Introduction to Hazardous Waste Management

1. Introduction to Hazardous Waste Management University of Alaska Fairbanks Environmental Health, Safety, and Risk Management September 2009

2. 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

3. Overview of hazardous materials regulations

4. 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 Health and Safety Administration (OSHA) • Title 29, Code of Federal Regulations (29 CFR) • Environmental Protection Agency (EPA) • Title 40, Code of Federal Regulations (40 CFR) The International Fire and Building Codes also regulate hazardous materials.

5. Hazardous Materials Regulations (cont.) • DOT regulations tell 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.

6. DOT Regulations The 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: Class 1: Explosives Class 2: Compressed Gases Class 3: Flammable Liquids Class 4: Flammable Solids Class 5: Oxidizers Class 6: Poisons & Toxics Class 7: Radioactive materials Class 8: Corrosives Class 9: Miscellaneous hazardous materials that don’t fit any other hazard class… (dry ice, for example)

7. OSHA Regulations OSHA regulations include the following standards: • Hazard Communication Standard (a.k.a., Hazcom, Right-to-Know) • Occupational Exposure to Hazardous Chemicals in Laboratories • includes 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 OSHA also establishes permissible exposure levels (PELs) for hazardous chemicals.

8. EPA Regulations The EPA regulations help us protect our environment, and include the following: • Resource Conservation Recovery Act Hazardous Waste Regulations (RCRA) • Clean Air Act • Clean Water Act • Toxic Substances Control Act (TSCA) • Emergency Planning & Community Right-to-Know • Worker Protection Standard for Agricultural Pesticides

9. Hazardous Waste Regulations EPA regulates hazardous waste in Alaska by authority of the Resource Conservation Recovery Act. RCRA controls include: • Identification of hazardous wastes • Tracking wastes from “cradle to grave” • Setting standards forgenerators of wastes, transporters of wastes, and Treatment, Storage & Disposal Facilities

10. Primary RCRA requirements RCRA requires that you: • Ensure that containers are labeled with a description of their contents • Do not have more than the maximum permissible volumes of waste stored in your lab • Ensure that lids and caps are securely fastened at all times, except when putting wastes into the containers • Ensure that all materials are properly segregated • Use containers that are compatible with the waste you are putting into them • Use containers that are intact (no cracks, holes, etc.) • Ensure that spills and overfills do not occur • Ensure that mismanagement does not occur

11. Requirement for training The purpose of this training is to comply with the 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 wastes 2. understand how to package and label hazardous wastes 3. understand how to have their hazardous materials disposed 4. know how to respond effectively to emergencies

12. 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.

13. Hazardous waste at UAF An overview of sources of hazardous waste at UAF, and of their ultimate fate…

14. Sources of Hazardous Waste at UAF Sources of hazardous wastes 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

15. Hazardous Waste Generators The RCRA definition of a hazardous waste 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 hazardous waste that they produce per month: CESQG = Conditionally Exempt Small Quantity Generator SQG = Small Quantity Generator LQG = Large Quantity Generator > 1000 kg/month or >1 qt. of acutely hazardous waste/month

16. UAF’s Waste Generator Status • The UAF main campus is currently regulated as a Large Quantity Generator of hazardous waste. • UAF’s extended sites are currently regulated as Conditionally Exempt Small Quantity Generators • Examples: Toolik Field Station, Palmer Research Farm, FITC in Kodiak, Seward Marine Center, Lena Point Fisheries Facility, etc.

17. Hazardous Waste Management at UAF • EHS&RM assists UAF waste generators with their waste disposal needs. • Wastes are stored in the Hazardous Materials Facility (HMF), which serves as the Central Accumulation Area (CAA) for UAF. • RCRA-regulated hazardous wastes are shipped every 90 days from the HMF. • Wastes are shipped 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.

18. What is hazardous waste?

19. EPA definition of a solid waste • EPA begins by defining everything 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. • (Again, no need to memorize that!)

20. EPA definition of a hazardous waste • If the waste material meets certain criteria, and is not somehow exempted or excluded from the regulations, it may be a RCRA-regulated hazardous waste. • 40 CFR 261.3: definition of a hazardous waste: • (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: • (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, 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. • (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.

21. So… is your waste a hazardous waste?

22. The good news… • The good news is, you don’t have to make that determination. • The UAF Hazmat team will decide whether your waste is a RCRA-regulated hazardous waste, a non-regulated hazardous waste, or a non-hazardous waste. • Even though you don’t have to decide what to call your waste, let’s look at the different categories as defined by the EPA.

23. Categories of Hazardous Waste Hazardous wastes are regulated because they present special hazards to man or to the environment if they are improperly disposed of or discarded. Hazardous waste determinations are based upon whether the material is a: • Characteristic waste • Listed on the D-list or TCLP • A 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)

24. Characteristic Wastes • D001 – Ignitable Wastes (flashpoint is less than 1400 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 reactives, normally unstable materials, cyanides & sulfides…) • D004 - TCLP Wastes (Toxicity Characteristic Leaching Procedure)

25. 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: product washwaters from the production of dinitrotoluene via nitration of toluene • U-listed wastes are toxic wastes • P-listed wastes are acutely hazardous wastes

26. Examples of U-Listed Wastes U-listed chemicals are commonly found in UAF labs.

27. Examples of P-Listed Wastes P-listed chemicals are also fairly common in UAF labs.

28. Universal Wastes Universal wastes include the following materials that are commonly found in the workplace • Batteries • Fluorescent lamps • Pesticides • Thermometers (containing mercury) • Used oil

29. Universal wastes: Batteries • Used Battery collection containers are available at many locations on campus. • Contact your Lab Manager, CHO, Shop Supervisor or EHS&RM for more information.

30. Universal wastes: Fluorescent Lamps • UAF collects fluorescent and other lamps for recycling • Lamp shipments are made periodically to EcoLights Northwest. • The Facilities Services Electric Shop does the vast majority of lamp replacement on campus. • If you have fluorescent lamps (or other types of lamps) that you use in your research, and are responsible for replacing them, EHS&RM 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.

31. Universal wastes: pesticides and waste from mercury thermometers • Please fill out a UAF Non-radioactive Hazardous Materials Transfer Request Form if you have waste pesticides or mercury from broken thermometers. • The transfer forms will be explained later in the training. • Note: if you break a thermometer, do not try to clean it up yourself. Call UAF Hazmat at 474-5617 immediately for assistance. • Do not ever throw the material in the trash, or dump it down the drain.

32. Universal waste: 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. Used oil must be: • Collected in clean containers in good condition (no leakers please) • 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 • Keep the “used oil” container closed (lid in place and secured) except when adding or removing used oil • Call EHS&RM Hazmat (474-5617) to have your used oil removed

33. Waste in your lab What do I do with my wastes and unwanted chemicals?

34. Satellite accumulation areas • Each lab that generates waste is referred to as a “Satellite Accumulation Area” (SAA) • When EHS&RM removes the waste from a SAA, it is transferred to the UAF Hazmat Facility or “Central Accumulation Area”

35. Waste Storage Limits for SAAs • For SAAs, the waste storage limits are: • Up to 55 gallons of a U-listed waste • Up to 1 quart (1 liter) of a P-listed waste • Note: you do not need to accumulate 55 gallons or 1 quart of P-listed waste before requesting waste removal! • 50 gallons of waste at a SAA will likely be in violation of Fire & Building Codes Space is a very valuable asset. Give us a call anytime to remove your waste (474-5617).

36. To Make a Waste Removal Request • Complete the Non-Radioactive Hazardous Materials Transfer Request form. • Forms are available from your Lab manager, Chemical Hygiene Officer, Shop Supervisor, or EHS&RM. • There is no charge to your lab for chemical waste disposal. • The transfer forms are numbered and come with a similarly numbered adhesive label (fluorescent orange) that must be applied to the waste collection container.

37. Completing the transfer form • Fill out the upper portion of the transfer form. • Name and contact info • Location of waste (building and room number) • Chemical(s) in waste, and their concentrations • For mixtures, list all constituents • If more room is needed, attach a separate list to the form • Type of container and physical state of the waste • Number of containers, their volume, and the total volume

38. Haz Mat Transfer Request Form

39. Multiple Containers If you have multiple containers of the same waste stream (identical contents), just fill out one form. Unnumbered adhesive labels are available to go on multiple containers. Use the number as identified on the upper right hand side of the transfer form and identify the container as being 1 of 4; 2 of 4, etc.

40. Getting your waste picked up • Call 474-5617 to schedule a pickup, or if you have any questions about your waste. • The form comes in three parts… Save the pink copy for your files. Give the white and yellow copies to EHS&RM when they come to pick up your waste.

41. Take-home messages What you need to remember…

42. 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. • If you need waste containers, contact EHS&RM or your Chemical Hygiene Officer to inquire about availability.

43. Before you start a project… • Plan ahead • Is there a product or procedure available that will accomplish the task without 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, check with EHS&RM or your department Chemical Hygiene Officer for the availability of surplus chemicals.

44. 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 EHS&RM. • 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). • Call EHS&RM at anytime to request waste removal.

45. Emergency Response Chemical spills, release of hazardous materials, fires, and evacuation

46. 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 EHS&RM Hazmat Section or, if necessary, the FNSB Hazmat Team, 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 EHS&RM).

47. 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.

48. 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.

49. Emergency Procedures: Release of Hazardous Materials • In the event of an emergency or if anyone is in danger, call 911. • 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.

50. 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.