HAZARDOUS WASTE REDUCTION UNDER GENERATOR STATUS For presentation at the 40th International Conference of the Campus Safety Association hosted by Western Washington University, Bellingham, Washington. INTRODUCTION Reducing the amount of hazardous waste which is generated and ultimately incinerated, treated, or burned, is of concern to each business, institution and individual. Waste reduction results in lower disposal costs, decreased liabilities and lessens the overall environmental burden. Each of these results would certainly be a major goal of any effective management program. The Environmental Protection Agency in conjunction with the various state regulatory agencies has consistently required hazardous waste reduction activities. Page two (2) of the 1991 EPA Biennial Report calls for extensive documentation of waste reduction activities. Techniques such as elementary treatment, source reduction, substitution, recycling and others have represented the standard waste reduction options. For most industries and some Universities these do represent viable options. However, at the University of Alabama and many other Universities, the full range of waste reduction techniques are not advisable due to program and regulatory restrictions. Under generator status treatment options are not allowed at the collection facility. Chemical substitution and source reduction may not be an option due to research and laboratory requirements. The purpose of this presentation is to detail the waste reduction techniques and procedures which are used by the University of Alabama's Hazardous Material Management Program. These procedures have been developed under the constraints of generator status. PROGRAM HISTORY The Hazardous Material Management Program at the University of Alabama was begun in 1987. The responsibility for operation of this program was assigned to the Office of Health and Safety. The initial program goals were to insure University compliance with applicable state and federal regulations, provide training and information to the campus community and manage material in such a way as to minimize disposal costs. Procedures developed for the purpose of meeting the first two goals were quickly implemented. Minimizing disposal costs proved to be a much more difficult problem. Three of the universally recognized practices were deemed to be impractical at the University of Alabama. While elementary treatment, source reduction and substitution may be advisable for many companies and institutions they were seen as unacceptable. Elementary treatment at the source of collection which is the Hazardous Material Management Program's Central Storage Facility was illegal under generator designation. In the absence of a permitted treatment, storage and/or disposal (TSD) facility, elementary neutralization can take place in small quantities at the site of generation. However, site of generation treatment would have been contradictory to one of the foundation philosophies of the Hazardous Material Management Program. The concept of the program was initially and remains based upon simplicity of utilization as viewed by the individual faculty or staff member. The program did not want to place the added burden of requiring treatment of specific chemicals upon the faculty. A treatment option would also place among several hundred individuals the responsibility for adequate and thorough treatment of chemicals. Total compliance was viewed as questionable. The program did not feel the environmental risk was worth the possible benefits. Source reduction and substitution would also contradict the basic philosophy of the program. Faculty, staff and researchers have never been asked by the Hazardous Material Management Program to reduce chemical purchases or to substitute materials. The program has never had the administrative authority to make such requests nor is it wanted. Chemical purchases are approved by the responsible department head or Dean with no input from the Hazardous Material Management Program unless it is requested. In light of the restrictions imposed by generator status and the operating principles of the program itself the methods of reducing the amounts of hazardous waste and their corresponding disposal costs appeared to be very limited in 1987. WASTE DISPOSAL COST REDUCTION DEVELOPMENT It was quite evident at the inception of the Hazardous Material Management Program that means of reducing the amount of waste generated and the corresponding disposal costs must be found. Not only to meet EPA guidelines but also to reduce the overall environmental burden of the University of Alabama. The initial procedure for accomplishing this goal was recycling. The recycling program began in 1987 with the construction of a Central Storage Facility (CSF). In the daily operation of the program, materials which are picked up at various laboratories and other sites of generation are brought into the Central Storage Facility (CSF) by employees of the Office of Health and Safety. The materials are then segregated into categories of management characteristics as determined by Health and Safety technicians. One of these categories made up of chemicals which may be usable in some applications is called recyclable surplus. An example of such a material is an acid which is no longer usable for research or teaching purposes but may be suitable for etching or diluted and used as a cleaner. A listing of all recyclable surplus held in storage is periodically distributed throughout the University. The material is offered to any faculty or staff member at no charge. Table 1 as shown clearly illustrates the positive effect of a campus wide recycling plan. Since operation of the program began a total of 6,352.2 kilograms of materials have been redistributed for use that otherwise would have been managed as hazardous waste. The resulting disposal cost reduction is estimated at $53,867.40. TABLE 1 Fiscal Year Surplus Recycled CHG * Savings $ 87-88 350.2 $ 2171.24 88-89 386.2 $ 3610.97 89-90 1826.7 $ 13079.17 90-91 2534.2 $ 30689.16 91-92 1254.9 $ 4316.86 * Savings is determined by using the disposal cost per kilogram for the fiscal year. However as disposal costs rose and the long term liabilities associated with hazardous waste deepened in scope and application a search began for additional reduction methods. Disposal costs in an of themselves were ample incentive for further development. Table 2 illustrates the effects of increasing disposal costs. With the advent of the land bans and other factors, costs escalated to $12.11 per kilogram in fiscal year 1990-91. TABLE 2 Fiscal Year CHG Disposal $ $/KG 87-88 6355.2 39,400.00 6.20 88-89 16518.2 154,517.31 9.35 89-90 8778.8 62,851.72 7.16 90-91 8441.0 102,233.50 12.11 91-92 25950.5 89,171.75 3.44 Prior to the 1991-1992 fiscal year the problems of reducing waste and the corresponding disposal costs were examined by each person employed in the Hazardous Material Management Program as part of a team concept. The result of this approach was a coordinated effort of all individuals involved toward the goal of reducing hazardous wastes and their disposal costs. One previously developed program was reemphasized. Two procedures were added and aggressively implemented. The procedures which would be utilized during the 1991-92 fiscally year were: 1. Recycling 2. Analysis 3. Bulking RECYCLING The already successful recycling program was reemphasized for 1991-92. While the total amount recycled did not reach the levels of 1989-1990 and 1990-1991, over 1,250 kilograms of chemicals were used which otherwise would have been disposed of as waste. 1989-1990 and 1990-1991 levels of material recycled, correspond to very fiscally conservative years at the University of Alabama. One of the few benefits of institutional belt tightening appears to be increased usage of surplus chemicals. ANALYSIS A three phase chemical analysis protocol was developed for use in the Hazardous Material Management Program. While the analysis procedure has the least direct effect upon cost, its importance in relation to the bulking procedure is foremost. Phase one involves a fingerprint analysis of the subject material. In this analysis physical characteristics such as flash point, reactivity, PH and solubility are determined. In addition sulfide, cyanide and oxidizer screens are performed. If the material is a known pure compound this information may be obtained from a chemical dictionary or the Handbook of Chemistry and Physics. The information then allows the material to be placed in a category such as flammable, acid, basic, reactive, etc. The item may then be bulked or scheduled for phase 2 analysis. Phase 2 analysis consists of in house quantitative analysis. A particular material may be analyzed for the presence of metals using the atomic absorption spectrometer (AA) or it might be analyzed for the presence of poly chlorinated biphenyls (PCBs) using a gas chromatograph (GC). The type of analysis depends upon the physical characteristics of the material and it's history of use. Phase 3 involves quantitative Toxicity Characteristic Leachate Procedures (TCLP) analysis by an independent laboratory. TCLP analysis is relatively expensive, however, only 55-gallon containers of material are analyzed in this manner. Lab pack items are consolidated prior to this. The waste and cost reduction benefits of a thorough analysis scheme are evident with careful examination. Analysis allows full documentation of non hazardous wastes. While these may still be disposed of via hazardous waste contractor, a disposal price of $200 per 55 gallon drum compares very favorably with that of a regulated waste. In addition regimented analysis allows for the bulking of many materials which otherwise would be disposed of as lab pack items. BULKING At the beginning of the 1991-1992 fiscal year an aggressive bulking procedure was implemented. Lab pack items and other small quantity items are bulked together into 55 gallon drums if the individual item meets any one of the classifications as established by analysis. The various classifications are determined by University of Alabama personnel. They are based primarily on solubility, PH and reactive testing as determined by mixing a representative sample of the potential bulk item with the material which it may be bulked with. Other analysis parameters have a secondary determination for potential bulking. In 1991-92, a total of 224 individual containers were shipped off site via a contractor for disposal. Of these only 19 were managed as lab packs. Ninety two percent (92%) of the items disposed of as hazardous waste in 1991-92 by the University of Alabama was managed us bulk items. The savings in the 1991-92 fiscal year which resulted from bulking were estimated at $271,000.00. While this estimate may not be exact it does document the advantage of an aggressive bulking program. Table 2, illustrates the dramatic effect of bulking. Disposal cost per kilogram was lowered from $12.11 in 1990-91 to $3.44 in 1991-92. The safety aspect of bulking was considered at length prior to implementing the program, however, by using thorough analysis procedures and capability testing no personnel have been injured while involved in bulking materials. CONCLUSIONS The reduction or minimization of hazardous waste is very difficult for most institutions which operate under generator status. The absence of a permit places limits upon the technologies and procedures which may be utilized. At the University of Alabama, recycling, analysis and bulking have been utilized. The waste reduction results have not been spectacular. However, during the past fiscal year over 1200 kilograms of material was identified as non regulated and maanaged as such. The cost reduction benefits have been much more dramatic. In the 1992-92 fiscal year the estimated savings was calculated to be $275,000. The most apparent reduction was lowering the $12.11 per kilogram disposal fee in 1990-91 to $3.44 in 1991-92. Overall the waste and cost reduction measures have had positive benefits for the University. The total environmental burden has been decreased and monies have been saved which can now be applied toward other programs. While these procedures are simple and straight forward the reductions are documentable and they have a cummulative positive effect in the development of a campus environmental management philosophy. These measures have proven to be successful at the University of Alabama. They will not apply to all institutions. However, this presentation was made in the hopes that some of the information might assist other Universities in the further development of their hazardous material management programs.