Hazardous Waste Management Program
Part of ESH's responsibilities is the orderly disposal of chemical wastes which are deemed hazardous by the Environmental Protection Agency. Proper chemical waste storage depends upon the individuals generating the waste until ESH can pick it up.
Once the waste is picked up, it is taken to a centralized storage area. There the waste is stored or bulked into other waste streams until arrangements can be made with a hazardous waste disposal firm for removal from campus. Most of the waste generated on campus is sent off site and burned for energy recovery or incinerated in furnaces approved by the EPA.
The cost for the disposal of hazardous waste is budgeted through the Department for Facilities Management. No charges are currently assessed to the departments for the disposal of waste regulated under the EPA Resource Conservation and Recovery Act (RCRA). Radioactive waste is not included in this arrangement.
Improper storage of hazardous waste by the individuals who generate the waste can result in a fine being levied against the University. The EPA performs unannounced periodic inspections of the University and fines for dirty catch containers, open tops, and mislabeling have been known to be as high has $10,000. Fines against satellite collection centers will not be paid by ESH.
ESH is open to suggestions and welcomes questions about the hazardous waste system. Our goal is to provide a practical, economical, low-hassle system for disposal of hazardous waste for the University community.
The Environmental Protection Agency allows individual states to regulate the hazardous waste produced and destroyed within its boundaries. The Commonwealth of Kentucky has its own state agency, the Natural Resources and Environmental Protection Cabinet (Kentucky EPA). This agency has broad powers in the area of rule making, inspection, and enforcement. Kentucky EPA has created a list of chemicals which they have deemed hazardous.
Chemical compounds, which are made up of all or part of the chemicals on this list, are regulated and must enter into the hazardous waste disposal system once they are of no value to the generator. The Material Safety Data Sheet (MSDS) is a very useful source for determining the make-up of a particular product or compound. If the chemicals making up a compound do not appear on the KY EPA list, it may still be characterized as a hazardous waste under the following definitions:
The Kentucky EPA considers four additional characteristics to determine if a waste is hazardous or not. If a waste exhibits one or more of these characteristics, it is deemed hazardous waste. They are Ignitability, Corrosivity, Reactivity, and Toxicity. The Kentucky EPA does not allow a hazardous waste to be diluted to disqualify it from being a characteristic waste. Acids or bases can be neutralized to meet the Kentucky EPA standards.
Definitions of Characteristic Waste
IGNITABILITY: Has properties including a flash point of less than sixty degrees C (140 degrees F), using the Pensky-Martens closed cup tester.
CORROSIVITY: Is aqueous and has a pH of less than or equal to 2 or greater than or equal to 12.5. or corrodes steel at a rate set by the National Association of Corrosion Engineers.
REACTIVITY: Is normally unstable and readily undergoes violent change without detonating. It reacts violently with water. It performs potentially explosive mixtures with water.
TOXICITY: A waste which shows toxicity using the Total Characteristic Leachation Process (TCLP).
In addition to the regulations of Kentucky EPA, there are limitations set by the City of Murray regarding what goes into their waste water system. Their regulations prohibit the discharge of waste with a pH of less than 6. Other restrictions pertain to the discharge of fats, waxes, and grease, plating solutions, and liquids above 150 degrees F. (65 degrees C). Heavy metal discharge limits include silvers. If desired, the City of Murray 's regulations can be obtained by calling ESH at 3480.
For assistance in determining if something is a hazardous waste, call ESH. If information is unavailable, save the waste until it can be determined how it can be disposed of. Be sure that you carefully determine what the waste is and mark it on the label. ESH will try to make a determination about the waste in a timely manner. Unknown wastes are particularly expensive to dispose of. If a generator of a waste cannot identify what is in it, they may be asked to share in the cost of analysis. Draining unknown waste can result in criminal prosecution of the individual who performs the action.
Approximately every three years a survey will be performed to determine the type and amount of hazardous waste being produced on campus. Please try to be as accurate as possible when completing this survey. It is not necessary to wait for the survey to make changes known. If you anticipate considerable variations in the amount or type of waste being generated in your operation, please make the office of ESH aware of these changes.
Hazardous Waste Storage
The individuals whose labs, shops, studios, etc., produce hazardous waste are responsible for its storage while it is in their areas. The Kentucky EPA designates the individual responsible for these areas as an employee of the university and entitles them as operators. Every point of generation (satellite center) must be under the control of a faculty or staff member. It cannot be the ultimate responsibility of an uncompensated student to be a designated operator.
The operator's responsibilities include five things:
1. The outside of the containers containing hazardous waste must be kept free of any waste or potential waste. This includes wet or dry accumulations on the containers.
2. Containers must have the tops securely closed at all times. Exceptions are only when waste is actively being added or removed.
3. Containers must be clearly labeled "Hazardous Waste". The contents of the container must be clearly indicated on the outside of the container. Under extraordinary circumstances, "Unknown" may be placed on the label.
4. Accumulation of more than 55 gallons of hazardous waste in any satellite center is not permitted. Pick-ups are generally made on Friday. ESH can be contacted at extension 3480 during normal working hours. Pick-ups will be made on the following Friday.
5. Hazardous waste to be picked up must be in a closed container. Missing tops, broken bags and bottles cannot be transported to the accumulation center. If you are in need of a container to hold a particular product, contact ESH.
If the staff of the Office of ESH is unable to pick up the hazardous waste for some reason, a message will be left explaining the deficiency. Once the deficiencies have been corrected, contact ESH to arrange for pick up. If you have questions concerning the message, call ESH at 3480.
Hazardous Waste Pick Ups
It is the responsibility of the ESH Office to pick up, store, and dispose of all chemical
waste deemed hazardous. It is the goal of the staff of ESH to do this in compliance
with the Kentucky EPA regulations.
TO ARRANGE FOR A PICK UP:
1. Inspect the container of waste making sure it is properly labeled as a hazardous waste. Include a description of that waste on the label. Write out chemicals by name and not by formula. The container should also be clean and have a top on it.
2. Call ESH at extension 3480 during the week between the hours of 7:00 a.m. and 4:00 p.m. Leave your name, location of the waste, a brief description of the waste, and amount.
3. If the point of pick-up is normally locked and has controlled entry, arrangements will need to be made to have someone meet ESH personnel performing the hazardous waste pick-up. ESH can generally get into most areas unassisted.
Pick-ups are made each Friday during semesters. Alternative arrangements can sometimes be made under special circumstances. Because of the small staff of the ESH office, pick-ups cannot usually be made the day of the request.
If an ESH catch container is being used, a replacement will be provided the same day of the pick up. It will have a hazardous waste label on it including information about the type of the chemical waste which is to go into the container. If you are generating a waste which does not match the description on the container, make arrangements for another container to meet your needs. Avoid mixing chemical wastes unless you have discussed the situation with ESH. They can provide you with additional containers and/or labels as necessary.
The hazardous waste labels have a blank for the accumulation start date. This applies when the waste is stored in the hazardous waste centralization point. Leave it blank while it is in your area. Questions concerning labeling can be directed to ESH.
There is a general inspection and clean out of all the satellite collection centers near the end of each semester. If a container has accumulation in it of 30% or more, it will be emptied. Deficiencies in the operation of the satellite accumulation centers will be reported to the individual (faculty or staff) responsible for that station. If corrections are not made, deficiencies will be reported to superiors.
There is presently no charge for the pick-up and disposal of hazardous waste determined by the departments or individuals generating the waste. ESH is not budgeted for paying fines levied against satellite collection points by the Kentucky EPA.
Changes in Waste Generation
The dynamic nature of the University community causes constant changes in the amounts and types of hazardous waste being generated. Fluctuations in individual waste streams as to the amounts of waste generated do not significantly impact the hazardous waste system. Fluctuations greater or less than 25% do need to be reported to the ESH Office so that adequate planning can be done in the area of budgeting and registration. Small amounts of waste chemicals of one liter or less are not required to be reported.
A change in the amount of waste being generated should be reported to the ESH Office and include the following information:
1. The chemical make-up of the waste.
2. The amount of waste to be generated.
3. If this will be a reoccurring waste stream or a one time only occurrence.
4. Name of the individual producing the waste.
5. Location where waste will be generated.
A catch container and label can be provided, if necessary, for the new waste being generated. The size and type of the container will depend on the amount of waste to be produced.
Relocation and Retirements
It is important that the ESH office have accurate information regarding the room number and responsible individual for each waste being produced. If you are moving from one lab, studio, shop, etc. to another, please notify ESH of the anticipated date of the move.
If you plan to leave behind unused chemicals, compounds, or products, be sure they are labeled regarding content. Do not leave unmarked chemicals in your work area. The next person to use the space will, more than likely, not know what it is and throw it out. Labeling all chemicals in your work area is required under the existing Campus Hazardous Communication program. (OSHA 1910.1200) Labels, which come on the products, are usually sufficient to meet OSHA regulations. If you are in need of a copy of the Murray State Hazard Communication Program, call the ESH office and one will be provided for you.
Chemical Spills and Releases
In the event of a chemical spill or release which you are not capable of handling:
1. Evacuate the area immediately around the spill. This may include evacuation of the room in which the spill occurred. If evacuation of the building is necessary, pull the fire alarm.
2. Post someone near the entrance to prevent people from entering the area.
3. Call Ext 2222 (Public Safety Office). During normal working hours, you should call the ESH office direct at 3480.
4. Give your name, the location of the spill, what has spilled, and approximately how much.
5. After the call, maintain a safe distance from the area involved and wait for emergency response personnel to arrive.
During normal working hours, personnel from the ESH Office will typically take around ten minutes to arrive. This is subject to change with circumstances. In extreme cases the City of Murray Fire Department will be sent to assist ESH or take charge of the spill clean up process.
Evacuation distances are influenced by a great deal of variables. Evacuation distances for chemical spills will be at least:
SMALL SPILL <5 FEET DIAMETER Keep Back 50 FEET
LARGE SPILL >5 FEET DIAMETER Keep Back 150 FEET
It is not necessary to report small spills, which are handled by the chemical users.