Appendix C - Hazardous Waste Storage and Other Misc. Info
CU Hazardous Waste Policy for PPE Use
Personal protective equipment, PPE, is required by Hazardous Waste Regulations for small and large quantity generators. It is also vital for the health and safety of the generator. Personal protective equipment should be considered the last line of defense. Physical contact and exposure time with Hazardous Waste should be limited in all “Satellite Accumulation Areas”. All generators of Hazardous Waste, whether they are Faculty, Staff, Graduate Students, Undergrads or Visitors to Clemson University, are required to use PPE. This PPE must consist of safety glasses, lab coats or equivalent such as uniforms provided specifically for the job, and gloves. Gloves should be suitable for the hazardous waste that is being managed.
Nitrile gloves protect against most chemicals and infectious agents.
Rubber gloves protect against mild corrosive material.
Neoprene gloves protect against most solvents, oils, and mild corrosive materials.
Avoid latex gloves as many people are allergic or develop allergies to this material. Latex gloves also lose their structural integrity when exposed to most chemicals. Solvents and corrosive liquids actually degrade these gloves on contact.
The following sites may be used to help in the selection of the gloves recommended for specific chemicals:
Disposal of Controlled Drugs Pharmaceuticals at Clemson University
Currently there are 2 methods for disposal of off specification and out of date Controlled Drugs/Substances that are regulated by DEA. These methods include Reverse Distribution or disposal through the Hazardous Waste Disposal Contract managed by the Office of Research Safety.
*Please note that Controlled drug and Controlled Substance are one and the same and are used interchangeable in this document.
Do not wait until you are in need of immediate disposal of a DEA Controlled Substance. Because of the paperwork involved, notifications and scheduling required, this is a lengthy disposal procedure. Notification should start at least 2 months prior to the actual time/date these substances need to be removed from your inventory.
Under Reverse Distribution:
The licensee must file the DEA form 41 with their local DEA office and also request a copy of the Companies currently approved by DEA to receive these controlled drugs. Then the licensee will follow the proper procedures provided by one of those companies in order to complete the transfer. The licensee must package and mail the materials to the reverse distribution company and keep all related records. The Office of Research Safety’s Hazardous Waste Management Facility cannot provide this service or be in possession of controlled substances. Any controlled substances that inadvertently come into the Office of Research Safety’s Hazardous Waste Management Facility possession will be returned to the licensee immediately.
Under the Hazardous Waste Disposal Contract:
The licensee notifies the Hazardous Waste Officer that they have controlled drugs ready for disposal. The licensee will also supply a list of these controlled drugs to include name, DEA classification, amount and lot number. The Hazardous Waste Officer will then arrange disposal with the Hazardous Waste Disposal Contractor. The Hazardous Waste Disposal Contractor will fill out all forms needed for disposal including the DEA Form 41. They will submit this paperwork to the Hazardous Waste Officer for the appropriate signatures as needed. The Hazardous Waste Disposal Contractor will then file all paper work with the appropriate agencies. A date will be set for the Hazardous Waste Disposal Contractor’s DEA licensed representative to arrive on campus and take possession of the controlled drugs from the licensee. Note: The controlled drugs will remain with the licensee until the Hazardous Waste Disposal contractor’s representative takes physical possession of them.
Please take all precautions not to lose control of any Controlled Substance as this constitutes a serious violation of your license. DEA Controlled Substances include all those containers labeled with a large "C" and respective Roman numerals as to their classification by DEA.
Sanitary Sewer Disposal of Controlled Substances and Pharmaceuticals is forbidden at Clemson University main campus. Our treatment plant has no industrial discharge permit for such materials. And many of them can be harmful to the environment. The Office of Research Safety Hazardous Waste Management Facility can and will provide services for the other Pharmaceuticals that are NOT Controlled Drugs under DEA. These can be declared as Hazardous Wastes and we will pick them up and properly destroy them.
If you are unsure of whether your Pharmaceuticals are Controlled Substances (for example, the label is missing, the compound was made in the laboratory or the items is from very old stock before the common use of the large "C") you can consult lists from the Department of Justice, Drug Enforcement Division: http://www.deadiversion.usdoj.gov/schedules/index.html
There you will find two links: one to the "List of Controlled Substances" (I, II, III, IV and V), and one to "Exempted Lists". If your Pharmaceutical is NOT on the List of Controlled Substances, declare it as a chemical waste in the normal fashion.
If you find your Pharmaceutical's name on the list of controlled substances, consult the
"Exempted Lists." If your material is on the Controlled Substance list, but not the Exempted list, you have a controlled substance and will have to be disposed of via one of the two routes for Controlled Substance Disposal explained in this document. If it is on both lists, you have an exempted material. If you do find that you have an Exempt item, we ask that you expressly declare this type of waste separately from any other wastes as an "Exempt Controlled Substance" on the disposal declaration form, and the Licensee will have to co-witness the destruction and documentation of destruction when we come to pick it up. The licensee will have to place the declared material into some destructive media we will provide, and sign off on the destruction. This waste will then be further and permanently destroyed by incineration through the Hazardous Waste Disposal Contractor.
Standard Operating Procedure for Reacting Hazardous Waste
If a chemical effluent is generated and is still reacting at the end of a procedure, it is not yet a hazardous waste! It will not become a hazardous waste until the reaction/process is completed.
During the time the effluent is reacting, the generator should:
- Place the collection container labeled with the chemical constituents in a safe place (such as the chemical fume hood) inside Secondary Containment;
- Loosely cap the container until the reaction has stopped;
- Place a sign on the container that says:
“Caution: Contents Under Pressure, Loosely Capped Container”
When the reaction has completed, the generator should tightly close the cap, label the container with a Hazardous Waste label and declare the waste to the Hazardous Waste Officer with the Office of Research Safety for removal from the Satellite Accumulation Area to the Hazardous Waste Management Central Accumulation Area in the same manner as non-reacting hazardous waste is declared.
The Office of Research Safety will not collect waste that is still reacting; that waste is still considered to be “in process” until the reaction has finished.
Empty and old cylinders represent a real problem for the university and are not only expensive to deal with but can be dangerous as well. The following is a description of an incident that demonstrates some thought that should be put into the purchasing and management of these items at Clemson University.
This communication was to a Department Head…
I recently had our deactivation specialist come up on a non-football Saturday. He was to open and identify three old rusty cylinders found in a storage cabinet under a fume hood from a retiring professor’s laboratory. He also was to do the same for a "homemade" one we got from another professor’s storage room. The "homemade" one turned out to be hydrogen fluoride which reacted violently and sent a cloud of hydrochloric acid gas through the air when it was allowed to react with water to stabilize it. Of the three found under the hood, one had an obvious hole in it (and had emptied itself somewhere in the lab, I assume), one we verified as empty and we field-tested one to identify for later shipment. This last one cost over $1000.00 to dispose.
The real surprise was the two that had previously been given to us as "empty". They did not turn out to be so. One cylinder contained hydrogen bromide and was full. Some one had opened the valve and when nothing came out, they had mistakenly assumed it was empty. There were two like this. The other one was chlorine. Both valves were open and could have let go and discharged their contents into the lab at any time. We suspected that they were not empty and decided not to risk taking the valves out ourselves. A good thing huh?
The lesson here is that cylinders that have contained corrosive or oxidizing gasses or liquids cannot be considered empty by just opening the valve or by looking at the pressure gauge on the regulator. These gasses routinely clog the valves so that you cannot get the material out. Any cylinder that has contained a gas with these characteristics should be considered to still have material in it unless you can see into the cylinder because the valve has been removed or a hole has been drilled into it as our deactivation contractor does. This is the only way we can consider a cylinder to be truly empty. I would never recommend removing a valve on a cylinder that has held one of these types of gasses.
Solutions? Don't buy non-returnable cylinders of any gasses, especially of this kind. Buy only returnable cylinders so that you can send the cylinder back regardless of whether it’s empty or not. This may cost more up front but you really must figure in the entire cost. If you really need to see if one of these types of cylinders is empty, you could try to feed nitrogen back into the cylinder to see if it will repressurize. If nitrogen flows into the cylinder, you know the cylinder does not have a clogged valve and is empty so you can unscrew the valve from the cylinder and it will be scrap metal. This half of a day of deactivation described above, with seven small cylinders, cost us over $7000.00. We were lucky in that most of them were empty and we were able to field-test them so that we have very little further analysis and disposal costs.
Lessons learned: Buy gasses only in returnable or rented cylinders, especially those that contain corrosive or oxidizing liquids or gasses. Manage them carefully so that you keep track of their condition and location. Return them to the vendor as soon as you finish with your project. For further guidance contact the Office of Research Safety (864) 656-0341 or (864) 656-1770.
In addition to Fluorescent light tubes: for used oil, batteries and light ballast disposal contact the recycling center at Kite Hill.
Disposal of Used Printer Cartridges
These cartridges contain carbon black. This is a restricted waste because it is a flammable solid and a carcinogen. It cannot be disposed of in the dumpsters or on the ground. We have found both situations recently and the clean up of these has cost the university money. The Office of Research Safety reminds you that it is illegal to improperly dispose of these cartridges.
Most Cartridges come with a prepaid, return label and can be recycled at no cost to you. The Office of Research Safety encourages you to do so or contact the recycling center at Kite Hill. For further guidance on this and other hazardous waste management issues contact the Hazardous Waste Officer at 656-1770 or the Office of Research Safety at 864-656-0341.
Used Oil Management at Clemson University
Several years ago the state of South Carolina decided to declare used motor oil “hazardous Waste”. This declaration was at odds with the intent of the Resource Recovery and Conservation Act (RCRA) that originally defined hazardous wastes. The state rethought this decision and now considers used motor oil to be hazardous waste only if released to the environment or if improperly managed during its accumulation for recycling. Otherwise, used oil is exempt from some of the specific regulations that other hazardous waste must follow. The South Carolina Department of Environmental Control (DHEC) administers RCRA in our state.
Used oil is defined by the Environmental Protection Agency (EPA) as “any used oil that has been refined from crude oil, or any synthetic oil that has been used and as a result of such use is contaminated by physical or chemical impurities”. Farmers (with less than 25 gallons) and homeowners are excluded from any regulation. The exemption for used oil applied to Clemson University states that this material may be “accumulated speculatively” for recycling. “Accumulated speculatively” is defined as at least 75% of the material will be recycled in a given one year period. The EPA, DHEC, and Clemson University wants to encourage the recycling of this valuable waste, but also wants to protect the environment. The definition of recycling gets real tricky here. If the oil is re-fined as usable oil, it is truly recycled. If however, it is burned for energy recovery in a boiler or furnace (a form of recycling) it could release contaminants to the environments at these levels:
Arsenic 5ppm maximum
Cadmium 2ppm maximum
Chromium 10ppm maximum
Lead 100ppm maximum
Total Halogens 4000ppm maximum
Flash Point 100 deg. Minimum
Only after providing by laboratory analysis that it is “on-specification” and can be burned, can we allow anyone to take our oil for this purpose!
Oil filters are not hazardous waste and can be disposed of without special concern if handled in the following manner. They must not be “tern-plated”. This means coated with lead and other heavy metals to prevent corrosion. These tern-plated type filters have not been manufactured for several years and shouldn’t be of concern. All filters should be hot drained for 12 hours and crushed or punctured.
As you can see, this simple attempt at recycling could prove to be dangerous if you don’t know where your oil comes from and where it’s going. Because of the potential for waste oils and their related wastes to become hazardous wastes, the Office of Research Safety and the Hazardous Waste Officer must be consulted and informed of any activities in this area. It should not be the practice to accept oil from unknown sources or from outside the university. These questionable sources could lead to serious fines from DHEC. Please call the Office of Research Safety’s Hazardous Waste Management facility if you are having questions or problems with used oil management or any other hazardous waste problem at 864-656-1770.
Clemson Recycling Services under the management of Clemson University Facilities has a collection area for both uncontaminated used oil and oil filters. They should be contacted at 864-656-4219 with any questions concerning the recycling of these wastes.
Contaminated oils should be managed as a hazardous waste and declared to the Hazardous Waste Officer for proper disposal.
Guidance on Conducting Hazardous Waste Treatability Studies
The purpose of this document is to offer clarification regarding the conditional exemptions provided by the South Carolina Hazardous Waste Management Regulations R.61-79 (SCHWMR) for Hazardous Waste Treatability Studies. Per SCHWMR R.61-79.260.10 a “Treatability Study” means a study in which a hazardous waste is subjected to a treatment process to determine: (1) Whether the waste is amenable to the treatment process, (2) what pretreatment (if any) is required, (3) the optimal process conditions needed to achieve the desired treatment, (4) the efficiency of a treatment process for a specific waste or wastes, or (5) 60.11 References 260 - 10 the characteristics and volumes of residuals from a particular treatment process. Also included in this definition for the purpose of the 261.4 (e) and (f) exemptions are liner compatibility, corrosion, and other material compatibility studies and toxicological and health effects studies. A "treatability study" is not a means to commercially treat or dispose of hazardous waste. (11/90)
A researcher conducting a hazardous waste treatability study must comply with the exclusion regulations found in SCHWMR R61-79.261.4(e) and (f). These exemptions apply to the following categories of wastes:
1) non-acutely hazardous waste,
2) acutely hazardous waste
3) media (e.g., soil and debris) contaminated with acutely hazardous waste
4) media contaminated with non-acutely hazardous waste
Exclusions as they apply to generators or sample collectors:
The maximum quantities allowable for exemption that a generator or sample collector may use or ship to a testing facility or laboratory are limited to no more than:
1) 10,000 kg of media contaminated with non-acute hazardous waste,
2) 1000 kg of non-acute hazardous waste other than contaminated media,
3) 1 kg of acute hazardous waste,
4) 2500 kg of media contaminated with acute hazardous waste for each process being evaluated for each generated waste stream; and
The mass of each sample shipment does not exceed 10,000 kg; the 10,000 kg quantity may be all media contaminated with non-acute hazardous waste, or may include 2500 kg of media contaminated with acute hazardous waste, 1000 kg of hazardous waste, and 1 kg of acute hazardous waste.
The sample must be packaged so that it will not leak, spill, or vaporize from its packaging during shipment and the requirements for transportation are met.
Exclusions as they apply to transporters:
The transportation of each sample shipment must comply with U.S. Department of Transportation (USDOT), U.S. Postal Service (USPS), South Carolina Public Service Commission or other applicable shipping requirements.
If USDOT, USPS, or other shipping requirements do not apply to the shipment of the sample, the following information must accompany the sample:
1) the name, mailing address, and telephone number of the generator of the sample and of the facility performing the treatability study, and
2) the quantity of waste, date of the shipment, a description of the sample (including the EPA Hazardous Waste Number), and confirmation of the sample being shipped to a laboratory or testing facility that either
(1) has a RCRA permit,
(2) has interim status, or
(3) is exempt under 40CFR 261.4(f)
The generator or sample collector maintains the following records for a period ending 3 years after completion of the treatability study:
1) Copies of the shipping documents;
2) A copy of the contract with the facility conducting the treatability study;
3) Documentation showing:
(1) The amount of waste shipped under this exemption;
(2) The name, address, and EPA identification number of the laboratory or testing facility that received the waste;
(3) The date the shipment was made; and
(4) Whether or not unused samples and residues were returned to the generator.
The generator reports this information to the state in its annual report.
Exclusions as they apply to Laboratories or testing facilities:
(1) No less than 45 days before conducting treatability studies, the facility notifies the Department in writing that it intends to conduct treatability studies under this paragraph.
(2) The laboratory or testing facility conducting the treatability study has an EPA identification number.
(3) No more than a total of 10,000 kg of "as received" media contaminated with non-acute hazardous waste, 2500 kg of media contaminated with acute hazardous waste or 250 kg of other "as received" hazardous waste is subject to initiation of treatment in all treatability studies in any single day. "As received" waste refers to the waste as received in the shipment from the generator or sample collector.
(4) The quantity of "as received" hazardous waste stored at the facility for the purpose of evaluation in treatability studies does not exceed 10,000 kg, the total of which can include 10,000 kg of media contaminated with non-acute hazardous waste, 2500 kg of media contaminated with acute hazardous waste, 1000 kg of non-acute hazardous wastes other than contaminated media, and 1 kg of acute hazardous waste. This quantity limitation does not include treatment materials
(including nonhazardous solid waste) added to "as received" hazardous waste.
(5) No more than 90 days have elapsed since the treatability study for the sample was completed, or no more than one year (two years for treatability studies involving bioremediation) have elapsed since the generator or sample collector shipped the sample to the laboratory or testing facility, whichever date first
occurs. Up to 500 kg of treated material from a particular waste stream from treatability studies may be archived for future evaluation up to five years from the
date of initial receipt. Quantities of materials archived are counted against the total storage limit for the facility.
(6) The treatability study does not involve the placement of hazardous waste on the land or open burning of hazardous waste.
(7) The facility maintains records for 3 years following completion of each study that show compliance with the treatment rate limits and the storage time and quantity limits. The following specific information must be included for each treatability study conducted:
(i) The name, address, and EPA identification number of the generator or sample collector of each waste sample;
(ii) The date the shipment was received;
(iii) The quantity of waste accepted;
(iv) The quantity of "as received" waste in storage each day;
(v) The date the treatment study was initiated and the amount of "as received" waste introduced to treatment each day;
(vi) The date the treatability study was concluded;
(vii) The date any unused sample or residues generated from the treatability study were returned to the generator or sample collector or, if sent to a designated facility, the name of the facility and the EPA identification number.
(8) The facility keeps, onsite, a copy of the treatability study contract and all shipping papers associated with the transport of treatability study samples to and from the facility for a period ending 3 years from the completion date of each treatability study.
(9) The facility prepares and submits a report to the Department by March 15 of each year, that includes the following information for the previous calendar year: (6/08)
(i) The name, address, and EPA identification number of the facility conducting the treatability studies;
(ii) The types (by process) of treatability studies conducted;
(iii) The names and addresses of persons for whom studies have been conducted (including their EPA identification numbers);
(iv) The total quantity of waste in storage each day;
(v) The quantity and types of waste subjected to treatability studies;
(vi) When each treatability study was conducted;
(vii) The final disposition of residues and unused sample from each treatability study.
(10) The facility determines whether any unused sample or residues generated by the treatability study are hazardous waste under 261.3 and, if so, are subject to
parts 261 through 268, and part 270, unless the residues and unused samples are returned to the sample originator under the 261.4(e) exemption.
(11) The facility notifies the Department by letter when the facility is no longer planning to conduct any treatability studies at the site.
Please contact the Office of Research Safety for more guidance and/or assistance with reporting these studies to SCDHEC.
CU Environmental Remediation SOP
Clemson University maintains a Remediation Services Contract for planned (non-emergency) and emergency environmental remediation site work. This contract is managed by Environmental Safety and is meant to serve both research and institutional safety needs.
When the need to activate the contract arises, please contact:
W. Robert Newberry, Director of Environmental Safety
864–656-2583 or 864–722-7215 or email: email@example.com
Alternate: Robert McCrary @ 864-722-7190 or email: firstname.lastname@example.org
If the remediation work involves incidents in a research or teaching laboratory, the following should also be contacted:
Naomi Kelly, Research Safety Chemical Hygienist
864-656-7554 or 864-656-0341 or email@example.com
Kerri Kwist, Research Safety Biosafety Officer
656-7686 or firstname.lastname@example.org
Konstantin Povod, Research Safety Radiation Safety Officer
864-656-7165 or 864-650-8153 or email@example.com
JP Hooks, Environmental Health Manager
314-4610 or firstname.lastname@example.org
Prior to the start of any remediation work, if hazardous waste (RCRA or CERCLA) is involved or will be generated (whether research or institutional in nature), contact:
ON CAMPUS: June Brock-Carroll, Research Safety Hazardous Waste Officer
864-656-1770 or 864-633-6357 or email@example.com
When an Environmental Permit is Required
The environmental permitting policy for Clemson University requires all departments to evaluate their needs for any required environmental permits as appropriate for their operations. Obtaining these permits and complying with their requirements is the responsibility of the department, as are all fines and other penalties for non-compliance. Copies of all permits obtained must be sent to the applicable Clemson University Safety Office, (The Office of Research Safety or The Office of Environmental Safety), as indicated below. Each Safety Office will maintain a central repository for the university environmental permits that they oversee and audit permit compliance as necessary. This policy applies to all Clemson University operations, regardless of location.
Contractors working on behalf of Clemson University are required to comply with this policy if their operations require environmental permitting. Failure of a contractor to adhere to this policy will result in withholding all payments until proper permits are provided and penalties are satisfied.
Permits may be required under these circumstances:
1) Discharge into the air. Any new discharge into the air requires evaluation to see if it falls under our existing Title V permit, if another permit is required, or if the activity does not require a permit. (Environmental Safety)
2) Discharge into the "waters of the State." Any discharge that eventually can make its way into "the waters of the State" has to be reviewed to see if it is covered under an existing permit (NPDEA, Storm Water), requires its own permit, or is unregulated. (Environmental Safety)
3) Disturbance of or discharge on to soil. Activities disturbing soil (generally construction) or which discharges on to or in to the soil (generally petroleum products) must be evaluated for permit requirements. (Environmental Safety and Research Safety)
4) Collection and or disposal of chemical, biological, or radiological materials. These activities are regulated, and permits may be required. (Research Safety)
Upon request, the applicable CU Safety Office will review an activity to determine if a permit is required and also assist in obtaining the permit if desired.