Hazardous Waste Reduction Plan

Purpose

The main objective of this plan is to reduce or eliminate the generation of hazardous waste to the extent that is economically and technically feasible. In research, teaching, testing and many other operations on campus, generating chemical waste cannot be avoided. However, chemical waste can be managed as efficiently as possible to minimize the amount that is generated. The Director of Environmental Health and Safety (EHS) will be primarily responsible for coordinating the waste minimization plan.

The Pollution Prevention Act of 1990 requires all hazardous waste generators to reduce or eliminate the generation of hazardous waste whenever feasible. The University of Tennessee must report its efforts towards waste minimization to the Tennessee Department of Environment and Conservation (TDEC) on an annual basis. As a result, the university sets waste reduction goals for each waste stream.  These goals are outlined in detail in Appendix A.

Scope and Applicability

This waste minimization plan meets all of the requirements of the Tennessee Hazardous Reduction Act of 1990 (TCA 68-212-301), and encompasses all chemical waste operations conducted on the Knoxville campus and all off-campus activities that are part of the Knoxville campus’s mission.  The plan requires all individuals on campus who generate any type of hazardous waste to implement this plan by using resources that are economically and technically feasible to reduce or eliminate waste generation. Waste in any form represents lost money, lost resources, and lost labor.

Implementing a waste minimization program benefits everyone at UT Knoxville and the community by:

• Lowering waste disposal and compliance costs
• Reducing long-term liability for disposal
• Reducing costs of chemical purchases
• Reducing health and safety hazards
• Promoting environmental awareness
• Preventing pollution and conserving resources

Abbreviations and Definitions

EPA: Environmental Protection Agency

RCRA: Resource, Conservation and Recovery Act

TDEC: Tennessee Department of Environmental Quality

Procedures

Methods to Minimize Hazardous Waste Generation:

Waste reduction should be considered during all phases of a process including project/process design, purchasing, and use. The most effective location to minimize the amount of waste generated is at the point of waste generation. The policy of the University is to maintain an open-minded attitude towards application of any waste reduction option. Therefore, all faculty and staff are encouraged to constantly search for ideas that can be implemented to improve waste reduction efforts. The following methods should be considered to reduce the amount of hazardous waste produced on campus and the university will encourage use of these methods to meet its waste reduction goals.

Process modifications

This involves the use of micro-chemistry or using reduced volumes in an experiment.  Procedures to switch to micro-chemistry include:

• Switching from conventional to fast microprocessor-based, top loading balances that are sensitive to 0.1 mg.
• Use of chromatographic techniques, such as high performance and ion exchange that can clearly separate and purify milligram quantities of a substance.
• Use of microscale glassware, including pipettes, burettes, syringes, reactors and stills for handling reagents and their products.
• Switching from conventional to sensitive spectrometers that can analyze milligram quantities of substance.

Chemical waste exchange:

Laboratories should check with other departments on campus, with EHS or on the chemical waste exchange list on-line before ordering a specific chemical. It costs 20-40 times the original purchase price of a chemical to dispose of that same chemical. In fact, the American Chemical Society estimates that 40% of the chemical waste generated by labs consists of unused chemicals. This could be reduced if labs checked with other departments or their own stock before ordering chemicals. Do not accept any chemicals from another department or outside organization unless you are sure these substances will be used.

Product substitution with a non-hazardous or less hazardous material.

Examples of product substitution include:

• Using a biodegradable non-toxic preservative, such as ethanol, in lieu of formaldehyde-based substances (formalin).
• Replacing flammable scintillation fluid with non-hazardous biodegradable scintillation fluid.
• Replacing hazardous solvents or cleaning solutions in parts washers with non-hazardous solutions.

Avoid mixing hazardous waste with non-hazardous waste.

Do not mix water, or other non-hazardous substances with hazardous waste.  This will generate even more hazardous waste, which increases disposal cost. In the case of flammable solvents, the more water mixed with the hazardous waste, the more expensive the disposal costs. Flammable liquids with a high BTU content are typically sent for fuel blending and water mixed with the flammables lowers the energy contents thereby requiring more expensive disposal techniques. Also, do not mix used oil with solvents or heavy metals, or the used oil cannot be recycled.

Spill prevention:

Care should be taken when weighing or transferring chemicals to minimize spills. Containers should be sealed when not in use and processes should be contained (i.e. fume hoods) to prevent the escape of fumes or leaks into the environment.

Limiting quantities purchased.

Purchase chemicals in the smallest volumes needed. Consider buying pre-weighed or pre-measured reagent packets where waste generation is high.

 

Inventory management and control

Laboratories should constantly monitor their chemical inventory and dispose of any unwanted or expired chemicals through EHS.  New containers should be dated when they are received so that older products will be used first.

Good housekeeping practices:

This includes properly labeling all containers with their hazardous contents and keeping an up-to-date chemical inventory.

Training:

Include waste minimization practices in student and employee training sessions. All employees and students who generate hazardous waste should take the hazardous waste management and waste minimization training and quiz.

Segregation:

Waste should be properly segregated once they are generated and stored in chemically compatible containers. For example, acid waste should not be stored together with caustics and oxidizers should not be stored with flammables. Hydrofluoric acid waste should not be stored in glass containers. Waste should be stored in secondary containment (i.e. tubs) when appropriate to ensure proper segregation during storage.

Eliminating unknown chemicals

Chemicals that are unlabeled cost up to 10 times more for disposal than properly labeled chemicals. In fact, in 2001 UT Knoxville spent roughly $75,000.00 to identify unknown chemicals (that price does not include disposal fees). At the very minimum, containers need to be labeled with the chemical/product name and primary hazard. Lab checkouts are conducted by EHS when an employee is leaving the university to ensure they are not leaving behind unlabeled chemicals.

Recycling.

There are many good reasons to recycle. Some of these reasons include:

• Conserves energy
• Protects the environment
• Reduces the need to build new landfills and incinerators
• Saves money and energy
• Stimulates the development of green technologies
• Provides valuable raw materials to industry

Examples of current recycling programs at UT Knoxville are:

• Universal waste, such as rechargeable batteries, fluorescent lamps and used oil, are sent to commercial recyclers.
• Solvents with high BTU values are reclaimed and burned as fuel in incinerators.
• Mercury from thermometers and equipment is collected for retorting.
• Any used photographic fixer that is generated is processed for silver recovery.
• Old computer equipment is sent for electronics recycling.

Distillation:

Some solvents can be re-distilled and reused. Currently, the Chemistry Department re-distills acetone for reuse.

Elementary neutralization and reclamation.

• Acids and bases can be neutralized, as long as they don’t contain any heavy metals or organics.
• Gels can be directly injected with ethidium bromide to eliminate large volumes of liquid waste.

The following methods of disposal are not acceptable and are considered a violation of state and federal environmental regulations.

• evaporation
• dilution
• combustion
• storm sewer
• sanitary sewer
• sharps container
• regular trash
• biohazard waste containers

Mixture Rule:

In 1982, the EPA adopted the mixture rule 40 CFR § 261.3a) (2) (IV), which states that hazardous waste, when mixed with a non-hazardous substances remains hazardous. This rule does not apply when mixing occurs during a process, only when waste is being mixed. Combining wastes to render them nonhazardous is considered treatment. Intentional mixing of waste to change the characteristic is a direct violation of the US EPA Resource Conservation and Recovery Act (RCRA) land disposal treatment standards. A permit is generally required to treat hazardous waste.  There are some exceptions to this rule, however, please call EHS before attempting any method of disposal.

Implementation:

EHS shall characterize the waste stream from each area that generates hazardous waste. Generators of hazardous waste will be queried about the availability and feasibility of waste reduction. EHS shall work with all departments to implement waste reduction efforts.

Performance Measures:

• Document hazardous waste minimization efforts. These records will be kept as part of Appendix A that is available in the EHS office for review and inspection.
• Review hazardous waste reduction results from the Annual Hazard Waste Report that is filed with the Tennessee Department of Solid Waste.
• Statutory limits as defined by the Tennessee Department of Environment and Conservation.

Program Review:

This program shall be reviewed annually and amended as necessary. When it becomes apparent that the plan is deficient, it shall be revised.

Performance measures shall be monitored at least annually.

Training:

Employees who generate or handle hazardous waste shall be trained to reduce hazardous waste generation. The hazardous waste management and waste reduction training may be presented during the annual training for hazardous waste generators. In addition, a self-study course is available by contacting the Environmental Health and Safety department at 865-974-5084.

Waste Minimization Efforts:

Specific Examples of waste minimization efforts that were made but EHS during 2017.

• EHS is packaging non-hazardous lab pack waste separately from hazardous waste, which saves money and reduces reportable quantities on our State year-end report.
• EHS eliminated >600 unknowns at a cost savings of $20.00 per sample plus eliminating an addition $1,400.00 in disposal costs by performing testing and consolidating compatible waste streams together. The unknowns originated from Walter Life Science building.
• EHS personnel poured off solvent materials campus-wide, which saved UT $2,500.00 in disposal costs.
• EHS punched over 50 empty propane cylinders during 2018 and shipped the empty cylinders to metals recycling. A cost savings of $1,000.00
• EHS was able to find a re-use option for 50% of the hazardous waste that was collected on-site.
• EHS is managing the non-hazardous waste on-site through a “Waste to Energy” program that converts the waste to electricity thereby providing a greatly reduced carbon footprint for that material into a beneficial re-use product.

Recordkeeping

EHS shall keep a record of the waste minimization plans for at least three years.

References

40 CFR 239-282 (RCRA Regulations)

Tennessee State Regulations 0400-12-01

Disclaimer

The information provided in these guidelines is designed for educational use only and is not a substitute for specific training or experience.

The University of Tennessee Knoxville and the authors of these guidelines assume no liability for any individual’s use of or reliance upon any material contained or referenced herein. The material contained in these guidelines may not be the most current.

This material may be freely distributed for nonprofit educational use. However, if included in publications, written or electronic, attributions must be made to the author. Commercial use of this material is prohibited without express written permission from the author.