University of Richmond
OP-21: Hazardous Waste Management

A Waste Minimization Plan is required for all Large Quantity Generators (LQG) of hazardous waste. Our plan is targeted at reducing hazardous wastes generated by the sciences, and includes the following steps: A) Elimination of most P-List (Acutely Toxic) materials from the chemical inventory, preventing future disposals of more than one kilogram in any calendar month, which would require reverting to LQG status. B) Waste stream from two research laboratories’ glass-washing protocol. Amounts of waste are significant during summer research, and the two waste streams are compatible. Since the inception of this bulking program, one of the two laboratories has changed their protocol to allow the use of a dishwasher, which has cut the lab’s acetone wash use by half. Acetone wash has recoverable BTU value, and is used at EPA Permitted Treatment, Storage, and Disposal Facilities (TSD’s) for beneficial use fuel blending in cement kilns. This is an ongoing program since Academic Year 2009-2010. The program eliminated approximately 275 gallons (2200 lbs.) of flammable corrosive hazardous waste from being incinerated without recovering fuel value during the calendar year 2011. C) Mercury article (thermometers, etc.) exchange program where non-mercury thermometers were provided to researchers, when suitable replacements existed. Additionally, mercury thermometers which could not be replaced with non-mercury ones, are held in the Chemical Stockroom and checked out for use, preventing spills from extra thermometers rolling around in drawers. While an occasional mercury thermometers are discovered, there have been no mercury spills from broken thermometers since this program was fully instituted at the end of Academic Year 2009-2010. D) Chemical Inventory Reduction and Redistribution Program: The American Chemical Society estimates that unused chemicals can constitute up to 40% of the wastes generated by a lab. Therefore, purchasing and inventory functions are vital to reducing hazardous wastes. a. Purchasing Prior to purchasing new chemicals, the Stockroom Manager reviews the inventory to determine if the department has an existing supply of the chemical in the Stockroom. While bulk purchasing may seem less expensive per gram of material, studies have shown that eventual disposal costs drive the price much higher when excess chemicals are purchased., Therefore, when chemical purchases are made, the Stockroom Manager purchases only the quantity required for the research project or instructional experiment. b. Inventory Management The Stockroom Manager maintains an accurate electronic inventory of all chemicals in the Gottwald Center for the Sciences. Each chemical is assigned a unique inventory number. A bar coded label is placed on each chemical, with the inventory number and chemical’s date of receipt. Chemical stock is rotated on a first in / first out basis to minimize aging. c. Laboratory Unit Inventory Review All Faculty and Staff are encouraged to perform an annual inventory review to determine if: All chemicals listed on the inventory are present All bar-coded chemicals in the lab are listed on the inventory Chemicals have not deteriorated or aged beyond usefulness Peroxide-forming chemicals are in good condition, and are tested for peroxides All chemicals have a foreseeable use, or are returned to the Stockroom (see below) d. Return to Stock Program Many chemical reagents can be used by other laboratories. Even those chemicals deemed too old for research use may be useful in teaching laboratories, where a high level purity is not required. All chemicals which have no foreseeable use in the laboratory unit should be returned to the Stockroom for potential redistribution within the department(s). Those chemicals which are no longer usable will be evaluated for redistribution by a vendor (chemical recycling company), or declared a waste and properly disposed through the hazardous waste contractor. We are in the third year of this program, and we have found that approximately 50% of chemicals returned as part of this program, are suitable for use in teaching laboratories. e. ChemSavers chemical redistribution service The University has used the services of ChemSavers, Inc. for several years. Through this program where the company repackages and resells virgin chemical reagents, we have eliminated 140.6 pounds of chemicals which would have been disposed as a hazardous waste since 2009. Some of the recycled chemicals were P-Listed chemicals (acutely toxic), which could cause an increase in generator status, back to LQG, if more than one kilogram is discarded in any calendar month We have instituted all of these steps, which allowed the University to reduce the generator status to Small Quantity Generator. This not only eliminated an annual $1000/year fee, but it also reduced labor and transportation costs for waste shipments due to longer allowable on-site accumulation times. An added benefit was the reduction in fuel used by the waste disposal company when they were transporting the wastes more frequently.

Hazardous waste contractors selected for Virginia state contract, extend the same pricing to all universities. The University of Richmond has used two permitted Hazardous Waste Transporters to take wastes to EPA Permitted Treatment, Storage, and Disposal (TSD) facilities. We strictly use incineration as a disposal method, unless it is not allowable by regulation. In the past year, only one waste stream (from a major equipment overhaul) was not suitable for incineration, and this waste will not be generated in the future. Universal waste light bulbs are collected by the Electrical Shop, and maintained in sealed boxes until shipped off-site. To minimize storage issues, fluorescent tubes are crushed in a bulb crusher (equipped with HEPA filter) as allowable by regulation. All fluorescent bulbs are sent to a proper reclamation center. Universal waste batteries are collected by the Facilities Storeroom and taken to Batteries Plus to be reclaimed. Information Services also maintains Universal Waste batteries and e-scrap, which are shipped periodically, and tracked on a reclamation database by the contractor.