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ESH Manual Page: 8000: Environmental Management

This plan states policies and procedures for managing solid waste generated at the Sanford Laboratory. The policies and procedures are established to comply with the hazardous waste management requirements of Resources Conservation and Recovery Act (RCRA), South Dakota Codified Law (SDCL 34-A11) and Administrative Rule (ARSD 74:28) and meet the Sanford Laboratory goals of:

  1. Eliminating the generation of hazardous waste through product substitutions;
  2. Reducing the generation of hazardous waste where elimination is impractical; and
  3. Ensuring the management of recyclable materials in an environmentally sound manner.

Waste may be categorized into two sub-categories: solid waste and non-solid waste. The term solid waste is defined by regulation as a solid, liquid or gas.   Solid waste may be subdivided into hazardous waste, special waste, and mixed waste. The regulations governing solid waste are complex.  Generation, storage, disposal, recycling and reclamation are important considerations. 

Solid waste at the Sanford Laboratory is generated from both science and facility support operations.  Science waste is generated by performing work related to a specific experiment or group of experiments by a science group or person.  Facility waste is generated by operations in support of the underground and surface infrastructure surrounding the science experiments.   The Sanford Laboratory is considered the generator of the solid waste derived from both science and operations and as such is responsible for the management, disposal, recycling and reclamation of the solid waste.


3.1. The Laboratory Waste Manager (LWM) is responsible for:

  • Writing and implementing of the Solid Waste management Policy and Procedures at the Sanford Laboratory.
  • Communicating the importance of the Solid Waste management Policy and Procedures to all Sanford Laboratory personnel.
  • Directing and providing training to operations staff, science, contractors, and users of the Sanford Laboratory for the performance of their tasks as it relates to solid waste generation.
  • Reading and understanding federal, state, and county laws and regulations relating to solid waste and staying current with changes in the laws, rules, and regulations
  • Interfacing with federal, state and local regulatory agencies.
  • Maintaining the required documents and records of solid waste training, generation, shipment and disposal as outlined in the record keeping section of this document.
  • Conducting weekly inspections of SAA not directly under the control of a generator including examining containers for leaks, structural imperfections, content levels, segregation, and proper identification.
  • Managing the arrangements of solid waste pick up and ensuring the disposal is safely and properly performed by facility personnel and solid waste disposal contractors at an appropriate facility.
  • Maintaining the hazardous waste storage inventory and at the end of each month counting hazardous waste generated during that month (to document generator status).

3.2. The EHS Director is responsible for:

  • Providing adequate human fiscal and administrative resources to assure compliance with Solid Waste management Policy and Procedures at the Sanford Laboratory.
  • Tracking and reviewing hazardous waste compliance performance.

3.3. The Operations Foremen are responsible for:

  • Communicating the importance of the Solid Waste management Policy and Procedures at the Sanford Laboratory throughout their respective departments.
  • Assuring that departmental staff and facilities comply with these policies.
  • Planning and implementing the removal of waste materials from satellite accumulation areas.
  • Providing the LWM the necessary resources to help comply with solid waste regulations.
  • Obtaining annual solid waste training (including hazardous waste) once/year (1-hour).  Operations foreman will also identify each person under his or her authority who generates, or handles solid waste to receive this training.

3.4. Science and facility personnel are responsible for:

  • Adhering to the Solid Waste management Policy and Procedures at the Sanford Laboratory.
  • Participating in the Sanford Laboratory’s waste minimization program by conducting their work in a manner to minimize potential adverse environmental impacts.
  • Planning activities and experiments in which the use and creation of hazardous materials is minimized.
  • Obtaining annual solid and hazardous waste training for those individuals to generate of handle solid waste.
  • Identifying all solid waste streams arising from work activities  and reporting this to the LWM.
  • Working with the LWM to document proper disposal of all waste streams associated with their work.
  • Storing chemicals in accordance with prudent laboratory practice.
  • Storing solid waste in accordance with this document. 
  • Familiarizing themselves with the properties, health risks, and precautions required for handling their respective solid waste.
  • Contacting the LWM with any questions regarding chemical and solid waste management including training chemical/waste identification, regulations, reference materials, signage, container requirements, or other aspects of chemical or waste management.

Disposal is the discharge, deposit, injection, dumping, spilling, leaking or placing of any waste on any land or water. 

Generator Status refers to the producer of a hazardous waste.  The Sanford Laboratory is considered the generator for all hazardous waste at the site and is ultimately responsible for the management of hazardous waste (and solid waste) including handling and disposal (see 40 CFR part 262). Federal regulations delineate three separate classifications of generator status dependent upon the quantity of hazardous waste generated (produced) in a specific month. 

 Conditionally Exempt Small Quantity Generator (CESQG) is a generator which produces no more than 220 pounds of non-acute hazardous waste and less than 2.2 pounds of acute waste (P-list) in any one month and stores no more than 2,200 pounds of non-acute waste on-site at any time. 

Small Quantity Generator (SQG) is a generator which produces between 220 pounds and 2,200 pounds of hazardous waste or no more than 2.2 pounds of acute waste in any one month 

 Large Quantity Generator (LQG) is a generator which produces more than 2,200 pounds of hazardous waste or more than or equal to 2.2 pounds of acute waste in any one month. 

There are increasing regulatory requirements with each increasing generator quantity classification. Consequently, it is important to track both the amount of solid waste (and hazardous waste subset) generated each month at the site.  This plan requires each laboratory generator to provide monthly information quantities of wastes generated to the Laboratory Waste Manager (LWM).  This information will be entered into a spreadsheet to document generator status. 

 Hazardous Waste is a solid waste that exhibits a characteristic defined by the following:

 Ignitability (40 CFR 261.21)
 Corrosivity (40 CFR 261.22)
 Reactivity (40 CFR 261.23)
 Toxicity (40 CFR 261.24) 

A solid waste is determined a characteristic hazardous waste either by testing or by process knowledge. A hazardous waste may also be defined by listing, that is, named in any one of four lists (F-list, K-list, U-list and P-list) found in 40 CFR 261.30 through 40 CFR 261.33. There are over 700 hazardous wastes listed and include wastes derived from manufacturing processes (such as solvents) and discarded (unused) commercial chemical products. 

Mixed Waste is a waste that is both radioactive and hazardous waste (low level) as defined by RCRA or is a radioactive PCB waste. 

Radiological Waste is material that becomes potentially radioactive by either exposure to particle beams capable of causing activation, or by coming in contact with transferable radioactive contamination.  

Recycling is taking a material and using it 

  1. as an ingredient in an industrial process without first reclaiming it. 
  2. as an ‘effective’ substitute for a commercial product, and
  3. by returning it to the process that first generated it without first being reclaimed (closed loop recycling) 

Reclamation is processing a waste material to recover a usable product or if it the material is regenerated. 

Resource Conservation and Recovery Act (RCRA) is the set of federal regulations enacted to manage solid waste and the subset of waste regulated as hazardous waste. 

Satellite Accumulation Area (SAA) is a designated collection point for hazardous waste that is located at or near the point of waste generation and is ‘under the control’ of the waste generator. 

Solid Waste- is any discarded, abandoned, accumulated, or inherently waste-like material as defined by federal requirements; and that is not excluded from regulation under 40 CFR 261.4 (a) by variance or by a non-waste determination provided for in 40 CFR 260.30 or 40 CFR 260.34.  A solid waste may be either a liquid, solid, sludge, or contained gaseous material.  Examples of materials regulated as solid waste include materials accumulated for recycling, used in a manner constituting disposal (such as land application), burned for disposal or energy recovery, accumulated speculatively; as well as spent materials, by-products, commercial chemical products, and scrap metals.   In general, discarded materials are materials having the potential to enter the environment via mechanisms that are not associated with the material’s intended use as a product. Relevant exclusions include domestic sewage, industrial wastewater that are point source discharges subject to regulation under the section 402 of the Clean Water Act, nuclear materials or by-product material as defined by the Atomic  Energy Act of 1954 as amended by 42 U.S.C. 2011, and certain mining waste  or oil and gas exploration and production wastes.

Toxic Substances Control Act (TSCA) is the set of federal regulations enacted to control substances determined to cause unreasonable risk to public health or the environment. Asbestos, polychlorinated biphenyls (PCBs), and are included in these regulations. 

Universal Waste are relatively common hazardous wastes that may be managed under the less stringent requirements of 40 CFR 273 that facilitate recycling.  These wastes include batteries, pesticides, lamps (such as light bulbs that contain mercury), and mercury-contained equipment (such as floats, thermometers, thermostats, etc.) Note, unused mercury in a flask is not considered a universal waste (but rather a hazardous waste) if it is to be abandoned or discarded.  Wastes must be recycled to be managed as universal waste, and wastes that are not ultimately recycled cannot be accumulated as universal waste. 

Used Oil is any oil that has been refined from crude oil or any synthetic oil that has been used and as a result of such is contaminated by physical or chemical impurities.


A. Potential solid waste shall be identified with the LWM at the start of a project or work. Characterization, container type (DOT approved), labeling, storage, handling, and disposal practices will be discussed and documented.  A SOP will be developed for the management of each waste and will include PPE requirements, monitoring the amount of waste generated/month, container type, container labeling, container management, waste materials that may come in contact with the generated waste, and waste disposal. A three ring binder will be established for each area (divided by function or location) describing the generated wastes and the management of these wastes. A complete set of these binders will be kept by the LWM. 

B. Wastes will typically be generated and temporarily stored at an SAA (see Appendix B) or other designated areas approved by the LWM. All storage sites will be documented and inspected regularly by the LWM or his/her designee as designated by the SOP for that area. 

C. A waste pick-up will be arranged by contacting the LWM or his designee preferably one week in advance of the desired pick-up date.   Please provide the following information:

  • your name.
  • phone number 
  • department name 
  • building 
  • the type and quantity of waste to be picked up 
  • size of containers to be picked up and
  • physical state of the waste  

D. The LWM and his or her designee will pick up the waste and move it to the permanent waste storage locker for storage for pending shipment for and disposal as arranged by the LWM.  The container(s) will examined for proper labeling, condition, and DOT compliance. 

E. The LWM will schedule the waste for pick-up and disposal. 

F. An e-mail confirmation will be sent to the originator of the waste to document proper disposal. 

G. Workers in the area or at the entire site, depending on where the waste will be generated,  will be trained to standards developed in procedure  1.


Sanford Laboratory personnel who generate hazardous waste are required to have training appropriate to their level of responsibility. This training will be provided initially at the time of employment, and on an annual basis. The training is arranged by the LWM and will be given at least twice per year. Special training will also be provided by the LWM upon request from personnel working in areas with unusual hazardous waste management requirements. Training for hazardous waste management at the Laboratory will be updated to reflect the most current regulatory requirements. 

  • Identification of hazardous waste.
  • Container use, marking, labeling, and on-site transportation 
  • Accumulation area requirements 
  • 180-day storage area requirements 
  • Emergency procedures.  

6.1. Special Training

Anyone with oversight responsibility for packaging and transportation of hazardous materials or hazardous waste is required by law to have training related to the preparation of hazardous materials for shipment. Individuals who supervise or prepare those materials for transport and/or sign manifest documents must complete course work that meets USDOT regulations. No Sanford Laboratory personnel may arrange for disposal, transport, shipment, or sign hazardous waste manifest documents without completing the appropriate training, as required by current USDOT regulations. 


The LWM, or his or her designee, will sign Sanford Laboratory hazardous waste manifests. 

Hazardous waste contracts will be developed and managed by the LWM and include general hazardous waste, radiological waste, universal waste, and solid waste other than hazardous waste.  The LWM will create files on all treatment, storage, disposal facility (TSDF) disposal firms to document compliance history and achievement

 Records of all hazardous waste manifests will be kept on site for a minimum of three years from the TSDF returned copy date. Manifests beyond this date may be stored on site or in archives for a minimum of thirty years to serve as an accurate accounting of material shipped to potential CERCLA (Superfund) sites; 

Written communication must be received from TSDFs prior to waste shipment verifying the designated TSDF is authorized for the hazardous wastes being offered for shipment, has capacity to accept such hazardous waste, and will assure the ultimate disposal method is followed; 

Land Disposal Restriction (LDR) notices, LDR determination records, Hazardous Waste Profile Sheets, and Exception Reports will be kept with the associated manifests. These documents are to be kept with the manifest for the time period indicated herein; 

Waste analyses and laboratory analytical reports will be kept with the hazardous waste manifests for the established time period (three years on site). Note that laboratory analytical reports may be kept with hazardous waste profiles, in contract files, permitting files, or in individually designated files depending on the nature of the contract and/or waste materials; 

Personnel training records on current personnel will be kept until closure of the facility. Training records on former employees must be kept for at least three years from the date the employee last worked at the facility; 

Notification and documentation to prove secondary material is not “Solid Waste” will be maintained until closure; 


8.1. Appendices

  • Appendix A:  Identification of a Hazardous Waste
  • Appendix B:  Hazardous Waste Collection and Storage
  • Appendix C:  Hazardous Waste Disposal
  • Appendix D:  Hazaroud Waste Emergency Response
  • Appendix E:  Common Wastes Generated and Their Management