In the past, UAF facilities have been inspected annually.
Our goal is to comply with all regulations.
Hazardous waste at UAF An overview of sources of hazardous waste at UAF, and of their ultimate fate…
Sources of Hazardous Waste at UAF
Sources of hazardous wastes at UAF include:
Research and academic laboratories
Shops and repair facilities
Art and theater departments
Facility maintenance and grounds
Power Plant operations
Experimental Farm operations
Hazardous Waste Generators
The RCRA definition of a hazardous waste generator is:
Any person, by site, whose act or process produces hazardous
waste identified or listed in 40 CFR 261.3.
Generators are classified by the volume of hazardous waste
that they produce per month:
CESQG = Conditionally Exempt Small Quantity Generator
SQG = Small Quantity Generator
LQG = Large Quantity Generator > 1000 kg/month or
>1 qt. of acutely hazardous waste/month
UAF’s Waste Generator Status
The UAF main campus is currently regulated as a Large Quantity Generator of hazardous waste.
UAF’s extended sites are currently regulated as Conditionally Exempt Small Quantity Generators
Examples: Toolik Field Station, Palmer Research Farm, FITC in Kodiak, Seward Marine Center, Lena Point Fisheries Facility, etc.
Hazardous Waste Management at UAF
EHS&RM assists UAF waste generators with their waste disposal needs.
Wastes are stored in the Hazardous Materials Facility (HMF), which serves as the Central Accumulation Area (CAA) for UAF.
RCRA-regulated hazardous wastes are shipped every 90 days from the HMF.
Wastes are shipped by EPA-permitted transporters to EPA-permitted treatment, storage, and disposal facilities.
Annual costs: $125,000 for disposal; $400,000 total cost of hazmat program at UAF.
What is hazardous waste?
EPA definition of a solid waste
EPA begins by defining everything as a “solid” waste (including solids, liquids, gases, and semi-solids)
40 CFR 261.2 provides the definition of “solid waste”:
(a)(1) A solid waste is any discarded material that is not excluded by § 261.4(a) or that is not excluded by variance granted under §§ 260.30 and 260.31.
(2) A discarded material is any material which is:
(i) Abandoned, as explained in paragraph (b) of this section; or
(ii) Recycled, as explained in paragraph (c) of this section; or
(iii) Considered inherently waste-like, as explained in paragraph (d) of this section; or
(iv) A military munition identified as a solid waste in 40 CFR 266.202.
(Again, no need to memorize that!)
EPA definition of a hazardous waste
If the waste material meets certain criteria, and is not somehow exempted or excluded from the regulations, it may be a RCRA-regulated hazardous waste.
40 CFR 261.3: definition of a hazardous waste:
( a) A solid waste, as defined in § 261.2, is a hazardous waste if:
(1) It is not excluded from regulation as a hazardous waste under § 261.4(b); and
(2) It meets any of the following criteria:
(i) It exhibits any of the characteristics of hazardous waste identified in subpart C of this part. However, any mixture of a waste from the extraction, beneficiation, and processing of ores and minerals excluded under § 261.4(b)(7) and any other solid waste exhibiting a characteristic of hazardous waste under subpart C is a hazardous waste only if it exhibits a characteristic that would not have been exhibited by the excluded waste alone if such mixture had not occurred, or if it continues to exhibit any of the characteristics exhibited by the non-excluded wastes prior to mixture. Further, for the purposes of applying the Toxicity Characteristic to such mixtures, the mixture is also a hazardous waste if it exceeds the maximum concentration for any contaminant listed in table I to § 261.24 that would not have been exceeded by the excluded waste alone if the mixture had not occurred or if it continues to exceed the maximum concentration for any contaminant exceeded by the nonexempt waste prior to mixture.
(ii) It is listed in subpart D of this part and has not been excluded from the lists in subpart D of this part under §§ 260.20 and 260.22 of this chapter.
So… is your waste a hazardous waste?
The good news…
The good news is, you don’t have to make that determination.
The UAF Hazmat team will decide whether your waste is a RCRA-regulated hazardous waste, a non-regulated hazardous waste, or a non-hazardous waste.
Even though you don’t have to decide what to call your waste, let’s look at the different categories as defined by the EPA.
Categories of Hazardous Waste
Hazardous wastes are regulated because they present special hazards to man or to the environment if they are improperly disposed of or discarded.
Hazardous waste determinations are based upon whether the
material is a:
Listed on the D-list or TCLP
A listed waste
materials specifically identified on one of the following lists: F, K, U or P lists
Universal waste (batteries; lamps; pesticides; mercury from thermometers)
D001 – Ignitable Wastes (flashpoint is less than
140 0 F) includes oxidizers…
D002 – Corrosive Wastes (pH less than or equal to
2 or greater than or equal to 12.5)
D003 – Reactive Wastes (water reactives,
normally unstable materials, cyanides &
D004 - TCLP Wastes
(Toxicity Characteristic Leaching Procedure)
F-listed wastes are from non-specific sources
Example: halogenated solvents used to degrease equipment
K-listed wastes are from specific sources
Example: product washwaters from the production of dinitrotoluene via nitration of toluene
U-listed wastes are toxic wastes
P-listed wastes are acutely hazardous wastes
Examples of U-Listed Wastes U-listed chemicals are commonly found in UAF labs. Acetaldehyde 1,4-Dioxane Acetone Ethyl acetate Acetonitrile Ethyl ether Aniline Formaldehyde Benzene Methyl alcohol Bromoform Methylene chloride 1-Butanol Phenol Chloroform Toluene
Examples of P-Listed Wastes P-listed chemicals are also fairly common in UAF labs. Allyl alcohol Osmium tetroxide Ammonium vanadate Phenylthiourea Arsenic acid Potassium cyanide Arsenic trioxide Sodium azide Carbon disulfide Sodium cyanide 2,4-Dinitrophenol Thiosemicarbazide Fluorine Vanadium oxide Nitric oxide Vanadium pentoxide
Universal wastes include the following materials that are commonly found in the workplace
Thermometers (containing mercury)
Universal wastes: Batteries
Used Battery collection containers are available at many locations on campus.
Contact your Lab Manager, CHO, Shop Supervisor or EHS&RM for more information.
Universal wastes: Fluorescent Lamps
UAF collects fluorescent and other lamps for recycling
Lamp shipments are made periodically to EcoLights Northwest.
The Facilities Services Electric Shop does the vast majority of lamp replacement on campus.
If you have fluorescent lamps (or other types of lamps) that you use in your research, and are responsible for replacing them, EHS&RM can provide lamp collection boxes and labels to you.
Boxes must be labeled with the words, “Universal Waste Lamps”, “Waste Lamps”, or “Used Lamps” to identify the contents.
Universal wastes: pesticides and waste from mercury thermometers
Please fill out a UAF Non-radioactive Hazardous Materials Transfer Request Form if you have waste pesticides or mercury from broken thermometers.
The transfer forms will be explained later in the training.
Note: if you break a thermometer, do not try to clean it up yourself. Call UAF Hazmat at 474-5617 immediately for assistance.
Do not ever throw the material in the trash, or dump it down the drain.
Universal waste: Used Oil
Used oil means any oil that has been refined from crude oil, or any synthetic oil, that has been used and as a result of such use, is contaminated by physical or chemical impurities.
Used oil must be:
Collected in clean containers in good condition (no leakers please)
Storage and transfer containers must be marked with the words “Used Oil”
Never add solvents, part washer fluids, carb cleaners, or glycol to your used oil
Keep the “used oil” container closed (lid in place and secured) except when adding or removing used oil
Call EHS&RM Hazmat (474-5617) to have your used oil removed
Waste in your lab What do I do with my wastes and unwanted chemicals?
Satellite accumulation areas
Each lab that generates waste is referred to as a “Satellite Accumulation Area” (SAA)
When EHS&RM removes the waste from a SAA, it is transferred to the UAF Hazmat Facility or “Central Accumulation Area”
Waste Storage Limits for SAAs
For SAAs, the waste storage limits are:
Up to 55 gallons of a U-listed waste
Up to 1 quart (1 liter) of a P-listed waste
Note: you do not need to accumulate 55 gallons or 1 quart of P-listed waste before requesting waste removal!
50 gallons of waste at a SAA will likely be in violation of Fire & Building Codes
Space is a very valuable asset. Give us a call anytime to remove your waste (474-5617).
To Make a Waste Removal Request
Complete the Non-Radioactive Hazardous Materials Transfer Request form.
Forms are available from your Lab manager, Chemical Hygiene Officer, Shop Supervisor, or EHS&RM.
There is no charge to your lab for chemical waste disposal.
The transfer forms are numbered and come with a similarly numbered adhesive label (fluorescent orange) that must be applied to the waste collection container.
Completing the transfer form
Fill out the upper portion of the transfer form.
Name and contact info
Location of waste (building and room number)
Chemical(s) in waste, and their concentrations
For mixtures, list all constituents
If more room is needed, attach a separate list to the form
Type of container and physical state of the waste
Number of containers, their volume, and the total volume
Haz Mat Transfer Request Form
If you have multiple containers of the same waste stream (identical contents), just fill out one form.
Unnumbered adhesive labels are available to go on multiple containers.
Use the number as identified on the upper right hand side of the transfer form and identify the container as being 1 of 4; 2 of 4, etc.
Getting your waste picked up
Call 474-5617 to schedule a pickup, or if you have any questions about your waste.
The form comes in three parts… Save the pink copy for your files. Give the white and yellow copies to EHS&RM when they come to pick up your waste.
Take-home messages What you need to remember…
Wastes: containers and storage
Only use containers that are compatible with the materials to be collected.
Always label containers with a description of their contents.
Don’t store incompatible materials together.
Do not store wastes in the fume hood. Store in the appropriate storage cabinet (e.g., flammable, acid).
Provide secondary containment for liquid wastes.
ALWAYS keep the container closed (lid firmly secured).
A funnel in an open bottle is NOT a lid.
Check waste storage areas regularly (weekly).
Inspect containers to make sure they aren’t getting brittle or starting to crack.
If you need waste containers, contact EHS&RM or your Chemical Hygiene Officer to inquire about availability.
Before you start a project…
Is there a product or procedure available that will accomplish the task without generating a hazardous waste?
Strive for waste minimization
Only make as much solution as you need
Substitute less hazardous chemicals if possible
Use microscale chemistry techniques
Before purchasing chemicals, check with EHS&RM or your department Chemical Hygiene Officer for the availability of surplus chemicals.
Other things to think about
Check the P-list. If you plan to generate a P-listed waste, contact your Chemical Hygiene Officer, Lab Manager or EHS&RM.
Never combine wastes.
If you don’t generate them together as part of a procedure, then do not mix them.
May create hazardous reactions in the bottle (worst-case scenario), or make it more expensive for us to dispose of it (not a good scenario, but at least it didn’t blow up).
Call EHS&RM at anytime to request waste removal.
Emergency Response Chemical spills, release of hazardous materials, fires, and evacuation
Report all spills to UAF Dispatch (474-7721) or call 911 if there is an immediate threat of harm to life or property.
Dispatch will call EHS&RM Hazmat Section or, if necessary, the FNSB Hazmat Team, to request assistance with spill cleanup.
Depending on the nature of the spill, you may be asked to complete the UAF Oil and Hazardous Substance Spill Reporting Form (available from EHS&RM).
Chemical Spills (cont.)
If you have not been trained and/or do not have the appropriate personnel protective equipment, please call for assistance!
Never put yourself or others at risk to cleanup a spill.
If you don’t know…don’t go.
Emergency Procedures: Fire
Activate the nearest fire alarm pull station and call 911.
Evacuate the building and go to the Evacuation Assembly Point or designated area of safe refuge.
Advise emergency personnel of anyone still inside the building
Do not re-enter the building until authorized by emergency personnel.
Emergency Procedures: Release of Hazardous Materials
In the event of an emergency or if anyone is in danger, call 911.
Move away from the site of the hazard to a safe location.
Follow the instructions of emergency personnel.
Alert others to stay clear of the area.
Notify emergency personnel if you have been exposed or have information regarding the release.
Emergency Procedures: Evacuation
Know the evacuation procedures and evacuation route information for your area.
Evacuate the building using the nearest safe exit.
Do not use elevators!
Take personnel belongings (keys, purses etc., but don’t put yourself or others at risk by delaying evacuation).
If possible, secure any hazardous materials or equipment.
Follow the directions given by emergency personnel.
Go to Evacuation Assembly Points (EAPs) designated on the emergency evacuation sign for the building.
Assist persons with disabilities.
Do not leave the area/campus until your status has been reported to your supervisor or instructor.