Spill Contingency Plan

PURPOSE

The purpose of the hazardous waste contingency plan is to outline those procedures that would be implemented in the event of a hazardous waste spill at Bowling Green State University. Such procedures are designed to minimize the effects of spilled hazardous wastes on University students, personnel, facilities, the surrounding community, and the environment in general. This contingency plan will identify potential sites and activities that may be involved in a spill of hazardous wastes. The potential sites/activities will be addressed separately, specifying the necessary spill control guidelines pertinent to each particular setting.

SCOPE

The generation of hazardous waste at BGSU is typical of other colleges and universities. Relatively small quantities of a wide variety of chemicals make up the majority of the University's waste streams.

The most apparent potential risks associated with spills of hazardous waste exist in their movement to various storage areas and their transfer to more suitable storage containers. Coupling this understanding with the University's waste stream generation, it is estimated that the amount of hazardous waste that might be involved in a spill would be fairly small. Conversely, the probability of a spill occurring during storage in a centralized waste storage area would not be as great as the previously explained activities, even though larger overall quantities of waste might be involved. Larger quantities of hazardous waste are stored on campus, but only in several locations. These areas do however, represent locations where spills might occur.

While the most reasonable estimated quantities of spilled hazardous wastes might be minimal, the quality of the spilled waste may present the most serious risk. Corrosive, toxic, and reactive chemicals in high concentrations may be found in the normal academic waste streams. Therefore, it is prudent that all efforts be made to decrease spill potentials, while being adequately prepared to respond to and control any spills that may occur.

Other considerations within the scope of this contingency plan include those individuals responsible for assessment and reporting of spill incidents. From a spill management perspective, departmental personnel such as lab instructors, custodial or maintenance supervisors, as well as hazardous waste liaisons and/or campus security personnel would normally provide initial contact. It should be noted that hazardous waste liaisons are individuals who represent the various academic and nonacademic departments that routinely generate hazardous wastes. These individuals have been selected by their respective departments to serve as contacts with the Department of Environmental Health and Safety's Hazardous Waste Coordinator. The departmental hazardous waste liaisons, working in conjunction with the Hazardous Waste Coordinator, have the responsibility of controlling the hazardous waste management activities within their departments.

An "Emergency Numbers/Procedures" listing (included below) has been developed which specifies the names and telephone numbers of individuals who would be called in the event of certain types of emergencies. In the case of chemical emergencies, representatives of several relevant academic departments have been listed as well as representatives from Facilities Services and the Department of Environmental Health and Safety. This emergency telephone listing has been distributed to pertinent University departments for use on a 24-hour basis. Several academic departments also have their own spill contingency procedures that will interface with this plan and assist in reducing the effects of any hazardous waste spills.

In conjunction with the spill control measures stated below, departments as well have an obligation to protect not only their employees but also students and others from exposures to chemicals utilized during routine activities involving the use of hazardous materials. Departments have a responsibility under the Public Employment Risk Reduction Act to develop spill control procedures as a part of an overall Chemical Hygiene Plan. All spill control procedures developed need to be reviewed periodically with all pertinent staff to maximize the response effort and to minimize problems during an actual response. All spill control measures considered need to interface with Standard Operating Procedures established by applicable University departments and areas as a part of their Emergency Management Plan

PROCEDURES

Collection of Waste/Temporary Departmental Storage

The initial collection and temporary storage of hazardous wastes in an academic environment mainly occurs in the laboratory. Following routine laboratory exercises and/or research experimentation, waste chemicals may be moved to designated waste storage areas within the laboratory itself (See Hazardous Waste Management Procedures). In some instances, compatible waste chemicals are commingled in proper storage containers within this same area. Both the movement and transfer of waste materials present circumstances where spills may occur. Only individuals experienced in the collection and transfer of hazardous waste should be involved with such activities within the labs. Periodically, the hazardous wastes that have accumulated within the labs are removed to a central departmental storage site. In some departments, the chemical stock room serves this purpose. Any movement of wastes from the labs to the central storage area must also be considered as an activity where spills might occur. Central departmental storage areas are possible sites for spills as well.

Because of the risk potentials described above, all departments/areas that generate hazardous waste need to provide basic spill control materials and have personal protective equipment readily available to reduce, as much as possible, adverse conditions caused by hazardous materials/waste spills. Laboratories and other areas where hazardous wastes collection activities occur should also have appropriate spill control materials within easy access. Absorbents, neutralizing materials, and suitable safety equipment (gloves, respirators, etc.) should be placed at strategic locations within the department. Note: Any individual assigned to wear a respirator for any activity, including response to spills, must have previously passed a physical examination and a formal fit testing program prior to using it in potentially hazardous environments. Fit testing must be performed in conjunction with procedures outlined in the University’s Respiratory Protection Program through the Department of Environmental Health and Safety.

If a spill occurs in a laboratory or similar academic setting, it is to be reported first to the instructor/responsible person in charge of the area in question. This response permits those who have (or should have) a reasonable understanding of the spilled waste material(s) to provide an initial assessment of the incident. Spills occurring during movement to the central storage area need to be evaluated by the individual transporting the waste material. If the central storage area is the location of a spill, the on-site stock room manager must initially assess the situation and determine subsequent actions to properly manage the spill.

Should the spill exceed the capabilities of the responsible departmental personnel to safely remediate the situation, others in the department (i.e. departmental hazardous waste liaisons, department chairs, etc.), and the University departments of Public Safety and Environmental Health and Safety must be contacted to assist in determining the subsequent course of action (containment, securing involved areas, evacuation of building occupants, etc.). If evacuation(s) need to be initiated, all related actions will follow Public Safety’s Standard Operating Procedures outlined in their Emergency Management Plan.

Should the spill exceed the remediation capabilities of University personnel, a hazardous materials management company would be contacted for their assistance. This contact would be made through the Department of Environmental Health and Safety. Telephone numbers for several chemical spill cleanup contractors and other emergency response entities are maintained by EHS.

Hazardous waste spills from the collection, transfer, and storage of hazardous wastes in a nonacademic setting pose risks similar to those found in academic departments. University trades, maintenance, and custodial departments however, generate more consistent "specific" wastes than their academic counterparts. These generation patterns may provide a greater ability to plan for and respond to the types of spills associated with nonacademic environments. In the event of a spill in a nonacademic area, the individual(s) who first encounter the spill will initially evaluate the situation and decide whether they can safely resolve the problem. Following this assessment, the individual(s) need to contact their immediate supervisor to inform him/her of the incident. Again, if the spill exceeds the capabilities of the responsible departmental personnel to safely rectify the situation, others in the department (i.e. departmental hazardous waste liaisons, etc.), and the University departments of Environmental Health and Safety and Public Safety would be called to assist in determining the subsequent course of action.

Transportation

Trained personnel from the Department of Environmental Health and Safety and/or the University’s hazardous waste management company move waste materials from campus buildings to the University’s Hazardous Waste Facility (See Procedures). Transportation primarily involves a University vehicle that contains a compartmentalized wooden shipping box or other protective shipping unit(s) within the transportation vehicle. The vehicle is equipped with spill control materials (i.e. absorbent) and protective equipment for use in case of a spill. A cellular phone is available during the transportation of hazardous wastes. If a chemical waste spill occurs during transfer to the facility, the driver of the vehicle will attempt to control the spill by using the materials mentioned above. If unable to safely remedy the situation, the driver will use the cellular phone or other reasonable means to contact the Department of Public Safety and/or other appropriate individuals as dictated by the incident.

Hazardous Waste Facility

The temporary storage of waste chemicals is accomplished in a State-approved facility designed for that purpose. The hazardous waste facility is located in the northwestern section of campus, away from occupied buildings. The building interior is separated into four areas - three rooms for the segregated storage of chemicals (flammable, corrosive, and toxic) and one common area which contains a chemical fume hood, fire detection and suppression system (smoke detectors and a dry chemical suppression system), and other emergency equipment (fire extinguisher, eye/body wash unit, and spill control station). Only personnel trained in hazardous materials/waste management are permitted to utilize this facility.

The facility is equipped with an alarm system that is directly connected to the University's Department of Public Safety through three dedicated telephone lines. The alarm panel in the Department of Public Safety is designed to detect various emergencies that might be taking place at the facility (breech in security, malfunction in the ventilation system, "trouble" or "alarm" conditions in the fire alarm system). Should an emergency occur while the building is vacant, an alarm will automatically sound outside the building as well as in the Department of Public Safety. Appropriate safety/fire personnel will be dispatched to the facility depending upon the type of emergency indicated by the alarm.

Emergency procedures relating to a fire or spill of hazardous materials within the facility are posted near the exit (see Appendix III). The Hazardous Waste Coordinator will inform all individuals needing to work in the facility (waste removal contractors, University Maintenance personnel, etc.) of the proper emergency response procedures. Such instruction will be provided prior to the work being performed.

If a fire or chemical spill occurs while the building is occupied, personnel occupying the building will attempt to control the situation through the use of available emergency/spill control equipment. If unsuccessful, the occupant(s) will leave the waste storage facility and immediately inform the appropriate department(s). If necessary, the building occupant will engage a manual alarm located on the security alarm panel (pushing the “_*” and “#” buttons simultaneously), to gain a more rapid response.

Following the clean up of any hazardous waste spill, all spill-related wastes that are generated will be collected and stored in accordance with current hazardous waste storage guidelines.

Waste Information/Training

Material Safety Data Sheets (MSDS) or similar chemical/product information that provides important health/safety data need to be easily accessible. In the event of a spill, the chemical/product information can be used to determine appropriate spill control measures and necessary emergency equipment pertinent to the existing circumstances. Because of the importance of the information found on these data sheets, an alphabetized file for each waste chemical should be kept at relevant locations (departmental stock rooms and in areas where hazardous wastes are stored). Since the University's Chemical Hygiene Program stipulates that all chemical/product MSDSs are kept on file within each department, MSDSs should already be available for the wastes generated from these materials.

University personnel initially responding to hazardous materials/waste spills (University police, Environmental Health and Safety personnel, etc.) need to be adequately trained. Proper assessment of the incident assists in maximizing the effectiveness of any response effort. Since these individuals will not be involved with containment or removal activities they will be trained in accordance with 40 CFR 311 and 29 CFR 1910.120 ("First Responder" training - Awareness Level and, if necessary, the Operations Level). Training programs will be provided as needed to maintain the highest possible level of training for those assessing the level of response necessary.

CHEMICAL EMERGENCY PHONE NUMBERS: