INTRODUCTION TO HAZARDOUS WASTE MANAGEMENT

University of Alaska Fairbanks

Environmental, Health, Safety, and Risk Management

May 2013

COURSE OUTLINE

Overview of hazardous materials regulations

Hazardous waste at UAF What is hazardous waste? What do I do with my hazardous waste? Emergency response

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OVERVIEW OF HAZARDOUS MATERIALS REGULATIONS

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HAZARDOUS MATERIALS REGULATIONS

Hazardous materials are regulated by three primary government agencies:

Department of Transportation (DOT) Title 49, Code of Federal Regulations (49 CFR)

Occupational Safety and Health Administration (OSHA) Title 29, Code of Federal Regulations (29 CFR)

Environmental Protection Agency (EPA) Title 40, Code of Federal Regulations (40 CFR)

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The International Fire and Building Codes also regulate hazardous materials

HAZARDOUS MATERIALS REGULATIONS (CONT.) DOT regulations direct us how to properly package,

identify, and label hazardous materials and hazardous wastes for transportation

OSHA regulations tell us how to protect ourselves from the effects of hazardous materials in the workplace

EPA regulations tell us how to protect our environment

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DOT REGULATIONS

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Class 1: ExplosivesClass 2: Compressed GasesClass 3: Flammable LiquidsClass 4: Flammable SolidsClass 5: OxidizersClass 6: Poisons and ToxicsClass 7: Radioactive materials Class 8: CorrosivesClass 9: Miscellaneous hazardous

materials that don’t fit any other hazard class… (i.e. dry ice)

DOT classifies hazardous materials into 9 primary hazard classes which are subdivided into multiple subsidiary risk groups. You don’t need to memorize these, but the primary hazard classes are:

OSHA REGULATIONSOSHA regulations include the following standards: Hazard Communication Standard (Hazcom, Right-to-Know) Occupational Exposure to Hazardous Chemicals in Labs,

including requirements for Chemical Hygiene Plans Respiratory Protection Standard Confined Space Entry Requirements Asbestos Standard Lead (Pb) Standard Bloodborne Pathogen Standard Formaldehyde, Benzene, and Methylene Chloride

standards

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OSHA also establishes Permissible Exposure Levels (PELs) for hazardous chemicals

EPA REGULATIONSCongress placed into law several acts that the EPA uses to establish regulation to protect our environment:Resource Conservation Recovery Act (RCRA)Clean Air ActClean Water ActToxic Substances Control Act (TSCA)Emergency Planning & Community Right-to-Know Act (EPCRA)Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)

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HAZARDOUS WASTE REGULATIONS

EPA regulates hazardous waste in Alaska by authority of the Resource Conservation Recovery Act. RCRA controls include:

Identification of hazardous wastesTracking wastes from “cradle to grave”Setting standards for generators of wastes, transporters of wastes, and Treatment, Storage & Disposal Facilities

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PRIMARY RCRA REQUIREMENTSRCRA requires that you: Label containers with a description of their contents Store only the permissible volume of waste in your lab Ensure lids and caps are securely fastened at all times,

except when putting wastes into the containers Ensure all materials are properly segregated Use containers that are compatible with your waste Use intact containers (no cracks, holes, etc.) Ensure that spills and overfills do not occur Ensure that mismanagement does not occur

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RCRA REQUIREMENT FOR TRAININGThe purpose of this training is to comply with requirements set forth by the EPA under 40 CFR 265.16 (Personnel Training)

The scope of the training is to ensure that UAF personnel who use chemicals:

1. Understand how to identify hazardous wastes2. Understand how to package and label hazardous

wastes3. Understand how to have their hazardous materials

disposed4. Know how to respond effectively to emergencies

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RCRA REGULATORY INSPECTIONS

EPA conducts unannounced Compliance Evaluation Inspections

In the past, UAF facilities have been inspected annually

Our goal is to comply with all regulations

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HAZARDOUS WASTE AT UAFAn overview of sources of hazardous waste at UAF, and its ultimate fate…

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SOURCES OF HAZARDOUS WASTE AT UAF

Sources of hazardous wastes (HW) at UAF include:

Research and academic laboratories Shops and repair facilities Art and theater departments Facility maintenance and grounds Power Plant operations Experimental Farm operations

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HAZARDOUS WASTE GENERATORS

The RCRA definition of a HW generator is: Any person, by site, whose act or process produces hazardous waste identified or listed in 40 CFR 261.3.

Generators are classified by the volume of HW that they produce per month:

CESQG = Conditionally Exempt Small Quantity Generator

SQG = Small Quantity GeneratorLQG = Large Quantity Generator > 1000 kg/month

or >1 qt. of acutely hazardous waste/month

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UAF’S WASTE GENERATOR STATUS The UAF main campus is regulated as a

Large Quantity Generator UAF’s extended sites are regulated as

Conditionally Exempt Small Quantity Generators Examples: Toolik Field Station, Palmer

Research Farm, Kodiak Seafood & Marine Science Center, Seward Marine Center, Lena Point Fisheries Facility (Juneau)

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HAZARDOUS WASTE MANAGEMENT AT UAF EHSRM assists UAF waste generators with

waste disposal needs Hazardous Materials Facility (HMF) stores waste

and serves as UAF’s Central Accumulation Area (CAA)

RCRA-regulated hazardous wastes are shipped Every 90 days from the HMF By EPA-permitted transporters to EPA-permitted treatment,

storage, and disposal facilities Annual costs: $125,000 for disposal; $400,000 total cost

of hazmat program at UAF

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WHAT IS HAZARDOUS WASTE?

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EPA DEFINITION OF A SOLID WASTE EPA begins by defining all waste as a “solid” waste

(including solids, liquids, gases, and semi-solids) 40 CFR 261.2 provides the definition of “solid

waste:” (a)(1) A solid waste is any discarded material that is not

excluded by § 261.4(a) or that is not excluded by variance granted under §§ 260.30 and 260.31.

(2) A discarded material is any material which is: (i) Abandoned, as explained in paragraph (b) of this section; or (ii) Recycled, as explained in paragraph (c) of this section; or (iii) Considered inherently waste-like, as explained in paragraph

(d) of this section; or (iv) A military munition identified as a solid waste in 40 CFR

266.202.

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No need to memorize that!

EPA DEFINITION OF A HAZARDOUS WASTE (CONT.) If the waste material meets certain criteria,

and is not somehow exempted or excluded from regulation, it may be a RCRA-regulated HW

The legal definition of HW is found in 40 CFR 261.3 (a) A solid waste, as defined in §  261.2, is a

hazardous waste if: (1) It is not excluded from regulation as a hazardous

waste under §  261.4(b); and (2) It meets any of the following criteria: (continue to next

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EPA DEFINITION OF A HAZARDOUS WASTE (CONT.) (i) It exhibits any of the characteristics of hazardous waste

identified in subpart C of this part. However, any mixture of a waste from the extraction, beneficiation, and processing of ores and minerals excluded under §  261.4(b)(7) and any other solid waste exhibiting a characteristic of hazardous waste under subpart C is a hazardous waste only if it exhibits a characteristic that would not have been exhibited by the excluded waste alone if such mixture had not occurred, or if it continues to exhibit any of the characteristics exhibited by the non-excluded wastes prior to mixture. Further,

(Continue to next slide)

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EPA DEFINITION OF A HAZARDOUS WASTE (CONT.) for the purposes of applying the Toxicity Characteristic to

such mixtures, the mixture is also a hazardous waste if it exceeds the maximum concentration for any contaminant listed in table I to §  261.24 that would not have been exceeded by the excluded waste alone if the mixture had not occurred or if it continues to exceed the maximum concentration for any contaminant exceeded by the nonexempt waste prior to mixture.

(Continue to next slide)

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EPA DEFINITION OF A HAZARDOUS WASTE (CONT.) (ii) It is listed in subpart D of this part and has not been

excluded from the lists in subpart D of this part under §§  260.20 and 260.22 of this chapter.

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You don’t need to memorize the definition of a hazardous waste either!

SO, IS YOUR WASTE A HAZARDOUS WASTE? EPA regulations (40 CFR 261.2) require that a

hazardous waste determination be made on a solid waste which has been generated

Even though you must manage your waste appropriately, you don’t have to decide what to call your waste

UAF EHSRM Hazmat team will make final hazardous waste determinations as outlined in 40 CFR 262.11

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Let’s look at the different categories as defined by the EPA

CATEGORIES OF HAZARDOUS WASTE

Hazardous waste determinations are based upon whether the material is a:Characteristic waste

Listed on the D-list or TCLP (Toxicity Characteristic Leaching Procedure)

Listed waste Materials specifically identified on one of the following lists: F, K, U or P

lists

Universal waste Batteries, lamps, pesticides, mercury from thermometers

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CHARACTERISTIC WASTES

D001 – Ignitable Wastes (flashpoint is less than 140º F) includes oxidizers D002 – Corrosive Wastes (pH less than or equal to 2 or greater than or equal to 12.5) D003 – Reactive Wastes (water reactive, normally unstable materials, cyanides & sulfides, etc) D004 – TCLP Wastes

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LISTED WASTES

F-listed wastes are from non-specific sources Example: halogenated solvents used to degrease

equipment

K-listed wastes are from specific sources Example: petroleum refining or pesticide manufacturing

U-listed wastes are toxic wastes P-listed wastes are acutely hazardous

wastes

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EXAMPLES OF U-LISTED WASTES

Acetaldehyde 1,4-Dioxane

Acetone Ethyl acetate

Acetonitrile Ethyl ether

Aniline Formaldehyde

Benzene Methyl alcohol

Bromoform Methylene chloride

1-Butanol Phenol

Chloroform Toluene

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U-listed chemicals are commonly found in UAF labs

EXAMPLES OF P-LISTED WASTES

Allyl alcohol Osmium tetroxide

Ammonium vanadate Phenylthiourea

Arsenic acid Potassium cyanide

Arsenic trioxide Sodium azide

Carbon disulfide Sodium cyanide

2,4-Dinitrophenol Thiosemicarbazide

Fluorine Vanadium oxide

Nitric oxide Vanadium pentoxide

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P-listed chemicals are also fairly common in UAF labs

UNIVERSAL WASTES

Universal wastes include the following materials that are commonly found in the workplace Batteries Fluorescent lamps Pesticides Thermometers (containing mercury)

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UNIVERSAL WASTES: BATTERIES Used Battery collection containers (white

5-gallon buckets) are available at many locations on campus

Contact your Lab Manager, CHO, Shop Supervisor or EHSRM for more information

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UNIVERSAL WASTES: FLUORESCENT LAMPS

UAF recycles fluorescent and other lamps Lamp shipments are made periodically to EcoLights Northwest

The Facilities Services Electric Shop does the vast majority of lamp replacement on campus

EHSRM can provide lamp collection boxes and labels to you Boxes must be labeled with the words, “Universal Waste

Lamps”, “Waste Lamps”, or “Used Lamps” to identify the contents

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UNIVERSAL WASTES: PESTICIDES

If you have waste pesticides: Fill out an online UAF Non-radioactive

Hazardous Materials Transfer Request. Don’t know how? Go to slide #41.

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UNIVERSAL WASTES: MERCURY THERMOMETERS

If you break a mercury thermometer: DO NOT try to clean it up yourself ---- Call UAF Hazmat at

474-5617 immediately for assistance Evacuate the area and keep traffic from walking through the

spill site NEVER throw the material in the trash or dump it down the

drain

Don’t need your mercury thermometers or wish to exchange unbroken thermometers for similar, non-mercury thermometers, free of charge? Call EHSRM at 474-5197 to get more information.

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OTHER WASTE: AEROSOL CANS Aerosol cans are considered hazardous waste under

the definition of “Characteristic Reactivity” 40 CFR Part 261.23: “….capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement.”

Often contain hazardous materials, either as the product or as the propellant

Most aerosol cans, regardless of contents, can never be completely emptied of propellant

Aerosol cans become a waste when… their contents are used up, malfunction (i.e. fail to spray), or when the contents are no longer needed

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OTHER WASTES: USED OIL

Used oil means: any oil that has been refined from crude oil, or any synthetic oil, that has been used and as a result of such use, is contaminated by physical or chemical impurities (40 CFR 279.1)

Used oil must be: Collected in clean containers in good condition (no

leakers) Storage and transfer containers must be marked with the

words “Used Oil” Never add solvents, part washer fluids, carb cleaners, or

glycol to your used oil

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OTHER WASTES: USED OIL (CONT.) Keep the “used oil” container closed (lid in

place and secured) except when adding or removing used oil

If you use a funnel for transfers, the funnel must be removed when not in use and the container capped

See slide #41 to make on online request to have your used oil removed

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WASTE IN YOUR LABWhat do I do with my wastes and unwanted chemicals?

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SATELLITE ACCUMULATION AREAS Each lab that generates waste is referred

to as a “Satellite Accumulation Area” (SAA)

When EHSRM removes the waste from a SAA, it is transferred to the UAF Hazmat Facility or “Central Accumulation Area”

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WASTE STORAGE LIMITS FOR SAAS

For SAAs, the waste storage limits are: Up to 55 gallons of a hazardous waste Up to 1 quart (1 liter) of a P-listed waste 50 gallons of waste at a SAA will likely be in

violation of Fire & Building Codes

Note: you do not need to accumulate 55 gallons or 1 quart of

P-listed waste before requesting waste removal!

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TO MAKE A WASTE REMOVAL REQUEST As of April 2012, the Division of Hazardous Waste at

EHSRM is using an online hazardous waste pick up request. Please discontinue using the old triplicate paper hazardous waste transfer request forms.

If you have not been trained in the use of the online request, call 474-5197 to schedule a training session. Or go to the EHSRM website for more information:http://www.uaf.edu/safety/laboratory-safety/chemical-inventory/

Remember: There is no charge to your lab for chemical waste disposal

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TAKE-HOME MESSAGESWhat you need to remember…

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WASTES: CONTAINERS AND STORAGE Only use containers that are compatible with the

materials to be collected Always label containers with a description of their

contents Don’t store incompatible materials together Do not store wastes in the fume hood. Store in the

appropriate storage cabinet (e.g., flammable, acid) Provide secondary containment for liquid wastes Always keep the container closed (lid firmly secured)

A funnel in an open bottle is NOT a lid Check waste storage areas regularly (weekly). Inspect containers to make sure they aren’t getting

brittle or starting to crack

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BEFORE YOU START A PROJECT Plan ahead

Is there a product or procedure available that will accomplish the task w/o generating a hazardous waste?

Strive for waste minimization Only make as much solution as you need Substitute less hazardous chemicals if possible Use microscale chemistry techniques

Before purchasing chemicals, log onto your EHS Assistant online inventory and click on the “Surplus Chemicals” button at the top of the main page. Contact EHSRM at 474-5617 to request transfer of surplus chemicals.

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OTHER THINGS TO THINK ABOUT

Check the P-list - if you plan to generate a P-listed waste, contact your Chemical Hygiene Officer, Lab Manager or EHSRM

Never combine wastes If you don’t generate them together as part of a

procedure, then do not mix them. May create hazardous reactions in the bottle (worst-

case scenario), or make it more expensive for us to dispose of it (not a good scenario, but at least it didn’t blow up)

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EMERGENCY RESPONSEChemical spills, release of hazardous materials, fires, and evacuation

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CHEMICAL SPILLS

Report all spills to UAF Dispatch (474-7721) or call 911 if there is an immediate threat of harm to life or property

Dispatch will call EHSRM Hazmat Section or the FNSB Hazmat Team, if necessary, to request assistance with spill cleanup

Depending on the nature of the spill, you may be asked to complete the UAF Oil and Hazardous Substance Spill Reporting Form (available from EHSRM)

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CHEMICAL SPILLS (CONT.)

If you have not been trained and/or do not have the appropriate personnel protective equipment, please call for assistance!

Never put yourself or others at risk to cleanup a spill!

If you don’t know…don’t go

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EMERGENCY PROCEDURES: FIRE Activate the nearest fire alarm pull station and

call 911 Evacuate the building and go to the Evacuation

Assembly Point or designated area of safe refuge

Advise emergency personnel of anyone still inside the building

Do not re-enter the building until authorized by emergency personnel

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EMERGENCY PROCEDURES: RELEASE OF HAZARDOUS MATERIALS

Call 911 in the event of an emergency or if anyone is in danger

Move away from the site of the hazard to a safe location

Follow the instructions of emergency personnel Alert others to stay clear of the area Notify emergency personnel if you have been

exposed or have information regarding the release

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EMERGENCY PROCEDURES: EVACUATION Know the evacuation procedures and evacuation route

information for your area Evacuate the building using the nearest safe exit Do not use elevators! Take personnel belongings (keys, purses etc., but don’t put

yourself or others at risk by delaying evacuation) If possible, secure any hazardous materials or equipment Follow the directions given by emergency personnel Go to Evacuation Assembly Points (EAPs) designated on the

emergency evacuation sign for the building Assist persons with disabilities Do not leave the area/campus until your status has been

reported to your supervisor or instructor

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FOR MORE INFORMATION…

Environmental, Health, Safety, and Risk Management

Visit our website at: www.uaf.edu/safety

Or call us at 474-5413

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