.
qualified contractors (Stantec and Clean Harbors) to be on-site and handling the containers and equipment. Further details
are as follows:
• See P3MMP § 1 Executive Summary — Explains that “Thatcher will continue to inspect the 90-day hazardous waste
storage and Phase 3 areas on a weekly basis” and will observe “all Phase 3 containers weekly to identify Containers
not in Good Condition,” and area managers will document the weekly area inspections. Containers will be inspected
for their condition and managed appropriately, in accordance with the sections cited below.
• See P3MMP § 2.3.1 — Explains that “Thatcher conducts weekly area monitoring and inspections. Observations from
inspections are recorded on inspection forms and historical inspection forms are archived at the Facility. Containers
observed not to be in good condition are addressed as necessary.”
• See P3MMP § 8:
o § 8.2 (Inspections) — Explains that “The 90-day hazardous waste storage and Phase 3 areas are inspected on a
weekly basis” and inspections are documented in forms “maintained by Thatcher.”
o § 8.3 (Management of ‘Containers Not in Good Condition’) — Describes how there are “regular area monitoring
and inspections,” including but not limited to: “weekly inspections of Phase 3 areas and maintenance of inspection
records”; “regular work area inspections” which result in addressing containers found to be “Not in Good
Condition”; identification of “Containers Not in Good Condition during daily operations” and following
“container management and/or reporting guidelines.” Also describes how any “During inspections, containers
found to be Containers not in Good Condition will be repackaged prior to moving the containers for storage in
the NWSA and will be managed for disposal.”
o § 8.4 (Phase 3 Container Area Review and Management).
o § 8.5 (Disposition and/or Disposal Material Management.
o § 8.6.4 (Container Repackaging) — Describes how only “knowledgeable staff” and “trained staff” and qualified
contractors (e.g., Stantec, Clean Harbors) will handle the containers, and all information will be carefully tracked.
• See App’x A § 16 (Thatcher Emergency Response Program) (describing personnel training)
• See App’x B (Solid and Hazardous Waste Management Plan), particularly but not limited to:
o App’x B § 5.2(d) — Requires that “Hazardous Waste Container Inspection Records shall be completed on a
weekly basis for all containers of hazardous waste in designated 90-day hazardous waste storage areas.”
o App’x B § 5.3(a) Container Management Plan, Container Inspections — Requires weekly inspection of
containers of hazardous waste in the 90-day hazardous waste storage areas and/or designated hazardous waste
satellite accumulation areas to check for leaks, deterioration, and labelling condition.
o App’x B § 6 Preparedness and Prevention Plan
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 § 6.1(m) — Explains that “Inspections of the 90-day hazardous waste storage areas shall be conducted
weekly and following any emergency response. Equipment shall be tested and maintained.”
 § 6.1(n) — Requires that Hazardous Waste Container Inspection records be “completed on a weekly basis
for all containers of hazardous waste,” and written records be promptly delivered to the Safety-Health-
Environment Department, while also requiring that any observed leaking or potential leaking be reported
“immediately.”
 § 6.2(m) Required Equipment for Operation of the Hazardous Waste Storage Areas — Instructs that “All
facility communications or alarm systems, fire protection equipment, spill control equipment, and
decontamination equipment, where required, will be tested, and maintained as necessary to assure its
proper operation in time of emergency.”