Hazardous Waste Management Plan

Hazardous Waste Management Plan

Purpose: To protect University students, faculty, and staff from the effects of improperly handled hazardous wastes; to minimize the quantities of hazardous wastes generated by the University; and to dispose of all hazardous wastes in accordance with applicable State and federal regulations.

The Hazardous Waste Management Plan is divided into two phases which will operate concurrently.

Phase I

Phase I will be considered as the operational segment and will involve the identification, collection, storage, and final disposal of hazardous wastes which are generated.

The initial task in overall program implementation will be to determine the quantities of hazardous "wastes" currently existing on campus. Included in this inventory would be those chemicals which are unlabeled or "unknowns" as well as those which are no longer needed or otherwise unusable. Potential generators of hazardous wastes (departments, etc.) will be provided the current listings of hazardous wastes identified under 40 CFR 261 and OAC 3745. By reviewing these listings, the departments should be able to determine their status as a hazardous waste generator or nongenerator.

Those which are identified as waste generators will be requested to select a departmental liaison who will be entrusted with the following major responsibilities:

1.

Serve as contact between their department and Environmental Health and Safety.
2. Provide an initial inventory of hazardous wastes currently present.
3. Through area consultation, project (as accurately as possible) quantities of
hazardous wastes generated by the department or area on a monthly basis.
4. Consult with those responsible for waste generation (laboratory faculty,
researchers, etc. providing information on proper waste handling procedures
(collection, storage, etc.).
5. Coordinate hazardous waste program protocol with Environmental Health and
Safety representative.
6. Assure that proper collection and disposal procedures are being followed within
the department or area.

A cooperative relationship between Environmental Health and Safety (EH&S) and departmental liaisons is vital in the success and implementation of the BGSU hazardous waste management program. Once the initial inventory has been completed, approved hazardous waste management companies will be contacted to provide cost estimates for waste disposal. The estimates will be reviewed and a company selected to conduct the initial removal and disposal project. To assist the company (and reduce project costs), the waste materials will be segregated into specific waste categories as defined by 40 CFR 261. If at all possible, the segregated wastes will be consolidated in designated areas to facilitate proper packaging by the hazardous waste management company. The initial shipment of waste will be sent to an EPA approved facility for incineration, if at all possible, or sent to a licensed hazardous waste landfill for proper disposal.

Subsequently, all hazardous waste materials will be collected and stored until proper disposal is required (180 or 270 days depending upon transportation distances). Wastes will be placed in approved containers and collected whenever deemed necessary. Storage will follow EPA guidelines with specific procedures being determined by departmental liaisons in conjunction with the EH&S representative. Disposal procedures will follow those that have previously been explained.

Phase II

In addressing the overall picture of a hazardous waste management program, a main emphasis must be placed on waste minimization. Such procedures not only result in lower program costs but more importantly, they lessen the quantities of hazardous waste which require formal handling procedures.

There are a number of methods that can be incorporated to accomplish this task. Some of these methods are as follows:

1. Recycling
Recycling can take several forms. One is the actual "recovery" of a "used" substance (i.e. solvents). Once recycled, these materials, even though they may be less pure, can be used in other processes or experimentation where high quality is not an issue. Another means of recycling is to develop an "orphan" chemical system whereby unneeded chemicals from one department can be given to another lab or department. This process not only eliminates the need and cost of disposal but it eliminates additional departmental "expenditures" for materials already on campus. An initial means to accomplish the latter task would be to determine the existing waste streams. By identifying those materials that are currently being purchased, a system to adjust future purchases can be developed. Once established, the orphan chemical system will serve as an integral part of the University's waste minimization program (NOTE: a grant established by OEPA is currently being pursued to begin this portion of the waste minimization plan).
2. Alteration in Experimentation
There are several processes that may be applied to minimize hazardous wastes generated from lab experimentation or research procedures. One method is the use of smaller quantities of "raw" materials already identified as being hazardous. This process would be acceptable if the experimentation or other use is not adversely affected by incorporating smaller quantities. A second means would be to substitute a non-hazardous material for the one(s) deemed hazardous. Again, the effect of this substitution to the results will determine whether this procedure would be feasible.
3. Neutralization
Neutralization techniques are utilized to render hazardous substances innocuous. Through normal chemical processes, the end products of experiments or other generated hazardous materials may be altered to form non-hazardous substances. Normal procedures would then be used dispose of the resulting non-hazardous material(s).

As previously stated, the above methodologies will be pursued in conjunction with the processes identified in Phase I. With the assistance of departmental liaisons, waste minimization techniques will be strongly emphasized. By stressing waste minimization, adverse effects posed to students, faculty, and staff will be lessened and overall disposal costs will decrease.

In order for any plan to be effective, it must periodically be reviewed. Since the disposal plan constitutes a cooperative effort, all involved parties (EH&S, departmental liaisons, etc.) will have an ongoing opportunity to recommend alterations of the plan. All recommended changes will be discussed collectively and agreed upon prior to their incorporation within the plan.

In summation, the hazardous waste management plan will consist of two concurrent phases. Phase I will be to identify, collect, and properly dispose of existing wastes as well as those generated in the future. Phase II will involve the minimization of hazardous waste generation.

With the cooperation of identified hazardous waste liaisons, pertinent University faculty and staff, and Environmental Health and Safety, the hazardous waste management plan will become part of normal University protocol. Through such cooperative efforts, the University the conditions of the program's purpose, and in doing so, provide a safer and healthier institution.