M. Waste Management

M1. Introduction

The purpose of this program is to ensure that Colgate University is in compliance with all federal, state, and local regulations pertaining to the handling, storage, and disposal of solid (hazardous), radioactive, and biological (medical) wastes.

Chemical waste may be disposed of in several different ways. Flammable and reactive liquids and solids are usually incinerated. This is the preferred disposal option, because it destroys the chemical and its associated hazards. Water based solutions can be treated at wastewater treatment plants designed for this purpose. Some materials may be landfilled, but this option has been made illegal by the EPA for most chemical wastes. This "landban" has significantly increased costs for incineration of chemicals as demand for incinerator use has risen and few new incinerators are permitted (there is currently a ban on new incinerator permits). Consequently, nearly all of the hazardous waste generated at Colgate is sent to a commercial hazardous waste incinerator or permitted fuel blending facility. The cost of disposal ranges from about $1 to more than $5 per pound. Responsible purchasing practices, effective recycling, and on site treatment strategies have the potential to contain costs for the near future. For the past few years, Colgate has participated in a consortium of smaller schools in the area to gain favorable disposal and transportation pricing.

The University is classified by the NYDEC as a category II Small Quantity Generator meaning that we generate less than 100 kg/month of hazardous waste and less than 1 kg/month of acute waste (P-listed waste). Since we contract for disposal on a yearly cycle, we can never store more than 1000 kg of waste or 1 kg of acute hazardous waste. If we exceed these quantities, our classification changes bringing more stringent requirements. It is up to each individual using hazardous materials to minimize or eliminate hazardous waste generation. The use of alternative chemicals which do not have to be treated as hazardous waste when they are discarded and reducing the size and scope of laboratory experiments to control the amount of waste produced are effective options.

The chart that follows shows the flow and the decision making tree for laboratory waste at Colgate. As the front line generators of hazardous waste, laboratory supervisors have a legal and moral responsibility to properly manage the wastes generated as part of their laboratory operations.

M2. Responsibilities

Federal and state laws stipulate that each individual who generates hazardous waste is personally liable and is responsible for assuring compliance with regulations and proper hazardous waste management. Each laboratory must insure that there is a mechanism in place for hazardous waste identification, storage, and disposal.

Each department will insure that there is a mechanism in place for hazardous waste disposal when faculty, staff, or students complete their work and leave the university. Chemicals left in laboratories after their owners have moved on create a serious burden for faculty and staff moving into vacated facilities. Unknown or improperly labelled chemicals can significantly increase costs for waste identification and disposal. The analysis of unknown wastes and associated costs is the responsibility of the departments generating the waste.

The CMO will provide coordination, containers, labels, WCSs, training, and other assistance.

M3. Waste Minimization

A. Planning and Purchases

It is your responsibility as generators of hazardous waste to make every attempt possible to minimize the amount produced. To the extent that chemicals can be recovered, recycled, or reused safely there is obvious economic incentive to do so. In addition, materials that are recovered, recycled, or reused do not become a liability problem or a problem for the environment.

The planning of every experiment must include the consideration of the disposal of leftover starting materials and of the products and by products that will be generated. Questions to be considered include the following:

• Can any material be recovered for reuse?
• Will the experiment generate any chemical that can be destroyed by a laboratory procedure?
• Will the experiment produce an acutely hazardous waste?
• Can any unusual disposal problem be anticipated? If so, the CMO must be informed beforehand.
• Are chemicals being acquired in only the quantities needed? Are any of the chemicals already on site? (in the stockroom or another lab)
• Is there the possibility of replacing a hazardous reagent or solvent with one with is less hazardous or more easily disposed of?

Almost 75% of our present laboratory waste consists of partially used or unopened bottles of chemicals that have been accumulating for decades. Chemicals should be purchased in the smallest possible volumes to reduce the amount of unused chemicals that could end up as laboratory wastes. As the cost of chemical reagents and disposal continues to climb, any reduction in volume of chemicals purchased will offer benefits. Keep in mind that the perceived economy of buying in bulk is more than offset by disposal costs for the package and its residues.

Surplus chemicals should be returned to the stockroom in a timely manner so that they have an opportunity for redistribution. Departments or individuals will be reimbursed for chemicals in good condition.

B. Recovery and Recycling

The recycling process is exempt from hazardous waste regulation except that waste accumulated prior to recycling must be managed according to accumulation requirements. Distillation is an example of a viable recovery option. All residues such as still bottoms from the recycling process are regulated and must be managed as hazardous waste.

Hazardous waste regulations now require that wastes containing mercury be sent to a facility where mercury can be recovered in a retort or roasting thermal process unit. These recovery methods are very expensive ($30/kg). Most mercury waste at Colgate is the result of broken thermometers or instruments. The remainder is from surplus reagents or experiments.

Waste minimization is the best way to reduce the disposal problems related to mercury. Liquid metallic mercury should be collected for shipment to a reclamation facility. Small quantities can be made relatively free of insoluble contaminants by filtering a few times through conical filter paper with a small hole at the bottom of the cone.

Alcohol or mineral spirit thermometers will be substituted for mercury thermometers whenever possible. In most cases, these can meet accuracy and range requirements. If mercury thermometers must be purchased, use only teflon coated. Stainless steel thermometers can be used in heating and cooling units.

Many substitutes are available for mercury reagents as well. Some alternatives to mercuric chloride as a biocide are solutions such as 5-10% methylene chloride, 1% formalin, 1 N hydrochloric acid, sodium azide, and sodium hypochlorite. If mercury compounds are used as catalysts, an alternative is to simply eliminate the catalyst and let the reaction run longer. Mercury free catalysts such as CuSO4 , TiO2 , or K2SO4 can be used in Kjedahl digests.

Mercury spills can be collected in a flask equipped with a pipette and rubber hose connected to a vacuum source. Small droplets of mercury can be amalgamated with zinc dust and the resulting solids swept up. Droplets in crevices can be converted to mercuric sulfide by dusting with sulfur powder.

Photographic fixer solutions cannot be discharged to the sink and will be collected for silver recovery. The CMO operates a silver recovery unit in Sb-3 McGregory.

Other candidates for recycling include precious metals, scrap metals, waste oil, and formaldehyde. Every effort must be made to determine if other materials can be reused, recovered, or recycled.

C. Treatment

In-lab treatment of small quantities of hazardous waste is an effective way of minimizing off site treatment and disposal costs. Elementary neutralization of corrosive wastes and treatment in accumulation containers is exempt from permitting requirements for hazardous waste treatment. Ideally, these treatment steps should be written into every laboratory procedure. Potential treatment methods include phase separation of organics/aqueous solutions and liquids/solids; acid/base neutralization; precipitation of toxic metals and inorganic salts; oxidation of inorganic cyanides and sulfides. Many procedures for the neutralization or destruction of laboratory wastes are available in the following reference books available in Cooley Science Library:

Hazardous Chemicals Information and Disposal Guide, by Dr. Margaret Ann Amour. CRC Press, Boca Raton, FL, 1987.

Prudent Practices for Disposal of Chemicals from Laboratories, by the National Research Council. National Academy Press, Washington, D.C., 1983.

Destruction of Hazardous Chemicals in the Laboratory, by George Lunn. Wiley, New York, NY, 1990.

TREATMENT OF HAZARDOUS WASTE SHOULD BE DONE VERY CAREFULLY AND IN ACCORDANCE WITH WRITTEN PROCEDURES TO AVOID INJURY.

M4. Chemical Waste

A. Identification

The first step in hazardous waste management comes when the two following questions must be answered:

1. Is this material a waste?
2. Is this waste a regulated hazardous waste?

The hazardous waste regulations apply to materials only when they become a waste and only if they are deemed hazardous under specific evaluation criteria.

Unneeded chemical reagents do not become a waste until a decision is made by the CMO to discard them. Unneeded chemicals reagents should be returned to the stockroom for redistribution.

B. Hazard Determination

Once you determine that a chemical material in your lab is a waste, it must be evaluated to determine if it is a hazardous waste. Hazardous wastes are defined by the New York State Department of Environmental Conservation following EPA regulations. Wastes can be hazardous in one of two ways: they are either wastes and spent materials that are hazardous by definition and contained in specific lists, or they exhibit one of four hazardous characteristics: ignitability, corrosivity, reactivity, or toxicity.

Listed Wastes

Wastes that are hazardous because they appear on one of four lists are called "listed hazardous wastes". The four lists are categorized as wastes from specific sources (K-list), wastes from non-specific sources (F-list), certain discarded commercial products (U-list), and "acutely hazardous" commercial chemical products (P-list). The F and K lists apply to general processes, while the U and P lists are for reagent chemicals. The P-list category which contains wastes such as cyanides is more rigorously regulated. As a SQG, we cannot generate more than 1 kg/month or store more than 1 kg of waste from the P-list. Generation of acutely hazardous waste must be closely monitored and coordinated with the CMO. Many of the spent solvents and solvent mixtures (methylene chloride, acetone, methanol, ethyl ether) generated in your labs are F-listed waste and must be managed as hazardous wastes. A number of the lab reagents used at Colgate are among the hazardous wastes included in the U and P list of commercial chemicals that are hazardous when they are discarded, off specification, container residues, or spill residues. Mixtures of hazardous and non-hazardous waste are regulated as hazardous waste. So, please segregate hazardous and non-hazardous materials whenever possible.

Characteristic Wastes

If a waste is not on one of the lists of hazardous wastes , you must determine if the waste possesses one or more of four hazardous characteristics defined below: ignitability, corrosivity, reactivity, or toxicity. Such wastes are called "characteristic hazardous wastes". A generator may use his knowledge based on the materials or processes used or may test the waste to determine if it possesses one of the four characteristics. Personnel who generate chemical waste should have enough general knowledge of the hazardous characteristics of their waste to classify it.

Ignitability

• a liquid, other than an aqueous solution containing less than 24 percent alcohol by volume, with a flash point below 140 degrees F (60 C).
• a non-liquid, which under standard conditions is capable of causing fire through friction, absorption of moisture, or spontaneous chemical changes and when ignited, burns in a manner that creates a hazard.
• an ignitible compressed gas, which includes gases that form flammable mixtures at a concentration of 13 percent or less in air.
• an oxidizer, such as permanganate, inorganic peroxide, or nitrate, that readily stimulates combustion of organic materials.

Reactivity

• normally unstable and readily undergoes violent change without detonation.
• reacts violently with water.
• forms potentially explosive mixtures with water.
• generates, when mixed with water, toxic gases, vapors, or fumes in a quantity sufficient to present a danger.
• is a cyanide or sulfide bearing waste that generated toxic gases, vapors, or fumes at a pH between 2 and 12.5.
• is capable of detonation or explosive reaction when subject to a strong initiating source or heated in confinement.
• is readily capable of detonation, explosive decomposition, or reaction at standard temperature and pressure.
• is an explosive

Corrosivity

• is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5.
• is a liquid that corrodes steel at a rate greater than 6.35 mm per year at a test temperature of 130 degrees F (55 C).

Toxicity

• tested using the Toxicity Characteristic Leaching Procedure (TCLP), which stimulates the leaching of materials in a landfill into the surrounding groundwater.

Good sources for assistance in hazard determination are MSDSs, chemical dictionaries, and labels. If you have questions about whether a certain material is considered a hazardous waste, please call the CMO at x7994.

C. Accumulation

An important step in the chemical disposal sequence involves the temporary storage of waste at or near the point of generation. Except when single chemicals are accumulated for recycling or recovery, waste accumulation generally involves bulking several materials into one container. For example, compatible solvents and other organic liquids can be consolidated since they are bulked into a 55 gal drum for transportation off-site.

Please adhere to the following guidelines for safe accumulation of chemical waste:

• Use the pre-labelled hazardous waste containers that are available from the CMO.
• Label containers with words that clearly identify the contents the FIRST time waste is put into them. Generic names like "Waste Organics" are acceptable, but keep in mind that a Waste Characterization Sheet (WCS) listing ALL of the chemical components must be filled out before the waste can be accepted for off-site disposal.
• Separate incompatible wastes streams.
• Keep waste collection containers closed at ALL times during storage except when adding or removing waste. This is true for solids as well as liquids. Many containers, like beakers or flasks, for example are not acceptable accumulation containers.
• Designate an area in your lab as a chemical waste accumulation area. Reserving a portion of a hood for this purpose is ok, so long as there is still enough room to work with toxic or flammable chemicals.
• Remove full waste containers from the laboratory. Do not allow large quantities of waste to accumulate in the hoods.

Some chemicals that are not regulated as hazardous waste can be disposed of in the sanitary sewer or normal trash. The decision to use one of these methods of disposal must be made after careful consideration of the consequences.

D. Sink Disposal

Laboratory drains are connected to the local sanitary sewer system with the effluent eventually going to Hamilton's Wastewaste Treatment Facility. Materials that cannot be disposed of via the sanitary sewer are materials that interfere with the treatment systems or chemicals that may cause a danger to the system or human health. These chemicals include but are not limited to:

• Any substance that alone or by interaction with other substances can cause fire or explosion. Prohibited materials include but are not limited to: solvents and alcohols, peroxides, oxidizers, sulfides, hydrides, carbides, chlorates, perchlorates, bromates, carbides, ethers, gasoline, kerosene. Generally this includes wastes that would be characterized as ignitible.
• Solid or viscous substances that may cause obstruction to the flow such as garbage, animal guts or tissues, hair, bones, feathers, sand, metal, glass, straw, plastics, wood, rags, oil, grease, or paper.
• Waste having a pH less than 5.0 or greater than 9.5. Wastewater with corrosive properties capable of causing damage or hazard to structures, equipment, or personnel at the treatment plant.
• Waste containing toxic substances in sufficient quantity to interfere with the wastewater treatment process, constitute a hazard to humans or animals, or create a toxic effect in the receiving waters.
• Any noxious or malodorous liquids, gases, or solids.
• Heavy metals.
• Waste of objectionable color such as dyes or stains.
• Waste with temperature that inhibits biological activity (exceeding 104^o F).
• Any wastewater containing radioactive isotopes. Certain amounts are acceptable. Contact the RSO prior to disposal.
• Any cyanide in excess of 2 mg/l by weight as CN.

Sink Disposal Procedures

• Drain disposal will be only into a drain that is connected to the wastewater treatment plant, never into a storm sewer drain that flows directly to surface water.
• The quantities of chemicals disposed of in the drain must be limited generally to not more than a few hundred grams or milliliters. Flush with at least 100 fold excess of waste at the sink. Lab supervisors must monitor disposal for adherence to guidelines on type, quantity, rate, and flushing procedures.

E. Trash Disposal

Non-hazardous solids can be disposed of in the trash (no liquid wastes are allowed in the landfill). As mentioned before, the decision to use the trash must be made after careful consideration of the consequences. Non-hazardous materials will create a hazard if solid particles are inhaled or reach the eyes. A custodian may come in contact with it when he or she empties the trash. Our grounds grew could be exposed to the material when they handle the trash and compact it in the truck. All of our solid waste goes to the Madison County Landfill and will be there essentially forever.

Do not dispose of chemicals loosely in the trash. Minimize potential for exposure by encasing non-hazardous chemicals in bags, boxes, or containers. Never dispose of large amounts of non-hazardous chemicals in the trash. Broken glass should be collected in puncture resistant containers and disposed of in such a way as to protect custodians and the grounds crew. All empty chemical containers are collected in the blue recycling bins. Empty containers that once held a hazardous material will be rinsed clean to remove any residue. All residue containing hazardous waste will be managed as such.

Substances known to be toxic will not be disposed of in the trash even if they are not regulated as hazardous waste. The following types of solid laboratory waste are generally considered non-hazardous or of low toxicity and may be placed in the trash depending on quantities involved:

organic chemicals

• naturally occurring a-amino acids and salts
• citric acid and its Na, K, Mg, Ca, and NH4 salts
• lactic acid and its Na, K, Mg, Ca, and NH4 salts
• sugars and starches

inorganic chemicals:

• borates: Na, K, Mg, Ca
• carbonates: Na, K, Mg, Ca, Sr, NH4
• chlorides: Na, K, Mg
• fluorides: Ca
• oxides: B, Mg, Ca, Sr, Al, Si, Ti, Mn, Fe, Co, Cu, Zn
• phosphates: Na, K, Mg, Ca, Sr, NH4
• sulfates: Na, K, Mg, Ca, Sr, NH4

laboratory materials NOT contaminated with hazardous materials:

• chromatographic paper and absorbents
• filter paper, filter aids, and glassware
• rubber and plastic protective clothing

M5. Radioactive Waste

Radioactive waste will be disposed of in accordance with our New York State User License and 6 NYCRR Part 380. Currently, the options are sanitary sewer disposal and decay in storage. There are detailed procedures that must be followed for each of these options. Contact the Radiation Safety Officer (RSO) before undertaking any operations involving radioactive materials.

M6. Biological Waste

M7. Procedures

Hazardous waste accumulated in labs will be collected and consolidated or labpacked at Sb-3 McGregory Hall. The following procedures will be followed for disposal and collection of hazardous waste:

• Fill out and sign a generator's Waste Characterization Form (WCS). All of the constituents of the waste material must be listed, especially the constituents that make it a hazardous waste. List all significant components and their concentrations or percentage of the whole. If the material is in solution, name the solvent(s). See the example that follows.
• Bring the waste and WCS to the CMO during window hours.

The waste will not be accepted if:

• It is not accompanied by a properly filled out WCS.
• It is not in the proper container with a label.

NO UNKNOWN WASTES WILL BE ACCEPTED!