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WORKSHOP PROCEEDINGS
Waste Management in Universities
and Colleges
Madison, Wisconsin
July 9-11, 1980
Edited and prepared for publication by
PEDCo Environmental, Inc.
11499 Chester Road
Cincinnati, Ohio 45246
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION V
230 SOUTH DEARBORN STREET
CHICAGO, ILLINOIS 60604
Printed for EPA by the Association of Physical Plant Administrators
of Universities and Colleges, a cosponsor of this seminar. Addition-
al copies of this book are available from APPA, Eleven Dupont Circle,
Suite 250, Washington, DC 20036 at $7.50 per copy, prepaid.
U.S. Environmental Protection Agency
Region V, Library
230 South Dearborn Street
Chicago. Illinois 60604
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ABSTRACT
In response to a request from the Wisconsin Department of Natural
Resources, Region V of the U.S. Environmental Protection Agency (EPA) spon-
sored a workshop on waste management in universities and colleges. The
workshop was held at Madison, Wisconsin, from July 9 to 11, 1980. It con-
sisted of four sessions: (1) Managing General University Waste/Regulatory
Concerns, (2) Chemical Waste Management, (3) Low-Level Radioactive Waste,
and (4) Research- and Hospital-Generated Waste. This report contains all
workshop papers that EPA received for publication.
Fnvfronment,! Protean en™
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CONTENTS
Page
Abstract
1. Managing General University Waste/Regulatory Concerns
Methods of Handling Nonhazardous Wastes at Colleges and 1-1
Universities
Larry A. Steinman
Energy Recovery—A Case Study of St. John's University, 1-6
Coll egevi lie, Minnesota
Gordon G. Tavis
Legal Issues in Hazardous Waste Management Affecting 1-14
Colleges and Universities
Helen H. Madsen
Federal Hazardous Waste Regulations as They Apply to 1-20
Colleges and Universities
Eugene Meyer
2. Chemical Waste Management
Introduction to Session on Chemical Waste Management 2-1
John F. Meister
Initiation and Development of the SIU-C Hazardous 2-6
Waste Program
John F. Meister
Operation of the SIU-C Hazardous Waste Program 2-17
John F. Meister
Sources and Identification of University-Generated Waste 2-26
Henry H. Koertge
Packaging, Transportation, and Disposal of Wastes Off 2-31
Campus
R. R. (Dick) Orendorff
rii
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CONTENTS (continued)
3. Low-Level Radioactive Waste
Introduction to Session on Low-Level Radioactive Waste 3-1
Warren H. Malchman
Application of Nuclear Regulatory Commission Regulations 3-3
to University Waste Disposal Practices
Carl 0. Paperiello
Safety Considerations in Disposal of Low-Level Radioactive 3-7
Waste
A. J. Solari
Experiences With Various Disposal Methods at the 3-13
University of Wisconsin-Madison
Elsa Nimmo
Experience With Incineration of Low-Level Radioactive 3-18
Waste at the University of Illinois
Hector Mandel and Lorion J. Sanders
4. Research- and Hospital-Generated Waste
Waste Disposal at the Medical Center of the University 4-1
of Illinois
Raymond S. Stephens
Case Study of Hospital Waste Management, University of 4-7
Minnesota
Robert A. Silvagni
Hospital Waste Reduction at the University of Minnesota 4-17
Hospitals
J. Michael Sprafka
Reaction Panel Notes: Session on Research- and Hospital- 4-21
Generated Waste
Donald Vesley
Reaction Panel Notes: Session on Research- and Hospital- 4-22
Generated Waste
Max J. Rosenbaum
Reaction Panel Notes: Session on Research- and Hospital- 4-23
Generated Waste
Edwin H. Hoeltke
Reaction Panel Notes: Session on Research- and Hospital- 4-26
Generated Waste
Harvey W. Rogers
iv
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SESSION 1
MANAGING GENERAL UNIVERSITY
WASTE/REGULATORY CONCERNS
METHODS OF HANDLING NONHAZARDOUS WASTES AT
COLLEGES AND UNIVERSITIES
Larry A. Steinman
This paper concerns methods of handling nonhazardous solid wastes at
colleges and universities. Waste characteristics are addressed because they
affect present and future handling strategies, especially recovery of energy
and materials. A nationwide telephone survey was conducted of 25 randomly
selected schools to determine the current handling methods and their costs.
INTRODUCTION
Most colleges and universities gener-
ate an extremely varied waste stream
cofisi sting of both hazardous and
nonhazardous wastes. The quantity
and composition of these wastes
depend upon factors such as the size
of the campus, types of degrees
offered, and extent of graduate and
research programs. This paper is
concerned with wastes from dormito-
ries, cafeterias, and classrooms and
all miscellaneous solid wastes not
covered by the U.S. Environmental
Protection Agency hazardous waste
regulations promulgated on May 19,
1980. The distinction between non-
hazardous and hazardous wastes is
necessary because of the much higher
cost of hazardous waste disposal
(based on either weight or volume).
Before the Clean Air Act (CAA) of
1970, direct incineration was a
common disposal alternative for many
colleges and universities. Dormitory
and physical plant incinerators were
operated with little or no air pollu-
tion control equipment and were able
to reduce total waste volume by
roughly 75 percent. After the CAA
standards went into effect, landfil-
ling became the next most cost-
effective disposal alternative
because of the high cost of retro-
fitting air pollution control equip-
ment to incinerators. As standards
for landfills become more stringent
and associated costs rise, onsite
incineration with proper air pollu-
tion controls and energy recovery
seems more attractive.
OPERATIONS IN SOLID WASTE HANDLING
College and
handling can
basic,
storage,
disposal.
includes
university solid waste
be divided into four
interrelated operations:
collection, transport, and
1 Resource recovery, which
recovery of materials and
energy, can form various loops with
the basic operations, depending on
how the recovery program is struc-
tured.
Mr. Steinman is an Environmental
Engineer with Region V of the U.S.
Environmental Protection Agency.
1-1
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Storage
The management of onsite storage is
particularly important because most
of the people who come into direct
contact with the waste stream do so
during this operation. The biode-
gradability of mixed solid wastes
dictates regular removal from onsite
storage containers. Containers
holding organic wastes should be
emptied each day. Equipment varies
from ordinary corner wastebaskets to
large containers that can store and
compact more than 50 cubic yards of
wastes. Public health, economics,
access, and aesthetics are the prime
considerations for storage equipment
selection and placement.
Collection
The cost of collection, primarily
labor, equipment, and equipment
maintenance accounts for 50 to 75
percent of the total annual cost of
solid waste management at colleges
and universities. The collection
schedule is dictated by the waste
biodegradability, methods of storage,
and efficiency of the equipment and
labor. The trend appears to be
toward reductions in labor and total
mileage where possible. Large-
capacity, front-loading compaction
trucks (requiring one person) and
rear- or side-loading trucks (re-
quiring two persons) are favored when
new equipment is purchased. Satel-
lite systems, in which smaller vehi-
cles transport campus waste to a
central storage and compaction point
before disposal, are gaining popular-
ity. Electric satellite vehicles
help reduce fuel consumption and thus
fit well into the system if funds are
available for capital expenditure.
Transport
Although large-capacity central
storage containers may be used in the
collection and transport process
(especially when a private contract
can be negotiated for container
hauling and disposal), the majority
of campus collection operations
involve direct transport of the
collected waste to final disposal.
If a local municipality or private
firm operates a transfer station,
that facility can be used. Because
most colleges and universities col-
lect wastes in limited numbers of
compaction vehicles, onsite transfer
stations cannot be economically
justified. The hauling distance to
final disposal usually dictates the
method of transport.
Disposal
Although landfilling is currently the
most frequent method of disposal,
resource recovery facilities (involv-
ing incineration with energy recov-
ery) are increasing. Larger institu-
tions are often viable markets for
recovered energy, and a few univer-
sities are participating in local
resource recovery efforts. The
cooperation of the city of Ames,
Iowa, with Iowa State University is
an example. Projects of this nature
are expected to increase.
WASTE CHARACTERISTICS
The composition of college and uni-
versity solid wastes plays a large
role in determining the handling
system used. In studying the wastes
generated in Monroe County, Indiana,
the author separately performed a
quantity and composition study of
Indiana University's waste stream and
determined the composition to be 53
percent mixed paper, 6 percent card-
board, 10 percent metal, 7 percent
plastic, 7 percent glass, 9 percent
food waste, 5 percent ash (some
dormitory incinerators still operate
1-2
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but are scheduled to close), and 3
percent miscellaneous materials
(e.g., rubber products, textiles, and
lawn trimmings). At this campus of
32,000 students, the waste generation
per student varied between 1.0 and
1.5 Ib/day. Compared with normal
residential waste, the university's
waste stream contained relatively
more paper (especially if the major-
ity of the ash was originally paper),
plastic, and metal, but less food
waste and miscellaneous materials.
Generally, the moisture content
(depending partly upon the storage
and collection system) would average
between 20 and 25 percent, whereas
the estimated heating value of the
waste stream would be 6000 Btu/lb.2
This heat value is 25 percent greater
than that of most municipal wastes,
but 50 percent less than the general
heating value of eastern coal and 15
percent less than the usual heating
value of western coal. The average
values are listed below:
Fuel
University wastes
Municipal wastes
Eastern coal
Western coal
Heating value,
Btu/lb
6,000
4,500
12,000
7,000
The characteristics of college and
university wastes are well suited to
resource recovery. The high heating
value makes incineration with energy
recovery attractive, the wastes are
clean (food waste is usually collect-
ed separately from the cafeteria),
and the large quantities of re-
cyclable products (e.g., bottles and
cans) allow easy separation of mate-
rials. Also, the high population
density of the university concen-
trates the waste stream in a reason-
ably small manageable area for col-
lection and transport. Storage
capacity, markets, and student par-
ticipation must be evaluated in
considering materials recovery.
Although the sale of waste materials
might not produce great revenue, it
would help defray the costs of col-
lection, transport, and disposal.
Depending on the program, a weight
reduction of 5 to 25 percent can be
realized through separation of
wastes.
NATIONAL SURVEY OF WASTE HANDLING
METHODS AND COSTS
A nationwide telephone survey of 25
colleges and universities was con-
ducted to determine general waste
handling methods and costs. Enroll-
ments at these institutions varied
from 1,000 to 38,000 full-time stu-
dents. Questions covered type of
collection (in-house or private
contract), costs, equipment used, and
extent of recycling operations. When
available, additional information was
gathered about such matters as labor
requirements, past handling prac-
tices, and general problem areas.
Although private contracting of waste
collection and disposal is gaining
popularity among municipalities
because of supposed cost savings from
more efficient operation, this trend
was not noticed in the university
survey. Approximately half the
schools contacted provided their own
collection and funded it as a line
item of the school budget; 75 percent
of these schools had more than 10,000
full-time students. Major factors
that affect whether a school provides
its own collection and disposal
services are the amount of wastes,
number of students, and past prac-
tices. In-house collection requires
a large amount of wastes for effi-
cient use of labor and equipment and
large capital expenditures to begin
or reequip a program.
1-3
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Survey data indicate that bigger,
often state-supported universities
could collect wastes more cheaply by
using their own staffs than by hiring
private collectors. Also, in-house
collection improved service and
administrative control and enhanced
campus security.
Approximately one-third of the insti-
tutions surveyed used private con-
tractors for waste collection and
disposal, which was funded as an
annual budget line item: 85 percent
of these colleges and universities
were attended by fewer than 10,000
full-time students. Limited waste
generation and capital investment
constraints are the primary factors
that make this option cost-effective
for smaller schools. The ease of
private contracting (i.e., much less
complex administrative functions) is
definitely a factor if in-house
collection offers no readily apparent
economic advantages. In places where
more than one private contractor
provides local services, occasional
rebidding of the contract ensures a
competitive situation.
More than 15 percent of the institu-
tions surveyed used in-house person-
nel and private contractors to handle
solid wastes. Generally, these
colleges and universities operated
satellite collection systems, in
which wastes from individual storage
containers were consolidated by
school staff using multipurpose
vehicles. Large, centrally located
containers, usually compactor-
equipped rolloffs, were used for
central collection. Private contrac-
tors collected these containers and
delivered them to the final disposal
site. Although such systems are
probably the most expensive means of
waste handling, they are workable
when disposal sites are far away.
Larger schools use satellite collec-
tion systems the most, primarily to
avoid large capital expenditures for
equipment. Fewer than 5 percent of
the colleges and universities sur-
veyed used miscellaneous services,
such as municipal or municipally
contracted handling. Small schools
(with 1,000 students or less) were
most likely to have an alternative
arrangement. Past practice appeared
to be a major determinant in selec-
ting a miscellaneous service, but
other previously mentioned factors
were significant.
Data show that waste handling costs
ranged from $20 to $100 per ton.
This wide range cannot be explained
simply by variations in local situa-
tions (e.g., labor costs, disposal
costs, and levels of services).
Instead, the primary reason seems to
be differences in recordkeeping and
accounting. Equipment maintenance
costs, for instance, may be recorded
under general vehicle maintenance and
thus may not appear in the waste
management budget. Also, management
and administrative duties may or may
not be included in direct costs of
solid waste handling. When all
factors were considered, average
handling costs were difficult to
develop because of insufficient data.
Nevertheless, an overall trend re-
flecting economies of scale was
evident. The costs of waste handling
per full-time student were generally
less at larger institutions than at
smaller ones.
RECOMMENDATIONS AND CONCLUSIONS
Colleges and universities should
regularly analyze their methods of
solid waste handling with an eye to
the future. In considering a change,
an institution should examine the
situation at other schools that are
anticipating or have recently made a
similar change.
1-4
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No arrangement is necessarily the
best for all institutions or for one
institution at all times. Because
handling costs are currently increas-
ing at roughly 15 percent per year,
what is economical now may not be in
the future. As landfilling becomes
increasingly expensive, recovery of
energy and materials will become more
attractive.
REFERENCES
1. Tchobanoglous, G. , H. Theisen,
and R. Eliassen. Solid Wastes.
McGraw-Hill, New York, 1977.
2. Mitchell, G. L., and C. W.
Peterson. Small-Scale and Low
Technology Resource Recovery.
Prepared for the U.S. Environ-
mental Protection Agency under
Contract No. 68-01-2653, SCS
Engineers, 1979.
1-5
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ENERGY RECOVERY—A CASE STUDY OF
ST. JOHN'S UNIVERSITY,
COLLEGEVILLE, MINNESOTA
Gordon G. Tavis
In workshops held nationwide, the Environmental Protection Agency issued the
following guidelines for anyone interested in the possibility of recovering
energy from solid waste. Following these guidelines, St. John's University in
Stearns County has instituted a program for energy recovery from solid waste.
The step that St. John's is taking introduces and demonstrates to the region
that such technological possibilities can be useful in many more places,
raises the level of energy consciousness in the county and state, emphasizes
source separation as the only feasible resource recycling approach available
to those living in predominantly rural areas, takes a research stance to be
involved in developing this technology to the fullest, and makes use of sav-
ings to enable the institution to be more competitive. This project demon-
strates the St. John's service orientation in the following ways: to the
county, by providing relief from its current landfill dilemma; to citizens, by
offering what previously had been planned as a tax-supported public venture;
to users, by providing a more stable, less costly, long-term solution for
handling solid wastes; and to interested agencies, corporations, and individ-
uals, by attempting a pilot project with currently available information and
consulting assistance.
INTRODUCTION
Energy recovery at St. John's Univer-
sity is an unusual case study because
it has only reached the equipment
fabrication stage and the building
that is involved is only now ready
for bidding. The incinerator is
scheduled to be fired up for testing
in mid-1981. This case is being
presented from the poststudy/planning
point of view, but since it is in a
preimplementation stage, we are
unable to present firm conclusions.
First, I will describe the founda-
tions at St. John's University upon
which this project grew. Then I will
detail the steps the Environmental
Protection Agency (EPA) outlined for
energy recovery projects. Finally, I
will explain the latest innovations
involving solid waste management in
Stearns County and share with you our
Father Tavis is Treasurer of the
Order of St. Benedict. He has held
various positions at St. John's
University, including Vice President
for Administrative Services and
Development and Prior of St. John's
Abbey. He received a B.A. from St.
John's University, completed divinity
studies at St. John's Seminary, and
earned a Master in Management at
Massachusetts Institute of Tech-
nology.
1-6
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hopes and expectations at St. John's,
but at the same time point out the
risks we are taking.
ST. JOHN'S UNIVERSITY
St. John's University is located at
St. John's Abbey, which is out in the
country. We provide our own water
supply, fire protection, security,
and wastewater treatment. We have a
daytime population of about 3000 and
nighttime population of about 2000.
Coal has historically been our major
energy source, although an oil-
burning boiler was added in the early
1970's. Natural gas is not avail-
able.
A single centralized power plant
provides all of the steam and domes-
tic hot water and about one-fourth of
the electrical needs of the campus.
Northern States Power Company (NSP)
supplies the remainder of the elec-
trical power.
This free-standing, independent
institution already has district
heating and to a certain degree is
already into cogeneration. A team of
stationary engineers at the power
plant has always given the highest
level of service to our community.
They are accustomed to handling the
bulk of coal and to removing the
ashes. They are also capable of
maintaining the equipment and keeping
it in service.
We probably could not have estab-
lished economic feasibility without
cogeneration. We certainly could not
have done so had the district heating
not been installed. The efficient
power plant team was also a necessary
part of the plan for energy recovery
from solid waste.
EPA PROCEDURAL STEPS
In workshops held nationwide, EPA
issued the following guidelines for
anyone interested in the possibility
of recovering energy from solid
waste: (1) establish a market for
the products to be produced, (2)
determine that a sufficient supply of
solid waste is available for the
project under consideration, (3) make
sure that financing is available, (4)
examine the technology to determine
the process best adapted to the
project, (5) determine the size of
the equipment, and (6) establish a
procurement process.
Market
We first had to ascertain what pro-
duct we could produce that would need
marketing. In our case, the possi-
bilities were limited because our
needs are so small and we are so
removed from other possible users.
The only viable approach to consider
was the one EPA calls Modular Combus-
tion Unit (MCU). These incinerator
units produce only steam, and the
campus with its multiple steam uses
was the market. Our steam uses
include electrical generation, domes-
tic hot water, dishwashing, clothes
dryers, and a heated swimming pool.
The steam demand varied from 5000
Ib/hour in the summer to 55,000
Ib/hour in the winter. Because
demand was always over 15,000 Ib/hour
during the 9-month school year, it
was concluded that we had a suffi-
cient market. It should be mentioned
that Pfeifer & Schultz/HDR were
retained for the study and implemen-
tation of the project.
Supply
Fortunately for us, a three-county
study had just been completed for
Stearns, Sherburne, and Benton
1-7
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Counties (November 1975). These
counties had been studying the feasi-
bility of locating a refuse-derived
fuel plant in the area. They con-
cluded that such a plant was not
feasible because less than 300 tons/
day of combustible waste was avail-
able.
From our viewpoint, the same study
indicated that an ample supply of
waste was available in Stearns County
for an MCU at St. John's. The county
board members agreed with us and on
two different occasions passed reso-
lutions encouraging St. John's to
move ahead on the project. Finally
on May 1, 1979, the county approved a
license for the operation of an MCU
at St. John's. Also, we were assured
of county board support in achieving
a full supply of solid waste.
Also to be considered are the
issue of waste ownership and the
establishment of authority concerning
its use. From the start, we skirted
this issue; St. John's was concerned
strictly from the standpoint of
energy. We obviously were not a
governmental body worried about waste
removal and able to set the charges
accordingly. We realized that we
would have to stay competitive with
landfill operations if we were to
maintain good relations with the
haulers and local citizens. This put
definite limits on our financing, but
so far we have received cooperation
from the independent haulers.
It has been suggested that wastewood
from St. John's 2000 acres could be
stored nearby and used as supplemen-
tary fuel, if we were to run low on
solid waste. In addition, the MCU we
have purchased would also allow coal
to be mixed in with the waste.
Financing
Through the U.S. Department of Hous-
ing and Urban Development (HUD), a
loan for $1,255,500 was granted for
energy conservation through the
reduction of fossil fuel consumption
in dormitories and related facili-
ties. A 3 percent, 40-year loan was
authorized in two parts: $681,000 on
September 29, 1977, and $574,500 on
October 11, 1978. Thus, HUD not only
made the financing available, but the
advantageous terms of the loan have
become a major factor in the pro-
ject's financial feasibility.
Although grants for financing energy-
saving projects are supposed to be
readily available, they are hard to
find. We have an application pending
at U.S. Department of Energy under
the title of "Synfuels, Solid Waste",
which we hope will provide funding
for the remainder of this $2,500,000
project.
We have recently become aware of the
Entitlements Program of the Depart-
ment of Energy. Through this pro-
gram, the Federal Government pays a
subsidy to all who burn alternate
fuels. Although I have not been able
to establish the exact dollar amount
per ton, because it varies with the
price of oil, it is estimated to be
in the neighborhood of $4.50/ton of
solid waste.
Technology
Because of its size, St. John's
limited its study to MCU's. Even
though EPA coined this generic term
to include all incinerators in which
solid waste might be burned and which
may or may not involve energy re-
covery, we found that the companies
in the field had very different
approaches to the subject. Techno-
logically, the companies were signif-
icantly different from one another.
BASIC, CONSUMAT, KELLEY, and others
build only according to their own
specifications. In addition, patents
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are pending in this field and a good
deal of technical data are not trans-
ferable from one company to another
and/or from manufacturing company to
engineering firm.
St. John's approached this as a
situation in which the decision was
not between vendors, but between
technologies. Because the products
were not comparable, we concentrated
our effort toward discerning which
technology was the best for our job.
We decided on BASIC Environmental
Engineering, Inc., of Glen Ellyn,
Illinois.
This equipment is designed for steam
production. It has a combination of
three heat recovery units: two
boilers--a water-wall unit in the
first combustion chamber and a water-
tube unit following the third combus-
tion chamber (each of these is made
by Deltak, a Minnesota firm that
specializes in waste heat recovery)--
and an economizer, which follows the
water-tube boiler.
All of the variables of the study
come into focus when an attempt is
made to determine the size of the
equipment. Consequently, size deter-
mination became the focal point for
most of our calculations. Some of
the variables considered were: steam
demand, waste supply, capital cost,
operational cost, rated capacities of
the equipment, number of days per
year the equipment could run, amount
of auxiliary fuel, amount of excess
steam, and size of building required
to handle the equipment. Based on
these and many other variables, we
decided to translate each unit's
ratings into a measure of financial
feasibility for determining size of
equipment and whether or not the
project should be attempted.
In our approach, Boiler No. 6 at St.
John's Power Plant was designated as
the MCU. Savings would occur only by
replacing coal and oil with solid
waste. Other costs of operating the
plant were left unchanged. To that
total was added the estimated cost of
operating and maintaining the incin-
erator plant while amortizing its
debt. On the revenue side were
tipping fees from the haulers and the
savings resulting from a reduction in
the cost of on-campus refuse removal.
(The Entitlements Program would also
add revenue.)
On the basis of various company
ratings for their different sizes and
models, a series of calculations were
made to compare units under consider-
ation. We added several conservative
restraints to each of these calcula-
tions. The daily Btu availability
was reduced 10 percent from 64 to 58
tons/day. The boiler's efficiency to
produce steam was lowered 5 percent.
It was further assumed that all
temperatures used for the study were
5 percent too sanguine. A final 10
percent reduction was added to cover
downtime that might occur over and
above the planned monthly maintenance
period. With this approach, the
BASIC Model 3000 emerged as the
system most able to handle the finan-
cial burden involved. This unit
consumes 24 million Btu/hour in order
to produce 17,000 Ib steam/hour. If
the solid waste is delivered to our
plant at the quoted average of 4500
Btu/lb, then 64 tons/ day of waste
will be burned at St. John's.
Procurement
The project was divided into two
elements: that which BASIC would
handle and that which Pfeifer and
Shultz/HDR would handle. The BASIC
contract included the incinerator,
boiler, and connected input and
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output systems. The Pfeifer and
Shultz/HDR contract covered the
building, the connections with the
existing facility, and improvements
leading to better electrical utiliza-
tion.
The procurement process also includes
a building permit from the township,
a license to operate an MCU in
Stearns County, a construction permit
from MPCA, and a future operating
permit from MPCA. The only remaining
portions of the procurement process
are contracts with haulers and with
the landfill where residues will be
taken and an operating permit from
MPCA after testing is completed.
STEARNS COUNTY
We are located in a predominantly
agricultural and dairy county. St.
Cloud, the population center in the
county, has an estimated 70,000
people in its metropolitan area. It
is 12 miles from St. John's.
The landfill the county was relying
on was recently designated out of
compliance, and its operating permit
is going to be revoked by MPCA within
1 year. The St. John's project has
therefore become absolutely vital.
In addition, the programs for source
separation and composting, which we
had briefly discussed with the county
planner, have moved to a position of
prominence. It will definitely take
longer to implement these programs,
but our county may eventually utilize
a model for total resource recovery
that involves recycling elements,
composting organic matter that will
help rebuild our agricultural top-
soil, and incinerating the remainder
for energy recovery.
RISKS
Many risks are associated with this
project. Even the so-called proven
elements of the technology are rela-
tively new; the use of that technol-
ogy for burning solid wastes is even
newer; and inclusion of heat recovery
is newer yet. Continuous-burn units
are the very latest, and they have
little or no operational history.
Because of the lack of historical
information, this project involves
many unanswered questions and addi-
tional risks. Planning has attempt-
ed, without success, to minimize all
of these problems while maximizing
uses for steam that exist over and
above demand, potential Federal and
state assistance, and relations with
haulers and surrounding municipal-
ities. The following list of ques-
tions is presented first to show that
St. John's is undertaking this pro-
ject with extreme caution; second, to
provide a list for others to consider
in their study of MCU's; and finally,
to emphasize numerous elements St.
John's will be attempting to analyze/
describe/record once the equipment is
fired up and functioning.
Waste Stream
1. Will the Btu content be at the
national average? Will it be
uniform?
2. Will the quantities of waste
required always be available?
Will they arrive in a smooth
stream?
3. Will 5^ days of hauling be
sufficient to enable 7 days of
burning?
4. Will the noncombustible content
exceed expectations?
1-10
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Will there be unusual amounts of
corrosive substances? Will it
be possible for the operator to
recognize and eliminate them?
Wi 11 we regret
and/or have to
equipment later?
not separating
install such
Equipment
2.
3.
4.
5.
6.
7.
8.
9.
Will this incinerator with
waterwall and watertube boiler
be as durable as the BASIC
incinerators already in exist-
ence?
Will the preventive maintenance
program planned be sufficient or
will it require more shutdowns?
Will downtime for handling
crises exceed our estimates?
Will the efficiency rating of
the boiler and the Btu require-
ments of the furnace prove
reliable?
Will the steam
steady enough
generation?
production be
for electrical
Will auxiliary fuel requirements
exceed expectations?
Will glass slagging plague us?
If the front-end loaders are
"the weakest link," will two be
able to provide uninterrupted
service?
Since this is the first BASIC
Modular Combustion Unit dedi-
cated strictly to solid waste,
will it meet MPCA standards?
10. Will internal and external ash
removal elements perform in
harmony with and with the same
efficiency as the remainder of
the unit?
Building
1. Will the tipping floor be large
enough to handle the 7-day burn
volume, if average Btu content
of the waste is dramatically
below the quoted national aver-
age of 4500 Btu/lb?
Ash Disposal
I. Will ash require sanitary land-
fill?
2. Will weight and/or volume of the
ash exceed expectations?
Governmental Regulations
1. Will future regulations
more restrictive? Will
retroactive?
be even
they be
2. Will restrictions be placed on
the waste stream? How will such
regulations affect the Btu
content?
3. Will state-imposed district or
regional arrangements interfere
with the assurances present in
the Stearns County Solid Waste
Plan?
Financial Feasibility
1. Will usable steam calculations
hold true?
2. Will coal boilers have to be
idling more than planned?
3. Will inflating coal costs actu-
ally prove to be 3 percent above
the quoted inflation rates of
the future?
1-11
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4. Will the tipping fee used
calculations be acceptable?
CONCLUSION
In spite of these risks, St. John's
University is still taking this step
because it appears feasible and
advantageous from an economic view-
point. The St. John's community is
willing to take this step because it
is evidence of what the community
preaches: energy conservation^
simple lifestyle, and stewardship.
It points to dedication to education,
introduces and demonstrates to the
region that such technological possi-
bilities can be useful in many more
places, raises the level of energy
consciousness in the county and
state, impacts a campaign for source
separation as the only feasible
resource recycling approach available
to those living in predominantly
rural areas, takes, a research stance
with this project to be involved in
developing this technology to its
fullest, and makes use of savings to
enable the institution to be more
competitive.
Finally, this project demonstrates
the service orientation of the people
at St. John's to the county, by
providing relief from its current
landfill dilemma; to citizens, by
offering from a private source what
previously had been planned as a
tax-supported public venture; to
users, by providing a more stable,
less costly, long-term solution for
handling solid wastes; and to inter-
ested agencies, corporations, and
individuals, by attempting a pilot
project with available information
and consulting assistance.
It will be interesting to track this
project through its last months of
fabrication, construction, startup,
and testing; to check back as St.
John's verifies the data that of
necessity had to be estimated; to
witness the working out of the risks;
and to visit the site and operation
once operations are under way.
The following tables show capital
expenditures and operating budget for
this project.
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CAPITAL EXPENDITURES AS OF 10/28/80
Construction costs:
Building and equipment
Site improvement
Utility connections
Architectural and engineering costs
Legal and administrative
Interest during construction
Project contingency (2%)
$2,033,457
129,472
75,000
$2,237,929
$ 200,000
22,000
56,000
22,000
$2,537,929
OPERATING BUDGET OF INCINERATOR PLANT
Process equipment maintenance
Power plant connections maintenance
Instrumentation maintenance
Utility maintenance
Scale maintenance
Building and grounds
Auxiliary fuel
Rol 1 ing equipment
Insurance
Ash disposal
Labor
40 operators
Fringes
HUD loan repayment
$ 30,000
4,000
1,500
2,100
1,000
3,600
50,000
18,000
2,500
25,000
60,000
7,600
64,800
$ 270,100
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LEGAL ISSUES IN HAZARDOUS WASTE MANAGEMENT
AFFECTING COLLEGES AND UNIVERSITIES
Helen Madsen
Colleges and universities should become familiar with laws and regulations
concerning the generation of hazardous wastes at their facilities. These
institutions should be aware of petitioning procedures that must be followed
in regard to wastes generated on site. Provisions should be noted of any law
enabling the Environmental Protection Agency to grant exemptions and
variances.
APPLICABLE STATE AND FEDERAL LAWS
AND REGULATIONS CONCERNING HAZARD-
OUS WASTE MANAGEMENT
First, you should be familiar with
the laws and regulations that apply
to hazardous waste management at your
institution. Determine if you are
dealing only with state laws or both
state and Federal laws. Be aware
that your state may already have or
soon will have a hazardous waste
management act. For example,
Illinois already has regulations.
You should become generally familiar
with state statutes. There may or
may not be one designed to implement
the minimum requirements of the
Federal Resource Conservation and
Recovery Act (RCRA) of 1976. For
example, a Wisconsin statute (sec.
144.60 ff., Wis. Stats., effective
May 21, 1978) provides that all
persons (person means owner or opera-
tor, corporation, association, or
state agency) who store, transport,
treat, or dispose of hazardous wastes
must obtain a license from the
Department of Natural Resources.
You should pay particular attention
to provisions of any such law regard-
ing powers of the Environmental
Protection Agency (EPA) to grant
exemptions and variances (sees.
144.62(5) and 144.64(b), Wis. Stats.)
because you may have to consider
applying for relief from the most
stringent provisions of the state law
or regulations.
You need to find out whether your
state already does or shortly will
have a hazardous waste management
program that qualifies for interim
authorization from EPA. If so, in
Ms. Madsen is Assistant Director of
the Office of Administrative Legal
Services at the University of
Wisconsin-Madison. Her experience
includes private general practice in
several states and service as an
attorney to the Naval Ship Systems
Command. She holds an A.B. from
Mount Holyoke College, and a J.D.
from Cornell Law School.
1-14
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the long run (after the next 6 to 10
months) you will be dealing primarily
with state environmental protection
authorities who will be implementing
the Federal hazardous waste manage-
ment regulations. In the short run
(over the next 6 to 10 months) you
probably will be dealing with both
state and Federal agencies.
If your state does not anticipate
receiving early (by the end of 1980)
interim authorization for its pro-
gram, it will be entering into a
cooperative arrangement with EPA that
specifies the respective responsibil-
ities of Federal and state author-
ities until authorization of the
state program. If you are in one of
these states, you or your institu-
tion's attorney should try to obtain
a copy of the cooperative agreement.
Institutions in these states should
continue to deal with both state and
Federal agencies until EPA author-
ization is obtained; such an arrange-
ment may involve considerable over-
lapping of enforcement and reporting.
AVOIDING DISCLOSURE TO EPA OF UNPUB-
LISHED RESEARCH DATA
As a second issue, you should be
aware of potential problems under the
Code of Federal Regulations (CFR)
regarding disclosure of unpublished
research data (see 40 CFR sec. 260.2,
40 CFR sec. 2.203 and sec. 2.208 ff).
For example, when dealing with a
waste that is not listed as hazardous
but that may have one of the four
hazardous characteristics (ignitabil-
ity, corrosivity, reactivity, and
extraction procedure toxicity), an
institution must decide what records
will be kept as evidence of the
determination of whether the waste is
hazardous. The institution must also
decide who will keep such records.
You will need to obtain waste and
test records or other information,
such as scientific references, to'
establish the characteristics of the
waste (see 40 CFR sec. 262.11, p.
33143, May 19, 1980). In some cases,
the institution may decide to have
the researcher keep such records.
As you may know, college and univer-
sity researchers are quite reluctant
to disclose any information or data
regarding their research prior to
publication in a scholarly journal or
book. Most university researchers
believe that a scientist should not
be compelled to disclose the results
of his/her research until the scien-
tist is satisfied as to the accuracy,
reliability, and therefore the scien-
tific significance of the data. The
decision to publish and the accept-
ance for publication after peer
review are the best indication of the
accuracy of the raw research data.
Furthermore, research data often are
owned by the researcher and not the
university. I suspect that all of
your institutions have strong poli-
cies supporting the scientist's
position on nondisclosure and his or
her rights to the data.
Therefore, if you anticipate having
researchers keep records for the
purposes of your hazardous waste
management program, I believe you
should urge the researchers to keep
the hazardous waste records physical-
ly separate and distinct from their
research data. As a participant in
the hazardous waste management pro-
gram, the professor will be acting as
an authorized university official
implementing a program and not as a
scientific researcher. If records on
hazardous waste are kept in lab
notebooks where research data are
also kept, there is risk of disclo-
sure of the research data to the
government and therefore ultimately
to the public. By keeping these data
1-15
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together, at the very least you run a
clear risk of a dispute with the
government auditors over what can or
cannot be released or disclosed to
them.
The Federal Freedom of Information
Act (FOIA) requires the Federal
Government to make available to the
public, upon request, any information
in the Government's possession,
unless the information comes within
certain narrow exceptions, e.g.,
business confidentiality. The EPA
Hazardous Waste Regulations (40 CFR
sec. 260.2) provide that any such
information provided to EPA will be
made public unless a claim of busi-
ness confidentiality is asserted.
Once that claim is asserted, however,
Government lawyers, not your univer-
sity, must decide what is confiden-
tial. I suggest that you avoid
complicated legal issues regarding
what is confidential research infor-
mation under the FOIA by keeping
research data physically separate
from hazardous waste records. If
this is done, your university and its
researchers may be saved valuable
time in trying to resolve legal
issues with the Federal Government on
nondisclosure of research data.
ONSITE AND OFFSITE TRANSPORTATION AND
DISPOSAL OF HAZARDOUS WASTES AS
DEFINED IN THE REGULATIONS
Onsite is defined as contiguous
property (properties that border on
one another) owned by a college or
university, which may be divided by a
public or private right-of-way where
access is only by crossing, or non-
contiguous property connected by a
private right-of-way to which the
public has no access (see 40 CFR sec.
260.10(48), p. 33075, May 19, 1980
Fed. Reg.). Offsite is defined as
movement of hazardous wastes along,
as opposed to across, a public
right-of-way.
If it is possible to transport and
treat or dispose of your hazardous
waste onsite (and this may be pos-
sible for institutions that are small
in size, or not geographically spread
out, or for those moving hazardous
wastes only a short distance), then
you need not use the manifest system
described in 40 CFR Part 263.
If you transport, treat, and dispose
of hazardous waste onsite, you must
obtain an EPA identification number
for your facility, keep records of
test results for 3 years, and follow
Part 264 or 265 of the regulations
for treatment or disposal facilities,
which includes knowing amounts,
assuring proper disposal, and insti-
tuting certain detailed safeguards in
the event of emergencies and to
prevent accidents.
REQUIREMENTS FOR DISPOSAL OF HAZARD-
OUS PESTICIDE WASTES AT INSTITUTIONS
WITH FARMS (see 40 CFR sec. 262.51)
The farmer must rinse containers
three times and comply with disposal
instructions on the pesticide labels.
HOW TO AVOID BECOMING A STORAGE
FACILITY IF YOUR INSTITUTION IS A
GENERATOR OF HAZARDOUS WASTE BUT HAS
LITTLE OR NO ONSITE DISPOSAL
Any generator of hazardous wastes
that accumulates those wastes for
more than 90 days is treated as the
operator of a storage facility and
must meet the expensive provisions of
40 CFR Part 264 or 265 (how to store
safely) and become a licensed storage
facility under Part 122.
1-16
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Your institution can avoid becoming a
storage facility by adhering to the
following:
Ship all hazardous waste offsite
within 90 days after it starts
to accumulate.
Mark on the container the date
the hazardous wastes starts to
accumulate for purposes of the
90-day period.
Place the waste in containers or
tanks that comply with the regu-
lations.
Label and mark each container
according to 40 CFR sees. 262.31
and 262.32 (in accordance with
U.S. Department of Transporta-
tion (DOT) regulations)
Comply with the preparedness and
prevention procedures (40 CFR
sees. 265.30 through 265.37),
contingency plan and emergency
procedures (sees. 265.50 through
265.57), and personnel training
provisions (sec. 265.16).
(Also, see 40 CFR sec. 262.34.)
PROCEDURES AVAILABLE TO INSTITUTIONS
SEEKING EXCEPTIONS TO OR CHANGES IN
THE FEDERAL REGULATIONS
First, you may petition that a par-
ticular waste at an individual facil-
ity be excluded from the lists of
hazardous wastes given in 40 CFR sec.
261.30 or 261.33 on the grounds that
the waste is not hazardous to human
health or the environment as it is
handled in your facility. You may
also use this petition to exclude a
waste from the definition of a haz-
ardous waste, even though it has been
so defined as a result of the mixing
of a solid waste with a hazardous
waste (see sec. 261.3 on definition
of hazardous wastes). The basic
procedural steps are:
The facility makes a petition to
EPA.
Through sampling and testing, it
is proven that the waste does
not meet the criteria for being
listed as a hazardous waste or
as having any hazardous waste
characteristics.
The Administrator of EPA makes a
tentative decision, publishes it
in the Federal Register, and
gives to any interested person
requesting it an informal hear-
ing on the petition.
A final decision is issued after
any such hearing.
The full burden of obtaining an
exclusion is on the generator or
disposal facility. If chemical
wastes are being generated on a
recurring basis, your institution
should consider this procedure to
exclude wastes. (See 40 CFR sec.
260.22.)
A second procedure for seeking excep-
tions is to petition for equivalent
testing or analytical methods.
Testing is required of generators and
disposal facilities under Parts 261,
264, and 265. You may decide that a
less-expensive alternative testing
method performs as well as the speci-
fied test. Sections 260.20 and
260.21 provide a method to petition
for the approval of your alternate
testing method. Again the clear
burden of proof is on the petitioner.
A third way to seek an exception is
under the general rulemaking petition
provision (40 CFR sec. 260.20, p.
33076, May 19, 1980 Fed. Reg.). This
provision allows anyone to petition
1-17
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for a change in any provision in
Parts 260 through 265 of the regula-
tions.
The petitioner must demonstrate the
need and justification for the pro-
posed action. Most likely such a
procedure would be too time-consuming
and expensive for one institution to
undertake; however, I urge your
institution to send any serious
concerns you have with the regula-
tions to the American Council on
Education (ACE). If many institu-
tions of higher education have the
same concern, a petition for regula-
tory change or an interpretation
could be instituted by ACE.
Finally, the comments to the Federal
Register (Part 261 p. 33088-9, May
19, 1980) states that EPA wishes to
be informed of situations in which
strict application of the regulations
has unintended results. I assume a
letter to EPA would satisfy this
request. If you write such a letter,
send a copy of it to ACE in Washing-
ton. In appropriate cases, EPA would
react to problems by providing regu-
latory amendments, interpretive
guidance, and reasonable implementa-
tion and enforcement procedures.
KINDS OF ENFORCEMENT PROCEDURES AND
LEGAL REMEDIES AVAILABLE TO EPA AND
STATE ENVIRONMENTAL PROTECTION AGEN-
CIES SEEKING COMPLIANCE
The Federal Resource Conservation and
Recovery Act (RCRA) states that EPA
may take administrative action to
enforce the Act. The Administrator
issues a notice to the violator, who
then has 30 days to comply with
conditions specified in the notice.
If the notice is not obeyed, the
Administrator issues a compliance
order or asks the U.S. Attorney to
sue the violator in Federal District
Court. The Administrator must give
notice to the state (in cases involv-
ing an EPA-authorized program) 30
days prior to issuing the order. The
violator must comply within the time
given or seek an adminstrative hear-
ing within 30 days to explain its
position on why the order is not
appropriate. The Act provides for a
civil penalty of up to $25,000 per
day for each violation. Any facility
determined a violator could lose any
permit issued by the EPA or state
environmental protection agency.
The Act also provides for criminal
penalties. It is an offense to know-
ingly do the following:
Transport hazardous waste to a
facility that does not have a
Federal or state permit.
Dispose of hazardous
without a permit.
waste
Make false statement or repre-
sentation on a manifest, record,
or permit application.
penalty is up to $25,000 per day
each violation, or imprisonment
up to 1 year, or both. The U.S.
Attorney would institute any criminal
action in Federal court.
The penalty
for
to
You should consult your state law for
enforcement procedures available to
your state agency. (For example, the
remedies and penalties in sec.
144.73, Wis. Stats., parallel those
in the Federal act.)
FINANCIAL RESPONSIBILITY REQUIRE-
MENTS
Federal hazardous waste regulations
(as proposed in 40 CFR sec. 265.140
ff., p. 33260, May 19, 1980 Fed.
Reg.) provide financial responsibil-
ity requirements for owners and
operators of facilities that treat,
store, or dispose of hazardous
1-18
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wastes. Storage is defined as hold-
ing in a tank, container, waste pile,
or surface impoundment. Treatment is
defined as incineration or chemical,
thermal, or other physical treatment
(p. 33228, May 19, 1980, Federal
Register). Disposal is defined as
underground injection, landfill, or
land treatment. (These are not final
regulations; the comment period is
unti 1
July 18, 1980.)
Section 265.1 states that the finan-
cial requirements apply to all owners
and operators who have complied
reauirements for interim st;
with
interim status.
will apply when
yuui suctLt; receives an authorized
hazardous waste program.
The Federal statute provides that you
Can Obtain interim ctatnc fho a
requirements for
State requirements
your state
interim
licensed facility)
three requirements:
status (be a
by fulfilling
3.
Own and operate a facility
that was in existence on
October 21, 1976.
By August 18, 1980, file a
preliminary notification
with EPA; state that you
are an owner or operator of
a treatment, storage, or
disposal facility for
hazardous wastes, give the
location and a general
description of your activi-
ties, and state the identi-
fied or listed hazardous
wastes handled by your
institution.
Make an application to EPA
for a permit.
Once you have interim status as a
licensed facility, under the proposed
regulations your institution must
provide financial assurance for the
eventual closure of your facility.
If you are a disposal facility, you
must also provide financial assurance
for post-closure monitoring and
maintenance.
If you have no landfill or land
treatment procedure, but either store
(hold over 90 days) or treat hazard-
ous waste (e.g., incinerate hazardous
wastes), then only sec. 265.143
applies. Under the proposed regula-
tions, you must do one of the follow-
ing:
Provide a closure trust fund
with a bank or other financial
institution.
Provide a surety bond guarantee-
ing performance of closure.
Provide a standby letter of
credit assuring funds for clo-
sure.
Provide more than one type of
financial instrument.
Meet a financial test for clo-
sure, e.g., at least $10 million
in net worth.
If you are a municipality, meet
a revenue test.
For those of you who represent state
institutions, the proposed regula-
tions do not specify financial re-
sponsibility, but the comments say
that where a state assumes legal or
financial responsibility for closure
or liability coverage for the facil-
ity, the owner or operator would be
exempt from Federal financial re-
quirements. Your state institution,
as part of the state, is most likely
legally and financially covered for
any possible closure of your hazard-
ous wastes facility.
You may wish to discuss this matter
with your institution's risk manager
so that he or she can become aware of
the new potential liabilities.
1-19
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FEDERAL HAZARDOUS WASTE REGULATIONS AS THEY APPLY TO
COLLEGES AND UNIVERSITIES
Eugene Meyer
On May 19, 1980, the Environmental Protection Agency promulgated a complex set
of regulations under the provisions of the 1976 Resource Conservation and
Recovery Act (RCRA) passed by the U.S. Congress. These regulations establish
"cradle-to-grave" control over the generation, transportation, and disposal of
hazardous waste. This article reviews how these regulations apply to the
hazardous waste practices at colleges and universities that generate large
amounts of such waste.
Each year colleges and universitites
generate significant amounts of
hazardous waste. For decades these
wastes probably have been discarded
in the same careless fashion as those
in the various manufacturing and
processing industries—often just
dumped in quarries, nearby waterways,
and local landfills. The results of
such improper disposal of hazardous
wastes are now becoming evident in
every sector of our Nation. Public
drinking water supplies and irre-
placeable aquifers have been de-
stroyed, surface waters have been
rendered unusable, fires and explo-
sions have threatened whole communi-
ties, and the health and safety of
untold numbers of people have been
threatened by exposure to pollutants
in our air, soil, and water.
The U.S. Environmental Protection
Agency (EPA) has recently initiated a
major program that aims to rectify
this untenable state of affairs. On
May 19, 1980, EPA promulgated a
complex set of regulations under the
provisions of the 1976 Resource
Conservation and Recovery Act (RCRA)
passed by the U.S. Congress. These
regulations establish "cradle-to-
grave" control over the generation,
transportation, and disposal of
hazardous waste. Such control is
accomplished by imposing recordkeep-
ing and reporting requirements on
generators and transporters of haz-
ardous waste, establishing a manifest
system to track shipments of hazard-
using proper labels
The regulations
that the waste be
properly permitted
storage, and disposal
The intent of Congress
ous wastes, and
and containers.
further require
delivered to
treatment,
facilities.
is to require industry to change its
Dr. Meyer is a Regional Expert on
hazardous waste management with U.S.
EPA Region V. He formerly served as
Professor of Chemistry and Chairman
of the Division of Natural Sciences
at Lewis University. His publica-
tions include a text on the chemistry
of hazardous materials. He holds a
Ph.D. from Florida State University
and has done postdoctoral work at the
Institute for Nuclear Physics
Research in Amsterdam.
1-20
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bad practices and to insure the safe
management of hazardous waste with a
minimum amount of economic disrup-
tion. The Act does not specify
industry alone, however; all genera-
tors, transporters, disposers, or
treaters of hazardous waste are
affected by the regulations. The
purpose of this article is to review
how these regulations apply to haz-
ardous waste practices at colleges
and universities.
The first question we need to ask is:
Does a specific college or university
generate hazardous waste? The answer
to this question depends upon several
factors. Let's first examine what
EPA means by a solid waste. The
Agency defines solid waste as any
garbage, refuse, sludge, or other
waste material. The last category
includes any solid, liquid, semi-
solid, or contained gaseous material
resulting from industrial, commer-
cial, mining, agricultural, or com-
munity activities that is discarded
or is being accumulated, stored, or
physically, chemically, or biolog-
ically treated prior to being dis-
carded; or is sometimes discarded
after having served its original
intended use; or is a manufacturing
or mining by-product that is some-
times discarded. The Agency also
excludes the following materials from
the solid waste classification:
domestic sewage, wastes that mix with
domestic sewage in a sewer system
before entering a publicly owned
treatment works; industrial waste-
water discharged from point sources
that are subject to regulation under
the Clean Water Act; and source,
special, nuclear, or by-product
materials defined by the Atomic
Energy Act of 1954.
Once a college or university decides
that it is a generator of solid
waste, the next step is to determine
whether that waste is hazardous under
the RCRA regulations. This can be
done by one of three procedures.
First, the generator may simply
proclaim the solid waste to be haz-
ardous; this might be done if the
generator believes the waste is
likely to substantially endanger
human health and the environment.
Second, the college or university may
test a representative sample of the
waste to determine if it exhibits any
of the characteristics that EPA has
defined as belonging to a hazardous
waste; that is, is the waste ignit-
able, corrosive, chemically reactive,
or EP toxic (based on extraction
procedure)? These features of a
solid waste are discussed in the
following paragraphs.
Ignitability
A solid waste is considered
ignitable if it is (1) a liquid
with a flash point of less than
60°C (excluding solutions con-
taining less than 24 percent
alcohol by volume); (2) capable
under standard temperature and
pressure of causing fire through
friction, absorption of mois-
ture, or spontaneous chemical
changes, and when ignited, burns
so vigorously and persistently
that it causes a hazard; (3) an
ignitable compressed gas; or (4)
a strong oxidizer.
Corrosivity
A solid waste is corrosive if it
is aqueous and has a pH less
than or equal to 2, or greater
than or equal "to 12.5; or is a
liquid and corrodes steel at a
rate greater than 6.35 mm per
year at a test temperature of
55°C.
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Chemical Reactivity
A solid waste is considered
chemically reactive if it is
normally unstable and readily
undergoes violent changes with-
out detonating; reacts violently
with water; forms potentially
explosive mixtures with water;
generates toxic gases, vapors,
or fumes when mixed with water
in a quantity sufficient to
present a danger to human health
or the environment; contains
cyanide or sulfide in a suffi-
cient quantity to generate
harmful gases when exposed to pH
conditions between 2 and 12.5;
is capable of detonation or
explosive reaction when exposed
to a strong initiating source or
heated under confinement; or is
readily capable of detonation or
explosive decomposition or
reaction at standard tempera-
tures and pressures.
EP Toxicity
The toxicity of solid wastes is
evaluated by using an extraction
procedure (EP) developed by EPA
and designed to identify wastes
that, if improperly managed, are
likely to leach hazardous con-
centrations of 14 toxic constit-
uents into the groundwater.
These contaminants are arsenic,
barium, cadmium, chromium, lead,
mercury, selenium, silver,
endrin, lindane, methoxychlor,
toxaphene, 2,4-D, and 2,4,5-TP
si 1 vex. A solid waste is con-
sidered EP toxic if the concen-
tration of any of these contam-
inants in a waste sample exceeds
100 times the levels specified
in the drinking water regula-
tions.
The third procedure by which a col-
lege or university may establish
whether or not their waste is classi-
fied as hazardous by the RCRA regula-
tions is to determine if the waste
contains any of the 745 substances
the EPA lists as hazardous. The
first of the four lists of hazardous
substances covers 16 types of hazard-
ous waste generated from nonspecific
sources and includes such wastes as
spent plating bath solutions from
electroplating operations. The
second list covers 69 wastes from
specific industries; 22 entries are
under the organic chemistry industry
alone, and include such processes as
the centrifuge residue from toluene
diisocyanate production and distilla-
tion bottoms from the production of
nitrobenzene. The remaining two
lists are more extensive and more
generally applicable. One includes
the generic name (and tradename, when
known) of certain substances that the
EPA has designated as acutely hazard-
ous; the other covers 239 substances
that are considered toxic.
An important facet of the regulations
as they apply to colleges and univer-
sities is the small-quantity exclu-
sions. Those generators that produce
a total of less than 1000 kg (2200
Ib) in any calendar month do not need
to notify the EPA of their activities
concerning hazardous wastes; that is,
only those generators that accumulate
greater than 1000 kg of hazardous
waste are subject to regulation. The
generator must ensure, however, that
the hazardous waste is disposed of at
facilities the State has approved for
the handling of municipal or indus-
trial wastes. Furthermore, small
generators must also comply with the
hazardous waste regulations if they
accumulate more than 1 kg of any of
the substances listed as acutely
hazardous.
1-22
-------
Because small generators are exempt
from the regulations, RCRA will not
apply to about 91 percent of the
hazardous waste producers in this
Nation. This 91 percent includes
numerous small businesses, such as
gas stations and many of the small
colleges and universities who create
only 1 percent of the waste targeted
to be covered by these regulations.
Although environmental protection
groups have criticized the EPA for
this small generator exemption, the
EPA believes it is in the best inter-
ests of this program to apply the
limited resources to the control of
the large producers, who create 99
percent of the hazardous waste prob-
lem. This approach allows the
Federal government to concentrate its
control efforts where they will be
most effective.
Under the RCRA regulations, all
applicable generators, transporters,
or receivers of hazardous waste must
notify EPA before August 19, 1980,
that they are engaged in such activ-
ities. After receiving notification,
EPA assigns an identification number
to the notifier; and after November
19, 1980, only those parties with an
EPA identification number can legally
continue hazardous waste operations.
Let us suppose that a college or
university decides that it does gen-
erate hazardous waste. When a prop-
erly authorized generator of hazard-
ous waste ships that waste off the
college property to a disposal facil-
ity, the generator incurs further
responsibility. The generator must
first designate an approved facility
to which the waste will go; must
contract with an authorized trans-
porter to take it there; and perhaps
most important, must initiate a
manifest tracking system that will
keep recorded tabs on every stage of
the waste's journey to its destina-
tion. The transporter and the re-
ceiving treatment or disposal facil-
ity are then required to sign th'e
manifest and return the signed copy
to the generator.
At a miaimum, the manifest must
contain the following information:
name and address of the generator;
names of all transporters to be used
in shipment of the hazardous waste;
name and address of the permitted
facility designated to receive the
waste; EPA identification numbers
assigned to all who handle the waste;
U.S. Department of Transportation
description of the waste; quantity of
the waste shipped and number of
containers; and the generator's
signature certifying that the waste
has been properly labeled, marked,
and packaged in accordance with
applicable regulations.
Under this system, generators now
assume major new responsibilities
pertaining to the whereabouts of
wastes leaving their facilities. If
the generator does not receive a
signed manifest from the waste
receiver within a specified period,
the generator must then inform EPA.
Similarly, the generator must notify
EPA when the manifest system detects
waste missing from any shipment. All
of the transporters of hazardous
waste have been supplied with
emergency-response center phone
numbers, which they must call in case
of an accidental discharge of a
hazardous waste during shipment.
Under the regulations, the trans-
porters are responsible for cleaning
up any spill or leakage of wastes
occurring during shipment.
The manifest tracking and response
regulations should give EPA a broad
idea of where hazardous wastes are
being disposed of. For the first
time, we will know how much waste
1-23
-------
there is, where it is going, what is
being done with it, and what portions
are missing or spilled.
The last phase of the regulatory
system sets standards for facilities
permitted to treat, store, or dispose
of hazardous wastes. These facili-
ties, whether they are located on the
generator's site or not, are required
to comply with operating standards
covering proper safety measures, to
develop emergency procedures, to
monitor and train employees, to
assume long-term financial respon-
sibility, and to participate in the
manifest system. These facilities
will also be required to obtain
permits based on the latest techno-
logical advances in waste treatment
management. Facilities that fail to
meet these requirements will either
be closed down or not be permitted to
open. At the beginning of the new
regulatory program, existing treat-
ment, storage, and disposal facil-
ities may receive interim permission
to continue operations pending review
of their permit applications. These
facilities will be obliged to comply
with certain operating standards
during their continuation in the
interim status. Because of the
number of sites involved, the process
of issuing permits will take time;
priority is to be given to review of
the applications of new hazardous
waste facilities.
We all recognize the unprecedentedly
high standard of living of our pres-
ent society, which is based consider-
ably upon chemical technology. The
EPA is not calling for the disman-
tling of industries or the stoppage
of research involving hazardous
materials; however, we are beginning
to recognize the various difficulties
involved in proper disposal of the
by-products of modern technology.
Thus, we have been forced by tragic
events such as that at Love Canal to
look seriously at our handling of
hazardous wastes. The outlook is
good for effective management of
these wastes, given the support of
state and local governments, indus-
try, environmental groups, and the
general public. These regulations
should be regarded as the first step
of a framework for a sound national
program for the control of hazardous
wastes.
1-24
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SESSION 2
CHEMICAL WASTE MANAGEMENT
INTRODUCTION TO SESSION ON
CHEMICAL WASTE MANAGEMENT
John F. Meister
In yesterday's sessions we learned
about the Resource Conservation and
Recovery Act (RCRA) and various other
regulations and how they pertain to
solid waste disposal and in partic-
ular about how they affect colleges
and universities. We also learned
about some of the innovative methods
that universities are using to re-
cycle materials and recover energy
from their solid waste. These meth-
ods can generate income, reduce
operating costs, and generally bene-
fit the university in the long run.
Now we want to shift our emphasis
within the field of university waste
management to the topic of "hazard-
ous" waste disposal. Hazardous
wastes are those wastes generated
from a variety of academic and opera-
tional areas within the university
that require special attention. They
are not glamorous, nor are they
generally considered capable of being
recycled, generating an income, or
providing energy. They are wastes
that all of us wish would just go
away, but don't. They are wastes
that no one wants—the university
(generator), the community, or our
society. We have no choice, however,
but to deal with them because they
are real and very present. What are
they? They are the chemical, radio-
active, medical, and research wastes
generated in the everyday activities
of a university.
Specifically, we want to look at the
topic of chemical wastes. First, we
should define chemical wastes and
place them in their position within
the overall galaxy of solid wastes.
As the name implies, chemical wastes
differ from conventional solid wastes
(e.g., paper, garbage, and packing
materials). Chemical -wastes are
primarily generated in academic
laboratories and classrooms, but are
also produced in other areas such as
the Physical Plant. They include
small bottles of old laboratory
chemicals, containers of waste paint
shop and solvents, and drums of
water-conditioning chemicals used for
corrosion control in the steam plant.
In another perspective,
wastes that Subsection C
ous waste regulations)
gated to control.
they are the
(the hazard-
was promul-
Why should we be concerned with the
proper management with these wastes?
The disposal of chemical wastes or
rather their improper disposal has
added a new lexicon of terms to our
national vocabulary—polychlorinated
biphenyl (PCB), Love Canal, dioxin,
kepone. Worse still, the improper
disposal of chemical wastes has added
a new perspective to the concept of
national disaster. On August 7,
Mr. Meister is Director of Pollution
Control with Southern Illinois Uni-
versity at Carbondale.
2-1
-------
1978, President Carter declared a
"national disaster" at Love Canal,
New York, in response to the conse-
quences of the chemical wastes buried
there many years ago. Since then, we
have learned almost monthly of other
abandoned dump sites leaking or
threatening to leak hazardous materi-
als into the environment. Names such
as Love Canal, Valley of the Drums,
West Memphis, and Wilsonville have
been etched into our consciousness.
Other incidents such as the contami-
nation of cattle feed in Michigan
with polybrominated biphenyl (PBB),
PCB contamination of food products in
the Rocky Mountain States last
summer, and improper motor oil dis-
posal that killed racehorses in
Missouri remind us that chemical
wastes can have a great and long-
lasting impact on our environment.
Many of these incidents involved
chemicals improperly disposed of many
years ago, but only now are the
consequences being manifested.
Estimates indicate that roughly 90
percent of all hazardous-toxic wastes
produced in this country are improp-
erly disposed of. Very few, of the
many thousands of public waste dumps
have been inventoried as to their
present threat. No one knows how
many other dumps exist on private
property.
We have been told that life would be
impossible without chemicals. Al-
though the lifestyle that we have
developed in the past 30 years de-
pends on products of the petrochemi-
cal and chemical industries, it bears
testimony not that life would be
impossible without chemicals, but
that we enjoy life much more because
of them. Yet these same chemicals,
when indiscriminately disposed of,
cause many of our environmental
problems.
Why did the hazardous waste problem
develop only recently? One reason
was that the chemicals were new to
mankind. The chemical industry was
not aware of potential health effects
associated with their use and dis-
posal, nor were there regulations
requiring health tests to be made on
the effects of long-term exposure to
such chemicals before their manufac-
ture or use. Many adverse health
effects were not evident for years
because of the long latency period of
some chemicals. Other chemicals
showed harmful effects only after
many years of exposure.
Another reason was that only until
recently, nobody was aware that these
chemicals had become so pervasive in
the environment, and were contami-
nating soil and drinking water sup-
plies. Industry had no precedent for
dealing with such chemicals, and the
state-of-the-art method of disposal
was placing waste in lagoons and open
dumps, because land was plentiful and
cheap. At the very best, putting
chemical wastes and byproducts in
55-gallon metal drums before placing
them into the ground was considered
adequate protection. In addition,
because disposal of wastes was a cost
burden, unscrupulous individuals took
advantage of the situation and of-
fered to dispose of the wastes at a
very low cost. These "midnight
dumpers" disposed of wastes in any
way possible, such as dumping them
into rivers and sewers and pouring
them on farmers' fields.
Contamination was not evident for a
long time. The wastes remained only
briefly where they initially were
dumped because, as geology has shown,
the land is often not as solid or
stable as it appears. Also, when
water passed over or mixed with
wastes, leachates containing the
chemicals were created. These
2-2
-------
leachates eventually reached streams,
lakes, and underground drinking water
supplies, and all life forms that
used the water were exposed to the
chemicals. Only in the past decade
has the scientific community had the
analytical tools (e.g., atomic
adsorption and gas-liquid chromatog-
raphy) to detect the presence of
these chemical wastes. Many studies
have now shown their presence and
effects throughout the ecosystem.
Mercury has been detected in fish and
birds from lakes with no industries
located nearby, and other ecosystems
have died because of exposure to
toxic chemicals. Many humans have
become seriously ill or died from
using well water contaminated with
toxic elements such as arsenic and
cadmium leached from abandoned dump
sites miles away.
Awareness of the presence of these
wastes and their associated health
effects was an ecological bombshell
from whose effects we are still
reeling. At first, this awareness
was limited to the scientific commu-
nity; however, the discovery of
numerous abandoned dump sites
throughout the country has shown that
improper waste disposal was not an
isolated incident, but the general
rule.
We do not want to condemn the chemi-
cal industry and imply that all
environmental and health concerns
were ignored to minimize costs. Many
generators of chemical wastes were
truly unaware of the potential harm.
Very few people 20 to 30 years ago
could foresee the consequences of
waste disposal practices then consid-
ered adequate. As already stated, no
previous examples of chemical waste
disposal were available; nor were
there analytical instruments to
detect environmental contamination.
Further, many generators used methods
such as incineration and recycling to
dispose of their wastes. Again it
must be emphasized that land disposal
in unconfined dumps was the state-
of-the-art method of that era.
The public, however, now demands
cleanup of past dumps and control
over the future disposal of these
types of wastes. Congress has re-
sponded with passage of the Resource
Conservation and Recovery Act of
1976, which directs the U.S. Environ-
mental Protection Agency (EPA) to
develop regulations to control and
regulate hazardous waste disposal.
The present administration has also
responded by proposing special legis-
lation to establish a "superfund,"
which would be used to clean up
abandoned chemical dump sites.
How does all this relate to univer-
sity waste disposal? And why should
we as universities be concerned with
waste disposal practices? We are all
aware of the many chemicals and
chemical products that are used by
universities. Many chemicals in
their pure form are used in laborato-
ries and classrooms. Other chemical
products such as paints, sealers,
transformer fluids, water treatment
chemicals, and pesticides are used
throughout the institution. Many of
these are the same chemicals that
have caused environmental mishaps.
What happens to these chemicals and
chemical products? In years past,
only two disposal options were avail-
able to individual generators. They
could put wastes either down the sink
or in the garbage can. True, some
chemicals received special attention
because the generator was aware of
potential hazardous effects of im-
proper disposal, but this was the
exception. Even if an individual was
concerned, generally no alternatives
were available unless he himself
2-3
-------
disposed of the waste. Most re-
searchers and academicians considered
their jobs to be teaching and re-
search and were not concerned with
the operational aspects of cleanup
and disposal of generated wastes. On
the other hand, the operational staff
charged with such duties generally
looked for the cheapest disposal
alternatives because they did not
understand what they were disposing
of. Lack of communication between
the generator or user of laboratory
chemicals, who generally should have
been aware of their hazardous proper-
ties, and the disposal staff resulted
in the same situation as in the
industrial sector; the cheapest,
easiest \method of disposal was used
with little regard for environmental
effects. This is intended not as a
condemnation of academic and opera-
tional units, but as a description of
the situation that generally pre-
vailed at many universities.
Many examples of the results of
improper chemical waste disposal by
universities have been documented.
Specifically, I will refer to inci-
dents at SIU-C, which probably resem-
ble incidents elsewhere. Several
times after pickups of containers
full of bottles of old chemicals,
fires broke out in the garbage dis-
posal truck, probably as a result of
the bottles breaking and chemicals
interacting. Similarly, many fires
and small explosions would occur at
the landfill where chemical wastes
were indiscriminately dumped. When
the landfill equipment would smash
and break the containers, chemicals
would be allowed to mix and run over
and through the soil. Many chemicals
from containers with no labels were
arbitrarily poured together to save
space, and noxious fumes would
result. Periodically, the local
sewage treatment plant experienced an
"upset" or reduced efficiency with
the activated sludge treatment proc-
ess. Although these upsets were
never directly traced to the univer-
sity, they generally occurred at a
time when different academic depart-
ments were cleaning out old unneeded
chemicals. Many other examples could
be cited, and each university could
undoubtedly add its own version. It
is believed that the case for proper
university disposal of chemical
wastes is self-evident from the
preceding.
Congress has mandated that control
should be established over the dis-
posal of al1 hazardous wastes in the
United States. The EPA has responded
to this mandate by establishing
hazardous waste disposal regulations.
The obligations of the university are
not clear in these regulations. The
EPA admits that the regulations were
designed to apply to large industrial
generators and that universities were
not intended as primary targets;
however, the intent and goal are
clear. Universities that generate
hazardous waste will have to abide by
the regulations.
Universities use chemicals and dis-
pose of wastes just as industries do,
but in smaller quantities. The types
of chemical wastes produced by a
university, however, are limitless,
because each laboratory or department
uses different chemicals. Although
many chemicals are completely harm-
less, some are extremely toxic. Many
wastes are unknown products, as they
are products of chemical reactions in
classrooms or represent the contents
of old bottles no longer labeled.
Are universities generators and
subject to the new regulations? Is
it legal for universities to try to
treat some of their own wastes; or
must they secure a treatment site
permit? By listing each waste sepa-
rately could universities avoid being
2-4
-------
listed as generators through the
exemption clause? It is hoped that
this workshop will answer these
questions.
Because of the persistence and fore-
sight of certain individuals and
groups, many universities recognized
some time ago the need to establish
disposal programs. To learn from
their experiences, frustrations, and
successes is the purpose of these
papers. They have already gone
through many of the situations that
all of us will face sooner or later,
and together we can discuss the
operational aspects of a hazardous
waste program.
How do you establish a waste disposal
operation? How do you identify the
wastes that need special attention?
What are the realistic disposal
options? How do you sell the need
for this type of program, knowing its
successful administration will un-
doubtedly cost more than the present
disposal program?
academic staff to
a program? These
this session's
How do you get the
participate in such
are the issues that
papers have been
designed to address. The first paper
is a case study of the operation of a
hazardous waste program, the second
paper concerns the identification and
sources of wastes, and the third
paper deals with the subject of
disposal options. It is hoped that
all of us will learn something that
we can use in the establishment of a
working program at our respective
institutions.
Despite many specific questions
dealing with the regulations and
their applicability, one fact is
clear: chemical waste disposal will
be forever changed. The debate is
finished regarding whether or not
improper chemical waste disposal has
harmed us environmentally and whether
disposal should be controlled. The
resounding conclusions are "Yes!" and
"It will be controlled!" Consequent-
ly, it is believed that universities'
and similar institutions will have to
view chemical waste disposal in a new
perspective. No longer will they be
able to linger behind the "ivy-
covered walls" and in the "ivory
towers." They will have to recognize
that their wastes, although minimal,
are also part of the problem. Uni-
versity administrators, academic and
research personnel, and operational
staff must all work together to
prevent indiscriminate waste disposal
in the future. Education is needed
to apprise those who generate chemi-
cal wastes of the dangers of improper
disposal and to encourage the collec-
tion and separation of such wastes
from regular solid waste. Adminis-
trators need to be informed of the
legal requirements facing their
institutions and the costs of non-
compliance. Operational staffs need
to learn how to implement a workable
effective waste disposal program. It
is hoped that these papers will be a
first step in this process.
2-5
-------
INITIATION AND DEVELOPMENT OF
THE SIU-C HAZARDOUS WASTE PROGRAM
John F. Meister
PROGRAM CONCEPTION
Background and Justification
Southern Illinois University at
Carbondale (SIU-C) is a major univer-
sity of 22,000 students. It is
located in Carbondale, Illinois,
approximately 90 miles southeast of
St. Louis, Missouri. The university
currently offers approximately 100
undergraduate and 60 graduate
degrees.
In 1970 the university realized that
there was a need for a operational
department responsible for coordi-
nating university compliance with the
rapidly expanding environmental
regulations. Thus the university
established a Pollution Control (PC)
Department, which is involved in
university compliance in all environ-
mental fields. Table 1 lists the
objectives and full responsibilities
of the department, and Figure 1 shows
a breakdown of its various activi-
ties.
One of PC's specific responsibilities
is to review proposed and promulgated
environmental regulations. With the
passage of the Resource Conservation
and Recovery Act (RCRA) in 1976, PC
became aware of the need to evaluate
current university
disposal practices
posed standards. A
tion showed that
chemical waste
against the pro-
program existed and that the common
method of disposal was dumping wastes
down the drain or placing them in the
garbage can. Overall awareness of
the potential dangers of haphazard
disposal appeared to be lacking, and
no alternatives were available to
those few individuals who were con-
cerned about the dangers of chemical
disposal. Many examples of indis-
criminate disposal and their environ-
mental consequences were documented;
e.g., fires and explosions in the
garbage truck and/or the landfill,
upsets at the local sewage treatment
plant, explosions in sinks and store-
rooms, and the generation of noxious
fumes.
Following this investigation, PC
prepared a report, in the form of a
policy paper, for the SIU-C adminis-
tration. They briefed the admin-
istration on the RCRA Regulation and
on PC's findings regarding current
disposal practices. They also
pointed out the implications of the
current practices in that the Univer-
sity was in fact a generator of the
types of wastes the regulation was
designed to control. It was argued
quick investiga-
no centralized
Mr. Meister is Director of Pollution
Control with Southern Illinois Uni-
versity at Carbondale.
2-6
-------
TABLE 1. OBJECTIVES AND RESPONSIBILITIES OF THE
POLLUTION CONTROL DEPARTMENT AT
SOUTHERN ILLINOIS UNIVERSITY-CARBONDALE
1. To inform and advise the University Administration of all current and/or
potential environmental/pollution matters affecting the continued opera-
tion of SIU-C. To advise and help the Administration determine and
implement policy to insure that SIU-C does not violate existing or pro-
posed environmental standards and to establish SIU-C as a model of envi-
ronmental compliance and protection in the areas of air, water, and land
pollution.
2. To coordinate and prepare SIU-C responses to non-SIU-C regulatory bodies
regarding environmental matters and to serve as liaison to such regula-
tory bodies.
3. To coordinate and direct research into the sources and solutions of
environmental pollution at SIU-C and Southern Illinois. To supervise
ongoing laboratory monitoring of all discharges originating on campus to
determine if environmental standards are being violated.
4. To assist other operational and academic units of SIU-C regarding envi-
ronmental and pollution problems.
5. To train SIU-C students to serve as environmental scientists and engi-
neers by providing both advice and practical working experience with
real-life situations.
2-7
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f\3
CO
PUBLIC HEALTH
-Food inspections
-Pest control
-Complaints
-Miscellaneous
assistance
ADMINISTRATIVE
-Advisement to SIU-C administration
-Liaison to EPA and other regulatory agencies
Permits
Operational
-Environmental job training
Managerial
Technical
-Legal review of environmental regulations
-Coordination of Pollution Control programs
-Academic internships and practicums
-Literature review of pollution control
-Liaison to community on environmental matters
-Advisement to other SIU-C operations on envi-
ronmental matters
-Environmental awareness
-Grant preparation
_T
SOLID WASTE
-Resource recovery proj-
ects (recycling)
Operational
Feasibility studies
-Grant preparation
-Interaction and advise-
ment to local communities
-Interaction with regula-
tory agencies
-Literature review of
state of the art of
solid waste management
and resource recovery
-Compost and sludge
management
-Research
-Training
WATER RESOURCES ANALYSIS
-Operational
NPDES reports
Drinking water
T.O.N. wastewater treatment
Campus Lake
Sanitary storm sewers
Field monitoring
-Analytical lab
-Research
-Special projects
-Proposals, data management and
project reports
-Training
AIR MONITORING
-Ambient air quality
moni toring
-Weather station
-Pollution Control and
EPA joint projects
-Research
-Training
HAZARDOUS WASTE
-Response to SIU-C inci-
dents involving hazard-
ous wastes
-Storage of hazardous
wastes
-Disposal of hazardous
wastes
-Record keeping of haz-
ardous wastes
-Exchange (reuse) of
hazardous wastes
-Legal review of regula-
tions
-Research
-Training
Figure 1. Pollution Control Department at SIU-C.
-------
that the University, as a tax-
supported institution and supposedly
on the forefront of technology,
should set an example for others to
emulate. In summary, PC recommended
that a centralized chemical waste
disposal program be established.
Such a program would have several
objectives. The first would be to
control disposal practices of hazard-
ous wastes to eliminate environmental
contamination and/or human health
threats. Since the RCRA regulations
were not designed around University
operations, the second would be to
develop an established working pro-
gram that could serve as a role model
to provide guidance to the EPA and
others on how to apply the regula-
tions to a university situation.
Finally, such a program could provide
"hands-on" experience to students
interested in hazardous waste manage-
ment.
The administration took the recom-
mendation under consideration and,
after a brief review, decided that PC
should be allowed to proceed in the
development of such a program.
Because at that time there was no
legal mandate requiring such a pro-
gram at the university, however, the
administration felt that no addition-
al or new funds could be allocated to
such a program. In essence, PC was
given approval but no support.
University Reaction
After reviewing its internal objec-
tives and goals, PC decided to pro-
ceed with the development of a haz-
ardous waste program. The potential
threat of harm from chemical waste
disposal was such that a real location
of funds from other PC programs was
justified. Also, PC believed that
sooner or later the university would
be forced into such a program and
efforts prior to that date would be
beneficial in showing "good faith" to
regulatory agencies as well as devel-
oping a workable program.
Selling the concept of a centralized
disposal program to administrators
and departments generating the wastes
was much more difficult than origi-
nally thought.
In making their decision not to
provide any fiscal support to the
program, the administration also felt
that any program developed should be
primarily advisory in nature. There-
fore, they would neither make it
mandatory nor encourage participa-
tion. Consequently, the initial
response of various university con-
stituencies to the program was varied
but basically negative. The adminis-
trative academic personnel believed
that disposal methodologies were the
prerogative of the individual aca-
demic researchers and that PC, an
operational department, had no juris-
diction within academic affairs
unless requested. Even then, any
activities or recommendations should
be approved at the academic vice-
presidential level. Several factors
no doubt contributed to this atti-
tude: this was a new program, it was
not required (at that time) by exter-
nal regulations on the university as
a whole, and there was a general
misunderstanding regarding the seri-
ousness of the entire issue of waste
disposal.
The response and attitudes expressed
by operational units were also en-
lightening and interesting. As
documented elsewhere, operational
units (physical plant, janitorial,
etc.) are also major generators of
hazardous wastes on university cam-
puses. Not only do they generate
wastes themselves, but they also may
be responsible for the disposal of
the wastes generated by the other
areas of the university. They were
favorable to the establishment of a
2-9
-------
central program, but with many reser-
vations. General responses were
along the following lines: "Why
change; we've always done it this
way!" "We know the best way to do it
already."
much."
"It's going to cost too
These official attitudes were almost
in total opposition to the attitude
expressed by many individual waste
generators. The majority of re-
searchers, instructors, storeroom
supply officers, etc., who were
contacted as to the possibility of
developing this program were very
enthusiastic and supportive. As the
individuals actually dealing with the
chemicals and producing the wastes,
they were aware of the properties of
the wastes and consequently had a far
better perspective of the dangers
posed by indiscriminate disposal.
Therefore, they saw the need for such
a program and expressed considerable
willingness to work with PC in estab-
lishing such a program.
Aware of both the positive and nega-
tive attitudes toward the program, PC
decided to proceed with its develop-
ment. The fact that the generators,
both academic and operational, who
used the chemicals were willing to
participate was justification enough
to proceed.
PROGRAM DEVELOPMENT
Identification
Next, PC turned its attention to
operational aspects of developing the
program. The problems that seemed
largest, those of determining which
wastes to control and how to enlist
the generator's participation, were
tackled simultaneously, in that the
solution to one complemented the
other. Because no legal definition
of hazardous waste existed when the
program was initiated, the program's
function was to be primarily advis-
ory. Because of these constraints,
PC decided that a hazardous waste
should be defined as any waste that
the generator believed to be of such
nature that it should receive special
handling. The generator's knowledge
of waste was the deciding factor in
determining hazardousness. Thus, if
requested, PC could then take over
the responsibility for the disposal
of the waste. Initially, PC's pri-
mary input would be an educational
one of informing the generators of
the dangers of past and present
indiscriminate disposal, explaining
the need for a university control
program, and defining what wastes
should be controlled and what actions
PC would undertake to prevent envi-
ronmental contamination.
In correspondence with the various
university departments, PC described
the program as voluntary and indi-
cated that the wastes were to be
those chosen by the generator.
Nevertheless, examples of specific
wastes that should initially be
controlled were listed—wastes that
were universally accepted by scien-
tists as harmful to the environment,
such as poisons, cyanides, acids, and
arsenic. Most, if not all, gener-
ators that PC contacted agreed that
those wastes definitely should be
controlled. They were to add their
own lists of chemicals or chemical
byproducts that they believed should
be controlled, but control over any
of these wastes was to be purely
voluntary.
With the passage of time, the Envi-
ronmental Protection Agency began
listing specific compounds that were
illegal to release into the environ-
ment; e.g., 65 priority pollutants
under the Clean Water Act, PCB's
under the Toxic Substances Control
Act. In the opinion of PC, these
2-10
-------
-- GRADUATE ASSISTANT
POLLUTION CONTROL DIRECTOR
STORAGE EXCHANGE LAB ANALYSIS
WORKS IN CLOSE ASSOCIATION WITH
POLLUTION CONTROL DIRECTOR
ro
i
PAID STUDENT
WORKERS TRAINED
BY POLLUTION
CONTROL DEPT.
STUDENT WORKERS
AND VOLUNTEERS
— I VOLUNTEERS I
Figure 2. Personnel breakdown.
-------
DISTILLATION
ro
i
^ CHEM
IDENT
REUSE
CLEANING
EVAPORATION
DILUTION
IAH ncc SOLUTION
LAB USE
SIU TREATMENT CHEMICAL PRECIPITATION
EXCHANGEABLE
DESTRUCTION NEUTRALIZATION
RECEIVED MOT TAKEN THFDMJII nircTm.rTTnu
IN X TIME THERMAL DESTRUCTION
STORAGE
NON-EXCHANGEABLE LANDFILL
ICAL NON-SIU DISPOSAL DESTRUCTION
IFIED
RECYCLED
ALLEVIATES SELF
NOT RECEIVED
MINOR
Figure 3. Hazardous waste chemical pathway.
-------
specific lists gave them the author-
ity to place these chemical compounds
on a master list of compounds that
had to be turned over to PC for
disposal. After review, the admin-
istration concurred and the Hazardous
Waste Program (HWP) was off on a
legal footing as a mandatory program.
To encourage generators' participa-
tion for wastes not listed by a
regulatory agency, PC sent numerous
memos to each departmental chairman
explaining the needs and objectives
of the program. They also arranged
for slide presentations to depart-
mental staffs showing examples of
past environmental damage, as well as
examples of wastes that should be
controlled. Insofar as possible, the
HWP was presented as a potential and
valuable service to the department,
in that PC personnel would assist
departmental stockroom personnel and
purchasing agents in reviewing the
chemicals they had, deciding which
ones were usable and which ones
needed to be discarded, and notifying
each department of the presence of
needed chemicals that another depart-
ment might have but no longer needed.
Most departments soon realized the
value of such assistance as well as
the need for proper disposal of
chemical wastes.
Within the department, the PC staff
concentrated its attention on the
"stockroom manager." In most of the
departments that use chemicals, one
individual is usually in charge of
ordering, disbursing, etc. the sup-
plies. Because this individual is
generally aware of most all the
activities carried on within the
department, PC believed that if this
individual could be convinced of the
need for proper disposal, he or she
could serve as the focal point for
the entire department. When issuing
chemicals, the stockroom manager
could instruct the various staff
members on the need for proper dis-
posal, and he or she could serve as
the department's centralized collec-
ting point from which PC could pick
up the assembled waste. Because
these individuals are in the respec-
tive departments and working with the
researchers, they would have some
knowledge of the specific chemicals
used, the properties of these chemi-
cals, and possibly how to dispose of
them. As a result of selling the
program as a beneficial service to
the departments and the close inter-
action with stockroom managers and
departmental safety officers, PC was
soon overwhelmed with the number of
participating departments and, spe-
cifically, the number of wastes being
turned over for disposal.
The promulgation of the hazardous
waste regulation on May 19, 1980,
closed the loop for any wastes not
previously controlled. The regula-
tions not only specifically listed
many additional chemicals, but also
characteristics (e.g., toxicity,
reactivity, corrosivity, ignitabil-
ity) that would qualify all others.
This listing gave PC the final tool
for making the SIU-C HWP mandatory
for all generators; however, PC's
educational input and willingness to
work with the generators had already
produced a high rate of voluntary
participation, which was believed to
be preferable inasmuch as the gener-
ators were participating because they
were aware of the dangers of indis-
criminate disposal.
Partially as a result of this early
participation, the program retained
the same definition of a hazardous
waste, i.e., generator decision, even
after the May 19, 1980, promulgation.
Because university academic personnel
tend to resent a mandatory program,
greater participation is achieved
2-13
-------
with a voluntary type of relation-
ship. In addition, new and different
chemicals and chemical compounds are
continually being developed and/or
used in new combinations within a
university, and a detailed listing of
mandatory wastes would soon be out of
date. The volunteer type of program
encourages PC to maintain close
contact with the generators and helps
to establish close ties that are
mutually beneficial. Generators are
not reluctant to turn over their
wastes because they understand the
need and objectives of the program,
and by turning all wastes over to PC,
they free themselves of the responsi-
bility for proper disposal and/or the
consequences. By accepting al1
wastes, PC can be certain that the
truly hazardous wastes have been
properly disposed of.
Staff
Another major problem in the estab-
lishment of the HWP was the develop-
ment of a trained staff. With no
additional funds to hire additional
staff, PC was forced to recruit from
within its current staff. As a
result, PC is staffed entirely by
undergraduate and graduate students
interested in obtaining "hands on"
training in preparation for a career
in the environmental control field.
When the need of the program was
explained, numerous students already
employed in the solid waste manage-
ment and recycling programs volun-
teered to work additional hours to
help establish the hazardous waste
program. Although they demonstrated
outstanding dedication and eagerness,
their knowledge of chemistry and
chemical procedures required to
identify chemical compounds was
restricted. A special attempt to
recruit chemistry majors was only
partially successful, as few were
interested in obtaining this type of
applied training. Consequently, PC
developed its own chemistry training
program, which was conducted by
upperclassmen who had already had
several years of experience in han-
dling chemicals and wastes. Outside
experts, such as EPA chemists and
administrators, were also used. In
addition to chemistry and safety
training, the program also covered
basic environmental ism. The who,
what, and why of the program's objec-
tives were explained in detail, as
were the regulations. As a result of
this special training, the PC hazard-
ous waste staff is believed to be
thoroughly competent in all aspects
of chemical waste disposal.
Because the entire staff is comprised
of students, the turnover rate is 100
percent every few years. This makes
training a very important aspect of
the program. Students in their
freshman and sophomore years are
actively recruited. To be accepted
in the program, students must be
enrolled in the "hard" sciences or
engineering, already have taken or
soon be taking core chemistry
courses, be interested in a career in
the environmental field, and have
worked as a volunteer in the program
for at least one semester to see if
they are really interested. Students
with nonscience majors can assist in
the program by doing such things as
recordkeeping and memo writing, but
actual handling of wastes or treat-
ment can only be done by those who
have had extensive training and a
solid background in chemistry and
safety. Because of the high turn-
over, records are kept of all activi-
ties, procedures, methods, etc., and
this has helped to establish pro-
cedure manuals that can be easily
followed.
Although all members of the PC haz-
ardous waste staff are trained in all
2-14
-------
aspects of the program, specific work
assignments are made to facilitate a
smooth operational program. Assign-
ments are based primarily on the
individual's interest; e.g., those
interested in chemical identification
are assigned to the Lab Analysis
section. Students from nonscience
backgrounds work- in the Legal Review,
Education, and Records sections.
Figure 2 shows a personnel and work
assignment breakdown. Approximately
25 to 30 students work fulltime in
the program with another 10 to 12
volunteers. Day-to-day decisions are
made by a graduate assistant who has
come up through the ranks of the
program.
A large percentage of the PC hazard-
ous waste staff have gone on to
full time employment in the waste
disposal field. Both the specialized
PC training in the concepts of envi-
ronmental control (i.e., knowledge of
the. regulations and their back-
grounds) and the actual "hands on"
experience make them very hirable.
Storage-Treatment
Initially, not much thought was given
to the program's storage and treat-
ment of wastes. The volume of wastes
was expected to be fairly low, and
something would be worked out on an
as-needed basis. In the meantime, a
corner of the PC lab could be used to
store the wastes. As mentioned
earlier, however, the actual gener-
ators within the university were
immediately receptive to the program,
and the volume of wastes soon sur-
passed PC's ability to store them.
The overflow was placed in hallways,
basements, and any place available.
This handling created safety viola-
tions in itself, and many times
defeated the purpose of the program
in that incompatible wastes were
being stored together, often haphaz-
ardly.
The administration responded to this
need by allowing PC to utilize an
old, no-longer-needed, mobile home
shell, which could accommodate a
great volume of the wastes while the
decision was being made as to what to
do with them. Because the trailer
was only a shell (with no shelves,
tables, or electricity) and all the
windows had been boarded up, the
doors afforded the only light and
ventilation. In the summer the high
temperature caused many wastes to
volatilize, and in the winter the low
temperatures caused liquids to freeze
and contents to spill out and mix.
The real danger stemmed from the
trailer's being located adjacent to a
17-floor resident dormitory.
It was apparent that this facility
did not really meet storage needs.
In the fall of 1978, another mobile
home shell was obtained; however,
tnis one was located away from the
central campus, in the Physical Plant
storage yard among the farms. The
yard is kept under lock and key. The
PC Department equipped the trailer
with safety equipment, work tables,
and storage shelves, much of which
was recycled from other University
facilities. We learned that metal
shelves and the like were unsuitable
because they soon corroded. The
trailer is "provided with heat in the
winter and ventilation in the summer.
This storage facility has worked
well.
The shortage of funds made it neces-
sary to seek inexpensive treatment
techniques. One approach was to try
to maximize the amount of waste
treated by PC and thereby keep the
costs for off-campus disposal to a
minimum. Another approach was to
seek methods wherein one waste could
be used to treat others. Initially,
low-cost methodologies, i.e., dilu-
tion (sewer dumping) and evaporation,
2-15
-------
were used for primary treatment.
These methods worked satisfactorily
and helped to hold down costs.
Eventually, after experience had been
gained, new and more sophisticated
disposal techniques were developed,
such as chemical precipitation and
thermal destruction in the campus
boilers. We also found that many
wastes could be distilled, cleaned
up, and reused, which further reduced
the number requiring disposal. New
techniques were developed whenever a
sufficient amount of waste with
similar characteristics accumulated.
All techniques were checked out with
references such as Sax "Dangerous
Properties of Industrial Materials"
before they were attempted, and the
resultant byproducts (e.g., super-
natants, sludges) were checked for
hazardous properties prior to further
handling. Some treatment techniques
were abandoned after experimentation
either because the procedure was too
hazardous for the staff or because it
was too costly.
One of the most successful programs
developed was a chemical exchange
program, in which reusable chemicals
are segregated and delivered to other
users on campus according to need.
Thousands- of wastes are recycled as a
result of this program.
After several years of experience, we
worked out a procedural flow chart
describing the fate of a collected
hazardous waste. Upon notification
of the presence of a waste, the PC
staff investigates the situation and
decides how it should be handled,
based on volume, chemical properties,
etc. Figure 3 is a flowchart showing
the fate of a waste collected by PC.
Summary
After a period of
SIU-C hazardous
program is fully operational and has
the full backing of the administra-
tion and the enthusiastic support of
the actual generators. As a result
of this program, the University's
chemical wastes are collected, iden-
tified, stored, and ultimately dis-
posed of in an environmentally
approved manner.
development, the
waste disposal
2-16
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OPERATION OF THE SIU-C HAZARDOUS WASTE PROGRAM
John F. Meister
Pollution Control, an operational division within Southern Illinois University
at Carbondale charged with the environmental compliance of the university, has
developed a hazardous waste management program for university-generated wastes
that can pose a threat to human health and the environment. The purpose of
this program is to prevent haphazard or indiscriminate disposal of these
wastes. Major functions include collection and storage, identification,
treatment, and environmentally safe disposal of the waste. Treatment options
depend on the chemicals involved and include evaporation, precipitation,
neutralization, and distillation. Many wastes are recycled into academic
laboratories through an in-house chemical exchange program. Wastes that
cannot be treated and reused are disposed of either on or off campus.
The SIU-C hazardous waste control
program currently has four basic
components: identification, storage,
treatment, and disposal of collected
wastes. In addition to these func-
tions, the PC hazardous waste (HW)
staff spends considerable time and
effort in several support functions,
including the provision of scientific
and operational assistance to various
departments on special waste prob-
lems. A review of pertinent rules,
regulations, newsletters, and jour-
nals keeps the staff abreast of the
latest techniques and processes.
Finally, ongoing educational efforts
are made to instruct generators of
the need for proper disposal.
individual or department using a
compound, chemical, or other material
that requires disposal. Any waste
that a generator believes should
receive special attention is included
in the program.
Most initial contacts are made by a
telephone conversation in which the
generator notifies Pollution Control
of the presence of a waste. Basic
information concerning the waste and
the generator is taken over the phone
and logged on a Hazardous Waste
Incident Report. The telephone logs
are reviewed by the division coordi-
nator, who schedules pickup of the
waste from the generator.
WASTE IDENTIFICATION
Inclusion of a particular waste in
this program is initiated by the
generator, who is defined as any
Mr. Meister is Director of Pollution
Control with Southern Illinois
University at Carbondale.
2-17
-------
Pollution Control will, in most
cases, actually do the collection and
transportation of the waste. Al-
though this procedure is more expen-
sive than having the generator or the
generator's students deliver the
waste, it provides better protection
from the potential dangers of waste.
These dangers are especially great if
inexperienced students transport the
hazardous waste. The PC staff uses a
pickup truck equipped with special
safety and cleanup equipment in case
of a spill or leak.
At the time of the collection, the PC
staff meets with the generator and
obtains and records such pertinent
information as specific chemical
composition, generation rate, special
notes on toxicity and environmental
hazards, and any information regard-
ing proper disposal that the genera-
tor might be aware of. If the gener-
ator is new to the hazardous waste
program, the staff explains how the
program operates, what sort of stor-
age containers should be used, and
what other wastes should be included.
If the waste is definitely nonhazard-
ous, the staff tells the generator
how he or she can, in the future,
properly dispose of it. The contain-
er of wastes is labeled with a spe-
cial hazardous waste label, if the
original label is no longer intact or
does not indicate the actual con-
tents.
The waste is then brought back to
Pollution Control. A special section
of the laboratory, which is equipped
with a fume hood, has been set aside
for use by the HW staff. The waste
is "inventoried" into the hazardous
waste record system, and all perti-
nent information is recorded in a log
book and on a 4- by 6-inch index
cards. These provide the central
record system for keeping track of
all wastes handled.
The HW chemists then evaluate how the
waste will be handled. Although past
experience is important in the evalu-
ation, references such as the "Hand-
book of Chemistry and Physics" (Weast
1979), "Dangerous Properties of
Industrial Materials" (Sax 1977), and
"Toxic and Hazardous Industrial
Chemicals Safety Manual" (Interna-
tional Technical Information Insti-
tute 1979) are the primary sources
used to determine toxicity and haz-
ards associated with the waste.
Additional information from these re-
ferences is recorded on the label, in
the record book, and on the index
card.
Operationally generated wastes such
as copier and duplicating fluids and
photo-developing chemicals may re-
quire more extensive investigation.
Because the chemical makeup of these
products is often not on the label or
container, the HW staff must contact
the manufacturer to obtain a list of
the chemicals present in the product,
information on environmental effects,
and recommendations for proper dis-
posal before decisions can be made
regarding further handling.
Unknown wastes are labeled as such
and set aside until they can be
analyzed to determine the presence of
any hazardous waste characteristics.
Although the generator is requested
to try to determine the identity of
the waste before pickup, it may still
remain unknown. These result from
academic staff turnovers etc. Gradu-
ally, the backlog of old chemicals
has been cleaned out and disposed of,
and departments being informed of the
importance of proper identification
to prevent accidents is resulting in
a reduction of the number of unknown
wastes.
Identification of the chemical nature
of the waste determines the method of
2-18
-------
further storage and disposal. If the
waste contains no chemical or com-
pound whose release into any phase of
the environment is forbidden by the
U.S. Environmental Protection Agency
(EPA), it is marked nonhazardous and
set aside for conventional disposal,
either by dilution and dumping into
the sewer or by placement into a
solid waste stream. All other wastes
are determined to be exchangeable or
nonexchangeable. Exchangeable wastes
are those that can be reused in their
present forms somewhere on campus.
Nonexchangeable wastes are those that
will require further treatment and
disposal. Because of the importance
of identification, chemistry students
comprise the greatest portion of the
hazardous waste student work force.
Continual special training sessions
are held to upgrade their ability to
identify toxic and hazardous proper-
ties of waste.
WASTE STORAGE
Several storage facilities are used
between collection and treatment or
disposal. As mentioned, selection of
storage facilities depends on the
type of waste and method of disposal.
A portion of the PC laboratory that
includes a fume hood is used for
storage during identification and
inventory. All volatile wastes are
kept under the fume hood. Wastes
that are determined to be nonhazard-
ous are stored in inconventional
storage areas until they can be
disposed of conventionally. Wastes
that can be treated relatively easily
are also stored in the PC laboratory
because most chemical treatment takes
place there. Wastes for which there
is an immediate demand by another
department (e.g., relatively pure
solutions) are also stored temporar-
ily in the PC laboratory.
Storage facilities that the generator
might possess are also utilized,
especially in cases when the genera-
tor produces large amounts of a
single type of waste. The PC staff
will provide large appropriate con-
tainers such as drums and teach the
generator safe procedures for col-
lecting and storing the waste. When
these containers are full, the PC
staff removes the waste. For
example, the Physiology Department
receives 55-gallon drums to store
phenol wastes from cadavers in anat-
omy work, and the Environmental
Engineering Department receives
15-gallon plastic carboys to collect
wastes from tests of chemical oxygen
demand. These in-house larger stor-
age containers drastically reduce the
number of collection trips and
short-term storage requirements in
the PC facilities.
The primary storage facility used for
all remaining wastes after collection
and inventory is a converted "mobile
home" trailer located in the Physical
Plant storage yard. The storage yard
is roughly 1% miles from the center
of campus and located among the
university farms. The entire storage
yard is kept under lock and key at
all times, and the trailer is located
in a remote corner of the yard behind
large concrete storage bunkers. The
trailer has been modified internally
by the addition of shelves and cabi-
nets in all the rooms and the instal-
lation of work tables. Safety equip-
ment has been located at easily
accessible points. Several large
openings have been made in the walls
to provide ventilation in the warmer
months.
Different types of wastes that can
react with one another are stored in
separate rooms. An inventory system
is used to number wastes in the
trailer for easy location and re-
2-19
-------
trieval. Within the room or space
allocated to a type of waste (e.g.,
organic solvents) the wastes are
segregated by final destination. For
example, those awaiting treatment and
reuse are stored separately from
those awaiting shipment and off-
campus disposal.
WASTE TREATMENT
Available treatment options include
evaporation, precipitation, neutral-
ization, distillation, cleaning, and
exchange. The goal of the hazardous
waste program is to treat the maximum
number of wastes and thus reduce the
quantity that must be shipped off
campus for landfill disposal.
The choice of treatment option is
based on the nature and type of
chemicals that the waste contains.
Generally, the decision is made at
the time when the waste is invento-
ried and reference information is
gathered. References such as those
mentioned earlier are used to verify
the capability of treatment and to
determine proper procedures. All
treatment is done in safe areas by
trained chemists and staff members
who are equipped with appropriate
safety equipment. Records are kept
of all treatment activities.
Evaporation
A large number of wastes are water
soluble (e.g., salts and heavy
metals). If the water is evaporated,
the volume and weight of wastes
requiring final disposal are drasti-
cally reduced. Further, many dilute
organic solvents are received that
can be evaporated into the atmosphere
at a slow, controlled rate with no
harm.
Evaporation is performed at the site
of the hazardous waste storage facil-
ity. On the west side of the trailer
a lean-to type of structure was
constructed with lumber and covered
with clear heavy-gauge plastic.
Several plastic evaporating pans were
placed under the lean-to. Each pan
is approximately 4 feet in diameter
and contains no more than 6 inches of
liquid. The purpose of the lean-to
is to prevent rain from reaching the
evaporating liquids.
The waste liquids are placed in the
pans and allowed to evaporate. The
sludges and residues that remain
after evaporation are removed from
the pans and packed for ultimate
disposal. The advantages are a
drastic reduction of weight and
volume and the simplified storage,
packing, and shipping requirements of
a solid as opposed to the original
liquid.
Evaporation generally proceeds rapid-
ly because of the sun's heat under
the plastic and usually is carried
out between the months of April and
October. During this time a very
large amount of wastes can be treat-
ed. During the colder months some
wastes are evaporated under the fume
hood within the PC facility. Also,
some nontoxic wastes are evaporated
in the mechanical rooms of the chem-
istry building.
Precipitation
Many waste solutions can be chemical-
ly treated to precipitate the hazard-
ous element. The precipitate can
then be separated and stored, and the
supernatent can be disposed of con-
ventionally. Again, the advantages
are the reduction in weight and
volume and the conversion of the
waste into a solid.
2-20
-------
Because precipitation is a chemical
process, it is carried out in the
laboratory in small quantities by
trained chemists. The process can be
used throughout the year. The pre-
cipitates are collected, and those of
the same chemical type can be com-
bined to save space.
Precipitation is a process in which
one waste product can be used to
treat another; thus, two wastes can
be eliminated simultaneously. For
example, waste chromic acid can be
treated with waste sodium hydroxide.
Both wastes are eliminated, a precip-
itate (chromium) is formed, and the
remainder of the solution can be
disposed of. Chromium is a valuable
byproduct that can be stored and sold
as a raw product.
The opposite of precipitation-
solubilization is carried out on some
solid wastes. These are solids that
are soluble in solvents, which then
can be incinerated or combusted in
the campus boilers. Benzyl compounds
are examples of wastes that can b'e
treated by this method.
Neutralization
Neutralization, like precipitation,
is a chemical process wherein differ-
ent wastes are mixed together. Their
chemical properties are such that
they will neutralize the hazardous
properties of one another. The
classic chemical neutralization,
which is extensively used in the HW
program, is the mixing of acids and
bases. The end product generally can
be disposed of down the drain with no
harm. All neutralizations are car-
ried out in the laboratory under con-
trolled conditions, and end products
are checked before disposal to ensure
that no hazardous properties remain.
Distillation
Many departments and researchers on
campus use considerable amounts of
solvents that become contaminated
with other solvents or wastes.
Through distillation the solvents can
be separated and recovered with a
high degree of purity. These sol-
vents can then be recycled to the
generator for reuse. Distillation
not only eliminates waste disposal
but also saves the institution money.
Considerable quantities of such
solvents as xylene, acetone, alcohol,
and benzene have been recycled to
various departments on campus.
Cleaning
Many
wastes are chemicals that have
y become dirty. Simple clean-
or physical
Many wastes are chemical
simply become dirty. S
ing, filtering, washing, w, ^njoi^ui
separation returns the chemical to
usable form for reuse by the gener-
ator or another user. Mercury is a
commonly received waste that can be
reused in manometers, barometers, and
other devices after simple cleaning.
Exchange
Many chemicals received by the HW
program are still pure enough for
direct reuse. These are chemicals
that a generator no longer needs and
wishes to dispose of to conserve
shelf space. They are generally in
their original containers and thus
easily identifiable.
To reduce the wastes requiring off-
campus disposal, save costs, and
promote the concept of recycling, the
Pollution Control Hazardous Waste
division instituted an exchange plan
for this type of chemical waste.
When wastes are received, their
exchange possibilities are evaluated.
Homogenous wastes that are still in
their original containers and have
2-21
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been disposed of merely because they
are no longer needed are set aside
for possible exchange purposes.
Periodically, a list of all accumu-
lated exchangeable wastes is prepared
and distributed to interested depart-
ments on campus. Pollution Control
provides no assurance as to the
quality of the chemicals, but does
provide them free of charge. Not all
chemicals are claimed, but most of
them are.
The program offers advantages to all
parties. The recycling of the wastes
makes treatment and disposal unneces-
sary and thus reduces the cost of the
HW program and, ultimately, of dis-
posal. The receiving department
obtains chemicals at no cost, the
concept of recycling is promoted, and
the participants are reminded of the
benefit of the HW program.
The quantity of wastes recycled
indicates the success of the program.
During 1978, more than 300 gallons of
solvents and 3000 different chemicals
were returned to academic depart-
ments. The replacement cost of these
chemicals, if they had to be pur-
chased, was calculated at more than
$20,000. Because of the success of
past exchanges, many departments now
have standing requests for certain
chemicals as they are received by the
HW division. This helps reduce
storage requirements of the program.
WASTE DISPOSAL
The residues that remain after treat-
ment are disposed of both on and off
campus. On-campus disposal consists
of sewer dumping, thermal destruction
in the campus boilers, and special
biological treatment. Off-campus
disposal consists of shipment to an
EPA-approved hazardous waste landfill
and is mandatory for all wastes and
residues considered extremely toxic
or harmful to humans or the environ-
ment.
All disposal operations are carried
out by trained staff members. Each
disposal is recorded in the files,
and the 4- by 6-inch index card for
the chemical is removed and placed in
a box labeled "disposed of chemi-
cals." This completes a "cradle-to-
grave" record of the waste within the
SIU-C hazardous waste program.
On-Campus Disposal
Di1ution--
Many wastes, both nonhazardous and
hazardous, can be safely disposed of
via sanitary sewer. If the material
can be adequately diluted and will
not be reconcentrated or biomagni-
fied, then it can be safely disposed
of in this manner. Waste that can be
biologically stabilized through the
wastewater treatment process also can
be dumped. Research is done on all
such wastes before dumping to ensure
that they will not harm the collec-
tion system or interfere with the
sewage treatment process.
For ensuring immediate and proper
dilution, the decision was made to
dump wastes directly into a manhole
rather than down a laboratory sink.
After a thorough search, a manhole
was selected. The upstream flow rate
at this manhold was determined to be
roughly 350 gallons per minute at
certain regular times during the day.
During disposal, a 4-inch-diameter
PVC pipe is inserted vertically in
the manhole, and the wastes are
dumped into the pipe, which acts as a
funnel and conducts the wastes into
the sewer channel and prevents them
from contacting the sides of the
manhole. A full-flowing, Jg-inch
garden hose is also placed inside the
2-22
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pipe to ensure that wastes are washed
down and to provide additional dilu-
tion. The rate of waste dumping is
controlled to allow complete mixing
and flushing. Sewage samples are
taken downstream from the manhole for
pH and other tests to determine
whether the wastes are creating
problems.
Incineration--
Because of their chemical makeup,
many other wastes (primarily alcohols
and organic solvents) contain certain
amounts of heating value. Some of
these are used to dissolve certain
other waste chemicals, and the re-
maining liquid solvents are taken to
the physical plant steam boilers,
where they are sprayed on the coal as
it is placed into the firebox. The
high temperatures (1200° to 1400°F)
are sufficient for thermal destruc-
tion of the wastes.
Other--
The PC HW division is continually
investigating other forms of dispos-
al. A system of biological land
spreading is being examined, and
research is continuing on methods of
chemical destruction of wastes.
Methods of on-campus disposal are
being sought because they are much
cheaper than methods of off-campus
disposal. Additionally, when the HW
division is responsible for disposal,
the waste is known to be destroyed
and thus no longer to threaten the
environment or human health.
Off-Campus Disposal
Certain wastes, because of their
toxicity and environmental hazard
potential, are not treated or dis-
posed of on campus, but are shipped
off campus to avoid the risk of
exposure during treatment. Wastes
sent off campus include those that
require special disposal permits,
those that are subject to regulations
specifying where and how they may be
disposed of (e.g., polychlorinated
biphenyls), and those for which no
on-campus disposal system works.
Phenolic wastes collected on campus
are sent to a local industrial waste-
water treatment plant for disposal.
The local industry employs phenols in
its manufacturing process and has an
activated sludge treatment process
capable of destroying phenolic
wastes. The industry has agreed to
accept SIll-C waste, which it slowly
feeds into its wastewater treatment
plant.
Other wastes requiring off-campus
disposal are sent to an EPA-approved
hazardous waste landfill. A permit
is received from the EPA for this
disposal. The HW staff packs the
wastes into 55-gallon drums in ac-
cordance with EPA and Department of
Transportation specifications cover-
ing the types of wastes that may be
packed together, types of packing
materials, and types and conditions
of drum. Labels on the drums indi-
cate the types of waste, and written
records are made. The waste drums
are then delivered to the recipient,
who is responsible for transportation
and disposal.
SUPPORT FUNCTIONS
In addition to the collection, treat-
ment, and disposal of wastes, the PC
staff provides several support func-
tions that round out the overall
program and contribute to its suc-
cess. Student members of the staff
are used on these projects.
Advice
Periodically, special problems re-
garding chemicals and waste disposal
2-23
-------
arise within the university. Many of
these are not associated with col-
lecting and disposing of waste;
rather, a department or individuals
are seeking advice on how to handle a
situation. For example, they may be
preparing a grant proposal and need
information on handling and' storage
of chemicals. In other cases, an
operational department may be consid-
ering a change of chemicals and want
advice on whether the new chemicals
will be safe.
Emergency Response
If a dangerous leak or spill of
chemicals occurs anywhere on campus,
the HW staff is utilized to contain
and dispose of the spill. When
noxious fumes were found to be enter-
ing the vivarium via floor drains,
the HW staff investigated the situa-
tion, found that individuals were
pouring chemicals down the drain in
upstairs laboratories, and informed
them of proper disposal methods.
Review
To keep informed of changing technol-
ogy and regulations, the HW staff has
established a library complete with
copies of the latest "operational"
journals in the field of solid waste
management and chemical literature.
Current periodicals such as the
Hazardous Waste Newsletter, Chemical
Regulation Reporter, and Environmen-
tal Reporter are studied, in addition
to the Federal Register and other
reports on state and Federal regula-
tions. This review of literature
enables the staff to respond to new
regulations, as well as keep informed
of the state of the art of treatment
and disposal.
Education
Educational efforts were essential in
establishment of the PC program.
Although the success of the program
is now the best tool for drawing more
individuals into it, an educational
plan has been devised for new univer-
sity staff members. The plan con-
sists of explaining why the PC pro-
gram is necessary, how it works, and
how the individual can be involved.
Also, slides showing the environmen-
tal hazards of improper disposal have
been prepared for presentation to
departments and other interested
groups. When necessary, memos are
sent to generators and to all depart-
ments to remind them of the program
and inform them of changes.
The HW staff, which consists entirely
of students, also requires special
training and education. The fact
that all workers are volunteers
interested in a career in waste
management and seeking experience
gives motivation and simplifies the
training. The staff members are
taught through individualized in-
struction, as well as through semi-
nars and workshops. Students with
extensive academic chemical back-
ground are used to teach others.
Special Projects
The HW staff is also used to conduct
special studies on current problems
faced by the university. With its
modern equipped laboratory and refer-
ence library, the staff can perform
studies on short notice and at low
cost. Many waste streams have been
analyzed to determine if hazardous
wastes are present, and a study is
now being undertaken to determine the
presence and level of pesticides in
the Campus Lake watershed.
CONCLUSION
The SIU-C hazardous waste program is
a successful example of how a univer-
2-24
-------
sity can safely dispose of its chemi-
cal wastes in an environmentally
acceptable manner. The program has
been developed over the past several
years in recognition of the fact that
the university is a generator of
hazardous waste. It is operated
completely by student staff and has
developed a workable system of iden-
tifying, collecting, storing, treat-
ing, and disposing of chemical wastes
generated on campus. Wastes that
formerly were placed with the solid
waste or dumped down the drain are
now isolated and controlled. As a
result, toxic, hazardous wastes pro-
duced by the university are no longer
indiscriminately disposed of. Thus,
the threat to the environment and
human health from improper chemical
waste disposal has been significantly
reduced.
2-25
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SOURCES AND IDENTIFICATION OF
UNIVERSITY-GENERATED WASTE
Henry H. Koertge
Since 1973, the University of Illinois at Urbana/Champaign (UIUC) has had an
established collection system for campus-wide pickup of waste chemicals. Some
of the procedures that evolved under this system are now or soon will be
required by environmental regulations. The major portion of this paper in-
volves a discussion of ways and means to identify the persons (or departments)
on campus who are generating such waste. This can be accomplished by (1)
advertising the chemical waste disposal service, (2) keeping track of chemical
storeroom purchases, and (3) monitoring research projects.
The history of the management (or
mismanagement) of chemical wastes at
universities probably parallels the
experience of industries throughout
the country. In the past, chemical
waste has been volatilized, burned,
buried, and dumped in both sanitary
and storm sewers. These methods of
disposal have been applied either
legally or illegally, depending on
the local situation. In fact, some
of these seemingly inappropriate
means of disposal may be the best
methods available today, even from an
environmental standpoint. The appro-
priateness of these disposal methods,
however, depends on the quantities
involved, dilution available, and
individual hazardous characteristics.
The environmental impact of wastes
from a university community depends
to a great extent upon the relative
size of the university as compared
with the local metropolitan area. A
small campus could dispose of a fair
percentage of its hazardous chemicals
if it were discharging
tary sewers of a large
sanitary district.
to the sani-
metropolitan
Many universities, however, have
determined that these long-practiced
means of disposal are inadequate,
inappropriate, or illegal because the
quantities and characteristics of
many of the chemicals have an adverse
impact on air, land, and water qual-
ity. It should be noted that univer-
As Director of the Division of Envi-
ronmental Health and Safety at the
Urbana-Champaign Campus of the Univ-
ersity of Illinois, Mr. Koertge is
in charge of inspection and consul-
tation services for health and
safety. He has extensive experi-
ence as a sanitary engineer and has
published articles in several
health journals. He holds a B.S.
and M.S. from the University of
Illinois at Urbana.
2-26
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sity-generated chemical waste is dif-
ferent from industrial chemical
waste. This difference may turn out
to be a considerable problem for
colleges and universities because the
rules and regulations that have been
or are being established by Federal
and State Environmental Protection
Agencies are designed to cover indus-
trial hazardous waste materials.
The main difference between univer-
sity- and industry-generated chemical
waste is the quantity and number of
materials involved. On the campus of
the University of Illinois at
Urbana/Champaign (UIUC), the quanti-
ties of hazardous chemical wastes
packaged for disposal range from 1
gram to 55 gallons, extremely small
quantities when compared with indus-
trial wastes. The various types of
materials are possibly as numerous as
the 16,500 different chemicals
listed in the Registry of Toxic
Effects of Chemical Substances pub-
lished by the National Institute for
Occupational Safety and Health
(NIOSH) in 1975. In addition to
these manageable wastes, colleges and
universities have to dispose of
extremely difficult-to-manage mate-
rials. These materials are classi-
fied on the UIUC campus as unknowns,
pyrophorics, and explosives. It is
theorized that eventually each campus
will need a specially designed incin-
erator capable of burning explosives,
pyrophorics, and unknowns. Regula-
tory agencies will be obliged to
allow campuses to burn unknowns
because generation of unmarked or
otherwise unknown chemicals cannot be
prevented and if incineration is not
permitted, the waste will probably be
disposed of illegally.
Another characteristic of univer-
sity-generated waste is that much of
it is not waste per se because it has
not been used or mixed in any manner.
In fact, it could probably best be
described as leftovers.
Since the criteria for defining
hazardous wastes include ignitability
(flammability), corrosivity, reactiv-
ity, and EP (extraction procedure)
toxicity, all waste chemicals (left-
overs) will probably be identified as
hazardous. The regulatory agencies
are considering the addition of the
following items to the list of cri-
teria just mentioned; organic toxic-
ity, carcinogenicity, mutagenicity,
teratogenicity, bioaccumulation
potential, phytotoxicity, and infec-
tivity. Currently, a waste is con-
sidered hazardous if it has any of
the following characteristics:
Ignitability (Flammability). If a
liquid, the material has a flash-
point of less than 60°C (140°F); if
not a liquid, is capable of causing
fire through friction, absorption
of moisture, or spontaneous chemi-
cal changes; or is an ignitable
compressed gas or an oxidizer as
defined in the Code of Federal
Regulations.
Corrosivity. The material is
aqueous and has a pH of less than 2
or greater than 12.5, or it cor-
rodes steel at a rate greater than
6.35 millimeters per year at a test
temperature of 55°C.
Reactivity. The material is nor-
mally unstable; reacts violently
with water; forms potentially
explosive mixtures with water;
generates toxic gases, vapors, or
fumes when mixed with water; or is
cyanide- or sulfide-bearing.
EP Toxicity. If an extract of the
material contains certain concen-
trations of various contaminants,
such as arsenic, barium, cadmium,
chromium, lead, mercury, salinium,
or silver.
2-27
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In addition, some lists define wastes
as hazardous primarily because they
are toxic. These are listed in the
Federal Register (Volume 45, No. 98,
Monday, May 19, 1980) along with
complete definitions of the four
characteristics just listed. An
examination of these characteristics
indicates that almost all leftover
chemicals on a college/university
campus will be considered hazardous.
Many different sources of hazardous
chemical waste are found on a
college/university campus. Among
these is the physical plant or opera-
tions and maintenance unit with its
various crafts and services. Exam-
ples of these crafts and services and
the wastes they create are shown in
Table 1.
Field operations of agricultural
colleges are another campus source.
TABLE 1. POSSIBLE WASTES FROM CRAFTS AND SERVICES
Craft/service
Possible wastes
Painters
Janitors
Groundsmen
Water treatment
personnel
Brickmasons
Electricians
Car pool (garage)
Machine shop
Paints and solvents
Bleaches, wax removers
All types of pesticides and fer-
tilizers
In the areas of water supply, swim-
ming pools, cooling towers, and
boilers/hot water heating systems,
many toxic chemicals (e.g.,
chlorine, anticorrosive chemicals,
and biocides) are used
Muriatic acid
PCB's from transformers
Cleaning solvents
Cutting oils
2-28
-------
Pesticides and fertilizers, partic-
ularly experimental pesticides, may
create special problems and require
special solutions.
Perhaps the most obvious sources of
chemicals are the many laboratories
on all campuses. Categorized as
chemical and biological, these are
found in the following areas: chemi-
cal sciences, life sciences, agricul-
ture, veterinary medicine, and col-
lege of medicine.
Besides these somewhat obvious
sources, other sources of hazardous
chemicals exist, but are less sus-
pect. Included in this group are the
engineering colleges, especially the
chemical/biological laboratories of
the Environmental Engineering Depart-
ment; however, all the other engi-
neering departments use various
chemicals (particularly oils and
gases). All shops should be checked
as sources of chemical wastes, in-
cluding those in the college of
education, because they may use
various chemicals such as paints and
solvents in their industrial shop
courses. Art colleges and depart-
ments also use plastic materials and
a great variety of paints and sol-
vents.
The proper disposal of all hazardous
chemicals in accordance with all
applicable rules and regulations
requires the establishment and fund-
ing of a unit to be in charge of such
an endeavor. The campus must staff
the unit with technical/professional
personnel and equip it for pickup,
transportation, and collection of
hazardous chemicals. Every campus
probably has some semblance of a
hazardous chemical waste disposal
system. The system may have grown
erratically and now be close to
evolving into a full-fledged recog-
nizable system, or it may be a long-
recognized, acceptable, efficiently
managed system. It is doubtful,
however, that any college/university
is 100 percent efficient in the
collection and proper disposal of all
hazardous waste chemicals. Some are
still being volatilized in chemical
fume hoods, flushed to a sanitary
sewer, or dumped in garbage cans.
Whether a particular campus is begin-
ning a chemical waste disposal pro-
gram or expanding upon an existing
one, several methods are available
for developing a list of hazardous
chemical users.
First, it may be appropriate to
advertise the existence of the col-
lection and disposal service for
hazardous waste chemicals. This
could be accomplished by placing an
article or advertisement in the
campus student newspaper or in a
faculty/staff publication, or by
sending a letter to the heads of all
academic and administrative units.
The correspondence should include
details of the service and a request
for information concerning the quan-
tities and types of materials expec-
ted to be generated. If this is a
new service, a list of waste materi-
als on hand for immediate disposal
should be requested.
Another means of determining hazard-
ous chemical users is through the
purchasing department or through the
chemical store operation. At UIUC,
the chemical storeroom has a comput-
erized inventory list, which is
flagged so that the Division of Envi-
ronmental Health and Safety is auto-
matically sent a copy of the chemical
purchase order for a limited number
of chemicals --those appearing on the
original Occupational Safety and
Health Administration (OSHA) carcino-
gen list and a few others. At UIUC,
the present system of collection and
disposal is near capacity, and there
2-29
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has been no need to expand the list
of users by increasing the numbers of
flagged chemicals.
Another method of identifying hazard-
ous chemical users is through the
monitoring of new research projects.
At UIUC, a one-page form is filled
out and sent to the campus research
board for each externally funded
research proposal. One section of
this form asks the user whether or
not hazardous materials or procedures
are utilized. It also asks if the
material can be categorized as a
chemical hazard, biohazard, or radia-
tion hazard. A copy of each research
proposal transmittal form that indi-
cates the use of hazardous chemicals
is sent to the Divison of Environ-
mental Health and Safety. Thus, it
is possible to determine potential
hazardous chemical users and to be
made aware of other potential safety
problems.
Another possible means of determining
hazardous chemical users is to check
with the campus radiation safety
officer. The radiation safety offi-
cer probably has a list of labora-
tories using radioisotopes. Experi-
ence at the UIUC campus indicates
that most, if not all, of these
laboratories use chemicals that are
deemed hazardous.
As mentioned earlier, any leftover
chemical is probably considered
hazardous under one or more of the
criteria of the Environmental Protec-
tion Agency because this type of
chemical waste usually consists of
"straight" chemicals. If additional
information is necessary to determine
whether or not a particular chemical
exhibits one or more of the criteria,
it may be necessary to invest in an
automated information retrieval
system. Utilization of computer and
communication technology through
access to bibliographic and knowledge
data bases may become a necessity.
Since university campuses use vast
amounts of chemicals, it would be
impossible, or at least impractical,
to do all of the necessary research
necessary to list the various charac-
teristics of the chemicals—and even
more impractical to test the chemi-
cals. Basic background and specific
examples of retrieval systems are
provided in an article entitled
"Automated Information Retrieval
Science and Technology," by Doszkocs,
Rapp, and Schoolman, in Science, Vol.
208, April 4, 1980, pp. 25-30. At
UIUC, the Division of Environmental
Health and Safety has purchased a CRT
terminal with a modem, a microcom-
puter, and a printer terminal. This
equipment will record, store, select,
and recall information on chemical
purchases and usage, as well as
computerize the radioisotope inven-
tory for the radiation safety pro-
gram. This can provide the following
specific information in regard to
chemical safety and disposal:
Inventory—the chemical,
used, location of users.
amounted
Flagging of highly toxic/carcino-
genic chemicals.
Recordkeeping for annual report on
chemical disposal.
Access to 90 percent of all chemi-
cal purchase data on campus.
Direct access link to national data
base for data recall, including
physical characteristics, toxicolo-
gical information, and references.
2-30
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PACKAGING, TRANSPORTATION, AND DISPOSAL OF WASTES OFF CAMPUS
R. R. (Dick) Orendorff
This paper is presented to assist academic institutions in meeting state and
Federal regulations concerning the packaging, transportation, and disposal of
wastes. Because the Resource Conservation and Recovery Act (RCRA) was pri-
marily designed to regulate the chemical manufacturing industry, institutions
(both hospitals and universities) are forced to comply with regulations that
are, in many ways, vague or nonapplicable to their operations.
TYPES OF WASTES
Wastes are divided into three cate-
gories. The first is general refuse
(i.e., garbage), which is nonhazard-
ous, is not stringently regulated,
and poses little or no disposal
problem. The second type is radio-
active waste, currently regulated by
the Nuclear Regulatory Commission and
some state agencies. The third waste
category is our problem child--
hazardous chemical wastes. This
material is now regulated by the
Department of Transportation (DOT),
U.S. Environmental Protection Agency
(EPA), and state environmental pro-
tection agencies. This paper ad-
dresses disposal of hazardous chemi-
cal wastes and compliance with appli-
cable DOT, U.S. EPA, and state EPA
regulations.
RESPONSIBILITIES OF CHEMICAL WASTE
GENERATORS
The generator is legally responsible
for proper disposal of hazardous
chemical wastes. The generator's
responsibilities include the notifi-
cation by the generator to the U.S.
EPA of hazardous waste generation,
arrangement with a licensed disposal
facility to accept the wastes, cor-
rect packaging of the wastes in
accordance with DOT regulations,
accurate completion of permits and
shipping manifests, and proper trans-
portation to the disposal facility.
To clarify the entire procedure,
let's review a step-by-step descrip-
tion of chemical waste disposal.
First, you must read the U.S. Federal
Register of May 19, 1980, particular-
ly Parts I through V. Note carefully
which materials are hazardous and
which are nonhazardous. If hazardous
wastes are being generated, the law
requires notification form [EPA
Mr. Orendorff is a Technical Repre-
sentative of Nuclear Engineering Co.,
Inc. He has been employed by private
industry and government and has more
than 18 years of experience, includ-
ing work in chemical research and
engineering. He holds a B.S. from
the University of Illinois at Urbana-
Champaign.
2-31
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8700-13-(5/80)] to be filed with the
U.S. EPA by August 19, 1980.
Next, contract a licensed disposal
facility to accept the hazardous
waste. If the facility is in
Illinois, list the hazardous waste on
a supplemental permit and obtain
approval from the Illinois EPA.
Because approval is subject to waste
compatibility segregation, especially
in the case of laboratory waste,
determine general chemical families
based on reactivity. All laboratory
waste packed in a single drum must be
compatible to avoid violent reac-
tions. For example, one drum may be
packed with inorganic acids and
oxidizers; another may contain insec-
ticides, pesticides, herbicides,
heavy metals and their salts, reduc-
ing agents, alkaline caustics, cya-
nides, sulfides, and chlorides; and a
third drum may contain organic sol-
vents, organic acids, and inert
organic chemicals. Each drum con-
taining laboratory wastes must have
an itemized list showing the name and
quantity of every chemical in the
drum. This list must be attached to
the permit.
After approval by the disposal facil-
ity and state EPA, proper packaging
is the next step. An acceptable
packaging procedure is as follows.
Place approximately 2 to 3 inches of
absorbent material in the bottom of
an open-head, DOT-approved, 55-gallon
steel drum. Fill it one-third full
with containers of laboratory waste,
add a sufficient amount of absorbent
material, and gently agitate the drum
to allow absorbent material to fill
in spaces around the containers.
This process will reduce breakage in
transit. Pack the middle one-third
of the drum in an identical manner.
Repeat the procedure for the top
third of the drum, but allow 2 to 3
inches at the top of the drum for
more absorbent material. The large
size bolt (5/8) and ring should be
used for locking the lid on the drum
t.n pn<;iirp int.pnrit.v riurinn ishinmpnt.
bize uu i L (3/oj dnu ring s>nuuiu ue
used for locking the lid on the drum
to ensure integrity during shipment
and disposal.
A manifest itemizing the contents of
each drum must accompany the ship-
ment. The DOT regulations for label-
ing drums of hazardous chemicals
(whether waste or raw materials) must
be observed. Consult Title 49 of the
Code of Federal Regulations for lists
of regulated chemicals, proper ship-
ping names, hazard classes, labeling
requirements, exceptions, and pack-
aging requirements. Determine the
hazard class for drum of laboratory
wastes (e.g., corrosive, poison A,
poison B, flammable liquid, flammable
solid, poison gas, oxidizer, or
organic peroxide) and affix the
proper hazard label to the drum.
When properly packaged and labeled,
the drums are ready for shipment.
The final step is shipment of the
drums to the contracted licensed
disposal facility. In some states
(e.g., Illinois), a licensed waste
hauler must be employed.
SUMMARY
Proper disposal of wastes will re-
quire considerable effort. An insti-
tution, may need to develop a new
department for waste disposal. Also,
the possibility of recycling some
chemical wastes should be investi-
gated, because reuse would be econom-
ically desirable and because landfill
space is limited. As technology
progresses, incineration is another
alternative to be considered.
The reluctance of many people to
accept disposal facilities, especial-
ly in their own neighborhoods,
threatens the survival of the dispos-
2-32
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al industry. The industry desperate-
ly needs assistance in public educa-
tion from all waste generators.
Chemical waste is generated during
the manufacture of every product.
Therefore, everyone must either
assume responsibility for pollution
control and promote environmentally
sound disposal of chemical waste or
do without these products that con-
tribute to our high standard of
living.
2-33
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SESSION 3
LOW-LEVEL RADIOACTIVE WASTE
INTRODUCTION TO SESSION ON LOW-LEVEL
RADIOACTIVE WASTE
Warren H. Malchman
The growing apprehension about nucle-
ar materials may result in the un-
availability of disposal sites for
low-level radioactive materials. The
nuclear accident at Three Mile Island
has caused problems for the nuclear
industry in general and teaching and
research institutions utilizing
radioactive materials.
In the past year, costs for the
disposal of nuclear waste have surged
upward. Price increases and disposal
site regulations have had a debili-
tating effect on nuclear industry
operations and related activity.
Site shutdowns and cutbacks have
forced the utilization of more expen-
sive alternate sites. Site shutdowns
have also resulted in an increase in
the number of regulations and much
stricter enforcement which will
necessitate more involved procedures
with regard to all aspects of low-
level radioactive waste disposal
operations.
It's important to understand why the
disposal of low-level radioactive
waste involves huge expenses and
widespread concern, especially as it
relates to research and teaching
institutions. To understand the
basis of the problem, we need to
examine Federal licensing require-
ments for byproduct materials listed
in the Code of Federal Regulations,
Title 10, Part 30.18. The Code
states that any person (and it is
important to emphasize "person") is
exempt from requirements for a li-
cense set forth in the regulations to
the extent that such a person re-
ceives, possesses, uses, transfers,
owns, or acquires byproduct material
in individual quantities that do not
exceed limits set forth in the Code
of Federal Regulations, Title 10,
Part 30.71, Schedule B. This means
that any person can acquire and
possess radionuclides in limited
quantities without control (for
example, 14C — 100 uCi, 3H — 1000
uCi, 125I - 1 pCi, 60Co - 1 uCi, and
so on). It is important to emphasize
that this applies to individual
possession. Licenses issued to
institutions do not permit unregu-
lated exempt quantities. The Nuclear
Regulatory Commission has long con-
tended that unless one regulates the
"exempt" quantities, one cannot
As Director of the Office of Radia-
tion, Chemical, and Biological Safety
at Michigan State University, Mr.
Malchman is responsible for the
development and implementation of a
comprehensive radiation, chemical,
and biological safety program. He
has extensive experience in radiation
safety and has presented papers at
international conferences. He holds
a B.S. from the University of
Buffalo, and an M.S. from the_ Univer-
sity of Rochester.
3-1
-------
determine when there is an accumula-
tion to licensable levels. Licensees
must revert to permissible air and
water levels as the lower limit below
which no concern about radioactivity
is necessary. These maximum permis-
sible concentrations in air and water
are listed in the Code of Federal
Regulations, Title 10, Part 20,
Appendix B, Table II, which pertains
to unrestricted area permissible
levels.
The law is different in its applica-
tion to institutions vs. individuals.
Fear of high-level radiation from
accidents at nuclear plants has
spread a fear of all radioactive
materials regardless of quantity.
There is general agreement that
present government regulations on
low-level waste should be revised and
that hospitals and colleges need not
go to great expense to dispose of
materials containing minute amounts
of radioactivity. These could be
safely handled by conventional dis-
posal methods. Without more realis-
tic solutions for disposal of low-
level wastes, the magnitude of medi-
cal and biomedical research and
treatment efforts will have to be
drastically curtailed, and perhaps
eventually halted.
3-2
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APPLICATION OF NUCLEAR REGULATORY COMMISSION REGULATIONS
TO UNIVERSITY WASTE DISPOSAL PRACTICES
Carl J. Paperiello
The Code of Federal Regulations (CFR) authorizes several methods of disposal
of byproduct radioactive material. These methods include release of radio-
active gases and liquids to the environment, disposal of radioactive sub-
stances as directed in 10 CFR 20.301, and transfer by Nuclear Regulatory
Commission (NRC) licensees to other licensees for ultimate disposal. The
disposal of radioactive wastes is a major problem for universities, and inci-
dents have occurred involving the handling of university waste.
Several methods of disposal of by-
product radioactive material are
authorized by Nuclear Regulatory
Commission (NRC) Regulations in the
Code of Federal Regulations, Title
10, Parts 20 and 30 (10 CFR 20 and 10
CFR 30). These methods include
release of radioactive gases or
liquids to the environment, as autho-
rized by 10 CFR 20.106; disposal of
radioactive substances, as directed
in 20 CFR 20.301; and transfer by NRC
licensees to other licensees for
ultimate disposal, as authorized by
10 CFR 30.41.
Certain conditions govern the release
of unrestricted radioactive material
to the environment. Material re-
leased as liquid must be either
soluble or readily dispersible in
water, and at the point of release,
it must meet concentration limits
specified in 10 CFR 20. Radioactive
gases that are released must also
meet concentration limits specified
in 10 CFR 20. Disposal in sanitary
sewers is authorized by 10 CFR
20.303; however, certain concentra-
tion limits must be met and the
overall release limit is 1 curie per
year. Burial in soil is currently
authorized by 10 CFR 20.304.
The amount of waste per burial and
the number of burials permitted per
year are limited by 10 CFR 20.
Recent rulings have proposed elimi-
nating this method of disposal except
as specifically authorized in an NRC
license. As of January 28, 1981,
this method of disposal will be
prohibited except as specifically
authorized in an NRC license. This
As Chief of the Materials Radiologi-
cal Protection Section 1 in the
Region III Office of the Nuclear
Regulatory Commission, Dr. Paperiello
supervises the inspection program for
materials licenses in Illinois, Iowa,
Minnesota, Missouri, and Wisconsin.
His experience includes work as a
radiation specialist and research
scientist. He holds a Ph.D. from the
University of Notre Dame.
3-3
-------
provision of 10 CFR 20 will probably
be greatly restricted by the end of
1980. A facility is permitted to
incinerate waste, as authorized by 10
CFR 20.305, if it has obtained an NRC
license. Transfer of a license to an
approved recipient, as governed by 10
CFR 30.41, is the most widely used
waste disposal method. If a site can
be found that will accept the materi-
al, there is almost no limit on the
amount of waste that can be trans-
ferred.
Current problems in waste disposal
involve the transfer of waste to an
authorized recipient for ultimate
disposal by burial. The closing of
burial sites in West Valley, New
York; Maxey Flats, Kentucky; and
Sheffield, Illinois, has resulted in
a significant increase in disposal
cost because of longer shipping
distances and higher fuel costs.
Currently, only three states operate
approved burial sites for the dis-
posal of radioactive waste. With the
shipment of radioactive waste from
Three Mile Island, these three states
perceived themselves as the nuclear
waste dumps for the rest of the
country. This perception was com-
pounded by the public's increased
awareness and concern with the haz-
ards of chemical waste dumps. None
of these citizens wanted a nuclear
"Love Canal" in their state.
Furthermore, after the Three Mile
Island accident heightened the pub-
lic's awareness of the activites of
the nuclear industry, several trans-
portation incidents occurred at the
burial site in Beatty, Nevada. These
incidents, all involving out-of-state
shipments of nuclear waste, caused
the Governor of Nevada to close the
site. The Governors of the remaining
two states with operating sites,
noting that they had similar prob-
lems, closed or threatened to close
their sites unless corrective action
was taken. The NRC reached an agree-
ment with the Governors of these
three states to place NRC inspectors
full time at the burial sites to
inspect incoming waste shipments. At
the time of the agreement, the NRC
had no jurisdiction over the shipment
of small quantities of radioactive
material (amounts less than Type B),
which were under the jurisdiction of
the Department of Transportation
(DOT). Therefore, on December 3,
1979, 10 CFR 71 was changed to re-
quire NRC licensees to comply with
DOT regulations found in 49 CFR
170-179. Also published in the
Federal Register at the time of the
agreement were the enforcement sanc-
tions that would be used in the event
of noncompliance.
The NRC still has inspectors at the
burial sites to examine incoming
shipments of waste. In cases of
noncompl iance with NRC or DOT regu-
lations, enforcement action is taken,
which includes the issuance of civil
penalties.
The disposal of radioactive wastes
involves two major problems for
universities. The first concerns the
disposal of liquid scintillation
vials. Because these vials contain
an organic liquid that is not misci-
ble with water, they cannot be re-
leased to either the environment or
the sewer (pursuant to 10 CFR 20.106
or 10 CFR 20.303). Their volume and
the flammable nature of their con-
tents preclude burial (pursuant to 10
CFR 20.304), an option that probably
will not be available by the end of
1980. Therefore, incineration (pur-
suant to 10 CFR 20.305) and transfer
of liquid scintillation vials (pursu-
ant to 10 CFR 30.41) are the only
practical alternatives for the dis-
posal of these substances. The
latter option has been used most
often. The second problem involves
3-4
-------
the disposal of radioactive animals
and other biological media. This
problem is compounded if biohazards
are also involved. Incineration and
transfer of radioactive animals and
other biological media are generally
the only viable alternatives for the
disposal of these substances. Both
of these waste disposal problems are
compounded by the fact that most
university waste is either flammable
or combustible.
Four incidents involving the handling
of university waste have been re-
ported to the NRC Region III office.
The first incident involved what
appears to be a generic problem--
corrosion of waste drums. Storage of
these drums in damp areas for long
periods of time had resulted in
corrosion from the outside. Also,
corrosive chemical or biological
material had attacked the steel and
caused corrosion from the inside out.
Storage in this manner violates a DOT
regulation [49 CFR 173.392(.c)(l)]
that requires material to be packaged
in strong, tight parcels to prevent
leakage of radioactive material
during transportation. (It should be
noted that corrosion also can be
caused by liquid scintillation fluids
and tissue solubilizers.)
The discovery of a leaking corroded
drum in a shipment arriving at a
burial site can result in a civil
penalty from the NRC. In addition,
the state could ban the shipper from
the site.
The second incident involved a drum
containing an isotope of a type and
quantity not indicated on the ship-
ping papers. In this labeling viola-
tion of the DOT regulation, the
shipping papers indicated that the
drum contained small quantities of 3H
and 14C. They did not indicate the
presence of a much stronger 90Sr
source. This noncompliance can
result in a civil penalty. Univer-
sity health physicists must partic-
ularly guard against the placement of
other hazardous substances in drums
reserved for radioactive (radwaste).
The third incident involved the
burial of material in violation of
limits established by 10 CFR 20. In
such cases, the NRC may require the
licensee to dig up the material and
dispose of it properly or obtain a
license amendment authorizing the
burial. In the latter case, the
licensee must demonstrate that the
material would not represent a hazard
or potential hazard if allowed to
remain in its current location.
The fourth incident involved a non-
radiological issue. Because toluene
and xylene used in liquid scintilla-
tion fluids are flammable, radio-
active waste containing these liquids
must be stored in accordance with
local fire codes.
A long-term solution to the four
problems raised by these incidents
would be to open new regional burial
sites that include faclities for
disposal of flammable and combustible
material by incineration as well as
solidification facilities for aqueous
liquids. All long-term solutions
will take years to implement; how-
ever, short-term solutions can be
implemented now.
One short-term solution is to pro-
hibit the disposal of nonradioactive
material in radwaste drums. In some
laboratories using radioactive mate-
rial, all waste is disposed of in the
radwaste drum, a practice that should
no longer be allowed. Waste should
be surveyed and segregated.
A second short-term solution is to
segregate and hold short-lived radio-
active material for decay and even-
tual disposal as normal trash. I
3-5
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have frequently found short-lived
isotopes such as "mTc, 67Ga, 313I,
51Cr, and 32P in radwaste barrels in
waste haulers' wastehouses. I have
also dicovered drums containing only
short-lived material that would have
decayed to background levels before
reaching the burial site. The second
solution can be made practical
through careful segregation of iso-
topes having half-lives as long as 60
days. If this method causes the
university to exceed its possession
limits, the NRC Materials Licensing
Branch can issue a license amendment
authorizing an increase in the lim-
its. In this case, the licensee will
be asked to describe his storage
facility to ensure that material is
properly secured and presents no
radiation hazard to the public.
Otherwise, a license amendment is not
needed to use this method.
A third short-term solution is the
use of incineration. In 45 FR 67018,
published October 8, 1980, it is
proposed that 10 CFR 20 be amended to
allow the release of up to 5 curies
per year of 3H and 1 curie per year
of 14C to the sewer in addition to
the 1 curie of material now per-
mitted. Animals and liquid scintil-
lation vials containing 3H or 14C
below certain limits could be dis-
posed of without regard to radioac-
tivity. The NRC will grant a license
amendment authorizing incineration
(pursuant to 10 CFR 20.305) if the
licensee can show that the airborne
concentrations at the release point
will not exceed 10 CFR 20 limits and
the ash will be handled properly. In
response to frequent calls from
licensees who inquire about the
procedure for building an inciner-
ator, I suggest they hire a local
contractor who knows how to build an
incinerator that meets all local and
state ordinances and Federal EPA
standards for nonradioactive incin-
eration. Licensees should then
demonstrate that their incinerator
will meet NRC requirements. F.or
university and hospital waste, NRC
requirements are usually easy to meet
because the specific activity of the
material to be incinerated is very
low. The major problem usually
involves meeting the regulations
concerning nonradioactive pollutants.
If all of the short-term solutions
are adhered to, the only waste a
university would ship for burial
would be dry, noncombustible radio-
active material with a half-life in
excess of 60 days. For most institu-
tions, this would be a small fraction
of the waste currently being shipped.
3-6
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SAFETY CONSIDERATIONS IN DISPOSAL OF LOW-LEVEL RADIOACTIVE WASTE
A. J. Solari
Evidence indicates that the fastest-growing type of low-level radioactive
waste poses little danger to human health. Further, safe disposal of all
radioactive waste seems possible. We in universities should properly dispose
of our own waste and help educate the public about safety considerations.
First, we must define low-level
radioactive waste. Although an
adequate definition does not exist,
we can arrive at a working definition
by eliminating what is not low-level.
We can eliminate high-level waste,
which is legally defined as reactor
fuel elements and the first solvent
extractions from them. We can elim-
inate radioactivity in its natural,
unrefined, or unconcentrated states.
We can also eliminate transuranics
because they are usually treated
separately. Everything else can be
considered low-level waste.
One difficulty with this definition
is that the quantity of radioactivity
in an item considered low-level waste
varies enormously. At the upper end,
university kilocurie irradiator
sources are "low-level waste." At
the lower end, there i-s scarcely any
limit. If measurement or calculation
reveals activity above the natural
background level, the waste is con-
sidered radioactive. (Nobel Prize
winner Yalow of radio-immuno-assay
fame testified that if she injected
into an animal an amount of carbon-14
and potassium-40 equal to the quan-
tity nature had put in her body, she
would have to treat the animal as
radioactive waste.) Thus, the activ-
ity range of low-level radioactive
waste encompasses 14 to 15 orders of
magnitude.
The physical form of the material
varies from animal carcasses and
other biological agents to paper,
plastic, glassware, and metal.
Individual items vary in size from
contaminated hypodermic needles to
building rubble or accelerator mag-
nets.
Where does the bulk of institutional
low-level waste originate? A study
by the University of Maryland for the
Nuclear Regulatory Commission (NRC)
estimated that medical and academic
institutions shipped 7771 cubic
meters of low-level waste for burial
in 1977. Medical institutions sup-
plied 7 percent of this waste, bio-
logical research institutions ac-
counted for 79 percent, and other
sources provided the remaining 14
percent.
Mr. Solari is Director of the Radia-
tion Control Service of the Univer-
sity of Michigan.
3-7
-------
That the life sciences generate the
bulk of the waste is no surprise to
the university health physicist. Our
engineers and physicists purchase a
source the size of a cigarette fil-
ter, and it is the same size when
they turn it in for disposal as
radioactive waste. On the other
hand, those working in biological
research often receive an ounce of
radioactive solution and turn in for
disposal 150 pounds of glassware,
animal carcasses, excreta, and vials.
The Maryland study of waste disposal
in 1977 reported that a total of 1688
Ci was shipped; 81 percent (1367 Ci)
of this was hydrogen-3, which along
with carbon-14 would have a long-
range impact. The study also noted
the fastest-growing waste form was
liquid scintillation waste, which by
any criteria is considered low-level
waste. According to the July 1975
issue of the newsletter Health Physi-
cist, a survey at the University of
Colorado, which was verified by
studies at eight other institutions,
revealed that the average specific
activity of these solutions is only
0.0006 uCi/ml.
How dangerous is this fast-growing
waste? In NUREG-0656, the NRC calcu-
lated the dose to a maximally exposed
individual from incinerator effluents
produced in the disposal of liquid
scintillation waste by combustion.
The assumptions underlying the calcu-
lations were extremely conservative
and thus yielded results higher than
would be expected from an actual
facility. These results were normal-
ized to 1 Ci per year for tritium and
0.01 Ci per year for carbon-14.
Inhalation of hydrogen-3 would expose
an individual to 0.04 mrem per year,
and ingestion of hydrogen-3 would be
equivalent to a dose of 0.512 mrem
per year. Inhalation of carbon-14
would cause exposure to 0.0114 mrem
per year, and ingestion of carbon-14
would result in a dose of 3.09 mrem
per year.
Professor Whipple in "The Environ-
mental and Ecological Forum 1970-
1971" assumed that a powerplant would
release 10,000 Ci of tritium to the
environment. He claimed that until
the last of these tritium atoms
decayed, the total resulting radia-
tion exposure of the world population
would be "1.3 man-rem spread over the
whole teeming mass of humanity."
According to Whipple, if all the
years of life lost because of the
tritium produced by a nuclear power-
plant in one year were added, the
result would be one-tenth of a man-
year. The release of 1 Ci of tritium
per year from the combustion of
scintillation waste would shorten a
total life span by 5.25 minutes.
Further, the Colorado survey indi-
cated that 440,000 gallons of scin-
tillation waste is needed to produce
1 Ci.
Eisenbud (in Science) has noted that
both hydrogen-3 and carbon-14 are
produced naturally by interaction of
cosmic rays with the atmosphere.
Because tritium is produced at a rate
of 1.9 million Ci per year and
carbon-14 is produced at a rate of
38,000 Ci per year, steady-state
global inventories amount to 34
million Ci of hydrogen-3 and 315
million Ci of carbon-14. Eisenbud
maintains that compared with these
quantities, the amounts of hydrogen-3
and carbon-14 present in the wastes
from clinics and laboratories are
minimal; roughly 2390 facilities in
the United States used one or both of
these nuclides in 1978 and shipped a
total of 720 Ci of hydrogen-3 and 221
Ci of carbon-14 to waste burial
grounds.
3-8
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These data suggest that the fastest-
growing category of low-level radio-
active waste is scarcely a radioac-
tive hazard at all, but is instead a
chemical or fire hazard. At present,
however, liquid scintillation waste
is still considered radioactive
waste.
Universities use other radionuclides.
How hazardous are these when disposed
of in an appropriate fashion? For
most institutions proper disposal
means shipping waste to a commercial
burial ground, although a few insti-
tutions have burial sites of their
own.
The NRC study "Evaluation of Alter-
nate Methods for the Disposal of Low
Level Radioactive Wastes" (NUREG
CR-0680) discussed a hypothetical
shallow land burial facility. Some
of the parameters are listed in Table
1. It was assumed that after 150
years the site would be reclaimed,
people would move in, and wells would
be drilled. To protect these indi-
viduals and reduce their radiation
exposure to permissible limits would
require that wastes not exceed the
maximum concentrations indicated in
Table 2. The concentrations were
used to calculate the amount of
radioactive material that could be
packaged into a single 55-gallon
steel drum. The effect of 150 years
of isolation is obvious from the
value shown for cobalt-60. This NRC
study (NUREG CR-0680) could lead to a
more useful definition of low-level
radioactive waste.
Universities with research reactors
also generate high-level radioactive
waste. How dangerous is the disposal
of such waste? Plans for disposal of
high-level radioactive waste involve
deep burial in stable geological for-
mations after placement in a fire-
proof, waterproof glass matrix. In
the June 1971 issue of Scientific
America, Professor Bernard Cohen
calculated that if nuclear-powered
facilities generated all U.S. elec-
tricity, buried nuclear waste would
cause four fatalities in the first
million years.
What if the stable geological forma-
tions and the glass matrix failed to
meet expectations? Professor Cohen
calculated that random burial at a
depth of 2000 feet (e.g., under
houses, schools, farm lands, and
water supplies) would produce a death
rate of 1.1 per year during the first
200 years and 0.4 per year there-
after.
Although experimental verification of
these calculations is impossible, one
encouraging sign is the "Okla Phenom-
ena," which occurred in what is now
the Republic of Gabon in Africa. At
least four reactor zones went criti-
cal 1.8 billion years ago and pro-
duced an average of 20 kilowatts of
terminal power for half a million
years. In "The Health Hazards of Not
Going Nuclear," Peter Beckmann dis-
cusses this incident. He states that
12,000 pounds of waste fission pro-
ducts, and 4,000 pounds of plutonium
(virtually all decayed now) have not
budged an inch out of their reactor
zones in 1.8 billion years. This
situation was produced by blind
chance, and no particularly favorable
chemical or other immobilization
mechanisms were at work. Beckmann
asks, "Cannot men do at least as
well?"
If these reports are true, why is
there resistance to burial grounds?
Why have operators of such grounds
shut down or restricted their intake?
Why do we need this conference if
low-level radioactive waste is a low
health hazard compared with other
everyday hazards? Although part of
3-9
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TABLE 1. PARAMETERS OF A SHALLOW LAND BURIAL FACILITY
No. of trenches
Measurements of each trench
Minimum distance to site bounds
Distance from trench bottom to aquifer
Distance to surface water (river)
Water velocity in aquifer
Depth at which trench is covered
315
100 m by 8 m by 6 m
160 m
10 m
1000 m
100 m/yr
1.0 m
TABLE 2. MAXIMUM WASTE CONCENTRATIONS AT A SHALLOW LAND BURIAL FACILITY
Waste
3H
14C
60Co
90Sr
239pu
137Cs
Maximum
concentration,
pCi/cm3
15
0.024
55,000
0.17
1.0
8.3
Activity per
55-gallon drum
3 Ci
5 mCi
11,450 MCi
35 mCi
208 mCi
1.7 Ci
Pathway
Well water
Food channel
Direct exposure
Food
Reclamation
Direct exposure
3-10
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the explanation may be agitation by
those exposed to nuclear power, I
believe that a change in social
awareness and expectations is the
more basic reason. We live in the
era not only of Three Mile Island,
but also of Love Canal and the Valley
of the Drums. Routinely the evening
news reveals a chemical dump just
discovered not far from homes or
schools. What's in those drums? No
one knows. Who put them there? No
one steps forward. Who is going to
remove the waste? Silence. Who is
going to guarantee that homes,
schools, etc. are safe? No one. Who
is responsible for the mess?
Is it surprising that the public now
expects each new technological devel-
opment to be analyzed thoroughly and
understood from start to finish
before a commitment is made by gov-
ernment or large industry to that
technological development? Would the
State of Michigan have approved the
use of polybrominated biphenyl (PBB)
as a fire retardant if the citizens
had known that it could so strongly
affect so many people? Would the
public of yesterday have approved the
development of the horseless carriage
if they had known that it would cause
50,000 deaths per year?
The public wants to ensure that there
are no more Love Canals. Can the
generators of radioactive waste
convince the public that precautions
are being taken, that strict stan-
dards are being observed, and that
every effort is being made to protect
the environment from radiation, the
"ultimate pollution." Bumper stick-
ers proclaim "Be active, not radio-
active." Although the most vocal
groups direct criticism primarily at
powerplants, they are not reluctant
to confront universities.
In part, the nuclear industry is a
victim of its own behavior. Waste
disposal was a low-priority item.
Some effort was expended to find a
use for fission products, but that
effort foundered. After that,
scarcely enough high-level waste was
produced to justify a large commit-
ment. Besides, there was always time
to attack the problem in the future.
Then some tanks at Hanford leaked.
Does this inspire confidence?
Salt mines in Kansas were investi-
gated and found satisfactory for
disposal of high-level radioactive
waste. Political opposition oc-
curred, however, and flaws were found
that eliminated further consideration
of that site. Again confidence in
the Atomic Energy Commission was
shaken.
Are we in universities doing every-
thing in our power to earn the confi-
dence of the public in our own waste
handling system? I think we need to
do more.
To summarize, I believe strong evi-
dence suggests low-level radioactive
waste can be disposed of safely and
with minimal impact on human health.
We in universities need to make
certain that we do our part by prop-
erly packing, labeling, and moni-
toring waste and educating the pub-
lic.
BIBLIOGRAPHY
Beckmann, P. The Health Hazards of
Not Going Nuclear. The Golem
Press, Boulder, Colorado, 1976.
Bell, M. D. Progress Report on NRC's
Low-Level Waste Program. In:
Proceedings of the 10th Annual
National Conference on Radiation
Control. HEW Pub. No. (FDA)
79-8054, pp. 254-256, 1979.
3-11
-------
Blanchard, R. L. , et al. Supple-
mentary Radiological Measure-
ments at the Maxey Flats Radio-
active Waste Burial Site:
1976-1977. EPA-520/5-78-011,
September 1978.
Eichholz, G. G. Environmental Aspect
of Nuclear Power. Ann Arbor
Science Publishers, Inc., Ann
Arbor, Michigan, 1980.
Marshall, E. Radioactive Waste
Backup Threatens Research.
Science, 206:431-433, 1979.
Montgomery, D. M. , H. E. Kolde, and
R. L. Blanchard. Radiological
Measurements at the Maxey Flats
Radioactive Waste Burial Site:
1974 to 1975. EPA-520/5-76-020,
January 1977.
Morisawa, S. , et al. ,
Safety Assessment
Level Radioactive
Storage Facility:
Risk Evaluation by
Radiological
for a Low-
Solid Waste
Preliminary
Reliability
Techniques.
35:817-834,
Health
1978.
Physics,
National Academy of Sciences. The
Shallow Land Burial of Low-Level
Radioactivity-Contaminated Solid
Waste. Panel on Land Burial,
Committee on Radioactive Waste
Management, Commission on
Natural Resources, NRC, 1976.
O'Connel, M. F. , and W. F. Holcomb.
A Summary of Low-Level Radio-
active Wastes Buried at Commer-
cial Sites Between 1962-1973,
With Projections to the Year
2000. Radiation Data and
Reports, 15:759-767, 1974.
Shealy, H. G. Impact of the Proposed
Federal Government Taking Over
Low-Level Waste Burial Sites.
In: Proceedings of the 10th
Annual National Conference on
Radiation Control. HEW Pub. No.
(FDA) 79-8054, 1979. pp. 257-
258.
Straub, C. P.
Wastes.
Technical
ton, D.C.
Low-Level Radioactive
U.S. AEC Division of
Information, Washing-
, 1964.
U.S. Energy Research and Development
Administration. Management of
Wastes from the LWR Fuel Cycle.
In: Proceedings of Internation-
al Symposium, Denver, Colorado,
July 11-16, 1976. ERDA Report
No. CONF-76-0701 (ABSTS).
U.S. Environmental Protection Agency.
Proceedings: A Workshop on
Issues Pertinent to the Develop-
ment of Environmental Protection
Criteria for Radioactive Wastes,
Reston, Virginia, February 3-5,
1977. U.S. EPA Report No.
ORP/CSD-77-1, 1977.
Wheeler, M. D. Burial Grounds. In:
Proceedings of Symposium on
Management of Wastes From the
LWR Fuel Cycle, July 1976. ERDA
Report No. LA-UR-76-1722, 1976.
3-12
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EXPERIENCES WITH VARIOUS DISPOSAL METHODS AT
THE UNIVERSITY OF WISCONSIN-MADISON
Elsa Nimmo
Research and medical personnel at the University of Wisconsin-Madison generate
approximately 20,000 ft3 of low-level radioactive waste each year. This waste
is in the form of animal carcasses, scintillation vials, packages of paper and
plastic refuse, and 5-gallon containers of liquids. In order to handle this
high volume, low-level radioactive waste in a safe and lawful manner, the
university relies on a centralized system of collection and processing to
prepare waste for disposal by incineration, burial in local landfills, and
storage for decay or disposal by a commercial waste service. Past operating
experience has demonstrated the value of stringent administrative and physical
controls in the prevention of improper disposal of radioactive substances.
The waste handling system and controls currently in use at the University of
Wisconsin-Madison will be discussed.
I'd like
brief
waste
sity
year,
personnel
20,000 ft3
to begin by presenting a
overview of the radioactive
handling program at the Univer-
of Wisconsin-Madison. Each
university research and medical
generate approximately
of low-level radioactive
waste. This waste consists of animal
carcasses, liquid scintillation
vials, papers, plastic, and liquids.
The university uses a central collec-
tion and processing system to prepare
these wastes for disposal. Three
full-time technicians are permanently
assigned to waste disposal duties.
We estimate that approximately one-
half to one-third of their time is
spent on radioactive waste, with the
remainder spent on nonradioactive
chemical and biological waste. These
individuals are responsible for
collecting the waste, preparing it
for disposal, and maintaining the re-
quired records.
I should preface my next remarks by
saying that we don't have any new
solutions to the problem of low-level
radioactive waste disposal. At the
University of Wisconsin-Madison, we
are currently using the same waste
disposal methods that we've used in
previous years. These methods are
incineration, local landfill burial,
storage and decay, and use of a
commercial radioactive waste disposal
firm. Many changes have been made in
our radioactive waste handling pro-
Ms. Nimmo is Radiation Safety Officer
at the University of Wisconsin-
Madison. She is a member of the
State Radiation Protection Council
Subcommittee on Credential ing of
X-Ray Technicians and a member of the
Advisory Panel of the Senate Subcom-
mittee on Uranium Exploration Safety.
She holds a B.S. from the University
of Redlands, California, and an M.S.
from the University of .Wisconsin-
Madison.
3-13
-------
gram, but they have been in the areas
of organization and control.
One problem that all waste disposal
services continually face is the
difficulty in obtaining cooperation
from the individuals who generate the
waste. It isn't that lab workers or
faculty members intentionally cause
problems, but, like people every-
where, they tend to consider an item
properly disposed of once they throw
it into a waste container. Thus, a
critical part of any radioactive
waste disposal program is education
of the individuals generating the
waste.
The university's efforts in waste-
generator education involve the
following components:
I. We provide detailed written
waste handling instructions. We
specifiy exactly what type of
packaging is aceptable, includ-
ing catalog numbers if persons
choose to order packaging mate-
rials from university stores.
We also provide what we hope are
simple-to-use labels.
2. Before a new faculty member
can become authorized to use
radionuclides on campus, a
health physicist visits the
facility. One purpose of this
visit is to discuss the proposed
procedures for handling wastes.
Because many of the researchers
may have used radionuclides at
another institution, this is a
good opportunity for us to
clarify our requirements.
3. Students and laboratory
workers are required to pass an
exam on radiation safety before
using radionuclides. This exam
includes questions on proper
waste disposal procedures.
4. Probably the most valuable
part of our educational effort
takes place in discussions
between the health physics staff
and laboratory workers. In the
course of their regular un-
announced inspections, health
physics technicians ask lab
workers to explain and demon-
strate how radioactive wastes
are handled in their lab. This
gives lab workers an opportunity
to ask questions and to clear up
any misunderstandings.
5. Finally, when the wastes
are collected, health physics
technicians pay close attention
to be certain that wastes are
packaged and labeled correctly.
Whenever a problem is noticed
(e.g., the label does not speci-
fy the quantity of material or a
package identified as containing
tritium has a surface exposure
rate of 2mR/hour), the techni-
cians immediately contact the
authorized faculty member. If
problems persist with a partic-
ular research group, a citation
may be issued and the authorized
user may have his or her radio-
nuclide ordering privileges
suspended.
This discussion about the educational
program is worthwhile for several
reasons. First, we need to be cer-
tain that the packaging and informa-
tion provided are adequate to protect
our own personnel from nonradiation
hazards as well as from possible
radiation hazards. For example,
people need to be reminded regularly
to package syringes and glassware
correctly. It is somewhat disturbing
to be poked with a syringe while
collecting waste. Second, if we are
to dispose of radioactive waste
correctly, we have to know what type
of waste we are dealing with. Third,
3-14
-------
we have other requirements related to
practical considerations that are
unique to our particular disposal
system. For instance, we tend to get
very perturbed if we find solids
mixed in with the liquids given to us
for incineration. If liquids contain
sludge, plastic gloves, animal tis-
sues, or other solids, the half-life
of the pumps used to transfer liquids
from their storage tanks to the
incinerator will drastically decrease
and the whole system will soon be
down for repairs. It is therefore
important for the health physics
staff to provide lab workers with
detailed information on our require-
ments, including, if possible, the
reasons behind them.
Now I'd like to discuss our waste
collection system. Both radioactive
and nonradioactive animal carcasses
are collected three times a week and
other solid and liquid chemical and
radioactive waste is collected twice
a week. Researchers phone the Safety
Department in advance to request
collection of the waste. This de-
partment hauls the wastes to locked
storage cabinets (animal carcasses
are hauled to locked freezers), which
are usually located on the loading
docks of the buildings. Occasional-
ly, the freezers or cabinets may be
full or a person may want to dispose
of waste that would cause the expo-
sure rate at the cabinet surface to
exceed 2mR/hour. When this happens,
this person arranges for the waste
disposal technicians to call him or
her when they arrive at the building.
They then transport the waste to the
loading dock.
As I mentioned earlier, the techni-
cians thoroughly check the waste they
collect. All packages are scanned
with a Geiger-Muller (GM) counter
regardless of whether they are iden-
tified as containing radioactivity or
chemicals only. The labeling is
checked to be certain that the mate-
rial, quantity, and authorized user
are indicated. Except for wastes
that will be incinerated, everything
is taken directly to the university's
waste storage area and sorted.
Radioiodines, phosphorous-32, and
other short-lived materials are put
in storage areas reserved for decay-
ing waste. Other long-lived or
relatively high-level solid wastes
are packed into 55-gallon drums that
are approved by the Department of
Transportation (DOT) and eventually
shipped to a commercial waste dis-
posal service. By volume, the major-
ity of the waste consists of paper
and plastic lab bench covers, paper
towels, gloves, etc., possibly con-
taminated with small quantities of
tritium or carbon-14. This waste is
segregated for future burial in a
local landfill.
Now I'd like to discuss each disposal
method in more detail.
INCINERATION
Our current license from the Nuclear
Regulatory Commission (NRC) permits
us to burn a combined total of 50
mi Hi curies of carbon-14 and tritium
per day and a total of 1 millicurie
per incineration of all other byprod-
uct material. For the past I~h
years, incineration of radioactive
materials has been limited to two
incinerators: one used for solvents
and radioactive liquids and the other
for animal carcasses and scintilla-
tion vials. A member of the health
physics staff must first check all
waste to be burned in the incinera-
tors. An individual lab worker or
faculty member cannot bring radio-
active waste to an incinerator and
have it burned.
3-15
-------
In 1979, the solvent destructor was
used to dispose of approximately l~h
curies of tritium and 220 millicuries
of carbon-14 contained in a total of
22,000 gallons of liquids. Calcula-
tions based on Button's Diffusion
Equation show that the resulting
worst-case air concentration averaged
over 1 year was 9/100 of 1 percent of
the maximum permissible concentration
(MPC) for an unrestricted area. This
concentration is for any point of
reasonable human occupancy. By "any
point of reasonble human occupancy,"
I mean any spot to which persons
might have access without resorting
to extreme measures. In our current
license renewal, increased incinera-
tion limits are requested primarily
to allow incineration of radioactive
liquids other than tritium and
carbon-14 that will otherwise have to
be solidified and shipped to a
licensed disposal service.
In 1979, approximately 840 mini-
curies of tritium, 52 millicuries of
carbon-14, and relatively small
quantities of an assortment of other
radionuclides were disposed of in the
solid waste incinerator. The result-
ing maximum air concentration aver-
aged over 1 year at any point of
reasonable human occupancy is calcu-
lated to be less than 5 percent of
the MPC for an unrestricted area.
Again, Sutton's Equation was used and
a worst-case was assumed (e.g., it
was assumed that the entire quantity
of each radionuclide was present in
the effluent).
Individual researchers currently are
not charged for any waste disposal
service except for the incineration
of liquid scintillation vials. These
charges were established because
scintillation vial incineration is an
unusually labor-intensive operation.
The operator must place the vials in
the incinerator a few trays at a
time, adding additional trays every
10 minutes or more. The heat melts
the plastic tops off the glass vials
and ignites the contents. The incin-
erator operator must be careful to
leave an ash buildup in the inciner-
ator before burning vials to prevent
the glass from melting on the hearth.
Although incineration has many advan-
tages, it does not eliminate all of
the burned waste. In 1979, the
university shipped twenty-five 55-
gallon barrels of ash to a licensed
disposal service. This accounted for
over half of all radioactive waste
shipped to a commercial disposal
service in that year. Any ash that
causes GM readings to exceed the
background level is considered radio-
active and is packed directly into a
DOT-approved 55-gallon drum as the
incinerator is cleaned. If very
low-energy, nonvolatile beta emitters
are incinerated in the future, a more
sophisticated system for beta analy-
sis would have to be used to deter-
mine whether ash must be handled as
radioactive waste.
LOCAL LANDFILL BURIAL
By volume, 50 percent of the collect-
ed waste currently is buried in a
local landfill. Once again, the
major radionuclides possibly present
are tritium, carbon-14, and sulfur-
35. Worst-case calculations have
been done to evaluate the possible
effects of this disposal method on
water quality. In the following
calculation, it was assumed that no
radioactive material was leached from
the soil until the landfill had
reached the end of its useful life
and that in the following year, all
of the radioactive material that had
accumulated there in the previous 20
years (the average lifespan of a
landfill in Wisconsin) was leached
3-16
-------
out. If data for this university's
1978 landfill burial are used as
annual averages and data on average
annual Wisconsin rainfall are also
used, this worst-case calculation
would show that less than 5 percent
of the MPC for an unrestricted area
would be present in the leached water
itself.
STORAGE AND DECAY
Disposal by decay is my favorite
method. By meeting just a few condi-
tions, it is an ecologically as well
as economically pleasing disposal
method. In order for institutions to
take full advantage of this disposal
method, their NRC license limits must
be generous enough to allow them to
hold radionuclides for decay while
their stocks continue to be replen-
ished. They must also have available
a secure, well-shielded storage area
with sufficient capacity for the
types of wastes they wish to store.
At the University of Wisconsin-
Madison, we are fortunate to have an
underground storage area that at one
time held what must have been an
enormous quantity of molasses. A
ventilation system is currently being
installed because the use of a com-
pactor is anticipated in the future.
SHIPMENT TO A LICENSED COMMERCIAL
WASTE DISPOSAL SITE
Like other institutions, the Univer-
sity of Wisconsin-Madison has had
problems with shipment of low-level
radioactive wastes in the past year.
In an average year, one to three such
shipments are made; in 1979, a single
shipment of forty-seven 55-gallon
barrels went to the NECO site in
Washington State. At this time, no
animals, scintillation vials, or
solidified liquids are being shipped.
The disposal of low-level radioactive
waste appears likely to remain one of
the major problems faced by radiation
safety programs at colleges and
universities in the near future.
Each institution must explore for
itself the possibility of using
alternative disposal methods in case
one or more disposal methods become
unavailable.
3-17
-------
EXPERIENCE WITH INCINERATION OF LOW-LEVEL
RADIOACTIVE WASTE AT THE UNIVERSITY OF ILLINOIS
Hector Mandel and Lorion J. Sanders
Since July 1977, the University of Illinois at Urbana/Champaign (UIUC) has
been disposing of liquid scintillation counting fluid (LSCF) by incineration.
For two and a half years, LSCF has been filtered and added to the No. 2 fuel
oil used to fire the boilers at the UIUC Abbott Power Plant. Only minor
problems were encountered during the first year, and these were related to
equipment and corrosion. The use of stainless steel and a seal less pump has
allowed the system to operate problem free for the past year. Local anti-
nuclear forces and power plant employees expressed opposition during the first
few months of operation, but a public meeting of the UIUC Radiation Hazards
Committee and a training session with the power plant employees apparently
convinced the public and the plant employees that incineration is the best
method for disposal of LSCF. Since the power plant boilers are presently
being converted to burn natural gas, a system is being designed and built to
allow injection of LSCF into the gas-fired boilers.
Disposal of low-level liquid radio-
active waste at the University of
Illinois at Urbana/Champaign (UIUC)
was not a problem until the Sheffield
disposal site was shut down. Aqueous
waste has always been disposed of
through the sewerage or solidified
with plaster of paris and then dis-
posed of as solid waste. (Figure I
shows the amount of solid waste
disposed of per year.) Liquid scin-
tillation waste, which is composed of
volatile, flammable, and toxic organ-
ic compounds, cannot be disposed of
through the sewerage, however, and is
not easily solidified. Although it
is inevitable that some of the liquid
scintillation waste will find its way
into laboratory sinks and down the
drains, large-scale disposal of
liquid scintillation waste through
sewerage is very undesirable. Be-
cause the Sheffield disposal site is
only 100 miles from the UIUC campus,
it was easy to collect liquid scin-
tillation waste and truck it there.
Mr. Mandel is Head of the Health
Physics Section of the Division of
Environmental Health and Safety at
the University of Illinois. He holds
a B.S. and an M.S. from the Univer-
sity of Illinois at Urbana-Champaign.
Mr. Sanders has served for 13 years
as Health Physicist with the Division
of Environmental Health and Safety at
the University of Illinois. His
experience also includes work as a
health physicist on nuclear-powered
ships. He is a graduate of Navy
Nuclear Power School in New London,
Connecticut.
3-18
-------
1960 1964 1968 1972 1976
YEAR
1980
Figure 1. Solid radioactive waste.
3-19
-------
Fortunately, by the time operations
had ceased at the Sheffield waste
site, the Nuclear Regulatory Commis-
sion (NRC) had granted UIUC approval
(in the form of a license amendment)
to incinerate liquid scintillation
waste in the University Power Plant
(Abbott Power Plant).
The liquid waste disposal system
(Figure 2) consists of a tank that
can hold up to 150 gallons of liquid,
a feed pump, an automatic level-
sensing device for the tank, and
associated valves and piping. The
entire system is located close to the
site where the oil tanker trucks hook
up to deliver fuel oil to a nearby
180,000-gallon day tank. The system
is designed so that the metering pump
automatically mixes the liquid scin-
tillation waste with the fuel oil as
it is injected into the day tank.
The University of Illinois paid about
$2,000 to build and operate the
liquid waste disposal system, but
saved about $12,000 during the first
10 months of operations. The univer-
sity encountered technical and polit-
ical problems during the first year
of operation, however.
The technical problems involved the
waste feed pump and the waste storage
tank. The first problem concerned
the original metering pump, whose
neoprene seals required an inordinate
amount of maintenance. This original
pump was replaced by a magnetically
coupled, sealless, centrifugal pump,
which has not required any major
maintenance for more than a year.
The other major problem concerned the
original storage tank, which was made
of cylindrical carbon steel. Because
of extensive corrosion on the inside
of this tank, the line filter fre-
quently became loaded with flakes of
rust. Last summer the original tank
was replaced with a custom-built
stainless steel tank in order to
eliminate or at least minimize corro-
sion. Although the associated piping
is all carbon steel, major corrosion
problems are not expected to develop
because the lines are frequently
backflushed with fuel oil.
Another problem that developed in-
volved the level gauge that was in-
stalled inside the original tank.
This level indicator was basically a
conductivity probe that frequently
gave false readings as a result of
changes in the conductivity of the
liquid scintillation waste. Conduc-
tivity would change as a function of
temperature or as a function of the
impurities in the liquid scintilla-
tion waste. When the waste storage
tank was replaced, a new level sensor
was also installed. The new sensor
is a pressure-measuring device, which
is located under the tank.
The University Power Plant (Abbott
Power Plant) burns an average of
about 50,000 gallons of fuel oil per
day. Stack gaseous release rate
(Table 1) can be calculated easily by
taking into account the amount of air
required to burn each gallon of fuel
oil. Thus, average permissible daily
limits have been derived for the
isotopes that appear in the liquid
scintillation counting waste (Table
2). It is interesting to note that
in 1 day, UIUC could burn twice as
much 14C as they purchase in 1 year,
and an entire year's acquisition of
3H could be burned in less than 2
months without exceeding the release
limits. (Figure 3 shows orders of
isotopes on a yearly basis.) Only
small fractions of the purchased
isotopes wind up in the liquid scin-
tillation waste. Because release
limits are very restrictive for
radioisotopes such as 125I and 131I,
it is necessary to set aside waste
that contains 125I and allow it to
decay. (See Table 2.)
3-20
-------
TANK TRUCK
CO
I
ro
DRAIN
PRESSURE
SENSOR
FUEL
FEED PUMP
180,000-gal
"DAY" TANK
II VII
YSTRAINER
WASTE FEED
PUMP RECIRCULATING]
VALVE
Figure 2. Liquid waste disposal system.
-------
TABLE 1. ABBOTT PLANT STACK EMISSIONS
Fuel oil burned daily = 50,000 gal
Air requirement per pound of fuel oil = 14 Ib air
University use of excess air = 18 Ib air
Combustion results in ~ 5% increase in gas volume corrected to standard
temperature and pressure (STP).
Thus, for each pound of fuel oil burned, the stack emits:
18 Ib air x 454 fex^f^x 1.05
= 6.6 x 106 cm3 air/1b fuel
Fuel oil weighs 7.5 Ib/gal; thus, the daily emission is:
6.6 x 106 x 7.5 x 50,000 = 2.5 x 1012 cmVday
3-22
-------
TABLE 2. AVERAGE PERMISSIBLE DAILY LIMIT (APDL) AT THE ABBOTT POWER PLANT'
Isotope
45Ca
14C
51Cr
3H
125 j
32p
35S
APDL, mCi/day
2.5
250
200
500
0.20
5
22.5
Total burned in year
1977-1978
0.11
21.20
0.18
22.32
0.17
2.19
0.09
1978-1979
0.06
8.70
0.06
613.35
0.39
5.63
0.17
1979-1980
0.19
10.21
115.88
0.09
5.89
3.13
Based on data contained in 10 CFR 20 App. B, Table II, Column I; concen-
tration at the point of release, based on 2.5 x 1012 cmVday.
3-23
-------
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Political problems resulted when some
of the power plant employees became
alarmed after discovering that they
were working near radioactive mater-
ials. The radioactive materials in
the scintillation fluid are in such
low concentrations, however, that
posting of the area around the waste
storage tank is entirely unnecessary.
The workers at the plant were advised
of the hazards involved in storage of
the liquid scintillation waste at the
power plant. They were told that the
radioactivity in the liquid scintil-
lation waste could very easily be
disposed of through the sewerage;
however, because the waste contains
volatile, flammable, toxic, and
possibly carcinogenic organic chemi-
cals, the best way to dispose of it
is by incineration.
It should be noted that the UIUC does
not expect to be able to use this
system again after this summer. The
boilers at the Abbott Power Plant are
presently being converted from fuel
oil to natural gas, and plans are
under way to convert to coal within
the next few years. The UIUC cur-
rently has about 200 gallons of
liquid scintillation waste in stor-
age. The NRC has approved (Tables 3a
and 3b) the incineration of waste in
the natural gas boilers, but the
injection system has not been de-
signed or built. The advantage of
the present system is that the waste
is mixed with the fuel oil before the
fuel is injected into the boilers.
Injection of the liquid scintillation
waste into the gas-fired boilers,
however, will require a separate
injection system with a nozzle. The
UIUC is presently in the process of
procuring the nozzle and associated
equipment (Table 4). It should then
be a relatively simple matter to
install the pump and run the piping
over to the boiler.
3-25
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TABLE 3a. LICENSE CONDITIONS FOR BURNING LSCF IN GAS BOILERS
Airflow rate in both stacks at the Abbott Power Plant is 100,000
ftVmin (average daily stack exhaust); therefore, the average daily stack
exhaust for one stack is: 50,000 ftVmin (STP).
50,000 ftVmin x 60 min/h x 24 h/day = 7.2 x 107 ftVday
7.2 x 0.107 ftVday x 1728 rnVft3 x 16.387 cm3/m3 = 2.04 x 1012 cms/day
Thus, for example, the power plant could burn a specified amount (shown
in Table 3b) of a single radioisotope without exceeding the NRC environmen-
tal limits at the point of release.
3-26
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TABLE 3b. AMOUNTS OF A SINGLE RADIOISOTOPE THAT COULD
BE BURNED WITHOUT EXCEEDING NRC LIMITS
Isotope,
2.04 x 1012cm3
14C
3H
125J
131 J
32p
35S
45Ca
47Ca
51Cr
85Sr
90Sr
NRC limit,3 pCi
1 x 10"7
2 x 10"7
8 x 10"11
1 x 10"10
2 x 10"9
9 x 10"9
1 x 10"9
6 x 10"9
8 x 10"8
4 x 10"9
3 x 10"11
Average
permissible
limit/day, jjCi (mCi)
2.04 x 105 (204)
4.07 x 105 (407)
163 (0.163)
203 (0.203)
4.07 x 103 (4.07)
1.83 x 104 (18.3)
2.03 x 103 (2.03)
1.22 x 104 (12.2)
1.63 x 105 (163)
8.155 x 103 (8.15)
61.16 (0.061)
Based on data contained in 10 CFR 20 App. B, Table II, Column I.
3-27
-------
TABLE 4. ESTIMATED COST OF MATERIALS FOR GAS BOILER INJECTION
Item
3/8-inch (inner diameter)
stainless steel, No. 316,
Schedule 40
Injection nozzles
Toluene monitoring pump
valves
Y-strainer
Couplers
Elbows
Tees
Check valve
Total
Amount needed
400 ft
6
1
1
20
10
3
1
Cost per item
$ 3.00/ft
13.70
1,816.00
54.82
1.69
3.20
4.28
130.00
Total cost
of items
$1,200.00
82.20
1,816.00
54.82
33.80
32.00
12.84
130.00
$3,623.42
3-28
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SESSION 4
RESEARCH- AND HOSPITAL-GENERATED WASTE
WASTE DISPOSAL AT THE MEDICAL CENTER OF THE
UNIVERSITY OF ILLINOIS
Raymond S. Stephens
This paper examines the main problems of hazardous waste disposal and then
discusses the waste disposal standard used by the Medical Center of the
University of Illinois. The central feature of this standard is color coding,
and careful procedures have been developed for segregating, handling, and
treating wastes.
The problem of waste collection and
disposal has many solutions. If
there were only one solution, we
would all react to a grand pronounce-
ment and solve the problem in short
order.
BACKGROUND
First, let's examine
problems in hazardous
tion:
the six main
waste collec-
Identification of type of waste.
Wastes can be a solid, liquid,
or gas. Further, they can be
combustile or noncombustible;
can vary greatly in weight,
shape, and volume; and can have
special characteristics such as
odor, appearance, or putresci-
bility.
Identification of the source of
the hazardous material. Major
problems are encountered in
identifying the sources of
hazardous wastes. For example,
materials that look similar can
come from multiple sources.
Collection systems traditionally
bring similar materials togeth-
er, names and labels on materi-
als are generally not discern-
ible, and retrieval of samples
from the waste stream is unde-
sirable.
Identification of hazards asso-
ciated with each waste sample.
We must identify the particular
hazard associated with each
waste sample before combining
the samples. Labeling is of
great importance because the
cost of analyzing an unknown
material is considerable and
because the consequences of
opening a container of such
material can be significant.
Simply classified, wastes can be
flammable, combustible, or
explosive; toxic; reactive;
corrosive; infectious; and
sharp. Yes, one of the features
of hazardous wastes is simply
Mr. Stephens is Director of the
Environmental Health and Safety
Office of the University of Illinois
at the Medical Center, Chicago.
4-1
-------
the presence of sharp corners,
edges, or points, which can
lacerate and puncture the han-
dler.
Segregation of waste by types
and hazards. Several advantages
result from segregating wastes
by type and hazard at the points
where they are produced. Segre-
gation increases the efficiency
of the treatment processes if
similar wastes are combined at
the beginning of the waste
stream. Also, segregating
facilitates waste handling by
gathering materials of like
consistency, shape, and size.
Another advantage is that segre-
gation prevents dangerous inter-
action between different types
of wastes, such as contact
between corrosive and flammable
material.
Handling of wastes at sources.
Hazardous wastes require either
treatment where they are pro-
duced or packaging for transpor-
tation.
Treatment of wastes. We have
six means of treating wastes:
i nci nerati on, steri1i zati on,
chemical reaction, physical
alteration, decay, and re-
cycling. Any of these, or any
combination of them, can de-
crease the volume of hazardous
wastes and even make wastes fit
for disposal as ordinary rubbish
in the waste stream. Let me
emphasize that the persons who
produce wastes (and I insist
that wastes are produced by
persons, not by departments,
colleges, or firms) are best
able to recommend and institute
the applicable treatments of the
wastes they produce.
If wastes are not treated where they
are produced, they must be adequately
packaged for transportation • to
another site where treatment or final
disposal can take place. Packaging
is a key matter in successful treat-
ment of hazardous waste. A package
must be impervious to the material
placed in it, must be adequately
sealed to prevent loss of material,
must resist penetration by the physi-
cal character of the material (i.e.,
must be sufficiently strong and
puncture-resistant), and must not
react with the waste enclosed. The
package must also be large enough for
the convenience of the user but small
enough to be handled. Finally, the
color of the package, labels, or
insignia applied must give both the
waste producer and the waste handler
information as to how the material
will be handled.
The final phase in the collection and
disposal of hazardous wastes is
transportation to the disposal site.
Wastes must be properly packaged so
that manual handling, vehicle motion,
or other such factors do not allow
release of materials en route to the
disposal site. Other presentations
in this workshop have already dealt
with the permits required for waste
generators, waste transporters, and
disposal site operators.
WASTE DISPOSAL AT THE MEDICAL CENTER
The University of Illinois Medical
Center in Chicago has developed a
hazardous waste disposal standard.
The handling of hazardous wastes is
of primary concern because such
wastes can affect the health and
safety of all university faculty,
staff, other employees, and students
at the Medical Center. Persons
working in areas where these materi-
als are generated must not expose
4-2
-------
others, especially housekeeping,
maintenance, and service workers, to
danger. Thus, users must cooperate
with safety personnel to ensure the
proper packaging, transportation, and
disposal of hazardous wastes.
The central feature of the hazardous
waste disposal program is color
coding. Blue bags, which contain
tissues, organs, carcasses, and other
wastes (both infectious and noninfec-
tious), go to a pathological inciner-
ator. Orange bags, which contain
specimens, cultures, and other infec-
tious wastes, go to an autoclave.
All other bags, which contain ordi-
nary rubbish and nonhazardous solid
waste, go to a compactor. The choice
of color for the ordinary rubbish bag
depends primarily on cost. The most
economical bags may happen to be
black, brown, some other color, or
colorless. Blue or orange bags,
however, are never used for ordinary
rubbish.
Chemical wastes are handled separate-
ly, and at no time should large quan-
tities of chemical wastes be allowed
to accumulate. Chemical wastes must
simply be identified, labeled, and
packaged in boxes that are accom-
panied by lists of contents. Pro-
ducers of chemical wastes are cau-
tioned not to place incompatible
chemicals in the same box. Boxes are
transported to a central point, where
the chemical waste disposal vendor
removes them from the campus.
Disposable needles and syringes
require special handling. Our stud-
ies have shown that persons handling
rubbish have received nearly as many
puncture wounds as the persons using
needles and syringes in their work.
We believe that no waste handler
should be stuck by an object pro-
truding from waste container and
instruct users to dispose of needles
and syringes in a special cardboard
carton upon which a clipping device
is mounted. This device permits the
user to clip both the needle and the
syringe at the hub and drop the parts
into the carton. To make proper
disposal convenient, we allow unlim-
ited numbers of cartons to be kept at
locations where needles are used.
Other disposal methods (e.g., systems
that crush needles, melt the syringe
and needle into a block, or return
the needle to a protective sheath)
pose impediments to the user and have
resulted in improper handling and
disposal.
Aerosol cans also deserve special
handling and must be kept separate
from ordinary rubbish. The only
requirement for safe and sensible
disposal is to mark a container that
contains aerosol cans.
Like needles, sharps can penetrate
packages and puncture the waste
handler. Broken glass and sharp
instruments can find their way into
ordinary waste and can lacerate and
infect the handler. Again, the
primary need is to segregate such
materials, place them in containers
that resist penetration, and label
the containers as holding broken
glass or sharps.
Radioactive wastes are disposed of in
other prescribed ways, which are
specified by our Radiation Safety
Manual. This paper will not discuss
methods of radioactive waste dis-
posal.
Autoclaves must be tested monthly and
weekly in patient-care areas to
determine whether or not they are
working properly. The Housekeeping
Department assigns more than one
trained person to do autoclaving.
Thus, if one person is absent, the
process is not interrupted. All
4-3
-------
incinerator, autoclave, and compactor
personnel are required to wear
gloves, face masks, and safety
glasses. Carts in which hazardous
waste containers are transported must
be steam cleaned at least once a week
whenever contaminated with infectious
waste.
We double-bag blue- and orange-coded
wastes. A clear plastic bag (or bag
of any other color except blue or
orange) is placed inside a blue or
orange bag to give extra protection.
When the waste is ready to be dis-
carded, the inside bag is tied first;
then the blue or orange bag is tied.
The Medical Center's waste disposal
standard specifies the following
1 ing wastes:
: u I ^(Juaa i
bLcuiudru bpeu 11 leb the following
procedure for hand!'
Blue-coded wastes.
Blue-coded
wastes, which are disposed of in
the pathological incinerator,
include infectious human organs,
infectious animal carcasses and
organs.
noninfectious human
organs and tissues from autopsy
and operating rooms, and nonin-
fectious animal carcasses,
organs, tissues, and wastes.
All these materials are combust-
ible. Each blue bag must be 2
mills thick, must be sealed with
a tie, and must be transported
directly to the pathological
incinerator for handling by a
crew trained in the use of that
incinerator.
Orange-coded wastes. These
wastes are understood by the
producer and by the handler to
require autoclaving before
disposal. They include infec-
tious human tissues, materials
from autopsy and operating
rooms, infectious animal tissues
and wastes, clinical laboratory
specimens, microbiological cul-
tures, disposable waste from
patients in isolation areas, and
other infectious waste materials
that may or may not be com-
bustible. Orange-coded wastes
are first collected in covered
containers that are lined with
heavy-duty autoclavable dispos-
able orange bags bearing bio-
hazard signs and labels. Ideal-
ly, the wastes are autoclaved at
the places where they are pro-
duced. In an area without an
autoclave, personnel must trans-
port such wastes to an available
autoclave. Bags must be opened
and water must be added to the
contents before autoclaving to
ensure proper decontamination.
Autoclave tapes are used on
orange bags to show that they
have been autoclaved. After
autoclaving, orange-coded waste
may be collected by housekeeping
personnel and disposed of in the
rubbish compactor.
Disposable and unwanted chemi-
cals and chemical wastes.
Flammable and combustible liq-
uids that are miscible with
water in all proportions may be
flushed down the drain if such
liquids do not exceed one pint
and are thoroughly mixed with at
least 3 gallons of water. Other
nonhazardous wastes may be
disposed of in regular waste
containers. If chemicals cannot
be safely discharged in one of
these manners, the following
procedure is required:
1. Properly seal and clearly
label every bottle or container.
2. Sort chemicals according to
the kinds of hazards they pose.
3. Individually wrap each
bottle with packing material and
4-4
-------
put the bottles into a cardboard
box. Clearly mark each box
according to the kinds of haz-
ards posed by its contents.
4. Fill out the request form
for disposal of unwanted chemi-
cals.
5. Contact the Building In-
spector, who picks up the chemi-
cals and transports them to a
storage area for removal.
Used needles and syringes. The
following disposal procedure is
prescribed for used needles and
syringes:
®
1. Mount Destruclip on top of
disposal carton.
2. Destroy used
syringe with the
Clip the needle from the hub and
the tip from the syringe.
needles and
Destruclip
3. Deposit remaining syringe
parts into disposal carton.
4. Fill the carton, autoclave
it, seal it with tape, and put
it inside a clear plastic bag.
Housekeeping personnel pick up
and dump the bag into the com-
pactor with ordinary rubbish.
In areas where an autoclave is
not available, cartons may be
sealed with tape and put inside
orange biohazard bags. Each
department is then responsible
for transporting such filled
cartons to the autoclave area.
Miscellaneous wastes.
The
standard prescribes the manners
in which aerosol cans, broken
glass, and sharp instruments are
to be packaged for disposal.
The standard includes a simple re-
quest form for identifying chemicals
to be disposed of and provides a
waste disposal flow chart showing how
various wastes are packaged, color
coded, and disposed of. At present,
the standard represents a starting
point for the proper diposal of
various hazardous wastes. With
experience, we expect to make im-
provements, including modifications
in the waste-generating departments
and in the means of transportation
and disposal.
4-5
-------
SPECIMENS, CULTURES,
AND OTHER INFECTIOUS
WASTES
INFECTIOUS BROKEN
GLASS AND
SHARP INSTRUMENTS
AEROSOL
CANS
TISSUES, ORGANS,
CARCASSES, AND
OTHER INFECTIOUS
WASTES
BLUE
BAG
NEEDLES
AND
SYRINGES
01
f J
ORANGE
BAG
PLASTIPAK
CARTON
ORDINARY
RUBBISH
6
ORANGE
BAG
PATHOLOGICAL
INCINERATOR
CHEMICAL WASTES AND
UNNEEDED CHEMICALS "
JPUNCTURE-
/RESISTANT
'CONTAINER
ORANGE
BAG
NONINFECTIOUS
BROKEN GLASS AND
SHARP INSTRUMENTS
CLEAR BAG
OR ANY OTHER
COLOR EXCEPT
BLUE AND
ORANGE
/MARKED
(CONTAINER
Ifc
PUNCTURE-
RESISTANT
CONTAINER
AUTOCLAVE
•\ \
- 1 1
1 1
'/ '
\ ^ \
\
COMPACTOR
CARDBOARD
BOX
(CALL BUILDING INSPECTOR)
B B
STORAGE
AREA
Waste disposal flow chart.
-------
CASE STUDY OF HOSPITAL WASTE MANAGEMENT, UNIVERSITY OF MINNESOTA
Robert A. Silvagni
The purpose of the presentation is to present past and present waste manage-
ment programs serving the Health Science - Hospital Complex of the University
of Minnesota. The presentation is geared to illustrate the various external
influences that affect the collection, storage, and disposal of hospital and
health research wastes.
BACKGROUND
The main campuses of the University
of Minnesota are located in Minnea-
polis and St. Paul and are within
four miles of each other. Most of
the University's hospital and health
activities are on the Minneapolis
campus. The St. Paul campus, known
as the farm campus, is where the
Veterinary Hospital and Veterinary
School are located. For the purpose
of this presentation, the reference
to biohazardous infectious wastes
generated at the St. Paul campus will
be those generated at the Veterinary
Hospital and/or the Veterinary
School. The Minneapolis campus
generates biohazardous infectious
wastes in the Health Science Complex,
which consists of the following
units:
Medical School
Dental School
Teaching Hospital (220 beds)
Research Hospital
Heart Hospital
Cancer Hospital
Biomedical Research Laboratories
ORGANIZATIONAL RESPONSIBILITIES FOR
WASTE MANAGEMENT
The Physical Plant Department pro-
vides waste disposal service for the
hospital, the Health Science Complex,
and the balance of the university.
The hospital is charged for waste
disposal services because of its
charter status; however, the Physical
Plant provides waste disposal serv-
ices to the rest of the university
through its maintenance budget.
An independent entity known as Uni-
versity Hospitals reports to the
president of the university; whereas
the numerous biomedical laboratories
may be affiliated with other opera-
ting departments.
Mr. Silvagni is an Environmental
Engineer at the University of Min-
nesota. His experience includes 11
years of private and regulatory work
in solid waste management. He holds
a B.S.C.E. from Norwich University
and an M.S.C.E. from West Virginia
University.
4-7
-------
The Department of Environmental
Health and Safety is responsible for
technical guidance, procedural guide-
lines, and review of university
operations on matters pertaining to
environmental health, sanitation, and
safety.
This department establishes the
operational framework under which
Physical Plant waste disposal serv-
ices are provided, i.e., definitions
of biohazardous infectious wastes,
hazardous waste, etc. (see Defini-
tions of Hazardous Waste at the end
of this report).
In response to the various regula-
tions, guidelines, and internal pro-
cedures, an operational framework has
been developed whereby the Physical
Plant manages the various waste
streams. Figure 1 outlines the
management scheme for these wastes.
Because of specialized management and
disposal requirements, seven major
waste streams have emerged:
1.
2.
3.
4.
5.
Normal solid waste. Classroom,
office, generally all wastes not
classified or further defined
below. Approximately 20 tons/
day.
Biohazardous infectious waste.
As defined by the Department of
Environmental Health and Safety.
Packaged in red plastic bags.
About 3000 Ib/day.
Chemical hazardous waste. State
Pollution Control Agency Defini-
tion. 10 to 55 gallon drums/
month.
Low-level radioactive waste.
Research animals.
Ib/day.
About 1000
6. Animal waste, bedding. Approxi-
mately 1 ton/day.
7. Anatomical waste.
The biohazardous infectious waste
stream has been the most troublesome
and costly. As late as 1978, the
university utilized a traveling grate
mass burning incinerator to dispose
of research animals, refuse (normal
solid waste), biohazardous infectious
wastes, and animal bedding wastes.
This incinerator was readily avail-
able and convenient to use, and
operational costs were met out of a
utility budget; therefore, internal
procedures liberally defined these
wastes as biohazardous infectious
wastes. As a result, red bags (sig-
nifying biohazardous infectious
waste) were used in a generous man-
ner, and not much attention was paid
to their proper use.
The State and the Federal Environmen-
tal Protection Agencies eventually
required the university to phase out
the incinerator because of poor emis-
sions control. In response, the
university diverted its normal waste
to area landfills and contracted with
a small private incinerator to burn
its biohazardous infectious wastes.
The switch to the commercial inciner-
ator necessitated a 30-mile round
trip three times a day plus payment
of $0.10 per pound of waste. These
changes increased the university's
waste disposal costs by 10 times in
one fiscal year. These costs are
broken down as follows:
1. Special trucks and carts to haul
the infectious waste the 30-mile
round trip at a cost of $0.10
per pound. Estimated annual
cost, $176,015.
4-8
-------
WAil t
GENERAL CAMPUS
OFFICE
CLASSROOMS
1
1 TRANr>rTR
i 1
STATION — '
LAND DISPOSAL
INLINtKAl l(}n
WASTE LABORATORY
CHEMICALS
WASTE OILS
SOLVENTS, BASES
ACIDS
CYLINDERS
PESTICIDES,
HERBICIDES
DRUGS
PACKAGED STORAGE
EXPLOSIVE.
SHOCK-
SENSITIVE
HIGHLY EXPLOSIVE,
SHOCK-SENSITIVE
SPECIAL
ARRANGEMENT
DEMOLITION
LOW-LEVEL
RADIOACTIVE
ANIMALS
SOLIDS
LIQUIDS
STORAGE
DISPOSAL
ISOLATION
uncTFC;
PF^FiPTH flNTMil <;
HfKPTTii cm Rflrt:
BANDAGES
ANIMAL PARTS
TWFCTT T ni re
•- INflNERATIOfi
OTHER WASTES
ANIMAL
FLY ASH
CONSTRUCTION
GROUNDS WASTE
TREE WASTES
STORAGE
LAND DISPOSAL
Figure 1. Solid waste categories.
4-9
-------
2. Haulage of waste to a landfill
10 miles away at a cost of
$20-$40 per truckload. Esti-
mated annual cost of $48,000.
To further add to the problem, the
university has also spent more than
$100,000 to upgrade its incinerator,
and additional funds are required
before the incinerator can meet
minimum air quality emission cri-
teria. The university must continue
to upgrade the incinerator because
the commercial incinerator that burns
their biohazardous infectious wastes
continues to break down. If the
commercial incinerator were to shut
down, the university would be in the
difficult situation of not being able
to dispose of its biohazardous infec-
tious wastes. Furthermore, since the
commercial incinerator is the only
one available, it cannot always
handle the volume of wastes to be
incinerated; therefore, the univer-
sity must store its wastes until they
can be accepted by the incinerator.
SOURCE REDUCTION
In an effort to reduce the amount of
biohazardous infectious waste, the
University Hospital and the Depart-
ment of Physical Plant cofunded a
source reduction study. In brief,
the project reviewed the following
elements:
The importance of this study is that
it revealed that changes made in the
definitions and procedures for waste
management required review and input
from various hospital health science
experts. For example:
The operating room staff can
control and segregate wastes
between the biohazardous infec-
tious waste stream and the
infectious waste stream without
difficulty.
The microbiology laboratory
staff are well aware and know-
ledgeable about their wastes so
that they could autoclave all of
it without difficulty if proper
operating procedures could be
developed.
The staff of each operating station
within the hospital were interviewed
regarding the generation of biohaz-
ardous infectious waste in their
station and were asked to recommend
changes that would reduce infections.
The interview team was comprised of
the biohazardous officer, the infec-
tion control officer, and the custo-
dial services representative.
This study resulted in source separa-
tion changes that precipitated a 45
percent reduction in the volume of
biohazardous wastes and a projected
$100,000 per year cost saving:
Study of one-time-use products. 1.
Project to educate employees to
use red bags properly.
Development of different options
to reduce biohazardous infec-
tious wastes through operational
changes.
One part in this project con-
cerned throwaway/single use
products. This effort was made
to determine those products that
could be replaced by reusable
products and to develop a method
for assessing the disposal cost
so it could be added to the
purchase price of the product.
The results showed disposal
costs clearly do not support
product replacement at this
time.
4-10
-------
The project staff also investi-
gated the purchase of a new
infectious waste incinerator.
This investigation revealed that
the State Pollution Control
Agency was issuing incinerator
operating permits based on the
manufacturer's submitted test
data and not an actual field
emission test data. Further-
more, technical problems asso-
ciated with units now operating
made it impossible to test these
units. Therefore, no further
consideration was given to
purchasing our own unit until
more performance data could be
obtained and incinerator toxic
emissions could be assessed more
extensively.
The most important finding of
the work conducted during this
project concerned the role of
ejnployee-staff education—we
simply had not done a good job
of telling our staff how to
dispose of their wastes prop-
erly. To correct this problem,
we had a health education
specialist develop a program
that included the following:
a. An audio-visual program
(slide-tape) for presenta-
tion to all employees (old
and new) that reviews the
waste management problem
and their individual re-
sponsibi1ities.
b. Development of a waste
management brochure.
c. A series of staff meetings
at all levels, including
management, to increase
awareness of waste disposal
and outline responsibil-
ities.
In closing, a comprehensive review
was made of waste management at the
University of Minnesota Hospitals.
This study revealed that certain
changes could be made to assist in
source separation of wastes. By
making these changes, we were able to
realize a 45 percent reduction in the
infectious wastes stream.
4-11
-------
REGULATIONS PERTINENT TO THE GENERATION, STORAGE, HANDLING,
AND DISPOSAL OF WASTE AT THE UNIVERSITY OF MINNESOTA
FEDERAL
Department of Transportation
Sets requirements for separa-
tion, containerization, label-
ling, and shipping of hazardous
materials.
Nuclear Regulatory Commission
Regulates all use of radioactive
material, including handling,
packaging, shipping, and final
disposal of wastes.
Environmental Protection Agency
Proposes regulations covering
identification, generation,
storage, transportation, treat-
ment, and final disposal of
hazardous wastes (other than
radioactive). Manifest system
following movement of wastes is
an integral part of these regu-
lations.
Regulates disposal of pesticides
and pesticide-contaminated
materials.
STATE
Minnesota Department of Health
Hospital regulations are being
revised to include requirements
for handling infectious waste.
Will probably require incinera-
tion or sterilization.
Minnesota
tion
Department of Transporta-
Regulations equivalent to DOT
regulations; also cover intra-
state shipping.
Minnesota Pollution Control Agency
Regulates solid waste disposal,
including a general duty clause
that states that no material
shall be handled in a manner
that damages the environment. A
proposed revision defines the
category of "special infectious
waste" and excludes this mate-
rial from sanitary landfills.
Sets limits for
incinerators.
emissions from
Sets incinerator
dards.
emission stan-
Proposes regulations for hazard-
ous wastes that have similar
effect as Federal proposed
regulations, except that infec-
tious waste control is left to
the Department of Health.
4-12
-------
OTHER
Joint Commission on Accreditation of
Hospitals
Requires incineration or steri-
lization of pathogenic wastes.
Department of Environmental Health
and Safety
Sets university policies re-
garding handling and disposal of
biological, chemical, and radio-
active wastes. These policies
meet or exceed all applicable
external regulations.
4-13
-------
DEFINITIONS OF HAZARDOUS WASTE
The following broad definitions are
included in the present Solid Waste
Regulations (SW-1) of the Minnesota
Pollution Control Agency (MPCA) and
the proposed hazardous waste Guide-
lines and Regulations of the U.S.
Environmental Protection Agency.1
1. MPCA - Toxic and Hazardous
Wastes. Toxic and hazardous
wastes are waste materials
including but not limited to
poisons, pesticides, herbicides,
acids, caustics, pathological
wastes, radioactive materials,
flammable or explosive mate-
rials, and similar harmful
chemicals and wastes which
require special handling and
must be disposed of in a manner
to conserve the environment and
protect the public health and
safety.
2. EPA - A solid waste, or com-
bination of solid wastes, which
because of its quantity, concen-
tration, or physical, chemical
or infectious characteristic
may:
a) Cause or significantly
contribute to an increase
in mortality or an increase
in serious irreversible
or incapacitating revers-
ible illness, or
b) Pose a substantial present
or potential hazard to
human health or the envi-
ronment when improperly
treated, stored, trans-
ported, or disposed of, or
otherwise managed.
Agency (MPCA) define infectious
wastes more specifically. The MPCA1
definition of special infectious
wastes and the SHD2 list of hazardous
infectious wastes are identical as
quoted below. One important distinc-
tion in the preface to the definition
is that the MPCA definition applies
to both animals and humans and the
SHD definition applies only to
humans.
Infectious Waste Defi ni ti'pns.
Infectious waste is defined as waste
which originates from the diagnosis,
care or treatment of a person that
has been or may have been exposed to
a contagious or infectious disease.
Such waste includes, but may not be
limited to, the following:
a) Hazardous Infectious Waste:
1. All wastes originating from
persons placed in isolation
for control and treatment
of an infectious disease.
1 Federal
1978.
Register, December 18,
1 Proposed Amendments to SW-1 MPCA.
2 SHD Regulations for Free Standing
Outpatient Surgery Areas, p. 11.
4-14
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2. Bandages, dressings, casts,
catheters, tubing, and the
like, which have been in
contact with wounds, burns,
or surgical incisions of a
suspected, known or medi-
cally identified hazardous
infectious nature.
3. Laboratory and pathology
waste of an infectious
nature which has not been
autoclaved.
4. All anatomical waste,
including human parts or
tissues removed surgically
or at autopsy.
5. Any other waste as defined
by the State Board of
Health which because of its
potential infectious char-
acteristics or hazardous
nature requires handling
and disposal in a manner
prescribed for (1) through
(4).
The SHD also defines a category of
general infectious waste that can be
disposed of directly into an MPCA
approved sanitary landfill.
b) General Infectious Waste (Con-
taminated Waste):
1. Bandages, dressings, casts,
catheters, tubing, and the
like, which have been in
contact with wounds, burns,
or surgical incisions, but
are not suspected or have
not been medically iden-
tified as being of a haz-
ardous infectious nature.
2. Discarded hypodermic nee-
dles and syringes, scalpel
blades, and similar mate-
rials, except when sus-
pected or identifed to be
of a hazardous infectious
nature.
3. Incinerator ashes
infectious waste.
from
Although it is possible to provide
considerably more background infor-
mation on the subject of hazardous
waste definitions [e.g., difference
between Department of Transportation
(DOT) and EPA definitions, specific
EPA tests for defining various haz-
ardous properties, long lists of
chemicals on EPA lists, etc.], it
seems more appropriate that the
committee agree on an operational
definition. The following is sug-
gested for committee review and
revision.
A hazardous or special waste at the
University of Minnesota is considered
as solid material or containerized
liquids that may require special
handling and disposal because of
potential adverse effects on humans,
animals, or the environment. Effects
may be physical, chemical, and/or
infectious. At the university,
hazardous wastes shall include the
following general categories or
combinations thereof:
Infectious—Contaminated with
pathogenic micro-organisms.
Pathologic—Human or animal
tissue, including blood.
Flammable and combustible liq-
uids.
Corrosive waste—Base with pH
>12; acid with pH <3; and solid
acids or bases.
Explosive or reactive wastes—
Normally unstable, undergoes
violent change (such as reaction
of sodium with water), or can be
detonated.
4-15
-------
Radioactive wastes—Isotopes or
materials contaminated with
radioisotopes.
Toxic chemicals—Can cause
chronic or acute disease; in-
clude but are not limited to the
following:
Pesticides
Carcinogens
Heavy metal
Chlorinated organics
4-16
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HOSPITAL WASTE REDUCTION AT THE UNIVERSITY OF MINNESOTA HOSPITALS
J. Michael Sprafka
In May 1978, the University of Minnesota was placed in a serious dilemma
regarding hospital waste when the Minnesota Pollution Control Agency cited and
closed the university's onsite incinerator for air quality violations. As a
result, the Department of Physical Plant Operations, which manages the univer-
sity's waste materials, decided to initiate a waste-reduction project in the
university's hospital complex. This project, conducted in cooperation with
the hospital administration, was one of several pursued by Physical Plant
Operations to alleviate the magnitude of the waste management problem.
The difficulties related to solid
waste management have increased
continually at the University of
Minnesota as a result of economic
factors and new environmental health
regulations. In the past, all of the
university's solid waste, including
bi ohazardous-i nfecti ous materi als,
was disposed of in an onsite inciner-
ator. The availability of this
incinerator allowed the University of
Minnesota Hospitals to develop inter-
nal waste management practices that
liberally defined biohazardous-
infectious and nonbiohazardous-
infectious waste.
As time progressed, the Minnesota
Pollution Control Agency restricted
the use of the university's inciner-
ator. Because of continual inciner-
ator emission problems, the univer-
sity phased out the incinerator as a
disposal option and entered into a
costly contract with a commercial
facility for the incineration of
biohazardous-infectious waste.
These increased costs prompted the
Physical Plant to propose this study
to reduce the amount of biohazardous-
infectious waste generated within the
hospital complex. The study combined
the efforts of the Department of
Physical Plant Operations and the
Department of Environmental Health
and Safety. The project was funded
by three university departments:
Hospital Administration, Central
Administration, and Physical Plant
Operations. The project staff devel-
oped an advisory panel consisting of
administrative personnel who were
capable of providing consultation
during the course of the project.
Mr. Sprafka is a Research Fellow at
the University of Minnesota. He is
currently involved in a research
project sponsored by the Departments
of Epidemiology and Environmental
Health to determine health risks
associated with organic contaminants
in the environment. He holds a B.A.
and an M.S. from the University of
Minnesota.
4-17
-------
The study consisted of two major
components:
1. An analysis of the external
and internal solid waste
management costs at the
university hospitals.
2. The development of waste
management policies and
procedures to maximize
source separation of bio-
hazardous-infectious waste
from nonbiohazardous waste.
A third component of this study
consisted of an evaluation of all
single-use disposable items to deter-
mine the feasibility of replacing
these items with reusable items. The
results indicated that a reduction in
the use of disposable products would
not significantly affect the cost
associated with hospital solid waste
disposal. A formula was developed,
however, whereby the disposal cost
per product can be factored into the
purchase price to provide a more
complete cost profile.
The model for the external hospital
waste disposal cost is comprised of
two components. The first component
includes the cost associated with the
transport of waste materials; the
second includes the cost incurred for
the use of the disposal site. The
boundaries of the external cost model
are defined by the administrative
responsibilities of two university
departments: Hospital Administration
and Physical Plant Operations. The
total external disposal cost includes
the cost of vehicles, transport,
labor, maintenance, and ultimate
disposal.
Information regarding the quantity of
hospital waste was obtained from
records of daily waste weights main-
tained by these two departments. A
combination of total cost and weight
information provided a disposal cost
per pound for both waste streams.
The results of this analysis indicate
that the external disposal cost is
approximately $0.18 per pound for
biohazardous-infectious waste and
less than $0.01 per pound for nonbio-
hazardous waste. For fiscal year
1980, the total weight of hospital
solid waste is projected to be
6,200,088 pounds, and the total cost
of external solid waste transport and
disposal is projected to be $224,014.
Biohazardous-infectious waste makes
up only 15.3 percent of the total
projected hospital solid waste
weight; yet it accounts for 78.6
percent of the total cost outlay for
external hospital solid waste trans-
port and disposal.
A long-term operational cost covering
labor, fringe benefits, and plastic
bags is associated with the internal
collection of solid waste within
university hospitals and clinics.
Not included in this analysis is the
cost of nursing staff and house-
keepers to transport the waste from
patient rooms to the central storage
area, administrative costs, and
several operational costs such as
cart maintenance and upkeep. All of
the information for this analysis was
provided by Physical Plant Operations
and Environmental Services, which are
the administration units directly
responsible for internal solid waste
management.
The second component of this study
was an evaluation of the solid waste
handling and disposal practices in
the hospital with the aim of identi-
fying problems in the system. During
the course of the investigation,
employees were carefully informed
about the Hospital Waste Reduction
Project and became involved to vary-
4-18
-------
ing degrees in suggesting improve-
ments in the system. Hospital per-
sonnel were regarded as a crucial
resource, not only in describing
current waste management practices,
but also in identifying problems and
devising feasible solutions.
The assessment of employee practices,
knowledge, and concerns entailed
several data-gathering methods,
including observational and question-
naire surveys, individual and group
interviews, and focus group discus-
sions. Assessments were made of the
knowledge and use of existing dis-
posal options, practical requirements
for waste handling in work areas, and
concerns about waste management. The
assessment process focused on hospi-
tal laboratories, nursing stations,
outpatient clinics, and the Depart-
ment of Environmental Services, but
other units, such as X-ray, Surgery,
and Central Sterile Processing, were
also considered.
Several concerns and needs were
identified as a result of the assess-
ment. Major inconsistencies in the
use of red plastic bags (the desig-
nated biohazardous waste container
for the hospital) and in other as-
pects of the waste management system
were found to be the primary problem
interfering with the efficiency of
the system. Inappropriate disposal
practices could be related directly
to the lack of clean, consistent
policies and procedures for waste
handling and disposal in the hospi-
tal.
A second but closely related finding
was that the red plastic bags did not
seem to signify to many employees
that the contents were biohazardous.
They may have recognized that red
bags were supposed to contain bio-
hazardous-infectious waste, but
because large quantities of normal
waste were being disposed of in the
red bags, they did not necessarily
exercise caution in their handling.
Because professional and technical
personnel were able to evaluate the
hazard potential based upon the waste
material itself rather than the color
of its containment bags, it is be-
lieved they probably could also
discriminate and separate biohaz-
ardous-infectious and normal waste
prior to placing it into the appro-
priate disposal container. The
casual attitude of employees toward
some waste in red bags also suggested
that they were no larger being a-
lerted by the bag's red color. The
impact of the color code could be
strengthened by limiting the use of
red bags to waste that poses a true
biological hazard.
In many areas of the hospital, all
waste was disposed of in the bio-
hazardous-infectious waste stream.
The biosafety officer and unit admin-
istrators evaluated the biological
hazard potential of waste materials
in the unit and devised safe, prac-
tical means of separating biohazard-
ous- infectious waste from normal
waste. This separation was based on
the following definitions of biohaz-
ardous-infectious waste:
1. Waste that originates from
the care or treatment of a
patient who is ill as a
result of a communicable
infectious agent or who is
suspected of being infected
and capable of transmitting
a communicable infectious
agent.
2. Waste that originates from
clinical or research labo-
ratory procedures involving
communicable infectious
agents, unless such waste
has been properly decontam-
4-19
-------
inated
process
ing).
by an
(e.g.,
approved
autoclav-
3. All needles and sharps
regardless of whether such
waste is contaminated with
communicable infectious
agents and/or has been
decontaminated by an ap-
proved process.
4. Large quantities of tissue
removed during surgical
procedures regardless of
the infectious nature of
the patient.
5. Waste that the Hospital
Infection Control Committee
defines as biohazardous-
infectious waste.
The project staff assisted on imple-
menting improved waste separation
practices in the following areas:
operating rooms, hospital laborato-
ries, X-ray department, and all
hospital stations. In addition,
Physical Plant operations provided
clearance for all nonbiohazardous
waste glass to be discarded into the
"normal hospital waste" stream.
Thus far the implementation of these
waste handling changes has effec-
tively reduced the volume and weight
of biohazardous-infectious waste by
an estimated 45 percent and produced
a savings of approximately $75,000
(computed over a 1-year time period).
The results of the waste reduction
project indicate that nonbiohazard-
ous- infectious wastes were entering
the biohazardous waste stream as a
result of unclear definitions of
biohazardous waste, lack of specific
procedures, and insufficient staff
awareness regarding hospital solid
waste.
continuous staff
program. Con-
the University of
an autoclaving
The maintenance of an effective waste
management program relies on source
separation and a
trai ni ng/awareness
tinuing programs at
Minnesota include
experimentation that specifies the
time, temperature, container materi-
al, and container configuration
required for complete decontamination
of waste from hospital laboratories
and provides an educational slide-
tape presentation on waste management
procedures for hospital personnel.
Future considerations for hospital
solid waste programs should include
recycling of solid waste materials,
feasibility of mechanized internal
waste transport systems, optimization
of waste containers and liners, and
feasibility of the use of onsite
incineration units equipped with heat
recovery for the ultimate disposal of
all hospital solid waste.
4-20
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REACTION PANEL NOTES: SESSION ON RESEARCH- AND
HOSPITAL-GENERATED WASTE
Donald Vesley
The aim of the reaction panel is to
synthesize constructive ideas based
on the case studies presented. These
ideas might help the U.S. Environ-
mental Protection Agency (EPA) formu-
late appropriate regulations for dis-
posal of hazardous waste from hospi-
tals. Major points about such waste
are discussed in these notes.
Disposal of hazardous waste is a
long-standing problem that has been
aggravated by recent events. Hospi-
tals have discontinued onsite incin-
eration because of current air pollu-
tion control regulations and hesitate
to upgrade or replace incinerators
because of uncertainty about future
regulations. Meanwhile, escalating
fuel costs and diminishing availabil-
ity of landfill sites indicate that
future dependence on that type of
disposal may become prohibitively
costly.
The definition of infectious waste is
subject to disagreement. A narrower
definition would reduce the need for
special disposal and increase the
percentage of waste that could be
handled in normal channels.
The quantity of hazardous chemical
and radioactive waste generated by
hospitals is relatively small com-
pared with the quantity of infectious
waste. Nevertheless, onsite inciner-
ation of chemical and radioactive
waste would greatly reduce handling
costs.
Hospitals should conduct careful
cost/benefit analysis before insti-
tuting expensive disposal methods.
The record of hospitals has been
excellent in avoiding the spread of
infectious disease to the community
via the solid waste stream.
A long-range solution to the problem
of hazardous waste disposal should
include the following features:
Containerized collection and
transportion by vacuum tubes to
minimize handling costs and
aerosol spread
Direct feed to high-technology,
onsite incinerators designed to
minimize air pollution problems
Heat-recovery systems to reduce
both dependence on fossil fuels
and total costs
Future EPA regulations should be
consistent with this solution and
encourage hospitals and universities
to adopt the features listed.
Dr. Vesley is Professor of Environ-
mental Health and Director of the
Department of Environmental Health
and Safety at the University of
Minnesota.
4-21
-------
REACTION PANEL NOTES: SESSION ON RESEARCH-
AND HOSPITAL-GENERATED WASTE
Max J. Rosenbaum
If regulations proposed by the U.S.
Environmental Protection Agency (EPA)
are applicable to the average-size
hospital facility, management admin-
istrative burdens and costs will
greatly increase. Because no specif-
ic guidelines have yet been issued on
disposal of hazardous waste from
hospitals, perhaps the EPA can still
be convinced to devise rational
criteria for determining what waste
constitutes a real hazard and how to
dispose of it safely and most econom-
ically.
I suggest that a biohazardous classi-
fication system similar to that used
by the National Center for Disease
Control to rate the hazard potential
of infectious organisms on a scale of
1 to 4 might be appropriate for EPA
guidelines. In such a system wastes
contaminated by more dangerous patho-
gens would require consideration for
EPA manifest control, whereas wastes
posing less hazard could be handled
in a less restrictive manner.
I further suggest that, before prom-
ulgating regulations on disposal of
hospital waste, the EPA should spon-
sor a study committee comprised of
experts and public individuals to
assess the risks involved and to
focus on problems requiring special
attention.
The need for reasonable guarantees of
public safety in waste disposal is
clear. Regulatory overkill, however,
is not needed. We must be aware not
only of the inflationary effect of
unnecessary expenditure, but also of
the energy required. Further, the
use of elaborate and extensive incin-
eration disposal methods will un-
doubtedly contribute to the increase
in atmospheric carbon dioxide and the
"greenhouse effect." We must always
be mindful of our delicate ecosystem
and the interdependency of its compo-
nents.
I urge, most emphatically, that all
aspects of the problem be considered
before promulgation of the impending
regulations. If regulations are
still necessary, they should be as
rational, feasible, and economical as
possible.
Dr. Rosenbaum
Officer at
Wisconsin.
is Biological Safety
the University of
4-22
-------
REACTION PANEL NOTES: SESSION ON RESEARCH-
AND HOSPITAL-GENERATED WASTE
Edwin H. Hoeltke
On May 19, 1980, the Environmental
Protection Agency (EPA) issued Regu-
lations for Hazardous Waste Disposal
through the Federal Register. These
regulations are a detailed followup
of the Resource Conservation and
Recovery Act (RCRA) enacted by Con-
gress in 1976. This Act has had a
great impact on all industrial opera-
tions in our country, including those
associated with health care and
institutional activities.
In the 20 years I have been involved
in the management of hospital opera-
tions, I have seen many changes and
resolved many problems, none of which
compares with the problems created by
the Clean Air Act of 1970, the Re-
source Conservation and Recovery Act
of 1976, and the EPA Hazardous Waste
Disposal Regulations. These problems
are such that one apparent solution
creates another problem.
For the past 8 years I have been
chairman of the Environmental Com-
mittee of the American Society for
Hospital Engineering. During this
time we have wrestled with the prob-
lems created by the Clean Air Act,
environmental issues involving ethyl-
ene oxide and nitrous oxide, and the
current hazardous waste disposal
regulations. Each phase of our
committee activities over this period
of time has been related to the
environment. As a result of this
activity, we have made many contacts
and attempted to assist health care
institutions by working jointly with
the manufacturers of the single-use
items that contribute to the large
volume of disposable materials leav-
ing health care facilities and with
the regulatory representatives of the
U.S. Government agencies. In addi-
tion, we have drawn on the expertise
of other professional societies and
attempted to work together to resolve
these problems.
Recently, I had the privilege of
presenting a paper to the Interna-
tional Federation of Hospital Engi-
neers in Washington, D.C., in cooper-
ation with a representative of the
Washington Office of the EPA. As a
result of that opportunity, I believe
that for the first time there was
positive feedback between our society
and EPA. This is not to say that we
have not had cooperation in the past,
but since we are dealing with prob-
lems that are not totally definable,
it is obvious that joint oppor-
tunities for discussion are required
and hopefully desired. To indicate
Mr. Hoeltke is Assistant Administra-
tor at Christ Hospital in Cincinnati,
Ohio. He is also the Chairman of the
American Society for Hospital Engi-
neering Environment Committee (an
affiliate society of the American
Hospital Association).
4-23
-------
the extent of the uncertainties of
the problem, let me quote a paragraph
from Section 261.5 of the May 19,
1980, Federal Register regarding the
Hazardous Waste Rules and Regula-
tions:
In enacting the Resource Conser-
vation and Recovery Act, Con-
gress was responding to a prob-
lem of unknown magnitude and
dimension with specific refer-
ence to the generation of haz-
ardous waste. The House Commit-
tee stated, "One of the major
problems to be addressed in the
hazardous waste area is the lack
of information concerning the
components, volume, and sources
of hazardous waste. To date
there has been no survey or
other wide ranging investigation
of the sources of hazardous or
potentially hazardous waste
generation or disposal. As a
result, little is known about
the actual volume of hazardous
waste being generated, the
geographical distribution of the
generators, or the extent to
which hazardous wastes are
transported."
This passage indicates the uncertain-
ty of the definitions of all of the
materials possibly considered as
hazardous waste items under the
proposed regulations.
Hospitals and other institutions are
uncertain if they have to register as
hazardous waste generators because
they do not know the volume of chemi-
cals they use and which ones are
among those listed as hazardous in
the Federal Register of May 19, 1980.
As stated in the Federal Register,
the Regulation is primarily directed
toward large users of chemicals. No
definitions have been established
relative to infectious wastes, which
most certainly will have the greatest
impact on health care institutions.
It is possible, however, that many
large university-affiliated hospitals
with large research operations may be
required to register. Unlike many
other industries, hospitals and
research facilities are multidisci-
plined operations; therefore, they
are involved in many areas of poten-
tial concern to EPA and other regula-
tory groups within the state govern-
ments.
As stated in the regulation, it is up
to the individual health care facil-
ity to determine whether or not it
meets the qualifications that require
registration as a hazardous waste
generator. This regulation primarily
concerns the use of chemicals in
quantities that exceed 1000 kilograms
per month. It is therefore necessary
for each facility to gather data
concerning chemical usage and to
document their findings. If a facil-
ity does not generate 1000 kilograms
per month, it will not be required to
register. If a facility does gener-
ate more than 1000 kilograms per
month, however, it must register
before August 18, 1980.
I suggest that necessary data be
gathered from all of the areas of an
organization utilizing any of the
chemicals listed in the Federal
Register that are not disposed of
through the sewage system. It should
be noted that the exclusion portion
of the regulation exempts any waste
discharged through the municipal
sewer systems.
This investigation should be utilized
as a basis for determining compli-
ance, and the data gathered should be
kept on file for at least 3 years as
documentation of the decision regard-
ing registration. If at a later date
a facility is questioned about not
4-24
-------
filing, these data must be produced
to avoid severe penalties. In gath-
ering these data, it should be noted
that the EPA intends to reduce the
regulatory level to 100 kilograms per
month within the next 2 to 5 years.
Therefore, it will be necessary to
retain any information gathered
relative to determining whether or
not a facility is a generator of
hazardous waste.
The EPA is currently determining
appropriate definitions of infectious
waste. In this area, active input
and cooperation must take place
between the various professional
societies such as American Associa-
tion of Physical Plant Administra-
tors, American Society for Hospital
Engineering, and other related
groups. I encourage total coopera-
tion in determining and gathering
data relative to the types of waste
found in the various areas of health
care operation. Considerable work
has already been done that could be
utilized as backup data to begin the
process of cooperative exploration.
I also suggest that activities be
coordinated to include a method of
keeping facilities apprised of any
changes produced by state and Federal
regulations. Facilities in many
states are also under the jurisdic-
tion of state EPA regulations that
must be adhered to. State regula-
tions have yet to define infectious
waste because they intend to utilize
the definitions that will be estab-
lished by the U.S. EPA later this
year.
All institutions should consider
utilization of onsite incineration as
a source for removing and disposing
of hazardous waste. This will re-
quire the fewest number of people and
permit consideration of the primary
original intent of RCRA--conserving
resources while resolving other
environmental problems. The best way
to recover the high Btu content from
the waste materials disposed of in
health care institutions is to incin-
erate them on site and to apply heat
recovery systems to the facility
operation. As an example, in a
typical 700-bed hospital, the waste
heat from incineration would be ample
to heat all of the hot water for the
laundry and the entire domestic hot
water system for the facility in any
given day. These general solutions
require further study, and I look
forward to the opportunity of working
together with other professional
societies and the concerned regula-
tory agencies in this effort.
4-25
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REACTION PANEL NOTES: SESSION ON RESEARCH-
AND HOSPITAL-GENERATED WASTE
Harvey W. Rogers
This paper consists of two parts.
The first summarizes key points from
the presentations by Ray Stephens,
Robert Silvagni, and Michael Sprafka;
the second comments on how the
Resource Conservation and Recovery
Act (RCRA) affects facilities devoted
to biomedical research and health
care. Also discussed in the second
part is an incineration project
developed by the National Institutes
of Health (NIH) for disposal of waste
chemicals.
KEY POINTS FROM PRESENTATIONS
Mr. Stevens reviewed hazardous waste
handling procedures at the University
of Illinois. His basic strategy for
defining, classifying, and handling
hazardous wastes is similar to the
approach used by NIH. This workable
approach stresses that the waste
generator knows the waste best and
consequently is the appropriate
individual to determine which han-
dling and disposal option available
to the university should be used for
a particular waste stream. One major
difference in the handling strategies
of the University of Illinois and NIH
involves the disposal of waste tissue
(human and animal). The university
autoclaves this material and then
incorporates it in the general waste,
whereas the NIH incinerates all such
waste material. Even though proper
autoclave procedure can effectively
eliminate any threat of infection
from such material, the NIH prefers
incineration because this option not
only mitigates potential adverse
health effects, but also destroys a
waste that might be unaesthetic at a
sanitary landfill. The NIH is for-
tunate in having sufficient inciner-
ator capacity to treat waste tissue
in this fashion.
Mr. Silvagni discussed hazardous
waste management and source reduction
strategies developed at the Univer-
sity of Minnesota. In a slide de-
picting the waste mix generated at
the university, Mr. Silvagni captured
the complexity of defining the waste
mix and developing handling strat-
egies for the various waste cate-
gories. Hospitals, universities, and
biomedical research facilities can
all expect to generate an equally
complex mix of hazardous wastes. As
Mr. Silvagni demonstrated, the first
step in any management system for
such a waste mix must b^e a thorough
characterization of sources, cate-
gories, and properties of the waste
generated.
Mr. Rogers is Chief of the Environ-
mental Systems Section, Division of
Safety, National Institutes of
Health.
4-26
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Mr. Sprafka described a system by
which the waste mix at the University
of Minnesota was analyzed for poten-
tial source reduction application.
Complete system costs, as well as
existing procurement and utilization
policies, were reviewed. He showed
that a modification in some of these
policies resulted in very significant
cost reductions, particularly when
arbitrary definitions had caused
nonhazardous waste to be incorporated
in the expensive hazardous waste
stream. This study pointed out the
need to define waste categories
carefully in developing or revising
handling strategies and the need to
review procurement policy carefully
for ultimate system costs (e.g.,
reusables vs. disposables).
Often the individuals who decide on
safety policy or manage the physical
plant have better data to make such
evaluations than do the procurement
or administrative personnel of large
facilities.
IMPACT OF RCRA
The impact of RCRA on large facili-
ties such as NIH is significant. A
major concern is the tracking of
hazardous chemicals generated by such
a facility. Unlike industry, bio-
medical research facilities generate
a widely varying mix of chemicals
that changes with time. Even though
the quantity of any given chemical is
often small (e.g., gram or milligram
quantities) each substance must be
tracked; this requirement poses a
significant task for the facility
management.
Also, NIH is interested in the defi-
nition of infectious waste to be
issued in the fall of 1980 by the
U.S. Environmental Protection Agency
(EPA). It is hoped that the defi-
nition does not incorporate noninfec-
tious waste in broad source cate-
gories. For example, if all animal
waste from biomedical research facil-
ities is defined as infectious,
disposal costs would escalate signif-
icantly. Much animal waste is from
clean animals (animals not chemically
or biologically challenged) and is no
more harmful than cage litter from
the home gerbil cage. At NIH alone,
almost 8 tons of "clean" animal
bedding is disposed of with general
waste each day without detrimental
effects. A sweeping definition, such
as the example mentioned, would
unnecessarily force all animal bed-
ding to be handled as hazardous
waste. Because the NIH incinerators
are not sized for such a load, the
waste would have to follow the route
of hazardous waste chemicals. Such
disposal not only would be expensive,
but also would use up valuable prime
landfill space that should be re-
served for truly hazardous wastes.
Each day, the NIH generates 200 to
300 pounds of chemical wastes ranging
from waste oils and solvents to
widely varying laboratory reagents.
Generation of 1500 compounds in a
month is not unusual. These com-
pounds range from relatively nonhaz-
ardous sugars and media constituents
to more hazardous flammable, toxic,
or reactive compounds such as ether,
toluene, or mercury compounds.
Although the waste mix varies from
month to month, the organic fraction
(e.g., oils, solvents, organic chemi-
cals) is somewhat predictable and
accounts for most of the waste.
The NIH has explored incineration of
organic waste chemicals. Five com-
mercially available units and the NIH
medical/pathological waste incin-
erator were tested for the ability to
destroy waste chemicals. A repre-
sentative, but relatively innocuous
4-27
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mix of chemicals was fed to each
incinerator in two trial burns. The
chemicals were packaged in glass and
plastic containers resembling reagent
containers, and emissions were sam-
pled for participates, nitrogen
oxides, sulfur oxides, chlorides,
unburned hydrocarbons, carbon monox-
ide, carbon dioxide, and two tracer
chemicals.
Several of the units performed well
and easily met the particulate stan-
dard for incineration. Results were
encouraging enough that NIH con-
sidered procuring a unit for more
rigorous testing at its main campus
to establish clear operating limits
and develop confidence in its de-
struction capabilities.
The NIH has not pursued this project
further, largely because RCRA re-
quirements for measuring incinerator
performance are unknown. The pro-
posed standards issued in December
1978 contained performance criteria
that would make emission analysis
difficult, if not impossible (partic-
ularly for destruction efficiency).
Also, the combustion efficiency
equation did not correlate well with
NIH observations of incinerator
effectiveness. Consequently, NIH is
delaying the commitment of further
funds to this project until EPA
issues final performance criteria.
The session was closed and followed
by questions from the audience.
4-28
-------
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APPA Publications
1978-79 Comparative Costs and Staff-
ing Report for Physical Plants of Col-
leges and Universities is a compilation
of data on unit costs, wages, and salaries
broken down by geographic region, en-
rollment, and academic program. 525
Formula Budgeting: An Approach to Fa-
cilities Funding, by David L. McClin-
tock, reviews formula budgeting prac-
tices used at various times by six states
to allocate funds for support of state
colleges and universities. $6
Campus Planning and Construction de-
tails a multiphase concept in planning,
constructing, and renovating facilities.
This concept examines each project
from its initial design, through construc-
tion, to maintenance consideration after
the structure is completed. The author
offers numerous alternatives to each
suggestion he makes, depending upon
possible variables at different institu-
tions. 5/5
Mortgaging the Future: The Cost of De-
ferring Maintenance examines the
causes of the deferred maintenance
problem. The author, Dr. Harvey H.
Kaiser of Syracuse University, covers
the financial aspects and organizational
structure of deferred maintenance as
well as suggesting methods of evaluating
and addressing the problem. $6
Comprehensive Maintenance and Repair
Program: Guidelines and Standards for
the Maintenance and Repair of State
Owned Facilities provides standards that
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agement. 57.50
Proceedings of APPA's 67th Annual
Meeting (1980), Toronto, Canada. "The
Eighties—Time for Conservation" was
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includes papers on topics such as energy
management, cost control, resource con-
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tions. $10
Proceedings of APPA's 66th Annual
Meeting (1979), Seattle, Washington.
"Knowledge for the 80s" was the theme
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papers on topics such as campus se-
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savings, and computerized telephone
control systems. 57.50
A Basic Manual for Physical Plant Ad-
ministration, by George O. Weber, is
an instructional and operational manual
for facilities administration. $15.50
Remodeling, Renovation and Conversion
of Educational Facilities is a compila-
tion of papers by noted physical plant
administrators on the when and how
of facility renovation, restoration, and
conversion. 57.50
Housekeeping Procedure Manual, pre-
pared by the Department of Building
Services at Purdue University, contains
a complete housekeeping program for
building custodians. Includes instruc-
tions for operating automatic floor
scrubbers, floor machines, and many
other helpful maintenance suggestions.
55
APPA Newsletter, a fast-paced monthly
communication of newsworthy people,
places, and events emphasizing what's
happening now in physical plant depart-
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education association circles. Includes
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project news, new members, and an In-
formation Exchange column. The sub-
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Accessibility Publications
Modifying the Existing Campus Build-
ing for Accessibility: Construction
Guidelines and Specifications will in-
clude detailed design drawings for ac-
cessibility modifications to existing
buildings for use by architects and con-
tractors. Available from the Superin-
tendent of Documents, U.S. Govern-
ment Printing Office, North Capitol and
H Streets, NW, Washington, DC 20402.
Scheduled publishing date is June 1981.
Accessible Products Catalog will review
currently available construction prod-
ucts designed for accessibility, using the
latest standards and criteria. Listings
will include manufacturers' name and
product descriptions. .Available from
G.P.O. Scheduled publishing date is
June 1981.
Adapting Historic Campus Structures
for Accessibility highlights solutions to
problems involved in modifying older
buildings for use by handicapped per-
sons. 54.25. Order (Stock No. 065-000-
00034-2) from G.P.O. (address above).
Creating an Accessible Campus is a com-
prehensive guide to accessibility for
handicapped persons, including Section
504 regulations, general design recom-
mendations, science laboratory design,
instructional aids, and sources of fund-
ing. 572.50
Steps Toward Campus Accessibility fea-
tures photo-essays on progress campuses
have made in overcoming architectural,
attitudinal, and communications bar-
riers to handicapped persons. 55.50
Energy Task Force Publications
Energy Cost and Consumption Audit Re-
port 1976-1979 contains energy con-
sumption data resulting from a survey
of 500 colleges and universities broken
down by campus and type of facilities.
It includes variables for size and type
of facilities, fuel, and number of heating
and cooling degree days. 520
Controlling Energy Through Micropro-
cessor Utilization is based on the work-
book used for an Energy Task Force
seminar series. The publication provides
information on establishing a micropro-
cessor-based energy management sys-
tem including goals and objectives, sys-
tem design, types of control systems,
sources and costs, purchasing proce-
dures, and selling the program. 5/5
Cogeneration: A Campus Option? by
Robert and Wendy Goble, describes the
steps involved in implementing a cam-
pus cogeneration facility. Includes de-
scriptions of campuses that are cogen-
erating as well as available technology
and EPA regulations. A must for the
campus considering cogeneration.
5/2.50
Energy Conservation Checklist for Uni-
versities and Colleges lists suggestions
for conservation programs, primarily
taken from existing programs of about
35 institutions. $3
Energy Management for Colleges and
Universities is a 140-page manual based
-------
on information developed for an Energy
Task Force workshop series to help fi-
nancial and physical plant personnel im-
plement a well conceived energy man-
agement program. This is an essential
tool for ensuring that colleges and uni-
versities continue to meet the instruc-
tional, research, and public service
needs they have served. $20
Campus Energy Management Projects
contains case studies of energy man-
agement projects implemented by col-
leges and universities involving the
building envelope, electrical systems,
HVAC systems, building operations,
utilities production and operation. $7.50
Two Training Manuals
Available in Spanish
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in Spanish: "Basic Blueprint Reading,"
and "Reading Schematics and Sym-
bols" ($29.50 each). Orders may be
mailed to Publications Secretary,
APPA, Eleven Dupont Circle, Suite
250, Washington, DC 20036.
APPA Publications Order Form
I would like to order the following APPA publications:
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copies of @
copies of @
All orders must be accompanied by either cash or a purchase order. One dollar billing
charge if order is not prepaid. If amount is over $26.00, no billing charge is added.
Name
Title
Institution
Address
City
State
Zip
Send orders to: Association of Physical Plant Administrators
of Universities and Colleges
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Washington, B.C. 20036
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