Hamiltonsundstrandcorp Draft Hazrdouswaste Permit

CONNECTICUT HAZARDOUS WASTE RENEWAL PERMIT
PERMIT TO OPERATE A
PART B HAZARDOUS WASTE FACILITY PERMIT UNDER
THE RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
HAMILTON SUNDSTRAND CORP.
PERMIT NUMBER: DEEP/HWM-165-005

EPA ID No. CTD001145341
HAMILTON SUNDSTRAND CORPORATION

ONE HAMILTON ROAD
WINDSOR LOCKS, CONNECTICUT 06096-0010
TABLE OF CONTENTS
SECTION TITLE PAGE

Section I STANDARD FACILITY CONDITIONS
Section II PERMITTED ACTIVITIES
(A) Waste Management Units . . . . . . . . . II-3
(1) Container Storage Area . . . . . . . . II-4
(2) Loading and Unloading Area . . . . . . . II-4
(3) Staging Area . . . . . . . . . . . II-4
(4) Compactor Unit . . . . . . . . . . II-5
(5) Tank Storage Area . . . . . . . . . II-5
(6) J-Lot Area . . . . . . . . . . . II-6
(B) Chemical Management . . . . . . . . . II-6
(1) Specific Waste Prohibitions . . . . . . . II-6
(2) Permitted Wastes and Other Materials . . . . . II-8
(3) Permit Waste Management . . . . . . . II-9
Section III OPERATING CONDITIONS
(A) Operating Conditions Applicable to all Permitted Activities . III-3
(B) Container Storage Area Operating Conditions . . . . III-3
(C) Non-Hazardous Waste Tanks Storage Operating Conditions . III-15
(D) Loading and Unloading Area . . . . . . . . III-16
(E) Staging Area . . . . . . . . . . . III-16
(F) Compactor Unit . . . . . . . . . . . III-17
(G) J-Lot Area Activities . . . . . . . . . . III-17
Section IV GENERAL CONDITIONS
(A) Imminent Hazard Actions . . . . . . . . . IV-3
(B) Required Transfer Notice . . . . . . . . . IV-3
(C) Waste Analysis . . . . . . . . . . . IV-3
(D) Security . . . . . . . . . . . . . IV-4
(E) General Inspection Requirements . . . . . . . IV-4
(F) Personnel Training . . . . . . . . . . IV-5
(G) Special Requirements for Ignitable, Reactive or
Incompatible Wastes And/or Other Co-Stored Materials . . IV-6
(H) Preparedness and Prevention . . . . . . . . IV-8
(I) Contingency Plan . . . . . . . . . . IV-10
(J) Manifest System . . . . . . . . . . . IV-14
(K) Operating Record . . . . . . . . . . IV-14
(L) Availability, Retention and Disposition of Records . . . IV-15
(M) Biennial Report . . . . . . . . . . . IV-16
(N) Closure . . . . . . . . . . . . . IV-16
(O) RCRA Corrective Action Requirements . . . . . IV-20
(P) Financial Requirements . . . . . . . . . IV-21
(Q) Air Emission Requirements, Subpart CC . . . . . IV-22
(R) Universal Wastes . . . . . . . . . . . IV-23
(S) Used Oil . . . . . . . . . . . . IV-23
(T) Applicable Laws . . . . . . . . . . . IV-23
(U) Location Standards . . . . . . . . . . IV-21
Section V COMPLIANCE SCHEDULE

TABLE OF CONTENTS (Continued)
ATTACHMENTS TITLE
(A) Waste Analysis Plan

(B) Inspection Schedule Plan
(C) Personnel Training Plan
(D) Contingency Plan
(E) Closure Plan
TABLES TITLE
Table II-1 Container Storage Area Volumetric Capacities

Table II-2 Typical Compactor Wastes
Table II-3 Non-Hazardous Waste Tanks Storage Area Volumetric Capacities
FIGURES TITLE
Figure J-1 Hazardous Waste Facility – Facility Overview

Section I Hamilton Sundstrand Corp.
Standard Facility Conditions EPA ID No. CTD001145341
RCRA Part B Permit Renewal Permit No. DEEP\HWM-165-005
SECTION I
STANDARD FACILITY CONDITIONS
RCRA HAZARDOUS WASTE FACILITY RENEWAL PERMIT

ONE HAMILTON ROAD
WINDSOR LOCKS, CONNECTICUT O6096-0010

File:20210308 HS Section I - REV (2) cph, EPA. ac (ERM)a.doc Page I-1

SECTION I
TABLE OF CONTENTS
SECTION TITLE PAGE
(A) Design and Operation . . . . . . I-3

(B) Effect of Permit . . . . . . . I-3
(C) Severability . . . . . . . I-3
(D) Confidential Information . . . . . . I-3
(E) Duties and Requirements . . . . . . I-3
(1) Duty to comply . . . . . . I-3
(2) Duty to reapply . . . . . . I-4
(3) Need to halt or reduce activity not a defense . . I-4
(4) Duty to mitigate . . . . . . I-4
(5) Proper operation and maintenance . . . . I-4
(6) Permit actions . . . . . . . I-4
(7) Property rights . . . . . . I-4
(8) Duty to Provide Information . . . . I-5
(9) Inspection and entry . . . . . . I-5
(10) Monitoring and records . . . . . I-5
(11) Signatory requirements . . . . . I-6
(12) Transfers . . . . . . . I-6
(13) Reporting requirements . . . . . I-6
(14) Computation of time . . . . . I-8
(15) Waste minimization . . . . . I-9
(16) Additional requirements . . . . . I-9
(17) Federal and State Laws . . . . . I-9
(18) Modification of the Compliance Schedule . . . I-9
(19) Delegation of a Licensed Environmental Professional . I-10
(20) Incorporation by Reference . . . . . I-10
(F) Definitions . . . . . . . . I-11

SECTION I
(A) DESIGN AND OPERATION. The Permittee shall operate, maintain and repair its
facility to minimize the possibility of a fire, explosion, or any unplanned sudden or
non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or
surface water which could threaten human health or the environment.
(B) EFFECT OF PERMIT
(1) Except as is provided for in the Regulations of Connecticut State Agencies

(RCSA) Section 22a-449(c)-110(a) (2) and except for any federally enforceable
requirement(s), compliance with this Permit during its term constitutes
compliance, for purposes of enforcement, with Section 22a-449(c) of the
Connecticut General Statutes (CGS). This Permit may be modified, revoked and
reissued, or terminated by the Commissioner of the Department of Energy and
Environmental Protection (“the Commissioner”) during its term as set forth in
RCSA Section 22a-449(c)-110(a) (1), which incorporates by reference Title 40 of
the Code of Federal Regulations (CFR) Sections 270.41, 270.42 and 270.43, as
modified by Section 22a-449(c)-110(a) (2).
(2) The issuance of this Permit does not authorize any injury to persons or property or
invasion of other private rights, or any infringement of state or local law or
regulations.
(C) SEVERABILITY. The provisions of this Permit are severable, as specified in 40 CFR
124.16, and if any provisions of this Permit, or the application of any provision of this
Permit to any circumstances is held invalid, the application of such provision to other
circumstances and the remainder of this Permit shall not be affected thereby.
(D) CONFIDENTIAL INFORMATION. The Permittee may claim that any information
required to be submitted by this Permit contains or constitutes a trade secret in
accordance with Section 1-210(b) (5) of the CGS.
(E) DUTIES AND REQUIREMENTS
(1) Duty to comply. The Permittee shall comply with all conditions of this Permit,
except that the Permittee need not to comply with the conditions of this Permit to
the extent and for the duration that such noncompliance is authorized in an
Emergency Permit that explicitly authorizes any such noncompliance.
Noncompliance by the Permittee with the terms of this Permit, except under the
terms of an Emergency Permit, shall constitute a violation of this Permit and any
applicable laws or regulations and is grounds for enforcement action, for permit
termination, revocation and reissuance or for denial of a permit renewal.
Emergency Permit as used herein shall mean Emergency Permit as identified in
40 CFR 270.61. Unless superseded by a more stringent provision in this Permit,
in which case the more stringent provision of this permit shall apply, as a
condition of this Permit, the Permittee shall comply with all of the applicable
requirements of the state’s hazardous waste regulations RCSA Section
22a-449(c)-100 et seq., including any applicable portion of 40 CFR 260 through
279 incorporated by reference therein.
(2) Duty to reapply. If the Permittee wishes to continue engaging in an activity

regulated by this Permit after the expiration date of this Permit, the Permittee shall
apply for a renewal permit at least one-hundred-eighty (180) calendar days before
this Permit expires, in accordance with Section 22a-3a-5 of the RCSA and any
other applicable law.
(3) Need to halt or reduce activity not a defense. It shall not be a defense for a
Permittee in an enforcement action that it would have been necessary to halt or
reduce any activity authorized by this Permit in order to maintain compliance with
the conditions of this Permit.
(4) Duty to mitigate. In the event of noncompliance with this Permit, the Permittee
shall take all reasonable steps to minimize releases to the environment and shall
carry out such measures as are reasonable to prevent its noncompliance from
having significant adverse impacts on human health or the environment. No
action taken by the Permittee pursuant to this section of this Permit shall affect or
limit the Commissioner's authority under any other statute or regulation.
(5) Proper operation and maintenance. The Permittee shall at all times properly
operate and maintain the Facility and all systems of storage, treatment and control
(and related appurtenances) installed or used by the Permittee to achieve
compliance with this Permit. Proper operation and maintenance at a minimum
includes effective performance, adequate funding, adequate operator staffing and
training, and adequate analytical data, including appropriate quality assurance
procedures. This provision requires the operation of back-up or auxiliary
facilities or similar systems only when necessary to achieve compliance with the
conditions of this Permit.
(6) Permit actions. This Permit may be modified, revoked and reissued, or
terminated as provided for in 40 CFR, Subpart D, Parts 270.40 through 270.43, as
modified by RCSA Section 22a-449(c)-110(a)(2), and in accordance with all
applicable law, including but not limited to, Sections 22a-6g and 6h of the CGS
and Section 22a-3a- 5 of the RCSA. The filing of a request by the Permittee for a
Permit modification, revocation and reissuance, or termination, or a notification
of planned changes or anticipated noncompliance, does not stay any condition of
this Permit.
(7) Property rights. This Permit does not convey any property rights of any sort, or
any exclusive privilege to the Permittee.

(8) Duty to provide information. The Permittee shall furnish to the Commissioner,
within a reasonable time, any information that the Commissioner may request to
determine whether cause exists for modifying, revoking, reissuing, or terminating
this Permit, or to determine compliance with this Permit. The Permittee shall also
furnish to the Commissioner, upon request, copies of records required to be kept
by this Permit.
(9) Inspection and entry. The Permittee shall allow the Commissioner, or an
authorized representative, upon the presentation of credentials and other
documents as may be required by law to:
(a) Enter at reasonable times upon the Permittee's premises where a permitted
facility or activity is located or conducted, or where records shall be kept
under the conditions of this Permit;
(b) Have access to and copy at reasonable times, any records that shall be kept
under the conditions of this Permit;
(c) Inspect at reasonable times any facilities, equipment (including monitoring

and control equipment), practices or operations regulated or required
under this Permit; and
(d) Sample or monitor at reasonable times, for the purposes of assuring the
Permittee's compliance with this Permit or as otherwise authorized by
RCRA, any applicable statute, any substances or parameters at any
location.
(10) Monitoring and records
(a) Samples and measurements taken for the sole purpose of monitoring shall
be representative of the monitored activity.
(b) The Permittee shall retain records of all monitoring information, including
all calibration and maintenance records and all original strip chart
recordings for continuous monitoring instrumentation, copies of all reports
required by this Permit, the certification required by 40 CFR 264.73(b)(9),
and records of all data used to complete the application for this Permit and
comply with the requirements of this Permit, for a period of at least three
(3) years from the date of the sample, measurement, certification, report or
application. This period may be extended by request of the Commissioner
at any time. The Permittee shall maintain records from all groundwater-
monitoring wells and associated groundwater surface elevations for the
active life of the facility.
(c) Records for monitoring information shall include:
(i) The date, exact place and time of sampling or measurements;

(ii) The individual(s) who performed the sampling or measurements;

(iii) The date(s) analyses were performed;
(iv) The individual(s) who performed the analyses;
(v) The analytical techniques or methods used; and
(vi) The laboratory results of such analyses.
(d) Each record or report required by this Permit, including, but not limited to,
records in the Operating record for the Facility and reports submitted to
the Commissioner, shall be true, accurate and complete to the best of the
knowledge and belief of the person responsible for generating or signing
such record or report, based on personal examination and familiarity with
the information contained in the record or report, including all attachments
thereto, and reasonable investigation, including, as necessary, inquiry of
those individuals responsible for obtaining the information contained in
such record or report.
(11) Signatory requirements. The Permittee's application and all reports or

information submitted to the Commissioner by the Permittee pursuant to this
Permit shall be signed by the person specified in and contain the certification
prescribed by RCSA Section 22a-449(c)-110(a)(1), incorporating 40 CFR 270.11.
(12) Transfers. This Permit is not transferable to any person without the advance
written authorization of the Commissioner, who may request whatever
information the Commissioner deems necessary regarding the potential transferee.
Before any such transfer, the Permittee and any proposed transferee shall fully
comply with the requirement of Section 22a-6o of the CGS and any applicable
requirement of 40 CFR 260 seq., relating to the transfer of the Facility or the
Permit, including but not limited to 40 CFR 270.40. The Commissioner may
require modification or revocation and reissuance of this Permit to change the
name of the Permittee and as an incident to any such transfer incorporate such
other requirements, as he deems necessary.
(13) Reporting requirements
(a) Anticipated noncompliance. The Permittee shall give as much advance

written notice as possible to the Commissioner of any planned changes in
the Facility or activity that may result in noncompliance with any
requirement of this Permit.
(b) Compliance. Except where otherwise provided for in this Permit, reports
of compliance and noncompliance with, or any progress reports on,
interim and final requirements contained in any compliance schedule
(Section V) of this Permit shall be submitted no later than fourteen (14)
calendar days following each schedule date.
(c) Twenty-four (24) hour reporting:

(i) The Permittee or his/her designee shall orally report to the

Commissioner any waste related activity at the Facility,
irrespective of whether such activity is in compliance with the
requirements of this Permit, which does or may pose an imminent
and substantial endangerment to human health or the environment,
immediately but not later than twenty-four (24) hours from the
time the Permittee becomes aware or should be aware of the
circumstances causing any such endangerment. The report to the
Commissioner shall include:
(A) Name, address, and telephone number of the Permittee;

(B) Name, address, and telephone number of the Facility;
(C) Date, time and type of incident;
(D) Description of the occurrence and its cause;
(E) Name and quantity of waste(s) or constituents thereof
involved;
(F) The extent of injuries, if any;
(G) An assessment of actual or potential hazards to human
health and the environment;
(H) Estimated quantity and disposition of recovered waste that
resulted from the incident;
(I) All information concerning the release of any waste or
constituents thereof that may cause an endangerment to
public drinking water supplies; or
(J) All information concerning a release or discharge of waste
or constituents thereof or of a fire or explosion from the
Facility, which could threaten human health or the
environment.
(ii) A written submission shall also be provided within five (5)

calendar days of the time the Permittee becomes aware of the
circumstances described in subdivision (i) above. The written
submission shall contain a description of the endangerment and its
cause; the period of endangerment including exact dates and times,
if the endangerment has been abated, and if not, the anticipated
time it is expected to continue, and steps taken or planned to
reduce, eliminate, and prevent reoccurrence of the endangerment.
The Permittee shall maintain in the Operating record of the Facility
a copy of all of such written reports. The Commissioner may
waive the five (5)-calendar days written notice requirement in
favor of a written report within fifteen (15) calendar days of the
incident requiring reporting.
(iii) Nothing in this section shall affect or relieve the Permittee of its
obligations under Section 22a-450 of the CGS.
(d) Manifest discrepancy report. The Permittee shall report manifest

discrepancies in accordance with 40 CFR 264.72, which is hereby

incorporated by reference herein.
(e) Unmanifested waste report. The Permittee shall report unmanifested

waste in accordance with 40 CFR 264.76, which is hereby incorporated by
reference herein.
(f) Biennial report. The Permittee shall fully and accurately complete and
submit to the Commissioner by March 1 of each even numbered year a
biennial report regarding waste activities at the Facility for the previous
calendar year on a form or electronic method prescribed by the
Commissioner. In addition, the Permittee shall provide any other
information that the Commissioner specifies relating to the activities at the
Permittee’s Facility.
(g) Other Noncompliance. The Permittee shall report all instances of

noncompliance with this Permit not otherwise required to be reported by
this Permit to the Commissioner along with any other required monitoring
report, but no later than thirty (30) calendar days of the date the Permittee
is aware, or reasonably should have been aware, of any such
noncompliance. Any such report shall contain the information listed in
paragraph (13) (c) (i) of this Section as well as all steps taken to correct
any such noncompliance.
(h) Other information. When the Permittee becomes aware that it failed to
submit any relevant facts or incorrect information in a permit application,
report or other document provided to the Commissioner regarding this
Permit, the Permittee shall promptly submit such relevant facts or correct
information to the Commissioner.
(i) Requirements Incorporated. Different sections of this Permit contain

requirements for the Facility. Compliance with all of the provisions in
each Section of this Permit is required, even if one section or provision of
this Permit does not specifically refer to or incorporate requirements from
another section or provision of this Permit.
(14) Computation of Time.
(a) Computation of time. Except as is expressly provided for in this Permit,

the computation of time periods set forth in this Permit shall be as follows:
(i) Any time-period scheduled to begin on the occurrence of an act or

event shall begin on the day after the act or event.
(ii) Any time-period scheduled to begin before the occurrence of an act
or event shall be computed so that the period ends on the day
before the act or event.
(iii) If the final day of any time period falls on a federally or state
recognized legal holiday, the time period shall be extended to the

next working day. If the final day ends on a Saturday or Sunday,
the time-period shall not be extended to the next working day.
(b) Submission of reports. Where this Permit requires the submission of a

written report, a notification or other information or documentation to the
Commissioner, such report, notification or other information or
documentation shall be deemed submitted, including but not limited to,
submissions made by electronic mail, on the date such report, notification
or other information is received by the Department of Energy and
Environmental Protection (“the Department”).
(15) Waste Minimization. The Permittee shall have a program in place to reduce the
volume of toxicity of the waste that is generated to the degree determined by the
Permittee to be economically practicable; and the method of treatment, storage or
disposal currently available to the Permittee, which minimizes the present and
future threat to human health and the environment.
(16) Additional Requirements. Requirements not included in this Permit, which

become effective by statute or regulation and not made specifically inapplicable
to facilities with a Permit, shall apply to the Permittee's Facility. In the event of
any conflict between this Permit and any such requirement, the Permittee shall
comply with the more stringent requirement, if the Permittee does not fully
comply with the more stringent requirement, the Department may enforce either
requirement.
(17) Federal and State Laws. Nothing in this Permit shall be construed to prohibit any
federal, state, or political subdivision thereof from imposing any requirements to
the extent authorized by law, which are more stringent than those imposed by this
Permit. In addition, nothing in this Permit shall relieve the Permittee of its
obligation to comply with any other applicable federal, state, or local statute,
regulation, or ordinance.
(18) Modification of the Compliance Schedule Submittals.
(a) The Permittee may request to modify the submittal due dates of the
Compliance Schedule (Section V) of this Permit at any time. Such
requests shall be submitted for the Commissioner review and written
approval and shall include sufficient justification for such request(s).
(b) The Commissioner may grant extensions of submittal due dates based on
the Permittee’s demonstration that sufficient justification for the extension
exists. Extensions to due dates, which this Permit explicitly defines as
being due by a certain time or during a certain time interval, may be
granted by the Commissioner if the Permittee demonstrates sufficient
justification for the extension.

(19) Delegation of a Licensed Environmental Professional
(a) Pursuant to RCSA Section 22a-133v, a Licensed Environmental

Professional (LEP) may verify that site-wide environmental investigation
at the Facility has been performed in accordance with prevailing standards
and guidelines and remediation activities have addressed any and all
requirements of the Commissioner and have achieved compliance with the
RSRs.
(b) The LEP shall submit the Final Report for site-wide corrective action for
the Commissioner and EPA review and written approval in conjunction
with the submission of the verification.
(c) In the event the Commissioner revokes the delegation of site-wide

investigation and oversight of site-wide corrective action, the Permittee
shall ensure that all reports and documents required by this Permit are
submitted for the Commissioner and EPA review and written approval
within the timeframes specified.
(d) The Permittee shall notify the Commissioner in writing of the identity of
any LEP other than the one approved by the Commissioner, within then
(10) calendar days after assigning or retaining any LEP for the purpose of
addressing the actions required by this Permit. The Permittee shall submit
to the Commissioner a description of the assigned LEP’s education,
experience and training which is relevant to the work required by this
Permit within ten (10) calendar days after a request for such a description
has been made. Nothing in this paragraph shall preclude the
Commissioner from finding a previously acceptable LEP unacceptable.
(20) Incorporation by Reference.
(a) Unless specifically excluded by the state hazardous waste management

regulations, when a provision of the Code of Federal Regulations (CFR) is
used in this Permit, all notes, comments, appendices, diagrams, tables, and
figures referred to or cited in such provision shall also be included in such
reference. In addition, when a provision of the CFR is used or cited in this
Permit, such reference shall include all modifications made to any such
provision by the state hazardous waste management regulations.
(b) When a provision of the CFR is used in this Permit, unless otherwise
noted all internal references contained therein shall also be included by
such reference. In addition, each such internal reference to the CFR is
intended to include any modifications to such internal reference made by
the state hazardous waste management regulations.
(c) In the event of any inconsistency or duplication in the requirements of the

provisions incorporated by reference from 40 CFR 260 et seq., the state
hazardous waste management regulations, and the provisions of this

Permit, the provision that is more inclusive or more stringent shall prevail
and shall be enforceable.
(F) DEFINITIONS. The following terms shall be defined as follows for the purpose of this
Permit. Any term not otherwise defined herein shall be defined as that term is defined in
the RCSA Section 22a-449(c)-110(b) and (c).
(1) "Active Portion" means that portion of the Permittee's facility where wastes are
being or have been managed, placed and which has not undergone closure in
accordance with the terms of this Permit.
(2) “Area of Concern” or “AOC” shall mean any area at the Facility where hazardous
waste or hazardous constituents have or may have been released.
(3) “Battery” means a device consisting of one or more electrically connected

electrochemical cells, which is designed to receive, store, and deliver electric
energy. An electrochemical cell is a self-contained system consisting of an anode,
cathode, and an electrolyte, plus such connections (electrical and mechanical) as
may be needed to allow the cell to deliver or receive electrical energy. The term
battery also includes an intact, unbroken battery from which the electrolyte has
been removed.
(4) “Bulking” means the act of adding, consolidating, or combining like wastes.
(5) “Code of Federal Regulations” or "CFR," in reference to all or any portion of 40

CFR 124 and 40 CFR 260 to 279, inclusive, shall mean the Code of Federal
Regulations revised as of July 1, 2000. All other references to the Code of Federal
Regulations (i.e., reference to provisions other than 40 CFR 124 and 40 CFR 260
to 279, inclusive) shall mean the Code of Federal Regulations, in effect on the date
that this Permit is issued by the Commissioner.
(6) “Commissioner” shall mean the Commissioner of Energy and Environmental

Protection of the state of Connecticut, or the Commissioner’s duly authorized
designee.
(7) "Container" shall mean any portable device, not including a roll-off container, a
separate type of container defined below, in which a waste or material is stored,
transported, treated, or otherwise managed.
(8) "Container Storage Area" means the container storage area and other
appurtenances as specified in Section II, of this Permit.
(9) “Containment Pallet” shall mean a pallet on which containers are placed equipped
with a self-contained secondary containment system sufficient to contain 10
percent of the volume of all containers or 100 percent of the volume of the largest
container, whichever is greater, on the pallet.
(10) “CR01” shall mean any waste material containing or contaminated by PCBs
(Polychlorinated Biphenyls) in concentrations at or above fifty (50) ppm (parts per
million). These include, but are not limited to, PCB oils, items, and equipment.
(11) “CR02” shall mean oil or petroleum waste that is not a hazardous waste and is no
longer suitable for the services for which it was manufactured due to the presence
of impurities or loss of original properties and is not miscible in water. The term
includes, but is not limited to, crude oil, fuel oil, lubricating oil, kerosene, diesel
fuel, motor oil, non-halogenated oil, and oils that are recovered from oil separators,
oil spills, or tank bottoms.
(12) “CR03” shall mean oil or petroleum waste that is not a hazardous waste and is no
longer suitable for the services for which it was manufactured due to the presence
of impurities or loss of original properties and is miscible in water. The term
includes, but is not limited to, cutting oil emulsions and coolants.
(13) “CR04” shall mean any wastes that are not a hazardous waste and are liquid, free
flowing or contain free draining liquids and are toxic, hazardous to handle and/or
may cause contamination of ground and/or surface water if improperly managed.
The term includes, but is not limited to, grinding wastes, waste sludge, antifreeze
wastes and glycol solutions.
(14) “CR05” shall mean any chemical solid or semi-solid waste, excluding a hazardous
waste, from a commercial, industrial, agricultural, or community activity. The
term includes, but is not limited to, grinding, dusts, tumbling, sludge, scrap plastic
and rubber flash and other ground or chipped waste solid.
(15) "Daily" or “Day” shall mean a twenty-four (24) hour period beginning at midnight.
(16) “Department” or “DEEP” shall mean the Connecticut Department of Energy and
Environmental Protection.
(17) “Department of Transportation” or “DOT” shall mean the U.S. Department of

Transportation.
(18) “Empty” shall mean as prescribed in 40 CFR 261.7(b) and shall also apply to
containers of non-hazardous waste or other materials.
(19) "Facility" shall mean the contiguous land, and structures, other appurtenances, and
improvements on the land within the boundaries/perimeter of the property shown
on Figure J-1, Hazardous Waste Facility (HWF), Facility Overview.
(20) "Final Closure" shall mean the completion of the closure of all the Waste
Management Areas at the Permittee's facility in accordance with the requirements
of this Permit.

(21) "Hazardous Waste" or "Hazardous Wastes" shall mean any waste material which
may pose a present or potential hazard to human health or the environment when
improperly treated, stored, transported, disposed of or otherwise managed,
including, but not limited to, hazardous wastes specified in 40 CFR Part 261 and
RCSA Section 22a-449(c)-101. The term “hazardous wastes” shall include: (a)
hazardous wastes that are included in the federal hazardous waste program, even if
such wastes have not been added to the State’s hazardous waste program; and (b)
all hazardous waste included in the state’s hazardous waste program, even if such
waste is not included in the federal hazardous waste program.
(22) "Hazardous Waste Storage Areas" shall mean the building where the Permittee's
hazardous wastes or materials (including non-hazardous wastes) are managed,
including all areas incidental to such management as shown on Figure II-1, Waste
Management Area Layout and specified in Section II of this Permit.
(23) “J-Lot Area Activities” means a designated area to store non-RCRA hazardous
wastes roll-offs, virgin product on racks, and non-flammable compressed gas
cylinders in a locked cage.
(24) “Lab Pack Container” or “Lab Pack” shall mean a container that meets the
requirements of 49 CFR 173.12, including inner, outer packaging and other
requirements.
(25) “Liquid” or Liquid Form” shall mean visibly free flowing, a nearly incompressible
fluid that conforms to the shape of its container but retains a (nearly) constant
volume independent of pressure. As one of the fundamental states of matter (the
others being solid, gas and plasma), it is the only state with a definite volume but
no fixed shape.
(26) “Less than 90-Days Hazardous Waste Storage Areas” shall mean those portions of
the Permittee’s facility where hazardous wastes or other materials are stored for
less than 90-days, including all areas incidental to such storage.
(27) "NIOSH" shall mean the federal National Institute of Occupational Safety and
Health.
(28) “Non-Hazardous Waste” shall mean any waste material which may pose a present
or potentially hazard to human health or the environment when improperly treated,
stored, transported or disposed of or otherwise managed, excluding hazardous
waste.
(29) “Non-RCRA Regulated Media” means Non-RCRA waste solids such as

contaminated media (CR05), construction debris, spent filters, scrap metals,
unwanted wood and any other material that is not prohibited by this Permit.
(30) “OSHA” shall mean the federal Occupational Safety and Health Administration.

(31) "Other Material" or "Other Materials" shall mean:
(a) The following commercial chemicals, provided such commercial

chemicals are used by the Permittee at the Facility:
(i) New, unused, or virgin commercial chemicals, including chemical

intermediates and mixtures;
(ii) Off-specification commercial chemicals products;
(iii) Commercial chemicals reused without processing of any kind.
(32) "Partial Closure" means the closure of a Waste Management Area in accordance
with the applicable closure requirements of this Permit while other Waste
Management Areas continue in operation or active.
(33) “PCB” or “PCBs” shall mean any chemical substance that is limited to the
biphenyl molecule that has been chlorinated to varying degrees or any combination
of substances which contains such substances.
(34) “PCB Item” shall mean any PCB Article Container, PCB Container, PCB
Equipment, as those terms are defined in 40 CFR 761.3, or anything that
deliberately or unintentionally contains or has as a part of it any PCB or PCBs.
(35) “Permittee” shall mean Hamilton Sundstrand, Corporation.
(36) “Release” or “Spill” shall mean spilling, leaking, pouring, emitting, emptying,
discharging, pumping, escaping, leaching, dumping, discharging or disposing of
wastes or other materials, or constituents thereof, from any tank and associated
equipment, container, transportation vehicle, and any other article or device used
to contain, convey, or transport waste or other materials into or onto anything or
anywhere, including, but not limited to an area used for secondary containment,
except as an authorized activity under Section II of this Permit.
(37) “Remediation Standard Regulations” or “RSRs” shall mean Regulations of

Connecticut State Agencies (RCSA) Sections 22a-133k-1 through 22a-133k-3.
(38) “Roll-off Container” shall mean a container that meets the criteria specified by the
U.S. Department of Transportation that is a minimum of ten (10) cubic yards to a
maximum of seventy (70) cubic yards in size and into which waste or other
material is placed that is solid or semi-solid, but not liquid. Roll-off containers are
designed to be transported on vehicles specifically designed to load and off-load
the container. Roll-off Storage Area is shown on Figure J-1, Hazardous Waste
Facility (HWF), Facility Overview, and as specified in Section II of this Permit.
(39) “Scrap Metal” shall mean bits and pieces of metal parts (e.g., bars, turnings, rods,
sheets, wire) or metal pieces that may be combined with bolts or soldering which
when worn or superfluous can be recycled.
(40) “Site” means the same or geographically contiguous property that may be divided
by public or private right-of-way, provided the entrance and exit between the
properties is at a crossroads intersection, and access is by crossing as opposed to
going along, the right-of-way. Non-contiguous properties owned by the same
person but connected by a right-of-way that he controls and to which the public
does not have access, is also considered part of the site property.
(41) “Staging Area” shall mean the designated area located in the Container Storage
Area as shown on Figure J-1, Hazardous Waste Facility (HWF), Facility
Overview, and as specified in Section II of this Permit.
(42) “Storage” shall mean the holding or accumulation of waste or other materials for
a temporary period of time in accordance with this Permit.
(43) “Sufficiently impervious” means:
(a) Free of gaps, cracks and areas of bare earth;

(b) Capable of containing any hazardous waste, used oil or other material that
may be accidentally or otherwise released such that any such waste, used
oil or other material released does not migrate or seep from or through the
secondary containment system into the environment;
(c) Compatible with any waste, used oil or other material that may be
accidentally or otherwise released into the secondary containment system;
(d) If necessary, coated with a material resistant to weathering or damage such
that any waste, used oil or other material that may be accidentally or
otherwise released into the secondary containment system does not
migrate or seep from or through the secondary containment system into
the environment; and
(e) Free of floor or other drains, catch basins or similar structures that would
allow hazardous waste, used oil or other material to be released into the
environment.
(44) “Tank” shall mean a stationary device, designed to contain an accumulation of

waste or other material, which is constructed primarily of non-earthen materials
(e.g., concrete, steel, and plastic) which provide structural support.
(45) “Tank Systems” shall mean the Aboveground Tanks 121A and 121B and the
ancillary equipment, including, but not limited to, any equipment that conveys
waste to and from the tank, containment system, etc.
(46) “Universal Waste” shall mean the wastes (batteries, pesticides, mercury-
containing equipment, and lamps) covered under 40 CFR 273, and used
electronics specified in RCSA Section 22a-449(c)-113(b)(4).
(47) “Used Oil” shall mean any oil refined from crude oil or synthetic oil, that: (A) has
been used and as a result of such use is contaminated by physical or chemical

impurities; or (B) is no longer suitable for the services for which it was
manufactured due to the presence of impurities or a loss of original properties.
(48) “Wastes” shall mean “hazardous wastes,” “CR01,” “CR02,” “CR03,” “CR04,”
and “CR05,” wastes, “non-hazardous wastes,” “Used Oil,” Scrap Metal,”
“Universal Waste,” and all waste which after treatment at the Facility, no longer
exhibits the characteristic of a hazardous waste and can be land disposed under 40
CFR Part 268.
(49) “Waste Management Units” or “Waste Management Areas” unless specifically

limited by this Permit or unless the context unequivocally indicates otherwise
(e.g., that reference is being made to only one and not both areas), shall mean all
of the waste management units at the Permittee’s Facility, including the
loading/unloading areas, staging area, container storage area, compactor unit area,
and the J-Lot area, all of which are shown on Figure J-1, Hazardous Waste
Facility (HWF), Facility Overview, and as specified in Section II of this Permit
including all secondary containment areas associated with these areas.

Section II Hamilton Sundstrand Corp.
Permitted Activities EPA ID No. CTD001145341
RCRA Part B Permit Renewal Permit No. DEEP/HWM-165-005
SECTION II
PERMITTED ACTIVITIES
RCRA PART B HAZARDOUS WASTE RENEWAL PERMIT

ONE HAMILTON ROAD

File:20210308 SECTION 2 HS REV (3) cph ac(ERM) .doc Page II-1

SECTION II
TABLE OF CONTENTS
SECTION TITLE PAGE

(A) Waste Management Units . . . . . II-1
(1) Container Storage Area . . . . II-1
(a) Authorized Activity . . . . II-1
(b) Permitted Capacity . . . . II-1
(c) Secondary Containment Volume . . II-3
(d) Permitted Wastes . . . . II-3
(2) Loading and Unloading Area . . . . II-4
(b) Permitted Wastes and Other Materials . II-4
(c) Prohibited Wastes . . . . II-4
(3) Staging Area . . . . . II-4
(d) Permitted Capacity . . . . II-5
(4) Compactor Unit
(c) Secondary Containment . . . II-6
(d) Permitted Wastes . . . . II-6
(e) Prohibited Wastes . . . . II-6
(5) Tank Storage Area . . . . . II-7
(c) Secondary Containment . . . II-7
(d) Permitted Wastes . . . II-8
(6) J-Lot Area . . . . . . II-8
(d) Permitted Capacity . . . . II-9
(B) Chemical Management . . . . . II-9
(1) Specific Prohibitions . . . . . II-9
(2) Permitted Materials . . . . . II-10
TABLES TITLE
Table II-1 Container Storage Area Volumetric Capacities . . II-11
Table II-3 Typical Compactor Wastes . . . . . II-12
Table II-2 Tank Storage Volumetric Capacities . . . . II-13
FIGURE TITLE
Figure J-1 Hazardous Waste Facility – Facility Overview . . II-14

SECTION II
PERMITTED ACTIVITIES
This Permit authorizes only those activities that are explicitly provided for in this Permit. As
used in this Permit, the terms "management" or "storage" shall not be construed to authorize any
activity that is not explicitly authorized by this Permit.
(A) WASTE MANAGEMENT AREAS. This Permit authorizes the Permittee to store and
manage hazardous waste and other materials in the Hazardous Waste Facility building
(HWF). The HWF includes an office, locker/shower room, packaging area,
shipping/receiving area and Waste Storage and Management Areas such as the Container
Storage Area, Loading/Unloading Area, Staging Area, Compactor Unit Area, Tank
Storage Area and J-Lot Area as described herein. These Waste Management Areas are
identified on Figure J-1, Hazardous Waste Facility (HWF) Facility Overview.
The Permittee shall operate, maintain, and repair the facility in conformance with the
requirements of this Permit. In the event of a conflict between the application
(Application Number 202005929) dated March 26, 2020, and as amended, submitted by
the Permittee and this Permit, the requirements of this Permit shall take precedence and
apply.
The Permittee shall comply with the following requirements for each Waste Management
Area:
(1) CONTAINER STORAGE AREAS (CSA)
(a) Authorized Activity. The Permittee is authorized to store and manage

containers of wastes and/or other materials in the HWF.
(b) Permitted Capacity. The Permittee shall ensure that at no time does the
total volume or quantity of waste or other materials in the CSA exceed a
combined total of 55,000 gallons. A typical distribution of the CSA
volume capacity is presented in Table II-1, Container Storage Area
Volumetric Capacity,
For purposes of determining compliance with the volume capacity limit,

each container in this area shall be assumed full. This excludes containers
labeled as empty and empty over-packs.
(c) Secondary Containment Volume. The Permittee shall ensure that the CSA
has a secondary containment volume sufficient to hold at least 10 percent
of the total permitted volume of all the wastes or 100 percent of the largest
container, whichever is greater.
(d) Permitted Wastes and Other Materials. Provided it is not otherwise

prohibited by this Permit, the Permittee shall not bring to, place within or

allow in the CSA any waste or other material other than those waste codes
identified in Section II (B) (2) along with those types identified for the
CSA in Table II-1. Provided secondary containment capacity is not
exceeded and materials are compatible with other materials or wastes
stored in the area, the Permittee may store other materials in the CSA.
(2) LOADING/UNLOADING AREA
(a) Authorized Activity. The Permittee shall ensure that any loading and/or
unloading of waste or other materials onto transportation vehicles for off-
site shipment is conducted in accordance with the Operating Procedures of
the Facility.
(b) Permitted Wastes and Other Materials. Provided it is not otherwise

prohibited by this Permit, the Permittee shall not bring to, place within or
allow in the Loading/Unloading Area any waste or other material other
than those wastes codes identified in Section II (B) (2) and/or other
compatible materials.
(c) Prohibited Wastes. The Permittee shall not allow in the Loading/
Unloading Area any wastes or other materials that are specifically
prohibited by this Permit in Section II (B) (1), Specific Prohibition.
(3) STAGING AREA
(a) Authorized Activity. The Permittee is authorized to stage containers in a

dedicated area of the HWF for up to five (5) days.
(b) Permitted Wastes and Other Materials. The Permittee shall not store,
treat, mix, bulk, dispose of, or engage in the management of any waste or
other material in the Staging Area other than the staging of permitted
compatible wastes listed in Section II (B) (2) and other materials in
accordance with Section II (B) (3). The Staging Area Compatibility
determinations shall comply with the requirements of 49 CFR Part
177.848(e), Hazardous Materials Load and Segregation Chart.
(c) Prohibited Wastes. The Permittee shall not allow in the Staging Area any
wastes or other materials that are specifically prohibited by Section II (B)
(1) of this Permit.
(d) Permitted Capacity. The Permittee shall ensure that at any one time, the
total volumetric storage capacity of the Staging Area shall not exceed a
combined total of 5,500 gallons. This combined total includes either 100 -
55-gallon containers or a combination of totes and various sizes
containers.

(4) COMPACTOR UNIT AREA
(a) Authorized Activity. The Permittee is authorized to operate a Compactor

Unit to compact rags and other waste materials into a drum to minimize its
volume. The Permittee shall ensure that the compactor unit is operated in
accordance with the operating procedures and the conditions stipulated in
this Permit. Should a need to replace the compactor unit be necessary, the
Permittee shall submit a written notification to the Commissioner prior to
replacement and installation of such a compactor unit. Such a notification
shall include but is not limited to a letter justifying the equipment
replacement and equipment specifications. [In the event of replacement,
the compactor unit shall be replaced with equipment that is equivalent and
is equipped with air emissions controls with high performance efficiency].
(b) Permitted Capacity. The Permittee shall ensure that only a 55-gallon
container is utilized at any one time.
(c) Secondary Containment. The Permittee shall ensure that the base area of
the compactor unit is in good condition at all times (no visible cracks).
(d) Permitted wastes. The Permittee shall ensure that the management of
wastes in the compactor unit are not prohibited by this permit, at a
minimum, shall include those wastes listed in Table II-2, Typical
Compactor Wastes. The waste types may be rags, empty containers
(punctured aerosol cans) and oil filters.
(e) Prohibited wastes. The Permittee shall not allow in the Compactor Unit
Area any wastes or other materials that are specifically prohibited by
Section II (B) (1) of this Permit. In addition, compressed gas cylinders are
prohibited from being compacted.
(5) TANK STORAGE AREA
(a) Authorized Activity. The Permittee is authorized to store and manage non-RCRA
hazardous wastes in the Aboveground Tank Systems identified in Table II-3,
Tank Storage Volumetric Capacities. Should a need to replace the pumping
systems associated with the tanks be necessary, the Permittee shall submit a
written notification to the Commissioner prior to replacement and installation of
such systems. Such a notification shall include but is not limited to a letter
justifying the equipment replacement and equipment specifications. [In the event
of replacement, the pumping systems shall be replaced with equipment that is
equivalent].
(b) Permitted Capacity. The maximum permitted storage capacity for the
Aboveground Tank Systems activities shall not exceed 12,000 gallons. The
permitted maximum capacities for each storage tank system are as tabulated in

Table II-3, Tank Storage Volumetric Capacities
(i) The Permittee shall not allow more than 6,000 gallons to be placed in the
Aboveground Tank I.D. 121A.
(ii) The Permittee shall not allow more than 6,000 gallons to be placed in the
Aboveground Tank I.D. 121B.
(c) Secondary Containment. The Permittee shall ensure that the Aboveground Tanks,
121A and 121B, system is equipped with a double walled steel with a 100 %
containment capacity of the volume of the tank.
(d) Permitted Wastes. Provided it is not otherwise prohibited by this Permit, the
Permittee shall not allow any waste in any individual tank system other than those
types which are associated with the waste identified below:
(i) Tank I.D. 121A. Non-hazardous waste liquids.
(ii) Tank I.D. 121B. Used Oils, and non-hazardous combustible liquids/oils.
The used oils are accumulated for off-site recycling.
(6) J-LOT AREA
(a) Authorized Activity. The Permittee shall ensure that the J-Lot Area is operated in
accordance with the Facility Operating Procedures and the conditions stipulated in
this Permit.
(b) Permitted Wastes and Other Materials. The Permittee shall not store, treat, mix,
bulk, dispose of, or engage in the management of any waste or other material in
the J-Lot Area other than the storing of non-RCRA hazardous wastes roll-offs,
virgin product storage, accumulation of spent non-flammable compressed gas
cylinders in a locked cage for recycling and disposal.
(c) Prohibited Wastes. The Permittee shall not allow any wastes or other materials
that are specifically prohibited by Section II B (1) of this Permit.
(B) CHEMICAL MANAGEMENT
(1) Specific Prohibitions. The Permittee shall not allow any of the following
wastes, other materials to be brought to, processed, stored, or managed anywhere
within the Waste Management Area(s):
(a) Explosives identified in 49 CFR 173.50 (Class 1) and Forbidden Explosives

identified in 49 CFR 173.54, Subpart C, except for lab pack Research and
Development (R&D) Wastes.

(b) Compressed gases, as defined in 49 CFR 173.115, except for containers

which contain aerosol cans of 32 ounces or less, laboratory clean out or
discarded Research and Development (R&D) wastes; and non-flammable
compressed gases.
(c) Materials that are Poison by Inhalation, as defined in 49 CFR 173.115,

173.132 and/or 173.133.
(d) Infectious materials, as defined in 49 CFR 173.134 (DOT Class 6.2) except
for those generated onsite through first aid and other medical needs.
(e) Cryogenic liquids, as defined in 49 CFR 173.115(g).
(f) Any forbidden hazardous material identified in 49 CFR 173.21 and 173.54.
(g) Shock sensitive materials, defined as materials that are readily capable of
detonation or explosive decomposition or reaction at normal temperatures
and pressures, and materials sensitive to mechanical or localized thermal
shock at normal temperatures and pressures, including materials designed by
NFPA 704 as having a Reactivity Hazard Rating of 4.
(h) Special Hazards: The limits identified below are maximum storage
quantities of the combined total of both liquid and solid wastes present at the
Permittee’s Waste Management Area(s). These limitations apply per area.
(i) Liquid and Solid Oxidizing Materials, as defined in NFPA 43A;

Class 2 oxidizers shall not be stored in excess of 1,000 pounds,
Class 3 oxidizers shall not be stored in excess of 2,000 pounds, and
Class 4 oxidizers shall not be stored in excess of 100 pounds.
(ii) Organic Peroxide Formulations, as defined in NFPA 43B;

Class I Organic Peroxides, are prohibited,
Class II Organic Peroxides, are prohibited,
Class III Organic Peroxides, shall not be stored in excess of 1,500
pounds, and
Class IV Organic Peroxides shall not be stored in excess of 10,000
pounds.
(iii) Gaseous Oxidizers, as defined in NFPA 55 (formerly NFPA 43C).
(k) Liquids, or waste or other materials that contain liquids, in roll-off

containers. This Prohibition, however, does not apply to liquids that may
have settled during transportation/storage, provided that liquids that have
settled during transportation/storage shall be limited to liquids present in a
separate distinct phase that do not occupy more than one inch in a
container.

The Specific Prohibitions in Section II (B)(1) of this Permit do not apply to the
products or materials used by the Permittee in its laboratory or for maintenance at
its property, provided such products or materials are present in quantities no
greater than necessary for use by the Permittee.
(2) Permitted Wastes and Other Materials. Provided it is not otherwise prohibited
by this Permit, the Permittee shall not bring to, place within, or allow in the Waste
Management Areas any waste other than the wastes codes or types listed below.
(i) The following hazardous wastes, identified by the waste code(s) in 40

CFR Part 261, Subparts C and D:
D001, D002, D003, D004, D005, D006, D007, D008, D009, D010, D011,
D018, D021, D022, D026, D027, D028, D029, D035, D039 and D040
F001, F002, F003, F005, F006, F007, F008, F009, F011, F019, F039
PO11, P012, P029, P030, P064, P068, P087, P096, P098, P104, P105,
P106, P120
U002, U019, U031, U044, U057, U067, U075, U080, U102, U117, U121,
U122, U133, U134, U144, U151, U154, U159, U160, U161, U165, U188,
U197, U210, U213, U219, U220, U223, U226, U228, U239
(ii) Universal wastes;
(iii) Non-RCRA hazardous (Connecticut Regulated Wastes) as defined under

the Connecticut General Statutes (CGS), Section 22a-448. These wastes
are:
(a) Waste PCBs, waste code CR01,

(b) Waste oil, waste code CR02,
(c) Wastewater soluble oil, waste code CR03,
(d) Waste chemical liquids, waste code CR04, and
(e) Waste chemical solids, waste code CR05;
(iv) Used Oil;
(v) Other Materials;
(vi) Crushed metal drums and scrap metal and any other waste or material that
the Commissioner has approved, in writing, for management at the
Facility as scrap metal; and
(vii) Lab Packed wastes. Includes expired or spent materials, unused products
or materials, and laboratory waste in small quantities. The Lab packed
wastes shall be those waste codes permitted for the facility.

(viii) Biomedical Wastes.
(3) Permitted Waste Management
(a) The Permittee may store and manage wastes and other materials (e.g.,
virgin and off-specification commercial chemicals from technical,
analytical, reagent, grade chemicals, chemical intermediates, products,
non-hazardous wastes and any chemical mixture), except where otherwise
prohibited by this Permit, (e.g., shock sensitive materials) in the permitted
Waste Management Area(s) providing that the Permittee first complies
with the conditions listed below.
(b) Prior to placing into the permitted Waste Management Area(s) any
hazardous wastes or other materials, the Permittee shall determine that the
materials can be properly managed in accordance with the terms and
conditions of this Permit. At a minimum, the Permittee shall:
(i) Demonstrate that each hazardous waste or other material is not

specifically prohibited by Section II (B) (1) and the applicable
degree of hazard as defined in the Waste Analysis Plan,
incorporated herein as Attachment A, has been determined for each
hazardous waste or other material.
(ii) Characterize each hazardous waste or other material for those

parameters specified in the Waste Analysis Plan.
(iii) Verify, using the procedures specified in the Waste Analysis Plan,
that each hazardous waste or other material is compatible with all
co-stored materials.
(iv) Demonstrate that each hazardous waste or other material is being

stored in an appropriate container or tank system as required by
Section III, Operating Conditions. At a minimum, identify through
review of available data that the tank system or container is
compatible with the stored waste or other material.
(v) Demonstrate that each hazardous waste or other material is

compatible with the containment structure or other device as
required by Section III, Operating Conditions, at a minimum,
identifying through review of available data (e.g., manufacturer’s
specifications), that the waste or other material is compatible with
the coating used on the containment structure.
(vi) Demonstrate that the Contingency Plan adequately addresses all

potential hazards posed by each hazardous waste or other material,
specifically considering the suitability and compatibility of the

waste or other material with protective clothing (e.g., boots,

gloves, suits, etc.), availability of appropriate respirator protection
and emergency response equipment, monitoring equipment (e.g.,
explosion detection equipment, vapor analyzers, dragger tubes etc.)
and other relevant equipment.
(vii) Demonstrate that the Contingency Plan includes necessary

response procedures which, at a minimum, identify personal
protective equipment (PPE) required to properly handle the waste
and other material, and identify the appropriate response
procedures for handling incidents involving the waste or other
material.
(viii) Maintain an SDS or equivalent (e.g., waste profile) for each

hazardous waste or other material approved for storage or
management in accordance with Section IV (I)(2) to be located
with all necessary reference material as indicated in the
Contingency Plan. Such data shall be used in the event of an
incident requiring the implementation of that plan.
(c) The information used to make the demonstrations required by Section II

(B) (3) (b) shall be clearly documented and maintained in the operating
record until final closure of the Facility.
(d) The Permittee shall store and manage universal wastes in accordance with
RCSA Section 22a-449(c)-113.
(e) The Permittee shall store and manage used oil in accordance with RCSA
Section 22a-449(c)-119.
(f) The Permittee shall store and manage Non-RCRA wastes under CGS
Section 22a-448. Specifically, Non-RCRA waste codes CR01, CR02,
CR03, CR04, and CR05.

TABLE II-1
CONTAINER STORAGE AREA VOLUMETRIC CAPACITY
STORAGE MAXIMUM MAXIMUM WASTE GROUP TYPICAL WASTES
AREA NUMBER OF CAPACITY
CONTAINERS IN GALLONS
Rack - A 90 4,950 Ignitable and Ignitable and combustible liquids such as
Combustible paints, resins (non-isocyanate) and adhesives.
Rack – B 90 4,950 Toxics Burnable such as rags, oily debris, paint filters
and aerosol cans.
Rack – C 90 4,950 Toxics Burnable such as rags, oily debris, paint filters
and aerosol cans.
Rack – D 90 4,950 Toxics Burnable such as oily rags, oil filters, paint
filters and aerosol cans. Halogenated
solvents, fluorescent lamps, accumulation
containers for consolidating wastes such as
aerosol cans, epoxy resin, catalyst.
Rack – E 108 5,940 Toxics Machine sludges and metal hydroxide sludges
(cubic yard boxes). Treated Metal Powders.
Rack – F 108 5,940 Toxics Soils - Sporadic contaminated soils, Ultra
Filtration Zyglo filters, carbon canister filters,
silver recovery canisters and Treated Metal
Powders.
Rack – G 108 5,940 Toxics Aqueous wastes from processes such as solder
rinse water; vapor blast water and floor wash
water, concrete sawcut waters, dust collector
sludge containing water. Biomedical wastes
Rack – H 36 1,980 Supplies or toxics Used for supplies, may be used for storage of
toxic wastes.
Lab Pack Varies 55 Toxics/Other Miscellaneous wastes requiring segregation.
Cabinet
(SSC-7)
Lab Pack Varies 55 Ignitable and Miscellaneous wastes which are ignitable or
Cabinet-FC combustible wastes combustible.
(SSC-3)
Acids 24 1,320 Acids Wastes like chromic acid, phosphoric acid and
(SSC-2) fixer from printing, lead acid batteries.
PCB 24 1,320 PCB/Resin PCB’s in one room and Isocyanates and other
(SSC-4) / resins in another room.
Resin
(SSC-5)
Alkaline or 24 1,320 Alkaline or Alkaline wastes such as developer from
Cyanide Cyanide printing ammonia, sodium hydroxide and
(SSC-1) cyanides.
Building 24 1,320 Toxics Heated building for water-based waste when
WB the outside temperature falls below the
(SSC-6) freezing point (winter storage).
Totes Various size 3,951 Toxics/Corrosive Hazardous coolants, oils, waters
Roll-offs 30 cubic yards 6,059 Contaminated soils, machine sludges
TOTAL 55,000 GALLONS
Staging A combination 5,500 Compatible wastes Area preparation for container storage or
Area of totes and offsite shipment.
containers

TABLE II-2
TYPICAL COMPACTOR WASTES
WASTE PROFILE WASTE TYPES ESTIMATED ANNUAL

NUMBER QUANTITY IN
POUNDS (LBS)
WL13001 Haz Solidified paints. 60
WL13015 Haz Containers contaminated with paints 2,200

and resins.
WL13016 Haz paint & resin contaminated debris. 2,600
WL15001 Haz Rags & Contaminated debris. 65,000
WL15002 Haz Acid Filters. 1,200
WL15003 Haz Alkaline Filters. 300
WL15007 Haz Paint Filters. 500
WL15009 Haz absorbents. 20
WL15011 PPE, Paint Chips, Poly, Filters c/w Lead. 450
WL15018 Haz rags contaminated with fuel. 2,200
WL15022 Haz filters contaminated with fuel. 700
WL15034 Haz rags & debris from EPF. 1,200

TABLE II-3
TANK STORAGE VOLUMETRIC CAPACITIES
TANK VOLUME WASTE CODES TYPE OF WASTES

CAPACITY
(in gallons)
Tank 121A 6,000 CR04 Non-hazardous waste

liquids.
Tank 121B 6,000 CR02, CR03 Used Oil (for off-site

recycling), non-
hazardous combustible
liquids/oils.

FIGURE J-1
HAZARDOUS WASTE FACILITY (HWF)
FACILITY OVERVIEW

Waste Liquids
Burnables
Burnables
Burnables,
SSC-1
SSC-2
SSC-3
SSC-6
SSC-4
SSC-5
Resin Bldg. RB
SSC-7
HAZARDOUS WASTE FACILITY

Hamilton Sundstrand, Windsor Locks, Connecticut Project Number: 0533194
HAZARDOUS WASTE FACILITY (HWF) A.L.C

FIGURE J-1
FACILITY OVERVIEW
Section III Hamilton Sundstrand Corporation
Operating Conditions EPA ID No. CTD001145341
SECTION III
OPERATING CONDITIONS

ONE HAMILTON ROAD

File:20210623 Rev4 HS SECTION 3 Renewal cph2.doc Page III-1

SECTION III
TABLE OF CONTENTS
SECTION TITLE PAGE
(A) Conditions regarding the Facility and all Waste

Management Permitted Areas at the Hazardous Waste
Facility Building (HWF) , , , , , , III-3
(B) Container Storage Area Operating Conditions . . . III-12
(C) Non-Hazardous Waste Tanks Storage Operating Conditions . III-15
(D) Loading and Unloading Areas . . . . . III-16
(E) Staging Area . . . . . . . . III-16
(F) Compactor Unit . . . . . . . III-17
(G) J-Lot Area Activities . . . . . . . III-17

SECTION III
(A) CONDITIONS REGARDING THE FACILITY AND ALL WASTE

MANAGEMENT PERMITTED AREAS AT THE HAZARDOUS WASTE
FACILITY BUILDING (HWF).
In addition to any other requirements of this Permit, the Permittee shall comply with the
following requirements regarding the Facility, including the Waste Management Areas at
the Hazardous Waste Facility Building (HWF):
General Conditions
(1) The Permittee shall:
(a) Operate the HWF so as to prevent any waste or other material from
potentially causing or resulting in a hazard to human health or the
environment (e.g., fires, explosions, toxic fumes);
(b) Ensure that all waste or other materials in the Waste Management Area(s)
is secure and remains inaccessible to unauthorized persons; and
(c) Prevent unknowing entry or entry by unauthorized persons at the HWF;
(d) Ensure that at all times there is a single point of contact from the Facility
who:
(i) Is aware of the waste or other materials at the HWF, including but
not limited to, the hazards posed by such waste or other materials;
and
(ii) Can authorize response actions in the event of a release or

emergency condition at the HWF.
(2) The Permittee shall, at all times, provide a safe working environment for
employees at the Facility. At a minimum, the Permittee shall ensure that:
(a) There is adequate ventilation in the Waste Management Area; and
(b) Whenever Facility personnel may be exposed to wastes or other materials,

appropriate protective equipment is utilized, as specified by, but not be
limited to, the Safety Data Sheets (SDSs – formerly known as MSDSs), or
by the National Institute for Occupational Safety and Health (NIOSH).
(3) The Permittee shall not transport, load, unload, transfer, treat, manage. or handle
any waste or other materials, within, over or on any area of the Facility that has
the bare soil or unprotected surfaces. In addition, the Permittee shall maintain all
traveled surfaces in good repair so that such surfaces can withstand the
mechanical stress of traffic to which they are subjected and prevent damage to
containers and spillage of waste or other materials during the use of such surface.
For purposes of this provision, asphalt shall not be considered an “unprotected
surface.”
(4) The Permittee shall transport containers of waste or other materials at the Facility
using forklifts, hand trucks and/or other equipment capable of transporting such
containers.
(5) The Permittee shall prevent damage to containers of waste or other materials due
to freezing and shall protect such waste or other materials from high temperature.
(6) The Permittee shall not manage waste or other material at the HWF in a manner
which does or could:
(a) Generate extreme heat or pressure, fire, explosion, or violent reaction;

(b) Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient
quantities to threaten human health or the environment;
(c) Produce uncontrolled flammable fumes or gases in sufficient quantities to
pose a risk of fire or explosion;
(d) Damage the structural integrity of the item used to contain such waste or
other material; or
(e) Through other like means, threaten human health of the environment.
Training
(7) The Permittee shall ensure that all waste or other materials at the Facility are
handled or managed by personnel who have completed all of the required training
specified in the Personnel Training Plan (PTA), incorporated herein as
Attachment C to this Permit.
(8) The Permittee shall ensure that the receipt and/or transfer of containerized waste
or other material is performed by appropriately trained personnel, experienced in
the use of such equipment and techniques, as specified in the Personnel Training
Plan, incorporated herein as Attachment C to this Permit.
Markings
(9) The Permittee shall post fixed markings or signs at the Waste Management
Area(s) clearly designating the location of each group or type of wastes or other
materials being managed as appropriate. Each sign or marking shall be secure,
legible, and clearly visible from a distance of twenty-five (25) feet.
(10) The Permittee shall ensure that each container with hazardous waste is labeled or
marked clearly with the words “Hazardous Waste” and other words that identify
the contents of the container such as “flammable,” “acid,” “alkaline,” “cyanide,”
“reactive,” “halogenated solvent” or the chemical name of the contents of the

container.
Spills, Releases and Accumulated liquids
(11) The Permittee shall operate the HWF in a manner that minimizes the possibility
of spills or releases of waste or other materials. The Permittee shall manage and
maintain all of the Waste Management Areas within the HWF to prevent run-on
into such area and prevent spills, releases, or accumulated liquids, including, but
not limited to, precipitation from escaping a Waste Management Area.
(12) The Permittee shall remove all spilled or leaked waste or any liquid, including but
not limited to precipitation, that accumulates in any Waste Management Area(s)
or containment area, including secondary containment. The Permittee shall
remove such waste or liquid immediately upon detection, but, in no event later
than twenty-four (24) hours from the time such waste or liquid should have been
discovered. The Permittee shall ensure that any such spillage or leakage or liquid
remains within the secondary containment area of a Waste Management Area.
Notwithstanding the foregoing, if on a Saturday, Sunday or a federal holiday,
observed by Hamilton Sundstrand and the Facility is closed., except for the
potential receipt of waste or other materials from an emergency event, if
precipitation accumulates in a Waste Management Area(s), including a secondary
containment area(s), the Permittee shall have until the end of the next business
day when the Facility is open to remove such precipitation.
(13) The Permittee shall manage all spilled or leaked waste or any liquid, including,
but not limited to, precipitation, removed from a Waste Management Area(s) as a
hazardous waste, unless the Permittee demonstrates that such waste or liquid is
not a hazardous waste pursuant to 40 CFR 262.11 (Hazardous Waste
Determination). If not required to be managed as a hazardous waste, the
Permittee shall manage all such waste or liquid in accordance with this Permit and
all applicable requirements.
Notifications/Reports
(14) (a) The Permittee shall immediately notify the Commissioner using CT
DEEP’s Emergency Response & Spill Prevention Division (ERSPD) 24-
hour telephone number 860-424-3338 or, if that number is unavailable, at
860-424-3333 or toll free at 1-866-337-7745, of:
(i) Any spill or release at the HWF, including, but not limited to, a
leak from any container whose integrity has been compromised; or
(ii) Any emergency evacuation of the Facility for any purpose.
(b) The Permittee shall immediately notify the Director of the Waste
Engineering and Enforcement Division (WEED) by email at
DEEP.WEEDNotification@ct.gov of:
(i) Any partial shutdown of the Facility that substantially disrupts

normal operations for more than twenty-four (24) hours; or
(ii) Any significant threat to human health or the environment.
(c) In addition to the provisions of Section III (A)(14)(a) of this Permit, the
Permittee shall comply with all other applicable reporting or notification
requirements regarding any spill or release at the Facility, including but
not limited to, requirements under Section 22a-450 of the CGS and 40
CFR Part 302.
(15) (a) In addition, to any other information that may be required by the ERSPD,
within fifteen (15) calendar days of a spill or release at the HWF, the
Permittee shall submit a written report containing the following
information to the Director of WEED:
(i) Likely route of migration of the spill or release;
(ii) Characteristics of the surrounding soil (soil composition, geology,

hydrogeology, etc.);
(iii) Results of any monitoring or sampling conducted in connection with

the spill or release (if available). If sampling or monitoring data
relating to the spill or release are not available within fifteen (15)
calendar days, such data shall be submitted to ERSPD and WEED as
soon as they become available;
(iv) Proximity to down gradient drinking water wells, surface water,

populated areas, wetlands or other environmentally sensitive areas,
and habitat for endangered or threatened species; and
(v) Description of all response actions taken or planned.
(b) The Permittee shall maintain on-site copies of all reports required under
Section III (A)(15)(a) and all subsequent reports filed with the Department
regarding each such incident in the Operating Record until Final Closure
of the Facility.
(16) The Permittee shall ensure that the secondary containment systems for the Waste
Management Areas comply with the applicable requirements of 40 CFR 264.175
and 40 CFR 264.193.
Base and Berm Requirements for Secondary Containment System (Coating)
(17) The Permittee shall ensure that the base of the secondary containment for the
Waste Management Areas is free of cracks or gaps and is sealed with a chemical
resistant, impermeable coating compatible with all waste or other material, in
such Waste Management Area such that the secondary containment system will
contain leaks, spills or other liquids, including, but not limited to precipitation. At
a minimum:
(a) The application of a chemical resistant impermeable coating shall be in

conformance with the manufacturer’s specification. Prior to applying the
coating, the Permittee shall inspect the Waste Management Area(s). If
visible residue or any other material that could affect the performance of
the coating is found, the residue and material shall be removed in
accordance with Section III (A) (18) of this Permit.
(b) When there are gaps or cracks, in a secondary containment system or a

Waste Management Area’s coating needs repair or application, the
Permittee shall follow the procedures in Section III (A) (18), (19) and (20)
of this Permit.
(18) Whenever the integrity of a Waste Management Area’s base, berm or coating
specified in Section III (A) (17) is impaired or in need of repair or re-application,
the Permittee shall:
(a) Remove all waste and other materials from the Waste Management Area
or affected portion thereof, as necessary;
(b) Inspect the area for the presence of visible residue (stains, debris, wetness)
and if visible residue is found, remove the residue by scrubbing and
washing, and/or scarifying as necessary. When removing residue, the
Permittee shall only use materials that are standard in the industry for such
purpose;
(c) Determine the nature and extent of the impairment;
(d) Repair the affected area, or repair and/or reapply the coating of the
affected area as soon as possible, but not later than thirty (30) calendar
days after the Permittee discovers that the integrity of the area or of the
coating has been impaired or is in need of repair; and
(e) When conditions arise which do not allow this work to be completed in
the allowed thirty (30) days, the Permittee shall provide “additional”
secondary containment for all wastes stored in the affected area until the
reported impaired area inside the Waste Management Area has been
completed. A record of this alternate secondary containment measure, the
extent of impairment noted and the reason and length of delay in re-
application of coating shall be made and maintained in the Operating
Record until final closure of the Facility.
(19) The Permittee shall not use or place waste or other material in a Waste
Management Area, or any portion thereof, in which the integrity of the secondary
containment is impaired or under repair. If only a portion of the secondary
containment in a Waste Management Area is impaired or in need of repair or

coating reapplication, the Permittee may continue to use other portions of the
same Waste Management Area provided that:
(a) The secondary containment in these other portions is not impaired, or in

need of repair or coating reapplication; and
(b) Before the Permittee uses any portion of the Waste Management Area, the
Permittee shall take all the necessary measures to ensure that waste or
other material does not or cannot migrate to any portion of the Waste
Management Area where the secondary containment is impaired or is in
need of repair or coating reapplication.
(20) When the integrity of the secondary containment system of a Waste Management
Area is impaired or has been repaired or coating reapplied, the Permittee shall
record in the Operating Record for the Facility the following information, to be
kept until Final Closure of the Facility:
(a) The location of the Waste Management Area requiring repair or coating
reapplication;
(b) The type and degree of repair or reapplication needed;
(c) The method(s) of repair or reapplication;
(d) The date the need for the repair or coating reapplication was noticed;
(e) The date(s) all repair(s) were made or coating(s) reapplied; and
(f) The name, title and identity of the person who determined that the repair
or coating reapplication was sufficient to allow the Waste Management
Area or portion thereof to be used again and the date of such inspection
and any comments of the inspector regarding the repair or coating
reapplication.
(21) Before resuming use of a Waste Management Area requiring repair or

reapplication of a coating, the Permittee shall ensure that the area is free of cracks
or gaps and the area’s coating is sufficiently impervious to contain leaks and/or
spills, including inspection of the berm and base of the Waste Management
Area(s) to ensure the integrity of the coating.
Land Disposal Restrictions (LDR)
(22) The Permittee shall comply with the land disposal restrictions in 40 CFR Part 268.
As part of such compliance, the Permittee shall not mix hazardous waste that
does not meet the applicable treatment standard in 40 CFR Part 266, Subpart D,
with debris that changes the treatment classification of such waste (i.e., from
waste to hazardous debris).
(23) Except as provided in 40 CFR 268.50 (d) and (e), the Permittee shall ensure that
each container of hazardous wastes restricted from land disposal is subject to the
following restrictions:

(a) The Permittee may store land-banned hazardous wastes solely for the
purpose of the accumulation of such quantities of hazardous waste as
necessary to facilitate proper treatment, storage, or disposal; and
(b) Each on-site container of land-ban hazardous waste shall be clearly

marked to identify its contents and the date of initial accumulation.
(24) In accordance with 40 CFR 268.50(b) and (c), the storage of hazardous wastes
restricted from land disposal shall not exceed one year or three-hundred-sixty-five
(365) days from the date the hazardous waste was placed into storage at the
Facility.
Inspections
(25) The Permittee shall inspect the HWF, each Waste Management Area, and all
safety equipment, emergency response equipment, security devices and operating
and structural equipment to prevent releases and to ensure such equipment
remains in good working order for the safer operation of the Facility and
compliance with this Permit. At a minimum, the Permittee shall perform
inspections in accordance with the Inspection Plan, incorporated herein as
Attachment B to this Permit. The Permittee shall respond as soon as possible to
any problem or deficiency identified by any such inspection.
(26) The Permittee shall record inspections of each Waste Management Area in an
inspection log. This log shall include the date and time of the inspection, the
name of the inspector, company affiliation if by a company hired by the
Permittee, a notation of the observations made, and the date and nature of any
repairs or required actions. The inspection log shall be maintained in the
Operating Record for the HWF.
(27) The Permittee shall ensure that inspection records (on the forms required by the
Inspection Plan) are maintained in the Facility Operating Records for at least three
(3) years.
(28) Prior to placing any container of hazardous waste or other materials into the waste
storage management areas, the container shall be visually inspected by the
Facility technical personnel or his/her designee (e.g., material handler) to ensure
that the waste container is properly labeled. If a discrepancy if found, this
information shall be reported to an immediate supervisor or an appropriate
supervisor prior to further processing of the material. If an immediate response is
not possible, the container may be kept in the staging area on secondary
containment pending resolution of the problem.
Closure
(29) In addition, to any requirements in Section IV of this Permit, the Permittee shall
close the Facility in accordance with the Closure Plan, incorporated herein as
Attachment E or as revised of this Permit. When closing or partially closing the
Facility, the Permittee shall demonstrate that any contaminants remaining after
closure will not impact human health, or any environmental media including
ground water, surface water, sediments, soils, or air in excess of recommended
exposure limits or factors considering all potential routes of exposure. At a
minimum, the closure performance standards for each hazardous waste and other
constituent of concern shall meet the remediation standard regulations, RSCA
22a-113k-1 et seq. The Permittee shall notify the Department in writing of any
partial closure of the Facility at least forty-five days prior to the initiation of the
activity and if necessary, any Department review and/or approval of any
modifications and/or revisions to the Closure Plan.
Aisle Space
(30) At all times, the Permittee shall maintain aisle space, at a minimum, of twenty-
eight (28) inches, between the double row of containers stored in racks or pallet of
containers to allow for container inspections.
(31) The maximum stacking height of palletized containers in the permitted container
storage areas shall be limited to two tiers high. Oxidizer storage shall be limited
to only one tier high.
Traffic Control and Vehicles Idling
(32) The Permittee shall control all traffic related to the operation of the Facility in
such a way as to mitigate the queuing of vehicles and prevent excessive or unsafe
traffic impacts in the area where the Facility is located.
(33) The Permittee shall prominently post and maintain signs in appropriate areas
warning that trucks at the Facility cannot idle for more than three (3) consecutive
minutes, pursuant to RCSA Section 22a-174-18(b)(3).
Signage
(34) The Permittee shall post a sign with the legend, “Danger – Unauthorized
Personnel Keep Out,” at each entrance of the HWF, and at other locations, in
sufficient numbers to be seen from any approach to the HWF. The legend must
be written in English and in any other language predominant in the area
surrounding the HWF and shall be eligible from a distance of at least twenty-five
(25) feet. The Permittee may use signs with a legend other than “Danger” –
Unauthorized Personnel Keep Out,” to comply with this provision, provided such
posting otherwise meets the requirements of this provision and the legend on the
sign clearly indicates that only authorized personnel are allowed to enter onto the
HWF property and that entry onto the HWF property can be dangerous.
Waste Acceptance Criteria
(35) Prior to the placement of hazardous waste into a container, the Permittee shall
conduct the hazardous waste characterization, verification, and waste
compatibility evaluation and/or testing described in the WAP incorporated herein
as Attachment A, of this Permit.

(36) The Permittee shall manage all wastes whose identities cannot be verified in
accordance with the procedures in the WAP incorporated herein as Attachment A,
by placing such waste in a designated storage rack or staging area.
Organic Peroxide Storage
(37) The Permittee shall comply with the following requirements are met when
managing organic peroxides:
(a) The chemical name shall be posted on the container or unit utilized to
manage the organic peroxide;
(b) The temperature range at which the organic peroxide can be safely
managed shall be identified and posted on the container utilized to manage
the organic peroxide; and
(c) Any container containing organic peroxide wastes shall be kept in the
designated storage cabinet or a refrigerator as specified by the
manufacturer.
Oxidizers Storage
(38) The Permittee shall ensure that the following requirements are met when
managing oxidizers:
(a) Oxidizers shall only be stored in designated cabinets or refrigerators; and
(b) The chemical name shall be posted on the corresponding container or unit
utilized to manage the oxidizing material, as well as maintained them in a
well-ventilated area and kept as cool as possible to minimize any fires or
explosion hazard.
Special Requirements for ignitable and Reactive Waste
(39) In accordance with 40 CFR 264.176 and 40 CFR 270.15(c), the Permittee shall
ensure that containers holding ignitable or reactive waste are located at least 15
meters (50 feet) from the Facility’s property line.
(40) The Permittee shall take precautions to prevent accidental ignition or reaction of
ignitable waste at the HWF. This waste shall be separated and protected from
sources or ignition or reaction including, but not limited to, open flames, smoking,
cutting, and welding, hot surfaces, frictional heat, sparks (static, chemical
reactions), and radiant heat.
(41) The Permittee shall ground/bond any container, including, but not limited to, a
Transportation Vehicle, of ignitable waste or other materials stored or managed in
the HWF, at least during the addition and removal of waste or other material to
and from any such container.

(42) The Permittee shall post “No Smoking” signs in conspicuous locations where
ignitable or reactive waste are managed or stored at the HWF and confine
smoking and open flames to specially designated locations.
Commingling
(43) Prior to the bulking or other commingling of hazardous wastes and other materials
within the Waste Management Area(s), the Permittee shall assure compliance
with all applicable sections of the Waste Analysis Plan (“WAP”), incorporated
herein as Attachment A.
(44) For each bulking or other commingling of hazardous wastes and other materials
with the waste storage and management areas, the Permittee shall ensure that
prior to any bulking or other commingling taking place all necessary information
accompanies the waste and contains at a minimum the following information:
(a) The information which can be utilized to track the material being
bulked/commingled;
(b) U.S. EPA waste code(s), as applicable;
(c) Facility treatment, storage, or management area/unit to and from which the
waste is to be transferred;
(d) Quantity of material to be bulked and/or commingled; and
(e) Signature, initials, or other means of identification of the site technical
personnel who has authorized the bulking/commingling and verified waste
compatibility.
(45) The Permittee shall not mix or commingle an incompatible waste as specified in
40 CFR 264, Appendix V. In addition, the Permittee shall not place an
incompatible in a container that has not been decontaminated and that previously
held an incompatible waste, product, or other material.
(46) The Permittee shall ensure that at all times the storage of hazardous wastes from a
given hazardous waste compatibility group be separated from materials from a
different compatibility group (incompatible wastes or other materials), or
protected from them by means of dike, berm, or other device.
(47) The Permittee shall ensure that all areas used to store containerized waste comply
with all applicable National Fire Protection Association (NFPA) Guidelines and
Occupational Safety and Health (OSHA), General Industries Standards,
whichever is more stringent.
(B) CONTAINER STORAGE AREA OPERATING CONDITIONS
Condition of Containers (40 CFR 264.171)
(1) If a container or roll-off container holding waste or other material is not in good
condition (e.g., there is severe rusting, cracks, apparent structural defects or
bulging) or begins to leak, the Permittee shall immediately place the compromise
container in a salvage container that is in good condition and complies with 49

CFR Part 173, or transfer the waste or other material from such container or roll-
off to a container or roll-off that is in good condition and complies with 49 CFR
Part 173. The Permittee shall manage, including disposal, all waste generated
from a container or roll-off that is not in good condition in accordance with this
Permit and all applicable requirements.
(2) The Permittee shall ensure that no container or roll-off of waste or other material
has any superfluous waste, liquids, sludges, or solids on the exterior of such
container. This does not include dried paint or similar material and dirt/dust.
Compatibility of Waste with Containers (40 CFR 264.172)
(3) The Permittee shall ensure that each container or roll-off container with waste or
other material at the HWF is made of or lined with materials that will not react
with and are otherwise compatible with the waste or other materials so as not to
impair the ability of such container to contain such waste or other materials. The
Permittee shall ensure that only containers or roll-offs that have been approved by
the U.S. Department of Transportation (DOT) for use with a given waste or other
material are brought to or used at the HWF Waste Management Area(s).
Management of Containers (40 CFR 264.173)
(4) (a) The Permittee shall ensure that all containers holding wastes stored or
managed at the Facility are not opened, handled, managed, or stored in a
manner that may rupture the container or cause it to leak.
(b) The Permittee shall ensure that all containers holding hazardous waste are
always closed during storage, except when it is necessary to add or
remove waste or in an emergency where it may be necessary to repackage
the waste from one container to another.
Inspections (40 CFR 264.174)
(5) The Permittee shall inspect, at least weekly, the container Waste Management
Area in accordance with the Inspection Plan, incorporated herein as Attachment B
and shall perform inspections as required by 40 CFR 264.174. At a minimum, the
Permittee shall inspect for (a) leaking containers; (b) deterioration of containers;
and (c) deterioration of containment system caused by corrosion or other factors.
(6) The Permittee shall visually inspect each container prior to offering for
transportation to ensure that each container is packaged and marked as required
by 40 CFR 262.30 (Packaging – DOT Requirement), and 262.32 (Marking –
“Hazardous Waste” or other designation for non-hazardous waste, with a generic
description of the waste , and other relevant information), as applicable.
Containment (40 CFR 264.175, as modified by 22a-449(c)-104(a)(2))

(7) The Permittee shall ensure that the container storage management area has the
secondary containment capacity for the volume specified in Section II, Permitted
Activities of this Permit.
(8) The Permittee shall ensure that the containment system for the container storage
management area is maintained and operated as follows:
(a) The base of the container storage management area shall be free of cracks or
gaps and be sufficiently impervious so as to contain leaks, any spills until
the collected material is detected and removed; and
(b) The base of the containment systems shall be pitched to capture liquids
resulting from leaks or spills.
(9) The Permittee shall ensure that the strength and thickness of the secondary
containment is sufficient to prevent failure owing to pressure gradients, physical
contact with the waste, climatic conditions, and the stress of daily operation.
Waste Incompatibility (40 CFR 264.177)
(10) The Permittee shall not place incompatible hazardous wastes, or hazardous wastes
and other incompatible materials in the same container; and shall not place
hazardous waste in an unwashed container that previously held an incompatible
hazardous waste or other material unless the Permittee is in compliance with the
Waste Analysis Plan, incorporated herein as Attachment A of this Permit.
Closure (40 CFR 264.178)
(11) The Permittee shall ensure that at the time of closure of the Container Waste
Management Area, all hazardous waste residues are removed from the
containment system. In addition, any remaining containers, liners, bases, and soil
containing or contaminated with hazardous waste or hazardous waste residues are
decontaminated or removed in accordance with the Closure Plan, incorporated
herein as Attachment E, of this Permit.
Air Emissions Standards, Subpart CC (40 CFR 264.179)
(12) The Permittee shall manage all hazardous waste placed in containers in
accordance with the applicable Air Emission requirements specified in 40 CFR
264, Subpart CC. At a minimum, the Permittee shall comply with 40 CFR
264.1086 (containers); 264.1088 (Inspection and Monitoring Requirements);
264.1089 (Record keeping Requirements); and 264.1090 (Reporting
Requirements).
(13) The Permittee shall ensure that all the containers in the container Management
Area meet the U.S. Department of Transportation (DOT) regulations specified in
49 CFR 173 and 178.

(14) The Permittee shall ensure that all the containers holding hazardous waste are
equipped with a cover and closure devices that form a continuous barrier over the
container openings such that when the cover and closure devices are secured in
the closed position there are no visible holes, gaps, or other open spaces into the
interior of the container.
(15) RCRA empty containers, as defined in 40 CFR 261.7, are exempt from complying
with Air Emission requirements.
(16) The Permittee shall maintain the records specified by 40 CFR 264.1089(b) and
(e), in the Operating Record for the Facility for at least three (3) years.
(C) NON-HAZARDOUS WASTE TANKS STORAGE OPERATING CONDITIONS
(1) The Permittee shall not place any waste in Tank 121A or Tank 121B that could
cause the tank, their ancillary equipment, or the containment system to rupture,
leak, or otherwise fail.
(2) The Permittee shall use appropriate controls and practices to prevent spills and
overflows from Tank 121A and Tank 121B or the containment systems. These
shall include at a minimum:
(a) Spill prevention controls (e.g., check valves, dry disconnect couplings); and
(b) Overfill prevention controls (e.g., level sensing devices, high level alarms,
automatic feed cutoff).
Tank Inspections
(3) The Permittee shall conduct daily inspections of Tank 121A and the Tank 121B in
accordance with the Inspection Plan or revised Inspection Plan presented as
Attachment B, at a minimum it shall include the following:
(a) Procedures for inspecting overfill controls (high level alarms, automatic-
waste feed cut-off, and all other overfill/spill control equipment associated
with each tank system to ensure that it is in good working order);
(b) Above ground portions of the tank system to detect corrosion or releases
of waste; (all piping, including flanges, joints, valves, and other
connections, sealless or magnetic coupling pumps, flow metering devices
associated with each tank system to ensure that it is in good working
order);
(4) The Permittee shall document in the operating record for the Facility an
inspection of, at a minimum, those items in Section III (C) (3) above for the life of
this Permit.

Response to Tank Leaks or Spills
(5) The Permittee shall immediately remove from service any tank system or
secondary containment from which there has been a leak or spill, or which is
otherwise unfit for use (i.e., no longer satisfies the approved design or operational
requirements). The Permittee shall comply with the following requirements:
(a) Cessation of use of such tank systems, preventing flow or addition of

wastes to such tanks systems. The Permittee shall immediately stop the
flow of hazardous waste into the tank systems or secondary containment
systems and inspect such tank systems to determine the cause of the
release;
(b) Containment of visible releases to the environment. The Permittee shall

immediately conduct a visual inspection of the release and based upon that
inspection:
(i) Take all measures necessary to prevent further migration of the

leak or spill to other portions of the facility or to the environment;
and
(ii) Remove, and properly dispose of, all released waste and any
visible contamination.
Closure and Post-Closure
(6) The Permittee shall close the tank systems in accordance with the Closure Plan
incorporated herein as Attachment E or as revised. At a minimum, at the time of
closure of a tank system, the Permittee shall remove all waste residues,
contaminated containment system components, contaminated structures, and
equipment contaminated with waste.
(D) LOADING AND UNLOADING AREAS
(1) The Permittee shall not allow containers of waste to remain at the Loading and
Unloading Areas for more than twenty-four (24) hours.
(2) The Permittee shall inspect the Loading and Unloading Areas in accordance with
the Inspection Plan, incorporated herein as Attachment B, of this Permit.
(3) The Permittee shall not load or unload containerized waste on bare soil or other
unprotected or uncoated surfaces.
(E) STAGING AREA
(1) The Permittee shall ensure that all the containerized waste on the staging area is
compatible with each other. The Staging Area compatibility determination shall
be in accordance with the requirements of 49 CFR Part 177.848(e), Hazardous
Materials Load and Segregation Chart.
(2) The Permittee shall not allow any containers of waste to remain at the staging area
for more than five (5) days.
(3) The Permittee shall ensure that any leaking container in the staging area is
immediately over packed in a salvage drum and/or that the contents are
immediately transferred to another container.
(4) The Permittee shall ensure that the stacking of containers containing waste in the
staging area other than containers of less than five (5) gallon capacity shall be
limited to not greater than one (1) tier.
(5) The Permittee shall maintain a drum cart or a forklift truck in the Facility to allow
for quick transfer or movement of containers in the event of an emergency.
(6) The Permittee shall maintain at the staging area a minimum aisle space of twenty-
eight (28) inches between rows of containers to allow for inspection of containers
or mitigation of spills or leaks.
(7) The Permittee shall inspect the staging area whenever in use in accordance with
the Inspection Plan or revised Inspection Plan, incorporated herein as Attachment
B, of this Permit.
(F) COMPACTOR UNIT
(1) The Permittee shall operate the compactor unit in accordance with the Standard
Operating Procedures (SOP) and the conditions stipulated in this Permit.
(2) The Permittee shall remove the container utilized to accumulate compacted waste
from the compactor unit area once such a container reaches its full capacity. The
container shall be stored in a designated container storage area of the Facility.
(3) The Permittee shall maintain the compactor unit container closed at all times
except when adding or removing waste.
(4) The Permittee shall inspect the compactor unit in accordance with Inspection Plan
or revised Inspection Plan, incorporated herein as Attachment B, of this Permit.
(5) The Permittee may replace the compactor unit during the life of this Permit by
providing written notification to the Department of such replacement. The
replacement shall be an equivalent or newer compactor model equipped with high
air emissions control efficiency.
(G) J-LOT AREA ACTIVITIES
The Permittee shall ensure that the following activities in this designated area are
inspected in accordance with the Inspection Plan, incorporated herein as Attachment B.

(1) Accumulation and storage of spent non-flammable compressed gas cylinders

containing refrigerants in a locked cage. The cylinders size accumulated in the
locked cage may range between 20 pounds to 125 pounds.
(2) Storage of virgin product on racks.
(3) Storage of non-RCRA wastes in roll-off containers. The Permittee shall ensure
that:
(a) Non-RCRA hazardous wastes stored in roll-off containers contain no free

draining liquids except for trap liquids incidental to waste settling.
(b) Any roll-off container containing waste shall remain covered at all times
when not in use.
(c) Roll-off containers are located on a base that has sufficient structural
strength to withstand the weight of the roll-off and its contents.

Section IV Hamilton Sundstrand Corp.
General Facility Conditions EPA ID No. CTD001145341
SECTION IV
GENERAL FACILITY CONDITIONS

ONE HAMILTON ROAD

File:20210622 HS SECTION 4 Renewal cph 719.doc Page IV- 1

SECTION IV
TABLE OF CONTENTS
GENERAL CONDITIONS
SECTION TITLE PAGE
(A) Imminent Hazard Actions . . . . . . IV-3

(B) Required Transfer Notice . . . . . . IV-3
(C) Waste Analysis . . . . . . . IV-3
(D) Security . . . . . . . . IV-4
(E) General Inspection Requirements . . . . . IV-4
(F) Personnel Training . . . . . . . IV-5
(G) Special Requirements for Ignitable, Reactive or
Incompatible Wastes and/or Other Co-Stored Materials . . IV-6
(H) Preparedness and Prevention . . . . . . IV-8
(I) Contingency Plan . . . . . . . IV-10
(J) Manifest System . . . . . . . IV-14
(K) Operating Record . . . . . . IV-14
(L) Availability, Retention and Disposition of Records . . . IV-15
(M) Biennial Report . . . . . . . IV-16
(N) Closure . . . . . . . . IV-16
(O) RCRA Corrective Action Requirements . . . . IV-20
(P) Financial Requirements . . . . . IV-21
(Q) Air Emission Requirements, Subpart CC . . . . IV-22
(R) Universal Wastes . . . . . . . IV-23
(S) Used Oil . . . . . . . . IV-23
(T) Applicable Laws . . . . . . IV-23
(U) Location Standards . . . . . . . IV-23

SECTION IV
GENERAL FACILITY CONDITONS
(A) IMMINENT HAZARD ACTIONS. Notwithstanding any provision of this Permit,

enforcement actions may be brought pursuant to Section 7003 of Resource Conservation
Recovery Act (RCRA), Section 22a-6 of the Connecticut General Statutes (“CGS”), or
any other applicable law.
(B) REQUIRED TRANSFER NOTICE. In addition to complying with the requirements of

Section I (E) (12), before transferring ownership or operation of the Facility during the
operating life, the Permittee shall notify the new owner or operator in writing of the
requirements of this Permit, Title 40 CFR Parts 264 and 270, and of the Regulations of
Connecticut State Agencies (RCSA) Sections 22a-449(c)-100 et. Seq. The Permittee
shall provide such new owner or operator with a copy of this Permit.
The Permittee’s failure to notify the new Permittee of the requirements of this Permit in
no way relieves the new Permittee of his obligations to comply with all applicable
requirements.
(C) WASTE ANALYSIS
(1) The Permittee shall follow the procedures described in the Waste Analysis Plan,
incorporated herein as Attachment A. Such a Waste Analysis Plan, at a minimum,
shall comply with the requirements of 40 CFR 264.13.
(2) The Permittee shall maintain, at all times, a copy of the up-to-date Waste Analysis
Plan at the Facility. A copy of any revisions made to the Waste Analysis Plan
shall be kept in the Facility’s Operating Record.
(3) The Permittee shall maintain waste data/profile sheets, and copies of all records,
documents or other information required to demonstrate compliance with the
Waste Analysis Plan in the Facility’s operating record. This specifically includes,
but it is not limited to:
(a) Waste characterization, verification and analysis of each hazardous waste

stream stored at the Facility as required by the Waste Analysis Plan, and
(b) Compatibility analysis as required by the Waste Analysis Plan.
(4) The Permittee shall, at all times, have available for inspection and review by the
Department or EPA copies of all records, forms, procedural documents, manuals,
etc., used to achieve compliance with the Waste Analysis Plan.
(5) Unless otherwise specified in the Waste Analysis Plan, all hazardous waste
characterization and analytical work performed in accordance with the Facility
Waste Analysis Plan shall be as specified in the EPA document SW-846, “Test
Methods for Evaluating Solid Waste, Physical/Chemical Methods,” latest edition.

(D) SECURITY
(1) The Permittee shall prevent the unknowing entry and minimize the possibility for
the unauthorized entry of persons or livestock onto the active portion of the
Facility.
(2) The Permittee shall ensure that the main entrance to the Waste Management Area
is locked at all times unless authorized personnel are present.
(3) The Permittee shall ensure that the warning signs bearing the legend “Danger –
Unauthorized Personnel Keep Out” shall remain posted in sufficient numbers to
be seen from any approach to the Waste Management Area(s). The signs shall be
written in English and shall be legible from a distance of at least of twenty-five
(25) feet.
(4) The Permittee shall maintain all security equipment systems in good repair at all
times until final closure of the Facility.
(E) GENERAL INSPECTION REQUIREMENTS
In addition to any other inspection, requirements specified elsewhere in this Permit, the
Permittee shall:
(1) Perform inspections of the Facility in accordance with the Facility Inspection
Schedule incorporated herein as Attachment B. The Permittee shall maintain the
Inspection Plan approved by the Commissioner at the Facility at all times.
(2) Inspect the Facility for malfunctions and deteriorations, operator errors, and
discharges, which may be causing or may lead to:
(a) Releases of hazardous waste constituents to the environment, and
(b) A threat to human health or the environment.
(3) Remedy any deterioration or malfunction of equipment or structure, which the

inspection reveals on a schedule that the problem does not lead to an
environmental or human health hazard. Where a hazard is imminent or has
already occurred, remedial action shall be taken immediately.
(4) Ensure that records of inspections are maintained at the Facility at all times, and
contain such information and be on such forms as prescribed by the Facility
Inspection Schedule, incorporated herein as Attachment B. The Permittee shall
maintain the records pertaining to inspections, remedial actions and repairs
resulting from such inspections for at least three (3) years from the date of
inspection.

(F) PERSONNEL TRAINING
(1) The Permittee shall conduct personnel training as required by 40 CFR 264.16.
This training shall comply with the requirements of 40 CFR 264.16(d) (3) and
shall include training in all of the elements outlined in the Personnel Training
Plan, incorporated herein as Attachment C. The Permittee shall train all Facility
Personnel so as to ensure that the performance of their duties ensures that the
Facility remains in compliance with this Permit. The Permittee shall maintain a
copy of the Personnel Training Plan and all records demonstrating compliance
with the training requirements of this Permit at the Facility at all times.
(2) The Permittee shall ensure that the Personnel Training provided to employees at
the Facility includes, but is not limited to, the following, if relevant to an
employee’s position:
(a) Implementation of the Facility Contingency Plan;

(b) The activities authorized and prohibited by this Permit;
(c) The waste prohibitions contained in Section II of this Permit;
(d) The communications or alarm systems at the Facility;
(e) Sampling methods and sample handling procedures required to comply
with the terms of this Permit;
(f) The requirements of the Waste Analysis Plan (Attachment A);
(g) The hazards associated with and the safe handling practices for all of the
wastes or other materials authorized to be managed at the Facility;
(h) The selection and use of proper personnel protection equipment and
emergency equipment;
(i) The marking and labeling requirements of this Permit;
(j) Subpart CC (RCRA Air Emission Requirements);
(k) Emergency response procedures, including but not limited to, routes of
exposures associated with any release, relevant technical information
regarding any waste or other material authorized to be managed at the
Waste Management Area(s) of the Facility and the requirements specified
in 40 CFR 264.16(a)(3);
(l) The requirements regarding the use of manifests, bill of lading or other
required shipping papers;
(m) The requirements regarding the management of wastes and other materials
relevant to each employee’s position; and
(n) On the job training and instruction given to Facility personnel regarding
the safe handling and the management procedures of authorized wastes
and other materials managed at the Facility that are relevant to each job
position.
(3) The Permittee shall ensure that the facility personnel successfully complete the
requirements for Personnel Training and the training requirements of this Permit
no later than six (6) calendar months after the effective date of their employment
or before any assignment to a new Waste Management Area(s) or a new position
in the Facility. The Permittee shall ensure that no untrained employees handle,
manage, or become involved in managing waste and other materials authorized by

this Permit. Employees shall not work in unsupervised positions until they have
completed the training requirements of this Permit.
(4) The Permittee shall ensure that all Facility personnel receive and successfully
complete an annual review of the Personnel Training within 365 days of the date
that any such personnel received initial training or the previous year’s annual
review of the training program.
(5) The Permittee shall maintain the following documents and/or records in the
Facility Operating Record:
(a) The job title for each position at the Facility related to hazardous waste
management and the name of the employee filling each job;
(b) A written job description for each position listed under paragraph
IV(F)(5)(a). This description shall be consistent with descriptions for
other similar positions at the Facility but must include the requisite skill,
education or other qualifications, and duties of employees assigned to each
position;
(c) A written description of the type and duration of both introductory and
continuing training that will be given to each person filling a position
listed under Section IV (F)(5)(a) of this Permit; and
(d) Records that documenting that the training or job experience required by
40 CFR 264.16(a), (b), and (c) and as specified in the Personnel Training
Plan, incorporated herein as Attachment C, has been given to, and
completed by, Facility personnel or other qualified personnel.
(6) The Permittee shall keep training records on current personnel until Final Closure
of the Facility. Training records on former employees shall be kept for at least
three (3) years from the date the employee last worked at the Facility. Personnel
training records may accompany personnel transferred within the same company.
(7) The Permittee shall ensure that anyone providing training to Facility personnel
shall be trained in hazardous waste management procedures or other relevant
procedures and be thoroughly familiar with the requirements of this Permit. The
Permittee shall also ensure that any training provided to Facility personnel
includes instructions which teaches Facility personnel waste management
procedures relevant to the positions in which they are employed.
(G) SPECIAL REQUIREMENTS FOR IGNITABLE, REACTIVE, OR

INCOMPATIBLE WASTES AND/OR OTHER CO-STORED MATERIALS. The
following requirements are in addition to any other requirements specified in this Permit
regarding ignitable, reactive, or incompatible wastes and/or other co-stored materials.

(1) The Permittee shall prevent accidental ignition or reaction of ignitable or reactive
waste or other materials at the Facility. At a minimum, the Permittee shall ensure
that:
(a) Any waste or other material is separated and protected from all sources of
ignition or reaction, including but not be limited to: open flames, smoking,
cutting, welding, hot surfaces, frictional heat, sparks (static, electrical, or
mechanical), spontaneous ignition (e.g., from heat-producing chemical
reactions), radiant heat, and any other condition that could cause the waste
or other material to ignite.
(b) All cutting, welding or other operations involving open flames performed
within the proximity of any ignitable waste has been approved in advance
in writing by the designated safety personnel or under the direct
supervision of the Facility’s Emergency Coordinator or Alternate
Emergency Coordinator (designee). Written approval shall be maintained
at the location of the activity during the entire time the activity is taking
place.
(c) No smoking shall be allowed in any Waste Management Area where

ignitable or reactive waste or other material is being stored, handled, or
otherwise managed.
For purposes of this subsection, the term “ignitable waste” shall be defined as
any substance or material exhibiting the characteristics of ignitability as described
in 40 CFR 261.21.
(2) The Permittee shall prevent reactions which:
(a) Generate extreme heat or pressure, fire or explosions, or violent reactions;
(b) Produce uncontrolled toxic mists, dusts, fumes, or gases capable of

threatening human health or the environment;
(c) Produce uncontrolled flammable fumes or gases capable of posing a risk

of fire or explosion;
(d) Damage the structural integrity of any Waste Management Area,

container, tank or any emergency equipment; or
(e) Through other like means, threaten human health or the environment.
(3) The Permittee shall ensure no smoking or open flames occur wherever there is a
hazard from ignitable or reactive wastes or other materials. The Permittee shall
prominently display and maintain a "No Smoking" sign(s) in each such area.
Each “No Smoking” sign shall be legible from a distance of twenty-five (25) feet.

(4) The Permittee shall ensure that containers holding ignitable or reactive wastes or
other materials are located at least 15 meters (50 feet) from the Facility property
line.
(H) PREPAREDNESS AND PREVENTION
(1) Operation of Facility (40 CFR 264.31). The Permittee shall maintain and operate
the Waste Management Area so as to prevent fire, explosion, or any unplanned,
sudden or non-sudden, release of waste or waste constituent(s) thereof or other
materials to or from any Waste Management Area to air, soil, surface water or
ground water.
(2) Required Equipment (40 CFR 264.32). The Permittee shall ensure that the
emergency equipment specified in the Contingency Plan, incorporated herein as
Attachment D, is available at all times. The Permittee shall locate all of the
emergency equipment as shown or described in the Facility Contingency Plan.
The Permittee shall, at a minimum, have at the Facility:
(a) An internal communications or alarm system;

(b) A device, such as a telephone, capable of summoning emergency
assistance from local emergency response teams;
(c) Portable fire extinguishers, fire control equipment, spill control and
decontamination equipment; and
(d) Water at adequate volume and pressure to supply water hose streams, or
foam producing equipment.
(3) Testing and Maintenance of Equipment (40 CFR 264.33). The Permittee shall
test and maintain all safety equipment as necessary and in accordance with the
manufacturer’s recommendation but at least annually to ensure its proper
operation in case of an emergency. The Permittee shall ensure that the Waste
Management Area(s) communications systems, alarm systems, fire protection
equipment, emergency equipment, spill control equipment, and decontamination
equipment are immediately accessible and operate properly at all times. The
Permittee shall inspect and test such equipment in accordance with all applicable
laws, regulations, ordinances, and the Facility Inspection Plan, incorporated
herein as Attachment B. The Permittee shall maintain in the Operating Record for
the Facility written records indicating the date and time of each inspection, the
name of the inspector, the results of the testing of the equipment noted in this
paragraph, any action(s) taken in response to such testing and the date and nature
of any necessary corrective measures.
(4) Access to Communications or Alarm System (40 CFR 264.34). The Permittee
shall ensure that whenever waste or other material is being moved, sampled,
poured, emptied, pumped or otherwise handled at the Waste Management Area(s)
all personnel involved have immediate access to an internal alarm or emergency
communication device, either directly or through visual or verbal communication
with other facility personnel. In the event that only one employee is engaged in
activities identified in this paragraph, the Permittee shall ensure that the employee
has immediate access to a device, such as a telephone (immediately available at
the scene of operation) or a hand-held two-way radio, capable of summoning
external emergency assistance.
(5) Required Aisle Space (40 CFR 264.35). The Permittee shall maintain aisle space
width in the Waste Management Area(s) to allow the unobstructed movement of
personnel, fire protection equipment, spill control equipment and decontamination
equipment in case of an emergency.
(6) Arrangements with Local Authorities (40 CFR 264.37)
(a) Whenever any changes occur in the Facility layout or operation, or in the
Facility Contingency Plan itself, which materially affects implementation
or execution of such, the Permittee shall, within fifteen (15) calendar days
of the approval of a modification to this Permit or within fifteen (15)
calendar days of such change if no permit modification is needed, send in
an electronic format or by certified mail, return receipt requested, to
police, fire departments, hospitals and emergency response teams in the
vicinity of the Facility, including but not limited to those listed below, the
revisions to the Contingency Plan. At a minimum, the Permittee shall
notify the following entities:
(i) St. Francis Hospital, Hartford, Connecticut

(ii) Bay State Medical Center, Springfield, Massachusetts
(iii) Windsor Locks Fire Department
(iv) Windsor Locks Police Department
(v) Clean Harbors, Emergency Response Services
(vi) Tradebe Environmental Services, Emergency Response Contractor
(vii) Windsor Locks Local Emergency Planning Committee
(b) The Permittee shall ensure that each entity under contract with the
Permittee to provide emergency response services at the facility has a
permit, issued by the Commissioner pursuant to Section 22a-454 of the
CGS, authorizing such entity to provide emergency response services.
(c) The Permittee shall invite the police department; fire department,
hospital(s) and governmental emergency response teams listed in Section
IV (H) (6) (a) of this Permit to visit the Facility and shall attempt to make
arrangements to enable each such entity to respond in the event of an
emergency at the Facility. At a minimum, the Permittee shall provide
each such entity with information regarding the layout, alarm systems and
emergency equipment at the Facility, the wastes and other materials which
are or may be at the Facility and the health and environmental hazards
associated with all such wastes and other materials, places where Facility
personnel may be located, entrances to and exits from the Facility,
evacuation routes, and the contacts for all persons or entities who might
provide emergency response services to the Facility. The Permittee shall

maintain in the Operating Record for the Facility records demonstrating
compliance with the requirements specified in this condition, including
any records it receives in response to actions under this condition.
(I) CONTINGENCY PLAN
(1) The Permittee shall ensure that the provisions of the Facility Contingency Plan,
incorporated herein as Attachment D, are carried out and shall follow the
emergency procedures described below, whenever there is an emergency event
such as a fire, explosion, or release of waste or waste constituent(s) thereof or
other materials or constituent(s) thereof which threaten human health or the
environment. The Permittee shall provide in an electronic format emergency
planning information to the local Emergency Response Teams that may respond
to an emergency at the Facility.
(2) Content of the Contingency Plan. The Permittee shall maintain at all times at the
Facility, a Contingency Plan which has been approved by the Commissioner,
which describes the actions the Facility personnel shall take in response to an
emergency event which threatens or may potentially threaten human health or the
environment. At a minimum the Plan shall include:
(a) A description of arrangements agreed to by the Police Department, Fire

Department, hospital(s), the Permittee’s emergency response contractors
and, as applicable, federal, state, and local emergency response teams to
coordinate emergency services pursuant to 40 CFR 264.37;
(b) An up-to-date list of the names, addresses, and telephone numbers (office,
home and cellular as applicable) of all persons qualified to act as
emergency coordinators. Where more than one person is listed, one shall
be identified as the primary emergency coordinator and others shall be
listed in the order in which they shall assume responsibility as alternates;
(c) Specify a 24-hour contact information for the designated Emergency

Coordinator to be used by the Local responders in case of an emergency;
(d) An up-to-date list of the emergency equipment at the Facility (such as fire
extinguishing systems, spill control equipment, communications, and
alarm systems (internal and external) and decontamination equipment). In
addition, the plan shall include the location, number, and a physical
description of each item on the list, and a brief outline of the capability of
each piece of emergency equipment;
(e) An evacuation plan for Facility personnel that describes the signal(s) to be
used to initiate an evacuation, evacuation routes, and alternate evacuation
routes (in cases where the primary routes could be blocked by releases of
waste, fire, or explosion);
(f) A protocol for determining who will make decisions and remain in charge
when responding to an emergency at the site; and
(g) An up-to-date inventory of all wastes and other materials on-site. This
inventory shall identify the wastes and other materials in each Waste
Management Area.
(3) Copies of the Contingency Plan. The Permittee shall maintain the most recent
version of the Contingency Plan, incorporated herein as Attachment D, as
approved by the Commissioner at the Facility at all times. The Emergency
Coordinator, alternate Emergency Coordinator(s), and any other personnel
responsible with the implementation of the Contingency Plan shall receive copies
of the Contingency Plan and all updates to the Contingency Plan and shall be
briefed on the implications of any such changes.
(4) Amendment of the Contingency Plan.
(a) The Permittee shall immediately amend the Contingency Plan in

accordance with the permit modifications procedures specified in Section I
(E) (6) of this Permit whenever:
(i) The Contingency Plan fails in an emergency;

(ii) The Facility changes in its design, construction, operation,
maintenance, or changes the response measures that must be taken
in an emergency;
(iii) A modification to the list of emergency coordinator(s) is
necessary; or
(iv) A modification to the list of emergency equipment is necessary.
(b) The Contingency Plan changes specified in Section IV (I) (4)(a) of this
Permit are mandatory; however, the Permittee may submit to the
Department, in writing, a request to make any other changes to the
Contingency Plan. These requested modifications should be submitted
with an application, accompanied by the appropriate fee, for a permit
modification.
(c) The Permittee shall provide notification, as required in Section IV (H) (6)
of this Permit, regarding any changes in the Contingency Plan.
(5) Emergency Coordinator. In accordance with 40 CFR 264.55, the Permittee shall
ensure that at all times there shall be at least one employee either at the Facility or
on-call (i.e., available to respond to an emergency event by reaching the Facility
within a short period of time), with the responsibility for coordinating all
emergency responses measures. This Emergency Coordinator or Alternate
Emergency Coordinator shall be thoroughly familiar with all aspects of the
Facility's Contingency Plan, all operations and activities at the Facility, the
location and characteristics of waste handled the location of all records within the
Facility, and the Facility layout. In addition, the Emergency Coordinator shall
have the authority to commit the resources needed to implement the Contingency
Plan. The Emergency Coordinator or his designee shall have available on a 24
hour-a-day, 7 day-a-week basis up-to-date waste characterization data and/or
shipping papers.
(6) Emergency Procedures.
(a) Whenever there is an imminent or actual emergency event, the Emergency

Coordinator or Alternate Emergency Coordinator shall immediately:
(i) Activate internal Facility alarms or communication systems, where

applicable, to notify all Facility personnel; and
(ii) Notify appropriate state or local agencies and/or private emergency

response providers with designated response roles.
(b) Whenever there is an emergency event (release, fire, or explosion), the

Emergency Coordinator or Alternate Emergency Coordinator shall
immediately identify the character, location, source, amount and extent of
any waste, other material, or any constituent(s) thereof, which have been
or may have been released. The Emergency Coordinator or Alternate
Emergency Coordinator may do this by observation, review of Facility
records and, if necessary, by chemical analysis.
(c) Concurrently, the Emergency Coordinator or Alternate Emergency

Coordinator shall assess possible hazards to human health or the
environment that may result from the emergency. This assessment shall
consider both direct and indirect effects of the emergency (e.g., the effects
of any toxic, irritating, or asphyxiating gases that are generated, or the
effects of any hazardous surface water run-off from water or chemical
agents used to control fire and heat-induced explosions).
(d) If the Emergency Coordinator or Alternate Emergency Coordinator

determines that the Facility has had an emergency that threatens or may
potentially threaten human health or the environment, the Permittee shall
report his findings as follows:
(i) If the Emergency Coordinator’s assessment indicates that

evacuation of local areas may be advisable, the Permittee shall
immediately notify local and state authorities. The Emergency
Coordinator or Alternate Emergency Coordinator shall be available
to assist local and state officials and decide whether local areas
should be evacuated;

(ii) The Permittee shall immediately notify the Commissioner using

the 24-hour emergency response and spill prevention number (860)
424-3338, or a toll free number 1-866-337-7745 or such other
number that may be specified by the Commissioner, and provide
orally to the Commissioner the information in Section IV (I)
(6)(d)(iii) of this Permit; and
(iii) As required by federal law, the Permittee shall notify either the
government official designated as the on-scene coordinator for that
geographical area, (in the applicable regional Contingency Plan
under 40 CFR Part 1510) or the National Response Center using
their 24-hour toll free number 1-(800) 424-8802. The notification
shall include:
(1) Name and telephone number of the reporter;

(2) Name and address of the Facility;
(3) Time and type of incident (e.g., release, fire, explosion);
(4) Name and quantity of waste(s) or constituent(s) thereof
involved, to the extent known;
(5) The extent of injuries, if any; and
(6) The possible hazards to human health or the environment.
(e) During an emergency, the Emergency Coordinator or Alternate

Emergency Coordinator shall take all reasonable measures to ensure that
fires, explosions, and releases do not occur, re-occur, or spread. These
measures shall include stopping operations, collecting, and containing any
released wastes, other materials, or any constituent(s) thereof and
removing or isolating containers or vehicles.
(f) If operations are suspended in response to an emergency, the Emergency

Coordinator or Alternate Emergency Coordinator shall monitor for leaks,
pressure build up, gas generation, or ruptures in valves, pipes, containers,
or other equipment, where and when appropriate.
(g) Immediately after an emergency event, the Emergency Coordinator or

Alternate Emergency Coordinator shall provide the assistance necessary to
the emergency responders for recovering and either storing or disposing of
recovered waste, other materials or any constituent(s) including
contaminated soil, surface water or any other material that results from a
release, fire, or explosion at the Waste Management Area(s).
(h) The Emergency Coordinator or Alternate Emergency Coordinator shall

ensure that, in the affected area(s) of the Facility:
(1) No waste that may be incompatible with any recovered waste or

contaminated soil, surface water or any other material that results
from a release is stored or disposed of until cleanup procedures are
completed; and
(2) All emergency equipment listed in the Contingency Plan is cleaned

and fit for its intended use before operations are resumed.
(i) The Permittee shall notify the Commissioner as well as state and local
authorities that the Facility is in compliance with Section IV (I) (6)(h) of
this Permit, before resuming any operations in the Waste Management
Areas at the Facility.
(j) The Permittee shall note in the Operating Record the time, date and details
of any incident that requires implementing the Contingency Plan. Within
fifteen (15) calendar days after the incident, the Permittee shall submit a
written report on the incident to the Commissioner. The report shall
include:
(1) Name, address, and telephone number of the Permittee;

(2) Name, addresses, and telephone number of the Facility;
(3) Date, time, and type of incident (e.g., fire, explosion);
(4) Description of the emergency event and its cause;
(5) Name and quantity of waste or constituent(s) thereof involved;
(6) The extent of injuries, if any;
(7) An assessment of actual or potential hazards to human health or
the environment, where this is applicable;
(8) Estimated quantity and disposition of recovered material that
resulted from the incident and all response actions taken or to be
taken;
(9) All corrective measures taken or to be taken in response to the
incident; and
(10) All corrective measures taken or to be taken to ensure that the
incident does not happen again.
(J) MANIFEST SYSTEM (40 CFR 264.73). Whenever a shipment of hazardous waste is
initiated from the Facility, the Permittee shall comply with the applicable requirements of
Sections of 22a-449(c)-100 through 119 and 22a-449(c)-11 of the RCSA, the
requirements of 40 CFR 262, and the applicable sections of 40 CFR 264 Subpart E,
regarding hazardous waste manifests.
(K) OPERATING RECORD (40 CFR 264.73). The Permittee shall maintain, in writing or
in an electronic record that can be easily accessed or reproduced upon request by the
Commissioner, the following information in the Facility’s Operating Record until Final
Closure of the Facility:
(1) A record of the wastes and other materials received into the Waste Management
Area(s) including the dates such wastes or other materials were received, the
quantities and the dates such wastes and other materials were removed from the
Waste Management Area(s);
(2) Records and/or results of waste analyses performed as specified in the Waste
Analysis Plan, and 40 CFR 264.13, 268.4(a) and 40 CFR 268.7;
(3) Summary reports and details of all incidents that require implementing the
Contingency Plan, as specified in paragraph IV (I)(6)(j) of this Permit;
(4) Records and results of inspections as required by this Permit and the Inspection
Schedule Plan, incorporated as Attachment B. The records and results of such
inspections shall be kept for three (3) years from the date of any such inspection;
(5) Monitoring, testing or analytical data, and corrective action where required by 40
CFR Part 264 Subpart F or any regulatory section noted in 40 CFR 264.73(b)(6);
(6) The latest closure cost estimate prepared in accordance with 40 CFR 264.142(a)
and (c) and, when this estimate has been adjusted in accordance with 264.142(b),
the latest adjusted closure cost estimate;
(7) A certification by the Permittee that it has a program in place (i.e., in accordance
with the biennial hazardous waste report requirement) to reduce the volume and
toxicity of hazardous waste to the degree determined by the Permittee to be
economically practicable; and that the proposed method of treatment, storage or
disposal currently available to the Permittee which minimizes any threat to human
health and the environment;
(8) A copy of all notices or certifications, the information contained in the notice
(except the manifest number) and the certification and demonstration, if
applicable, required by 40 CFR 268.7; and/or 40 CFR 268.8 prior to shipping any
waste to an off-site permitted facility; and
(9) Any other information required by this Permit or by any applicable law to be
maintained in the Facility Operating Record (i.e., copies of biennial report).
(L) AVAILABILITY, RETENTION, AND DISPOSITION OF RECORDS
(1) The Permittee shall ensure that all records required under Sections 22a-449(c)-
100 to 119 of the RCSA, and this Permit, including all plans, are furnished upon
request, and made available at all reasonable times for inspection to any officer,
employee, or representative of the Department of Energy and Environmental
Protection (DEEP) or EPA.
(2) The retention period for all records required under Sections 22a-449(c)-100 to119
of the RCSA and this Permit shall automatically be extended during the course of
any unresolved enforcement action regarding the Facility until such enforcement
action is fully resolved or for any reasonable period of time as may be requested
by the Commissioner. Any exemption from this requirement shall require the
written approval of the Commissioner.
(M) BIENNIAL REPORT. The Permittee shall prepare and submit a biennial report to the
Commissioner by March 1st of each even numbered year regarding waste activities at the
Facility for the previous calendar year on a form prescribed by the Commissioner. In
addition, the Permittee shall provide any other information that the Commissioner
specifies relating to the activities at the Facility. The Permittee shall comply with all the
requirements of 40 CFR 264.75.
(N) CLOSURE
(1) Closure performance standard. The Permittee shall close the Facility in a manner
that:
(a) Minimizes the need for further maintenance;
(b) Controls, minimizes, or eliminates, to the extent necessary to protect

human health and the environment, the escape of waste, other materials,
constituents thereof, leachate, contaminated run-off, or waste
decomposition products to the soil, ground water or surface waters or to
the atmosphere; and
(c) Complies with the closure requirements of Section 22a-449(c)-104 of the

RCSA, any applicable portions of 40 CFR Part 264, Subpart G
(Applicable to Closure), and requirements in 40 CFR 264 Subparts I and J,
the CT DEEP “RCRA Closure Plan Guidance” document and the Closure
Plan, incorporated herein as Attachment E of this Permit.
(2) Closure Plan. The Permittee’s Closure Plan shall contain all the information
specified in 40 CFR 264.112(b), except that whenever the word “hazardous
waste” is used in 40 CFR 264.112(b), it shall mean “waste” and “other materials”
as those terms are defined in this Permit and where the term “hazardous waste
management unit” is used in 40 CFR 264.112(b), it shall mean “Waste
Management Unit/Area” as that term is defined in this Permit.
(a) Written Plan. The Permittee shall have a written Closure Plan. A copy of
the Permittee’s most current Closure Plan shall be kept at the Facility until
final closure is completed and certified in accordance with Section IV (N)
(6) of this Permit. A copy of the most current Closure Plan shall be
furnished to the Commissioner upon request and shall be provided on the
day of inspection, to any officer, employee or representative of the
Department or EPA. Attachment E of this Permit presents a copy of the
most recent Closure Plan.
(b) Content of the Plan. The Closure Plan shall identify steps necessary to
perform partial and/or final closure of the Facility. The Closure Plan at a
minimum shall include the following:

(1) A description of how each Waste Management Area shall be

closed in accordance with 40 CFR 264.111;
(2) An estimate of the maximum inventory of wastes onsite at the

Facility and a detailed description of the methods to be used during
partial closure and final closure, including methods for removing,
transporting, and disposing of all wastes and other materials;
(3) A detailed description of the steps needed to remove or

decontaminate all residues from wastes and other materials and
contaminated containment system components, equipment,
structures, and soils during partial and final closure, including
procedures for cleaning equipment and removing contaminated
soils, methods for sampling and testing surrounding soils,
groundwater, or other environmental media and criteria for
determining the extent of decontamination required to satisfy the
closure performance standard;
(4) A detailed description of other activities necessary during the

closure period to ensure that all partial closures and final closure
satisfy the closure performance standards; and
(5) A schedule for closure of each Waste Management Area and an

approximate year for final closure of the Facility.
(c) Amendment of the Closure Plan
(1) The Permittee shall submit an application accompanied by the

appropriate fee, to the Commissioner to request a permit
modification to amend the Closure Plan at any time prior to the
notification of partial or final closure of the Facility. A copy of the
proposed amended plan shall be included with the application. If
changes are made, the Permittee shall maintain a summary of
changes identifying the differences from the Closure Plan that was
issued with this Permit.
(2) The Permittee shall submit an application to the Commissioner for

a permit modification to authorize a change in the Closure Plan for
the Facility whenever:
(a) A change in operating plans or Facility design affecting the

Closure Plan;
(b) There is a change in the expected year of closure;
(c) In conducting partial or final closure activities, unexpected
events occur requiring a modification of the Closure Plan;
or
(d) New or additional information becomes known which
requires a modification of the Closure Plan.
(3) The Permittee shall submit an application for a permit modification

to the Commissioner including a copy of the proposed amended
Closure Plan for approval at least sixty (60) calendar days prior to
the proposed change in the Facility design or operation, or no later
than sixty (60) calendar days after an unexpected event has
occurred which has affected the Closure Plan. This requirement to
amend the Closure Plan is in addition to and shall not relieve the
Permittee of its obligation to comply with the permit modification
procedures specified in Section I (E) (6) of this Permit regarding
any changes in an operating plan for or design of the Facility. If an
unexpected event occurs during the partial or final closure period,
the Permittee shall submit a proposed amendment to the
Commissioner no later than thirty (30) calendar days after the
unexpected event. Any such proposed amendment shall constitute
and be treated as a request to amend this Permit and shall require
the submission of an application accompanied by the appropriate
fee to modify this Permit.
(4) The Commissioner may request modifications to the Closure Plan

under Section IV (N) (2) (c) (2) of this Permit. If such a request is
made before the Permittee’s Closure Plan has been modified by the
Commissioner pursuant to Section IV (N) (2)(c) of this Permit, the
Permittee shall make the requested modifications within sixty (60)
calendar days of the request by the Commissioner, or within thirty
(30) calendar days if an unexpected event occurs during partial or
final closure. If an unexpected event occurs during the partial or
final closure period, the Permittee shall submit a proposed
amendment to the Closure Plan to the Commissioner no later than
thirty (30) calendar days after the unexpected event. Any such
proposed amendment shall constitute and be treated as a request to
amend this Permit and shall require the submission of an
application, accompanied by the appropriate fee, to modify this
Permit.
(d) Notification of partial closure and final closure for the Regulated Waste
Management Area(s)
(1) The Permittee shall notify the Commissioner in writing at least

forty-five (45) calendar days prior to the date it expects to begin
either partial or final closure of the Facility and submit the closure
plan for the Facility to the Commissioner with such notice. The
date when the Permittee “expects to begin closure” shall be no
later than thirty (30) calendar days after the date on which any
Waste Management area receives the known final volume of
hazardous wastes, or if there is a reasonable possibility that the
Waste Management Area will receive additional hazardous wastes,

no later than one year after the date on which such area receives
the most recent volume of hazardous wastes.
(2) If the Facility’s permit is terminated, or if the Facility is otherwise

ordered, by judicial decree or final administrative order requiring
the Permittee, to cease receiving wastes or to close, then the
requirements regarding notification of Partial Closure and/or Final
Closure does not apply. However, the Permittee shall close the
Facility in accordance with the deadlines established in 40 CFR
264.113.
(3) Disposal or decontamination of equipment, structures and soils. Within ninety

(90) calendar days of the approval of the Permittee’s Closure Plan, or ninety (90)
calendar days after receiving the known final volume of waste at the Waste
Management Area(s), whichever is later, the Permittee shall properly
decontaminate or remove from the Waste Management Area or Permitted
Facility, all waste and other materials, as applicable, in accordance with the
Closure Plan approved by the Commissioner and all applicable requirements
Sections 22a-449(c)-100 through 119 of the RCSA. The Commissioner may
approve a longer period for closure if the Permittee demonstrates to the
Commissioner’s satisfaction that the activities required to comply with the
approved Closure Plan will take longer than ninety (90) calendar days to complete
and that the Permittee has taken and will continue to take all steps needed to
prevent threats to human health and the environment and will comply with any
additional conditions deemed necessary by the Commissioner arising from the
Partial or Final Closure.
Any such demonstration shall be made at least thirty (30) calendar days before the
expiration of the ninety (90) calendar days period in Section IV (N) (3) of this
Permit.
(4) Time allowed for closure. The Permittee shall complete Partial and/or Final
Closure activities, as applicable, in accordance with the Closure Plan approved by
the Commissioner within one hundred eighty (180) calendar days after such
approval or within one hundred eighty (180) calendar days after receiving the
final volume of waste at the Facility or any Waste Management Area(s), as
applicable. The Commissioner may approve a longer period for closure if the
Permittee demonstrates to the Commissioner’s satisfaction that the activities
required to comply with the approved Closure Plan will by necessity take longer
than one hundred eighty (180) calendar days to complete and that the Permittee
has taken and will continue to take all steps needed to prevent threats to human
health and the environment and will comply with any additional conditions
deemed necessary by the Commissioner arising from the Partial or Final Closure.
Any such demonstration shall be made at least thirty (30) calendar days before the
expiration of the on- hundred-eighty (180) calendar days period in Section IV (N)
(4) above.
(5) The Permittee shall manage all waste generated during Partial or Final Closure
shall be managed in accordance with all applicable statutes and regulations.
(6) Certification of closure. Within sixty (60) calendar days of completion of Partial
Closure or Final Closure of the Facility or any Waste Management Area, as
applicable, the Permittee shall submit to the Commissioner by registered mail, a
certification signed by both the Permittee and by an independent registered
professional engineer, licensed to practice in the state of Connecticut (“licensed
P.E.”) stating that the Waste Management Area or the Facility, as applicable, has
been closed in accordance with the Closure Plan approved by the Commissioner.
Documentation supporting the independent registered professional engineer’s
certification shall be furnished to the Commissioner upon request, until the
Commissioner releases the Permittee from the financial assurance requirements
for closure under Section IV (P) of this Permit.
(O) RCRA CORRECTIVE ACTION REQUIREMENTS
(1) The Permittee shall continue to perform Corrective Action activities to comply
with the United States Environmental Protection Agency (USEPA), RCRA
3008(h) Orders, RCRA Docket Numbers I-88-1075 and I-94-1046. The
Permittee shall complete a Corrective Measures Study (CMS) in accordance with
the USEPA RCRA 3008(h) Orders and implement corrective measures in
accordance with the CMS and remedy implementation scheduled therein. In the
June 10, 2009 letter to United Technologies, the Department designated the
USEPA as the lead regulatory agency overseeing the Corrective Action
requirements, with the responsibility of completing and verifying the investigation
and remediation delegated to a Licensed Environmental Professional (LEP). The
Department will serve as a support agency with a focus on providing assistance as
needed.
(2) The Permittee shall continue to maintain at the Facility a current detailed written
estimate of such portion of the cost of performing site-wide corrective action as
required by the USEPA, RCRA 3008(h) Orders, RCRA Docket Numbers I-88-
1075 and I-94-1046 and any subsequent Remedial Action Plan developed by the
Permitted Facility. The Permittee shall maintain a financial assurance mechanism
acceptable to the Commissioner consistent with the requirements described in 40
CFR 264 Subpart H. The Permittee shall maintain such financial assurance
mechanism until site-wide corrective action is complete and the Commissioner
notifies the Permittee in writing that the Permittee is no longer required to
maintain such financial assurance. The cost estimate for performing site-wide
corrective action must be revised annually following the procedures described in
40 CFR 264.142. The latest adjusted cost estimate shall be kept at the Facility
and provided for the Commissioner’s review and written approval in an annual
report/update. A copy of the annual report shall also be provided to USEPA.

(4) The Permittee shall provide monthly progress reports to USEPA on Corrective
Action work accomplished and planned.
(5) The Permit shall submit copies of technical plans and reports related to the
investigation and remediation of the establishment to the Department and USEPA
as they are completed. Reports shall be submitted to both agencies electronically
with written reports available upon request to gilbert.aaron@epa.gov and
sandy.brunelli@ct.gov, including the USEPA monthly progress reports on work
accomplished in electronic format.
(P) FINANCIAL REQUIREMENTS
(1) The Permittee shall prepare and maintain at the Facility, pursuant to 40 CFR
264.142, a written estimate of the cost of closing the Facility in accordance with the
approved Closure Plan.
(2) The Permittee shall adjust the cost estimates for closing the Facility to reflect
inflationary costs as required by Section 22a-449(c)-104 of the RCSA, incorporating
40 CFR 264.142(b). The adjustment shall be made each year on the anniversary date
of the establishment of the mechanism(s) of financial assurance for closure until the
Commissioner releases the Permittee from the financial assurance requirements of
this Permit in accordance with Section IV (P)(5) of this Permit. The Permittee shall
maintain the latest adjusted closure cost estimate in the Operating Record for the
Facility and a signed original shall be submitted to Director of the Waste
Engineering and Enforcement Division, Bureau of Materials Management and
Compliance Assurance, CT DEP, 79 Elm Street, Hartford, Connecticut 06106. A
fifteen percent (15%) contingency shall be applied to the estimate for unforeseeable
elements or events which may increase the cost of performing closure.
(3) The Permittee shall revise the closure cost estimate whenever Partial Closure of the
Facility or any Waste Management Area has been completed or there is a change in
the Closure Plan that will affect the cost of closure. Any revised closure cost
estimate shall then be adjusted for inflation as specified in Section IV (P) (2) of this
Permit.
(4) The Permittee shall establish and continuously maintain financial assurance for the
Facility using one or more of the methods specified in 40 CFR 264.143 (a)-(f). The
Permittee shall maintain such financial assurance in effect until the Commissioner
notifies the Permittee in writing that it is no longer required to maintain such
financial assurance in accordance with 40 CFR 264.143(i).
(5) Release of the Permittee from the requirements of Financial Assurance (40 CFR
264.143(i). Within sixty (60) calendar days after receiving certifications from the
Permittee that final closure of the Facility has been completed in accordance with the
approved Closure Plan, the Commissioner will notify the Permittee in writing that
either the Permittee is no longer required to maintain financial assurance for closure
of the Facility, or that the Commissioner has reason to believe that Final Closure has
not been completed in accordance with the approved Closure Plan. The
Commissioner shall provide the Permittee with a detailed written statement of any
such reason to believe that closure has not been in accordance with the approved
Closure Plan. The Permittee shall maintain the financial assurance required by
Section IV (P) (4) of this Permit in effect until the Commissioner notifies the
Permittee in writing that it is no longer required to maintain such financial assurance.
(6) Liability Requirements (40 CFR 264.147(a), Coverage for Sudden Accidental
Occurrences). The Permittee shall establish and continuously maintain liability
coverage for sudden accidental occurrences at the Facility in the amounts and in the
manner specified in 40 CFR 264.147(a). The liability coverage shall be in the
amount of at least $1 million per occurrence with an annual aggregate of at least $2
million, exclusive of legal costs. The Permittee shall ensure that the wording of any
instrument used for the purposes of compliance with this section of this Permit is
identical to the wording specified in 40 CFR 264.151, as modified by 22a-449(c)-
104(a)(2). The Permittee shall maintain such liability coverage in effect until the
Commissioner notifies the Permittee in writing that the Permittee is no longer
required to maintain such coverage, as is provided for in RCSA 22a-449(c)-
104(a)(1), which incorporates by reference 40 CFR 264.147(e).
(7) Liability Period of Coverage (40 CFR 264.147(e)). Within sixty (60) calendar days
after receiving certification from the Permittee that Final Closure of the Facility has
been completed in accordance with the approved Closure Plan, the Commissioner
will notify the Permittee in writing either that the Permittee is no longer required to
maintain liability coverage for the Facility, or that the Commissioner has reason to
believe that final closure has not been in accordance with the approved Closure Plan.
The Commissioner shall provide the Permittee with a detailed written statement of
any such reason to believe that closure has not been in accordance with the approved
Closure Plan. The Permittee shall maintain in effect the liability coverage required
by Section IV (P) (6) of this Permit until the Commissioner notifies the Permittee in
writing that such coverage is no longer required.
(8) The Permittee shall comply with the requirements specified in 40 CFR 264.148 in
the event of incapacity of the Permittee, guarantors, or financial institutions.
(Q) AIR EMISSION REQUIREMENTS - SUBPART CC
(1) Air Emission Requirements for Containers of Hazardous Waste:
(a) The Permittee shall manage all hazardous waste placed in containers in
accordance with the Air Emission requirements specified in 40 CFR 264.1086
(containers), 264.1088 (Inspection and Monitoring Requirements), and
264.1089 (Record keeping requirements).
(b) The Permittee shall ensure that all the containers in the container storage
management area meet the U.S. Department of Transportation (DOT)
regulations specified in 49 CFR Parts 173 and 178.
(c) RCRA empty containers, as defined in 261.7, are exempt from complying
with the Air Emission requirements.
(d) The Permittee shall ensure that all the containers are equipped with a cover
and closure devices that form a continuous barrier over the container openings
such that when the cover and closure devices are secured in the closed
position there are no visible holes, gaps, or other open spaces into the interior
of the container.
(R) UNIVERSAL WASTES. The Permittee shall comply with all applicable requirements
specified in Section 22a-449(c)-113 of the RCSA.
(S) USED OIL. The Permittee shall comply with all applicable requirements specified in
Section 22a-449(c)-119 of the RCSA.
(T) APPLICABLE LAWS. Even if not specified in this Permit, the Permittee shall comply
with all applicable federal, state, and local laws.
(U) LOCATION STANDARDS. The Permittee shall ensure that the Facility complies with the
requirements of 40 CFR 264.18. If the Permittee determines that the Facility does not
comply with these requirements, the Permittee shall immediately notify the Commissioner
in writing who based upon such notification may take whatever action is deemed appropriate

Section V Hamilton Sundstrand Corp.
Compliance Schedule EPA ID No. CTD001145341
SECTION V
COMPLIANCE SCHEDULE
RCRA HAZARDOUS WASTE FACILITY RENEWAL PERMIT

ONE HAMILTON ROAD

File: 20210714 HS SECTION 5 REV1a.doc Page V-1

SECTION V
COMPLIANCE SCHEDULE
The Corrective Action requirements are currently being overseen by the United States
Environmental Protection Agency (USEPA), therefore any documentation stipulated int
this Section V, shall be submitted to USEPA for review and writing approval.
(1) Corrective Action. In the June 10, 2009 letter to United Technologies, the
Department designated the United States Environmental Protection Agency
(USEPA) as the lead regulatory agency overseeing the Corrective Action
requirements, with the responsibility of completing and verifying the investigation
and remediation delegated to a Licensed Environmental Professional (LEP). The
investigation and remediation shall be conducted to comply with the two (2)
consent orders issued by USEPA, RCRA 3008(h) Order, Docket Numbers 1-88-
1075 and 1-94-1046. The Department will serve as a support agency with a focus
on providing assistance as needed. The Permittee shall ensure that it complies
with:
(a) Corrective Action Schedule. Following the Commissioner’s letter dated

June 10, 2009, delegating the lead for corrective action implementation to
a Licensed Environmental Professional (LEP), the Permittee submitted a
“corrective action schedule” to the Commissioner and USEPA for
investigating and remediating releases of hazardous waste and hazardous
substances at or from the Facility. In the LEP delegation letter the
Commissioner stipulated that unless the Commissioner has approved an
alternative schedule in writing, the Permittee shall investigate and
remediate the Facility in accordance with the corrective action schedule,
which was submitted to the Commissioner and USEPA on a letter dated
July 16, 2009. Beginning in 2022, an updated schedule shall be submitted
by August 1st of each year to the USEPA with a copy to the Department
that will include the following elements:
(i) A public participation plan that provides:
(A) Public participation prior to initiation of remediation,

including at a minimum ensuring public notice, using the
procedures described in RCSA Section 22a-449(c)-
105(h)(7);
(B) Remedial Action Plan (RAP) Public Notice. The RAP

must be public-noticed in coordination with USEPA and in
accordance with RSCA Section 22a-449(c)-105(h) (7) (A).
In addition, within thirty (30) days of public notice, a copy
of the public notice shall be provided to the Department
and USEPA;

(C) Public participation is required prior to a final

determination that remediation is complete, pursuant to
RCSA Section 22a-449(c)-105(h)(7), and as applicable, as
required by any RCRA permit conditions, RCRA Order or
by a permit application disposition procedure. A public
notice shall be published, at the Permittee’s expense, in a
newspaper having a substantial circulation in the affected
area; and be provided to all persons on the Facility mailing
list maintained pursuant to 40 CFR 124.10(c) (1) (ix); and
indicate the basis for USEPA’s and the Commissioner’s
acceptance of the LEP’s verification and the determination
that remediation is complete. The notice will state that the
Commissioner will accept public comments on the tentative
determination that remediation is complete for at least
forty-five (45) days from the date of publication. After this
public notice period, a final verification report must be
submitted to the Department and USEPA.
(D) Response to Public Comments. Comments must be

addressed in accordance with RCSA Section 22a-449(c)-
105(h) (7) and should be coordinated with USEPA. If
comments are received during any public comment period,
whether received directly by the Permittee or if forwarded
from the Commissioner, then the Permittee shall, within
sixty (60) days of receiving such comments, submit to the
Commissioner and USEPA a written summary of all such
comments and a written response to each such comment.
The Commissioner and USEPA shall review such summary
and responses and shall adopt it as the Commissioner’s
own, adopt it with modifications, or reject it and prepare a
response to each such comment. The Permittee shall send a
copy of the initial summary and responses to each person
who submitted comments.
(ii) Investigation Completed. Within thirty (30) days of completion of

investigation, written notice must be provided to the Department
and USEPA stating that this task is complete.
(iii) Submission of an Ecological Risk Assessment (ERA) to evaluate

the potential for ecological receptors to be exposed to
contaminants and to ensure that remedial goals and objectives
address protection for those receptors from existing or potential
contaminant exposures.
(iv) Submission of a Corrective Measures Study (CMS) which also

satisfies the requirements contained within Attachment VI of the
USEPA, RCRA 3008(h) Order, Docket No. 1-88-1075.
(v) Corrective Measures Implementation/Start Remediation. Within

thirty (30) days of remediation being started, written notification of
the remediation start date must be provided to the Department and
USEPA.
(vi) In accordance with the existing schedule for submittal, the

Permittee shall submit, to USEPA, for review and comment a
Remedial Action Plan (RAP) prepared by the delegated licensed
environmental professional (LEP) prior to its implementation. At
the time of such review, or at any other time, the USEPA may
notify the Permittee that the USEPA’s review and written approval
of any investigation or remedial action is necessary. Additionally,
the USEPA may review the verification to determine if
remediation is complete.
(vii) Construction Complete. This is accomplished when all remedial

systems have been constructed and are operational (including the
date that natural attenuation is accepted as a remedy). This
determination can be made even if there are institutional or
engineering controls that are in place to maintain site stability. In
addition, written notification must be provided to the Department
and USEPA within thirty (30) days of the site meeting this
achievement.
(viii) Submission, for USEPA approval, of documentation that

demonstrates the achievement of the Migration of Contaminated
Groundwater under Control Environmental Indicator.
(b) The Permittee shall submit copies of technical plans and reports related to
the investigation and remediation of the establishment to the Department
and USEPA as they are completed. Reports shall be submitted to both
agencies electronically with written reports available upon request to
(gilbert.aaron@epa.gov and sandy.brunelli@ct.gov); including the
USEPA monthly progress reports on work accomplished in electronic
format.

ATTACHMENTS
All the attachments included in the RCRA Part B Renewal Permit are from Hamilton Sundstrand
Corporation – Permit Renewal Application submitted to the Department in April 1, 2020, and as
amended.
The RCRA Part B Renewal Permit List of Attachments as:
(A) WASTE ANALYSIS PLAN

(B) INSPECTION PLAN
(C) PERSONNEL TRAINING PLAN
(D) CONTINGENCY PLAN
(E) CLOSURE PLAN
Please note that the List of Attachments cited above differs from what was provided in the
Hamilton Sundstrand’s Permit Application. The table below is a crosswalk between the
Attachments contained in this Permit and where they can be found in the Permit Application.
PERMIT APPLICATION NUMBER

OF PAGES
Attachment A: The documentation in this Attachment can be found in 53

Waste Analysis Plan Attachment K – Waste Analysis Plan
Attachment B: The documentation in this Attachment can be found in 40

Inspection Plan Attachment L – Inspection Plan
Attachment C: The documentation in this Attachment can be found in 19

Personnel Training Attachment O – Personnel Training
Attachment D: The documentation in this Attachment can be found in 50

Contingency Plan Attachment M – Contingency Plan (Integrated
Contingency Plan)
Attachment E: The documentation in this Attachment can be found in 58

Closure Plan Attachment Q – Closure Plan and Cost Estimate
ATTACHMENT (A)
WASTE ANALYSIS PLAN

(Submitted with the RCRA Part B Permit Renewal Application in April 1, 2020)

ONE HAMILTON ROAD
WINDSOR LOCKS, CT 06096-1010
EPA ID No. CTD 001145341

PERMIT NUMBER: DEEP\HWM-165-005
ATTACHMENT K
Waste Analysis Plan

WINDSOR LOCKS, CT
ATTACHMENT K
WASTE ANALYSIS PLAN

Section Page
1.0 WASTE CHARACTERIZATION ........................................................................... 1
2.0 WASTE VERIFICATION........................................................................................ 4
3.0 SPILL CHARACTERIZATION .............................................................................. 4
4.0 COMPATIBILITY EVALUATION ......................................................................... 5
5.0 DEGREE OF HAZARD DETERMINATION .................................................... 11
6.0 ANNUAL RECHARACTERIZATION ............................................................... 11
7.0 WASTE ANALYSIS REQUIREMENTS PERTAINING TO LAND
DISPOSAL RESTRICTIONS ............................................................................. 12
TABLES
TABLE 1 EXAMPLE OF CONTAINER STORAGE AREA AND WASTE TYPES
TABLE 2 TEST METHODS AND PARAMETER CODES
TABLE 3 SAMPLING EQUIPMENT
TABLE 4 EXAMPLES OF SAMPLE COLLECTION AND ANALYTICAL TECHNIQUES:
CONTAINERIZATION, PRESERVATION, AND HOLDING TIMES
FIGURES
FIGURE 1 WASTE DISPOSAL TRAVELER
FIGURE 2 ANALYTICAL PROCEDURES FOR UNIDENTIFIED WASTE
FIGURE 3 CHAIN-OF-CUSTODY
FIGURE 4 RGN COMPATIBILITY CHART
FIGURE 5 LDR FLOWCHART
FIGURE 6 LDR NOTIFICATION FORM
EXHIBITS
EXHIBIT A UTC WASTE DETERMINATION TOOL
EXHIBIT B UTC EH&S STANDARD WORK: WASTE DETERMINATION IN THE U.S.
EXHIBIT C RGN COMPATIBILITY ASSESSMENT TABLE
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WINDSOR LOCKS, CT
ATTACHMENT K
WASTE ANALYSIS PLAN
1.0 WASTE CHARACTERIZATION
1.1 Hazardous and Regulated Waste
Hamilton Sundstrand Corporation, Windsor Locks Facility (HSC; WLOX) generates a

wide variety of waste streams which are managed at the Hazardous Waste Facility
(HWF) on-site. To ensure that the wastes are properly characterized, stored, and
managed, waste analysis must be performed in accordance with the Waste Analysis
Plan in Attachment A of the HWF’s RCRA Part B Permit and the procedures outlined
in this document. This Work Guide is commonly referred to as WL-EHS-GUI-0100-00
and can be used interchangeably with the current nomenclature listed above. Table 1
outlines the types of waste managed at the HWF and their corresponding storage
locations.
1.2 Waste Determinations
Waste determinations are conducted initially on wastes generated from manufacturing

and process activities prior to storage in the HWF. Potential wastes such as non-
product-related materials that exit the operation are also assessed. New materials and
waste accumulation container requests are reviewed per the WLOX EH&S Material &
Facility/Process Modification Review Procedures. The waste determinations are
completed based on the definitions in 40 CFR Part 261, by knowledge of the process,
or by sampling and laboratory analysis. The initial waste characterization for each
waste stream stored at the HWF will be maintained in the facility Operating Record. A
current copy of the waste determination report which is generated through a computer
database is maintained as part of the HWF Operating Record.
Wastes generated on-site are characterized through manufacturer’s information,
process information, and/or laboratory analysis. All wastes are characterized by using
the UTC Waste Characterization Tool, which is provided in Exhibit A, the requirements
of the HWF’s RCRA Part B Permit and the UTC EH&S Standard Work for Waste
Determinations in the U.S., which is provided in Exhibit B. That information is then
input into the WAP database.
Recharacterization of a waste stream each time it is generated is not required because
waste streams are closely tracked at the point of generation. When a new waste
container is requested (per the WLOX EH&S Material & Facility/Process Modification
Review Procedures), prior to issuance of the container the waste stream is
investigated to ensure it is consistent with the current copy of the waste determination
report.
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In the following instances, wastes will be reviewed and characterized via knowledge of
process or sampling:
1. A change in a process/operation that impacts the composition of the
waste stream;
2. The addition of a new process/operation; and,
3. Discovery of an unidentified waste.
All wastes profiles will be reviewed annually for verification by sampling or employee
interviews, and recorded in the Database titled “Waste Analysis Plan” (WAP
database). The minimum waste sampling frequency is performed in accordance with
the sampling frequency table presented on page 9 of the UTC EH&S Standard Work
for Waste Determinations in the U.S. (Exhibit B). Waste may be sampled more
frequently based on the results of the annual review.
When characterizing waste, the following parameters are considered:
1. Physical properties;
2. Chemical composition;
3. Compatibility determination (Section 4.0);
4. Degree of hazard (Section 5.0); and
5. Applicable Land Ban disposal treatment standards in accordance with 40

CFR 268.7 (Section 7.0).
6. Variability of waste
Containers of hazardous wastes generated at the HSC facility are tracked by waste
disposal travelers and by computer using the EH&S Desk WIMS program. An example
waste disposal traveler form is provided in Figure 1. Prior to the movement of waste
from the point of generation or an accumulation area to the HWF, a waste disposal
traveler is completed by facility personnel familiar with the waste. At a minimum, this
form identifies the department group generating the waste; the container ID or
machine number; the location; the waste description; and the name and phone
number of the associate responsible for generating the waste. The information
included on the waste disposal traveler allows the waste to be associated with the
corresponding waste stream identified during the waste determination and
appropriately managed. Waste streams that do not have the characterization
parameters identified above are not accepted into the HWF for storage.
1.3 Sampling and Analysis
When necessary for waste characterization, sampling is performed in accordance with

EPA requirements set forth in the latest EPA publication SW-846 “Test Methods for
Evaluating Solid Waste; Physical and Chemical Methods”. Table 2 presents parameter
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WINDSOR LOCKS, CT
codes, the rationale for testing, and the test methods to be used for the testing of the
HWF’s hazardous and non-hazardous waste. When necessary, laboratory analysis is
performed at a State Certified analytical lab. Results of chemical analyses are
maintained by the Site EH&S Department.
The Environmental Operations-HWF staff performs waste characterization sampling at
the facility in accordance with the procedure outlined in this document (WL-EHS-GUI-
0100-00 Waste Analysis Plan Procedures). The Site Environmental, Health and
Safety (Site EH&S) staff and/or EH&S consultants also perform sampling of
groundwater and soil and of various materials for asbestos and PCB programs.
Representative sampling from the storage containers follow the procedures outlined in
SW-846. Samples are collected with equipment and techniques capable of obtaining a
representative sample of waste throughout the entire depth of the container. Samples
taken from waste streams with various phases include aliquots from each phase. For
example, if a container is 80 percent liquid and 20 percent sludge, the sample will
contain the same percentage of each phase and/or each phase will be sampled
separately.
When sampling large areas for waste characterization, for example concrete pads
designated for removal, the number of samples taken is based on the square footage
and configuration of the area. Samples from a hopper or roll-off are obtained from the
top, middle, and bottom layers to ensure that the sample is representative of the entire
load. Parameters to be analyzed for are determined on a case by case basis
depending on the historic use of an area and any records of past spills or releases.
Tank systems are periodically sampled for waste characterization. In addition, the
facility identifies, by use of waste disposal travelers and the consolidation reports, all
possible waste streams that have been added to a tank system. The resulting tank
system waste stream carries with it the applicable Connecticut Regulated codes
associated with the waste streams that have been added.
Sampling equipment will vary according to the physical and chemical characteristics of
the waste stream. Table 3 provides a summary of the typical sampling equipment used
for specific waste types. Samples are collected in certified clean wide-mouth glass
jars with Teflon lids, or if applicable, poly containers. Samples are kept refrigerated or
placed in coolers prior to shipment or delivery directly to the lab.
Decontamination of sampling equipment can consist of methanol, nitric acid, and
deionized water. These materials remove organics and metals from the sampling
equipment. In many cases dedicated sampling equipment, such as coliwasa tubes,
are disposed of after each use and do not require decontamination.
Samples are closely tracked by assigning them an identification number. In addition to
the identification number the following information is recorded: sample date, sample
location, description of the waste, and parameters for which the sample will be tested.
If any samples are not immediately analyzed, they are containerized and preserved in
accordance with the methods specified in SW-846, or as required in the specific
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WINDSOR LOCKS, CT
approved test method being utilized. Table 4 provides a list of containerization,

preservation, and holding times. The sample container is labeled with the sample
identification and analytical tests to be conducted. After the sample container is
labeled, the chain-of-custody sheet is completed. An example of the chain-of-custody
sheet is presented in Figure 3. The original results with a copy of the chain-of-custody
are maintained by Site EH&S. The test results/waste analysis and related sampling
documentation will be maintained as part of the HWF Operating Records.
Figure 2 presents the analytical procedures employed to characterize unknown
wastes. The logistics in the flow of the analytics aid in categorizing the waste stream
as well as characterizing it. The flow chart includes specific laboratory tests that can
be carried out to aid in the characterization of the unknown waste.
On-site analysis of wastes at the HWF is not performed. Testing of wastes is limited to
pH screening using pH meters and pH test strips. If performed, this testing is simply
used to field verify the pH of a waste stream. All analysis of waste for characterization
is performed at an off-site certified laboratory. Therefore, a site-specific laboratory
analysis quality assurance/quality control plan is not required. Should actual chemical
analysis be performed on-site a quality assurance/quality control plan will be
developed and maintained for the analyses performed.
2.0 WASTE VERIFICATION
In addition to the initial waste characterization previously described, a secondary

check to verify the proper characterization of the wastes will be carried out. The waste
verification applies to waste streams which include the following:
 All waste chemicals and other materials generated on-site which are stored or
otherwise managed in the HWF. Waste verification for waste chemicals and
other materials generated on-site is done by reviewing records associated with
the waste (i.e., waste disposal traveler).
 Any waste managed within the HWF prior to the transfer of bulking of a waste
stream into a storage tank, container, or container storage area, to confirm that
the contents of the storage tank, container, or other processing area and the
materials are compatible in accordance with Section 4.0 of this document.
Any waste streams that do not have the required characterization and/or do not meet
the verification parameters are not stored in the HWF.
3.0 SPILL CHARACTERIZATION
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WINDSOR LOCKS, CT
Residues from spills that occur must be characterized so the resulting wastes can be
properly managed and stored at the HWF.
 Spill residues from known sources – Spill residues from known sources of wastes
in storage at the HWF shall be evaluated or analyzed for the appropriate
parameters referenced in Table 2, Parameters and Rationale. The results from
these evaluations of analyses shall be used to characterize the spill residues.
 Spill residues from Unknown Sources – Spill residues from unknown sources shall
be evaluated in accordance with Figure 2, Analytical Procedure for Unidentified
Waste, to identify the waste, determine the proper waste management and
compatibility group and ensure that sufficient information is obtained for proper
storage or management of the waste. If the material does not fall within the
permitted hazardous waste codes, the material shall not be managed in the HWF
and must be shipped off-site to an approved facility within 90 days.
4.0 COMPATIBILITY EVALUATION

Compatibility evaluations of wastes are necessary to ensure proper management and
storage of wastes in the HWF. Commingling of incompatible waste can result in
undesired and dangerous reactions. To evaluate the potential for such reactions to
occur, waste streams are reviewed for compatibility. Prior to storage in the HWF, all
wastes are categorized and characterized. The wastes are assessed for compatibility
with the container or tank they are stored in, compatibility with other waste stored in
close proximity, and compatibility with the physical structure of the HWF.
All waste is characterized prior to arrival at the HWF, which minimizes the need for
additional testing. The waste characterizations are reviewed and the waste is tested as
needed. Information from the waste disposal traveler forms can be used to identify and
segregate these wastes for storage. In addition to the waste disposal traveler forms,
the SDSs and the Reactivity Group Number (RGN) are both used to determine
compatibility. A chart detailing RGN compatibility is included in Figure 4. RGNs are
assigned to each waste based on its physical and chemical hazards. The RGNs are
then compared to determine if the wastes are compatible. The use of this information
ensures that only compatible wastes are stored together. Table 1 presents a
description of the waste streams generated at the HSC facility. The table lists the
storage area, waste group, waste IDs associated with the waste group/storage area, a
description of typical wastes, and the probable RGNs associated with the waste group.
Wastes are considered incompatible if upon mixing or contact, a reaction may occur
which leads to the following:
 Generation of heat or pressure, fire or explosion, or violent reactions;
 Production of toxic mists, fumes, dusts, or gases in sufficient quantities to
threaten human health or the environment;
 Production of flammable fumes or gases in sufficient quantities to pose a risk of
fire or explosion
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WINDSOR LOCKS, CT
 Damage to the structural integrity of the container, containment structure, or

any other structure;
 Threatens human health or the environment.
Storage of wastes at the HWF is arranged to ensure that incompatible wastes are
segregated. For example, acids are stored separate for alkalis. See the facility map
on file at the HWF for layout of HWF. The entire storage area floor has been coated
with a material that is appropriate for the storage of all the waste types stored. If an
area has reached full capacity, the HWF Manager may determine if a container can be
stored with another type of waste. As stated above, this determination is based on the
waste disposal traveler, SDS, laboratory results, and/or the RGN table. For RGN pairs
that may indicate a reaction due to incompatibility, the wastes are segregated and
these drums are moved to another area, as necessary. However, in certain
circumstances the actual hazard of the material may allow for co-storage with a
material that based solely on RGN may be considered incompatible. For example,
non-hazardous waste acid aqueous solution with a pH of 4 will be labeled Waste Acid
but could be stored in the solvents area of the HWF since it is not incompatible with
solvents. When it is known by material knowledge, manufacturer information, process
knowledge, and/or laboratory analysis that a material does not exhibit the reactivity
associated with a particular RGN for the given waste, that RGN is not applied.
Additionally, incompatible RGNs may be assigned to the same waste stream due to
the chemical makeup of the waste. The materials considered incompatible based on
RGN pairs may have been mixed in the same container without an undesired reaction
and are considered “co-located” prior to the waste’s arrival at the HWF. Instances
where the RGN pairs show incompatibility yet waste is still co-located are described in
Section 4.1 below.
4.1 Waste Storage
The following section details the storage arrangement for typical wastes. The RCRA
Part B Permit limits the total volumetric storage capacity of all containers in the storage
area to a total of 55,000 gallons. Secondary containment requirements include a
containment volume of 10% of all waste, or 100% of the largest container, whichever
is greatest. Although some waste may be deemed incompatible by RGN, due to
concentration, or other factors they have been determined to be acceptable for storage
together. Specific examples of incompatible RGN pairs are described below. A
detailed breakdown of waste stored on each rack and the subsequent compatibility
issues are included in Exhibit C - RGN Compatibility Assessment Table.
Rack Storage:
Rack A, Ignitable/Combustible (90 drums) – Miscellaneous liquid flammables such as
paints, resins (non-isocyanate), and adhesives, jet fuel, calibration fluids, aerosol cans,
and hazardous oils will generally be incinerated and stored on this rack since it is
farthest from the Packaging Room, and accessible to fire trucks. These wastes fall
primarily into the RGN of 101- Combustible and Flammable Materials, Miscellaneous
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WINDSOR LOCKS, CT
and 29 – Hydrocarbon, Aliphatic, Saturated. There are no incompatible RGN pairs

stored on this rack.
Racks B, C Toxics/Burnables (90 drums) - Typical wastes include solids such as rags
and debris, oil filters, paint filters and miscellaneous burnable solids.. There are no
incompatible RGN pairs stored on Rack B. Rack C has one incompatible RGN pair,
24/106. This incompatibility results in solubilization of toxic substances. This
incompatibility is not an issue as the wastes with these RGNs are not mixed.
Rack D Toxics/Burnables/Universal waste (90 drums) - Typical wastes include solids
such as light bulbs, batteries, and accumulation containers containing aerosols,
adhesives, and catalysts. There are no incompatible RGN pairs stored on this rack.
Rack E Toxics, Sludges (108 drums) - Typical wastes are sludges from machining
operations consisting mainly of aluminum and steel which may contain some cadmium
and chromium. Metal hydroxide sludge and other wastewater treatment sludges
(cake) consist mainly of iron with low amounts of chrome and nickel. Treated metal
powders resulting from additive manufacturing processes may be stored on this rack.
These powders will be treated with mineral oil in a long term storage area (LT90) prior
to entering the HWF, thus the material will not exhibit the characteristics of ignitability
or reactivity and CT regulated waste codes CR02, CR04, and CR05 may be
applicable. There are no elemental metals such as pure sodium or phosphorous which
are extremely reactive. If at any time such extremely reactive metal wastes exist, they
would be isolated from other wastes in a manner similar to the method used for
oxidizer storage. The machine sludges are stored next to the Soil Rack for
compatibility. There are two incompatible RGN pairs on this rack that result in
solubilization of toxic substances; 10/24 and 24/106. This result is not an issue on this
rack because most of the incompatible pair examples have been pre-mixed prior to
disposal and do not show any signs of a hazardous reaction. There are two
incompatible RGN pairs on this rack that result in flammable gas generation and heat
generation; 10/22 and 22/106. The incompatibility of 22/106 originates from dry metal
alloy and water mixtures. The metal powders will not be considered incompatible after
treatment with mineral oil because the oil surrounds the metal alloys to prevent oxygen
and water from reacting with the powder. Therefore this result is not anticipated to be
an issue. The incompatibility of 10/22 originates from caustic solids and metal
powders. Metal powders will be treated with mineral oil prior to entering the storage
rack, therefore it is highly unlikely the metal powders and caustic solids would mix.
Rack F Toxics, Soils (108 drums) - Typically not much waste is stored in this rack due
to the limited amount of waste generated. The Corrective Action Group occasionally
generates waste soils when investigating construction activities that involve
subsurface work. Other typical wastes are soils, sodium bicarbonate, and carbon
canister filters. Treated metal powders resulting from additive manufacturing
processes may be stored on this rack. These powders will be treated with mineral oil in
a long term storage area (LT90) prior to entering the HWF, thus the material will not
exhibit the characteristics of ignitability or reactivity and CT regulated waste codes
CR02, CR04, and CR05 may be applicable. There are two incompatible RGN pairs on
this rack that result in solubilization of toxic substances; 7/24 and 24/106. This result is
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WINDSOR LOCKS, CT
not an issue on this rack because many of the incompatible pair examples have been
pre-mixed prior to disposal and do not show any signs of a hazardous reaction. There
is one incompatible RGN pair on this rack that result in flammable gas generation and
heat generation; 22/106. The incompatibility of 22/106 originates from dry metal alloy
and water mixtures. The metal powders will not be considered incompatible after
treatment with mineral oil because the oil surrounds the metal alloys to prevent oxygen
and water from reacting with the powder. Therefore this result is not anticipated to be
an issue.
Rack G Toxics, Aqueous wastes, Universal wastes (108 drums) - Typical wastes are
rinse waters from processes, floor wash water, used electronics, and biomedical
waste. There is one incompatible RGN pair stored on this rack, 24/106. The
incompatibility results in solubilization of toxic substances. This result is not an issue
on this rack because many of the incompatible pair examples have been pre-mixed
prior to disposal and do not show any signs of a hazardous reaction. Additionally, the
concentration of toxic substances is very low.
Rack H Supplies or Toxics (36 drums) - Supplies such as pails, and bags are typically
stored in this rack. Space is available for wastes if needed in the future.
Storage Buildings:
These are self-contained, heated units approximately 15 ft x 10 ft, with 500 gallons of
containment capacity. These are used to store wastes that may be incompatible with
most of the chemical families as indicated on the RGN table.
Acid Storage Building (SSC-2) - This building houses acids such as chromic acid,
phosphoric acid, and fixer from printing. These wastes are isolated since they are
reactive with most chemical families such as caustics, halogenated solvents,
hydrocarbons, and flammables. Separate storage shelves are located inside and used
to store oxidizers that are acidic. There are multiple sets of incompatible RGN pairs
stored in this area, however the incompatibility results is either solubilization of toxic
substances which has already been discussed, and heat generation which is an
inherent physical property when mixing or diluting acids. Since no on-site
neutralization is being performed, it is unlikely that any heat generation will occur
during storage.
Alkaline/Cyanide Storage Building (SSC-1)_- This building houses alkalines such as
ammonia solutions, sodium hydroxide and potassium hydroxide. Cyanides are not
used in the plating processes at the HSC facility. These wastes are isolated since
they are reactive with most chemical families such as acids, halogenated solvents,
hydrocarbons, and flammables. Separate storage shelves are located inside and used
to store oxidizers that are alkaline. There are two incompatible RGN pairs stored in
this area, 10/24 and 24/106. The incompatibility results in solubilization of toxic
substances. This result is not expected to be an issue as the wastes are not mixed
and if they were, the result would not present a danger in the area.
PCB/Resin Storage Building (SSC-4 & SSC-5) - This building contains two rooms that
are divided by a ceiling to floor wall, each with separate containment. PCB wastes are
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WINDSOR LOCKS, CT
stored in one room while isocyanates are stored in the other. Waste that is classified
as PCB waste (waste that contains 50 parts per million (ppm) of polychlorinated
biphenyls (PCBs) or is contaminated with material who’s source contained 50 ppm of
PCBs) is managed in drums. This material is stored in the PCB shed located at the
HWF.There is one incompatible RGN pair: 18/106. Wastes with RGN 18 are stored
within SSC-5 and wastes with RGN 106 are within SSC-4. The construction of this
building with two separate rooms prevents wastes with RGN’s 18 and 106 from
coming into contact. All RGN’s within individual storage rooms are compatible.
Incompatible wastes are not co-located.
Storage Building for Water-based Wastes (SSC-6) - This storage building is for water-
based wastes to keep from freezing in the winter. In addition, small, self-contained
cabinets may also be made available for segregating special wastes.
Cabinet Storage:
Flammable Cabinet (SSC-3) - Typical wastes stored in the flammable cabinet are
small containers of flammables and combustibles.
Lab Pack Cabinet Toxics/Others (SSC-7) - This cabinet is used for miscellaneous
wastes that are not corrosive or flammable. This cabinet is used to store toxics or
otherwise hazardous materials requiring segregation (provided that RGN’s are
compatible). Separate containers are located inside of the cabinet to provide
segregation.
Drum Load Staging Area:

This area is used to stage containers prior to shipment for proper treatment and
disposal. Containers are removed from designated storage areas at which time proper
DOT shipping labels are affixed to each container.
Peroxides:
These are typically segregated and stored in a refrigerator since they are temperature
sensitive. The temperature range at which the organic peroxide can be safely stored
must be identified on the container.
Waste in Tank Systems:
HSC bulks waste in tank systems. Currently, there are two waste tanks at the HWF.
These tanks and the typical wastes stored in them are described below.
Non-Hazardous Tank I.D. 121A (a.k.a 121 in database) - This tank previously
contained flammable wastes. Partial closure of tank 121A was achieved on August
15, 2013 and the tank was repurposed for storage of non-hazardous process waters
and coolants.. Typical wastes include FPI rinsewaters, glycols, floor stripping and
wash waters. These waters are sent off-site for treatment.
Used Oil: Non-Hazardous Combustible Liquids/Oils I.D 121B (a.k.a 122 in database) -
Typical wastes are high flash petroleum based cleaners, preservative oils, various
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WINDSOR LOCKS, CT
cutting, lubrication and hydraulic oils, and other metal working fluids. The used oils are
sent off-site for recycling.
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WINDSOR LOCKS, CT
5.0 DEGREE OF HAZARD DETERMINATION
In addition to characterizing each waste, prior to storage at the HWF the degree of
hazard for each material must be determined. The degree of hazard determination
can be made based on the following methods:
 Review of the Safety Data Sheets (SDS) associated with the waste. This can
include the SDS for the primary ingredients/virgin materials in the waste. The
SDS includes information on the physical and chemical hazards associated with
the material and can be used to determine the applicable degree of hazard.
 Using an NFPA Standard (e.g., NFPA 704, NFPA 325M, NFPA 49, NFPA 430,
NFPA 432, NFPA 55, etc.) a determination can be made on the applicable
degree of hazard and/or hazard class rating for each of the primary ingredients
in the wastes.
 Additional methods for assessing hazards such as HMIS or GHS classification

information may be used to determine the degree of hazard.
When determining the degree of hazard in a mixture containing two or more

chemicals, there are two possible options for the determination:
1. Obtain the individual degree of hazard rating for each component using the
methods described above. The mixture can be assigned the degree of hazard
which represents the most severe degree of hazard rating. If an individual
component does not have a degree of hazard rating, one can be assigned using
the NFPA 704 quantitative or qualitative determination method (or another
approved method). The selection and assignment of method and degree of hazard
rating must be documented in the evaluation.
2. If the principal hazards of the mixture are known, the degree of hazard for the
mixture can be assigned. The method to be used to assign the overall degree of
hazard rating shall be the quantitative or qualitative method described in NFPA
704, or an alternate approved method.
The assignment of the individual degrees of hazards, as well as the overall degree of
hazard for the mixtures must be documented and the record of the determination will
be maintained in the HWF Operating Record until the HWF is closed.
6.0 ANNUAL RECHARACTERIZATION
Each waste is recharacterized three hundred sixty-five (365) days after the initial
waste characterization as described in Section 1.
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7.0 WASTE ANALYSIS REQUIREMENTS PERTAINING TO LAND DISPOSAL

RESTRICTIONS
As described in Section 1, identification of hazardous waste streams at HSC is

determined by definition or by representative sampling and analysis of the waste. Of
these waste streams it has been determined by knowledge of the process generating
the waste or by analytical results obtained during the initial identification of the waste
that essentially all hazardous waste generated by HSC is subject to the Land Disposal
Restriction (LDR) regulations (40 CFR 268). Current practice at Hamilton Sundstrand
is to treat all hazardous waste as though it is subject to the LDR regulations. A flow
chart for determining applicable treatment standards and Underlying Hazardous
Constituents (UHCs) is presented in Figure 5.
HSC is required to document the LDR applicability in the waste determination. These
records are maintained in the operating record. An example LDR Notification Form is
provided in Figure 6. The following information must be documented for all hazardous
wastes:
1. Treatability group
2. Significant hazardous waste codes
3. Regulated hazardous constituents known to be present
4. For wastes which are characteristically hazardous, UHCs must be identified.
Wastes that are listed, or wastes that are characteristic but are being treated at a
Clean Water Act Treatment Facility or equivalent, are not subject to review for UHCs.
Otherwise, the wastes will be reviewed for UHCs.
K.12
WINDSOR LOCKS, CT
TABLES
1- Example of Container Storage Area and Waste Types
2- Test Methods and Parameter Codes
3- Sampling Equipment
4- Examples of Sample Collection and Analytical Techniques: Containerization,
Preservation, and Holding Times
K.13
WINDSOR LOCKS, CT
Table 1 – Example of Container Storage Area and Waste Types
Maximum Maximum Reactivity

Storage
number of Capacity in Waste IDs Group Typical Wastes Incompatibility
Area
Containers Gallons Number*
Rack A 90 4,950 05_, 06_, 09_, 16, 17, 19, 29, Ignitable and combustible liquids such All RGNs compatible
10_, 12_, 13_, 34, 101 as paints, resins (non-isocyanate) and
14_, 16_ adhesives
Rack B 90 4,950 15_ 24, 29, 101 Burnables such as rags and debris, oil All RGNs compatible
filters, paint filters and cleaning fuels
Rack C 90 4,950 06_, 12_, 14_, 4, 24, 29, 101, Burnables such as rags, oil filters, paint 24/106
15_, 16_, 18_ 106 filters and aerosol cans
S
Rack D 90 4,950 15_, 16_, 21_ 21, 22, 24 Burnables such as rags, oil filters, paint All RGNs compatible
solvents, fluorescent lamps,
accumulation containers for
consolidating wastes such as acid
debris in over pack, alkaline debris in
over pack, grease, aerosols cans, epoxy
resin, catalyst.
10/24 & 24/106
Rack E 108 5,940 11_, 12_, 15_, 10, 16, 22, 23, Machine sludges and metal hydroxide
S
16_, 17_ 24, 29, 101, sludges (cubic yard boxes). Treated
10/22 & 22/106
106 metal powders.
GF & H***
K.14
WINDSOR LOCKS, CT
Maximum Maximum Reactivity
Storage Area number of Capacity in Waste IDs Group Typical Wastes Incompatibility
Containers Gallons Number*
7/24 & 24/106
Rack F 108 5,940 11_, 12_, 13_, 7, 16, 22, 24, Soils – Sporadic contaminated soils,
S
15_, 16_, 17_, 29, 101, 106 ultra filtration Zyglo filters, carbon
22/106
18_ canister filters and silver recovery
GF & H***
canisters. Treated metal powders.
Rack G 108 5,940 02_, 10_, 11_, 17, 24, 29, 101, Aqueous wastes from processes such 24/106
15_, 16_, 17_, 106 as solder rinse water, vapor blast water
S
18_ and floor wash water, concrete sawcut
waters, dust collector sludge containing
water, biomedical waste
Rack H 36 1,980 NA NA Used for supplies, may be used for NA

storage of toxic wastes
Lab Pack Varies 55 21_, 22_ * Miscellaneous wastes that are mainly All RGNs compatible
Cabinet – toxic but not corrosive or flammable
Toxics/Other**
(SSC-7)
Lab pack Varies 55 06_, 09_, 21_ 24, 101 Miscellaneous wastes which are All RGNs compatible
Cabinet – FC ignitable or combustible
(SSC-3)
Acids 24 1,320 01_, 02_, 11_, 1, 3, 24, 106 Wastes like chromic acid, phosphoric 1/24; 3/24; 1/106;
15_, 17_, 21_, acid and fixer from printing, lead acid 24/106
(SSC-2)
22_ batteries.
S&H
PCB (SSC-4)/ 24 1,320 SSC-4: 20_ SSC-4: 16, PCBs in one room and Isocyanates
101, 106 and other resins in another room. 18/106
Resin (SSC-5) H & G****
SSC-5: 13_, 22_ SSC-5: 18, 103
K.15
WINDSOR LOCKS, CT
Maximum Maximum
Storage Reactivity
number of Capacity in Waste IDs Typical Wastes Incompatibility
Area Group Number
Containers Gallons
Alkaline or 24 1,320 03_, 04_, 10_, 10, 24, 104, Alkaline waste such as developer from 10/24 & 24/106
Cyanide 11_, 15_, 21_, 106 printing ammonia, sodium hydroxide
S
22_ and cyanides.
(SSC-1)
Building – 24 1,320 NA NA Heated building for water based waste NA

WB when the outside temperature falls
below the freezing point (winter
(SSC-6)
storage).
Totes Various 3,951 NA NA Hazardous coolants, oils, waters. NA

size
Roll-off 30 cubic 6,059 12_, 16_, 20_ 19, 22, 24, 101, Contaminated soils, machine sludges. NA
yard 106
Total 55,000 gallons
Staging A 5,500 Area preparation for container storage

Area combination or offsite shipment.
of totes and
containers
*Compatibility is determined as needed.

**Toxics or otherwise hazardous materials requiring segregation (provided that RGN’s are compatible)
***See Section 4.1 for an explanation of these incompatibilities.
****All RGN’s within individual storage rooms are compatible. Incompatible wastes will not be co-located.
S – Solubilization of Toxic Substances, H – Heat Generation, GF – Flammable Gas Generation
K.16
WINDSOR LOCKS, CT
Table 2 – Parameters and Rationale
SW-846 Test
WAP-2 Methods
WAP-2 Test
Parameters Analytical Rationale
Method (most current
Method
methods used)
Volatiles Gas 8010, 8015 8260 Due to the chemical

Chromatography 8020 composition of the materials
as noted on the SDS and
Ignitability Pensky-Martens 1010 1010, 1030 based on the generating
(D001) Closed Cup process the waste may
contain several hazards.
Corrosivity Electrometric 9040 9041
(pH) (D002) Measurement
Reactivity None None None

(D003)
Metals Atomic 3010 3005

(Total - Absorption
aqueous)
Metals Atomic 3050 3050

(Total - Absorption
solids)
Metals Atomic 7060, 7080, 6010, 7471

Absorption 7130, 7190,
7196/7197,
7420, 7470,
7471, 7740,
7760
Toxicity TCLP 1311 1311
PCB Gas 8080 8082 Based on the generating

Chromatography operations, this waste stream
may contain PCBs.
Expired N/A These wastes are expired

Shelf Life shelf life and unused material.
Due to SDS’s and the close
tracking of the waste with the
traveler tickets, these waste
streams are not sampled.
These wastes are
characterized by definition.
K.17
WINDSOR LOCKS, CT
SW-846 Test
WAP-2 Methods
WAP-2 Test
Parameters Analytical Rationale
Method (most current
Method
methods used)
Varies, SW-846 Test These waste streams are

case-by- Methods from normal cleaning or may
case dependent on result from spill. Each event
the parameters will be tested for the
and rational. applicable parameters.
Knowledge N/A Based on source/description

of Process, and generating operation,
by definition these waste streams are
characterized by process
review and/or by definition.
Due to the close tracking of
waste with the traveler
tickets, these wastes may or
may not be periodically
sampled and analyzed.
The test methods specified in this table represent the current SW-846 test methods. These
current test methods replace the outdated methods specified in the facility’s RCRA Part B
Permit.
K.18
WINDSOR LOCKS, CT
Table 3 – Sampling Equipment
Sampling Point Waste Type Drum Storage Tank
Free Flowing Liquids and Coliwasa Weighted Bottle

Slurries
Sludges Trier Trier
Moist Powders or Granules Trier Trier
Dry Powders or Granules Thief Thief
Sand or Packed Powder or Auger Thief

Granules
Large Grained Solids Large Trier Large Trier
K.19
WINDSOR LOCKS, CT
Table 4 – Examples of Sample Collection and Analytical Techniques:

Containerization, Preservation, and Holding Times
Matrix/ Parameters to Sample Container Preservation

Maximum Holding Time
be Analyzed Type and Materials Method
LIQUIDS
Mercury (TCLP) Widemouth glass Cool to 4 C 6 months for TCLP

6 months for analysis
Mercury (TCLP) Widemouth glass Cool to 4 C 28 days for TCLP

28 days for analysis
Volatile Organics 40 ml VOA Vial Cool to 4 C; pH <2 14 days

HCl; Na2S2O3
Semivolatile organics 1 Liter Amber glass Cool to 4 C 7 days for extraction

Na2S2O3 40 days for analysis
Pesticides, herbicides, 1 Liter Amber glass Cool to 4 C 7 days for extraction

and insecticides
pH: 5-9 40 days for analysis
Polychlorinated 1 Liter Amber glass Cool to 4 C 7 days for extraction

biphenyls (PCBs)
Dioxins and furans 1 Liter Amber glass Cool to 4 C 7 days for extraction
Na2S2O3 40 days for analysis
Metals (total) 1 Liter polyethylene Cool to 4 C 6 months for analysis

pH <2 HNO3
Mercury (total) 1 Liter polyethylene Cool to 4 C 28 days*

or Widemouth glass
pH <2 HNO3
Chromium (VI) 500 ml Amber glass Cool to 4 C 24 hours
pH Glass or None Analyze immediately

polyethylene
Total organic halogens 1 Liter Amber glass Cool to 4 C 7 days

(TOX)
pH <2 H2SO4
Total organic carbon 1 Liter Amber glass Cool to 4 C; pH <2 28 days

(TOC)
K.20
WINDSOR LOCKS, CT

HCl or H2SO4
Concentrated Waste Widemouth Glass None 14 days

Samples w/Teflon lines
SOLIDS
Volatile organics (total) Widemouth glass Cool to 4 C 14 days

w/Teflon liner
Semivolatile organics Widemouth glass Cool to 4 C 14 days for extraction

(total) w/Teflon liner
Pesticides, herbicides, Widemouth glass Cool to 4 C 14 days for extraction

and insecticides (total w/Teflon liner
EPA scan)
Polychlorinated Widemouth glass Cool to 4 C None*

biphenyls (PCBs) w/Teflon liner
Dioxins and furans Widemouth glass Cool to 4 C 14 days for extraction

w/Teflon liner
Mercury (total) Widemouth glass Cool to 4 C 28 days for extraction

w/Teflon liner
Chromium (VI) Widemouth glass Cool to 4 C 24 hours

w/Teflon liner
All other metals (total) Widemouth glass None 6 months for extraction
w/Teflon liner
6 months for analysis
pH Widemouth glass None Analyze immediately

w/Teflon liner
Total organic halogens Widemouth glass Cool to 4 C 7 days

(TOX) w/Teflon liner
Total organic carbon Widemouth glass Cool to 4 C 28 days

(TOC) w/Teflon liner
Toxic volatile organics, Widemouth glass Cool to 4 C 14 days for TCLP

per TC rule w/Teflon liner
K.21
WINDSOR LOCKS, CT

Toxic semivolatile Widemouth glass Cool to 4 C 14 days for TCLP

organics, per the TC w/Teflon liner
7 days for extraction
rule
TC pesticides and Widemouth glass Cool to 4 C 14 days for TCLP

herbicides w/Teflon liner
7 days for extraction
Concentrated Waste Widemouth glass None 14 days

Samples w/Teflon liner
Metals (TCLP) Widemouth glass Cool to 4 C 6 months for TCLP

w/Teflon liner 6
months for analysis
Mercury (TCLP) Widemouth glass Cool to 4 C 28 days for TCLP

w/Teflon liner 28 days
for analysis
*Hold times are based on most current SW-846 methods and may differ from the hold
times presented in Table WAP-4 in the RCRA Part B permit.
K.22
WINDSOR LOCKS, CT
FIGURES
1- Waste Disposal Traveler
2- Analytical Procedures for Unidentified Waste
3- Chain of Custody
4- RGN Compatibility Chart
5- LDR Flowchart
6- LDR Notification Form
K.23
WINDSOR LOCKS, CT
Figure 1 – Waste Disposal Traveler

A. Complete the traveler with information A-L. (Some items may already be preprinted.)
Information A-F can be transferred right from the waste label. Information C is the
container number (Drum ID) or for non-routine waste list the tank or machine brass tag
number. G is the quantity and size of container (i.e. 1, 55 gallons). H is for any specific
information such as the name of a paint. I is the work order number received after calling
Environmental Operations-HWF for pick up.
B. Secure completed traveler to the container

WASTE DISPOSAL TRAVELER
Fill Date Generating Dept. Group Container ID or Brass tag or Tank No. Location (Bldg and Col. No.)
A B C D
Profile ID Label Description Qty Size
E F Container
G
Additional Description ( Trade name or chemical name if applicable) Pickup Work Order No.
H
Generating Dept. Associate’s printed name Phone Ext.
I
-
Signature J K L
Environmental Operations-HWF Use Only Delivery Work Order No.
WLEHS-WI201.2
-
EXAMPLES ONLY, NOT FOR USE.

MAY NOT BE CURRENT
K.24
WINDSOR LOCKS, CT
Figure 2 – Analytical Procedure for Unidentified Waste
LIQUID/SLUDGE LIQUID
Visual Check for Phases

Separation Procedures
Separate Phases
Solid Liquid Check Specific Gravity (Spg)
Filter Solids
from Liquids Spg <1 Spg =1 Spg > 1
Test for Categorize Waste

Solid Liquid Test for Flashpoint (Fp) TC Metals with Ion
Chromotography
Reduced Particle Test for TC Metals Test for pH

Size if Appropriate and Organics
Test for TC
Metals, Organics, Above TC Above TC Below TC Below TC Above TC Above TC Below TC Below TC
and Reactivity Level and Level and Level and Level and Level and Level and Level and Level and
pH < 2 or pH > 12.5 2 < pH < 12.5 pH < 2 or pH > 12.5 2 < pH < 12.5
> 140 F < 140 F < 140 F > 140 F
No Yes
RCRA Nonhazardous RCRA Hazardous Nonhazardous

Nonhazardous RCRA Hazardous Hazardous
Nonhalogenated solvents Halogenated solvents
Test for TC organics Test for

TC Organics
Test for FP
Above TC Below TC
Level Level
Above TC Below TC Below TC
Above TC
Level and Level and Level and
Level and
< 140F < 140F > 140F RCRA Nonhazardous
> 140F
Hazardous
RCRA Hazardous Nonhazardous
K.25
WINDSOR LOCKS, CT
Figure 3 – Example of Chain of Custody from Lab
K.26
WINDSOR LOCKS, CT
Figure 4 – RGN Compatibility Chart
K.27
WINDSOR LOCKS, CT
Figure 5 – LDR Flowchart
K.28
WINDSOR LOCKS, CT
Figure 6 – LDR Notification Form
K.29
WINDSOR LOCKS, CT
K.30
WINDSOR LOCKS, CT
K.31
WINDSOR LOCKS, CT
K.32
WINDSOR LOCKS, CT
EXHIBITS
A- UTC Waste Characterization Tool
B- UTC EH&S Standard Work: Waste Determination in the U.S.
C- RGN Compatibility Assessment Table
K.33
WINDSOR LOCKS, CT
Exhibit A
UTC Waste Determination Tool
K.34
WINDSOR LOCKS, CT
Exhibit B
UTC EH&S Standard Work: Waste Determination in the U.S.
K.35
WINDSOR LOCKS, CT
Exhibit C
RGN Compatibility Assessment Table
K.36
Rack E
Incompatible RGN Pairs on this rack: 10/24; 24/106; 10/22; 22/106
Is this RCRA RGN compatible RGN compatible

Waste Desired Incompatibility
Waste Stream name Description of process generating waste EPA waste codes hazardous Handling and storage requirements RGN within waste within ALL waste
ID Rack Result
waste? stream? streams on Rack?
MHS from industrial wastewater treatment of plating N
11001 METAL HYDROXIDE SLUDGE F006, F019 Yes Rack-E Machine sludge E 24 Y S
process chemicals and rinses. (10/24; 24/106)
N
11002 MACHINE SLUDGE -Machining of various metal parts. I.d. & o.d. grinders D006, D007, D008 No Rack-E Machine sludge E 24, 29 Y S
(10/24; 24/106)
E N
11029 FPS-1 FILTER PRESS SUMP WTF, Cleaning of collection sump for filter press F006,F019 No 24, 106 N (24/106) S
F (10/24; 24/106)
C
12012 CARBON & TEFLON FROM Dust cvollector from torit from cloud tower and N/A No 1A2/55, RACKS-DEF E 101 Y Y NA
F
N
15011 PPE, PAINT CHIPS, POLY, ABATEMENT OF LEAD PAINT FROM FACILITY AND D008 Yes Racks-B,C,D Toxics/Incinerables E 10, 24 N (10/24) S
(10/24; 24/106)
LEAD TAPE USED TO MASK OFF PARTS FOR PLATING, PARTS D007 D008 IF NOT N
15029 LEAD TAPE C/W CHROME Yes 1A1/55 Rack-E Machine sludge E 24 Y S
ARE RINSED PRIOR TO REMOVAL RECYCLED (10/24; 24/106)
PPE, RAGS C/W MHS, ACIDS container used in disposal of rags and ppe contaminated D006, D007, D008, F006, N
15034 Yes RACK-E E 10, 24 N (10/24) S
& ALKALINES with metal hydroxide sludge, sodium F019 (10/24; 24/106)
N
15042 GLASS BEAD & DEBRIS C/W Cyclone BT ORE 2027 in a booth, blast fan D006 No Rack-E Machine sludge E 24 Y S
(10/24; 24/106)
Plating debris PVC, steel pipe from metal finishing tanks area VARIES BY EVENT (USUALLY N
15043 PLATING DEBRIS Yes Rack-E Machine sludge E 24 Y S
(ie tank 1216 1113 & 1319) D007), sample each event (10/24; 24/106)
turning, milling, and machining of magnesium
D003 IF NOT COVERED 1A1/55 must be filled with mineral oil
15051 MAGNESIUM CHIPS & TURNINGS alloys. Chips are disposed of in a container provided Yes E 23, 101 Y Y NA
WITH MINERAL OIL prior to HWF acceptance
by hazardous waste. FACILITY SERVICES FILLS
16052 USED SOLDER Electronics D008 if not recycled No 1A1/55 Rack-E E 23 Y Y NA
C
16056 RAGS C/W STANNIC Wiping excess stannic chloride solution after the N/A No 1A2/55, RACKS-DEF E 101 Y Y NA
F
C
16057 PAPER C/W CARBON & Trimmin excess carbon coating form hudson press N/A No 1A2/55, RACKS-DEF E 101 Y Y NA
F
Ship offsite,rack storage or SSC-2 if E N
17035 WTF RO MEMBRANE WTF EVAPORATOR CLEANING SOLUTION D002,F006,F019 Yes 106 N (24/106) S
corrosive SSC-2 (10/24; 24/106)
E N
17036 WTF RO MEMBRANE Cleaning RO system mebranes with organic acid and F006,F019 Yes Ship offsite,rack storage or 106 N (24/106) S
F (10/24; 24/106)
E N
11___ TREATED METAL POWDERS Additive Manufacturing waste treated with mineral oil CR02, CR04, CR05 No 16, 22 Y GF & H
F (10/22; 22/106)
S Solubilization of toxic substance

GF Flammable gas generation
H Heat generation
Rack F
Incompatible RGN Pairs on this rack: 7/24; 24/106; 22/106

ID Rack Result
Industrial waste water treatment Sludges from Waste E N
11015 WTF SUMP SLUDGES F006,F019 No Rack-G Aqueous 24, 106 N (24/106) S
Treatment Plant. F (7/24; 24/106)
WTF, RO FILTERS, RO System water softener media, E N
11018 WTF Filtration media F006, F019 Yes Rack-G Aqueous 24 Y S
Evaporator salts F (7/24; 24/106)
E N
11029 FPS-1 FILTER PRESS SUMP WTF, Cleaning of collection sump for filter press F006,F019 No 24, 106 N (24/106) S
F (7/24; 24/106)
12002 FIBERGLASS DUST SANDING AND GRINDING OF FIBERGLASS PARTS N/A No 1A2/55 F NA Y Y NA
C
12012 CARBON & TEFLON FROM Dust cvollector from torit from cloud tower and N/A No 1A2/55, RACKS-DEF E 101 Y Y NA
F
N
12015 BRAZE POWDER & CEMENT Brazing, Cleaning out heat exchanger brazing N/A No 1A2 / Rack-E, Machine sludge F 24 Y S
(10/24; 24/106)
Machining, Armex Blast Media is blasted onto parts to
12024 SODIUM BI-CARB BLAST remove old paint, residues of oil, carbon etc. in preparation N/A No F NA NA Y NA
for painting.
N
12032 Nickel Catalyst Cubes No F 24 Y S
(7/24; 24/106)
12043 Non Haz Soil from Site Soil and debris generated from AECOMM site N/A No none F * * * NA
13020 TETRA-ETCH SOLUTIONS Teflon etching on space hardware. D001 D002 Yes Lab Pack Cabinet F 7, 101 Y N (7/24) S
15012 CONCRETE MAINTENANCE AND/OR RENOVATION (REMOVAL VARIES BY EVENT Yes F * * * NA
N
15023 MERCURY (SOLIDS- Scrapping of mercury containing devices and/or spill D009 Yes Lab Pack Cabinet F 24 Y S
(7/24; 24/106)
container used in disposal of rags and ppe contaminated

E N
15034 PPE, RAGS C/W MHS, ACIDS & ALKALINES with metal hydroxide sludge, sodium hydroxide , sodium F006, F019 Yes Rack-G Aqueous 24 Y S
F (7/24; 24/106)
bisulfite, sulfuric acid or ferrous sulfate.
16003 CARBON (AIR) Capturing of fugitive emissions from tanks. Carbon N/A No Rack-F Soils F 101 Y Y NA
16019 CARBON C/W ZYGLO FINAL EFLUENT FILTER FROM ZYGLO RINSEWATER N/A No 1A2/55 Rack-F F 101 Y Y NA
16050 ROCKHARD FILTER MEDIA Carbon unit using CP blend media 0812-0001 n/a No 1A1/55 Rack-F F 29, 101 Y Y NA
C
16056 RAGS C/W STANNIC Wiping excess stannic chloride solution after the N/A No 1A2/55, RACKS-DEF E 101 Y Y NA
F
C
16057 PAPER C/W CARBON & Trimmin excess carbon coating form hudson press N/A No 1A2/55, RACKS-DEF E 101 Y Y NA
F
Cleaning RO system mebranes with sulfamic acid and caustic E N
17036 WTF RO MEMBRANE F006,F019 Yes Ship offsite,rack storage or 24, 106 N (24/106) S
soda F (7/24; 24/106)
18086 HMI Nickel Powder & Water Laser Sintering of Various Metal Powders using N/A No Rack E/F F NA Y Y NA
E N
11___ TREATED METAL POWDERS Additive Manufacturing waste treated with mineral oil CR02, CR04, CR05 No 16, 22 Y GF & H
F (10/22; 22/106)
* depends, compatibility determined as needed

S Solubilization of toxic substance
GF Flammable gas generation
H Heat generation
Resin - SSC-5
Incompatible RGN Pairs on this rack: NA

ID Rack Result
OUTDATED NON-ISOCYANATE RESIN These resins are outdated/past shelf life, no longer needed Small quantities only storage requirements Desired
13007 CR05 NO 103
CLOSED CONT. or failed QC lab test reviewed for every item on receipt Rack
D003 Other codes reviewed as Small quantities only storage requirements

13008 Shopmaster RC and Spent TDI Resin FLUSHING OF FOAM MACHINE in Space Systems YES SSC-5 18,103 * * *
received reviewed for every item on receipt
U223, D003 Other code Small quantities only storage requirements

13009 Unused TDI Resin SCRAPPING OF UNUSED OUT OF SPEC OR UNWANTED CHEMICALS YES SSC-5 18 * * *
reviewed as received reviewed for every item on receipt
22003 NON DOT REGULATED LAB Mainly unused chemicals, small containers na No Lab Pack Cabinet LAB TC * * * *
* depends, compatibility determined as needed

ATTACHMENT (B)
INSPECTION SCHEDULE PLAN

ONE HAMILTON ROAD

ATTACHMENT L
Inspection Schedule and Log

WINDSOR LOCKS, CT
ATTACHMENT L
INSPECTION SCHEDULE
TABLE OF CONTENTS
Section Page
1. CURRENT INSPECTION PROGRAM 1
1.1 General Description 1

1.2 Inspection Schedule and Checklists 2
1.3 Hazardous Waste Facility Weekly Inspections 3
1.3.1 Weekly Inspection Checklist 3
1.3.2 Weekly Inspection Checklist, Non-Bulk Container Storage Areas 6
1.3.3 Spill Response Equipment Inspection Checklist 6
1.3.4 Vehicle Inspection Checklist 6
1.4 Hazardous Waste Facility Daily Inspections 7
1.4.1 Hazardous Waste Facility Daily Inspection Checklist 7
1.5 Subpart CC.Compliance Annual Inspection 9
1.5.1 Compactor Subpart CC Compliance Checklist 9
2. RECORD RETENTION 9
Attachments
EXHIBIT L-1 INSPECTION CHECKLISTS AND WORK INSTRUCTIONS
WINDSOR LOCKS, CT
ATTACHMENT L
INSPECTION SCHEDULE
As a permitted TDSF, Hamilton Sundstrand is required to have a written inspection

schedule in accordance with Regulations of Connecticut State Agencies (RCSA) section
22a-44(c)-104 incorporating by reference 40 CFR 270.14(b)(5) and 264.15(b).
1. CURRENT INSPECTION PROGRAM

The Hamilton Sundstrand Part B Permitted Hazardous Waste Facility (HWF) and
related options are routinely inspected to monitor compliance with applicable
regulations and to prevent the release hazardous waste constituents to the environment
and any threats to human health.
1.1 General Description

Hamilton Sundstrand personnel perform inspections at the HWF of the following:
hazardous and non-hazardous waste containers (including roll-off containers), non-
hazardous waste tanks, loading/unloading areas, waste management related
activities (such as the waste compactor), and emergency equipment and supplies.
The results of these inspections are recorded on inspection checklists. Copies of the
current inspection checklists are included in Exhibit L-1.
Information on the inspection checklists includes the inspector's name and signature, the
date and time of the inspection, items to be inspected, deficiencies found, and
observations or corrective actions. If a deficiency is noted, appropriate and complete
information is recorded, including a description of the problem, the nature of the repair or
remedial action needed and the time-frame the repair or corrective action is to be
conducted (non-emergency or immediate).
Non-emergency maintenance refers to repairs not immediately required to prevent a
threat to human health or the environment. If an inspection reveals that non-emergency
maintenance is needed, the corrective action will be implemented as soon as possible to
preclude further damage and reduce the need for emergency repairs. If a release to the
environment or threat of explosion occurs during the course of an inspection or any time
between inspections, the inspector will notify the Emergency Coordinator per the
Contingency Plan and remedial action will be immediately taken.
L.1
WINDSOR LOCKS, CT
1.2 Inspection Schedule and Checklists
Hamilton Sundstrand conducts inspections of waste management units (WMUs) in

accordance with the following schedule:
Inspection Name Inspection Type Frequency

HWF Weekly Inspection  1.3.1 — Weekly Inspection Checklist Weekly
(See Section 1.3)  Hazardous Waste Compactor
 Universal Waste
 Hazardous Waste Roll-off Storage Area
 Tote Drop-Off Area
 Containment System Condition
(Epoxy Coating)
 Emergency Equipment
 Perimeter Fence/Security
 J-Lot Inspection
 Non-flammable Compressed Gas Storage
Area
 Non-hazardous Waste Roll-off Storage
Area
 Housekeeping
 1.3.2 - Weekly Inspection Checklist, Non-Bulk
Container Storage Areas (Hazardous and Non-
hazardous Waste)
 1.3.3 - Spill Response Equipment
 1.3.4 - Vehicle Inspection
HWF Daily Inspection  1.4.1 — HWF Daily Inspection Checklist Daily*

(See Section 1.4)*  Tank Systems
 Tank Storage Areas
 Monitoring Equipment
 Sensors
 Loading/Unloading Areas
 Staging Area
 Pre-Transport Requirements
Subpart CC Compliance  1.5.1 - Compactor Subpart CC Inspection Annually
Annual Inspection Checklist
(See Section 1.5)
*Inspections are completed on normally scheduled operating days; Monday through

Friday, excluding weekends, company recognized holidays, and during adverse
weather conditions recognized by the Governor of Connecticut.
The types of inspections are described in more detail below.
L.2
WINDSOR LOCKS, CT
1.3 Hazardous Waste Facility Weekly Inspections
The weekly inspection of the HWF includes the completion of four inspection logs. The
first weekly inspection log documents compliance items for the hazardous waste
compactor area, universal waste storage area, waste container storage areas (including
roll-offs), the tote drop-off area, the facility containment system, emergency equipment,
the perimeter fence and J-Lot. The second inspection log documents compliance items
in specific non-bulk container storage areas (i.e., the eight storage racks, two lab pack
cabinets, and four storage sheds), The third weekly inspection log documents adequate
inventory of spill response equipment in the HWF vehicle, the spill rack, and the PPE
cabinet. The final weekly inspection log documents the HWF vehicle maintenance
items. Exhibit L-1 contains the work instructions inspection checklists for each of the
weekly inspection logs. Descriptions of each of the weekly inspections are presented
below.
1.3.1 Weekly Inspection Checklist
Below is an overview of each of the Weekly Inspection Checklist compliance inspection

items.
Hazardous Waste Compactor

The hazardous waste compactor will be inspected weekly to ensure the compactor
area is free of leaks and/or spills and that the compactor (including air emission
control system) is in good condition.
Universal Waste
Universal wastes at the HWF are inspected weekly to ensure:
 Containers/items are marked/labeled,

 Bulbs/mercury thermostats are in closed containers in good condition,
 Batteries are in containers and/or are in good condition,
 All materials are marked with an accumulation start date, and
 All materials are stored for less than one year.
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WINDSOR LOCKS, CT
Hazardous Waste Roll-off Storage Area

The roll-off area in the HWF is inspected weekly (when roll-off is present) to ensure:
 Containers are closed,

 Containers are in good condition (No signs of corrosion, bulging, dents,
leaks, or spills),
 Containers are marked and labeled properly,
 No evidence of release is present, and
 Adequate aisle space for container inspection and emergency response
Tote Drop-Off Area

The tote drop-off area in the HWF is inspected weekly (when totes are present) to
ensure:

leaks, or spills),
 Adequate aisle space for container inspection and emergency response,
 No spills or leaks are present in the area, and
 Adequate segregation of incompatible materials.
Containment System Condition (Epoxy Coating)

The containment system should be maintained in good condition and have no
visible cracks. The epoxy coating should have no visible signs of erosion.
Emergency Equipment
Emergency equipment in the HWF (fire extinguishers, personnel decontamination
equipment, required signage, emergency lighting) is inspected weekly to ensure it is
available and accessible. Fire extinguishers located at the facility are maintained
and tested by Emergency Services. Warning signs/postings, communications
equipment, and emergency lighting are included in the HWF weekly inspection.
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WINDSOR LOCKS, CT
Perimeter Fence/Security
The perimeter fence and gates are inspected to ensure they are in good condition
and locked when not being used. In addition, the doors to each of the waste
storage buildings and waste storage cabinets are inspected to ensure they are
operating properly.
J Lot Area
Non-hazardous storage units located in the J-Lot area will also be inspected
weekly for the items described below.
Non-flammable Compressed Gas Storage Area

Non-flammable compressed gas storage area will be inspected to ensure
that all cylinders stored in the area are for non-flammable gas, gas cylinders
are secure, and the perimeter fencing is locked.
Non-hazardous Waste Roll-off Storage Area

The non-hazardous waste roll-off area in J-lot is inspected weekly to ensure:

leaks, or spills),
 No evidence of release is present, and
 Adequate aisle space is provided for container inspection and emergency
response.
J-Lot Housing
The J-Lot will also be inspected for general housekeeping (i.e., clean,
uncluttered, free of debris).
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WINDSOR LOCKS, CT
1.3.2 Weekly Inspection Checklist, Non-Bulk Container Storage Areas
Below is an overview of each of the Weekly Inspection Checklist, Non-Bulk Container

Storage Areas compliance inspection items.
Container Storage Areas

Hazardous waste, non-hazardous waste, and PCB waste in the HWF are
inspected weekly to ensure:

leaks, or spills),
 Wastes are compatible with containers,
 Adequate segregation of incompatible materials,
 Adequate aisle space for container inspection and emergency response,
 Emergency equipment and communication equipment are readily available,
and
 Adequate general housekeeping.
Secondary Containment System

The secondary containment system of the container storage area is inspected
weekly for:
 Leaks or spills, and

 Deterioration or cracks present in the epoxy coating.
1.3.3 Spill Response Equipment Inspection Checklist
An inventory of spill response equipment is inspected weekly to ensure there is a

minimum amount of each spill response inventory item present and available for use in
the event of a release. The items are inspected against a list of equipment that is
described in the facility's Contingency Plan included as Attachment M.
1.3.4 Vehicle Inspection Checklist
The HWF spill response vehicle is inspected weekly to ensure the vehicle is in good
operating condition (e.g., proper fluid levels, proper operation of lights, horn, etc.) in the
event of an emergency.
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WINDSOR LOCKS, CT
1.4 Hazardous Waste Facility Daily Inspections
The daily inspection requirement is documented on a single inspection log. The

inspection log covers the tank systems (non-hazardous waste) including the tank
monitoring equipment and sensors associated with the pump systems and tank
containment sumps. Also included on the inspection log are compliance items for the
loading/unloading areas, the staging area, and pre-transport requirements for hazardous
waste containers offered for shipment. Exhibit L-1 contains the work instructions and the
inspection checklist for the HWF daily inspections. Daily inspections are completed on
normally scheduled operating days; Monday through Friday, excluding weekends,
company recognized holidays, and during adverse weather conditions recognized by the
Governor of Connecticut.
1.4.1 HWF Daily Inspection Checklist
Below is an overview of each of the HWF Daily Inspection Checklist compliance

inspection items.
Tank Systems
Below is an overview of each of the HWF Daily Inspection Checklist
compliance inspection items for the tank system.
Tank Storage Areas

The non-hazardous waste tanks are inspected daily, on operational days,
to ensure:
 The tanks are properly marked and labeled,

 The tank, piping and supports are in good condition (no evidence of
leaks or corrosion),
 There are no spills or leaks, and
 The secondary containment system has no signs of erosion and spills
Daily tank level readings are also recorded on the daily checklist.
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WINDSOR LOCKS, CT
Monitoring Equipment
Monitoring equipment is inspected daily, on operational days, to ensure
proper operation. The monitoring equipment included in the daily inspection
are:
 The high level alarms for each tank,
 The valve controls,
 The non-hazardous and combustible pump monitors, and
 The non-hazardous and combustible high/low monitor
Sensors
Liquid sensors are inspected daily, on operational days, to ensure proper
operation. The sensors included in the daily inspection are:
 The Packaging Room pumps (two units)
 The non-hazardous tank (Tank 121A) containment sump, and
 The used oil: non-hazardous combustible liquids/oils tank

(Tank 121B) containment sump.
Loading/Unloading Areas
The loading/unloading areas inspected include the southeastern and southwestern
entrances of the HWF and the waste tank offload pump and pumping stations.
Inspections of these areas confirm that there is no evidence of a spill or release
that occurred during loading/unloading events.
Staging Area
The Staging Area is used for waste being received at the HWF, prior to placement
in specific storage locations. The inspections are performed on days the Staging
Area is in use to confirm applicable requirements are met (i.e. capacity, length of
staging, aisle space, etc.).
Pre-Transport Requirements
On days that hazardous waste is offered for shipment from the HWF, the
containers being shipped are inspected to ensure the containers are stored in
DOT-compliant packaging for the waste and that the packages are marked and
labeled in accordance with RCRA and DOT requirements.
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1.5 Subpart CC Compliance Annual Inspection

The Subpart CC compliance annual inspections include the completion of one
inspection log. The inspection log documents 40 CFR 264 Subpart CC inspections for
the compactor unit. Exhibit L-1 contains the work instructions and the inspection
checklist for the unit requiring Subpart CC inspection. A description of the Subpart CC
inspection is presented below.
1.5.1 Compactor Subpart CC Compliance Checklist

The compactor requires annual assessment for 40 CFR 264 Subpart CC air emission
requirements to ensure volatile organics are not emitted to the atmosphere. A
photoionization detector (PID) or equivalent instrument will be used to monitor vapor
emissions from potential system release points (e.g., unit door, control devices).
Emission monitoring will be performed, at a minimum, on an annual basis.
It should be noted that as a permit requirement, Hamilton Sundstrand is required to
manage hazardous waste in containers meet the DOT requirements promulgated in 49
CFR 173 and 49 CFR 178. Since Hamilton Sundstrand does not perform stabilization
in containers nor use containers greater than 121 gallons in light materials service,
Subpart CC compliance requirements for containers outside the compactor area will be
met through the use of DOT-compliant containers.
2. RECORD RETENTION
Inspections are conducted and recorded as described herein and inspection records
are maintained as a component of the HWF Operating Record.
The inspection checklists may periodically be revised or reformatted, without changes to
the scope of the inspection. In the event Hamilton Sundstrand wishes to modify the
scope of the inspections or remove items identified in the current inspection checklists, a
permit modification will be formally requested.
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EXHIBIT L-1
INSPECTION CHECKLISTS AND WORK
INSTRUCTIONS
HWF Weekly Inspection Checklist and Work Instruction

HWF Weekly Inspection Checklist and Work Instruction – Non-Bulk Container Storage Areas
HWF Weekly Spill Response Equipment Inspection Checklist and Work Instruction
HWF Weekly Vehicle Inspection Checklist and Work Instruction
HWF Daily Inspection Checklist and Work Instruction
Annual HWF Subpart CC Compactor Compliance Checklist and Work Instruction
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Hamilton Sundstrand Corporation
Windsor Locks, Connecticut
HWF Weekly Inspection Checklist
Work Instruction
The Hazardous Waste Facility (HWF) Weekly Inspection Checklist is the document used to
document compliance with the storage units in the HWF listed below:
 Hazardous Waste Compactor Area
 Universal Waste
 Hazardous Waste Roll-off Storage Arena
 Tote Drop Off Area
 Containment System Condition (Epoxy Coating)
 Emergency Equipment
 Perimeter Fence/Security
 J-Lot Non-Flammable Compressed Gas Storage Area
 J-Lot Non-Hazardous Roll-off Storage Area
 J-Lot Housekeeping
For each of the above areas, a series of questions associated with the required inspection items
must be answered to document the status of the containers and/or the storage area. The questions
are presented below with the conditions along with guidance to properly answer the question.
Hazardous Waste Compactor Area
 Is there only one drum in use in the compactor area?
Verify there is only one drum located in the compactor area. If there is no more than one drum
in the compactor area, place a “” in the Status column. If there is more than one drum in the
compactor area, place an “X” in the Status column. Document the corrective actions taken and
the date the actions were completed at the bottom of the form.
Is the active drum closed?
Verify the container of hazardous waste is properly closed unless waste is physically being added
or removed. If the container is properly closed place a “” in the Status column. If the
container is observed not properly closed, place an “X” in the Status column and properly close
the container. Document the corrective actions taken and the date the actions were completed at
the bottom of the form.
 Is the area free of spills and/or leaks?
The compactor area must be checked for spills or leakage. Leakage must be cleaned up and, if
necessary, reported per WI 202. If the area is free of spills/leaks, place a “” in the Status
column. If there is evidence of spills or leaks, place an “X” in the Status column. Arrange to
have defective containers replaced. Remove the spill/leak/accumulated liquid immediately (must
be completed within 24 hours), including liquids resulting from precipitation. Clean any spill
residues with the solutions found in Tables III-1 or III-2 of the Permit as appropriate. Document
the corrective actions taken and the date the actions were completed at the bottom of the form.
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 Is the compactor in good condition (i.e., air emission controls in-place, compactor unit
functioning correctly)?
The compactor must close properly, have air emission controls in place (i.e., no gaps in the door
when closed, no gas in the exhaust piping, connected to a control device), and function in a
manner that prevents the release of hazardous waste or hazardous waste constituents to the
environment. If the compactor unit is in good condition and operating properly, place a “” in
the Status column. If the compactor unit exhibits a defect in the unit or exhaust system or is not
operating properly, place an “X” in the Status column. Document the corrective actions taken
and the date the actions were completed at the bottom of the form.
Universal Waste
 Are Universal Wastes (bulbs, batteries, mercury, e-waste) present? If yes:
o Are all containers/items marked and dated?
o Are all bulbs/mercury in closed containers and in good condition?
o Are all batteries in containers and/or in good condition?
o Are all materials stored <1 year from accumulation date?
Indicate whether universal waste is currently stored in the HWF. If universal wastes are in
storage, answer each of the additional questions. Enter a “” in the Status column for each
compliant item. Enter a “X” in the Status column for each non-compliant item. Document all
corrective actions taken and the date the actions were completed at the bottom of the form.
 Are Roll-offs containers presently in storage?
Indicate whether roll-off containers are present in the storage area. If yes, answer the subsequent
questions. If no roll-off containers are in storage, proceeded to the next section.
 Are all roll-off containers covered/closed?
All waste roll-offs must be closed with proper covers. Tarps must not be torn and doors must be
closed. The covers must be in good condition, fit properly and be in place, unless being used at
that time. If each of the containers is properly closed, place a “” in the Status column. If one
or more containers are observed not properly closed, place an “X” in the Status column and
properly close the container. Document the corrective actions taken and the date the actions
were completed at the bottom of the form.
 Is the roll-off container in good condition (No signs of corrosion, leaking, damage,
bulging, or otherwise in poor condition)?
Each waste roll-off must be checked to make sure it is in good condition and that corrosion has
not started. A dented or rusted container will be reported to the Environmental Operations for
corrective action. If the containers are in good condition, place a “” in the Status column. If
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one or more containers in a storage area are not in good condition, place an “X” in the Status
column and notify Environmental Operations to arrange to have the condition corrected.
Document the corrective actions taken and the date the actions were completed at the bottom of
the form.
 Is the roll-off marked with the words "Hazardous Waste" and other words describing
the waste (‘Plain Language”)?
Each hazardous waste roll-off container must be labeled with a hazardous waste label, as well as
other words to describe the waste. If each of the containers of waste in a storage area is
marked/labeled properly, place a “” in the Status column. If the containers are not marked
properly, place an “X” in the Status column and arrange to have the proper markings applied to
the container. Document the corrective actions taken and the date the actions were completed at
 Are roll-off markings/labels legible and visible for inspection?
Containers must be positioned in such a way that the label is immediately visible. If the
markings/labels are visible at the time of inspection, place a “” in the Status column. If the
markings/labels are not visible at the time of inspection, place an “X” in the Status column and
arrange to have the proper markings reapplied to the container or to have a new marking/label
applied. Document the corrective actions taken and the date the actions were completed at the
bottom of the form.
 Is the roll-off marked with Date Entered Storage (DES)?
All hazardous waste roll-off containers must have a Date Entered Storage (DES) clearly marked
and the label. Hazardous waste roll-off containers which have been accumulating hazardous
waste for 11 months from the DES on the label must be moved off site within 1 month. If the
accumulation start date is marked on each of the containers in storage, place a “” in the Status
column. If the containers are not marked with accumulation start date at the time of inspection
place an “X” in the Status column and arrange to have the containers marked with the
accumulation start date. Document the corrective actions taken and the date the actions were
completed at the bottom of the form.
 Is the area free of spills or leaks?
The roll-off container storage area must be checked for spills or leakage. Look completely
around each container checking the seams for any leakage. Always look around the bottom of
the container and on the floor surface for any leakage. Verify the HWF roof has no leaks that
would contribute to accumulated liquids. Leakage will be cleaned up and, if necessary, reported
per WI 202. If the area is free of spills/leaks, place a “” in the Status column. If there is
evidence of spills or leaks, place an “X” in the Status column. Arrange to have defective
containers replaced. Remove the spill/leak/accumulated liquid immediately (must be completed
within 24 hours), including liquids resulting from precipitation. Clean any spill residues with the
solutions found in Tables III-1 or III-2 of the Permit as appropriate.
In the event of a release to the environment, notify the HWF supervisor immediately and notify
all appropriate parties in accordance with WI 202.
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 Is there adequate aisle space around the roll-off to allow for the movement of personnel
and emergency equipment?
There must be a minimum aisle space of 30 inches between rows of containers to allow for
inspection of containers or mitigation of spills or leaks. If there is at least 30 inches of aisle
space present, place a “” in the Status column. If there is not at least 30 inches of aisle space,
place an “X” in the Status column and arrange to have the containers rearranged to provide
adequate aisle space. Document the corrective actions taken and the date the actions were
Tote Drop Off Area
 Are containers presently in storage? (Circle)
Indicate whether containers are present in the storage area. If yes, answer the subsequent
questions. If no containers are in storage, proceeded to the next section.
 Are all containers closed?
All waste containers must be closed with proper covers, unless waste is being added or removed.
If each of the containers is properly closed, place a “” in the Status column. If one or more
containers are observed not properly closed, place an “X” in the Status column and properly
close the container. Document the corrective actions taken and the date the actions were
 Are all containers in good condition (No signs of corrosion, leaking, damage, bulging, or
otherwise in poor condition)?
Verify each container in the storage areas is in good condition. Items to inspect include whether
containers exhibit signs of corrosion, leaking, damage, bulging, or are otherwise in poor
condition. If the containers are in good condition, place a “” in the Status column. If one or
more containers in a storage area are not in good condition, place an “X” in the Status column
and notify Environmental Operations to arrange to have the condition corrected. Document the
 Are containers storing hazardous waste marked with the words "Hazardous Waste"
and other words describing the waste (‘Plain Language”)?
Each hazardous tote container must be labeled with a hazardous waste label, with the words
“Hazardous Waste” as well as other words to describe the waste. If each of the containers of
waste in a storage area is marked/labeled properly, place a “” in the Status column. If the
containers are not marked properly, place an “X” in the Status column and arrange to have the
proper markings applied to the container. Document the corrective actions taken and the date the
actions were completed at the bottom of the form.
 Are all container markings/labels legible and visible for inspection?
markings/labels are not visible at the time of inspection place an “X” in the Status column and
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bottom of the form.
 Are all containers in storage marked with a DES date (Date Entered Storage)?
Verify that each container in storage is marked with the “Date Entered Storage” (DES). If the
DES is marked on each of the containers in storage, place a “” in the Status column. If the
containers are not marked with DES at the time of inspection, place an “X” in the Status column
and arrange to have the containers marked with the DES. Document the corrective actions taken
and the date the actions were completed at the bottom of the form.
 Is the container identification number written on all containers?
Verify that each container actively receiving waste is marked with container identification
number. If the container identification number is marked on each of the containers in storage,
place a “” in the Status column. If the containers are not marked with container identification
number at the time of inspection place an “X” in the Status column and arrange to have the
containers marked with the container identification number. Document the corrective actions
taken and the date the actions were completed at the bottom of the form.
 Is there adequate aisle space between containers to allow for the movement of personnel
There must be a minimum aisle space of 30 inches between rows of containers to allow for
inspection of containers or mitigation of spills or leaks. If there is at least 30 inches of aisle
space present, place a “” in the Status column. If this not is at least 30 inches of aisle space
completed at the bottom of the form
 Is the area free of spills, leaks, or accumulation of liquids?
Look completely around each container checking the seams for any leakage. Always look
around the bottom of the container and on the floor surface for any leakage. Leakage will be
cleaned up and, if necessary, reported per WI 202. If the area is free of spills/leaks, mark the
“Y” column. If there is evidence of, spill or leaks, mark the “N” column. Arrange to have
defective containers replaced. Remove the spill/leak/accumulated liquid immediately (must be
completed within 24 hours), including liquids resulting from precipitation. Clean any spill
residues with the solutions found in Tables III-1 or III-2 of the Permit as appropriate.
 Are containers storing incompatible materials segregated by a physical means (i.e.
walls, berms, containment devices, etc.)?
Incompatible materials (acids and alkali/cyanide) must be separated by a berm, dike, wall, other
means or a distance pre-approved by Environmental, Health and Safety so that incompatible
material does not come in contact. If the materials in stored in totes are adequately segregated,
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place a “” in the Status column. If the materials in stored in totes are not adequately
segregated, place an “X” in the Status column and arrange to have the container moved to be
adequately segregated. Document the corrective actions taken and the date the actions were
 Is the containment system in good condition (no cracks or erosion of coating)?
The purpose of the epoxy coated concrete floor and berm is to contain any released material into
the area and to prevent its release into the environment. Observe the entire area, checking the
floor and berm for damage, erosion or cracks and for deterioration of the epoxy coating.
If the coating is in good condition, place a “” in the Status column. If there is evidence of
damage, erosion, cracks or deterioration of the coating, place an “X” in the Status column.
Arrange to have containers in damaged areas relocated to prevent spills from impacting the
defective area. Clean any spill residues found with the solutions found in Tables III-1 or III-2 of
the Permit as appropriate. Repair the defect as soon as possible (must be completed within 30
days). Document all corrective actions taken and the date the actions were completed at the
bottom of the form. Documentation should include the date the defect was found, the date the
repair was made, the type of defect found, the method used to repair the defect, and the signature
of the person verifying the repair was completed.
Emergency/Spill Response Equipment
 Are fire extinguishers and decontamination equipment (eye wash and safety shower)
present and accessible?
Verify that all five fire extinguishers and decontamination equipment (eye wash stations, safety
showers) are present and accessible. If the equipment is present and accessible, place a “” in
the Status column. If any equipment is absent or inaccessible, place an “X” in the Status column.
the form.
 Is emergency communications equipment accessible and working (two-way
radios/telephone/intercom)?
Verify that the emergency communication equipment is in proper working order. If the
equipment is working properly, place a “” in the Status column. If the equipment is not
working properly, place an “X” in the Status column. Document the corrective actions taken and
the date the actions were completed at the bottom of the form.
 Are warning signs present and legible (“No Smoking, “Hazardous Waste Storage
Area”, “Unauthorized Personnel Keep Out”)?
Each entrance and perimeter fence line must have “No Smoking”, “Hazardous Waste Storage
Area”, and “Unauthorized Personnel Keep Out” signs. If the signs are present and legible, place
a “” in the Status column. If the signs are not present or are not legible, place an “X” in the
Status column. Document the corrective actions taken and the date the actions were completed
at the bottom of the form.
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 Are the fence and gates in good condition?

 Are locks present for each of the gates?
 Are gates locked when not in use?
The HWF is surrounded by a perimeter fence equipped with a locked gate. Each fence line must
be visually inspected for any abnormal conditions which would allow unauthorized personnel to
enter the area. Inspect the fence and gate to verify they are in good condition, and that locks are
present and in good condition. Gates must be locked when not in use. Enter a “” in the Status
column for each compliant item. Enter an “X” in the Status column for each non-compliant
item. For each “X” in the Status column, document the corrective actions taken and the date the
 Are the doors to the waste storage condos and waste storage cabinets operating
properly?
Verify that the doors to the waste storage condos and waste storage cabinets (i.e., lab pack,
oxidizers) are functioning properly and can be closed. If the doors to the waste storage units are
in good condition and operating properly, place a “” in the Status column. If the doors to the
waste storage units are not operating properly, place an “X” in the Status column. Document all
J-Lot Non-Flammable Compressed Gas Storage Inspection
 Are all cylinders non-flammable gas?
Only non-flammable refrigerant gases are permitted for storage in the J-Lot area. If all cylinders
in storage consist of non-flammable gases, place a “” in the Status column. If materials other
than non-flammable gases are stored, place an “X” in the Status column. Document all
 Are all cylinders secured so they will remain upright?
The compressed gas cylinders in storage must be secured against falling. If the cylinders are
secured, place a “” in the Status column. If the cylinders are not secured, place an “X” in the
Status column. Document all corrective actions taken and the date the actions were completed at
J-Lot Hazardous Waste Roll-off Storage Area
 Are Roll-off containers presently in storage?
Indicate whether roll-off containers are present in the storage area. If yes, answer the subsequent
questions. If no roll-off containers are in storage, proceeded to the next section.
 Are all roll-off containers covered/closed?
All waste roll-offs must be closed with proper covers. Tarps must not be torn and doors must be
closed. The covers must be in good condition, fit properly and be in place, unless being used at
that time. If each of the containers is properly closed, place a “” in the Status column. If one
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or more containers are observed not properly closed, place an “X” in the Status column and
properly close the container. Document the corrective actions taken and the date the actions
 Is the roll-off container in good condition (No signs of corrosion, leaking, damage,
bulging, or otherwise in poor condition)?
Each waste roll-off must be checked to make sure it is in good condition and that corrosion has
not started. A dented or rusted container will be reported to the Environmental Operations for
corrective action. If the containers are in good condition, place a “” in the Status column. If
one or more containers in a storage area are not in good condition, place an “X” in the Status
column and notify Environmental Operations to arrange to have the condition corrected.
the form.
 Is the roll-off marked with other words describing the waste?
Each hazardous waste roll-off container must be marked with words to describe the waste. If
each of the containers of waste in a storage area is marked properly, place a “” in the Status
column. If the containers are not marked properly, place an “X” in the Status column and
arrange to have the proper markings applied to the container. Document the corrective actions
 Is the area free of spills or leaks?
The roll-off container storage area must be checked for spills or leakage. Look completely
around each container checking the seams for any leakage. Always look around the bottom of
the container and on the floor surface for any leakage. Verify the roof has no leaks that would
contribute to accumulated liquids. Leakage will be cleaned up and, if necessary, reported per WI
202. If the area is free of spills/leaks, place a “” in the Status column. If there is evidence of
spills or leaks, place an “X” in the Status column. Arrange to have defective containers replaced.
Remove the spill/leak/accumulated liquid immediately (must be completed within 24 hours),
including liquids resulting from precipitation. Clean any spill residues with the solutions found
in Tables III-1 or III-2 of the Permit as appropriate.
 Are roll-off markings/labels legible and visible for inspection?
markings/labels are not visible at the time of inspection, place an “X” in the Status column and
bottom of the form.
 Is the roll-off marked with a DES?
All hazardous waste roll-off containers must have a Date Entered Storage (DES) clearly marked
Page 8 of 9
Work Instruction
on the label. Hazardous waste roll-off containers which have been accumulating hazardous
waste for 11 months from the DES on the label must be moved off site within 1 month. If the
accumulation start date is marked on each of the containers in storage, place a “” in the Status
column. If the containers are not marked with accumulation start date at the time of inspection
place an “X” in the Status column and arrange to have the containers marked with the
accumulation start date. Document the corrective actions taken and the date the actions were
 Is there adequate aisle space around the roll-off to allow for the movement of personnel
There must be a minimum aisle space of thirty (30) inches between rows of containers to allow
for inspection of containers or mitigation of spills or leaks. If there is at least 30 inches of aisle
space present, place a “” in the Status column. If there is not at least 30 inches of aisle space,
J-Lot Housekeeping
 Is the J-Lot area in good order (clean, uncluttered and free of debris)?
Verify the J-Lot area is clean and free of clutter and debris. If good housekeeping is observed,
place a “” in the Status column. If housekeeping deficiencies are observed, place an “X” in the
Status column. Document all corrective actions taken and the date the actions were completed at
Page 9 of 9
Non-Bulk Container Storage Areas
Work Instruction
The Hazardous Waste Facility (HWF) Weekly Inspection Checklist, Non-Bulk Container
Storage Areas is the document used to document compliance with the non-bulk container storage
units in the HWF listed below:
 Rack Storage Areas A through H
 Flammables Room
 Toxics Lab Pack Cabinet (Lab Pack Cabinet-Toxics/Other) – SSC-7
 Flammables Lab Pack Cabinet (Lab Pack Cabinet –Flammable) – SSC-3
 Acids Storage Shed (Bldg-AB) – SSC-2
 PCB/Resin Storage Shed (Buildings PB and RB) – SSC4 & SSC-5
 Alkaline or Cyanide Storage Shed (Bldg-CB) – SSC-1
 Water Building (Building WB) – SSC-6
For each of the non-bulk storage areas, a series of questions associated with the required
inspection items must be answered to document the status of the containers and/or the storage
area. The questions are presented below with the conditions along with guidance to properly
answer the question.
 Within maximum allowable waste quantities?
Verify the amount of waste in each storage area is at or below the maximum amount of waste
that may be stored. The maximum number of containers is provided in the second column of the
table. The maximum capacity in gallons is provided in the third column of the table. (Note: for
storage areas that list a maximum number of containers and a maximum capacity in gallons, the
number of gallons is equivalent to the maximum number of containers allowed at 55-gallons per
container). If the maximum number of containers and the maximum capacity in gallons are
below the thresholds, place a “” in the appropriate space. If the maximum number of
containers or the maximum volume capacity is exceeded, place an “X” in the appropriate space
and arrange the container storage so that no quantity limitations are exceeded. Document the
deficiencies found, corrective actions taken and the date the actions were completed at the
bottom of the form.
 Adequate aisle space?
Verify that there is at least 30 inches of aisle space in the storage areas to allow for inspection or
the movement of personnel and emergency equipment. If there is at least 30 inches of aisle
space in the area, place a “” in the appropriate space. If there is not at least 30 inches of aisle
space place an “X” in the appropriate space and arrange to have the containers rearranged to
provide adequate aisle space. Document deficiencies found, the corrective actions taken and the
date the actions were completed at the bottom of the form.
 Waste stored in appropriate rack/ cabinet/building (adequate segregation of
incompatibles and containers are grounded/bonded as applicable)?
Verify each container is marked with the correct code for the rack/cabinet/building where the
Page 1 of 3
Work Instruction
container is stored. This storage system is used to ensure that incompatible materials do not
come in contact with one another (e.g., acid and alkali/cyanide). Verify only PCB-contaminated
materials are stored in the PCB shed. Verify that all flammable containers requiring grounding
and bonding are grounded and bonded appropriately. If the label on each container indicates the
storage is appropriate for the area in which it is stored, place a “” in the appropriate space. If
one or more containers are located in an incorrect storage area, place an “X” in the appropriate
space and arrange to have the container moved to the correct storage area. Document
deficiencies found, the corrective actions taken and the date the actions were completed at the
bottom of the form.
 Containers closed?
Verify each container of hazardous waste is properly closed (no open lids, no loose or missing
bungs, ring bolts tightened, etc.) unless waste is physically being added or removed. If each of
the containers is properly closed, place a “” in the appropriate space. If one or more containers
are observed not properly closed, place an “X” in the appropriate space and properly close the
container. Document the container number(s), the deficiencies found, the corrective actions
 Containers in good condition?
Verify each container in the storage areas is in good condition. Items to inspect include whether
containers exhibit signs of corrosion, leaking, damage, bulging, or are otherwise in poor
condition. If the containers are in good condition, place a “” in the appropriate space. If one or
more containers in a storage area are not in good condition, place an “X” in the appropriate space
and notify Environmental Operations to arrange to have the condition corrected. Document the
container number(s), the deficiencies found, the corrective actions taken and the date the actions
 Proper marking/labeling, markings/labels in good condition, legible and visible?
Verify the following:
 Each container is labeled.
 Each container has the correct label.
 Each container of hazardous waste is marked with the words “Hazardous Waste” and other
words to describe the contents (i.e., “Plain language”).
 Each container in storage is marked with the “Date Entered Storage” (DES).
 Each container in storage is marked with a container identification number.
 Each container of PCB-bearing waste has a yellow PCB label affixed.
 Markings/labels on each container in storage are in good condition (not damaged or peeling).
 Markings and/or labels on each container in storage are visible during the inspection.
If each of the waste containers in a storage area is marked/labeled properly with the labels in
good condition and visible during the inspection, place a “” in the appropriate space. If the
containers are not marked properly, place an “X” in the appropriate space and arrange to have
Page 2 of 3
Work Instruction
the proper markings applied to the container. Document the container number(s), the
deficiencies found, the corrective actions taken and the date the actions were completed at the
bottom of the form.
 Containers approaching storage time limit?
Document containers of non-PCB waste that have a DES greater than 11 months or containers of
PCB waste that have a DES greater than 5 months, as these containers must be moved off-site
within 1 month. If the DES on each waste container indicates the waste does not require
shipment within the next month, place a “” in the appropriate space. If the DES on any waste
container indicates the waste requires shipment within the next month, place an “X” in the
appropriate space and note the container identification numbers requiring shipment within the
next month at the bottom of the form. Once the containers are shipped, document the shipment
date on the bottom of the form.
 Is container compatible with the waste stored?
Verify that each container is compatible with the waste that it is stored inside (e.g., no acids in
metal drums). If each of the containers is compatible with the waste stored, place a “” in the
appropriate space. If one or more containers are not compatible with the waste that is stored
inside, place an “X” in the appropriate space and arrange to have the waste transferred to a
compatible container. Document the container number(s), the deficiencies found, the corrective
actions taken and the date the actions were completed at the bottom of the form.
 Base is in good condition and free of spills/leaks/accumulated liquids?
Verify there is no evidence of corrosion or other deterioration of the epoxy coating on the floor
in each storage area. Verify there is no evidence of spills/leaks/accumulated liquids in each
storage area. If floor coating is in good condition, with no spills/leaks/accumulated liquids in the
area, place a “” in the appropriate space. If there is evidence of deterioration of the floor
coating or spills/leaks/accumulated liquids in the area, place an “X” in the appropriate space.
Arrange to have containers relocated to prevent spills from impacting the defective area. Clean
any spill residues found with the solutions found in Tables III-1 or III-2 of the Permit as
appropriate. Repair the defect as soon as possible (must be completed within 30 days).
Document deficiencies found, all corrective actions taken and the date the actions were
completed at the bottom of the form. Documentation should include the date the defect was
found, the date the repair was made, the type of defect found, the method used to repair the
defect, and the signature of the person verifying the repair was completed.
In the event of a release to the environment, notify the HWF supervisor immediately. The HWF
supervisor or designated personnel must notify all appropriate parties in accordance with WI
202.
Page 3 of 3
Inspector’s Name: Signature _
Date: Time: am pm
Instructions: Please use ink. Results of weekly inspections of must be recorded in this log. If the inspection item is
compliant, place a “” in the Status column. If the inspection item is non-compliant, place an “X” in the Status column. If
any deficiencies are found, a description of the deficiencies must be recorded in the "Observations" column. Prompt and
immediate action must be taken to correct any deficiencies observed. The date and the nature of all corrective actions must
be recorded in the "Corrective Actions and Date Completed" area.
Inspection Item Status Observations
Hazardous Waste Compactor Area
Is there only one drum in use in the compactor area?
Is the active drum closed?
Is the area free of spills and/or leaks?
Is the compactor in good condition (i.e. air emission controls in-
place, compactor unit functioning correctly)?
Universal Waste
Are Universal Wastes (bulbs, batteries, mercury, e-waste) present?
YES NO
If yes:
Are all containers/items marked and dated?
Are all bulbs/mercury in closed containers and in good
condition?
Are all batteries in containers and/or in good condition?
Are all materials stored <1 year from accumulation date?
Are Roll-offs containers presently in storage? (Circle)
YES NO
If yes, answer the following questions.
Are all roll-off containers covered/closed?
Is the roll-off container in good condition (No signs of corrosion,
leaking, damage, bulging, or otherwise in poor condition)?
Is the roll-off marked with the words "Hazardous Waste" and other
words describing the waste (‘Plain Language”)?
Are roll-off markings/labels legible and visible for inspection?
Is the roll-off marked with a Date Entered Storage (DES)?
Is the area free of spills or leaks?
Is there adequate aisle space around the roll-off to allow for the
movement of personnel and emergency equipment?
Tote Drop Off Area
Are containers presently in storage? (Circle)
YES NO
Are all containers closed?
Are all containers in good condition (No signs of corrosion, leaking,
damage, bulging, or otherwise in poor condition)?
Are containers storing hazardous waste marked with the words
"Hazardous Waste" and other words describing the waste (‘Plain
Language”)?
Are all container markings/labels legible and visible for inspection?
Are all containers in storage marked with a DES date (Date Entered
Storage)?
Is the container identification number written on all containers?
Is there adequate aisle space between containers to allow for the
Is the area free of spills, leaks, or accumulation of liquids?
Are containers storing incompatible materials segregated by a
physical means (i.e. walls, berms, containment devices, etc.)?
(Page 1 of 3)
Date: Time: am pm

Is the containment system in good condition (no cracks or erosion of
coating)?
Emergency Equipment
Are fire extinguishers and decontamination equipment (eye wash
and safety shower) present and accessible?
Is emergency communications equipment accessible and working
(two-way radios /telephone/intercom)?
Are warning signs present and legible (“No Smoking, “Hazardous
Waste Storage Area”, and “Unauthorized Personnel Keep Out”)?
Is the emergency exit light operating properly?
Are the fence and gates in good condition?
Are locks present for each of the gates?
Are gates locked when not in use?
Are the doors to the waste storage condos and waste storage cabinets
operating properly?
J-Lot Non-Flammable Compressed Gas Storage Inspection
Are all cylinders non-flammable gas?
Are all cylinders secured so they will remain upright?
J-Lot Non-Hazardous Roll-off Storage Area Inspection
Are Roll-offs containers presently in storage? (Circle)
YES NO
Are all roll-off containers covered/closed?
Is the roll-off in good condition (No signs of corrosion, leaking,
damage, bulging, or otherwise in poor condition)?
Is the roll-off marked with the words describing the waste?
Is the area free of spills or leaks?
Are roll-off markers/labels legible and visible for inspection?
Is the roll-off marked with a DES?
Is there adequate aisle space around the roll-off to allow for the
J-Lot Housekeeping
Is the J-Lot area in good order (clean, uncluttered and free of
debris)?
Describe Corrective Actions and Date Completed:
(Page 2 of 3)
Date: Time: am pm

Instructions:
Waste stored in appropriate

allowable waste quantities?
Base in good condition and

Is the container compatible
Waste approaching storage
Please use ink. Results of weekly inspections of must be recorded in this log. A “” indicates a
Proper marking/labeling,
Containers of Hazardous
containers are grounded/
(adequate segregation of
markings/labels in good
compliant condition for the inspection item. An “X” indicates a deficiency in the inspection item. If
bonded as applicable)?
with the waste stored?

Adequate aisle space?
rack/ cabinet/building
condition, legible and
accumulated liquids?
any deficiencies are found, a description of the deficiencies must be recorded in the “Describe
Containers in good
free of spills/leaks/
Containers closed?
incompatibles and
Within maximum
Deficiencies, Corrective Actions and Date Completed” area at the bottom of the log.
time limit?
condition?
Prompt and immediate action must be taken to correct any deficiencies observed. The date and the
visible?
nature of all corrective actions must be recorded in the “Describe Deficiencies, Corrective Actions
and Date Completed” area.
MAXIMUM MAXIMUM
COMMON WASTE
STORAGE AREA NUMBER OF CAPACITY
GROUP
CONTAINERS (GALLONS)
Rack - A 90 4,950 Ignitable/Combustible
Rack – B 90 4,950 Toxics
Rack – C 90 4,950 Toxics
Rack – D 90 4,950 Toxics
Rack – E 108 5,940 Toxics
Rack – F 108 5,940 Toxics
Rack – G 108 5,940 Toxics
Rack – H 36 1,980 Supplies or Toxics
Flammables Room 4 220 Ignitable/Combustible
Toxics/Other waste
Lab Pack Cabinet-Toxics/Other* (SSC-7) Varies 55
requiring segregation
Lab Pack Cabinet-Flammable (SSC-3) Varies 55 Ignitable/Combustible
Acids Bldg-AB (SSC-2) 24 1,320 Acids
PCB/Resin Bldg PB and RB (SSC-4 &
24 1,320 PCB/Resin
SSC-5)
Alkaline or Cyanide Bldg-CB (SSC-1) 24 1,320 Alkalines or Cyanide
Water Bldg WB (SSC-6) 24 1,320 Toxics
*Toxics or otherwise hazardous materials requiring segregation (provided that RGN’s are compatible)
Describe Deficiencies, Corrective Actions and Date Completed:
(Page 3 of 3)
Spill Response Equipment
Inspector’s Name: Signature:
Date: Time: am pm
Instructions for Inspectors:
Enter your name and the date and time of the inspection in the areas indicated above. Indicate for each inventory
item whether or not the minimum quantity is present. If the minimum inventory not present, indicate “” in the
“Min. Qty Present” column. If the minimum inventory is not present, indicate “X” in the “Min. Qty Present”
column and indicate the deficiency in the “Comments/Corrective Actions” column. Upon completion of the
inspection, sign the inspection form and submit to the HWF Supervisor.
Instructions for Supervisors:
Review the inspection form for deficiencies regarding the appropriate minimum quantity(s) present. If there is a
deficiency in any minimum quantity, indicate in the “Comments/Corrective Actions” area the date of the
corrective action was closed and include supporting information (e.g., order date, purchase order number). At the
completion of the review and implementation of the corrective actions found (if any), enter your name and sign
the inspection form.
Minimum Min. Qty
Inventory Item Comments/Corrective Action
Quantity Present?
HWF SPILL RESPONSE VEHICLE
Broom 1 each
Catch Basin Cover 1 each
Empty 5-gallon Pails with Lids 1 each
Garbage Bags (Box) 1 box
Shovel 1 each
Speedy Dry (Bag or Bucket) 1 each
Squeegee 1 each
Tyvek Suits 2 each
Spill Response Lock Box
Absorbent Socks 1 each
Caution Tape 1 each
Gloves 2 each
Labels and Travelers 1 each
pH paper 1 each
Spill Pads, Gray 5 each
Spill Pads, White 5 each
HWF SPILL RACK
Booties 5 each
Catch Basin Tubes/Hooks 2 each
Double Diaphragm Pump 1 each
Drip Pans & Pillows 1 box
Emergency Tote 1 each
Emergency Vacuum 2 each
Gloves, Nitrile 1 box
Hoses 2 each
Page 1 of 2
Spill Response Equipment
Inspector’s Name: Signature:
Date: Time: am pm
Minimum Min. Qty
Inventory Item Comments/Corrective Action
Quantity Present?
Push Brooms 4 each
Poly liners for Roll-offs 1 each
Shovels 4 each
Sodium Bicarbonate (Outside Unit) 1 Container
Speedy Dry 10 bags
Spill Booms (White Large) 4 each
Spill Matting, Gray 1 box
Spill Pads, Gray 1 box
Spill Pads, Pink 1 box
Spill Pads, White 1 box
Spill Socks, Gray/Blue 1 box
Spill Socks, Pink 1 box
Spill Socks, White 1 box
Sump Pump 1 each
HWF PPE CABINET
Aprons 4 each
Booties 2 each
Ear Plugs 1 box
Face Shields 4 each
Gloves, Leather 1 box
Gloves, Neoprene 1 box
Gloves, Nitrile 1 box
Level B Suits 2 each
Level C Suits 1 box
Mercury Cleanup Kit 1 box
Particulate Masks 1 box
pH Paper 1 box
Respirator Cartridges (Mercury/Chlorine) 2 each
Respirator Cartridges (Multi-gas) 2 each
Respirator Cartridges (Organic Vapor) 2 each
OTHER
Catch Basin Cover (Near Tank Transfer Station) 1 each
Page 2 of 2
HWF Weekly Vehicle Inspection Checklist
Vehicle Registration No. C 140435
Inspector’s Name: Signature
Date: Time: am pm
Instructions: Please use ink. Results of weekly inspections of must be recorded in this log. If the inspection item is
operating properly or in acceptable condition, place a “” in the Status column. If the inspection item is not
acceptable, place an “X” in the Status column. If any deficiencies are found, a description of the deficiencies must be
recorded in the "Observations" column. Prompt and immediate action must be taken to correct any deficiencies
observed. The date and the nature of all corrective actions must be recorded in the "Corrective Actions and Date
Completed" area. All repairs and fluid additions (excluding gasoline) to be performed by maintenance garage
personnel. Immediately notify supervisor of any defects found during inspection.
A copy if this inspection report must remain in the vehicle during the current week of operation.
Engine oil
Radiator (coolant)
Wipers and Windshield washer fluid
Defroster
Tires and Rims
Horn
Brakes and Parking Brake
Mirrors
Windshield
Headlights
Brake lights
Back-up lights
Parking Lights
Turn Signals
Hazard Flashers
Tail Lights
License Plate Light
Visible leaks, (e.g., oil, coolant, brake fluid)
Gas gauge Fuel Level: E 1/4 1/2 3/4 F
Registration
Insurance card
Safety Equipment Seat belts working properly Odometer Reading: ________________
Page 1 of 1
HWF Daily Inspection Checklist
Work Instruction
The Hazardous Waste Facility (HWF) Daily Inspection Checklist is the document used to document compliance
with the areas in the HWF listed below:
 Tank Storage Areas
 Tank Monitoring Equipment
 Tank System Sensors
 Loading and Unloading Areas
 Staging Area
 Pre-Transport Requirements
For each of the inspected areas, a series of questions associated with the required inspection items must be answered
to document the status of the containers and/or the storage area. The questions are presented below with the
conditions along with guidance to properly answer the question.
Inspections are completed daily on normally scheduled operating days; Monday through Friday, excluding
weekends, company recognized holidays, and during adverse weather conditions recognized by the Governor of
Connecticut.
TANK STORAGE AREAS (T-121A and T-121B)
 Are the tanks marked with the words describing the contents?
Verify the non-hazardous tank (T-121A) is marked with the words describing the contents. Verify the combustible
tank (T-121B) is marked with the words describing the contents and marked with the words “used oil”. If the tank is
marked properly, place a “” in the Status column. If the tank is not marked properly, place an “X” in the Status
column and arrange to have the proper markings applied to the tank. Document the corrective actions taken and the
date the actions were completed at the bottom of the form.
 Is the tank system in good condition, including piping and tank supports (No evidence of leaks or
corrosion)?
Each tank must be checked to make sure it is in good condition and that corrosion is not present. Also check the
tank supports to ensure they are not corroding, cracked or otherwise defective. Any issues must be documented and
reported to the Environmental Operations supervisor for corrective action. If the tank system is in good condition,
place a “” in the Status column. If the tank system is not in good condition, place an “X” in the Status column.
Document all corrective actions taken and the date the actions were completed at the bottom of the form.
 Is the area free of spills/leaks?

Each tank must be checked for spills/leakage. Look completely around each tank checking the seams for any
leakage, as well as the piping going to the pump stations. Always look around the bottom of the tank and on the
floor surface for any leakage and, if necessary, report leaks per WI 202. If the area is free of spills/leaks, place a
“” in the Status column. If there is evidence of spills or leaks, place an “X” in the Status column.
If a spill is detected within the tank containment area:
1. Immediately stop addition of waste and find the cause.
2. Within 24 hours (or if demonstrated at earliest practical time) remove as much waste from tank as needed to stop
leak and to allow repair. Major repairs require certification.
3. Remove spill immediately, or at least within 24 hours (includes precipitation)
4. If there is a release to the environment, notify the appropriate entities per WI 202 (within 24 hours to DEEP spill
division; within 15 days to enforcement division, unless < 1 pound and cleaned up immediately).
Page 1 of 4
Work Instruction
 Is the containment system in good condition (no cracks or erosion of coating)?
The purpose of the epoxy coated concrete floor and berm is to contain any released material and to prevent a release
into the environment. You must walk around the entire area checking the floor and berm for damage, erosion or
cracks, and for deterioration of the epoxy coating. You must make sure that the floor and berm will prevent any
liquid spillage from being released into the environment.
If the coating is in good condition, place a “” in the Status column. If there is evidence of deterioration of the
coating, place an “X” in the Status column. Clean any spill residues found with the solutions found in Tables III-1
or III-2 of the Permit as appropriate. Repair the defect as soon as possible (must be completed within 30 days).
Document all corrective actions taken and the date the actions were completed at the bottom of the form.
Documentation should include the date the defect was found, the date the repair was made, the type of defect found,
the method used to repair the defect, and the signature of the person verifying the repair was completed.
 Current Level? _________________

The level of each tank must be recorded in gallons. If a tank is full or near capacity, notify the Environmental
Operations supervisor.
MONITORING EQUIPMENT:
 Non-Hazardous and Combustible Tank Monitors

Verify the "High" alarm for each tank is off (Immediately notify foreman if a "High'" alarm is on the alarm screen).
Verify both the "Containment Sump Leak S1" and the "Interstitial Leak S2" alarms are in the alarm screen. If there
are no alarms present, place a “” in the Status column. If any of the alarms are present, place an “X” in the Status
column. Document all corrective actions taken and the date the actions were completed at the bottom of the form.
 Valve Controls
Verify the "Discharge Valve Control" switches are in the "Closed" position and green on the control panel for both
tanks. If the valve controls are in the correct position, place a “” in the Status column. If either of the controls is
in the incorrect position, place an “X” in the Status column. Document all corrective actions taken and the date the
 Non-Hazardous and Combustible Pump Monitor

In order to test the alarm panel, horn and light indicators, perform the following tasks:
1. Push the "Test" button.
a. The alarm should sound and control panel should read “test alarm”
2. Push the horn silence, "Alarm Reset" button and clear the alarm from the alarm screen
If each of the pump monitoring equipment alarms/LEDs functioned as designed during the test, place a “” in the
Status column for each test item. If any of the pump monitoring equipment alarms/LEDs functioned improperly
during the test, place an “X” in the Status column for each improper response. Document all corrective actions
SENSORS:
 Packaging Room Pump Stations

In order to test the packaging room pump stations and verify the waste tank leak detection system is operational,
perform the following tasks:
1. Lift the leak detection sensor in each pump station containment area.
a. Ensure the alarm sounds, red light is lit and alarm comes in on the Control Panel and Exterior
Strobe Light is “on”
Page 2 of 4
Work Instruction
2. Push the horn silence, "Alarm Reset" button and clear the alarm from the alarm screen
Note: When either tank reaches approximately 5,000 gallons, the tank "high" level alarm will light up and the airline
solenoid will deactivate the pump stations so no more waste can be pumped into the tank.
If each of the alarms systems functioned as designed during the test, place a “” in the Status column for each test
item. If any of the pump monitoring equipment alarms systems functioned improperly during the test, place an “X”
in the Status column for each improper response. Document all corrective actions taken and the date the actions
 T121A Top Tank Containment Sump

In order to test the non-hazardous tank containment sump sensor, perform the following tasks:
1. Lift the containment sump sensor located on the top of Tank 121A.
b. Push the horn silence, "Alarm Reset" button and clear the alarm from the alarm screen
 T121B Top Tank Containment Sump

In order to test the combustible tank containment sump sensor, perform the following tasks:
1. Lift the containment sump sensor located on the top of Tank 121B.
b. Push the horn silence, "Alarm Reset" button and clear the alarm from the alarm screen
If each of the alarm systems functioned as designed during the test, place a “” in the Status column for each test
item. If any of the pump monitoring equipment alarms/LEDs functioned improperly during the test, place an “X” in
the Status column for each improper response. Document all corrective actions taken and the date the actions were
LOADING AND UNLOADING AREAS
 Are the following areas free of spills, leaks, and accumulated liquids?
Check for spills, leaks, and accumulated liquids at the following loading/unloading areas:
 The asphalt surface and concrete flooring of the tanks offloading station;
 The southeast loading dock (outside of the packaging room);
 The southwest loading dock;
 The tank pumping stations in Packaging Room.
If a leak or spill is found, report as necessary per WI 202. If the areas are free of spills/leaks, place a “” in the
appropriate Status column. If there is evidence of, spill or leaks in one or more of the areas, place an “X” in the
Status column. Document all corrective actions taken and the date the actions were completed at the bottom of the
form.
If a spill is detected within the loading/unloading area:

1. Immediately stop loading/unloading operations and find the cause.
2. Remove spill immediately, or at least within 24 hours (includes precipitation)
3. If there is a release to the environment, notify the appropriate entities per WI 202 (within in 24 hours to DEP spill
division; within 15 days to enforcement division, unless < 1 pound and cleaned up immediately).
Page 3 of 4
Work Instruction
 Are wheel chocks located in the loading/unloading area?
Verify the wheel chocks are in place at the loading dock. If the wheel chocks are in place or are in use at the time of
the inspection, place a “” in the appropriate Status column. If the wheel chocks are missing, “X” in the Status
column. Document the corrective actions taken and the date the actions were completed at the bottom of the form.
STAGING AREA
 Is waste present in the Staging Area?

Document the presence or absence of containers in the staging area. If containers are present, proceed to answer the
subsequent questions. Place a “” in the Status column next to the subsequent questions to indicate the Staging
Area is in compliance for that inspection item. Place an “X” in the Status column next to the subsequent questions
to indicate the Staging Area is not in compliance for that inspection item. For each “X”, document the corrective
actions taken and date the actions were completed at the bottom of the form.
If no containers are present, no further evaluation of the Staging Area is required.
PRE-TRANSPORT REQUIREMENTS
 Will hazardous waste be offered for shipment today?
Document whether hazardous waste is scheduled for shipment on the day of inspection. If a shipment is scheduled,
ensure each container that will ship complies with the following requirements prior to shipment:
 Hazardous waste is packaged in appropriate UN-specification container(s) in accordance with 49 CFR 173 and
49 CFR 178.
 Containers are labeled in accordance with the requirements in 49 CFR 172 Subpart E (e.g., proper hazard class
labels).
 Containers are marked in accordance with the requirements in 49 CFR 172 Subpart D (e.g., the DOT proper
shipping name and identification number).
 Containers that are less than 110 gallons are marked with the following:
o “HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the
nearest police or public safety authority or the U.S. Environmental Protection Agency.”,
o Facility’s Name and Address,
o Facility’s EPA Identification Number, and
o The Manifest Tracking Number.
Place a “” in the Status column next to the subsequent questions to indicate the containers are in compliance for
that inspection item. Place an “X” in the Status column next to the subsequent questions if one or more of the
containers is not in compliance for that inspection item. For each “X”, document the corrective actions taken and
date the actions at the bottom of the form.
If no shipment is occurring on the day of inspection, no further evaluation of the pre-transport requirements is
required.
Page 4 of 4
HWF Daily* Inspection Checklist
Date: Time: am pm
*Inspections are completed daily on normally scheduled operating days; Monday through Friday, excluding weekends,
company recognized holidays, and during adverse weather conditions recognized by the Governor of Connecticut.
Please use ink. Results of daily inspections of must be recorded in this log. If the inspection item is compliant, place a “”
in the Status column. If the inspection item is non-compliant, place an “X” in the Status column. If any deficiencies are
found, a description of the deficiencies must be recorded in the "Observations" column. Prompt and immediate action must
be taken to correct any deficiencies observed. The date and the nature of all corrective actions must be recorded in the
"Corrective Actions and Date Completed" area.

Tank Storage Areas
121A-HWF Non-Hazardous Process Waters Tank
Is the tank marked with the words describing contents?
Is the tank system in good condition, including piping and tank
supports (No evidence of leaks or corrosion)?
Is the area free of spills/leaks?
coating)?
Current Level? _________________
121B-HWF Combustible Tank-Used Oil
Is the tank marked with the words describing contents?
Is the tank system in good condition, including piping and tank
supports (No evidence of leaks or corrosion)?
coating)?
Current Level? _________________
MONITORING EQUIPMENT
Non-Hazardous and Combustible Tank Monitors
“HIGH LEVEL” alarm is off for Tank 121A
““HIGH LEVEL” alarm is off for Tank 121B
“Containment Sump Leak ” and “Interstitial Leak ” sensors are not
in alarm condition
Valve Controls
T121A “Discharge Valve Control” switch is in the “Closed” position
and green on the control panel
T121B “Discharge Valve Control” switch is in the “Closed” position
and green on the control panel
Non-Hazardous and Combustible Control Panel
Verify the following occurs upon pushing the “Test” button
The alarm is present on the panel, horn sounds, red light is lit on
the panel, and Exterior Strobe Light is “on”
Page 1 of 3
Date: Time: am pm
SENSORS
Packaging Room Pump Stations
Verify the following occurs upon lifting the T121A waste tank leak
detection sensor
Verify the following occurs upon lifting the T121B waste tank leak
detection sensor
T121A Top Tank Containment Sump
Verify the following occurs upon lifting the leak detection sensor on
top of the T121A waste tank:
The alarm sounds, red light is lit on the Control Panel and
Exterior Strobe Light is “on”
T121B Top Tank Containment Sump
Verify the following occurs upon lifting the leak detection sensor on
top of the T121B waste tank:
Loading and Unloading Areas
Are the following areas free of spills/leaks/accumulated liquids?
Asphalt and concrete in front of the Tank Off-load Pump
Southeast Loading Dock
Southwest Loading Dock
Tank Pumping Stations in Packing Room
Are wheel chocks located in the loading/unloading area?
Staging Area
Is waste present in the Staging Area? YES NO
If yes, answer the following questions:
Has the material been stored area for less than 5 consecutive days
(including weekends)?
Is there at least 28 inches of aisle space between rows of
containers, labels facing out
Are the materials in the area compatible?
Are containers greater than 5 gallons staged in a single layer?
Page 2 of 3
Date: Time: am pm
Pre-Transport Requirements
Will hazardous waste containers be offered for shipment today? YES NO
If yes, answer the following questions regarding each container prior
to shipment:
Is each container shipped packaged in DOT-compliant
packaging for the waste?
Is each container labeled in accordance with DOT requirements
prior to shipment?
Is each container marked in accordance with DOT
requirements?
Is each container marked with the words “Hazardous Waste”,
generator name & address, and manifest tracking number?
Page 3 of 3
HWF Compactor Subpart CC Compliance Checklist
Work Instruction
The Hazardous Waste Facility (HWF) Compactor Subpart CC Compliance Checklist is the document
used to demonstrate compliance with the air emission requirements in 40 CFR 264 Subpart CC for
the compactor unit. A series of questions associated with the required inspection items must be
answered to document the compliance of the compactor unit. The questions are presented below
with the conditions along with guidance to properly answer the question.
 Calibration Gas Used (Concentration)
Indicate the calibration gas used. According to Method 21 of 40 CFR 60 Appendix A as referenced
in 40 CFR 264 Subpart CC, the calibration gas must be either methane or n-Hexane. Indicate the gas
concentration in parentheses.
 Background VO Concentration: ________________
Take a VO reading of the ambient air in the area of the compactor (approximately 6-12 feet away).
Record the value in the space provided.
 Do the waste streams entering the compactor unit have ≥ 500 ppm by weight volatile
organics
40 CFR 264 Subpart CC regulations are only applicable to waste streams that have a volatile
organics (VO) concentration of 500 parts per million (ppm) or more. If the waste managed in the
compactor has a VO concentration of 500 ppm of more, place a “” in the Status column. If the
waste managed in the compactor does not have a VO concentration of 500 ppm or more, place an
“X” in the Status column, and indicate in the waste is not subject to Subpart CC requirements at the
bottom of the form.
 Are the following areas free of gaps, spaces or other openings:
Visually inspect the compactor door when closed, the piping leading from the compactor to the
carbon vessel and the carbon vessel for signs of gaps, spaces or other openings. If no gap, spaces or
other openings are found in the inspected items, place a “” in the Status column. If gaps, spaces or
other openings are found in the inspection items, place an “X” in the Status column, and document
the corrective actions performed and the date completed at the bottom of the form.
 During compactor operation, record maximum VO readings from the following areas:
Record the maximum VO concentrations at the following locations on the compactor unit:
o Along the interface of the compactor door and compactor unit,
o Along the perimeter of any piping joints, and
o At the outlet of the carbon unit.
If a leakage is indicated along any of the units, slowly sample the interface where leakage is
indicated and until the maximum reading is obtained. Record the maximum reading in the space
provided.
 Is each of the readings less than 500 ppm above background?
Subtract the background VO concentration from the maximum VO concentration found for each area
inspected. If each of the corrected readings is less than 500 ppm, place a “” in the Status column.
If any of the corrected readings is 500 ppm or more, place an “X” in the Status column. Indicate at
Page 1 of 2
Work Instruction
the bottom of the form the locations that exhibited VO emissions of 500 ppm or greater, and the date
and time of the corrective action. Corrective actions must be initiated within 5 days, but must be
completed within 45 days.
Page 2 of 2
Date: Time: am pm
Instructions: Please use ink. Results of weekly inspections must be recorded in this log. If the inspection item
is compliant, place a “” in the Status column. If the inspection item is non-compliant, place an “X” in the Status
column. If any deficiencies are found, a description of the deficiencies must be recorded in the "Observations"
column. Prompt and immediate action must be taken to correct any deficiencies observed. The date and the
nature of all corrective actions must be recorded in the "Corrective Actions and Date Completed" area.
Calibration Gas Used (Concentration):
Background VO Concentration: ________________
Do the waste streams entering the compactor unit have ≥ 500 ppm by
weight volatile organics?
Are the following areas free of gaps, spaces or other openings:
Compactor Door (when closed)?
Piping between the compactor outlet and carbon unit?
Carbon Canister?
During compactor operation, record maximum VO readings from the
following areas:
Compactor Door ppm
Piping joints between the compactor outlet and carbon unit ppm
Carbon Canister outlet ppm
Is each of the readings less than 500 ppm above background?
Page 1 of 1
ATTACHMENT (C)
PERSONNEL TRAINING PLAN

ONE HAMILTON ROAD

ATTACHMENT O
Personnel Training
WINDSOR LOCKS, CT
ATTACHMENT O
PERSONNEL TRAINING
TABLE OF CONTENTS
Section Page
1. TRAINING PROGRAM DESCRIPTION .................................................................... 1
1.1 Job Title/Job Description .............................................................................. 1
1.2 Training Content and Techniques ................................................................ 1
1.3 Training Implementation ............................................................................... 2
1.4 Relevance of Training to Job Position .......................................................... 3
1.5 Training for Emergency Response ............................................................... 3
2. TRAINING FREQUENCY AND DOCUMENTATION ................................................. 4
Attachments
EXHIBIT O-1 HWF JOB TITLES AND DESCRIPTIONS
EXHIBIT O-2 DETAILED DESCRIPTIONS OF TRAINING COURSES
EXHIBIT O-3 TRAINING PLAN
O.i
WINDSOR LOCKS, CT
ATTACHMENT O
PERSONNEL TRAINING
This attachment of the permit renewal application discusses the personnel training
program in effect at Hamilton Sundstrand’s Windsor Locks facility for personnel who
have job responsibilities relating to the handling of hazardous waste in accordance with
RCSA 22a-44(c)-104 incorporating by reference 40 CFR 270.14(b)(12) and 264.16.
1. TRAINING PROGRAM DESCRIPTION

40 CFR 264.16(a)(1)
Hamilton Sundstrand’s hazardous waste training program is designed to ensure that all
facility personnel with hazardous waste responsibilities and duties have been trained to
perform these functions in a way that ensures the facility’s compliance. Training is both
a regulatory obligation and a method to assist with maintaining compliance.
Hamilton Sundstrand has instituted a program to train new employees and to provide
continuing training for all employees who manage hazardous wastes. The purpose of
the training is to prepare personnel to operate and maintain the Hazardous Waste
Facility (HWF) in a safe and compliant manner.
The training program consists of both classroom and on-the-job training to instruct
personnel on proper performance of their duties. The training program is designed to
train personnel in the safe storage, handling, and management of hazardous waste and
the applicable environmental regulations and requirements of the permit.
1.1 Job Title/Job Description

40 CFR 264.16(d)(1) and (2)
The job titles and job descriptions for HWF personnel involved with hazardous waste
management operations are identified in Exhibit O-1 at the end of this section. This
information, along with the name of the employee filling each job title is maintained in
the training documentation (See Section 2).
1.2 Training Content and Techniques

40 CFR 264.16(d)(3)
Hamilton Sundstrand conducts a variety of training courses for its employees. Most of
these are conducted onsite and all are conducted by qualified staff. Occasionally an
outside organization is contracted to present a seminar or demonstrate hands-on
techniques. A brief summary of the courses are presented below (detailed descriptions
are included in Exhibit O-2).
1. General Hazardous Waste Awareness Training:
O.1
WINDSOR LOCKS, CT
Hazardous Waste Awareness Training is held several times a year for new and
existing employees who are involved in handling hazardous waste. Refresher
training is held annually. Some of the topics covered in the program include an
overview of applicable environmental regulations, waste management
procedures and emergency reponse procedures (including evacuation).
2. Hazardous Waste TSDF Training:
Targeted towards employees who handle waste within the HWF. This training
includes a comprehensive review of hazardous waste regulations and RCRA Part
B requirements for the facility. This training may include specialized offsite
training for certain personnel to include new/updated techniques or important
regulatory changes.
3. Hazardous Waste Operations and Emergency Response (HAZWOPER)
Training:
Consistent with 40 CFR 264.16(a)(4), emergency response training for facility
employees includes training in accordance with Occupational Safety and Health
Administration (OSHA) Section 29 CFR 1910.120(p)(8) and 1910.120(q). This
training is administered to employees who respond to releases of hazardous
substances, including Emergency Coordinators and Waste Handlers.
4. Hazardous Material Transportation (DOT) Training
Personnel who are responsible for DOT compliance (hazardous materials and
hazardous waste), including container packaging and marking, vehicle
placarding, and offering hazardous waste for transportation, complete DOT
training for shippers/offerors. This training is prepared and presented in
accordance with 29 CFR 172 Subpart H.
5. Contingency Plan Training for Emergency Coordinators
For personnel identified as Emergency Coordinators in the Contingency Plan.
This training is administered to provide an understanding of when to implement
the Contingency Plan and the responsibilities of the emergency coordinators.
1.3 Training Implementation

40 CFR 264.16(a)(2)
A tabulated training plan by job title is presented as Exhibit O-3. The training plan is
implemented by persons trained in hazardous waste management procedures and
includes instruction which teaches facility personnel hazardous waste management
procedures (including contingency plan implementation) relevant to the positions in
which they are employed.
General Hazardous Waste Awareness Training is performed by qualified personnel

from the EH&S Department and refresher training is provided by each business unit’s
O.2
WINDSOR LOCKS, CT
EH&S Coordinator. The training, developed by the EH&S Department, is provided via
an electronic training program.
Hazardous Waste TSDF Training is performed by qualified personnel from the EH&S
Department.
HAZWOPER Training is performed by qualified outside contractors such as the

Connecticut Fire Training Academy or inside personnel from the Emergency Services
Department. Note: The Emergency Services Department also presents courses and
demonstrations on fire prevention/fighting techniques.
DOT Training is conducted by qualified outside contractors familiar with the

requirements for offering/shipping hazardous waste, including shipping paperwork and
manifests.
Contingency Plan Training for Emergency Coordinators is performed by qualified

Hamilton Sundstrand employees or outside contractors.
1.4 Relevance of Training to Job Position

40 CFR 264.16(a)(2)
All personnel involved with managing the HWF are given broad instruction including
annual hazardous waste TSDF training, Hazwoper training and DOT training for
offerors/shippers. Personnel are instructed in both preventive procedures and
contingency procedures in the event that a spill or problem occurs. Details of the course
materials and actual training plan are included in Exhibits O-2 and O-3.
1.5 Training for Emergency Response

40 CFR 264.16(a)(3)
The training program has been designed to ensure that facility personnel are able to
respond effectively to emergencies. Training content includes emergency procedures,
emergency equipment, and emergency systems, including, where applicable:
(i) Procedures for using, inspecting, repairing, and replacing facility emergency
and monitoring equipment;
(ii) Key parameters for automatic waste feed cut-off systems;
(iii) Communications or alarm systems;
(iv) Response to fires or explosions;
(v) Response to ground-water contamination incidents; and
(vi) Shutdown of operations.
The Hazwoper course includes a review of the Site’s Contingency Plan. The
Contingency Plan describes the alarm system, communications equipment, fire fighting
O.3
WINDSOR LOCKS, CT
equipment, and other emergency equipment. It describes onsite response measures,

evacuation procedures, availability of local response agencies, and local clean-up
procedures. Additionally, internal and external emergency phone numbers are listed.
The training programs also instruct employees in the correct procedures for use of
emergency self-contained breathing apparatus (SCBA)/protective gear, ppe, use of
monitoring equipment, and emergency alarms.
2. TRAINING FREQUENCY AND DOCUMENTATION

40 CFR 264.16(b), (c) and (d)
All pertinent employees receive training within six months of employment, transfer to the
facility or to a new position at the facility. Employees attend refresher courses and
complete on-the-job training annually. No new employee will work in the management of
hazardous wastes unsupervised until he/she has completed the requisite training.
Training records include the names of each employee filling a HWF job description as
well as records that document the training dates and content. These records, including
employee course completion logs with names and signatures, are maintained in the
EH&S Department. All records are maintained indefinitely for current employees, and/or
a minimum of three years from an employee’s last day of service.
The training plan included in Exhibit O-3 includes the names of personnel currently
filling the applicable job descriptions. In the event that personnel change and notification
is not required (i.e. no substanative change to the compliance program or plans, such
as the Contingency Plan), the training plan will be updated but a permit modification will
not be required. If a personnel change affects the compliance programs for the site (i.e.
Emergency Coordinators) this information will be updated in the appropriate plans and
documents, a permit modification will be filed with the DEEP, and other applicable
agencies will be notified.
O.4
WINDSOR LOCKS, CT
EXHIBIT O-1
HWF JOB TITLES AND DESCRIPTIONS
O.5
WINDSOR LOCKS, CT
Emergency Response Coordinator
Job Function Category: Contingency Plan Emergency Response Coordinator (primary

and alternate).
Job Description: The following information can be supplemented by company Job

Descriptions obtained from the Human Resources department, using the applicable
employee job code.
Typical Duties Include:
 Contingency Plan Implementation

 Activates internal alarms or communications systems (as applicable).
 Notifies state or local agencies if their help is needed.
 Identifies the character, exact source, amount, and extent of released
material.
 Assesses possible hazards to human health or the environment.
 Notifies local authorities if evacuation may be advisable and notifies the
National Response Center or the on-scene coordinator for the geographical
area.
 Takes all reasonable measures necessary to ensure that fires, explosions,
and releases do not occur, recur, or spread to other hazardous waste.
 Monitors for leaks, pressure buildup, gas generations, or ruptures in valves,
pipes, or other equipment, if the facility stops operations.
 Provides for treating, storing, or disposing of recovered waste contaminated
soil or surface water, or any other material, immediately following the
emergency.
 Ensures all emergency equipment listed in the contingency plan is cleaned
and fit for its intended use before operations are resumed.
 Informs owner/operator so she/he can notify the Director or Commissioner
and appropriate local authorities that cleanup procedures are complete and
equipment has been decontaminated.
 Records the date and time and details of the incident in the Operating
Record.
O.6
WINDSOR LOCKS, CT
Hazardous Waste Management Personnel
Job Function Category: Hazardous Waste Management Personnel include those staff
whose job responsibilities include compliance with the hazardous waste regulations and
operation/compliance of the HWF. This may include Environment, Health & Safety
Professionals, Managers, or Supervisors.

employee job code.
 Reviews regulations associated with hazardous waste management and

determines requirements to ensure compliance.
 Develops plans such as contingency, closure, and waste analysis.
 Develops and assists in the implementation of procedures for the handling,
storage, sampling, inspection, and transportation of hazardous wastes.
 Maintains operating record and compiles and submits regulatory reports,
including biennial report.
 Supports hazardous waste training program through technical guidance, course
development, and/or delivery.
O.7
WINDSOR LOCKS, CT
Hazardous Waste Handler
Job Function Category: Hazardous Waste Handlers include staff that work in the
hazardous waste facility and are responsible for day-to-day operations involving waste
management, storage and shipment.

employee job code.
 Issues empty containers for the collection of hazardous waste.

 Moves hazardous waste from point(s) of generation to the RCRA Part B
permitted facility.
 Ensures containers in HWF are labeled, closed and in good condition
 Ensures HWF is maintained in a compliant manner, including aisle space,
housekeeping, markings/signage, etc.
 Operates waste compactor
 Inspects waste storage areas (including hazardous waste, used oil, universal
waste and non-hazardous Connecticut regulated waste)
 Loads waste onto trucks for transport to offsite Treatment, Storage, and
Disposal Facilities (TSDFs).
O.8
WINDSOR LOCKS, CT
EXHIBIT O-2
DETAILED DESCRIPTIONS OF TRAINING COURSES
O.9
WINDSOR LOCKS, CT
General Hazardous Waste Awareness Training
Target Audience:
The training is typically presented in a single classroom session. The intent is to
train employees working in various production areas (shop floor employees) on the
regulations applicable to their position. This includes employees within a business
unit who generate and handle hazardous waste in satellite containers of <90 day
accumulation areas.
Instructors:
Site Environmental, Health and Safety including Environmental Operations:
Environmental Coordinators for the business units. This training is also provided
electronically via an online training program. Training content in the electronic
version was developed by the EH&S Department, and it contains the same content
as in-person training.
Course Frequency and Length:
Annually: 1-2 hours
Materials:
Slides include the following topics:
o Overview of applicable environmental regulations

o Discussion of hazardous properties of the chemicals managed at the
facility, including waste type
o Waste container handling and management
o Waste container labeling and storage
o Waste management procedures
o Emergency response procedures (including evacuation)
O.10
WINDSOR LOCKS, CT
Hazardous Waste TSDF Training
Target Audience:
This training in provided to employees who work in the permitted Hazardous Waste
Management Facility (including Hazardous Waste Handlers and their management).
Instructors:
Site Environmental, Health and Safety including Environmental Operations
supervisor or outside consultant.
Annually; 2 hours
Materials:
Slides and materials describing the specific requirements of the RCRA hazardous
waste regulations and the permitted facility including:
o Waste Determinations
o Waste Minimization
o Container Management
o Security
o Inspection Requirements
o Special Requirements
o Ignitable/Reactive Wastes
o Universal Wastes
o Used Oil
o Compactor Management
o Non-hazardous/Connecticut Regulated Wastes
o Preparedness/Prevention and Contingency Plan
o Shipping Paperwork and Records and DOT compliance
o Operating Record
o Post Emergency Actions (including inspection and repair of facility)
O.11
WINDSOR LOCKS, CT
Hazardous Waste Operations and Emergency Response (HAZWOPER) Training
OSHA 29 CFR 1910.120
Target Audience:
This training is provided to employees who respond to releases or potential releases

of hazardous substances including Primary and Alternate Emergency Coordinators
and hazardous waste personnel and handlers.
Instructors:
All trainers must have received training at the hazardous materials technical level
(1910.120) and have successfully completed a train the trainer course at the
operational level (1910.120), or they shall have training and/or academic credentials
and instructional experience necessary to demonstrate competency in the subject
matter.

Initial training- 40 hrs; annual refresher- 8 hrs.
Materials:
Training materials are designed to meet the requirements of 29 CFR Part 1910.120,
including the following.
• Site-specific emergency response procedures and personnel roles and
responsibilities.
• Safety, health and other hazards present on the site (including hazardous
waste)
• Use of personal protective equipment
• Shutdown of critical equipment
• Medical surveillance requirements including recognition of symptoms and
signs which might indicate over exposure to hazards
• Decontamination procedures specific to the site
• Emergency response plan including the necessary PPE and other equipment
required to safely respond to an emergency
• Spill control procedures
• Procedures for using, inspecting, repairing, and replacing facility emergency
and monitoring equipment;
• Communications or alarm systems
• Other emergencies (including medical)
O.12
WINDSOR LOCKS, CT
Hazardous Material Transportation (DOT) Training

49 CFR Part 172 Subpart H
Target Audience:
This training is provided to employees who are responsible for DOT compliance
(hazardous materials/waste), including container packaging and marking, vehicle
placarding, and offering hazardous waste for transportation (i.e. manifesting).
Instructors:
All trainers must have ꞏreceived DOT training for shippers/offerors and must be
experienced in 49 CFR 171-173 regulations.

Initial training- 8hrs: refresher (once every three years) – 4 hrs.
Materials:
Training materials are developed in accordance with 49 CFR Part 172 Subpart H and
including the following.
• DOT Hazardous Materials Overview and Hazardous Materials Table
• DOT Segregation Chart
• General Awareness & Familiarization
• Shipping Paperwork and Manifests
• Function Specific Issues
• Safety
• Registration
• Enforcement
• Recent Changes
• Security
• Hazardous Materials Incident Report and Preparation Guide
O.13
WINDSOR LOCKS, CT
Contingency Plan Training for Emergency Coordinators

40 CFR Part 172 Subpart H
Target Audience
This training is provided to employees who are named in the facilities hazardous
waste Contingency Plan as Emergency Coordinators.
Instructors
Instructors can include EH&S Professionals, in-house training representatives, or a

contractor.
Annually, 1 hr
Training is designed to provide an understanding of when to implement the plan and
responsibilities of emergency coordinators
 Overview of hazardous wastes handled at facility
 Locations of emergency equipment
 Incident Command System
 Notification Procedures
 Guidelines for implementation of Contingency Plan
 Responsibilities of the Emergency Coordinator
O.14
WINDSOR LOCKS, CT
EXHIBIT O-3
TRAINING PLAN
O.15
WINDSOR LOCKS, CT
RCRA Part B HWF Training Plan
Job Titles
Course Name Shop Floor Hazardous Waste

Hazardous Waste Emergency
Employees Management
Handler Coordinator
Personnel
General Hazardous
Waste Awareness X X X X
Hazardous Waste
TSDF Training X X X
HAZWOPER Training X X X
49 CFR DOT Training X X
Contingency Plan for

X
Emergency Coordinators
Notes:
General Hazardous Waste Awareness training has been listed for reference only. This training is not critical to HWF
operations or Part B permit compliance, it is provided to all shop floor employees as part of the new hire process.
Other training which is not included in this training plan may also be received by hazardous was management personnel,
handlers and emergency coordinators. This training may include OSHA and DOT requirements applicable to their job
functions including Powered and Industrial Vehicles, Hazardous Materials Training, Confined Space Entry, etc.
O.16
WINDSOR LOCKS, CT
RCRA Part B HWF Training Plan
Job Title Names of Staff Currently Filling Positions*
Shop Floor Employees Names have not been included. Shop Floor employees do not perform activities
in the HWF, their responsibilities are limited to generation and collection of
waste on the shop floor only. This is awareness training and is listed here for
reference only. This training is managed under a separate program.
Hazardous Waste
Mark Rainone, Environmental Operations Manager
Management Personnel
Jeannie St. Hilaire, Hazardous Waste Facility Supervisor
Hazardous Waste Handler Douglas Burkholder, Hazardous Waste Handler
Gary White, Hazardous Waste Handler
Chris Joyal, Hazardous Waste Handler
Emergency Coordinator Primary: Jeannie St. Hilaire, Hazardous Waste Facility Supervisor
Alternate: Mark Rainone, Environmental Operations Manager
Alternate: Andy Kulas, Emergency Services Manager
Note:
Staff other than those listed above may be designated to receive the training courses specified in the plan. Staff listed are
those responsible for implementation and compliance of the RCRA Part B permit and HWF.
*Table is current as of March 2020. In the event that personnel change and notification is not required (i.e. no substantive
change to the compliance program or plans, such as the Contingency Plan), the training plan will be updated but a permit
modification will not be required. Names of Staff Currently Filling Positions will be updated and recorded in the operating
record of the HWF as necessary. If a personnel change affects the compliance programs for the site (i.e. Emergency
Coordinators) this information will be updated in the appropriate plans and documents, a permit modification will be filed
with the DEEP, and other applicable agencies will be notified.
O.17
ATTACHMENT D
CONTINGENCY PLAN
(INTEGRATED CONTINGENCY PLAN)

ONE HAMILTON ROAD

WINDSOR LOCKS, CT
ATTACHMENT M
HAZARDOUS WASTE CONTINGENCY PLAN
Hamilton Sundstrand
1 Hamilton Road
Windsor Locks, Connecticut 06096
March 2020
M.i
WINDSOR LOCKS, CT
Table of Contents
Page
1. INTRODUCTION 1
1.1 Purpose and Scope 1

1.2 General Facility Description 1
1.3 Description of Industrial Activity 1
1.4 Waste Inventory and Storage Locations 2
2. EMERGENCY RESPONSE PLAN 5
2.1 Emergency Coordinators 5

2.2 Duties and Responsibilities of the Coordinator 5
3. SPILL AND LEAK PREVENTION 7
3.1 Preventative Measures 7

3.2 Special Material Storage Considerations 8
3.3 Material Compatibility 9
3.4 Inspection and Monitoring Program 9
3.5 Housekeeping Program 10
3.6 Emergency Power/Backup 10
3.7 Employee Training Program 11
3.8 Security 12
4. EMERGENCY RESPONSE PROCEDURES 14
4.1 Implementation 14
4.2 Countermeasures 15
4.2.1 Incidental Spills 15
4.2.2 Non-Incidental Spills 15
4.2.3 Fires and Explosions 16
4.2.4 Utilities Interruption 17
4.2.5 Gas Leak 17
4.2.6 Medical Emergencies 17
4.3 Internal and External Communications and Alarm Systems 18
4.4 Evacuation Plan for Facility Personnel 18
4.5 Post-Emergency Actions 18
4.6 Emergency Equipment 19
5. INCIDENT REPORTING REQUIREMENTS 20
5.1 Plan Implementation Records 20

5.2 Spill Reporting 20
5.3 CERCLA Spill Reporting Requirements 21
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WINDSOR LOCKS, CT
6. EMERGENCY SPILL CONTROL NETWORK 23
6.1 Arrangements with Local Emergency Response Agencies 23

6.2 Notification Lists 24
7. AMENDMENT AND DISTRIBUTION OF THE PLAN 25
TABLES
Table 1 Emergency Contact Information

Table 2 Emergency Equipment List
FIGURES
Figure 1 Site Location Map
DRAWINGS
Drawing 1 Site Plan and Location of Emergency Response Equipment
APPENDICES
Appendix A Classification of Characteristically Hazardous Waste

Appendix B List of Incompatible Wastes
Appendix C Contingency Plan Transmittal Letters
Appendix D Contingency Plan Implementation Record
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ACRONYMS
CERCLA Comprehensive Environmental Response, Compensation and Liability Act

CFR Code of Federal Regulations
DEEP Connecticut Department of Energy & Environmental Protection
EPA United States Environmental Protection Agency
HWF Hazardous Waste Facility
SDS Safety Data Sheet
NRC National Response Center
PA Public Address
RCSA Regulations of Connecticut State Agencies
RQ Reportable Quantity
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1. INTRODUCTION
1.1 Purpose and Scope
This Hazardous Waste Contingency Plan (Plan) has been prepared for the Hazardous Waste
Facility (HWF) operated by Hamilton Sundstrand at their manufacturing plant located at 1
Hamilton Road in Windsor Locks, Connecticut. This Contingency Plan satisfies the
preparedness, prevention and contingency planning requirements promulgated in the Resource,
Conservation and Recovery Act (RCRA) hazardous waste regulations, including Title 40 Code
of Federal Regulations (CFR) Part 264 Subpart D and 40 CFR Part 264 Subpart C. In response
to these regulations, this Plan has been developed to guide facility response efforts in the event
of an emergency. The Plan objective is to provide procedures/protocols to substantially reduce
hazards to human health or the environment from fires, explosions, or any unplanned sudden or
non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface
water.
1.2 General Facility Description
Hamilton Sundstrand maintains an approximately 300-acre facility located in Windsor Locks,

Connecticut. The property is bound to the south and west by Connecticut Route 20 and
residential properties, to the north by Schoephoester Road and Bradley International Airport, and
to the east by woodland and commercial properties. A site location map is provided as Figure 1.
The Site is developed with numerous structures including manufacturing, office, and operations
support buildings, as well as paved parking lots and landscaped areas. A Site Plan for the facility
is provided as Drawing 1.
1.3 Description of Industrial Activity
There are various processes at the facility which generate hazardous wastes and/or non-
hazardous wastes. Principal activities at the facility include the design and manufacture of
aerospace components such as electronic components, space suits, space shuttle/space station life
support systems, propellers, jet engine fuel control systems, guidance systems and aircraft
environmental control systems.
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WINDSOR LOCKS, CT
1.4 Waste Inventory and Storage Locations
Hazardous, non-hazardous, and universal wastes generated from site activities are stored in the
HWF located on the southwest portion of the campus. The HWF totals approximately 15,000
square feet and is primarily a covered, unheated storage area with a concrete base coated with
epoxy resin. Chemical storage in the HWF is divided into eight drum storage racks (designated
Racks A through H), two lab pack cabinets for small-quantity wastes, four self-contained storage
units (referred to as “condos”), a 30 cubic-yard roll-off container, a flammables cabinet, and two
6,000-gallon aboveground storage tanks for used oil and non-hazardous liquid, respectively.
Each storage area within the HWF is marked with signs describing the chemicals or wastes
stored in the area.
All hazardous wastes are stored in Department of Transportation (DOT) approved shipping
containers that are compatible with the materials being stored. Non Hazardous liquids are stored
in a tank adjacent to the HWF Packaging Room. Containers remain closed at all times except
when adding or removing wastes. Adequate aisle space is provided to facilitate weekly container
inspections and emergency access and egress. Incompatible waste streams are separated as
appropriate. All containerized wastes generated at the facility are shipped from the southwest
loading dock located adjacent to the Staging Area. Non-hazardous liquids and waste oils stored
in the tank units are transferred for shipment through piping located at the southeast corner of the
HWF.
The hazardous wastes handled at the Site are identified and characterized in accordance with
federal and state regulations. Waste determination documentation and profiles are maintained at
the facility for review by CTDEEP. Guidance for classification of characteristically hazardous
waste is provided in Appendix A.
The types of waste streams generated at the facility and potentially stored at the HWF are as
follows:
Storage Maximum Maximum Major Typical Hazardous and Connecticut-
Area Number of Capacity in Hazard Type Regulated Wastes
Containers Gallons
Ignitable and combustible liquids such as
Ignitable and
Rack - A 90 4,950 paints, resins (non-isocyanate) and
Combustible
adhesives.
Burnables such as rags, oil filters, paint
Rack – B 90 4,950 Toxic
filters and aerosol cans.
Burnables such as rags, oil filters, paint
Rack – C 90 4,950 Toxic
filters and aerosol cans.
Rack – D 90 4,950 Toxic Burnables such as rags, oil filters, paint
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WINDSOR LOCKS, CT
Storage Maximum Maximum Major Typical Hazardous and Connecticut-

Area Number of Capacity in Hazard Type Regulated Wastes
Containers Gallons
solvents, fluorescent lamps, accumulation
containers for consolidating wastes such
as acid debris in over pack, alkaline
debris in over pack, grease, aerosols cans,
epoxy resin, catalyst.
Machine Sludges and metal hydroxide
Rack – E
108 5,940 Toxic sludges (cubic yard boxes). Treated metal
powders.
Soils- Sporadic contaminated soils, ultra
filtration Zyglo filters, carbon canister
Rack – F 108 5,940 Toxic
filters and silver recovery canisters.
Treated metal powders.
Aqueous wastes from processes such as
solder rinse water; vapor blast water and
Rack – G 108 5,940 Toxic floor wash water, concrete saw cut
waters, dust collector sludge containing
water; and biomedical wastes
Supplies or Used for supplies, may be used for
Rack – H 36 1,980
Toxic waste storage of toxic waste.
Lab Pack
Cabinet- Miscellaneous wastes that are mainly
Varies 55 Toxic/Other*
Toxics/Other toxic but not corrosive or flammable
* (SSC-7)
Lab Pack
Ignitable and Miscellaneous wastes which are ignitable
Cabinet Varies 55
Combustible or combustible.
FC (SSC-3)
Wastes like chromic acid, phosphoric
Acids
24 1,320 Acid acid and fixer from printing, lead acid
(SSC-2)
batteries
PCB
(SSC-4) / PCBs in one room; isocyanates and other
24 1,320 PCB/Resin
Resin resins in another room.
(SSC-5)
Alkaline or Alkaline wastes such as developer from
Alkaline or
Cyanide 24 1,320 printing ammonia, sodium hydroxide and
Cyanide
(SSC-1) cyanides.
Heated building for water based waste
Bldg WB
24 1,320 Toxic when the outside temperature falls below
(SSC-6)
the freezing point (winter storage).
Toxic/
Totes Various size 3951 Hazardous coolants, oils, waters
Corrosive
Roll-off 30 cubic yard 6,059 Contaminated soils, machine sludge
TOTAL 55,000
*Toxics or otherwise hazardous materials requiring segregation (provided that RGNs are compatible)
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WINDSOR LOCKS, CT
In addition, the HWF houses one 6,000-gallon aboveground tank containing non-hazardous
liquid wastes, and one 6,000-gallon aboveground tank containing non-hazardous used oil. These
two tanks are located in a covered annex on the southeast side of the HWF.
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2. EMERGENCY RESPONSE PLAN
2.1 Emergency Coordinators
The Emergency Coordinators have been designated based on their familiarity with the facility
and the hazardous waste generation and management. The Emergency Coordinators are trained
in accordance with Hamilton Sundstrand training programs to take action in the event of an
emergency at the facility. The Emergency Coordinators are familiar with all aspects of this Plan,
the operations and activities of the facility, the location and characteristics of wastes handled, the
location of facility records, the facility layout, and the location and use of all emergency
equipment. The names and addresses of the Emergency Coordinators along with home
telephone numbers, office telephone numbers, and cell phone numbers are listed in Table 1. This
table will be maintained and updated in response to facility personnel changes.
2.2 Duties and Responsibilities of the Coordinator
The Primary Emergency Coordinator (or Alternate Emergency Coordinator if the Primary
Coordinator is unavailable) is authorized to commit the necessary resources, equipment, and
personnel to carry out this Plan in order to deal with an emergency situation that may arise at the
HWF. At all times, at least one Emergency Coordinator will be present at the facility or on call
and capable of reaching the facility in time to respond effectively to any potential emergency.
Any person discovering a spill, fire, explosion, or any unplanned release of hazardous waste
constituents to the air, soil, or surface water, must immediately notify their Supervisor, who will
immediately notify the Emergency Coordinator. The Emergency Coordinator must immediately
perform the following actions:
 Evaluate the emergency and decide whether to implement the Contingency Plan.
 When applicable, activate internal facility communication systems or alarms to notify all
facility personnel of the emergency and of an evacuation.
 Ensure that all employees have evacuated the building.
 Whenever there is a release, fire, or explosion of hazardous waste; identify the character,
exact source, amount, and the size of the area impacted by any released materials. This
may be done by observation, review of facility records, or by chemical analysis.
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 Assess the potential hazards to human health or the environment that may result from the
release, including fires or explosions. The assessment will consider both the direct and
indirect effects of the incident (e.g., the effects of any toxic, irritating, or asphyxiating
gases that are generated or the effects of any hazardous surface runoff from contaminated
water or chemical agents used to control fire, and heat induced explosions).
 Supervise the emergency response activities.
 Notify outside emergency, state, and local agencies of the emergency with designated
response roles if their help is needed.
 Based on the severity of the emergency, supervise the evacuation of local areas outside
the facility if the local police or fire department officials order an evacuation.
 Coordinate all reasonable measures necessary to respond in a defensive fashion without

actually trying to stop the release (i.e., contain the release from a safe distance, keep it
from spreading, and prevent exposures) and ensure that fires and explosions do not
spread by removing or isolating containers of incompatible materials and taking other
similar defensive actions.
 As appropriate dispatch contractors for cleanup operations and supervise all cleanup
operations performed by contractors.
 Perform follow-up emergency reporting procedures.
 Maintain response equipment and supplies.
All recovered materials will be properly containerized under the supervision of the Emergency
Coordinator. The Emergency Coordinator must also ensure that no material or waste, that may
be incompatible with the released material, is stored in the affected areas until cleanup
procedures are completed. A guide for determining chemical incompatibility is included in
Appendix B.
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3. SPILL AND LEAK PREVENTION
Hamilton Sundstrand has implemented spill prevention procedures to minimize the

potential harm to human health and the environment. The information presented below is
a summary of Hamilton Sundstrand’s spill prevention policies as they pertain to
hazardous wastes. Additional information regarding preventative measures implemented
at the facility is provided in Hamilton Sundstrand’s, Spill Prevention, Control, and
Countermeasure Plan.
3.1 Preventative Measures
Secondary containment is provided for all hazardous waste containers which contain
liquids located in the HWF. Any releases occurring from hazardous waste liquid
containers located within this area would be contained within the provided secondary
containment.
All secondary containment provided for liquid hazardous waste containers located within
the HWF have a capacity equal to or greater than ten percent of the total storage volume
or 100 percent of the volume of the single largest container. If incompatible hazardous
waste liquids are stored (i.e., flammable and corrosive liquids), the containers are
segregated in different storage racks or in isolated containment units (condos) within the
HWF. Hazardous waste liquids are contained in 55-gallon closed-top drums, to minimize
the potential for a spill.
The non-hazardous liquids storage tank and the non-hazardous used oil tank are both of
double-walled construction and are located in a concrete-walled annex that is equipped
with liquid level sensors to detect overfill and leak conditions. The tanks are equipped
with high level and low level liquid level sensors. Transfer piping associated with the
storage tanks is also double walled. In the event of a failure of the inner wall of a transfer
pipe, liquids would flow in the outer wall of the pipe to a containment sump equipped
with liquid level sensors. The tanks undergo periodic integrity testing.
Wastes contained in tanks are periodically shipped off-site by a licensed waste hauler.
To minimize the potential for a release during transfer, waste haulers and Hamilton
Sundstrand personnel will adhere to the following standardized transfer procedures
during all shipments and deliveries:
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 Transfer operations for shipping wastes and receiving virgin product will be
supervised by Hamilton Sundstrand personnel;
 Truck drivers will coordinate with appropriate Hamilton Sundstrand before

transfer begins;
 Delivery truck wheels will be chocked before transfer begins;
 Catch basin covers will be placed over down gradient catch basins prior to
transferring liquids when it is determined necessary, and absorbents will be
readily available to contain any spills that may occur;
 The driver and Hamilton Sundstrand personnel will remain present and attentive
at all times during transfer.
3.2 Special Material Storage Considerations
Organic Peroxide Storage
Hamilton Sundstrand will comply with the following requirements when managing
organic peroxide in the HWF:
 The chemical name will be posted on the container utilized to manage the organic
peroxide;
 The temperature range at which the organic peroxide can be safely managed will
be identified and posted on the container utilized to manage the organic peroxide;
and
 Any container containing organic peroxide wastes will be kept in the designated
storage cabinet or a refrigerator as specified by the manufacturer.
Ignitable Wastes
Hamilton Sundstrand will ensure that containers holding ignitable or reactive waste are
located at least 15 meters (50 feet) from the property line and will not manage any
ignitable waste at the HWF unless the waste is protected from any condition that may
cause the waste to ignite. Hamilton Sundstrand will make allowances for the grounding
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of any containers of ignitable materials stored or managed in the HWF at least during the
addition and removal of wastes to and from containers.
3.3 Material Compatibility
Hazardous waste containers will be selected by the Environmental Health & Safety
Office based on the characteristics of the waste added to the container. Additionally,
incompatible wastes will not be co-mingled within the same waste container. A guide for
determining material incompatibility is provided as Appendix B.
Specifically, Hamilton Sundstrand will not mix or commingle a waste specified in 40

CFR 264, Appendix V, Group A with a waste specified in Group B. In addition,
Hamilton Sundstrand will not place a waste listed in Group A with a waste listed in
Group B in a container or a tank that has not been decontaminated and that previously
held an incompatible waste, product or other material.
Hamilton Sundstrand will ensure that at all times hazardous wastes from a given
hazardous waste compatibility group be separated from materials from a different
compatibility group (incompatible wastes or other materials), or protected from them by
means of dike, berm, wall or other device. The staging area compatibility determination
will be in accordance with the requirements of 49 CFR Part 177.848I, Hazardous
Materials Load and Segregation Chart.
3.4 Inspection and Monitoring Program
To minimize the chance of a release of hazardous waste or hazardous waste constituents

to the environment, Hamilton Sundstrand has developed and implemented an inspection
schedule for hazardous waste container storage, emergency and personal protective
equipment, and waste container loading/unloading areas. Containers located within the
HWF are checked for physical integrity, leaks or corrosion, and correct labeling.
Secondary containment systems are inspected for cracks and signs of waste container
leakage. The inspection of the HWF, 90 day storage areas, and outlying satellite
accumulation areas are done on a weekly basis. The inspection of emergency and
personal protective equipment is also done on a weekly basis. Waste container
loading/unloading areas are inspected on the day of a waste shipment. Examples of the
inspection forms are included in Hamilton Sundstrand’s Hazardous Waste Facility
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WINDSOR LOCKS, CT
Procedures. Copies of the inspection schedule and inspection forms are maintained for a
minimum of three years.
If, during the course of the inspection, the inspector observes a problem, it will be noted
on the appropriate form and the inspector will notify the appropriate person. A
subsequent corrective action will be entered when the situation is rectified with
appropriate reference to the date on which the deficiency was discovered.
3.5 Housekeeping Program
Hamilton Sundstrand employs good facility housekeeping practices to reduce the

potential for accidental spills and ensure a safe work place for its employees. Good
housekeeping practices employed at this facility include:
 Maintaining adequate aisle space throughout the facility to facilitate transfer

activities and emergency response;
 Keeping waste and chemical storage areas free of debris and obstructions;
 Keeping aisle ways and floors clear, dry and in good repair;
 Cleaning leaks and incidental spills immediately so as not to create a slip hazard;
 Maintaining company vehicles to minimize leaks, and
 Keeping paved areas clean and free of debris.
It is the responsibility of all Hamilton Sundstrand employees to maintain their respective

workplaces in a clean and orderly manner. Department supervisors are responsible for
ensuring that employees adhere to good housekeeping practices at all times. Work areas
will be periodically inspected for deficiencies in cleanliness and good physical
appearance.
3.6 Emergency Power/Backup
The fire alarm system and exit signs are capable of operating under emergency power
conditions from battery power backup supply. The HWF has a backup generator capable
of supplying power to various systems, as needed.
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3.7 Employee Training Program
To comply with state and federal regulations, Hamilton Sundstrand has developed a
comprehensive employee training program designed to “ensure that facility personnel are
able to respond effectively to emergencies by familiarizing them with emergency
procedures, emergency equipment, and emergency systems”. At a minimum, all
employees shall be made aware of the need to dial 1-911 from a facility phone or (860)
654-1911 from a cell phone in the event of an emergency. All employees must also be
familiar with primary and secondary evacuation routes from the facility. Awareness,
hazard recognition, and emergency notification training is the responsibility of the
Environment, Health & Safety division.
All personnel who perform hazardous waste-related activities, and/or are responsible for
ensuring that the facility’s waste management procedures comply with applicable
regulations must receive hazardous waste training. Employees must successfully
complete the hazardous waste training program within six months after their date of hire,
or their assignment to a new position within the facility. In addition, facility personnel
must take part in an annual review of the initial training program. This annual review will
incorporate any changes in regulatory requirements or the facility’s waste management or
emergency procedures.
Hamilton Sundstrand’s hazardous waste training program is intended to teach employees

hazardous waste management procedures relevant to their positions and duties, and
ensure that they are able to perform their duties in compliance with applicable
regulations. The training program consists of both in-house classroom training and on-
the-job training. Employees may additionally be provided with additional off-site
classroom training. For current employees, all training records as they pertain to
hazardous waste, including initial training and annual review, will be kept at the facility.
The records of former employees will be maintained for a minimum of three years.
Elements of Hamilton Sundstrand’s hazardous training program include the following:
 Hazardous Waste Regulations;
 Waste Determinations;
 Container Management (storage, labeling/marking, compatibility);
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 Manifests/Land Disposal Restrictions;
 Properties of Facility Waste;
 Reporting and Recordkeeping;
 Waste Minimization;
 Waste Packaging/Shipping/Offering (DOT);
 Procedures for using, inspecting, repairing and replacing facility emergency and
monitoring equipment;
 Communications and/or alarm systems;
 Response to fires, explosions and releases of hazardous waste constituents;
 Response to groundwater contamination incidents;
 Shutdown of operations; and
 Evacuation procedures.
3.8 Security
Unauthorized access to the Hamilton Sundstrand facility is strictly prohibited. To restrict

unauthorized entry and minimize the potential harm to employees and company property,
Hamilton Sundstrand has implemented the following security measures:
 All visitors are required to pass through one of several guard posts at the facility
to obtain a visitor’s badge;
 Visitors must be escorted by a Hamilton Sundstrand employee at all times while

at the facility unless they have been authorized to work independently and display
the appropriate contractor badge;
 At least one Hamilton Sundstrand employee is present during all shipments to

and from the facility;
 Exterior doors and gates are locked during non-operational hours;
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 A presence is maintained at the Hamilton Sundstrand campus through the

operation of three shifts on weekdays and during weekends. The HWF is staffed
during regular business hours;
 Adequate lighting is provided throughout the parking lots to discourage acts of

vandalism;
 A “No Smoking” policy is maintained within the facility to reduce the potential
fire risk;
 "No Smoking" signs are posted in areas of ignitable or combustible materials; and
 "Hazardous Waste" signs are posted in areas of hazardous waste storage.
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4. EMERGENCY RESPONSE PROCEDURES
4.1 Implementation
The decision to initiate an emergency response is made by the Emergency Coordinator upon
immediate awareness and assessment of a spill, fire, explosion, or release of hazardous waste or
hazardous waste constituents that could threaten human health or the environment. Upon
notification, the Emergency Coordinator will immediately proceed to the area of the incident to
assess the situation and make the decision to what extent emergency response should be
implemented.
The Emergency Coordinator has the authority to commit the resources required to carry out
emergency hazardous waste responses and to implement the Contingency Plan. All personnel
identified as participants in the implementation of the Contingency Plan and key management
personnel have been provided with copies of the Contingency Plan as well as training in its
implementation.
Specific emergency response procedures applicable to the facility are described and/or
referenced in the sections below. The conditions under which the Emergency Coordinator may
implement the Contingency Plan include the following:
 Fire.
 Explosion.
 Imminent danger of a Fire or Explosion involving hazardous materials resulting in the

igniting of hazardous wastes or release of toxic materials.
 A spill that could result in release of flammable liquids or vapors, thus causing a fire or
explosion hazard.
 Spills that could cause the release of toxic liquids or fumes which harm employees.
Other factors that are considered prior to the implementation of emergency procedures are:
 Past experience.
 Specific process operation.
 Location.
 Inherent danger of release.
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WINDSOR LOCKS, CT
 Ability to contain and mitigate.
 Potential hazards to human health and the environment.
Summary information on the general classes of hazardous materials that may be encountered
during an emergency scenario is included in Appendix A. The Safety Data Sheet (SDS) for a
particular material should be referenced for information concerning the specific properties,
hazard data, and special precautions and procedures recommended by the manufacturer. SDSs
for all hazardous chemicals used in the facility are accessible to all employees.
4.2 Countermeasures
4.2.1 Incidental Spills
Minor releases which are incidental in nature, and which may occur during normal operations,
are not considered emergencies and are not covered by this Plan. If incidental releases occur
during normal work practices they will be addressed through normal housekeeping activities of
the employee(s) involved. An incidental release, as defined by the Occupational Safety and
Health Administration (OSHA) in 29 CFR 1910.120, is any release where “…the substance can
be absorbed, neutralized, or otherwise controlled at the time of release by employees in the
immediate release area, or by maintenance personnel”. Incidental spills or drips which do
migrate to a drain, outside of a building, or to the atmosphere are to be managed in accordance
with Hamilton Sundstrand’s, Spill/Medical Response & Evacuation Plan.
4.2.2 Non-Incidental Spills
Upon awareness of a non-incidental spill at the HWF (i.e. a spill that is beyond the ability of
employees to contain, or one that moves to a drain, outside the building, or to the atmosphere),
the employees must immediately notify the Emergency Coordinator. The Emergency
Coordinator will determine if the HWF personnel have the ability and proper equipment to
contain the release. If the containment of the release is beyond the capability of the HWF
personnel, the Emergency Coordinator will immediately notify Hamilton Sundstrand Emergency
Services by calling 1-911 from a facility telephone or (860) 654-1911 from a cell phone as stated
in Hamilton Sundstrand’s, Spill/Medical Response & Evacuation Plan. Emergency Services is
staffed 24 hours per day, 7 days per week. Once Emergency Services is notified, they will enact
Hamilton Sundstrand’s Integrated Contingency Plan.
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WINDSOR LOCKS, CT
Upon receiving notification of a release, fire, or explosion, the Emergency Coordinator must
immediately identify the character, exact source, amount, and extent of any released materials
through observation, review of facility records and manifests, and, if necessary, by chemical
analysis.
The Emergency Coordinator will coordinate the spill cleanup with the Emergency Cleanup
Contractor and will supervise all cleanup activities performed, including collecting and
containerizing the absorbent material and the spilled material for disposal off the site. The
contractor will also clean the spill area, as necessary and collect the cleaning materials for
disposal. The waste must be managed in accordance with all applicable requirements of state
and federal hazardous waste management. Wastes will also be managed according to Hamilton
Sundstrand’s, Hazardous Waste Facility Procedure and Site Waste Management Procedure.
4.2.3 Fires and Explosions
Except for small fires that can be readily extinguished (also known as incipient-stage), fire
suppression actions will be undertaken by Emergency Services. For incipient-stage fires
contained to the area of origin in which no hazardous materials are stored, an employee may
attempt to extinguish the fire using a fire extinguisher provided the employee is properly trained
to do so.
Any employee involved in or observing a fire or explosion shall report it immediately by

activating the nearest fire alarm box and calling extension 1-911 to alert Emergency Services in
accordance with Hamilton Sundstrand’s, Spill/Medical Response & Evacuation Plan. In areas
where no alarm box exists, the individual shall call Emergency Services at extension 1-911.
Emergency Services is staffed 24 hours per day, seven days per week. Upon notification,
Emergency Services will implement Hamilton Sundstrand’s, Integrated Contingency Plan.
If available, trained and designated Site personnel will report to the Emergency Coordinator for
possible assignment to shut down facility electrical power, shut off natural gas, shut down
heating and ventilation systems, or other tasks as requested by the Incident Commander. If
operations are stopped in response to a fire, explosion or release, the Emergency Coordinator or
their designee will monitor for leaks, pressure buildup, gas generation, or ruptures in valves,
pipes, or other equipment, wherever this is appropriate. The Incident Commander is the person
responsible for coordinating all facets of emergency response activities at the scene. The chief
fire department officer typically assumes the role of Incident Commander upon arrival at the
scene.
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Actions to prevent the reoccurrence or spread of fires or explosions will include stopping
processes and operations, collecting and containing released waste. The Emergency Cleanup
Contractor will also be contacted to respond to the potential for contaminated runoff from fire
fighting activities.
4.2.4 Utilities Interruption
If there is a loss of electricity, the Emergency Coordinator will contact the electrical provider,
Eversource (previously Connecticut Light & Power), at (860) 947-2000 to determine how long
the facility will be without power. Based on the duration of the power outage, the Emergency
Coordinator may instruct employees to return to work following the incident, or may authorize
employees to leave the HWF. Exit signs remain lit by battery power during outages to guide
employees out of the building if needed. The fire alarm system also remains operational.
4.2.5 Gas Leak
The enclosed portion of the HWF is heated by propane gas. Any employee who observes
indications of a propane gas leak at the facility must immediately notify the Emergency
Coordinator. In the event of an actual propane leak, the Emergency Coordinator will initiate an
immediate evacuation of the facility by activating the fire alarm system and dialing 1-911 from a
facility telephone or (860) 654-1911 from a cell phone to alert Emergency Services. The
Emergency Coordinator will also contact Hamilton Sundstrand Facilities & Services to notify
them of the leak.
Employees may be instructed by the Emergency Coordinator to eliminate ignition sources prior
to evacuating the HWF, provided that it is safe to do so. The Emergency Coordinator may also
instruct employees to assemble at an alternate assembly point if it is believed the gas leak is near
the supply line to the building. Based on instructions from Hamilton Sundstrand Facilities &
Services and/or local emergency response personnel, the Emergency Coordinator may also be
asked to shut off the main propane gas valve located inside the HWF to mitigate potential harm
to life or property.
4.2.6 Medical Emergencies
Hamilton Sundstrand employees who are not specifically engaged by Emergency Services are
not expected to perform rescue or medical/first aid duties. Generally, Emergency Services
personnel will perform these duties as needed. In the event of a medical emergency, Hamilton
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WINDSOR LOCKS, CT
Sundstrand employees should immediately notify the Emergency Coordinator and, if necessary,
dial 1-911 from facility phones to notify Emergency Services.
4.3 Internal and External Communications and Alarm Systems
The primary internal emergency communication device used to notify employees of an

evacuation is an audible/visual alarm system. The alarm system can be activated through any of
the pull stations located throughout the HWF. Activation of the fire alarm also alerts Hamilton
Sundstrand Emergency Services of the evacuation. The fire alarm system is tested annually by
Emergency Services to ensure reliability and proper operation.
The secondary internal communication device at the facility is the public address (PA) system
which is used daily to page employees throughout the HWF. The PA system is not routinely
tested since it used daily.
External communication devices used to summon emergency assistance include facility

telephones, two-way radios, and cell phones. The two-way radios carried by HWF personnel are
used for communication between HWF employees and may also be used to alert Emergency
Services.
4.4 Evacuation Plan for Facility Personnel
In the event of an emergency that requires evacuation, the Emergency Coordinator will activate
the internal facility communication system (fire alarm system and/or PA system) to notify all
facility personnel to evacuate. Evacuations of the HWF will be performed in accordance with
Hamilton Sundstrand’s, Spill/Medical Response & Evacuation Plan. Upon evacuating the
building, HWF personnel will congregate at Refuge Area #6.
4.5 Post-Emergency Actions
Immediately after an incident, the Emergency Coordinator shall make arrangements for the
treatment, storage, or disposal of recovered hazardous waste or any other contaminated material.
For hazardous waste incidents requiring implementation of the Contingency Plan, the Emergency
Coordinator must ensure that in the affected areas of the facility:
 No waste that may be incompatible with the released material is treated, stored, or
disposed of until cleanup procedures are completed.
M.18
WINDSOR LOCKS, CT
 All emergency equipment is cleaned and fit for its intended use before operations are
resumed.
The EPA Regional Administrator, the Commissioner of the DEEP, and appropriate local
authorities must be notified that the facility is in compliance with the above before operations are
resumed. Details of the Contingency Plan incident must be recorded in the facility operating
record. Post-incident written notification requirements are described in Section 5 – Reporting
Requirements.
4.6 Emergency Equipment
Hamilton Sundstrand maintains fire-fighting and spill response equipment located throughout the
HWF. Portable fire suppression systems are located throughout the building, along with fire
hoses capable of delivering water. The main fire suppression system located in the building is
classified as a “wet” system which delivers water to heat activated sprinkler heads located in the
ceiling of the office, Packaging Room, and Flammable Room.
The equipment description/capabilities and locations of the equipment are listed in Table 2.
HWF personnel are familiar with all equipment and locations. The emergency equipment is
inspected on a weekly basis. Upon completion of response actions for a release or spill, all non-
disposable personal protective equipment and spill cleanup equipment must be decontaminated
and readied for reuse and depleted stocks of neutralizing/absorbing materials must be replenished
and protective clothing cleaned or replaced. Any emergency equipment that has been damaged
beyond repair must be replaced.
The Emergency Coordinator must visually inspect all emergency equipment, after it has been
decontaminated to ensure cleanliness and proper operation. The decontamination solution and
the rinse waters shall be collected for proper disposal. The container of decontamination fluids
must be sealed, labeled, and stored in the HWF in accordance with Hamilton Sundstrand’s,
Hazardous Waste Facility Procedure and, Site Waste Management Procedure. The Emergency
Coordinator will also manage the reordering of disposable personal protective equipment and
spill cleanup equipment consumed as a result of the response actions for a release or spill.
M.19
WINDSOR LOCKS, CT
5. INCIDENT REPORTING REQUIREMENTS
5.1 Plan Implementation Records
In accordance with RCRA regulations, the Emergency Coordinator must note the time, date, and
details of any incident that requires the implementation of the Contingency Plan. Incidents
requiring Plan implementation will be recorded in the log provided as Appendix D. In addition,
the Emergency Coordinator must submit a written report to the Regional Administrator (EPA
Region 1) within 15 days of the incident. The report must include:
 Name and telephone number of the individual making the call;
 Name and address of the facility;
 Date, time, location, and type of incident (e.g., oil, chemical, or hazardous waste release,
fire, etc.);
 Name and quantity of material(s) involved, to the extent known;
 Extent of injuries, if any;
 Assessment of possible hazards to human health or the environment outside the facility;
 Corrective actions being taken, and
 Estimated quantity and disposition of recovered materials, if any.
Incidents which require reporting under RCRA are also reportable to the State Emergency
Response Commission (SERC) at 860-424-3373 and the National Response Center (NRC) at
(800) 424-8802. A report to the local fire department is also recommended.
In the event of an incident requiring implementation of the Contingency Plan, including injury,
fire, evacuation, or a major spill, Emergency Services personnel must make internal notifications
in accordance with Hamilton Sundstrand’s Integrated Contingency Plan.
5.2 Spill Reporting
The Emergency Coordinator will report any spill which occurs at the facility to the DEEP,
Emergency Response Unit, by calling 860-424-3338 or 1-866-DEP-SPIL (1-866-337-7745). A
M.20
WINDSOR LOCKS, CT
spill is defined by DEEP as any oil or petroleum products, chemicals, wastes or other dangerous
materials that are released in any manner. The Emergency Coordinator must report the
following information to DEEP immediately, but not later than 24 hours of any spill:
 The location of the spill;
 The quantity and type of substance, material or waste released;
 The date and cause of the incident;
 The name and address of the owner; and
 The name and address of the person reporting the incident and his/her relationship to the
owner.
A written submission shall be provided to the DEEP as required. Additional contact telephone
information for the DEEP spill reporting is included in Table 1. Hamilton Sundstrand’s spill
reporting will also be completed in accordance with the Hamilton Sundstrand Spill Release
Notification & Follow Up Reporting Guidance, which incorporates corporate guidelines.
5.3 CERCLA Spill Reporting Requirements
In the event of a hazardous substance release in excess of the applicable reportable quantity (RQ)
for a particular material, as defined by the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), the Emergency Coordinator will report the release
to the following agencies:
 National Response Center at (800) 424-8802;
 CT DEEP at 860-424-3338 or 1-866-DEP-SPIL (1-866-337-7745); and
 Windsor Locks Fire Department at (860) 627-1468.
The RQs for hazardous substances and hazardous wastes are listed in 40 CFR Part 302.4.
Hazardous wastes that are hazardous for the characteristics of ignitibility, reactivity, or
corrosivity have a default RQ of 100 pounds. If a CERCLA hazardous substance is not included
in 40 CFR Part 302.4, the default RQ is one pound.
M.21
WINDSOR LOCKS, CT
The following information will be provided to the DEEP, Fire Department, and NRC in the event
of release in excess of the established RQ:
 Name and telephone number of the individual making the call;
 Name and address of the facility;
 Date, time, location, and type of incident (e.g., oil, chemical, or hazardous waste release,
fire, etc.);
 Name and quantity of material(s) involved, to the extent known;
 Extent of injuries, if any;
 Assessment of possible hazards to human health or the environment outside the facility;
 Corrective actions being taken, and
 Estimated quantity and disposition of recovered materials, if any.
A written report documenting the incident will be forwarded to each agency, as required, within
fifteen (15) days of the initial notification. The follow-up report will include the same
information as reported for the initial verbal notification.
M.22
WINDSOR LOCKS, CT
6. EMERGENCY SPILL CONTROL NETWORK
6.1 Arrangements with Local Emergency Response Agencies
In an attempt to better coordinate a response to an emergency, Hamilton Sundstrand will provide

copies of this Contingency Plan to those agencies and emergency cleanup contractor that will be
contacted in an emergency. A copy of the Plan will familiarize those responding with the layout
of the facility and the hazardous wastes handled on site.
The following agencies and Emergency Cleanup Contractor shall be provided with a copy of the
Contingency Plan:
 DEEP
 Windsor Locks Fire Department
 Windsor Locks Police Department
 St. Francis Hospital, Hartford, Connecticut
 Bay State Medical Center, Springfield, Massachusetts
 State Emergency Planning Commission
 Clean Harbors Environmental Services (Emergency Cleanup Contractor)
 Tradebe Environmental Services (Emergency Cleanup Contractor)
Once distributed, copies of the transmittal letters documenting the submission of this Plan to the
various agencies listed above will be included in Appendix C, as well as any supplemental
distribution. The police and fire departments have been notified that it will be their decision and
responsibility to enact evacuation proceedings for neighboring areas.
Agreements between Hamilton Sundstrand and the Emergency Cleanup Contractors provide for
emergency response services on an as needed basis that would commence immediately upon
receiving a verbal authorization from the Emergency Coordinator. Hamilton Sundstrand will
provide the agencies listed above with changes to this Plan and ensure an updated copy of this
M.23
WINDSOR LOCKS, CT
Plan is maintained at the facility. The Emergency Coordinator shall maintain correspondence
with any agency listed in Appendix C that may be called upon in the event of an emergency.
In the event that state or local authorities decline to enter emergency response agreements,
Hamilton Sundstrand will document the refusal in the operating record.
6.2 Notification Lists
A list of contact phone numbers of state, local, federal regulatory agencies that must be contacted
in the event of an emergency or spill is found in the Emergency Contact List located in Table 1
of this Plan.
M.24
WINDSOR LOCKS, CT
7. AMENDMENT AND DISTRIBUTION OF THE PLAN
This Plan will be maintained and updated by the Emergency Coordinator of the HWF as
necessary. The Plan will be reviewed at least once every five years to determine if more
effective spill prevention and/or emergency response procedures are appropriate to the facility.
The Plan will be reviewed and immediately amended by the Emergency Coordinator, if
necessary, whenever:
1. Applicable regulations are revised;
2. The Plan fails in an emergency;
3. There are changes in the facility design, construction, operation, maintenance practices,
or other circumstances that may increase the potential for fire, explosion, or release of
hazardous waste or hazardous waste constituents, or changes in the response necessary in
an emergency;
4. The list of Emergency Coordinators changes; or
5. The list of emergency equipment changes.
Hamilton Sundstrand is required to maintain an updated copy of this Plan at the facility. The
Plan must be available for review by employees during normal working hours, and must be made
available to EPA or DEEP upon request. The Plan must also be submitted to all local police
departments, fire departments, hospitals, and state and local emergency response teams that may
be called upon to provide emergency services. Copies of this Plan have been distributed to the
Emergency Coordinators, local emergency agencies, and the Emergency Cleanup Contractors
listed in Table 1. A copy of this Plan will be maintained in the HWF at the Emergency
Coordinator’s desk.
M.25
WINDSOR LOCKS, CT
TABLES
Table 1
Emergency Contact Information
Hamilton Sundstrand Hazardous Waste Facility

1 Hamilton Road, Windsor Locks, CT 06096
Hamilton Sundstrand Emergency Services* 1-911 from internal phones

(860) 654-1911 from cell phones
*Hamilton Sundstrand Emergency Services will contact Windsor Locks Fire and Police
Emergency Numbers in the case of an emergency.
Primary Emergency Response Coordinator

Jeannie St. Hilaire, Hazardous Waste Facility Supervisor Work: (860) 654-5232
136 Cedar Street Home: (203)824-9113
Wallingford, CT 06492 Cell: (860) 987-8423
Alternate Emergency Response Coordinator

Mark Rainone, Sr. Manager, Env Ops. Work: (860) 654-3888
6 Deanna Ln Home:(860)-983-1126
Wolcott, CT 06716
Alternate Emergency Response Coordinator

Andy Kulas, Sr. Manager Emergency Services Work: (860) 654-2878
12 Hughes Lane Home: (860) 623-2583
Windsor Locks, CT 06096
24 Hour Emergency Response Spill Contractors

Clean Harbors Environmental Services, Bristol, CT (800) 583-8917
Tradebe Environmental Services, Meriden, CT (888) 276-0887
Local Hospital Emergency Service Contacts

St. Francis Hospital, Hartford, CT (860) 714-4000
Bay State Medical Center, Springfield, MA (413) 794-0000
Town of Windsor Locks Emergency Contacts

Windsor Locks Emergency 911
Windsor Locks Police Department (860) 627-1461
Windsor Locks Fire Department (860) 627-1468
Windsor Locks Fire Marshal (860) 627-1467
State Emergency Response Commission

C/O Connecticut Department of Energy & Environmental Protection
79 Elm Street (860) 424-3373
Hartford, CT 06106
Table 1
Emergency Contact Information

Connecticut 24 Hour Emergency Spill Response

Connecticut Department of Energy & Environmental Protection
Emergency Response Unit (866) 337-7745 (24 hr)
79 Elm Street (Mon.-Fri. 8 am to 4:30 pm) (860) 424-3338
Hartford, CT 06106 (Alternate) (860) 424-3333
State Police
Fire, Emergency, and Building Services (860) 685-8300
Federal Emergency Response Contact

National Response Spill Center (800) 424-8802
Poison Control Contact

Connecticut Association of Poison Control Center (800) 222-1222
Utility Contacts
Connecticut Light & Power (Electricity) (860) 947-2000
Hamilton Sundstrand Facilities & Services (Propane) x2345
Table 2
Emergency Equipment List

Equipment Type Capability Estimated Storage Location

Quantity
Aprons Body PPE 4 PPE Locker
PPE Locker
Booties Body PPE 7
Spill Response Rack
HWF Vehicle
Broom Used to collect contaminated Speedy Dry 5
Spill Response Rack
Covers catch basins to prevent migration of liquids during a HWF Vehicle
Catch Basin Cover 2
release Near Tank Transfer Station
Catch Basin Tubes/Hooks Used to open catch basin grates 2 Spill Response Rack
Caution Tape Delineates exclusion zones 1 roll HWF Vehicle
Drip Pans and Pillows Contains small chemical liquid spills 1 box Spill Response Rack
Ear Plugs Hearing PPE 1 box PPE Locker
Office
Emergency Sprinkler Heat-activated sprinkler heads on ceiling designated to quench
Multiple Packaging Room
System facility fires. Tested monthly by Emergency Services.
Flammable Room
Emergency Tote Temporary storage of moderate liquid spills 1 Spill Response Rack
Emergency Vacuum Removal of small chemical liquid spills 2 Spill Response Rack
Empty 5 Gallon Pails with Temporary storage of small chemical spills and absorbent
1 HWF Vehicle
Lids media
Storage of solid or chemical media if media transfer is Trailers on south end of HWF
Empty Drums 100-200
necessary Drum Rack
Provide flooding sprays of potable water to flush chemicals
Eye Wash and Shower splashed into eyes or sprayed onto the body. Inspected weekly 1 Packaging Room
by vendor.
Face Shields Eye and face PPE 4 PPE Locker
Table 2

Estimated
Equipment Type Capability Storage Location
Quantity
Multi-purpose dry chemical and gas fire extinguishers. Packaging Room
Fire Extinguisher 2
Inspected monthly by Emergency Services. North of Flammable Room near stairs
Packaging Room
Fire Hose Provide flooding streams of water for fire protection 2
Office area across from breakroom
Across pavement to northeast of HWF
Fire Hydrant Provide potable water for fire suppression 2
Across pavement to northwest of HWF
Electronic wall-mounted fire alarm boxes designed to notify
Hamilton Sundstrand Emergency Services. Once activated, a
Fire Pull Box Multiple Throughout HWF
siren-style “woo woo woo” alarm will sounds. Tested annually
by Emergency Services.
Fork Trucks Relocate damaged or leaking drums 2 Packaging Room
Garbage Bags Used to collect contaminated debris and PPE 1 box HWF Vehicle
Multiple PPE Locker
Gloves, Leather Hand PPE
Sets Outside Packaging Room
Gloves, Neoprene Hand PPE 1 box PPE Locker
PPE Locker
Multiple
Gloves, Nitrile Hand PPE Outside Packaging Room
Sets
Spill Response Rack
Hoses Used during transfer of liquid chemicals 2 Spill Response Rack
Used to identify hazardous waste containers and track their
Labels and Travelers 1 set HWF Office
movement at the facility
Level B Suits Body PPE 2 PPE Locker
Level C Suits Body PPE 1 PPE Locker
Mercury Cleanup Kit Contains small mercury spills and confines vapors 1 box PPE Locker
Table 2

Estimated
Quantity
Particulate Masks (3M) Respiratory PPE 1 box PPE Locker
PPE Locker
pH Paper Used to test the pH of liquid chemical spills 2
HEF Vehicle
Provides visual and audible indication of alarm conditions in the
storage tanks. Once activated, a rapid “beep beep beep” alarm
will sound. Alarm conditions include:
1. High liquid level in storage tanks
2. Low liquid level in storage tanks
3. Liquid present in containment sump that receives leaks
Tank Overfill Alarm 1 Northeast corner of Packaging Room
from the interstitial spaces of the double-walled transfer
pipes and from transfer pump failures.
4. Liquid present in interstitial space of double-walled
storage tanks
5. Float levels triggered by piping failures near the storage
tanks
Provides visual indication of an alarm condition in the storage
Tank Overfill Alarm Light 1 Near southeast loading dock
tanks
Office
Telephone Routine and emergency communications 2
Packaging Room
Tyvek Suits Body PPE 2 HWF Vehicle
Respirator Cartridges
Respiratory PPE 2 PPE Locker
(Multi-Gas)
(Organic Vapor)
(Mercury/Chlorine)
Table 2

Estimated
Quantity
HWF Vehicle (1)
Absorbent Socks
Used to absorb liquid chemical spills Multiple Spill Response Rack
(Grey/Blue/Pink)
(1 box grey/blue, 1 box pink)
HWF Vehicle
Speedy Dry Used to absorb liquid chemical spills 11 bags
Spill Response Rack
Spill Matting (Grey Rolls) Used to absorb liquid chemical spills 1 box Spill Response Rack
1 box Spill Response Rack
Grey Spill Pads Used to absorb liquid chemical spills
5 ea HWF Vehicle
Pink Spill Pads Used to absorb liquid chemical spills 1 box Spill Response Rack
1 box Spill Response Rack
White Spill Pads Used to absorb liquid chemical spills
5 ea HWF Vehicle
Spill Booms (White, large) Contain liquid chemical spills 4 Spill Response Rack
Sump Pump Collect and remove spilled materials 1 Spill Response Rack
Double Diaphragm Pump Collect and remove spilled materials 1 Spill Response Rack
Poly liner for Roll Offs Contain spilled materials 1 Spill Response Rack
Spill Response Rack
Shovels Clean up spills/spill response materials 5
HWF Vehicle
FIGURE 1
SITE LOCATION MAP

0 1,000 2,000 4,000
Feet
Connecticut Hartford County

LAT. 41.925 LON. -72.688
HARTFORD COUNTY
CONNECTICUT ¯
SITE
Approximate Location
Hazardous Waste Storage
Facility
J:\Projects\SiteLocationMaps\Aerospace Systems\_MXD\Figure1-SiteLocationMap_20200214.mxd - 2/14/2020|SRV
Copyright:© 2013 National Geographic Society, i-cubed
SITE LOCATION MAP

USGS 1:24K 7.5' Quadrangle, 2013:
Windsor Locks, CT
Hamilton Sunstrand Corporation GIS Review: AC

1 Hamilton Road CHK'D: AC
Hartford County 0533194
Environmental Resources Management

Drawn By:
SRV-2/14/20 FIGURE 1
DRAWING 1
SITE PLAN AND LOCATION OF EMERGENCY RESPONSE EQUIPMENT

Spill Response Inventory: HWF Spill Rack
Equipment Minimum Amount
Emergency Vacuum
SCHEDULE OF SAFETY EQUIPMENT
2 ea
Emergency Tote 1 ea
Speedy Dry 10 bags
Spill Matting (Grey Rolls) 1 box
Grey Spill Pads 1 box
Pink Spill Pads 1 box
White Spill Pads 1 box
Drip Pans and Pillows 1 box
Grey/Blue Socks 1 box
Pink Socks 1 box
White Socks 1 box
Sump Pumps 1 ea
Double Diaphragm Pump 1 ea
Hoses 2 ea
Slip-On Booties 5 ea
Poly Liners for Roll Offs 1 ea
Catch Basin Tubes/Hooks 2 ea
Spill Booms (White, Large) 4 ea
Push Brooms 4 ea
Shovels 4 ea
T Labels and Travelers
Burnables
Burnables
Burnables,
H
SSC-7
SSC-3
J
SSC-4
N Resin Bldg. RB
SSC-1 SSC-5
Project Number: 0533194

Waste Liquids
A.L.C
SSC-2 SSC-6
C
T
Spill Response Inventory: HWF Vehicle

Equipment Minimum Amount
Speedy Dry (1 bag or bucket) 1 bag
Garbage Bags (Box) 1 box
Shovel 1 ea
Broom 1 ea
White Spill Pads 5 ea Spill Response Inventory: HWF PPE Cabinet
Grey Spill Pads 5 ea Equipment Minimum Amount
Absorbent Socks 1 ea Level C Suits 1 box
Empty 5 Gallon Pails with Lids 1 ea Level B Suits 2 ea
Tyvek Suits 2 ea Booties 2 ea
Gloves 2 ea Nitrile Gloves 1 box
Catch Basin Cover 1 ea Neoprene Gloves 1 box
pH Paper 1 ea Leather Gloves 1 box
Squeegee 1 ea
Respirator cartridges 2 ea
Caution Tape 1 roll (Multi-Gas)
Respirator Cartridges 2 ea
(Mercury/Chlorine)
Respirator Cartridges 2 ea
(Organic Vapor)
Face Shields 4 ea
Particulate Masks (3M) 1 box
Aprons 4 ea
pH Paper 1 box
Ear Plugs 1 box
Mercury Cleanup Kit 1 box
APPENDIX A
CLASSIFICATION OF CHARACTERISTICALLY HAZARDOUS WASTE

CLASSIFICATION OF CHARACTERISTICALLY HAZARDOUS WASTE
The hazardous wastes generated at the facility have been identified and characterized in
accordance with applicable regulations. This information is maintained by site EH&S. The
hazardous characteristics of the various wastes fall into one or more of the following categories:
Types of Hazardous Waste EPA Hazardous Waste Code

Ignitable Waste D001
Corrosive Waste D002
Reactive Waste D003
Toxic Waste D004 – D043
Hazardous Waste Code Descriptions:
 D001: Ignitability Characteristic (Solvents) - Liquid with a flash point below 60°C
(140°F)
 D002: Corrosivity Characteristic (Acids, alkalis) - Aqueous material with pH less

than or equal to 2 or greater than or equal to 12.5
 D003: Reactivity Characteristic (Aerosol cans / Cyanide or sulfide bearing waste)

– Aerosol cans. Also included are cyanide or sulfide wastes which, when exposed
to pH conditions between 2 and 12.5 can generate toxic gases, vapors, or fumes.
 D004 - D043: Toxicity Characteristic (Acids, organics, solvents, etc.) - These

categories include a wide variety of organics and inorganics materials toxic to
humans by either short-term or long-term exposure as listed in federal regulations.
All containers used for storage of hazardous waste are clearly marked and labeled. The markings
and labels provide information that may be used to obtain additional detailed information
regarding the constituents present in the waste.
APPENDIX B
LIST OF INCOMPATIBLE WASTES

LIST OF INCOMPATIBLE WASTES
Group 1-A Group 1-B

Acetylene Sludge Acid Sludge
Alkaline Caustic Liquids Acid and Water
Alkaline Cleaners Battery Acid
Alkaline Corrosive Liquids Chemical Cleaners
Alkaline Corrosive Battery Fluid Electrolyte, Acid
Caustic Wastewater Etching Acid Liquid or
Solvent
Corrosive Acids
Spent Acid
Spent Mixed Acid
Spent Sulfuric Acid
Potential Consequences: Heat Generation, Violent Reaction
Group 2-A Group 2-B

Aluminum Any Waste in Group 1-A or 1-B
Beryllium
Calcium
Lithium
Magnesium
Potassium
Sodium
Zinc Powder
Other Reactive Metals & Metal Hydrides
Potential Consequences: Fire, Explosion, and Generation of Flammable Hydrogen Gas
Group 3-A Group 3-B

Alcohol Any Concentrated Wastes in Groups 1-A or 1-B
Water Calcium
Lithium
Metal Hydrides
Potassium
Other Water Reactive waste
Potential Consequence: Fire, Explosion, Heat Generation, Generation of Flammable or

Toxic Gases
LIST OF INCOMPATIBLE WASTES (continued)
Group 4-A Group 4-B

Alcohol Concentrated Group 1-A or 1-B Waste
Aldehydes Group 2-A Waste
Halogenated Hydrocarbons
Nitrated Hydrocarbons
Unsaturated Hydrocarbons
Other Reactive Organic Compounds
& Solvents
Potential Consequences: Fire, Explosion, or Violent Reaction
Group 5-A Group 5-B

Spent Cyanide & Sulfide Solutions Group 1-B Waste
Potential Consequences: Generation of Toxic Hydrogen Cyanide or Hydrogen Sulfide Gas
Group 6-A Group 6-B

Chlorates Acetic Acid & Organic
Chlorine Acids
Chlorites Concentrated Mineral Acids
Chromic Acids Group 2-A Waste
Hypochlorites Group 4-A Waste
Nitrites Flammable & Combustible Waste
Permanganates
Peroxides
Other Strong Oxidizers
Potential Consequences: Fire, Explosion, or Violent Reaction
Group 7-A Group 7-B

Ammonia Group 6-A Waste
Iron, Galvanized Steel
Copper, Brass, Bronze
Gold, Mercury, Silver
Halogens
Sulfuric Acid
Other Concentrated Mineral Acids
Potential Consequences: Explosion, Violent Reaction, and Generation of Toxic Gases

APPENDIX C
CONTINGENCY PLAN TRANSMITTAL LETTERS

*NOTE: The Contingency Plan will be distributed to stakeholders after CT DEEP reviews
and approves the document. The transmittal letters will be included with the final copy of
the Plan. Transmittal letters are filed with the operating records.
APPENDIX D
CONTINGENCY PLAN IMPLEMENTATION RECORD

CONTINGENCY PLAN IMPLEMENTATION RECORD1
Hazardous Waste Facility

Hamilton Sundstrand
1 Hamilton Road, Windsor Locks, CT
DATE TIME DETAILS2
1. In accordance with RCRA regulations, the Emergency Coordinator(s) must note the time, date, and details of any incident that requires the
implementation of this contingency plan. All incidents requiring Plan implementation will be recorded in this log.
2. Provide all relevant details, including, but not limited to, the location and nature of the emergency (spill, fire, leak, etc.), the quantity/source of
spilled materials if any, to whom the emergency was reported and when, any injuries, and any corrective actions taken.
ATTACHMENT E
CLOSURE PLAN

ONE HAMILTON ROAD

ATTACHMENT Q
Closure Plan and Cost Estimate

WINDSOR LOCKS, CT
ATTACHMENT Q
CLOSURE PLAN AND FINANCIAL ASSURANCE
TABLE OF CONTENTS
SECTION PAGE
Q1 INTRODUCTION ....................................................................................................... 1

Q1a Purpose .......................................................................................................... 1
Q1b Scope .............................................................................................................. 1
Q1c Permit Status ................................................................................................. 2
Q1d Facility Description ........................................................................................ 2
Q1e Environmental Setting .................................................................................. 3
Surface Water Bodies .................................................................................. 4
Groundwater .................................................................................................. 5
Geology .......................................................................................................... 5
Q2 DESCRIPTION OF REGULATED UNITS ............................................................. 5

Q2a Hazardous Waste Container Storage Area .............................................. 6
Q2b Combustible Used Oil Tank and Non-Hazardous Waste Tank ............. 7
Q2c Compactor ...................................................................................................... 8
Q2d J-Lot Area .......................................................................................................... 8
Q3 CLOSURE APPROACH .......................................................................................... 8

Q3a Assessment at Closure ................................................................................ 9
Q3b Structural Integrity Assessment .................................................................. 9
Q4 CLOSURE ACTIVITIES ......................................................................................... 10

Q4a Tank Decontamination and Confirmatory Sampling .............................. 10
Q4b Compactor & Equipment Decontamination............................................. 11
Q4c Floor Decontamination and Confirmatory Sampling ............................. 12
Q4d Worker Safety and Decontamination ....................................................... 13
Q4e Generated Waste Disposal........................................................................ 14
Q5 SAMPLE METHODOLOGIES AND HANDLING PROCEDURES .................. 14

Q5a Sampling Equipment Decontamination ................................................... 14
Q5b Sample Analyses ........................................................................................ 14
Q5c Field and Laboratory Quality Assurance and Control ........................... 15
Trip/Equipment Blanks ............................................................................... 15
Duplicate Samples ...................................................................................... 15
Q6 QUALITY ASSURANCE DURING CLOSURE ACTIVITIES ............................ 17
Q7 DOCUMENTATION ................................................................................................ 18
Q8 SECURITY ............................................................................................................... 18

i
WINDSOR LOCKS, CT
Q9 CLOSURE COST PROJECTION ......................................................................... 19
Q10 CLOSURE TIMING PROJECTION ...................................................................... 19
Q11 FINANCIAL ASSURANCE .................................................................................... 19
Q12 CERTIFICATION ..................................................................................................... 20
Q13 REFERENCES ........................................................................................................ 21
TABLES
Q-1 CONTAINERIZED HAZARDOUS WASTES STORED

Q-2 PRELIMINARY CONSTITUENTS OF CONCERN
Q-3 BASIS FOR CLOSURE COST PROJECTION
Q-4 CLOSURE SCHEDULE PROJECTION
FIGURES
Q-1 SITE LOCATION MAP

Q-2 SITE MAP
Q-3 HAZARDOUS WASTE FACILITY LAYOUT
EXHIBITS
Q-1 CHECKLIST FOR TECHNICAL REVIEW OF RCRA PART B APPLICATION:

CLOSURE PLAN
Q-2 DEEP FIGURES ON CLOSURE OF HWSAS
Q-3 CURRENT CLOSURE COST ESTIMATE
Q-4 CERTIFICATION STATEMENT
Q-5 WASTE PERMIT 2004 & 2010
Q-6 FINANCIAL ASSURANCE
ii
ATTACHMENT Q
CLOSURE PLAN AND FINANCIAL ASSURANCE
Q1 INTRODUCTION
Q1a Purpose
This document is a facility Closure Plan for various regulated units at the Hamilton
Sundstrand Corporation facility, located in Windsor Locks, Connecticut (“the
facility”). The EPA Identification number for this facility is CTD001145341. This
Closure Plan is provided in accordance with the requirements for a Part B Permit
application, as presented at 40 CFR 270.14 and 264 and 265 (Subpart G). This
document was prepared using the Connecticut Department of Energy &
Environmental Protection (CTDEEP) “Draft RCRA Closure Plan Guidance for
Treatment, Storage and Disposal Facilities Container Storage Areas and Tank
Systems” as well as the Environmental Protection Agency (EPA) “Regulatory
Completeness Checklist for Hazardous Waste Storage, Treatment and Disposal
Facilities.” The completeness checklist is presented as Exhibit Q-1. A figure
developed by CTDEEP that illustrates the anticipated steps for closure of HWSAs
are provided in Exhibit Q-2.
The regulated units are those which are subject to Part B permitting, including
waste container management/storage areas, the staging area, waste tanks, a waste
compactor, J-Lot area and unloading/loading areas. These regulated units, all of
which are located at Hamilton Sundstrand’s Hazardous Waste Facility (HWF), are
described in detail in the Part B Permit.
Closure is not expected to be implemented in the foreseeable future. For planning

purposes, a closure year of 2035 is provided. A copy of this Closure Plan will be
retained in-house until the certification of closure has been accepted by the
regulatory agencies. The Closure Plan will also be updated according to
modifications that occur at the facility. Hamilton Sundstrand will notify the
regulatory agencies of its intent to close at least 180 days prior to cessation of
hazardous waste storage and treatment operations at its facility.
Upon completion of closure, Hamilton Sundstrand will submit to the Connecticut

Department of Energy & Environmental Protection a certification that the facility has
been closed in accordance with the approved Closure Plan.
Q1b Scope
In accordance with 40 CFR 264.111, closure of the regulated units will be

performed in a manner that:
(a) minimizes the need for further maintenance; and
(b) controls, minimizes or eliminates, to the extent necessary to protect

human health and the environment, the post-closure escape of
1
hazardous waste, hazardous constituents, leachate, contaminated
run-off, or hazardous waste decomposition products to the ground or
surface waters or to the atmosphere; and
(c) complies with the closure requirements of this subpart, including, but
not limited to, the requirements of 264.178, 264.197, 264.310 and
264.601 through 264.603.
Connecticut DEEP has provided a draft guidance document to facilitate the closure
process. The guidance document is a 3-part program, and is designed to facilitate
decision-making during actual closure. Ultimately, the principal decision that must
be rendered is whether clean closure or contingent closure (i.e., “closure as a
landfill”) should occur. The manner of closure will be determined at the time of
closure. For planning purposes, CTDEEP suggests that clean closure is presumed.
It is the intent of Hamilton Sundstrand to achieve clean closure, so post-closure

monitoring is not required. Should it be determined that post-closure and
monitoring are necessary, a post-closure plan will be submitted at the time of
closure.
Q1c Permit Status
Hamilton Sundstrand originally received a RCRA Waste Permit on September 7,

2004, this permit was re-issued on September 29, 2010. A copy of the front page of
the original permit and re-issuance are included in Exhibit Q-5. As indicated in the
permit, the regulated areas at Hamilton Sundstrand are as follows:
Container Storage Areas

Tank Storage Areas
 Non-Hazardous Waste Liquids (I.D. 121 A)
 Used Oil: Non-Hazardous Combustible Liquids/Oils Tank (I.D.
121 B)
Loading/Unloading Areas
Staging Area
Compactor Unit
J-Lot Area
Detailed descriptions of the regulated units are provided in Section Q2.
Q1d Facility Description
Hamilton Sundstrand Corporation is located at One Hamilton Road, in Windsor

Locks, Connecticut. A property map identifying current conditions at the site is
provided as Figure Q-1. The site is located within a well-developed suburban area,
surrounded by agricultural land. Refer to Exhibit I-2a and I-2b of Attachment I for a
map of the surrounding land use. The facility employs roughly 4,000 people.
2
Prior to 1944, land that is now occupied by Hamilton Sundstrand was used for
residential and agricultural purposes. In 1944 the State of Connecticut purchased
this plot of land. The United States Army then purchased a large portion of the
property and occupied it between 1944 and 1945. The US Army utilized the land as
a base for military and personnel equipment and as a training camp. In 1951, most
of the military base was purchased by United Aircraft Corporation (later named
United Technologies in 1975) for use by Hamilton Standard. Facility construction
occurred between 1952 and 1953. During the time frame between 1952 and 1958,
surrounding property was purchased from private landowners to maintain the
growing facility. In 1999 Hamilton Standard merged with The Sundstrand
Corporation thus creating a new corporate entity, Hamilton Sundstrand Corporation.
UTC Aerospace Systems (UTAS) was formed in August 2012 when parent United
Technologies Corporation (UTC) merged existing subsidiary Hamilton Sundstrand
with Goodrich Corporation. In 2018, UTC acquired Rockwell Collins, and merged
with UTAS to form Collins Aerospace. Hamilton Sundstrand Corporation is currently
operating as Collins Aerospace.
The facility consists of four large buildings (Buildings 1, 1A, 2, and 3) and several
smaller buildings including the Hot Fuel Lab, Customer Service School, Fuel Cell
Management Building, Industrial Wastewater Treatment Facility, and Plating
Facility. Buildings 1 and 2 are the main facilities where manufacturing, shipping and
receiving, assembly and test, and engineering occurs. Buildings 1A and 3 are used
primarily as office space. The HWF is located in the southern part of the property,
west of the former Building 2A Pad. A site map is provided as Figure Q-2.
Work performed at the facility includes the research, development and

manufacturing of aircraft and spacecraft equipment. These operations encompass
such industrial processes as electroplating, machining, degreasing, and rig testing.
Hazardous wastes generated on site from these processes consist of

acid/alkali/metal solutions and sludges, solvents (non-halogenated), used oils,
ignitables (e.g., non-halogenated solvents, alcohol’s, and fuels), and unused or
outdated materials.
Hazardous and non-hazardous waste is accumulated and stored in containers and

two aboveground tanks located in Hamilton Sundstrand’s HWF (described in
Section Q2). The RCRA hazardous wastes that Hamilton Sundstrand handles are
listed on the Part A. The waste types and handling methods are provided on Table
Q-1. The majority of hazardous wastes are stored and shipped off-site for final
disposal. A portion of the waste that is generated by the Hamilton Sundstrand,
Windsor Locks facility is treated by an on-site wastewater treatment plant (WWTP)
that is permitted under the Clean Water Act.
Q1e Environmental Setting
The Hamilton Sundstrand, Windsor Locks facility resides on approximately 300

acres of land located primarily in Windsor Locks, Connecticut with portions of the
facility extending into the towns of East Granby and Windsor, Connecticut. The
3
facility’s geographic coordinates are approximately 42 degrees, 55 minutes, 35
seconds north latitude (41˚ 55’ 35”N) and 72 degrees, 41 minutes, 35 seconds west
longitude (72˚ 41’ 35”W). The facility is bounded in the north by Schoephoester
Road on the south by Route 20, and on the east by Hamilton Road. The northern
boundary is land occupied by Bradley International Airport and the southern,
eastern, and western boundaries consists of private residential land.
Topography
The topography at the facility is terraced with the highest elevation (approximately
170 feet, above mean sea level or msl) at the northern extent of the facility, adjacent
to Bradley International Airport. The lowest elevation (approximately 85 feet, above
mean sea level) is at the southern extent of the facility, adjacent to Rainbow Road.
The highest terrace forms a plateau that contains Buildings 1 and 2, (including the
Hazardous Waste Facility) and the associated parking areas and access roads.
Topographic elevations decrease sharply towards the southern extent of the
property near Building 3. Drainage ravines transect the terraces in a south-
southeast orientation. The west branch of Seymour Hollow ravine is situated along
the western border of the facility. Rainbow Brook ravine is situated along the
western border of the facility, and a small valley associated with an unnamed
intermittent stream (Unnamed Stream) originates at the approximate center of the
site and continues south. Steep slopes are also found along the eastern and
western shores of Watts Pond, located along the west side of the site (Dames &
Moore, 1992).
Surface Water Bodies
As illustrated on Figure Q-1, there are four surface water bodies located at or near
the facility and include: Rainbow Brook, Seymour Hollow Brook, “Unnamed
Stream”, and Watts Pond. The water body nearest to the HWF is Watts Pond. Watts
Pond is a manmade pond created in 1965 with a total surface area of 5.75± acres.
Rainbow Brook is located on the western side of the facility. The headwaters are
located northwest of the facility in the vicinity of Bradley International Airport. The
brook then flows in a southerly direction along the western border of the property.
The brook fans out into separate channels before emptying into Watts Pond. These
stream channels discharge into Watts Pond at various locations. The Rainbow
Brook exits at the southeastern portion of Watts Pond and continues to flow in a
southern direction where it eventually empties into the Farmington River.
Seymour Hollow Brook, which also originates in the vicinity of Bradley International
Airport, runs along the eastern portion of the property and flows in a southerly
direction and converges with Rainbow Brook just south of the facility before
emptying into the Farmington River.
The headwaters of the “Unnamed Stream” is situated approximately 250 feet south
of Building 2. It flows south for a distance of 1,700 feet before it merges with
Rainbow Brook just south of the property.
4
Groundwater
Groundwater at the site is classified by the Connecticut Department of Energy &

Environmental Protection as “GB.” The goal for GB groundwater areas is to prevent
further degradation of groundwater by preventing discharges which would cause
irreversible contamination.
Two aquifers have been identified within the vicinity of the facility and include: 1) an
overburden (surficial) aquifer composed of unconsolidated glacial and post-glacial
sediments, and 2) a bedrock aquifer. A layer of glacial till separates the two
aquifers (Dames & Moore, 1992).
Groundwater flows in a general south/southwesterly direction towards the

Farmington River, which serves as the regional groundwater discharge point.
Groundwater flow contained within the upper portions of the subsurface is averted
toward surface waters, Rainbow Brook and Seymour Hollow Brook, in the western
and eastern portions of the site respectively. Data have shown that downward
vertical gradients exist in the overburden aquifer. This evidence can be attributed to
the significant difference between the horizontal and vertical hydraulic conductivity
within and between the soil layers in the subsurface (Dames & Moore, 1992).
The nearest water supply wells are owned by others are located off-site and are
approximately 4,500 feet east of the HWF.
Geology
Site geology is characteristic of North Central Connecticut. Regionally, the bedrock

is typically overlain by deposits of glacial till consisting of an unsorted, non-stratified
mixture of clay, silt, pebbles, cobbles, and boulders in varying proportions (Dames &
Moore, 1992). Depth to bedrock ranges from 63.75 to 170 feet on the site. The
thickness of the till appears to range from 5 feet to 130 feet.
The depth to groundwater ranges from 29 to 55 feet with an average of 41.5 feet.
The soil in this area is classified as poorly graded fine to medium sand. Although
clayey type soils are not abundant on the site, silt and clay horizons are found in
this area. Silt/clay seams range in thickness of0.5 to 3 feet, and are encountered at
depths of less than 10 feet to over 50 feet below grade (Dames & Moore, 1992).
Q2 DESCRIPTION OF REGULATED UNITS
The HWF consists of the following regulated units to be closed:
a. Hazardous Waste Container Storage Area, Loading/Unloading and Staging

Area
b. Two Aboveground Storage Tanks:
-Tank 121A – Non-Hazardous Waste Liquids, Non-Hazardous
- Tank 121B - Used Oil: Non-Hazardous Combustible Liquids/Oils
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c. Compactor Unit
d. J-Lot Area
A layout of the HWF is provided as Figure Q-3. The facility consists of a raised,
rectangular, concrete pad (approximately 2 feet above ground level) and measures
approximately 120 feet by 160 feet. The perimeter of the facility is surrounded by a
berm and fence. A roof covers the whole facility. Areas within the HWF include an
office, locker/shower room, packaging area, shipping/receiving area, aboveground
tank area and waste storage areas. The entire facility is roofed. The office,
locker/shower room and packaging areas are totally enclosed. A description of each
area is provided in the following sections.
Q2a Hazardous Waste Container Storage Area
The hazardous waste container storage area has a maximum storage capacity of
55,000 gallons (including containerized waste located in the staging area).
Containerized wastes are stored on racks segregated into the following groups:
Ignitables/Combustibles, Toxics/Burnables, Toxics/Sludges, Toxics/Soils, and
Toxics/Aqueous.
Within the storage area are the loading/unloading and the staging areas. The
loading/unloading areas are utilized to load and unload wastes. The staging area is
used to stage wastes while in transition to either the container storage area or
packaged for offsite shipment.
The HWF also houses four 15 feet by 10 feet, 500-gallon capacity, heated, self-
contained, moveable hazardous waste storage sheds to segregate incompatible
wastes. The segregated wastes stored in the sheds are as follows: acids, alkaline
wastes, PCB/Isocyanate type wastes, and water-based wastes. Two cabinets to
store and segregate small containerized wastes are also situated within the
hazardous waste storage area and include; the lab pack cabinets situated on the
north side of the building near the PCB/Isocyanate shed and the flammable cabinet
located in the flammable room on the southern side of the facility.
A refrigerator is also utilized to store and segregate small containers of wastes that
are temperature sensitive and for samples being sent to the laboratory for analysis.
Lab Pack Cabinets are utilized to store small containers of wastes.
The facility does not currently receive wastes from off-site.
Wastes that are to be transferred from their original containers to the bulk storage
tanks are brought into the Packaging Room, a part of the HWF. In the Packaging
Room, liquid wastes are pumped out of the individual drums into the bulk tanks.
Pumping is performed in accordance with a Hamilton Sundstrand empty drum
procedure until the drums are “RCRA empty.” After pumping is finished, the RCRA
empty drums are moved to and stored in the Used Empties Storage Trailer located
6
at the HWF. At final disposition, the used empty drums are sent to an outside drum-
reclamation facility.
Record drawings of the HWF are provided in the Part B permit application. A berm
(installed as secondary containment) surrounds the perimeter of the storage area
including the virgin material storage area. Both areas share the same concrete pad
but the virgin product storage area has its own containment system. A roof covers
the entire HWF as well as a poly tarp which shields the northern side of the facility
along the “virgin product storage” area. The tank storage area and the HWF are
separated by a concrete wall on the south side of the facility.
The lower base of the storage area consists of a concrete floor slab overlain by a
compacted washed sand layer. Above the sand layer is a 60-mil HDPE impervious
protective liner. This liner is covered with a layer of compacted washed sand
followed by an eight-inch concrete slab. The concrete is coated with an epoxy
sealant. Floor sections of the HWF are graded/sloped to control run-off.
There are nine observation wells located throughout the Hazardous Waste Facility.
The wells are constructed of a 4-inch diameter 20-slot PVC screen and riser. The
upper portion of the well is encased in an epoxy-coated watertight seal
manhole/vault with a width of 12¼ inches.
Q2b Combustible Used Oil Tank and Non-Hazardous Waste Tank
Hamilton Sundstrand bulks waste in two aboveground storage tanks (Tank 121A
and 121B) located in a roofed structure extending from the HWF just south of the
packaging room. The tanks were installed in June of 1994. Both tanks are
horizontal, cylindrical, double wall, steel with 100% containment capacity within the
interstitial spacing. The outside of the tanks are fiberglass coated to a minimum
thickness of 100- mil for corrosion protection (all exposed steel surfaces, including
tank appurtenances, are coated with approximately 8-mil of epoxy coating). The
tanks have a capacity of 6,000 gallons each and are 12.5 feet in length and 9.0 feet
in diameter.
Tank 121A holds non-hazardous liquids. Tank 121A previously contained

hazardous waste liquids, however partial closure of Tank 121A was achieved on
August 15, 2013.
Tank 121B holds combustible liquids such as used oils. Typical materials stored in
Tank 121B consist of liquid wastes with high flash points such as alcohol based
cleaners, preservative oils, and various cutting, lubrication and hydraulic oils. Tank
121B is designed to hold RCRA regulated hazardous wastes but is used to hold
both non-hazardous and combustible wastes which are sent off-site for used oil
recycling.
Both tanks are batch fed and wastes are manually added to the tanks from
containers through pump stations (one pump station for the non-hazardous tank
and one for the combustible tank) located inside the packaging room. The pump
7
station in the flammable room was removed during the partial closure of Tank 121A.
During loading and unloading operations, an operator is always present. Double
wall containment piping is implemented as a secondary containment precaution.
The primary pipes are constructed of steel while the secondary pipes are
constructed of fiberglass reinforced epoxy. All piping runs to leak detection sumps.
Any liquid accumulated within the interstitial space is able to drain freely into the
leak detection sumps.
The tanks are separated from the rest of the HWF by a masonry fire barrier wall.
The wall is made of 8-inch concrete blocks and stands 10 feet tall.
The rectangular perimeter of the storage area that houses the two tanks consists of
a fence and a fire retardant poly tarp installed on the north, south and west sides of
the tank area. The perimeter of the area is also surrounded by a 1- foot, 6-inch cast
in place concrete berm.
The tanks are atop a 7-inch thick raised pad (same elevation as the HWF)
measuring 40 feet by 20 feet. The 12- inch thick reinforced concrete pad and berm
are coated with an epoxy sealant. Both are installed over a 60-mil high density
polyethylene (HDPE) liner. This is the same HDPE liner that covers the whole area
of the HWF.
Q2c Compactor
The waste compactor is located in the packaging room of the HWF and is used to
compact wastes into a drums. The main waste is rags and debris contaminated with
paints, solvents, coolants and oils. The compactor measures approximately 4 feet
wide by 7 feet high by 3 feet deep. The exhaust is vented to a carbon canister for
air emission control.
Q2d J-Lot Area
The J-Lot Area is located on the southern end of the HWF. Several activities are
performed in the J-Lot Area, including: non-flammable compressed gas storage (in
locked cage); and non-RCRA hazardous waste roll-off storage.
Q3 CLOSURE APPROACH
Once it is decided that closure should commence, the condition of the regulated
units will be assessed to determine whether a release to the surrounding
environment could have potentially occurred. This determination will consist of
inspection of the structural integrity of each unit. If the structural integrity is
acceptable, site characterization for the regulated units will be limited to the
structure. However, if the structural integrity is determined to be inadequate, then
characterization of the surrounding soils will be performed.
Characterization of regulated unit structures is discussed in this section, and was
8
developed using Part 1 of the ”Draft RCRA Closure Plan Guidance for Treatment,
Storage and Disposal Facilities Container Storage Areas and Tank Systems.”
Closure activities for both the container storage area and tank systems are
discussed in Section Q4.
Corrective Action activities are a component of the current Part B permit. Hamilton
Sundstrand is working in conjunction with CT DEEP and EPA to investigate and
remediate historic operations. One of the areas listed is the former Hazardous
Waste Storage Area, identified as Solid Waste Management Unit 3 (SWMU 3). The
Closure Approach focuses on the current HWF. SWMU 3 will be addressed once
closure of the current HWF has been implemented. Historic sampling results from
SWMU 3 are available on file at Hamilton Sundstrand and at the CT DEEP.
Constituents of Concern identified through the above noted processes will be listed
along with associated potential human exposure pathways and appropriate risk or
health based standards. These standards will be used as the Media Closure
Criteria (MCC) for this Closure Plan. Risk and health based standards will be
developed from Connecticut Remediation Standard Regulations (RSRs), found at
RCSA 22a-133K-1 through -3, for exposure through ingestion and the USEPA Risk-
based Compounds (RBC) Table for exposure through inhalation. Dermal exposure
risk will be based on the RBC lists for industrial soil. Consistent with the RSRs, only
those Constituents of Concern (COCs) identified as Volatile Organic Compounds
(Henry’s Law Constant greater than 10-5 and Molecular Weight less than 200) will
be evaluated for environmental and human risk through an inhalation pathway.
CTDEEP will be notified at least 45 days prior to initiation of actual closure activities.
Closure of the hazardous waste storage area and the two storage tanks will involve
decontamination and removal of equipment and structures.
Q3a Assessment at Closure
At closure initiation, the hazardous waste inventory will be removed from the facility
and properly disposed of at a RCRA regulated facility. The maximum inventory
volume would be 55,000 gallons based on design; however, it is not anticipated that
Hamilton Sundstrand will store that quantity of waste. Additional waste inventory
includes the volume of two 6,000 gallon tanks of waste (Tanks 121A and 121B),
and other non-hazardous wastes (J-Lot roll-off, non-flammable compressed gas
cylinders, and universal wastes).
Q3b Structural Integrity Assessment
Once the waste inventory is removed, the integrity of the concrete floor will be
assessed by visual inspection. The inspection will be performed consistent with the
EPA’s Technical Guidance (EPA/530/R-93/005) “Determining the Integrity of
Concrete Sumps.” The inspector will look for deterioration and/or cracks which may
have resulted in failure of the floor and exposure of underlying soils. The inspection
will include identification of significant stains and floor pitting. If cracking or other
signs of deterioration are identified, it will be concluded that a release had the
9
potential to impact the subsurface, and that further investigations are warranted.
To facilitate this portion of the Structural Integrity Assessment, records of any repair
work performed in the Hazardous Waste Facility area will be permanently entered
into the operating record of the facility. These records will be used to support the
conclusion that the flooring was maintained in a good condition.
During the initial assessment, the nine observation wells located throughout the
HWF will be opened to determine whether any liquids have accumulated beneath
the floor. If liquid has accumulated at any of the wells, a sample will be collected
and analyzed for the parameters identified on Table Q-2.
If any constituents are detected above naturally occurring levels, it will be concluded
that a release has occurred and that further investigations are warranted. Therefore,
investigations into the floor subsurface may occur if signs of a release or the
potential for a release to have occurred are evident. Investigations would consist of
concrete chip sampling, soil sampling, and could lead to concrete and soil removal.
Tank system integrity assessment will be conducted to determine whether the tank
system could have leaked. The assessment will include, at a minimum, a review of
the leak detection monitoring records. If the test results show the tank system could
not have leaked, subsurface soils will not be investigated for presence or extent of
contamination. The completed integrity assessment will be appended to the closure
plan.
This Closure Plan presumes that the initial assessment at the time of closure will
not result in the need for further investigations. This presumption is made because
(1) the tanks and floor near loading/unloading areas are inspected daily and the
remaining portions of the HWF are visually inspected weekly, consistent with 40
CFR 264.15 and 264.174, and (2) the floor is coated with a chemical-resistant and
impervious epoxy that is routinely maintained. However, if at the time of closure
evidence of an actual or potential release of waste is observed, the CTDEEP will be
notified and a Sampling Characterization Work Plan will be developed. The
purpose of the work plan will be to outline the steps to achieve clean closure at the
facility.
Q4 CLOSURE ACTIVITIES
Q4a Tank Decontamination and Confirmatory Sampling
Waste stored within Tanks 121A and Tank 121B will be removed using vacuum
trucks. Any remaining waste residues within the tanks may require the aid of
mechanical agitators, additional rinsing with water, and manual labor for full
removal. After removal of all waste inventories, each tank and its lines (along with
storage pads and containment berms) will be pressure washed with non-phosphate
detergent solvent followed by a triple rinse. To facilitate rinsing, a high pressure
spray-head or spray-wand will be operated aggressively to direct rinsing solution to
all hard to reach areas. Each rinse solution may be increased in strength and used
10
where heavy residue build-up is suspected. Piping and other appurtenances will be
decontaminated by triple flushing.
Once cleaning and rinsing has been performed, the tank interiors will be visually
inspected to determine whether any materials remain in the tanks. Further pressure
washing will occur, if necessary, based on visual inspection until it is observed to be
visually clean or it is determined that further power washing is likely to be
ineffective. If possible, the tank interiors will be photographed to document
cleaning. It is estimated that a maximum of 600 gallons of wastewater per tank will
be generated during pressure washing and rinsing.
Wash and rinse waters will be collected and characterized for off-site disposal. The
resulting water is expected to be non-hazardous due to the non-hazardous nature of
the materials stored.
Once cleaning is complete, it is anticipated that each tank system will be dismantled
as disposed as scrap metal. A Bill-of-Lading will be used to document the amount of
scrap metal generated and recycled. Sampling handling procedures are described
in Section Q5.
Q4b Compactor & Equipment Decontamination
Most of the containers in the HWF are stored on racks. Additionally, there are four
portable storage sheds used to isolate incompatible wastes and a cage in the J-Lot
area. The racks, sheds and cage will be decontaminated by power washing using a
non-phosphate detergent, followed by triple rinsing.
Partial closure of the hazardous waste compactor was completed in August 2015.
An in-kind compactor was installed within the same footprint of the HWF. The
compactor will be power washed, but may also require wiping and scraping to
remove any gross contamination. Once decontamination has been completed, each
cleaned unit will be visually inspected for any staining. If staining is observed, an
attempt will be made to further remove the stain by using a bristle brush. If the
bristle brush is not effective, no further cleaning will be attempted.
Floor surfaces surrounding fixed equipment will be isolated by means of tarp berms
or adsorbent pillows to containerize and collect cleaning and rinse waters. Small,
moveable, or portable equipment such as secondary containment pallets will be
moved to a central decontamination area that will be similarly isolated by means of
berms and tarps. Pressure washing, triple rinsing, and separate collection of wash
and rinse water will be employed. Wash water and rinse water will be collected
separately as the wash water will be expected to have contamination levels higher
than the rinse water. The final rinse will be analyzed for the COCs. If the results of
the analysis are less than the MCC, the final rinse will demonstrate the
decontamination. If the final rinse has levels of COCs above the MCC, additional
pressure washing and rinsing will occur with analysis of the rinsate until it is
11
determined that further cleaning will not provide a beneficial result. The wash and
rinse water itself will be vacuum collected and analyzed for the Constituents of
Concern. If the results of the analysis are less than the MCC, the water will be
classified as non-hazardous waste. Otherwise, the water will be classified as a
hazardous or non-hazardous waste and disposed of properly.
It is anticipated that approximately 2,000 gallons of wastewater will be generated

from these activities. The wastewater will be sampled for the constituents listed on
Table Q-2. If the results are less than the MCC listed on Table Q-2, the wastewater
will be disposed of as non-hazardous waste. Otherwise, the wastewater will either
be classified as hazardous or non-hazardous waste. Regardless, disposal will
occur at a permitted facility by a licensed transporter.
Once decontamination activities have been completed for the equipment, it is

anticipated that the units will be dismantled and sold as scrap metal. A Bill-of-
Lading will be used to document the amount of scrap metal generated and recycled.
Q4c Floor Decontamination and Confirmatory Sampling
The concrete floor surface has an epoxy sealant, including the packaging area, rack
storage area, tank area, staging area, and loading and unloading areas, and the J-
Lot area. Decontamination of the Hazardous Waste Facility will consist of pressure
washing the floor with a non-phosphate detergent. The floor will also be rinsed with
clean water following pressure washing activities. Floor surfaces will be isolated by
means of tarp berms or adsorbent pillows to containerize and collect cleaning and
rinse waters. Wash water and rinse water will be collected separately as the wash
water will be expected to have contamination levels higher than the rinse water.
The final rinse will be analyzed for the COCs. If the final rinse has levels of COCs
above the MCC, additional pressure washing and rinsing will occur with analysis of
the rinsate until it is determined that further cleaning will not provide a beneficial
result. Wash and rinse waters will be collected using a wet vacuum and transferred
into appropriate containers.
It is estimated that an additional 2,000 gallons of rinse waters will be generated

during pressure washing of the floor within the HWF.
The floor of the Hazardous Waste Facility is maintained with epoxy sealant
therefore, no failure is expected to have occurred. However, CTDEEP requires that
sampling of the floor should occur to verify that a release did not occur. Therefore,
following decontamination, concrete chip sampling will occur using a hammer drill.
At this time, it is envisioned that approximately 50 discrete samples will be collected
from throughout the storage portion of the HWF. The number of samples is based
on the area where hazardous wastes are currently stored, plus a lesser number of
samples for other open areas (including the J-Lot area). The locations where the
samples will be collected will be determined at the time of closure, and will likely be
both randomly and judgmentally determined. The samples will be analyzed for the
COCs listed in Table Q-2. However, samples with the highest probability of
contamination, such as samples from stained areas will be analyzed for COCs
12
defined in in 40CFR Part 264 Appendix IX (less pesticides, herbicides, insecticides,
fungicides, rodenticides, dioxins and furans). Additionally, background concrete
chip samples may be collected to account for the inherent concentration of metals
typically found in concrete.
The sample results will be compared to the MCC listed on Table Q-2 and to
background. Should results be found greater than these criteria, the extent of the
release will be ascertained, which may necessitate sampling of the soil below the
surface. Also, concrete scarification and removal may occur at certain sections of
the facility. These decisions will be made once the results of the sampling effort
have been received and evaluated, and in consultation with CTDEEP.
Q4d Worker Safety and Decontamination
Precautions will be taken so that safe conditions are maintained for those engaged
in closure activities. The contractor performing closure activities will certify that the
provisions of Occupational Health and Safety Act (OSHA) as amended have been
followed. A Health and Safety Plan for the RCRA closure activities will be required
of the contractor pursuant to the OSHA regulatory requirements found in 29 CFR
1920.120.
During closure there will be contact between the regulated materials and both
equipment and personnel conducting the closure activities. Therefore, equipment
and personnel must be decontaminated.
Removal of concrete and soil are not anticipated. However, if required, the
procedure for equipment decontamination will consist of two steps: (1) physically
removing as much material as possible and (2) pressure washing or steam-cleaning
the equipment to remove any remaining materials. All residual material will be
containerized and disposed of appropriately. Water generated during the pressure
washing or steam-cleaning process will be collected in a polyethylene lined basin
and removed using a dedicated bucket and/or pump. The wash water will be
containerized and disposed of appropriately.
Personnel equipment in contact with material from the regulated unit will be
decontaminated by washing with a non-phosphate soap solution and rinsing with
tap water. The wash water will be collected, characterized and managed and
disposed of accordingly.
Expendable items (i.e., Tyvek suits, gloves) will also be containerized, characterized
and managed and disposed of accordingly. In addition, the polyethylene sheets
used for decontamination activities will be containerized and disposed of
appropriately.
Decontamination of the equipment will be documented with close-up photographs of

each piece of equipment after cleaning as a visual examination is the criteria for
13
decontamination of equipment. Photographs taken to document closure will be
submitted as part of closure certification.
Q4e Generated Waste Disposal
Wash waters and rinse waters will be characterized and transported off-site for
disposal by a licensed transporter to a permitted facility to be determined at the time
of closure. If the wastewater sampling results from a particular wastestream are
less than the MCC, the wastewater from that wastestream will be classified as non-
hazardous. Otherwise, the wastewater will be properly characterized (as hazardous
or non-hazardous waste), managed appropriately on-site, and disposed of at a
licensed facility.
As previously mentioned, the tanks, compactor, racks, storage sheds and other
appurtenances will be managed as scrap metal. A Bill-of-Lading for the scrap metal
will be obtained to document removal and disposal.
Other waste that will be generated from the decontamination and confirmatory
sampling of the regulated units include personal protective equipment (PPE). This
material will be containerized and will be discarded as a hazardous waste once
closure has been completed.
Q5 SAMPLE METHODOLOGIES AND HANDLING PROCEDURES
Q5a Sampling Equipment Decontamination
All sampling equipment will be decontaminated between samples to avoid cross-

contamination. As concrete chip sampling is necessary, sampling equipment will be
thoroughly decontaminated between points. The decontamination procedure will
consist of the following sequence: non-phosphate detergent scrub, tap water rinse,
methanol solution scrub, deionized water rinse, nitric acid solution rinse and a final
deionized water rinse.
Rinse waters from equipment decontamination procedures will be containerized

with the rinse waters generated as a result of the area decontaminations for
disposal purposes.
Q5b Sample Analyses
Samples collected will be analyzed for the COCs identified for each of the
respective regulated units. Samples will be analyzed in accordance with the
procedures identified in SW-846. The EPA method numbers for all COCs are
presented on Table Q-2. The table also indicates the parameter holding times, the
type of sample container for each parameter, preservative, and the detection limit
range. Samples with the highest probability of contamination, such as samples from
stained areas, will be analyzed for COCs defined in 40 CFR Part 264 Appendix IX
(except for pesticides, herbicides, insecticides, fungicides, rodenticides, dioxins and
furans).
14
Samples at each sampling location will be given a unique identifying number. A
sample label will be affixed to each sample container at the time of collection to
prevent sample misidentification. Information recorded on the sample label will
include: (1) Sample identification number, (2) Client/project name and location, (3)
Date and time of sample collection, (4) Sample preservatives, and (5) identification
of sampler.
Samples will be hand-delivered to a State of Connecticut certified laboratory in the

shortest time possible. The samples will be kept chilled at four degrees Celsius
until delivery is accomplished.
Control of samples will be maintained at all times using Chain-of-Custody forms.

The Chain-of-Custody forms will be completed and signed by all persons involved in
the chain of possession with the date and time, and accompany each cooler or
other shipping container to the receiving laboratory.
Q5c Field and Laboratory Quality Assurance and Control
Quality assurance and quality control (QA/QC) protocols will be followed in the field
and laboratory in accordance with the SW-846 of latest revision. The director of the
certified laboratory performing the analysis will perform data validation and
document quality control per SW-846.
Each quality assurance/quality control (QA/QC) sample will be given its own sample
number. The identity of these samples will be withheld from the laboratory
conducting the analysis.
Trip/Equipment Blanks
The purpose of the trip and equipment blanks is to determine whether samples
and/or sampling equipment have been exposed to contaminants.
The trip blank will be prepared by the laboratory which supplies the sample
containers and ultimately analyzes the samples. Sample containers for each
parameter will be filled with laboratory de-ionized water. The trip blanks will
accompany the sample containers from the time that they leave the lab until the
time that they are returned to the lab for analysis. The trip blank will then be
submitted, unopened, to the lab as if it had been collected in the field. One trip
blank per day will be submitted for those days when aqueous samples are
collected. The equipment blanks will be prepared using laboratory supplied de-
ionized water and sample containers.
Duplicate Samples
The objective of duplicate sampling is to check the accuracy of the laboratory

analysis. Duplicate samples will be collected in the field, and will constitute
approximately 10 percent of all samples collected. The duplicate sample consists of
15
one sample split into two equal aliquots. The duplicate will be assigned a
sequential number such that the receiving laboratory will not be aware that a
duplicate exists. The duplicate will be handled and collected as any other sample
collected.
16
Q6 QUALITY ASSURANCE DURING CLOSURE ACTIVITIES
Hamilton Sundstrand will provide an on-site inspector familiar with both the facility
and the plans and specifications for closure. The inspector will be present during all
phases of closure activities and will monitor closure activities and document
satisfactory completion of all phases of the work.
General inspections will be made throughout closure. Inspections shall be

performed in accordance with the applicable recommendations and guidelines
contained in the EPA Technical Guidance Document "Construction Quality
Assurance for Hazardous Waste Land Disposal Facilities," EPA/530-SW-86-031.
This document provides target criteria for the acceptance of work performed. The
inspector will be familiar with this document.
The QA/QC program for closure activities at the facility will be implemented by an
independent professional engineer to be selected at the time when closure activities
are implemented. All aspects of the closure activities will be monitored and
coordinated by the professional engineer or his/her designated representative. The
professional engineer or the designated representative will act as the QA/QC
Coordinator.
Qualifications of the independent professional engineer and his/her designated

representative will be provided to the regulatory agencies prior to initiation of
closure activities. The responsibilities of the QA/QC Coordinator will include, but
will not be limited to, the following:
 Verification that all raw data are interpreted correctly. This includes all
laboratory analytical data from samples collected and submitted for analysis.
 Establishment of a liaison between Hamilton Sundstrand, the contractor and

the regulatory agencies. As liaison, the QA/QC Coordinator will oversee all
communication matters between parties and the resolution of any and all
minor departures from the approved Closure Plan.
 Collection and/or observing the collection of the clean closure verification

samples. All samples will be submitted to a State of Connecticut certified
laboratory for analysis. All laboratory analyses will be conducted using
QA/QC procedures specified in the EPA document Test Methods for
Evaluating Solid Waste, SW-846 (latest edition).
Periodic and routine visits will be made to the site during the closure period to
observe closure activities and inspect the adequacy of all work. The QA/QC
Coordinator will, at a minimum, observe each individual stage and item of work.
The Coordinator will also review all documentation collected at the facility at the
time of each inspection. The date and results of each inspection will be recorded by
the certified Coordinator in a log book at the facility.
17
At this time, the identification of the remediation contractor who will implement the
closure activities is unknown. Once Hamilton Sundstrand has notified the
regulatory agencies of its intent to close the regulated units, and has obtained
approval for this closure plan, it is anticipated that Hamilton Sundstrand will perform
any remediation activities necessary to close the regulated units under the guidance
of an independent registered Professional Engineer.
Q7 DOCUMENTATION
Proper documentation of all QA/QC activities will facilitate the final certification of
closure and will provide Hamilton Sundstrand with a permanent record of the
closure activities. Documentation will include the following:
a. Results from confirmatory sampling and analysis.
b. A sequential, dated, photographic record documenting each step of

closure.
c. Summary of pre-closure meetings, inspection reports and daily logs

maintained during closure.
d. All minor modifications made to the approved Closure Plan and

description of how it was determined to be a minor modification.
e. Closure certification statements.
f. As-built drawings that document initial and final conditions.
g. QA/QC results for any construction materials brought on-site and left in
place to facilitate closure.
h. Hazardous waste determination results, final disposition location, and

copies of waste manifests.
Q8 SECURITY
Security requirements are promulgated at 40 CFR 264.14. In the regulations, it is

stated that "the owner must prevent the unknowing entry and minimize the
possibility of unauthorized entry of persons or livestock onto the active portion of the
facility."
Road access to the southern edge of the facility is along State Route 20, to the
north it is along Hamilton Road, and the east it is along Cargo Road. State Route 20
is located adjacent to the property line and carries the largest volume of traffic of
any road in the area. From all of these entrances, traffic enters onto site roads and
to parking areas. All roads are well maintained and traffic delays usually are not
encountered. Access to internal site roads is controlled by manned access control
points.
18
The facility has a 24-hour surveillance system that provides continuous security for
all of its operations. Security is provided by a number of factors including a fence
around the entire site, closed-circuit television monitoring, and a 24-hour guard
service that controls personnel and vehicular access to the site. Guard posts, and
general and restricted traffic patterns are outlined in Figure Q-2.
Q9 CLOSURE COST PROJECTION
Closure cost requirements are promulgated at 40 CFR 264.142. As previously

indicated, clean closure will be pursued for each regulated unit. The projected
closure cost based on the pursuit of clean closure is presented on Table Q-3. The
cost projections for implementing this closure plan includes; removal of waste
inventories; decontamination of tanks, container storage pad and associated
hardware; disposal of wash waters and solvents; and certificate of closure.
The closure cost projection will be kept on file at the facility, and will be revised
annually or whenever changes in the closure activities or closure plan increase the
cost of closure. If, during a calendar year, the closure cost estimates are not
affected by changes in closure activities, the closure cost estimates will be adjusted
to reflect changes brought about by economic inflation. The Department of
Commerce’s Annual Implicit Price Deflator for Gross National Product will be used
to make this adjustment.
Q10 CLOSURE TIMING PROJECTION
The regulations specified in 40 CFR 264.113 present time limits for completion of
closure activities. The time limit is 180 days from receipt of the closure approval by
the regulatory agencies. A schedule of closure will be provided prior to
implementation of closure activities. It is anticipated at this time that closure for
each of the regulated units will be achieved within 180 days of the beginning of
closure activities, or 180 days after the closure plan is approved, whichever is later.
Notification of closure will be provided at least 45 days prior to the start of closure
activities. Table Q-4 shows the proposed schedule of individual closure activities.
As stated previously, for planning purposes the anticipated closure date is January
1, 2035.
Q11 FINANCIAL ASSURANCE
Financial assurance during the closure period is required per 40 CFR § 264.143, as
incorporated per RCSA § 22a-449(c)-104(a)(1) and (a)(2). Financial assurance is a
mechanism established and made available to the CTDEEP to assure closure of the
facility. Hamilton Sundstrand has established a letter of credit, supported by a
standby trust agreement, in an amount consistent the current calculated closure
cost estimate included in Exhibit Q-3. Hamilton Sundstrand will continue to annually
adjust this closure cost estimate, and letter of credit as necessary, for inflation per
19
40 CFR § 264.142, as incorporated per RCSA § 22a-449(c)-104(a)(1) and (a)(2).
Hamilton Sundstrand will continue to annually submit a summary of the current
closure and post-closure cost estimates to CTDEEP.
Copies of the above-referenced letter of credit and the standby trust agreement can
be found in Attachment R. The CTDEEP holds the original letter of credit and
standby trust agreement, which also cover the current calculated post-closure cost
estimate. The CTDEEP also holds the original payment bond covering third-party
liability per 40 CFR § 264.147, as incorporated per RCSA § 22a-449(c)-104(a)(1)
and (a)(2). A copy of which can also be found in Attachment R.
Q12 CERTIFICATION
Within 60 days of completion of closure, Hamilton Sundstrand will submit to the

regulatory agencies certification by Hamilton Sundstrand and by an independent
registered professional engineer that the regulated units have been closed in
accordance with specifications in the approved Closure Plan. The certification will
be submitted pursuant to 40 CFR 264.115. The proposed Certification is provided
as Exhibit Q-4.
20
Q13 REFERENCES
Connecticut DEEP, “Draft RCRA Closure Plan Guidance for Treatment, Storage
and Disposal Facilities Container Storage Areas and Tank Systems,” current
version (undated):
https://www.ct.gov/deep/lib/deep/waste_management_and_disposal/remediation_w
aste/RCRA_Closure_Plan_Guidance.pdf
US EPA, “Test Methods for Evaluating Solid Waste, Volume II,” SW-846, Third
Edition, November 1986.
US EPA, “Determining the Integrity of Concrete Sumps,” EPA/530/R-93-005, 1991.
United States Environmental Protection Agency’s Technical Guidance (EPA/530/R-

93/005 and EPA/530-SW-88-031).
Dames & Moore, 1992, Environmental Setting, RCRA Facility Investigation Phase I
Report, for Hamilton Standard.
21
TABLES
Q-1 Containerized Hazardous Waste Stored

Q-2 Preliminary Constituents of Concern
Q-3 Basis for Closure Cost Projection
Q-4 Closure Schedule Projection
TABLE Q-1
CONTAINERIZED HAZARDOUS WASTES STORED
BASIS FOR PRELIMINARY CONSTITUENTS OF CONCERN
RCRA CLOSURE PLAN
WINDSOR LOCKS, CONNECTICUT
EPA HAZARDOUS WASTE DESCRIPTION WASTE PARAMETERS PRELIMINARY CONSTITUENTS

WASTE NUMBER OF CONCERN
D00l Ignitable Not Applicable Not Applicable (Ignitability)
D002 Corrosive Not Applicable Not Applicable (Corrosivity)
D003 Reactive Not Applicable Not Applicable (Reactivity)
D004 Arsenic Arsenic Arsenic
D005 Barium Barium Barium
D006 Cadmium Cadmium Cadmium -
D007 Chromium Chromium Chromium

D008 Lead Lead Lead
D009 Mercury Mercury Mercury
D0l0 Selenium Selenium Selenium
D0ll Silver Silver Silver
D018 Benzene Benzene Benzene
D021 Chlorobenzene Chlorobenzene Chlorobenzene
D022 Chloroform Chloroform Chloroform
D026 Cresol Cresol Cresol
D027 Dichlorobenzene, 1,4- Dichlorobenzene, 1,4- Dichlorobenzene, 1,4-
D028 1,2-Dichloroethane 1,2 Dichloroethane 1,2 Dichloroethane
D029 1,1-Dichloroethylene 1,1-Dichloroethylene 1,1-Dichloroethylene
D035 Methyl ethyl ketone Methyl Ethyl Ketone Methyl Ethyl Ketone
D039 Tetrachloroethylene Tetrachloroethylene Tetrachloroethylene
D040 Trichloroethylene Trichloroethylene Trichloroethylene
TABLE Q-1
RCRA CLOSURE PLAN
EPA HAZARDOUS PRELIMINARY

WASTE NUMBER WASTE DESCRIPTION WASTE PARAMETERS CONSTITUENTS
OF CONCERN
F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene Tetrachloroethylene
Tetrachloroethylene, Trichloroethylene, Methylene Chloride, 1,1,1- Trichloroethylene Trichloroethylene
trichloroethane, carbon tetrachloride and chlorinated fluorocarbons. Methylene chloride Methylene chloride
All spent solvent mixture/blends used in degreasing containing, 1,1,1-trichloroethane 1,1,1-trichloroethane
before use, a total of ten percent or more (by volume) of one or more Carbon tetrachloride Carbon tetrachloride
of the above halogenated solvents or those solvents listed in F002, Chlorinated fluorocarbons Chlorinated fluorocarbons
F004 and F005; and still bottoms from the recovery of these spent
solvents and spent solvent mixtures.
F002 The following spent halogenated solvents: Tetrachloroethylene, Tetrachloroethylene Tetrachloroethylene
methylene chloride, trichloroethylene, 1,1,1-trichloroethane, Methylene chloride Methylene chloride
chlorobenzene, 1,1,2-trichloro-1,2,2-trifluoroethane, ortho- Trichloroethylene Trichloroethylene
dichlorobenzene, trichlorofluoromethane, and 1,1,2-trichloroethane; 1,1,1-trichloroethane 1,1,1-trichloroethane
all spent solvent mixture/blends containing, before use, a total of O-Dichlorobenzene O-Dichlorobenzene
10% or more (by volume) of one or more of the above halogenated Trichlorofluoromethane Trichlorofluoromethane
solvents or those listed in F001, F004 or F005; and still bottoms Chlorobenzene Chlorobenzene
from the recovery of those spent solvents and spent solvent 1,1,2-Trichloroethane 1,1,2-Trichloroethane
mixtures.
F003 The following spent non-halogenated solvents: Xylene, acetone, Xylene Xylene
ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl, ketone, n- Benzene Benzene
butyl, alcohol, cyclohexanone and methanol; all spent solvent Acetone Acetone
mixture/blends containing, before use, a total of 10% or more (by Ethyl Benzene Ethyl Benzene
volume) of one or more of the above halogenated solvents or those
listed in F001, F002 or F004; and still bottoms from the recovery of
those spent solvents and spent solvent mixtures.
TABLE Q-1
RCRA CLOSURE PLAN

OF CONCERN
F005 The following spent non-halogenated solvents: Toluene, methyl Toluene Toluene
ethyl, ketone, carbon disulfide, isobutanol, pyridine, benzene, 2- Benzene Benzene
ethoxyethanol and 2-nitropropane; all spent solvent mixture/blends Methyl ethyl ketone Methyl ethyl ketone
containing, before use, a total of 10% or more (by volume) of one or Carbon disulfide Carbon disulfide
more of the above halogenated solvents or those listed in F001, F002 Pyridine Pyridine
or F004; and still bottoms from the recovery of those spent solvents 2-Ethoxyethanol 2-Ethoxyethanol
and spent solvent mixtures.
F006 Wastewater treatment sludges from electroplating operations except Cadmium Cadmium
from the following processes: 1) sulfuric acid anodizing of Chromium (hexavalent) Chromium
aluminum; 2) tin plating on carbon steel; 3) zinc plating (segregated Nickel Nickel
basis) on carbon steel); 4) aluminum or zinc-aluminum plating on Cyanide (Complexed) Cyanide (Complexed)
carbon steel; 5) cleaning/stripping associated with tin, zinc and
aluminum plating bath solutions from electroplating operations.
F007 Spent cyanide plating bath solutions from electroplating operations. Cyanide Cyanide
F008 Plating bath residues from the bottom of plating baths from Cyanide Cyanide
electroplating operations where cyanides are used in the process.
F009 Spent stripping and cleaning bath solutions from electroplating Cyanide Cyanide
operations whose cyanides are used in the process.
F011 Spent cyanide solutions from salt bath pot cleaning from metal heat Cyanide Cyanide
treating operations.
TABLE Q-1
RCRA CLOSURE PLAN

OF CONCERN
F019 Wastewater treatment sludges from the chemical conversion coating Chromium (hexavalent) Chromium (hexavalent)
of aluminum except from zirconium phosphating in aluminum can Cyanide (complexed) Cyanide (complexed)
washing when such phosphating is an exclusive conversion coating
process. Wastewater treatment sludges from the manufacturing of
motor vehicles using a zinc phosphating process will not be subject
to this listing at the point of generation if the wastes are not placed
outside on the land prior to shipment to a landfill for disposal and
are either: disposed in a Subtitle D municipal or industrial landfill
unit that is equipped with a single clay liner and is permitted,
licensed or otherwise authorized by the state; or disposed in a
landfill unit subject to, or otherwise meeting, the landfill
requirements in § 258.40, § 264.301 or § 265.301. For the purposes
of this listing, motor vehicle manufacturing is defined in paragraph
(b)(4)(i) of this section and (b)(4)(ii) of this section describes the
recordkeeping requirements for motor vehicle manufacturing
facilities
F039 Leachate (liquids that have percolated through land disposed wastes) Refer to other waste streams. Refer to other waste streams.
resulting from the disposal of more than an restricted waste
classified as hazardous under Subpart D of this Part. (Leachate
resulting from the disposal of one of more of the following EPA
Hazardous Wastes and no other Hazardous Wastes returns it’s EPA
Hazardous Waste Number(s): F020, F021, F022, F026, F027 and/or
F028.
P011 Arsenic oxide As2O5 Arsenic Arsenic
P012 Arsenic oxide As2O3 Arsenic Arsenic
P029 Copper cyanide Copper, Cyanide Copper, Cyanide
P030 Cyanides (Soluble cyanide salts) not otherwise specified Cyanide Cyanide
TABLE Q-1
RCRA CLOSURE PLAN

OF CONCERN
P064 Methyl isocyanate Cyanide Cyanide
P068 Methyl hydrazine Hydrazine Hydrazine
P087 Osmium tetroxide Osmic Acid Not Applicable
P096 Hydrogen phosphide Phosphorous Not Applicable
P098 Potassium cyanide; K(CN); Potassium cyanide Cyanide, Potassium Cyanide
P104 Silver cyanide Silver, Cyanide Silver, Cyanide
P105 Sodium azide Sodium Not Applicable (Reactivity)
P106 Sodium cyanide Na(N); Sodium cyanide Cyanide Cyanide
Pl20 Vanadium oxide Vanadium Vanadium
U002 Acetone Acetone Acetone
U019 Benzene Benzene Benzene
U031 Butyl alcohol Butanol Not Applicable
U044 Chloroform 1,1,1-Trichloroethane 1,1,1-Trichloroethane
U057 Cyclohexanone Cyclohexanone Not Applicable (Ignitability)
U067 Ethylene dibromide Ethylene Dibromide Ethylene Dibromide
U075 Dichlorodifluoromethane; Methane dichlorodifluoro- Dichlorodifluoromethane Dichlorodifluoromethane
U080 Methane, dichloro- Methylene Chloride Methylene Chloride
U102 Dimethyl phthalate Dimethyl Phthalate Dimethyl Phthalate
U117 Ethyl ether Ethyl Ether Not Applicable (Ignitability)
U121 Methane, trichlorofluoro-; Trichloromonofluoromethane Trichloromonofluoromethane Trichloromonofluoromethane
Ul22 Formaldehyde Formaldehyde Formaldehyde
TABLE Q-1
RCRA CLOSURE PLAN

OF CONCERN
U133 Hydrazine Hydrazine Hydrazine

U134 Hydrofluoric acid Fluoride Not Applicable (Corrosivity)
U144 Lead Acetate Lead Lead
Ul51 Mercury Mercury Mercury
Ul54 Methanol Methanol Not Applicable (Ignitability)
Ul59 Methyl ethyl ketone Methyl Ethyl Ketone ' Methyl Ethyl Ketone
U160 Methyl ethyl ketone peroxide Methyl Ethyl Ketone Methyl Ethyl Ketone
Ul61 Methyl isobutyl ketone Methyl Isobutyl Ketone Not Applicable (Ignitability)
Ul65 Naphthalene Naphthalene Naphthalene
U188 Phenol Phenol Phenol
U197 p-Benzoquinone; 2,5-Cyclohexadiene-1; 4-dione Benzene Benzene
U210 Tetrachloroethylene Tetrachloroethylene Tetrachloroethylene
U213 Tetrahydrofuran Tetrahydrofuran Not Applicable (lgnitability)
U219 Thiourea Thiourea Thiourea
U220 Toluene Toluene Toluene
U223 Toluene diisocyanate Benzene, Toluene Toluene, Cyanide
U226 Ethane, 1,1,1-trichloro-; Methylchloroform 1,1,I-Trichloroethane 1,1,I-Trichloroethane
U228 Trichloroethylene Trichloroethylene Trichloroethylene
U239 Xylene Xylene Xylene
TABLE Q-2
PRELIMINARY CONSTITUENTS OF CONCERN
SAMPLE HANDLING AND MEDIA CLOSURE CRITERIA
RCRA CLOSURE PLAN
MEDIA CLOSURE CRITERIA
TYPICAL SAMPLE SOLIDS

PRELIMINARY CONSTITUENTS ANALYTICAL DETECTION PRESERVATION HOLD WATER
RES DEC GB PMC GPC
OF CONCERN METHOD LIMITS METHODS TIMES (mg/Kg) (mg/Kg) (ug/l)
INORGANICS
Arsenic 6010 Soil: Soil: Ice (4o C) 10 0.5 mg/l 50
Copper 6010 1-5 mg/Kg 2500 13 mg/l 1300
Silver 6010 6 months 340 0.36 mg/l 36
Vanadium 6010 470 0.50 mg/l 50
Lead 6010 400 0.15 mg/l 15
Mercury 7470 20 0.02 mg/l 2
Cadmium 6010 Water: HNO3 (pH<2), 34 0.05 mg/l 5
Chromium (hexavalent) 7196 Water: Ice (4o C) 100 NE 110
Barium 6010 1-10 ug/l 4700 10 mg/l NE
Selenium 6010 340 0.5 mg/l 50
Nickel 6010 1400 1 mg/l 100
Cyanide (total) 9014 For cyanide in For cyanide in water: 14 days 1400 NE 200
water: 70 mg/l 10 NaOH (pH above 12)
ppb Ice (4o C)
OTHER PARAMETERS
Corrosivity (towards steel) 1110
Ignitability 1010, 1030 NA Na ASAP NA NA NA
Reactivity Chapter 7
PCBS 8082 1 mg/kg Ice (40 C) No Hold Time
TABLE Q-2
RCRA CLOSURE PLAN

RES DEC GB PMC GPC
VOLATILE ORGANICS
Acetone 8260 500 140 700
Methyl Ethyl Ketone 8260 500 80 400
Toluene 8260 500 40 200
Xylene 8260 Soil: Soil: Ice (4o C) 500 19.5 530
Tetrachloroethylene 8260 1-10 ug/kg 12 1 5
Trichloroethylene 8260 56 1 5
Methyene Chloride 8260 82 1 5
1,1,1-trichloroethane 8260 14 days 500 40 200
Carbon Tetrachloride 8260 4.7 1 5
o-Dichlorobenzene 8260 Water: Water: 500 3.1 600
Trichlorofluoromethane 8260 1-10 ug/L HCl, Ice (4o C) 500 260 1300
Chlorobenzene 8260 500 20 100
1,1,2 - trichloroethane 8260 11 1 5
Benzene 8260 21 0.2 1
Ethyl benzene 8260 500 10.1 700
Carbon Disulfide 8260 500 140 700
2-ethoxyethanol 8260 NE NE NE
Chloroform 8260 100 1.2 6
1,2 - Dichloroethane 8260 6.7 0.2 1
1,1 - Dichloroethylene 8260 1 1.4 7
Ethylene Dibromide 8260 0.007 0.1 0.05
Dichlorodifluoromethane 8260 NE NE NE
Naphthalene 8260 1000 56 280
TABLE Q-2
RCRA CLOSURE PLAN

RES DEC GB PMC GPC
Hydrazine ASTM D-1385 5 ppb NE NE NE
Formaldehyde SW8315A 6.2 µg/L 3 days NE NE NE
SEMIVOLATILE ORGANICS
Dimethylphthalate 8270 Soil: 7/14 days to 1000 1100 5600
Thiourea None available 660 µg/Kg Ice (4°C) extract
Phenol 8270 (liquid/solid) 40 1000 800 4000
Pyridine 8270 Water: days to analysis NE NE NE
10 µg/L
TABLE Q-3
HWM FACILITY CLOSURE COST PROJECTION
RCRA CLOSURE PLAN
HAMILTON SUNDSTRAND COPRORATION
I GENERAL INFORMATION
A. Units being closed at HWF
1. 1,000 Waste Containers 55,000 gal.
2. (2) tanks:
1. Non-Hazardous Waste liquid 6,000 gal. (121A)
2. Used oil: NonHazardous Combustible Liquids/Oils
6,000 gal. (121B)
12,000 gal.
3. Rag Compactor 55 gal container capacity
II MATERIAL QUANTITY CALCULATIONS
A. Tank inventory = 12,000 gals.

B HWF container inventory= 55,000 gals.
C. Tank and pipe flushing with detergent and rinse water = 600 gals. ea
D. Washing of concrete, racks, compactor, cabinets, etc. = 4,000 gals.
III LABOR
A. Tank inventory removal/cleaning/sampling

Estimate (2) workers for (3) days= 48 hours
B. HWF inventory removal
Estimate (15) truck loads requiring (2) workers, (8) hours/load = 240 hours
C. Tank and pipe flushing, rinsing and sampling
Estimate (2) workers for 30 hours = 60 hours
D. Washing concrete areas, racks, compactor, cabinets, etc.
Estimate (3) workers for (5) days = 120 hours
E. Concrete Floor and Compactor Sampling
Estimate (2) workers for (3) days = 48 hours
IV COSTS
A. Tank inventory removal

Labor= 48 hrs x $80.00/hr = $3,840
Disposal= 12,000 gal x $2.00/gal = $24,000
$27,840
B. HWF Inventory removal
Labor= 240 hrs x $80.00/hr = $19,200
Disposal= 1,000 drums x $400/drum= $400,000
Disposal of waste roll offs
(30 CY @ $200/CY non haz; 30 CY @ $400/yd haz) $18,000
Disposal of miscellaneous equipment= $45,000
$482,200
C. Tank and pipe flushing, rinsing and sampling
Labor= 60 hrs x $80.00/hr = $4,800
Testing of rinse water= 6 tests x $440/test= $2,640
Disposal of detergent and rinse= 1,200 gal x $.86/gal = $1,032
Disposal of tanks and pipes= 2 tanks x $5,500/tank= $11,000
$19,472
D. Washing of concrete areas, cabinets, compactor, etc.
Labor= 120 hrs x $80.00/hr= $9,600
Disposal= 4000 gals x $.86/gal= $3,440
$13,040
E. Concrete Floor and Compactor Sampling
Labor = 48 hrs x $85.00/hr= $ 4,080
Sampling equipment and PPE $ 5,500
Sampling = est. 50 tests x $850/test= $42,500
$52,080
F. Inspections and certifications of closure= $39,000

Lab Testing of QA/QC samples (10) x $825= $8,250
$47,250
======
Subtotal $641,864
15% Contingency $96,280
$738,144 (2020)
$547,000 (in 2004)

$629,305 (in 2007)
$629,305 (in 2008)
$662,515 (in 2011)
$739,618 (in 2018)
TABLE Q-4
CLOSURE SCHEDULE PROJECTION

RCRA CLOSURE PLAN
DAYS FROM RECEIPT OF

ACTIVITY
CLOSURE APPROVAL
1. Hazardous Waste Inventory Removal 60
2. Floor and Tank Integrity Assessment 75*
3. Equipment Decontamination and Removal 90
4. Floor Decontamination and Confirmatory 120

Sampling
*This schedule assumes that sampling beneath the floor will not be necessary. If the
concrete floor integrity is found to be compromised, a sampling plan will be submitted to
Connecticut DEEP for review and comment. The review and additional characterization
effort will likely extend/change the closure schedule.
FIGURES
Q-1 Site Location Map

Q-2 Site Map
Q-3 Hazardous Waste Facility Layout
0 1,000 2,000 4,000
Feet
Connecticut Hartford County

LAT. 41.925 LON. -72.688
HARTFORD COUNTY
CONNECTICUT ¯
SITE
ond
tts P
Wa
Approximate Location
Hazardous Waste Storage
Facility
J:\Projects\SiteLocationMaps\Aerospace Systems\_MXD\Figure1-SiteLocationMap_20200214.mxd - 2/14/2020|SRV
Copyright:© 2013 National Geographic Society, i-cubed
SITE LOCATION MAP

USGS 1:24K 7.5' Quadrangle, 2013:
Windsor Locks, CT
Hamilton Sunstrand Corporation GIS Review: AC

1 Hamilton Road CHK'D: AC
Hartford County 0533194

Drawn By:
SRV-2/14/20 FIGURE Q-1
LP17
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1
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BOX
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LP-123
LP-133
BLDG. LP-131
2 LP-124
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LP42 BROKE 10" CLAY
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POSSIBLE OLD
(CARHISOR???) REMOVE
LES
12" O.C/
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30" DEE
LP-125
WFR
2L
200W
P
200W
LP41
BROKE PIPE
-WITH PLUG
4" STORM DRAIN (226)

FROM ROOF OUT
BUILDING TO 10" CLAY
-5'6"-6' DEEP
JJ3
COMMUNICATION
VAULT WITH CABLE
2"-4" CONDUIT BREAK AND PLUG 10"
CLAY PIPE RECONNECT
RETURN LEADER
BLDG.
2" ABANDONED PIPE 12"
BELOW GRADE ENDS AT INSTALL NEW 8" PLASTIC
SLEEVE FOR RETURN
LP-132
COMMUNAL VAULT
LEADER
Map Reference:
OLD CB REMOVED PIPE
OPEN ENDED TO DIRT
LP-129
LP29
PIPE
10" CLAY PIPE 8"
SLEAVED PVC 5'6"-6'
DEEP
10" CLAY
12 4"xH.P
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EN
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39
Site background from base mapping provided by Hamilton Sundstrand.

1
LP LP-126
2L
200W
200W
LP40 SET OF 4" CONDUIT
RUNWAY ABOVE
TUNNEL
ROOF DRAW
ABOVE GRAVEL
N 897169.54
E 1017431.27
RIM ELEV 165.58
T/O PVC ELEV 165.09
8" OR 10"
Speed
Reducing
Strips
Horizontal datum unknown.
N 897143.82 N 897142.02
E 1017518.96 E 1017527.92
RIM ELEV 165.30
RIM ELEV 165.27
T/O PVC ELEV 165.01 T/O PVC ELEV 165.00
N 897142.84
E 1017522.82
RIM ELEV 165.32
T/O PVC ELEV 165.08 N 897140.42
E 1017531.94
RIM ELEV 165.22
T/O PVC 165.00
LP-128
LP-134
143W
CAM
₂
LP-127
E
L PIP
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2L TF
200W OU
200W
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LP43 EX
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4L
LP31
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LP48
LP44
G. 7
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4L
LP61
LP30
BLD
1L
LP47
LP85
1L
LP35
1L
LP140
Figure Q-2
1L
2L
200W
200W
LP45
1L
4L
LP60
1L
Site Map
2L
1L
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200W
LP46 1L

LP38
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200W
200W
4L
LP59
1L
1L
LP68 70W
WW-1
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LP67
Windsor Locks, CT
WW-2
1L
70W
1L
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LP36
4L
LP84
Strips
Reducing
Speed
1L
70W
WW-3
1L
LP37
4L
LP83
1L
70W
WW-4
1L
70W
WW-5
LP82
4L
CS
3-11 4"xH.P
.1980
NATU
RAL
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CS
WW-6
1L
70W
www.erm.com ERM
1L
70W
WW-7
WW-8
1L
70W
REVISIONS
Sym. Description Date Name
4L
LP69
BLDG.
1L
A Part B Permit Edits

70W
1L
WW-10 70W
WW-9
LP71
4L
02/12/2020 ERU
3
1L
4L
LP67 LP70
3L
LP72
1L
1L
LP68
Scale: 1" = 200'

CULVERT
Project Number: 0533194

INLET
Date: 02/12/2020
Drawn By: E. R. U.
Waste Liquids
Burnables
Burnables
Burnables,
SSC-1
SSC-2
SSC-3
SSC-6
SSC-4
SSC-5
Resin Bldg. RB
SSC-7
HAZARDOUS WASTE FACILITY

Hamilton Sundstrand, Windsor Locks, Connecticut Project Number: 0533194
HAZARDOUS WASTE FACILITY (HWF) A.L.C

FIGURE Q-3
FACILITY LAYOUT
EXHIBITS
Q-1 Checklist for Technical Review of RCRA Part B

Application
Q-2 DEEP Figure on Closure of HWSA
Q-3 Current Closure Cost Estimate
Q-4 Certification Statement
Q-5 Waste Permit 2004 & 2010
Q-6 Financial Assurance
Q-1 Checklist for Technical Review of RCRA Part B
Application
EXHIBIT Q-1
CHECKLIST FOR TECHNICAL REVIEW OF RCRA PART B PERMIT APPLICATION
CLOSURE PLAN REQUIREMENTS
Location of
Information in
Item in Current Application Authority Requirements Closure Plan
SECTION I
Closure Plan Documentation 40CFR270.14(b)(13) Section Q
Closure Performance Standard 264.111 A description of how closure:
 Minimizes the need for further maintenance Section Q1b
 Controls, minimizes or eliminates post-closure escape of Section Q3
hazardous waste, hazardous constituents, leachate, Section Q4
contaminated run-off, or hazardous waste decomposition
products to the ground or surface waters or to the atmosphere.
 Complies with the closure requirements of Subpart G and unit-
specific closure requirements.
Description of partial or final closure procedures 40CFR264.112(b)(12) Final Closure must minimize the need for further maintenance Section Q3
and (2) and must control post-closure release to groundwater, surface
water, soil and the atmosphere
Description of maximum unclosed portion during 40CFR264.112(b)(2) Section Q2
the active life of the facility
Estimate of maximum waste inventory in storage 40CFR264.112(b)(3) Section Q2a
and treatment during facility life Section Q2b
Location of
Information in
Item in Current Application Authority Requirements Closure Plan
SECTION I
Description of procedures for removal or 40CFR264.112(b)(4) Section Q4
decontamination of hazardous waste residue,
equipment, structures and soils
Methods for sampling and testing Section Q5
Criteria for determining decontamination levels Section Q5
Table Q2
Description of additional activities performed 40CFR264.112(b)(5) Section Q4b
during the closure Section Q4c
Section Q4d
Section Q6
Description of how all facility equipment and 264.114  Decontamination procedures Section Q4b
structures will be decontaminated or disposed of 264.112(b)(4)  Criteria for determining decontamination Section Q4c
when closure is completed  List of equipment, structures, and soils
 Disposal of contaminated soil and residues
 Decontamination of clean up materials and equipment
 Demonstrate decontamination has been effective
264.111(b)  A demonstration that any hazardous constituents left will not
impact environmental media in excess of agency established
exposure levels, and direct contact will not pose a threat to
human health and the environment.
Location of
Item in Current Application Authority Requirements Information in
Closure Plan
Closure of Containers 264.178 A description of how at closure, all hazardous waste residues Section Q4b
will be removed from the containment system, and how
remaining containers, bases, and soil containing or contaminated
with hazardous waste or hazardous waste residues will be
decontaminated or removed.
Closure of Tanks 264.197(a) A description of how at closure, all hazardous waste residues Section Q4a
will be removed from tanks, discharge control equipment, and
secondary containment structures, and the facility will be
decontaminated.
Description of closure schedule including: 40CFR264.112(b)(6)
 Total time to close each unit The hazardous waste must be treated, removed or disposed of Section Q1a
within 90 days after receiving the final volume of waste; all Section Q10
closure activities must be completed within 180 days after
receiving the final volume of waste
• Timetable of closure activities Table Q-4
Estimate of year of closure 40CFR264.112(b)(7) Estimate of year of closure is required for those facilities that Section Q1a
use trust funds to establish financial assurance and are expected Section Q10
to close before expiration of the permit
Financial Assurance mechanism for Closure 270.14(b)(15) A copy of the established financial assurance mechanism for Section Q11
264.143 facility closure adopted in compliance with 264.143. The
Exhibit Q-6/
264.151 mechanism must be one of the following {I-5(a) through I-5(f)}
Attachment R
and include due dates and use standard wording.
* The Closure Plan assumes clean closure can be obtained.
Q-2 DEEP Figure on Closure of HWSA
Q-3 Current Closure Cost Estimate
EXHIBIT Q-3
CURRENT CLOSURE COST ESTIMATE
RCRA CLOSURE PLAN
Closure Activity Unit Quantity Cost per Unit Total

A. Tank inventory Labor (Hours) 48 $80 $3,840
removal (tank 121A, Disposal of waste (6,000 12,000 $2.00 $24,000
121B) gallons per tank)
Subtotal A $27,840
B. HWF Inventory Labor (Hours) 240 $80 $19,200
removal Disposal of waste 1,000 $400 $400,000
(containerized (55 Gallon Drums)
waste) Disposal of waste in roll off 30 CY $200 (non $6,000
30 CY Non-Haz (J-Lot) haz)
30 CY Haz 30 CY $12,000
$400 (haz)
Disposal of miscellaneous 1 $45,000 $45,000
equipment (Lump Sum
Unit)
Subtotal B $482,200
C. Tank and pipe Labor (Hours) 60 $80 $4,800
flushing, rinsing, Lab testing of rinse water 6 $440 $2,640
and sampling (3 samples per tank)
Disposal of detergent and 1,200 $0.86 $1,032
rinse water (600 gallons
per tank)
Dismantling, disposal or 2 $5,500 $11,000
recycling of tanks and
piping (per tank)
Subtotal C $19,472
D. Washing of Labor (Hours) 120 $80 $9,600
concrete Disposal of rinse water 4,000 $0.86 $3,440
areas/floors, (Gallons)
cabinets, Subtotal D $13,040
compactor, J-Lot,
etc.
E. Concrete Floor Sampling Labor (Hours) 48 $85 $4,080
and Compactor Sampling Equipment and 1 $5,500 $5,500
Sampling PPE (Lump Sum)
Lab Testing of concrete 50 $850 $42,500
wipes (per sample)
Subtotal E $52,080
F. Inspections, Engineering (Lump Sum 1 $39,000 $39,000
QA/QC, oversight of Fee)
closure activities, Lab Testing of QA/QC 10 $825 $8,250
report preparation samples (per sample)
and certification of Subtotal F $47,250
closure
Closure Cost Estimate $641,864
Contingency (15%) $96,280
Total Closure Cost Estimate (2020) $738,144
Q-4 Certification Statement
EXHIBIT Q-4
CERTIFICATION OF CLOSURE
RCRA CLOSURE PLAN
I, , being a duly licensed

Professional Engineer registered in the State of Connecticut, and I,
(Owner or Operator) do hereby
certify that the former hazardous waste management unit(s), which are located in
the Hazardous Waste Facility and known as the Hazardous Waste Container
Storage Area and the two above ground Waste Storage Tanks at the Hamilton
Sundstrand Corporation facility in Windsor Locks, Connecticut, have to the best of
my knowledge and belief, as noted herein, been closed in accordance with the
plans and specifications in the Closure Plan approved by the Connecticut
Department of Energy & Environmental Protection. Closure of the aforementioned
facility was completed.
Seal/Stamp P.E. Signature: Date:

Title:
Business Address
Business Telephone:
Engineer License No.:
State of Issue: Connecticut
Owner/Operator Signature: Date:

Title:
Business Address:
Business Telephone:
Q-5 Waste Permit 2004 & 2010
Q-6 Financial Assurance
(Financial Assurance documents are provided in

Attachment R)

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CONNECTICUT HAZARDOUS WASTE RENEWAL PERMIT

HAMILTON SUNDSTRAND CORP.

PERMIT NUMBER: DEEP/HWM-165-005

HAMILTON SUNDSTRAND CORPORATION

SECTION TITLE PAGE

Section V COMPLIANCE SCHEDULE

(A) Waste Analysis Plan

Table II-1 Container Storage Area Volumetric Capacities

Figure J-1 Hazardous Waste Facility – Facility Overview

STANDARD FACILITY CONDITIONS

RCRA HAZARDOUS WASTE FACILITY RENEWAL PERMIT

EPA ID No. CTD001145341

File:20210308 HS Section I - REV (2) cph, EPA. ac (ERM)a.doc Page I-1

SECTION TITLE PAGE

(A) Design and Operation . . . . . . I-3

(F) Definitions . . . . . . . . I-11

File:20210308 HS Section I - REV (2) cph, EPA. ac (ERM)a.doc Page I-2

(B) EFFECT OF PERMIT

(1) Except as is provided for in the Regulations of Connecticut State Agencies

(E) DUTIES AND REQUIREMENTS

(2) Duty to reapply. If the Permittee wishes to continue engaging in an activity

File:20210308 HS Section I - REV (2) cph, EPA. ac (ERM)a.doc Page I-4

(c) Inspect at reasonable times any facilities, equipment (including monitoring

(10) Monitoring and records

(c) Records for monitoring information shall include:

(i) The date, exact place and time of sampling or measurements;

(ii) The individual(s) who performed the sampling or measurements;

(11) Signatory requirements. The Permittee's application and all reports or

(13) Reporting requirements

(a) Anticipated noncompliance. The Permittee shall give as much advance

(c) Twenty-four (24) hour reporting:

File:20210308 HS Section I - REV (2) cph, EPA. ac (ERM)a.doc Page I-6

(i) The Permittee or his/her designee shall orally report to the

(A) Name, address, and telephone number of the Permittee;

(ii) A written submission shall also be provided within five (5)

(d) Manifest discrepancy report. The Permittee shall report manifest

discrepancies in accordance with 40 CFR 264.72, which is hereby

(e) Unmanifested waste report. The Permittee shall report unmanifested

(g) Other Noncompliance. The Permittee shall report all instances of

(i) Requirements Incorporated. Different sections of this Permit contain

(14) Computation of Time.

(a) Computation of time. Except as is expressly provided for in this Permit,

(i) Any time-period scheduled to begin on the occurrence of an act or

recognized legal holiday, the time period shall be extended to the

(b) Submission of reports. Where this Permit requires the submission of a

(16) Additional Requirements. Requirements not included in this Permit, which

(18) Modification of the Compliance Schedule Submittals.

File:20210308 HS Section I - REV (2) cph, EPA. ac (ERM)a.doc Page I-9

(19) Delegation of a Licensed Environmental Professional

(a) Pursuant to RCSA Section 22a-133v, a Licensed Environmental

(c) In the event the Commissioner revokes the delegation of site-wide

(20) Incorporation by Reference.

(a) Unless specifically excluded by the state hazardous waste management

(c) In the event of any inconsistency or duplication in the requirements of the

hazardous waste management regulations, and the provisions of this

(3) “Battery” means a device consisting of one or more electrically connected

(5) “Code of Federal Regulations” or "CFR," in reference to all or any portion of 40

(6) “Commissioner” shall mean the Commissioner of Energy and Environmental

(17) “Department of Transportation” or “DOT” shall mean the U.S. Department of

File:20210308 HS Section I - REV (2) cph, EPA. ac (ERM)a.doc Page I-12

(29) “Non-RCRA Regulated Media” means Non-RCRA waste solids such as

File:20210308 HS Section I - REV (2) cph, EPA. ac (ERM)a.doc Page I-13

(31) "Other Material" or "Other Materials" shall mean: