Hazardous Waste Management Program

Hazardous wastes come in many shapes and forms.  They can be liquids, solids, contained gas, or sludge.They can be the byproducts of laboratory experiments or simply discarded commercial products, like cleaning fluids or pesticides. Whatever their form, proper management and disposal are essential to protect human health and the environment. Protecting employees from occupational exposure to hazardous waste is a great concern. Federal laws have established liability for improper handling, processing and disposal of these wastes.

Monmouth University generates hazardous waste in day-to-day activities, such as routine byproducts of chemistry laboratories, photography labs, art department, health center, Woods Theatre, and Facilities Management. The University, individual employees and students can be held liable for improper disposal of hazardous waste. This plan presents a compilation of information on the regulations and procedures which must be used to handle and dispose of hazardous wastes generated at Monmouth University.

In 1965, to encourage environmentally sound methods for disposal of household, municipal, commercial, and industrial refuse, Congress passed the first federal law requiring safeguards on these activities: the Solid Waste Disposal Act. Congress amended this law in 1976 by passing the Resource Conservation and Recovery Act (RCRA). The primary goals of RCRA are to:

	Protect human health and the environment from the potential hazards of waste disposal.
	Conserve energy and natural resources.
	Reduce the amount of waste generated.
	Ensure that wastes are managed in an environmentally sound manner.

As more information about health and environmental impacts of waste disposal became available, Congress revised RCRA in 1980 and in 1984. The 1984 amendments are referred to as the Hazardous and Solid Waste Amendments.

RCRA is divided into sections called Subtitles. Subtitles C and D set forth a framework for the U.S. Environmental Protection Agency’s (EPA’s) comprehensive waste management program. EPA’s Subtitle C program establishes a regulatory framework for managing hazardous waste from generation until ultimate disposal. EPA’s Subtitle D program establishes a system for managing solid (primarily nonhazardous) waste, such as household waste.  RCRA also regulates underground storage tanks (UST’s) that store petroleum or certain chemical products under Subtitle I. Requirements exist for the design and operation of these tanks and the development of systems to prevent accidental spills.

About the Hazardous Waste Management Program

The Office of Affirmative Action, Human Relations and Compliance is responsible for coordinating the disposal of hazardous waste from University operations. This office provides compliance and safety services through technical support, information and training programs, consulting services, and periodic auditing of safety practices and regulatory compliance. This office also prepares and submits the Biennial Hazardous Waste Generator and Exception Reports.

Hazardous waste generators (individuals and departments) are responsible for determining whether their waste is hazardous and accounting for the final disposal of their waste. Generators are required to properly manage hazardous accumulation sites (containers, packaging, markings, and labels) and to notify Facilities Management for a pickup whenever the threshold quantity (see section III.) of the hazardous waste is reached. At Monmouth University the following departments have been identified as hazardous waste generators:

	Chemistry
	Biology
	Art and Design
	Woods Theatre
	Health Center
	Photo Lab in the Student Center (Outlook)
	Photo Lab in Wilson Hall (University Photographer)
	Facilities Management

Other potential hazardous waste generators include:

	University Bookstore
	Print Shop
	Psychology
	Athletic Trainers Facility

Classification of Waste as Hazardous

In accordance with the Code of Federal Regulation, 40 CFR, waste is considered hazardous if:

	It is on either of two lists of specific chemical substances developed by the Federal Environmental Protection Agency (EPA). Most commonly used organic solvents, e.g. acetone, methanol, toluene, xylene, methylene, chloride etc.) are included.  For a detailed listing, contact the Office of Affirmative Action, Human Relations and Compliance or refer to the web site in section XIV.
	It is on a list of nonspecific sources that includes a broad range of spent halogenated and non-halogenated solvents.
	It is on a list of specific sources that includes primarily industrial processes.
	It exhibits any of the following characteristics as defined by the EPA (definitions are abbreviated):

Ignitable

	Is a liquid with a flash point less than 60 degrees Centigrade.
	Is not a liquid and not capable under normal conditions of causing fire through friction, absorption of moisture or spontaneous chemical changes.
	Is an ignitable compressed gas.
	Is an oxidizer.

	Is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5.
	Is a liquid and corrodes steel at a rate greater than 0.250 inches per year at 55 degrees Centigrade.

	Is normally unstable.
	Reacts violently with water.
	Forms potentially explosive mixtures with water.
	Cyanide or sulfide wastes that generate toxic gases, vapors, or fumes at pH conditions between 2 and 12.5.
	Is capable of detonation or explosive decomposition if submitted to strong initiation or under standard temperature and pressure.
	Is classified as a Department of Transportation explosive.

Toxicity Characteristic

	Is found to contain certain metals, pesticides or selected organic above specified levels in an extract of the waste.
	Is otherwise capable of causing environmental or health damage if improperly disposed (this is a judgement you must make based upon your knowledge of the material from the Material Safety Data Sheet of the literature).

Accumulation of Hazardous Waste at Point of Generation

Hazardous waste may be accumulated in an area of a laboratory or facilities operation near the point of generation. The principal worker(s) generating the waste must control this area. State and federal regulations stipulate how waste generators must store hazardous waste and require the following:

• Any container used to accumulate hazardous waste must be labeled with the words "hazardous waste" (regardless of its location) as soon as accumulation begins. This includes accumulation of hazardous wastes within a laboratory or hazardous waste in a facilities operation.
  
• Be sure that the container is compatible with the hazardous waste. Use containers that are made of, or lined with, materials which will not react with, and are otherwise compatible with, the hazardous waste to be accumulated. Often the original container is suitable.
  
• Waste containers must be closed at all times, except when being filled. Do not leave funnels in the containers.
  
• Be sure that containers in the waste accumulation area do not leak. Consider the use of secondary containment, such as a tray, larger container or basin. If a leaking container is found, immediately clean up any spilled material according to established spill cleanup procedures and transfer the waste into a container that is in good condition.
  
• No more than one quart of an acutely hazardous waste of 55 gallons or other hazardous waste may be accumulated in a satellite waste accululation area. If this threshold quantity is reached, the worker must transfer the waste to the Facilities Management accumulation area within three calendar days. The container must bear a hazardous waste label with the accumulation date, either the date the threshold quantity
• was reached or the date it was placed in the Facilities Management accumulation area marked on the container.
  
• Like any hazardous waste accumulation in the laboratory or work area, be sure to segregate the containers according to the type of waste.

There is one 180-day accumulation area on campus, which is maintained and located behind the Facilities Management building. Facilities Management (Fire & Safety Supervisor) must approve any accumulation of wastes in this area. Wastes accumulated in this area will be shipped to an off-site authorized commercial facility within 180 days from the date accumulation began as indicated on the container.

The following are excerpts from the US Environmental Protection Agency (EPA) regulations regarding hazardous waste storage:

Accumulation: 40 CFR 262.34 (c)

1)  A generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in Sec. 261.33(e) in containers at or near any point of generation where wastes initially accumulate which is under the control of the operator of the process generating the waste without a permit or interim status and without complying with paragraph (a) of this section provided he:

	Complies with Sections 264.171, 265,172, and 265.173(a) of this chapter and
	Marks his containers either with the words "Hazardous Waste" or with other words that      identify the contents of the containers.

2)  A generator who accumulates either hazardous waste or acutely hazardous waste listed in Sec. 261.33(e) in excess of the amounts listed in paragraph (c) (1) of this section at or near any point of generation must, with respect to that amount of excess waste, comply within three days with paragraph (a) of this section or other applicable provision of this chapter. During the three-day period, the generator must continue to comply with paragraph (c) (1) (I) through (II) of this section. The generator must mark the container holding the excess accumulation of hazardous waste with the date the excess amount began accumulating.

Condition of Containers: 40 CFR 265.171

If a container holding hazardous waste is not in good condition, or if it begins to leak, the owner or operator must transfer the hazardous waste from this container to a container that is in good condition, or manage the waste in some other way that complies with the requirements of this part.

Compatibility of Waste with Container: 40 CFR 265.172

The owner or operator must use a container made of or lined with materials which will not react with and is otherwise compatible with the hazardous waste to be stored, so that the ability of the container to contain the waste is not impaired.

Management of Containers: 40 CFR 264.173 (a)

A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste.

Policy on Drain Disposal of Hazardous Waste

Facilities Management administers a Hazardous Waste Disposal Contract that provides a safe and legal means for the proper disposal of hazardous waste through EPA permitted waste disposal companies. This arrangement has been in effect for many years and the procedures in the various Science and Facilities departments for getting your waste into this system are well established.

Recent regulatory developments have made it more important than ever that generators of hazardous waste not dispose of hazardous wastes by any other routes. The Regional Sewerage Authority has stringent rules concerning drain disposal of hazardous wastes. In Attachment A, you will find the Regional Sewerage Authority rules, which list Prohibited Wastes.

These restrictions, in addition to New Jersey Pollutant Discharge Elimination Rules, effectively preclude drain disposal of most wastes. There are a few wastes for which either drain disposal or disposal via laboratory trash is safe and permissible. Check the list in Attachment B to determine which disposal method is acceptable.

The Regional Sewage Authority has initiated a program of sampling sanitary sewer lines immediately downstream from industrial and other large users (including Monmouth University). The implications of any adverse findings from this program are obvious.

Please take a close look at the procedures for handling hazardous wastes in your laboratory or work area and avail yourself of the existing hazardous waste disposal system. Seek ways to minimize wastes as much as possible. If you have specific questions about waste disposal, contact the Office of Affirmative Action, Human Relations and Compliance.

Packaging Hazardous Wastes by the Generator

Materials that are to be disposed of as hazardous waste should be placed in sealable containers. Waste disposal cost is based on volume, not weight; therefore, whenever possible, containers should be filled, leaving headspace for expansion of the contents. Often the original container is perfectly acceptable.

Containers must be kept closed except during actual transfers. Do not leave a hazardous waste container with a funnel in it.

Labeling of Hazardous Waste Containers by the Generator

Waste containers must be labeled with the words Hazardous Waste along with the names of the principal chemical constituents and the approximate percentage.

Labeling should be accurate and legible and should include the name of the generator, the name of the lab or the department, and an extension where someone who is knowledgeable about that specific waste can be reached in case questions arise during packaging for disposal.

Disposal Procedure

Hazardous waste pickups should be coordinated in Facilities Management by the Fire & Safety Supervisor on an as-needed basis. Do not call for hazardous waste pickup until the waste is properly identified, packaged and labeled. It is the user’s responsibility to identify and properly label all hazardous wastes. The disposal contractor cannot legally transport or dispose of unidentified/unknown waste.

Arrangements for chemical analysis of unknowns can be made through your department and the Office of Affirmative Action, Human Relations and Compliance.

Procedure for Disposal of Empty Hazardous Waste Containers

Chemical/product containers that have been emptied (generally this means drained of their contents by normal methods including pouring, pumping, aspirating, etc.) are not regulated as hazardous waste. Each container must be triple-rinsed with water or other suitable solvent and air-dried to ensure that it is free of liquid or other visible chemical residue. Containers with caps removed that have been triple-rinsed in a ventilated area can be placed in the trash or recycled. If the original contents were highly toxic, the container should be rinsed first with an appropriate solvent and the washing disposed of as hazardous waste. Containers meeting these criteria should be placed in receptacles provided by Facilities Management.

The waste generator must determine whether the washings must be collected and disposed of as hazardous waste. For volatile organic solvents (e.g. acetone, ethanol, ethyl acetate, ethyl ether, hexane, methanol, methylene chloride, petroleum ether, toluene, xylene, etc.) not on the list of acutely hazardous wastes, the emptied container can be air-dried in a ventilated area (e.g. a chemical fume hood) without triple rinsing. If residues remain after triple rinsing, the container should be placed with hazardous waste for disposal.

Used Oil

As of October 21, 1996, used oil is no longer considered a hazardous waste, per the New Jersey Department of Environmental Protection, with the following exceptions:

1. Vacuum pump oil from laboratories will be treated as hazardous waste due to the possibility of contamination with other chemicals.
2. Many cutting oils may not meet the definition of used oil. Contact Facilities Management (Fire & Safety Supervisor) before disposing of cutting oils in order to determine whether they should be treated as used oil or hazardous waste.
3. PCB contaminated oil must be treated as hazardous waste. Contact Facilities Management (Fire & Safety Supervisor) if there is any suspicion of PCB contamination.
4. Oil mixed with any other hazardous wastes must be treated as hazardous waste.

Used oil will be collected and disposed of by a commercial facility approved by the NJ Department of Environmental Protection for used oil disposal.

Used Oil Collection Tips

1. Minimize the amount of water in the oil.
2. Keep all collection vessels, especially drums, sealed except when filling the container.
3. Label containers "Used Oil", not "waste oil" or "hazardous waste".

Spills or Releases of Oil

1. Oil spills should be cleaned up immediately. Use absorbent materials (vermiculite) and lined 5-gallon pails.
2. Releases to the environment (including releases to the sewer, soil, or impervious surfaces outdoors) must be reported immediately to the Office of Affirmative Action, Human Relations and Compliance.

Mercury Disposal

As of October 21, 1996, waste metals that will be reclaimed are no longer considered hazardous waste per the New Jersey Department of Environmental Protection. Mercury and Mercury debris (e.g. broken thermometers, spill debris) will be collected by Facilities Management personnel and sent to a mercury reclamation/recycling pant. Mercury compounds will continue to be handled as hazardous waste.

Disposal Procedures

1. Collect mercury in a sealable container. Place broken thermometers or similar materials in a sealable plastic bag or plastic glass jar.
2. Label the container "WASTE MERCURY".
3. Call Facilities Management (Fire & Safety Supervisor) at Ext. 5244 to notify them of the mercury waste.
4. Keep the material in your laboratory or work area until it is picked up.
5. Any department that currently has a process for properly disposing of waste mercury can use their own procedure.

Broken Thermometers and Similar Materials

In the event that a thermometer, manometer or similar mercury-containing device breaks, proceed as follows:

1. Put on a pair of gloves and eye protection.
2. Pick up the broken glass or debris and place in a puncture-resistant container.
3. Clean up any remaining mercury using a mercury spill kit.
4. Place the mercury in a glass or plastic jar or a sturdy plastic bag. Only add visibly contaminated debris. Seal the bag and affix a label identifying the material as "mercury spill debris."
5. Follow the mercury disposal procedures outlined above.

Consider replacing your mercury thermometers with non-mercury or digital thermometers. Fisher Scientific and Lab Safety Supply offer a range of non-mercury thermometer options.

Photographic Effluent

A key characteristic of photo processing effluent is the silver concentration found in photographic fixer of bleach-fix effluent.

At Monmouth University all photography labs must recover silver from photo processing effluent before the solution can be discharged into the sewer. In addition, personnel (students and employees) working in this area must follow the recommendations of the manufacturer, Kodak, contained in the Environmental Guidelines for Amateur Photographers. A copy of this guideline can be obtained through the Office of Affirmative Action, Human Relations and Compliance.

Batteries

Used batteries containing hazardous metals (e.g. mercury, cadmium, lead, and silver) are classified as universal waste rather than hazardous waste. This allows Monmouth University to recycle the batteries, while continuing to ensure that the batteries are handled in an environmentally sound manner.

Facilities Management administers a collection program to encourage this recycling effort. Batteries may be brought to the Facilities Management building.

Waste Minimization

The U.S. Congress made waste minimization a national policy and the responsibility of each waste generator. On each waste manifest for hazardous waste pickups, Monmouth University must certify that the University has tried, to the extent economically feasible, to minimize the amount of hazardous waste generated at our institution.

Meeting the objectives of waste minimization at Monmouth University requires the cooperation of everyone who produces hazardous wastes. General principles for waste minimization, in order of priority, are:

1. Elimination-any modification that results in the elimination of waste generation.
2. Substitution-replacement of hazardous substances with less hazardous materials.
3. Scale Reduction-a reduction of the amount of hazardous materials used in a procedure.
4. Recycling-the use of waste materials either back into the same process or into a different process.
5. Reclamation-any process that allows materials to be used again after some sort of purification, such as solvent distillation.
6. Treatment-an additional step added to an experimental or analytical procedure to reduce or eliminate the toxicity of the waste.

An excellent on-line reference for waste minimization is the American Chemical Society publication Less is Better. Another good reference, written for educational institutions, is the Laboratory Waste Minimization and Pollution Prevention Guide, produced by the Batelle Seattle Research Center.

List of Hazardous Wastes

A complete list of hazardous waste can be found in 40 CFR Subchapter I – Solid Waste Part 260 – Hazardous Waste Management System: General Subpart D- List of Hazardous Wastes.

This information can be accessed on-line at:

www.epa.gov/docs/epacfr40/chapt-I.info/subch-I/   (click on Part 261)

Also these lists are available in the Office of Affirmative Action, Human Relations and Compliance.

For problems or questions regarding this web contact [dmunson@monmouth.edu]