INTRODUCTION TO HAZARDOUS WASTE MANAGEMENT University of Alaska Fairbanks Environmental, Health, Safety, and Risk Management May 2013
Jan 31, 2016
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
slide)20
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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