Hazardous Waste Shipping Procedures
Pre-transport regulations are designed to provide safe transportation of a hazardous waste from origin to ultimate disposal. The pre-transport regulations used by the Department of Transportation (DOT) for transporting hazardous waste (49 CFR 172, 173, 178, and 179) were adopted by the South Carolina Public Service Commission and are referenced in R.61-79.262. These pre-transport regulations apply only to hazardous waste shipped off site.
Labeling and Marking
An approved hazardous waste label (Figure III-3) shall be affixed to each hazardous waste container prior to off-site shipment. Labeling requirements and marking regulations are found in R.61-79.262 and 49 CFR 172.101, Hazard Material Table. These regulations specify the following:
- containers must be labeled in accordance with the DOT Hazardous Materials Table (available from the Hazardous Materials Manager); and
- containers must be marked with the following information:
- Proper chemical name
- Percent of constituents if applicable
- EPA waste codes
- University Tracking I.D. number
- Accumulation Date
The Hazardous Materials Manager is responsible for ensuring this information is provided prior to off-site shipment.
When hazardous waste is shipped off-site for treatment or disposal, it must be accompanied by a properly completed and signed Uniform Hazardous Waste Manifest. This form has multiple copies for distribution as described in this section. The facility to which the waste will be shipped will provide a copy of the blank manifest to Clemson University. Blank manifests may also be obtained from SCDHEC. Emergency response information for each waste shipped must accompany all manifest.
The Uniform Hazardous Waste Manifest must be completed by Clemson University before offering any hazardous wastes for shipment. To facilitate record keeping, the manifests are numbered in sequential order and no numbers are skipped.
The information listed in line 9b of the Hazardous Waste Manifest (US DOT Description) must comply with DOT requirements (49 CFR 172.101) for proper shipping name, hazard class and identification number.
The quantity is to be specified by a whole number only (line11) and includes the entire container. The units for this quantity (line 12) must also conform to DOT standards. SC Hazardous Waste Management Regulations require that the units be listed on the manifest in pounds.
The EPA waste code number for each waste listed in line 9b must be identified in line 13.
As a generator of hazardous waste, Clemson University is responsible for initiating the manifest with each shipment of waste. The generator completes the sections of the manifest outlined above and signs and dates the appropriate section of the manifest. At the time the waste is picked up, the transporter signs and dates the manifest in the appropriate section indicating that he has accepted the waste and agrees to deliver it to the designated treatment, storage or disposal facility.
The generator must keep one copy of the manifest, which has been signed by the generator and transporter for each shipment of waste made to a hazardous waste facility. The original copy of the manifest must accompany the waste shipment along with two additional copies. Once the disposal facility receives the waste, the facility representative signs the manifest and returns it to the generator. Clemson University must retain the returned copy of the manifest signed by the receiving treatment, storage or disposal facility for three years from the date of shipment. Copies of manifests for shipments of hazardous waste sent out of South Carolina must be submitted to SCDHEC within 45 days of receiving the returned copy of the manifest from the disposal facility.
Land Disposal Restriction Certification
Listed and characteristic hazardous wastes have been evaluated by EPA to determine their suitability for land disposal. The result of this evaluation is a treatment standard for each waste. Any waste meeting the treatment standards may be land disposed without restriction in a RCRA land disposal unit. If the treatment standard for a waste is not met, the waste cannot be land disposed without prior treatment.
Information defining the restricted wastes and their treatment standards is available from the Manager of Environmental Programs. Whether the waste is restricted under the Land Disposal Restrictions 40 CFR Part 268 will be determined by testing the waste or using knowledge of the waste. At the time the waste is shipped for off-site disposal, a Notification and Certification Form must be completed in full and must accompany the shipment. This form will identify the appropriate land disposal treatment standards and whether or not these standards have been met.
All laboratory analyses used to determine if a waste is subject to the land disposal restrictions will be conducted in accordance with approved EPA test methods and procedures. For wastes with treatment standards expressed as constituent concentrations in the waste extract (40 CFR 268.41), waste residues or an extract of such residues will be tested using the toxicity characteristic leaching procedure (TCLP). For wastes with treatment standards expressed as constituent concentrations in the waste (40 CFR 268.43), waste residues will be tested using a total constituent analyses (TCA).
Clemson University is responsible for providing the transporter with the proper placards when required to comply with DOT shipping and labeling requirements. If more than 1,000 pounds of flammable and/or combustible material are offered for shipment at one time, the placards for flammable and/or combustible material must be provided. The appropriate placards will be maintained at the facility or will be purchased by Clemson University prior to shipping quantities requiring placarding. Placards must be located on all sides of the motor vehicle.
Record keeping and Reporting
One copy of each manifest prepared for a hazardous waste shipment must be kept at the facility until the original signed copy is returned from the disposal facility which received the waste. The copy signed by Clemson University, the transporter and the receiving facility must be maintained at the facility for three years from the date of shipment. If a hand-signed copy is not returned from the disposal facility within 35 days of the shipping date, Clemson University must contact the transporter or the disposal facility to determine the status of the hazardous waste.
If the completed manifest has not been returned from the disposal facility within 45 days of the date the waste was shipped from Clemson University, the Hazardous Materials Manager will submit an Exception Report to SCDHEC. The report must contain a copy of the manifest retained by Clemson University and a letter of explanation stating what efforts have been made to locate the completed manifest and the results of those efforts.
All manifests and exception reports must be maintained at the facility for at least three years from the date the report was filed or the waste shipment was made.