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Environmental Management ProgramPurpose This program provides general procedures and guidelines for [COMPANY] environmental management program. The [COMPANY] environment includes the soil, water, air, and natural habitat within and around [COMPANY] boundaries. This program defines and establishes the responsibilities of the Environmental Management Department (EM) and [COMPANY] facility manager for managing and conducting environmental activities. This program also ensures the cooperation and support of all [COMPANY] facilities in an effort to achieve the environmental goals of the [company] to meet Federal, State, and Local environmental regulatory requirements. Applicability This Directive applies to all [COMPANY] facilities, employees and on-site contractors. Definitions Air Releases. Release of substances to the air that are known to cause, or reasonably anticipated to cause, death, injury, or serious adverse effects to human health or the environment. Biohazardous Sharps Waste. Devices capable of cutting or piercing that are contaminated with biohazardous waste. Examples include contaminated hypodermic needles, scalpels, razor blades, X-acto blades, and box cutter blades. Bio-hazardous Waste. Waste (including animal carcasses) contaminated with infectious agents known to cause human illness and not contaminated with radioactive materials or hazardous chemicals. Controlled Waste. Waste streams not classified as hazardous (according to regulation) but that require specific processing, handling, or disposal different from other solid wastes. Dangerous Spill. A spill of materials or waste that may be a threat to human health or the environment if not contained and controlled. Debris. Solid material exceeding a 60-millimeter particle size, intended for disposal, and is a manufactured object, or plant or animal matter, or natural geologic material. However, the following materials are not debris: any material for which a specific treatment standard is provided in 40 CFR, Subpart D, Part 268, namely lead acid batteries, cadmium batteries, and radioactive lead solids; process residuals such as smelter slag and residues from the treatment of waste, wastewater, sludge, or air emission residues; and intact containers of hazardous waste that are not ruptured and that retain at least 75 percent of their original volume. A mixture of debris that has not been treated to the standards provided by 40 CFR 268.45 and other material is subject to regulation as debris if the mixture is comprised primarily of debris, by volume, based on visual inspection. Empty Acutely Toxic Container. A container or inner liner removed from a container that has held an acutely hazardous waste is empty if the container or inner liner has been triple rinsed using a solvent capable of removing the commercial chemical product or manufacturing chemical intermediate. ("Triple rinse" refers to containers that have been flushed three times, each time using a volume of diluent at least equal to 10 percent of the capacity of the container. This solution should be collected in a properly labeled container.) Empty Compressed Gas Cylinder. A container that has held a hazardous material that is a compressed gas is empty when the pressure in the container approaches atmospheric pressure. Empty Container. A container or an inner liner removed from a container that held any hazardous material/waste, except a compressed gas or a container that is identified as an acute hazardous waste is empty if all removable materials have been removed using the practices commonly employed to remove materials from that type container (e.g., pouring, pumping, and aspirating); no more than one inch of residue may remain on the bottom of the container. Note: Empty containers can be hazardous. Environmental Activities. Includes all projects, studies, analyses, monitoring, and operational involvement of [COMPNAY] operations where the objective is pollution abatement and/or improvement of environmental quality. Included are such activities as environmental assessments, environmental impact statements, construction and operational permits, air and water quality modeling and monitoring systems, ecological baselining, plant operations, effluent monitoring, sanitary landfill, and pesticides applications. Hazardous Material. Any material defined as hazardous under 29 CFR 1910.120(c) and includes material presenting health and/or physical hazard; such material has one or more toxic, flammable, corrosive, or reactive properties. Hazardous Waste. A waste or combination of wastes that can pose a substantial or potential hazard to human health or the environment when not properly managed; possesses at least one of four characteristics (ignitable, corrosive, reactive, or toxic) or appears on special EPA lists; includes toxic waste, spilled materials, and unused chemicals. Hazardous Waste Generator. Organization that creates hazardous waste byproducts. Investigation-Derived Waste (IDW). Waste generated during well drilling (soil cuttings), purged water from monitoring wells, rinse waters, etc., from investigations of potentially contaminated sites. Maximum Achievable Control Technology. Technology required for major sources of listed hazardous air pollutants, reflecting maximum degree of emission reductions achievable, taking into account availability, cost, and other factors. Medical Waste. Bio-hazardous waste, bio-hazardous sharps,waste, and pathology waste. Noncompliance Activities. Areas where environmental activities are not in compliance with Federal, State, and local environmental laws and regulations. Pathology Waste. Recognizable human anatomical parts and fixed human surgery specimens and tissues. Recycling. The diversion of materials from the solid waste stream and the beneficial reuse of such materials. Small Spill. Any spill that is not dangerous and can be properly cleaned up by the personnel responsible for the spill. Solid Waste. Garbage, refuse, sludge, and other discarded solid materials, including solid waste materials resulting from industrial, commercial, and agricultural operations, and from community activities; but does not include solid or dissolved materials in domestic sewage or other significant pollutants in water resources, such as silt, dissolved or suspended solids in industrial wastewater effluents, dissolved materials in irrigation return flows, or other common water pollutants. Special Waste. A waste that does not fall into the categories of hazardous or nonhazardous waste. Examples are spray on foam insulation, media blasting, batteries, universal waste, used oil. Storm Water. Any runoff water or contained water resulting from rain. Underground Storage Tank (UST). A storage tank and its integral piping system that has greater than 10 percent of its storage capacity in contact with the ground. Universal Waste. Those wastes that would normally be regulated as hazardous wastes, but that have been classified as "universal wastes" with alternative management standards. Examples include batteries, pesticides, mercury-containing thermostats, and lamps Used Oil. Any oil that has been refined from crude oil or synthetic oil, will no longer be used for its original purpose, and must be disposed of or recycled. Responsibilities [COMPANY] Management is responsible for all environmental compliance activities at all company facilities. The Environmental Manager (EM) has overall environmental responsibilities as the center focal point for environmental activities. Under the delegated authority of the [COMPANY] owners, the EM provides continuous surveillance, review, evaluation, and assurance of environmental activities at all levels throughout the company. Under this authority, the EM has control for approval or cessation of all phases of acquisition and operation of hazardous or potentially hazardous facilities, systems, or equipment that may result in noncompliance with regulatory standards. All facility managers shall ensure that internal organizational plans and procedures are maintained to implement and comply with the Federal, State, and Local environmental laws and regulations. Procedures Personnel Training and Certification. As required to meet Federal, State, and Local regulations, ordinances, and guidelines, all personnel involved in hazardous waste operations and transportation, chemical inventory, storm water management, asbestos, lead, and PCB abatement activities, emergency and chemical spill activities are required to undergo a training and certification program. Supervisors are responsible for ensuring that their employees complete the appropriate training. Hazardous Waste Operations and Emergency Response (HAZWOPER) (29 CFR 1910.120). Employees designated to participate in emergency response operations or site remediation must be trained and certified before taking part in actual emergency operations and must receive annual refresher training. Annual refresher training is provided by the EM and meets OSHA 29 CFR 1910.120 requirements. Records of training and certification shall be retained by the employer for at least 5 years. Hazardous Waste Personnel Training. Training and certification must be given to all hazardous waste operations personnel working at any [COMPANY] Hazardous Waste Storage Facilities. This training must occur within six months of being hired, with employees not working in an unsupervised capacity until they are trained. Training must be renewed every 365 days. The employer shall retain records of training and certification for at least 5 years. Hazardous and Controlled Waste Generator Training. Training must be given to personnel who utilize accumulation sites. This training must occur within six months of being hired or of assuming new duties that are associated with hazardous waste, with employees not working in an unsupervised capacity until they are trained. Training must be renewed annually. This training is provided by the EM. Chemical Inventory Reporting Training. All personnel using hazardous chemicals must attend this training. This training is necessary for [COMPANY] to maintain an accurate chemical inventory for reporting purposes. Incident Command Training. Employees designated to manage emergency response operations must be trained and certified and must receive annual refresher training. Annual refresher training is provided by the EM and meets 29 CFR 1910.120 requirements. The employer shall retain records of training and certification for at least 5 years. Storm Water Inspection Training. All personnel involved in storm water inspections shall attend an annual training class provided by the EM to ensure that inspections are being carried out regularly and correctly. Pollution Prevention Training. All personnel shall have access to voluntary pollution prevention training provided by the EM. This training will be self-paced, self-explanatory, and will increase employee awareness of pollution prevention goals and opportunities. Air Compliance Awareness Training. Operators of Title V Permit significant, insignificant, and trivial sources shall be trained in basic essentials in equipment maintenance, source inspection, and record keeping. Spill Prevention, Control, and Countermeasures Training. All above ground storage tank (AST) and UST users and operators shall attend an annual spill prevention briefing provided by the EM. These briefings will cover the following: loading and unloading procedures; site drainage; spill response procedures; applicable pollution control laws and regulations; known spill events or failures, malfunctioning storage components, and precautionary measures. Environmental Essentials for Construction Contractors. The training will provide basic principles of understanding for construction contractors for waste management, chemical management, threatened and endangered species, and wetland locations. Waste Management
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