University of Richmond
OP-25: Hazardous Waste Management

A Waste Minimization Plan is recommended by EPA for Small Quantity Generators 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. B) 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 C) 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. 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 uses Veolia Environmental Services, Inc., to take wastes to EPA Permitted Treatment, Storage, and Disposal (TSD) facilities. We utilize a hierchy of disposal options with starting with recycling then energy recovery and finally incineration as a disposal method. The University of Richmond does not typically utilize land disposal. 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.

Not applicable.

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 declared a waste and properly disposed through the hazardous waste contractor. Only available to Biology and Chemistry departments because the chemicals are not available for public use.

Computers are purchased and distributed within a three year replacement schedule. At the end of three years, the computers are assessed to determine if the unit is still usable or if it has reached the end of its useful life. If still functional, the computer is redeployed; if not the computer is sent to Arrow Value Recovery for recycling or donation. Each year, the Office for Sustainability, President's Office, and Information Services sponsor an electronics recycling or e-waste collection. Arrow Value Recovery, the company that handles University e-waste, is on campus to collect personal electronic waste from University employees and students. The event averages a collection of 4,000 pounds of electronic waste each year.

Arrow Value Recovery has stringent controls on the following: Landfill avoidance for all electronic materials. Downstream processor transparency and controls. Prohibition on disposition of non-working electronics except to approved downstream processors. Prohibition of child or prison labor anywhere in the supply chain. Certification to ISO 9001, ISO 14001, OHSAS 18001, R2 and RIOS requirements. Certification to additional industry standards on a global level. Compliance with regional requirements, including the WEEE Directive in Europe