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1. Introduction to Hazardous Waste Management University of Alaska Fairbanks Environmental Health, Safety, and Risk Management September 2009 (updated June 2011)

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 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) The International Fire and Building Codes also regulate hazardous materials

5. 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

6. DOT Regulations Class 1: Explosives Class 2: Compressed Gases Class 3: Flammable Liquids Class 4: Flammable Solids Class 5: Oxidizers Class 6: Poisons and Toxics Class 7: Radioactive materials Class 8: Corrosives 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 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 (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 OSHA also establishes permissible exposure levels (PELs) for hazardous chemicals

8. EPA Regulations Congress placed into law several acts that the EPA uses to establish regulation to protect our environment: • Resource Conservation Recovery Act (RCRA) • Clean Air Act • Clean Water Act • Toxic Substances Control Act (TSCA) • Emergency Planning & Community Right-to-Know Act (EPCRA) • Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)

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 for generators of wastes, transporters of wastes, and Treatment, Storage & Disposal Facilities

10. Primary RCRA Requirements RCRA 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

11. RCRA Requirement for Training The purpose of this training is to comply w/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. 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

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

14. 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

15. 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 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 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, FITC in Kodiak, Seward Marine Center, Lena Point Fisheries Facility

17. Hazardous Waste Management at UAF • EHS&RM 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.

18. What is hazardous waste?

19. 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. 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 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: • (i) It exhibits any of the characteristics of hazardous waste identified in subpart C of this part. However, any mixture of a Cont’d

21. EPA Definition of a Hazardous Waste • 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. Cont’d

22. EPA Definition of a Hazardous Waste • (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. You don’t need to memorize that either

23. 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 EHS&RM Hazmat team will make final hazardous waste determinations as outlined in 40 CFR 262.11 Let’s look at the different categories as defined by the EPA

24. Categories of Hazardous Waste 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

25. Characteristic Wastes • D001 – Ignitable Wastes (flashpoint is less than 1400F) 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 (Toxicity Characteristic Leaching Procedure)

26. 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

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

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

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

30. 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

31. 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 • 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

32. Universal Wastes: Pesticides and Waste from Mercury Thermometers • If you have waste pesticides or mercury from broken thermometers • Please fill out a UAF Non-radioactive Hazardous Materials Transfer Request Form • The transfer forms will be explained later in the training • If you break a mercury thermometer • DO NOT try to clean it up yourself ---- Call UAF Hazmat at 474-5617 immediately for assistance • NEVER throw the material in the trash or dump it down the drain

33. 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 • Become a waste when • their contents are used up, • malfunction (i.e. fail to spray), or • when the contents are no longer needed

34. 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

35. Other Wastes: Used Oil (cont’d) • 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 closed when not in use • Call EHS&RM Hazmat (474-5617) to have your used oil removed

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

37. 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”

38. 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! Space is a very valuable asset. Give us a call anytime to remove your waste (474-5617).

39. 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.

40. 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

41. Haz Mat Transfer Request Form

42. 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

43. 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

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

45. 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

46. 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, check with EHS&RM or your department Chemical Hygiene Officer for the availability of surplus chemicals

47. 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)

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

49. 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 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 EHS&RM)

50. 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.