Why do we need to dispose of School Chemicals?

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1 School Chemical Disposal City of Leon Valley Conference Center 6421 Evers Road Leon Valley, TX October 14, :30 to 11:30

2 Presentation outline Why do we need to dispose of School Chemicals? Definitions Regulations Options fordisposing of school chemicals. Funding Partners and/or Local Recycling options Planning Lessons Learned

3 Definitions TAC Texas Administrative Code CFR Code Code of Federal Regulations Solids Waste means a solid waste as defined in (a)(1) ()() any discarded material that is not excluded by (a) Materials are solid waste if they are abandoned by being: Disposed of; or Burned or incinerated, etc

4 Definitions Hazardous Waste (a) A solid waste, as defined in 261.2, is a hazardous waste if: It is not excluded from regulation as a hazardous waste under 261.4(b) and etc. CESQG Conditionally Exempt Small Quantity Generator Generates no more than 100 kilograms (220 pounds) of hazardous waste in a calendar month Most schools will be a CESQG unless you have Acute Hazardous Waste P listed waste under A total of one kilogram (2.2 pounds) of acute hazardous waste will require following all ofthe regulations under part 262 etc.

5 Acute Hazardous Waste P010 Arsenic acid P075 Nicotine, & salts P011 Arsenic pentoxide P087 Osmium tetroxidet P012 Arsenic trioxide P098 Potassium cyanide P015 Beryllium powder P104 Silver cyanide P021 Calcium Cyanide P105 Sodium azide P022 Carbon disulfide P106 Sodium cyanide P029 Copper cyanide P108 Strychnine, & salts P030 Cyanides (soluble cyanide salts) P120 Vanadium pentoxide P042 Epinephrine P001 Warfarin, & salts

6 Regulations 30 TAC refers you to 40 CFR Part 261 In 40 CFR CESQG Most schools will fall under these regulations ()G (a) Generates no more than 100 kilograms (220 pounds) of hazardous waste in a calendar month The school may have more than 220 pounds but it would have accumulated ltdover many years. Unless you possess Acute Hazardous Waste A total of one kilogram (2.2 pounds) of acute hazardous waste will require following all of the regulations under part 262 etc. This only happens occasionally.

7 Disposal Options Milk Run School to school in a geographical area for waste removal Cost savings by consolidating the materials together In other words materials are consolidated into the same containers Some disposal contractors will not do this This may not fit into their waste management system Consolidation of materials at one location This may not be an option but saves considerably Material needs to be segregated prior to relocation CHMM Chapters and/or local industry may assist with this part of the service Each school individually This is the most expensive option, each school has waste containers

8 Disposal Funding Sources ISD, City and/or County Budget Grants TCEQ and/or Council of Governments EPA Industry Grants Exxon CHMM Chapters Local Industry Exxon has provided funding and staffing to assist the schools in the Parishes that boarder their Louisiana plants Donations Alumni associations

9 Local Recycling or Disposal Options Share items with other schools or ISDs Acids Bases Divide large volumes into smaller containers to share Local industry Maytakeitemsfor disposal thru their disposal facilities Can your local WWT Plant treat the inorganic acids and bases? Let their staff do this if possible

10 Planning Steps to follow 1. Partner with a hazardous waste disposal company or a chemist tfrom local lindustry if possible 2. Inventory the material to determine the cost Make sure you have all of the material 3. Can the material be consolidated at one location or will each school have to be picked up 1. This drives up the cost of disposal 4. Will the ISD have to go out for bid? 1. The RFP process can take several weeks if not months

11 Rural High School in Central Louisiana

12 Rural High School in Central Louisiana

13 Central Louisiana School Clean Out Campaign Funded by a LDEQ grant Removed waste from 8 schools in the Parish for an invoice total of $15, ($1, per school) Approximately 7,000 pounds of waste High hazard ditems were: Spontaneous combustibles Water reactive materials Ethyl ether bromine

14 North Central Louisiana School Clean Out Campaign Funded by a LDEQ grant Removed waste from 9 schools in the Parish for an invoice total of $17, ($1, per school) Included dwaste from the 3 private schools Approximately 2,010 pounds of waste The City school board paid $30K to a disposal company the year before and they left items behind that I took This included 828 grams of Uranyl Nitrate from two schools This material costs $13.80 per gram to dispose of High hazard items were: Radioactive compounds Spontaneous combustibles Water reactive materials Ethyl ether cyanides bromine

15 North Central Louisiana School Clean Out Campaign Funded by a LDEQ grant Removed waste from 12 schools in the two Parish for an invoice total of $11, ($ per school) Included waste from the 2 private schools Approximately 3,742 pounds of waste This included 80 grams of Uranyl Acetate This material costs $13.80 per gram to dispose of High hazard itemswere: Radioactive compounds Spontaneous combustibles Water reactive materials Ethyl ether cyanides bromine

16 Lessons Learned Take a good thorough inventory See if a waste disposal contractor will assist with this I make a point to go to every school even though they claim to not have anything Perform the clean out during the school year Faculty usually are not interested in coming in during the summer It helps having the teachers available to determine what they are and are not using Provide an escort for the disposal company The contractor will not want to wait until the chemistry teacher has a break to see them for the waste pick up Make sure that all of the material has been inventoried before the RFP has been released Sorry but ti just tfound dten more boxes in the attic Convince the teachers that they do not need all of the material in their store rooms Don t have your teachers package the materials

17 Questions Questions Thank You for your Attention Thank You for your Attention Kelby Neal, HHW Business Development Manager PSC Environmental Services ofc cell

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