Note: Never dispose of hazardous substances down sink drains unless specifically authorized.
Contact your Generator Assistant for more details.

Summary of Hazardous Waste Requirements

1.1       How Do I Know If My Waste Is Hazardous?

Some examples of hazardous waste are:

·        flammable liquids, such as nonhalogenated solvents

·        corrosive liquids, such as strong acids and bases

·        solid oxidizers

·        wastes that contain heavy metals and halogenated organics

·        greases and oils

The first step in determining if you have a hazardous waste is to understand the materials that go into your process, how the materials are used, and how they flow into and out of the process. You must be aware of any potential reactions that might occur that could change the nature of the chemicals you are using. It is quite possible that your process could change hazardous materials into materials that are no longer hazardous, e.g., neutralization or complexing of an acid or base with a buffer compound. Though less common, you should also be aware of the potential to create hazardous materials during your process.

One important information source that can help you determine if your waste is hazardous is the Material Safety Data Sheet (MSDS) for each chemical you use. Before working with any chemical, you should review the MSDS and understand the hazards of the material. More information on working with hazardous materials can be found in the Chemical Hygiene and Safety Plan. As a general rule, you should never work with hazardous materials and generate hazardous waste without being properly trained in safe handling and management practices for such work. Once you have an understanding of the materials in your waste, you can proceed to evaluate the waste as hazardous for possible regulation. Your first responsibility as a hazardous waste generator is to complete appropriate training. The Hazardous Waste Handling Facility (HWHF) will accept waste only from generators who have completed the training course EHS 604: Hazardous Waste Generator Training. There are provisions for visitors or guests that will be on site for < 30 days and will be generating hazardous waste. These guests must complete the Web-based, EHS 623: Hazardous Waste Generator Training for Visitors/Guests.  This class is not a substitute for EHS 604.

Once a by-product of your work/research is created, you must declare that it is waste, or have determined recycling or reuse options prior to its generation. Recycling and reuse requirements can be very complicated and must be developed prior to the generation of the waste; otherwise, you may be storing waste illegally.

A waste is regulated as hazardous based on a comparison with criteria found in both Federal and State of California hazardous waste regulations. When EPA developed regulations for the management of hazardous waste, it based its regulations on two general criteria: (1) characteristics of the waste and (2) waste on specific lists. Waste Management (WM) personnel use these criteria in determining the storage, treatment, and disposal of hazardous waste.

If any of the definitions below apply to your waste, the container must be labeled as “Hazardous Waste,” and managed accordingly. If you are unsure whether your waste is hazardous, you may simply label the waste, and then call your generator assistant. There is no penalty for labeling nonhazardous waste.

Once you have determined that your waste is hazardous, sink disposal is strictly prohibited unless specifically authorized.  Contact your Waste Generator Assistant for more details.

1.1.1      Characteristic Waste

Characteristic waste is considered hazardous based on specific properties of the material. The four basic properties that can define a characteristic waste are ignitability, corrosivity, reactivity, and toxicity.

1.1.1.1   Ignitability

A waste is ignitable if:

(1) it is a liquid with a flash point of less than 140°F, unless the liquid is an aqueous alcohol solution with less than 24% alcohol by volume; (2) it is not a liquid and is capable of causing fire through friction, absorption of moisture, or spontaneous chemical changes; (3) it is an ignitable compressed gas; or (4) it is an oxidizer.

Examples of Ingitable Waste

Ignitable liquids: acetone, acetonitrile, benzene, hexane, methanol, ethanol, isopropanol, toluene, xylene, methyl ethyl ketone, lacquer thinner.

Ignitable compressed gases: hydrogen, methane, acetylene, propane, butane, spray-paint cans.

Oxidizers:  ammonium persulfate, sodium nitrate, potassium permanganate, sodium perchlorate, hydrogen peroxide (aqueous solution greater than or equal to 8%), potassium peroxide.

1.1.1.2   Corrosivity

A waste is corrosive if:

(1) it is aqueous and has a pH ≤ 2 or ≥ 12.5, as measured by a pH meter; (2) it is a liquid and corrodes steel at a rate greater than ¼-inch per year in a standard corrosivity test; (3) it is not aqueous, and when mixed with an equivalent weight of water, produces a solution having a pH ≤ 2 or ≥ 12.5 (in California only); or (4) it is not a liquid, and when mixed with an equivalent weight of water, produces a solution that corrodes steel at a rate greater than ¼-inch per year in a standard corrosivity test (in California only).

Examples of Corrosive Waste

Corrosive aqueous liquids: hydrochloric acid, sulfuric acid, nitric acid, perchloric acid, acetic acid, sodium hydroxide solution, potassium hydroxide solution.

1.1.1.3   Reactivity

A waste is reactive if:

(1) it is normally unstable and readily undergoes violent change without detonating; (2) it reacts violently with water; (3) it forms potentially explosive mixtures with water; (4) it generates toxic gases, vapors, or fumes when mixed with water; (5) it contains cyanides or sulfides and can generate toxic gases when exposed to pH conditions between 2 and 12.5; or (6) it is explosive under standard temperature and pressure conditions, or it can explode if subjected to a strong initiating source or heated under confinement.

Examples of Reactive Waste

Sodium metal, potassium metal, lithium metal, concentrated sulfuric acid, picric acid, trinitrobenzene, metal azides, amides, benzoyl peroxide.

1.1.1.4   Toxicity

A waste is toxic if:

(1) it can release sufficient amounts of specific toxic metals or organics in standard leaching or extraction tests (there are more vigorous extractions and more constituents of concern in California); (2) it contains sufficient total amounts of specific toxic metals, organics, or asbestos (California only); (3) it has an acute oral LD50 less than 2,500 milligrams per kilogram (California only); (4) it has an acute dermal LD50 less than 4,300 milligrams per kilogram (California only); (5) it has an acute inhalation LC50 less than 10,000 parts per million as a gas or vapor (California only); (6) it has an acute aquatic 96-hour LC50 less than 500 milligrams per liter in a standard aquatic toxicity test (California only); (7) it contains specific known human carcinogens in a single or combined concentration equal to or exceeding 0.001% by weight (California only); (8) it has been shown through experience or testing to pose a hazard to human health or the environment because of carcinogenicity, acute or chronic toxicity, bioaccumulative properties, or persistence in the environment (California only).

Because of the unknown and potential hazards associated with nanomaterials, these wastes must be managed as nanomaterial containing waste streams with the characteristic of toxicity.

Examples of Toxic Waste

Waste containing the following metals or inorganics above specific limits: antimony, arsenic, barium, beryllium, cadmium, chromium, cobalt, copper, lead, mercury, molybdenum, nickel, selenium, silver, thallium, vanadium, zinc, asbestos, fluorides.

Waste containing the following organic constituents above constituent-specific limits:  benzene, carbon tetrachloride, chlorobenzene, chloroform, cresols, 1,2-dichloroethane, methyl ethyl ketone, nitrobenzene, pyridine, tetrachloroethylene, trichloroethylene, PCBs.

If you are not sure whether your waste is hazardous due to a regulated characteristic, consult with the generator assistant assigned to your division or building.

1.1.2      Listed Waste

The definition of a “listed waste” is more convoluted. At Berkeley Lab, the listed wastes that create the most questions are typically solvents. EPA regulations require us to consider how the solvent was used in the process. EPA considers listed waste to be hazardous, regardless of its concentration or physical characteristics.

Generally, the waste generator is the only person who can provide enough information for us to make this determination. The following examples are meant to illustrate the information required by the Berkeley Lab Waste Management Group in order to comply with EPA and State regulations.

Example 1: A Waste Is Described as 50% Acetone and 50% Hexane

Case 1 — Assume your experimental procedure requires that you mix acetone and hexane in a 50:50 ratio, and that this mixture is used in your process. In this case, the listed waste criteria would not apply, because the acetone was not at 100% before you used it in your process; instead, it was 50%. Therefore, only the characteristic criteria would apply.

Case 2 — Suppose you use pure acetone as a solvent in one process, and pure hexane in a separate process. One day, you add 1 gallon of used or “spent” acetone to your waste container; the next day, you add 1 gallon of used or “spent” hexane. This waste is also a 50:50 mixture of acetone and hexane, but now since the acetone was at 100% when it was used in your process, the entire waste has to be managed as a “listed waste.”

Example 2: A Waste Is Described as 4% Methylene Chloride, 48% Phenol, and 48% Chloroform

Case 1 — Assume your experimental procedure requires a mixture of methylene chloride, phenol, and chloroform in a 4:48:48 ratio prior to use in your experiment. After use, this is added to your waste container. In this case, because the methylene chloride added to the mixture was less than 10% before use, only a characteristic waste code applies.

Case 2 — Assume that this mixture occurred after the experimental process. One day, 2,400 mL of a 50:50 mixture of phenol chloroform is added to your waste container. A few days later, 100 mL of used 100% methylene chloride is added to this same container. In this scenario, the entire waste container is subject to the “listed waste” rule, because the concentration of methylene chloride was greater than 10% when it was added to the waste container.

These examples also illustrate the need to maintain an accurate Accumulation Log (see Figure 1-1). Follow-up phone calls by your generator assistant can be minimized or avoided by doing the following:

1.            Review the list of chemicals in Table 1-1; use nonhazardous substitutes, if possible.

2.            List the concentrations of all waste constituents.

3.            Fax copies of detailed Accumulation Logs.

4.            Tell Waste Management if the material is used or surplus unused material.

5.            Discuss your generating process with your generator assistant.

Interpretation of the regulations has limited the treatment options, and thereby disposal options, for “listed” waste. Once a “listed” chemical used as a solvent enters a waste stream, it may carry that designation, regardless of the fate of the originally listed molecule. Furthermore, any other waste that is mixed with that waste, no matter what the final concentration, may also be designated as listed hazardous waste. Many surplus, unused, or off-specification chemicals are also considered listed waste when discarded. Avoiding “listed” chemicals is a good way to enhance waste minimization. For example, substituting ethanol for methanol in many chemical processes might cost more initially, but it could greatly reduce the complications and costs associated with disposal.

If, after review of this concept and the associated lists, you are unsure whether you have a listed or characteristic waste, consult with the generator assistant assigned to your division or building.

1.1.3                Chemical Compatibility

Incompatible chemical wastes should never be mixed together. Uncontrolled chemical reactions may endanger your safety and the safety of those around you. The act of mixing together separate wastes may also result in a regulatory violation for unpermitted treatment. Benchtop treatment may be an alternative if your goal is to avoid mixed waste charges (see Section 3.5 of this document). If you are unsure whether to add a particular chemical mixture to your waste container, please contact your generator assistant. Additional information may be found at
http://response.restoration.noaa.gov/chemaids/react.html

 

 

Figure 1-1. Example of a completed Hazardous Waste Accumulation Log.

Table 1-1. EPA F-Listed Hazardous Wastes

F-Listed hazardous wastes include spent solvents used in degreasing or other solvent operations, and various spent solvents that are no longer useful for their original purpose.

 

 

1.1.4      Excess Laboratory Chemicals and Laboratory Cleanouts

The Waste Management Group encourages you to periodically remove unwanted chemicals from your work area to maintain a safe and compliant workplace. It is of the utmost importance that if you intend to leave Berkeley Lab, you must determine the fate of any chemicals you leave behind [see RPM Section 1.19 (Space Management)]. Your division might have specific rules regarding remaining chemicals. However, abandoned chemicals present compliance and safety liabilities. If chemicals are left behind without proper documentation, significant costs will be charged to the division to characterize these items. To that end, we ask that you do the following:

1.     Determine if any other researcher in your area wants the chemicals. If so, please transfer custody to them and update the Chemical Management System.

2.            If your chemicals are to be disposed of, use the Chemical Management System link to the electronic Hazardous Waste Requisition to request waste pickup

Stock solutions and experimental products can be added to the requisition with items from the Chemical Management System.  Radioactive and mixed wastes cannot be submitted electronically at this time and must be requisitioned separately  (see Section 2)

1.2       I Know My Waste Is Hazardous; Now What?

As a generator of hazardous waste, you must understand the necessary steps to safely and compliantly accumulate waste. For typical waste accumulation in small quantities, i.e., less than 55 gallons, you will need to understand and follow all rules applicable to a Satellite Accumulation Area (SAA), which is an area at or near the point of waste generation. The requirements for waste accumulation and setup of an SAA are covered in Section 1.3 (Where Do I Store My Waste?) and in training classes EHS 604: Hazardous Waste Generator and EHS 614: Satellite Accumulation Area Manager. If you do not establish your own SAA but use one that is under the management of a designated SAA manager, you must coordinate use of the SAA with that responsible individual.

Hazardous waste regulations dictate that you, as the generator, are responsible for the complete and accurate characterization of your waste. Precise characterization is essential to ensure

·        safe handling,

·        protection of the environment,

·        compliance with federal and state packaging requirements,

·        compliance with conditions of Berkeley Lab’s HWHF Permit,

·        compliance with land-disposal restrictions, and

·        acceptance of the wastes by appropriate recycling or disposal facilities.

All wastes must be characterized fully, as directed by the criteria in Section 1.2.1, before they can be accepted for transport to the HWHF.

1.2.1      Characterization

Because most chemical waste is generated during specific processes in the course of your activities or experiments, you should know the chemical content of your waste from your “knowledge of the process” you used to generate it (see Section 1.1, “How Do I Know if My Waste Is Hazardous?”). In fact, the individual generating the waste is, in most cases, recognized as a more accurate source than certified analytical laboratories for specifying components and their concentrations in a given waste sample. Most hazardous waste generated at Berkeley Lab can be characterized through process knowledge. However, this approach must be supported by precise, documented information (see Section 1.2.1.1, “Hazardous Waste Characterization Criteria”). To use and justify process knowledge for characterization, you must

·        know the hazardous properties of all chemicals used,

·        have a thorough understanding of how the chemicals were used,

·        understand the chemistry of the reaction to determine if hazardous chemicals were produced where none existed before, and

·        know whether the process converted hazardous chemicals to nonhazardous ones.

1.2.1.1   Hazardous Waste Characterization Criteria

Once you have determined that your waste is hazardous (see Section 1.1, “How Do I Know if My Waste Is Hazardous?”) and have identified the type(s) of hazard(s), all hazardous and nonhazardous components must be fully identified and documented. It is important to account for 100% of the contents of each waste container, including trace amounts of known hazardous components or other materials of concern (such as nanomaterials). A common problem is the failure to recognize that water and hydrogen ions (pH), if present, must be listed as components. Hazardous waste characterization may be achieved in the following ways:

·        By maintaining records (logs) of accumulation that draw upon knowledge of the procedures and processes that generated the wastes. The logs contain an entry each time a chemical is added to a container (Figure 1-1), and a link to the forms. To use and justify process knowledge for containers with repetitive additions of various constituents, this record must be a timely and accurate reflection of what has been added to the container. When the container is no longer needed, this record becomes the basis to develop summaries, which will be provided as part of a pickup request. For waste that is collected in this manner, this record of accumulation must accompany all subsequent document submittals to the Waste Management Group.

·        By consulting an MSDS for each hazardous component, and listing quantitative information for all hazardous and nonhazardous components.

·        By developing a generic description when the material has a well-known standard composition (e.g., waste alkaline batteries or broken mercury thermometer).

·        By using analytical results from a certified laboratory on known, unchanging waste streams (i.e., a waste profile), or by using complete analytical results from a certified laboratory for each waste. Analytical results from a noncertified laboratory may be used if adequate analytical records and procedures are documented and available to the Waste Management (WM) Group of the Environment, Health, and Safety (EH&S) Division, but will only be considered as a qualified form of your process knowledge.

When a Hazardous Waste Disposal Requisition Form (Figure 1-2) is submitted, each entry on the Requisition should indicate whether the waste determination is based on process knowledge, MSDS information, or analytical information.

Figure 1-2. A completed Hazardous Waste Disposal Requisition Form.

1.2.2      Labeling of Waste Containers

As a hazardous waste generator, you are responsible for assuring that any container used to accumulate hazardous waste is properly labeled in order to meet regulatory requirements and assure the safety of those around you. The labeling requirement applies from the moment the first drop of waste is placed in the container. At that point, you must fill out and attach a Hazardous Waste Label to the waste container. Figure 1-3 is an example of a properly completed Hazardous Waste label.

The Hazardous Waste Label identifies:

·        the waste generator,

·        the contents of the container,

·        information on the hazardous characteristic(s) of the waste, and

·        establishes the waste generation start date.

The waste generator must fill in the start date when the first addition is made to the waste container. Each primary waste container must have a label attached, indicating the composition of the material. A manufacturer’s label does not serve this purpose, even if proper hazard information is on the label.

All entries on the Hazardous Waste Label must be legible. It is recommended that entries be made with a permanent marker or a pen containing permanent ink. Ballpoint pens, pens with water-soluble ink, or pencils should not be used to fill out Hazardous Waste Labels. For large primary waste containers such as carboys, the Hazardous Waste Label should be affixed to an area of the container that is easily visible for inspection and emergency-response purposes. A waste container that is too small for a label can be placed in a ziplock plastic bag, with a Hazardous Waste Label affixed to the bag. If this method is used, be sure there is a very clear association between the Hazardous Waste Label and the actual primary waste container.

The “Contents” section of the Label can be completed using one of the following three approaches:

1.      By chemical name. If the material is a mixture, identify at least two or three of the major constituents that contribute to the primary hazard(s), including nonhazardous constituents, if appropriate. For waste containing nanomaterials, the description must include “contains nanomaterials.”

Examples: 1 M hydrochloric acid, aqueous solution; used acetone; contains acetone, hexane, methanol. Remember, if the composition is changing due to repetitive additions of compatible waste materials, maintain an Accumulation Log for the container, and record each entry on the log.

Figure 1-3.  Example of a properly completed Hazardous Waste Label.

 

2.      By manufacturer and specific product (for example, trade name or number, catalog number, etc.), including the primary hazardous materials listed in the MSDS for the specific product.

Example:  BioRad Protein Assay Dye Reagent; contains methanol and phosphoric acid.

Chemical identification information of manufactured products may also be found in the Aldrich Catalog of Fine Chemicals; the NIOSH Registry of Toxic Effects of Chemical Substances; and The Merck Index: An Encyclopedia of Chemicals, Drugs, and Biologicals.

3.      By complete generic description of the material, only if the material is a mixture with a well-known standard composition. The description should indicate whether the material is new, has exceeded its shelf life, is spent, etc. If the material is a process waste, such as a cleaning agent or an etching bath, list all of the potential contaminants from the process in addition to the known constituents. For machine coolants, identify the metals for which the coolants were used. The generic description must be sufficiently complete to adequately characterize the waste material.

Example: Chromic acid dip-tank waste with copper. “Photochemicals” is insufficient because a wide variety of chemicals is used in photoprocessing. The description must be more specific, such as “alkaline photo developer” or “used photo fixer with chromate bleach.”

1.2.2.1   When Is a Solid Really a Liquid?

The physical form of the waste (solid, liquid, gas) is critical to the characterization and acceptance of the waste to the offsite treatment and disposal facility. If a waste container contains both a solid and any amount of free liquid (liquid not bound by an absorbent), it is a “liquid”. It is permissible to mark the label as both a “solid” and a “liquid”.

1.2.3      Waste Container Acceptability

As a waste generator, you must assure that any container you use for waste meets certain minimum requirements. First and foremost, you must assure that the container and its closure are compatible with the waste placed in the container. You must also assure that the container is kept closed at all times except when adding waste. It is a regulatory violation to accumulate and subsequently store hazardous waste in an open container.  Container compatibility information can be found at http://www.coleparmer.com/techinfo/chemcomp.asp and in the Chemical Hygiene and Safety Plan.

1.2.3.1   Flammable Wastes

Accumulation of flammable wastes must be in accordance with the National Fire Protection Association (NFPA) and Occupational Safety and Health Administration (OSHA) safety guidelines. NFPA 45, Fire Protection for Laboratories Using Chemicals, Table 10.1.4 (2004 Edition), and OSHA 1910.106d, Table H-12 restrict the sizes and types of containers that can be used for storage of flammable liquid waste in the workplace.

Flammable or ignitable wastes may not be accumulated in plastic containers of any type other than a listed and approved safety can (Figures 1-4 and 1-5 show examples of flammable waste cans). Approved, reusable safety cans are available from the Waste Management Group in 5-, 2.5-, and 1-gallon capacities. If you have small amounts of flammable waste, glass containers may be used, but the maximum allowable waste quantity in a glass-container is 1 pint for Class IA liquids, and 1 quart for Class IB liquids (Figure 1-6)¹. Table 1-2 lists the appropriate containers for small quantities of flammable liquids.

1. Surplus, unused flammable liquid in the original manufacturer’s container is acceptable.

 



Figure 1-4. Five-gallon flammable waste can.

 



Figure 1-5. 2.5-gallon flammable waste can.

 



Figure 1-6. Glass bottles suitable for 1A flammable liquids
(1 pint) or 1B flammable liquids (1 quart).

 

Various containers are available from Waste Management, or a variety of Laboratory supply vendors.

Information on the classification of flammable liquids can be found in the Berkeley Lab Chemical Hygiene and Safety Plan.

In some instances where your building has an appreciable amount of flammable and combustible liquids, you may be required to store flammable and combustible wastes in flammable liquid safety cabinets to comply with California Building and Fire Codes. Please refer to the Chemical Hygiene and Safety Plan for more information or contact the Berkeley Lab Fire Marshal at extension 6370.

 

Table 1-2. Appropriate Containers for Small Quantities of Flammable Liquids

Flammable Liquid Category Waste quantity (Maximum) Container Type*** Class IA—Flash point below 73°F (22.8°C), and a boiling point below 100°F (37.8°C) (e.g., acetaldehyde, diethyl ether, pentane) ≤1 pint 1 pint, glass >1 pint 1 gallon safety can Class IB—Flash point below 73°F (22.8°C), and a boiling point at or above 100°F (37.8°C) (e.g., acetone, acetonitrile, carbon disulfide, cyclohexane, 1,2-dichloroethane, diethylamine, ethyl alcohol, heptane, hexane, isopropyl alcohol, methyl alcohol, methyl ethyl ketone, tetrahydrofuran, toluene) ≤1 quart 1 quart glass >1 quart 2.5 or 5 gallon safety can Class IC—Flash point >73°F, but <100°F (e.g., p-xylene) ≤1 gallon 1 gallon safety can >1 gallon 5 gallon safety can

*** Without regard to container type, surplus unused flammable liquid in the original manufacturer’s container is acceptable.

 

1.2.3.2   Solvent-Contaminated Rags

Fire Code requires that large containers (> 1 quart) for the accumulation of solid ignitable wastes (e.g., solvent-contaminated rags) have self-closing lids that are sufficiently tight to restrict the supply of oxygen. As a waste- minimization or pollution-prevention alternative, please consider the Reusable Rag and Absorbent Program.

1.2.3.3   Acids or Bases

To prevent accidents and injuries, liquid corrosive wastes should be accumulated in polyethylene or plastic containers that are known to be compatible with acids or bases.

 

1.2.4      Waste Segregation

As a waste generator, you must assure that wastes are collected in a manner that segregates chemicals that could potentially react when mixed. In general, you should have separate containers for each compatible waste stream. Collect acids with acids, bases with bases, etc. Keep oils with known or suspected PCB content separate from non-PCB-containing oils.

1.3       Where Do I Store My Waste?

Prior to pickup by Waste Management Group staff, or while you are accumulating waste from your process, the container must be stored in an SAA or Waste Accumulation Area (WAA). This section discusses both types of storage.

1.3.1      Satellite Accumulation Area (SAA)

An SAA is an area in a laboratory, shop, or other facility designated by the generator for the accumulation of hazardous waste. It requires no formal authorization from Waste Management. Even a single small bottle of a hazardous waste requires establishing an SAA in your laboratory or work area.

The SAA Manager is responsible for enforcing proper waste accumulation at the SAA. The waste generator is responsible for assuring that his/her containers are properly labeled and kept closed unless adding waste, and that proper accumulation records are maintained. If your work area has an existing SAA, ask the SAA Manager if you can use it. If there is no SAA in your area, details for setting up, using, and maintaining an SAA are provided in Sections 1.3.1.1 – 1.3.1.4. SAA Manager guidelines can be found in Section 1.3.1.2, “Managing Containers in the SAA,” or in the training course EHS 614: SAA Manager.

1.3.1.1   Setting Up an SAA

Hazardous waste regulations require the SAA to be located at or near the point of waste generation, and that it be under the control of the generator. The SAA must be at or near the site where the waste is generated so the SAA can be controlled by staff while they are working. Your SAA must be located in the room where the waste is generated, or in an immediately adjacent room (with no intervening hallway). The intent of this requirement is to provide virtually full-time monitoring of the SAA by the individual(s) generating the waste.

Regulations and best management practices require that the SAA be located away from all exit doors or areas where it could hamper egress in the event of a fire or spill. Appropriate spill cleanup materials should be located near your SAA, especially if large amounts of wastes (up to 55 gallons) are accumulated.

The SAA must be clearly designated using the yellow sign depicted in Figure 1-7. If there is uncertainty regarding the boundaries of the SAA, the area should be clearly marked off with tape, arrows, and other signage to unambiguously define the SAA boundary (Figure 1-8).

All hazardous wastes must be stored in the SAA. Maximum storage allowed is 55 gallons of any particular hazardous waste stream, or up to 1 quart of acutely or extremely hazardous wastes (see Appendices II and III, respectively). If you wish to accumulate more than 10 gallons (and fewer than 55 gallons) of liquid ignitable waste in an SAA, Fire Code requires that your SAA be located in a metal flammables cabinet. This determination might also be influenced by storage of other flammable liquids in the vicinity of your SAA. If you have questions concerning application of the Fire Code in your work area, please contact the Berkeley Lab Fire Marshall at extension 6370.

 



John Smith85/118 x 5877 Acids, solvents, oil

Figure 1-7. A properly completed SAA sign

 



Figure 1-8. Hazardous waste stored in an SAA.

 

1.3.1.2   Managing Containers in the SAA

All wastes must be in containers compatible with the waste. Accumulate liquid corrosive wastes in polyethylene or plastic containers that are known to be compatible with acids or bases. Flammable or ignitable wastes may not be accumulated in plastic containers of any type other than a listed and approved safety can. Approved, reusable safety cans are available from the Waste Management Group in 5-gallon, 2.5-gallon, and 1-gallon capacities. If you have small amounts of flammable waste, glass containers may be used, but the maximum allowable glass-container size is 1 pint for Class IA liquids, and 1 quart for Class IB liquids (see Section 1.2.3.1, “Flammable Wastes,” for further discussion of flammable liquid waste storage).

Various containers are available from Waste Management, or a variety of Laboratory supply vendors  via Ebuy .

Information on the classification of flammable liquids may be found in the Berkeley Lab Chemical Hygiene and Safety Plan at http://www.lbl.gov/ehs/chsp/html/flammable.shtml.

Keep primary waste containers tightly closed at all times except when you are adding waste. The container may be opened up to 15 minutes while you add waste. A funnel in a container opening is not considered closed unless the funnel itself seals to the container, preventing spillage. Container closures must be secure. Cork, rubber, or ground-glass stoppers; aluminum foil; and polyethylene film or parafilm are not allowed. If the waste is likely to generate gases during storage, vented caps should be used, or the waste should be treated using an approved benchtop treatment procedure. Plastic bags used as containers must be closed (twist-tie, ziplock, tape, staple, or spring clamp). Do not add waste to a hazardous waste container after you have submitted the pickup requisition for that container to the HWHF.

Prepare and label all waste containers with red-and-white hazardous waste labels. Labels must be complete and correct at all times. Figure 1-3 is an example of a properly completed hazardous waste label. If the container is too small for a label, place it in a ziplock bag and attach the label to the bag.

1.3.1.3   Secondary Containment

Secondary containment is required for all liquid hazardous wastes and all wastes accumulated in glass containers. The secondary containers must be compatible with the chemicals they contain. The requirement for secondary containment of waste containers in an SAA or a Mixed Waste Satellite Accumulation Area (MWSAA) is a best-management practice throughout industry and government. Secondary-containment capacity of 110% of the largest container being stored is an industry standard. The secondary containment requirement does not depend on the actual volume of waste being stored, only the largest container in storage. Remember that physical space and segregation of incompatible chemicals in secondary containment are important as well. Each container should be stored safely.

Metal containment is acceptable for noncorrosive wastes.

Example 1:  A lab SAA contains three 1-liter bottles of waste. Secondary containment should be able to contain 110% of 1 liter or 1.1 L. In this case, an 8” × 10” plastic photo tray is acceptable. (8” × 10” × 1” = 80 cubic inches or 1.3 liters).

Example 2: A lab SAA contains a 5-gallon flammable waste can, two 1-pint bottles, and a 20 mL vial. Secondary containment should be able to contain 110% of 5 gallons or 5.5 gallons (20.8 L). In this case, a polyethylene, 5-gallon, 18” × 26” × 6” Rubbermaid tote is appropriate (18” × 26” × 6” = 2,808 cubic inches or 46 L).

Example 3:  A lab MWSAA has a collection container for scintillation vials. The typical storage configuration is a plastic bag inside a 12.2 gal container. A full bag is approximately 750 vials (20 mL each) or 15 liters of liquid. Secondary containment should be able to contain 110% of 15 liters or ~4.4 gallons. The secondary containment requirement is satisfied by the plastic bag inside a 12.2-gallon container. Waste Management provides the plastic bag and 12.2-gallon container.

Secondary containment tubs and trays are available from several suppliers with whom Berkeley Lab has system contracts that facilitate ordering. Other plastic trays and tubs are available from suppliers such as VWR with a two-day delivery time. Appropriate containment options can be found in the Labels/Supplies section of this Web page.

1.3.1.4   Additional SAA requirements

Keep incompatible wastes physically separate, in secondary containment as well as in the primary container (e.g., acids and bases, oxidizers and organics, water reactives and aqueous wastes).

As a waste minimization strategy and to minimize cost, keep halogenated solvents separate from nonhalogenated solvents.

California regulations allow waste accumulation for up to one year in an SAA; however, under Berkeley Lab policy, waste may be accumulated in SAAs for up to 275 days (nine months). This is not an HWHF Permit condition. To comply with Berkeley Lab policy, waste must be removed from the SAA within the 275-day timeframe. Waste containers should be requisitioned for pickup as soon as they become full, and must be removed from the SAA within three days after reaching the 55-gallon accumulation volume limit. Waste remaining in an SAA greater than one year may subject the Lab to fines from regulatory agencies.

Do not store chemicals, empty bottles, or other items in your SAA, because these items might be mistaken for unlabeled hazardous waste. Good housekeeping practices should also be implemented to provide easy access to your SAA.

Waste may be stored in Potter St. SAAs for more than 275 days provided that the waste has been requisitioned by the generator and processed by Waste Management technicians. Waste from Potter St. is shipped directly to the offsite treatment and disposal facility several times during the year.

Several poster-type summaries of SAA requirements are available on this Web site under Generator Resources/SAA Management Tools (SAA Sign, SAA Guide1) . These can be posted at or near the SAA to assist you in maintaining a compliant SAA.

 

1.3.2      Waste Accumulation Area (WAA)

A Waste Accumulation Area (WAA) is a storage area designed for the accumulation of hazardous wastes for up to 90 days, in total quantities that can exceed 55 gallons (208 liters) of hazardous waste, one quart (0.946 liter) of extremely hazardous waste, or one quart (0.946 liter) of acutely hazardous waste. Berkeley Lab policy allows the accumulation of hazardous waste in a WAA for a maximum of 60 days to assure compliance with state regulations. This is not an HWHF Permit condition. The 60-day storage period begins on the date (called the “WAA receival date” or the “accumulation start date”) when waste is first placed in the container.

WAAs offer benefits to large-quantity waste generators. They provide a single area for the accumulation of large quantities of waste, and in the event of a spill, they prevent hazardous materials from entering the environment by means of required secondary containment. In addition, they contain emergency equipment in the event of a spill or release. The actual need for a WAA is best determined through consultation between the waste-generating organization and the generator assistant. A WAA cannot be established without prior EH&S approval.

The physical requirements for WAAs include:

·        secondary containment,

·        shelter from the elements,

·        controlled access,

·        appropriate signs,

·        a method to separate incompatible wastes,

·        sufficient access to allow pickup of waste, and

·        a washable surface (e.g., concrete or asphalt).

Where possible, the WAA should be a distance of approximately 50 feet from sanitary sewers or storm drains. The WAA must also be located at least 50 feet from the facility property line if flammable or reactive waste is being accumulated.

The following safety equipment must be maintained at or near all WAAs:

·        portable fire extinguisher and/or fixed fire-suppression system,

·        emergency spill kit,

·        emergency eyewash and safety shower,

·        telephone (either at the WAA or nearby, with a sign indicating the direction to the nearest phone),

·        personal protective equipment (e.g., gloves, safety glasses),

·        appropriate hazard warning signs (e.g., Flammables, Hazardous Waste Area),

·        posted contingency plan for dealing with spills and other accidental releases of hazardous wastes, and

·        posted names and telephone numbers (day and night) of responsible individuals (WAA Manager and Alternate).

When no further waste needing a WAA is to be generated, it must be closed according to State regulations.

For more information about WAAs, please consult LBNL/PUB-3093, Guidelines for the Management of Waste Accumulation Areas (WAAs) at Berkeley Lab.




1.4       How Do I Get Rid of My Hazardous Waste?

Sink disposal of hazardous substances is strictly prohibited unless specifically authorized. This prevents violations of environmental regulations. Contact your Waste Generator Assistant for more details. 

You should request a pickup of your hazardous waste when:

√    your container is full,

√    the container is approaching 275 days (9 months) old,

√    you no longer need the container to accumulate waste, OR

√    as often as you wish.

There are two ways to request a pickup: (1) electronically or (2) through a handwritten requisition. Allow 2 weeks for pickup.

1.4.1      Electronic Requisition

The electronic requisition is available at https://ehswprod.lbl.gov/shoebox/login.asp or by clicking “Haz Waste Req” on the Quick Links section of the Waste Management Web page. The simple instructions will guide you through all the information necessary to notify us that you have waste ready for pickup.  If you have any questions or problems, please contact your Generator Assistant.

1.4.2      Paper Requisition

Alternatively, you might wish to fill out a waste requisition by hand. Figure 1-2 is an example of a completed Hazardous Waste Disposal Requisition Form.

1.4.2.1   How to Fill Out a Hazardous Waste Disposal Requisition Form

The following are instructions for filling out the required information. If information is missing, you will be contacted by Waste Management to complete the information before your waste can be picked up. The requisistion is separated into several sections: general information, "Waste Description", "Accumulation Start Date" (Figure 1-2), and an “EH&S Use” section.

The instructions below describe the types of information needed for “General Information” and “Waste Description” sections only:



General Information

Date—This is the date you are filling out the requisition.

Account No.—This is the account number or project ID under which the waste was generated.

SAA/WAA Location: Bldg.—This is the building in which the waste container is located for pickup.

Rm.—This is the room in which the waste container is located for pickup.

Name, Employee ID#, Division, and Phone—This is information about the person to contact if there are any questions about the waste. This should also be the person whose signature appears at the bottom of the requisition and on the Hazardous Waste Label. This information is used by the technicians to confirm the container when picking up the waste.

Is this waste from an RMA?—Circle either “Y” or “N.” If you circled “Y,” then your hazardous waste was generated in a Radiological Material Area (RMA), and it must be certified by the generator to be free of radioactive contamination before the waste can be removed. By signing the RMA Waste Certification Form (Figure 1-9), you are certifying that your hazardous waste is free of radioactivity. This completed form will be faxed to Waste Management with the Hazardous Waste Disposal Requisition Form (Figure 1-2), Accumulation Log (Figure 1-1), and any other information.

If you cannot certify that your waste is free of radioactivity [other than naturally occurring radioactive material (NORM)], additional testing and analysis of the waste will be needed. Since your waste might require sampling and analysis, please allow an extra two to four weeks for pickup. If you cannot certify that your waste is free of radioactivity, fax your Hazardous Waste Disposal Requisition Form to the Waste Management Group early enough to comply with the 275-day accumulation time limit.

Waste Description

Process Knowledge, Analytical, or MSDS—Check one of these boxes based on information you are using to complete the description of the waste.

Earliest Accumulation Start Dates—This is the date the waste was first created. This date should be found on the Hazardous Waste Label on the container. This information is used to identify the container when the technicians come to pick up the waste.