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E-10A: REGULATED WASTE MANAGEMENT For Conditionally Exempt Small Quantity Generators (CESQG's) 1. DETERMINING IF WASTE IS HAZARDOUS OR HAZARDOUS Because it requires detailed understanding of the hazardous waste regulations to determine whether waste streams are hazardous,the best way to determine if a waste stream is hazardous is to contact your Corrugated Packaging Environmental Engineer. The engineer will provide assistance and will coordinate assistance with an approved hazardous waste contractor. 2. MAINTAINING ALL REQUIRED DOCUMENTATION AND RECORDS e Once you have completed the evaluation, Heritage Environmental Services, LLC (the only approved hazardous waste contractor) will assist in providing comprehensive waste profiles for all your hazardous and regulated waste streams. File these profiles and futureprofiles in File#3110 (Hazardous Waste Profiles). • For each shipment of hazardous/regulated waste, Heritage will prepare a manifest. You will need to file your copy of the manifest in File#3120 (Hazardous Waste Manifests). You should receive a copy of the completed manifest from the disposal facility verifying that the waste was received and disposed of properly within 35 days. File this copy with your original in File 43120 (Hazardous Waste Manifests). If you do not receive a copy of the completed manifest from the disposal company with 35 days,contact the Corrugated Packaging Environmental Engineer assigned to your facility and they will assist you in preparing and submitting an"Exception Report". File a copy of the"Exception Report" with the manifest in question in File# 3120 (Hazardous Waste Manifests). • Weekly Waste Inspection of Waste Storage Areas: After completing the weekly inspection and filling out the inspection form, file in File #3130 (Hazardous Waste Area Inspection Reports). • Hazardous Waste Storage Area Log: The log should contain the following information: (a) Description of each waste container in the storage area. (b) Dates/times when waste containers were placed in and removed from the storage area. (c) Amount of waste (in pounds) in each container. This must be in pounds to document you have not exceeded a total of 220 pounds hazardous waste generated in one month which is your limit as a Conditional Exempt Small Quantity Generator (CESQG). Conversion factors to convert liquid volumes to pounds measurement can be obtained from the Corrugated Packaging Environmental Engineer assigned to your site or from the approved hazardous waste management contractor (d) Dates/times/amounts when waste is added to containers in storage area(in pounds). Again, this helps to document you are under the total 220 pounds limit of hazardous waste generated in one month to maintain CESQG status. When logs are completed, file in File#3130 (Hazardous Waste Storage Area Reports). 3. HANDLING AND STORING REGULATED WASTE STREAMS Specific waste stream procedures have been prepared that describe all handling and storing requirements. The applicable procedures must be reviewed by those responsible for managing the waste stream. (See Attached) 4. WEEKLY INSPECTIONS OF WASTE STORAGE AREAS The weekly inspection of waste storage areas form (and log) is attached. If there are any "NO" answers in the comments section of the form, it must be reviewed and resolved with your immediate supervisor. List and date any corrective action in the space provided on the form. File completed inspection forms/logs in File #3130 (Hazardous Waste Area Inspection Forms). E10a - 1