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EAST TENNESSEE STATE UNIVERSITYHazardous Waste Management
Table of Contents
Chromic Acid Separation of Halogenated and Non-Halogenated Wastes Hazardous Waste Manifesting and Turn-In ETSU Hazardous Waste I.D. Tag (Sample) ETSU Hazardous Waste Manifest (Sample) "Empty" Waste Containers Nonhazardous Waste Disposal Disposal of Chemicals in the Sanitary Sewer System EMERGENCY SPILLS Planning for Chemical Spill Emergencies Hazardous Chemical Spill Clean-up Guidelines Rescue First Aid Confine Report Secure Clean-up Who Cleans Up a Spill What to do When You Clean-up a Spill Comments
APPENDICES A. Maximum Concentration of Contaminants for the Toxicity Characteristics B. Glossary C. Commercial Chemical Products D. References
INTRODUCTION The proper disposal of chemical wastes is essential to the environmental protection of East Tennessee State University, as well as, the surrounding community. It is important, therefore, to dispose of all chemicals in a safe, efficient and cost-effective manner. To ensure a successful hazardous waste management program, the Health and Safety Office has developed these procedures to help East Tennessee State University personnel provide for the safe and proper disposal of chemical waste. The objectives of the Health and Safety Office in issuance of these procedures are:
!To maintain a healthful and safe work environment through scheduled, periodic removal of chemical waste from East Tennessee State University facilities.
With a cooperative effort on the part of the East Tennessee State University faculty and staff, and through adherence to the procedural guidelines contained herein, the attainment of these objectives can be realized. OVERVIEW OF HAZARDOUS WASTE
Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA), passed in 1976, was the first comprehensive federal effort to regulate both solid and hazardous wastes. RCRA regulates anyone engaged in the creation, transportation, treatment and disposal of hazardous wastes.
The main purpose was to address the problem of how to safely dispose of the large volumes of waste, including hazardous waste, generated by our society.
RCRA was established to accomplish three goals:
In order to achieve these goals, three distinct programs, among others, were established under RCRA:
Hazardous Waste Definition
Congress defined hazardous waste as a "solid waste, or combination of solid wastes," which because of its quantity, concentration, chemical, or infectious characteristics may:
Although Congress defined the term hazardous waste, the Environmental Protection Agency (EPA) was required to develop the regulatory framework which the regulated community could use to identify their wastes as hazardous. According to the EPA, a waste is hazardous if it meets one of four conditions:
ACADEMIC INSTITUTIONS AS HAZARDOUS WASTE GENERATORS
Background
Until 1984, most academic institutions that generated hazardous wastes were exempt from many of the RCRA requirements for generators, because they generated less than 1,000 kg per month of hazardous waste. However, when that limit was lowered to 100 kg per month for conditionally exempt small quantity generators, almost all colleges and universities fell under the regulations established by RCRA.
On June 21, 1989, EPA submitted "Hazardous Waste Management: Report to Congress -- Management of Hazardous Waste Generated from Educational Institutions." This report provides an overview of statutes and regulations that affect universities. Also, current hazardous waste practices and related problems found at universities are discussed. Although the report examines hazardous waste management at academic institutions, the report did not recommend to congress any changes in the present regulations. Until such changes are made, universities will remain subject to all RCRA requirements.
RCRA Enforcement
Of the various regulations that the generator must follow, the generator must also share in the responsibilities for the safe management and ultimate disposal of all wastes. If the transporter or disposal facility fails to take proper care of the waste or does not prevent the wastes from being released into the environment, the generator can and will be held responsible.
EPA is authorized to seek civil and criminal penalties for RCRA violations. Educational institutions have not been excluded. Several universities have been found guilty of RCRA violations and have had to pay substantial penalties. Under new (Oct. 1990) revisions, individuals guilty of RCRA violations can be personally brought to court and face mandatory penalties, as well as, imprisonment. One substantial meaningful penalty for violation of EPA Regulations is that the institution and in consequence faculty, staff and researchers may not receive Federal funds.
Due to these developments, universities must ensure that staff, faculty members, and students are properly trained concerning waste management practices.
HAZARDOUS WASTE MINIMIZATION
East Tennessee State University is committed to the protection of human health and the environment. To meet these commitments, the University strongly encourages its employees to utilize chemical waste minimization (waste reduction) techniques to reduce the volume and toxicity of chemical wastes produced at the University. An important benefit from waste minimization is that it will help reduce the University's escalating chemical disposal costs.
The following describes common waste minimization techniques:
GENERATOR GUIDELINES
The Health & Safety Office is responsible for the management of all chemical waste (hazardous and non-hazardous) generated by East Tennessee State University. In order to comply with the many regulations set by RCRA, ETSU policies have been adopted to ensure safe and efficient disposal of wastes generated in academic laboratories.
The Health & Safety Office will manage the collection, transportation and off-campus disposal of hazardous waste generated in academic teaching and research facilities. However, assistance from the academic community is needed during the first (and in essence) most important step of the process - the generation phase.
RCRA Regulations as adopted and promulgated by the Tennessee Hazardous Waste Management Regulations (Tennessee Rule Chapter 1200-1-11) pertaining to Generators and Transporters of Hazardous Wastes, require specific methods of collecting and storing the waste at the point of generation. The following is a listing of policy guidelines which need to be complied with in all academic and research laboratories. Following these guidelines will not only bring ETSU into compliance, but will greatly assist the Health and Safety Office in the safe handling and proper disposal of all hazardous waste.
CHEMICAL WASTE HANDLING GUIDELINES
CHROMIC ACID The use of sodium or potassium dichromate dissolved in concentrated sulfuric acid as a cleaning solution presents special handling and disposal problems. Chromic acid is a powerful oxidizing agent, and as such, has the potential to explode on contact with certain oxidizable organic materials. In addition, it is both toxic and corrosive. Instances of burns to both skin and clothing due to spillage of chromic acid cleaning solutions have occurred. The Health and Safety Office urges you to consider the following list of alternate cleaning agents that have been proven to be satisfactory as cleaners and significantly less toxic and hazardous.
- Alconox (powder) - S/P Contrad 70 (concentrated liquid) - S/P Laboratory Detergent Concentrate (powder) - Fisherbrand Sparkleen (powder) - FL-70 Concentrate (concentrated liquid) - Liquinox Liquid Detergent (liquid) - NoChromix - Isoclean (concentrated liquid) - Count-Off (concentrated liquid) - Lift Away Concentrated Decontaminant (liquid) - RBS 35 Concentrate (concentrated liquid)
SEPARATION OF HALOGENATED AND NON-HALOGENATED WASTES Separated and well-defined wastes are easier and less expensive to dispose of than mixed and unknown wastes. Since high levels of halogens in the organic solvents cannot be properly destroyed in most incinerators, several disposal agencies are not approved by EPA to handle these wastes. Therefore, it is essential to indicate the composition of all waste liquids and, if a mixture, the approximate percentage by volume of each constituent. The percentage composition must be clearly indicated on the "ETSU Hazardous Waste Tag". Departments should attempt to keep the halogen content of their organic solvents below 1.0% by volume. The following provide guidelines for placing waste in the differing waste solvent containers.
a. Acceptable as non-halogenated waste solvents
- Non-halogenated organic solvents - Solutes containing small amounts of halogens
b. Halogenated solvents that should be in separate containers
- Halogenated organic solvents
- Solutions of acids or bases - Aqueous solutions of toxic organic chemicals - Metallic compounds containing, Ag, As, Ba, Cd, Cr, Hg, Ni, Pb, Sb. - Sulfides or inorganic cyanides - Strong oxidizers or reducers - Water reactive substances - Large amounts of water
Departments who generate large volumes of individual solvents should consider recycling methods such as distillation, rather than costly disposal. The amount of money saved in solvent purchase costs usually far exceeds the capital expense for such equipment and the success of such programs is well documented, as is the purity of recovered solvent.
HAZARDOUS WASTE MANIFESTING AND TURN-IN
Each container of hazardous waste must have an ETSU Hazardous Waste Tag filled out and securely attached to the container. The tag is numbered and corresponds to an internal ETSU Manifest which bears the same number. The manifest must also be completed and remain with the container until the waste is picked-up by Health and Safety.
When the waste is ready to be picked-up, a Physical Plant work order request should be completed and submitted to Physical Plant. Any special waste handling requirements should be included on the work order request. At the time of pick-up, the blue copy of the manifest is left with the department as their record that the waste has been properly turned-in.
"EMPTY " WASTE CONTAINERS
A container or an inner liner removed from a container that has held any hazardous wastes, except a compressed gas or an acute hazardous waste, is empty if all wastes have been removed that can be removed using the practices commonly used to remove materials from that type of container, (i.e., pouring, pumping), and the following conditions are met:
A container that has held a hazardous waste that is a compressed gas is empty when the pressure in the container approaches atmospheric.
A container or inner liner that has held an acute hazardous waste is empty if the container or inner liner has been triple-rinsed using a solvent capable of removing the chemical product or if the container has been cleaned by another method that has been shown in the scientific literature, or by tests conducted by the generator, to achieve equal removal. NONHAZARDOUS WASTE DISPOSAL
Examples of nonhazardous waste are given on the following pages. These chemicals were selected because they:
List of Solid Nonhazardous Waste Acid, Ascorbic Acid, Benzoic Acid, Boric Acid, Casamino Acid, Citric Acid, Oleic Acid, Lactic Acid, Phosphotungstic Acid, Phthalic Acid, Salicylic Acid, Silicic Acid, Stearic Acid, Succinic Acid, Tartaric Agar Albumen Aluminum Hydroxide Aluminum Metal Aluminum Oxide Amino Acids (naturally occurring) Ammonium Bicarbonate Ammonium Carbonate Ammonium Chloride Ammonium Citrate Ammonium Lactate Ammonium Phosphate Ammonium Sulfate Ammonium Sulphamate Barium Carbonate Barium Sulphate Brain Heart Infusion Brom Phenol Blue Broth, Nutrient Calcium Borate Calcium Carbonate Calcium Chloride Calcium Citrate Calcium Lactate Calcium Phosphate Calcium Sulphate Cobalt Oxide Copper Oxide Crystal Violet Dextrose Drierite Extract, Malt Extract, Yeast Ferrous Ammonium Sulphate Galactose Gelatin Graphite Gum, Arabic Gum, Guaic Hematoxylin Iron Oxide Kaolin Lactose Lithium Carbonate Lithium Chloride Lithium Sulphate Magnesium Borate Magnesium Carbonate Magnesium Chloride Magnesium Citrate Magnesium Lactate Magnesium Oxide Magnesium Phosphate Magnesium Oxide Magnesium Sulphate Maltose Manganese Manganese Acetate Manganese Chloride Manganese Dioxide Manganese Oxide Methyl Red Methyl Salicylate Methylene Blue Paraffin Pepsin Peptone Petroleum Jelly Potassium Acetate Potassium Bicarbonate Potassium Bisulphate Potassium Bitartrate Potassium Borate Potassium Bromate Potassium Bromide Potassium Carbonate Potassium Citrate Potassium Chloride Potassium Iodide Potassium Lactate Potassium Phosphate Potassium Sodium Tartrate Potassium Sulphate Potassium Sulphite Potassium Sulphocyanate Pumice Sodium Acetate Sodium Ammonium Phosphate Sodium Benzoate Sodium Bicarbonate Sodium Bisulphate Sodium Bisulphite Sodium Borate Sodium Bromide Sodium Carbonate Sodium Chloride Sodium Citrate SDS (Sodium Dodecyl Sulfate)
Sodium Formate Sodium Iodide Sodium Lactate Sodium Phosphate Sodium Salicylate Sodium Silicate Sodium Succinate Sodium Sulphate Sodium Thioglycollate Sodium Thiosulphate Sodium Tungstate Starch Strontium Carbonate Strontium Phosphate Strontium Sulfate Sulphur Sugars Sucrose Talcum Powder Thymol Tin Metal Tin Oxide Trypticase Tryptone Urea Wax, Bee's Zinc Oxide
DISPOSAL OF CHEMICALS IN THE SANITARY SEWER SYSTEM
Some chemical wastes, (less than 100 grams at a time) can be safely disposed of into the sanitary sewer system if they are water soluble, degradable, and properly diluted. Chemicals in solid form should first be dissolved in water. All chemicals put into the sanitary sewer system should be followed by a 20 to 50 fold dilution of water. If you intend to dispose of more than one pound of any one of these chemicals, or if you have any questions, call the Health and Safety Office.
The following list comprises water-soluble compounds of low-toxic-hazard cations and low-toxic-hazard anions. Compounds of any of these ions that are strongly acidic or basic should be neutralized before disposal down the drain.
Cations Al3+ Ca2+ Cu2+ Fe2+, 3+ H+ K+ Li+ Mg2+
Na+ NH4+ Sn2+ Sr2+ Ti3+, 4+ Zn2+ Zr2+
Anions BO33! B4O72! Br! CO32! Cl! HSO3! OCN!
OH! I! NO3! PO43! SO42! SCN!
EMERGENCY SPILLSPlanning For Chemical Spill Emergencies
Hazardous Chemical Spill Cleanup Guidelines
Chemical spill or hazardous materials emergency situations should be handled as a fire emergency. Initial response in a fire situation can be summarized as RESCUE, CONFINE, REPORT, SECURE, and CLEANUP (FIGHT FIRE). These principles can also be applied to a hazardous materials spill situation.
1. Rescue
Just as you are not to re-enter a burning building, do NOT go back into an area where a chemical spill has occurred unless you have the proper equipment and training. In many documented cases, rescuers not wearing proper protective equipment have been overcome by toxic or asphyxiating gases trying to rescue other victims and died as a result. Do not make this mistake.
As you leave an area involved in a chemical spill, assist people exiting the area.
2. First Aid
General:
Chemical spills over large body areas:
Victims of Bromine spills:
Victims of Hydrogen Fluoride (HF) spills:
3. Confine
4. Report
Call Public Safety 9-911 or 4480:
Call Health & Safety Office:
The type of information you will be requested to provide when you call 9-911 or Health & Safety consists of the following:
5. Secure
Until Emergency Responders arrive on the scene, you and your staff will have to block off entrances to the spill site and prevent people from entering the contaminated area.
6. Cleanup
Based on the chemical spill situations, decide who will do the cleanup. If you are going to do the cleanup, follow the procedures listed in the "What To Do When You Clean Up A Chemical Spill" section below.
Who Cleans Up A Chemical Spill
The following guidelines are offered to help you decide if you should clean up a chemical spill.
YOU CLEAN UP THE SPILL
For chemical spills which do not involve injury, do not represent a fire hazard, are less than one gallon, and for which you have the proper training and proper protective equipment to do the cleanup, you clean up the spill.
WE CLEAN UP THE SPILL
For all other chemical spill situations, including those for which you have any questions or doubts about your ability to clean up the spill, call the Health and Safety Office at 929-6201. Report all injuries, fires, explosions and potentially life threatening situations first to 9-911 or 4480, then to Health and Safety.
What To Do When You Clean Up A Chemical Spill
If you have the proper training, proper personal protective equipment and the proper material to absorb and clean up your chemical spill, and no one has been injured, the spill is contained, and the spill is not life threatening or a fire or explosion hazard, then follow these procedures:
5. Confine or contain the spill.
6. Spills that require special handling:
Acid Chlorides:
Mercury:
Alkali Metal (e.g. Sodium or Potassium Metals):
White (Yellow) Phosphorus:
7. Remove absorbent material with a broom and dust pan.
8. Wet mop spill area.
Comments
Questions arise as to what constitutes a large spill requiring a chemical cleanup team and what are the limitations of the spill kits commonly purchased for laboratories.
A "large" spill can be as small as a few milliliters if the material is a highly volatile, toxic compound spilled in a confined space. Many times you will have to make a professional judgement as to the severity of the spill. When in doubt, you can always call the Health & Safety Office for advice.
Chemical spill cleanup kits are very handy to have in the lab and other service areas which use chemicals. The kits are useful if you and your fellow workers know how to use them properly. Chemical absorbent or neutralizing powder and pads can be used to quickly contain a spill.
Spill kits may contain a disposable organic vapor/acid gas respirator. Know what type of respirator you have - read the labels. Since respirators are certified for only certain types of chemicals, ensure the respirator provided or the one(s) available in your department are suitable for the material spilled. Once again, read the labels prior to using the respirator.
All disposable respirators are only effective in an atmosphere that is not deficient in oxygen (below 19.5 percent oxygen). Additionally most have limits on the concentrations to which they will provide adequate protection. Unless you have monitoring equipment which identifies the concentration, it is best to call the Health & Safety Office to determine if you should use the respirator to go back into a room to clean up a chemical spill.
Be aware of the fact that while you may be in a well ventilated room, the Lower Explosive Limit (LEL) of a chemical may be reached at the surface of the spill and you want to avoid any sparks or sources of ignition during the cleanup. Personal protective equipment in the Spill Kit will not protect you from a flash fire. Many times, the best way to handle the spill of a highly volatile compound, such as diethyl ether or chloroform, is to open windows and fume hoods, leave the room, close and lock the door and let the room air out. In these cases, call Public Safety and the Health & Safety Office so they can monitor the situation. In most cases of a chemical bottle breaking in a laboratory, however, you will not need to call the fire department as the lab ventilation system is usually designed to handle such situations.
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