Hazardous Waste Manifests 5-31-17: Audio edits – See FOUL – 4, 8, 5, 12, 13, 14, 15, orig 18, orig 19 & 17 (delete) 6-21-17: Audio edits – See 1st Proof – 4,12,14 7-17-17: Audio edits – SME Review 1 – 8,9,12,20,21,24 7-26-17: No audio edits – 1st E-Proof Hazardous Waste Manifests 5-31-17: PRODUCER - ORIGINAL SLIDES DELETED per SME (13. Review (cont.), 14. Answers, 15. Answers (cont.), #17 Continuation Sheets) Welcome to this training session on Hazardous Waste Manifests. Any generator who offers hazardous wastes for transportation for off-site treatment, storage, or disposal must prepare a manifest using a U.S. Environmental Protection Agency, or EPA, Uniform Hazardous Waste Manifest (federal Form 8700-22). Regulations regarding hazardous waste manifests are found at 40 CFR 262 Subpart B. Training is necessary to ensure compliance. Anyone responsible for signing a manifest or for completing any part of this specialized shipping paper should receive training in completion of the manifest. This training session will show you how to properly complete a manifest and will explain how the parts of the manifest are distributed.

Goals Understand importance and function of a manifest Know how to complete a manifest Understand tracking system By the end of the session, trainees will: Understand why manifests are important documents and know how they function to provide accurate information and tracking data for generators, transporters, receiving facilities, and regulators; Know how to properly complete a manifest, including how to fill in all blocks on the form, using the correct Department of Transportation, or DOT, shipping names and terminology; and Understand the tracking systems for hazardous wastes, including how the parts of the six-part manifest form are distributed.

The Manifest Form Shipping document for hazardous wastes Unique manifest tracking number Each party signs and keeps copy Provides “cradle-to-grave” tracking The Uniform Hazardous Waste Manifest (Form 8700-22) is the shipping document that travels with hazardous waste from the point of generation, through transportation, to the final treatment, storage, or disposal facility, or TSDF. Historically, this document has been used to track both hazardous and regulated waste. However, currently, the manifest is required solely for wastes defined as hazardous. Each form contains a unique preprinted manifest tracking number, which is assigned to a shipment of hazardous wastes. The manifest is a six-part form. Each party in the chain of shipping, including the generator, signs and keeps a designated part of the manifest. In this way, a shipment of hazardous waste can be traced from the generator to its final disposal, as well as all points in between. You can see why this is called a “cradle-to-grave” system for tracking wastes. © BLR®—Business & Legal Resources

Completing the Manifest 5-31-17: text/audio edit – see FOUL 6-21-17: text/audio edits – See 1st Proof Completing the Manifest Six-part/copy form Directions on back of form Generators fill out most of form 20 numbered sections Fill out all sections according to instructions Six-part/copy form Directions on back of form Generators fill out most of form 20 numbered sections Fill out all sections according to instructions Now let’s talk about completing the manifest. The manifest is a six-part, or six-copy, form, which you will see in the next few slides. Directions for completing a manifest are preprinted on the reverse of each original manifest. The name of the party to whom each of the six copies goes is also preprinted on each copy. Generators are responsible for completing most parts of the form. The form includes 20 numbered sections, some with multiple parts. It is essential to fill out all the numbered sections and to do so correctly. © BLR®—Business & Legal Resources

Items 1–3 5-31-17: text/audio edit – see FOUL Let’s start with Items 1 to 3. These include some basic information. Item 1: the Generator’s U.S. EPA ID Number. This is a 12-digit/letter combination. Item 2: Page 1 of ___. Be sure a number is filled in here. If there is no continuation sheet, you should fill in the number 1. Item 3: Emergency response phone number. Enter a phone number for which emergency information can be obtained in the event of an incident during transportation. © BLR®—Business & Legal Resources

Items 4–5 Item 4: Manifest tracking number. See the tracking number that has been preprinted on the form and enter it in this box. Item 5: Generator’s name and specific mailing address. Enter the name of the generator and the mailing address to which the completed manifest signed by the designated facility should be mailed. © BLR®—Business & Legal Resources

Items 6–8 Item 6: Transporter 1 information. Enter the company name and the U.S. EPA ID number of the first transporter. Item 7: Transporter 2 information. Enter the name and the U.S. EPA ID number of the second transporter if you are contracting a second. If none is expected, enter “none.” If more than two transporters are to be used, a continuation sheet will be necessary to list the information applicable for Transporter 3. Item 8: Designated receiving facility information. Enter the company name and site address of the facility designated to receive the wastes on this manifest. Also, enter the designated facility’s 12-letter/digit ID number and phone number. © BLR®—Business & Legal Resources

Items 9a, 9b, and 10 5-31-17: text/audio edit – see FOUL 7-17-17: text/audio edit – see SME R1 Items 9a, 9b, and 10 Description of the materials being shipped beginning with item 9a and 9b. Item 9a: U.S. DOT description. Enter an “x” in this item next to the corresponding hazardous material identified in 9b. This indicates that the material is hazardous waste. Item 9b: U.S. DOT description. Enter the DOT proper shipping name, hazard class, or division, ID number (UN/NA), and packing group for each waste identified in 49 CFR 172. Include technical names and reportable quantity references, if applicable. Check to be sure you have this information right and are using the correct DOT terminology. Item 10: Container number and type. Enter the number of containers for each waste and the appropriate abbreviation for the type of container, for example, DM, CF, or TC. Here’s an important tip: One of the most frequently cited manifest violations is the use of the abbreviation “DR” for drum instead of “DM” as specified in the manifest instructions. Always use DM for drum. © BLR®—Business & Legal Resources

Items 11–14 7-17-17: text/audio edit – see SME R1 Descriptive data continues in items 11 to 14. Item 11: Total quantity. Enter in designated boxes the total quantity of waste. Round partial units to the nearest whole unit, and do not enter decimals or fractions. Item 12: Unit of measure. Enter in designated boxes the appropriate abbreviation for the unit of measure, such as, K, L, M. As with Item 10, only abbreviations listed in the manifest instructions are allowed. Be sure that units of measurement are consistent, and report quantities in pounds for easier calculation. Item 13: Waste codes. Enter up to six federal and state waste codes to describe each item of waste identified in Item 9b. Item 14: Special Instructions and additional information. Here a generator may insert additional information or information that does not fit in other numbered blocks. This space can be used to list any special handling, shipment-specific, or additional descriptive information about the shipped materials, such as waste profile numbers, container codes, chemical names, physical state, as well as alternative facility designations, or the tracking number of the original manifest of rejected wastes. This section should be very specific in listing quantity and contents. © BLR®—Business & Legal Resources

Items 15–17 Items 15 to 17 include certifications and signatures. Item 15—Generator’s certification. This is the generator’s signature space. It is very important because this is where the generator assumes all the liability inherent in the hazardous waste management regulations. Additionally, by signing and dating, generators certify that they are doing everything economically practicable to minimize the generation of hazardous waste at the facility. Be sure to press very hard to get your signature to transfer to all parts of the manifest. Item 16—International shipments. The import or export box must be checked, and the point of exit or entry into the United States (city and state) must be entered. If applicable, the date the waste left the United States and the transporter’s signature must be completed. Item 17—Transporter 1 and/or Transporter 2 signature. Transporters sign to acknowledge receipt of materials. © BLR®—Business & Legal Resources

Items 18–20 Items 18 to 20 are for receiving facilities or TSDFs. Item 18a—TSDF discrepancy indication space. This is where the TSDF notes any differences between what the manifest says will be received and what is actually received. For example, if you ship 10 drums and only 9 drums show up at the TSDF, that fact would be noted. If the discrepancy cannot be resolved within 15 days of receipt of the waste, the TSDF must mail a copy of the manifest, a letter describing the discrepancy, and an outline of steps taken to resolve the discrepancy to the state in which it is authorized to operate. Manifest discrepancies may also include rejected wastes (full or partial shipments the TSDF cannot accept) or container residues. Item 18b—Alternate facility (or generator). Enter the name, address, phone number, and EPA ID number of the alternate facility that the rejecting TSDF has designated. Item 18c—Signature of alternate facility (or generator). The authorized representative of the alternate facility must sign or date this field to acknowledge receipt of the waste(s). Item 19—Hazardous waste report management method codes. Enter the most appropriate waste report management code for each waste listed in Item 9b. This is entered by the first TSDF that receives the waste. Item 20—Facility owner or operator certification of receipt of hazardous materials covered by this manifest or rejection of the waste as noted in Item 18a. © BLR®—Business & Legal Resources

5-31-17: text/audio edit – see FOUL 6-21-17: : text/audio edit – see 1st Proof Review Q: True or False—The manifest is a six-part form with three numbered sections for each part. Section 1 of the manifest is: Emergency response phone number; Generator’s EPA ID number; or Manifest tracking number. If there are more than two transporters involved in the shipment of hazardous waste, where is the third or subsequent company names recorded on the manifest? Add a new section to the manifest; Make a copy of the manifest page where transporters are listed and add the names; or Attach a continuation sheet to the manifest? A: Let’s review by seeing if you can remember the information that goes in some of the numbered spaces on the manifest. True or False —The manifest is a six-part form with three numbered sections for each part. False. It is a six-part form with 20 numbered sections. Section 1 of the manifest is—Emergency response phone number, Generator’s EPA ID number, or Manifest tracking number. Section 1 of the manifest is the Generator’s EPA ID number. If there are more than two transporters involved in the shipment of hazardous waste, where are the third or subsequent company names recorded on the manifest—Add a new section to the manifest; Make a copy of the manifest page where transporters are listed and add the names; or Attach a continuation sheet to the manifest? A third or subsequent company name is recorded on the manifest by attaching a continuation sheet. Section 1 of the manifest is the Generator’s EPA ID number. A third or subsequent company name is recorded on the manifest by attaching a continuation sheet. False. It is a six-part form with 20 numbered sections. © BLR®—Business & Legal Resources

Questions? Be sure you understand: The importance of completing the manifest How to complete the manifest What each section includes At this point, be sure you understand: The importance of completing the manifest, How to complete the manifest, and What each section includes.

Attachments Continuation sheets Land disposal restriction forms 5-31-17: text/audio edit – see FOUL 6-21-17: text/audio edit – see 1st Proof Attachments Continuation sheets Land disposal restriction forms Hazardous waste determinations Analytical results Emergency response information Now let’s talk about possible supplements to the hazardous waste manifest, starting with the continuation sheet. Many other documents may be attached to a hazardous waste manifest: The continuation sheet, Form 8700-22A, is used if more than two transporters are to be used to transport waste or if more space is required for the DOT description of hazardous materials and any related information; Land disposal restriction forms; Hazardous waste determinations; Copies of analytical results, such as TCLP, or Toxic Characteristics Leaching Procedure, tests; and Emergency response information.

Copy Distribution: Step 1 5-31-17: text/audio edit – see FOUL Copy Distribution: Step 1 Now let’s focus on the process of distributing copies of the manifest. First, here are a few basics: As we’ve said, there are six copies (or pages) in the manifest package. Some pages of the manifest are left behind as each shipment proceeds from its point of generation to its ultimate destination. Instructions for each handler — that is, generator, transporter, TSDF—are printed on the back of the manifest page the handler will retain. Next, let’s review the copy distribution process, step-by-step. Step 1: The generator completes the manifest. Transporter 1 arrives and the waste is transferred to the transport vehicle. The generator then retains page 6 (the bottom copy). The generator must retain a copy of the manifest for 3 years. Finally, the transporter leaves the site with the waste and pages 1 through 5 of the manifest.

Copy Distribution: Step 2 Now let’s review Step 2: The transporter arrives at the TSDF with the shipment of hazardous waste; The TSDF signs for receipt of the waste and takes pages 1 through 4; and The transporter retains page 5.

Copy Distribution: Step 3 Finally, Step 3: The TSDF mails: Copy 1 (top page) to the destination state agency (if required); Copy 2 to the generator state agency (if required); Copy 3 back to the generator; and The TSDF keeps copy 4 in its files for at least 3 years. If the destination state agency does not receive the second copy noting receipt at a disposal facility, the agency will follow up with the generator. Keep for 3+ years

Distribution: Special Situation When shipments are returned: TSDF must: Mail signed copy Complete appropriate sections Retain a copy for 3 years Generator must: Provide a copy to the transporter Send a copy to the facility When a TSDF rejects a shipment, the TSDF will return it to the generator or ship it to another TSDF using either the original or a new manifest. The TSDF must: If using a new manifest, mail a signed copy of the manifest to the generator identified in Item 5 of the new manifest. If using the original manifest, complete the appropriate sections of the manifest, retain a copy for its records, and then give the remaining copies to the transporter to accompany the shipment. Retain at the TSDF’s site, a copy of each manifest for at least 3 years from the date the waste is accepted by the transporter. The generator who is accepting the return, in addition to signing the appropriate sections of the manifest (Item 18c or Item 20), must: Provide a copy of the manifest to the transporter. Within 30 days of delivery of the rejected shipment, send a copy of the manifest to the designated facility that returned the shipment to the generator. Retain at the generator’s site a copy of each manifest for at least 3 years from the date of delivery.

Transparent Tracking Each recipient of a manifest copy is now capable of tracking waste from its point of generation to its point of disposal. If all parties do their part, the waste disposal process is fully transparent and can be traced in the completed manifest. You can see that this is a great way to ensure and document proper disposal. © BLR®—Business & Legal Resources

Exception Reports No copy after 35 days No copy after 45 days 7-17-17: text/audio edit – see SME R1 Exception Reports No copy after 35 days No copy after 45 days No copy after 60 days What happens if this system for transparent tracking breaks down? If a large quantity generator, or LQG, does not receive a manifest copy from the TSDF within 35 days after Transporter 1 picks up a shipment, the generator must take steps to find the waste, including contacting the transporter. This is also true for TSDFs that have rejected and returned either full or partial loads or nonempty containers to the generator and have not received a manifest copy. If the LQG has not received a copy of the manifest within 45 days of initial pickup, an exception report must be filed with the EPA administrator in the region. TSDFs follow this requirement also when they have not received a copy of the manifest within 45 days of the pickup of a shipment that the TSDF has rejected and returned to the generator. The exception report must include a copy of the manifest in question as well as a letter outlining the efforts the generator has made to find the waste. The rules are different for small quantity generators, or SQGs. SQGs that have not received the signed return copy of the manifest within 60 days of the date the waste was accepted by the initial transporter must submit a legible copy of the manifest, with an indication by handwritten or typed note on the manifest itself (or an attached piece of paper) that the generator has not received confirmation of delivery, to the EPA regional administrator.

Unmanifested Waste Reports 7-17-17: text/audio edit – see SME R1 Unmanifested Waste Reports Identification of facility, transporter, generator Date received Waste description Method of treatment, storage, disposal Signed certification Explanation Identification of facility, transporter, generator Date received Waste description Method of treatment, storage, disposal Signed certification Explanation If a facility accepts for treatment, storage, or disposal any hazardous waste from an off-site source without an accompanying manifest, or without an accompanying shipping paper, and if the waste is not excluded from the manifest requirements, the owner or operator must prepare and submit a letter to the EPA within 15 days after receiving the waste. The letter must contain: The EPA identification number, name, and address of the facility and, if available, of the generator and transporter; The date the facility received the waste; A description of and the quantity of each unmanifested hazardous waste the facility received; The method of treatment, storage, or disposal for each hazardous waste; The certification signed by the owner or operator of the facility or his or her authorized representative; and An explanation as to why the waste was unmanifested, if known.

Match the term with its action below. Exercise Match the term with its action below. Continuation Sheet Exception Report Unmanifested Waste Report Generator & TSDF State Environmental Agencies Land Disposal Restriction Form Are sent copies of manifests Are sent copies of manifests Used when waste has no manifest Used when waste has no manifest Attached to manifest to document restrictions Attached to manifest to document restrictions Used for more than two transporters Used for more than two transporters Now let’s try another exercise. Match the item in the column at left to the description at right. Here are the answers: Continuation sheet—Used for more than two transporters. Exception Report—Copies of completed manifest do not arrive at generator or TSDF that has returned a partial or full shipment to the generator. Unmanifested Waste Report—Used when waste has no manifest. Generator & TSDF State Environmental Agencies—Are sent copies of manifests. Land Disposal Restriction Form—Attached to manifest document to restrictions. Copies of completed manifest do not arrive at generator or TSDF Copies of completed manifest do not arrive at generator or TSDF

Questions? Be sure you understand: Continuation sheets Attachments Copy distribution Be sure you understand: Continuation sheets Attachments Copy distribution At this point, be sure you understand: Continuation sheets, Attachments, and Copy distribution. What questions do you have about this training material?

Key Points to Remember Essential to compliance 7-17-17: text/audio edit – see SME R1 Key Points to Remember Essential to compliance Fill out all items correctly Copies to generator, transporter, TSDF Copies to state agency Let’s summarize today’s training session. Manifests are straightforward documents that are essential pieces of the compliance puzzle for a hazardous waste generator, transporter, or receiving facility. It is important that the manifest be completed in full and that all appropriate items are completed correctly. Manifests have designated parts for generators, transporters, and receiving facilities. It is essential that all parties involved retain their copies for at least 3 years. A state that requires manifest copies to be sent to the generator and/or the destination facility allows the state environmental agency to track where hazardous wastes go and how long they take to get there.