Chapter 20
HAZARDOUS WASTE DISPOSAL
Contents
Approved by Nancy Rothermich
Revised 02/08
20.1 Policy
20.2 Scope
20.3 Hazardous, Radioactive, Mixed, and Medical/Biohazardous
Waste Guidelines at Berkeley Lab
20.3.1 Characterization: Determining if Your Waste
is Hazardous, Radioactive, Mixed, or Medical Biohazardous
20.3.2 Compliance: Storing Waste at the Site of Generation
20.4 Responsibilities of the Waste Management Group
20.5 Required Training
20.6 Glossary
20.7 Standards
20.8 References
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The Berkeley Lab Waste Management policy is to:
Comply with all laws and regulations governing hazardous, radioactive, mixed,
and medical/biohazardous wastes.
Remove these wastes from generator areas safely and efficiently.
Minimize the wastes generated at Berkeley Lab.
Operate the Hazardous Waste Handling Facility (HWHF) in a manner that complies
with all regulations.
This chapter provides general information on the management of the following
kinds of wastes:
Hazardous waste (i.e., wastes that are regulated by EPA or the State of California)
Radioactive waste (containing radioactivity distinguishable from background)
Mixed waste (waste containing both hazardous and radioactive components)
Medical/biohazardous
waste (waste that requires
inactivation of
the biological material in an approved manner prior to
final disposal)
This chapter does not apply to solid or liquid sanitary wastes.
This chapter also provides guidance on how to find more specific information
on selected waste management topics and how to contact Waste Management personnel
for consultations on specific topics.
Hazardous, radioactive, mixed, and medical/biohazardous wastes are generated
during routine research and support activities at Berkeley Lab. Waste generators
are responsible for accurate and complete characterization of their wastes,
for compliant management of them within their workplaces, and for minimizing
the amount of waste generated. Consult the following publications and your Generator
Assistant for additional information:
PUB-3092, Guidelines
for Generators to Meet HWHF Acceptance Requirements for Hazardous, Radioactive,
and Mixed Wastes at Berkeley Lab
PUB-3093, Guidelines for Management of Waste Accumulation Areas (WAAs)
at Berkeley Lab
Medical/Biohazardous
Waste Generator Guidelines (part of the Biosafety Manual)
The first step in waste disposal is to determine if your waste is hazardous,
radioactive, mixed, or medical/biohazardous.
Use the information in LBNL/PUB-3092 to determine if your waste is hazardous,
radioactive, or mixed.
Use the information provided in the Medical/Biohazardous Waste Generator
Guidelines (part of the Biosafety Manual) to determine if your waste is
medical.
If you have any questions about the nature of your waste, you should contact
an EH&S Generator Assistant to help you in your determination.
It is vitally important that wastes be accurately and completely characterized.
Doing this properly is the generator's responsibility. If waste is characterized
improperly, it may be shipped to an inappropriate facility, compromising the
public health and safety.
All generators are required to set up special waste storage areas and follow
all regulations while the waste is in the generator area, including:
Limiting the amount and kind of waste that can be stored,
Segregating and separating waste according to its hazard category,
Maintaining adequate primary and secondary containment,
Maintaining proper packaging and labeling, and
Storing waste within allowable time frames.
Specific waste storage areas include:
Satellite
Accumulation Areas (SAAs), which are used for the accumulation
of small amounts of hazardous wastes for up to 275 days (nine months). Details
about setting up and maintaining SAAs appear in the Guidelines for Generators
to Meet HWHF Acceptance Requirements for Hazardous Wastes at Berkeley Lab
(part of LBNL/PUB-3092).
Radioactive
Waste Collection Areas (RWCA), which must be used for storing
low-level radioactive wastes. Details about setting up and maintaining RWCAs
appear in Guidelines
for Generators to Meet HWHF Acceptance Requirements for Radioactive Wastes at
Berkeley Lab (part of LBNL/PUB-3092).
Mixed
Waste Satellite Accumulation Areas (MWSAAs), which are used for the
accumulation of mixed wastes for up to 275 days (nine months). Details about
setting up and maintaining MWSAAs appear in Guidelines
for Generators to Meet HWHF Acceptance Requirements for Mixed Wastes at Berkeley
Lab (part of LBNL/PUB-3092).
Waste Accumulation
Areas (WAAs), which are used for the accumulation of larger
amounts (>55 gallons) of hazardous wastes for up to 60 days. WAAs are most
appropriate for areas such as shops, where only a few kinds of hazardous wastes
are generated in large quantities. Specific rules apply to WAAs, including security,
labeling, and signage, contingency plans, and emergency equipment, as detailed
in LBNL/PUB-3093, Guidelines for Management of Waste Accumulation Areas (WAAs)
at Berkeley Lab.
Solid medical and biohazardous waste is stored and
managed at the generator's site
according to the guidance in the Medical/Biohazardous
Waste Generator Guidelines.
Medical/biohazardous wastes are transferred by the generator from the generator's
laboratory to an approved medical waste pickup site, where they are picked
up by an outside contractor. Regulated
medical waste, stored in red biohazardous bags, must be transferred from
the generator’s laboratory weekly. Unregulated biohazardous waste,
stored in clear biohazardous bags, does not need to be transferred weekly;
it should be transferred when the container is full or if there is a noxious
odor.
EH&S's Waste Management personnel at Berkeley Lab are responsible
for:
Assisting generators in all matters on wastes, including characterization,
labeling, packaging, and safe and compliant management in the workplace.
Ensuring that generators have properly characterized their waste and have
correctly, packaged and labeled it before it is picked up.
Removing all hazardous and mixed waste from the generator's site in a safe
and timely manner.
Operating the HWHF in a manner that ensures safety and complies with all
regulations.
Reviewing and approving all off-site facilities used for treatment and disposal
of radioactive, mixed, and hazardous waste.
Signing all hazardous waste shipping documents to an off-site facility.
Tracking the waste from the time a disposal requisition is received at the
HWHF to its final disposition in a treatment, storage, and disposal facility
(TSDF) or other storage site.
Maintaining all records regarding the waste.
Transporting all open containers of hazardous material between nonadjacent
buildings at LBNL and between LBNL and off-site locations (e.g., UC Berkeley
Campus).
The following training is required for generators of hazardous, radioactive,
mixed, and medical/biohazardous wastes.
EHS 604, Hazardous Waste Generator Training, is required for all generators
of hazardous waste at Berkeley Lab.
EHS 622, Radioactive and Mixed Waste Generator Training, is required
for all generators of radioactive and/or mixed wastes at Berkeley Lab.
EHS 610, Waste Accumulation Area Supervisor's Training, is required
for WAA managers at Berkeley Lab.
EHS 730, Medical and Biohazardous Waste Training, is required for
all generators of medical/biohazardous waste at Berkeley Lab.
Acutely hazardous waste is any waste that is listed in 22 CCR, Chapter
11, Article 4, as an EPA-defined "P-listed" hazardous waste. These wastes typically
are toxic or reactive. Acutely hazardous waste is a federal definition,
whereas extremely hazardous waste (see definition below) is a State of
California definition.
Biohazardous waste is waste that requires biological inactivation in
an approved manner prior to final disposal, and includes, but is not limited
to, the following discarded items:
Primary human cell lines and tissue cultures
Organisms with recombinant DNA
Cultures and stocks of infectious agents
Potentially infectious agents
(e.g., bacteria, viruses, fungi, prions)
Toxins
Live and attenuated vaccines
Blood, blood products, and other
potentially infectious materials that may contain human blood-borne pathogens
Carcasses
Tissue specimens
Recognizable human or animal body parts
Soil, plants, and pathogens controlled
by the United States Department of Agriculture (USDA)
Labware (not defined as a sharp) that has come into contact with the aforementioned
waste streams (e.g., contaminated plastic pipettes, pipette tips, petri dishes,
centrifuge tubes, eppendorf tubes, disposable gloves, and wipes)
More information can be found at the Medical/Biohazardous
Waste Generator Guidelines located on EH&S's Waste Management Web site.
Characterization is the detailed documentation of the waste constituents
such that the appropriate treatment, storage, and disposal decisions can be
made. Characterization can include process knowledge (see definition below),
required analyses, or written documentation (log books, formulas, etc.).
Extremely hazardous waste is any hazardous waste or mixture of
hazardous wastes that, if human exposure should occur, may likely result in
death, disabling personal injury, or serious illness because of its quantity,
concentration, or chemical characteristics. (From 22 CCR 66260.10.)
Hazardous waste is defined as:
- Wastes that exhibit one or more of the criteria for identification of "hazardous
waste" (22 CCR 66261.21-66261.24). These criteria are:
- Toxicity
- Ignitability
- Reactivity
- Corrosivity
- Wastes listed in the California Code of Regulations (22 CCR 66261.31 —
22 CCR 66261.33) and the Code of Federal Regulations (40 CFR Part 261.31 —
261.33). These wastes include certain discarded commercial chemical products,
off-specification products, container residues, and spill residues.
- Wastes listed as "dangerous" or "extremely hazardous" in the Washington
Administrative Code, Chapter 173-303.
Process knowledge means the ability of the generator to characterize
waste based on the chemical materials from which the waste was derived or the
process by which the waste was generated. It also means being able to verify
the characterization with the documented procedures used and data accumulated
during the waste-generation process.
Low-level waste is waste containing radioactivity distinguishable from
background levels that is not classified as high-level waste, transuranic waste,
spent nuclear fuel, or byproduct material, as defined in DOE Order 435.1. At
LBNL, low-level waste is divided into several different categories, described
in LBNL/PUB-3092, Guidelines for Generators to Meet HWHF Acceptance Requirements
for Hazardous, Radioactive, and Mixed Wastes at Berkeley Lab.
Medical waste, according to federal and California laws, refers to waste
that is generated or produced as a result of the diagnosis, treatment, or immunization
of humans or animals; in research pertaining to the treatment, diagnosis, or
immunization of humans or animals; or in the production or testing of biologicals
(medicinal preparations made from living organisms and their products including
serums, vaccines, and anti-toxins) and is either:
Biohazardous or
Sharps (devices with sharp edges capable of piercing or cutting the skin)
Mixed medical waste is any mixture of medical and nonmedical waste,
with the following exceptions:
Waste that is both medical/biohazardous and hazardous
is considered to be hazardous waste and is subject to hazardous waste regulations.
Waste that is both medical/biohazardous and radioactive
is considered to be radioactive waste and is subject to radioactive regulations.
Waste that is medical/biohazardous, hazardous, and radioactive
is considered to be mixed waste and is subject to both hazardous and radioactive
waste regulations.
Mixed waste is any radioactive waste that is also a hazardous waste.
Pathological waste is defined at Berkeley Lab as any recognizable human
or animal body part and tissue. The most common pathological waste found at
Berkeley Lab is animal carcasses.
No path to disposal waste (NDP) is any waste for which no disposal facility
currently exists.
A Radioactive Materials Area (RMA) is an area where the potential exists
for contamination due to the presence of unencapsulated or unconfined radioactive
materials or an area that is exposed to beams or other sources of particles
(neutrons, protons, etc.) capable of causing activation.
A Satellite Accumulation Area (SAA) is an area in an individual laboratory,
shop, or other facility designated by the generator for the accumulation of
waste, not to exceed 208 liters (55 gallons) of hazardous waste or 0.95 liter
(1 quart) of extremely or acutely hazardous waste. The area must be at or near
the point of waste generation and under control of the person generating the
waste.
Sharps are devices having acute rigid corners, edges, or projections
capable of piercing or cutting the skin. These include both regulated (contaminated
with biohazardous waste) and sharps that pose a safety hazard.
Transuranic wastes are any wastes that, without regard to source
or form, are contaminated with alpha-emitting transuranium radionuclides (elements
93 and higher) with half-lives greater than 20 years and concentrations greater
than 100 nCi/g at the time of assay. Radium sources and U-233 are also considered
to be transuranic wastes. Radioactive waste with quantities of transuranic radionuclides
in concentrations of 100 nCi/g of waste or less is considered to be low-level
waste.
A Waste Accumulation Area (WAA) is an officially designated area for
the accumulation and storage of large quantities of hazardous waste.
40 CFR Sections 260–279, Hazardous Waste; 761.1, PCBs
29 CFR 1910.120, Training
29 CFR 1910.1001, Asbestos Hazardous Waste Control Law, Hazardous
Waste Control Law
29 CFR 1910.1030, Bloodborne Pathogens Standard
22 CCR Section 66260.1 et seq. (and all permits pursuant) 49 CFR 171–173, 177–178 (DOT), selected sections on packaging,
shipping, and carrier loading Federal Facility Compliance Act (FFCA) California Health and Safety Code, Section 25100 et seq. California Health and Safety Code, Sections 117600–118360, California
Medical Waste Management Act
FFCA Order for LBNL HWCA 95/96-016, Site Treatment Plan for Mixed Waste
Berkeley Municipal Code, Chapter 11.52, Hazardous Materials Management
as applied to generator areas Waste Disposal Site Waste Acceptance Criteria
DOE Order 435.1, Radioactive Waste Management, as appropriate
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