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Hazardous Waste Management

Introduction

Hazardous waste may be generated from laboratory operations, facilities operations and maintenance, construction and renovation activities, photo processing, and a variety of other activities at the University. Hazardous waste is a particular class of "solid" waste (which includes solid, liquid, or gaseous material) which, if improperly managed, poses a substantial threat or potential hazard to human health and the environment. Typical hazardous wastes generated at the University of Maryland include, but are not limited to, spent solvents, waste laboratory chemicals, waste paints and waste oil.

Hazardous waste is subject to a complex regulatory scheme to ensure that uniform and consistent waste identification, storage and disposal procedures are followed by persons trained in the proper management of these waste substances. In a responsibility that cannot be reassigned to others, the Environmental Protection Agency (EPA) assigns the generator of hazardous waste "cradle to grave" responsibility for the proper management of these substances after the point of generation. This strict liability scheme creates a powerful incentive for regulatory compliance, including waste minimization. In Maryland, the Maryland Department of the Environment (MDE) is the agency responsible for the implementation and enforcement of hazardous waste regulations.

The Department of Environmental Safety (DES) is responsible for assisting University personnel with hazardous waste management procedures including waste identification, storage, packaging, manifesting, shipping, disposal, reporting, records keeping and personnel training. This Fact Sheet provides University personnel involved in the generation of hazardous waste with an overview of regulatory requirements for the management of these wastes.

Applicable University Policy

• University of Maryland Environmental, Safety and Health Management Policy
• Environmental Services Facility/Auxiliary Storage Facility Contingency Plan
• The University of Maryland Emergency Management Plan
• Hazardous and Regulated Waste Procedures Manual, 2001.

Applicable Regulation

• 40 CFR 260 - Hazardous Waste Management System: General
• COMAR 26.13- Disposal of Controlled Hazardous Substances

Summary of Requirements

The scope and complexity of regulatory requirements which generators are subject to, is directly related to a generator's "status". A generator's status is based on the quantity of hazardous waste generated per site on a monthly basis. MDE has established specific hazardous waste regulations for large quantity generators (LQG), and small quantity generators (SQG). MDE has assigned a separate status for the generation of waste oil. The following summary of requirements provides a general overview of regulatory requirements applicable to most generators of hazardous waste. Contact DES for additional guidance.

1. Waste Identification: Hazardous waste includes substances that are solids, liquids and gases. The EPA definition of hazardous waste includes substances that possess a hazardous characteristic (e.g. toxic, ignitable, corrosive or reactive with other substances), or substances that are listed as hazardous waste by the EPA on the basis of their usage or chemical constituents. The MDE regulations include specific methodology for the identification of hazardous waste.
2. Labeling: Containers which store hazardous waste must be properly and clearly labeled. Labels (available through Chemistry Stores) must include: 1) the words "Hazardous Waste"; 2) the container contents in words (e.g., "Waste Oil"); 3) the hazards associated with the waste in words (e.g., "Toxic"); and 4) the accumulation start date. The accumulation start date must be written on the label of each waste container when the maximum of 55 gallons of hazardous waste or one quart of acutely hazardous waste has been reached.
3. Accumulation and Storage: Hazardous waste regulations established a two- tiered waste accumulation and storage system: satellite accumulation and main accumulation.

Satellite Accumulation: Hazardous waste accumulation and storage which is at the point of generation and under the control of the person generating the waste is called satellite accumulation. Regulations allow a maximum of 55 gallons of hazardous waste or 1 quart of acutely hazardous waste at each satellite accumulation area. Satellite accumulation containers must be closed unless waste is being added or removed from the container. Once a satellite accumulation container becomes filled, full containers of hazardous waste may be stored at the point of generation for a maximum of 3 days before being transferred to a designated, main accumulation area having certain design and monitoring requirements. Hazardous waste should be stored in leakproof tubs or another type of containment device within satellite storage areas. All containers must be kept closed unless adding or removing waste material.

Main Accumulation: Main accumulation and storage of hazardous waste is subject to strict time limitations. Large quantity generators of hazardous waste are allowed to store hazardous waste on-site for a maximum of 90 days, however, the University's main storage area, Building #344, may exceed this time limit since a site specific hazardous waste storage permit was obtained from MDE.

4. Manifesting: Hazardous waste must be shipped with a special shipping paper called a hazardous waste manifest. Each location has a unique EPA Generator ID number that must appear on the manifest.
   
   

   For the University of Maryland, DES is responsible for shipping and managing all hazardous waste manifests.

5. Transportation and Disposal: Hazardous waste may be transported only by a licensed hazardous waste transporter and may be sent only to a licensed treatment, storage and disposal facility.



6. Emergency Preparedness and Prevention: In accordance with regulatory requirements, the University maintains a Hazardous Waste Management Contingency Plan. This Plan is designed to prevent and to minimize hazards to the public or to the environment from fires, explosions, spills or other unplanned releases of hazardous waste. Hazardous waste regulations also require generators to comply with emergency preparedness and prevention requirements. These requirements include a testing and maintenance program for various emergency equipment (e.g., fire and spill equipment, emergency alarms and communication systems). The University is also required to make arrangements with local emergency agencies such as the fire department, police department, spill response contractors and State and local emergency planning committees. All laboratories are required to have a Chemical Spill Kit to respond to small, incidental spills. Chemical Spill Kits are available through Chemistry Stores.



7. Waste Minimization: Generators of hazardous waste are required by the EPA to minimize the volume and toxicity of the hazardous waste they generate. The elements of a hazardous waste minimization plan may be found in the University's Hazardous and Regulated Waste Procedures Manual and the DES Fact Sheet entitled Hazardous Waste Minimization.



8. Recycling: Hazardous waste recycling activities require a permit. Contact DES for assistance with permitting requirements if you intend to conduct hazardous waste recycling.

Required Training

Persons involved in the management of hazardous waste must complete a training program which teaches them how to perform their duties in compliance with applicable hazardous waste regulations. Persons must be trained within 6 months of hire and annually thereafter. Generators are required to maintain a written program which describes training program contents, who is trained and why, and recordkeeping procedures. DES provides an online hazardous waste training program which may be accessed at http://www.des.umd.edu.

Reporting

The following outlines typical reporting requirements for generators of hazardous waste:

• Generators are required to submit a biennial hazardous waste report which summarizes hazardous waste generation and management activity for the previous year.
• Hazardous waste manifests generally must be submitted immediately to MDE.
• Any change in generation status or types of hazardous waste generated requires prompt notification to MDE.

These reporting requirements are fulfilled by DES.

Inspections

Regulations require that hazardous waste areas (main accumulation areas) be inspected on a weekly basis. Satellite accumulation areas (e.g., laboratories) should also be inspected weekly.

Recordkeeping

Hazardous waste regulations require that the following records be maintained for a minimum of 3 years:

• waste analysis/determination records;
• manifests;
• biennial reports; and
• exception reports.

Land disposal restriction (LDR) notifications/certifications, which typically accompany hazardous waste manifests, are required to be maintained for a minimum of 5 years. Manifest and LDR notifications/certifications copies are maintained by DES for retention and compilation into an EPA-required biennial report of University waste activities. Exception reports are required to be filed with MDE if and when certain copies of hazardous waste manifests are not received by specified time limits.

University Resources

Written 5/98
Revised 4/05

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