EPA/530-SW-89-040A
Executive Summary Only
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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EXECUTIVE SUMMARY
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 waste disposal costs.
EPA'a 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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