Handling Hazardous Waste and Maintaining Hazardous Waste Accumulation

Handling Hazardous Waste and Maintaining Hazardous Waste Accumulation Areas at James Madison University May 2010

Introduction What is a Hazardous Waste? —Hazardous wastes include discarded chemicals, reagents, oil paints and thinners, unusable chemicals, unidentified chemicals, chemicals who’s properties have changed with time, and left-over reagents and by-products from previous employees, students, and professors. Where are Hazardous Wastes found? —Hazardous wastes obviously occur in labs, but can also be found in art, facilities, grounds, and other non-laboratory locations.

Location §Within a lab or shop where waste is generated, it may be collected at the point of generation if identified as a “Satellite Accumulation Area” (SAA). § When a room, area, or building separate from the point of generation has been identified as the location to accumulate hazardous waste it must labeled as a “Hazardous Waste Accumulation Area. ” §JMU has SAA areas within labs and Hazardous Waste Accumulation areas identified in the Chemistry/Physics Building, ISAT Building, Burruss, and adjacent to the Housekeeping Trailer on Grace St.

Containers in the Hazardous Waste Accumulation Area When a container with chemicals is no longer needed, the chemical has been spent, or a waste container from a satellite accumulation area is full, it must be immediately moved to the Hazardous Waste Accumulation Area. The container must specify the following: • Contents • The words “Hazardous Waste” • The date the container entered the Hazardous Waste Accumulation Area

Documentation Hazardous Waste Accumulation Areas are required to have the following: §Weekly Inspection that verifies that the containers are intact and not leaking, are closed, labeled appropriately, and dated §Up to date inventory indicating what materials are in the space and the date on the container (a. k. a. when they were ‘accumulated’). If during the weekly inspection some aspect of the area is found ‘non-compliant (i. e. containers aren’t dated or don’t have the words “hazardous waste”), immediately correct the problem. If the problem cannot be immediately corrected, note the issue on the inspection form and indicate what corrective measures are being pursued. Once the issue is addressed, indicate as such on the inspection form. SAA Satellite Accumulation Areas are not required to maintain a formal inventory nor inspection log. However, the contents of the containers must be known, the containers must be of suitable integrity and kept closed when not in use, and the total volume in a SAA cannot exceed 55 gal.

Tracking Waste Accumulation JMU’s contiguous campus is classified as a Small Quantity Generator (SQG) of waste. To maintain that status, the University cannot • Generate more than 1000 kg of hazardous waste per month • Generate more than 1 kg of P-listed* waste in a month • Store waste for longer than 180 days For these reasons, an accurate inventory of the waste stored in the accumulation areas is vital. *P-listed waste are the acutely toxic waste streams like cyanide salts and solutions, sodium azide, osmium tetroxide, nicotinic acid, etc. .

Tracking Waste Accumulation JMU properties which have the potential to generate waste, but which are not contiguous to the main campus include: The Studio Art Center Memorial Hall Bus garage and Alternative Fuels Lab Each of these locations is classified as a “Conditionally Exempt Small Quantity Generator” (CESQG). To remain a CESQG, each location must ensure that no more than 100 kg (220 lbs) of waste is generated in a month, never to exceed 1000 kg (2200 lbs) total. JMU personnel are not authorized to transport waste from these locations.

Waste Removal and Transport A properly licensed waste contractor will package and remove waste from each of the Hazardous Waste Accumulation Areas as well as directly from the CESQG locations (i. e. The Studio Art Center, Memorial Hall, and the Bus Garage/Alt. Fuels Lab). Within the contiguous campus, JMU personnel may transport hazardous wastes such as paints, lubricants, and other maintenance or facilities-derived materials. However, JMU personnel are NOT authorized to transport any waste from the CESQG locations nor should they be transporting any laboratory-generated wastes or chemicals.

Emergencies If there is a small spill, you may intervene to mitigate and/or clean up only under the following conditions: ü The identity of the spilled material is known. and ü The hazards of the spilled material are known. and ü The area is sufficiently large and/or ventilated so as to assure the small spill will not generate a hazardous environment (i. e. IDLH or LEL conditions). and ü You feel comfortable doing so. If any of these conditions are not met, evacuate the area and report the spill by calling JMU Police from a cell phone at 568 -6911 or from a JMU landline at x 6911

Spill Clean-up Small spills, which meet the aforementioned criteria, may be cleaned up with a universal absorbent like vermiculite or clay (kitty litter) or other materials suitable for the type and volume of the spill. Once utilized, the absorbent material must be packaged in a container suitable for the contents and treated as hazardous waste (a. k. a labeled, dated, placed in appropriate area). If you are unsure about the proper clean-up method, evacuate the area and report the spill by calling JMU Police from a cell phone at 568 -6911 or from a JMU landline at x 6911

Summary Satellite Accumulation Areas (SAA) Hazardous Waste Accumulation Areas Conditionally Exempt Small Quantity Generator (CESQG) Ø must be at the point of waste generation (like in a science lab or maintenance shop) Ø have a volume limit of 55 gal total, but not a time limit Ø once containers are full they must be moved to the Hazardous Waste Accumulation Area Ø locations are separate from point of generation Ø have a time limit of 180 days Ø contiguous campus is limited to accumulating no more than 2200 lbs (1000 kgs) of haz waste and 2. 2 lbs (1 kg) of p-listed waste per month to maintain small quantity generator status Ø locations are not contiguous to campus and include Memorial Hall, Studio Center, Alt. Fuels Lab/Garage Ø limited to haz waste accumulations less than 220 lbs (100 kgs) per month

Responsibilities ALL employees must be thoroughly familiar with proper waste handling and emergency procedures that are relevant to their job responsibilities, both during normal facility operations as well as during emergencies. Instructors, research advisors, and supervisors are responsible for ensuring students understand their obligations with regard to handling all types of waste and know appropriate emergency procedures pertaining to any hazardous waste they work with or around.

Conclusion By following the aforementioned rules, JMU can safely manage its hazardous waste in compliance with applicable DEQ and EPA regulations. If you have any questions about the materials presented in this training, or about handling waste and associated documentation for your area, please contact Marcella Mullenax, JMU’s Environmental Health Coordinator, at Mullenmr@jmu. edu or 8 -4959.