Office of Environmental Health and Safety

Hazardous and Regulated Waste Management Plan

This Hazardous and Regulated Waste Management Plan describes chemical waste management practices at Connecticut College. This Plan includes waste generated at all College locations with the exception of the Science Departments in Hale Laboratory, New London Hall, Bill Hall, and Olin Science Center. Waste management procedures for those locations are described in the College's Laboratory Safety Handbook.

What is a Hazardous Waste?

In order to determine proper handling procedures and disposal, a decision must be made regarding whether the chemical waste is a hazardous waste, or is otherwise regulated. Connecticut DEP and federal EPA regulations (40 CFR) define various categories of hazardous and regulated chemical waste. A hazardous waste as defined by RCRA, is any discarded material that is not excluded by the regulations and that meets either of the following criteria:

• F-Listed Wastes (Commonly found wastes, ranging from solvents to wastewater treatment sludges.)
• K-Listed Wastes (Wastes that are generated from specific processes or sources within certain industries. K-Listed wastes are not generated at Connecticut College.)

• P-Listed Wastes (Chemicals that are considered to be "acutely" hazardous, because of their high toxicity.)
• U-Listed Wastes (Chemicals that are considered waste because they are no longer needed, they are spilled, or they are off-specification.)

In addition, Used Oil containing more than 1000 ppm total halogens must also be managed and disposed of as hazardous waste.

Hazardous Waste Characterization

The individual generating the waste is responsible for dermining if the waste is a "Hazardous Waste" as defined by regulation. This can either be done by:

• testing the waste according to the methods set forth in Subpart C of 40 CFR part 261, OR
• applying knowledge of the hazardous characteristic(s) of the waste in light of the materials or the processes used ("knowledge of process".)

A generator can use his/her knowledge of a waste to make a determination as to whether the waste is a characteristic hazardous waste. In order to use knowledge to characterize the waste, the generator must consider the raw materials that constitute the waste, and/or the process(es) that result in the waste being generated.

In considering the materials that make up the waste, the generator needs to examine the specific chemical and physical characteristics of the waste material. Information such as Material Safety Data Sheets (MSDSs) can be a helpful resource. However, while MSDSs can provide useful information regarding ignitability (flash point), corrosivity (pH), and reactivity, they tend to be less useful when it comes to identifying the toxic characteristics of waste. MSDSs do not include all of the ingredients in a certain material, but only those that make up greater than 1% of the total constituents of that material. This means that a waste may contain a toxic constituent exceeding the regulatory limit (making it a hazardous waste), but this constituent may not necessarily be included on the MSDS. Generators should also be aware that MSDSs are representative of raw materials; the MSDS may not accurately represent a waste material that is generated by the use of a particular raw material.

In considering the process that generates the waste, the generator needs to ask himself/herself: How does the operation/process affect the waste? For example, does the process make the waste ... more concentrated? ... more dilute?... contain free liquids?... become contaminated? ...etc.

One critical factor in using knowledge to characterize waste, is that the knowledge must be applied appropriately. In other words, the knowledge that is applied must be valid and verifiable. A generator should not just assume that a waste is non-hazardous without providing some type of supporting, verifiable information to justify that conclusion. Using knowledge of the waste to conduct a hazardous waste determination involves a well thought out process in which the waste materials or the process generating the waste are considered. It should be noted that, more often than not, it is easier to use knowledge of the waste to characterize it as hazardous than it is to characterize it as non-hazardous.

Hazardous Waste Disposal

At Connecticut College, generator of any hazardous waste is responsible for providing information that will allow the Director of Environmental Health and Safety to properly characterize and mainifest the waste for disposal. The Director of Environmental Health and Safety is the only person authorized to schedule shipments of wastes described in this plan, and to sign manifests and/or bills of lading. He may, when necessary, designate this authority for a particular shipment to a trained and qualified alternate.

As previously discussed, all wastes must be properly characterized prior to disposal. Contact the Director of Environmental Health and Safety before generating any new waste streams, to facilitate that characterization.

Generator Status

Connecticut College is a Small Quantity Generator (SQG). A Small Quantity Generator is one who generates greater than 100 kilograms but less than 1,000 kilograms of hazardous waste in a calendar month, provided that such waste does not include more than:

• a total of one kilogram of acute hazardous wastes, or
• a total of 100 kilograms of any residue or contaminated soil, waste, or other debris resulting from the clean-up of a spill, into or on any land or water, of any acute hazardous waste, provided that there is no more than a total of one kilogram of acute hazardous waste contained in that residue, soil, waste or debris.

Accumulation Time Limits and Quantities

A small quantity generator may accumulate hazardous waste on-site for 180 days or less provided that the quantity of waste accumulated on-site never exceeds 1,000 kilograms.

Satellite Accumulation Areas

A Satellite Accumulation Area is the location at the point of generation where containers of waste are accumulating as waste is generated. Routine hazardous waste generation locations and wastes are listed below.

Physical Plant:

• Oil based paint and paint related waste (solvents) in the paint shop.
• Paint solids contaminated with lead in the paint shop.
• Pressurized aerosol cans for disposal in the storeroom.
• Part washer solvent in the garage and Power Plant.
• Waste compressor oil.

Print Shop:

• Paper and cloth solids contaminated with blanket wash (perchlorethylene), inks and other solvents.
• Spent Stabilizer and Plate Activator from the DPM 2000 Plate Maker.
  

Cummings Art Center:

• Some waste glaze materials from the Ceramics Studio.
• Spent fixer in the photographic darkroom.
• Spent engraving acids.
• Paint thinners, paints, inks and other solvent containing materials.
• Inks and paints containing any of the RCRA metals (such as cadmium, chromium, lead, etc.)
• Parts washer solvent in the Paint Studio.
  

While the waste is being accumulated, it is the responsibility of the supervisor of the area generating the waste to ensure that the waste is properly labeled and managed until it is delivered to the storage facility.

Satellite Accumulation Storage Rules

• Waste must be stored in containers, which are compatible with the waste and have a tight fitting cap or cover.
• Waste containers MUST be kept tightly closed at all times, except when adding waste.
• Waste containers, which are going to be used as the shipping container must be DOT approved.
• Waste containers must be in a secure location and under the control of the person generating the waste.
• Waste containers must be in good condition, and not leaking, or damaged.
• No more than one container of a particular waste can be kept at one time.
• When a container of waste is full or when that type of waste will no longer be generated, it must be taken to the waste storage area within 72 hours.

To minimize the hazard of incompatible chemical reactions, wastes should not be mixed without prior approval from the Environmental Health and Safety Office.

Waste containers must be labeled with an orange "HAZARDOUS WASTE" label.

The label must contain:

• Waste name,
• waste components (if a mixture of chemicals),
• hazard(s), and
• the name and telephone extension of the generator of the waste.

The "Date Filled" spaces must be filled in when the container is full, or the waste will no longer be generated. (Again, the container must be transported to the Hazardous Waste Storage Area within three days.) Indelible markers or ballpoint pens should be used for labeling. Do not use abbreviations.

180 Day Storage Hazardous Waste Storage Facilities

There are five Hazardous Waste Storage Facilities at Connecticut College. Four storage facilities are located in academic buildings, of which three are located in science buildings (Hale Laboratory, New London Hall and Bill Hall). These facilities are described in the Laboratory Safety Handbook, and will not be discussed here. The fourth academic building with a HAZWASTE Storage facility is Cummings Art Center.

The non-academic Hazardous Waste Storage Facility is located at the Service Building at the south end of campus. Storage facilities are inspected weekly by the Director of Environmental Health and Safety. In addition to assessing storage and container compliance, the Director uses this weekly inspection to ensure that accumulation limits are not exceeded. Emergency information is posted on the main door of the facility, including:

• emergency phone number of Campus Safety (Extension 111.),
• name and contact information of the emergency coordinator,
• location of fire extinguishers and fire alarm pull station,
• location of spill control materials, and
• location of the eyewash and deluge shower

There are separate storage bays in the facility for different types of waste. All liquids, and lead acid batteries are stored on secondary containment.

Wastes are shipped off-site using a licensed hazardous waste transporter. All hazardous waste is taken to licensed facilities which treat, recycle, incinerate, or otherwise dispose of the materials using EPA approved methods for the particular waste type. Waste is shipped at least every 180 days, or more frequently to comply with storage limits.

Management of Connecticut Regulated Wastes

Following are the Connecticut and other regulated wastes and their generation/ accumulation locations:

• spent antifreeze in the garage,
• spent oil from A/C systems in the garage,
• used motor oil in the garage, and
• asbestos in Hazardous Waste Storage Facility.

Containers and aboveground tanks used to store used oil must be labeled or marked clearly with the words "Used Oil." Used motor oil is accumulated in a 275 gallon tank, which is stored within secondary containment inside the Physical Plant garage. When the tank is full, an approved automotive waste removal company, removes the oil for recycling. This tank is inspected on a weekly basis.

Mixtures of used oil and hazardous waste are subject to regulation, and must be treated as hazardous waste. Therefore, only used motor oil should be disposed of in the "Used Oil" tank, in the Physical Plant Garage.

Spent automotive anti-freeze, is accumulated in a 55 gallon drum, stored on secondary containment within the garage. It is tested periodically to ensure that it is not a hazardous waste. It is also removed by the automotive waste disposal company.

Used oil filters are punctured at the top, and drained for 24 hours. The oil is disposed of in the used oil tank. After draining for 24 hours, the filters are disposed of in the regular trash.

Disposal of Non-Hazardous Wastes

Liquid wastes which are non-hazardous, are water soluble, and do not contain solids may be flushed to the sewer with copious amounts of water. Liquids which are not water soluble must be solidified (absorbed) and disposed of as a solid. Non-hazardous solid waste must be labeled "non-hazardous" and can then be put in the trash.

IMPORTANT: Please check with the Director of Environmental Health and Safety prior to disposal to make sure the material is appropriate for sewer or trash disposal.

Disposal of Empty Containers

Under Hazardous Waste regulations, chemical containers are considered empty when no more content can be poured out, and an inch or less of content remains. These containers can be recycled or disposed of in the regular trash. This does not apply to containers that have held acutely toxic chemicals, as listed in the RCRA Hazardous Waste List. Contact the Director of Environmental Health and Safety for instructions.

Aerosol cans are accumulated in the Physical Plant storeroom. Periodically, the aerosol cans are de-pressurized using an appropriate can puncturing device, and the liquid contents accumulated as hazardous waste. The empty cans are placed of in the "Metals" recycling dumpster, pending pick-up for recycling by Conn Carting, Inc. Under no circumstances are can containers (or equipment) containing CFCs discharged to the atmosphere.

Disposal of Gas Cylinders

Prior to purchase of gas cylinders, arrangements should be made with the distributor for return of empty cylinders. Empty non-returnable small propane cylinders may be disposed of in the regular trash, provided the generator can demonstrate they are empty.

Disposal of Unknowns

It is extremely difficult and costly to identify the content and hazards of unlabeled materials. If you have unknowns, please contact the Director of Environmental Health and Safety. Please indicate to the best of your knowledge what the material is likely to be based on its characteristics and the location at which it was found.

Spill Response Procedures

Large spills of hazardous materials, be it waste material or a in-use chemical product, will be handled as described on page 11-1 of the Integrated Contingency Plan (ICP). The following is a summary of those procedures:

• Make everyone in the immediate vicinity aware of the spill.
• Evacuate the area, if necessary.
• Call Campus Safety at extension 111 or 911. Campus Safety will contact the Director of EH&S.
• Restrict access to impacted and threatened areas.
• Keep unprotected personnel upwind of spill area.
• Avoid contact with spilled product.
• Eliminate ignition sources that may be present.
• Prevent released material from entering sewers and confined spaces.
• Consider potential mixing of incompatible materials.
• Use explosion-proof and spark-proof equipment where necessary.
• The EH&S Director shall determine if a reportable incident occurred and facilitate reporting as required by law.
• If it can be done safely, every effort should be made to contain the spill, and prevent it from spreading. There are "spill kits" staged at the following locations:

  - Physical Plant Garage;
  - Physical Plant Hazardous Waste Storage facility;
  - Power House;
  - Harris Kitchen;
  - Chemical stockroom, Hale Laboratory;
  - Chemical stockroom, New London Hall;
  - Chemical stockroom, Olin Science Center;
  - Bill Hall Hazardous Waste Storage facility; and
  - Cummings Art Center Hazardous Waste Storage facility.

Training

As a Small Quantity Generator, there are training requirements for all employees who generate, transport or otherwise manage hazardous waste. This training includes proper waste handling, and emergency procedures, relevant to the individual's responsibilities. Initial training is performed prior to assuming waste handling responsibilities, then every three years. Students who generate or handle hazardous waste, are trained by the supervising faculty member. Records of training are maintained by the Director of Environmental Health and Safety.

For comments or questions, contact 
Steve Langlois, Director of Environmental Health and Safety, (860) 439-2252