Hazardous Waste Management

Value Statement

Austin Community College (ACC or the College) is committed to safe handling and management of hazardous and solid wastes as well as pollution prevention through compliance with applicable Federal, State and local laws. This written Hazardous Waste Management Program (HWMP or Program) was developed to protect human health and safety, appropriately manage chemical inventory, reduce the impact to the environment, manage disposal costs, and ensure regulatory compliance.

Hazardous materials and wastes on each campus can range from burned out fluorescent lights to oily rags to toxic laboratory wastes. Waste materials can be managed by a wide variety of faculty and staff. This program will provide information for the proper management and disposal of three types of wastes found at ACC: Hazardous Wastes, Regulated Non-Hazardous Wastes, and Universal wastes. No wastes should ever be disposed of in trash bins or poured down a drain without first having a hazardous waste determination performed by EHS staff.

This program will inform faculty, staff, employees, and students at ACC of policies created to ensure the College complies with all laws and regulations surrounding the proper management of solid and hazardous wastes. The Program pertains to determinations and classifications of wastes, managing and storing hazardous wastes, and proper disposal procedures for hazardous and other regulated wastes. ACC Environmental, Health, Safety and Insurance Office (EHS) administer this program. Compliance with the HWMP is legally mandated through federal and state statutes and requires the full cooperation of all College departments.

Applicable Hazardous Waste Management Laws and Regulations

The U.S. Environmental Protection Agency (EPA) is authorized by Congress to regulate hazardous wastes under the Resource Conservation and Recovery Act (RCRA). RCRA authorizes the EPA to develop, promulgate and enforce laws and regulations concerning all aspects of hazardous waste management in the US. These laws and regulations are found in the Code of Federal Regulations, Volume 40, Parts 260-279. The Texas Commission on Environmental Quality (TCEQ) administers RCRA for the State of Texas through their Industrial Solid Waste and Municipal Hazardous Waste regulations. State of Texas regulations are found in the Texas Administrative Code (TAC), Title 30, Part I, Chapter 335.

Non-compliance can result in substantial fines and penalties being levied against the College. Penalties for non-compliance in Texas may be civil, criminal, or administrative violations with fines up to $25,000 per violation per day and up to a 15-year prison term for individuals. A single container could have numerous violations if improperly managed. The individual responsible for any violation may also be held personally liable. Potential rule violations can range from failure to properly label a hazardous waste container up to intentionally disposing of hazardous wastes into the sewer, into the air (such as leaving containers of solvents open in a fume hood), or in the regular trash.

RCRA establishes what is known as “cradle-to-grave” waste ownership for hazardous waste generators. Basically, once a hazardous waste is created, the College is entirely responsible for its proper management until it is destroyed, recycled, or otherwise treated so it is no longer hazardous. Legally this liability remains with ACC and cannot be transferred to another party or entity. The individual who creates the hazardous waste is legally responsible for complying with all associated storage and management laws and regulations until it is removed by the vendor. Management and disposal procedures for the College are based on this HWMP which has been derived from state and federal regulations.

Per regulations, any ACC faculty, staff or other employees who decide to discard any item that meets the definition of a hazardous waste automatically become a Hazardous Waste Generator. Making hazardous waste determinations requires specialized knowledge and training. Only qualified EHS staff can classify wastes as hazardous or non-hazardous. Most wastes at ACC have already been identified and classified and procedures exist for their management and disposal.

All businesses, including academic institutions and government agencies, which generate hazardous wastes, must comply with the applicable Federal and State regulations. The HWMP and related procedures provide information regarding hazardous waste identification, outlining correct procedures for safe and proper waste management, and disposal procedures as they pertain to faculty and staff. The EHS Department works with waste generators in each department and unit to assist in identifying and classifying any hazardous waste and inform each person what rules and measures apply to managing and storing wastes correctly. The ultimate responsibility to ensure proper storage and management remains with the employee and department that created the waste.

Regulations break waste generators up into various classifications depending on the amounts of waste produced each month. A Small Quantity Waste Generator (SQG) is defined as a location generating between 220 and 2200 pounds of hazardous waste, or 2.2 pounds of acutely hazardous waste, per month. Any ACC campus classified as a SQG must comply with the applicable hazardous waste management and storage laws and regulations. This includes on-site waste storage in your area, waste container management, proper labeling and marking of containers, etc. SQG campuses are registered with and under the auspices of the TCEQ.

ACC will follow SQG regulations for all campuses as they inherently provide levels of personnel and environmental safety. This strategy allows the College to apply a consistent set of standards and guidelines across the district for proper management of hazardous waste.

Important to understand waste generators are never relieved from liability for damages caused by their waste through mismanagement. This liability remains even after it has been transferred to a third party vendor. Strict Liability along with Joint and Several Liability provisions of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980 allows the government to hold any one individual entity, known as a Potentially Responsible Party (PRP), singularly responsible and liable for the entire cost associated with remediating a contaminated site if they have ever shipped any wastes to that location.

The government does not have to prove it was the PRP’s waste that was actually released or was responsible for causing any environmental harm or damage. Nor does it matter that the PRP was in full compliance with environmental laws and regulations in effect at the time they shipped waste to that location. With Strict Liability the government is not required to assess individual blame or prove intent or negligence on the part of the generator. Furthermore, these rules are retroactive in their application and apply regardless of whether a generator has not shipped waste to a facility for any number of years. Thus due diligence and selection of a qualified hazardous waste vendor and any disposal facilities is critical in protecting generators from future liability.

Duties and Responsibilities

ACC Chancellor: The Chancellor is the College official ultimately responsible for compliance with environmental health and safety regulations. Additionally, responsibility and liability for the Program extends to the Board of Trustees. The ACC College Chancellor and Board of Trustees shall show visible support for environmental compliance and safety as a value at ACC through funding and appropriate staffing in support of the Program.

ACC Executive Team and Administrators: Responsible for implementing the Program in their individual areas and departments, showing visible support for the program, and for ensuring a healthy and safe environment for the College’s employees and students.

Deans, Unit Directors, and Department Chairs: Responsible for implementing the Program and assuring compliance within their disciplines, departments, areas, or units. The various associated duties may be delegated to personnel within the department or unit; however, the ultimate responsibility remains with the Dean, Unit Director or Department Chair. Non-compliance issues must be promptly addressed by the Department Chair, Dean, or Unit Director.

EHS: Administers the Program for the. Responsibilities include:

Providing assistance to College faculty and staff with the implementation of and compliance with this Program, including but not limited to training, making hazardous waste determinations and classifications, oversight of hazardous waste disposal, establishing and coordinating area compliance audits, and assisting with corrective actions.
Providing initial and refresher hazardous waste training as necessary.
Compiling and maintaining a list of all the College’s hazardous waste generator locations so that RCRA training can be scheduled and documented for employees assigned to those areas.
Maintaining a manifest master file. Regulations require manifests be maintained for a minimum of 3 years.
Maintaining a liaison with the appropriate regulatory authorities (TCEQ, EPA, etc.). a) Submitting information to the TCEQ as required. b) Submitting required annual waste summaries to the TCEQ when appropriate.
Ensuring a contract with a qualified and properly licensed hazardous waste disposal contractor is in place at all times. EHS will perform due diligence and inspections of hazardous waste disposal contractors and associated facilities to ensure they are in regulatory compliance.
Coordinating scheduling with contracted waste disposal vendor for hazardous waste pick-ups at all campuses and facilities, and to be present for all waste shipments or management activities. Only appropriately trained and qualified EHS Coordinators (or the EHS Executive Director as backup) are allowed to sign manifests and paperwork for all shipments of regulated wastes. The U.S. Department of Transportation (DOT) rules govern transportation of hazardous waste. EHS will ensure personnel with manifest signature authority have received the mandated documented training regarding hazardous waste shipments as required by the DOT.
Coordinating with generators at each campus to prepare for scheduled hazardous waste pick-ups and provide them with necessary supplies for waste storage, management and shipments at those locations.
Coordinating sampling and testing for identification of unknown materials with the College’s designated environmental contractor whenever testing is needed prior to shipping waste from an ACC facility.
Providing support through technical consultations with ACC’s hazardous waste generators.

Faculty and staff are responsible for

Knowing and understanding how they fit into the HWMP
Complying with applicable provision of the Program and regulations
Properly storing and managing hazardous wastes they generate.
Ensuring waste containers are properly labeled and in good repair.
Knowing what is in each waste container and preventing mixing of incompatible waste that could create a dangerous situation through unwanted chemical reactions.
Completing paperwork to notify EHS they require waste pickup service.

Hazardous Waste Management Program

Introduction

The Program is administered by EHS with authority through the Associate Vice Chancellor of Business Services. Faculty and staff who generate wastes at the College are responsible for properly managing them. Any newly created wastes that have not undergone a hazardous waste determination by EHS should be evaluated as soon as possible to ensure compliance with management requirements and storage time limit regulations. It is the potential generator’s responsibility to notify EHS before beginning any process that creates a new waste not already evaluated for waste classification.

Each academic, vocational, or support department, including any instructional facilities and locations under ACC control, that produces hazardous wastes in any manner must also ensure personnel who may come into contact with hazardous wastes have received documented training in hazard awareness and waste management. That training includes ACC policies for proper handling and storage. The Dean or Director of each department, unit, or area has the ultimate responsibility for maintaining compliance with these requirements.

Compliance with the Program ensures compliance with applicable regulations and reduces adverse effects to human health and the environment.

Training

All employees who manage or handle hazardous waste must receive appropriate training. Initial training will be provided to all ACC employees participating in any hazardous waste related activities and before they are allowed to work with hazardous waste without supervision from a trained staff member. Refresher training must be completed within 13 months of previous training. All employees will receive necessary training through EHS which shall include:

Overview of EPA and TCEQ regulations
Generator responsibilities
Hazardous waste determination
Waste classification, labeling, segregation and storage requirements
Spill cleanup procedures
Disposal Procedures Send all training records to EHS. EHS will maintain records and documentation for all RCRA required training.

Making Hazardous Waste Determinations

Waste is defined as any material an individual determines is no longer fit for its intended use and should be thrown away, recycled, or discarded. Only qualified EHS staff should make a solid waste determination for any unwanted materials that have not been generated and classified before. All training with respect to RCRA regulations must be reviewed and approved through the EHS Executive Director. Regulations hold generators responsible for determining if a solid waste constitutes a hazardous waste. From the time a waste is classified as hazardous generators are responsible for complying with proper management and storage rules and regulations. For waste materials that are hazardous, the moment a person responsible for its creation and final disposition makes a decision to discard it they become a hazardous waste generator and all applicable regulations apply.

ALL WASTES MUST BE EVALUATED AND CLASSIFIED AS HAZARDOUS OR NONHAZARDOUS. CONTACT THE EHS OFFICE CONCERNING NEW OR EXISTING WASTE STREAMS THAT ARE UNCLASSIFIED.

Most hazardous materials and waste regularly generated at ACC have already been evaluated and identified by EHS. Any materials or items that have not been previously evaluated must be classified by EHS before they are discarded.

There are two methods for making hazardous waste determinations: Generator Knowledge or Analytical Testing by an EPA approved laboratory. Analytical testing is very expensive and time consuming so generator knowledge is the preferred method for classifying wastes. Since it is also incumbent upon waste generators to properly label and manage wastes they generate, they should keep track of what materials have been added to each waste container. Only the discovery of unknown materials should require analytical testing to make a hazardous waste determination.

Any materials, items, or products (including fluorescent light bulbs, batteries, aerosol cans, etc.) that are not regular rubbish, trash or garbage, need to be classified by EHS as either hazardous or non-hazardous.

EHS will make arrangements with the approved hazardous waste vendor to pick up and dispose of wastes after each semester or more frequently if the need arises.

Generator Responsibilities – Storage & Management Requirements

Any person generating hazardous waste must properly manage it until a hazardous vendor manifests and removes the container from the storage area. This includes

Segregating incompatible waste chemicals. Do not mix chemicals that may react and cause unsafe conditions in the lab or storage areas.
Proper container management, including marking and labeling each container and using containers compatible with the wastes’ characteristics.
Labeling requirements: The container must be labeled. This means labeling with the words “Hazardous Waste” or the actual contents of the container and the date waste was first placed in the chemical storage area for your department and location. (Note that you can use an indelible ink pen to write “Hazardous Waste” and the Date on the top or side of the container. It is not necessary to use pre-printed labels for waste containers.)
Must keep container lids securely closing the container at all times unless adding or removing waste.
Never remove a label or tag from a cylinder no matter what the size. Disposal of unknown cylinders is very expensive and dangerous to have at any location.
Notify EHS you have waste for disposal using the ‘Chemical Waste Request for Disposal Form’. Should include information on the type of waste. Waste is picked up after each semester and a reminder notice with the form attached will be emailed a few weeks before the pickups are scheduled.
Please return request from for disposal back to EHS as soon as possible to ensure your material is picked up. Any requests received a few days before the scheduled pickups or on the week pickups are occurring likely will not be on the pickup schedule and would have to be stored until the next time the hazardous waste vendor is scheduled.

It is illegal to dispose of hazardous waste in any of the following ways:

Disposal through the sanitary drain such as sink drain, floor drain or urinal or toilets.
Evaporation inside or outside a fume hood.
Disposal in the regular trash.
Disposal through storm drain, on paved surface, or on the ground.

Empty Containers: RCRA regulations have specific conditions that must be met before a container can be considered empty and no longer managed as hazardous. EPA regulations stipulate that an empty chemical container:

Shall not contain free liquid or solid residue;
Pesticide containers or containers which contained acutely hazardous materials must be triple rinsed AND the rinse water collected for disposal as hazardous waste
Have the label removed or defaced;
Have the lid or cap removed; and
Have a hole punched in the bottom (for metal or plastic containers).

Currently the approved hazardous waste vendor supplies containers. If you need additional containers call EHS.

Disposal of Non-hazardous Wastes

This document does not address regular office trash, rubbish or garbage. It is geared toward disposing chemical products and ‘Special Waste’ covered under Texas laws. Trash generated from other academic or administrative work (such as trash from experiments in Chemistry, paint wastes from maintenance activities, etc.) is managed under the HWMP. With prior documented approval from the EHS Office, any non-hazardous waste may be disposed using the sanitary sewer or regular trash. Additional information about non-hazardous waste disposal can be obtained below or from the EHS Department.

Not all chemical wastes are hazardous and will not have to be managed as such. The following guidelines for determining which non-hazardous wastes are suitable for disposal through normal waste channels were developed after careful review of TCEQ regulations.

No hazardous wastes can be placed in the regular trash. “Regular trash” refers to placing material into any trash receptacle inside a building or dumpsters outside of a building. Custodial services will not empty trash cans that contain any type of chemical container. Liquid waste such as bottles of unused or partially used solutions may never be disposed of in the regular trash or dumpsters. Cylinders must be managed through the HWMP.

Certain solid, non-hazardous chemicals are suitable for disposal using the trash. Solid, non-hazardous waste must be placed directly in the dumpsters outside the building and not into the trashcans inside a building.

The following types of solid waste, which are generally considered non-hazardous or of low toxicity can be put directly into dumpsters outside the building.

Organic chemicals:

Sugars and starches
Naturally occurring amino acids and salts
Citric acid and its Na, K, Mg, Ca, NH4 salts
Lactic acid and it’s Na, K, Mg, Ca, NH4 salts

Inorganic chemicals:

Sulfates: Na, K, Mg, Ca, Sr, NH4
Phosphates: Na, K, Mg, Ca, Sr, NH4
Carbonates: Na, K, Mg, Ca, Sr, NH4
Oxides: B, Na, Ca, Sr, Al, Si, Ti, Mn, Fe, Cu, Zn
Chlorides: Na, K, Mg
Borates: Na, K, Mg, Ca
Fluorides: Ca

(As noted above, liquid solutions of such wastes should not be put into the dumpsters. Contact the EHS Office for instructions for disposal of such liquid solutions.)

Laboratory materials not contaminated with hazardous chemicals:

Chromatographic absorbents
Filter papers, filter aids, and glassware
Rubber and plastic protective clothing

If there is any question as to whether a waste is acceptable for regular trash please contacts the EHS Office for further guidance.

Determining Generator Status

The Generator Status for each campus will be determined by the EHS office. EHS keeps track of how much hazardous waste is generated each month per individual ACC campus in order to determine generator status and what regulatory requirements impact that location. TCEQ also requires annual waste summaries be submitted outlining how much waste was generated at the campus.

EHS determines a campus generator classification by weighing the amount of hazardous waste produced each month throughout the calendar year. The total weight of hazardous waste for each month determines the generator category. If volumes of waste from a campus increase beyond a certain weight limit it causes that campus to be reclassified in a higher generator category. Moving into a higher generator category will result in having to comply with more stringent regulatory requirements at that physical street address.

Classification of Hazardous Wastes and Segregation Requirements

Hazardous chemical wastes are categorized into the following hazard classes:

Halogenated solvents
Non-halogenated solvents – Flammables
Acids (inorganic or organic) – (Addition of any amount of organic acid makes the entire container ‘organic’.)
Bases (inorganic or organic) – (Addition of any amount of organic base makes the entire container ‘organic’.)
Heavy metals (silver, cadmium, lead, mercury, etc.)
Poisons (inorganic or organic)
Reactive, (such as sulfides, cyanides, water-reactive chemicals, etc.)

Different classes of hazardous chemical waste must not to be commingled in the same container in order to prevent dangerous, unwanted reactions. For example, do not combine inorganic heavy metal compounds with organic acidic waste solvents. Never combine oxidizers with organic materials.

In addition, do not combine non-hazardous waste (e.g., mixture of water, dilute acetic acid, and sodium bicarbonate) with hazardous chemical waste. Areas should contact EHS for guidance with these determinations.

Universal Wastes

Universal waste is a subset of hazardous waste. Universal waste regulations were designed to encourage recycling and proper disposal of commonly generated hazardous wastes while also reducing the regulatory burden on generating facilities. If these specific relaxed regulations are not followed Universal Wastes must be managed as hazardous wastes and subject to full RCRA regulations for management and storage. Basically, the TCEQ Universal Waste Rule offers relaxed alternatives for managing the following types of hazardous waste in Texas:

Batteries including lead-acid as described in 40 CFR 273.2;
Pesticides as described in 40 CFR 273.3;
Mercury Thermostats as described in 40 CFR 273.4;
Lamps (mercury, metal halide, etc.) as described in 40 CFR 273.5; and
Paint and paint related waste as described in 30 TAC 335.262(b). (Texas only)

For more information please refer to the EHS website on ‘Universal Waste Procedures’ or contact EHS for additional information.

Proper Storage of Hazardous Wastes

An integral piece of the Hazardous Waste Management Program is container storage areas. These areas are used to store waste containers prior to shipment. Each individual hazardous waste generator is responsible for care and control of their container storage areas. Generators in charge of such areas should:

Ensure the waste containers are accessible to the EHS for inspections and pickups.
Accumulate their waste in safe, transportable containers that are properly labeled and stored to prevent human exposure to, or environmental release of, the hazardous waste materials. NOTE: Any material spilled down the side of the container is a hazardous waste spill and appropriate measures should be implemented to clean the container and surrounding area. This prevents inadvertent exposures.
Ensure that hazardous waste containers are compatible with the hazardous chemical waste contents (e.g., do not use metal containers for corrosive waste).
Use containers that are in good condition and do not leak. Empty chemical glass jugs and bottles can be reused for waste collection provided they have been appropriately rinsed clean and all labels regarding the original contents have been removed or blacked out.
All containers must have suitable screw caps or other means of secure closure. Also true for universal wastes such as spent fluorescent tubes.
If you require waste containers contact EHS for assistance on selection of appropriate container type and size and placement/storage.

Never overfill waste containers. Expansion from vapor pressures and excess weight can lead to spills, releases, explosions, conditions dangerous to human health, and extensive environmental exposure.

The following guidelines will help prevent overfill of containers:

Containers of solids must not be filled beyond their weight and volume capacity. Call EHS with any questions about this guideline.
Jugs and bottles should not be filled above the shoulder of the container.
Containers that are 5 gallons or less should have at least two inches of space between the level of the liquid and the top of the container.
Containers larger than 5 gallons should have at least four inches of space left at the top.

Any time a material is not intentionally being added or removed from the container it must be kept tightly closed. Containers must be closed or sealed at all times to prevent leakage or spills. Acetone escaping from a container that was not sealed tightly is considered a chemical spill.

Satellite Accumulation Areas

The following requirements pertain to Satellite Accumulation Areas (SAA):

The area must be under the control of the generator(s) and secured from “Unauthorized Entry”.
Area has warning signs and containers have hazardous wastes labels. Emergency contacts are posted. These signs are available from the EHS Office.
Hazardous waste is stored in a designated and marked area.
Storage containers are properly labeled with the words “Hazardous Waste”, or with other words that identify the contents of the containers. Once full the date must be written on the container.
Storage containers are in good condition. If container begins to leak, the generator must transfer the hazardous waste from the leaking container to a container in good condition.
Storage containers must be compatible with the hazardous waste being stored (i.e. made of or lined with materials which will not react with the hazardous waste).
Storage containers must be kept closed with lids on tight except when adding waste.
Full storage containers must be properly labeled as per Section K of this document, and marked with the date the container becomes full and ready for removal.
Areas must be accessible to EHS personnel.
Hazardous waste containers are separated from non-waste chemical containers.
Per regulations, no more than 55 gallons of any one hazard class of waste or one quart of acutely hazardous waste is permitted to be stored in a Satellite Accumulation Area.
Full containers equaling 55 gallons of waste cannot be stored for more than three days. Write date on container once it is full and ready for moving to 180-Day storage. The generator must transfer full containers to a 180-Day Accumulation Storage Area within three days.
Appropriate spill Control Equipment is available.
Weekly inspection of the Satellite Accumulation Area must be completed, using the form in Appendix C.

Container Labeling & Marking

Chemical product containers used for waste accumulation must have the chemical label removed, destroyed or defaced. A new label noting the contents are hazardous waste must be applied.
EPA regulations require hazardous waste containers be labeled with the words “Hazardous Waste” and the date from when the first drop of waste is placed in the container.
Containers at ACC can be labeled in one of three methods:
- A pre-printed label, either from a vendor who provides such labels, or
- Creating labels using a computer and printer, or
- Using a sharpie or other indelible ink pen to hand write the required information

Identify the hazardous waste constituents on the label so the waste vendor knows what chemicals it contains for safety and handling and will be able to use the appropriate treatment method.

EXAMPLE: See below to properly complete your hazardous waste label if creating and printing from your computer or handwriting:

______________________________________________________________________________

HAZARDOUS WASTE ACCUMULATION START DATE:

CONTENTS: (Example: acetone, chloroform, hexane, oil, water)

HANDLE WITH CARE! CONTAINS HAZARDOUS OR TOXIC WASTE

__________________________________________________________________

A generator who is accumulating hazardous waste on-site in containers must ensure the containers are properly marked (40 CFR 262.34). Ensure each waste container under your control is properly marked.

Fill in the Accumulation Start Date when the waste container is full and/or ready for pickup.
Chemical name/Common name. CHEMICAL FORMULAS OR ABBREVIATIONS ARE NOT ACCEPTABLE ON CONTAINER LABLES. List all chemical components in a waste container (including water).

Hazardous Waste Tracking & Disposal

The EHS Office will provide the Chemical Waste Request for Disposal form, coordinate disposal requirements with generators, maintain records of disposal services, and provide reports as appropriate to Federal or State agencies.

TCEQ and EPA regulations require the “cradle to grave” tracking of hazardous waste shipments in order to ensure proper disposal. Two forms are specifically required: the Uniform Hazardous Waste Manifest and land disposal restriction documentation. ACC has the hazardous waste disposal vendor prepare all manifests and land disposal restriction forms on behalf of the College. The EHS Office is responsible for reviewing all paperwork for accuracy and correctness and signing all manifests by hand.

Individuals signing manifests must be certified to do so through appropriate and current training under 49 CFR – U. S. Department of Transportation (DOT) regulations. The EHS employee who signs the manifest retains the back copy after it is signed by both EHS and the initial transporter of the shipment. The EHS office files their copy with associated paperwork from the shipment. Remaining copies of the manifest and other paperwork are given to the transporter.

The TSD facility will sign the manifest upon receipt of the shipment. At this point, the transporter is given a manifest copy for their records showing all material was delivered. The TSD facility keeps a copy and returns a signed and dated copy to the EHS Office which documents the wastes were received as manifested. This copy is kept in EHS records for at least three years. The TSD facility must treat the hazardous waste to meet appropriate standards. ACC is responsible for conveying required information regarding hazardous waste treatment to the disposal vendor. A Land Disposal Restriction (LDR) form must accompany any hazardous waste shipment to a treatment facility. The LDR includes information on the waste constituents, categories, and testing data, if available. It also denotes what treatment standards must be met or specific technology that must be used. ACC must maintain land ban documentation for at least three years.

Emergency Preparedness & Contingency Planning

An ‘Emergency Coordinator’ shall be designated to coordinate any emergency response measures in the event of a chemical spill or unplanned release. The Emergency Coordinator must be on the premises or on call. The EHS Executive Director is the Emergency Coordinator for all ACC campuses. EHS will provide the required signs for hazardous materials storage areas and waste generating areas. Each campus should have posted next to the telephone or in a visible location on the outside waste storage buildings with the following information:

Location of fire extinguishers and spill control material
If present, fire alarm; and
The telephone number of Campus Police Dispatch.

As part of a facility’s contingency planning, EHS will attempt to make arrangements with the appropriate local emergency response authorities regarding the type of hazardous materials and hazardous waste handled at the facility. Arrangements to familiarize the Austin Fire Department and emergency response teams with the layout of the facility, properties of hazardous substances handled at the facility and associated hazards, and areas where hazardous materials and wastes are stored at each campus location.

Recordkeeping & Reporting

Hazardous Waste Manifest – Generators are required to keep a copy of each signed manifest for three years from the date the waste was shipped offsite.
Land Ban Documentation – Generators are required to retain on-site a copy of all notices, certifications, waste analysis data including Land Disposal Restrictions for at least three years.
Contingency Plans – CESQGs and SQGs are not required to maintain a written contingency plan.
Annual Waste Summary – Generators must submit an annual waste summary to the TCEQ.

The TCEQ uses this information to calculate a generator’s annual waste generation fee. The EHS Office will compile and complete these reports every year as necessary per regulations.

Notifying EHS to Schedule Pickup

Hazardous wastes are picked up across the ACC District at the end of each semester. EHS works with the hazardous waste vendor to schedule their arrival, the locations for waste pickups, and what additional supplies will be needed to replace full containers taken for disposal.

Complete an ACC Chemical Waste Request for Disposal Form and send it to the EHS Department if you have materials or wastes that need to be removed. Requests can be sent electronically as PDF, faxed to EHS fax number or mailed via intercampus mail. This notification will get you on the schedule of areas/rooms needing waste removal. Pickup request forms can be obtained by emailing a request to the EHS Department.

The EHS Office arranges vendor-performed routine hazardous waste pickups at the end of each semester or more frequently as necessary. Approximately one month prior to each pickup, EHS will contact all hazardous waste generators and request they complete a Chemical Waste Request for Disposal Form, identifying the hazardous wastes each generator has for the upcoming waste shipment.

These requests are then compiled into a master list and provided to the hazardous waste disposal vendor. People requesting hazardous waste pickups shall ensure that their waste containers meet the following requirements:

The containers are not sitting in the corridors or areas where accidental waste release could cause a chemical exposure to personnel.
Ensure containers are identified by chemical name/common name. Chemical formulas are not acceptable.
Ensure containers of liquid and solid waste are in good condition so that handling can be done in a safe manner and that containers do not leak during handling at a later date. Containers must be suitable for the types of chemicals they hold and must be suitable for storage for at least 180 days. Containers must be closed or sealed in such a manner that leakage will not occur. ACC’s hazardous waste disposal vendors will not pickup containers that are open, have improper caps, leaks, outside contamination, or are not properly identified.
All hazardous waste containers are properly segregated and clearly marked regarding the contents, hazards and other pertinent information.
For lab packs send a Lab Pack Waste Request for Disposal form that includes a list of all chemicals and quantities to the EHS & Insurance Office.

Other Regulated Wastes

Dry Solid Materials

Used dry solid materials (paper, rags, towels, gloves, or Kim Wipes, etc.) contaminated with a listed hazardous constituent or with extremely toxic chemicals must be double-bagged in heavy-duty plastic bags and disposed as hazardous waste. DO NOT use red biohazard bags for chemical wastes no matter how toxic. ACC has also opted to treat dry solid materials contaminated with a characteristic hazardous constituent (a wipe in contact with a flammable solvent, such as acetone) as hazardous waste. This is due to the potential for these materials to also have been in contact with a listed hazardous constituent or extremely toxic chemical. The EHS Office permits an alternative to hazardous waste disposal of dirty solvent rags through the use of a commercial laundry service. In this case, the commercial laundry service routinely picks up dirty solvent rags (that are typically stored in red metal flip top cans) for laundering and replaces them with clean rags.

Used Oil, Oil Filters, and Antifreeze

Used oil is defined by EPA as ‘any 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’. In order to meet the criteria of used oil a substance must meet the following:

Origin: Must be derived from crude or synthetic oil,
Use: Must have been used as a lubricant, coolant, noncontact heat-transfer fluid, hydraulic fluid or other similar purpose,
Contamination: Must be contaminated with physical impurities and/or chemical impurities as a result of use.

Used oil should be stored in storage drums or tanks. Label all containers and tanks with the words “Used Oil”. Keep containers and tanks in good condition. Do not allow tanks to rust, leak, or deteriorate. As a good management practice, keep containers and tanks closed unless adding to or removing used oil. Do not mix any hazardous material or waste with used oil.

To be sure that your used oil does not become contaminated with hazardous waste, store it separately from all solvents and chemicals and do not mix it with anything. Used oil contaminated with a listed hazardous waste must be managed and disposed of as a hazardous waste. Non-contaminated used oil does not require an EPA hazardous waste code. ACC sends used oil out for recycling. When a used oil pick up is required, contact EHS and a pick up will be scheduled. Used oil can be accumulated indefinitely provided it is non-contaminated. Please accumulate at least 55 gallons before calling for a pick up.

Used oil filters are also picked up for recycling. Texas law prohibits the dumping of used oil on land, in sewers, and in waterways. Texas has also banned used oil and used oil filters from being placed in or accepted for disposal in a landfill. Currently ACC has two areas, Riverside Campus Automotive and Round Rock Campus Automotive, which generate used oil and used oil filters for vendor recycling.

Used antifreeze removed from vehicles may be a hazardous waste. The EPA or TCEQ have not issued specific regulations for used antifreeze, but general rules for hazardous waste can apply. After antifreeze goes through a radiator it may be contaminated with gasoline, oils and metals (includes lead, mercury, cadmium, chromium, copper and zinc). Metals and benzene (from gasoline) are toxic and may cause the used antifreeze to be a hazardous waste. Antifreeze would also be considered hazardous if it were mixed with a hazardous material such as a degreasing solvent or gasoline. In addition, antifreeze could be hazardous if it comes from an old car where the antifreeze has been sitting for years and has picked up enough metals such as lead to be characterized as hazardous for metals content.

Recycling is ACC’s preferred disposal option for used antifreeze. If ACC’s used antifreeze cannot be recycled, it must be disposed of as hazardous waste. Many sewage treatment agencies responsible for wastewater treatment prohibit waste antifreeze disposal into sanitary sewers. Used antifreeze should never be dumped into a sanitary sewer, storm drain, ditch, dry well or septic system. Waste antifreeze disposed of down storm drains or into surface waters and streams causes serious water quality problems and may harm people, pets and wildlife.

Gas Cylinders

Gas cylinders should be returned to the manufacturer or distributor whenever possible. Non-returnable gas cylinders should be labeled and disposed of as hazardous waste. Gas cylinders should always be stored upright with the safety cap covering the valve. They should also be secured in some manner that prevents them from falling over. Do not remove any identifying tags or labels as that renders the contents unknown. Unknown cylinders being stored at a campus are very dangerous and very costly to dispose of.

Photographic Process Waste

Photographic wastes from web labs likely contain silver and may not be poured into the sinks. It must be treated as hazardous waste. Silver recovery units are available that include a filtration system to remove silver from the solutions. Photographic lab effluent that does not contain silver may be discarded down the sink through the sanitary sewer system.

Unknown Chemical Waste

“Unknown” chemical waste will be handled by EHS. Place a tag or label the container with “unknown” for the chemical waste description. In addition, mark or label the container as ‘hazardous waste’ and date. ACC will manage the waste as hazardous until testing results indicate otherwise. Any area generating an unknown chemical waste will be required to supply a documented corrective action provided by the Dean, Director or unit head of the generating area.

Bio-hazardous Waste

Sharps (needles, razor blades, scalpel blades, syringes, glass Pasteur pipettes, etc.) are classified as biohazardous waste even if they are not contaminated. These items may not be placed in the regular trash. Sharps must be placed in a “puncture resistant” container or plastic/metal container. For additional information on disposal of bio hazardous waste, please refer to the EHS web site Bio-Hazardous Waste Procedure or contact EHS for additional information.

Contractor Generated Wastes

Any hazardous waste that is generated in conjunction with contractor / vendor work performed for ACC falls under the same regulatory requirements as if ACC is the generator. Project managers, project coordinators and purchasing are responsible for clearly delineating in the contract that the contractor is responsible for managing the hazardous waste generated by a project. The contract must clearly state that the vendor assumes responsibility for disposing of hazardous waste generated by a project in adherence to all applicable state and federal regulations. If it is not clearly stated in the contract that the vendor is responsible for hazardous waste disposal, ACC is responsible for proper disposal of any hazardous waste generated from the project being performed for the College. The project manager will be required to follow procedures outlined in this document. ACC still retains ultimate responsibility as generator of the hazardous waste. Refer to Contractor Safety Manual.

Source Reduction

The Pollution Prevention Act of 1990 (Federal Regulation) made the prevention of pollution and reduction of waste generation, a national priority. The Texas Waste Reduction Policy Act requires regulated waste generators to prepare and implement a Pollution Prevention Plan.

Such plans have been developed where necessary and are coordinated by EHS and those departments generating hazardous waste. One key to the Plan is “front-end minimization”. Front-end minimization means reducing hazardous waste by reducing the quantities of hazardous chemicals used and by substituting less hazardous materials. Teaching laboratories and other working groups (Building and Grounds, etc.) that generate hazardous waste should review their purchasing practices and systems, chemical usage patterns, and workplace activities to identify potential points of their operations where source reduction and waste minimization can be implemented.

Prudent Practices and Special Concerns

Minimizing Quantities of Hazardous Waste –Common practice is to order chemicals in larger quantities than necessary to take advantage of reduced costs. As a result, aging reagents or solvents are left over and end up needing disposal. Besides reducing the disposal cost, smaller inventories reduce exposure to personnel and create a safer environment. Storage of unused chemicals for an extended period of time tends to increase the risk of an accident.
Substitution – Substitution of non-hazardous or less hazardous chemicals for a hazardous chemical is a commonly used method of reducing potential hazards and hazardous wastes. Examples include using sustainable cleaning products instead of toxic, flammable organic solvents; “Nochromix” instead of toxic chromic/sulfuric acids; water-based paints instead of oil-based paints; alcohol thermometers instead of mercury thermometers; and non-carcinogenic solvents instead of carcinogenic solvents. Substitution should be utilized when practical.
Surplus Chemical Exchange – The concept of exchanging excess solvents and reagents with other labs or departments needing these materials reduces purchasing and disposal costs. Exchange of materials should be emphasized. EHS must be contacted to arrange for transportation of chemicals.
Unknown Chemicals – Unknowns present a special problem in labs, especially when laboratories change occupants or processes. Labs should be cleaned up and old unneeded chemicals disposed of by the occupant who is terminating the use of the lab. Immediately label all chemicals so that they do not become unknowns. (All chemicals, mixtures and solutions should be clearly labeled at all times.) All unknowns will have to be analyzed by a certified environmental laboratory in order to have constituents or characteristics identified for proper waste classification and disposal treatment. Analysis is often expensive and time consuming but there is no alternate solution to proper identification of unknown hazardous waste or materials. Thus proper container labeling serves the dual purpose of increased safety in the lab and less expensive disposal costs.
Special Laboratory Disposal Methods – The EPA and the TCEQ provide several regulatory exclusions that allow generators to treat hazardous waste without a permit. One on-site treatment method is elementary neutralization. This treatment is used to neutralize corrosive (D002) wastes. For example, small amounts of common inorganic acids (except hydrofluoric and chromic acids) can be diluted and neutralized to a pH between 5 and 10 and disposed of via the sanitary sewer. Inert, non-toxic salts, sugars and buffers can be diluted and disposed via the sanitary sewer. Be sure to contact the EHS & Insurance Office before any treatment or disposal of chemical waste is performed in the laboratory.
Reactive Materials – Reactive wastes include cyanides, sulfides, air and/or water reactives, oxidizers, explosives, and some flammable solids. Special care must be exercised when handling these materials to prevent contact with incompatible materials that could result in an unwanted dangerous reaction. Reactives should be isolated from other hazardous waste. For example, water reactives should be stored in a desiccator. Picric acid should always be saturated with water. Reactive wastes will be stabilized by the hazardous waste vendor if necessary for safe transportation or shipping.
Non-hazardous Waste Disposal – All chemical wastes that do not meet the definition of a RCRA hazardous waste must still be disposed of properly to protect human health and the environment. In most cases, disposal via the sanitary sewer or the trash is not permitted; however, there are exceptions, which will be made by the EHS Office on a case-by-case basis.

Emergency Procedures

Chemical-using personnel and students enrolled in classes where hazardous materials are used or hazardous wastes are generated are required to receive training on the hazards associated with chemicals used and how to respond to emergencies. ACC Hazard Communication Program requires that ACC employees be informed of hazardous materials that they might use or be exposed to at work. In addition, the program includes training on handling spills and other emergencies. Safety Data Sheets (SDSs) are a source of this information and should be maintained for all chemicals used or stored within a workplace. Special cleanup supplies for chemical spills should be available and employees should be trained on how to use them.

The EHS office can provide additional information on handling specific chemical spills. Hazardous waste disposal procedures should be followed for disposal of contaminated clothing, rags, absorbent materials or other waste generated from clean up of spills or leaks. All chemical-using areas should post emergency numbers near telephones. All chemical users should know emergency numbers and follow EHS procedures for chemical spills that may occur in their work area(s).Refer to ACC Hazardous Material Spill Procedure

ACC Hazardous Materials Spill Procedures

Section I: Major Spill Procedures

Major spills will include hazardous material spills:

over 1 liter, and/or
have chemicals that have a hazard rating of 3 or above , and/or
spills of an unknown chemical.

Procedures:

Evacuate the immediate area, close doors to the area and restrict access.
Contact Austin Community College Police Department at 512 223-7999 to report the spill. Provide information on :
- the identity of the chemical spilled,
- quantity spilled,
- exact location and
- Information on hazard ratings (look for NFPA / HMIS labels on containers or MSDS).
- Report any injuries or chemical exposure
Campus Police will immediately contact the EHS Office at 512-223-1015.
EHS staff will make assessment and contact appropriate Fire Department for HazMat Response if spill is of nature that would require their response.
Obtain an SDS and provide a copy to the responding party and the EHS Office. If you have appropriate spill cleanup training, initiate recommended containment and other procedures that can be safely and reasonable accomplished per your level of emergency spill response training.
If EHS determines the hazardous material can be cleaned up by ACC personnel, Environmental Health Safety and Insurance Office will provide guidance on all aspects of clean up including personal protective equipment and proper disposal of all associated waste.

Section 2: Minor Spills Procedures

Minor spills will include hazardous material spills:

Less than one liter, and
Has a hazard rating below 3 in all hazard categories

Procedures

Instructional labs / work areas that contain any type of chemical should have a chemical spill kit available to deal with small spills of any chemicals used in that area. It is the laboratory supervisors’ responsibility to handle small-scale chemical spills in their lab. A small-scale spill of a known material is generally considered to be one liter or less and have a hazard rating of less than 3 in all categories.

When a small scale chemical spill occurs:

DURING BUSINESS HOURS: immediately contact the EHS Department, 512- 223-1015. Notify them that a minor spill has occurred. Provide following information:

Name of chemical
Quantity spilled
Location of spill

Immediately notify the lab supervisor and others in the area of the spill.
Restrict access to area. It may be necessary to evacuate the lab until the material is effectively cleaned up.
Obtain a Safety Data Sheet for the material. Refer to the SDS for spill cleanup instructions. It is required that a SDS be kept available for each chemical used in the lab for this purpose. Section 6 will address spill cleanup procedures, while section 8 will indicate exposure controls and necessary personnel protective equipment (PPE) for dealing with a the spill.

AFTER BUSINESS HOURS: Immediately notify ACC Police Department Dispatch at 512-223-7999. They will then notify Environmental Health and Safety. General Spill Cleanup Procedures:

Simple acid and caustic spills – should be neutralized with an appropriate neutralizing agent.

For ACID spills (hydrochloric or sulfuric acid): use sodium bicarbonate, sodium sesqicarbonate or other products specific for acid spill neutralization.
For CAUSTIC spills (sodium or potassium hydroxide): citric acid would be a suitable neutralizing agent.
Add neutralize to spill and allow time to work (i.e., wait until the bubbling reaction stops.)
When using a neutralizing spill kit, these kits are buffered and will not have a bubbling action.
Test the pH of the spill after the neutralization reaction has stopped with pH paper. Once a pH of between 6 and 9 has been achieved, the material can be transferred into an appropriate secondary container for disposal.
Mark any containers with cleanup materials as “Hazardous Waste” and with label identifying what material was cleaned up.
Contact the EHS Office for assistance with labeling and for chemical waste pick up.

Note: Some acids will require special procedures for spill cleanup. Some examples are chromic acid and hydrofluoric acid. Immediately contact the EHS Office when a spill of this type occurs.

Solvent Spills: (benzene, methylene chloride, xylene, etc):

Sprinkle absorbent medium such as sand or vermiculite to absorb the spill and prevent spread.
Sweep up and transfer the spilled material into an appropriate secondary container.
Mark the container with the “Hazardous Waste” label and contact the EHS Office.

Solids:

Most solid chemical spills can be swept up and transferred directly to a secondary container after the spill occurs.
Mark the container with a “Hazardous Waste” label and contact the EHS Office.

Mercury Spills:

Mercury spills require special clean up procedures
Use the commercial Mercury Spill Kit. Instructions for cleanup are located on the Mercury Spill Kit container.
For broken mercury thermometers, clean up spilled mercury and place with the broken thermometer glass in a sealable plastic bag for disposal. Contact EHS Office.
For mercury spills greater than 1 thermometer, contact EHS or Campus Police Dispatch.

Bio-hazard Spills:

Bio-hazardous spills have the potential of containing disease carrying organisms which can infect persons exposed to the spilled material; therefore it is critically important to handle biohazard spills appropriately when they happen.
Spills involving bodily fluids (i.e., blood, plasma, saliva, biological cultures, etc.) should immediately be decontaminated with a 10% bleach solution or other CDC approved commercial disinfectant approved to kill pathogenic disease causing organisms including HIV and Hepatitis viruses.

Whenever possible, have person generating fluids (their own) clean up any spill of bodily fluids. Appropriate personal protective equipment should be worn during any biohazard spill cleanup including: splash goggles, rubber or nitrile gloves and yellow Tyvek, rubber apron or lab coat to protect the responder from self-contamination.

Apply the disinfectant to the spilled material and solution stand for 15 minutes to allow the disinfectant to work. Once the material has had time to be totally disinfected, use an absorbent medium to soak up liquids. All the materials should then be swept up and placed into an approved red biohazard waste bag with the international biohazard symbol.

All bio-hazardous waste not containing a cut/puncture hazard is considered regular biohazardous wastes. This would include any type of blood or serum products, tissues, absorbent papers with biological contamination etc. These materials should be wrapped securely and then placed in an approved biohazard bag. This bag is then placed into cardboard boxes. Contact EHS Office if you need biohazard boxes or the outer cardboard containers. Contact Environmental Health Safety and Insurance Office with any questions on clean up or bio-waste labeling/disposal.

Appendix A: Definitions

Accumulation Start Date – The date when a hazardous waste is first placed into a container. This is the date from which a Small Quantity Generator has 180 days to dispose of the waste.

Acutely Hazardous Waste – These are wastes that the EPA has determined to possess extremely hazardous properties that make them lethal in very small quantities. These include all “P” listed wastes found in the federal regulations (40 CFR Part 261.33(e)).

Characteristic Hazardous Waste – Waste that exhibit one or more of the four characteristics referenced in the federal regulations (40 CFR Part 261 Subpart C); Ignitability, Corrosivity, Reactivity, Toxicity.

Disposal – The discharge, deposit, injection, dumping, spilling, or placing of any solid waste or hazardous waste (whether containerized or non-containerized) into or on any land or water so that such solid waste or any constituent thereof may enter the environment or be emitted into the air or discharged into any water, including ground waters.

EPA Identification Number – The number assigned by the Environmental Protection Agency to each generator, transporter, and processing, storage or disposal facility..

Facility – Includes all contiguous land, and structures, other appurtenances, and improvements on the land used for storing, processing, or disposing of municipal hazardous waste or industrial solid waste.

Generator – Any person, by site, who produces municipal hazardous waste or industrial solid waste; any person who possesses municipal hazardous waste or industrial solid waste to be shipped to any other person; or any person whose act first causes the solid waste to become subject to hazardous waste regulations. Person refers to an individual, trust, firm, corporation, Federal Agency, State, political subdivision of a State, municipality, or any interstate body.

Hazardous Material – A substance or material, including a hazardous substance, which has been determined by the Secretary of Transportation to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and which has been so designated.

Hazardous Waste – Any solid waste listed or identified in Title 40 Code of Federal Regulations, Part 261, Subpart C and D or exhibiting the characteristics of ignitability, corrosivity, reactivity, toxicity or specifically listed in Part 261.

Lab Pack – Method of shipping and treating unused, obsolete or spent chemicals, determining the optimum disposal process. Qualified personnel pack these materials in compliance with EPA and DOT regulations. The DOT mandates that waste materials be segregated. packaged, labeled and shipped according to its regulations.

Listed Hazardous Waste – Includes wastes from non-specific and specific industries and commercial chemical products that become hazardous wastes when discarded. Listed wastes have a chemical specific or generic mixture identification number assigned by the EPA. For example; Phenol is U188, a certain chlorinated solvent mixture might be F002 depending of the mixture. Listed waste consists of four lists defined by the EPA, the K-list, F-list, U-list and P-list.

Manifest – A legal shipping document containing required information which must accompany shipments of Municipal Hazardous Waste or Texas Class I-Industrial Solid Waste transported on public roads or thoroughfares.

Mixed Waste – A radioactive waste that is mixed with a hazardous waste.

Person – Any individual, corporation, organization, government or governmental subdivision or agency, business trusts, partnership, association or any legal entity.

Processing – The extraction of materials, transfer, volume reduction, conversion to energy, or other separation and preparation of solid waste for reuse or disposal, including the treatment or neutralization of hazardous waste, designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste, or as to recover energy or material from the waste or so as to render such waste non-hazardous or less hazardous; safer to transport, store, and dispose; or amenable for recovery, amenable for storage, or reduced in volume.

Recyclable Materials – Wastes that are recycled. Recycled material is used, reused, or reclaimed.

Reclaimed material – Is processed or regenerated to recover a usable product. Examples: Recovery of lead from spent batteries, or regeneration of spent solvent.

Satellite Accumulation Area – An area, system, or structure used for temporary accumulation of hazardous waste prior to transport to the central accumulation area.

Solid Waste – Any garbage, refuse, sludge from a waste treatment plant, water treatment plant, or air pollution control facility or other discarded material, including solid, liquid, semi-solid, or contained gaseous material resulting from industrial, municipal, commercial, mining and agricultural operations, and from community and institutional activities.

Storage – The holding of solid waste for a temporary period, at the end of which the waste is processed, disposed of, recycled, or stored elsewhere.

Texas Solid Waste Number – The number assigned by the TCEQ to each generator, transporter, and processing, storage, or disposal facility.

TCEQ – The Texas Commission on Environmental Quality is the governing agency responsible for administering Federal EPA regulations in Texas: regulates hazardous and industrial solid waste generation, storage, transportation, treatment and disposal; and regulates the cleanup of inactive and abandoned hazardous waste sites.

Transporter – Any person who conveys or transports municipal hazardous waste or industrial solid waste by truck, ship, pipeline or other means.

Universal Waste – Any hazardous waste subject to 40 CFR Part 273 and 30 TAC 335.261 to include:

Batteries including lead-acid as described in 40 CFR 273.2;
Pesticides as described in 40 CFR 273.3;
Mercury Thermostats as described in 40 CFR 273.4;
Lamps as described in 40 CFR 273.5; and
Paint and paint related waste as described in 30 TAC 335.262(b).

Used Oil – Used oil is any petroleum-based or synthetic oil that has been used

Waste – Any material for which there is no use and is to be discarded as valueless.

Appendix B: Identification of Hazardous Waste

CLASSIFICATION OF SOLID WASTES: HAZARDOUS vs. NON-HAZARDOUS

Personnel classifying waste streams must be RCRA certified through appropriate and current RCRA training as specified in 40CFR Parts 260-279. All RCRA training must be approved through the Director of EHS. A solid waste is if it meets the regulatory definition of “hazardous waste”. “Hazardous waste” is any waste that is defined as being hazardous in 40 CFR Section 261.3 and 30 TAC Chapter 335, rule 335.504. A material is “hazardous waste” if it meets one or more of the following:

1. It is a chemical listed 40 CFR Part 261.31, Part 261.32, or Part 261.33(e) and (f). By definition, EPA designated these wastes as hazardous. These wastes are incorporated into lists published by the Agency. These lists are organized into four categories:

The F-list (non-specific source solvents). This list identifies wastes from common manufacturing and industrial processes, such as spent solvents that have been used in cleaning or degreasing operations. Because the processes producing these wastes can occur in different sectors of industry, the F-listed wastes are known as wastes from non-specific sources. Wastes included on the F-list can be found in the regulations at 40 CFR §261.31

The K-list (source-specific wastes). This list includes certain wastes from specific industries, such as petroleum refining or pesticide manufacturing. Certain sludges and wastewaters from treatment and production processes in these industries are examples of source-specific wastes. Wastes included on the K-list can be found in the 4 regulations at 40 CFR §261.32.

The P-list and the U-list (discarded commercial chemical products). These lists include specific commercial chemical products in an unused form. Some pesticides and some pharmaceutical products become hazardous waste when discarded. Wastes included on the P- and U-lists can be found in the regulations at 40 CFR §261.33.

2. It is a mixture or solution containing a listed chemical and a non-hazardous material.

3. Waste that does not meet any of the listings explained above may still be considered a hazardous waste if exhibits one of the four characteristics defined in 40 CFR Part 261 Subpart C — ignitability (D001), corrosivity (D002), reactivity (D003), and toxicity (D004 – D043). The waste is ‘characteristically hazardous’ in that it meets the definition of one of the following for Characteristic Waste:

a) Ignitability – Ignitable wastes can create fires under certain conditions, are spontaneously combustible, or have a flash point less than 60 °C (140 °F). Examples include waste oils and used solvents. For more details, see 40 CFR §261.21. The test methods used to determine ignitability include the Pensky-Martens Closed-Cup Method for Determining Ignitability (Method 1010a) or the Setaflash Closed-Cup Method for Determining Ignitability (Method 1020b), and the Ignitability of Solids (Method 1030)

b). Corrosivity – Corrosive wastes are liquid acids or bases (pH less than or equal to 2, or greater than or equal to 12.5) that are capable of corroding metal containers, such as storage tanks, drums, and barrels at a rate greater than ¼ inch per year. Battery acid is an example. For more details, see 40 CFR §261.22. The test method that may be used to determine corrosivity is the Corrosivity Towards Steel (Method 1110a)

c). Reactivity – Reactive wastes are unstable under “normal” conditions. They can cause explosions, toxic fumes, gases, or vapors when heated, compressed, or mixed with water or other chemicals. Examples include hydrogen cyanide and explosives. For more details, see 40 CFR §261.23. There are currently no test methods available.

d). Toxicity – Toxic wastes are harmful or fatal when ingested or absorbed (e.g., containing mercury, lead, etc.). When toxic wastes are disposed on the land (i.e., landfills) contaminated liquid may leach from the waste and pollute ground water. Toxicity is defined through a laboratory procedure called the Toxicity Characteristic Leaching Procedure (TCLP) (Method 1311). The TCLP test helps identify wastes likely to leach concentrations of contaminants that may be harmful to human health or the environment. For more details, see 40 CFR §261.24.

Appendix C: ACC Chemical Waste for Disposal form

Chemical Waste for Disposal Form