by: Tommi Smith, Department of Facilities Management Office: 963-5683, Email: tsmith@tnstate

1. Handling, Storage and Disposal of “Hazardous Waste”in Accordance withEnvironmental Regulations (RCRA) by: Tommi Smith, Department of Facilities Management Office: 963-5683, Email: tsmith@tnstate.edu http://www.tnstate.edu/VPBF/fmo/Safety/safety.asp

2. Welcome to the World of RCRA • RCRA is an acronym for the Resource Conservation Recovery Act • Enacted in 1976 • Found in Title 40 of the Code of Federal Regulations (CFR), Parts 260-299 • It is a system to govern hazardous waste from “cradle-to-grave.” i.e. from point of generation to ultimate disposal, and beyond

3. “Cradle-to-grave” • The grave is forever • If there is EVER a problem at a hazardous waste disposal facility or site in the future and there exists any shred of evidence that TSU sent waste to that facility, the regulators will come knocking on the door asking for money to help clean the mess up.

4. Why is This Important to Youas a Student? • You will face these regulations in the “Real World” • The university will be subject to “enforcement action” by regulators: • the university can fined a substantial amount of money • the regulators can order your labs/research to be shut down for a period of time • the university can be fined substantial amounts of money • There is substantial amount of overlap between environmental regulations and safety regulations • We want you to be safe and you ought to want to be safe

8. What is a Waste? The regulations that define the term “waste” are very detailed and quite difficult to understand. Here’s a quick summary • Anything that has been discarded or is destined to be discarded/disposed of. • Anything being held on to but not being treating as a valuable commodity, e.g. neglected or abandoned. • Anything being held on to for which there is no intended specific use. e.g. “we might use it some day”

9. What is a Waste?, cont. • An inspector may pick up or point to a container of something and ask “what are you using this for?” If your answer is, “I don’t know, we might use it some day,” the inspector could declare the material a “hazardous waste” under the “speculative accumulation” provision of the RCRA regulations. • You MAY keep a chemical after its expiration date if it is still useful AND you are using it, not just holding on to it. Keep in mind the inspectors have some pretty broad powers to pronounce something a “hazardous waste” They can say something is a “hazardous waste” and you have to prove it is not.

10. Waste?

11. Waste!!!and a waste of money 20 plus year old ethyl ether. Ethyl ether tends to form peroxides over time which can cause a deflagration upon opening the container. Cost of disposal, roughly $3600.00

12. Waste or Speculative Accumulation?

13. What is “Hazardous Waste” • “Hazardous Waste” is a term that is specific to RCRA regulations and has very detailed descriptions. • There are a lot of waste materials that are dangerous or “hazardous” but they are not a “Hazardous Waste” under RCRA regulations. • Infectious or Biohazardous Wastes are NOT “Hazardous Wastes” • Radioactive Wastes are NOT “Hazardous Wastes”

14. Other Dangerous Wastes • Radioactive Wastes are regulated by the Nuclear Regulatory Commission (NRC) • regulations found in 10 CFR parts 30, 40, 50, etc. • Infectious/Biohazardous Wastes are regulated by the EPA • regulations found in 29 CFR 1910.1030 • regulations found in 40 CFR part 60, 62, 63, etc. • “Universal Wastes” – actually are “hazardous wastes” per RCRA definitions but are regulated less stringently. • “Dangerous Goods” regulated by Department of Transportation (DOT) • regulations found in 49 CFR parts 100-185 • “Special Wastes” and other waste classifications • regulations typically enacted by individual states

15. Categories of “Hazardous Wastes” • “Characteristic” Waste • A waste that exhibits any one or any combination of 4 characteristics • “Listed” Waste • The EPA, and some states, have developed lists of chemicals that are deemed “hazardous wastes”

16. Characteristic Wastes • Ignitability - burns readily • Reactivity – explosive, reacts violently with water, etc. • Corrosivity – within certain ranges on pH scale • Toxicity – toxic to environment (on a list and present at a minimum level)

17. Listed Wastes “P” list – these chemicals have been determined to acutely toxic and have much more stringent regulations applied to them. “U” list – chemicals that may not have any hazardous characteristics but are deemed hazardous “F” – a very confusing list that applies to solvents used for degreasing and cleaning – would not necessarily apply to labs “K” – wastes are specific to certain industrial processes – none apply to TSU The lists can be found on the EPA website at the web address below: http://www.epa.gov/epawaste/hazard/wastetypes/listed.htm

18. Regulators • The Principle regulators for the state of Tennessee are TDEC (Tennessee Department of Environment and Conservation). • The EPA has been coming up from Atlanta lately and going around with the TDEC personnel inspecting colleges/universities and other facilities. • They are checking to see if hazardous wastes are handled, stored and disposed in accordance with the regulations.

19. Various Responsibilities of TSU Personnel • Environmental Health and Safety (EH&S) personnel in the Department of Facilities Management ensure that hazardous wastes make it off campus and are disposed of in accordance with regulations. Also recording keeping and reporting. • Your PI/Faculty/Staff have the responsibility to ensure that the chemicals and hazardous wastes are handled and stored properly on-site. • Your responsibility is to keep and eye out for violations and do what you can to correct them. • If you cannot correct a violation, then gently encourage compliance. And, if that doesn’t work, report the violation(s).

20. Satellite Accumulation Area • Your laboratory or other areas where chemicals are used is considered a “satellite accumulation area.” • A satellite accumulation area is: • at or near the point of generation • under the control of the operator

21. Basic Rules for SatelliteAccumulation Areas • No more than 55 gallons of waste can be stored. • No more than 1 quart of an acute (“P” listed waste) can be stored. • Containers must be kept closed except when adding or removing waste. • “Closed” means the container must pass the “tip” test

23. Basic Rules for SatelliteAccumulation Areas cont. • Containers must be properly labeled • Use the words “Hazardous Waste,” no abbreviations • Label must identify the contents of the container • “Unknown” is not an acceptable label • Incompatible wastes must be kept separate • Container must be compatible with the waste and in good shape

24. Unacceptable Labels

25. Tools available from the EH&S office in the Department of Facilities Management to help with properly labeling waste and keeping the satellite accumulation area in order

26. Incompatibility Do Not Store Alphabetically http://www.biosci.ohio-state.edu/safety/safety/IncompatibleChemicals.htm

27. Incompatibility • The MSDS (Material Data Sheet) can provide some information about incompatibility • MSDSs must contain a section that contains “Reactivity Data” which will provide some useful information • It will not always be in the same place from one MSDS to another, but it will be there, somewhere. • Other helpful information an MSDS must contain • some information abut the ingredients of the product • some information about the physical characteristics of the product • Some MSDSs are better than others, so do not rely on them 100%

28. Material Safety Data Sheet (MSDS)

30. TSU Procedures for Satellite Inspection Areas • An inspection checklist has been developed that is similar to that used at other universities and colleges. • This goes a little above and beyond the minimum requirements of the regulations but following it will pretty much ensure that no violations will be found • Because these are procedures are in writing, the regulators will hold us to them.

32. TSU RCRA Inspection Record • Date, Department, Inspector(s) – accurate and complete records are vital for satisfying inspectors. • Containers Closed – already discussed • Marked “Hazardous Waste” – already discussed • Secondary Containment – in case a container leaks, this will catch the it. It can be simple, but must be compatible with the waste being stored.

33. TSU RCRA Inspection Record • Containers not more than 2 high – looks bad and you are asking for leaks • Near Point of Generation – already discussed • No more than 55 gal. regular waste or 1 quart “P” listed waste – already discussed • Fire Extinguisher – Keep an eye on the fire extinguishers in and around your labs. If you see a problem, submit a Work Order to Work Control in Facilities Management via the web at http://scorpius.tnstate.edu/home.html or call x5668

34. TSU RCRA Inspection Record • Spill Containment/Clean up Equipment – containment and clean up materials must be compatible with the chemicals you are cleaning up. • If spill exceeds your resources or ability to clean it up, call Facilities Management during normal business hours or Campus Police outside of normal business hours. • If you are able to clean up a spill, treat the clean up materials along with the chemical as a hazardous waste. Put everything in a container that is compatible with the waste and label the container appropriately.

35. TSU RCRA Inspection Record • Empty Containers Managed – with the exception of “P listed” wastes, “empty” containers should be thrown away with out rinsing them out first. • “Empty” by RCRA definition means that the container contains “no more than 3 percent by weight of the total capacity of the container. • If you choose to rinse the containers before disposing of them, the rinse water/agent becomes a hazardous waste and would have to be collected, handled, stored and disposed in accordance with RCRA regulations. • Empty containers for “P listed” chemicals must be handled, stored and disposed of as a hazardous waste . Do not rinse these containers out. The rinse water/agent will be a “P listed” waste.

36. TSU RCRA Inspection Record • Containers in Good Condition – already discussed • Plan for Managing Poor Containers – If there are any containers that are in poor condition, make a note of what you are going to do about it. Or, what you did do about it. Use the “Notes” section at the bottom of the form if you need more space to write. • Containers Compatible for Waste – already discussed • Notes Section – make note of discrepancies, plans for correction, to whom reported, etc.

37. Find the Violations

38. My Absolute Worst Case Scenario

39. Annual Training Required • Training on this subject is required annually. • This can be done within your department. • Facilities Management can provide training • On-line training modules are being developed

40. Questions? Thank You!