RCRA PART A APPLICATION
MAYO CLINIC ROCHESTER
MND083467688
200 FIRST STREET SOUTHWEST
ROCHESTER, MN 55905
RCRA PART B APPLICATION
MAYO CLINIC ROCHESTER
MND083467688
200 FIRST STREET SOUTHWEST
ROCHESTER, MN 55905
CERTIFICATION
I certify under penalty of law that this document and all attachments were prepared under my direct supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete.
Jeffrey W. Bolton
______Administrative Officer
______DATE
TABLE OF CONTENTS
MAYO CLINIC ROCHESTER RCRA PART B
SECTION B Facility Description Topographic Maps Sewer Locations Well Locations Baldwin Building Basement Floor Plan Wind Rose Data Fire Hydrant Locations Floor Plan Map
SECTION C Waste Characteristics Unknowns Waste Analysis Plan
SECTION D Process Information Room Layout and Containment System Base Sealant Characteristics Containment Capacity Calculations
SECTION E Operations Manual
SECTION F Procedures to Prevent Hazards Inspection Logs Property Boundary
SECTION G Contingency Plan Baldwin Building Location Baldwin Building Basement Floor Plan Emergency Coordinators Fire Emergency Procedures Emergency Equipment List Emergency Equipment Locations Container Storage Room Emergency Equipment and Features Evaluation Procedures Reporting Form
SECTION H Personnel Training Job Descriptions
SECTION I Closure Plan Cost Estimate Financial Assurance Mechanism
SECTION J Subpart AA Subpart BB Subpart CC
SECTION B
FACILITY DESCRIPTION
B-1 GENERAL DESCRIPTION
Reference: 7001.0050 D - E and 7001.0560 A
The Mayo Clinic Rochester campus consists of several medical diagnostic and research facilities in Rochester, Minnesota which generate hazardous wastes. These wastes are brought to a centralized storage and accumulation area located in the basement of the Baldwin Building in Rochester. Wastes stored in the Baldwin Building are removed within one year of generation for off-site treatment, recycling, or disposal. In addition, a small portion of the wastes are chemically treated on-site to render them nonhazardous using elementary neutralization.
This application is for authority to maintain the hazardous waste container storage area within the facilities property boundaries in the basement of Mayo's Baldwin Building located at:
Second Street and Fourth Avenue, SW Rochester, MN
The container storage area will be utilized to hold hazardous wastes for periods exceeding 90 days, as necessary. In addition, wastes generated at off-site Mayo VSQG facilities in other Minnesota locations, will occasionally be transferred to the Baldwin Building for storage. The general provisions of the VSQG rules will apply.
Mayo Clinic Rochester, as a provider of healthcare and medical research, operates several laboratories and clinics vital to this mission. The facilities which generate wastes which will be stored in the Baldwin Building include, but are not limited to, the following: Mayo Building Plummer Building Medical Sciences Building Guggenheim Building Conrad N. Hilton Building Rochester Methodist Hospital Ozmun Building Charlton Building and Charlton North Baldwin Building Gonda Building Stabile Building Charter House Support Center North (VSQG) Mayo Family Clinic Northeast (VSQG) Mayo Family Clinic Northwest (VSQG) Mayo Family Clinic Southeast (VSQG) Facilities Warehouse (VSQG)
The Baldwin Building storage room is used to store wastes generated within the Baldwin Building and other contiguous Mayo facilities. The locations of the Mayo facilities contiguous to the Baldwin Building are shown on Exhibit B-1.
The wastes stored at the Baldwin Building are generated as the result of several varied activities. A portion of the wastes are used or unused pure chemical reagents which are no longer of use to laboratory or clinic personnel. The reasons for discarding these pure chemicals include:
The chemical's shelf life may have expired;
The chemical may have been obtained for an experiment which has been completed; or;
The chemical may have been left in a laboratory when operations were terminated.
Each Division, Department or Section involved in the use of chemicals at Mayo Clinic Rochester is, in conjunction with Hazardous and Radioactive Waste Management, responsible for evaluating its wastes and ensuring that wastes meeting the hazardous criteria are properly managed prior to transfer to storage. Generators of hazardous wastes contact Hazardous and Radioactive Waste Management of Mayo Clinic Rochester and request that the wastes be picked up at the point of generation. Wastes generated at the facilities contiguous to the Baldwin Building will be transported to the storage area in a waste transport cart using Mayo-owned subways shown in Exhibit B-1. Wastes generated at other Mayo VSQG off-site facilities will be brought to the Baldwin Building loading dock by Mayo owned and operated vehicles, and from there to the storage room by hand cart.
B-2 TOPOGRAPHIC MAP
Reference: 7001.0050 F and 7001.0560 R
Exhibit B-2 is a topographic map showing the Baldwin Building and surrounding areas for a distance of one mile as required by 7001.0050 F.
The locations of all known injection or withdrawal wells in Rochester are provided in Exhibit B-3. This information was furnished by the Olmsted County Department of Health and reflects the location of all wells of which they have knowledge. Additional wells may exist of which neither Mayo nor the County have any knowledge.
The hazardous waste storage room is located in the basement of the Baldwin Building. Exhibit B-4 shows the floor plan of the Baldwin Building basement.
Exhibit B-5 presents wind rose information gathered over the one-year period January 2 to December 30, 1982 at the Rochester Airport.
There is no 100-year floodplain in the immediate area of the Baldwin Building. Further details concerning flood boundaries are presented in Section B-3b of this application. Fire hydrants are located within 100 feet of the Baldwin Building.
B-3 LOCATION INFORMATION
B-3a General Location Standards
Reference: 7001.0560 T and 7045.0460 Subp. 2
As shown in Exhibit B-2, the Baldwin Building is not located in a wetland or within a shoreland. It is located within the developed business district of the city of Rochester and is not unsuitably located to provide adequate protection of ground and surface waters. No significant air emissions are expected from this facility.
B-3b Floodplain Standard
Reference: 7001.0560 S
The Baldwin Building is not within the 100-year floodplain. As such, compliance with the Floodplain Standard has been demonstrated.
B-4 TRAFFIC PATTERNS
Reference: 7001.0560 J
Hazardous waste will be transported to the Baldwin Building by handcart or light duty vehicle. Vehicles will utilize public roads in the vicinity of the Baldwin Building and the private roadway leading to the Baldwin Building loading/unloading area (refer to Exhibit B-1). Transport carts will be used to move wastes within Mayo-owned buildings and subways.
Wastes leaving the Baldwin Building storage area will be transported to the loading dock by cart. At the dock, the wastes will be loaded onto contractor owned and operated trucks for transport to the ultimate treatment/disposal location. Shipments of wastes are made approximately every six weeks. Usually only one truck is needed.
No traffic control signals or signs are located within the facility.
EXHIBIT B-1
MAYO FACILITIES MAP
EXHIBIT B-2
USGS TOPOGRAPHIC MAP
EXHIBIT B-3
WELL LOCATIONS
EXHIBIT B-4
BALDWIN BUILDING BASEMENT FLOOR PLAN
0…0
EXHIBIT B-5
WIND ROSE DATA
EXHIBIT B-6
PROPERTY DESCRIPTION
Property Lots Block Plat
Parking Lot 28 Lots 8 and 9 Block 2 Original Parking Lot 1 Lots 1-7 Block 6 Original Parking Lot 2 Lots 2-7 Block 2 Original Parking Lot 7 Lots 8-10 Block 7 Original Parking Lot 6 Lots 1-14 Block 12 Original Parking Lot 5 Lots 1-2 Block 13 Original Medical Science Bldg Lots 3-7 Parking Lot 4 Lots 1-7 Block 14 Original Baldwin Lots 1-6 Block 15 Original Plat Lots 4-5 Block 1 Head & McMahon Harwick Lots 1-7 Block 16 Original Plat Guggenheim, Hilton, Lots 1-14 Block 17 Original Plat Mitchell Bldg (Medical School). 201 Building Lots 2, 3, 5, 6 Block 18 Original Plat Parking Lot 19 Lots 9, 10 Franklin Heating Station Lots 11-14 Pavilion Lot 3 Block 23 Original Plat Plummer & Siebens Lots 4-9 Block 24 Original Plat Mayo All Block 25 Original Plat Parking Lot 21 Block 27 Original Plat Ozmun East Damon West Ramp All Block 29 Original Plat Gonda Building All Block 30 Original Plat Colonial Lots 1-6 Block 38 Original Plat Eisenberg Lots 7-12 Charlton Lots 7-12 Block 39 Original Plat Lots 2-3 Block 40 Original Plat Parking Lot 10 Lots 1-4 Block 41 Original Plat Lot 6 Block 43 Original Plat MRI Building Lots 7-12 Block 44 Original Plat 119 Building Lots 5-6 RMH Property Lots 1-4 Parking Lot 14 Lots 5-6 Block 45 Original Plat RMH Property Lots 1-4, 7-12 East Ramp Lots 7-12 Block 46 Original Plat Charterhouse Lots 1-12 Block 52 Original Plat RMH Lots 1-12 Block 38 Original Plat Lots 1-12 Block 39 Lots 1-4 Block 44 Lots 7-11 Block 45 Lots 9-12 Block 51 (may not be accurate) Lots 2-3 Block 53 Lots 7-11 Block 53 Stabile Building Opus Building Lot 1 Block 2 Head & McMahon Lots 5-7 Block 14 Original
Property Lots Block Plat
Baldwin Building Lots 4 & 5 Block 1 Head & McMahon Parking Lot 8 Ozmun Block 7 William McCullough
ZONING MAP
Mayo Owned/Leased Buildings
SECTION C
WASTE CHARACTERISTICS
This section describes the chemical and physical characteristics of the hazardous wastes to be stored in the Baldwin Building and presents the Waste Analysis Plan which will be utilized at the Mayo Clinic Rochester to assure accurate identification and characterization of wastes.
C-1 CHEMICAL AND PHYSICAL ANALYSES
Reference: 7001.0560 B
Due to the diverse and changing nature of activities at the Mayo Clinic Rochester, the types and characteristics of the wastes to be stored in the Baldwin Building will vary considerably with time. For this reason, the wastes listed in Part A of this application and described in this section include several chemicals which may never be stored in the Baldwin Building. Such flexibility is essential if the Mayo Clinic Rochester is to fulfill its mission effectively.
The research studies conducted at Mayo are diverse and involve many different aspects of medical science. Chemical reagents are often acquired for those studies but not totally consumed during the course of the research. Although attempts are made to locate other Mayo research activities which can utilize these chemicals, the majority of the chemical reagents received must be disposed of as waste. These wastes are usually in their original containers which range up to one-gallon in size.
Because of the nature of the waste-generating activities at Mayo, virtually every waste will be positively identified prior to storage at the Baldwin Building. Wastes accepted for storage will either be in their original, labeled containers or in other appropriate containers (such as safety cans or plastic/glass bottles) and labeled as to their contents by the generator. Occasionally, an unknown chemical waste will be received by Hazardous and Radioactive Waste Management. Such unknowns will typically only be generated during the cleanup of a laboratory which has been in use for an extended period of time. Unknowns are identified according to the procedures described in Exhibit C-1 and Section C-2 of this application.
Laboratories which generate solvent wastes are equipped with safety cans for the accumulation of those wastes. The full cans are removed from the point of generation and replaced with empty cans. Flammable solvents to be stored in the Baldwin Building are transferred to 55-gallon drums for pick up by Mayo's waste disposal contractor. Other waste streams with sufficient volume to warrant similar handling are also consolidated into 55-gallon drums and stored in the Baldwin Building.
Hazardous wastes generated at Mayo as the result of maintenance operations will also be stored in the Baldwin Building. These wastes are typically empty or partially full 1 to 5- gallon paint cans containing paint residues as well as spent mineral spirits and/or paint thinner. These wastes are typically consolidated in 55-gallon drums.
Another type of waste that may be stored in the Baldwin Building is, unused, old or outdated pharmaceuticals that meet one or more of the requirements to be classified as a hazardous waste. Mayo pharmacies and medical clinics discard such pharmaceuticals in appropriate, labeled containers when their shelf life has expired or they are otherwise determined to be of no further beneficial use.
The storage facility is sized to hold 40 drums plus wastes that are stored on shelves in reagent sized containers within trays.
Laboratory Safety Data Sheets are obtained from the manufacturers and suppliers of chemicals utilized at Mayo and copies are available using the Mayo intranet. This is managed by the Mayo Safety Office.
C-2 WASTE ANALYSIS PLAN
Reference: 7001.0560 Part C and 7045.0458 Subp. 2
Wastes generated at Mayo Clinic Rochester which are believed to be hazardous but which have not been positively identified to the satisfaction of the Hazardous and Radioactive Waste Management staff will be investigated in the following manner.
1. Individuals working at the site of generation and/or individuals previously associated with the generation on-site of the unknown product, will be contacted to assist to identify that unknown substance.
2. Simple identification procedures carried out in a vented fume hood will be initiated to include, but are not limited to:
a. Visual checks to note color, clarity, stratification, and discharge of vapors or fumes.
b. pH determination if liquid to determine corrosivity.
c. A small amount of a solid unknown is heated in an open flame. If unknown is liquid, a cotton tipped swab sample of the unknown is employed. If the material burns producing soot or chars, it is considered to be organic.
3. The Mayo Clinic Rochester also relies on contract laboratory services for the identification of unknown wastes. Typical analyses requested include toxic characteristic leaching procedure, pH, and density. flash point, gas chromatography scan, and BTU/lb. Others are requested as necessary. Presently, laboratory services are provided by TESTAMERICA Analytical Testing Corp, Nashville, TN. TESTAMERICA is accredited the Minnesota Department of Health, laboratory number 047-999-345, and by the American Association for Laboratory Accreditation. Drummed liquid solvent wastes are analyzed for content periodically. However, the analysis may be repeated if Hazardous and Radioactive Waste Management Staff is notified or has reason to believe that the process or operation generating the hazardous waste, or non-hazardous waste if applicable, has changed. The frequency of
testing will be such to ensure that the analysis is accurate and up-to-date. An instrument, a coliwasa, will be utilized to obtain the drummed sample for analysis.
4. All wastes accepted from other Mayo facilities are similarly identified prior to acceptance.
C-3 WASTE CODES
The following waste codes are stored in the facility:
D001 through D043 (any waste exhibiting any one or more of the characteristics of a hazardous waste as described in 7045.0131); and F001, F002, F003, F004, F005, F027; and all P and U listed waste codes as listed in 7045.0135 subpart 4, par. E and F; and MN01, MN02, MN03.
A more detailed description of the wastes typically stored in the facility is found in Exhibit C-2.
EXHIBIT C-1
UNKNOWNS WASTE ANALYSIS PLAN
Analytical Classification Tests for Unknown Chemicals
Test 1: Air Reactivity
When the unknown bottle is opened under a fume hood, a visual check is made for discharge of vapors or fumes.
Test 2: Burn Test
20-100 mg of the solid unknown is transferred to a stainless steel spatula and heated in an open flame. If the material is a liquid, a stainless steel loop which holds a drop of the unknown is employed. A cotton swab may also be used. If the material burns with production of soot or chars, it is considered to be organic.
If the material burns vigorously or explodes instantaneously, it is considered to be flammable or explosive.
Test 3: Water Reactivity
1-2 gms of the unknown is placed in 10 ml of distilled water. The mixture is checked for temperature change and evolution of gas or vapor. If no temperature change or vapor of gas production, the unknown is considered to be non-water reactive.
Test 4: pH Determination:
If the material is soluble in water, the pH is measured using an electronic pH meter. If this material is organic and insoluble in water, the pH is measured using wide range pH paper.
Test 5: Acid Base Reactivity
Alternately, 2 ml of 6N Hydrochloric Acid or 2 ml of 6N Sodium Hydroxide is added to aqueous unknown. The evolution of heat, gases or vapors indicates that the material is reactive.
Test 6: Organic Peroxides
The following test should detect nearly all peroxides even when present in small amounts. (Veer and Gasparic, 1971).
Reagent 1 gm of titanium dioxide is mixed with potassium bisulfate. The mixture is melted until transparent. The melt is cooled and dissolved in 5 ml conc. sulfuric acid, and diluted to 500 ml with distilled water.
Two ml of the reagent is added to 100 mg of the unknown and the mixture warmed. A yellow color is indication of peroxides.
EXHIBIT C-2
TYPICAL WASTE DESCRIPTIONS
TYPICAL MAYO HAZARDOUS WASTE GENERATION
CODE NAME CATEGORY PHYSICAL TYPICAL WASTE SOURCE ANNUAL STATE CODES VOLUME (EST) H1 Non halogenated Flammable liquid Liquid F002, F003, F004, Laboratory operations <500 gal solvents F005 D001, D018, D022, D038 H3 Paint & paint thinner Flammable liquid Liquid F001, F002, F003, Painting operations 1100 gal D001, D007, D008, D009, D011, D028, D035 H4 Miscellaneous chemicals All Solid & D022, D002, U006, Laboratory operations 9500 lbs Liquid P069, P005, D001 H15 Mercury Solutions Poison Liquid & D009 Laboratory operations 100 lbs Solid
SECTION D
PROCESS INFORMATION
D-1 CONTAINERS
Reference: 7001.0570 A, B, and C
All wastes stored in the Baldwin Building storage facility will be contained within appropriate glass, metal, polyethylene, or polypropylene containers up to 55 gal in size. The storage facility provides for adequate secondary containment.
D-1a(1) Description of Containers
Reference: 7001.0570 B and 7045.0526 Subps. 2 and 3
A large portion of the wastes to be stored in the Baldwin Building are unwanted laboratory reagents in their original containers. These original containers range up to one gallon in size and are selected by the manufacturers of the chemicals as compatible with the chemicals.
Wastes received for storage will also include chemicals which have been placed in containers other than manufacturers' originals. Waste solvents, such as acetone, alcohols and methylene chloride are typically accumulated in 5-gallon safety cans at the point of generation. The full cans will be brought to the Baldwin Building storage room and their contents transferred to new or reconditioned POP specification drums for storage until ultimate removal and disposal by a permitted contracted. Paint, paint thinners, and aqueous based wastes are all "bulked" into the same type 55-gallon steel or plastic drums for storage until shipment to the disposal facility. Only drums approved by USDOT for the type of material to be stored and transported will be used. No mixing of waste types occurs. Waste chemicals are placed in sealed glass or polyethylene containers up to one gallon in size at the point of generation. These containers are typically the same as or similar to containers which originally held the chemical being collected and, therefore, are appropriate for storage of the substance. Wastes will only be accepted for storage if completely sealed with chemical-resistant caps in leak-free containers.
Wastes which are received for storage in containers other than the 5-gallon safety cans will be placed in laboratory packs (as prescribed by 7045.0538 subpart 12) or, in the case of wastes generated in large volumes, accumulated in appropriate POP drums.
D-1a(2) Container Management Practices
Reference: 7045.0526 Subp. 4
The Mayo Clinic Rochester's container management practices, coupled with the Baldwin Building safety features, provide for the safe storage and management of all containerized hazardous wastes. The key aspects of the management system utilized at the Baldwin Building storage area are summarized in this section.
Wastes are never placed in storage in leaking, cracked, or otherwise damaged containers which could cause an accidental release of contents. The contents of containers discovered to have leaks or damage which could cause a release of contents will be immediately transferred to a secure, compatible container. Drums will be inspected and verified to be free of damage, such as perforations, creases, rust or gouges, prior to use.
Containerized waste never remains open while in storage. Containers will only be opened for the purposes of adding wastes, removing wastes, sampling or otherwise inspecting the wastes or their containers.
Containerized wastes are not handled in a manner which is likely to result in rupture or leakage. Although the movement of breakable glass containers or wastes necessitates their handling by Mayo employees and contractors, such handling is always conducted using best practical management practices. Workers never attempt to move more wastes at one time than is prudent. Waste carts or manual drum trucks are utilized for moving wastes in areas outside of the room and, when appropriate, within the room.
Containers of wastes are not stacked.
D-1a(3) Secondary Containment System Design and Operation
Reference: 7001.0570 A and 7045.0526 Subp. 6
The Baldwin Building storage area is equipped with three distinct secondary containment systems. First, the room itself, by virtue of its design, will totally contain any accumulated liquids which reach the floor until detected and removed. Second, the shelf units utilized to store small containers of wastes are equipped with individual spill trays which prevent wastes which may leak or be spilled onto the shelf units from reaching the floor. Third, the pallets used on the floor are “containment pallets”, hold approximately 44 gallons each, and are interconnected. Illustrations of the storage room are provided in Exhibit D-1 showing its layout and features of the secondary containment system. Note that orientation of the pallets and drums may change but will not exceed storage limits and will provide appropriate aisle space. Additional details of the base containment system are provided in the remainder of this section. Section F of this application contains additional information concerning the individual shelf unit spill trays.
D-1a(3)(a) Requirement for the Base to Contain Liquids
Reference: 7045.0526 Subp. 6.A(1)
The container storage room floor consists of a 6-inch reinforced concrete base. The floor is sealed with Sherwin William's Rexthane Polyurethane Varnish (B44, V20) or its equivalent. The polyurethane provides an abrasion-resistant seal which is unaffected by strong acids, bases or solvents. The interior walls of the room are also sealed with polyurethane to a height of four inches to prevent lateral migration of any accumulated liquids. A coat of Benjamin Moore aliphatic acrylic urethane gloss (M74/M75) has been added to the floor for additional protection.
Both doors to the room are equipped with 4-inch ramps to prevent accumulated liquids from passing through doorways.
The room is totally enclosed and will not be subject to precipitation or run on.
D-1a(3)(b) Containment System Drainage
Reference: 7001.0570 A(2) and 7045.0526 Subp. 6.A(2)
As shown in the drawings provided in Exhibit D-1, the storage room is equipped with one floor drain. The drain is enclosed by a 3-inch high curb. Thus, only accumulations of liquids which far exceed the design spill will enter the drain. Liquids entering the drain will flow directly from the room to a 400-gallon tank accessible from the explosion well located outside the room's northwest wall. Accumulated liquids which exceeded the combined capacity of the room's secondary containment structure and the overflow storage would be discharged to the municipal sewer system.
No drainage is provided for accumulated liquids which reach a level of three inches or less above the floor. Accumulated liquids within the room would be removed manually using the procedures and tools described in the Contingency Plan (Section G of this application). The presence of accumulated liquids would be detected through the Inspection Plan (Section F).
All wastes stored in the room are placed on shelves, on the drum pallets, or inside secondary containment. These structures serve to elevate all containers a minimum of three inches, thereby preventing contact with any accumulated liquids. Secondary containment serves to segregate wastes from one another as well. Secondary containment is not required for containers of solid waste materials.
D-1a(3)(c) Containment System Capacity
Reference: 7--1.057 A(3) and 7045.0526 Subp. 6.A(3)
The maximum amount of wastes that would ever be present in the storage room at one time is 2962 gallons. This is based on 40, 55-gallon palletized drums and the shelves completely filled with 1-gallon containers. The design spill capacity of the room must be equal to 10 percent of the maximum volume in storage, or 296 gallons.
The room's secondary containment system is designed to provide containment for three inches of accumulated liquids, or over 900 gallons. Combined with the room's 400- gallon overflow tank, total secondary containment capacity is in excess of 1300 gallons. Supporting calculations are provided in Exhibit D-2.
D-1a(3)(d) Control of Run-on
Reference: 7001.0570 A(4) and 7045.0562 Subp. 6.B
The totally enclosed nature of the building and the design of its external drainage system prevent any precipitation run-on from reaching the room.
D-1a(4) Removal of Liquids From Containment System
Reference: 7001.0570 A(5) and 7045.0562 Subp. 6.C
As described in the facility inspection plans, presented in Section F of this application, the storage room is visually inspected weekly.
The Contingency Plan, presented in Section G of this application, describes the procedures which would be implemented should accumulated liquids be detected. These procedures consist of removing the liquids using sorbents and other appropriate tools and placing collected liquids, sorbents, and contaminated materials in suitable containers for ultimate disposal. Experience has shown that only small spills occur in the storage room. No electrical machinery is operated in the room. The primary cleanup method for all spills is absorption.
D-1b Containers With Free Liquids
The Baldwin Building container storage room is designed, constructed, maintained and operated to meet the requirements applicable to the storage of containerized free liquids.
D-1 TANKS
Not applicable.
D-3 WASTE PILES
Not applicable.
D-4 SURFACE IMPOUNDMENT'S
Not applicable.
D-5 INCINERATORS
Not applicable.
EXHIBIT D-1
CONTAINER STORAGE ROOM LAYOUT
AND
SECONDARY CONTAINMENT SYSTEM
EXHIBIT D-2
CONTAINMENT SYSTEM CAPACITY CALCULATIONS
SECTION E
OPERATIONS MANUAL
MAYO CLINIC ROCHESTER
OPERATIONS/MAINTENANCE MANUAL HAZARDOUS AND RADIOACTIVE WASTE MANAGEMENT PROGRAM
BALDWIN BUILDING STORAGE FACILITY
30 January 2017
GENERATION The wastes stored at this facility are generated as a result of several varied PROCESSES/ activities. A significant portion of the wastes are used or unused chemical CHARACTERISTICS reagents which are no longer of use to Clinic personnel. Reasons for discarding these chemicals include:
1. The chemical's shelf life has expired.
2. The chemical may have been associated with an experiment which has been completed.
3. The investigator is ceasing his/her research at Mayo and the laboratory is being closed.
4. The chemical may be a hazardous by-product of an experiment or clinical diagnostic test.
5. The chemical may be an outdated prescription pharmaceutical qualifying by definition as a hazardous waste.
6. Internal remodeling projects generating paint, paint sludge, and thinners.
Characteristics which make these wastes hazardous are toxicity, flammability, corrosivity, reactivity, oxidizer, and lethality.
CONTAINERS All wastes stored in the Baldwin Building are contained within appropriate glass, metal, or plastic containers.
A portion of the wastes are unwanted reagents and stored in their original containers. These containers, which range in size from a small vial to one gallon, have been selected by the manufacturers as compatible with the chemicals.
Some wastes received for storage include chemicals which have been placed in containers other than the manufacturers' originals. Waste solvents, such as acetone, xylene, and alcohols are placed in 5-gallon safety cans at their point of origin. When full, these cans are brought to the storage facility and transferred to 55-gallon drums for storage prior to ultimate removal and disposal by a permitted contractor. Contaminated paint thinners and paint arising from remodeling and construction areas within the Mayo complex are managed in a similar fashion.
Process wastes collected from research labs or chemical diagnostic testing are collected in various sized compatible containers with sealing screw on caps. These also are placed in POP containers with absorbent material for shipment. All hazardous waste containers are visually inspected prior to use, as well as prior to packaging in disposal drums to ensure that they are intact, undamaged, and capable of containing the wastes long-term without concern for breakage or leakage.
WASTE Wastes obtained from generating areas are poured into a provided ACCUMULATING collection and transfer container or collected as is in their original PROCEDURES manufacturer’s container. Such wastes are subsequently then poured or placed into their POP shipping container. Waste generators or the hazardous waste staff managing the transfer and disposal of the waste visually assess when containers are full. Procedures call for filling drums to a level approximately 4-inches from their tops and other small containers (up to 1-gallon) up to 1-inch from their tops to allow for expansion which may occur due to temperature changes during off-site disposal transport.
WASTE ADDITIONS/ Liquid waste streams are collected at their point of generation in transfer COMPATIBILITY containers, brought to the storage facility, and placed in drums specific to that waste stream. To avoid problems associated with compatibility, wastes are individually stored by specific waste stream within the storage facility. Further, outdated/unwanted chemical reagent bottles are stored on shelves, by compatibility, in individual plastic trays so as to prevent mixing of chemicals, should spontaneous breakage occur.
CONTAINER All hazardous waste containers stored in this facility will be kept closed CLOSURE except when in use. Closure may be achieved by replacing the drum bungs, bung vents, or lids and locking rings. Bungs should be tightened using a bung wrench. Locking rings should have the bolt inserted and tightened. Use of a closing funnel with lid latches or a self-sealing vent is also acceptable.
MOVING Containers will be moved in and out of the storage room using either a cart CONTAINERS or a drum cart. Containers with handles may be moved by using the handle.
TRANSFER Hazardous wastes are moved from their point of generation to the storage PROCEDURES facility by Mayo's hazardous waste staff. Such transfers occur through a pedestrian subway connecting Mayo facilities and involve the use of a specially selected cart. The cart features containment capabilities designed to control spills should breakage occur during transport. The containment feature also protects against waste containers slipping off the cart during transport.
LABELING Internal collection containers are labeled "Hazardous Wastes." Additionally, plastic coated tags are attached to each container or the material name written directly on the container to designate its intended contents. Shipping containers are further labeled with appropriate MPCA/EPA hazardous waste labels and DOT hazard labels.
INSPECTIONS Weekly inspections of the facility are conducted by a Hazardous and Radioactive Waste team member using the checklist provided in Section F of the Part B permit application. The intent of the inspection process is to identify any leaks or spills or other deficiencies which might result in a leak or spill or be of an essential nature in an emergency. SPILLS Supplies to manage small spills are located in the Emergency Supply Cabinet located immediately outside of the door to the storage facility (Attachment 1). Larger spills are managed by accessing the chemical spill carts. Employees not involved with the contingency plan would follow those steps noted on the Emergency Procedure sign (Attachment 3).
RECORD KEEPING Movement of hazardous waste out of the facility is tracked on Uniform Hazardous Waste Manifests. Since all waste stored in this facility is generated on-site, or at a Mayo owned MN VSQG, there is no manifest procedure for incoming waste. A log is maintained listing all wastes as they are placed in the room for storage. An erasable white board just outside the door is used to track current inventory within the permitted room.
Copies of this log and other entries in the operating record are maintained in the storage cabinet outside the facility and in the hazardous waste processing room, currently Guggenheim 112. Elements of the operating record are listed in Exhibit E-1.
SEGREGATION All hazardous wastes are stored according to compatibility within secondary containers in the storage facility. Items stored on shelves are placed in plastic trays to contain any potential spillage which may occur. Containers of waste where the storage container serves as the secondary container or is a DOT POP package, may be placed directly on the floor.
CONTAINER The hazardous waste storage facility is an indoor facility and as such, containers are not subject to moisture or sunlight. Additionally, storage pallets or shelves are used to elevate the wastes above the floor to protect against water resulting from plumbing malfunctions or accidents.
MANUAL Copies of this manual will be maintained at the storage facility and at the LOCATIONS hazardous waste processing laboratory, currently Guggenheim 112.
EXHIBIT E-1
ELEMENTS OF THE OPERATING RECORD
Elements of the Operating Record
The following information shall be recorded and maintained in the operating record until closure of the facility:
The name, address, phone number, contact name and U.S. EPA identification number for each hazardous waste generator which sends their wastes to Mayo.
A description and the quantity of each hazardous waste received, and the method(s) and date(s) of its storage at the facility.
The location of each hazardous waste within the facility and the quantity of each location.
Records and results of waste analyses performed as specified in the waste analysis plan.
The training plan and personnel training documentation records.
The contingency plan.
Summary reports and details of all incidents requiring implementation of the contingency plan.
Records and results of inspections.
All closure cost estimates.
Waste minimization certification and signature.
Land disposal restriction notices, if required, for each waste stream shipped.
SECTION F
INSPECTION SCHEDULES AND PROCEDURES TO PREVENT HAZARDS
SECTION F
PROCEDURES TO PREVENT HAZARDS
The information provided in this section is submitted in accordance with the requirements of Part 7001.0560 Subparts D, E, F, H, and I and Part 7001.0570 Subparts E and F. This information is provided to demonstrate compliance with applicable subparts of the regulations contained in Parts 7045.0452, 7045.0456. 7045.0462, 7045.0464 and 7045.0526.
F-1 SECURITY
F-1a Security Procedures and Equipment
Reference: 7001.0560 Subp. D & 7045.0452 Subp. 4
The container storage area fulfills the security procedures and equipment requirements by providing a barrier and means to control entry to the room in which hazardous wastes will be stored (see F-1a(2) below).
F-1a(2) Barrier and Means to Control Entry
Reference: 7045.0452 Subp. 4
The container storage room has only two access points. Both of the access points are steel fire doors which are kept closed and locked anytime that the room is not being utilized by authorized personnel. Only authorized personnel, which includes the Mayo Hazardous and Radioactive Waste Management Staff and Security personnel, are issued keys to the doors of the container storage room.
F-1a(3) Warning Signs
Reference: 7045.0452 Subp. C
Signs are mounted and maintained on both entrances to the container storage room which bear the legend "WARNING—UNAUTHORIZED PERSONNEL KEEP OUT." These signs are legible from a distance of at least 25 feet.
F-2 INSPECTION SCHEDULE
Reference: 7001.0560 Subp. E, 7045.0452 Subp. 5, and 7045.0526 Subp. 5.
Inspections of the container storage room and related safety equipment are performed on a routine, periodic basis by the Mayo Hazardous and Radioactive Waste Management staff or another Mayo employee trained and knowledgeable in the inspection procedures and requirements.
F-2a General Inspection Requirements
Reference: 7045.0452 Subp. 5A and 7045.0526 Subp. 5
The container storage area is inspected for the purpose of identifying any malfunctions or deterioration, operator errors or discharges which may: (1) be causing or may lead to release of hazardous constituents to the environment; (2) constitute a threat to human health, or (3) impair the ability to respond to emergencies involving the container storage facility.
F-2a(1) Types of Problems and Schedule
Reference: 7045.0452 Subp. 5B
Exhibits F-1 and F-2 present example inspection log sheets to be used in conducting inspections of the container storage room and related equipment. The log sheets identify the types of problems which the inspector looks for during each inspection. Copies of blank log sheets are available for use as needed.
F-2a(2) Frequency of Inspection
Reference: 7045.0452 Subp. 5C and 7045.0526 Subp. 5
Two inspections are conducted of the container storage room; a weekly inspection for signs of leakage, container deterioration, secondary containment system deterioration, deterioration of security devices, and function of certain emergency equipment; and a monthly inspection of all safety and emergency equipment. The specific items covered by the weekly and monthly inspections are identified in the inspection log sheets presented in exhibits F-1 and F-2, respectively.
In addition, the Baldwin Building loading dock is inspected immediately after any hazardous waste shipment has passed through the dock area for indications of spills.
The frequency of all inspections has been determined based on an assessment of the possible rate of deterioration of the item and the probability of an environmental or human health hazard occurring if the deteriorations, malfunctions or errors go undetected between inspections.
F-2b Specific Process Inspection Requirements
F-2b(1) Container Inspections
Reference: 7045.0526 Subp. 5
As a part of the routine weekly inspection, containers are checked to verify that no spills, leakage or unacceptable deterioration have occurred. This is accomplished by visually inspecting each spill tray in which small waste containers are held (refer to Section F-5 for tray descriptions), all safety cans, all waste drums and all other waste containers in which wastes are present. If necessary, drums resting on the floor pallets will be moved and rotated to allow inspection of all surfaces.
The floor and door ramps are inspected to assure that no cracks or gaps have developed and that the floor sealant has not been abraded or corroded to an unacceptable thickness. Similarly, the floor drain dike is inspected to verify its soundness.
F-2c Remedial Actions
Reference: 7045.0452 Subp. 5D
Any deterioration or malfunction of equipment or structures associated with the container storage room will be corrected expeditiously by Mayo so as to minimize further deterioration, health, and environmental hazards and the need for emergency repairs. Where the situation presents an imminent hazard, immediate remedial action will be taken.
F-2d Inspection Logs
Reference: 7045.0452 Subp. E
The inspection logs presented in exhibits F-1 and F-2 are completed and retained on-site for at least three years from the date of each weekly and monthly inspection. The inspections conducted as part of each waste loading/unloading operation will be noted in the container storage room operating log. The operating log entries include the date and time of the inspection, the name of the inspector, and a notation of the observations made. The dates and nature of all repairs and remedial actions undertaken at the container storage room will also be described in the operating log. The operating log records will be retained on-site for a period of at least three years.
Inspections are made by one of the hazardous waste staff members or other Mayo employee trained and knowledgeable in the inspection procedures and requirements. The person making the inspection and noting a deficiency by practice takes care of the problem immediately and is empowered to do what is necessary. Any item requiring follow up will be followed by the hazardous waste staff until completion.
F-3 WAIVER OF PREPAREDNESS AND PREVENTION REQUIREMENTS
Reference: 7001.0560 Subp. F
The Mayo Clinic Rochester does not request a waiver of the preparedness and prevention requirements specified in 7045.0462.
F-3a Equipment Requirements
Reference: 7001.0560 F and 7045.0462 Subp. 3
All required communications and fire fighting equipment are proved in the immediate vicinity of the container storage room. Section G-5 of this application describes the capabilities and locations of this equipment. Section F-2 describes the inspection of the equipment.
F-3b Aisle Space Requirements
Reference: 7001.0560 F and 7045.0462 Subp. 6
Sufficient aisle space (approximately 24-inches) is maintained in the passageways leading to the container storage room and within the room itself to allow for the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment in the event of an emergency.
F-4 PREVENTIVE PROCEDURES, STRUCTURES, AND EQUIPMENT
Reference: 7001.0560 H
F-4a Loading/Unloading Operations
Reference: 7001.0560 H(1)
Wastes are loaded and unloaded at two locations within the Baldwin Building; the container storage room and the Baldwin Building loading dock.
Wastes are normally brought to the room for storage in small (5-gallons or less) containers on a cart although containers of up to 55-gallons may be used. The entrances to the room are equipped with sloped ramps allowing the cart to be safely moved into and out of the room. Wastes are taken from the room in appropriate POP DOT shipping containers ranging to 55 gallons, using handcarts, to the loading dock where they are immediately loaded onto transport trucks. The Baldwin Building's dedicated freight elevator is used to move wastes between floors. Wastes are transported only when securely fastened or otherwise contained in a handcart or DOT POP packaging. Only tightly sealed, leak-free containerized wastes are transported.
F-4b Runoff
Reference: 7001.0560 H(2)
All hazardous waste handling areas at the Baldwin Building are under cover thus eliminating the possibility for storm water run-on or runoff.
F-4c Water Supplies
Reference: 7001.0560 H(3
All wastes stored or handled within the Baldwin Building will remain within enclosed building structures. These are no known pathways by which spilled or leaked wastes could contaminate water supplies.
F-4d Equipment and Power Failure
Reference: 7001.0560 H(4)
The container storage room automatic fire extinguishing system does not rely on external power sources and is not subject to power failure. Emergency lighting, which
automatically activates in the event of a power failure, is located within the container storage room, access halls, and stairways leading to the room. Additional information concerning the location of emergency lighting is provided in Section G-5 of this application.
F-4e Personnel Protection Equipment
Reference: 7001.0560 H(5)
The container storage room is equipped with an exhaust fan which maintains a negative pressure in the room at all times. The fan serves to minimize the potential for accumulation of hazardous vapors within the room and surrounding areas.
During the handling of hazardous wastes, facility personnel wear protective clothing, such as aprons, gloves, steel-toe shoes, safety glasses, face shields and respirators, as appropriate. Section G-5 of this application identifies the personnel protective equipment kept on hand at the Mayo Clinic Rochester. All personnel involved in the direct management of the wastes are trained in the proper use of safety equipment, as described in Section H of this application.
F-5 PREVENTION OF IGNITION OR REACTION OF IGNITABLE, REACTIVE OR INCOMPATIBLE WASTES
Reference: 7001.0560 I and 7045.0456
Ignitable wastes are stored in the Baldwin Building container storage room. Several design features and operating procedures serve to minimize the potential for accidental ignition of wastes. These include:
1. No smoking is allowed in the container storage room. Readily legible signs on both entrance doors to the room will bear the legend "NO SMOKING OR OPEN FLAMES." All Mayo facilities are "NO SMOKING" areas.
2. The room is constructed to all NFPA standards for the storage of flammable materials. See Exhibit F-4 for a copy of the Rochester Fire Department permit.
3. Only explosion-proof electrical wiring, switches, and fixtures are used inside the room.
4. No metal cutting, welding or other activities which could produce sparks, frictional heat, or other potential sources of ignition are allowed within the room when ignitable wastes are present.
5. Tools utilized in the room, such as bung wrenches, are made of non sparking materials.
6. No devices which could produce sparks or heat sufficient to ignite waste materials are allowed in the room when ignitable wastes are present.
The only wastes mixed in the container storage room are waste solvents and aqueous based carcinogenic compounds, which are received in 5-gallon safety cans or smaller containers. Solvents are mixed with solvents, carcinogens are mixed with carcinogens; there is no intermixing of these or other materials. Identity of the solvents to be mixed will be verified before mixing begins. These wastes are transferred to drums for eventual shipment off-site. Various references may be used to determine compatibility. Small scale laboratory testing may occur prior to large scale mixing of wastes to ensure compatibility.
To further minimize the potential for the uncontrolled reaction of wastes, all wastes in containers of 1-gallon in size or smaller are kept in spill trays. The spill trays are flat, plastic trays measuring approximately 18" x 12" x 6". Spill trays containing wastes are stored on the shelf units located along the periphery of the container storage room. Up to three trays are placed on each shelf. The spill trays serve to contain any leaks of individual containers which may occur, thereby minimizing the potential for incompatible or reactive wastes to mix.
Only compatible wastes will be placed within the same tray. The compatibility of each waste with other wastes in the tray in which it is to be placed will be verified by appropriate reference.
Exhibit F-3 provides a drawing of the container storage room showing the nearest Mayo Clinic Rochester property boundary. A line parallel to the property boundary at a 50-foot distance is also shown. As indicated, only some of the wastes stored within the room are located less than 50 feet from the property boundary. Because the container storage room is located two stories below ground level and equipped with walls and doors having fire tolerance ratings of three hours, Mayo Clinic Rochester requests a continuation of the waiver of the special requirement contained in 7045.0526 Subpart 7 stating that all ignitable and reactive wastes be stored at least 50 feet from the property boundary. Such a waiver would be consistent with the Federal standards contained in 40 CFR 264.176 (FR 49, p. 23, 289, June 5, 1984) allowing the 50-foot setback to be reduced to 10 feet if a minimum fire rating of two hours is provided for facility walls.
EXHIBIT F-1
WEEKLY INSPECTION LOG SHEET
YEAR ______MAYO CLINIC ROCHESTER WEEKLY INSPECTION LOG SHEET HAZARDOUS WASTE CONTAINER STORAGE FACILITY
ITEMS INSPECTED OR OBSERVED ACCEPTABLE 1. General a. Doors and locks not corroded or sticking Complete date, time, and b. Warning signs present and legible initials of inspector indicating c. Telephone system operative items were inspected and are d. Exhaust fan operative functional, operational, or e. Freight elevator operative incompliance. f. Eyewash flushed for 3 min.
2. Containers UNACCEPTABLE a. Drummed wastes not leaking, dented, corroded, open Indicate by number and letter, b. Containers in spill trays not cracked, area of non-compliance. punctured, or leaking Report incident and corrective c. Other containers not corroded, leaking, or action on attached inspection open sheet. Initial all entries. d. Labeled and dated
3. Containment a. Base shows gaps, cracks, or accumulation of liquids b. Base sealant shows abrasion or corrosion c. Drain curb shows gaps or cracks d. Door ramps show gaps or cracks
NAME AND TITLE OF INSPECTOR:______
MONTH WEEK 1 WEEK 2 WEEK 3 WEEK 4 WEEK 5 JAN Date: Date: Date: Date: Date: Time: Time: Time: Time: Time: FEB Date: Date: Date: Date: Date: Time: Time: Time: Time: Time: MAR Date: Date: Date: Date: Date: Time: Time: Time: Time: Time: APR Date: Date: Date: Date: Date: Time: Time: Time: Time: Time: MAY Date: Date: Date: Date: Date: Time: Time: Time: Time: Time: JUN Date: Date: Date: Date: Date: Time: Time: Time: Time: Time: JUL Date: Date: Date: Date: Date: Time: Time: Time: Time: Time: AUG Date: Date: Date: Date: Date: Time: Time: Time: Time: Time: SEP Date: Date: Date: Date: Date: Time: Time: Time: Time: Time: OCT Date: Date: Date: Date: Date: Time: Time: Time: Time: Time: NOV Date: Date: Date: Date: Date: Time: Time: Time: Time: Time: DEC Date: Date: Date: Date: Date: Time: Time: Time: Time: Time:
YEAR ______CORRECTIVE ACTION RECORD FOR MAYO WEEKLY INSPECTION LOG SHEET
EXHIBIT F-2
MONTHLY INSPECTION LOG SHEET
YEAR ______MAYO MONTHLY INSPECTION LOG SHEET HAZARDOUS WASTE CONTAINER STORAGE FACILITY
ITEMS INSPECTED OR OBSERVED ACCEPTABLE 1. General a. Emergency lighting operative Complete date, time, and initials of b. Emergency eyewash flushed for 3 inspector indicating items were minutes and operative inspected and are functional, c. Emergency shower flushed and operative operational, or in compliance. d. Fire extinguisher missing or low pressure e. Sprinkler system pressure low f. Fire extinguishers charged UNACCEPTABLE
2. Emergency Supply Cabinet Indicate by number and letter, area of a. First aid supplies missing or outdated non-compliance. Report incident and b. Protective clothing missing corrective action on attached inspection sheet. Initial all entries.
NAME AND TITLE OF INSPECTOR: ______
JANUARY FEBRUARY MARCH APRIL
Date: Date: Date: Date: Time: Time: Time: Time:
MAY JUNE JULY AUGUST
Date: Date: Date: Date: Time: Time: Time: Time:
SEPTEMBER OCTOBER NOVEMBER DECEMBER
Date: Date: Date: Date: Time: Time: Time: Time:
YEAR ______CORRECTIVE ACTION RECORD FOR MAYO MONTHLY INSPECTION LOG SHEET HAZARDOUS WASTE CONTAINER STORAGE FACILITY
INCIDENT CORRECTIVE ACTION DATE
EXHIBIT F-3
PROPERTY BOUNDARY
EXHIBIT F-4
ROCHESTER FIRE DEPARTMENT PERMIT
SECTION G
CONTINGENCY PLAN
SECTION G
CONTINGENCY PLAN
This contingency plan has been prepared to reflect the requirements of Chapters 7045.0466 through 7045.0470. It describes the procedures to be undertaken in the event of fires, explosions, or unplanned releases of hazardous wastes or hazardous waste constituents at Mayo Clinic Rochester's hazardous waste container storage facility to minimize hazards to human health or the environment.
G-1 GENERAL REQUIREMENTS
Reference: 7045.0466
Mayo's container storage facility is located in the basement of the Baldwin Building at:
Second Street and Fourth Avenue, Southwest Rochester, MN 55902
Exhibit G-1 is a drawing of the vicinity of the Baldwin Building. The location of the hazardous waste storage room is indicated on the drawing. Exhibit G-2 provides a floor plan of the basement level and indicates the locations of the container storage facility.
The container storage area is used to store containers of hazardous waste ranging in size from small ampules to 55-gallon drums. The type of wastes kept in the room will vary over time and may include toxic, ignitable, corrosive, reactive, oxidizer, lethal, and PCB bearing.
Wastes are brought to the storage room for other Mayo Clinic operations, stored in containers, repackaged (as required) and periodically shipped off-site for treatment and disposal.
G-2 EMERGENCY COORDINATORS
Reference: 7045.0466 Subp. 4(D) and 7045.0468 Subp. 1
At all times there will be at least one employee either on the facility premises or on-call with knowledge of facility operations and proper training to serve as emergency coordinator. The primary and alternate emergency coordinators are listed in Exhibit G-3.
In the event that a potential or actual waste release, fire, or explosion is detected, the primary coordinator will be contacted. If the primary coordinator cannot be reached immediately, the notifying party will attempt to reach an alternate coordinator beginning with the first alternate coordinator and proceeding through the list until a coordinator is contacted.
The emergency coordinator present at the scene has the authority to commit the resources of the Mayo Clinic Rochester, as necessary, to implement and carry out this Contingency Plan.
G-3 IMPLEMENTATION OF THE CONTINGENCY PLAN
Reference: 7045.0466 Subp. 3
The criteria which could result in implementation of the Contingency Plan are summarized below.
1. Fire and/or explosion
a. A fire causes the release of toxic vapors.
b. The fire cannot be readily controlled by personnel present at the scene and threatens to ignite other materials within the room or at other locations on-site.
c. The fire could possibly spread to off-site areas.
d. Use of water or water and chemical fire suppressants could result in contaminated runoff or sewer discharges.
e. An imminent danger exists that an explosion could occur, causing a safety hazard because of flying fragments, shock waves, or damage to the building foundation.
f. An imminent danger exists that an explosion could result in release of toxic material at the facility.
2. Spills or Material Release
a. The spill could result in release of flammable liquids or vapors, thus causing a fire or gas explosion hazards.
b. The spill could cause the release of toxic liquids or vapors.
c. The spill can be contained on-site, but the potential exists for ground water contamination.
d. The spill cannot be contained on-site and could potentially result in a release to the city storm sewer system.
G-4 EMERGENCY RESPONSE PROCEDURES
G-4a Notification
Reference: 7045.0468 Subps. 2 and 5
In the event a potential or actual fire, spill or explosion involving the container storage area is discovered, the employee discovering the problem will immediately notify the Mayo Clinic Rochester telephone operator (911). Telephones are located throughout the Mayo campus. There is a telephone immediately outside the entry/exit door to the storeroom and multiple others within 100 feet of the door. The operator transfers the 911 call to Mayo Security who simultaneously dispatches an officer to the scene and contacts the Chemical Spill Team. Upon
direction by the Spill Team, telephone operators or Security notify Mayo Administration, the administration of the two neighboring hospitals, and emergency room staff at those hospitals of the actual or potential incident. In addition to this standard procedure, described in Exhibit G- 4, the operator would notify the primary emergency coordinator (or an alternate, if the primary is unavailable). The Mayo Clinic Rochester administrator first notified of the incident may activate the Mayo Hospital Incident Command System (HICS).
If the reported incident involves an explosion, fire or potential fire, the telephone operator would also notify the Rochester Fire Department and on-call maintenance personnel. The responsibilities of each of these parties are outlined in Exhibit 4.
Upon arriving at the scene, the emergency coordinator would identify the wastes involved and the hazards posed, notify any additional local authorities needed to respond to the incident (through the operator or HICS), and remain on the scene to notify responding parties of the hazards poses and assist in their mitigation. Upon assessing the situation, the emergency coordinator will notify the Minnesota Pollution Control Agency (800/422-0798) and the National Response Center (800/424-8802) if it is determined that a release, fire or explosion involving hazardous wastes has occurred which threatens human health or the environment outside the Baldwin Building.
These notifications would include:
1. Name and telephone number of the emergency coordinator (or, if established, the HICS);
2. Name and address of the facility;
3. Name and nature of incident;
4. Name and qualities of materials involved, to the extent known;
5. Extent of injuries, if any; and
6. The possible hazards to human health or the environment outside the Baldwin Building.
G-4b Identification of Hazardous Wastes
Reference: 7045.0468 Subp. 3
The emergency coordinator will identify the character, amount, and source of the hazardous waste involved through a visual inspection. Current inventory logs will be consulted as needed. If the visual inspection is inconclusive, samples will be taken and chemically analyzed, provided sufficient time is available to acquire and utilize such laboratory data in responding to the incident.
G-4c Assessment
Reference: 7045.0468 Subp. 4
During any emergency at the facility, the emergency coordinator will assess the possible direct and indirect hazards to human health and the environment as well as the potential need for evacuation. This assessment will include the direct and indirect effects of any material release, fire, or explosion (e.g. the effects of any toxic gases which could be generated, the effects of any hazardous sewer discharges or chemical agents used to control the fire).
G-4d Control Procedures
Reference: 7045.0466 Subp. 3
The specific Contingency Plan control procedures that are implemented in the event of a fire and/or explosion are described in Exhibit G-4. The procedures which would be utilized to control chemical spills and leaks are as follows.
1. Report the spill to the emergency coordinator as rapidly as possible.
2. Contain the spill. This would likely require spreading a sorbent material over the entire spill area.
3. The emergency coordinator will go to the spill area as rapidly as possible and decide what needs to be done. He/She will take immediate steps to stop and prevent further spillage. If help is needed, he/she will summon the necessary manpower and equipment. He/She will do whatever is necessary to minimize or eliminate danger to people, equipment, and the facility, including ordering the evacuation of the building, if necessary.
4. The final step in containment and control is clean-up. In the case of a small spill where a sorbent material has been used for containment, the material would be swept up after it has absorbed the material. This material would go into a drum, plainly marked as to contents and that is for disposal in an approved hazardous waste management facility.
All spills will be completely cleaned as rapidly as possible. This takes priority over all matters with the exception of safety and health.
G-4e Prevention of Recurrence or Spread of Fires, Explosions or Releases
Reference: 7045.0468 Subp. 7
A primary goal of emergency actions will be to: (1) contain the fire or spill and, (2) prevent its continuance, spread or recurrence. The procedures described in Section G-4d will be employed to achieve these goals.
G-4f Storage and Treatment of Released Material
Reference: 7045.0410 Subp. 1
The emergency coordinator will contact the hazardous waste manager who will make arrangements for the timely treatment, storage or disposal of recovered waste, contaminated absorbent or any other material that results from a release, fire, or explosion at the facility. Collected materials would either be stored on-site or immediately removed by contractors for treatment/disposal.
G-4g Incompatible Wastes
Reference: 7045.0470 Subp. 1
If incompatible wastes are involved in the incident or must otherwise be handled, the emergency coordinator will take whatever precautions are needed to prevent interaction or reaction of incompatible waste. This would be accomplished through careful segregation of incompatible wastes.
G-4h Post-Emergency Equipment Maintenance
Reference: 7045.0470 Subp. 1
Following any emergency, all emergency equipment listed in Section G-5 will be inspected and expeditiously cleaned, repaired or replaced, as necessary.
G-5 EMERGENCY EQUIPMENT
Reference: 7045.0466 Subp. 4.E
Exhibit G-5 lists the emergency equipment at the facility. Included are descriptions of the items and their capabilities. Exhibit G-6 is a floor plan of the ground floor, subway level, and basement in the Baldwin Building showing the location of emergency equipment. Exhibit G-7 is a floor plan or the container storage room showing the location of safety equipment/features.
G-6 COORDINATION AGREEMENTS
Reference: 7045.0464 and 7045.0466 Subp. 4.C
The Mayo Clinic Rochester has made arrangements with local authorities to provide appropriate assistance in responding to emergencies at the facility. Copies of this Contingency Plan have been given to the local police, fire department, and the hospital. These agencies were asked to review and comment on the plan, and have planned the actions they will take in responding to emergencies.
The following organizations were sent copies of the Contingency Plan:
Saint Marys Hospital – Vickie Ernste, Mark Krajewski Rochester Fire Department – Chief Greg Martin Rochester Police Department – Chief Roger Peterson Olmsted County Emergency Management – Capt. Mike Bromberg
A copy of the transmittal email is found in Exhibit G-10.
G-7 EVACUATION PLAN
Reference: 7045.0466 Subp. 4.F
Evacuation procedures would be carried out whenever an emergency situation endangers occupants of the Baldwin Building. Exhibit G-8 outlines the procedures and facility personnel responsibilities to be observed in evacuating the Baldwin Building. Evacuation route signs for all Mayo buildings are posted on each floor. The emergency coordinator is authorized to initiate an evacuation of the building.
If the nature of the emergency indicates that surrounding buildings should also be evacuated, the emergency coordinator will advise the operator and/or the HICS. Appropriate Mayo Clinic Rochester staff and local fire and police departments would be advised in turn.
G-8 REQUIRED REPORTS
Reference:
7045.0468 Subp. 5.A
As required, any emergency event that requires implementing the Contingency Plan will be reported in writing within 15 days to the EPA Regional Administrator. The Minnesota Pollution Control Agency will be notified before operations resume. A reporting form for emergency events is shown in Exhibit G-9. A spill or release of a hazardous substance that exceeds the reportable quantity under Title III of SARA will be immediately reported to:
(1) Local Emergency: 911 (2) State Emergency Response: (800)422-0798 or (651)649-5451 (3) National Response Center: 1-800-424-8802
A record of the emergency event will be entered in the operating record.
G-9 LOCATION OF CONTINGENCY PLAN
Copies of the plan will be located in the safety cabinet just outside the storage facility and in the hazardous waste processing room, currently Guggenheim 112.
G-10 AMENDMENTS TO PLAN
This Contingency Plan will be amended as necessary. Amendments will be forwarded to the MPCA to update the permit and amendments will be placed in all copies of the plan.
EXHIBIT G-1
BALDWIN BUILDING LOCATION
EXHIBIT G-1
EXHIBIT G-2 BALDWIN BUILDING BASEMENT FLOOR PLAN
Baldwin Building Basement Floor Plan
EXHIBIT G-3
EMERGENCY COORDINATORS
EMERGENCY COORDINATORS
COORDINATOR TELEPHONE HOME ADDRESS
1. Gregory Smith (507)284-6369(O) 3008 5th AVE NW (507)292-7876(H) Rochester, MN 55901
2. Raymond W. Gladkowski III 704 18th St SE (507)284-6600(O) Rochester, MN 55904 (507)351-9260(H)
3. Peter Nitschke (507)284-6981(O) 2628 13th Ave NW (507)280-9211(H) Rochester, MN 55901
4. Chemical Spill Team (507)284-2179 External or On Call 911 Internal, Mayo Clinic Rochester ask for Chemical Spill Team
EXHIBIT G-4
FIRE EMERGENCY PROCEDURES
EXHIBIT G-5
EMERGENCY EQUIPMENT LIST
2017
Hilton 11th Floor Mechanical Space- Primary Response Cart Inventory Checklist
DATE JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC NUM 1. ABSORBENTS* - 1 GAL MINIMUM EACH 1
2. ABSORBENT TUBES 2 3. BOOTS – SLIP ON 4 4. CHEMICAL SUIT 4 5. DRAIN STOPPER 1 6. FIRE EXTINGUISHER 1 7. FIRST AID KIT 1 8. FLASHLIGHT BATTERIES - EXTRA SET 1 9. GLASSES – SAFETY/GOGGLES – PAIR 4 10. GLOVES – NITRILE 4 11.MANUAL - SACH'S 1 12. PAIL - 5 GAL/BAGS - HEAVY PLASTIC 3 13. PUTTY - REPAIR EPOXY 2 14. RESPIRATOR - FULL FACE 1-SM/2-LG/1-XL a. CONNECTIONS TIGHT - VALVES OPERATIONAL
b. FACEPIECE CONDITION ACCEPTABLE
c. RUBBER PARTS PLIABLE AND FLEXIBLE
d. DISINFECT AND CLEAN AFTER EACH USE 15. WARNING SIGNS - PLASTIC STAND UP 2 16. TOOLS**NONSPARKING - EACH 1 17. BINOCULAR 1
18.ACCURO DRAGER PUMP IN BLUE CASE 1
19. XYLENE DRAGER TUBES 10 10 20. ALCOHOL DRAGER TUBES 5 21. FORMALDEHYDE DRAGER TUBES *INCLUDES: SOLUSORB, NEUTRASORB, NEUTRACIT, SESQUICARBONATE **BROOM, DUST PAN, SQUEEGEE, SHOVEL
INITIALS OF INSPECTOR
YEAR 2017
Hilton 11th Floor Mechanical Space - Secondary Response Cart Inventory Checklist
DATE JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC NUM 1. ABSORBENTS* BOX 1 - 2 2. ABSORBENT TUBES 2 3. BOOTS – SLIP ON 4 4. CHEMICAL SUIT 4 5. FIRE EXTINGUISHER 1 6. FLASHLIGHT - FREE STANDING 1
7. FLASHLIGHT BATTERIES - EXTRA SET 1
8. GLOVES – NITRILE 4
9. GLASSES – SAFETY/GOGGLES – PAIR 2 10. PUTTY - REPAIR EPOXY 1 11. SCBA GEAR - SET 2 a. CYLINDER MINIMUN>20 (RECORD GUAGE PRESSURE) b. CYLINDER MINIMUM>20 (RECORD GUAGE PRESSURE) c. REGULATOR/WARNING DEVICE TESTED d. REGULATOR/WARNING DEVICE TESTED e. FACEPIECE CONDITION ACCEPTABLE f. FACEPIECE CONDITION ACCEPTABLE g. X-TRA CYLINDER MINUMM>20 (RECORD PRESSURE) h. X-TRA CYLINDER MINUMM>20 (RECORD
PRESSURE)
*Appropriate Quantity of Solusorb, Neutrasorb, and/or Neutracit will be loaded at time of need. INITIALS OF INSPECTOR
YEAR______
SAFETY CABINET INVENTORY
JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC DATE NUM 1. FIRST AID KIT 1 2. CONTENGENCY PLAN 3. SAFETY GLASSES 4 PR 4. CHEMICAL SUITS 6 5. RUBBER GLOVES 6 PR 6. ABSORBENT PILLOWS 4 LG 7. ABSORBENT PILLOWS 6 SM 8. ORGANIC VAPOR/ACID GAS RESPIRATORS 2 9. SOLUSORB – SOLVENT ABSORBENT 10. NEUTRASORB – ACID NEUTRALIZER 11. NEUTRACIT – CAUSTIC NEUTRALIZER
INITIALS OF INSPECTOR
EMERGENCY SUPPLIES AND EQUIPMENT
OVERHEAD SPRINKLER SYSTEM
Location: Baldwin Building container storage room
Description:
Automatic fire protection is provided by an aqueous film forming foam system. The system is a factory packaged concentrate and control unit with piping and closed sprinkler heads. The system is sized for 100 square feet per head coverage, 0.16 gpm per square foot discharge density, and a 3% (3M "Light Water") concentrate solution. A flow alarm signals the fire alarm system on activation of a sprinkler head.
FOAM FIRE FIGHTING SYSTEM
Location: Outside ease door to Baldwin Building container storage room
Description
Automatic fire protection is provided by an aqueous film forming foam system. The system is a factory packaged concentrate and control unit with piping, 2 hand hose stations, and a closed sprinkler head. The system has 0.16 gpm per square foot sprinkler discharge density, and the hand hose stations are designed for 50 gpm of a 3% (3M "Light Water") concentrate solution. A flow alarm signals the fire alarm system on activation of a sprinkler head or the fire hoses.
EXHIBIT G-6
EMERGENCY EQUIPMENT LOCATIONS
EXHIBIT G-7
CONTAINER STORAGE ROOM
EMERGENCY EQUIPMENT AND FEATURES
EXHIBIT G-8
OTHER EMERGENCY PROCEDURES FROM MAYO MEDICAL CENTER EMERGENCY PREPAREDNESS PLAN
EXHIBIT G-9
REPORTING FORM
REPORTING FORM FOR EMERGENCY EVENTS*
NAME, ADDRESS, AND TELEPHONE NUMBER OF FACILITY:
DATE, TIME, AND TYPE OF INCIDENT:
NAME, HAZARD RATING, AND QUANTITY OF MATERIAL(S) INVOLVED:
EXTENT OF INJURY (IF ANY):
ASSESSMENT OF ACTUAL OR POTENTIAL HAZARDS TO HEALTH OR THE ENVIRONMENT:
ESTIMATED QUANTITY AND DISPOSITION OF MATERIAL RECOVERED FROM THE INCIDENT:
*This report is to be completed for any emergency event that requires implementing the Baldwin Building Hazardous Waste Storage Contingency Plan and must be submitted within 15 days to:
US Environmental Protection Agency Region V 77 West Jackson Boulevard Chicago, IL 60604-3507 (312)353-2000 or (800)621-8431
EXHIBIT G-10
CONTINGENCY PLAN TRANSMITTAL EMAIL
From: Smith, Gregory D., CHMM [RO B-15WF] Sent: February 21, 2017 12:58 To: Ernste, Vickie K., M.S.N., R.N.; Greg Martin ([email protected]); Krajewski, Mark J., R.N.; Mike Bromberg; Roger Peterson ([email protected]) Subject: Contingency Plan For Mayo Hazardous Waste Facility Attachments: Contingency Plan MAYO CLINIC BALDWIN BUILDING.docx
The Mayo Clinic operates a hazardous waste storage facility located in the Baldwin Building. This facility is permitted by the Minnesota Pollution Control Agency and is required to have a Contingency Plan for emergencies. A copy of the most recent version of that plan is enclosed for your information.
Please contact me at 284-6369 with any questions you may have regarding this plan.
Gregory D. Smith, M.S., CHMM Hazardous and Radioactive Waste Manager Facilities Operations & Equipment Services Phone: (507)284-6369 E-mail: [email protected] ______Mayo Clinic 200 First Street S.W. Rochester, MN 55905 www.mayoclinic.org
SECTION H
PERSONNEL TRAINING
SECTION H
PERSONNEL TRAINING
The information presented in this section describes the personnel training program for the Baldwin Building storage facility as required in 7001.0560 K and 7045.0454.
H-1 OUTLINE OF TRAINING PROGRAM
Reference: 7001.0560 K
H-1a Job Titles and Duties
Reference: 7045.0454 Subps. 6.A and 6.B
The routine management of hazardous wastes at the Baldwin Building storage facility is the responsibility of the Hazardous and Radioactive Waste staff. This currently consists of two technicians and one manager. The Hazardous and Radioactive Waste Manager is responsible for the administration of the hazardous waste program at Mayo, including training of hazardous waste management personnel, and for regulatory affairs related to hazardous waste management. Formal job descriptions are found in Exhibit H-1.
H-1b Training Content, Schedules, and Techniques
Reference: 7045.0454 Subps. 5 and 6.C
Facility personnel with responsibilities for hazardous waste management will successfully complete a program of classroom instruction and on-the-job training which teaches them to perform their duties in a way that ensures compliance with all relevant requirements of the Resource Conservation and Recovery Act. Training techniques may include lectures, videos, hands-on demonstrations, and on-the-job training.
This program is conducted and directed by a person trained in hazardous waste management procedures (see Section H-1c). The program includes instructions which teach facility personnel hazardous waste management procedures including preparedness, prevention, and contingency plans relevant to the positions in which they are employed.
The training program ensures that facility personnel are able to respond to emergencies by familiarizing them with emergency procedures, equipment and systems. An outline of the training program is presented in Figure H-1.
Facility personnel take part in an annual review of the initial training program. The annual review includes the key elements identified in Figure H-1 as well as a review of the past year's incidents (if any) and storage facility records. The annual training reviews are led by the Hazardous and Radioactive Waste Technologists and utilize an open discussion format.
H-1c Training Director
Reference 7045.0454 Subp. 2
The hazardous and radioactive waste management personnel training program is directed by Mr. Gregory D. Smith. Mr. Smith has a Masters of Science in Environmental Health and Safety Management and is a Certified Hazardous Materials Manager. He is knowledgeable in all aspects of the hazardous waste management regulations (state and federal). Mr. Smith completed "Personal Protection and Safety for Hazardous Waste Operations, 40-hr Program" in October 1993 at Clean Harbors Environmental Services and a similar 24-hr class from Clean Harbors Environmental Services in April 1996.
Figure H-1
MAYO CLINIC ROCHESTER HAZARDOUS WASTE MANAGEMENT PERSONNEL TRAINING PROGRAM OUTLINE
1. WASTES HANDLED
A. Waste types and sources B. Hazardous properties C. Material Safety Data Sheets (MSDS)
2. CONTINGENCY PLAN
A. Criteria for plan implementation B. Procedures for plan implementation C. Spill cleanup procedures/equipment D. Responding to fires and explosions E. Notification procedures F. Evacuation procedures
3. PREVENTATIVE PROCEDURES
A. Handling chemicals B. Transporting waste chemicals C. Segregation of incompatible wastes
4. SAFETY EQUIPMENT
A. Determining when safety equipment is appropriate B. Determining what equipment to use C. Procedures for use of equipment D. Care and storage of equipment
5. REVIEW OF PAST YEAR'S RECORDS
A. Accidents B. Inspection logs C. Manifests
H-1d Relevance of Training to Job Position
Reference: 7045.0454 Subp. 3
The Hazardous and Radioactive Waste Technologists receive the training described in section H- 1b and H-1e. This training program includes instruction on the hazardous waste management procedures relevant to the position held by this person. Specifically, the Hazardous and Radioactive Waste Technologists are trained in safe waste handling procedures as well as procedures to be used in responding to accidents such as fires, spills or explosions.
H-1e Training for Emergency Response
Reference: 7045.0454 Subp. 3
Mayo's personnel training program has been designed to emphasize the use of safe, established procedures for hazardous waste management to minimize the possibility of accidental occurrences such as spills, fires, and explosions. However, because there exists a recognized possibility for the occurrence of such accidents, Mayo's training program includes comprehensive instruction in the proper response to emergencies. Response procedures appropriate to the occurrence of spills, fires, explosions and personal injuries are included in the training program. Additionally, all Hazardous and Radioactive Waste personnel may be trained as 24 hour HAZWOPER technicians.
H-2 IMPLEMENTATION OF THE TRAINING PROGRAM
Reference: 7045.0454 Subps. 4, 5, 6 and 7
The current Hazardous and Radioactive Waste Technologists have successfully completed a program of pertinent classroom training and on-the-job training which is equivalent to the training program described in Section H-1. Annual repeats of the training review, described in Section H-1b, have been instituted at Mayo. New employees will not work in unsupervised positions until they have completed the training program described in Section H-1b.
The following documents and records will be kept and maintained at Mayo regarding personnel involved in the management of hazardous wastes at the Baldwin Building storage facility:
1. Job title for each position at the facility related to hazardous waste management and the name of the employee filling each job.
2. A written job description for each position listed under item 1.
3. A description of the type and amount of both initial and continuing training received by each person involved in hazardous waste management at the Baldwin Building.
4. Records documenting that required training has been given to and completed by facility personnel. These records will be kept until facility closure or 3 years after an employee no longer works in the facility, whichever is shorter.
EXHIBIT H-1
JOB DESCRIPTIONS
Job Title: Hazardous and Radioactive Waste Manager
Job Description: Oversees the collection, shipment, and disposal of all hazardous wastes within Mayo Clinic Rochester in Rochester, MN. Prepares and signs manifests and other documents for shipments. Directs the training of all hazardous waste technologists. Responds to chemicals spills if needed. Implements Contingency Plan. Audits disposal contractors. Serves as the primary contact for regulatory issues and inspections involving the hazardous waste program.
Qualifications: Four year degree in a technical field; Certified Hazardous Materials Manager. Experience in the waste management field. Completion of appropriate hazardous materials training courses and on-the-job training.
Training: Hazardous waste regulations (state and federal), DOT Regulations, waste minimization, Contingency Plan.
Incumbent: Gregory D. Smith, MS, CHMM
______
Job Title: Hazardous and Radioactive Waste Technologist
Job Description: Collects hazardous wastes. Segregates waste into appropriate categories for storage. Prepares wastes for shipment. Signs manifests and other shipping documents in the absence of the hazardous waste manager. Performs elementary neutralizations of wastes when appropriate. Responds to chemical spills if needed. Will be called upon if Contingency Plan is implemented.
Qualifications: High school graduate. Experience in waste collection and disposal. Completion of appropriate hazardous materials training courses.
Training: Proper containers, proper labeling, waste handling, waste compatibility, waste minimization, periodic inspections, accumulation rules, DOT regulations, hazardous waste regulations, Contingency Plan.
Incumbents: Peter Nitschke, Ronald Rank, Travis Brandt, CHMM
______
Job Title: Hazardous and Radioactive Waste Assistant Supervisor
Job Description: Assumes the role of HRW Manager in the absence of the HRW Manager. Collects hazardous wastes. Segregates waste into appropriate categories for storage. Prepares wastes for shipment. Signs manifests and other shipping documents in the absence of the hazardous waste manager. Performs elementary neutralizations of wastes when appropriate. Responds to chemical spills if needed. Will be called upon if Contingency Plan is implemented.
Qualifications: A Bachelor’s Degree in chemistry, physics, environmental, or earth science, and 5 years relevant work experience is required. Associates Degree and 10 years’ experience may be substituted. Completion of appropriate hazardous materials training courses.
Training: Proper containers, proper labeling, waste handling, waste compatibility, waste minimization, periodic inspections, accumulation rules, DOT regulations, hazardous waste regulations, Contingency Plan.
Incumbents: Raymond W. Gladkowski III, MS, CHMM
SECTION I
CLOSURE PLAN/COST ESTIMATE
SECTION I CLOSURE PLAN AND FINANCIAL REQUIREMENTS
This section is submitted in accordance with the requirements of 7001.0560 L, N, and Q and addresses the regulatory requirements of 7045.0486, 7045.0488, 7045.0502, 7045.0504, 7045.0518, and 7045.0526 subpart 9.
The Baldwin Building Closure Plan, contained in this Section, details all the actions necessary to close the facility and the estimated time and costs to complete these actions. In addition, this Section describes the financial assurance and liability insurance mechanisms to be utilized by Mayo.
I-1 CLOSURE PLAN
Reference: 7045.0486 and 7045.0526 Subp. 9
Mayo will maintain a copy of the closure plan on-site at all times. The director of the Minnesota Pollution Control Agency will be notified at least 180 days prior to the start of closure and, following completion, will be provided certification by Mayo and an independent registered professional engineer that the facility was closed in accordance with the closure plan.
I-1a Closure Performance Standard
Reference: 7045.0486 Subp. 2
Mayo's closure plan eliminates the need for any post closure maintenance. It was designed to: (1) ensure that the facility will not require further maintenance and controls, (2) minimize or eliminate threats to human health and the environment, and (3) avoid escape of hazardous waste, hazardous waste constituents, leachate, contaminated rainfall, or waste decomposition products to the ground or surface wastes or to the atmosphere.
I-1b Partial and Final Closure Activities
Reference: 7045.0486 Subp. 3.A
Mayo neither plans for nor anticipates that any partial closure activities will occur. Final closure is estimated to take place in the year 2035. It is anticipated that the storage facility will remain open and functional until that time. Should it become necessary to close the facility before that time, Mayo will follow the steps outlined in this plan.
I-1c Maximum Waste Inventory
Reference: 7045.0486 Subp. 3.B
The maximum operating inventory of hazardous waste in storage at any one time will be 2962 gallons.
I-1d Inventory Removal and Disposal or Decontamination of Equipment
Reference: 7045.0486 Subp. 3.C
Closure will be accomplished by contracting for removal and ultimate disposal of all Baldwin Building chemical wastes with an authorized, permitted hazardous waste disposal facility. Wastes will be containerized in DOT-approved shipping containers prior to removal from the Baldwin Building. The room floor, shelf units, and drum platform, as well as any other surfaces suspected of being contaminated with chemical wastes, will be decontaminated by hand scrubbing with a strong industrial detergent. All surfaces will be double-rinsed with water after detergent washing. Rinse waters will be collected and placed in 30-gallon or 55-gallon drums for disposal. Solid cleanup residues, including brushes, sponges, and mops will be assumed to be contaminated and drummed separately for disposal. All liquid and solid cleanup residues will be transported from the site and disposed of by permitted, authorized hazardous waste transporters and disposal firms under contract to Mayo Clinic Rochester.
I-1e Schedule for Closure
Reference: 7045.0486 Subp. 3.D. and 7045.0488 Subp. 1
There is no plan now or in the foreseeable future to close this facility. However, the year 2035 has been selected as the expected closure date for the purposes of complying with the information requirements.
The director of the Minnesota Pollution Control Agency will be notified by the Mayo Clinic Rochester within 180 days of the start of closure. A closure work plan will be submitted for MPCA review at that time.
Closure will be completed according to the following schedule:
Day 0 - Receive last volume of waste for storage. Day 30 - Complete removal for ultimate disposal of all wastes. Day 60 - Complete decontamination. Day 90 - Complete closure, submit required certifications.
When closure has been completed, both an appropriate Mayo Clinic Rochester representative and an independent registered professional engineer will submit certifications to the regional administrator that the facility was closed in accordance with the approval closure plan. (Note: To accomplish this, the independent, registered, professional engineer will be present during decontamination activities.)
I-1f Extension for Closure Time
Reference: 7045.0488 Subp. 2
The Mayo Clinic Rochester does not request an extension for closure time.
I-2 POST CLOSURE
Reference: 7045.0490
No post closure plan is required for this facility since it will only store wastes in containers and all wastes will be removed at closure.
I-3 NOTICE IN DEED AND NOTICE TO LOCAL LAND AUTHORITIES
Reference: 7045.0494 and 7045.0496
Not applicable.
I-4 CLOSURE COST ESTIMATE
Reference: 7045.0502
This cost estimate has been prepared to reflect the cost of closing Mayo's storage facility at the point in its operating life when closure would be most expensive. This would occur when the maximum inventory was on-site (2962 gallons).
The closure cost estimate assumes the purchase of all required supplies and labor and the use of contracted waste transport and disposal services. The close cost estimate and the calculations supporting the closure cost estimate are shown in exhibit I-1.
The cost estimate will be revised annually to adjust for inflation
I-5 FINANCIAL ASSURANCE MECHANISM FOR CLOSURE
Reference: 7045.0504
Mayo is demonstrating financial responsibility for conducting closure by means of the financial test. Exhibit I-2 contains an original of the financial test instrument, our independent certified public accountant's special report, and a copy of our independent certified public accountant's report on examination of Mayo's financial statements.
I-6 POST-CLOSURE COST ESTIMATE
Reference: 7045.0506
Since all wastes are disposal of off-site, there will be no post closure activities or cost.
I-8 LIABILITY INSURANCE
Reference: 7045.0518
Mayo has elected to satisfy the liability requirements by demonstrating that it passes the financial test. Exhibit I-2 contains an original of the financial test instrument, our independent certified public accountant's special report, and a copy of our independent certified public accountant's report on examination of Mayo's financial statement.
EXHIBIT I-1
CLOSURE COST ESTIMATE
CLOSURE COST ESTIMATE
AS OF MARCH 28 2016
2962 gal @ $6.70/gal 2962 $ 6.70 $ 19,845.40 2. Labor to prepare materials for shipment 32 hrs @ $48/hr 32 $ 48.00 $ 1,536.00 3. Industrial detergent and related cleaning equipment $ 485.00 4. Sump pump purchase $ 125.00 5. Labor to decontaminate storage room 24 hrs @ $48/hr 24 $ 48.00 $ 1,152.00 6. Rinsate disposal 200 gal @ $6/gal 200 $ 6.70 $ 1,340.00 7. Waste transportation 2 @ $1,500/trip 2 $ 1,500.00 $ 3,000.00 8. Independent professional engineer 16 hrs @ $120/hr 16 $ 110.00 $ 1,760.00 9. Subtotal $ 29,243.40 10. Contingencies 15% of Item No. 9 0.15 $ 29,243.40 $ 4,386.51 11. Administrative costs 15% of Item No. 9 0.15 $ 29,243.40 $ 4,386.51 12. TOTAL CLOSURE COST $ 38,016.42 ESTIMATE
EXHIBIT I-2
FINANCIAL ASSURANCE MECHANISM FOR CLOSURE
AND LIABILITY INSURANCE
SECTION J
ORGANIC AIR EMISSIONS
SECTION J
ORGANIC AIR EMISSIONS
The information presented in this section describes the applicability of and compliance with 40 CFR 264, Subpart AA, Subpart BB, and Subpart CC
J-1 40 CFR 264, Subpart AA, “Air Emission Standards for Process Vents.”
No activities to which the provisions of this subpart apply occur in the facility.
J-2 40 CFR 264, Subpart BB, “Air Emission Standards for Equipment Leaks.”
No activities to which the provisions of this subpart apply occur in the facility.
J-3 40 CFR 264, Subpart CC, “Air Emission Standards for Tanks, Surface Impoundments, and Containers.”
Only DOT containers are used for storage of wastes in the facility. Containers used are 55 gallons or smaller. In accordance with 40 CFR 264.1086(b)(1)(i) and 40 CFR 264.1086(c)(1), Mayo meets the requirements of Container Level 1 Standards and this subpart through use of DOT specification containers.
Inspections required by 40 CFR 264.1086(c)(4) will be performed. Any discrepancies and their disposition, will be noted in the Facility operating record. Exhibit E-1 provides a listing of the elements of the operating record.