Hazardous Waste Management Plan
This Hazardous and Regulated Waste Management Plan describes chemical waste management practices at Connecticut College. This Plan includes waste generated at all College locations with the exception of the Science Departments in Hale Laboratory, New London Hall, Bill Hall and Olin Science Center. Waste management procedures for those locations are described in the College's Laboratory Safety Handbook.
Hazardous Waste Disposal
At Connecticut College, generator of any hazardous waste is responsible for providing information that will allow the Director of Environmental Health and Safety to properly characterize and manifest the waste for disposal. The Director of Environmental Health and Safety is the only person authorized to schedule shipments of wastes described in this plan, and to sign manifests and/or bills of lading. He may, when necessary, designate this authority for a particular shipment to a trained and qualified alternate.
As previously discussed, all wastes must be properly characterized prior to disposal. Contact the Director of Environmental Health and Safety before generating any new waste streams, to facilitate that characterization.
Connecticut College is a Small Quantity Generator (SQG). A Small Quantity Generator is one who generates greater than 100 kilograms but less than 1,000 kilograms of hazardous waste in a calendar month, provided that such waste does not include more than:
- a total of one kilogram of acute hazardous wastes, or
- a total of 100 kilograms of any residue or contaminated soil, waste, or other debris resulting from the clean-up of a spill, into or on any land or water, of any acute hazardous waste, provided that there is no more than a total of one kilogram of acute hazardous waste contained in that residue, soil, waste or debris.
Accumulation Time Limits and Quantities
A small quantity generator may accumulate hazardous waste on-site for 180 days or less, provided that the quantity of waste accumulated on-site never exceeds 1,000 kilograms.
Satellite Accumulation Areas
A Satellite Accumulation Area is the location at the point of generation where containers of waste are accumulating as waste is generated. Routine hazardous waste generation locations and wastes are listed below.
- Oil based paint and paint related waste (solvents) in the paint shop.
- Paint solids contaminated with lead in the paint shop.
- Pressurized aerosol cans for disposal in the storeroom.
- Part washer solvent in the garage and Power Plant.
- Waste compressor oil.
- Paper and cloth solids contaminated with blanket wash (perchlorethylene), inks and other solvents.
- Spent Stabilizer and Plate Activator from the DPM 2000 Plate Maker.
Cummings Art Center:
- Some waste glaze materials from the Ceramics Studio.
- Spent fixer in the photographic darkroom.
- Spent engraving acids.
- Paint thinners, paints, inks and other solvent containing materials.
- Inks and paints containing any of the RCRA metals (such as cadmium, chromium, lead, etc.)
- Parts washer solvent in the Paint Studio.
While the waste is being accumulated, it is the responsibility of the supervisor of the area generating the waste to ensure that the waste is properly labeled and managed until it is delivered to the storage facility.
Satellite Accumulation Storage Rules
- Waste must be stored in containers, which are compatible with the waste and have a tight fitting cap or cover.
- Waste containers MUST be kept tightly closed at all times, except when adding waste.
- Waste containers, which are going to be used as the shipping container must be DOT approved.
- Waste containers must be in a secure location and under the control of the person generating the waste.
- Waste containers must be in good condition, and not leaking, or damaged.
- No more than one container of a particular waste can be kept at one time.
- When a container of waste is full or when that type of waste will no longer be generated, it must be taken to the waste storage area within 72 hours.
- To minimize the hazard of incompatible chemical reactions, wastes should not be mixed without prior approval from the Environmental Health and Safety Office.
Waste containers must be labeled with an orange "HAZARDOUS WASTE" label.
The label must contain:
- Waste name
- The identity of all chemicals in the container. Do not use chemical formulae or abbreviations
- Hazard(s), and
- The name and telephone extension of the generator of the waste.
- The "Date Filled" spaces must be filled in when the container is full, or the waste will no longer be generated. (Again, the container must be transported to the Hazardous Waste Storage Area within three days.) Indelible markers or ballpoint pens should be used for labeling.
180 Day Storage Hazardous Waste Storage Facilities
There are five Hazardous Waste Storage Facilities at Connecticut College. Four storage facilities are located in academic buildings, of which three are located in science buildings (Hale Laboratory, New London Hall and Bill Hall). These facilities are described in the Laboratory Safety Handbook, and will not be discussed here. The fourth academic building with a HAZWASTE Storage facility is Cummings Art Center.
The non-academic Hazardous Waste Storage Facility is located at the Service Building at the south end of campus. Storage facilities are inspected weekly by the Director of Environmental Health and Safety. In addition to assessing storage and container compliance, the Director uses this weekly inspection to ensure that accumulation limits are not exceeded. Emergency information is posted on the main door of the facility, including:
- Emergency phone number of Campus Safety (Extension 111.)
- Name and contact information of the emergency coordinator
- Location of fire extinguishers and fire alarm pull station
- Location of spill control materials, and
- Location of the eyewash and deluge shower
There are separate storage bays in the facility for different types of waste. All liquids, and lead acid batteries are stored on secondary containment.
Wastes are shipped off-site using a licensed hazardous waste transporter. All hazardous waste is taken to licensed facilities which treat, recycle, incinerate, or otherwise dispose of the materials using EPA approved methods for the particular waste type. Waste is shipped at least every 180 days, or more frequently to comply with storage limits.
Management of Connecticut Regulated Wastes
Following are the Connecticut and other regulated wastes and their generation/ accumulation locations:
- Spent antifreeze in the garage
- Used motor oil in the garage, and
- Asbestos in Hazardous Waste Storage Facility.
Containers and aboveground tanks used to store used oil must be labeled or marked clearly with the words "Used Oil." Used motor oil is accumulated in a 275 gallon tank, which is stored within secondary containment inside the Physical Plant garage. When the tank is full, an approved automotive waste removal company, removes the oil for recycling. This tank is inspected on a weekly basis.
Mixtures of used oil and hazardous waste are subject to regulation, and must be treated as hazardous waste. Therefore, only used motor oil should be disposed of in the "Used Oil" tank, in the Physical Plant Garage.
Spent automotive anti-freeze, is accumulated in a 55 gallon drum, stored on secondary containment within the garage. It is tested periodically to ensure that it is not a hazardous waste. It is also removed by the automotive waste disposal company.
Used oil filters are punctured at the top, and drained for 24 hours. The oil is disposed of in the used oil tank. After draining for 24 hours, the filters are disposed of in the regular trash.
Disposal of Non-Hazardous Wastes
Liquid wastes which are non-hazardous, are water soluble, and do not contain solids may be flushed to the sewer with copious amounts of water. Liquids which are not water soluble must be solidified (absorbed) and disposed of as a solid. Non-hazardous solid waste must be labeled "non-hazardous" and can then be put in the trash.
IMPORTANT: Please check with the Director of Environmental Health and Safety prior to disposal to make sure the material is appropriate for sewer or trash disposal.
Disposal of Empty Containers
Under Hazardous Waste regulations, chemical containers are considered empty when no more content can be poured out, and an inch or less of content remains. These containers can be recycled or disposed of in the regular trash. This does not apply to containers that have held acutely toxic chemicals, as listed in the RCRA Hazardous Waste List. Contact the Director of Environmental Health and Safety for instructions.
Aerosol cans are accumulated in the Physical Plant storeroom. Periodically, the aerosol cans are de-pressurized using an appropriate can puncturing device, and the liquid contents accumulated as hazardous waste. The empty cans are placed of in the "Metals" recycling dumpster, pending pick-up for recycling by Conn Carting, Inc. Under no circumstances are can containers (or equipment) containing CFCs discharged to the atmosphere.
Disposal of Gas Cylinders
Single use propane (i.e. Coleman®) type cylinders are all steel cylinders that can be recycled. The only requirements are to ensure the cylinder is completely empty and that either the main valve or the pressure relief valve is removed. These valves are similar to valves found in the stems on car tires and can be unscrewed from the fittings. To remove the valve, you will need a long tire stem tool which can usually be purchased at an auto parts or hardware store.
BEFORE removing the valve, make certain the cylinder is empty. To empty the cylinder, take it outside, away from any open flame or possibility of spark, and attempt to light the blowtorch, lantern or stove. If the cylinder is truly empty, remove the valve as described above, and discard in the Metals Dumpster for recycling.
Disposal of Unknowns
It is extremely difficult and costly to identify the content and hazards of unlabeled materials. If you have unknowns, please contact the Director of Environmental Health and Safety. Please indicate to the best of your knowledge what the material is likely to be based on its characteristics and the location at which it was found.
Spill Response Procedures
Large spills of hazardous materials, be it waste material or a in-use chemical product, will be handled as described in the Emergency Response Plan (ERP), and on the Hazardous Materials Spill Response page. Following is a summary of those procedures:
- Make everyone in the immediate vicinity aware of the spill.
- Evacuate the area, if necessary.
- Call Campus Safety at extension 111 or 911. Campus Safety will contact the Director of EH&S.
- Restrict access to impacted and threatened areas.
- Keep unprotected personnel upwind of spill area.
- Avoid contact with spilled product.
- Eliminate ignition sources that may be present.
- Prevent released material from entering sewers and confined spaces.
- Consider potential mixing of incompatible materials.
- Use explosion-proof and spark-proof equipment where necessary.
- The EH&S Director shall determine if a reportable incident occurred and facilitate reporting as required by law.
- If it can be done safely, every effort should be made to contain the spill, and prevent it from spreading. There are "spill kits" staged at the following locations:
- Physical Plant Garage
- Physical Plant Hazardous Waste Storage facility
- Power House
- Harris Kitchen
- Chemical stockroom, Hale Laboratory
- Chemical stockroom, New London Hall
- Chemical stockroom, Olin Science Center
- Bill Hall Hazardous Waste Storage facility, and
- Cummings Art Center Hazardous Waste Storage facility
- Boat House
- Campus Safety Vehicles
As a Small Quantity Generator, there are training requirements for all employees who generate, transport or otherwise manage hazardous waste. This training includes proper waste handling, and emergency procedures, relevant to the individual's responsibilities. Initial training is performed prior to assuming waste handling responsibilities, then every three years. Students who generate or handle hazardous waste, are trained by the supervising faculty member. Records of training are maintained by the Director of Environmental Health and Safety.