University of Louisville
OP-21: Hazardous Waste Management

UofL's Department of Environmental Health & Services (DEHS) promotes (via its website and through on-site training to University maintenance, support, research and clinical personnel) that the best method for chemical waste minimization in laboratories and clinical areas is for each lab, clinic or work area to keep an up-to-date chemical or product inventory control. Product substitution with a non-toxic or less hazardous chemical is also encouraged. Chemical purchases are often reduced by borrowing and sharing chemicals between laboratories. Departments are encouraged to exchange chemicals whenever possible. The DEHS chemical redistribution program allows lab personnel to identify chemicals that are only partially used and have not exceeded their shelf life or been altered in any way. Some chemicals may be unused and still in the original sealed container. In some cases, these chemicals can be used by someone else at the University. Reusable chemicals collected by DEHS are brought to the central accumulation area, recorded, segregated, and held for redistribution instead of disposal. Each chemical may be reviewed prior to acceptance. The person who receives the chemical is responsible to determine the suitability of the chemical for their use. In May 2010, DEHS initiated a pilot mercury thermometer exchange program in which UofL employees were encouraged to exchange mercury thermometers for free less-toxic replacements. DEHS ensured that the mercury thermometers were then disposed of properly and the mercury was recycled. The US EPA has identified mercury as one of their waste minimization priority chemicals, making the reduction of mercury a priority.

DEHS has developed a Disposal Guide, available on line at https://louisville.edu/dehs/waste/Guide/toc.html to provide assistance to University personnel in the proper handling and disposal of waste chemicals, or chemical products in the laboratory. Although the guide was specifically written to outline procedures for chemical wastes, it also contains valuable information on many other types of wastes (i.e., radioactive, infectious, asbestos, PCBs, gas cylinders, empty containers, controlled drugs, and waste oils). Hazardous Waste Training is required of any and all University personnel who may come into contact with or handle hazardous waste in the laboratory setting. This training is required within the first 90-days of employment and should be refreshed every three years. All labs where hazardous wastes are generated and managed at the University of Louisville are considered satellite accumulation areas. This is a regulatory designation which allows generators in these areas to operate under the minimum of regulatory oversight. As such, the following five points are all that generators need to know to operate in compliance with the law. It is critical that generators know and understand these points and that they manage their waste in accordance with them: • The container holding the hazardous waste MUST BE marked with the words "Hazardous Waste". No variation of these words is permissible. • The container holding the hazardous waste must be in good condition. This means no cracks, no rust, and no leaks. • The container holding the hazardous waste must be compatible with the waste and any waste mixtures in that container must also be compatible. • The container holding the hazardous waste must be closed at ALL TIMES. The only exception to this is when waste is being added to or removed from the container. • Accumulation of hazardous waste in any satellite accumulation area cannot exceed 55 gallons at any time. If the area accumulates acutely hazardous waste, one quart is the maximum amount allowed to be accumulated. A list of the acutely hazardous wastes is available from DEHS. University personnel are able to request chemical waste pick-up by DEHS online at https://louisville.edu/dehs/waste/disposal.html. All chemical wastes generated by UofL operations and activities are transported and stored at the DEHS managed Environmental Protection Services Center (EPSC), located at 1810 Arthur Street, Louisville, KY. The Kentucky Division of Waste Management approved the renewal of the hazardous waste management permit (KYO-001-012-012) to the EPSC effective on September 30, 2009. The EPSC receives waste and stores and/or treats it for eventual shipment to a permitted off-site treatment, storage, or disposal facility. The EPSC also manages such non-hazardous wastes as: • Mixed waste • Polychlorinated Biphenyls • Waste Oils • Pesticides/Herbicides not specifically listed or characterized in 40 CFR 261 • Off-spec or out-dated pharmaceuticals • Off-spec or out-dated chemicals not specifically listed in 40 CFR 261 or characteristically hazardous. Several routine operations are required for the proper handling and shipment as well as control of the waste minimization program and disposal costs. Operations utilized at the EPSC may include, but are not limited to the following: • Addition of absorbents to containers for shipment. • Lab packing of wastes for shipment to an off-site facility for disposal or treatment. • Blending/bulking of compatible materials into larger containers for eventual shipment off-site for disposal or treatment. • Stabilization of reactives on a case-by-case basis for storage or shipment off-site. DEHS solicits proposals to effect the contractual packaging, transportation and management of chemical and hazardous wastes which are generated at all UofL sites. Management of chemical and hazardous wastes is accomplished through recycling plus disposal or disposal (i.e., incineration). The current selected contractor, Pollution Control Industries (PCI) is a company that is familiar with and adheres to all of the federal, state and local regulations pertaining to hazardous wastes. The contract term is for the period on one year beginning on the date of award with an option to renew for up to four additional one-year periods, all parties concurring. The acquisition of these services is made by competitive negotiation procedures in accordance with KRS 45A.085. Contractor evaluation criteria include: previous hazardous waste disposal projects; recycling/disposal facilities owned, operated and controlled by the contractor; actual waste recycling or disposal options, i.e. recycling, fuels blending, incineration, or innovative new technologies; ability to handle all waste streams/use of subcontractors to handle individual waste streams; proven experience with handling wastes at other colleges and/or Universities; schedule of standard fees; previous regulatory compliance issues, federal and state violations and subsequent corrective actions and outcomes; and financial responsibility and liability for services.