Hazardous Waste and Chemical Management for Facilities

1. Hazardous Waste and Chemical Management for Facilities Glenn Magley MKC Enterprises, Inc. glenn@mkcenterprises.com

2. Hazardous Waste Management Learning Objectives • The generator of hazardous waste will be able to: • Identify hazardous waste • Ensure it is properly managed 1. 2. 3. 4.

3. Hazardous Waste Module • State and federal regulations require that employees who produce (generate) hazardous waste must be trained. • This module has been developed to meet this expectation.

4. Hidden HazardsDangerous chemicals in school labs an explosive situation By Katheleen Conti, Boston Globe Staff  |  April 10, 2005 Chemistry lesson one: Accidents happen, like the recent spill at Exeter High School in New Hampshire, when fumes in a lab class sent three students to the hospital and shut down the school for the day. Chemistry lesson two: Adding unknowns to the mix -- like improper storage and handling of toxic substances -- can be a formula for disaster. In January, firefighters responding to an alarm triggered by a chemistry experiment at Pope John XXIII High School in Everett found a jar containing a potentially volatile material that is used to produce rocket fuel. Deemed unstable, the chemical -- 2, 4-dinitrophenol -- was detonated by the State Police Bomb Squad.

5. Chemicals Ordered Removed By Tarron Lively, THE WASHINGTON TIMES, Published March 25, 2005 D.C. Public Schools Superintendent Clifford B. Janey issued a protocol yesterday for removing potentially dangerous chemicals from schools, after a series of mercury contaminations and the revelation that a previous removal effort was incomplete.     The nine-page protocol lists more than 200 chemicals including mercury, chlorine, chloroform, ether, hexyl alcohol and nicotine. The protocol was issued to the principals of each of the city's roughly 150 public schools. The school system's Hazmat Removal Team, D.C. Fire and Emergency Medical Services and the American Association for the Advancement of Science helped create the protocol and will handle the removal and disposal of the materials.       School administrators ordered all potentially hazardous materials removed after an October 2003 mercury spill at Ballou High School in Southeast. The incident closed the building for more than a month, and cleanup cost at least $1 million. A student who was charged in the case had taken the mercury from a science lab.     However, investigations into the recent mercury incidents at Cardozo High School and Hardy Middle School revealed that potentially hazardous materials were still inside schools.

6. Recently In Colorado, 300 schools were inspected. • They Reported:           99% had inherited their inventories          98% had incompatible storage          94% had shock sensitive compounds          85% had inadequate chemical hygiene plans          65% had inadequate functioning fume hoods          30% had explosive chemicals          15% had radioactive materials

7. The EPA “Reaches Out” • In February 2007, EPA Region 4 launched the Colleges and Universities Compliance Incentive Initiative, encouraging. • Region 4 mailed letters to public and private colleges in the southeastern United States to “highlight the opportunity to take advantage of voluntary environmental self-audits” . • This provides incentives for schools to voluntarily discover, disclose, and correct non-compliance. • Disclosures may receive a partial or complete reduction in financial penalties.

9. Summary of Incentives underEPA’s Audit Policy • Penalty mitigation • No recommendation for criminal prosecution. • No routine requests for audit reports.

10. Contact: Sheryl Rosner, EPA Office of Public Affairs, (617) 918-1865 • For Immediate Release March 3, 2005; Press Release #sr050301 • The U.S. Environmental Protection Agency announced today that it has proposed a $171,050 penalty against Plymouth State University, in Plymouth, NH for violations of hazardous waste laws. …. • Specifically, EPA claims that the University failed to: • make hazardous waste determinations; • properly store hazardous waste; • maintain spill and fire control equipment; • post “no smoking” signs; • post emergency telephone numbers; • keep hazardous waste containers closed; • mark hazardous waste containers with accumulation dates; • conduct inspections of hazardous waste storage areas. EPA seeks $171,050 from Plymouth State University, Plymouth, NH for Hazardous Waste Violations

11. EPA Cites Puerto Rico University at Mayaguez for Multiple Violations of Environmental Safety RulesWednesday, October 5, 2005 The U.S. Environmental Protection Agency (EPA) has cited the University of Puerto Rico (UPR) in Mayagüez for violating EPA Regulations… and proposed that the university pay nearly $1 million in penalties for these violations. ……. UPR submitted self-disclosures under EPA's Audit Policy … Normally, EPA would grant relief from financial penalties for self- disclosed violations, but it was determined that UPR was not eligible for full relief because UPR was not correcting all its violations. As a result, EPA conducted its own comprehensive inspection .. and found numerous violations. EPA and the Commonwealth found that UPR failed to operate its facility in a manner that would minimize the risk of releasing hazardous wastes … The containers held wastes ranging from used oil, various acids and spent solvents to formaldehyde. UPR was also storing hundreds of containers of old and expired chemicals, such as picric acid, in an unsafe manner.

12. What is a Waste?

13. EPA describes several ways something becomes a waste: • Discarded • Inherently waste-like (dioxins) • Use constituting disposal • Speculative accumulation • 40 CFR Part 261 (www.access.gpo.gov)

14. Speculative accumulation: pack rats

16. Compliance Tips Helpful Tip #1: How do you tell whether it’s waste? • Is it in good condition and labeled? • Is it currently legal for use in the U.S.? • Has anyone used it in the last year or two? Be honest. • Will anyone use it in the next year or two? Be brutally honest.

17. Is it a Hazardous Waste?

18. Hazardous Waste Classification Can be a: • Solid • Liquid • Gas • Sludge Hazardous waste is a material that no longer has an intended value

19. Hazardous Waste Definition • The following categories are not considered hazardous waste: • Sewage • Regular trash • Radioactive waste • Biohazard waste

20. Determination of Waste Status • The burden of proof to determine if a waste material is defined as “hazardous” is on the generator • May need to analyze the waste to determine its status

21. Hazardous Waste Categories • Characteristic waste • Ignitable • Reactive • Corrosive (pH <2.5 or >11) • Toxic – Arsenic, Barium, Cadmium, Chromium, Lead, Mercury, Selenium, Silver • Listed waste • EPA has lists of hazardous waste, mostly based on toxicity and often process-specific

22. Some hazardous wastes are obvious

23. Some are not

24. How do you tell it’s hazardous?

25. Hazardous Waste 101 How do you tell? • Ask the vendor • Use the MSDS Book • Use the MSDS Online

26. Hazardous Waste • Examples of hazardous waste: • Mercury from a broken thermometer • Flammable Paints and Solvents • Waste isopropyl alcohol • Aerosols • Electronic circuit boards (lead solder)

27. Hazardous Waste Locations • Laboratories and Classrooms • Maintenance Facilities (paint, pesticides, maintenance fluids) • Light Bulbs • Nursing Schools / Health Services • Buildings repurposed from science curriculum

28. Universal Waste

29. Universal Waste Types • Lamps (contain mercury) • Batteries (rechargable) Ni-Cd, Lead Acid, NiMH • Pesticides – recalled or out-dated • Mercury-containing thermostats • Other mercury-containing devices • Fluorescent Light Ballasts containing PCBs • Cathode Ray Tubes

30. Proper Labeling • All waste containers must be properly labeled. • Hazardous Materials Must have the words “Hazardous Waste” • “Used Oil” • “Universal Waste -- Lamp(s),” or “Waste Lamp(s),” or “Used Lamp(s)", • Must include all hazardous components • Labels are available at Safety and Risk Management

31. UNC-Charlotte Failed to: • close container being used to accumulate universal waste lamps; • label containers “Universal Waste-Lamps,” or “Waste Lamp(s)” or “Used Lamp(s)”; • show how long the waste lamps had been accumulated. • properly label 7 5-gallon containers of used oil with the words “Used Oil”. • conduct weekly inspections; • close Eleven containers; • label 8 containers with words “Hazardous Waste” Fined: $19,633

32. EPA, Macy’s Announce Settlement Over Hazardous Waste Management Violations Release date: 08/27/2008 Contact Information: John Senn (212) 637-3667, (New York, N.Y.) The U.S. Environmental Protection Agency (EPA) and Macy’s Retail Holdings, Inc., have agreed to a settlement over hazardous waste management violations at Macy’s stores in Albany and Garden City, N.Y. EPA alleged in 2007 that Macy’s failed to properly identify and handle spent fluorescent and other types of light bulbs at the two stores.Macy’s has agreed to pay a $49,725 penalty and to voluntarily ensure that its approximately 75 stores throughout New York, New Jersey and Puerto Rico remain in compliance with the requirements for the handling of spent light bulbs.

33. What do I do once I found it?

34. Improper Waste Management

35. Management of Chemical Waste • Separate incompatible material • Label Each Waste Container • Seal each waste container • Keep track of constituents (rough quantities) • Store waste in appropriate locations (cabinets, not in active hoods)

36. Proper Labeling • All waste containers must be properly labeled. • Hazardous Materials Must have the words “Hazardous Waste” • “Used Oil” • “Universal Waste -- Lamp(s),” or “Waste Lamp(s),” or “Used Lamp(s)", • Must include all hazardous components

37. Improper Labeling

38. Improper Methods of Disposal for Hazardous Waste • Hazardous waste should not be: • Placed In regular trash • Mixed with biohazard waste (red bag or sharps) • Flushed down the drain • Allowed to reach surface water (rivers, lakes) via storm sewer system • Allowed to evaporate (note - open containers imply evaporation)

39. Where did the waste go?

40. Satellite Accumulate Area • Satellite accumulate area – is defined as the area (typically a room) where the hazardous waste is generated. • Must be designated with signs • Containers must remain closed except when adding material. • Containers must be marked with the words “Hazardous Waste”. • Can not exceed 55 gallons of waste.

42. Reduction of Chemical Waste • Replace reagents with less toxic alternatives (green chemistry) • Work in smaller scales • Centralize purchasing • Buy only what you need for 1 year • Supervise what is coming into stock • Neutralize acids and bases (not chromic or fuming acid)

43. Containers • Contents must be compatible with container material • Problems: • Certain solvents placed in plastic containers • Hydrofluoric acid in glass containers

44. Empty Container Definition • An empty container is defined as: • All waste has been emptied using common practice • Maximum of 1 inch of product remains in container • No more than 3% by weight of the container remains (tanks <110 gallons)

45. Examples of Violations

46. Summary of Most Common Violations • Waste containers were not marked “Hazardous Waste” • Waste Containers without dates of accumulation • Waste Containers are not closed • Universal waste light bulbs were not being managed properly • Training of employees who handle hazardous waste is not documented • Inspections were not recorded on a weekly basis • Onsite Treatment of wastes is occurring. • Waste material has not been determined as being hazardous • Not all MSDS’s

47. Violations

48. Violations (cont.)

49. Liabilities • Injury to Students / Personnel • Violations can be up to $5,000 each • Willful Neglect • Repeat Offenses • Violations with Immediate Threat to Human Health or Environment - $25,000 • Unreported spills, Dumping, Misrepresentation =

50. Chemical Management and Handling