Chapter 20
WASTE MANAGEMENT

Contents

Approved by Nancy Rothermich
Revised 04/10


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 20.3.1.1 Nitric acid (HNO3) in Wastes 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

NOTE:
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20.1 Policy

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.
  • 20.2 Scope

    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.

    20.3 Hazardous, Radioactive, Mixed, and Medical Waste/Biohazardous Guidelines at Berkeley Lab

    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)
  • 20.3.1 Characterization: Determining if Your Waste is Hazardous, Radioactive, Mixed, or Medical/Biohazardous

    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.

    20.3.1.1 Nitric Acid (HNO3) in Wastes

    Nitric acid waste solutions that would normally be collected in an SAA must be handled following the rules below. These requirements below are in addition to any rules that apply to the use of these chemicals, such as segregation, PPE requirements, safe work practices, and work authorizations.  

    Waste that contains organic constituents must never be added to a nitric acid waste container, and waste that contains nitric acid must never be added to an organic solvent waste container. These mixtures can generate significant amounts of gaseous products that have caused pressure explosions in closed containers.

    It is the responsibility of the waste generator to ensure that there are no ongoing reactions in any waste container that result in a pressure buildup within the container. Where reactions of any type generate pressure, appropriate quenching steps must be incorporated to terminate such reactions. In no case can a vented cap be used as a control mechanism to relieve pressure buildup in a waste container. 

    Nitric Acid (HNO3) Waste Solutions (Including Aqua Regia Mixtures)

    Solutions with organic matter or metallic impurities. Any waste solution that results from a process requiring the mixing of nitric acid and organic chemicals or that contains nitric acid and metallic impurities from a process such as cleaning or etching may not be stored in an SAA. Waste mixtures of this type must be neutralized using a Waste Management Group (WMG) approved benchhtop treatment procedure. The neutralization step must be completed immediately upon completion of the experimental procedure. The benchtop treatment requirements and a procedure template are located at http://www.lbl.gov/ehs/waste/wm_benchtop.shtml. The neutralization step must be completed immediately upon completion of the experimental procedure. In general, this means that the waste must be treated before leaving for the day. Contact your Waste Generator Assistant for guidance.

    Solutions with no organics or metal impurities. Reaction mixtures that contain nitric acid or aqueous nitric acid solutions without metallic or organic impurities and have been declared as waste and contain greater than 5% nitric acid by weight (0.8 M) may not be stored as a waste in any SAA. In the absence of actual concentration information, the waste may not be stored in an SAA if the pH is less than 1 as determined by a pH meter or narrow range pH paper.

    Waste of this type must either be carefully diluted to reduce the concentration of the nitric acid to 5% or, in the absence of actual concentration information, neutralized using a WMG approved-benchtop treatment procedure. Contact your Waste Generator Assistant for guidance.

    An example procedure is located at http://www.lbl.gov/ehs/waste/doc/Benchtop_Nitric_Kisielowski.pdf.

    Surplus unused nitric acid purchased and kept in the original, manufacturer’s container and declared as waste is the only exception to the above rules. In this case, the bottle must be tightly closed, sealed with tape to prevent the addition of any other substances, and have a completed Hazardous Waste label. These solutions must be stored in an SAA that is totally separate from an SAA that stores organic waste mixtures such as spent solvents. Separate secondary containment trays for these waste types stored in the same SAA do not meet the required separation criteria.

    Note: Acid dilution/neutralization is exothermic and potentially hazardous. The hazards and controls of these processes are described in the Waste Management Group Benchtop Treatment Requirements.

    20.3.2 Compliance: Storing Waste at the Site of Generation

    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.

  • 20.4 Responsibilities of the Waste Management Group

    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).
  • 20.5 Required Training

    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.
  • 20.6 Glossary

    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:

    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.

    20.7 Standards

  • 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

  • 20.8 References

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