Introduction to Hazardous Waste Management

Report
INTRODUCTION TO
HAZARDOUS WASTE
MANAGEMENT
University of Alaska Fairbanks
Environmental, Health, Safety, and Risk Management
May 2013
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
2
OVERVIEW OF
HAZARDOUS
MATERIALS
REGULATIONS
3
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
4
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
5
DOT REGULATIONS
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:
Class 2:
Class 3:
Class 4:
Class 5:
Class 6:
Class 7:
Class 8:
Class 9:
Explosives
Compressed Gases
Flammable Liquids
Flammable Solids
Oxidizers
Poisons and Toxics
Radioactive materials
Corrosives
Miscellaneous hazardous materials
that don’t fit any other hazard
class… (i.e. dry ice)
6
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
7
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)
8
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
9
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
10
RCRA REQUIREMENT FOR TRAINING
The purpose of this training is to comply with
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.
2.
3.
4.
Understand how to identify hazardous wastes
Understand how to package and label hazardous wastes
Understand how to have their hazardous materials disposed
Know how to respond effectively to emergencies
11
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
12
HAZARDOUS
WASTE AT UAF
An overview of sources of hazardous
waste at UAF, and its ultimate fate…
13
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
14
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
15
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,
Kodiak Seafood & Marine Science Center, Seward Marine
Center, Lena Point Fisheries Facility (Juneau)
16
HAZARDOUS WASTE MANAGEMENT
AT UAF
 EHSRM 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
17
WHAT IS
HAZARDOUS
WASTE?
18
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.
No need to memorize that!
19
EPA DEFINITION OF A HAZARDOUS
WASTE (CONT.)
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: (continue to next slide)
20
EPA DEFINITION OF A HAZARDOUS
WASTE (CONT.)
 (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,
 (Continue to next slide)
21
EPA DEFINITION OF A HAZARDOUS
WASTE (CONT.)
 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.
 (Continue to next slide)
22
EPA DEFINITION OF A HAZARDOUS
WASTE (CONT.)
 (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 the definition of
a hazardous waste 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 EHSRM 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 (Toxicity Characteristic Leaching Procedure)
 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 –
 D002 –
 D003 –
 D004 –
Ignitable Wastes (flashpoint is less than
140º F) includes oxidizers
Corrosive Wastes (pH less than or equal to
2 or greater than or equal to 12.5)
Reactive Wastes (water reactive,
normally unstable materials, cyanides &
sulfides, etc)
TCLP Wastes
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: petroleum refining or pesticide manufacturing
U-listed wastes are toxic wastes
P-listed wastes are acutely hazardous wastes
27
EXAMPLES OF U-LISTED WASTES
Acetaldehyde
1,4-Dioxane
Acetone
Ethyl acetate
Acetonitrile
Ethyl ether
Aniline
Formaldehyde
Benzene
Methyl alcohol
Bromoform
Methylene chloride
1-Butanol
Phenol
Chloroform
Toluene
U-listed chemicals are commonly found in UAF labs
28
EXAMPLES OF P-LISTED WASTES
Allyl alcohol
Osmium tetroxide
Ammonium vanadate
Phenylthiourea
Arsenic acid
Potassium cyanide
Arsenic trioxide
Sodium azide
Carbon disulfide
Sodium cyanide
2,4-Dinitrophenol
Thiosemicarbazide
Fluorine
Vanadium oxide
Nitric oxide
Vanadium pentoxide
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 (white 5-gallon
buckets) are available at many locations on campus
Contact your Lab Manager, CHO, Shop Supervisor
or EHSRM 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
EHSRM 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
If you have waste pesticides:
Fill out an online UAF Non-radioactive Hazardous
Materials Transfer Request. Don’t know how? Go
to slide #41.
33
UNIVERSAL WASTES:
MERCURY THERMOMETERS
If you break a mercury thermometer:
 DO NOT try to clean it up yourself ---- Call UAF Hazmat at 474-
5617 immediately for assistance
 Evacuate the area and keep traffic from walking through the spill site
 NEVER throw the material in the trash or dump it down the drain
 Don’t need your mercury thermometers or wish to
exchange unbroken thermometers for similar, non-mercury
thermometers, free of charge? Call EHSRM at 474-5197 to
get more information.
34
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
 Aerosol cans become a waste when…
 their contents are used up,
 malfunction (i.e. fail to spray), or
 when the contents are no longer needed
35
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
36
OTHER WASTES: USED OIL (CONT.)
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
removed when not in use and the container capped
See slide #41 to make on online request to have
your used oil removed
37
WASTE IN YOUR
LAB
What do I do with my wastes and
unwanted chemicals?
38
SATELLITE ACCUMULATION AREAS
Each lab that generates waste is referred to as a
“Satellite Accumulation Area” (SAA)
When EHSRM removes the waste from a SAA, it is
transferred to the UAF Hazmat Facility or “Central
Accumulation Area”
39
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!
40
TO MAKE A WASTE REMOVAL
REQUEST
 As of April 2012, the Division of Hazardous Waste at EHSRM is
using an online hazardous waste pick up request. Please
discontinue using the old triplicate paper hazardous waste
transfer request forms.
 If you have not been trained in the use of the online request, call
474-5197 to schedule a training session. Or go to the EHSRM
website for more information:
http://www.uaf.edu/safety/laboratory-safety/chemical-inventory/
Remember: There is no charge to your lab for chemical waste disposal
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
43
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, log onto your EHS Assistant online
inventory and click on the “Surplus Chemicals” button at the
top of the main page. Contact EHSRM at 474-5617 to request
transfer 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 EHSRM
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)
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 EHSRM 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 EHSRM)
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
 Call 911 in the event of an emergency or if anyone is in
danger
 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

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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
51
FOR MORE INFORMATION…
Environmental, Health, Safety, and Risk Management
Visit our website at: www.uaf.edu/safety
Or call us at 474-5413
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