v?/EPA
United States
Environmental Protection
Agency
Office of
Soild Waste
Washington.D.C. 20460
EPA/530-SW-89-040
April 1989
Solid Waste
Report to Congress:
Management of
Hazardous Wastes from
Educational Institutions
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
APR 26 1989
THE ADMINISTRATOR
HonorabJfioCT. Danforth Quayle
President of the Senate
Washington, DC 20510
Dear Mr. President:
I am pleased to transmit the Report to Congress, entitled
"Management of Hazardous Wastes From Educational Institutions,"
in response to Section 221(f) of the Hazardous and solid Waste
Amendments of 1984.
As requested, this Report identifies the problems associated
with the management of such wastes and analyzes the feasibility
and availability of environmentally sound methods for the
treatment, storage, or disposal of hazardous waste from such
institutions. At the request of the U.S. Department of
Education, the Report is also directed at hazardous waste from
adult education programs and programs of education of less than
two years' duration.
Enclosure
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.
*
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
THE ADMINISTRATOR
Honorable James C. Wright
Speaker of the House
of Representatives
Washington, DC 20515
Dear Mr. Speaker:
I am pleased to transmit the Report to Congress, entitled
"Management of Hazardous Wastes From Educational Institutions,"
in response to Section 221(f) of the Hazardous and Solid Waste
Amendments of 1984.
As requested, this Report identifies the problems associated
with the management of such wastes and analyzes the feasibility
and availability of environmentally sound methods for the
treatment, storage, or disposal of hazardous waste from such
institutions. At the request of the U.S. Department of
Education, the Report is also directed at hazardous waste from
adult education programs and programs of education of less than
two years'duration.
Enclosure
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EPA/530-SW-89-040
REPORT TO CONGRESS: MANAGEMENT OF HAZARDOUS WASTES
FROM EDUCATIONAL INSTITUTIONS
Prepared by:
U.S. Environmental Protection Agency
Office of Solid Waste
April 1989
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ........................... v
EPA' s Recommendations
Changes EPA Has Made or Proposed to Make
Commenters' Suggestions
CHAPTER 1: INTRODUCTION ....................... 1
1.1 Purpose and Scope ...................... 1
1.2 Sources Consulted to Prepare the Report ........... 2
1.3 Organization of the Report .................. 2
1.4 Definition of "School" .................... 3
CHAPTER 2: STATUTORY AND REGULATORY OVERVIEW ............. 4
2.1 Resource Conservation and Recovery Act ............ 4
2.1.1 Background ....................... 4
2.1.2 RCRA Subtitle C Program ................ 4
2.1.3 Hazardous and Solid Waste Amendments of 1984 ...... 5
2.2 RCRA Hazardous Waste Regulations ............... 5
2.2.1 Generators of Hazardous Waste ............. 6
2.2.2 Transporters of Hazardous Waste ............ 9
2.2.3 Treaters, Storers, and Disposers of Hazardous Waste . . 10
2.3 Other Applicable Regulatory Programs ............. 10
CHAPTER 3 : CURRENT HAZARDOUS WASTE MANAGMENT PRACTICES
AT EDUCATIONAL INSTITUTIONS ................ 11
3 . 1 Introduction ......................... 11
3.2 The Nature of Schools .................... 11
3.3 Secondary Schools ...................... 15
3.3.1 Introduction ...................... 15
3.3.2 Sources and Characteristics of Wastes ......... 17
3.3.3 Quantity of Waste Generated .............. 17
3.3.4 Storage and Disposal of Wastes ............. 21
3.4 Colleges and Universities ................. 21
3.4.1 Introduction ...................... 21
3.4.2 Sources and Characteristics of Wastes ......... 21
3.4.3 Quantity of Waste Generated .............. 24
3.4.4 Storage and Disposal of Wastes ............. 26
CHAPTER 4: PROBLEMS ASSOCIATED WITH MANAGEMENT OF HAZARDOUS
WASTES FROM EDUCATIONAL INSTITUTIONS ........... 28
4.1 Problems Related to Hazardous Waste Handling ......... 28
4.1.1 Waste Identification .................. 29
4.1.2 Handling and Collection ................ 30
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TABLK OF CONTENTS
4.1.3 Storage and Packaging 30
4.1.4 Transportation 31
4.1.5 Treatment 31
4.1.6 Incineration 32
4.1.7 Disposal 33
4.1.8 Recordkeeping 34
4.2 Feasibility and Availability of Hazardous Waste
Management Methods 34
4.2.1 Accumulation and Storage 35
4.2.2 Transportation 36
4.2.3 Treatment 37
4.2.4 Incineration 38
4.2.5 Disposal 39
CHAPTER 5: POSSIBLE WAYS TO IMPROVE MANAGEMENT OF HAZARDOUS WASTES
FROM EDUCATIONAL INSTITUTIONS 41
5.1 Solutions Within Schools 41
5.1.1 Waste Identification 42
5.1.2 Handling and Collection 42
5.1.3 Storage and Packaging 42
5.1.4 Transportation 43
5.1.5 Treatment 43
5.1.6 Incineration 44
5.1.7 Disposal 44
5.1.8 Recordkeeping 44
5.1.9 Waste Reduction Strategies 45
5.2 Solutions Among Schools 46
5.2.1 Information Exchange 46
5.2.2 Collective Waste Handling and Recycling Programs .... 47
5.2.3 Incineration 47
5.2.4 Prevention and Reduction Strategies 47
5.3 Guidance from EPA, the States, and Others 48
5.3.1 Information Exchange 48
5.3.2 Centralized or Collective Programs 49
5.3.3 Guidance Manuals on Handling Hazardous Wastes 49
5.3.4 Regulatory Guidance 50
5.4 Regulatory Changes EPA Has Made or Proposed to Make 52
5.4.1 Permitting 52
5.4.2 Burning Hazardous Wastes 52
5.5 Suggestions for Regulatory Reform 53
5.5.1 Definition of "On-Site" 54
5.5.2 Waste Characterization and Generation 54
5.5.3 Transportation 54
5.5.4 Extended Storage 55
5.5.5 Other Regulatory Reforms 55
5.6 Conclusion 56
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TABLE OF CONTENTS
REFERENCES 57
APPENDIX A: CASE STUDIES OF EDUCATIONAL INSTITUTIONS A-l
APPENDIX B: REGULATIONS APPLICABLE TO TREATMENT, STORAGE, AND
DISPOSAL FACILITIES B-l
APPENDIX C: WASTE IDENTIFICATION AND MINIMIZATION C-l
APPENDIX D: SOURCES OF ADDITIONAL INFORMATION D-l
APPENDIX E: ORGANIZATIONS COMMENTING ON THE REPORT E-l
APPENDIX F: RESPONSES TO QUESTIONS ON EPA'S HAZARDOUS WASTE
MANAGEMENT REGULATIONS F-l
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LIST OF TABLES
Table
3-1 Number and Enrollment of U.S. High Schools (Including
Vocational High Schools) (1982-83) 16
3-2 High School Course Offerings Likely To Produce Hazardous Waste . 18
3-3 U.S. Institutions of Higher Education by Type and
Control, Fall 1983 22
3-4 College-Level Courses Likely To Result in Hazardous Waste
Generation 23
A-l College and University Case Studies A-2
A-2 High School Case Studies A-3
C-l Typical Operations: Materials Used and Hazardous
Wastes That May be Generated by Laboratories C-11
C-2 Waste Minimization for Laboratories C-12
C-3 Typical Operations: Materials Used and Hazardous Wastes
That May be Generated by Vocational Shops C-14
C-4 Waste Minimization for Vocational Shops C-18
C-5 Categories of Specific Hazardous Wastes, Including EPA
and DOT Information C-19
LIST OF EXHIBITS
C-l Sample Notification of Hazardous Waste Activity Form
(EPA Form 8700-12) C-37
C-2 Sample Uniform Hazardous Waste Manifest (EPA Form 8700-22) . . C-39
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EXBCUTIVE STJMMARY
Pursuant to Section 221 (f) of the Hazardous and Solid Waste Amendments of
1984 (HSWA), the U.S. Environmental Protection Agency (EPA) is reporting to
Congress the findings of its study of problems associated with managing
hazardous wastes from educational institutions. EPA has prepared this report
in consultation with the Secretary of Education, the States, and appropriate
educational associations. The report is factual in nature. EPA was not
directed to develop recommendations for regulatory or statutory changes.
Therefore, this report has not recommended any regulatory or statutory
changes. This report identifies the statutory and regulatory requirements for
educational institutions managing hazardous waste, examines current hazardous
waste management practices at such institutions, and identifies the hazardous
waste management problems encountered by them. As required by the statute, it
presents an analysis of the feasibility and availability of environmentally
sound methods for the treatment, storage, and disposal of hazardous wastes
from these institutions. The report concludes by identifying possible ways
for educational institutions to improve hazardous waste management.
The 30,000 educational institutions nationwide generate about 2,000 to
4,000 metric tons of hazardous waste per year, representing much less than 1
percent of the 240,000,000 metric tons of hazardous waste generated annually
in the United States. Secondary schools and small colleges and universities
contribute less hazardous waste than large colleges and universities with
large scientific research programs. Most schools are small quantity .
generators; some large universities are large quantity generators.
Educational institutions have large numbers of independent hazardous waste
generation points that produce variable waste streams. Generators include
academic laboratories, art and vocational departments, and maintenance
activities. Current waste management practices range from storage in chemical
stockrooms, closets, or laboratories and disposal by the drain or dumpster to
multimillion-dollar treatment, storage, and disposal facilities. Some of
these practices are not allowed under current regulations. Waste management
activities at educational institutions include on-site or off-site
accumulation and storage; chemical and physical treatment, including recycling
and recovery; incineration; and disposal. Educational institutions also
transport waste to off-site treatment, storage, or disposal facilities. The
types and quantities of waste generated by schools directly influence the
technical and economic feasibility of using certain treatment, storage, and
disposal methods. In general, secondary schools are less aware and concerned
about hazardous waste management than are universities. Those colleges and
universities with centralized waste management programs; more extensive
research programs; and better funding, staffing, and training are better able
to manage the wastes they generate. Budgetary and management constraints
frequently do not allow educational institutions to develop and adequately
fund waste management programs. Due to the liabilities of improper hazardous
waste management, educational institutions are making greater attempts to be
in compliance.
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Most problems in hazardous waste management at educational institutions ,
arise from the institutions' lack of awareness about hazardous wastes and the
applicable regulations; the transient nature of student populations; the
highly variable waste streams generated, which contain multiple constituents;
the insufficient resources available for hazardous waste management programs;
the high cost and location of off-site treatment, storage, and disposal; and
the difficulties in complying with the hazardous waste regulations. Some
schools are aware of appropriate hazardous waste management methods and have
attempted to reduce the quantities and hazardous nature of wastes that they
generate. Some schools have participated in cooperative strategies to reduce
their wast'e disposal costs.
EPA'S RECOMMENDATIONS
The following are EPA's recommendations concerning hazardous waste
management at schools:
• EPA and the States can increase schools' awareness of the hazardous
nature of the waste generated, the appropriate hazardous waste
management techniques, and the applicable regulations by exchanging
information between schools and regulators, providing guidance
manuals, and holding local or regional forums to exchange ideas and to
develop notification and guidance literature.
• EPA and the States can help to make schools more aware of liability
costs of mismanagement and can suggest that schools use existing
organizational structures to run hazardous waste management programs.
This may enable schools to better use their existing funds.
• EPA, the States, and local governments can reduce schools'
difficulties in complying with the hazardous waste regulations by
providing Federal, State, and local guidance.
• Schools can reduce problems caused by the highly variable
multicomponent waste stream by reducing the amount of waste generated,
reducing the hazardous nature of the waste, and keeping better track
of the waste.
• Schools can establish cooperative programs with other schools to
exchange information, reduce the amount of waste generated, and reduce
waste management and disposal costs.
• Schools that do not generate great quantities of waste may find mobile
treatment units to be a feasible solution.
• Under certain conditions, schools can accumulate waste without a
permit and then ship the waste off-site to a permitted treatment,
storage, or disposal facility.
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CHANGES EPA HAS MADE OR PROPOSED TO MAKE
EPA has already made or proposed to make the following regulatory changes
that could alleviate problems with hazardous waste management at educational
institutions:
• Issued small quantity generator requirements that are more tailored to
such generators. Many schools are small quantity generators.
• Exempted from regulation small quantities of hazardous waste, when
evaluated in treatability studies.
• Proposed reducing permitting requirements for small quantity burners.
COMMENTERS' SUGGESTIONS
The States, the regulated community, and other commenters have suggested
the following regulatory or statutory changes, which could alleviate
difficulties in complying with the hazardous waste regulations. EPA has not
evaluated these suggestions, and the Agency is not recommending that these
changes be made. EPA could examine these options in the future.
• EPA should clarify existing regulations as they apply to educational
institutions.
• EPA should consider reducing the regulatory requirements for managing
hazardous waste as they currently apply to educational institutions.
• EPA and the States should allow land disposal of all lab packs, even
those containing wastes prohibited from land disposal. (This
suggestion would require statutory changes.)
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CHAPTER 1
INTRODUCTION
1.1 PURPOSE AND SCOPE
Pursuant to Section 221(f) of the Hazardous and Solid Waste Amendments of
1984 (HSWA), the U.S. Environmental Protection Agency (EPA) has studied and
evaluated the problems associated with managing hazardous wastes generated by
educational institutions. Section 221 (f) states the following:
"(1) The Administrator of the Environmental Protection Agency shall, in
consultation with the Secretary of Education, the States, and
appropriate educational associations, conduct a comprehensive study
of problems associated with the accumulation, storage and disposal
of hazardous wastes from educational institutions. The study shall
include an investigation of the feasibility and availability of
environmentally sound methods for the treatment, storage or disposal
of hazardous waste from such institutions, taking into account the
types and quantities of such waste which are generated by these
institutions, and the nonprofit nature of these institutions.
"(2) The Administrator shall submit a report to the Congress containing
the findings of the study carried out under paragraph (1) not later
than April 1, 1987.
"(3) For purposes of this subsection—
"(A) the term "hazardous waste" means hazardous waste which is
listed or identified under Section 3001 of the Solid Waste
Disposal Act;
"(B) the term "educational institution" includes, but shall not be
limited to,
"(i) secondary schools as defined in section 198(a)(7) of
the Elementary and Secondary Education Act of 1965; and
"(ii) institutions of higher education as defined in section
1201 (a) of the Higher Education Act of 1965."
The report is factual in nature. EPA was not directed by the law to
develop recommendations for regulatory or statutory changes. Therefore, this
report has not recommended any regulatory or statutory changes. This report
identifies the statutory and regulatory requirements for educational
institutions to manage hazardous waste, examines current hazardous waste
management practices at such institutions, identifies the hazardous waste
management problems encountered by them, and concludes by identifying possible
ways for educational institutions to improve hazardous waste management. EPA
will make this report publicly available, to help increase the awareness of
those responsible for managing hazardous waste from educational institutions.
The term "hazardous waste," as used in this report, means any hazardous waste
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specified in 40 CFR Part 261. This report does not address the management of
infectious waste from educational institutions (EPA has previously prepared a
manual on infectious waste management, which can be consulted for
recommendations on the management of infectious waste generated by educational
institutions (see EPA 1986a)).
This report primarily focuses on hazardous waste generated by
universities, colleges, high schools, and vocational schools. The findings of
this report can also apply to waste generated at facilities providing adult
education and programs of education of less than 2 years' duration, because
factors affecting the management of such waste would be similar for all levels
and categories of educational institutions. "School," as used in this report,
is defined in Section 1.4.
1.2 SOURCES CONSULTED TO PREPARE THE REPORT
This report is based upon a number of sources from the published
literature and is intended to identify problems shared by many educational
institutions. As part of a study for EPA, Tufts University carried out a
series of case studies of hazardous waste management in schools (Tufts
University 1987). The researchers assumed that the management practices of
schools that generate larger quantities of hazardous wastes, or schools that
understand hazardous waste management, could be used as examples of
environmentally sound management of hazardous waste. Thus, more colleges and
universities (institutions of higher education) than high schools were
included in the Tufts University case studies, even though there are about
eight times as many high schools and vocational schools as colleges and
universities (U.S. Department of Education 1985-86). Appendix A contains
descriptions of the case study schools discussed by Tufts University in its
report. The case study data presented is based on interpretations made by
Tufts University researchers, as documented in their report. In addition to
the case studies, Tufts University researchers contacted 47 educational
institutions and State agencies in 13 States. To prepare this report, EPA
consulted with the U.S. Department of Education, the States, and appropriate
educational associations. Appendix E contains a list of organizations
commenting on the report.
1.3 ORGANIZATION OF THE REPORT
The Resource Conservation and Recovery Act (RCRA), Subtitle C, is the
major Federal statute affecting the management of hazardous waste generated by
schools. Chapter 2 presents a general discussion of the background of RCRA,
the hazardous waste management program, and HSWA, which expanded the scope of
RCRA. Following that is a discussion of the specific RCRA regulatory
requirements pertaining to schools and of the other regulatory programs that
apply to hazardous waste management in schools. Chapter 3 analyzes
information on the types and quantities of wastes at schools, current
management practices, and the schools' awareness of the hazardous waste
regulations. The schools are divided into secondary schools and higher
educational institutions and, for each, the report discusses the quantity,
type, and level of awareness of hazardous wastes and methods for treating,
storing, or disposing of them.
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Chapter 4 discusses the problems related to handling hazardous wastes at
educational institutions and the feasibility and availability of
environmentally sound methods for the treatment, storage, and disposal of
hazardous wastes at schools. Chapter 5 identifies possibilities for improving
hazardous waste management at schools. Possible solutions to these problems
are divided into those to be carried out within schools, between schools,
through guidance from State and Federal regulatory agencies, and by regulatory
change.
This report includes six appendices. Appendix A summarizes information on
the institutions interviewed in the Tufts University case studies. Appendix B
includes information on RCRA requirements for treatment, storage, and disposal
facilities, which may be applicable to some larger schools. Appendix C
presents an example of information on how schools can identify and, in some
cases, minimize the quantities of wastes they generate. Appendix D contains
addresses and telephone numbers of national hotlines, and regional and State
offices, as additional sources of information. Appendix E presents a list of
those organizations commenting on this report. Appendix F contains reponses
to questions on EPA's existing regulations.
1.4 DEFINITION OF "SCHOOL"
"School," as used in this report refers to the following categories. A
"secondary school" is a day or residential school that provides secondary
education, as determined by individual State laws, except that it does not
include any education beyond the 12th grade. An "institution of higher
education" is an educational institution in any State that meets all of the
following criteria:
• It admits as regular students only individuals having certificates
of graduation from high schools, or recognized equivalent of such
certificates.
• It is legally authorized within the State to provide a program of
education beyond high school.
• It provides one of the following: an educational program for
which it awards a bachelor's degree; a 2-year program that is
acceptable for full credit toward a bachelor's degree; a 2-year
program that prepares the student to work as a technician at a
semiprofessional level in engineering, scientific, or another
technological field.
• It is a public or nonprofit institution.
• It is accredited by a nationally recognized accrediting agency or
association, or, if not so accredited, is an institution whose
credits are accepted, on transfer, by at least three institutions
that are accredited, for credit on the same basis.
Education programs of less than 2 years' duration include those conducted by
community and junior colleges and technical institutes, whether used to
prepare students for vocational or avocational pursuits.
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CHAPTER 2
STATUTORY AND REGULATOR? OVERVIEW
Educational institutions that generate, transport, treat, store, or
dispose of hazardous wastes are subject to the hazardous waste regulations
issued under authority of RCRA Subtitle C. The first section of this chapter
provides the history and goals of the RCRA program. The second section
presents a summary of the RCRA Subtitle C program regulations that apply to
all generators, transporters, treaters, storers, and disposers of hazardous
wastes, including educational institutions that conduct these activities. The
third section identifies other Federal regulatory programs that may affect
educational institutions .handling hazardous wastes.
2.1 RESOURCE CONSERVATION AND RECOVERY ACT
2.1.1 Background
Congress passed the first solid waste legislation, the Solid Waste
Disposal Act of 1965, to support the development of improved waste disposal
methods and of solid waste disposal plans by States and interstate agencies.
This act was amended by the Resource Recovery Act of 1970 and, more
significantly, by RCRA in 1976. These amendments were the first steps in
requiring the development of a comprehensive program for the management of
hazardous wastes. RCRA was initially amended in 1980 and extensively, amended
by HSWA in 1984.
RCRA requires that solid wastes be managed properly and set the following
specific goals:
• Protecting human health and the environment
• Reducing waste and conserving energy and natural resources
• Reducing or eliminating the generation of hazardous wastes as
expeditiously as possible
RCRA is structured into nine subtitles (A through I), six of which address
general RCRA provisions. The remaining three subtitles, C, D, and I (Subtitle
I was added by HSWA in 1984), address the three programs developed under
RCRA: the hazardous waste management program, the solid waste management
program, and the underground storage tank program, respectively. This report
concerns only Subtitle C, the hazardous waste management program.
2.1.2 RCRA Subtitle C Program
RCRA Subtitle C establishes the statutory framework for a regulatory
program that applies to hazardous waste from the point of generation through
all treatment, storage, and disposal processes, including transportation
between sites. The goal of this program is to ensure that hazardous waste is
handled in a way that protects human health and the environment.
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Section 3001 requires EPA to promulgate regulations identifying the
characteristics of hazardous waste and listing particular hazardous wastes.
Sections 3002, 3003, and 3004 require EPA to promulgate regulations
establishing standards applicable to three categories of hazardous waste
handlers: generators; transporters; and those who treat, store, and dispose
of hazardous waste.
2.1.3 Hazardous and Solid Haste Amendments of 1984
HSWA substantially expanded the scope and requirements of RCRA. Some HSWA
provisions may have significant effects on educational institutions that
handle hazardous waste. For example, HSWA added Section 3001(d) of RCRA,
which required EPA to promulgate standards for small quantity generators of
hazardous waste (those generating more than 100 kilograms (kg) but less than
1,000 kg of hazardous waste per month). These requirements include using the
Uniform Hazardous Waste Manifest form; treating, storing, or disposing of such
waste at a hazardous waste facility; and tracking waste shipments. Although
not all educational institutions are small quantity generators, many of them
will fall into this category and are therefore now regulated.
Other major HSWA provisions may affect all or a subset of educational
institutions, whether or not they are small quantity generators of hazardous
waste, depending on the treatment, storage, and disposal processes used at the
institutions and the types and quantities of waste handled. For example, HSWA
established the land disposal restrictions program, which prohibits land
disposal of specific waste streams, according to an established schedule.
This provision is now part of RCRA Section 3004. The restrictions on land
disposal apply to both small and large quantity generators of hazardous
wastes, although not to conditionally exempt small quantity generators (see 40
Code of Federal Regulations (CFR) 268.1 (c) (4)) . In particular, the land
disposal restrictions apply to lab packs, which are used to dispose of most
hazardous wastes from academic laboratories. If a lab pack contains any
restricted wastes, the entire pack may not be land disposed unless the
restricted wastes are removed before land disposal, treated, or unless the
waste is exempted or an extension is granted as set out in 40 CFR 268.l(c).
2.2 RCRA HAZARDOUS WASTE REGULATIONS
This section outlines the current RCRA hazardous waste regulations that
apply to generators of hazardous waste, including large and small quantity
generators; transporters of hazardous waste; and treaters, storers, and
disposers of hazardous waste. EPA promulgated the first hazardous waste
regulations on May 19, 1980. Since then, the Agency has issued additional
regulations and modifications to existing regulations. The RCRA hazardous
waste regulations are contained in 40 CFR Parts 260-268 and 270—272.
Part 260 presents the definitions of terms, general standards, and
overview information applicable to Parts 260—266 and 268. A section in Part
260 of special concern to educational institutions is the definition of
"on-site." "On-site" is defined as "the same or geographically contiguous •
property which may be divided by public or private right-of-way, provided the
entrance and exit between the properties is at a cross-roads intersection, and
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access is by crossing as opposed to going along the right-of-way ..." (40
CFR 260.10 and 270.2). This means that a campus intersected or traversed by
public roadways can be considered as one site, whereas a campus with locations
at different points in a city would be considered to have several sites. The
definition of "on-site" in the regulations establishes the site boundary for
all generator activities (such as notification, counting of waste quantity to
determine whether a generator is a small quantity generator, and determining
whether manifests are required for shipments).
Part 261 identifies a waste as "hazardous" if it meets at least one of the
following two criteria (and is not excluded from regulation as a hazardous
waste under §261.4(b)):
• if it exhibits any of four hazardous waste
characteristics—ignitability, corrosivity, reactivity, or
extraction procedure (EP) toxicity—or
• if it is listed as hazardous in Subpart D of Part 261.
Specific hazardous wastes are listed in §§261.31—.33. Those likely to be
generated by educational institutions are identified in Sections 3.3.2 and
3.4.2 of this report.
Parts 262—266 and 268 establish regulatory requirements for three
categories of hazardous waste handlers: generators; transporters; and those
who treat, store, and dispose of hazardous wastes. Educational
institutions handling hazardous wastes may fall into one or more of these
categories. However, educational institutions are unlikely to be "commercial"
waste facilities (in the business of accepting hazardous waste from other
generators for treatment, storage, or disposal) and therefore unlikely to
transport, treat, store, or dispose of hazardous wastes unless they also
generate the wastes. Once the hazardous wastes are generated (for example,
after schools have finished using hazardous chemicals), then schools may
treat, store, or dispose of the wastes on-site or ship them off-site to
commercial treatment, storage, or disposal facilities. Schools that treat,
store, or dispose of wastes on-site must comply with the permitting or interim
status regulations.
Part 270 outlines the hazardous waste permit program. Part 271
establishes the requirements for authorization of the State hazardous waste
management programs. Part 272 lists the approved State hazardous waste
management programs. The hazardous waste regulations are intended to be
implemented by the individual States; however, if a State does not choose to
implement the hazardous waste program, EPA runs the program.
2.2.1 Generators of Hazardous Waste
Section 260.10 defines "generator" as "any person, by site, whose act or
process produces hazardous waste identified or listed in Part 261 of this
chapter or whose act first causes a hazardous waste to become subject to
regulation."
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2.2.1.1 Large Quantity Generators
As required under §262.11, all generators of solid waste must determine
whether their wastes are hazardous. A "large quantity generator" is defined
as (a) generating more than 1,000 kg of hazardous waste or 1 leg of acute
hazardous waste per month or (b) accumulating more than 1,000 kg of hazardous
waste, or 1 kg of acute hazardous waste, or 100 kg of acute hazardous spill
residue. A large quantity generator may not treat, store, dispose of, or
transport hazardous waste or offer it for transport without obtaining an EPA
identification number. Large quantity generators who transport hazardous
wastes off-site (or offer such wastes for transport) must prepare manifest
forms and follow manifest procedures (§§262.20—.23); prepare Biennial Reports
covering generator activities of the previous year (§262.41); and, if
necessary, submit Exception Reports notifying EPA of manifest problems
(§262.42). Generators must retain copies of all these reports (§262.40).
Generators may store the wastes for 90 days or less before shipping, provided
that they comply with §262.34. If a large quantity generator stores wastes
for more than 90 days in a tank or container or disposes of waste on-site, it
must have a treatment, storage, or disposal facility permit. However, under
§262.34 (c), a generator may accumulate up to 55 gallons of nonacute or 1 quart
of acute hazardous waste in satellite accumulation areas located near the
point of accumulation. The 90-day time limit begins only after the generator
exceeds quantity limits at the satellite areas and brings the excess waste to
the accumulation area. Generators shipping wastes off-site must also follow
the pretransport requirements (§§262.30—.34), including packaging, labeling,
marking, and placarding waste packages in accordance with applicable
Department of Transportation (DOT) regulations.
2.2.1.2 Small Quantity Generators
Section 260.10 defines a "small quantity generator" as one generating less
than 1,000 kg of hazardous waste in a month. For the purposes of this report,
"small quantity generator" refers to one generating between 100 and 1,000 kg
of nonacute hazardous waste per month. Small quantity generators, like large
quantity generators, must make hazardous waste determinations and obtain EPA
identification numbers, as specified by §§262.11 and 262.12. Similarly, small
quantity generators are subject to the same requirements as large quantity
generators for exports and imports of hazardous waste.
*
The manifest, accumulation, and recordkeeping and reporting requirements
for small quantity generators, however, are less stringent than those for
large quantity generators. The small quantity generator regulations in these
areas are outlined below. Recognizing the small business nature of many small
quantity generators, EPA has prepared a handbook explaining these requirements
(EPA 1986b).
Manifest Requirements (262.20—23): The manifest requirements for
small quantity generators are the same as those for large quantity generators;
however, EPA has exempted small quantity generators from manifest requirements
when the hazardous waste is reclaimed under contractual arrangements that
comply with §262.20(e). DOT regulations are codified in 49 CFR Subchapter C.
Transporters must be in compliance with all applicable DOT requirements of 49
CFR Parts 171-179 to be considered to be in compliance with EPA's transporter
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regulations under 40 CFR Part 263. However, the EPA regulations generally
contain the DOT requirements governing the transportation of hazardous
materials (including labeling, marking, placarding, using proper containers,
and reporting discharges). This ensures consistency between the EPA and DOT
programs and avoids duplication or conflicting requirements. The EPA manifest
satisfies DOT'S shipping paper requirement, and DOT has revised its
transportation regulations to cover the transportation of hazardous wastes and
to include both intrastate and interstate waste transport.
Pretransport and Accumulation Requirements (262.30-34(d), (•), (£)):
Although the pretransport packaging, labeling, marking, and placarding
requirements for small quantity generators are the same as those for large
quantity generators, the pretransport accumulation time requirements differ.
A small quantity generator may accumulate hazardous waste on-site for longer
periods of time (180 days, compared with 90 days for a large quantity
generator) without a permit or interim status, provided that the quantity of
waste accumulated never exceeds 6,000 kg and that the generator complies with
the applicable requirements of Part 265 and the safety requirements specified
in §262.34(d)(5). In addition, a small quantity generator who transports his
waste, or offers the waste for transport, over a distance of 200 miles or more
for off-site treatment, storage, or disposal may accumulate hazardous wastes
on-site for 270 days or less without a permit or interim status.
Recordkeeping and Reporting (262.44): Small quantity generators are
exempt from Biennial Reports, but they must comply with a modified form of
Exception Reports. In particular, a small quantity generator has 60 days to
receive its copy of the manifest before the exception reporting requirement is
triggered (compared with the 45-day limit for a large quantity generator). A
small quantity generator must notify the EPA Regional Administrator by mailing
a copy of the unreturned manifest with a note stating that the return copy was
not received from the treatment, storage, or disposal facility (40 CFR
262.42(b)). All other recordkeeping and reporting requirements remain the
same as for large quantity generators.
2.2.1.3 Conditionally Exempt Small Quantity Generators
Conditionally exempt small quantity generators (those who generate less
than 100 kg of nonacute hazardous waste per month) are not subject to the
requirements of Parts 262-268 and 270—272, provided that they comply with the
requirements specified in §261.5, as follows.
In particular, conditionally exempt small quantity generators may treat Or
dispose of their hazardous wastes in an on-site facility or ship those wastes
to an off-site treatment, storage, or disposal facility either of which—
• Is permitted under Part 270;
• Is in interim status under Parts 270 and 265;
• Is authorized to manage wastes by a State hazardous waste
management program approved under Part 271;
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• Is permitted, licensed, or registered by a State to manage
municipal or industrial solid waste; or
• Beneficially uses or reuses or legitimately recycles or reclaims
its wastes, or treats its wastes prior to beneficial use or reuse
or legitimate recycling or reclamation.
Conditionally exempt small quantity generators also may not generate more
than 1 kg of acute hazardous wastes listed in §§261.31, .32, and .33(e) per
month. Similarly, these generators may not generate more than 100 kg of any
residue or contaminated soil, waste, or other debris resulting from the
cleanup of a spill of any acute hazardous waste listed in §§261.31, .32, or
.33(e) per month. If the generator accumulates more than these allowable
quantities, all of the accumulated wastes become subject to the special
requirements for small quantity generators in Part 262. Conditionally exempt
small quantity generators also may not accumulate more than 1,000 kg of
nonacute hazardous waste on-site at any time. If the generator exceeds this
quantity restriction, it becomes subject to the small quantity regulations
(applicable to generators of between 100 and 1,000 kg of hazardous waste per
month).
2.2.2 Transporters of Hazardous Wast*
An educational institution that ships its hazardous waste off-site may or
may not be involved in the transportation of the waste, depending on the
quantity of waste generated and the proximity of the institution to the
off-site treatment, storage, and disposal facility. However, an educational
institution is unlikely to be a transporter of hazardous wastes if it is not
also the generator of the wastes.
Part 263 contains regulations for transporters of hazardous waste. These
regulations do not apply to on-site transportation of hazardous waste by
generators or owners or operators of hazardous waste management facilities.
These regulations also do not apply to transportation of conditionally exempt
small quantity generator waste (see §261.5) . Generators of hazardous waste
that also transport their wastes must comply with the regulations of Parts 262
and 263.
Transporters of hazardous wastes, like generators, may not operate without
first obtaining an EPA identification number. Transporters storing manifested
hazardous waste in containers meeting the DOT pretransport packaging
requirements of §262.30 for 10 days or less are not subject to the storage
regulations under Parts 264, 265, 268, and 270. In many cases, educational
institutions that transport hazardous wastes may be transporting wastes for
themselves, and therefore many of the transporter manifest requirements will
be covered by the generator manifest regulations (§§262.20, .21).
Transporters of export waste must comply with special manifest requirements;
these transporters probably will not be schools. Transporters may not accept
hazardous waste from a non-conditionally-exempt generator without a manifest
form, and they must retain a copy of the manifest and the shipping paper (if
the waste was shipped by water) for 3 years (or for such extended time as is
requested by EPA). Transporters of hazardous waste who discharge waste during
transportation must take appropriate immediate action to protect human health
and the environment (see §§263.30 and .31).
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2.2.3 Traaters, Storars, and Disposers of Hazardous Haste
Educational institutions that generate hazardous waste are subject to the
treatment, storage, and disposal regulations in Parts 264 and 265 only if they
treat, store beyond the accumulation time, or incinerate or dispose of their
hazardous waste on-site. Generators are allowed to store their waste on-site
for up to 90 days (180 to 270 days for small quantity generators) without
compliance with all the requirements of Parts 264 and 265, provided that
certain rules are followed (see §262.34). Although generators may treat
wastes in tanks without obtaining a permit, this practice is allowed only if
the tanks also do not meet the definition of a hazardous waste treatment unit
that is regulated in another Subpart.
Permitted treatment, storage, or disposal facilities must comply with all
the requirements of Part'264, and interim status facilities must comply with
the requirements of Part 265. Appendix B outlines regulations applicable to
owners and operators of treatment, storage, and disposal facilities. The
regulations summarized are specific to particular waste management processes
and include closure, post-closure, and financial regulations.
2.3 OTHER APPLICABLE REGULATORY PROGRAMS
Other Federal regulations may apply to educational institutions generating
and handling hazardous waste. These include the Department of Transportation
regulations, the Clean Water Act (CWA) regulations, and the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) regulations.
In addition, State and local governments regulate hazardous waste.
Thus, educational institutions that have disposed of wastes that contain
hazardous substances may be legally liable for cleanup if those hazardous
substances are mismanaged. In fact, there are some hazardous waste sites at
universities included on the National Priorities List for Superfund cleanup.
For example, the University of Minnesota burned chemical laboratory wastes in
an outdoor pit between 1960 and 1974, after which the pit was covered over.
In 1984 the Minnesota Pollution Control Agency found that ground water as far
as 2 miles to the northeast of the disposal site was contaminated with low
levels of chloroform. The university has supplied families in the area with
bottled water and has suggested several ways of solving the water
contamination problem (Sanders 1986). In another instance, North Carolina
State University buried containers of waste chemicals at an off-campus site
between 1969 and 1980. Wells near the disposal site have shown relatively
high concentrations of such compounds as chloroform, bromoform,
1,1,1-trichloromethane, and methylene chloride in the water. If a generator
sends hazardous waste to a site that is later placed on the National
Priorities List, that generator may be held liable for cleanup costs.
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*
CHAPTER 3
CURRENT HAZARDOUS HASTE MANAGEMENT PRACTICES AT EDUCATIONAL INSTITUTIONS
3.1 INTRODUCTION
This chapter presents current hazardous waste management practices at
schools and discusses school activities that generate hazardous waste. The
curricula and number of students at secondary schools, colleges, and
universities differ, causing differences in the types and quantities of wastes
generated by these institutions. The most commonly identified wastes are
those generated in laboratories. Other campus facilities however, also
generate hazardous wastes, although the quantities are generally smaller.
Waste management programs at schools range from nonexistent to simple
collection and disposal to extensive collection, recycling, on-site treatment,
and subsequent disposal. The level of awareness at a school is reflected by
the waste management program in place. Due to the liabilities of improper
hazardous waste management, educational institutions are making greater
attempts to be in compliance. Secondary schools are treated separately from
colleges and universities in this report, both because the level of awareness
is much lower in secondary schools than in colleges and universities, and
because the curriculum in secondary schools tends to be consistent throughout
the country, resulting in a limited number of types of hazardous waste
generated. Colleges and universities, in contrast, tend to offer a variety of
courses; in addition, some have extensive research programs that result in
wastes with more variable characteristics.
3.2 THE NATURE OF SCHOOLS
Academic institutions are different from most other generators of
hazardous waste in several respects. The mission of schools is to educate
students who are generally young and developing both physically and mentally
and need continual, close supervision. This is unlike industry, where, after
an initial training period, workers are left on their own. In addition,
industry sometimes promotes worker safety by offering bonuses to groups with
consistent safety records, which tends to increase the level of worker
awareness. Overall, industrial laboratories have a reputation for being more
aware of safety than academic laboratories (Sanders 1986). Historically,
educational institutions have not developed hazardous waste management or
health and safety programs to the same extent as industry. This lack of
development may stem from the large numbers of independently operating
laboratories within educational institutions. Industrial research groups tend
to operate under a central management, which allows relatively straightforward
implementation of hazardous waste management and health and safety programs
(Sanders 1986) . These differences may result in a different level of
commitment to safety issues and waste handling.
The funding mechanism at schools is also different from that of businesses
and may influence which waste management program is adopted. Schools
generally are nonprofit, with funds coming primarily from the public sector,
from private donations, or through tuition. A school budget is administered
by a school board, whose primary interest may be to get the most for the money
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available. School boards or State and municipal governments determine school
budgets, and they may be compelled to consider budget-related issues not
observed in industry. School boards may not have the flexibility that
industry has to develop waste management programs because of budgetary
restraints that can be out of their control (Tufts University 1987) . In
addition, waste management personnel at educational institutions do not always
receive the organizational support that their industrial counterparts may'
enjoy. Companies may have established waste management programs to decrease
their long-term liability for the waste. Academic institutions generally
operate on a shorter term than industry; furthermore, the turnover in staff
and students at educational institutions does not always allow for long-term
considerations (Sanders 1986).
Most schools do not have complete inventories of amounts of hazardous
waste generated, and some schools only dispose of hazardous wastes after large
amounts have accumulated, in a waste cleanout of multiyear accumulations
(Tufts University 1987). Therefore, the total quantity of hazardous waste
generated by educational institutions must be estimated by piecing together
data from various sources. EPA used data that it collected as part of its
survey of small quantity generators (EPA 1985) to estimate the quantity of
hazardous waste that schools generate. There are approximately 30,000
educational institutions acting as sources, and together they generate 2,000
metric tons of hazardous wastes. A few educational institutions can be
classified as large quantity generators, and the wastes that they generate are
not included in the 2,000-metric-ton estimate. Thus, the total quantity of
hazardous waste generated by schools is 2,000 to 4,000 metric tons per year
(Tufts University 1987), much less than 1 percent (0.0017 percent) of the
240,000,000 metric tons of total hazardous waste generated annually (EPA
1985). Some school administrators, faculty members, and maintenance workers
are unaware of what constitutes a hazardous waste. Consequently, the actual
quantity of hazardous waste generated may be underreported.
A typical educational institution manages hazardous wastes by first
assembling wastes at one or more locations, segregating the wastes by type,
and, if necessary, labeling the wastes. After the material has been stored on
campus, usually for no more than 90 days, it is picked up by a waste
transporting firm or waste disposal firm. The typical school generates
hazardous wastes in its laboratories and relies on landfills for disposal more
heavily than does the typical industrial firm. Before being transported off
the campus, waste containers are usually placed in lab packs, which may be
buried in landfills. (This practice is no longer allowed in many cases (see
40 CFR Part 268).) A lab pack is a 55-gallon drum capable of holding no more
than 15 gallons of liquid waste in bottles or cans. The remaining content of
the drum is a filler material that reduces the possibility of breakage and
that can absorb any liquid that is released, in case breakage does occur. The
lab packs are sometimes taken to processing facilities that combine treatment,
incineration, and landfilling to dispose of the lab packs (American Chemical
Society 1987.)
The following are some characteristics of educational institutions.
Although most laboratories at educational institutions are small quantity
generators or conditionally exempt small quantity generators, the amounts of
hazardous waste generated at some universities are larger than might be
imagined.
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Laboratories, which can be divided into those used primarily for research
and those used for teaching purposes, tend to generate most of the hazardous
wastes at educational institutions. Teaching laboratories expose students to
a variety of experiments to maintain student interest, and thus may generate a
large volume of wastes more varied than those generated by research
laboratories (Tufts University 1987). Most laboratories at educational
institutions produce a relatively large variety of wastes compared with
industrial plants, which may generate only a dozen or so wastes. For example,
in 1984 the University of Illinois disposed of 7,300 containers holding more
than 2,100 different chemicals and chemical mixtures. The University of
Massachusetts, Amherst, annually disposes of about 2,000 different chemicals
and chemical mixtures. These wastes will typically change in composition as
new research projects start, older projects end, and the directions of
research programs shift.
Arts, crafts, and vocational studies also generate hazardous wastes at
educational institutions. Toxic metal compounds are used in pottery glazes'
and in paint pigments to provide color. Chromium, lead, and nickel are
commonly used toxic metals. Building operations and maintenance activities
tend to contribute the least to overall quantity (Tufts University 1987) .
Nonlaboratory waste includes photographic wastes, solvents used as paint
thinners, and degreasing agents (McCann 1987). Chemicals used in photography
tend to contain silver, to be alkaline, and to constitute a handling problem
while being used (McCann 1987).
Academic waste streams are characterized by sporadic generation, a high
portion of unknown and unidentified substances, and mixed hazardous waste
composition (Tufts University 1987) . Factors affecting waste Quantities
generated' and changes in waste streams include the following:
• The types of activities conducted by the educational
institutions
• Commencement and termination of research projects
• Ending of semesters or terms
• Acceptance of donations of types or quantities of hazardous
materials not needed by a school
• Accumulation of unneeded hazardous supplies and materials
because of a failure to change purchasing practices and
commitments to reflect changes in curricula
• Laboratory relocation and staff changes, leading to abandonment
of unidentified and hazardous materials
The organization to handle the waste stream varies among educational
institutions, with the size of the laboratory program apparently the
determining factor. Schools with large scientific research programs tend to
be better organized to deal with hazardous waste, perhaps because of the
larger quantities of wastes generated at these institutions (Tufts University
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1987) . The larger schools (generally, colleges and universities) have the
following characteristics:
• Tend to generate 1,000 kg or more of hazardous waste per month
and thus are fully subject to the RCRA Subtitle C and EPA
regulatory requirements
• Have at least one EPA identification number
• Have a budget for hazardous waste packaging, transport, and
disposal activities
• Have at least one full-time-equivalent person responsible for
hazardous waste management, a person who is well informed and
trained and who is in communication with peers at other schools
• Have recognized their responsibilities and liabilities and will
have given adequate authority to responsible staff
Schools that do not have a substantial scientific research or medical
program have the following characteristics (Tufts University 1987) :
• Generate less than 100 kg of hazardous waste per month
(conditionally exempt small quantity generator) during most months
• Probably could accumulate or store more than 1 kg of acute
hazardous waste at a given time, making those wastes subject to
full regulation
• Probably could accumulate or store more than 100 kg of hazardous
waste at a given time, making those wastes subject to the
requirements under Part 262 for generators of 100 to 1,000 kg of
hazardous waste per month
• Awareness of, assignment of responsibility for, and comprehension
of proper hazardous waste management will range from limited and
incomplete to nonexistent
• Conformity with regulatory requirements or safe practices for
handling accumulation, storage, and disposal of hazardous wastes
will be the exception rather than the rule
• Proper collection, transportation, and disposal of hazardous
wastes will most likely have occurred through participation in a
community-organized one-time hazardous waste cleanup project, and
be limited to laboratory wastes
• Expenditures for hazardous waste management will be low compared
with the school's overall budget
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Some schools, particularly small ones, have participated in cooperative
strategies to reduce their waste disposal costs. For example, schools in a
region have cooperated by using the same waste disposal company, which
operates along a single designated route, and thereby have reduced their
transportation costs. A cooperative project has been under way in Minnesota
since 1981. The Minnesota Chemical Waste Assistance Project now serves about
160 high schools and 20 colleges throughout the State.
Nationally, 62 schools had Part B hazardous waste storage permits in 1986
(Tufts University 1987). This relatively small number is attributed to the
costly and time-consuming permit application process. Some schools that do
not have permits store hazardous wastes in excess of allowed limits. The
stored wastes include undesignated supplies, wastes refused by transporters
(including dioxin-containing materials; certain pesticides, such as ketone,
sodium peroxide, and red phosphate; and reactives, such as ethers and picric
acid), and unidentified past accumulations (Tufts University 1987).
From the Tufts University case studies, it appears that the principles and
specific requirements applicable to accumulation of hazardous wastes at or
near the point of generation ("satellite accumulation," 40 CFR 262.34 (c)) are
neither well nor widely understood. The practice of satellite accumulation is
widespread; examples include accumulation in storage cabinets, other sites in
or near laboratories, art studios, and maintenance shops. Generally, neither
accumulation nor storage facilities at high schools and small colleges were
adequate or in compliance with the regulations; furthermore, they frequently
overlooked the more stringent requirements applicable to acute hazardous
wastes. Conversely, larger universities managed storage and accumulation well
(Tufts University 1987) .
Information on the types and quantities of wastes generated by educational
institutions can be further broken down to differentiate between secondary
schools and colleges and universities.
3.3 SECONDARY SCHOOLS
3.3.1 Introduction
Very little information is available on the quantities and types of wastes
generated by secondary schools in the United States. There are approximately
16,000 secondary schools in this country, of various sizes, as seen in
Table 3-1. These schools are traditional high schools, vocational schools,
and schools that combine both types of curricula. The types of wastes
generated by secondary schools can be inferred from their curricula and the
types of materials likely to be used. In secondary schools, hazardous waste
management is viewed as an element of school safety, rather than as a
materials handling and disposal issue.
High school personnel generally have a lower level of awareness and
concern and a more limited knowledge of regulations and proper procedures than
do university personnel. Tufts University (1987) researchers found that
several of the high schools that they studied had no budget for dealing with
hazardous materials. In fact, they encountered some administrators and
science teachers who had no interest in developing waste management programs.
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Tabla 3-1
Number and Enrollment of U.S. High Schools
(Including Vocational High Schools)
(1982-83)
Schools
Enrollment
>9,999
1,000-9,999
<1,000
TOTAL
No.
1,632
5,501
8,725
15,858
Percent
10
35
55
100
Students
No.
24,236,000
12,626,000
2,985,000
39,847,000
Enrolled
Percent
61
32
7
100
Source: U.S. Department of Education, National Center of Educational
Statistics, Digest of Educational Statistics, Washington, D.C., 1985-86,
table 58.
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Seconday schools' current waste disposal practice is to use the drain or
the dumpster, or to follow other practices not authorized by the RCRA
regulations. However, the level of awareness on the part of school
administrators and faculty members is increasing, which is likely to change
current practices. Faculties and administrators accept the substitution of
less hazardous materials into school curricula on the basis of student safety,
but they are less ready to accept substitution on the basis of waste
management.
3.3.2 Sources and Characteristics of Wastes
Specific types of high school courses associated with hazardous waste
generation are listed in Table 3-2. Included in the table are the differences
in the percentages of schools offering these courses from 1973 to 1982.
Science curricula in secondary schools include courses in chemistry, biology,
earth sciences, and physical sciences. The National Institute of Occupational
Safety and Health has evaluated experiments performed in secondary schools and
the hazards associated with them (National Institute of Occupational Safety
and Health 1980). The data reveal that both toxic and nontoxic materials are
used, including some that are hazardous because of flammability or
reactivity.
Nonacademic activities at secondary schools also generate hazardous
wastes. For example, boilers generate waste as part of their water treatment
procedure and need to be cleaned to blow out any materials (for example, rust)
that accumulate in the pipes (Tufts University 1987).
3.3.3 Quantity of Waste Generated
Some studies are under way to determine the volumes of hazardous waste
generated by secondary schools, since there are few data available on such
volumes. In Minnesota in 1983, 78 high schools generated a yearly average of
40 kg each of hazardous waste (Ashbrook and Reinhardt 1985). Part of the
difficulty in determining these quantities is that some school personnel do
not know what constitutes a hazardous waste.
Many common practices at schools make it difficult or impossible to
determine how much hazardous waste is actually generated. For example, a
school may conduct a one-time cleanout of stockpiles of unused materials,
perhaps once every 10 years. (When the chemicals are discarded or intended
for discard, they become waste and subject to these regulations. There has
been no systematic study of how much waste is generated in this process.
Another practice that makes it difficult to specify how much waste schools
generate is that hazardous waste is disposed of routinely by using the sewer
system as the dumpster (Tufts University 1987, Sanders 1986). Volatile
compounds maybe stored under fume hoods while they vaporize and are disposed
(Stanley 1987, Kizer 1987). Many of these practices are not considered to be
safe laboratory practices, and in some cases they are not allowed under
current regulations.
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Table 3-2
High School Course Offerings Likely To Produce Hazardous Waste
Percentage of
Schools
Offering Course
Course
1973*
1982
Potentially
Hazardous Wastes
Agricultural Arts:
Agriculture
Horticulture/Landscaping
29.7
1.6
48.4
23.4
Graphic Arts:
Art 74.0 89.6
Graphics 6.0 33.3
Jewelry/MetalworJc 6.9 9.8
Pottery/Ceramics 16.2 28.8
Painting/Drawing/Design 19.6 36.0
Photo/Filmmaking 6.4 14.1
Pesticides, fertilizers
Oil-based paints, solvents
Inks, solvents, acids
Acids
Metals in glazes, silica ~
in clays
Oil-based paints, inks,
solvents
Silver, developing and
fixing chemicals
Industrial Arts:
Ca rpent ry/Woodwo rking
75.5
46.1
Leather/Textiles/Upholstery 2.1
Plastics 4.1
Photography 5.5
Printing/Photo/Graphics 3.3
Metalworking/Foundry 33.8
Welding 9.0
Auto Mechanics 18.3
90.6
70.3
6.9
4.8
41.7
31.7
47.5
Stains, solvents, wood
preservatives
Dyes
Ketones
Silver, photochemicals,
inks, solvents
Metal dust
Lead solder
Degreasing solvents, oil,
grease
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Tabla 3-2 (Continued)
Course
Power/Auto Mechanics
Science Courses :
Natural Science
Biology
Chemistry
Avocational Courses:
Trades and Industry
Graphic Arts
Print ing/ Lithography
Textile/Leather Products
Body and Fender Mechanics
Automobile Mechanics
Masonry
Carpentry
Woodworking, 1st Year
Woodworking, Advanced
Machine Shop
Sheet Metal
Metalworking
Percentage of
Schools
Offering Course
19733 1982b
17.6 33.1
89.3 99.7
79.9 97.8
88.1 89.4
24.0 94.0
3.1 3.2
1.9 10.3
1.3 10.3
4.4 17.9
12.5 11.7
2.5 9.5
6.4
4.0
3.9 4.3
7.0 17.7
1.8 0.1
1.2 0.7
Potentially
Hazardous Wastes
Various chemicals, acids,
bases
Inks, solvents
Dyes
Batteries, paints,
degreasing solvents,
oil, grease, acids,
alkaline waste
Paint, solvents, muriatic
acid
Stains, solvents, paints,
wood preservatives
Stripping and cleaning
solutions, plating bath
residues, acids, bases,
Welding and Cutting
Cosmetology
5.7
5.1
18.5
metal dust
Various chemicals
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Table 3-2 (Continued)
Percentage of
Schools
Offering Course
Course 1973
Health Courses :
Allied Health
Laboratory/Chemical Technology
Nursing
1982^
20.6
4.5
11.7
Hazardous Wastes
Various chemicals and
Pharmaceuticals
aBased on survey of 7,850 (out of 15,306) schools.
^Based on survey of 941 (out of 15,667) schools.
Source: A Trend of High School Offerings and Enrollment: 1972-1973 and
1981-1982, Evaluation Tech., Inc., under contract 300-83-0114 with the
Department of Education.
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3.3.4 Storage and Disposal of Wastes
At secondary schools, chemicals are stored either in chemistry stockrooms
or in closets. In a number of schools, there is a disregard for the
appropriate ways to store chemicals. Teachers frequently shelve materials
alphabetically, which may result in incompatible chemicals being stored near
one another, so a potentially reactive situation could exist (New York State
Environmental Facilities Corporation 1985). This is not considered safe
laboratory practice and, in some cases, may not be allowed under current
regulations.
i
Wastes generated by schools can be placed in three disposal categories:
• Wastes that are nonhazardous and disposable at the school
• Wastes that are hazardous but treatable at the school, using such
methods as detoxification
• Wastes that are hazardous and treatable only at a commercial
treatment, storage, or disposal facility (New York State
Environmental Facilities Corporation 1985)
One of the difficulties that secondary schools have in disposing of wastes
at an approved treatment, storage, or disposal facility is the cost.
Secondary schools' wastes tend to be in small volumes of variable
compositions, which can drive up disposal costs on a per gallon basis. Waste
transporters can only operate cost-effectively if they have full loads.
3.4 COLLEGES AMD UNIVERSITIES
3.4.1 Introduction
There are approximately 3,300 colleges and universities in the United
States (Table 3-3). The variation in size and length of program tends to
influence the level of awareness of the issue of hazardous waste management.
In general, larger schools with extensive research programs have the most
comprehensive waste management programs. Smaller schools may lack the funds
or the staff to deal with hazardous waste management, although Howard H.
Fawcett (as referenced by Sanders (1986)) has stated: "If the smaller schools
had a real desire to do a good job, they could find the money somewhere.
Often the amount of money needed is not all that great, perhaps a few thousand
dollars a year."
3.4.2 Sources and Characteristics of Wastes
There are a number of courses that can be expected to generate hazardous
wastes at colleges and universities, as seen in Table 3-4. Most of the
hazardous waste is generated by laboratories. Tufts University researchers
found that, in one case study university, 75 percent of the hazardous waste
was generated in research laboratories, 20 percent was generated in teaching
laboratories, and 5 percent was generated in machine shops. Another
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Table 3-3
U.S. Institutions of Higher Education
by Type and Control, Fall 1983
Type of Institution
Private Public
Category No. Percent No. Percent
2-Year Institutions 355 28 915 72
Universities and Other
4-year Institutions •' 1,447 72 565 28
TOTAL 1,802 55 1,480 45
Source: Department of Education, National Center for Educational
Statistics, Digest of Educational Statistics, Washington, D.C., 1985-1986
(after table 104).
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Tabla 3-4
College-Level Courses Likely To Result
in Hazardous Waste Generation
Course Category
Types of Potentially
Hazardous Wastes
Agribusiness and Agricultural Production
Agricultural Sciences
Allied Health Services
Biology
Chemistry
Communication Technologies
Computer and Information Sciences
Construction Trades
Crafts and Designs
Diagnostic and Treatment Services
Engineering
Environmental Control Technologies
Fine Arts
Health Sciences
Industrial Production
Life Sciences
Mechanical and Electromechanical Technologies
Mechanics and Repairers
Medical Laboratory Technologies
Multi/Interdisciplinary Studies
Physical Sciences
Physics
Precision Production
Science Technologies
Visual and Performing Arts
Pesticides, fertilizers, animal
Pharmaceuticals
Chemicals, Pharmaceuticals
Various chemicals
Photochemicals, lubricants
Lubricants, oil
Paints, solvents, inks
Various chemicals
Waste oils, solvents,
degreasers
Spent charcoal filters
Paints, solvents, metals, inks
Various chemicals
Degreasing solvents, oil,
grease, acids, alkaline bases
Various chemicals
Solvents
Degreasing solvents, paints,
oils
Various chemicals and
Pharmaceuticals
Various wastes
Various chemicals
Degreasing solvents
Various chemicals
Developing and fixing chemicals
Source: Index of Majors 1985-1986, College Entrance Examination
Board, New York, 1985.
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university reported that 75 percent of its waste came from chemistry research
laboratories, chemistry classrooms, the college of pharmacy, engineering and
physics, and vehicle maintenance and arts. At universities where medical
research is conducted, wastes from research and chemical laboratories in the
biomedical area may dominate the waste stream. These laboratories accounted
for 55 percent of the hazardous waste generated at the University of
Washington and its related facilities (Ellefson 1986).
The types of laboratory wastes vary, depending on the research projects
being conducted as well as the course offerings in a given academic year.
Ashbrook and Reinhardt (1985) reported that the major laboratory wastes are
spent solvents, spent acids and bases, and unwanted stock chemicals. Minor
laboratory wastes include spent toxic metals, degraded stock chemicals,
contaminated laboratory apparatus, chemicals that react with air and water,
potentially explosive chemicals, cyanides and sulfides, pesticides,
polychlorinated biphenyls, and small gas cylinders. The University of
Illinois disposed of 7,300 containers holding more than 2,100 different
chemicals and chemical mixtures in 1984. The University of Massachusetts,
Amherst, disposed of approximately 2,000 different chemicals and chemical
mixtures each year. The quantity of an individual waste ranges from a
55-gallon drum down to an ampoule (Sanders 1986) . The University of Minnesota
determined that in 1981, 1,350 of the most frequently used chemicals could be
designated as hazardous (Ashbrook and Reinhardt 1985).
Maintenance activities generate certain types of hazardous wastes, such as
spent solvents. Solvents are used as degreasing agents or paint thinners, and
the solvents used by art departments and maintenance operations have been
pooled before disposal. Additional maintenance materials that could be
hazardous are bleaches; pesticides; fertilizers; water treatment chemicals,
such as chlorine; and polychlorinated biphenyls from transformers (Koertge
1981) .
3.4.3 Quantity of Waste Generated
Some universities and colleges know in great detail the quantities of
hazardous waste that they generate, whereas others have no knowledge of the
quantities generated. This is a reflection of the yarious levels of effort
that schools have put into waste management programs. The quantity of waste
generated is increasing. At the University of Wisconsin, 36,000 kg of
hazardous wastes were generated in 1984; 50,000 kg, in 1985; and 105,000 kg,
in 1986. The quantity of hazardous waste generated by the University of
Illinois at Urbana-Champaign grew from 27,500 kg in 1984 to 37,000 kg in
1985. The University of Maryland, College Park, increased its hazardous waste
shipments to an outside disposal firm from 150 55-gallon drums in 1980 to 320
drums in 1985 (Sanders 1986). The increase in quantity of hazardous waste
generated resulted in a 113-percent increase in cost of handling and disposing
of wastes at the University of California, Davis (Ashbrook and Reinhardt 1985,
Sanders 1986) .
In an effort to minimize the quantity of hazardous waste generated,
colleges and universities are beginning to develop various programs, ranging
from scaling down experiments conducted in teaching laboratories to operating
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chemical exchange services between departments (Sanders 1986). Implementation
of these programs is expected to decrease the quantity of hazardous waste for
disposal from colleges and universities. For example, Professor Dana Mayo of
Bowdoin College has developed a microscale organic chemistry curriculum, using
1 to 10 milligrams of material, whereas miniscale experiments use 15 to 30
milligrams of material and traditional experiments use 50 to 100 milligrams
(Sanders 1986). There are a number of advantages to scaling down
experiments. Clearly, the quantity of material that a student is exposed to
decreases, as does the quantity of waste generated. One of the disadvantages
is that, because of the smaller quantities of material generated, more
sensitive analytical equipment may be required, and this could be a
substantial expense. Steve Larson (1986), director of the Office of
Environmental Health and Safety at Northeastern University, states that the
full transition to microscale experiments probably will not occur, because the
transition to miniscale experiments is already very costly and has not been
determined to be cost-effective for Northeastern University, given the costs
of disposing of the larger waste quantities currently generated. Mr. Larson
states further that disposal costs would determine the agenda for the
transition to microscale experiments, despite the advantages of microscale
laboratory practices.
Another example of a way schools have minimized the amount of waste that
needs disposal is the use of small-scale silver recovery devices in
photographic laboratories. These devices remove silver salts from a filter
system or a tank containing a sodium thiosulfate solution by an electrolytic
process. Cartridges are used to collect the silver and then are returned to
the manufacturer, which- supplies new cartridges and pays for the silver.
Other options for silver recovery include pickup of exhausted sodium
thiosulfate solution by a silver reclamation company, use of chemical recovery
methods, and metal displacement precipitation (Tufts University 1987).
At some schools, there are transfer services that take unwanted chemicals
from one department and make them available to another department that needs
them. This type of exchange decreases the stockpiling of chemicals in
storerooms, and reduces the operating cost of some laboratories, because
purchasing requirements are diminished. For example, Southern Illinois
University at Carbondale operates a comprehensive waste exchange through its
Pollution Control Department. In 1978, more than 3,000 different chemicals
and 300 gallons of solvents were exchanged in this program, at a savings of
more than $20,000 in purchasing costs (Meister 1981). The University of
Massachusetts, Amherst; the University of Wisconsin, Madison; and other
schools also operate similar formal and informal exchanges. The University of
Wisconsin recycles many unwanted but reusable chemicals that are typically
disposed of, and it publishes a newsletter five times a year that contains a
list of reusable chemicals. This type of program has saved more than $20,000
annually at the University of Wisconsin (Ashbrook and Reinhardt 1985). By
emphasizing segregation of nonhazardous from hazardous wastes, recycling,
incineration, and chemical treatment, the University of Wisconsin, Madison,
substantially reduces off-site disposal. Each year this university generates
about 25,000 gallons of hazardous waste, but only 550 gallons, or
approximately 3.5 percent, of waste is shipped off-site (Reinhardt 1987).
There are many more waste exchanges, such as the Northeast Waste Exchange in
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Syracuse, New York, and the Michigan Products Information Exchange in
Menominee, Michigan, that are not specific to only a few schools, but that
allow many schools to participate (Tufts University 1987) .
The use of less hazardous materials also is being adopted. At the
University of Wisconsin, Madison, for example, chromic acid cleaning solutions
are no longer available from the chemical stockroom, and a less hazardous
cleaning solution is available. This type of substitution does not
necessarily reduce the quantity of waste generated, but it may reduce the
potential hazard of the waste (Ashbrook and Reinhardt 1985).
3.4.4 Storage and Disposal of Wastes
The discussion of chemical storage can be divided into two areas:
stockpiled or new chemicals or supplies and wastes that have been removed from
the source (for example, a science laboratory or an art studio). If these
hazardous wastes are not stored properly, they can pose a threat to school
safety and, in some cases, may not be allowed under current regulations.
Schools have a large number of potential uses for chemicals. Typically,
chemistry and science departments store hundreds and sometimes thousands of
chemicals, and art studios and maintenance facilities store smaller numbers of
less diverse supplies. In addition to newly purchased chemicals, schools also
must store chemicals whose shelf lives have expired and chemicals that are no
longer needed; if these materials are intended for discard, they become wastes
and are subject to the hazardous waste regulations. This type of stockpiling
can cause a buildup of hazardous wastes. If all the chemicals are stored in
or tracked by a central agency within the school, the possibility exists for
the implementation of recycling programs, as discussed above. Centralization
can also help to minimize excessive purchasing of widely used chemicals
(Ashbrook and Reinhardt 1985, Sanders 1986) . Once materials have been
determined to be wastes, they generally are taken by health and safety
personnel to a central location, where they are stored and prepared for
disposal.
The levels of effort at colleges and universities for the storage and
disposal of wastes vary. A large number of schools continue to dispose of
chemical wastes via sewers and dumpsters. At Northeastern University, very
small rooms (12 by 18 feet) are used for storage, because there is a high
turnover of wastes from storage to disposal (Larson 1986). Southern Illinois
University at Carbondale uses a converted mobile home, as well as the
Pollution Control Laboratory, to store wastes. Volatile organics are stored
in the Pollution Control Laboratory, because the university either treats
these wastes or stores them under fume hoods. In the trailer, potentially
reactive wastes are stored in separate rooms to minimize potential hazards
(Meister 1981). The level of awareness is increasing, and cooperative
programs are being instituted to handle the small quantities of materials
generated by small colleges and universities. The Commonwealth of
Massachusetts, for example, has organized a "milk run" to consolidate wastes
from colleges and universities. Minnesota operates a similar program through
the University of Minnesota (Sanders 1986). Stanford University has built a
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$7 million installation for the storage, treatment, and disposal of wastes.
The facility has separate areas for handling infectious biological wastes,
chemical wastes, and low-level radioactive wastes. A high temperature
incinerator is operated at the facility. The University of Wisconsin and the
University of Arizona also have installed incinerators (Sanders 1986) .
Some disposal options are conducted in the laboratory. One option is the
neutralization of acids and bases, followed by disposal through the sewer.
Other destruction techniques are available if the researcher is willing to
investigate the possibilities. The advantage of in-house treatment and
disposal is that it reduces the space needed for storage and decreases
disposal costs (Ashbrook and Reinhardt 1985, Sanders 1986). Federal rules
allow generators to conduct treatment in tanks or closed containers without a
permit, under 40 CFR 262.34, but only if the tanks do not also meet the
definition of a hazardous waste treatment unit that is regulated in.another
Subpart. States may have more stringent requirements. Discharges to sewers
are generally regulated at the local level by restrictions on publicly owned
treatment works.
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CHAPTER 4
PROBLEMS ASSOCIATED WITH MANAGEMENT
OF HAZARDOUS WASTES FROM EDUCATIONAL INSTITUTIONS
This chapter identifies the problems encountered in managing hazardous
waste from educational institutions (Section 4.1) and discusses the
feasibility and availability of methods to manage such waste (Section 4.2).
4.1 PROBLEMS RELATED TO HAZARDOUS WASTE HANDLING
Educational institutions, like other entities that generate and manage
hazardous wastes, are faced with a range of problems. The following features
create hazardous waste management problems unique to schools:
• Most schools do not generate large quantities of hazardous waste, and
can be classified as conditionally exempt small quantity generators
(generators of less than 100 kilograms (kg) of hazardous waste per
month).
• Educational institutions have large numbers of independent hazardous
waste generation points that produce variable waste streams.
• Educational institutions are subject to budgetary and management
constraints that can limit the effectiveness of a waste handling
system, which may be reflected in inadequate funds for waste management
programs and staff.
• Although schools may use existing health and safety programs to
disseminate information on proper hazardous waste handling, many
schools do not have such programs.
• Faculty and staff at educational institutions have not been aware of
the regulations that may apply to them, or they may have chosen to
ignore the regulations, believing they do not have to comply.
• The transient nature of student populations makes it difficult to
educate students and to identify waste streams.
• Educational institutions have had difficulties in obtaining a RCRA
Part B permit.
Despite the higher level of awareness at the larger schools, the
possibility exists that schools will not properly classify, inventory, and
manage all waste streams, most often in one of the following ways (Tufts
University 1987):
• Failure to identify minor waste streams (for example, from
maintenance programs or shops)
• Noncompliance with regulations concerning transportation and the
need for multiple identification numbers where public highways
separate campuses or laboratories on a campus
• Storage of wastes that transporters will not accept
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The identification of wastes may require chemical analysis of some very
small quantities of waste if labels are missing. The variety of wastes
requires laboratories at schools to do an exceptional amount of paperwork to
keep track of wastes they ship to off-site disposal facilities (Sanders
1986). The wide variety of wastes may make regulatory compliance difficult,
because EPA requires that all wastes buried in landfills be identified by
chemical name. Educational institutions have encountered some difficulties in
complying with hazardous waste regulations, because of the complexity of the
rules. Some of these difficulties are alleviated by the small quantity
generator regulations 40 CFR 261.5.
The waste problem from the arts at colleges and universities varies from
that at secondary schools because of department sizes and operating budgets
(McCann 1987) . For example, in secondary schools, ceramic glazes are
purchased premixed, whereas at larger schools they may be purchased as powders
and mixed when needed. These powders are likely to introduce a short-term
inhalation hazard during mixing and a long-term storage problem. Silver is a
component of photographic fixer and is the principal waste generated by
black-and-white photography. Color processing is more complex and involves
the use of a variety of chemicals, some of which are potentially hazardous.
There is a lack of knowledge, particularly on the part of nonscience faculty,
of what constitutes hazardous waste and which activities generate hazardous
waste. Nonscience departments are beginning to recognize safety and health as
issues. In the arts, however, there is a reluctance to substitute a
nonhazardous material unless it can be demonstrated that it will produce the
desired aesthetic effect (McCann 1979).
4.1.1 Wasta Identification
Under the Resource Conservation and Recovery Act (RCRA), EPA regulations
sometimes require detailed knowledge of constituents and properties of waste
streams so they can be managed properly. This can be difficult because the
large number of sources of waste generation results in a variable
multicomponent waste stream. A detailed analysis of each waste container can
become very costly, with analysis costs sometimes exceeding disposal costs
(Ashbrook and Reinhardt 1985). Also, such recordkeeping requires a great deal
of time and paperwork for both the school and the waste handler, due to the
highly variable waste stream. This can make waste handling companies
reluctant to handle wastes generated by educational institutions.
The above discussion assumes that the laboratory worker or other
responsible staff member knows that the material generated is a hazardous
waste. In the absence of this knowledge, it is imperative that all materials
be labeled whether or not they are hazardous. As a result of the high
turnover rate in the student population, students may leave without properly
disposing of or labeling their unused or synthesized materials. If staff and
students are not diligent about maintaining records on which chemicals are
placed in waste containers, the hazardous waste manager becomes responsible
for conducting analysis as necessary and labeling the waste containers
properly.
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4.1.2 Handling and Collection
Ideally, proper handling of chemicals begins with understanding the
potential hazards related to their use. Each laboratory coordinator or the
health and safety officer should be responsible for disseminating information
on chemicals being used in the laboratory. The dissemination of information
can involve discussions on reactivity and possible health effects. In theory,
this type of activity appears to be relatively straightforward; in practice,
this may not be the case. Smaller schools (high schools and small colleges
and universities) generally do not have the staff to handle hazardous waste
management and to communicate chemical hazard information. Apparently, these
schools give waste handling a low priority. At some schools, the health and
safety officer is a member of the campus security force and may have little
training in waste management (Sanders 1986). Another problem related to waste
handling is the attitude of professors and research groups towards waste
handling. Some research groups consider themselves autonomous and operate
with little outside supervision; they may not adhere to instructions from the
health and safety officer because the group members believe either that it is
not their responsibility to deal with the waste or that they know more about
safety issues than the safety officer. Other researchers believe health and
safety procedures interfere with their academic freedom (Sanders 1986) .
If schools do not have active hazardous waste programs, wastes may
accumulate in laboratories, creating potential hazards and increasing the
likelihood that schools will have to dispose of large quantities of
materials. Wastes may not be packaged properly when they are transported for
disposal. These problems may arise from insufficient resources available for
hazardous waste management programs. School administrators and others who may
deal with waste management are not always aware of the regulations and
hazards. The basic problem of waste handling and collection is one of
information dissemination (Tufts University 1987, Sanders 1986) . If school
officials are not aware of regulations to which their institutions are
subject, they cannot respond adequately to waste management issues. However,
this does not relieve them of the obligation to comply with the hazardous
waste management regulations.
4.1.3 Storage and Packaging
The issue of storage of hazardous materials at educational institutions
can be divided into two categories: storage of chemicals for use in
laboratories or classrooms and storage of materials that are considered
wastes. Generally, chemicals are stored on shelves in laboratories and
classrooms and in closets and stockrooms. In some secondary schools and in
some colleges and universities, materials are shelved alphabetically, possibly
placing incompatible materials close together and creating a potentially
reactive situation (New York State Environmental Facilities Corporation
1985) . Schools have also accumulated wastes in fume hoods, storage cabinets,
and other places in or near laboratories, art studios, and maintenance shops,
subjecting laboratory workers to accidental exposure to hazardous wastes.
Some professors and teachers may store sizable amounts of chemicals on
laboratory shelves for 10 to 20 years, sometimes long after they have ceased
to be of use; some of these chemicals may have dangerously deteriorated
(Sanders 1986).
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Once materials are determined to be of no use to a particular laboratory,
they can be either stored before disposal or recycled and used by other
laboratories or departments, if they are still usable. If the materials are
to be discarded, then they are considered RCRA wastes and are subject to the
hazardous waste regulations. Thus, they need to be packaged for disposal,
accumulated, and stored according to these regulations. If the school has
developed a recycling program, then the materials must be stored in such a way
that they can be retrieved as needed. This approach requires the commitment
of space to the waste management program and to safely store materials, to
minimize reactions between chemicals stored on the shelves. Additionally,
this may require an initial investment to modify existing space so that the
area is well ventilated and well suited for segregating wastes.
Wastes should be stored in 55-gallon drums, tanks, or other suitable
containers (1-quart maximums are allowed for acute hazardous wastes) (see 40
CFR 262.34). Small containers of laboratory waste often are placed for
transport in a lab pack. A similar pack with a fiber drum has been used when
the material is intended for incineration. Once wastes are packed, if they
are not immediately transported off-site, they must be stored in an area where
they will be secure until off-site disposal. The size and sophistication
necessary for a storage area depend on the length of time the materials are
stored before disposal and on the quantities stored by the school (Sanders
1986) .
4.1.4 Transportation
The transportation of hazardous wastes occurs within the educational
institution or off the school property, to an approved treatment, storage, or
disposal facility. The Tufts University researchers (1987) found that in a
number of schools, untrained individuals transport wastes from the points of
generation to the storage locations. The person in charge of waste management
activities needs to be aware of the potential hazards of both on- and off-site
transport. If the wastes are moved from a laboratory to a storage facility
along a street to which the public has free access, the waste is subject to
the EPA manifest requirements and the DOT regulations, which require that the
generator and the transporter have the appropriate approvals and that the
materials be properly packaged and manifested (National Research Council
1983). It is not known whether schools follow the necessary procedures when
moving materials through campuses along public streets (Tufts University
1987) .
4.1.5 Treatment
Treatment can render a hazardous material less hazardous. A number of
laboratory methods have been used, including neutralization and distillation.
Normally, treatment devices are subject to hazardous waste tank rules.
However, elementary neutralization and recycling activities (for example,
recovery of solvents) are exempt from regulation (see 40 CFR 261.6). In
addition, on-site treatment of hazardous wastes in accumulation tanks is
exempt from the permitting requirements, although it must be in accordance
with other requirements. The treatment of waste can still result, in some
residual waste requiring disposal or additional treatment off-site. This
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residual waste may, in fact, still be considered hazardous and be subject to
the hazardous waste regulations. If the school does not use exempt treatment
methods, then it may find that the procedure to obtain the permit is costly,
and the school may decide to manage wastes in a different manner (Sanders
1986) .
Two treatment methods not fully in compliance with RCRA regulations were
used in the case study schools, described by the Tufts University (1987)
researchers: evaporation and neutralization. They observed limited treatment
during and after laboratory experiments or after accumulation. Evaporation
was commonly used in instructional laboratories to remove water or solvents
from chemical samples. The chemicals were generally exposed to air under fume
hoods or in large open-air drying pahs or evaporated in a drying oven.
Records were not available to document the Quantities or types of chemicals
treated in this manner. Unlabeled samples in fume hoods were observed during
site visits, suggesting that compatibility of stored chemicals may not have
been assured. The case study schools also neutralized wastes by using on-site
laboratory procedures, either incorporated into the experiments themselves or
performed by a laboratory assistant or instructor after the hazardous wastes
had been collected from individual students. None of the schools that were
small quantity generators operated "elementary neutralization units" as
defined in 40 CFR 270.2. The extent to which these techniques were used and
the resulting reductions in waste quantities were not documented in the Tufts
University report (1987) .
4.1.6 Incineration
Incineration is an effective method for the destruction of organic
compounds and biological materials. The major disadvantage of incineration is
that, at least for hazardous waste, it is a relatively expensive, complex
technology that has a high energy requirement. Incineration produces an ash
that may be a hazardous waste, and the method has potential for air
pollution. The operation of an incinerator at an educational institution
requires a large commitment of funds for construction and for safe and
efficient operation, which includes ensuring the availability of trained
personnel. The major problem associated with incineration is that most
schools, especially the smaller ones, cannot afford to employ it. The
technology is potentially viable only for the large institutions because of
the high costs involved in construction and maintenance, the complex and
expensive permitting, and the need for a highly skilled staff to operate the
units (Tufts University 1987).
Since the-chemical composition of the waste stream constantly changes, it
is difficult for schools to characterize the nature of the incinerator
emissions. This situation requires complex permitting and operating
procedures. A benefit of incineration, however, is to reduce the risk and
liability associated with hazardous waste management, because incineration
reduces the volume and degree of hazard of the waste.
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4.1.7 Disposal
Schools face several obstacles to ensuring disposal of hazardous wastes in
an appropriate manner:
• The need for funds to pay for an outside handler
• The need for funds for an on-site coordinator to manage the waste
management program
• A lack of clear understanding of the regulations and legal
requirements
• A lack of motivation to adhere to the law because of the perception
in the regulated community that regulatory enforcement agencies
generally do not place a high priority on compliance by schools
(Sanders 1986)
• The frequent complaint by school environmental safety officers that
many academic research groups consider themselves to be autonomous and
do not follow officers' instructions
• The large variety and small quantities of wastes produced by schools
• The continually changing nature of the waste stream, meaning that its
composition is not always known
• The prohibition from landfills of wastes containing explosive
chemicals and liquid wastes that may be generated in school
laboratories and the refusal of some waste handling firms to handle
them
A major problem that schools face is the high cost charged by some waste
handlers for small amounts of wastes. The variable waste stream and small
quantities can make reporting requirements extremely cumbersome. Washington
State University was informed by its waste handler that it would no longer
accept the university's wastes because they represented only 1 percent of the
handler's total waste, but accounted for 99 percent of the handler's problems
(Sanders 1986). A number of universities have reported that their costs have
risen by as much as 118 percent in the past 5 years (Sanders 1986, Ashbrook
and Reinhardt 1985) . The cost issue is significant for all schools, but it is
especially acute for secondary schools and small colleges.
Disposal methods include discharge to a sanitary sewer, dumping in a
dumpster, or burial in a landfill. All of these methods are used to some
extent by educational institutions (Sanders 1986) . Depending on the
generator's category (for example, less than 100 kg per month), these
activities may violate Federal or State rules. The effectiveness of a waste
management program in monitoring disposal safety varies from school to school,
and sometimes within departments. Schools that place a low priority on waste
disposal tend to restrict funding for such programs. Awareness of the
regulations and of safe disposal practices is increasing, however. With the
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exception of using drains, most educational institutions do not actually
perform the disposal task themselves. Most schools depend on off-site
landfills or discharge to the drain and ultimately to the water treatment
plant as their primary disposal method. As disposal costs increase and
regulations limit the use of landfills, educational institutions must search
out alternative solutions to their waste management problems.
Thus, educational institutions that have disposed of wastes that contain
hazardous substances may be legally liable for cleanup if those hazardous
substances are mismanaged. In fact, there are some hazardous waste sites at
universities included on the National Priorities List for Superfund cleanup.
For example, the University of Minnesota burned chemical laboratory wastes in
an outdoor pit between 1960 and 1974, after which the pit was covered over.
In 1984 the Minnesota Pollution Control Agency found that ground water as far
as 2 miles to the northeast of the disposal site was contaminated with low
levels of chloroform. The university has supplied families in the area with
bottled water and has suggested several ways of solving the water
contamination problem {Sanders 1986). In another instance, North Carolina
State University buried containers of waste chemicals at an off-campus site
between 1969 and 1980. Wells near the disposal site have shown relatively
high concentrations of such compounds as chloroform, bromoform,
1,1,1-trichloromethane, and methylene chloride in the water. If a generator
sends hazardous waste to a site that is later placed on the National
Priorities List, that generator may be held liable for cleanup costs.
4.1.8 Racordkeeping
EPA's hazardous waste regulations require that all wastes buried in
landfills be identified by waste code. Wastes of unknown composition may need
chemical analyses (which can be expensive and time-consuming). If a
university generates over 10,000 containers of waste in a year and if each
container holds a different mixture of chemicals, the university may have to
make over 10,000 entries on the waste record list.
4.2 FEASIBILITY AND AVAILABILITY OF HAZARDOUS WASTE MANAGEMENT METHODS
This section focuses on waste management methods that schools may use to
treat, store, or dispose of their hazardous wastes, especially "the
feasibility and availability of environmentally sound methods for the
treatment, storage or disposal of hazardous wastes from educational
institutions, taking into account the types and quantities of such wastes
which are generated by these institutions, and the nonprofit nature of these
institutions" (HSWA, Section 221(f)(!)). This section discusses the
feasibility and availability of the following on-site and off-site hazardous
waste management methods: accumulation and storage; transportation; chemical
and physical treatment, including recycling and recovery; incineration; and
disposal.
The technical feasibility of a given treatment, storage, or disposal
method refers to its applicability to one or more waste streams generated by
schools. For example, both on-site incineration and off-site incineration are
technically feasible for solvent wastes with high thermal content. Economic
feasibility refers to the economic viability of applying a given treatment,
storage, or disposal method to school wastes, given the quantities of waste
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generated and the nonprofit nature of a school. For example, a school
generating relatively small amounts of solvent wastes will not find it
economically feasible to build and operate an on-site incinerator. Off-site
incineration may be economically feasible for some schools. In several
regions, there is only a 20- to 30-percent cost differential between
incineration and landfilling. Processing facilities that break down lab packs
and combine treatment, incineration, and landfilling methods to provide the
best disposal method for each chemical waste are frequently competitive with
landfills (American Chemical Society 1987).
All of the treatment, storage, and disposal methods discussed in this
section are generally available in the hazardous waste management industry. A
school may determine availability of a method from known past use by schools
or, in the case of an off-site method, from the existence of commercial
facilities willing to provide the specific service. For example, on-site
incinerators are considered available if there are instances where schools of
similar size and nature have built and currently operate their own on-site
incinerators to dispose of their waste. However, the availability to schools
of off-site incinerators depends on the willingness of such facilities to
accept wastes.
The feasibility of treatment, storage, or disposal methods and their
availability to a school are largely determined by the location of the
treatment, storage, or disposal facility relative to the point of waste
generation; the types and quantities of waste generated by schools; and the
relative costs of treatment, storage, or disposal methods. A school
generating relatively small amounts of hazardous waste (100 to 1,000 kg per
month) may only find it economically feasible to use a commercial hauler to
ship the waste off-site after accumulating it on-site. However, extended
on-site accumulation may require the school to apply for a storage permit.
Some schools may find it too costly to apply for permits to store wastes and
to satisfy the storage requirements.
The nonprofit nature of most schools in the United States may contribute
to difficulties in accumulating the necessary funds to purchase expensive
equipment, such as a hazardous waste incinerator, thus decreasing the
likelihood of on-site treatment, storage, and disposal methods. As such, they
cannot legally make or distribute profits. Typically, schools do not raise
money in the traditional financial markets (bonds and stocks), but rather
through other channels (for example, public funding, tuitions, endowments).
Schools that are publicly funded or that receive small endowments may be
subject to tight budgetary constraints that would make it difficult for them
to undertake relatively capital-intensive waste management projects.
4.2.1 Accumulation and Storage
On-site accumulation and storage of hazardous waste are necessary steps in
waste management when wastes cannot be treated or disposed of immediately.
Accumulation and storage are followed by treatment and disposal, either
on-site or off-site. Accumulation is allowed without a permit, provided that
certain conditions are met (see Section 2.2.1).
Some schools may want to store waste beyond the allotted time to
accumulate enough hazardous waste for a more economical shipment off-site for
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treatment or disposal, and they should apply for a Part B hazardous waste
permit for storage. A Part B permit allows a school to store wastes longer
than the allowed 90, 180, or 270 days and make fewer shipments. For example,
New Mexico State University has applied for a Part B permit to store wastes
for longer than 90 days and effectively reduce shipping costs (American
Chemical Society 1984) .
In contrast, a school generating relatively large quantities of hazardous
waste (for example, more than 1,000 kg per month) may find it more economical
to do without a storage permit and to ship the waste every 90 days or less.
Although shipping costs would increase because of more frequent shipping, the
generator could save time and money by being subject to the less stringent
storage requirements of 40 CFR Part 262, compared with the Part B hazardous
waste permit requirements. In addition, storing waste for shorter periods of
time would decrease the opportunity for containers to leak, decreasing the
potential for incurring costs to clean up releases.
4.2.2 Transportation
4.2.2.1 On-Site
On-site transportation at educational institutions is the movement of
hazardous waste from one campus building to another building, where either
both buildings are on the same contiguous piece of property or both buildings
are separated by a public highway and the waste is shipped directly across the
road. The main reason for transporting waste on-site is generally to
accumulate and store it in one or more centralized locations. Neither EPA nor
DOT regulates on-site transportation of hazardous waste by generators or by
owners or operators of permitted hazardous waste management facilities (40 CFR
260.10).
4.2.2.2 Off-Site
Off-site transportation of hazardous waste is its movement from the point
of generation to an off-site location for treatment, storage, or disposal. In
all of the Tufts University case studies (1987), off-site transportation was
by licensed transporters. In general, schools do not transport their
hazardous waste off-site themselves, and therefore they are not required to
obtain any license or permit to transport the waste. Schools must, however,
comply with generator regulations under 40 CFR Part 262.
The Tufts University researchers found that off-site transportation by a
licensed transporter was either through a contract (continuing or one-time
arrangement) between the school and the transporter or by some form of
centrally initiated and managed episodic cleanout operation ("amnesty days,"
"operation clean sweep," or some other program similar to household hazardous
waste cleanouts). Frequently, transporters used by high schools were selected
by State agencies. A common practice in shipping waste off-site is to use lab
packs to contain the waste for easy handling during transport. Off-site
transportation can be costly to schools. To lower costs, a school may store
its waste on-site for a time or arrange with other schools to have their
wastes transported simultaneously.
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4.2.3 Treatment
*
Chemical and physical treatment methods are means by which hazardous
wastes are rendered less hazardous before transport and disposal or more
amenable to recycling and recovery.
On-site treatment methods applicable to schools include elementary
neutralization and distillation. Schools should check with the appropriate
regulatory agencies to inquire whether such activities are allowed. Normally,
elementary neutralization and treatment that is recycling, such as
distillation to recover solvents, are exempt from regulation. Also, on-site
treatment in accumulation tanks is exempt from permitting, unless the
treatment method is specifically regulated in a subpart of 40 CFR Part 264 or
265 (for example, thermal treatment). For wastes that are hazardous only
because of their corrosivity, neutralization is a simple means of rendering
them nonhazardous. Such wastes usually can be neutralized at the laboratory
bench and then flushed down the drain. The procedure is simple and
inexpensive, and it does not require a permit. As long as care is taken to
perform the initial mixing slowly, neutralization is not a hazardous
procedure. For laboratories that use solvents of known composition routinely,
the costs of recovering the solvents by distillation may be less than the
costs of purchasing new solvents and disposing of the used solvents. The cost
advantage of solvent recovery, however, must be weighed against certain
drawbacks, such as quality of the solvent recovered (for example, if top
quality is required) and availability of the solvent when needed (for example,
if the solvent is required for scheduled laboratory experiments) .
Several treatment technologies for hazardous wastes are available, or
potentially available, in mobile treatment units. These include incineration,
infrared destruction, and several chemical reaction technologies. EPA has
recently reported on these technologies, their permitting, and their use (EPA
1986c). As applications, costs, and permitting issues are developed and
resolved for mobile treatment units, schools should be aware of and consider
their potential use (Tufts University 1987).
All schools in the Tufts University study (1987) contracted for off-site
treatment of at least part of their hazardous wastes. Both high school and
college shops used commercial services that recycled degreasing and cleaning
liquids in tanks. This practice substantially reduced the amounts of spent
solvents that previously had to be disposed (Tufts University 1987). Several
major universities had formal or informal policies encouraging reliance on
off-site facilities. The motivation cited by university staff for selection
of off-site facilities was the avoidance of problems. In such cases, cost
considerations were distinctly secondary to concerns about the adequacy and
safety of on-site practices and liability exposure.
Although there are many treatment facilities and recyclers nationwide,
off-site treatment can be expensive. Because the volume of hazardous wastes
from schools is relatively small, companies in the hazardous waste business do
not find it profitable to serve educational institutions. Consequently, these
companies tend to charge relatively high prices to accept wastes from schools
(many companies have minimum charges). Also, the diversity of waste
composition from educational institutions presents a major problem for waste
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management contractors, which sometimes refuse to serve educational
institutions precisely for this reason (Ashbrook and Reinhardt 1985).
4.2.4 Incineration
Incineration, or controlled combustion at high temperature, is an
effective destruction method for virtually all organic compounds as well as
for some wastes that contain inorganic substances. Incineration significantly
alters the composition of wastes, usually generates ash that must be disposed,
and has air pollution potential. It has been designated by EPA as the best
demonstrated available technology to manage many wastes (for example, 40 CFR
268.42(a); 51 FR 40616 (November 7, 1986); 52 FR 25763, 25770, and
25772 (July 8, 1987); and 53 FR 31153, 31154, 31155, 31157, 31160, and
31169 (August 17, 1988)). The specific incinerator requirements vary,
depending on the specific situation, and are an integral part of the procedure
for granting permits (National Research Council 1983). Incinerators used for
destruction of hazardous waste must have EPA permits. The granting of an EPA
permit is contingent on a demonstration by trial burn tests that the
incinerator meets EPA performance standards.
The Tufts University researchers found that the incinerator at Stanford
University would handle up to 1,000 pounds of solid and liquid wastes per hour
at a construction cost of about $850,000, including the cost of a wet scrubber
and instrumentation. Permitting is a complex and expensive process, and
skilled staff are required to operate an incinerator. Thus, on-site
incineration may be economically feasible for only the largest institutions.
Despite the difficulties, a few large schools, such as the University of
Wisconsin and the University of Arizona, already have installed waste
incinerators on or near their campuses. The University of California is
considering the possibility of building several regional incinerators to
destroy the hazardous wastes from its numerous campuses. Several large
schools have expressed strong opposition to on-site treatment because of
on-site risks and problems and have indicated a preference for commercially
provided (off-site) treatment and disposal services.
Off-site incineration is an effective treatment method for almost all
organic compounds. Some waste disposal services will pack the laboratory
waste and arrange for its transportation and, as appropriate, for incineration
or disposal. In some cases, commercial incinerator operators may be willing
to accept school laboratory wastes. However, many commercial incinerator
operators do not accept unsegregated waste or waste packed in fiber drums,
such as lab packs (National Research Council 1983) . Incineration costs tend
to be higher than disposal costs. However, as new regulations concerning
disposal in landfills take effect, land disposal costs will increase and make
incineration more attractive. A number of schools have selected off-site
incineration as the method to manage their waste. As with selection of
off-site treatment, this was motivated more by concerns about adequacy and
safety of on-site practices and liability exposure than by cost considerations
(Tufts University 1987). To reduce the potential for future liabilities
associated with environmental releases, schools must ensure that their wastes
are being handled by permitted facilities with good operating procedures and
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compliance records. Schools should contact State and local agencies to check
on the permit status and compliance records of commercial incineration
facilities.
4.2.5 Disposal
Current on-site disposal of hazardous waste at educational institutions
includes disposal in an on-site landfill or direct discharge (of liquids and
sludges) into sanitary sewers through laboratory sinks and similar connections
("drain disposal"). To construct and operate an on-site landfill, a school
must obtain a Part B hazardous waste permit. The landfill must conform to EPA
regulations, and can accept only certain wastes because EPA has established a
ban on liquids in landfills and other restrictions on the land disposal of
certain hazardous wastes. Drain disposal must satisfy requirements set by
State and local agencies for discharge into publicly owned treatment works.
Although the the technology for constructing and operating landfills that
meet regulatory design requirements is available, schools generally would not
be attracted to this form of on-site disposal for several reasons, including
the following:
• Recent and ongoing regulatory developments aimed at limiting, to the
maximum extent possible, the reliance on land disposal of hazardous
waste
• Relatively high costs of permitting, construction, operation, closure
and post-closure care, and financial assurance requirements
• Mounting public opposition to landfill siting due to the potential
for future releases from the disposal site (for schools, public
opposition is likely to be compounded by public perception that schools
should not be in the business of disposing of hazardous waste)
Drain disposal is technically feasible, provided that the waste satisfies
certain requirements for physical form (for example, liquids and certain
sludges). If a school expects to discharge to publicly owned treatment works
certain wastes in amounts that exceed threshold values, it may be required to
apply for a discharge permit or to pay certain fees, which can be costly.
Indications of widespread drain disposal were observed in the Tufts University
study (1987). Again, drain disposal is neither illegal nor improper if it is
performed in conformance with State regulations and the receiving wastewater
system's requirements. However, there was no evidence that the smaller case
study schools were aware of these requirements or had established that their
practices satisfied these requirements. From the general absence of central
oversight and control in the smaller case study schools, the Tufts University
researchers concluded that the existence or extent of the practice was unknown
to school administrators (Tufts University 1987).
Off-site disposal of hazardous waste includes disposal in an off-site
landfill, a surface impoundment, a land treatment unit, or a waste pile. The
hazardous waste regulations currently ban the disposal of bulk liquids in
landfills unless they have been stabilized. The regulations restrict the
disposal of containerized liquid hazardous wastes in landfills, and also
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iinpose strict restrictions (for example, treatment standards) on the land
disposal of many solvents and other hazardous wastes. Schools must be aware
of and satisfy these requirements when they ship waste to off-site facilities
for land disposal.
In the future, land disposal of hazardous waste will be further
restricted, and schools may no longer be able to ship any of their waste
directly for off-site land disposal. For example, by the end of 1988, if a
school generates a listed solvent waste prohibited from land disposal, it must
ensure that the waste meets certain standards before land disposal of the
treatment residuals. Land disposal of the solvents themselves is restricted
under the land disposal restrictions program. In general, simply packaging in
lab packs for direct off-site land disposal is no longer feasible unless the
waste satisfies the current criteria for land disposal. Lab packs may be land
disposed if restricted wastes are removed before land disposal, the wastes
meet the treatment standard, or the no migration petition under §268.6 has
been successful (51 FR 40585, November 7, 1986). However, given the ban of
solvents and other wastes from landfills, generators of greater than 100 kg of
hazardous waste per month will have to investigate recycling or incineration
as management options for all of these wastes.
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CHAPTER 5
POSSIBLE HAYS TO IMPROVE MANAGEMENT OF HAZARDOUS HASTES
FROM EDUCATIONAL INSTITUTIONS
As stated in Chapter 1, the recommendations made in this chapter are
factual in nature. EPA was not directed by the law to develop recommendations
for regulatory or statutory changes. Therefore, this chapter does not
recommend any regulatory or statutory changes. This chapter discusses
potential solutions to hazardous waste management problems: how individual
schools can better manage hazardous waste (Section 5.1), programs that can be
developed among schools (Section 5.2), the type of guidance that EPA, the
States, and others may provide (Section 5.3), regulatory changes that EPA has
made or proposed to make (Section 5.4), and regulatory and statutory changes
recommended by commenters (Section 5.5). Section 5.6 presents conclusions.
5.1 SOLUTIONS WITHIN SCHOOLS
It appears that the key to managing hazardous wastes in secondary schools,
colleges, and universities is to increase school administrators' and
faculties' awareness of safety procedures and proper disposal methods for
chemical wastes. Ashbrook and Reinhardt (1985) state that no matter what
quantity of hazardous waste is generated, it is the responsibility of schools
to train their students in proper management techniques when dealing with
chemicals. Health and safety programs could publicize the hazards associated
with chemicals and aid in waste reduction and disposal programs.
Teachers, professors, and instructional and other personnel at all levels
of education who handle hazardous waste should be instructed in the proper
methods of hazardous waste handling and disposal, recordkeeping, and hazardous
waste reduction. This instruction should occur both as a part of original
training to qualify to teach or to perform a job and also in any continuing
education courses. For example, the Council of State Science Supervisors
(1984) encourages teachers at secondary schools not to use potentially
carcinogenic compounds. Also, the Michigan State Department of Natural
Resources is implementing a program designed to inform individuals working at
schools with classes from kindergarten through grade 12 about the hazardous
waste regulations (Peck 1987) . Its program is designed to ensure that schools
follow proper waste disposal practices and, if they do not, to provide
training. Schools could use their waste management program to teach students
proper waste handling.
To manage hazardous waste successfully, a school must recognize that it
uses or generates materials that can be classified as hazardous. A school
must be committed to allocating sufficient funds and staff to deal with its
hazardous waste management problems. This includes establishing and
maintaining hazardous waste management programs. A waste management program
should educate people about what constitutes a hazardous waste and how to
dispose of it properly. Similarly, information on handling, storage, and
packaging requirements should be available through this program. The level'of
commitment varies among schools, depending on size and type. Clearly, schools
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with larger research programs generate more hazardous wastes and need more
extensive programs. To make the most of limited funds, a school may find it
more cost-effective to educate and use its maintenance workers under existing
organizational structures rather than to introduce a new organizational
structure solely to manage hazardous waste. As procurement and liability
costs increase, schools affected have seen the need to staff and fund waste
management programs adequately. These programs can be district-wide in the
case of secondary schools, can be made up of a consortium of schools that pool
information and resources for disposal, or can be run by a large university
that acts as a treatment, storage, or disposal facility for smaller schools in
the area.
5.1.1 Waste Identification
The central issues in hazardous waste identification are the following:
When does a material become a waste? What makes a waste a hazardous
waste? School personnel need to segregate wastes, such as solvents, and
identify and record on a list the wastes placed in the waste containers. This
would then allow the health and safety coordinator to look at this list and
determine how the wastes can be disposed (Ashbrook 1986). School laboratories
should require that wastes be labeled. This is true for both teaching and
research situations. If unlabeled wastes accumulate, a cooperative program
within a school could be instituted to have students analyze the wastes as
part of a class project. This could limit the equipment that the hazardous
waste management team would need, as well as teach students to identify wastes
that they might not handle routinely. The type of laboratory analysis
performed at a school may not completely identify whether a waste is
hazardous, but might at least indicate when further analysis will be
necessary.
5.1.2 Handling and Collection
If a school does not have a centralized waste management program, as may
be the case in many smaller schools, wastes are likely to accumulate in
individual laboratories. This can result in the need to have a regular,
periodic 1-day cleanout of the school. In this instance, a waste handling
firm can be contracted to package and dispose of the wastes, thereby removing
the handling and collection problem from the school. Proper labeling of
chemicals is important to avoid large analytical costs.
Larger schools may need a more defined program. This can involve
providing a protocol for placing wastes in certain types of containers and
arranging for a weekly or monthly collection of these wastes. This type of
program requires cooperation between those generating the wastes and those
collecting them to ensure that wastes are placed in containers with compatible
wastes. If waste collectors are informed of the type and quantity of waste,
they can arrive with a container of the proper size with packing material to
prevent breakage. Selection of packing material can be based on the type of
wastes.
5.1.3 Storage and Packaging
Storage of materials involves the storage of newly purchased materials and
the storage of waste or materials that are no longer usable. An educational
institution can collect the waste generated from several departments and
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accumulate it up to the time limits allowed under the hazardous waste
regulations to maximize the amounts of waste disposed at one time. This
minimizes the number of collections, thus keeping disposal costs as low as
possible. However, a sch'ool must be aware of the risks of storage when
considering such a program.
In secondary schools and small colleges and universities, it may not be
possible to have this type of system. At larger schools, storage areas range
from a small room (Larson 1986) to a converted mobile home (Meister 1981) to
an entire building (Sanders 1986) . Proper recordkeeping also is necessary for
such a program. Schools could improve their tracking of hazardous waste
generation by implementing an internal manifesting system for on-site
transport. This approach has been successful in facilitating waste
classification and determining waste generation rates at several EPA
facilities. Schools can voluntarily (but EPA does not require them to)
implement an internal manifesting system. However, this does not relieve them
of the requirement to prepare the current manifest for off-site transport.
The packaging required for storage may be tanks, 55-gallon drums, or other
containers that are compatible with the waste to be stored. The method for
disposal will also influence the type of packaging. For example, a fiber drum
can be used to store and package wastes destined for an incinerator. Lab
packs or small containers can be used for storage of small quantities of
wastes. If wastes are segregated by their properties, the storage area and
number of containers needed can be reduced (Ashbrook and Reinhardt 1985).
5.1.4 Transportation
Spill prevention and safety assurance require that trained personnel be
involved and that they use proper containers. Containers should be resistant
to accidental breakage or opening whether they are hand-carried, carted, or
moved by vehicle. Off-site transport of hazardous waste is regulated both by
EPA under 40 CFR Parts 262 and 263 and by DOT under 49 CFR Parts 171-179. If
the school is connected by public roadways, then the school must comply with
DOT regulations. A school may need to have several storage areas with
separate pickups for a transporter so that public roadways do not have to be
traveled to take wastes to storage. On-site transport is not regulated by
either EPA or DOT, but care should be taken to prevent spills and to keep
track of all wastes.
5.1.5 Treatment
Physical and chemical treatment can render wastes less hazardous, thereby
facilitating their recycling or disposal. These activities should be in
compliance with applicable Federal and State regulations. Methods commonly
used are neutralization and distillation. These treatment techniques are
effective and can be performed in schools; in some instances, they can be
incorporated into teaching laboratory experiments. Advantages to treatment
are low energy requirements, usually permanent effects, and reduction in the
volumes of most wastes; disadvantages are the limited usefulness of treatment
methods and the fact that each waste needs a specific treatment method.
Neutralization of some wastes can be performed before drain disposal. This
type of procedure can be performed as part of an experiment. Acids or bases
are generally treated in this manner.
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Distillation and recovery of chemicals (for example, solvents) from wastes
is another treatment option, but there is no clear consensus on the
practicality or advantages of having a distillation facility at a school. At
the Massachusetts Institute of Technology, for example, the administration
encouraged the practice, but faculty and research staff resisted it (Tufts
University 1987). It is considered an appropriate practice where the volume
of wastes available for such treatment warrants a central facility with one or
more batch stills and its own management. Still bottoms might constitute
hazardous wastes, but the volumes to be shipped off-site would be reduced.
Schools also can treat some laboratory wastes by biological methods
(National Research Council 1983). Biological treatment is especially useful
for phenols, alcohols, aldehydes, ketones, and wastes from life science
laboratories. Biological treatment can be performed on a small scale. Under
RCRA, such treatment is allowed without a permit, but only in tanks.
Discharges of wastewater from any treatment process to the Nation's surface
waters are subject to regulation under the National Pollutant Discharge
Elimination System (40 CFR Part 403) or, if discharged to the sewer, to local
requirements for publicly owned treatment works.
5.1.6 Incineration
Incineration is an effective destruction method. It can be used for
almost all combustible liquid, semisolid, and solid wastes. A number of
schools operate incinerators; some are dedicated to biological wastes, such as
animal carcasses, and others are used for chemical wastes (Sanders 1986).
This method, however, is only available on-site to schools that have a large
commitment of funds to construct and operate an incinerator safely, which puts
the method beyond the reach of most educational institutions. Hazardous waste
incinerators must be permitted under RCRA, an extremely lengthy process.
5.1.7 Disposal
Educational institutions can dispose of hazardous wastes on-site by direct
discharge into sanitary sewers through laboratory sinks (drain disposal) or
off-site in a landfill, surface impoundment, land treatment unit, or waste
pile. Disposal of hazardous wastes into a sewer system is subject to CWA
regulations (40 CFR Part 403) . Schools should check the restrictions for
their local publicly owned treatment works. RCRA regulates the storage and
disposal of hazardous wastes before drain disposal. Hazards that must be
guarded against when using drain disposal range from reactions in and
corrosion of the plumbing system to adverse effects on the receiving waters.
Chemicals can be treated adequately or diluted before introduction into the
sewer system. Clearly, care should be taken to prevent incompatible mixtures
from being formed; only water-soluble or water-miscible substances should be
disposed and highly toxic or combustible substances should not be disposed by
this method. Land disposal of hazardous waste is allowed only under a RCRA
permit; this will be impractical for the vast majority of schools.
5.1.8 Racordkeeping
The regulations require that each waste be tracked from the time it is
generated through storage, transport, and disposal. The recordkeeping
requirements increase disproportionately relative to waste volume because of
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the numbers of wastes that educational institutions generate. Under current
regulations, there is no simple way schools can adapt to this situation, but
individuals who generate wastes should be encouraged to provide the maximum
amount of information possible on identification of the wastes and volumes
produced.
5.1.9 Waste Reduction Strategies
Educational institutions have the greatest control over prevention and
reduction strategies in managing hazardous wastes. It is within the scope of
faculties' and administrators' activities to minimize the exposures of
students and workers to hazardous materials and to minimize the amounts of
hazardous waste generated. As secondary school administrators and teachers
become aware of the potential hazards experienced, a move is under way to
reduce the amount of hazardous waste produced by substituting materials or
canceling courses. For example, at one high school visited by Tufts
University researchers during their study (1987), they found that substitutes
for hazardous materials were used in chemistry classes. In the electronics
course, etching was no longer performed because of the hazards associated with
the use of ferric chloride and hydrochloric acid. Substitution of less
hazardous materials in classroom experiments and the reduction of the scale of
experiments are approaches that have been encouraged (Council of State Science
Supervisors 1984, Sanders 1986). Some cleaning agents can be replaced (for
example, detergents may sometimes be used instead of chromic acid or alcoholic
potassium solutions).
Possible means of reducing the amounts of -hazardous wastes generated by
laboratories include using interactive computer simulation models rather than
actual chemical reactions in instructional laboratories and substituting less
hazardous or nonhazardous chemicals. Educational institutions can reduce
waste generation by minimizing the quantities of chemicals that they purchase
and store and by recycling. The applicability of the following educational
suggestions will depend on the size of the institution. A centralized
purchasing department can be helpful in coordinating purchases of the same
chemical by several research or teaching groups. The purchasing department
could also arrange with some principal investigators to purchase only parts of
their requests if the quantities seem excessive, or it could arrange for only
partial shipment, with the remainder shipped as needed. Such measures would
reduce the quantities of chemicals needing storage at a school and might
result in fewer chemicals exceeding their useful lives. When disposal costs
are added to the purchase prices of chemicals, it may be more expensive to buy
large quantities. Schools must maintain inventories of chemicals and rotate
stock, using older chemicals before their shelf lives expire. These
inventories are invaluable in organizing chemical exchange and reuse programs
among different departments in institutions. An advantage of a centralized
waste-handling area is that materials no longer needed by one laboratory group
may be of use to another. This is termed "waste exchange," a form of
recycling. Recycling programs of this type are operated at a number of
schools, as was discussed in Section 3.4.3 of this report. Ashbrook and
Reinhardt (1985) have reported that these programs can save thousands of
dollars. The existence of a centralized waste-handling area means that the
school administrators have committed space in which to store the wastes.
Duplicate purchases of chemicals may be reduced by circulating inventory lists
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to different departments. Under EPA rules, unused commercial chemical
products recycled in this manner are not solid waste until intended to be
discarded.
Educational institutions can reduce the volume of solvents involved in
cleaning glassware by reusing solvent for the initial cleaning and using fresh
solvent only for final cleaning, thus decreasing the amount of clean solvent
required. In some cases, solvent wastes can be distilled and reused for
classroom experiments or as thinners and degreasers by the maintenance
department. Some metals can be recovered in the laboratory (for example,
mercury can be recovered by filtration in a fume hood, and silver can be
recovered from photographic solutions by electrolytic techniques). These
activities must be in compliance with applicable Federal and State
regulations, but EPA rules currently do not apply to recycling devices (only
to storage tanks or containers used prior to recycling).
A necessary element in a prevention program is to identify materials that
can become or are hazardous. If a chemical is known, the regulations will
indicate whether it is considered hazardous. Research laboratories often
synthesize new chemicals, and they must determine whether the chemicals are
hazardous and how best to handle them. The safety issue is not always
addressed in discussions of hazardous waste; attention to safety may increase
the level of awareness and could prevent or reduce waste generation. The
knowledge of how best to handle chemicals can help students, faculties, and
staffs to substitute less hazardous materials, scale down experiments, and
minimize spills and improper disposal.
Other school operations (for example, vocational shops and maintenance
operations) also can minimize their wastes by using similar techniques, such
as reusing solvent for the first round of cleaning of paintbrushes and spray
guns. Paint wastes from spray painting can be reduced by selecting the
correct air pressure and following certain recommended procedures. HSWA
mandated that the generation of waste be minimized. The easiest way to reduce
waste volume is to not generate it in the first place. Appendix C contains
more details on waste minimization techniques.
5.2 SOLUTIONS AMONG SCHOOLS
Problems can be reduced through cooperative programs among schools to
exchange information, reduce the amount of waste generated, and manage the
waste generated.
5.2.1. Information Exchange
Information exchange programs can help secondary schools and small
colleges and universities learn which wastes are hazardous and the methods
available to minimize the use of hazardous materials in the classroom. An
informational program can aid both in recognition of the problem and in
developing handling capabilities. Tufts University (1987) reported that some
larger universities have prepared comprehensive handbooks for their chemical
users and waste generators. These handbooks could be made available on
request to smaller schools, for a small fee. Yale University provides
consultations to schools setting up waste management programs (Tufts
University 1987) .
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5.2.2 Collective Waste Handling and Recycling Programs
Collective programs could include the handling, collection, treatment,
transport, incineration, or disposal of hazardous wastes. The viability of
such a program would depend on schools being in close proximity, such as
within a secondary school district or a county or region of a State. One
disadvantage of a cooperative program is that transportation regulations must
be considered more carefully. Also, if a central facility receives waste from
a generator that is not conditionally exempt, the central facility must have a
RCRA storage permit. (An exemption is made for transfer facilities where
waste is consolidated, and the waste is stored in containers approved by the
Department of Transportation for 10 days or less (see 40 CFR 263.12) .)
The State of Minnesota has developed the Minnesota Chemical Waste
Assistance Project, which serves 160 high schools and 20 colleges throughout
the State. The project has five regional centers to which participants
periodically bring their wastes, which then are shipped to the University of
Minnesota for handling. This program also has a component that allows schools
to obtain chemicals from schools that are seeking to get rid of them. This
program enables participants to dispose of wastes at a relatively small cost
and helps to reduce the quantities of materials that accumulate at individual
schools (Sanders 1986).
Contracting with a waste handler could also be administered
cooperatively. This could allow for schools to dispose of their wastes
collectively, reducing the costs, and it could be accomplished in either of
two ways:
• By storing materials first in a regional facility similar to that in
the Minnesota project and, when enough material has been accumulated,
having it removed by a waste handler or
• By contracting with a waste handler to package and remove wastes from
all the individual schools in a given area.
5.2.3 Incineration
Incinerators are too expensive for smaller schools to install and
maintain. It could be possible, however, for several schools within a small
geographic area to cooperate to install an incinerator for their joint use.
The University of California has been investigating the possibility of
installing several regional incinerators to destroy wastes generated at its
campuses (Sanders 1986). It should be noted, however, that incineration can
be conducted only under RCRA interim status or a full RCRA permit.
5.2.4 Prevention and Reduction Strategies
A number of colleges and universities have had success in managing
recycling programs that take waste or unused chemicals to central locations,
where they are then made available to researchers who need the chemicals. (An
important point to consider is that the commercial chemical products listed,in
40 CFR 261.33 are not wastes if they are reused for their originally intended
purposes, even if the reuse is not by the original purchaser.) Recycling
programs could be expanded to include several schools in a geographical area
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to reduce wastes collectively (Sanders 1986). Lists of available chemicals
could be exchanged among participating schools. The advantages of such a
program are the savings both in purchasing and disposal costs. A disincentive
could be the need to transport chemicals from one campus to another, which
requires compliance with the transportation regulations. This can be true
even if the chemicals are not hazardous wastes, because DOT regulations apply
to hazardous materials, a broader universe than EPA's list of hazardous
wastes.
Secondary schools can work within school districts to standardize
curricula and ensure that all science courses use the same chemicals. This
would not necessarily reduce the quantity of hazardous waste generated, but it
would make disposal of the waste easier from the school district's point of
view because the quantities of any particular type of waste generated would be
larger and of more consistent composition. As part of the curriculum changes,
less hazardous materials also could be substituted into the experiments, which
would reduce the quantity of hazardous waste generated.
Colleges and universities operate more independently than do public
secondary schools. Even within State-run university systems, each campus
generally has its own administration. As a result, changes in curricula come
from within individual departments rather than through cooperative
agreements. However, there are some colleges and universities within the same
areas that have cooperative agreements so that students can take courses at
any school. Within this type of arrangement, a course could also be taught at
only one school to minimize the quantity of waste generated and to restrict
the waste to one location.
5.3 GUIDANCE FROM EPA, THE STATES, AND OTHERS
This section suggests ways that guidance from Federal and State agencies
and others can aid educational institutions in the management of hazardous
waste.
5.3.1 Information Exchange
State agencies could collaborate with educational associations to develop
programs that could include the following:
• Increasing awareness of those activities within schools that generate
hazardous waste, including those not associated with the science
department
• Providing instructions and procedures for identifying hazardous
wastes (including all wastes generated by conditionally exempt schools)
• Developing appropriate management guidelines, including source
reduction, recycling, and reuse
• Establishing safety procedures and emergency response measures
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Such programs should be useful to high schools and smaller postsecondary
institutions. Delivery mechanisms, including workshops and incorporation into
college-level and continuing education curricula, may require some State
funding.
5.3.2 Centralized or Collective Programs
Technical advice and assistance programs could be developed at the State
and local levels to aid concerned educators and administrators in developing
and auditing waste management programs. (Waste management programs are
sometimes reviewed periodically, by either those administering them or those
overseeing their progress, for effectiveness, cost, and other factors.)
Representatives from regulatory agencies, consultants, and faculty and staff
of major universities could be selected to form advisory committees to aid in
the establishment of effective hazardous waste management programs. Advisory
committees could be formed and funded by State education departments.
Computerized bulletin boards, newsletters, and regional conferences could be
developed under these programs to help schools develop waste management
programs. State-wide or regional hazardous waste packaging and transportation
programs could be organized to provide regular service to schools. The
organization could be a collaborative effort of State regulatory and education
agencies and waste transporters, assisted by chemical suppliers and
educational associations.
In addition to collective waste disposal programs, the collection service
could include informational programs to inform educators about waste handling
and waste'minimization. Methods of waste storing and packaging also could be
discussed to enhance waste generators' understanding of the regulations.
5.3.3 Guidance Manuals on Handling Hazardous Wastes
In recent years, a number of publications have appeared that can be used
by educational institutions to improve their hazardous waste handling
programs. A few of them are highlighted below.
5.3.3.1 Federal and State Manuals
EPA has prepared a reference guide that provides small quantity generators
with the information that they need to obtain an EPA identification number and
to complete Uniform Hazardous Waste Manifests (EPA 1986b). The manual
provides information for educational institutions on which wastes are
considered hazardous and on how to comply with the transportation
regulations. EPA has also developed some waste minimization information,
included as Appendix C of this report.
The National Institute of Environmental Safety and Health has been
mandated under section 209 of the Superfund Amendment and Reauthorization Act
of 1986 to develop an educational training program for hazardous waste
workers. It is possible that this manual will include information that would
be useful to schools, such as methods for in-house handling, treatment, and
storage.
A videotape (22 minutes) produced by EPA in 1987, entitled Lab
Compliance with RCRA, gives bench chemists and laboratory technicians a
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better understanding of what they must do to comply with the hazardous waste
regulations. Members of the public can borrow copies of this videotape for
2-week periods. For further information, contact Rolf Hill, Training Officer,
U.S. Environmental Protection Agency, Office of Waste Programs Enforcement,
401 M Street, SW (WH-527), Washington, DC 20460, (202) 475-7037.
The New York State Environmental Facilities Corporation (1985) has
prepared an informational guide on how secondary schools can manage hazardous
waste. The manual identifies problems related to waste management and
describes how to develop a safety and management program.
5.3.3.2 Other Manuals
The Council of State Science Supervisors (1984) reviewed high school
science curricula to identify which chemicals should be removed from use.
State educational agencies could combine the list that the council has
compiled with suggestions of other hazardous materials that could be removed
from curricula. A handbook could be developed that would include the
following:
• Hazardous materials that should be removed from use in the curricula
and alternatives that could be used
• Treatments that could be performed after experiments to render
hazardous materials nonhazardous
• Instructions for labeling all containers of substances used or
generated in experiments in compliance with RCRA regulations
The National Research Council (1983) published Prudent Practices for
Disposal of Chemicals from Laboratories, which can serve as a guide to
faculties of secondary schools, colleges, and universities. The book
discusses all aspects of waste handling and disposal. It also presents
Federal regulations that were promulgated before 1983.
Various guides issued by associations of waste generators and waste
management companies recommend (to ensure safety and minimize risk) that
on-site transportation of hazardous waste be performed only in authorized
vehicles by trained personnel. (Temporary storage in or near the laboratory
may be used to help minimize the number of trips necessary to transfer the
waste to a central storage location (Tufts University 1987).)
Two publications by the American Chemical Society, Less Is Better
(1985) and RCRA and Laboratories (1986), discuss waste minimization and
Federal regulations that apply to laboratories. Both discuss waste management
strategies and compliance with RCRA regulations.
5.3.4 Regulatory Guidance
Regional forums, consisting of representatives from EPA, State
environmental agencies, and educational institutions, could be convened to
discuss regulatory ambiguities and to formulate a guidance document for
regulatory personnel to deal with schools. Representative participation and
consensus building in these forums is critical. Topics for which regulatory
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interpretation and practical guidance would be useful to schools and
regulatory personnel include the following:
• Hazardous waste identification and classification, including
transition from supply to waste status
• Effective measures for encouraging recovery and recycling in schools
without compromising safety and without conflict with accumulation and
storage requirements
• Definition of "on-site" as it applies to educational institutions,
the tradeoffs between multiple accumulation locations and central
storage, and appropriate transportation containers and systems for use
in schools
• Management of incorrectly identified wastes upon return to a school
or rejection by a transporter
• Establishment and operation of waste treatment procedures and
facilities by schools in various categories and with varying permit
status
EPA, if resources are available, could perform the following activities to
educate the schools and universities about hazardous waste regulations and
about proper methods for handling and disposing of hazardous waste. With the
assistance of the States and educational institutions, EPA could prepare a
guidance document on hazardous waste management at schools similar to the one
that it developed for small businesses. An EPA guide would help to inform
educators about existing hazardous waste management regulations. Tufts
University (1987) and others (Sanders 1986, Ashbrook and Reinhardt 1985) have
found that the major problem within educational institutions is a lack of
understanding about which regulations apply to schools and how to implement
them. EPA could sponsor an educational program for hazardous waste handling
and disposal by entering into a cooperative effort with the States to gather a
list of wastes and their designations from the large schools and
universities. This information could be shared with smaller colleges and
secondary schools. The list could be updated on a regular basis.
The American Chemical Society (ACS) has suggested that EPA establish an
independent office to assist academic waste generators with cleanup problems
(ACS 1987). ACS believes that the safest approach for most laboratory spills
is expeditious handling by those individuals in the laboratory most
knowledgeable about the specific reagents or reaction products involved.
However, in the event of a spill or other environmental incident at an
educational institution, the responsible individuals may not have the
expertise to select the most cost-effective and environmentally sound cleanup
method properly. If they are required to take corrective action and not to
have the EPA perform the cleanup, they need access to sound advice regarding
options. An independent office, perhaps the EPA Small Business Ombudsman,
could be made available to advise schools on various cleanup alternatives.
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5.4 REGULATORY CHANGES EPA HAS MADE OR PROPOSED TO MAKE
EPA already has made or proposed to make the following regulatory changes
that could alleviate problems with hazardous waste management at educational
institutions. First, EPA has issued small quantity generator requirements
that are more tailored to such generators. Many schools are small quantity
generators. Second, EPA has exempted from regulation small quantities of
hazardous waste, when evaluated in treatability studies. Third, EPA has
proposed reducing permitting requirements for small quantity burners.
5.4.1 Permitting
In the past, facilities and laboratories, including university research
facilities, presently are restricted from conducting treatability studies (40
CFR 270, "Hazardous Waste Permit Program") unless they are permitted, have
interim status or have a^ research, development, and demonstration permit
(§270.65). Under recent amendments to §261.4, however, small quantities of
hazardous waste are exempt from regulation when such quantities are being
evaluated in treatability studies. Facilities conducting treatability studies
will be exempt from RCRA permitting requirements if they meet specific
quantity limitations for storage and treatment rates. The treatability
studies sample exemption will allow research facilities at universities to
conduct small-scale treatability studies without obtaining a research,
development, and demonstration permit (§270.65).
In the preamble to the final small quantity generatory rule (51 FR 10146,
March 24, 1986), a commenter suggested that EPA could reduce permit
requirements for all treatment activities at small quantity generator- sites.
The Agency's response was that when these generators are conducting the same
treatment and storage or treatment and disposal as other permitted facilities,
their on-site treatment activities pose a potential risk to human health and
the environment. Therefore, reduced or eliminated permitting requirements
would be inappropriate. The Agency went on to explain that no permitting
would be required if a generator chooses to treat its hazardous waste in its
accumulation tanks or containers in conformance with the requirements of
§262.34 and Subparts J or I of Part 265. Nothing in §262.34 precludes a
generator from treating waste when it is in an accumulation tank or container
covered by that provision. Small quantity generators, which generate between
100 to 1,000 kg of hazardous waste per month, are not required to obtain
interim status and a RCRA permit if the on-site management that they perform
is treatment in an accumulation tank or container that is exempt from
permitting during periods of accumulation (180 or 270 days).
5.4.2 Burning Hazardous Wastes
Under current regulations (40 CFR 270.62, "Hazardous Waste Incinerator
Permits"), the cost of the permitting process for incinerators is prohibitive
for most schools. Current regulations prohibit the burning for energy
recovery of wastes that have usable fuel value without a permit (40 CFR Part
266, Subpart D). However, EPA has recognized that this situation could make
it more difficult for small burners. Therefore, it has proposed, under
Subpart D of Part 266, small quantity burner requirements that conditionally
exempt from permit requirements those burners that burn between 7 and 300
gallons of hazardous waste per month on-site for energy recovery (52 FR 17035,
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-53-
May 6, 1987) . Additional conditions include the following: the number of
units at the site that burn the hazardous waste is limited, the burning must
be on-site, dioxin-containing hazardous wastes may not be burned under this
exemption, and the hazardous waste heat input rate is limited to 1 percent (by
volume) of the total fuel input. For burners that are unable to meet the
conditions for small quantity burners, permits still will be required and
certain technical standards must be met.
5.5 SUGGESTIONS FOR REGULATORY REFORM
This section discusses areas of potential regulatory change that could
ease the requirements to which educational institutions are subject. These
comments were suggested by parties commenting on the draft of this report.
EPA has not evaluated these suggestions, and thus the Agency is not
recommending that these regulatory changes be made. In general, EPA could
examine these options in the future. Discussion of these changes is generally
divided by sections in the Code of Federal Regulations.
Both the States and the regulated community recommended the following
changes:
• Clarify existing rules for small quantity generators as they apply to
educational institutions
• Tailor existing hazardous waste management regulations to educational
institutions, such as reexamining EPA's definitions of "on-site" and
"off-site," and standardizing hazardous waste regulations nationally
• Reduce hazardous waste management requirements for educational
institutions, for example
(1) Changing the waste identification and recordkeeping requirements
to simplify paperwork
(2) Reducing permitting requirements for small scale incinerators to
facilitate incineration as an economical treatment alternative
(3) Allowing longer on-site storage of laboratory waste without a
permit
Finally, the following suggestion would require statutory changes: allow
land disposal of all lab packs, even those containing waste prohibited from
land disposal. The Hazardous and Solid Waste Amendments of 1984 did not
specifically exempt lab packs that contain prohibited waste from the land
disposal restrictions regulations. If lab packs contain hazardous wastes
subject to the land disposal restriction, they are prohibited from land
disposal unless such wastes meet the applicable treatment standards. EPA
cannot alter this requirement without statutory changes.
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5.5.1 Definition of "On-Sita"
As suggested by several commenters, EPA could reevaluate the definition of
"on-site" (§§260.10 and 270.2) to a'ddress the problems of such generators as
universities, which have numerous buildings on a campus, yet are unclear as to
whether they should apply for one or several hazardous waste identification
numbers. This could include changing the definition of "on-site" to allow
educational institutions to collect hazardous waste from disparate geographic
locations, up to 25 miles apart operated by the same institution.
5.5.2 Haste Characterization and Generation
Currently, 40 CFR Part 262 ("Standards Applicable to Generators of
Hazardous Waste") requires that each chemical be reported by waste code and on
the manifest by DOT shipping description. Part 268 ("Land Disposal
Restrictions") requires wastes restricted from land disposal to have a
notification or certification sent to the receiving facility, which includes
an identification by waste code. Educational institutions have varied waste
streams as a result of the large numbers of chemicals used and the variable
quantities of waste generated. The National Research Council (1983) has
prepared a simplified, seven-category classification scheme. These classes
could be made uniform for EPA, Department of Transportation, and State
requirements for schools. This system would allow all manifests and records
to be based on these seven classes rather than on waste codes and would ease
the schools' recordkeeping burden. The scope of this regulatory change would
include allowing transfer, storage, and disposal facilities to accept wastes
from educational institutions without detailed identification of every
compound.
Current recordkeeping requirements are extensive because of the
requirement for waste stream identification. If the simplified classification
scheme discussed by the National Research Council (1983) were adopted, the
aggregate waste name could be used for lab packs that are used to transport
wastes off-site. The classification also could be used for on-site storage.
Another classification system could group solvents according to flammability,
by whether or not they are halogenated, and by other criteria. Simplified
classification also would allow records to be simplified, because the quantity
of each class of chemicals (not the quantity of each chemical) would be
recorded. EPA cautions, however, that certain requirements (specifically,
land disposal restrictions) are specific to waste codes, so there are limits
to the amount of simplification possible.
5.5.3 Transportation
Intersecting public roads and noncontiguous boundaries between university
property and other land, which are typical of an educational institution's
geographical layout, make interpretation of the regulations (40 CFR Part 263,
"Standards Applicable to Transporters of Hazardous Waste") difficult and make
compliance costly. Therefore, many educational institutions may be
transporting waste chemicals along city streets without EPA manifests and
without the packaging required by the Department of Transportation (Ashbrook
and Reinhardt 1985) . Perhaps special exceptions could be made for small
quantities of waste generated by schools. The American Chemical Society
suggests that EPA allow academic facilities to transport their own hazardous
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-55-
wastes to central collection areas on their property under the following
controlled conditions whether or not public roadways must be crossed:
• Development and maintenance of a transportation contingency plan
• Liability insurance to cover transportation
• Driver training in hazardous waste handling and incident response
• Development of route plans that minimize transport on public roads
• Use of Department of Transportation-specified packaging for the
transportation of all hazardous wastes
5.5.4 Extended Storage
The American Chemical Society suggests that EPA allow on-site storage of
laboratory wastes for over 90 days without requiring a treatment, storage, or
disposal permit. Because educational laboratories frequently do not generate
enough waste to facilitate economical transport to off-site facilities, a
substantially higher cost per unit for transportation is required in
comparison with industrial waste generators. Extended storage of quantities
not exceeding one truckload (80 drums) of waste could allow academic
generators to reduce these per unit costs to a reasonable level. If a time
limit is necessary, 1 year could provide a more reasonable amount of time to
accumulate economic quantities for shipment than do the present time
limitations. Since laboratory wastes consist primarily of small quantities of
chemicals in their original containers, the American Chemical Society does not
expect that extended storage of these materials will present a significant
safety problem when normal storage procedures are followed.
5.5.5 Other Regulatory Reforms
The following are other regulatory reforms suggested by various commenters
on the draft of this report. According to the National Research Council
(1983), EPA, DOT, State, and local regulations are inconsistent in some areas
dealing with hazardous waste disposal. For example, some State or local
regulations may have additional requirements. The National Research Council
recommends "the establishment of a mutually consistent, interlocking
regulatory approach among different agencies for handling and disposal of
small quantities of chemically diverse waste that are generated by many
laboratories." The advantage to a uniform set of regulations is that regional
or national groups could be assembled to discuss methods of compliance.
Consistent regulations would make it easier to provide guidance to educational
institutions on a national level and would facilitate their understanding of
the requirements. An example of the effectiveness of such an approach can be
found in the development of EPA's Uniform Hazardous Waste Manifest, which
combines many State forms and approaches into one. However, State hazardous
waste programs can be more stringent than the Federal program. Thus, there is
a limit to the amount of uniformity that can be achieved.
The American Chemical Society (1987) has suggested that EPA adopt a
definition for "academic laboratories." If Congress mandates EPA to
promulgate regulations for the management of hazardous waste from educational
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institutions, then the Agency could consider defining academic laboratories as
follows:
"Buildings and areas of buildings under the ownership and control of
secondary and higher education institutions in which operations
involving chemicals are carried out for the following purposes:
"(a) Investigation of physical, chemical, and biological properties of
substances;
"(b) Development of new or improved methods of synthesis, analysis,
separation or purification, or initial development of new or
improved chemical processes or products;
"(c) Application development; and
"(d) Practice in the field of study."
5.6 CONCLUSION
Educational institutions generate waste streams that contain large
varieties of chemicals, most in very small quantities. This puts educational
institutions in a unique category, because they are required under RCRA to
record and track each individual chemical once it becomes a waste. A number
of schools simply do not comply with the regulations, either because they are
unaware of them or because they assume that the regulations do not apply to
them. The level of awareness varies widely among schools.
This chapter has identified possible ways to improve management of
hazardous wastes from educational institutions. There is a need for an
increased awareness of the regulations and their application. Unless school
administrators and staff are made aware that they have a problem, it is
impossible for them to institute changes that will overcome it. Dissemination
of information by Federal and State agencies could increase the level of
awareness and thus increase compliance with the regulations. EPA hopes that
making this report publicly available will help to increase the awareness of
schools about the hazardous waste regulations and appropriate hazardous waste
management.
A number of options open to schools, both independently and collectively,
have been discussed. However, ensuring proper waste management may be
difficult for even the most diligent of schools. A higher level of awareness
and commitment may be necessary to ensure proper waste management.
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*
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4
REFERENCES
American Chemical Society. 1984. Forum on Hazardous Waste Management at
Academic Institutions. Rocky Mountain Regional Meeting. American
Chemical Society, Washington, DC.
American Chemical Society. 1985. Less Is Better. Prepared by the
Task Force on RCRA, American Chemical Society. Washington, DC.
American Chemical Society. 1986. RCRA and Laboratories. Prepared by
the Task Force on RCRA, American Chemical Society. Washington, DC.
*
American Chemical Society. 1987. Letter to Filomena Chau, Office of
Solid Waste, U.S. Environmental Protection Agency, October 23, 1987,
concerning ACS's review of the draft report to Congress.
Ashbrook, P. C. 1986. Letter to Alan Corson, Office of Solid Waste, U.S.
Environmental Protection Agency, October 8, 1986, concerning the
management of hazardous wastes at universities.
Ashbrook, P. C., and P. A. Reinhardt. 1985. "Hazardous Waste in Academia."
Environmental Science and Technology 19:1150—1155.
Council of State Science Supervisors. 1984. School Science Laboratories:
A Guide to Some Hazardous Substances. Prepared for the National
Institute of Occupational Safety and Health. Lancaster, VA. PB
87-108387.
Ellefson, M. 1986. Summary of 1985 Hazardous Waste Activities.
University of Washington Environmental Health and Safety Department.
March 3, 1986.
*
Kizer, F. 1987. Telephone conversation of Shawn Sager of ICF-Clement
Incorporated with Frank Kizer of the Council of State Science Supervisors,
Lancaster, VA, May 12, 1987, concerning the use of commercial hazardous
waste management facilities.
*
Koertge, H. H. 1981. Sources and identification of university-generated
waste in Madison Seminar Proceedings. Waste Management in Universities
and Colleges. U.S. Environmental Protection Agency, Region V, Waste
Management Branch, Chicago, IL. EPA 905/9-81-001. May 1981.
Larson, S. (Director of the Office of Environmental Health and Safety,
Northeastern University, Boston, MA). 1986. Interviewed by students from
the Center for Environmental Management at Tufts University, as reported
*A copy of this reference is available for review in the RCRA Docket, Room LG-100, U.S.
Environmental Protection Agency, 401 M Street, SW, Washington, DC 20460. Docket hours are 9
a.m.Sto 4 p.m., Monday through Friday, excluding public holidays. To review docket materials,
the public must make an appointment by calling (202) 475-9327.
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in the Tufts University report's preliminary case study of Northwestern
University, June 9, 1986.
McCann, M. 1979. Artist Beware. Watson-Guptill Publications, New York,
NY.
McCann, M. 1987. Telephone conversation of Shawn Sager of ICF-Clement
Incorporated with Michael McCann of the Center for Occupational Hazards,
New York, NY, May 12, 1987, to collect more information on the types of
wastes generated in art classes.
Meister, J. F. 1981. Operation of the SIU-C Hazardous Waste Program, in
Madison Seminar Proceedings. Waste Management in Universities and
Colleges. U.S. Environmental Protection Agency, Region V, Waste
Management Branch, Chicago, IL. EPA 905/9-81-001. May 1981.
National Institute of Occupational Safety and Health. 1980. Manual of
Safety and Health Hazards in the School Science Laboratory. Cincinnati/
OH. PB 83187435. November 1980.
National Research Council. 1983. Prudent Practices for Disposal of
Chemicals from Laboratories. National Academy of Sciences Press,
Washington, DC.
New York State Environmental Facilities Corporation. 1985. A Guide
to Information Services Related to the Safety and Management of Laboratory
Wastes from Secondary Schools. Albany, NY.
Peck, J. 1987. Telephone conversation of Shawn Sager of ICF-Clement
Incorporated with Joan Peck of the Waste Management Division, Department
of Natural Resources, State of Michigan, May 12, 1987, concerning training
of teachers to handle hazardous wastes.
Reinhardt, P. 1987. Telephone conversation of Shawn Sager of ICF-Clement
Incorporated with Peter Reinhardt of the University of Wisconsin, Madison,
December 21 and 22, 1987, to clarify the quantity of hazardous waste
shipped to an off-site landfill.
Sanders, H. J. 1986. "Hazardous Wastes in Academic Labs." Chemical and
Engineering News 64:21-31.
Stanley, D. 1987. Telephone conversation of Shawn Sager of ICF-Clement
Incorporated with David Stanley of the Center for Environmental
Management, Tufts University, Medford, MA, May 20, 1987, to gather
additional information on the Tufts report.
*A copy of this reference is available for review in the RCRA Docket, Room LG-100, U.S.
Environmental Protection Agency, 401 M Street, SW, Washington, DC 20460. Docket hours are 9 a.m.
to 4 p.m., Monday through Friday, excluding public holidays. To review docket materials, the
public must make an appointment by calling (202) 475-9327.
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Tufts University. 1987. Hazardous Waste Management in Educational
Institutions: A Report to the United States Environmental Protection
Agency. Prepared by the Center for Environmental Management, Tufts
University, Medford, MA.
U.S. Environmental Protection Agency. 1985. National Small Quantity
Hazardous Waste Generator Survey. Office of Solid Waste and Emergency
Response, Washington, DC. May 1985.
U.S. Environmental Protection Agency. 1986a. EPA Guide for Infectious
Waste Management. Office of Solid Waste and Emergency Response,
Washington, DC. May 1986. NTIS No. PB86-199130.
U.S. Environmental Protection Agency. 1986b. Understanding the Small
Quantity Generator Hazardous Waste Rules: A Handbook for Small
Business. Office of Solid Waste and Emergency Response, Washington,
DC. September 1986. EPA/530-SW-86-019.
*U.S. Environmental Protection Agency. 1986c. Mobile Treatment
Technologies for Superfund Wastes. Office of Solid Waste and Emergency
Response, Washington, DC. September 1986. EPA/540/2-86/003F.
*A copy of this reference is available for review in docket F-88-WEIA-FFFFF, located in the
RCRA Docket, Room LG-100, U.S. Environmental Protection Agency, 401 M Street, SW, Washington, DC
20460. Docket hours are 9 a.m. to 4 p.m., Monday through Friday, excluding public holidays. To
review docket materials, the public must make an appointment by calling (202) 475-9327.
**A copy of this reference is available for review in docket F-36-LDR-4-S0011, located in
the RCRA Docket, at the above address.
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APPENDICES
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A-l
APPENDIX A
CASE STUDIES OF EDUCATIONAL INSTITUTIONS
CONTENTS
A.I Introduction A-l
A. 2 Criteria for Selection of Cases A-l
A.3 Colleges and Universities A-4
A. 4 High Schools A-4
A.1 INTRODUCTION
Because detailed national studies do not exist in the literature, Tufts
University, under contract to EPA, conducted case studies at selected schools
throughout the country to obtain information about specific waste management
programs. Tufts researchers gathered data from site visits, personal
interviews, telephone interviews, correspondence, and privately circulated
materials, such as in-house instructions for waste disposal. The Tufts
University researchers visited 26 sites to obtain examples of all phases of
hazardous waste management at high schools, colleges, and universities, and
they conducted interviews with several individuals at each institution. They
also collected in-house records and toured the sites involved in managing
hazardous waste.
A.2 CRITERIA FOR SELECTION OF CASES
The Tufts University researchers visited high schools, colleges, and
universities in Massachusetts, Rhode Island, Vermont, Minnesota, Oregon,
California, and North Carolina. States that had lower small-quantity-
generator limits than those set by EPA (discussed in Chapter 2) were
included. Urban and rural sites, 2-year and 4-year postsecondary college
programs, and schools likely to cooperate, schools with special features in
their education programs, or schools with a good grasp of hazardous waste
management issues were included. Other characteristics thought to affect
hazardous waste management included size (measured by enrollment), public or
private status, and curriculum (especially that portion related to science).
The Tufts University researchers selected a representative sample of colleges
and universities covering the various types of these institutions, based on
directory and catalog data for colleges and universities that described the
institutions by type, enrollment, and research funds. The final selection of
high schools was made from those located close to the selected colleges and
included vocational schools. The case-study schools (19 colleges and
universities and 7 high schools) are described in Tables A-l and A-2; none are
identified, because a number of these schools required assurance of
confidentiality as a condition of participation.
The Tufts University researchers assessed the colleges and universities
and determined the generator category of each school studied: conditionally.
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A-2
Table A-l
Collage and Univarsity Case Studies
Research and
Development Funding .
D
Group
A
Enrollment
1,100C
1,200
1,900
2,500C
3,600
4,900
11,400
11,400
Type (Millions of Dollars)
Public -
Private —
Private —
Public —
Private —
Private —
Public —
Public
B
C
2,300
4,500
5,200
6,900
7,400
9,500
12,000
16,100
22,400
29,300
43,100
Private
Public
Public
Private
Private
Private
Private
Private
Public
Public
Public
—
—
^~
26
25
222
175d
123
65e
134
8
aj. Cass and M. Birnbaum, Comparative Guide to American
Colleges, New York, Harper and Row, 1983.
Research Support Data Disks, Washington, D.C., National
Science Foundation, 1984 (Table B-30); Federal Support to
Universities, Colleges and Selected Non-Profit Institutions,
Washington, D.C., National Science Foundation, August 1985 (Table B-34)
cNumber furnished by respondent.
Estimate.
eReported significant changes in fiscal year 1984 compared
with fiscal year 1983, due to reclassifying of science and engineering
awards and restructuring of some departments.
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A-3
Table A-2
High School Case Studies
Code
A
B
C
D
E
F
G
Enrollment
1,000
1,300
1,500
1,600
1,600
1,800
2,300
Type
Public
Public
Public
Public
Public
Public
Public
Nature
Vocational-technical
Comprehensive
Comprehensive
Comprehensive-vocational
Comprehensive
Comprehensive-vocational
Comprehens i ve
Location
Suburban
Suburban
Suburban
Suburban
Urban
Urban
Urban
-------
A-4
exempt small quantity generator (group A), small quantity generator (group B),
or large quantity generator (group C). The researchers discovered that groups
A and B had no substantial research and development funding.
A.3 COLLEGES AND UNIVERSITIES
The Tufts University researchers selected 19 colleges and universities
from across the country as case studies for this report. Of these 19
institutions, 10 were public and 9 were private schools, with enrollment
ranging from 1,000 to 43,000 students. Nine of the schools received
substantial amounts of research and development funding ($1.2 to $175 million
in 1984), and six of them were in the National Science Foundation's 1983
listing of the "top 100" recipients of industrial and Federal research and
development funds. The researchers found that comparing the amounts of
research funds received indicated relative potential for generation of
hazardous waste.
A. 4 HIGH SCHOOLS
Seven public high schools were studied, ranging in size from 1,000 to
2,300 students. There were four comprehensive high schools, two combined
comprehensive-vocational schools, and one vocational-technical school. Four
schools were in suburban areas and three were in urban areas.
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B-l
APPENDIX B
REGULATIONS APPLICABLE TO TREATMENT, STORAGE,
AND DISPOSAL FACILITIES
CONTENTS
B.I Closure and Post-Closure B-l
B.2 Financial Requirements B-l
B.3 Waste Management Processes B-2
B.3.1 Containers B-2
B.3.2 Tank Systems B-2
B.3.3 Incinerators B-2
B.4 Other Requirements B-3
This appendix presents regulations under 40 CFR Parts 264 and 265 specific
to particular waste management processes and closure, post-closure, and
financial responsibility requirements that apply to educational institutions
that must, for whatever reason, obtain EPA permits for treatment, storage, or
disposal. As stated in Section 2.2.3, permitted treatment, storage, or
disposal facilities must comply with all the requirements of Part 264, and
interim status facilities must comply with requirements of Part 265. Because
all of the provisions discussed below are similar for permitted and
interim-status facilities, references for these provisions will be given for
Part 264 only. These regulations are not applicable to conditionally exempt
small quantity generators. Part 266 addresses recycling. Regulations under
40 CFR Part 268, which concern the requirements for the restriction from land
disposal of hazardous waste, are discussed in Chapters 2 and 4 of this
report. Facilities seeking EPA permits should not rely on the summary
provided here, but rather should examine the regulations cited.
B.I CLOSURE AND POST-CLOSURE
Closure care regulations apply to all owners and operators of treatment,
storage, or disposal facilities; post-closure care regulations apply to
disposal facilities, waste piles and surface impoundments from which the
hazardous wastes will be removed at closure, and tank systems required to meet
the landfill regulations (Subpart G, §§264.110-.120). The owner or operator
must have a written closure plan and must close the facility in a way that
minimizes the need for further maintenance and that controls, minimizes, or
eliminates post-closure escape of hazardous wastes. The owner or operator
must begin post-closure care activities upon completion of closure and must
continue post-closure care for 30 years (unless the period is modified) in
accordance with the approved post-closure plan.
B.2 FINANCIAL REQUIREMENTS
Owners and operators of treatment, storage, or disposal facilities, unless
exempt, must comply with financial requirements (Subpart H, §§264.140-.151).
Each owner or operator must have a written, detailed estimate of the cost of
closing the facility and maintaining it after closure, in accordance with the
applicable requirements of Part 264. Each owner or operator must establish
financial assurance for facility closure and post-closure. Each owner or
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B-2
operator must obtain and maintain liability coverage for sudden accidental
occurrences; in addition, the owner or operator of a surface impoundment,
landfill, or land treatment facility must obtain and maintain liability
coverage for nonsudden accidental occurrences.
B.3 HASTE MANAGEMENT PROCESSES
The regulations discussed in this section are specific to particular waste
management processes and would apply to schools only if they used such
processes.
B.3.1 Containers
Regulations regarding the use and management of containers (Subpart I,
§§264.170—.178) apply to all treatment, storage, and disposal facilities that
store containers of haza'rdous waste, unless they are exempted by §264.1. The
owner or operator must use containers that are in good condition, do not leak,
and are made of or lined with materials that will not react with and are
otherwise compatible with the wastes to be stored. The owner or operator must
inspect areas where containers are stored for possible leaks and
deterioration, use a containment system in accordance with §264.175, and take
precautions to avoid mixing incompatible wastes. The owner or operator must
establish a buffer zone of at least 50 feet from the property line for
containers of ignitable or reactive wastes (§264.176).
B.3.2 Tank Systems
Regulations covering tank systems (Subpart J, §§265.190-200) apply to
treatment, storage, and disposal facilities that use tank systems to store or
treat hazardous wastes,- unless they are exempted by §264.1. In addition,
§264.193 exempts tanks storing or treating hazardous waste that contain no
free liquids and that are in a building with an impermeable floor, as well as
tanks that serve as part of a secondary containment system to collect or
contain releases of hazardous wastes. To prevent the release of hazardous
waste to the environment, the owner or operator must provide a secondary
containment and detection system in accordance with the technical standards
specified in §264.193, and if a leak or spill occurs, the owner or operator
must comply with the requirements of §264.196. The owner or operator also
must develop and follow a schedule and procedures for inspecting the tank
system. At closure, the owner or operator must remove or decontaminate all
wastes or waste residues or contaminated system components and manage them as
hazardous wastes, or close the tank system and perform post-closure care.
Hazardous waste tank owners should examine State regulations for applicable
provisions.
B.3.3 Incinerators
Incinerator regulations (Subpart 0, §§264.340-.351) apply to treatment,
storage, and disposal facilities (unless they are exempted by §264.1) that
incinerate hazardous wastes or that burn hazardous wastes in boilers or in
industrial furnaces to destroy them or for recycling purposes and that elect
to be regulated under Subpart 0. Certain wastes (identified in §264.340) are
exempt from all incineration requirements except waste analysis and closure
requirements. An incinerator of hazardous wastes must be designed,
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B-3
constructed, and maintained to meet the performance standards specified in
§264.343 and must be operated in accordance with operating requirements
specified in the permit. The owner or operator must conduct, at a minimum,
monitoring and inspection of the incinerators in accordance with the
requirements specified in §264.347. At closure, the owner or operator must
remove all hazardous waste and hazardous waste residue. When hazardous waste
is removed, at closure or during the operating life, the owner or operator
becomes a generator and must manage the waste in accordance with the generator
requirements under Part 262.
B.4 OTHER REQUIREMENTS
Those individuals who burn hazardous waste fuel for energy recovery are
subject to requirements under Subpart D of Part 266. Those who burn used oil
for energy recovery are subject to requirements under Subpart E of Part 266.
Hazardous wastes containing precious metals are subject to requirements under
Subpart F of Part 266; photoprocessing is an activity that may generate such
wastes.
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C-1
4
APPENDIX C
WASTE IDENTIFICATION AND MINIMIZATION
CONTENTS
C.I Introduction C-1
C.I.I How This Appendix Can Help Educational Institutions . . C-2
C.I.2 Using This Appendix C-2
C.2 Information Specific to Educational Institutions C-4
C.2.1 Overview C-4
C.2.2 Hazardous Wastes from Laboratories C-4
C.2.3 Hazardous Wastes from Vocational Shops C-5
C.2.4 Reference List C-5
C.3 Categories of Specific Hazardous Wastes C-6
C.1 INTRODUCTION
This appendix was prepared to serve as a reference guide for educational
institutions and to provide them with information they will need to accomplish
the following:
• Obtain an EPA identification number,
• Complete the Uniform Hazardous Waste Manifest for shipping their
hazardous wastes off-site,, and
• Begin planning how to minimize hazardous waste generation.
Appendix D contains addresses and phone numbers of EPA hotlines and
agencies that administer hazardous waste regulations and that can provide more
information on specific aspects of the regulations.
This appendix is divided into three sections. Section C.I provides an
introduction to the information excerpted from the guide. Section C.2
contains information specific to educational institutions, which will help
them to identify the hazardous wastes that they generate and identify
opportunities for minimizing hazardous waste. Tables C-1 and C-3 list the
typical operations and processes used within educational institutions, the
materials used, and the types of hazardous waste generated. Table C-1
examines the activities by laboratories, and Table C-3 examines the activities
by vocational shops. Tables C-2 and C-4 list techniques that can be used to
minimize or manage the kinds of waste generated. Table C-2 outlines
techniques for laboratories, and Table C-4 outlines techniques for vocational
shops. The reference list at the end of Section C.2 contains publications
that provide additional technical information on minimizing waste.
Section C.3 contains a chart (Table C-5) listing the hazardous wastes
discussed in Section C.2 and their proper Department of Transportation (DOT)
shipping descriptions and corresponding EPA hazardous waste numbers. The
information presented in Section C.3 is broadly applicable to both large and
small quantity generators of hazardous waste. The information in Section C.3
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C-2
that is summarized from the EPA regulations (40 CFR Part 261) and the DOT
regulations (49 CFR Part 172) is not comprehensive; the regulations and the
relevant agencies are the best sources for comprehensive and current
information (see Appendix D). Whether a generator of hazardous waste uses
this appendix or the regulations, the generator should describe the hazardous
waste generated as precisely and completely as possible.
C.I.I How This Appendix Can Help Educational Institutions
C.I.1.1 Obtaining an EPA Identification Number
If an institution generates more than about 220 pounds (one-half of a
55-gallon drum) of hazardous waste in any calendar month it must obtain an EPA
identification number. To apply for an identification number, the institution
must complete EPA Form 8700-12, "Notification of Hazardous Waste Activity,"
which can be obtained from the State hazardous waste management agency or the
EPA regional office. Item X of the form requires identification of hazardous
waste by its EPA hazardous waste number. Section C.3 contains EPA hazardous
waste numbers for wastes commonly generated by educational institutions.
C.I.1.2 Completing the Uniform Hazardous Waste Manifest
If an institution generates more than about 220 pounds (one-half of a
55-gallon drum) of hazardous waste in any calendar month and it ships the
waste off-site for treatment, storage, or disposal, it must complete a Uniform
Hazardous Waste Manifest. The manifest must accompany any hazardous wastes
shipped off-site. Item 11 of the manifest requires the proper DOT shipping
description for the wastes being transported. Section C.3 provides the proper
DOT shipping descriptions for a number of hazardous wastes commonly generated
by educational institutions.
C.I.1.3 Minimising tha Hazardous Hasta Generated
Suggestions for minimizing hazardous waste generation have been included
in the waste minimization tables (Tables C-2 and C-4) in this appendix. The
letters "WM" in Tables C-l and C-3 indicate that waste minimization
information for the specific process or waste so designated can be found in
Tables C-2 and C-4, which also contain more general information on waste
minimization and management. These suggestions may help educational
institutions to reduce the amounts of hazardous waste that they generate and
thus reduce the costs and liabilities that they face in managing these
wastes. The information contained in this appendix is not exhaustive; it is
intended to indicate the variety of cost-effective opportunities that are
available. See the references listed at the end of Section C.2 for additional
information.
C.I.2 Using This Appendix
Tables C-l and C-3 list processes and materials and the major hazardous
waste categories associated with them. An educational institution can
identify activities that may generate hazardous wastes and proceed to Section
C.3 for more EPA and DOT information.
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03
C.I.2.1 EPA and Department of Transportation (DOT) Information
In Table C-4 (Section C.3), wastes are entered in alphabetical order under
each category. The entries opposite the wastes provide DOT shipping
descriptions for the manifest and, in the extreme right column, the EPA
hazardous waste numbers for the notification form.
As indicated throughout Section C.2, many industries generate hazardous
wastes that are either listed, characteristic, or acute hazardous. Listed
hazardous wastes are wastes that EPA has identified by name in the
regulations. These wastes have EPA hazardous waste numbers that begin with
the letters "F," "K," "P," and "U." Characteristic hazardous wastes are
either ignitable, corrosive, reactive, or extraction procedure (EP) toxic.
See 40 CFR Part 261 for the regulations that define hazardous waste.
Ignitable Wastes: Ignitable wastes are liquids with flashpoints of
less than 140 °F (60 °C), solids that ignite spontaneously through
absorption of moisture or through friction and that burn vigorously, and
ignitable compressed gases or oxidizers as defined by DOT.
Corrosive Wastes: Corrosive wastes include aqueous solutions with pH
values less than or equal to 2 or greater than or equal to 12.5 and liquids
that corrode steel at rates of more than 0.25 inch per year.
Reactive Wastes: Reactive wastes include substances that are unstable
and readily undergo violent change; react violently with water; form
potentially explosive mixtures with water; are capable of detonation or
explosive reactions when exposed to strong initiating sources; generate
significant quantities of toxic gases when exposed to water or, in the case of
cyanide or sulfide-bearing wastes, have pH values between 2 and 12.5; are a
capable of detonation or explosive reactions at standard temperature and
pressure; or are forbidden, class A, or class B explosives as defined by DOT.
EP Toxic Wastes: Wastes are EP toxic if extracts from the wastes
contain more than the concentrations of arsenic, barium, cadmium, chromium,
lead, mercury, selenium, silver, endrin, lindane, methoxychlor, toxaphene,
2,4-D, or 2,4,5-TP specified in the Resource Conservation and Recovery Act
(RCRA) regulations at 40 CFR 261.24.
Acute and Listed Hazardous Wastes: Acute hazardous wastes-are also
listed hazardous wastes and are identified by EPA in the hazardous waste
regulations by EPA hazardous waste numbers between F020 and F027 or by numbers
that begin with the letter "P."
C.I.2.2 Waste Minimization
Tables C-2 and C-4 provide waste minimization suggestions corresponding to
the processes and wastes identified by "WM" in Tables C-l and C-3, as well as
general information on waste minimization and management. The number and
variety of books and reports concerned with waste minimization is large and is
rapidly growing. For additional information, and more detailed technical
descriptions of feasible waste reduction options, see the reference list at
the end of Section C.2.
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C-4
C.2 INFORMATION SPECIFIC TO EDUCATIONAL INSTITUTIONS
C.2.1 Overview
Educational institutions may include teaching and research laboratories
and may include vocational shops engaged in automotive and small engine
repair, automobile body repair, metalworking graphic arts production (for
example, printing or photography), and woodworking.
If an educational institution generates more than 220 pounds (about half
of a 55-gallon drum) of hazardous waste per month, it must obtain an EPA
identification number and, if it ships the waste off its property, fill out a
Uniform Hazardous Waste Manifest. Some States require the manifesting of less
than 220 pounds of hazardous waste, so each institution should check with its
State hazardous waste management agency to determine requirements under State
law.
Although not all educational institutions produce each of the wastes
listed, it is likely that every institution produces some of them. If a
school is unable to find a particular chemical that it uses or a waste that it
generates in Table C-l or C-3, it should contact it State hazardous waste
management agency or EPA regional office (see Appendix D for addresses and
phone numbers) or refer to EPA's Understanding the Small Quantity Generator
Rules: A Handbook for Small Business.
C.2.2 Hazardous Wastes from Laboratories
Laboratories generate too great a variety of wastes to identify in this
appendix. The following discussion identifies the general sources of
laboratory waste and provides examples of specific wastes generated by
laboratories.
The following wastes are commonly generated by laboratories:
• Spent solvents, used in cleaning, extraction, and other processes
• Unused reagents that are no longer needed, do not meet specifications,
have become contaminated, have exceeded their storage lives, or are
otherwise unusable in laboratories
• Reaction products, either of known or of unknown composition (to
facilitate disposal, laboratories should try to identify or
characterize reaction products to the extent possible and label them)
• Test samples that are not entirely consumed by the test procedure
• Contaminated materials, such as glassware, paper, and plastic products
Spent solvents and unused reagents generally constitute the majority of
laboratory wastes. Laboratories in general produce a variety of hazardous
wastes that are often ignitable, corrosive, reactive, EP toxic, or acutely
hazardous.
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C-5
Radioactive wastes, which some laboratories generate, are generally
regulated under the Atomic Energy Act and therefore are excluded from EPA
regulation under RCRA. EPA is presently developing regulations for the
management of low-level radioactive wastes under the Toxic Substances Control
Act. Nuclear Regulatory Commission and DOT regulations, however, may apply;
generators of radioactive wastes should contact the Nuclear Regulatory
Commission, the DOT Materials Transport Bureau, or the State transportation
agency for more information concerning proper transport and disposal of these
wastes.
Mixed wastes are wastes that are radioactive and either exhibit hazardous
characteristics or are listed as hazardous wastes. Mixed wastes are subject
to regulation under the Atomic Energy Act and under RCRA. Generators or
handlers of these wastes should contact the appropriate EPA Regional Office.
Table C-l lists typical laboratory processes and operations that use
products that may contain hazardous materials and that probably generate
hazardous wastes. Table C-2 provides recommendations to help minimize
hazardous waste generation by laboratories.
C.2.3 Hazardous Wastes from Vocational Shops
The majority of hazardous wastes from vocational shops include solvents
(for example, paint removers, thinners, or cleaning solvents), paint wastes,
and strong acid or alkaline solutions (for example, cleaning solutions).
Automobile body repair and woodworking operations generate waste solvents and
paints. The solvents may be flammable or toxic, and paints may contain heavy
metal pigments as well as hazardous solvents.
Graphic arts production may generate several types of wastes, depending on
the activities. Printing wastes include strong acid solutions used to clean,
etch, and coat plates and solvents used to clean plates, to apply
light-sensitive coatings, and to develop plates. The use of inks generates
wastes containing solvents or heavy metals. Photographic processing wastes
include processing solutions, developers, hardeners, and fixing baths. Many
used photographic processing solutions contain significant amounts of
dissolved silver.
Metalworking and automotive repair generate waste solvents and acid or
alkaline solutions used to clean metal and remove rust. Table C-3 lists
typical vocational processes and operations that use products that may contain
hazardous materials and may generate hazardous wastes. Table C-4 provides
recommendations to help minimize hazardous waste generation by vocational
shops.
C.2.4 Reference List
California Department of Health Services. 1985. Economic Incentives for
the Reduction of Hazardous Wastes. Prepared by ICF Consulting
Associates, Inc., Los Angeles, CA. This is a two-volume report, including
appendixes.
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C-6
California Department of Health Services, Alternative Technology and Policy
Development Section. 1986. Guide to Solvent Waste Reduction
Alternatives: Final Report. Prepared by ICF Consulting Associates,
Inc., Los Angeles, CA.
Campbell, Monica E., and William M. Glenn. 1982. Profit from Pollution
Prevention: A Guide to Industrial Waste Reduction and Recycling.
Pollution Probe Foundation, Toronto, Ontario, Canada.
Field, Rosanne A. 1986. Management Strategies and Technologies for the
Minimization of Chemical Wastes from Laboratories. North Carolina
Pollution Prevention Pays Program.
GCA Corporation, GCA/Technology Division. 1985. "Hazardous Waste Generation
and Source Reduction in Massachusetts: Draft Final Report." Bedford,
MA. GCA Corp., GCA-WR-4397.
Patterson, J. W. (ed.). 1985. Industrial Waste Management Series-Recovery,
Recycle and Reuse of Industrial Waste. Lewis Publishers, Inc., MI.
U.S. Environmental Protection Agency. September 1986. Understanding the
Small Quantity Generator Rules: A Handbook for Small Business. Office
of Solid Waste and Emergency Response, Washington, DC. EPA/530-SW-86-019.
U.S. Environmental Protection Agency. October 1986. Waste Minimization
Issues and Options, Volumes I, II, and III. Office of Solid Waste and
Emergency Response, Washington, DC. EPA/530-SW-86-041.
C.3 CATEGORIES OF SPECIFIC HAZARDOUS HASTES
Table C-5 contains EPA- and DOT-specific information for a number of
commonly generated hazardous wastes. Obtaining an EPA identification number
requires completing the "Notification of Hazardous Waste Activity" form. This
form requires inserting the appropriate EPA hazardous waste number in item X.
Exhibit C-l is a sample form.
The DOT waste description is necessary to complete the Uniform Hazardous
Waste Manifest. The DOT description includes the proper shipping name, the
hazard class, and the applicable UN/NA identification number. As required,
any additional information must appear either before or after the DOT
description, as appropriate. Table C-5 contains this information for many
commonly generated hazardous wastes. This information must be written in item
11 of the Uniform Hazardous Waste Manifest. Exhibit C-2 is a sample manifest.
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C-7
Exhibit C-l
Sample Notification of Hazardous Haste Activity Form (EPA Form 8700-12)
**«•«* 3"r ;f l.cr « ''
United Slates Environmental Protection Agency
Wasmnflion DC 20*60
P'aasa 'e'er '-o tr.* instruction tor
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notification it this >* not vour first notification enter your installation s EPA ID Number Cl
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Continue on reverse
-------
08
Exhibit C-l (Continued)
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1 certify under penalty ol law that 1 have personally examined and am familiar with the information submitted in
this and all attached documents, and that based on my inquiry of those individuals immediately responsible for
obtaining the information, 1 believe that the submitted information is true, accurate, andcomplete lamawarethat
there are significant penalties for submitting false information, including the possibility of fine and imprisonment
Signature Name and Official Title rtvot or armn Date Signed
£P* Form 8700 12 (R.v 11-851 Reverse
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C-9
Exhibit C-2
Sample Uniform Hazardous Waste Manifest (EPA Form 8700-22)
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-------
C-10
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Unu
N.
WasHNo.
T Handling Codes for Wastes Lined Apove
32 Special Handling Instructions and Additional Information
33 Transporter Acknowledgement of Receipt of Materials
Printed/Typed Name Signature
34 Transporter Acknowledgement ot Receipt of Materials
Printed/Typed Name Signature
35 Discrepancy Indication Space
Date
"•no OK '•*
1 1
0*t«
0-, '-
EPA Form 8700-22A (Rev. 9-86) Previous edition is obsolete
-------
C-ll
Table C-l
Typical Operations: Materials Used and Hazardous
Wastes That May Be Generated by Laboratories
Typical
Process or
Operation
Laboratories
Typical
Materials
Used
Solvents,
reagents,
samples,
disposable
labware
Waste
Minimization
Opportunities
MM*
Major
Hazardous
Waste
Categories
Acid or
alkaline
wastes
Solvent
wastes
aSpecific EPA and DOT information is contained in Table C-5.
"WM" indicates that waste minimization information for the specific
process or waste is in Table C-2, which also contains more general information
on waste minimization and management.
-------
Table C-2
Waste Minimization for Laboratories
Typical
Process
or Operation
Minimization and Management Opportunities
General Laboratory
Management Techniques
Purchase smaller quantities and smaller sized containers of chemicals. Chemicals often last
longer when kept in unopened, air- and moisture-free containers. Often chemists will not
use opened bottles of chemicals because of concern about purity. When large containers of
chemicals are purchased, significant portions frequently remain unused and must be
disposed. Purchase chemicals in sizes that are commensurate with use. When disposal costs
of unused materials are added to the purchase price of a chemical, it is often uneconomical
to buy large containers.
Maintain an inventory of all laboratory chemicals purchased, and keep track of the status
and age of the chemicals within a laboratory. Keep stock rotating. Use older chemicals
first. Do not purchase more chemicals than can be used within the shelf life of the
material. Depending on the size and resources of the laboratory, this inventory system can
be computerized or simply kept in a card file. Having an inventory of chemicals is a
prerequisite for the exchange and reuse of chemicals within a particular institution, or for
participation in a regional waste exchange. Duplicate purchases of chemicals can be reduced
by distributing the list of chemicals within an institution.
O
M
to
Some institutions maintain centralized storage areas for unused chemicals. Often these
chemicals are arranged on shelves in alphabetical order by name. This may cause
incompatible chemicals to be stored close together. Chemicals should be stored according to
chemical compatibility in storage areas that are well ventilated and monitored to ensure
that labeling of materials is adequate and that deteriorated chemicals do not remain in
storage.
Laboratories can distribute lists of unused chemicals within the institution or among a
group of local institutions. Lists of wastes, if prepared in sufficient quantities, can be
distributed to local and regional waste exchanges.
Chemical containers can often be returned to the manufacturer or distributor.
-------
Table C-2 (Continued)
Typical
Process
or Operation
Minimization and Management Opportunities
Chemical Substitution
Laboratories should evaluate the feasibility of using less hazardous materials in laboratory
procedures. The following are examples of this type of substitution:
— Replacements can be found for some cleaning agents. Tor example, laboratory detergents
can sometimes be used in place of such materials as chromic acid solution and alcoholic
potassium solution.
— Substitutes often can be found for benzene and carbon tetrachloride. For example, in
the standard qualitative test for halide ions, cyclohexane can be used instead of carbon
tetrachloride.
— Acetamide can be replaced, under specified conditions, by stearic acid in Such
laboratory procedures as phase changes and freezing point depressions.
Solvent Waste Management
and Recovery and Reuse
Solvent wastes should be labeled and segregated. Hastes should be segregated into at
least the following categories:
- Chlorinated solvents (for example, methylene chloride)
— Aliphatic hydrocarbon and oxygenated hydrocarbon solvents (for example, mineral spirits,
hexane)
— Aromatic hydrocarbons (for example, benzene)
If substantial quantities of any particular solvent are generated, they should be kept
separate.
The use of solvents for cleaning glassware can be reduced by employing used solvent for
the first cleaning, and fresh solvent for subsequent and final cleaning. This procedure
decreases the amount of clean solvent required.
O
I
-------
Table C-2 (Continued)
Typical
Process
or Operation
Minimization and Management Opportunities
Certain types of solvent wastes can be distilled in-house. Solvent stills are available
in a variety of small sizes, including high-quality fractional distillation units. Solvents
can be distilled for reuse within a particular laboratory or by other divisions in an
organization. For example, teaching laboratories can use recyled solvents from academic
departments for classroom experiments, which often can use solvents of lower purity.
Distilled solvents also can be used as thinners and degreasers by maintenance divisions in
an institution. Segregation of solvent wastes is extremely important in recycling and is a
good tracking system to account for the waste. Still bottoms must be handled as hazardous
waste.
Use of Chemicals for
Fuel
Recovery of Metals
Certain flammable organic solvents can be used as fuel in existing boilers. These organic
solvents include acetone, butyl alcohol, heptane, and hexane. It should be noted,
however, that the burning of waste chemicals in boilers may be restricted by local. State,
or Federal regulations or by the permits of particular boilers.
Small amounts of metallic mercury can be recovered by filtration, conducted in a hood.
The filter paper, however, must be disposed of as a hazardous waste.
Electrolytic recovery techniques can be used to recover silver from photographic
solutions.
Metals, such as platinum, palladium, and rhodium, contained in spent catalysts can be
recovered by chemical procedures specific to the particular metals.
O
I
Microscale Experiments
Conducting experiments on a smaller scale, using special glassware and other equipment, is
an option that can reduce both the quantities of reagents used and the amount of waste
generated.
-------
Table C-3
Typical Operations: Materials Used and Hazardous Hastes That May Be Generated by Vocational Shops
Typical
Process
or Operation
Typical
Materials Used
Typical Material
Ingredients on Label
Waste
Minimization
Opportunities*
Major Hazardous
Haste Categories
Degreasing; Metal and
Tool Cleaning; Engine
Parts, and Equipment
Equipment Cleaning
Rust Removal
Painting
Spray Booths,
Spray Guns, Brush
Cleaning; Paint
Removal and Paint
Preparation
Solvents, varsol,
carburetor cleaners,
degreasers, clean-
ing fluids, acids,
alkalies, engine
cleaners
Naval jelly, strong
acid or alkaline
solutions
Enamels, lacquers,
epoxies, alkyds,
acrylics, primers,
solvents
Solvents, paint
thinners, enamel
reducers, white
spirits
Automobile Engine and Body Repair, Metalworking
Petroleum distillates,
aromatic hydrocarbons,
mineral spirits, benzene,
toluene, petroleum
naphtha
Phosphoric acid,
hydrochloric acid,
hydrofluoric acid,
sodium hydroxide
Acetone, toluene,
petroleum distillates,
epoxy ester resins,
ntethylene chloride,
xylene, V.M.SP. naphtha,
aromatic hydrocarbons,
methyl isobutyl
ketones
Acetone, toluene,
petroleum distillates,
methanol, methylene
chloride, isopropanol,
mineral spirits,
alcohols, ketones,
other oxygenated
solvents
HM
KM
WM
Acid and alkaline
wastes
Ignitable wastes-
NOSC
Solvent wastes
Acid and alkaline
wastes
Ignitable wastes-
NOS
Paint wastes
Solvent wastes
Paint wastes
Solvent wastes
O
H*
tn
-------
Table C-3 (Continued)
Typical
Process
or Operation
Typical
Materials Used
Typical Material
Ingredients on Label
Waste
Minimization
Opportunities'3
Major Hazardous
Haste Categories
Used Lead-Acid
Batteries (Exclud-
ing Those Sent for
Recycling)
Car, truck, boat,
motorcycle, and
other vehicle
batteries
Graphic Arts
Acid and alkaline
wastes
Batteries (lead-
acid)
Plate Preparation:
Counter-Etch To
Remove Oxide
Deep-Etch Coat-
ing of Plates
Etch Baths
Apply Light Sen-
sitive Coating
Phosphoric acid
Deep-etch bath
Etch baths for
plates
Resins, binders,
emulsion, photo-
sensitizers,
gelatin, photo-
initiators
Phosphoric acid
Ammonium dichromate,
ammonium hydroxide
Ferric chloride
(copper), aluminum
chloride/zinc
chloride/hydrochloric
acid (chromium);
nitric acid (zinc,
magnesium)
Polyvinyl alcohol/
ammonium dichromate,
polyvinyl cinnamate,
fish glue/albumin, silver
halide/gelatin emul-
sion, gum arable/
ammonium dichromate
Acid and alkaline
wastes
Acid and alkaline
wastes
Heavy metal wastes-
solutions
Acid and alkaline
wastes
Heavy metal wastes-
solutions
Photographic processing
wastes
O
I
-------
Table C-3 (Continued)
Typical
Process
or Operation
Typical
Materials Used
Typical Material
Ingredients on Label
Waste
Minimization
Opportunities3
Major Hazardous
Haste Categories
Develop Plates
Developer
Lactic acid, zinc
chloride, magnesium
chloride
Photographic processing
wastes
Mash and Clean
Plates
Apply Lacquer
Ink
Making Gravure
Cylinders
Painting
Alcohols, solvents
Resins, solvents,
vinyl lacquer
Pigments, dyes,
varnish, drier,
extender, modi-
fier
Acid plating bath
Solvents, paint
with solvents,
heavy metals
Ethyl alcohol,
isopropyl alcohol,
methyl ethyl ketone,
trichloroethylene,
perchloroethylene
Polyvinyl chloride,
polyvinyl alcohol
ma laic acid, methyl ethyl
ketone
Titanium oxide, iron
blues, molybdated
chrome orange,
phthalocyanide pig-
ments, oils, hydro-
carbon solvents, waxes,
cobalt/zinc manganese
oleates, plasticizers
Copper,
acid
hydrochloric
Ethylene dichloride,
benzene, toluene,
ethylbenzene, chloro-
benzene, methyl ethyl
ketone
WM
WM
Solvent wastes
Solvent wastes
Ink-sludges with
chromium or lead
Ink—waste
O
I
Plating wastes
Ignitable wastes-
NOS
Paint wastes
-------
Tabla C-3 (Continued)
Typical
Process
or Operation
Typical
Materials Used
Typical Material
Ingredients on Label
Haste
Minimization
Opportunities*
Major Hazardous
Waste Categories**
Wood Cleaning and
Wax Removal
Petroleum distil-
lates, white
spirits
Woodworking
Petroleum distillates,
mineral spirits
Ignitable wastes-
NOS
Solvent wastes
Refinishing and
Stripping; Brush
Cleaning and
Spray Gun
Cleaning
Staining
Paint removers,
varnish removers,
enamel removers,
shellac removers,
paint solvents,
turpentine
Stains
Acetone, toluene,
petroleum distillates,
mineral spirits,
methanol, methylene
chloride, alcohols,
ketone, oxygenated
solvents
Mineral spirits,
alcohols, pigments
Ignitable wastes-
NOS
Paint wastes
Solvent wastes
Ignitable wastes-
NOS
Solvent wastes
O
M
CO
Painting
Enamels, lacquers,
epoxy, alkyds,
acrylics, primers,
solvents
Toluene, pigments, WM
titanium dioxide,
epoxy-ester resins, WM
aromatic hydrocarbons, WM
glycol ether, halo-
genated hydrocarbons,
vinyl acetate acrylic
Ignitable wastes-
NOS
Paint wastes
Solvent wastes
-------
Table C-3 (Continued)
Typical
Process
or Operation
Typical
Materials Used
Typical Material
Ingredients on Label
Haste
Minimization
Opportunities3
Major Hazardous
Waste Categories'7
Finishing
Varnish, shellac, Denatured alcohols,
polyurethane, resins, shellac,
lacquers petroleum distillates,
toluene diiaocyanate
Ignitable wastes-
NOS
Solvent wastes
"WM" indicates that wastes minimization information for the specific process or waste can be found in Table C-4, which also
contains more general information on waste minimization and management.
Specific EPA and DOT information is contained in Table C-5.
CNOS, Not otherwise specified.
-------
Table C-4
Haata Minimization for Vocational Shops
Typical
Process or
Operation
Major
Hazardous
Waste
Categories
Minimization and Management Opportunities
Metal
Cutting
Degreasing
Waste
cutting
oils
Solvent
wastes;
ignitable
wastes-NOSd
• In some metal-cutting operations, oils can be recycled, without any treatment, until they
are consumed.
• It is generally beneficial to standardize oils and, if possible, to use one type of oil for
many kinds of machining.
• Using leas hazardous solvent degreasers reduces the hazards and toxicity of the degreasing
process. Biodegradable water-based cleaners presently marketed may also be used for
degreasing.
• Covering the vapor degreasing unit reduces loss of solvent to the atmosphere. Rotating
parts before removal from the vapor degreaser allows condensed solvent to return to the
degreasing unit.
• Only degrease parts that must be cleaned. Do not routinely degrease all parts.
• Spent degreasing solvents can be recycled on site using small batch stills. Contractual
agreements can be entered into with companies that supply fresh solvents and remove and
recover the usable fraction of spent solvents.
o
o
Painting
Ignitable
wastes-NOS;
paint wastes;
solvent wastes
Certain spray-painting techniques can reduce the amount of paint required for
a job and can also reduce paint wastes. The techniques include setting correct air pressure
for the gun and the use of certain stroking techniques, such as overlapping the spray
pattern by 50 percent, maintaining a distance of 6-8 inches from the work piece, holding
the gun perpendicular to the surface, and triggering the gun at the beginning and end of
each stroke.
-------
Table C-« (Continued)
Typical
Process Or
Operation
Spray Booth,
Spray Guns,
and Brush
Cleaning
Major
Hazardous
Waste
Categories Minimization and Management Opportunities
Solvent • To conserve solvent in cleaning operations, dirty solvent should be used first. Fresh
wastes; solvent should only be used for final cleaning.
paint
wastes
aNOS, Not otherwise specified.
O
-------
Table C-5
Categories of Specific Hazardous Naates, Including EPA and DOT Information
Waste Designation
DOT Information for Item
DOT Proper Shipping Name
11 of the Uniform Hazardous Haste
Hazard Class3
Manifest
Identifi-
cation Additional
No. Information**
EPA
Hazardous
Haste No.
Acid and Alkaline Hastes
Acetic Acid
Ammonium Hydroxide
NH4OH, Spirit of Hartshorn, Aqua
Ammonia
Waste
Haste
not
44%
Acetic Acid (Aqueous Solution)
Ammonium Hydroxide (containing
less than 12% but not more than
ammonia)
Haste Ammonium Hydroxide (containing
less than 12% ammonia)
Chromic Acid
Hydrobromic Acid
HBr
Hydrochloric Acid
HC1, Muriatic Acid
Hydrofluoric Acid
HF, Fluorohydric Acid
Lacquer, Paint, or Varnish Removing
Liquid
Nitrates
Nitric Acid
HNOj, Aquafortis
Haste
Chromic Acid Solution
Haste Hydrobromic Acid (more than 49%
strength)
Haste
Haste
Waste
Haste
Haste
Haste
Haste
Haste
Hydrochloric Acid
Hydrofluoric Acid Solution
Paint Related Material
Paint Related Material
Paint Related Material
Nitrate, NOSd
Nitric Acid (over 40%)
Nitric Acid (40% or less)
Corrosive
Corrosive
ORM-A
Corrosive
Corrosive
Corrosive
Corrosive
Material
Material
Material
Material
Material
Material
Corrosive Material
Combustible Liquid
Flammable Liquid
Oxidizer
Oxidizer
Corrosive
Material
UN2790
NA2672
NA2672
UN1755
UN1788
UN1789
UN1790
NA1760
NA1263
NA1263
NA1477
UN2031
NA1760
(EPA-Corrosive) ,
(EPA-Corrosive) ,
(EPA-Corrosive) ,
(EPA-EP Toxic0),
(EPA-Corrosive) ,
(EPA-Corrosive),
(EPA-Corrosive) ,
(EPA-Corrosive) ,
(EPA-Ignitable) ,
(EPA-Ignitable) ,
(EPA-Ignitable),
(EPA-Ignitable),
(EPA-Corrosive) ,
RQ
RQ
RQ
RQ
RQ
RQ
RQ
RQ
RQ
RQ
RQ
RQ
RQ
D002
D002
D002
D007
D002
D002
D002
D002
D001
D001
D001
D001
D002
O
1
to
N
-------
Table C-S (Continued)
DOT Information for Item 11 of the Uniform Hazardous Waste Manifest *
Waste Designation
Oleum
Fuming Sulfuric Acid
Perchloric Acid
Identifi-
cation
DOT Proper Shipping Name Hazard Class' No.
Haste Oleum Corrosive Material NA1831
Waste Perchloric Acid (501-721) Oxidizer UN1873
Waste Perchloric Acid (not over 50%) Oxidizer UN1802
Additional
Information
(EPA-Corrosive) , RQ
(EPA-Ignitable), RQ
(EPA-Ignitable), RQ
EPA
Hazardous
Waste No.
0002
0001
D001
Phosphoric Acid
H3PO4' ""Phosphoric acid
Potassium Hydroxide
KOH, Potassium Hydrate, Caustic
Potash, Potassa
Sodium Hydroxide
NaOH, Caustic Soda, Soda Lye,
Sodium Hydrate
Sulfuric Acid
H2SO4, Oil of Vitriol
Waste Phosphoric Acid
Waste Potassium Hydroxide Solution
Waste Sodium Hydroxide Solution
Waste Sulfuric Acid, Spent
Corrosive Material -, UN1805 (EPA-Corrosive), RQ D002
Corrosive Material UNI814 (EPA-Corrosive), RQ D002
Corrosive Material
UN1824
(EPA-Corrosive), RQ D002
O
I
Corrosive Material UN1832 (EPA-Corrosive), RQ D002 ^
Batteries (Lead-Acid)
Lead-Acid Batteries (Excluding Those Battery, Electric Storage, Wet,
Sent for Recycling) Filled with Acid
Corrosive Material UN2794 (EPA-Corrosive), RQ
D002
Heavy Metal Wastes
Heavy Metal Solutions
Aqueous Washing Solutions from
Ink Formulation, Ink Tub Washwater
Hazardous Waste, Liquid, HOS
ORM-E
NA9189 (K086), RQ
K086
-------
Tabla C-5 (Continued)
DOT Information for Item 11 of the Uniform Hazardous Waste Manifest
Waste Designation
Ignitable Wastes, NOS, Petroleum
Distillates
Ignitable Wastes, NOS, Solvents
Sludges with Chromium or Lead:
Ink Sludge with Chromium or Lead
Ink Sludge Containing Heavy
Metals
Waste:
Various Constituent Solvents:
Benzene
Carbon Tetrachloride
Chloroform
1 , 2-Dichloroethane
DOT Proper Shipping Name
Ignitable
Waste Combustible Liquid, NOS
Waste Flammable Liquid, NOS
Waste Flammable Solid, NOS
Waste Petroleum Distillates
Hazardous Waste, Solid, NOS
Hazardous Waste, Liquid, NOS
Waste Ink
Waste Ink
Waste Ink
Waste Ink
Waste Ink
Waste Ink
Waste Ink
Waste Ink
Hazard Class'
Wastes — NOS
Combustible Liquid
Flammable Liquid
Flammable Solid
Flammable Liquid
Ink
ORM-E
ORM-E
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Identifi-
cation
No.
NA1993
UN1993
UN1325
UN1268
NA9189
NA9189
UN2867
UN1210
UN2867
UN1210
UN2867
UN1210
UN2867
UN1210
Additional
Information
(EPA-Ignitable) , RQ
(EPA-Ignitable) , RQ
(EPA-Ignitable), RQ
(EPA-Ignitable), RQ
(K086), RQ
(K066), RQ
(F005), RQ
(F005), RQ
(FOOD, RQ
(FOOD, RQ
(U044), RQ
(U044), RQ
(EPA-Ignitable) , RQ
(EPA-Ignitable), RQ
EPA
Hazardous
Waste No.
D001
D001
D001
D001
K086
K086
O
1
to
•0.
F005
F005
F001
F001
U044
U044
D001
D001
-------
T«bl« C-5 (Continued)
«
DOT Information foe Item 11 of the Uniform Hazardous Waste Manifest
Waste Designation DOT Proper Shipping Name Hazard Class'
Ethyl Benzene Waste
Waste
Methylene Chloride Waste
Waste
Tetrachloroethylene Waste
Waste
Toluene Waste
Waste
1, 1, 1-Trichloroethane Waste
Waste
Trichloroethylene Waste
Waste
Various Constituents from Pigments:
Aluminum Waste
Haste
Cadmium Waste
Waste
Chromium Waste
Waste
Cobalt Waste
Waste
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Identifi-
cation Additional
No. Information
UN2867
UN1210
UN2867
UN1210
UN2867
UN1210
UN2867
UN1210
UN2867
UN1210
UN2867
UN1210
UN2867
UN1210
UN2867
UN1210
UN2867
UN1210
UN2867
UN1210
(F003), RQ
(F003), RQ
(F002), RQ
(F002), RQ
(F002), RQ
(F002>, RQ
(FOOS), RQ
(FOOS), RQ
(F002), RQ
(F002), RQ
(F002) , RQ
(F002), RQ
(EPA-Ignitable), RQ
(EPA-Ignitable) , RQ
(EPA-EP Toxic), RQ
(EPA-EP Toxic), RQ
(EPA-EP Toxic) , RQ
(EPA-EP Toxic), RQ
(EPA-Ignitable) , RQ
(EPA-Ignitable) , RQ
EPA
Hazardous
Waste No.
F003
F003
F002
F002
F002
F002
FOOS
FOOS
F002
F002
F002 O
F002 jo
Ui
.
D001
D001
Dooe
oooe
D007
D007
D001
D001
-------
Table C-S (Continued)
Waste Designation
Copper
Cyanide
Lead
Nickel
Benzene
Benzol
Chlorobenzene
Monochlorobenzene, Phenylchloride
Combustible Liquid
Enamel
Ethyl Benzene
Ethvlene Dichloride
DOT Information
DOT Proper Shipping Name
Waste
Waste
Waste
Waste
Haste
Waste
Waste
Waste
Waste
Waste
Waste
waste
Waste
waste
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Ink
Benzene
Chlorobenzene
Combustible Liquid, NOS
Compound, Enamel
Ethyl Benzene
Ethvlene Dichloride
*
for Item 11 of the Uniform Hazardous Waste Manifest
Hazard Class3
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Paint Wastes
Flammable
Flammable
Liquid
Liquid
Combustible Liquid
Flammable
Flammable
Flammable
Liquid
Liquid
Liquid
Identifi-
cation Additional
No. Information
UN2867
UN1210
UN2867
UN1210
UN2867
UN1210
UN2867
UN1210
UN1114
UN1134
NA1993
NA1263
UN1175
UN1184
(EPA-Ignitable)
(EPA-Ignitable)
(EPA-Ignitable)
(EPA-Ignitable)
(EPA-EP Toxic) ,
(EPA-EP Toxic),
(EPA-Ignitable)
(EPA-Ignitable)
(FOOS) , RQ
(F002), RQ
(EPA-Ignitable)
(EPA-Ignitable)
(F003), RQ
(EPA-Ignitable)
, RQ
, RQ
, RQ
, RQ
RQ
RQ
, RQ
, RQ
, RQ
, RQ
, RQ
EPA
Hazardous
Waste No.
D001
D001
D001
D001
D008
DOOB
D001
D001
FOOS 9
N)
a\
F002
D001
D001
F003
D001
1,2-Dichloroethane
Flammable Liquid
Waste Flammable Liquid, NOS
Flammable Liquid
UN1993
(EPA-Ignitable), RQ
D001
-------
Table C-5 (Continued)
«,
DOT Information for Item 11 of the Uniform Hazardous Haste Manifest
Haste Designation
Heavy Metal Paints with:
Chromium
Lead
DOT Proper Shipping Name
Hazardous Waste, Solid, NOS
Hazardous Haste, Liquid, NOS
Hazardous Haste, Solid, NOS
Hazardous Haste, Liquid, NOS
Identifi-
cation
Hazard Class3 No.
ORM-E NA9189
ORM-E NA91B9
ORM-E NA9189
ORM-E NA9189
Additional
Information
tEPA-EP Toxic) , RQ
(EPA-EP Toxic) , RQ
(EPA-EP Toxic) , RQ
(EPA-EP Toxic), RQ
EPA
Hazardous
Haste No.
D007
D007
DOOB
D008
Methyl Ethyl Ketone
MEK, Methyl Acetone, Meetco,
Butanone, Ethyl Methyl Ketone,
2-Butanone
Methyl Isobutyl Ketone
Shell MIBK
Paint, Enamel, Lacquer, Stain,
Shellac, Varnish, Polishes,
Fillers, Lacquer Base, and
Thinners
Paint Dryer
Toluene
Toluol
Carbon Tetrachloride
Perchloromethane, Necatorina,
Benzinoform, CC1,
Haste Methyl Ethyl Ketone
Haste Flammable Liquid, NOS
Flammable Liquid
Flammable Liquid
UN1193
(FOOS), RQ
Haste Paints, Enamels, Lacquers, Stains, Flammable Liquid
Shellac, Varnish, Polishes, Fillers,
Lacquer Base, Thinners
Waste Paints, Enamels, Lacquers, Stains, Combustible Liquid
Shellac, Varnish, Polishes, Fillers,
Lacquer Base, Thinners
Haste Paint Dryer, Liquid
Flammable Liquid
Haste Toluene
Combustible Liquid
Flammable Liquid
Photographic Processing Hastes
Haste Carbon Tetrachloride ORM-A
UN1993 (F003), RQ
UN1263 (EPA-Ignitable), RQ
UN1263 (EPA-Ignitable), RQ
UN1168 (EPA-Ignitable), RQ
UN116B (EPA-Ignitable), RQ
UN1294 (FOOS), RQ
UN1846 (U211), RQ
FOOS
F003
DOOI
D001
DOOI
DOOI
FOOS
U211
O
I
ts)
-------
Table C-5 (Continued)
Waste Designation
Cyanide-Containing Liquids
Heavy-Metal-Containing Liquids
Photographic Processing Waste
Containing :
Cadmium
Chromium
Lead
Silver
Trichloroethylene
Trichloroethene, Ethinyl Trichloride,
Tri-Clene, Trielene, Tri
Spent Plating Wastes:
Wastewater Treatment Sludges from
Electroplating Operations Except
DOT Information
DOT Proper Shipping Name
Cyanide Solution, NOS
Hazardous Haste, Liquid, NOS
Hazardous Waste, Liquid, NOS
Hazardous Waste, Liquid, NOS
Hazardous Haste, Liquid, NOS
Haste Trichloroethylene
Hazardous Waste, Solid, NOS
Hazardous Waste, Liquid, NOS
for Item 11 of the Uniform
Hazard Class*
Poison B
ORM-E
ORM-E
ORM-E
ORM-E
ORM-A
Plating Hastes
ORM-E
ORM-E
Hazardous Haste Manifest
Identifi-
cation
No.
UN1935
NA9189
NA9189
NA9189
NA9189
UN1710
NA9189
NA9189
Additional
Information
(P030), RQ
(D006), RQ
(D007), RQ
(DOOB), RQ
(D011), RQ
(F002), RQ
(F006), RQ
(F006I, RQ
EPA
Hazardous
Haste No.
P030
D006
D007
DOOB
D011
F002
O
N)
CO
F006
F006
from the Following Processes: (1)
Sulfuric Acid Anodizing of Aluminum,
(2) Tin Plating on Carbon Steel, (3)
Zinc Plating (Segregated Basis) on
Carbon Steel, (4) Aluminum or
Zinc-Aluminum Plating on Carbon
Steel, (5) Cleaning and Stripping
Associated with Tin, Zinc, and
Aluminum Plating on Carbon Steel,
and (6) Chemical Etching and Milling
of Aluminum
-------
Table C-5 (Continued)
DOT Information for
Item 11 of the Uniform Hazardous Waste Manifest
Identifi-
Waste Designation
Spent Cyanide Plating Bath Solutions
from Electroplating Operations
Plating Sludges from the Bottom of
Plating Baths from Electroplating
Operations Where Cyanides Are Used
in the Process
Spent Stripping and Cleaning Bath
Solutions from electroplating Opera-
tions Where Cyanides Are Used in the
Process
Acetone
Aromatic Hydrocarbons
Benzene
Benzol
n-Butyl Acetate
n-Butyl Alcohol
DOT Proper Shipping Name
Hazardous Haste, Solid, NOS
Hazardous Waste, Liquid, NOS
Hazardous Waste, Solid, NOS
Hazardous Waste, Liquid, NOS
Hazardous Waste, Solid, NOS
Hazardous Waste, Liquid, NOS
Solvent Wastes
Waste Acetone
Haste Flammable Liquid, NOS
Haste Combustible Liquid, NOS
Haste Benzene
Haste n-Butyl Acetate
Haste Butyl Alcohol
Hazard Class*
ORM-E
ORM-E
ORM-E
ORM-E
ORM-E
ORM-E
(see also Paint Wastes)
Flammable Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Flammable Liquid
Flammable Liquid
cation
No.
NA9189
NA9189
NA9189
NA91B9
NA9189
NA9189
UN1090
UN1993
NA1993
UNI 1M
UNI 123
NA1120
Additional
Information
(F007), RQ
(F007), RQ
(F008), RQ
(F008), RQ
(F009), RQ
(F009), RQ
(F003), RQ
(EPA-Ignitable) , RQ
(EPA-Ignitable) , RQ
(FOOS), RQ
(EPA-Ignitable), RQ
(F003), RQ
EPA
Hazardous
Waste No.
FOOT
F007
F008
FOOS
F009
F009
0
F003 K>
vo
D001
D001
FOOS
D001
F003
sec-Butyl Alcohol, terc-Butyl Alcohol
Carbon Tetrachloride
Carbon Tet, Tetrachloromethane,
Perchloromethane, Tetraform, Carbona,
Halon 104, Necatorina, Benzinoform,
CC1.
Waste Carbon Tetrachloride
ORM-A
UN1846 (FOOD, RQ
F001
-------
Table C-S (Continued)
Waste Designation
Chlorobenzene
Monochlorobenzene, Phenylchloride
Chloroform
Trichloromethane
Dichlorobenzene
o-Dichlorobenzene
1, 4-Dioxane
DOT Information for Item
DOT Proper Shipping Name
Haste Chlorobenzene
Waste Chloroform
Waste Dichlorobenzene, Ortho, Liquid
Waste Dioxane
11 of the Uniform Hazardous, Waste
Identif
cation
Hazard Class* No.
Flammable Liquid UNI 134
ORM-A UN1888
ORM-A UN1591
Flammable Liquid UN1165
Manifest
i-
Additional
Information
(F002), RQ
.
(U044), RQ
(F002), RQ
(EPA-Ignitable), RQ
t.
EPA
Hazardous
Waste No.
F002
U044
F002
D001
Diethylene Ether, 1, 4-Diethylene Oxide,
Diethylene Oxide, Dioxyethylene Ether
Ethanol
Ethyl Alcohol, Grain Alcohol
Ethyl Acetate
Ethyl Benzene
Ethyl Ether
Ether, Diethyl Ether, Diethyl Oxide
Ethylene Dichloride
1, 2-Dichloroethane
Formalin
Formaldehyde Solution:
Flashpoint Greater Than 141 °F:
- Containers of 110 Gallons or
Less
- Containers of More Than 110
Waste Ethyl Alcohol
Waste Ethyl Acetate
Waste Ethyl Benzene
Waste Ethyl Ether
Waste Ethylene Dichloride
Haste Formaldehyde Solution
Waste Formaldehyde Solution
Flammable Liquid UN1170
Flammable Liquid UN1173
Flammable Liquid UN1175
Flammable Liquid UN1155
Flammable Liquid UN1184
ORM-A UN2209
Combustible Liquid UN2209
(EPA-Ignitable) , RQ
(F003) , RQ
(F003), RQ
(EPA-Ignitable), RQ
(EPA-Ignitable), RQ
(U122), RQ
(U122), RQ
D001
O
F003 CO
o
F003
D001
D001
U122
U122
Gallons
-------
Table C-S (Continued)
Waste Designation
DOT Information for Item 11 of the Uniform Hazardous Waste Manifest
DOT Proper Shipping Name
Hazard Classa
Identifi-
cation
No.
Additional
Information*
EPA
Hazardous
Waste No.
FlashPoint Less Than or Equal
To 141 °F:
- Containers of 110 Gallons
or Less
- Containers of More Than 110
Gallons
Glycol Ethers
May Include Numerous Compounds,
Including Diethylene Glycol and
Hexylene Glycol
Heptane
Heptane
Hexachloroethane
1,1,1,2, 2,2-Hexachloroethane
Hexane
n-Hexane
Ignitable Liquids
Isopropanol
Isopropyl Alcohol, TPA, Dimethyl
Carbinol, 2-Propanol
Isopropyl Acetate
Isopropyl Acetate
Kerosene
Kerosene, Fuel Oil No. 1
Waste Formaldehyde Solution
Waste Formaldehyde Solution
Waste Combustible Liquid, NOS
Waste Heptane
Waste Hexachloroethane
Waste Hexane
Haste Flammable Liquids, NOS
Waste Combustible Liquids, NOS
Waste Isopropanol
Waste Isopropyl Acetate
Waste Kerosene
ORM-A UN1198 (EPA-Ignitable), RQ D001
Combustible Liquid UN119B (EPA-Ignitable), RQ D001
Combustible Liquid NA1993 (EPA-Ignitable), RQ D001
Flammable Liquid
ORM-A
Flammable Liquid
Flammable Liquid
Combustible Liquid
Flammable Liquid
Flammable Liquid
UN1206 (EPA-Ignitable), RQ D001
NA9037 (U131), RQ U131
UN1208 (EPA-Ignitable), RQ D001
UN1993 (EPA-Ignitable), RQ D001
NA1993 (EPA-Ignitable), RQ D001
UN1219 (EPA-Ignitable), RQ D001
UN1220 (EPA-Ignitable), RQ D001
Combustible Liquid UN1223 (EPA-Ignitable), RQ D001
-------
Table C-5 (Continued)
Waste Designation
Methanol
Methyl Alcohol, Wood Alcohol
Methyl Ethyl Ketone
Methyl Acetone, Meetco, Butanone,
MEK, 2-Butanone, Ethyl Methyl Ketone
Methyl Isobutyl Ketone
MIBK
Methylene Chloride
Dichloromethane, Methane Dichloride,
Methylene Bichloride, NCI-CS0102,
Methylene Dichloride, Solaesthin,
Aerothene NM, Narkotil, Solmethine
Naphtha
Mineral Spirits, V.M.tP. Naphtha,
White Spirits
Pentane
Perchloroethylene
Perc, Tetrachloroethylene
Petroleum Distillate
Petroleum Ether
Petroleum Solvents
DOT Information for
DOT Proper Shipping Name
Waste Methyl Alcohol
Haste Methyl Ethyl Ketone
Haste Flammable Liquid, NOS
Haste Methylene Chloride
Haste Naphtha
Waste Naphtha
Haste Pentane
Waste Perchloroethylene
Waste Petroleum Distillate
Haste Petroleum Distillate
Waste Petroleum Ether
Haste Petroleum Distillate
Haste Petroleum Naphtha
Haste Petroleum Naphtha
Item 11 of the Uniform Hazardous Haste Manifest »
Hazard Class"
Flammable Liquid
Flammable Liquid
Flammable Liquid
ORM-A
Combustible Liquid
Flammable Liquid
Flammable Liquid
ORM-A
Combustible Liquid
Flammable Liquid
Flammable Liquid
Combustible Liquid
Combustible Liquid
Flammable Liquid
Identifi-
cation
No.
UN1230
UN1193
UN1993
UN1593
UN2SS3
UN2553
UN1265
UNI 8 97
UN1268
UN1268
UN1271
UN1268
UN1255
UN12SS
Additional
Information
(F003), RQ
(F005), RQ
(F003), RQ
(FOOD, RQ
(F002), RQ
(EPA-Ignitable),
(EPA-Ignitable),
(EPA-Ignitable) ,
(FOOD, RQ
(F002), RQ
(EPA-Ignitable) ,
(EPA-Ignitable) ,
(EPA-Ignitable) ,
(EPA-Ignitable) ,
(EPA-Ignitable) ,
(EPA-Ignitable) ,
RQ
RQ
RQ
RQ
RQ
RQ
RQ
RQ
RQ
EPA
Hazardous
Waste No.
F003
FOOS
F003
F001e
F002f
0
D001 CO
D001 M
D001
F0018
F002f
D001
D001
D001
D001
D001
D001
-------
Table C-5 (Continued)
DOT Information for
Item 11 of the Uniform Hazardous Waste
Manifest
Identifi- EPA
cation Additional Hazardous
Waste Designation DOT Proper Shipping Name
Phenol Waste Phenol
Waste Phenol (tar acid containing
over 50* phenol)
Propyl Alcohol Waste Propyl Alcohol
Propanol
Tetrachloroethylene Waste Tetrachloroethylene
Perchloroethylene, Perc, Tetralex,
Perawin, Perclene, Terlen, Didakene,
TetraCap, Antisal 1, Fedad-UN, Neme
Gemalgene, Perm-A-Clor, TCE, Benzinol,
Dow-Tri, Nialk, Vestrol, Trielin, PCE
Tetrahydrofuran Waste Tetrahydrofuran
THF
Hazard Class3 No.
Poison B UN1671
Poison B NA2821
Flammable Liquid UN1274
ORM-A ON1897
Flammable Liquid UN2056
Information*1 Waste No.
(U188), RQ U188
(U188), RQ U188
(EPA-Ignitable), RQ D001
(F001), R(j F001e
(F002), RQ F002f
(EPA-Ignitable), RQ D001
O
1
Toluene
Methacide, Methylbenzene,
Methylbenzol, Phenylmethane,
Toluol, Antisal 1A
Toluene Diisocyanate
1,1,1-Trichloroethane
Aerothane TT, Chlorten, Inhibisol,
Trichloroethane, Chlorothene NU,
NCI-C04626, Methylchloroform,
Chlorothene VG, Chlorothane NU,
Chlorotene
Waste Toluene
Waste Toluene Diisocyanate
Waste 1,1,1-Trichloroethane
Flammable Liquid
Poison B
ORM-A
UN1294 (FOOS), RQ
UN2076 (U223), RQ
UN2831 (FOOD, RQ
(F002), RQ
F005
U223
F001C
F0021
-------
Table C-5 (Continued)
DOT Information for
Waste Designation DOT Proper Shipping Name
Trichloroethylene Waste Trichloroethylene
Perm-A-chlor, Trielin, Triline,
Triol, Vestrol, Chlorylene,
Dow-Tri, Vitran, TCE, Nialk,
Philex, Tri-Clene
Trichlorotrif luoroethane Hazardous Waste, Liquid, NOS
Fluorocarbon 113, Freon 113,
Ucon 113, Frigen 113, 113TR-T,
Eakimon 11, Ucon 11, Isotron 11,
Freon 11, Freon MF, Fluorochloroform,
Arcton 9, Freon TE-35,
Freon T-ES 35, Freon TMC, Freon TF,
Arcton 63
Valclene Hazardous Waste, NOS
Varsol Haste Naphtha
White Spirits, Mineral Spirits, Waste Naphtha
Naphtha
White Spirits, Varsol Haste Naphtha
Mineral Spirits, Naphtha Haste Naphtha
Item 11 of the Uniform Hazardous Waste Manifest
Identifi-
cation
Hazard Classa No.
ORM-A UN1710
ORM-E NA9169
ORM-E UN9189
Flammable Liquid UN1256
Combustible Liquid UN12S6
Flammable Liquid UN2SS3
Combustible Liquid UN2553
EPA
Additional Hazardous
Information Waste No.
(F001), RQ F001
(F002), RQ F002
(FOOD, RQ F001
(F002), RCf F002
(F002), RQ F002
(EPA-Ignitable), RQ D001 W
(EPA-Ignitable), RQ D001 *
(EPA-Ignitable), RQ D001
(EPA-Ignitable), RQ D001
-------
Table C-S (Continued)
DOT Information for Item 11 of the Uniform Hazardous Waste Manifest ,
Identifi-
cation
Waste Designation DOT Proper Shipping Name Hazard Class3 Mo.
Additional
Information
EPA
Hazardous
Haste No.
Xylene
Xylol, Dimethyl Benzene
Haste Xylene
Flammable Liquid UN1307 (F003), RQ
F003
"Combustible" means that the flashpoint is less than 200 °F and greater than or equal to 100 °F; "flammable" means that the flashpoint is
less than 100 °F. V
The EPA hazardous waste number may be used in parenthesis in place of "EPA-" and the characteristic. The letters "RQ" may also appear before
the DOT proper shipping name. "RQ" is only required for materials that contain 100 Ibs. in one package, that ate wastes, and that exhibit the
characteristics of ignitability, corrosivity, or reactivity.
CEP toxic. Extraction Procedure toxic.
TJOS, Not otherwise specified.
eDegreasing use.
Other use.
O
CJ
in
-------
D-1
*
APPENDIX D
SOURCES OF ADDITIONAL INFORMATION
CONTENTS
D.I U.S. EPA Regional Offices D-1
D.2 State Hazardous Waste Management Agencies D-3
The following sources are available for assistance to educational
institutions in identifying and minimizing hazardous waste generation. These
include the EPA RCRA/Superfund Hotline (1-800-424-9346; in Washington, D.C.,
382-3000) and the EPA Small Business Ombudsman Hotline (1-800-368-5888; in
Washington, D.C., 557-1938). The National Response Center's function is to
receive reports of hazardous substance releases under CERCLA, oil discharges
under the Clean Water Act, and certain spill reporting requirements under RCRA
(e.g., §265.56(d)(2)) (1-800-424-8802; in Washington, D.C., 267-2675).
Many State hazardous waste management agencies and EPA regional offices
provide information to small businesses to help them identify and minimize
hazardous waste. This information could also help educational institutions.
An earlier EPA publication, Understanding the Small Quantity Generator
Hazardous Waste Rules: A Handbook for Small Business, contains complete
information for contacting State hazardous waste management agencies and EPA
regional offices. The handbook is widely available from trade associations,
State agencies, and the EPA RCRA/Superfund Hotline.
For facilities in States authorized to implement the RCRA hazardous waste
program, the authorized States are the best sources of additional
information. The best sources of information on facilities in States not yet
authorized (marked "unauthorized" in Section D.2) are the appropriate EPA
Regional Offices. The information on regional and State sources of
information in Sections D.I and D.2 is current as of June 1, 1988.
O.I U.S. EPA REGIONAL OFFICES
EPA Region I (Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island,
Vermont)
State Waste Programs Branch
JFK Federal Building
Boston, MA 02203
(617) 565-3698
EPA Region II (New Jersey, New York, Puerto Rico, Virgin Islands)
Air and Waste Management Division
26 Federal Plaza
New York, NY 10278
(212) 264-5175
-------
D-2
EPA Region III (Delaware, District of Columbia, Maryland, Pennsylvania,
Virginia, West Virginia)
Waste Management Branch
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-0980
EPA Region TV (Alabama, Florida, Georgia, Kentucky, Mississippi, North
Carolina, South Carolina, Tennessee)
Hazardous Waste Management Division
345 Courtland Street, NE.
Atlanta, GA 30365
(404) 347-3016
EPA Region V (Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin)
RCRA Activities Section
230 South Dearborn Street
Chicago, IL 60604
(312) 886-4434
EPA Region VI (Arkansas, Louisiana, New Mexico, Oklahoma, Texas)
Air and Hazardous Materials Division
1445 Ross Avenue
Dallas, TX 75202
(214) 655-6750
EPA Region VII (Iowa, Kansas, Missouri, Nebraska)
RCRA Branch
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2852
EPA Region VTII (Colorado, Montana, North Dakota, South Dakota, Utah,
Wyoming)
RCRA Implementation Branch
Waste Management Division (8HWM-RI)
999 18th Street, Suite 500
Denver, CO 80202-2405
(303) 293-1800
For Colorado and Montana: (303) 293-1798
For North Dakota and Utah: (303) 293-1500
For South Dakota and Wyoming: (303) 293-1790
EPA Region IX (American Samoa, Arizona, California, Guam, Hawaii, Nevada,
Trust Territories of the Pacific)
Toxics and Waste Management Division
215 Fremont Street
San Francisco, CA 94105
(415) 974-7472
-------
D-3
EPA Region X (Alaska, Idaho, Oregon, Washington)
Waste Management Branch (HW-112)
1200 6th Avenue
Seattle, WA 98101
(206) 442-2777
D.2 STATE HAZARDOUS WASTE MANAGEMENT AGENCIES
Alabama
Alabama Department of Environmental Management
Land Division
1751 Federal Drive
Montgomery, AL 36130
(205) 271-7730
Alaska (Unauthorized) (Call Regional Office first)
Department of Environmental Conservation
P.O. Box 0
Juneau, AK 99811
Program Manager: (907) 465-2666
Northern Regional Office (Fairbanks): (907) 452-1714
South-Central Regional Office (Anchorage): (907) 563-6529
Southeast Regional Office (Juneau): (907) 789-3151
American Samoa
Environmental Quality Commission
Government of American Samoa
Pago Pago, American Samoa 96799
Call regional office for Hawaii
Overseas operator (commercial call, (684) 663-4116)
Arizona
Arizona Department of Health Services
Office of Waste and Water Quality
2005 North Central Avenue, Room 304
Phoenix, AZ 85004
Hazardous Waste Management: (602) 257-2211
Arkansas •
Department of Pollution Control and Ecology
Hazardous Waste Division
P.O. Box 9583
8001 National Drive
Little Rock, AR 72219
(501) 562-7444
-------
D-4
California (Unauthorized) (Call Regional Office first)
Department of Health Services
Toxic Substances Control Division
714 P Street, Room 1253
P.O. Box 942732
Sacramento, CA 94234-7230
<916) 324-1826
or
State Water Resources Control Board
Division of Water Quality
P.O. Box 100
Sacramento, CA 95801
(916) 322-2867
Colorado
Colorado Department of Health
Waste Management Division
4210 East llth Avenue
Denver, CO 80220
(303) 320-8333 (ext. 4364)
Connecticut (Unauthorized) (Call Regional Office first)
Department of Environmental Protection
Hazardous Waste Management Section
State Office Building
165 Capitol Avenue
Hartford, CT 06106
(203) 566-8843, -8844
Delaware
Department of Natural Resources and Environmental Control
Waste Management Section
89 Kings Highway
P.O. Box 1401
Dover, DE 19903
(302) 736-4781
District of Columbia
Department of Consumer and Regulatory Affairs
Pesticides and Hazardous Waste Management Branch
Room 114
5010 Overlook Avenue, SW.
Washington, DC 20032
(202) 783-3192
Florida
Department of Environmental Regulation
Solid and Hazardous Waste Section
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, FL 32399-2400
(904) 488-0300
-------
D-5
Georgia
Georgia Environmental Protection Division
Hazardous Waste Management Program
Land Protection Branch
Floyd Towers East, Suite 1154
205 Butler Street, SE.
Atlanta, GA 30334
(404) 656-2833; toll free, (800) 334-2373
Guam
Guam Environmental Protection Agency
P.O. Box 2999
Agana, GU 96910
Call regional office for Hawaii
Overseas operator (commercial call, (671) 646-7579)
Hawaii (Unauthorized) (Call Regional Office first)
Department of Health
Noise and Radiation Division
P.O. Box 3378
Honolulu, HI 96801
(808) 548-4383
Idaho (Unauthorized) (Call Regional Office first)
Department of Health and Welfare IDHW-DEQ
Bureau of Hazardous Materials
Towers Building, 3d Floor
450 West State Street
Boise, ID 83720
(208) 334-5879
Illinois
Environmental Protection Agency
Division of Land Pollution Control
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794-9276
(217) 782-6761
Indiana
Department of Environmental Management
Office of Solid and Hazardous Waste
105 South Meridian Street
Indianapolis, IN 46225
(317) 232-4518, -4535
Iowa (Unauthorized) (Call Regional Office first)
U.S. EPA Region VII
Hazardous Materials Branch
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2887
-------
D-6
Kansas
Department of Health and Environment
Bureau of Waste Management
Forbes Field, Building 730
Topeka, KS 66620
(913) 296-1500, -1607
Kentucky
Natural Resources and Environmental Protection Cabinet
Division of Waste Management
18 Reilly Road
Frankfort, KY 40601
(502) 564-6716
Louisiana
Department of Environmental Quality
Hazardous Waste Division
P.O. Box 44307
Baton Rouge, LA 70804
(504) 342-4677
Main*
Department of Environmental Protection
Bureau of Oil and Hazardous Materials Control
State House Station No. 17
Augusta, ME 04333
(207) 289-2651
Maryland
Department of Health and Mental Hygiene
Maryland Waste Management Administration
Office of Environmental Programs
201 West Preston Street, Room 2A3
Baltimore, MD 21201
(301) 225-5709
Massachusetts
Department of Environmental Quality Engineering
Division of Solid and Hazardous Waste
1 Winter Street, 5th Floor
Boston, MA 02108
(617) 292-5589, -5851
Michigan
Michigan Department of Natural Resources
Hazardous Waste Division
Waste Evaluation Unit
Box 30028
Lansing, MI 48909
(517) 373-2730
-------
D-7
Minnesota
Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road North
St. Paul, MN 55155
(612) 296-6300, 297-1784
Mississippi
Department of Natural Resources
Division of Solid and Hazardous Waste Management
P.O. Box 10385
Jackson, MS 39209
(601) 961-5062
Missouri
Department of Natural Resources
Waste Management Program
P.O. Box 176
Jefferson City, MO 65102
(314) 751-3176
Missouri Hotline: (800) 334-6946
Montana
Department of Health and Environmental Sciences
Solid and Hazardous Waste Bureau
Cogswell Building, Room B-201
Helena, MT 59620
(406) 444-2821
Nebraska
Department of Environmental Control
Hazardous Waste Management Section
Call No. 98922
State House Station
Lincoln, NE 68509-8922
(402) 471-2186
Nevada
Division of Environmental Protection
Waste•Management Program
201 South Fall, Room 120
Carson City, NV 89710
(702) 885-4670, -5872
New Hampshire
Department of Environmental Services
Waste Management Division
6 Hazen Drive
Concord, NH 03301-6509
(603) 271-2942
-------
D-8
New Jersey
Department of Environmental Protection
Division of Waste Management
401 East State Street
Trenton, NJ 08625
Hazardous Waste Advisement Program: (609) 292-8341, -9880
Naw Mexico
Environmental Improvement Division
Hazardous Waste Section
P.O. Box 968
Santa Fe, MM 87504-0968
(505) 827-2922
Naw York
Department of Environmental Conservation
Bureau of Hazardous Waste Operations
50 Wolf Road, Room 207
Albany, NY 12233
(518) 457-0530
New York Small Quantity Generator Hotline: (800) 631-0666
North Carolina
Department of Human Resources
Solid and Hazardous Waste Management Branch
P.O. Box 2091
Raleigh, NC 27602
(919) 733-2178
North Dakota
Department of Health
Division of Hazardous Waste Management and Special Studies
1200 Missouri Avenue, Room 302
Bismarck, ND 58502-5520
(701) 224-2366
Northern Mariana Islands, Commonwealth of
Department of Environmental and Health Services
Division of Environmental Quality
P.O. Box 1304
Saipan, Commonwealth of Mariana Islands 96950
Call regional office for Hawaii
Overseas call, (670) 234-6984
Ohio (Unauthorized) (Call Regional Office first)
Ohio EPA
Division of Solid and Hazardous Waste Management
1800 Water Mark Drive
P.O. Box 1049
Columbus, OH 43266-0149
(614) 644-2956, -2934
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Oklahoma
Waste Management Service
Oklahoma State Department of Health
1000 Northeast 10th Street
P.O. Box 53551
Oklahoma City, OK 73152
(405) 271-5338
Oregon
Department of Environmental Quality
Hazardous and Solid Waste Division
811 Southwest 6th Avenue
Portland, OR 97204
(503) 229-5913
Toll free: (800) 452-4011
Pennsylvania
Department of Environmental Resources
Bureau of Waste Management
Division of Compliance Monitoring
P.O. Box 2063
Harrisburg, PA 17120
(717) 787-6239, -9870
Puerto Rico (Unauthorized) (Call Regional Office first)
Environmental Quality Board
P.O. Box 11488
Santurce, PR 00910-1488
(809) 723-8184
Rhode Island
Department of Environmental Management
Division of Hazardous Waste
Cannon Building, Room 204
75 Davis Street
Providence, RI 02908
(401) 277-2797
South Carolina
Department of Health and Environmental Control
Bureau of Solid and Hazardous Waste Management
2600 Bull Street
Columbia, SC 29201
(803) 734-5200
South Dakota
Department of Water and Natural Resources
Office of Air Quality and Solid Waste
Foss Building, Room 416
Pierre, SD 57501
(605) 773-3153
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Tennessee
Division of Solid Waste Management
Tennessee Department of Public Health
Customs House, 4th Floor
701 Broadway
Nashville, TN 37219-5403
(615) 741-3424
Texas
Texas Hater Commission
Attn: Hazardous and Solid Waste Division
Compliance Assistance Unit
P.O. Box 13807, Capitol Station
Austin, TX 78711-3087
(512) 463-7760
Utah
Department of Health
Bureau of Solid and Hazardous Waste Management
288 North 1460 West
P.O. Box 16700
Salt Lake City, UT 84116-0700
(801) 538-6170
Vermont
Agency of Environmental Conservation
Waste Management Division
103- South Main Street
Waterbury, VT 05676
(802) 244-8702
Virgin Islands (Unauthorized) (Call Regional Office first)
Department of Conservation and Cultural Affairs
P.O. Box 4399
Charlotte Amalie, St. Thomas, VI 00801
(809) 774-3320
Virginia
Department of Health
Division of Solid and Hazardous Waste Management
Monroe Building, llth Floor
101 North 14th Street
Richmond, VA 23219
(804) 225-2667
Hazardous Waste Hotline: (800) 552-2075
Washington
Department of Ecology
Solid and Hazardous Waste Program
Mail Stop PV-11
Olympia, WA 98504-8711
(206) 459-6322, -6305, -6913
In-State: 1-800-633-7585 (for disposal of household hazardous waste)
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West Virginia
Waste Management Division
1260 Greenbrier Street
Charleston, WV 25311
(304) 348-5935
Wisconsin
Department of Natural Resources
Bureau of Solid Waste Management
P.O. Box 7921
Madison, WI 53707
(608) 267-7554
Wyoming (Unauthorized) (Call Regional Office first)
Department of Environmental Quality
Solid Waste Management Program
122 West 25th Street
Cheyenne, WY 82002
(307)777-7752
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E-1
4
APPENDIX E
ORGANIZATIONS COMMENTING ON THE REPORT
CONTENTS
E.I Federal Agencies E-1
E.2 States E-1
E.3 Educational and Other Associations E-1
E.4 Universities and Other Educational Institutions E-1
E.I FEDERAL AGENCIES
U.S. Department of Education:
Office of the Assistant Secretary for Vocational and Adult Education
Office of Special Education and Rehabilitative Services
E.2 STATES
Connecticut (Department of Environmental Protection)
Illinois (Environmental Protection Agency)
Maryland (Department of the Environment)
Nebraska (Department of Environmental Control)
New Hampshire (Department of Education)
New Jersey (Department of Education)
Texas (Water Commission)
Wisconsin (Board of Vocational, Technical and Adult Education)
E.3 EDUCATIONAL AND OTHER ASSOCIATIONS
American Association of School Administrators
American Chemical Society
Association of State and Territorial Solid Waste Management Officials
(forwarded three States' comments)
National Association of College and University Business Officers
E.4 UNIVERSITIES AND OTHER EDUCATIONAL INSTITUTIONS
Washington State University
University of Washington
University of Illinois at Urbana-Champaign
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F-l
APPENDIX F
RESPONSES TO QUESTIONS ON EPA' a HAZARDOUS WASTE MANAGEMENT REGULATIONS
CONTENTS
F.I Reuse of Reagents ...................... F-l
F.2 Land Disposal of Lab Packs ................. F-l
F.3 Batch Treatment of Wastes .................. F-2
F.4 Waste Minimization Certification .............. F-2
F.5 Waste Treatment in Accumulation Tanks ............ F-3
F.6 Lab Packs As Disposal Units ................. F-3
F.7 Definition of "On-Site" ................... F-3
F.I REUSE OF REAGENTS
EPA should encourage recycling and reuse of discarded laboratory
reagents. (American Chemical Society (ACS), October 23, 1987; University of
Illinois at Urbana-Champaign, October 18, 1987)
Response :
EPA interprets this comment as referring to the reuse of unwanted
laboratory reagents. Section 261.2 of 40 CFR defines a solid waste as any
discarded material, which has been abandoned, recycled, or considered
inherently wastelike. Section 261. 2 (e) states that materials are not solid
wastes when they can be shown to be recycled or reused as effective
substitutes for commercial products. Laboratory reagents that are physically
located in stockrooms and awaiting transfer from one user to another, are
covered by §261. 2 (e); that is, they are not solid wastes.
F.2 LAND DISPOSAL OF LAB PACKS
Comment:
EPA should reauthorize the landfilling of laboratory waste in lab packs,
with certain restrictions, because lab packs represent an exceptionally small
percentage of the total wastes now being landfilled and there are no feasible
alternative disposal options for small quantities of some materials.
Additionally, in some cases', there are no economical alternatives to disposal
of these materials in landfills. (ACS, October 23, 1987)
Response :
Section 3004 (d) (2) (B) of the Resource Conservation and Recovery Act (RCRA)
prohibits land disposal of wastes containing certain metals above specific
concentrations. RCRA Section 3004 (e) (2) (B) prohibits the land disposal of '
flammable solvents (if they are categorized under EPA Hazardous Waste Number
F003) . Furthermore, RCRA requires EPA to ban the land disposal of untreated
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F-2
wastes on a schedule published on May 28, 1986. EPA cannot postpone
implementing present and proposed bans on the land disposal of hazardous
wastes, but these actions are required by law.
The reader should note, however, that wastes from conditionally exempt
small quantity generators are not subject to the land disposal restrictions
regulations (40 CFR 268), provided that these wastes are managed in accordance
with regulations under §261.5.
F.3 BUTCH TREATMENT OF WASTES
Comment:
EPA should allow batch treatment of laboratory wastes in quantities not
exceeding five gallons under controlled conditions. (ACS, October 23, 1987)
Response:
EPA regulations already allow certain types of on-site treatment in
elementary neutralization units and wastewater treatment units (as defined in
40 CFR 260.10), in tanks under §262.34(a) and (d), and in reclamation devices
(under §261.6(c) because the recycling process itself is exempt from
regulation).
F.4 HASTE MINIMIZATION CERTIFICATION
Comment:
Only large quantity generators are required to certify waste minimization
efforts on manifests. Only a few schools, mostly large universities, are
regulated as large quantity generators. (ACS, October 23, 1987)
Response:
The comment is incorrect. RCRA Section 3002(b) requires that the manifest
for a large quantity generator certify that it has a program to reduce the
volume or quantity and toxicity of the waste and that the proposed method of
treatment, storage, or disposal is one that minimizes the present and future
threat to human health and the environment. A rulemaking published in the
federal Register (51 FR 35190, October 1, 1986) modifies the requirements
for small quantity generators to require waste a minimization certification to
read as follows:
"If I am a large quantity generator, I certify that I have a program in
place to reduce the volume and toxicity of waste generated to the degree I
have determined to be economically practicable and I have selected the
practicable method of treatment, storage, or disposal currently available to
me which minimizes the present and future threat to human health and the
environment; OR, if I am a small quantity generator, I have made a good faith
effort to minimize my waste generation and select the best waste management
method that is available to me and that I can afford.'V
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F-3
F.5 WASTE TREATMENT IN ACCUMULATION TANKS
Comment:
The statement that "all on-site treatment in accumulation tanks also is
exempt from regulation" is not accurate. (ACS, October 23, 1987)
Response:
As mentioned in Section F.3, a generator can treat hazardous waste in
tanks without a permit under 40 CFR 262.34(a) and (d), as long as the
treatment does not fall under any part of the regulations (for example,
thermal treatment), and provided that certain requirements are met. However,
if a generator accumulates hazardous wastes in tanks or containers for more
than 90 days, the generator becomes an operator of a treatment, storage, or
disposal facility and becomes subject to the requirements of 40 CFR Parts 264
and 265 and the permit requirements of 40 CFR Part 270.
F.6 LAB PACKS AS DISPOSAL UNITS
Comment:
It is misleading to assume that landfill bans must have a significant
impact on the disposal of all laboratory chemicals. The term "lab pack" is
now far more appropriate in describing a packaging unit rather than a disposal
unit. . . . (ACS, October 23, 1987)
Response:
The Hazardous and Solid Waste Amendments of 1984 did not specifically
address lab packs. If lab packs contain banned hazardous wastes, they are
prohibited from being land disposed. Lab packs may be used as storage,
transportation, and, if they do not contain banned wastes, disposal units.
F.7 DEFINITION OF "ON-SITE"
Comment:
Many colleges and universities have asked for clarification on the issue
of filing for generator identification numbers and the determination of
eligibility for status as a small quantity generator. Most of these
institutions would like to file for only one identification number for the
many buildings situated on their campuses so that they can maintain single
"administrative umbrellas" over their several individual points of generation
(for example, laboratories, central chemical storage areas, maintenance shops,
power plants). The physical layouts of many campuses tend to confuse the
issue of how many notification forms to file. Some campuses, especially those
located in metropolitan areas, may be divided by public roads, and this
further complicates determination of generator status. Can a university
consider itself as one generation site in order to spread its administrative
umbrella over the entire campus?
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F-4
Response:
Several basic configurations exist for college campuses. The rural or
suburban campus might have several buildings on one contiguous piece of
property. This would be considered a single or individual generation site
even though one or more hazardous wastes are generated from one or more
sources. One EPA identification number would normally be assigned for the
site, and small quantity generator status would be determined by looking at
the total hazardous waste generated or accumulated on the site.
Many university campuses are divided by public roads or other
rights-of-way that they do not control. Nonetheless, parts of a campus may be
geographically contiguous and the entry and exit between the two may be
directly across from each other at a crossroads. Such a campus would be one
generator for all purposes.
A metropolitan campus may be constructed on a number of city blocks,
creating a situation where campus buildings are separated by city streets and
it is necessary to travel along public streets to go from one part of the
campus to the other. In these cases, each generation site (each city block or
each part of the campus) would be a generator (or a small quantity generator)
and assigned its own EPA identification number. Hazardous wastes being
shipped from one campus building (generator) to another building (a treatment,
storage, or disposal facility) where the sites are divided by a public street
would need a manifest while on the public street.
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