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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
                                      1-8

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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
                                      1-9

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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?
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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?
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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.
                                      1-21

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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

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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

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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

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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

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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

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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

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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

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                        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

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               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.
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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

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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

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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.
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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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                  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

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1960     1964     1968     1972      1976
                  YEAR
1980
    Figure  1.  Solid radioactive waste.
                 3-19

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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

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               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

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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

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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

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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

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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

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                       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

-------
     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

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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

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     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

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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

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          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

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                 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

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                  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

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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

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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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 Formula Budgeting: An Approach to Fa-
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