ENVIRONMENTAL AWARENESS/HAZARDOUS WASTE WORKBOOK

Course Introduction2

Environmental Laws2

Generation and Handling Hazardous Waste5

Universal Waste11

Costs of Managing Hazardous Waste14

Water and Air Pollution15

Industrial Hygiene Standards17

Course Conclusion18

Glossary of Terms19

Learning Activity22

ENVIRONMENTAL AWARENESS

HAZARDOUS WASTE WORKBOOK

INTRODUCTION

From the middle 1970s through the present, Congress has enacted many laws that have affected the way industry deals with the waste that is created. Universities are considered an industry under environmental laws. These laws are designed to protect life and the environment so that future generations will be able to enjoy the benefits of all our natural resources and not look back and curse us or be penalized for our lack of foresight. I will now introduce the laws that directly affect the Company and how we manage the waste products produced from our campus setting.

RESOURCE CONSERVATION AND RECOVERY ACT

The Resource Conservation and Recovery Act (RCRA) is considered to be the most far-reaching regulatory program ever undertaken by the Environmental Protection Agency (EPA). The RCRA was enacted in October 1976, and was amended in 1980, and again in 1984. RCRA regulations have significantly changed university practices for treatment, storage, and disposal of hazardous waste. In addition, The State of Texas has generated and established its own set of rules and regulations that exceed the federal laws for hazardous waste management.

Since the enactment of the RCRA, extensive regulation-laden requirements have affected universities. These regulations are designed to maintain safe work practices and preserve the environment. The regulations also provide for stiff criminal and financial penalties that have already caused some companies to dissolve because they could not or would not comply.

Most people have come to realize that the hazardous wastes generated as part of our modern economy pose problems that must be brought under control to preserve the environment and quality of life as we know it.

It has been estimated that approximately 250 to 275 million tons of hazardous waste are produced annually in the United States.

The EPA believes that only a small percentage of this waste is handled in an environmentally acceptable way. The EPA has found that the mismanagement of hazardous waste causes the following types of environmental damage: pollution of groundwater, contamination of surface waters, pollution of the air, fires or explosions, poisoning of humans and animals via the food chain, and poisoning of humans and animals via direct contact.

It is believed that there are thousands of abandoned hazardous waste disposal sites across the country that have not been discovered, including over a hundred sites in Texas. Whether they are the result of blatant disregard for regulations or simply the result of disposal practices that were considered proper in the past, these sites pose serious problems, especially for groundwater contamination and threat to public health.

While the magnitude of the overall environmental problem is unknown, there is little question that universities, businesses, cities, and federal and state agencies have disposed of hazardous wastes in ways that are now recognized to be inadequate to fully protect public health and the environment.

In fact the EPA has uncovered some of these sites within the City of Houston. Cleanup projects have been initiated to remove and properly dispose of the contaminated materials. Thus disposal and burial practices that were acceptable in the past are now costing millions of dollars for cleanup and proper disposal.

THE RCRA HAZARDOUS WASTE PROGRAM

The goal of the RCRA hazardous waste program is to regulate and manage all aspects of hazardous waste from the time it is generated to the time it is disposed of properly. This is commonly known as "cradle-to-grave" management. Those who are managing solid wastes are required to identify wastes that are hazardous, and then manage that hazardous waste at the large quantity generator facility in accordance with RCRA regulations.

WASTE DEFINITIONS

The scope of the RCRA is governed by the definitions of two key terms: "solid waste" and "hazardous waste." Commonplace words take on different meanings because of the new definitions written directly into the RCRA law by Congress. Thus, there can be little or no "private" interpretation of what the terms mean.

SOLID WASTE DEFINITION

Congress defines solid waste in RCRA, Section 1004 (27), as being: "any garbage, refuse, sludge from a waste treatment plant, or air pollution control facility and other discarded material, including solid, liquid, semi-solid, or contained gaseous material, resulting from industrial, commercial, mining, and agricultural operations, and from community activities..."(italics added). This definition encompasses more than the standard definition of "solid."

HAZARDOUS WASTE DEFINITION

As specified in RCRA, Section 1004 (5), Congress defined hazardous waste as "a solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may:

a)cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or

b)pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed."

The EPA has established criteria to identify hazardous wastes and has listed them by name. However, not all chemicals that can be hazardous are on this list. Therefore, the EPA identified characteristics that would further identify those hazardous wastes that were not listed by name. Many factors were considered including toxicity, potential for accumulation in tissue, flammability, corrosiveness, and other hazardous characteristics.

With this information, the EPA established four hazardous waste characteristics. These are waste substances that are: ignitable, corrosive, reactive and toxic.

It is important to understand that these characteristics and their definitions are the basis for federal and state regulations, as well as Company policies and procedures that deal with hazardous waste.

IGNITABLE (40 CFR 261.21) see Appendix A: page 4.

A solid waste is deemed to exhibit the characteristics of ignitability if it meets one of the four descriptions:

  1. A liquid with a flash point of less than 60oCelsius(140oF).
  2. A non-liquid that, under normal conditions, can cause fire through friction absorption of moisture, or spontaneous chemical changes and that burns vigorously and persistently.
  3. An ignitable compressed gas as defined by 49 CFR 173.300.
  4. An oxidizer as defined by 49 CFR 173.15.

Examples of each of these ignitable hazardous wastes are as follows: (1) Methyl Ethyl Ketone (MEK), (2) Aluminum Powder (Al), (3) Propane, and (4) Ammonium Nitrate (Fertilizer).

CORROSIVE (40 CFR 261.22) see Appendix A: page 4.

The corrosivity characteristic was established as a safeguard against hazardous wastes capable of corroding through metal containers that would result in the wastes escaping into the environment. Wastes with a pH at either the high or low end of the scale can harm human tissue and aquatic life, and may react dangerously with other wastes. Therefore, a solid waste is deemed corrosive if it is:

  1. Aqueous and has a pH of 2.0 or lower, or a pH of 12.5 or higher, or
  2. A liquid that corrodes steel at a rate greater than 6.35 millimeters (0.250 inches) per year at a test temperature of 130oF.

Examples are: (1) Sulfuric Acid with a pH < 2.0 and sodium hydroxide with a pH>12.5 and (2) photo fixer solution from a photography laboratory.

REACTIVE (40 CFR 261.23) see appendix A: page 4.

The EPA identified reactivity characteristics of hazardous waste to regulate wastes that are extremely unstable and have a tendency to react violently or explode when being handled or stored. A waste is considered reactive if it has any of the following properties:

  1. Normally unstable and readily undergoes violent changes without detonating.
  2. Reacts violently with water.
  3. Forms explosive mixtures with water.
  4. Forms toxic gases, vapors, or fumes when mixed with water.
  5. A cyanide or sulfide-bearing waste that gives off toxic gases, vapors, or fumes under normal conditions.
  6. Detonates or explodes when ignited or heated under pressure.
  7. Capable of detonation or explosive decomposition under normal conditions.
  8. A Class A or B explosive.

TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP) (40 CFR 261.24) see

Appendix A: pages 5 and 6.

The EPA decided that one of the most alarming dangers posed by hazardous wastes was the migration of toxic substances (arsenic, barium, lead, MEK, DDT, etc.) from landfill disposal sites into the water table. Consequently, the TCLP test is designed to identify wastes that are likely to leach toxic levels of certain substances into groundwater when improperly controlled.

The TCLP Toxicity test described in 40 CFR 261 Appendix II, is a specific test that duplicates the leaching action of a substance under controlled means, thus giving an indication of whether or not the substance would threaten groundwater. Maximum allowable concentrations are set so that safe levels can be identified.

Using these definitions and characteristics, the EPA developed the following three questions to help identify hazardous wastes:

  1. Does the solid waste exhibit a hazardous waste characteristic (ignitable, corrosive, reactive, or TCLP toxic)?
  2. Has the solid waste been found to be fatal in humans in low doses or, in the absence of human data, has it been shown to be dangerous in animal studies?
  3. Does the solid waste contain any of the toxic constituents identified and listed by the EPA?

WASTE CATEGORIES

Based on the previous criteria, the EPA then established the following three categories of hazardous wastes:

  1. Nonspecific source hazardous wastes (e.g., spent non-halogenated solvents, toluene, methyl ethyl ketone), 40 CFR 261.31.
  2. Specific source hazardous wastes (e.g., bottom sediment sludge from the treatment of wastewaters from wood preserving), 40 CFR 261.32.
  3. Discarded commercial chemical products, and all off-specifications species, containers, and spill residues, 40 CFR 261.33.

GENERATION AND HANDLING OF HAZARDOUS WASTE

Those involved with hazardous waste must carefully adhere to the "cradle-to-grave' philosophy. When proper care is taken, there is little or no chance for hazardous waste to become a threat to life or to the environment.

RCRA HAZARDS

The field of hazardous waste covers such a wide spectrum that the RCRA separated hazardous waste activities into four categories: 1. hazardous waste generation, 2. hazardous waste storage, 3. hazardous waste transportation, and 4. hazardous waste disposal.

HAZARDOUS WASTE GENERATION

A "generator" of hazardous waste is anyone or any organization that produces a hazardous waste(s) that can be identified or listed in 40 CFR 261.33-.33. This can be an individual, a company, university, or any government body, agency, or trust.

The definition of a generator refers specifically to a particular site of generation. Thus, a university system with several campuses can be a multiple generator and must meet RCRA requirements separately for each campus. The EPA definition of a generator does not distinguish between a company that produces hazardous waste frequently and one that does not. Being a generator is not restricted to only the universities involved in generating the hazardous waste. Those companies that handle hazardous wastes in various stages can also become "generators." For example, this could be a transporter (trucking company) that has an accident that results in a spill.

HAZARDOUS WASTE STORAGE

The EPA allows a large quantity generator to store its hazardous wastes on-site for a period up to 90 days without obtaining a permit to act as a storage facility. A small quantity generator may have up to 180 days to store waste, but this generally doesn't apply to the Company. The time restriction applies, regardless of whether the wastes will be treated or disposed of on-site, or taken to an off-site treatment, storage, or disposal (T/S/D) facility. Labels that identify the material as hazardous waste, the material name, and the date must be attached to the outside of the container. Once a designated container is filled, all of the hazardous waste it contains must be transported to an off-site storage, treatment, or disposal facility within 90 days.

However, in cases of unforeseen or uncontrollable circumstances, it is possible to get a temporary extension of 30 days if hazardous waste must be stored for more than the original 90 day period. Nevertheless, a general rule is that the generator becomes an operator of a storage facility, by definition, if the wastes are stored on-site for longer than 90 days. This may cause the generator to become subject to sanctions for failure to have a RCRA storage permit.

For remote waste generation sites on campus (laboratory, shop, etc.) a satellite accumulation station (SAS) may be set up. A SAS is governed by very specific rules regarding labeling, inspections, etc. The advantage, however, is that wastes can be collected and stored in the SAS without regard to the 90 day clock. Only 55 gallons of non-acute hazardous waste may be collected at a time. Within 3 days of attaining the 55 gallon limit, or when the SAS is no longer needed for accumulation, the waste must be moved to the 90 day storage area.

HAZARDOUS WASTE HANDLING AND DISPOSAL

Hazardous waste handling is a variety of steps that includes waste identification, segregation, and preparation. Also, it includes satellite accumulation stations (SAS), material inspection and pickup, transportation, material sorting, labeling, preparation, temporary storage requirements, documentation system, manifest paperwork, and shipment.

RCRA Section 3001 requires the EPA to establish standards applicable to generators of hazardous waste as follows:

  1. Record keeping that identifies the quantity, constituents, and disposition of hazardous waste
  2. Labeling of containers used to store, transport, or dispose of hazardous waste
  3. Use of appropriate containers
  4. Furnishing of information regarding a generator's hazardous waste to persons who transport, treat, store, or dispose of such waste
  5. Use of a manifest system and any other reasonable means necessary to ensure the proper disposal of hazardous waste
  6. Submission of reports to the EPA or Texas Natural Resource Conservation Commission (TNRCC) that identify the quantity and disposition of hazardous waste.

The Risk Management Department has the responsibility to carry out the actual steps for shipment of hazardous wastes. The department collects, combines, and stores waste materials less than 90 days in accordance with current EPA regulations. The waste is packaged in accordance with the specific requirements of the treatment, storage, or disposal (T/S/D) facility and the Department of Transportation (DOT). Labels are clearly marked and the contents are identified.

MANIFEST SYSTEM

The RCRA requires the use of a manifest system to verify that hazardous waste destined for off-site storage or disposal actually reaches its destination. The manifest is the paperwork/documentation that tracks the hazardous waste from its point of generation to its point of disposal. This is in line with the "cradle-to-grave" management philosophy.

The Risk Management Department completes a Uniform Hazardous Waste Manifest that controls each shipment of hazardous waste. With the manifest filled out and documented, the hazardous waste can be moved off site. Information to be included on the manifest includes the name, EPA identification number, and address of the generator, the Department of Transportation (DOT) description of the waste, the quantity being transported, the name and EPA identification numbers of the transportation company, and the name and address of the EPA-authorized facility that will receive the hazardous waste. Phone numbers of the transporter and the T/S/D facility must also be listed, along with emergency response information. The emergency response information includes names of responsible persons, their telephone numbers, spill response guides, treatment standards, etc.

An important aspect of the manifest system is the requirement that both a primary authorized T/S/D facility be identified to receive the hazardous waste. If the hazardous waste cannot be delivered to one of the designated facilities, the transporter must contact the generator who may either direct the transporter to another authorized facility or have the waste returned. The licensed carrier signs the manifest and ships the hazardous waste to an EPA - approved T/S/D facility. The generator copy of the manifest is retained by the Risk Management Department upon completion of the pickup. The remaining copies are forwarded to the T/S/D facility with the shipment for completion. The fully completed manifest must then be returned to the Company from the disposal facility within 45 days of shipment. If it is not, the Texas Natural Resource Conservation Commission must be notified. Usually the Risk Management Department contacts the disposer at 35 days if the manifest has not been returned. All correspondence and records are filed for future reference. Mistakes on a manifest that are not corrected can become an offense punishable by fine.

The manifest stands as a record of all persons or organizations who handled a particular hazardous waste shipment. It records the chain of accountability for disposal of the waste.

TREATMENT, STORAGE, OR DISPOSAL FACILITIES

The RCRA has an expanded definition of what a T/S/D facility is. It covers any type structures and /or improvements that are put on land (as well as the land itself) that are to be used in managing any form of hazardous waste.

HAZARDOUS WASTE TREATMENT

A facility is defined as a hazardous waste "treatment" facility if it uses: "Any method, technique, or process, including neutralization, designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to render such waste nonhazardous, or less hazardous; safer to transport, store, or dispose of; or amenable for recovery, amenable for storage, or reduced in volume. (40 CFR 260.10(a))" Therefore, if the purpose of the facility is to alter or change the waste to a neutral or less hazardous substance, regardless of the method used, it is a treatment facility.

HAZARDOUS WASTE STORAGE

A "storage" facility is one that is used to temporarily hold or store hazardous waste that will eventually be treated at, disposed of, or stored at another facility.