Hazardous Waste Management Training

Purpose of the Program
What a Hazardous Waste Is
Where Hazardous Wastes Are Generated at CCRI and What Kinds Are Generated
Where Hazardous Wastes Are Stored
How Hazardous Wastes Are Labeled
How Long Hazardous Wastes Can Be Stored
Response to a Spill or other Incident Involving Hazardous Wastes
Cleanup of Minor Spills by College Personnel if Permitted by Law
Emergency Response
Removal of Hazardous Waste From College Premises

Purpose of the Program

This program is intended to provide training required by the United States EPA (Environmental Protection Agency) for faculty, paraprofessionals and other CCRI employees whose duties involve the generation, handling, storage, transport, management or disposal of hazardous waste within the College. Any questions about hazardous waste handling should be referred to Rick Foote, Outsourcing Program Coordinator for Triumvirate Environmental at ccri.rfoote@ccri.edu or Chris Swartzel TE'e field chemist at ccri.cswarzel@ccri.edu. The information and training provided to individuals on the safe and legal management of hazardous waste will do the following:

Protect College employees and students from harm due to exposure to hazardous substances.
Protect the College environment and the environment at large.
Protect College property.
Protect the College from cleanup expenses resulting from accidental release of hazardous waste.
Protect the College from legal action from local authorities, the EPA and the Rhode Island DEM (Department of Environmental Management) stemming from the incorrect handling or discharge of hazardous waste.
Enable College courses, programs and maintenance activities that generate hazardous waste to continue to operate without exposing the College to the risk of civil and criminal penalties.

What a Hazardous Waste Is

A hazardous waste is a solid, liquid or solid material identified in 40 CFR 261 that is a "Characteristic Waste" with one or more of the following descriptions:

Ignitable ( a liquid with a flashpoint less than 141oF, a spontaneously combustible solid, an ignitable compressed gas or an oxidizer), or;
Corrosive (an aqueous solution with a pH below 2.0 or above 12.5) a liquid which corrodes steel at a rate of 0.25 inches per year, or;
Reactive (an unstable material, reacts with water, explosive, generates toxic gas or a cyanide or sulfide bearing waste), or;
Toxic (RCRA metals such as chromium, lead, silver, mercury, cadmium; or pesticides, organic solvents, chlorinated solvents); and
Is discarded, has served its intended use or is a manufacturing by-product, and;
That is not domestic sewage, a household waste or a sample collected for testing.

Where Hazardous Wastes Are Generated at CCRI and What Kinds Are Generated

Hazardous wastes are generated in the following areas, among others and may include:

Chemistry Laboratories (heavy metal solutions, organic residues and organic solvents).
Other Science Laboratories (mercury waste, dead batteries, used test reagents).
Dental Materials Laboratory (waste amalgam, waste impression material).
Ceramics Studios (glazes containing heavy metal pigments).
Other Art Studios such as Painting and Crafts (unneeded paints, paint thinners and pigments).
Photography Darkrooms (silver in used developer, fixer and fixer remover solutions).
Vehicle Maintenance Garages (used antifreeze, lubricants, sprays, crankcase oil).
Other Maintenance and Operations Activities (dead batteries, oil-base and aerosol paints,).
Janitorial Activities (unused cleaners, discarded chemicals).
Electrical Maintenance (burned-out fluorescent and mercury vapor lights, lighting ballasts).
Food Preparation Areas (cleaning supplies, oils).
Swimming Pool Maintenance (unused chlorinating and pH adjusting chemicals).
Computer Labs (obsolete computer equipment containing lead and other toxic substances).

Where Hazardous Wastes Are Stored

Hazardous waste is stored in two types of locations: in Satellite Accumulation Areas and in Main Hazardous Waste Storage Areas.

In Satellite Accumulation Areas, wastes are collected in a bulk container, typically a 30-gallon plastic drum or a five-gallon screw-top plastic pail, and stored at the point of generation until the collection container is full. Examples of wastes collected this way are photo developing solutions, organic residues and solvents and laboratory heavy metal solutions. Up to 55 gallons of hazardous waste or one quart of acutely hazardous waste may be accumulated for any length of time until the container is full. The area must be clearly marked, Satellite Accumulation Area and secured or separated from the normal laboratory or work area. Collection containers must always be securely closed except during the act of filling. It is the responsibility of the person whose activity generates the waste or the of the appropriate laboratory paraprofessional to have the container moved to the Main Hazardous Waste Storage Area within three days of filling a container by calling the office of the Physical Plant Director for transport assistance. Small, accurately labeled containers of unused chemicals may be taken directly to the Main Hazardous Waste Storage Area by the person originally responsible for the container and placed in a secondary containment vessel away from incompatible materials. If a person wishing to dispose of a surplus hazardous substance as waste does not have training and access to a Main Hazardous Waste Storage Area, he or she may ask a trained person, such as a chemistry paraprofessional for assistance or access. The EPA's Office of Solid Waste has published an article entitled "Frequently Asked Satellite Accumulation Area Questions available at http://www.epa.gov/osw/specials/labwaste/memo-saa.htm.

Main Accumulation (Hazardous Waste Storage) Areas at CCRI are: Flanagan Campus Room 3020, Knight Campus Room 0138, Liston Campus room 1300 and Newport Campus Room 001. Main Accumulation Areas are secure, restricted-access, locked rooms, with an impervious concrete floor and a berm to prevent escape of spilled waste. These are the locations where hazardous wastes are stored, separate from other materials, prior to removal by a licensed hazardous waste handler. Bulk collection containers are stored on the floor. Smaller, labeled containers are segregated according to compatibility on designated shelves inside secondary containers such as chemical resistant plastic trays. The Main Accumulation Areas have a Hazardous Waste sign posted on their doors and are equipped with an automatic fire suppression system, emergency cleanup equipment and two-way communication with the Department of Security Department and College Police. Each Main Accumulation Area must be inspected at least weekly by the Chemical Safety Coordinator, a laboratory paraprofessional or other trained, qualified person for leaks, proper segregation of chemicals and proper labeling. A log sheet is provided in each Main Hazardous Waste Storage Area to keep a record of these weekly inspections as required by the EPA. Bulk collection containers must have an EPA-approved label on the side, filled out as described below.

How Hazardous Wastes Are Labeled

Bulk collection containers must have a Hazardous Waste Label affixed to the side. An example of a Hazardous Waste Label is appended at the end of this document. Before any waste is put into a bulk waste container, the following information must be entered on the label in the appropriate spaces.

The full name of the College and the full address of the campus housing the waste.

The EPA ID Number for the campus. EPA identification numbers for the four CCRI campuses are:

Flanagan Campus, Lincoln, RI; EPA ID # RID040094328.
Liston Campus; Providence, RI; EPA ID # RID987475050.
Knight Campus, Warwick, RI; EPA ID # RID075709345.
Newport County Campus, Newport, RI; EPA ID # RIR000504407.

The EPA hazard name(s): Ignitable, Corrosive, Reactive or Toxic (one or more as needed)

A full description of the waste with all its components listed, using names, of substances, not chemical symbols.

Small, nonbulk containers of unused or unneeded chemicals may be identified only with their original labels as long as the label contains the complete name of the chemical, not just its formula. Containers of commercial products such as cleaning solutions and oils should be accompanied by the original product label and an MSDS.

(Burned-out fluorescent lights and mercury vapor lights are classified as Universal Waste by CCRI. Their disposal is described in CCRI's Universal Waste Plan.

How Long Hazardous Wastes Can Be Stored

According to Rhode Island law, all hazardous waste generators in the state, including CCRI, are classified as Large Quantity Generators. Bulk wastes collected in drums not to exceed 55 gallons capacity may be stored in a Main Hazardous Waste Storage Area no longer than 90 days from the time the container is filled. The Chemical Safety Coordinator schedules regular removal of wastes to conform to this storage time restriction.

Response to a Spill or other Incident Involving Hazardous Wastes

Due to the limited types of chemicals and wastes stored at this College, determining the source and nature of a spill is relatively simple. Ample area is provided within the storage rooms so that each drum, can or bottle can be visually inspected and any leaking container easily identified. All chemical and waste containers are properly labeled and easily identified by sight so the Chemical Safety Coordinator or other trained person can assess the source, amount, and extent of a released material by visual inspection. Precautions such as inventory reduction and use of secondary containers have been taken to minimize the potential for a spill. If a spill occurs, the first person on the scene should immediately contact the Department of Security and Safety and College Police for the campus at 333-7035 (FC), 825-2109 (KC), 455-6050 (LC) or 851-1621 (NC) and the Chemical Safety Coordinator at 333-7140. The Chemical Safety Coordinator or other qualified person will inspect the spill area and assesses the quantity spilled, determine the identity of the spilled material, and assess the potential for migration of the spill.

Cleanup of Minor Spills by College Personnel if Permitted by Law

For very small, minor leaks or spills, or spills of nonhazardous substances, each Main Hazardous Waste Storage Area is equipped with the following tools, engineering controls, emergency cleanup materials and personal protective equipment:

Spill Pillows for soaking up minor sills of solvents, oils, acids and bases.
Pails of loose absorbent material for soaking up spills of solvents, oils, acids and bases;
Pails of granular sodium carbonate for absorbing and neutralizing spilled acids.
Shovels and scoops for dispensing absorbent materials and sodium carbonate.
Empty pails and drums for containing absorbent material used to soak up spills.
Vinyl, latex and neoprene gloves.
Eye wash station.
Automatic exhaust ventilation
First aid kit
Chemical splash goggles.
Automatic carbon dioxide fire suppression system.

It is expected that the vast majority of spills at the College will be minor. If the spill is determined by someone trained in hazardous waste management to be minor (such as a small leak or small spill) and not a threat to the life, health or well-being of any individual, and does not produce any toxic or irritating vapors, then the following cleanup procedure may be carried out: If there is any doubt as to the severity of the incident, then notify the Chemical Safety Coordinator or the Department of Security and Safety and Campus Police.

The contaminated area is roped off or otherwise protected from unauthorized entry.
Absorbent is spread around the leaking container in sufficient quantity to absorb and contain the leaking material.
The spent absorbent medium is placed with scoops into a DOT-approved open head steel or plastic drum, whichever is appropriate for containing the spilled material. The drum must have a HAZARDOUS WASTE label on its side with the college name, campus address, campus EPA identification number, date the barrel was filled, and a complete chemical description of the waste inside. The barrel must be stored in a Main Hazardous Waste Storage Area prior to off-site disposal by a licensed hazardous waste handler.
Contaminated surfaces are cleaned with a non-toxic solvent or water-soluble cleaner and the contaminated cleaning supplies placed in the barrel with the bulk of the absorbed spill.

Emergency Response

Should an acute emergency situation arise, the College is prepared to react quickly and in a manner that will protect the safety of all employees and students, the safety of all emergency response personnel, and will mitigate potential adverse effects on the environment as outlined in Part IV of CCRI’s General contingency Plan, p 47, Fires-Policies and Procedures.

For all but minor spills, CCRI employees are forbidden by law to attempt cleanup operations. Anyone detecting or suspecting a large spill or other potentially serious incident must notify the Department of Security and Safety and College Police for the campus at 825-2109 (Warwick), 333-7035 (Lincoln), 455-6050 (Providence) or 851-1620 (Newport) and the Chemical Safety Coordinator at 401-333-7140. The Department of Security and Safety and Campus Police will determine if there is a need to notify the local fire department or evacuate the building. For any significant spill or incident, the College is also obligated by law to contact the Rhode Island Department of Environmental Management at 401-222-1360 during business hours or at 401-222-3070 after hours. One of the five cleanup contractors listed below will be called in by the Chemical Safety Coordinator or by the Department of Security and Safety and Campus Police to mitigate the spill.

Triumvirate Environmental
61 Inner Belt Road
Somerville, MA 02143
Tel: 800-966-9282

Fleet Environmental Services
100 Water Street
East Providence, RI 02914
Tel: 888-233-5338

Clean Harbors Environmental Services
1 Terminal Road
Providence, RI 02905
Tel: 800-641-0007

CYN Environmental Services
7 Morgan Mill Road
Johnston, RI 02919
Tel: 888-827-7455

ATC Lincoln Associates
333 Washington Highway
Smithfield, RI 02917
Tel: 800-659-3353 or 401-232-3353

For cleanup of spilled or released biohazardous material, the master Price Agreement lists the following contractor:

Clean Harbors Environmental Services
Terminal Road
Providence, RI 02905
Tel: 401-461-1300

Removal of Hazardous Waste From College Premises

Hazardous waste and unneeded excess chemicals may only be removed from College premises by a licensed vendor. The Chemical Safety Coordinator makes arrangements for pickup and disposal at regular intervals before the material exceeds the legal storage time. The Rhode Island Division of Purchases chooses the hazardous waste removal vendor and verifies the vendor's credentials and qualifications. The Chemical Safety Coordinator announces removal dates in advance in the Crier and by memos sent to all departments with the potential to generate hazardous waste. Original copies of hazardous waste manifests are on file in the College Police offices at each campus. Photocopies of all hazardous waste records are kept in the office of the Safety Coordinator.