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MUSC Hazardous Waste Training Occupational Safety and Health Program
HAZARDOUS WASTE TOPICS 1 General Information 2 What is a Hazardous Waste 3 Characteristic Hazardous Wastes 4 Listed Hazardous Wastes 5 How to Know If I Have a Hazardous Waste 6 Hazardous Waste Storage 7 Unknown Chemical Wastes 8 High Hazard Chemicals 9 Photo Waste 10 Fluorescent Bulbs
GENERAL INFORMATION In 1980, MUSC applied to SCDHEC to become a Permitted Treatment, Storage and Disposal Facility. In 1986, MUSC was granted permitted facility status and the additional regulatory requirements which come along with this status. Although this allows MUSC to store waste for up to one year, it guarantees that the South Carolina Department of Health and Environmental Control (SCDHEC) will conduct a yearly unannounced inspection with the United States Environmental Protection Agency (USEPA).
WHAT IS A HAZARDOUS WASTE A hazardous waste can be a solid, liquid or gas. Such solid gas wastes may be deemed hazardous by the USEPA and SCDHEC because they are very ignitable, corrosive, reactive or poison. The USEPA also publishes a list of hazardous wastes, each of which is assigned a unique alphanumeric designation. This list is broken into two groups which are characteristic wastes and listed wastes
CHARACTERISTIC HAZARDOUS WASTES Characteristic hazardous wastes are designated by an upper case “D” and three numbers (D 001 – D 043). Ø In order for a waste to be considered hazardous by characteristic, it must exceed numerical limits set by USEPA, with one exception*. *Reactive wastes (D 003) have no numerical limits but could be considered a characteristic hazardous waste for such reasons as reacting violently with water or air. It could also explode under standard temperature and pressure due to shock or friction.
MOST COMMON CHARACTERISTIC HAZARDOUS WASTES Type of Waste Limits Designation Ignitable Flash point < 140 °F D 001 Corrosive p. H ≤ 2. 0 or ≥ 12. 5 D 002 Reactive No numerical limits D 003
The limits on the remaining characteristic wastes (D 004 -D 043) are expressed in ppm. If a waste product is suspected of having lead (D 008) in it, a Toxic Characteristic Leaching Procedure (TCLP) test is performed on the waste to determine amount of leachable lead in waste. This test is used to mimic the decomposition of the waste if put in a landfill. For example, if the TCLP test results indicate 23. 0 ppm of lead in the sample, the waste would be considered a hazardous waste as the limit for lead is 5. 0 ppm. Some other common characteristic hazardous wastes are listed on the next slide.
OTHER EXAMPLES OF CHARACTERISTIC HAZARDOUS WASTES Type of Waste Limits Designation Silver 5. 0 ppm D 011 Lead 5. 0 ppm D 008 Arsenic 5. 0 ppm D 004 Lindane 0. 4 ppm D 013 Benzene 0. 5 ppm D 018
LISTED HAZARDOUS WASTES Listed hazardous wastes do not have numerical limits but, as a general rule, are determined to be a hazardous waste if any of one of the listed wastes is present in a waste product. However, the rules governing the waste determination for listed wastes are not always black and white. They are divided into four groups determined on how they are generated or how dangerous they are to the environment. For example, a researcher has a piece of lab equipment that has a non water soluble residue in the piping that needs to be cleaned. The researcher flushes the system with 250 ml of acetone and then flushes the system with 2 gallons of soap and water. The resulting soap, water and acetone generated from this clean up would be considered a hazardous waste as spent acetone is a listed hazardous waste.
FOUR LISTED WASTE GROUPS AND EXAMPLES Waste Group Examples Designation Hazardous waste from nonspecific sources Acetone, xylene, nitrobenzene F 001 -F 039 Hazardous waste from specific sources Emission control dust from the primary production of steel, spent potliners from primary aluminum reduction K 001 -K 900 * Toxic hazardous waste DDT, Carbon Tetrachloride, 1, 4 Dioxane U 001 -U 395 Acutely hazardous waste Arsenic trioxide, Phosgene, Sodium Azide P 001 -P 205 * - Some numbers skipped, about 120 wastes in this list
HOW DO I KNOW IF I HAVE A HAZARDOUS WASTE There are many common chemicals that are used extensively at MUSC which are known to be hazardous wastes when discarded. However, there are other more obscure or seldom used chemicals which do not fit in this category. To ensure proper disposal, a hazardous waste determination is required. The first step in making a hazardous waste determination is to use any common knowledge of the chemical in question. Is the chemical known to be very ignitable, reactive, corrosive or poison? If the answer is yes, then the chemical in question is probably a hazardous waste. However, this may not always be the case as Ethidium Bromide is very toxic but is not a characteristic or listed hazardous waste.
The next step in waste determination process is to look at the MSDS. Start with the “Disposal Considerations” section of the sheet. In rare cases the MSDS will state that the material is a RCRA hazardous waste when offered for disposal. However, this section will most likely indicate that the material should be disposed of by following state and federal regulations. In the later case, other sections of the MSDS may provide more helpful information. If the material in question is a commercial product that contains a mixture of different chemicals look at the “Product Composition” section and see if any of the constituents are known to be very ignitable, reactive, corrosive or poison.
Next, check the “Physical and Chemical Properties” section of the MSDS. This will usually have the p. H of the material which should indicate if the chemical would be a hazardous waste due to corrosively. Likewise, to determine if the chemical is a characteristic hazardous waste due to ignitability look at the “Fire Fighting Measures” section which should list the flash point. If the material can not be definitively determined to be a characteristic hazardous waste due ignitability, reactivity, corrosively or toxicity, it may still be a hazardous waste due to the level of some other characteristic constituent. It could also be a listed hazardous waste. At this point the OSHP office (792 -3604) should be contacted to determine the proper disposal method and how this material should stored after becoming a waste.
HAZARDOUS WASTE STORAGE Assuming that a waste has been determined to be a hazardous waste how should it be stored in the lab until it is picked up? Most labs are considered to be satellite accumulation areas. In order to remain in this category there should be no more that 55 gallons of hazardous waste stored in any lab. If the waste is an acutely hazardous waste (P 001 -P 2051) then no more than one quart of may be stored in the lab. All hazardous waste must be stored in a container that is compatible with the waste being stored in it. This container must be in good condition with a closeable lid. It should remain closed unless waste is being added to the container. USEPA and SCDHEC consider the container to be closed if it could be turned over and retain the contents of the container.
All hazardous waste in satellite storage should have a yellow MUSC hazardous waste labels affixed to the container the first time waste is placed in the container. This label should have the noun name of the chemical (no formulas or abbreviations). The other information such as building and room are not required by law but by MUSC OSHP. There should be no dates on the label as this waste is in satellite storage and does not require one. These labels are available from OSHP or can be printed from the OSHP webpage.
HAZARDOUS WASTE PICK-UP Complete the Chemical Waste Pick-up Form online when waste is ready for pick-up: http: //academicdepartments. musc. edu /vpfa/forms/risk/wastepickup. htm For questions please contact Bill Seaborn, Manager of Environmental Programs (843 -792 -0811)
There also wastes, such as ethidium bromide, that are not RCRA hazardous wastes but are dangerous and need to be disposed of through the OSHP hazardous waste disposal contractor. These type wastes should be labeled with the blue MUSC non hazardous waste label while in storage. The pick up request for these waste are the same as the request for the hazardous wastes.
UNKNOWN CHEMICAL WASTES All lab chemicals should be labeled regardless of whether they are wastes or usable material. When a pick up request is made and if the waste is totally unlabeled and no one in the lab is able to identify the waste, it will not be picked up. Not only is this unidentified waste potentially dangerous to the contractor but cannot be placed in the correct packing group for proper DOT shipping. In the event an unidentified waste is found, it will be the responsibility of the lab to determine what is in the container. This could be done by talking to all current lab personnel. Former occupants of the lab may also be a good source of information. The lab may also choose to analyze the waste.
HIGH HAZARD CHEMICALS The following excerpt was taken from a national hazardous waste newsletter: BOSTON - The Maine Community College System has agreed to pay $126, 600 to settle claims by the US Environmental Protection Agency that it violated regulations on the storage and handling of hazardous materials at Southern Maine Technical College in Portland, and at Eastern Maine Community College in Bangor. During its inspection of Eastern Maine Community College, EPA personnel identified several containers of waste picric acid. Inspectors found these containers near a teaching classroom, accessible to faculty and students.
There are many high hazard chemicals which, over time, can become potentially explosive when not handled properly. Picric acid or trinitrophenol, commonly used in Bouins Solution and Gram staining kits, is one of these chemicals. As a container of picric acid sits for five, ten or more years, the water in the picric acid solution evaporates, leaving dry picric acid. Dry picric acid is a high explosive similar in chemical structure and explosive properties to trinitrotoluene or TNT. In a dry state, picric acid can be detonated though shock, heat or friction.
Another more commonly found high hazard chemical with potentially explosive properties is ethyl ether. After being opened and exposed to air, ethyl ether can form explosive peroxides in the container and around the threads of the cap. Although rare, cases have been documented where an explosion has been caused by simply twisting the cap. Other chemicals such as tetrahydrofuran and 1, 4 dioxane are also potential peroxide formers.
When high hazard waste chemicals are found at MUSC, they must be treated before they can be transported. As MUSC does not have a permit to treat hazardous waste, a temporary emergency hazardous waste treatment permit must be obtained from SCDHEC. MUSC would also be cited by SCDHEC if an aged container of one of these chemicals is found during a yearly inspections.
Assuming SCDHEC is willing to grant MUSC a temporary emergency hazardous waste treatment permit, MUSC must then contract to have this waste treated. The cost of treatment for this type of waste starts at approximately $2500. However, depending on how many containers need to be treated, the cost may be substantially more.
There are ways to avoid having to treat these types of chemicals prior to disposal. If it is essential to use these types of chemicals, buy only as much as needed. If a picric acid containing compound is needed, purchase the compound premixed. If the compound must be made in the lab, purchase the lowest concentration of picric acid possible. When purchasing ethers, purchase small containers and use one completely before opening another. Date the container as soon as it is opened so the opening date is known when it comes time for disposal. Containers of ether that are less than 6 months old may be disposed of a typical flammable hazardous waste without treatment.
MORE COMMON HIGH HAZARD WASTES FOUND AND TREATED AT MUSC Picric Acid Sodium Azide Tetrahydofuran Ethyl Ether 1, 4 Dioxane Dinitrophenol
PHOTO WASTE Although digital photograph and x-ray technology is supplementing and in some cases curtailing the need for the traditional chemically developed photographs and x-rays, the old processes are still used in many places at MUSC. The old type chemical process uses photographic fixer and developers, which when discarded as a waste, can be a hazardous waste due to the silver content. This waste stream cannot be put down the drain to the sewer system but must be collected and disposed of through OSHP. However, if the waste from a particular machine has been tested and it is proven to be non hazardous, it may be discharged to the sewer system as long as there are no other hazardous characteristics such as p. H associated with the waste. Photographic waste with a high silver content (over 5. 0 ppm) may be run through a silver filtering system and discharged to the sewer system, again as long as there are no other hazardous characteristics. The silver filtering system must reduce the silver content of the waste below 5. 0 ppm of silver and be changed out per the manufacturers recommendations.
FLUORESCENT BULBS Are burned out fluorescent light tubes considered benign waste aside from the breakage hazard? No, fluorescent tubes contain mercury which is released when they are broken. As such, when unbroken, they are regulated by the USEPA and SCDHEC as Universal Waste which is a subset of hazardous waste. In most cases fluorescent bulbs are changed and handled my maintenance, although bulbs which have been changed by the occupants of an area have been found stored improperly.
• • In order to remain in compliance, used florescent tubes must be: Stored in an appropriate container such as the box it was shipped in Closed securely Labeled as “Universal Waste – Lamps” * Dated (when the first bulb in placed in the container) * - Universal Waste stickers may be obtained through OSHP
Contact for Questions Occupational Safety and Health Program 19 Hagood Avenue, Suite 908 Charleston, SC 29412 843 -792 -3604