Environmental Health &Environmental Health & Safety at FITy

Waste Handling

•Recycling•Refuse•Refuse•RCRA

27 August 2008g

QuestionsQuestions

• If possible please hold your questions toIf possible, please hold your questions to the end – I may cover it during the presentation I have 53 slidespresentation. I have 53 slides.

• If not, interrupt & I may or may not answer you on the spotyou on the spot.

• Otherwise contact me & I will get your answer.

Part 1: Waste – What the heck is hi ff?this stuff?

• Recycled MaterialsR f (G b )• Refuse (Garbage)

• Sewage• Regulated “Non-Hazardous” Waste• Universal WasteUniversal Waste• Hazardous Waste

Recycled Materials

Recycled MaterialsRecycled Materials• Non-Waxed Corrugated Cardboard at Specific Locations g p

on campus.• EMPTY spray cans of things you eat or wear may go in

th bl bithe blue bins.• ALL other spray cans must go to the Bin at the east end

of the Machine shop (bldg. 538).of the Machine shop (bldg. 538).• All clean scrap metal (not containers) should be turned in

to the Machine shop for recycle.• All empty metal containers that contained items you do

not eat or wear should be turned into the Safety Office for hazardous recycle.for hazardous recycle.

Refuse (Garbage)Refuse (Garbage)Items that may not be part of th li d

• Food Scraps

the recycling program and are:

p• Alkaline or Carbon Batteries• Clean: Paper products, Plastic, Elastomers &Clean: Paper products, Plastic, Elastomers &

Glass.(Clean may be “dirty” as long as the “dirt” is something you eat or wear OR Containers that have held hazardous materials but are “EPA” empty – nothing mayContainers that have held hazardous materials, but are EPA empty nothing may leak or drip out when open).

• At FIT, items you may have treated as H h ld T h t H t b ll dHousehold Trash at Home may not be allowed as Garbage.

SewageSewage• Water with, well poop, &&&.• Paper products designed to be “flushed.”• Soaps & Detergents.g• Non-Listed* Acid solutions with pH above 5.5• Non-Listed* Basic solutions with pH below 9.5p• Again, if you flush it at Home it may not be ok

here at FIT.

* Listed means on an EPA List which classifies it as a hazardous material

No Pictures ☺No Pictures ☺

Ok, I Lied

Regulated “Non-Hazardous” WasteRegulated Non Hazardous Waste

• Preserved Carcasses that have been fullyPreserved Carcasses that have been fully drained.

• Old Tires• Construction debris – concrete, sand, etc.• Bio-Medical WasteBio Medical Waste• Radioactive Wastes• Waste Cooking Oil• Waste Cooking Oil• Other Used Oils

Non-Hazardous does not mean not dangerous.

Universal WasteA hazardous waste that is excepted from handing & reporting requirements.handing & reporting requirements.Examples:

Batteries (Lead-Acid, Lithium, NiMH, NiCd, Silver ( , , , ,Oxide, etc.)Fluorescent or Halide LampsComputer MonitorsEnd of Life ElectronicsMercury Containing devicesMercury Containing devices

These are collected and specialty recycledThese are collected and specialty recycled

Hazardous WasteHazardous Waste

R l t d d RCRA R• Regulated under RCRA – Resource Conservation and Recovery Act – 1976

• No longer fit or useful for its original purpose

• Must be a SOLID WASTE.• OK, They don’t mean a physical stateOK, They don t mean a physical state

reasonable people define as “solid.”

“Solid Waste” ExamplesSolid Waste Examples• Waste solvents• Spent antifreeze• Acids with a pH <2

B ith H>12 5• Bases with a pH>12.5• “Contaminated” plastics• Heavy metalsHeavy metals• Listed in 40 CFR 265• http://ecfr.gpoaccess.gov/cgi/t/text/text-

idx?c ecfr&sid 4295d3dca3a7b103bd9e593e5db55a4fidx?c=ecfr&sid=4295d3dca3a7b103bd9e593e5db55a4f&rgn=div6&view=text&node=40:25.0.1.1.2.4&idno=40

• Etc……

How do you know if it is a H d W ?Hazardous Waste?

• Listed by Law – Either RCRA or TSCA• Listed by Law – Either RCRA or TSCA…• Look it up in the federal register

Ch k h MSDS M i l S f D Sh• Check the MSDS Material Safety Data Sheet• Exhibits a Characteristic

CharacteristicsCharacteristics

• Ignitability - D001Ignitability D001– Liquid with flash point <60C (140F) (Ethanol)

Ignitable compressed gas– Ignitable compressed gas– Physical Solid that will ignite by:

• Friction• Friction• Adding moisture• Spontaneous combustionSpontaneous combustion

CharacteristicsCharacteristics

• Corrosivity – D002

– Liquid with:• pH >12.5• ph < 2.0

CharacteristicsCharacteristics

• Reactivity – D003Reactivity D003

I t t ith t h k h t– In contact with water, shock, heat or pressure, the material may undergo a rapid or violent chemical changechemical change

Eg: Dry Picric Acid Sodium Metal– Eg: Dry Picric Acid, Sodium Metal

CharacteristicsCharacteristics

• Toxicity – D004 to D043Toxicity D004 to D043

Heavy Metals & alloys (Arsenic Steel &– Heavy Metals & alloys (Arsenic, Steel & Aluminum alloys)

– Many organics (TCE benzene)– Many organics (TCE, benzene)

ListedListed• F – from non-specified sourcesp

– Eg: Toluene, MEK or spent solvents containing these chemicals

• K – from specific sources– Wood preserving waste, chemical production waste

• P – acutely Toxic• P – acutely Toxic– Pesticide wastes, some pharmaceuticals, phenols, strychnine

• U – Off-spec chemicals, expired chemicals, spill residues– Formaldehyde, aldehydes, solutions of same

Over 111 pages of materials are listed

Part 2: Compliance here at FIT to H d W LHazardous Waste Law

• Other than us, who cares?

Inspections (Usually d)unannounced):

• FDEP - Every 2 years (Feb 2007 – 2-1/2 days)• EPA - Every 2 years (Oct 2007 5 days)

Fi M h ll 12 th l (A 2008)• Fire Marshall – 12 month cycle (Aug 2008)• Liability insurance – Annual (2x)

– Life safety fire (Jul – 2 days)– Life, safety, fire (Jul – 2 days)– Pollution Liabilty (Sep – ½ day)

• Melbourne City Zoning Board – Annualy g• Brevard County Emergency Management – Annual• OSHA - Anytime

InspectionsInspections

• Remember, the regulators are not at fault the laws governing these areas have– the laws governing these areas have

been in their present form (mostly) since 19861986

How have we fared so far?How have we fared so far?• FDEP – Large numbers of violations from Feb. 2007 inspection.FDEP Large numbers of violations from Feb. 2007 inspection.

~$180,000 in Fines & ~$600,000 in corrective measures.• EPA – Oct 2007 Inspection uncovered an additional $500,000 in

potential fines mitigated thru pre-arranged “corrective immunity ”potential fines, mitigated thru pre-arranged corrective immunity.• Fire Marshall – large numbers of violations in 2007, $300,000 in

corrective measures taken – follow up inspection in August 2008.Liability Insurance April 2008 15 pages of “recommended• Liability Insurance April 2008 – 15 pages of recommended changes.”

• City – Current & A-OkC• Brevard County – ditto

• OSHA – only spot checks to date.

Examples of The Problems:Examples of The Problems:

Proper ExamplesProper Examples

What Should You Do?What Should You Do?

• Our Generator StatusOur Generator Status• Training

S t llit A l ti A• Satellite Accumulation Areas• Labeling• MSDS• InventoryInventory

Generator StatusGenerator Status• CESQG – Conditionally Exempt Small Quantity Q y p Q y

Generator– Less than 220 pounds of Hazardous waste disposed

in any given month (1/2 drum)in any given month (1/2 drum)• SQG – Small Quantity Generator

– Between 220 pounds and 2200 pounds of hazardousBetween 220 pounds and 2200 pounds of hazardous waste disposed in any given month (1/2 to 5 drums)

• LQG – Large Quantity Generator– More than 2200 pounds of hazardous waste disposed

in any given month AND/OR more than 2.2 pounds of acutely toxic waste in the same period.

Why is this Important?Why is this Important?

• We are a LQGWe are a LQG.• An LQG is subject to all EPA rule &

regulation almost no exceptionsregulation – almost no exceptions.• Residences operate under an EPA

ti i t h illexception – your experience at home will not help you.

• How it was in the past, is not relevant.

TrainingTraining

• Law requires that anyone who handlesLaw requires that anyone who handles hazardous waste must be trained by a trainer in accordance with 40 CFR 265.16

• You cannot self train.• Law requires refresher training EVERYLaw requires refresher training EVERY

YEAR you will handle hazardous waste.• As a Student you are our 1st line ofAs a Student you are our 1 line of

defense to regulatory compliance.

Satellite Accumulation Areas (SAA)Satellite Accumulation Areas (SAA)

• If your lab has Listed or CharacteristicIf your lab has Listed or Characteristic materials – regulators expect/require a formal SAA.

• Hazardous waste containers must alwaysbe closed, unless adding or taking out. (All g g (Lab containers must always be closed unless in immediate use)

• Needs secondary containment for many materials – use of sinks is Forbidden for or

SAAnear SAA.

SAA ContinuedSAA Continued

• Must be inspected every week or more often byMust be inspected every week or more often by the responsible person for that Lab.

• SAA may hold up to 55 gallons of hazardous y p gwaste or until their assigned containers are full before they must “turn it in.” Otherwise they may remain there indefinitely.

• FIT must dispose every 90 days from the Central H d l iHazardous waste accumulation areas

Central Accumulation AreaCentral Accumulation Area

FIT Currently has 3

• Q407 room 710 – central main•OPS Solvent storage room• Mechanical Yard near Shipping

LabelingLabeling• EVERYTHING must be

labeled.• Waste must be

specifically labeled: HAZARDOUS WASTE

• If something is not labeled, regulatorslabeled, regulators assume it is waste.

LabelingLabelingThis does not just apply to Hazardous wastes.

Everything Must be labeled. Does not have to be fancy pre-printed labels.be fancy pre printed labels.

May NOT use abbreviations. Must Write it out.

MSDSMSDS

• Law requires that MSDS are readilyLaw requires that MSDS are readily available to anyone who might be in your lablab.– Includes facilities, janitors, 1st responders, etc.

Law requires that anyone working in your• Law requires that anyone working in your lab must have 1st read the MSDS BEFORE using any given substanceBEFORE using any given substance.

MSDS ContinuedMSDS Continued

• MSDS is your 1st line of defense in:MSDS is your 1 line of defense in:– Knowing what personal protection equipment

law requires you to use when using thelaw requires you to use when using the substance

– Knowing how the waste generated with thatKnowing how the waste generated with that substance needs to be handled – either explicitly or by characteristic evaluation

– Is the product Label Enough? NO.

InventoryInventory

• We are required by law to keep & maintain anWe are required by law to keep & maintain an annual inventory of all our chemicals.

• Universities to not have an exemption from this prequirement.

• We report this to (in various forms):p ( )– The City to confirm we are operating within our zoning

restrictions (all FIT is zoned for business use)– The Emergency folks: city, county, & state– The EPA & FDEP

DiscussionDiscussion

I d ll h ll h• I do not personally have all the answers; however, I know the resource people and references that do – both legal & technicalg

• I cannot over emphasize – ask questions. • YOU are legally liable for your actions. We will

support you with whatever you needsupport you with whatever you need.• peebles@fit.edu• FIT extension: 7715FIT extension: 7715• Cell: 321-917-5484