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 ------- 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. ------- -VI- 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. ------- -vii- 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.) ------- |