Case Western Reserve University EPA RCRA Program
The EPA RCRA Hazardous Waste Program at CWRU addresses the removal of chemical waste from the CWRU campus. This program also includes the disposal of TSCA wastes such as PCBs and other non-RCRA items and is a subset of the larger CWRU Waste Disposal program.
Scope: The CWRU EHS office administers the CWRU EPA RCRA program. The CWRU RCRA EPA program is designed with the responsible management of all waste materials generated on the campus in mind. This includes wastes that do not fall under the direct control of the EPA RCRA program such as TSCA.
The removal of all materials from the campus related to the EPA RCRA program are the responsibility of the CWRU EHS program. You may not utilize external sources without first consulting the CWRU EHS office. This includes construction debris, e-waste, and recycling activities including the removal of Freon from refrigeration devices, recycling of batteries, used oil, Fluorescent bulbs, mercury switches, manometers, thermometers, equipment, or any other hazardous materials.
The following document details the requirements of the EPA RCRA program and CWRU procedures.
Hazardous Waste Introduction
The Environmental Protection Agency issued a set of regulations to protect the environment from the release of harmful substances to the environment in October 21, 1976. The regulation issued is the Resource Conservation and Recovery Act (RCRA). This act was first amended and strengthened in 1984 with the passing of the Federal Hazardous and Solid Waste Amendments (HSWA). RCRA was then amended in 1992 and again in 1996. The RCRA act only covers active and future activities. Past abandoned sites are cover by the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) also known as Superfund.
What is a Hazardous Waste?
- Definition of a Waste
- 3745-51-03 Definition of hazardous waste
- 3745-51-07 Residues of hazardous waste in empty containers
A hazardous waste is a type of solid waste. A solid waste is considered any material that is discarded and may include a gas or semi solid. Do not be confused by the work solid and just think discarded chemical. If you have a solid waste then you need to determine if it is either specifically listed by RCRA on one of several lists or exhibits a characteristic that makes it a hazardous waste. We will examine these individually. CWRU manages all chemical wastes regardless of their RCRA classification in a responsible manner consistent with providing protection to the environment and community.
Hazardous Waste Characterization
The first question to determining if something is a hazardous waste is to determine if it exhibits a characteristic. The basic characteristics of hazardous waste include:
- D001-Ignitability: Any material that has a flash point below 140F, some gasses and some materials that can spontaneously catch fire meet this definition.
- 3745-51-21 Characteristic of ignitability.
- D002-Corrosivity: Any material that corrode flesh or metal and has a pH greater than 12.5 or less than 2. 3745-51-22 Characteristic of corrosivity.
- D003-Reactivity: There is no test for reactivity. Generally, any material that could react in a violent manner, release a toxic cloud, or has the potential to explode or react in a manner that could cause harm is considered reactive. Any material that can generate a sulfide or cyanide is reactive by definition. 3745-51-23 Characteristic of reactivity.
- D004-Toxicity: Toxicity The D list D005-D043 contains a list of chemicals. They are assigned a threshold above which they are considered an issue. If the material you have is present above that threshold for the Toxic Characteristic Leachate Procedure (TCLP),it is a hazardous waste. In the TCLP test the conditions of a landfill are simulated and an extraction is performed
- 3745-51-24 Toxicity characteristic.
- 3745-51-30 Lists of hazardous wastes - general.
- 3745-51-33 Discarded commercial chemical products, off-specification species, container residues, and spill residues thereof.
The P and U lists designate as hazardous waste pure and commercial grade formulations of certain unused chemicals. For a waste to be considered a P or U-listed waste it must meeting the following three criteria:
- The waste must contain one of the chemicals listed on the P or U list;
- The chemical in the waste must be unused; and
- The chemical in the waste must be in the form of a commercial chemical product.
EPA defines a commercial chemical product for P and U list purposes as a chemical that is either 100 percent pure, technical (e.g., commercial) grade or the sole active ingredient in a chemical formulation. An example of a sole active ingredient would be a can of bug spray. It contains a large volume of a solvent and a propellant but the active ingredient that makes it bug spray is the pesticide. Care must be taken when making this determination as in this case the propellant may also be flammable.
The U List regulates discarded commercial chemical products, manufacturing chemical intermediates, and off-specification commercial chemical products that contain certain ingredients, and any soil or debris contaminated by spills of those products or intermediates. The U-list wastes can be found at 40 CFR section 261.33.
The P-list identifies acute hazardous wastes from discarded commercial chemical products. The P-list can be found at 40 CFR section 261.33
An additional point for the research laboratory is that if more than 1kg of a P waste is generated and destine for disposal, it must be removed from the laboratory within THREE DAYS! This is important to remember.
D listed wastes D001-D003 were examined earlier as characteristic wastes while the remaining D list D004-D043 refers to the TCLP toxicity which was also discussed.
EPA F-Listed wastes are wastes from manufacturing and industrial processes (non-specific sources) such as solvents that have been used in cleaning or degreasing operations. You may have an F waste in your laboratory. Each definition is very specific. Just because you have, a chlorinated solvent does not make it an F002 for example.
The F-List has seven distinct subgroups, including:
- Spent solvent wastes (F001 – F005)
- Wastes from electroplating and other metal finishing operations (F006 – F012, and F019)
- Dioxin bearing wastes (F020 – F023 and F026 – F028)
- Wastes from production of certain chlorinated aliphatic hydrocarbons (F024 and F025)
- Wastes from wood preserving (F032, F034, and F035)
- Petroleum refinery wastewater treatment sludges (F037 and F038)
- Multisource leachate (F039)
The K-List of wastes are source-specific. There is very little chance that you will find a K waste in a research laboratory. If you think you have one please contact EHS for assistance.:
- Wood preservation (K001)
- Inorganic pigment manufacturing (K002 – K008)
- Organic chemicals manufacturing (K009 – K011, K013 – K030, K083, K085, K093 – K096, K103 – K105, K107 – K118, K136, K149 – K151, K156 – K159, K161, K174 – K175, and K181)
- Inorganic chemicals manufacturing (K071, K073, K106, and K176 – K178)
- Pesticides manufacturing (K031 – K043, K097 – K099, K123 – K126, and K131 – K132)
- Explosives manufacturing (K044 – K047)
- Petroleum refining (K048 – K052, and K169 – K172)
- Iron and steel production (K061 and K062)
- Primary aluminum production (K088)
- Secondary lead processing (K069 and K100)
- Veterinary pharmaceuticals manufacturing (K084 and K101 – K102)
- Ink formulation (K086)
- Coking (K060, K141 – K145, and K147 – K148)
EPA RCRA, in addition to the characteristic, lists specifically certain materials as hazardous waste. Any material mixed with any amount of a listed hazardous waste is fully a hazardous waste forever. Thus if you have a non-hazardous waste material such as a column material and you add to it any amount of a listed hazardous waste, the material is forever considered a hazardous waste even if the entire amount of the material making it a hazardous waste is gone down to the last molecule. Likewise adding a single drop to even a million gallons of water makes the water a hazardous waste. Keep this in mind as you work in your laboratory. In addition, bear in mind that if you spill a hazardous waste, everything you use to clean up the spill or that becomes contaminated is also now a hazardous waste.
A second type of mixed waste is a radioactive mixed waste. Any material that is regulated by the NRC remains regulated by the NRC if mixed with a hazardous waste. Once the primary hazard of radioactivity is gone the material reverts back to a hazardous waste.
In summary, a hazardous waste is a chemical that either meets a definition by virtue of its characteristic or meets the definition of one of the lists U, P, F, K, or D.
Satellite Accumulation of Wastes in a Laboratory
The chemical waste generated in the research laboratory is subject to the regulations of the EPA RCRA program and the CWRU Hazardous Waste Program. When you are collecting these materials, you are acting as a satellite accumulator of hazardous waste. This section will go over the rules associated with this activity and define your role and responsibility in the program.
OHIO EPA says the following:
When you accumulate a hazardous waste at a point of generation, you must comply with the following requirements:
- Mark your containers with the words “Hazardous Waste,” [Ohio Administrative Code (OAC) rule 3745-52-34(C)(1)(b)]
- Keep all containers used to accumulate your hazardous waste closed, unless you are adding or removing waste from them. [OAC rule 3745-66-73(A)]
- The containers you use to accumulate hazardous waste must be in good condition. If the container being used to accumulate hazardous waste is not in good condition, or if it begins to leak, you must transfer the contents to a container that is in good condition. [OAC rule 3745-66-71]
- The containers you use to accumulate hazardous waste must be compatible with the waste, or lined with a material, which will not react with the hazardous waste being accumulated. [OAC rule 3745-66-72]
When you accumulate more than 55 gallons of hazardous waste or more than one quart of acutely hazardous waste in containers, with respect to that amount of excess waste, remove the excess within three days of the date you place on the container and comply with the 90/180-day accumulation area requirements:
- During the three day period, continue to comply with OAC rules 3745-66-71, 3745-66-72 and 3745-66-73(A) summarized above.
- Mark the containers with the date when the accumulation limit was exceeded. [OAC rule 3745-52-34(C)(2)]
- Mark the containers while they are being accumulated on-site with the words “Hazardous Waste.” [OAC rule 3745-52-34(A)(3)]
The chemical does not change because it is now a hazardous waste destine for disposal. You must still store and handle the material in exactly the same way as the material you keep as stock material. If the material is flammable it must still be stored in a flammables cabinet. If it water reactive you still cannot put it under a sink, if it corrosive you still need to take care to store it. There are many other examples.
On example that comes up from time to time is worth specifically call out. If you generate a waste that is off-gassing, you must take care to not seal the container tightly to prevent the buildup of gas. This does not mean leaving the top off but instead cracking the top and placing it in a walk in fumehood until the condition subsides. This is the only exception where a container can be left in any condition other than fully sealed.
Compatible containers must be used. For any waste you generate consider the container you will use to collect and dispose of the hazardous waste. The material may spend considerable time in its container before it goes for final treatment and disposal. Here are some basic guidelines:
Do not place water-based waste into an unlined metal drum. It will over time rust and the container will lose its integrity.
Do not place a chlorinated or other halogenated solvent into an unlined metal drum. If any water is present or is picked up from the air, acids can be produced. Even in small amounts, these acids can react with the metal and corrode the container.
Do not place solvents into plastic containers unless you first determine the plastic is compatible with the solvent or solvent mixture you produce. Plastic melts!
Do not place materials such as hydrofluoric acid into a glass container as it will dissolve the glass. Another example you may not consider is strong base such as sodium hydroxide. Over time, the glass will be eroded. This is a slower process but must be taken into account.
If you are unsure of the material for the container you need, consult EHS for assistance before you generate the waste.
CWRU EHS provides tags you can place on the neck of your container. These tags are meant to make marking your containers simple and easy. However, you may decide to make your own labels or use a log. The information that must be present is as follows
Mark your containers with the words “Hazardous Waste” at all times. This is a requirement that has no exceptions. It should be the first line of any label or log you make. The EHS supplied tags have this information already on the tag for your use.
Mark all of your containers with the exact content of what is in them. Do not use abbreviations such as H2O.
Pick one of the following methods but not multiple methods for labeling your containers.
Method 1: Some containers are being filled a little at a time and are located in such a way that to write the content on the supplied EHS tags is not convenient or may not even have enough lines to keep a full log on a container. In this case, you may make up a log that is kept in direct eyesight of both the container and the operator. When the container is full, you can then transfer the final composition of the container to the EHS supplied tag. For this to work you must make sure that the container is labeled with the words hazardous waste AND an identifier that clearly shows which log belongs with which container. For example you might call your log Bobs waste bottle 1. This must be written at the top of the log and on the EHS tag on the keck of the container. It should be evident to anyone entering the laboratory that the container log belongs to this container.
Put the EHS hazardous waste tag on the bottle and write the name of the container as well as [See log “container name” for details.]
Method 2: Make a label of your own design. For some waste steams you generate you know precisely what your waste will be and it will rarely change. In this case, you can save a lot of effort by printing your own hazardous waste label. It must have all of the following information present:
The words HAZARDOUS WASTE, the building, room, and investigators name, the date the container is full or at least a slot to be filled in when the container is full, a clear non abbreviated description of the contents of the container. If you ever forget this list, see the back of any hazardous waste pickup request or an EHS hazardous waste tag.
When you container is full you must date the container. You should plan to have the container removed from your laboratory as soon as possible. By law, CWRU must remove any hazardous waste from the campus within 90 days. We need at least 60 to process and arrange for this to happen.
Filling the container
Once you have your chemically compatible labeled container, you will begin to fill the container. As you do this you must keep the container sealed at all times except when you are standing in front of the container adding material. If you leave for lunch or another reason or are not adding material the container must be tightly sealed at all times. Only a container that generates a gas may be left slightly open to allow pressure to escape. No other exceptions exist.
Storing the Container for Disposal
Once your compatible labeled, dated, and sealed container is full, you must remove the container to proper storage. Store it as you would if it were a stock container. If you can., dedicate a cabinet for flammable or corrosive wastes. If you plan to share a cabinet with non-hazardous waste mark the shelves that will be used for the wastes and those that will not. It should be clear to anyone opening a cabinet which containers are hazardous waste and which are not. Do not share selves to make this very clear.
Notes on Practical Considerations
Pipet tips. Weighing boats, Paper from cleanups of spills and other contaminated items
Some items are used to transfer material from one location to another or to measure out a quantity. Some are used to clean up a spill. In all these cases, there is a small amount of contamination present and we cannot just place them in the regular trash.
For contaminated items such as weighing boats or pipets, you can rinse out the contamination into a container for hazardous waste. Once the object is rinsed, it can be considered trash provided the contamination is completely soluble. If you have a residue left, you will have to collect the objects and send them out as hazardous waste. In all cases, plastic pipets must be treated as a sharp and placed into a box with a liner bag holding the tips. It is impossible to get all the liquid out.
For paper products or uncleaned tips, you cannot clean the contamination and therefore must treat them as hazardous waste. Since it is virtually impossible to know the exact concentration of the contamination, you need to label the container holding the waste as “trace chemical name paper from spill cleanup” along with all the other requirements for a hazardous waste.
Oils and Column waste and other slightly contaminated items.
Oils from oil bathes are generally considered as a clean oil and can be simple described as waste oil. Oils from vacuum pumps or that are used in a manner that might lead to contamination such as vacuum pumps or vapor traps must be handled slightly differently. If you have an oil that is contaminated you must note the materials that contaminate the oil as trace. So, for example, the oil from a vacuum pump used with a rotovap might be described as waste oil trace solvent1, solvent2, solvent3…. In this case, you most likely are going to list every solvent you use in the laboratory. It would easiest to make a label in advance for this purpose. Each time you use a different solvent check the box on the label.
Waste from running chromatography through a substrate column such as alumina or silica must be treated the same way as described for oil. You additionally would need to note if you used anything else on the column such as the item of interest. Of special interest is metals, as they will not elude off the column. Even if in the end you have dry media left, you must still add the trace solvents and constituents to the description on the label. These items may very well change how the waste is treated and disposed of.
Arranging for the Disposal of Hazardous Waste from the Laboratory
At this point, you have produced your hazardous waste, selected a compatible container, labeled it, protected the environment by keeping the container closed, dated it when full, and stored it in a compatible manner in the laboratory and are ready to see it leave. This section will cover the EHS Hazardous Waste Disposal Service.
CWRU EHS provides tags and a pickup request. When you are ready to have the hazardous waste removed from your laboratory, you fill out a pickup request and submit it to the EHS offices. Pickups occur every week on Thursday and Friday. If you deliver your requests to the EHS office prior to Tuesday of a given week there is a good chance it will leave the same week.
The form is comprised of two sections. The top section lets EHS know where and who you are while the bottom section tells us what you want to get rid of from the laboratory.
The contact is the person the person coming to get the waste will ask for
The location is the building and room where the contact resides. The contact will take the pickup person to the waste. EHS will not take unattended containers to prevent the accidental loss of research materials.
LC is the location code of your building
The account number is used to track expenses and will not be used to charge for the disposal of hazardous waste except in certain situations that will be cover later.
The main section of the form is used to tell EHS what you want to get rid of. It works as follows. Each container is a separate bottle and given a number. You use this same number for all line entries of a bottle. For example, if you have three components acetone, water, and methanol, you would write each item on a separate line with the same bottle number. You can list as many bottles on a page as there are lines.
If you are going to make the same waste stream repeatedly, I suggest you print a label and affix it to the pickup sheet. In fact, print two. One for the container and one for the form.
You DO NOT HAVE TO WRITE THIS FORM OUT BY HAND. YOU MAY MAKE A COPY IN THE COMPUTER OF YOUR OWN SO LONG AS IT HAS ALL THE INFORMATION ON IT.
If you make your own, form make sure to send in two signed copies. We leave you a copy signed by EHS stating that the material was removed and take the second copy back for our records.
Once the request is received EHS assigns a special identifier you can see in the top right. This is entered into a computer system that tracks everything ever given to EHS. We can go back to about 1995 with this system.
The request is given to a contractor who will meet your contact and remove the waste. This waste is taken to a special area and prepared for shipment. The waste is then taken off campus to a Treatment and Storage Disposal Facility where the description and hazardous waste characterization you did is used to determine how it is treated and finally disposed of. This is why you are a vital part of the chain of custody.
If you have a large volume of material to get rid of such as from a cleanout of a laboratory, contact EHS for assistance. In these cases, you may not have to do any of the paperwork as it will be packed out directly from the laboratory.
EPA promotes the recycling of materials that can easily be diverted from the hazardous waste stream for reuse. These items include:
- Universal Waste means any of the following hazardous wastes that are subject to the universal waste requirements of this part 273:
- Batteries as described in § 273.2;
- Pesticides as described in § 273.3;
- Mercury-containing equipment as described in § 273.4; and
- Lamps as described in § 273.5.
CWRU collects these items for recycling. If you have any of these items contact CWRU EHS for instructions.
Cleaning Up a Broken CFL or Mercury Lamp
From time to time lights containing mercury may break. The following procedure is taken from the EPA website https://www.epa.gov/cfl/cleaning-broken-cfl#qi
Typical fluorescent bulbs contain approximately 27 mg of mercury. When a cold bulb is broken, much of this mercury is absorbed onto the powder in the tube and plated on the glass. Only a small amount of free vapor exists that is free to enter a room. A running bulb on the other hand has a higher chance of releasing the mercury as a vapor. In both accounts, the amount of mercury released is relatively small. Quick pickup of the material after a period of room ventilation is sufficient to reduce exposure. The occupant or Facilities worker cannot clean up spills of larger amounts of mercury from sources such as UV bulbs, mercury microscope sources, thermometers, switches. These conditions must be addressed by the CWRU EHS office. Significant mercury can be present in these larger devices.
If a break occurs of anything other than a CFL or fluorescent bulb, leave the room and contact CWRU Dispatch. They will in turn contact EHS. Do not allow anyone back into the space.
In an office building or laboratory, there is sufficient air exchange to remove the vapor from the room within a short period of time for a CFL break. It is safe to clean up a broken CFL bulb if you are trained to do so.
Clean up of a broken bulb:
- Leave the area for at least 30 minutes before returning to attempt a cleanup. Notify EHS during this time period of the break.
- Put on protective gloves like those used in laboratories. Any kind of glove will be appropriate.
- Find a plastic bag or jar and carefully move the broken glass and dust into the container. The use of a little water will help keep the dust down.
- If you have a larger section of glass simply tape it shut and then place the remaining section in a larger plastic bag.
- Stiff paper or cardboard can be used as a shovel
- Sticky tape can be used to pick up small glass and dust.
- Use damp paper towels or disposable wet wipes to clean hard surfaces.
- If the break occurs on the carpet there is nothing you can do and must have EHS attend to the spill. The carpet may require removal.
- All collected material is considered hazardous waste and must be disposed of through the EHS program.
DO NOT VACUUM. Vacuuming is not allowed. Vacuuming could spread mercury-containing powder or mercury vapor. A vacuum, if used, would need to be disposed.
Be thorough in collecting broken glass and visible powder. Scoop up glass fragments and powder using stiff paper or cardboard. Use sticky tape such as duct tape, to pick up any remaining small glass fragments and powder. Place the used tape in the glass jar or plastic bag.
If practical, continue to air out the room where the bulb was broken for several hours after cleanup is accomplished.
- 3745-51-39 Conditional exclusion for used, broken CRTs and processed CRT glass undergoing recycling.
- 3745-51-40 Conditional exclusion for used, intact CRTs exported for recycling.
- 3745-51-41 Notification and recordkeeping for used, intact CRTs exported for reuse.
e-Waste is any device that contains an electronic component such as a computer or laboratory device. These types of devices must be collected and handled separate from the regular trash. CWRU has a recycling program specific to e-Waste. Details can be found at https://case.edu/sustainability/what-were-doing/recycling/
- 3745-51-08 PCB wastes regulated under the Toxic Substances Control Act
- 3714.01 Construction and demolition debris definitions.
Waste from construction sites may include items such as lead paint, PCB caulk, PCB light ballasts, fluorescent bulbs, asbestos and other such hazards. While many of these items fall under other EPA programs, they are universally handled through the CWRU EHS EPA RCRA program. If you are planning construction activities you are required to notify the CWRU EHS office in order that a suitable risk analysis can be conducted. This process may take considerable time so plan ahead.