HAZARDOUS WASTE MANAGEMENT
1.0 INTRODUCTION
Hazardous waste is strictly regulated by the Environmental Protection Agency under the Resource Conservation and Recovery Act (RCRA). This Act mandates a "cradle-to-grave" system for managing hazardous waste and applies to those who generate, store, transport, treat, recycle, or dispose of hazardous waste. The purpose of the Act is to protect human health and the environment from improper waste management practices.
At first environmental laws were mainly focused on industry, which generates the largest portion of hazardous waste. In 1986, however, amendments to RCRA extended the law to cover most colleges and universities. This was done in response to public concerns about pollution from the mismanagement of even small quantities of hazardous waste. Although not comparable in volume to industry, academic institution produce a large variety of hazardous waste, creating numerous waste management problems. In addition to chemistry laboratories, hazardous waste is routinely produced in areas such as biology, geology, art, printing, drama, and the physical plant.
Generators are legally and morally obligated to dispose of hazardous waste in a manner that will minimize damage to health and the environment. This effort requires the cooperation and commitment of workers, departments, and top management. The university provides generators with a legal and safe method to dispose of hazardous waste through a hazardous waste management service. This will normally be done at no cost to generators.
2.0 RESPONSIBILITIES
Individuals who generate hazardous waste are responsible for ensuring that their waste is managed properly. Chemicals must be disposed of in compliance with EPA, RCRA, and DOT regulations. Non-compliance with these regulations could result in fines and legal action. Fines of $25,000 per incident per day are possible for the institution, and individuals may be held criminally and civilly liable for violating waste management regulations. Even after legal disposal, generators retain responsibility for the waste as long as it can harm human health or the environment. Generators can dispose of hazardous waste in a responsible manner by ensuring that:
3.0 HAZARDOUS WASTE REDUCTION
Alternatives to hazardous waste disposal are needed because of concerns about the environment and the rising cost of landfilling and incineration. One strategy that is increasingly being used is to reduce the volume of waste generated. Waste reduction saves money, reduces the amount of hazardous materials in the work place, and decreases the amount of pollutants in the environment. Waste reduction activities include the use of smaller quantities, using less hazardous materials, and the redistribution of surplus chemicals that may become waste. Recognizing the importance of waste reduction, Virginia Hazardous Waste Regulations require that generators take steps to minimize the amount and toxicity of chemical waste. The following methods should be used to reduce the volume and toxicity of hazardous waste:
1. Chemicals should be purchased in the smallest quantities needed for immediate use. This reduces storage space, potential for chemical accidents, and the cost of disposal. Disposal costs can easily offset any savings incurred from purchasing larger quantities.
2. Whenever possible, hazardous chemicals should be replaced with less hazardous chemicals to reduce the amount and toxicity of waste.
3. Donations and samples of chemicals should not be accepted unless an immediate use is planned.
4. When hazardous materials are supplied for research purposes written agreements should include a provision for the return of unused amounts to the supplier.
5. Commonly used chemicals should be stored in a departmental central stockroom. This can reduce the volume of chemicals because workers can check the stockroom before ordering new chemicals.
6. An inventory of chemicals should be maintained by each department. The inventory should be examined before chemicals are purchased. An inventory can reduce unknowns, chemical degradation, and duplicate purchases.
7. A chemical surplus program should be developed to exchange unneeded chemicals among laboratories. A list of available chemicals should be distributed periodically to all departments. This can result in significant savings on purchasing new chemicals and reduce disposal costs.
8. Laboratories and chemical stockroom should be cleaned out periodically. Some chemicals degrade over time forming explosive by-products. Labels can be obliterated by corrosion or fall off. The disposal of explosives and unknowns can be very expensive.
9. When laboratory workers leave the university, all chemicals under their control should be identified and made available to other laboratories. It is important to ensure that all chemicals are identified to prevent the accumulation of unknowns.
10. Reduce or eliminate the hazard at the point of generation. Experiments should include consideration for the disposal of starting material and end products. If possible, chemical experiments should be designed to render waste less hazardous or non-hazardous at the end of the experiment. For example, neutralization of acids and bases should be part of laboratory experiments. This can reduce the volume and toxicity of waste and may avoid difficult disposal problems.
11. The quantity of hazardous waste generated in teaching laboratories can be reduced by using microscale techniques. These scaled-down experiments use smaller quantities of reagents and can lead to significant savings in costs of chemicals, energy, apparatus, space, and disposal costs.
12. Processes should be modified to generate less hazardous waste by using smaller amounts of chemicals, substituting less hazardous materials, recycling the material in the process, or by making equipment changes.
13. Efforts should be made to recycle hazardous waste. For example, waste mercury, lead, and oil can be recycled into usable materials and silver can be recovered from photographic waste.
14. The volume of waste can be reduced by separating non-hazardous from hazardous chemicals, evaporating aqueous solutions to concentrate toxic metals, and completely using materials such as paint and pesticides.
15. Unused chemicals (never opened) and gas cylinders should be returned to the manufacturer.
4.0 DEFINITION OF HAZARDOUS WASTE
Hazardous waste is any solid, liquid, or contained gaseous material that is no longer used and could be dangerous to human health or the environment if discarded. A waste is considered hazardous if it appears on an EPA list or meets its defined characteristics for ignitability, corrosivity, reactivity, or toxicity. A waste is also hazardous if the State determines it constitutes a hazard or if the waste is declared hazardous by the generator, transporter, treater, storer, or disposer. Waste should be presumed hazardous unless proven otherwise.
Listed waste
Waste is considered hazardous if it appears on any of the four lists of hazardous waste contained in the RCRA regulations. These wastes have been listed because they exhibit one or more hazardous characteristics or contain a number of toxic materials that have been shown to be harmful to health and the environment. The lists contain over 450 hazardous wastes, including waste from manufacturing processes and discarded chemical products. If a waste mixture includes any amount of a RCRA listed constituent, the entire waste is considered hazardous waste. The following Hazardous Waste Lists are available from the Safety Office:
1. F-listed hazardous waste from non-specific sources. This list includes spent solvents that are commonly found in laboratories. Any process using these solvents are covered by the regulations.
2. K-listed hazardous waste from specific sources. This list includes primarily industrial waste.
3. P-listed acutely hazardous waste substances. Chemicals on this list are highly toxic and represent an extreme hazard.
4. U-listed toxic wastes. Waste that is less hazardous than acute hazardous waste.
Characteristic waste
If a waste does not appear on an EPA list it still may be considered hazardous if it is ignitable, corrosive, reactive, or toxic. These determinations can be made by testing or through knowledge of the characteristics of the waste.
Ignitible
1. A liquid with a flash point below 140 F (60 C).
2. A solid that ignites easily and burns vigorously.
3. An ignitable compressed gas.
4. A strong oxidizer.
Hazardous waste that meets the definition of ignitability and is not listed is assigned an EPA Hazardous Waste Number of D001 on the Hazardous Waste Manifest. Examples include paint wastes, certain degreasers, and other solvents.
Corrosive
1. Aqueous and has a pH of 2 or lower (strongly acidic) or 12.5 or higher (strongly alkaline).
2. A liquid that corrodes steel at a rate of one-quarter inch or more per year.
Hazardous waste defined as corrosive and not listed is assigned an EPA Waste Number of D002 on the Hazardous Waste Manifest. Examples include acid and alkaline cleaning fluids, and waste battery acid.
Reactive
1. Normally unstable, readily undergoes violent change without detonating.
2. Reacts violently or forms potentially explosive mixtures with water.
3. Releases toxic gases, vapors, or fumes when mixed with water.
4. Contains cyanide or sulfide, releasing gases when exposed to conditions between pH 2 and 12.5.
5. Capable of detonation or explosive decomposition..
Waste that exhibits the characteristics of reactivity and is not listed has an EPA Waste Number of D003. Examples include cyanide plating waste, sodium, and waste bleaches.
Toxic
1. A chemical is considered toxic if it causes illness or death when taken into the body. A material is usually defined as toxic if the oral LD50 is less than 500 mg/kg, the dermal LD50 is less than 2000 mg/kg, or the inhalation LD50 is less than 2 mg/liter.
2. Wastes are classified as TCLP toxic (Toxicity Characteristic Leachate Procedure) if an extract from the waste contains high concentrations of certain heavy metals, solvents, or pesticides that could be released into the groundwater.
3. A chemical is assumed to be toxic if the toxicity is unknown and it cannot reasonable be inferred as non-toxic by analogy to similar compounds.
A waste that exhibits the characteristics of toxicity but is not listed has an EPA Waste Number of D004-D043. Examples include mercury, lead, cadmium, some solvents, and certain pesticides.
5.0 RESTRICTIONS
Virginia Hazardous Waste Management Regulations apply to the generation, storage, treatment, transportation, and disposal of hazardous waste. Radford University is classified as a "generator only." Under these regulations individuals who generate hazardous waste are prohibited from:
1. Treatment of a hazardous waste except as part of an on-going process at the point of generation (e.g., neutralization as the last step in a laboratory experiment). Acids and bases cannot be collected in a common container and neutralized.
2. Storage of a hazardous waste exceeding 90 days for a large quantity generator, or 180 days for a small quantity generator. Generator status depends on the total quantity of waste generated in any one month. Typically the university will be a small quantity generator.
3. Transportation of any hazardous waste from the generating facility (Radford University) except through a licensed disposal firm. Transportation to waste storage facilities on campus is restricted to properly trained individuals.
4. Discarding of hazardous waste in the general refuse, storm drains, or by burning, burial, sale, giveaway, or any route other than that provided by the waste disposal service. Chemical exchange between university departments is encouraged.
5. Biological, radioactive, and asbestos waste must be handled separately. Please call the Safety Manager for proper procedures. Radioactive wastes, even if it meets EPA criteria for hazardous waste, must be processed through the university program for radioactive waste. Radioactive waste cannot be mixed with general chemical waste.
6. Chemical mixtures from laboratories are acceptable as waste, however, ensure that only compatible chemicals are poured into common containers.
7. Disposal of hazardous waste in the sanitary sewer is prohibited unless steps are taken to render the material non-hazardous. Toxic, flammable, organic solvents, noxious, or lachrymatory chemicals cannot be disposed of in the sink. Strong acids and bases must be neutralized to pH 5.0-10.5 to be in compliance with local wastewater regulations. Acids and bases must be neutralized as part of an ongoing process.
8. Limited quantities of some wastes can be disposed of in the sanitary sewer. In general, only water soluble, non-toxic substances may be poured down the sink. The university must comply with local regulations regarding what can be poured into the sewer system. Wastes of slight hazard and borderline waste in small amounts may be disposed of in the sanitary sewer if permission has been obtained from the local sewer authority. Contact the Safety Manager before disposing of any chemicals into the laboratory sink.
6.0 PROCEDURES FOR CHEMICAL WASTE DISPOSAL
The following procedures are designed to ensure that hazardous waste generated at Radford University is handled in a safe and legal manner.
Identifying waste
Generators are responsible for the proper identification of their waste. Laboratory workers, for example, are in the best position to determine the hazards of materials they use or synthesize. Generators not familiar with chemicals should contact a chemist or the Safety Office for guidance. Any substance that no longer serves its intended purpose and is destined for disposal should be evaluated to determine if it meets the EPA definition for hazardous waste. Waste not meeting the EPA definition must still be disposed of in a safe and legal manner (e.g. secure landfill).
1. Determine if the material is a hazardous waste:
2. Ask the following questions about the waste:
3. Check the label and MSDS for key words such as: hazardous, explosive, blasting agent, poison gas, flammable solid, flammable liquid, combustible, oxidizer, organic peroxide, corrosive, chlorine, irritant, poison, dangerous, etc.
4. Be careful and use common sense. Every ingredient must be checked. When in doubt assume the material is a hazardous waste. Expenses involved in compliance with the regulations are very small compared to penalties for violations.
7.0 SEGREGATION
When combining waste in a laboratory ensure that compatible wastes are placed in the same container. An inventory log must be maintained for each container. Guidelines for chemical compatibilities are included in the Appendix of the Chemical Hygiene Plan.
1. For reasons of safety and economics, hazardous waste should be separated into the following waste streams:
2. Contractors usually charge more to dispose of halogenated solvents than non-halogenated solvents. Even a small amount of halogenated solvent in a drum of non-halogenated solvents may cause the drum to be charged at a higher rate.
3. Non-halogenated solvents can often be fuel blended. This is the least expensive waste to dispose. Care should be taken to avoid adding the following:
8.0 CONTAINERS
Hazardous waste must be stored in containers that are in good condition. Containers can be made of glass, plastic, or metal as long as they are compatible with the hazardous waste.
1. Chemicals for disposal must be placed in a sealed container, preferably with a screw type cap. Containers with cracked or corroded caps, paraffin, rubber, cork, or glass stoppers are not acceptable.
2. Corrosives and halogenated solvents should not be stored in metal cans. Metal cans are preferable for flammable liquids.
3. Glass bottles should stand in a suitable secondary container such as a tray or plastic bucket.
4. Containers must be clearly marked with a WASTE label, appropriate hazard warning label, and labeled as to contents.
5. The outside of all containers must be free of any chemical residue.
6. Larger quantities of solid materials such as pesticides may be disposed of in bags, provided that they are double-bagged and the outside bag is clear plastic.
7. Combine partially full containers of compatible waste so that containers are full whenever possible.
8. Place small amounts of waste in small containers. Waste containers cannot exceed 5 gallons for liquids and 50 pounds for solids. Small vials may be overpacked in a larger glass container.
9. Housekeepers are not responsible for transporting hazardous waste or transferring waste from leaking containers to secure ones.
10. An inventory log must be maintained for each waste stream container.
11. When the container is full complete a "WASTE" form and forward it to the Safety Office (Box 6909).
12. If the log sheet or request for pick up are not complete, discrepancies are found, or the container is leaking, the waste will not be removed from the collection area until the problem is corrected.
13. Containers with hazardous residues may be discarded in the regular trash if there is less than one inch of residue remaining and the waste is not an acutely toxic hazardous waste. Reasonable efforts must be made to completely empty the container. Containers with acute hazardous waste residues may be disposed in the regular trash if they have been triple rinsed with an appropriate solvent. The rinsate must be disposed as hazardous waste.
9.0 SCHEDULING A PICKUP
1. Complete the Hazardous Waste Form and send a copy to
the Safety Office. If you have several containers, place a unique number on the container
and reference it on the list. Print the name of the chemical carefully. In the amount
column, put the amount the container holds, not the amount left in the container.
2. Once received by the Safety Office arrangements will be made to collect and transport the waste to the university storage areas. This will typically be done on a weekly basis.
3. Prepare safe short term storage, with incompatibles separated until the waste is removed to a central location.
10.0 SPECIAL HANDLING
Gas Cylinders
1. Gas cylinders are very expensive and/or impossible to dispose of through a hazardous waste company. The cylinders should be returned to the supplier, if possible. Generally a rental charge or cash deposit on the empty cylinder is included in the purchase price. Lecture bottles should also be returned to the supplier.
2. Gas cylinders must be labeled according to DOT requirements and shipping papers properly completed prior to transportation. Please contact the Safety Manager for assistance.
Reactives & Explosives
1. Reactives and potential explosives require special handling for disposal. The procedure is very time consuming and expensive. To reduce disposal costs personnel should take necessary precautions to prevent the production and storage of waste explosives in laboratories. Many laboratories produce potential explosives by not following safety guidelines. Two of the most common items produced in this manner are peroxidized ethers and dry picric acid. Do not disturb potential explosives.
2. Peroxide forming compounds (ethyl ether, 1,4 dioxane, THF, etc.) should have a date of receipt and a date of opening on the container. Discard within six months if opened or one year if unopened.
3. Ensure that picric acid always contains at least 10% water.
Unknowns
1. Unknown wastes are handled on a case by case basis and can be very expensive to dispose. Please ensure that all chemicals are identified, properly labeled, and expiration dates are observed.
2. Unknown materials cannot be disposed of until a sample has been analyzed. Every possible effort should be made to identify each waste. Unknowns can be accepted conditionally, but may be returned to the department for chemical analysis (expenses to be paid by the department) if the hazardous waste contractor cannot categorize the waste.
3. Do not guess at the identity or create a name for an unknown. A wrongly identified waste could harm life and property. It could also subject the individual generator and the university to EPA regulatory fines and potential lawsuits.
11.0 SHORT TERM STORAGE OF HAZARDOUS WASTE
Numerous hazards are associated with the improper storage of hazardous waste in laboratories. Accidents can be reduced by careful planning of storage procedures and facilities. Containers should be periodically inspected to ensure that labels are legible, intact, and containers are not leaking. Containers should always be kept tightly sealed. Storage in laboratories should be minimized.
1. Hazardous waste shall be stored safely by the department until removed by the Safety Manager.
2. Waste should be stored in an assigned storage area that is cool, dry, well ventilated, and out of direct sunlight. Chemicals that may react together should be separated. A common and unsafe practice is to store all waste together. This practice may cause explosions, or the release of toxic vapors. Waste should be stored according to chemical class.
3. Toxic chemicals should be stored away from fire hazards, heat, and moisture, and isolated from acids, corrosives, and reactive chemicals. Special care should be taken to ensure that toxic chemicals are not released into the environment. Highly toxic chemicals should be stored in a hood in unbreakable secondary containers.
4. Corrosive chemicals should not be stored with combustibles, flammables, organics, or reactives. Acid and bases should not be stored together. Organic acids should be separated from sulfuric, nitric, perchloric acid and other strong oxidizers.
5. Flammable liquids should not be stored near exits, sources of heat, ignition, or near strong oxidizing agents, explosives, or reactives. Smoking is prohibited in storage areas. Storage areas should be adequately ventilated to prevent vapor build up. Proper fire extinguishers should be readily available. Metal dispensing and receiving containers should be grounded and bonded together by a suitable conductor to prevent static sparks. Storage in laboratories is limited to 10 gallons outside of flammable storage cabinets or approved safety cans. Storage in glass containers is limited to 1 pint for Class IA liquids and 1 quart for Class IB liquids.
6. Reactive chemicals should be protected from shock, heat, ignition sources, and rapid temperature changes. Containers should be separated from corrosives, flammables, organic materials, toxins, and oxidizers. Water reactive chemicals should be separated from sprinkler systems, emergency showers, eyewash stations and other water sources. Keep containers well sealed. Store water reactives under an inert non-flammable solvent. Reactive wastes shall be isolated and reported to the Safety Manager for immediate removal or special handling by the hazardous waste disposal firm.
7. Ethers, picric acid, and perchloric acid that have deteriorated in storage present potential explosion hazards. Ethers older than one year and picric acid and perchloric acid with visible crystal formation should not be touched or opened.
12.0 SUMMARY FOR HAZARDOUS WASTE REMOVAL
1. Confirm that no further use of the substance exists within the department.
2. Check to ensure the waste is hazardous according to EPA characteristics or listings.
3. Ensure that the waste is not subject to other regulations i.e., NRC for radioactive waste, RCRA for PCBs, EPA for asbestos, etc.
4. Identify each potential waste substance and mark the container with the chemical name or commercial product name.
5. Ensure that chemicals poured into common containers are compatible and that containers are appropriate for the waste material.
6. Properly complete the Hazardous Waste Form and send a copy to the Safety Manager (Box 6909).
7. Temporarily store each group of hazardous waste in accordance with safety requirements for that specific hazard category.
8. Establish an emergency spill program to control any accidental release of hazardous waste.