Waste Management Policy and Procedures

Delaware Valley College is committed to pollution prevention and the management of hazardous and solid wastes in compliance with applicable regulations. It is our goal to (a) reduce these wastes; (b) reuse or recycle them, when possible and (c) manage them safely and in accordance with the law.

Hazardous materials and wastes generated on campus range from soiled and oily rags to toxic laboratory wastes and are handled by a wide variety of trained faculty and staff. The following information is designed to provide an introduction to the proper management and disposal of wastes on campus. These wastes should never be poured down the drain.

To everyone who may play a role in the generation and management of these wastes, please remember the following basic tenets of good management:

1. Compliance and safety is everyone's job.
2. Manage the accumulation of wastes only at designated areas.

Batteries

All batteries used on campus will be sent off-site to a recycling facility. Batteries can be dropped off at the following locations:

• Physical Plant

Chemical Waste Segregation

Waste containers should be physically separated according to this compatibility chart.

• Acids - Inorganic
• Acids - Organic
• Bases - Alkaline
• Bases - Flammable
• Flammable Liquids
• High-Hazard Peroxide Formers
• Mercury or any Solutions Containing Mercury
• Metals or Solutions Containing Metals
• Oil
• Oxidizers
• Pesticides
• Photo Fixer; Developer; Other
• Reactives
• Silica Gel
• Solvents: Non-Halogenated Organic
• Solvents: Halogenated
• Water Reactive Compounds

Other Resources: Prudent Practices in the Laboratory by the National Research Council. You can also perform a "Google" search on ‘chemical compatibility storage' for several resources.

Contractor Responsibility for Hazardous & Universal Wastes

Outside contractors are responsible for the removal of any waste they create. It is recommended that clear guidelines be established on project scope documents.

Emergency Response Information

In the event of a hazardous material release, take the following actions:

Minor Chemical Spill - a small spill (e.g., <1 Liter) in your immediate work area that does not pose a significant risk of harm.

1. Alert people in the immediate area of spill.
2. If you clean up the spill, be sure to use the appropriate Personal Protective Equipment (PPE), such as safety goggles, gloves and long-sleeved lab coats.
3. Confine spill to a small area by circling the spill with absorbent and work inward. Use the appropriate kit to neutralize and absorb inorganic acids and bases.
4. Collect residue and place in container, label and dispose of as chemical waste. Check with your supervisor if it should be managed as a hazardous waste.

Major Chemical Spill - 1 Liter or Greater (and likely to produce a harmful concentration in the air)

1. Attend to injured or contaminated persons and remove them from exposure.
2. Alert people in the immediate area to evacuate.
3. If the spilled material is flammable, turn off ignition and heat sources if you can do so without putting yourself at risk.
4. Close the door(s) to isolate the area.
5. Call Campus Security at extension 2315 from a safe location.
6. Campus Security will contact EHS, who will secure a trained clean up crew to manage and dispose of spilled material.

Fire

1. Alert people in the immediate area
2. Vacate the area and pull the fire alarm
3. Contact campus police at extension 2315 once you are in a safe location.

Key Phone Numbers

Department of Public Safety and Security - extension 2315 or 911 for all emergencies

Equipment Disposal
When disposing of equipment review the following prior to disposal.

1. Was the equipment used in radioactive experiments or used to store radioactive materials? Does it have a radiation sticker or is there a radioactive source in the equipment? If yes, contact EH&S.
2. Could the equipment be contaminated with hazardous chemicals? If possible, the equipment should be thoroughly cleaned prior to disposal.
3. Was the equipment used with bio-hazardous material? If yes, the equipment should be decontaminated with appropriate cleaners.
4. If the equipment is a refrigerator or freezer or other type of equipment that could contain freon, contact maintenance services at extension 2228 to remove the freon prior to disposal.
5. Does the equipment contain oils, antifreeze or other types of chemicals? If yes, the chemical/oil should be drained prior to disposal. The drained material should be put into hazardous waste containers.
6. If the equipment could contain asbestos, such as an oven, the Physical Plant Office (extension 2228) should be contacted for disposal.
7. After following the above steps, make sure all hazard stickers are removed prior to disposal.
8. After following the above procedures, the equipment should be ready for pick up and disposal.

Gas Cylinder Disposal

1. Most five foot tanks are rented. When empty, these tanks are usually exchanged. Each department is responsible for this function.
2. Small, lecture-size gas cylinders should be returned to the manufacturer once empty. Keep manufacturer labels intact.
3. If gas samples, called "spuds" are received, arrangements should be made for return to the manufacturer. The department accepting these samples is responsible for this function.
4. Releasing contents of a cylinder as a disposal method is strictly prohibited.

Handheld Electronics

All small handheld electronics used on campus will be sent off-site to a recycling facility. They can be dropped off at the following locations:

• Physical Plant
• Media Center
• Information Services

Hazardous Waste - Definition

EPA regulations define a hazardous waste as a "solid waste or combination of solid wastes, which because of its quantity, concentration, chemical or infectious characteristics may (1) cause or significantly contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness or (2) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of or otherwise managed." EPA also states a waste is hazardous if it is "ignitable, corrosive, reactive or toxic" or fits one of these lists: (1) Non-Specific Source Wastes (F Codes); (2) Discarded Commercial Chemical Products, Off-Specification Species, Container Residues and Spill Residues; (3) Acute Discarded Waste [in its original form](P Codes); (4) Toxic Discarded Waste [in its original form] (U Codes).

Two important federal acts are:

RCRA: The Resource Conservation & Recovery Act passed in 1976. It empowered the Environmental Protection Agency (EPA) to regulate the disposal of solid and hazardous waste. In Pennsylvania, the Department of Environmental Protection (DEP) oversees this program. In 1984, the Hazardous & Solid Waste Amendments banned hazardous waste from landfills.

CERCLA: The Comprehensive Environmental Responsibility, Compensation and Liability Act, known as Superfund was enacted in 1980. This law makes the original generator of a waste responsible for that material forever.

Hazardous Waste Accumulation Areas
Main Accumulation Area (MAA): An area on campus where hazardous wastes are collected and managed prior to off-site shipment. Greater than 55-gallons of hazardous waste can be accumulated in MAAs. Check the following weekly:

• Containers Closed tightly
• No signs of leakage
• No signs of corrosion
• Segregated properly according to compatibility
• Proper aisle spacing
• Labels Marked as "hazardous waste"
• Marked with chemical constituents
• Marked with hazards
• Dated (upon entering waste area)
• Signage MAA signs visible
• Area marked as "hazardous waste"
• Emergency Information & Equipment Contact phone numbers available and posted
• Spill clean up supplies and PPE should be immediately available
• General Area secure (i.e. locked)
• Floor/Shelving in good shape

Satellite Accumulation Area (SAA): An area that is at or near the site of generation of hazardous waste. The SAA must be under the control of a designated person who works in the immediate work area. Storage is limited to one container per waste stream, which may not exceed 55 gallons. The management requirements are less stringent than for a Main Accumulation Area but must be checked weekly.

• Containers in secondary containment
• Containers fully and properly labeled
• Containers closed at all times except when adding or removing chemical
• Containers properly segregated
• Containers in good condition
• Area secure
• SAA signage posted
• Only one container per waste stream/type

Hazardous Waste - General Information

A hazardous waste contractor provides turnkey services for Delaware Valley College to safely and appropriately manage its hazardous waste. Motor Pool manages waste oil at the garage. Science Center staffs manage waste generated in the science center to include hazardous chemical waste, radioactive waste, sharps, biological waste, etc. Health Services manages biological waste generated at the infirmary.

• Segregate hazardous chemical waste according to compatibility.
• Choose appropriate impervious containers for storage.
• Flammable wastes should only be stored in 1 gallon containers except for 2.5 gallons stored in fireproof rated cans.
• All containers must be properly labeled with waste labels. Complete chemical names must be used. Hazard info should be noted.
• Date the container when full or when ready for disposal.
• Only one container at a time may be used to collect one waste stream (one type of waste). The container will have a maximum capacity of 55 gallons.
• Waste containers must be kept tightly closed at all times except when pouring in waste. Funnels may only be inserted when pouring in waste.

Hazardous Waste Manifest

Under the EPA/DEP Hazardous Waste regulations, it is specified that a hazardous waste manifest must be used for the shipping of hazardous waste. The manifest must accompany the waste wherever it goes.

To ship hazardous waste off the premises, the waste must be packaged and labeled. The College contracts an outside company to analyze, certify, package and label our drums and containers, as required by the U.S. Department of Transportation (USDOT). The contractor will transport the waste. Transporters must have an EPA identification number. The waste is then shipped to a facility permitted or authorized by the EPA to accept hazardous waste.

You must be approved to sign a manifest; annual training is required, and you must also be familiar with the waste shipment.

Basic Steps:

1. Currently, each state has its own manifest. Soon, EPA will be requiring a uniform manifest for every state.
2. Once the contractor is done packaging the shipment, they will record all materials to be disposed of on all or one of these forms:

1) packing slips
2) hazardous waste manifests
3) land ban forms.

3. You will be provided with all documentation. Check the manifest before signing for:

• Correct US EPA ID NO. - contact EHS for number
• All sections are complete and legible.
• Ensure that in section 3 - to have either your ‘department/name' or ‘EHS Office'. This will ensure that the final manifest signed by the destination site is sent back on a timely basis.
• The generator (you) sign section 16.

4. The contractor will leave you with copies 6, 7, and 8. Send all original copies to EHS. Make a copy for your files. Also send the other documentation noted above to EHS.
5. If/when you receive copy 3 in the mail, send original to EHS, and make a copy for your files.

The only way to ensure that the college is meeting ‘Small Quantity Generator Status' threshold quantities set by DEP is by totaling all waste generated on campus on a monthly basis. The number indicated on the waste manifest is the only way to accomplish this task.

Hazardous Waste - Training

All generators who are responsible for hazardous waste management in their area/department must receive annual awareness training. EHS will schedule this on an annual basis. Topics covered include generator status, hazardous waste determination, hazardous characteristics, accumulation and storage requirements, transportation procedures, manifests, land disposal restrictions, waste minimization, emergency response and record keeping.

Oil and Latex Paint Management

Hazards:

• Oil based paints and stains contain volatile organic compounds (VOCs) that vaporize at room temperature; vapors may be toxic when inhaled.
• Oil based paints and stains are flammable - store away from sources of sparks or heat.
• Old oil based paints and marine paints may contain lead, mercury, chromium or cadmium, which are toxic to humans, animals and the environment.

Handling:

• Containers should be opened in a well-ventilated area. Wear appropriate respirator (must be approved by medical professional to wear a respirator - contact EHS) when pouring off or mixing large volumes of oil-based paints.
• Identify leftover paint as latex or oil-based. Latex paint is labeled as such or has instructions to clean up with water. Oil based paint may be labeled: alkyd, contains solvents, clean up with mineral spirits, combustible, or enamel.
• Pourable paint may be reused, unless it contains lead. To test if paint is still good, paint a small test area on clean surface and allow to dry for 48 hours. Place a piece of masking tape over the paint and pull off. If paint comes off on the tape, the paint is no longer good.
• To store usable paint for long periods of time, cover the opening of the paint can with a piece of plastic wrap and seal the lid tightly. Store the can upside down and away from heat.
• Do not store latex paint outside or in unheated area. Frozen latex paint cannot be reused.
• Do not put liquid paint in the trash, down a storm sewer, or down a sink drain.
• Do not dry out oil based paints, stains or wood finishes for disposal in the trash. The volatile chemicals are air pollutants.

For surplus latex or oil-based paints:

• Take to the municipal surplus paint collection program, if available.
• If the paint is usable and there is a reasonable quantity, try to donate it to a community service organization or theater group.
• Latex paint can be disposed of as trash if dry. To dry small amounts, remove lid and let the paint dry in the can. For larger amounts, mix in "speedi dri" or pour one-inch layers of paint in a cardboard box lined with a plastic bag. Stir the paint occasionally to speed drying. Put completely dried paint in the trash.
• Hardened oil-based paint can also be disposed of in the trash.
• If no reuse or recycling option is available or convenient for oil-based paints, they should be saved for hazardous waste collection.

Pollution Prevention & Waste Minimization

End of Process Treatment

End of process treatments can be incorporated. This can include neutralization procedures or other standard practices outlined in many reference materials.

Management

Periodic inventories of chemical supplies, inventory control, and purchase of minimal quantities are all ways to manage chemicals in your area.

Process Modification

Use of micro-scale techniques or a decrease in the use of hazardous materials can reduce the amount of waste generated.

Product Substitution

Use of non-hazardous and less toxic chemicals in your area is a safe and environmentally friendly way to reduce chemical hazardous waste.

Recycling

Segregation and Characterization

Hazardous and non-hazardous waste should not be mixed. Follow guidelines on the proper segregation of hazardous waste to minimize costs.

Training

Employees and students should all be made aware of the above concepts to reduce waste generated.

Signage

Contact EH&S for MAA or SAA signage which is required to be posted by all accumulation areas.

• No Smoking Signs must be posted by all MAA's.
• "No Pouring Chemicals Down the Drain" signage available for sink areas.

Toner & Ink Cartridges

Used toner and ink cartridges may be sent back to the manufacturer. Most manufacturers are including return boxes for shipment with orders. Ink jet cartridge: please dispose of all expended cartridges at Information Services (Feldman basement).

Questions on disposal may be directed either to the distributor, Information Services or EH&S.

Universal Waste

Definition:

• Material that cannot go to a regular landfill, so it cannot be disposed of in the regular trash.
• Requires special handling procedures
• Must use a licensed disposal contractor.

Types:

• Lamps and Bulbs that contain mercury or lead. Examples include fluorescent, neon and mercury vapor.
• ‘Green Cap' bulbs are universal waste.
• Cathode Ray Tubes or CRTs contained in computer screens and television sets.
• Batteries to include nickel-cadmium and small sealed lead acid batteries.
• Larger lead acid batteries for cars are subject to other regulations.
• Thermostats that contain mercury.

Management

• Universal Waste must be kept in containers or packages.
• Containers must be kept closed and lack evidence of leakage, spillage, or damage.
• It is recommended that box dividers are used to avoid breakage.
• Designated storage areas must be set up to manage universal wastes on campus
• Waste lamps must be put in appropriate storage at the end of each work shift and placed in designated universal waste accumulation area(s).

Labeling

• The waste itself or the package must be labeled:

"Universal Waste - _____________" (type of waste)

Accumulation Time Limits

• Held for one year from the date generated.
• Containers should be dated with the beginning accumulation date.

Inventory

• An inventory system must be in place that identifies the date an item is placed in storage.
• Identify what is in storage at any given time.

Releases, Spills, or Breakage

• Must be immediately contained, cleaned up and the material disposed of properly.

Shipment

• Must track waste shipments and generation to know ‘waste status.'