The Resource Conservation and Recovery Act (RCRA), passed in 1976, established the first hazardous waste regulations in the United States. The United States Environmental Protection Agency (EPA) implements and enforces the federal hazardous waste regulations as well as authorized state agencies, such as the West Virginia Department of Environmental Protection (DEP). Under RCRA all regulated generators of hazardous waste, including Shepherd University, must manage their wastes from “cradle to grave.” There are six steps that Shepherd must follow in order to comply with hazardous waste regulations. The six steps are as follows:
- Identify (i.e. Make a Hazardous Waste Determination)
- Recycle, Treat, Dispose
Shepherd University is a Conditionally Exempt Small Quantity Generator (CESQG) of hazardous waste per EPA and DEP regulations. As such, the University is limited on the amount of hazardous waste it may generate per month. If monthly hazardous waste limits are exceeded, the University would move into a higher generator category. Consequently, Shepherd would be required to meet the more stringent requirements of a higher generator category and notify the WV DEP and US EPA of its status change.
It is essential for the University to count all hazardous waste generated on campus. At Shepherd, the Campus Environmental Safety Coordinator is responsible for tracking the hazardous waste generated on campus to ensure the University is staying within its regulatory quantity limits and to correctly notify the EPA and DEP of its generator status. In order to do this, hazardous waste generators on campus must be actively involved in the hazardous waste management process. This includes participating in training, making hazardous waste determinations (Is my waste a hazardous waste?), container management, labeling, and reporting.
If you are a generator of hazardous waste, non-hazardous chemical waste or are unsure if you are a generator of hazardous waste, please contact Dustin Robbins, so that a review of your waste streams and processes can be made.
Identifying Hazardous Waste
Hazardous Waste Determination
Shepherd University and its generators of hazardous waste are required to identify their hazardous wastes by making hazardous waste determinations. Hazardous waste determinations are made using knowledge of the waste or through analysis of the waste. After receiving hazardous waste training, generators should be able to make waste determinations of their waste streams. The hazardous waste determination process is one of, if not, the most important steps in the hazardous waste management process. Without accurate waste determinations, generators may end up managing their waste(s) incorrectly which can lead to compliance issues as well as an increased risk to environmental and human health. Furthermore, the University would not be able to accurately account for its monthly and total hazardous waste quantities.
When developing the hazardous waste regulations, the EPA was tasked by the Congress with listing specific hazardous wastes and determining characteristics that, when present in a waste, make it hazardous. Consequently, there are two steps in determining if you have generated a hazardous waste: 1. Determining if the waste is specifically listed on one of four lists and 2. Determining if the waste exhibits one or more of the four characteristics of a hazardous wastes. These steps are detailed below.
Step 1: Is It A Listed Hazardous Waste?
If a waste appears on one of the four lists of hazardous wastes below, then it is a regulated hazardous waste. The lists are as follows:
- F-Listed Waste (Wastes from non-specific sources)
- K-Listed Waste (Wastes from specific sources)
- P-Listed Waste (Unused commercial chemical products)
- U-Listed Waste (Unused commercial chemical products)
F- and K-listed wastes are different than P- and U-listed wastes in that they are generated from sources. For a searchable list of F- and K-listed hazardous wastes, click here (you will be directed to the EPA’s website). F-listed wastes are potentially found on Shepherd’s campus. K-listed wastes are not typically found on college campuses.
P- and U-listed wastes are unused commercial chemical products. To be a P- or U-Listed waste, the waste must be: 1. On the P or U list; 2. Unused; and 3. In the form of a commercial chemical product (i.e. 100% pure, technical grade or the sole active ingredient). For a searchable list of P- and U-listed hazardous wastes click here (you will be directed to the EPA’s website). Some examples of P-listed wastes include arsenic trioxide, carbon disulfide and sodium azide. Some examples of U-listed wastes include acetone, methanol and toluene.
Step 2: Does It Exhibit One Or More Characteristics Of A Hazardous Waste?
If the waste exhibits one or more of the four characteristics of a hazardous waste, then it is regulated as a hazardous waste. The four characteristics are as follows:
- Ignitability: Wastes that are hazardous due to the ignitability characteristic include liquids with flash points below 60°C, non-liquids that cause fire through specific conditions, ignitable compressed gases and oxidizers.
- Corrosivity: Wastes that are hazardous due to the corrosivity characteristic include aqueous wastes with a pH of less than or equal to 2, a pH greater than or equal to 12.5 or based on the liquids ability to corrode steel.
- Reactivity: Wastes that are hazardous due to the reactivity characteristic may be unstable under normal conditions, may react with water, may give off toxic gases and may be capable of detonation or explosion under normal conditions or when heated.
- Toxicity: Wastes that are hazardous due to the toxicity characteristic are harmful when ingested or absorbed and present a concern as they may be able to leach from waste and pollute groundwater. The toxicity of a waste is determined by the Toxicity Characteristic Leaching Procedure (TCLP).
For more information on characteristic hazardous wastes, click here to be directed to 40 CFR 261.20.
Hazardous Waste Determination Sheet
Each generator at Shepherd University is required to make hazardous waste determinations of the wastes they generate. Prior to engaging in actions or initiating processes that generate waste, generators are encouraged to decide if their waste stream(s) will generate hazardous waste. This will enable generators to be better prepared to manage their wastes appropriately. According to the EPA, from May of 2001 to May of 2011, colleges, universities and professional schools accounted for the fourth highest non-compliance rate for hazardous waste determinations in the United States. In order to ensure that generators and the University are meeting the hazardous waste determination requirement and to help guide its generators through the process, a “Hazardous Waste Determination Sheet” has been created. Generators are encouraged to complete a Hazardous Waste Determination Sheet for each waste that they generate to keep on file. The Campus Environmental Safety Coordinator (CESC) is available to assist generators in completing the Hazardous Waste Determination Sheet.
Hazardous waste must be containerized in a sturdy, leak-proof container that is compatible with the waste in which it is holding. Except when adding or removing waste to a container, all waste containers must remain closed at all times. Loose caps and lids are considered “open” and are US EPA and WV DEP violations. Incompatible wastes should never be mixed in the same container. Secondary containment (bins, trays, etc.) is encourage for all hazardous waste containers and should always be used for containers near drains.
Each container of hazardous waste must be properly labeled. Unlabeled and improperly labeled containers can lead to US EPA and WV DEP violations as well as other health and safety code violations (e.g. OSHA and NFPA). More importantly, unlabeled and improperly labeled containers present unnecessary health and safety hazards in the workplace. At minimum, each hazardous waste container must be clearly labeled with the following information:
- The words “Hazardous Waste“
- The Contents of the hazardous waste
- The Accumulation Start Date (i.e. date on which the waste was generated)
The Words “Hazardous Waste”
All hazardous waste containers must be labeled with the words “Hazardous Waste.” The words “Hazardous Waste” indicate that a waste determination has been made of the waste. Hazardous waste containers without the words “Hazardous Waste” can lead to labeling violations and waste determination violations.
Each label must include the contents of each waste container. No abbreviations, chemical formulas or other forms of shorthand may be used when labeling the contents of a hazardous waste container. Smaller containers can be overpacked in larger containers to provide space for the contents of the container to be communicated. Without communicating the contents of a hazardous waste container on a label, the proper handling, storage and ultimate treatment/disposal can be jeopardized. Furthermore, handlers down stream are put at risk by unlabeled and improperly labeled containers. Unknown containers of waste may require an an analysis of the waste to be made which can be very expensive to perform. Immediately replace labels that are worn, removed, or defaced in any way.
Accumulation Start Date
All containers should be labeled with the date on which a waste was first accumulated. This ensures that waste containers are not held for extended period of times and allows for accurate monthly accounting of waste.
Hazardous Waste Labels (MS Word format for printing on avery labels)
Non-Hazardous Waste Labels
Some materials are not RCRA-regulated hazardous wastes, but may need to be collected and provided to a disposal contractor. Ethidium bromide is an example of a non-hazardous waste that should be collected and provided to a disposal contractor for treatment or incineration. Do not label non-hazardous waste containers with the words “hazardous waste” or use hazardous waste labels on them. Label non-hazardous waste containers for collection with the words “Non-Hazardous Waste” or use the non-hazardous waste label below.
Empty Containers of Hazardous Waste
Containers that previously held hazardous waste or previously held chemicals that could become hazardous waste need to be evaluated prior to disposal or re-use to ensure that they are “RCRA empty.” For a container to be empty, it must meet specific criteria. Different criteria exists for non-acute hazardous waste and acute (P-listed) hazardous waste.
Empty Containers: Non-Acute Hazardous Waste Containers
Containers of non-acute hazardous waste are considered empty if all waste has been removed using methods commonly used to remove the contents from that type of container, e.g. pouring, pumping, scraping, etc. AND:
- No more than 1 inch (2.5 cm) of residue remains on the bottom of the container or inner liner, OR
- No more than 3 percent by weight of total capacity of the container remains in the container or inner liner if the container is less than or equal to 119 gallons; OR
- No more than 0.3 percent by weight of the total capacity of the container remains in the container or inner liner if the container is greater than 119 gallons in size.
Acute (P-Listed) Hazardous Waste Containers
Containers of P-listed wastes (acute hazardous wastes) must be triple-rinsed with a solvent capable of removing the hazardous waste from containers or inner liners in order for containers to be considered empty. The rinsate would still need to be collected and managed, so it is easier and safer to manage the containers as hazardous waste, rather than rinsing them.
All containers that meet the “empty” designation should have all labels removed or defaced and should have the word “Empty” written on them. This will ensure that others know that the container is, in fact, empty.
Hazardous Waste / Chemical Waste Pick-Up Request
Timely reporting of any hazardous waste generated at Shepherd is imperative. If you have generated waste and are in need of a pick-up, please complete the Hazardous & Chemical Waste Pick-up Request Form. Provide as much information as possible about the waste(s) when completing the form. Two different waste streams may be requested per form. After filling out the form, click the “SEND” button to submit the form. Submit additional request forms as needed.
Please note that not all wastes may be able to be moved from a collection site to a central storage location due to storage requirements, container size, or other factors. If this is the case, the waste will be moved on, or just prior to, the next scheduled waste disposal pick-up.
Hazardous Waste Disposal
The Campus Environmental Safety Coordinator is responsible for coordinating the shipment of hazardous wastes generated on campus to a permitted treatment, storage and disposal facility (TSDF). Although CESQGs do not have waste accumulation time limits, regular pick-ups of hazardous wastes are scheduled each academic year as a matter of prudence. Once scheduled, waste disposal contractors prepare the University’s wastes and assist with the completion of required paperwork for shipment to the TSDF. A uniform hazardous waste manifest is used to track the shipped waste. Once the waste is received by the TSDF, the TSDF will certify receipt of University’s hazardous waste using the manifest system. The TSDF will have up to one year to dispose of the wastes received. A certificate of disposal is typically provided to the University to further indicate that the University has satisfied its cradle-to-grave management responsibility of its hazardous wastes.
Hazardous Waste Training
Regular generators of hazardous waste and universal waste must be trained/informed prior to generating waste. If you or your department is in need of training, please contact Dustin Robbins. Training is essential as it provides generators with knowledge of applicable regulations and generator-specific responsibilities. Without training, generators can put themselves and others at risk and also jeopardize the University’s compliance with applicable hazardous waste regulations.
Waste minimization is a vital part of a waste management system. In an effort to minimize wastes from being shipped off site for disposal, treatment or recycling, efforts should first be made to see if any unwanted chemical products within a department or group on campus can be used by another. To help facilitate this process, employees may contact Dustin Robbins.
National Waste Minimization Program
The National Waste Minimization Program supports efforts that promote a more sustainable society, reduce the amounts of waste generated, and lower the toxicity and persistence of wastes that are generated. The Environmental Protection Agency has identified 31 “Priority Chemicals” for reduction. Shepherd faculty and staff are encourage to eliminate, substitute or reduce their use of these chemicals, if possible. The 31 Priority Chemicals and their respective Chemical Abstract Services Registry Number (CAS#) are as follows:
- 1,2,4-Trichlorobenzene (PDF), CAS#120-82-1
- 1,2,4,5-Tetrachlorobenzene (PDF), CAS# 95-94-3
- 2,4,5-Trichlorophenol (PDF), CAS# 95-95-4
- 4-Bromophenyl phenyl ether (PDF), CAS# 101-55-3
- Acenaphthene (PDF), CAS# 83-32-9
- Acenaphthylene (PDF), CAS# 208-96-8
- Anthracene (PDF), CAS# 120-12-7
- Benzo(g,h,i)perylene (PDF), CAS# 191-24-2
- Cadmium (PDF) (2 pp, 11K)7440-43-9
- Dibenzofuran (PDF), CAS# 132-64-9
- Dioxins/Furans (PDF) (considered one chemical on this list), CAS# 1746-01-6
- Endosulfan, alpha (PDF) & Endosulfan, beta (PDF) (considered one chemical on this list), CAS# 959-98-8 / 33213-65-9
- Fluorene (PDF), CAS# 86-73-7
- Heptachlor (PDF) & Heptachlor epoxide (PDF) (considered one chemical on this list), CAS# 76-44-8 / 1024-57-3
- Hexachlorobenzene (PDF), CAS# 118-74-1
- Hexachlorobutadiene (PDF), CAS# 87-68-3
- Hexachlorocyclohexane, gamma- (PDF) (Lindane), CAS# 58-89-9
- Hexachloroethane (PDF), CAS# 67-72-1
- Lead, CAS# 7439-92-1
- Mercury, CAS# 7439-97-6
- Methoxychlor (PDF), CAS# 72-43-5
- Naphthalene (PDF), CAS# 91-20-3
- Pendimethalin (PDF), CAS# 40487-42-1
- Pentachlorobenzene (PDF), CAS# 608-93-5
- Pentachloronitrobenzene (PDF) (Quintozene), CAS# 82-68-8
- Pentachlorophenol (PDF), CAS# 87-86-5
- Phenanthrene (PDF), CAS# 85-01-8
- Polycyclic Aromatic Compounds (PACs) / PAH Group (PDF) (as defined in TRI)
- Polychlorinated Biphenyls (PCBs) (PDF), CAS# 1336-36-3
- Pyrene (PDF), CAS# 129-00-0
- Trifluralin (PDF), CAS# 1582-09-8