8 - WASTE DISPOSAL

 

Section Contents

8.1	CHEMICAL WASTE - HAZARDOUS WASTE MANAGEMENT PLAN
8.2	RADIOACTIVE MATERIALS
8.3	BIOLOGICAL WASTES
8.4	UNIVERSAL WASTE
8.5	ELECTRONIC WASTE
8.6	REFERENCES

Disposal of chemical waste (hazardous waste), radioactive materials, biological agents, universal and electronic wastes must be in accordance with procedures established by Environmental Health & Safety (EHS).

 

8.1

CHEMICAL WASTE - HAZARDOUS WASTE MANAGEMENT PLAN

8.1.1	INTRODUCTION
8.1.2	SCOPE
8.1.3	THE CHEMICAL HYGIENE OFFICER
8.1.4	RESPONSIBILITIES
8.1.5	GENERATOR STATUS
8.1.6	HAZARDOUS WASTE DETERMINATION
8.1.6a	Characteristics
8.1.6b	Liquid Waste
8.1.6c	Examples of Hazardous Waste
8.1.6d	Examples of Waste That Do Not Fall Under HWMP
8.1.7	HAZARDOUS WASTE HANDLING
8.1.7a	Labeling Containers
8.1.7b	Waste Storage Areas
8.1.7c	Container Management
8.1.7d	Weekly Inspections
8.1.8	CONTINGENCY PLAN
8.1.9	PICK-UP SCHEDULE
8.1.10	TRAINING
8.1.11	RECORDKEEPING
8.1.12	WASTE MINIMIZATION

 

8.1.1 Introduction

The Resource Conservation and Recovery Act (RCRA) is the federal law that governs the handling of hazardous wastes. The Environmental Protection Agency (EPA) and the District of Columbia have developed regulations for compliance with RCRA. The District's regulations are in some instances more stringent or broader in scope than the EPA regulations.

This Hazardous Waste Management Plan (HWMP) serves as a guide for handling hazardous wastes generated at The Catholic University of America (CUA). The goal of the HWMP is to handle hazardous waste in a safe, efficient, and environmentally sound manner and to comply with local and federal regulations.

 

8.1.2 Scope

This plan applies to each department at CUA that generates hazardous wastes. It covers labeling, storage, transportation, inspections, and record keeping.

 

8.1.3 Chemical Hygiene Officer

Each department that generates hazardous waste must designate an individual or individuals to be its Chemical Hygiene Officer (CHO). CHOs will be responsible for ensuring that their departments comply with hazardous waste regulations. They will be trained to do so by EHS.

There are two groups of CHOs at CUA: (1) CHOs who manage Hazardous Waste Accumulation Areas and (2) CHOs that do not manage Hazardous Waste Accumulation Areas.

1. CHOs who manage Hazardous Waste Accumulation Areas:
   • Work in departments that generate hazardous waste on a regular basis, or
   • Work in departments that generate hazardous waste in quantities greater than 5 gallons every 90 days, or
   • Work in departments that generate highly hazardous waste.

   These departments include: Chemistry, Biology and Vitreous State Laboratory (VSL).

2. CHOs that do not manage Hazardous Waste Accumulation Areas:
   • Work in departments that infrequently generate hazardous waste
   • Work in departments that generate hazardous waste in quantities less than 5 gallons every 90 days.
   • The CHOs in these departments must contact EHS at x2698 anytime hazardous waste is generated or if there is concern regarding hazardous waste generation. EHS will pick up material in question within seven calendar days following contact.

   These departments include, but are not limited to: Architecture, Athletics, Art, Drama, Engineering, Facilities Maintenance, Law, Library, Music, Nursing, Campus Programs, Psychology.

 

8.1.4 Responsibilities

EHS:

• Maintain the HWMP, based on regulatory changes and the needs of the CUA community.
• Assist in implementing the HWMP on campus.
• Train generators and CHOs in the proper handling of hazardous waste.
• Remove hazardous wastes from their storage areas upon notification by the CHO.
• Arrange for the transportation and disposal of hazardous waste from campus within 180 days after a waste is deemed hazardous.
• Be the central repository for record keeping of all documents related to the accumulation, transportation, storage, treatment, and disposal of hazardous wastes.

Head of Hazardous Waste Generating Departments:

• Designate an individual or individuals to be Chemical Hygiene Officers.
• Ensure CHOs receive training.
• Implement this plan in the department.

Generators:

• Be familiar with the HWMP.
• Attend training provided by EHS.
• Identify or deem waste as hazardous waste.
• Work with their CHO to properly label, segregate and store hazardous wastes.

Chemical Hygiene Officers (Appointed by the Department Head):

• Attend initial and annual training in Hazardous Waste Management.
• Assist EH&S to implement the HWMP.
• Establish waste storage areas in the department with the assistance of EH&S.
• Assist generators to properly label, store, and segregate hazardous waste.
• Inspect waste storage areas weekly to ensure hazardous waste is properly labeled, stored, and segregated.
• Contact EH&S to collect and remove hazardous waste from the Hazardous Waste Accumulation Areas in a timely manner.
• Assist EH&S to identify hazardous waste to be removed from campus within 90 days.
• Maintain accurate files of inspection logs, and training documentation.

 

8.1.5 Generator Status

The University is regulated on the quantity of hazardous waste produced monthly. According to D.C. regulations, because the University generates more than 100 kilograms but less than 1,000 kilograms of hazardous waste per a calendar month, we are classified as a Small Quantity Generator. As such, we are permitted to accumulate hazardous waste on campus for no more than 180 days. The hazardous waste must be properly shipped from campus for disposal or treatment within that 180 days.

 

8.1.6 Hazardous Waste Determination

Solid Wastes:

Solid wastes are materials that are no longer used and are set aside for disposal. Solid wastes include abandoned items, those that are ready to be disposed, or those that are ready to be recycled. They do not include nuclear sources or domestic sewage, among other exceptions. Solid wastes may be solid, liquid, or gas.

Chemicals no longer suitable for use are subject to hazardous waste regulations. Some examples include:

• Chemicals that are no longer used, e.g., past the expiration date
• Chemicals with obliterated labels, e.g., corroded, faded, or smeared
• Chemicals with no labels, e.g., sample vials, jars, or beakers
• Samples that cannot be identified

Hazardous Waste:

RCRA defines a hazardous waste as a solid waste that because of its quantity; concentration; or physical, chemical, or infectious characteristics may cause or significantly contribute to an increase in serious; irreversible; or incapacitating, reversible illnesses or pose a substantial present or potential hazard to human health, safety, or welfare or to the environment when improperly treated, stored, transported, used, or disposed of or otherwise managed.

A solid waste is a hazardous waste if it is not excluded from regulations and it meets any of the following descriptions:

• Solid waste that exhibits one or more of the hazardous waste characteristics (termed a characteristic waste): ignitability, corrosivity, reactivity, or toxicity. (See Section 6.1)
• Solid waste that is identified on any of the hazardous waste lists (termed a listed waste): non-specific source wastes (F list), specific source wastes (K list), commercial chemical products (P and U lists). (See Section 6.2)
• Solid waste that is a mixture of a solid waste and one or more listed hazardous wastes.
• A mixture of solid waste and one or more characteristic hazardous wastes.
• Residues derived from the treatment of listed hazardous waste.

If there is uncertainty as to whether or not a solid waste is hazardous, deem the waste hazardous and apply the HWMP or contact EHS for assistance. 

Maximum Concentration of Contaminants for the Toxicity Characteristics

Contaminant	Chemical Abstracts Service (CAS) Number	Regulatory Level (mg/L)
Arsenic	7440-38-2	5.0
Barium	7440-39-3	100.0
Benzene	71-43-2	0.5
Cadmium	7440-43-9	1.0
Carbon Tetrachloride	56-23-5	0.5
Chlordane	57-74-9	0.03
Chlorobenzene	108-90-7	100.0
Chloroform	67-66-3	6.0
Chromium	7440-47-3	5.0
o-Cresol	95-48-7	200.0 a
m-Cresol	108-39-4	200.0 a
p-Cresol	106-44-5	200.0 a
Cresol	---	200.0 a
2,4-D	94-75-7	10.0
1,4-Dichlorobenzene	106-46-7	7.5
1,2-Dichloroethane	107-06-2	0.5
1,1-Dichloroethylene	75-35-4	0.7
2,4-Dinitrotoluene	121-14-2	0.13 b
Endrin	72-20-8	0.02
Heptachlor (and its epoxide)	76-44-8	0.008
Hexachlorobenzene	118-74-1	0.13 b
Hexachlorobutadiene	87-68-3	0.5
Hexachloroethane	67-72-1	3.0
Lead	7439-92-1	5.0
Lindane	58-89-9	0.4
Mercury	7439-97-6	0.2
Methoxychlor	72-43-5	10.0
Methyl ethyl ketone	78-93-3	200.0
Nitrobenzene	98-95-3	2.0
Pentachlorophenol	87-86-5	100.0
Pyridine	110-86-1	5.0 b
Selenium	7782-49-2	1.0
Silver	7440-22-4	5.0
Tetrachloroethylene	127-18-4	0.7
Toxaphene	8001-35-2	0.5
Trichloroethylene	79-01-6	0.5
2,4,5-Trichlorophenol	95-95-4	400.0
2,4,6-Trichlorophenol	88-06-2	2.0
2,4,5-TP (Silvex)	93-72-1	1.0
Vinyl chloride	75-01-4	0.2
a If o-, m-, p-Cresol concentrations cannot be differentiated, the total cresol concentration is used. The regulatory level of total cresol is 200 mg/L. b Quantitation limit is greater than the calculated regulatory level. The quantitation limit therefore becomes the regulatory level.

 

8.1.7 Hazardous Waste Handling

Once solid waste is identified as hazardous waste by the generator, the CHO, or EHS, it must be handled in accordance with the HWMP. Hazardous waste must not be: disposed or recycled with other forms of trash or waste, burned or allowed to evaporate into the air, disposed or diluted in water, disposed on or buried in the land.

An appropriate container (bottle, jar, etc.) must be used to accumulate waste. It must be labeled as discussed in Section 7.1 at the time the first drop is added to the container.

Hazardous waste containers must be kept closed except when adding or transferring waste and the contents of the containers must be compatible with the container. Hazardous waste containers must be segregated based on the hazards of the waste.

Hazardous wastes must be stored in designated Hazardous Waste Accumulation Areas; these areas must be equipped with secondary containment in the form of bins or a berm that would contain the waste in the event of a spill. A "Hazardous Waste Accumulation Area" sign must be posted at waste storage areas to indicate the presence of hazardous waste. The room that has a waste storage area will have access to a phone, access to an emergency eyewash and/or shower, basic spill cleanup equipment, a fire extinguisher, adequate aisle space, and a spill contingency plan. Weekly inspections of the waste storage area are required and the inspection must be documented in the logbook.

 

FRONT:

BACK:

 

Compatibility Table

Keep hazardous waste containers closed unless adding or removing waste.  If you use a funnel to transfer waste, remove the funnel after the transfer and close the container. A closed container is one whose contents would not spill if the container were knocked over. Depending on the design of the container, it may be properly closed by firmly applying a screw-on cap, bung, drum ring, etc.  Using tin foil, cork, paper towels, etc. are not considered ways of properly closing a container.

Use an overpack drum or container for containers that may leak or cannot be closed.  Overpack containers must also be compatible with the waste, be sealable, and may be filled with vermiculite to occupy extra space. Overpack containers for hazardous waste are available from several manufacturers, including Grainger.

When adding waste to a container, do not completely fill the container.  Leave space for the contents to expand. Containers and chemicals may expand or contract based on temperature. Transfer of hazardous waste is not recommended. If a transfer is necessary, ensure adequate spill response equipment is available, wear personal protective equipment (PPE), and use adequate transferring mechanisms, e.g., a funnel.

Ground ignitable hazardous waste to prevent sparks from igniting flammable vapors. Use a bonding wire and a ground wire when transferring flammable liquids into containers to prevent sparks caused by the buildup of static electricity during pouring operations.

Empty Containers                                                                                                                                      A container that held a P-listed waste is empty if it has been triple-rinsed using a solvent capable of removing the waste. Any rinsate must be collected as hazardous waste, but the container can be disposed of as regular trash. The alternative is to place the entire container in the Hazardous Waste Storage Area and label it as "container with residual from (insert the P-listed waste here)," as well as all other necessary information on the hazardous waste labels.

If the container did not hold a P-listed waste, the container is empty when all contents have been removed that can be removed by using common practices such as pouring, pumping, and aspirating. The container can be disposed of as regular trash if:

• No more than one inch of residue remains on the bottom of the container or inner liner
• For a 110 gallon container or less, no more than 3% of the total capacity of the container remains
• For a container larger than 110 gallons, no more than 0.3% of the total capacity of the container remains

A compressed gas cylinder is empty when the pressure in the container approaches atmospheric pressure. Many compressed gas cylinder suppliers recycle compressed gas cylinders as part of their contract.  Check with your supplier. 

 

8.1.7d   Weekly Inspections

CHOs are required to perform weekly inspections of Hazardous Waste Accumulation Areas, using a multi-week inspection form developed by EHS. EHS recommends that each CHO establish a schedule for inspections to ensure they become routine. For example, establish Wednesday mornings as the designated inspection time, and every week perform the inspection at that time.

Keep the inspection form adjacent to the Hazardous Waste Accumulation Area, either in a binder or in a covered, protective folder.

Use the form for a maximum of eight weeks. Use one form per Hazardous Waste Accumulation Area. The form consists of nine questions to guide you through the inspection. For any question that is answered with a "no", corrective actions must be noted at the bottom or on the back of the form.

When a form is complete, start a new inspection form. At that time, photocopy the completed form (both sides as necessary), mail the copy to EHS, and file the original.

Once a Hazardous Waste Accumulation Area has been established, a weekly inspection of that area is required, regardless of the quantity of waste in the storage area. Even if no waste has been added to a storage area, an inspection is still required.

The exception to this rule will be the December holiday break when the University is officially closed. CHOs will not have to perform the weekly inspection during that holiday break. EHS will complete a waste pickup prior to the closure to ensure the majority of all waste is removed from the Hazardous Waste Accumulation Areas. EHS will document this via a memorandum at that time. It is the CHOs responsibility to resume inspections the week following the holiday break when the University reopens.

If the CHO for a designated Hazardous Waste Accumulation Area is not able to complete the weekly inspection due to absence, it is his/her responsibility to ensure the inspection is completed. A database of CHOs, established by EHS, will be available.

 

8.1.8       Contingency Plan

The HWMP documents the University's commitment to manage hazardous waste to minimize the possibility of a release of hazardous waste into the environment. As part of this commitment, we maintain equipment on-site to facilitate spill cleanup and protect human health and the environment. In addition, to address emergency issues and large releases, we have made arrangements with the CUA Department of Public Safety, the local fire department, and an emergency spill response company.

The University has a Spill Prevention, Control, and Countermeasure (SPCC) Plan per EPA regulations. Each Hazardous Waste Storage Area is required by law to have in place a Contingency Plan designed to help manage spill response and emergency situations related to hazardous waste management.

The Contingency Plan for each Hazardous Waste Accumulation Area will be designed by EHS in consultation with the CHO for that area.

The Plan will include:

• A list of names, addresses, and phone numbers (office and home) of all persons qualified to act as emergency coordinator
• A list of all emergency equipment at the Hazardous Waste Accumulation Area such as fire extinguishing sytems, spill control equipment, communications systems, decontamination equipment, and emergency eye wash and showers
• The location and a physical description (schematic drawing) of each item, including the Hazardous Waste Accumulation Area
• An evacuation plan for facility personnel where there is a possibility that evacuation could be necessary

The Contingency Plan will be specific to a Hazardous Waste Accumulation Area and must be maintained at that Hazardous Waste Accumulation Area. The diagram will be posted at the door(s) to the room where the Hazardous Waste Accumulation Area is located. Revisions or amendments, when necessary, must be made in conjunction with EHS.

 

8.1.9       Pick-up Schedule

As a large quantity generator, the University must not accumulate a hazardous waste for more than 180 days. Therefore, it is imperative that hazardous waste that is stored in Hazardous Waste Accumulation Areas are managed in an organized and systematic manner to ensure compliance with the 180-day regulation.

It is the responsibility of the CHO to contact EHS to arrange a hazardous waste pick-up from the Hazardous Waste Storage Area. EHS will remove the waste from the storage area and transport the waste to the central hazardous waste accumulation point located in the campus Grounds Maintenance Complex. If EHS cannot transport the waste to the central accumulation point, we will arrange to have it removed from the Hazardous Waste Accumulation Areas using a qualified vendor. Keeping within the 180-dayclock, EHS will arrange for hazardous waste removal from campus using a qualified waste transportation and disposal company.

To guarantee 100 percent compliance with the 180-day regulation, EHS recommends using the weekly inspection form as a tracking calendar. The form is designed for sixteen consecutive weeks or 112 days of Hazardous Waste Accumulation Area inspections. When the form is completed, contact EHS to pick-up any hazardous waste from the Hazardous Waste Accumulation Area.

Even if a container was recently classified as hazardous waste and the 180-day clock just began, if it is at the end of the sixteen-week schedule, contact EHS.

If there is no waste in the Hazardous Waste Accumulation Area, there is no need to contact EHS.

No matter the quantity of hazardous waste in the Hazardous Waste Accumulation Area, send a copy of the completed inspection form to EHS for recordkeeping purposes.

To arrange for pick-up from the Hazardous Waste Accumulation Area, contact EHS via phone or email (CUA-EHS@cua.edu).

Prior to pick-up, ensure in-house recordkeeping is compete. Ensure inventories and inventory numbers used to track chemicals are updated. Each department is responsible for its own recordkeeping.

 

8.1.10      Training

Every Chemical Hygiene Officer (CHO) will receive annual training, or when new hazards are added to the CHO's responsibilities, in the hazardous waste management practices applicable to our University. EHS will provide the training for CHOs. EHS trainers will receive annual hazardous waste training from an independent firm. Generators of hazardous waste will receive Laboratory Safety Training or Hazard Communication Training based on either 29 CFR 1910.1200 or 29 CFR 1910.1450 depending on their work practices. Both Laboratory Safety Training and Hazard Communication Training will include a segment on the Hazardous Waste Management Plan (HWMP).

Newly hired employees will receive training on Hazardous Waste Management within 6 months of hire.  New employees are tracked with the assistance of applicable laboratory managers and Human Resources and contacted by EHS staff to ensure that all necessary training requirements are met within a timely manner.

Hazardous waste management training will include a review of the regulatory requirements set forth by the EPA, DOT, and OSHA. The training will focus on the details of the HWMP as described in this document, including proper hazardous waste handling and recordkeeping, and emergency procedures and equipment.

 

8.1.11      Recordkeeping

Document all waste management activities.

Documentation requirements:

• Proof of annual training in hazardous waste management will be documented on sign-in sheets and will be filed by EHS and maintained per regulatory requirements
• Weekly inspection forms must be managed by the CHO, filed, and saved for three years
• Photocopies of the weekly inspection forms will be managed by EHS, filed. and saved for three years
• All other hazardous waste documentation relating to shipment, regulatory reports, and land disposal records will be maintained by EHS for at least three years

 

8.1.12      Waste Minimization

Wherever feasible, the generation of waste is to be reduced or eliminated as expeditiously as possible. Implementing a comprehensive waste minimization program may reduce the generator status of the University and therefore reduce the compliance requirements.  It can reduce potential environmental liabilities and help protect the environment through more efficient resource utilization. It also reduces expenses by reducing waste treatment and disposal costs, raw material purchases, and other operating costs.

Benefits of waste minimization include economic savings, increased environmental integrity, decreased exposure to toxic materials, and an improved image for the University.

There are many ways to prevent or minimize hazardous waste generation. This list provides some ideas for waste minimization techniques.

• Develop a running inventory of chemicals on hand
• Use the inventory to track unused chemicals for possible use by other departments
• Maintain a limited inventory of chemicals on hand so those chemicals do not expire or deteriorate and necessitate disposal
• Purchase only the quantity of chemicals and materials needed. Find the minimum unit required for the work planned and order accordingly. Due to the high cost of chemical disposal, any savings realized by purchasing chemicals in bulk quantities are quickly erased when even a portion of the chemicals cannot be used and must be discarded.
• Reduce or eliminate the use of highly toxic chemicals in lab experiments
• Establish reasonable waste minimization goals within your department
• Perform laboratory experiments on a microscale whenever feasible
• Unopened and uncontaminated, unused portions of chemicals that you no longer need may find use elsewhere on campus
• Reuse or recycle spent solvents
• Recover metal from catalyst
• Initiate procedures to reduce mercury use; e.g., replace mercury-bearing instruments with alternatives
• Polymerize epoxy waste to a safe solid
• Replace chromic acid cleaning solutions with Alconox or a similar detergent
• Recycle office equipment such as computer monitors
• Clean with detergents and enzymatic cleaners rather than sulfuric acid/potassium dichromate cleaning solutions or ethanol/potassium hydroxide cleaning solutions
• Use citrus-based cleaners/degreasers instead of flammable/toxic solvents like acetone/benzene

Waste handling options and the priority in which they should be considered are illustrated below.

Prevention

Elimination

Reduction

Recycling

Disposal

 

8.2 Radioactive Materials

Refer to Radiation Safety Manual, Appendix D.

 

8.3 Biological Wastes

Refer to EHS Manual, Section 9 Biosafety (9.8 Biohazardous Waste Disposal) 

 

8.4 Universal Waste

The requirements for this Universal Waste (UW) Management Plan are based upon the EPA regulations found in 40 CFR 273.

Universal Wastes are those hazardous wastes, which are "universal" to most work environments.  Currently, the list of universal wastes consists of five categories of wastes at the federal level.  This program describes general management requirements for all UW and focuses on each UW with specific management requirements.  These include prohibited and allowed activities; procedures for notification; management, labeling and accumulation time limits; training and responses to releases; shipping documentation; and record-keeping.

Universal wastes at the federal level include the following items:

• Fluorescent lamps (federally regulated)
• Mercury-containing equipment (federally regulated)
• Batteries (federally regulated)
• Pesticides (federally regulated)
• Aerosol cans (federally regulated)

The University has a dedicated central location located at the Columbus Law School, Room 133A for accumulation and storage of UW.

Environmental Health & Safety (EHS) Responsibilities:

1. Maintain records associated with UW shipments, including analytical results conducted on any containers or shipments.
2. Maintain records associated with any training or briefings for individuals who manage UW.
3. Periodically inspect accumulation areas to ensure containers are properly labeled, closed and are not leaking or damaged.
4. Establish a central accumulation area for universal waste and separate collection containers for different types of batteries.
5. Schedule and maintain regular shipments of universal wastes using a reputable vendor.

Facilies Maintance & Operations (FMO) Electrical Shop Staff Responsibilities:

1. Properly remove all UW from the solid waste stream.
2. Package all used lamps back into manufacturer’s containers when replacing lamps.
3. Properly label each UW container with quantity, lamp type and date.
4. Ensure lids are closed except when UW are being added or removed.
5. Periodically inspect accumulation areas to ensure containers are properly labeled, closed and not leaking or damaged.

Accumulation Time Limits:                 

UW can be accumulated for up to year from the date the UW became a waste.  The University will transport all stored UW containers from the campus using a reputable transporter to a permitted, offsite recycle, treatment, or disposal facility.  All UW will be managed according to local, state, and federal law and every effort will be made to reduce the potential long-term financial and legal liability to the University.

The amount of time that a UW has been accumulated must be demonstrated, in one of the following ways:

• Direct marking of the universal waste;
• Marking the container the waste is in with the earliest date that waste began accumulating in that container;
• Marking a designated accumulation area with the earliest date that waste began accumulating in that area;
• Keeping an inventory that identifies the date that each universal waste became waste; or
• Keeping an inventory that identifies the earliest date that a universal waste became waste in a designated accumulation area.

UW Management Requirements:             

As with other hazardous waste, proper storage and handling of UW is critical to ensuring personnel safety and compliance with appropriate regulations.  General management requirements for all types of UW are as follows:

• UW cannot be disposed of as municipal wastes (trash) or residual wastes;
• UW may not be diluted or treated, except in response to a release;
• UWs must be managed in a way that prevents a release of any component;
• If containment of a UW is required, the container will be closed at all times except when adding or removing waste, the container must be compatible with the UW and its contents, and free of defects, design characteristics or damage that would lead to leakage, spillage or other environmental releases; and
• UW stored outside must be covered, to prevent precipitation from coming into contact with the waste.

Requirements for Batteries:

A battery either becomes UW on the date that it is removed from service, because it is no longer operable, or because it is no longer wanted or needed.

The materials of construction of the anode, cathode, and the electrolyte determine the waste battery’s regulatory status: 

Table I.  Common battery types that should be handled as UW, and their uses.

Battery Type	Uses
Alkaline*	·         Most common battery type, found in cell sizes AAA to D
Nickel/Cadmium (NiCd)	·         Some laptop computers ·         Rechargeable 9-volt, AA, or D cell batteries ·         Some walkie talkies
Lithium ion or nickel hydride	·         Cell phones ·         Cameras ·         Newer laptop computers
Lead acid batteries	·         Cars and motorcycles ·         Deep cycle electric backup power for lights and communications ·         (Sealed lead acid batteries can be as small as a D-cell battery.)
Mercury or silver oxide	·         Hearing aids ·         Watches

 

Batteries have traditionally contained large amounts of mercury and other heavy metals, which pose numerous threats to the environment.  If disposed in a landfill, these metals could leach into ground water reserves and possibly contaminate surface waters and living organisms.

* Since the mid-1980s, an ongoing effort by manufacturers has been made to reduce mercury content in alkaline batteries. As of 2000 there has been a 97 percent reduction. Alkaline batteries at Catholic University are collected and managed as universal waste.

Key Management Issues of Batteries:

• Batteries should be segregated into categories when storing and when a request for a pick-up is made. (Battery type is usually indicated on battery labels.)  Note:  Battery types may be mixed in one container, although it is not recommended.
• To prevent a buildup of heat or sparks, batteries larger than 9-volt should be stored such that the terminals are not touching. It is best to tape off all terminals to prevent contact.
• Store in a container that is closed except when adding or removing batteries.
• Each battery, container of batteries, or battery accumulation area must be labeled with the date that the battery was taken out of service, and one of the following: Universal Waste—Battery(ies),or  Waste Battery(ies); or Used Battery(ies).
• Separate any UW battery that shows evidence of leakage, spillage, or damage that could cause leakage in another container. The container must also be closed, structurally sound, compatible with the contents of the battery, and must lack evidence of leakage, spillage, or damage that could cause leakage.

Requirements for Mercury-Containing Devices:

Devices containing only mercury, such as mercury switches, older thermostats, sphygmomanometers, thermometers, manometers, or pressure gauges that are unbroken, may be managed as UW.  Call EHS Chemical Hygiene Officer 2698 or email cua-ehschem@cua.edu to have it picked up.  If the device is a result of work being done on campus in a location where it would otherwise be left, you may bring the device directly to your own work area, provided you double bag the device.  This will help prevent any possible release of mercury should it be dropped.

To manage a mercury-containing device as a UW, the following requirements must be met:

• Mercury containing devices that show any sign of leaking, spilling, or damage that could cause spillage must be stored in a container that is closed structurally sound container, compatible with the waste, and free of defects that could cause a leakage.
• Ampules containing mercury may be removed from a mercury containing device if:
  • Ampules are removed in a manner designed to prevent breakage of the ampules;
  • Ampules are removed only in or over a containment device;
  • A mercury clean-up system is in place to transfer any spilled mercury to a container that meets the requirements of 40 CFR 262.34;
  • The area where the ampule is removed is well ventilated and monitored to ensure compliance with applicable OSHA exposure levels for mercury[1];
  • Employees removing ampules are familiar with proper waste mercury handling and emergency procedures, including transfer of mercury from containment devices to appropriate container;
  • Removed ampules are collected and stored in appropriate containers;
  • Removed ampules are stored in closed, non-leaking containers that are in good condition; and
  • Removed ampules are packed in a container with packing materials adequate to prevent breakage during storage, handling and transportation.
• If any waste is generated from mercury containing device breakage or emptying of ampules (ampules themselves, spill clean-up debris, ), the Individual must determine if it exhibits the characteristic of hazardous waste for mercury. If the waste does meet the characteristic, it must be managed as a hazardous waste.

[1]  OSHA Vacated PELs: Mercury: TWA 0.05 ppm [0.5 mg(Hg)/m3 TWA (vapor)]; NIOSH: REL: 0.005 ppm (0.05 mg(Hg)/m3); ACGIH Threshold Limit Value (TLV): Mercury: 0.0025 ppm [0.025 mg(Hg)/m3 (TWA), skin].

Mercury containing devices or mercury device storage areas must be labeled with the date that it was removed from service and one of the following: Universal Waste: Mercury-Containing Device(s), Waste Mercury-Containing Device(s), or Used Mercury-Containing Device(s).

 

Requirements for Fluorescent Lamps:

A lamp becomes a waste on the day that it is removed from service, either because it is burned out or is no longer wanted or needed. 

Proper Management of Lamps includes:

• UW lamps must be protected to prevent breakage, leaks or damage. This is best accomplished by returning them to the original shipping container (with protectant baffles) and ensuring that the box is closed to prevent damage.  Do not mix new and used bulbs in the same container.
• Containers must be closed, structurally sound, compatible with the contents of the lamps and must not show evidence of leaks, spills or damage that could cause releases of mercury or other hazardous substances.
• Lamps may not be intentionally crushed or dismantled.
• If lamps are unintentionally broken, the broken lamps and residue must immediately be cleaned up using proper mercury clean up procedures, the area decontaminated, and the debris placed in a container. If the broken lamps and clean-up debris exhibit a characteristic of hazardous waste, it must be managed as a hazardous waste.
• Lamps or lamp accumulation areas must be marked with the date it is removed from service and one of the following: Universal Waste—Lamp(s), Waste Lamp(s), or Used Lamp(s).

Security Measures:

The following security measures will be provided at all outdoor storage areas for UW:

• An artificial or natural barrier that completely surrounds the universal waste storage area to prevent unauthorized entry by people or livestock;
• An entry that is controlled at all times; and
• A sign at all entries to the storage area with the legend Danger – Unauthorized Personnel Keep Out or other words indicating that only authorized personnel are allowed entry and that the area is potentially dangerous.

Response to Releases:

The handler of UW must immediately contain all releases of universal wastes and other residues from UW.

The handler of UW must determine whether any material resulting from the release is hazardous waste, and if so, must manage the hazardous waste in compliance with all applicable requirements of 40 CFR parts 260 through 272.  The handler is considered the generator of the material resulting from the release, and must manage it in compliance with Title 40 CFR Part 262.

Recordkeeping:

The UW generator should keep a record of each shipment of universal waste in the EHS Hazardous Waste Manifest book, maintained by the Chemical Hygiene Officer.

The record can be in the form of a log sheet, an invoice, a manifest, a bill of lading or another type of shipping document.  The record must include the following information:

• The name and address of the universal waste handler;
• Destination facility;
• Quantity of each type of universal waste; and
• Date of shipment.

These records will be kept for at least three years from the date of shipment.

 

8.5 Electronic Waste

The University strives to route all equipment with electronics through a process to divert them from landfills.  This diversion can be accomplished in several ways, which results in lowering the cost to buy new equipment, maximizing the revenue from sales and reducing the cost by lowering the frequency of bulk trash collection containers being emptied.

The Electronics Waste Program is primarily run and coordinated by the University's Asset Manager working out of the Environmental Health, Safety & Risk Management office under the Facilities Planning and Management division.

Upon notification from any University office of equipment or furniture that is no longer needed, the Asset Manager inspects the equipment for the following:

• type, location, quantity, size and weight of equipment;
• presence of any hazardous materials associated with the equipment; and
• time frame from the end user of when the equipment needs to be removed.

All hazardous materials are first removed by the University's Chemical Hygiene Officer and/or Radiation Safety Officer before the equipment is moved from its current location. Then, any equipment smaller than a full-sized refrigerator is moved to one of two collection points for further evaluation. Such evaluation shall include a combination of partial disassembly and at least one full start-up cycle. Larger equipment is fully evaluated in its current location prior to being moved for re-use or permanent disposal.

If the equipment is found to be reliable, safe and able to be supported by appropriate University services, a notice is sent to the Academic Vice President's office seeking any interested departments. If the equipment isn't supported, but otherwise reliable and safe, it is sold to any interested party and permanently removed from campus, with a signed General Counsel-approved release.

If the equipment isn't safe or reliable, it is first cannabalized for useful and/or regulatory-required components then shrink-wrapped to a pallet or large shipping container. Regulatory components are placed in a designated area for processing by the University Chemical Hygiene Officer.

Proceeds from sales are deposited into the University's General Fund, with 6% remitted to the District of Columbia for sales tax. The University is only exempt from sales tax on the purchase of supplies and equipment.

The University contracts to a vendor to remove all palletized electronics approximately 2-3 times per year, depending on the volume of equipment turned in. The vendor is required to recycle 100% of the shipment including the pallet and shrink-wrap, since there is a no-landfill clause. The vendor reports a total weight recycled for each shipment. The University Asset Manager annually reports these weights to the University's Assistant Director for Campus Facilities and Sustainability Initiatives.

 

8.6 References

• Title 40 of the Code of Federal Regulations, Parts 260-268, 270, 273, 279,
• District of Columbia Municipal Regulation, Title 20, Chapters 40-54
• Hazardous Waste Regulation, 40 CFR 260                                                                  
• EHS Chemical Safety Guide
• Chemical compatibility table from EHS Chemical Safety Guie
• EPA Compatibility Table 40 CFR 264, Appendix V
• Listing Information (F, K, P, U Lists)
• OSHA information on carcinogens