HAZARDOUS WASTE MANAGEMENT PROGRAM. For OTTERBEIN UNIVERSITY. Prepared by: 140 North Otterbein Avenue Westerville, Ohio 43081

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1 HAZARDOUS WASTE MANAGEMENT PROGRAM For OTTERBEIN UNIVERSITY Prepared by: 140 North Otterbein Avenue Westerville, Ohio 43081

2 Otterbein University 0 TABLE OF CONTENTS 1.0 PURPOSE AND SCOPE ROLES AND RESPONSIBILITIES Chemical Hygiene Officer Departmental Waste Representative Waste Handler Service Department APPLICABLE REGULATIONS Hazardous Waste Universal Waste GENERATOR STATUS Hazardous Waste Generator Status Universal Waste Generator Status ACCUMULATION TIME LIMITS Hazardous Waste Universal Waste Biological Waste GENERAL REQUIREMENT FOR HAZARDOUS WASTE DEPARTMENTAL HAZARDOUS WASTE GENERATORS Science Department (All Departments) Art Department Scenic Studio (Only) Theater Department Service Department Athletics Department Nursing UNIVERSAL WASTE GUIDELINES AND DEPARTMENTAL GENERATORS Discarded Batteries Waste Lamps Mercury Containing Equipment Ballasts Pesticides PREPAREDNESS AND PREVENTION INSPECTIONS Hazardous Waste Inspection Universal Waste Inspection OFF-SITE SHIPMENT/TRANSPORTATION RECORD KEEPING AND TRACKING Hazardous Waste Universal Waste Biohazard Waste TRAINING APPENDIX A... 12

3 Otterbein University PURPOSE AND SCOPE This document constitutes the Waste Management Plan for Otterbein University. The purpose of this program is to ensure proper management and disposal of waste within Otterbein University and its individual departments. This program is designed as a comprehensive reference guide for managing wastes at Otterbein University s Westerville, Ohio, campus. 2.0 ROLES AND RESPONSIBILITIES This section establishes roles and responsibilities for Otterbein University personnel involved in the management or generation of wastes. All questions regarding roles and responsibilities associated with this program should be directed to the Chemical Hygiene Officer. 2.1 Chemical Hygiene Officer Responsibilities include: Implementing the policies described in this program Categorizing wastes generated throughout the departments located at Otterbein University as hazardous or non-regulated; Service Department will be in charge of handling all universal wastes and their disposal. Assisting Service Department with universal waste when needed Assisting with selecting qualified transporters for hauling hazardous and regulated wastes Coordinating campus wide waste pick-ups Ensuring that weekly inspections of both the hazardous waste and universal waste storage areas are being conducted by designated personnel (see 12.2 for the Universal Waste Inspection) Ensuring that any Otterbein University staff involved with the handling of wastes receive appropriate waste training (Section 13) Maintaining all records associated with wastes generated within the University (Section 12). Service Department will maintain all Universal Waste records and submit annual report to CHO in March. Reviewing and updating this program annually Assisting with Westerville Fire Department and Security responses to large spill emergencies (Section 10 of this document) Advising individual departments where waste is generated that all State and Federal Regulations are followed

4 Otterbein University Departmental Waste Representative Each specific department within Otterbein University will have a designated individual to work with the CHO in managing wastes within the individual departments. The responsibilities of the waste representative are Complying with the policies and procedures outlined in this program Assisting with the identification of new wastes when applicable Contacting the CHO when a waste pick up is needed Ensuring that any universal waste generated within their department is taken to the service department for proper disposal 2.3 Waste Handler Responsibilities include: Reading and understanding the Waste Management Plan Coordinating with the Chemical Hygiene Officer for all chemical or biological waste pick ups Ensuring that all applicable training has been met 2.4 Service Department Responsibilities include: Coordinating all universal waste pickups within each individual department Storing all universal wastes prior to pickup by waste handler Maintaining universal waste pick up records Operating Aerosol Can Puncture Station (Hazardous Waste) 3.0 APPLICABLE REGULATIONS This section identifies the regulations that apply to Hazardous Wastes and Universal Wastes generated at Otterbein University. Regulations are implemented at the federal, state, and local levels. 3.1 Hazardous Waste Chemical waste generated within Otterbein University s campus that exhibit hazardous characteristics are defined under Ohio Administrative Code (OAC) Chapter and under federal regulation 40 CFR Part 260.

5 Otterbein University Universal Waste All spent batteries, lamps/ballasts, mercury containing equipment, and pesticides are considered to be Universal Waste and are defined under Ohio Administrative Code (OAC) Chapter and under federal regulation 40 CFR Part GENERATOR STATUS This section identifies what generator status Otterbein University is classified as for both hazardous waste and universal waste. 4.1 Hazardous Waste Generator Status Otterbein University is considered to be a Small Quantity Hazardous Waste Generator (SQG) by generating less than 1000 kilograms of hazardous waste in a calendar month. 4.2 Universal Waste Generator Status Otterbein University is considered to be a Small Quantity Handler of Universal Waste who does not accumulate 5,000 kilograms or more of universal waste at any time. 5.0 ACCUMULATION TIME LIMITS The following accumulation time limits must be adhered to for storing both hazardous waste and universal waste at Otterbein University: 5.1 Hazardous Waste The individual departments located within Otterbein University may accumulate waste as long as the volume is less than 55 gallons. If the volume exceeds this limit, the department must contact the CHO immediately to arrange for a waste removal, as the waste can only remain in the satellite area for 3 days. Once a container is full (55 gallons), the waste must be transported to the campus accumulation area (CAA), located at Room 313 in the Science Center. Once hazardous material is placed in the CAA, it will be dated with the day it was placed in the CAA and can be stored up to 180 days prior to being taken off site for proper disposal. The disposal will be arranged through the campus CHO. 5.2 Universal Waste

6 Otterbein University 4 Universal waste generated within Otterbein University will be managed by Services Department and stored within their department. As a Small Quantity Universal Waste Handler, Otterbein University may only accumulate universal waste for up to one year from the date of generation. See specific Universal Waste guidelines in Section 9.0 of this document. 5.3 Biological Waste Biological Waste generated within Otterbein University will be managed by the individual departments. All waste will be placed in appropriate Biohazard bags or biohazard-sharps containers and the CHO will be contacted for appropriate disposal. 6.0 GENERAL REQUIREMENT FOR HAZARDOUS WASTE Hazardous waste generated at Otterbein University must follow proper storage and handling to ensure personnel safety and compliance with appropriate regulations. The following guidelines must be followed when dealing with hazardous waste at Otterbein University: 1) If the type of waste generated is unknown, analytical testing must be completed to properly characterize the waste as hazardous. 2) All wastes generated per individual department are determined as hazardous waste or not at the point of generation and labeled accordingly. 3) Handlers will not dispose of hazardous wastes. 4) Handlers will not dilute or treat hazardous waste onsite with the exception of acids and bases which can be neutralized and poured down the acid trap drains. 5) Hazardous waste will be managed in a way that prevents a release of any component of the hazardous waste. 6) All containers used to store hazardous wastes will be: a. Closed at all times except when adding or removing wastes b. Compatible with the hazardous waste and its contents c. Free of defects, design characteristics or damage that would lead to leakage, spillage or other environmental releases 7) Hazardous waste must be stored to prevent potential reactions from occurring (i.e. ignitable and reactive). 8) Otterbein University s EPA indentation number is OHD DEPARTMENTAL HAZARDOUS WASTE GENERATORS Otterbein University generates a variety of hazardous wastes throughout its campus. The following are the individual departments and the types of hazardous waste generated:

7 Otterbein University Science Department (All Departments) Ignitable Wastes (Acetone, Toluene, Xylene, Alcohols, Hexanes) Corrosive Wastes (Acids Hydrochloric, Nitric, Sulfuric, Phosphoric; Alkalis Sodium Hydroxide, Potassium Hydroxide) Reactive Wastes (Sulfides, Cyanides, Sodium, Potassium) Toxic Wastes (Formaldehyde, Ethidium Bromide) Biological Wastes Generated wastes are stored (containerized and held) in each individual department, and then the Departmental Waste Representative will contact CHO for pick up and disposal coordination. Refer to Otterbein University s Chemical Hygiene Plan Section 18.0 for storage, controls, and hazards. 7.2 Art Department Scenic Studio (Only) Ignitable Wastes (Acetone, Toluene, Aerosol Cans, Paints) Corrosive Wastes (Etching Chemicals) Hold generated wastes in each individual department, and then the Departmental Waste Representative will contact CHO for pick up and disposal coordination. Refer to Otterbein University s Chemical Hygiene Plan Section 18.0 for storage, controls, and hazards. 7.3 Theater Department Ignitable Wastes (Acetone, Toluene, Paints) Hold generated wastes in each individual department, and then the Departmental Waste Representative will contact CHO for pick up and disposal coordination. Refer to Otterbein University s Chemical Hygiene Plan Section 18.0 for storage, controls, and hazards. 7.4 Service Department Ignitable Wastes (Acetone, Toluene, Aerosol Cans, Paints) Corrosive Wastes Hold generated wastes in each individual department, and then the Departmental Waste Representative will contact CHO for pick up and disposal coordination as needed. Universal waste and Recyclable materials are coordinated through the Service

8 Otterbein University 6 Department. Refer to Otterbein University s Chemical Hygiene Plan Section 18.0 for storage, controls, and hazards. 7.5 Athletics Department Biological Wastes (Sharps) Corrosive Wastes (Laundry Chemicals) Hold generated wastes in each individual department, and then the Departmental Waste Representative will contact CHO for pick up and disposal coordination. Refer to Otterbein University s Chemical Hygiene Plan Section 18.0 for storage, controls, and hazards. 7.6 Nursing Biological Wastes (Sharps) Hold generated wastes in each individual department, and then the Departmental Waste Representative will contact CHO for pick up and disposal coordination. Refer to Otterbein University s Chemical Hygiene Plan Section 18.0 for storage, controls, and hazards. 8.0 UNIVERSAL WASTE GUIDELINES AND DEPARTMENTAL GENERATORS The following are types of universal waste generated on Otterbein University s campus and the specific departments where they are generated. The guidelines outlined in the following points must be followed by all departments who generate universal wastes: 8.1 Discarded Batteries Each container holding batteries must be marked Universal Waste Batteries or Waste Batteries or Used Batteries or Non-Regulated RCRA Waste Batteries. NEVER mark containers as Hazardous Waste. All departments are responsible for collecting their own batteries as described below, and should hold their batteries in their areas until the last Friday of every month. On the last Friday of every month departments can bring them to the Service Department for proper disposal. A monthly notice will be sent for reminder. Sort batteries by type (i.e. alkaline, etc.) Keep containers closed except when batteries are being added or removed. Ensure the containers are structurally sound and compatible with the contents of the battery.

9 Otterbein University 7 Ensure the containers are in good condition and do not show signs of leaks, spills or damage. Ensure that the lithium battery terminals are taped off prior to shipment per Department of Transportation (DOT) regulation. Ensure that the transporter is qualified to transport waste batteries. Ensure that the batteries are sent to a facility that is permitted to recycle spent batteries. Departmental Generators: All Departments 8.2 Waste Lamps When a department has spent florescent bulbs for pick up, they can give them to the environmental cleaning service to be taken to the Service Department for proper disposal. Each container containing used lamps must be labeled as Universal Waste Lamp(s) or Waste Lamp(s) or Used Lamp(s). NEVER mark containers as Hazardous Waste. Avoid breaking lamps. Broken lamps may still be recycled depending on the recycling facility but broken lamps may lead to exposure to mercury. If a recycling facility will not accept broken bulbs, the bulbs must be evaluated to determine if they are hazardous waste. Place lamps in protective packaging so as to not release any of the possible contaminants contained in the lamp(s). If possible keep the original box the lamps came in. All broken bulbs should be stored in leak proof containers. Incandescent bulbs may be placed in the regular waste. Departmental Generators: All Departments 8.3 Mercury Containing Equipment Each container holding mercury containing equipment must be marked Universal Waste Mercury Containing Equipment or Waste Mercury Containing Equipment or Used Mercury Containing Equipment. In the event the device is a Mercury Containing Thermostat it should be labeled as such Universal Waste Mercury Thermostats or Waste Mercury Thermostats or Used Mercury Thermostats. NEVER mark containers as Hazardous Waste. Keep containers closed except when mercury containing equipment/thermostat are being added or removed. Ensure the containers are structurally sound and compatible with the contents of the mercury containing equipment/thermostat. Ensure the containers are in good condition and do not show signs of leaks, spills or damage.

10 Otterbein University 8 Do not remove mercury-containing ampules from universal waste mercurycontaining equipment. Ensure that the transporter is qualified to transport waste mercury containing equipment/thermostats. Ensure that the waste is being sent to a facility that is able to recycle the waste mercury containing equipment. Departmental Generators: Science Department (All Departments), Service Department. 8.4 Ballasts All ballasts should be considered to contain polychlorinated biphenyls (PCBs) unless they are clearly labeled Non-PCB-Containing. Ballasts that are assumed to contain PCBs should be placed in a DOTapproved drum that should be sent to a ballast recycling facility when full. Non PCB-containing ballasts should be sampled to determine whether they contain substances that would cause them to be regulated as hazardous waste. Departmental Generators: Science Department (All Departments), Theater Department, Service Department, Art Department, Nursing Department, Athletics Department 8.5 Pesticides Each container holding pesticide waste must be marked Universal Waste Pesticides or Waste Pesticides. NEVER mark containers as Hazardous Waste. Keep containers closed except when pesticide containers are being added or removed. Ensure the containers are structurally sound and compatible with the contents of the battery. Ensure the containers are in good condition and do not show signs of leaks, spills or damage. Ensure that the transporter is qualified to transport waste pesticide. Ensure that the pesticide is sent to a facility that is permitted to recycle spent pesticides. Departmental Generators: Service Department 9.0 PREPAREDNESS AND PREVENTION The following applies to the management of both hazardous and universal waste:

11 Otterbein University 9 1) The following equipment must be present in sufficient quantity to handle the amount of either hazardous or universal waste in each accumulation area: a. Portable fire extinguishers; b. Fire control equipment; c. Spill control equipment; d. Decontamination equipment. 2) Aisle space must be maintained to allow unobstructed movement of personnel, fire control equipment, spill control equipment, and decontamination equipment. 3) Emergency contact information must be posted at the telephone nearest to the accumulation site. Posted information should include: a. Spill control equipment available; b. Chemical Hygiene Officer s phone number, ; c. Security s phone number, ***-**** (or 911); d. Westerville Fire Department Station 111, located at 400 West Main Street, ***-**** (or 911); e. Westerville Police Department, phone number (or 911); f. Ohio Environmental Protection Agency Emergency Response Hotline,

12 Otterbein University INSPECTIONS 10.1 Hazardous Waste Inspection The campus accumulation area will be inspected weekly by designated personnel. A copy of each inspection form will be sent to the CHO for record keeping quarterly Universal Waste Inspection There are no inspection requirements for small quantity handlers of universal waste OFF-SITE SHIPMENT/TRANSPORTATION Hazardous and Universal waste may only be sent to a Transfer, Storage, Disposal, or Recycling facility. Prior to shipping the waste off-site, Otterbein University (generator) must obtain approval from the destination facility. All waste (both hazardous and universal) that meets the definition of a hazardous material under US Department of Transportation regulations must comply with all DOT requirements set forth in 49 CFR Otterbein University ensures that they will use a certified hazardous waste hauler RECORD KEEPING AND TRACKING 12.1 Hazardous Waste Small Quantity Hazardous Waste generators are required to keep records of the wastes that are generated onsite for a period of three (3) years. A copy of each signed uniform Hazardous Waste Manifest will be filed in a folder under the control of the CHO. Persons signing off on Hazardous Waste shipments must have documented training Universal Waste

13 Otterbein University 11 Small Quantity Universal Waste generators are not required to keep records of the wastes that are generated onsite. As a best practice, the Service Department will retain copies of all Bills of Lading and/or Manifests used for transporting Universal Wastes. A copy of each signed Bill of Lading or Manifest will be filed in a folder. Prior to March 1 st of each year, the Service Department will prepare a report of the amount of Universal Waste that was transported off site during the previous calendar year and submit it to the campus CHO. The report will include: (See Appendix 2) o The date of the shipment, o The type of universal waste shipped, o The amount of each waste shipped, o The name of the transporter, and o The name and location of the recycler receiving the waste 12.3 Biohazard Waste Otterbein University will keep all records of biological waste taken off site for disposal. As a best practice, Otterbein University s CHO will retain copies of all Bills of Lading and/or Manifests used for transporting Biohazard Wastes. A copy of each signed Bill of Lading or Manifest will be filed in a folder under the control of the CHO TRAINING The Chemical Hygiene or designee will train those dealing with wastes on the following: Proper waste identification (Hazardous, Universal, Biohazard, Solid, Recyclable) Proper storage containers and storage areas Proper segregation of wastes Proper use of spill control and clean-up for hazardous materials store and used on site Proper training on all applicable regulations

14 Otterbein University APPENDIX A 1. Definitions APPENDIX A Definitions Battery - This category includes hazardous waste batteries such as nickel-cadmium batteries and spent lead-acid batteries. The handler has the option of managing discarded lead-acid batteries under OAC Chapter (the UWR), or OAC rule UW batteries are defined in OAC rule (A) and OAC rule as devices consisting of one or more electrically connected electrochemical cells that are designed to receive, store and deliver electric energy. An electrochemical cell consists of an anode, cathode and electrolyte. A device is also considered a battery if it is intact, unbroken and the electrolyte has been removed. Lamps - This category includes hazardous waste lamps that meet the definition in OAC rule (A). Lamps are defined as the bulb or tube portion of an electric lighting device. A lamp is designed to produce radiant energy, most often in the ultraviolet, visible and infra-red regions of the electromagnetic spectrum. Lamps can exhibit the toxicity characteristic for some heavy metals (i.e., mercury, lead, cadmium). Examples of universal waste lamps include incandescent, fluorescent, high intensity discharge, neon, mercury vapor, and high pressure sodium and metal halide lamps. Container - means any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled. Destination Facility - means a facility that treats, disposes of, or recycles a particular category of universal waste, except those management activities described in paragraphs (A) and (C) of rule of the Administrative Code and in paragraphs (A) and (C) of rule of the Administrative Code. A facility at which a particular category of universal waste is only accumulated is not a destination facility for purposes of managing that category of universal waste. Generator - means any person, by site, whose act or process produces universal waste identified or listed in Chapter of the Administrative Code. Storage Means the holding of hazardous waste for a temporary period (180 days), prior to the end of the storage period the waste is removed and disposed. It also refers to the holding of universal waste for a temporary period (one year), at the end of which the universal waste is disposed of or stored elsewhere. Transportation - means the movement of hazardous waste or universal waste by air, rail, highway, or water.

15 Otterbein University 13 Universal Waste - means any of the following hazardous wastes that are managed under the universal waste requirements of Chapter of the Administrative Code: (1) Batteries as described in rule of the Administrative Code. (2) Lamps as described in rule of the Administrative Code. Universal Waste (UW) Handler - (a) Means: (i) A generator (as defined in this rule) of universal waste; or (ii) The owner or operator of a facility, including all contiguous property, that receives universal waste from other universal waste handlers, accumulates universal waste, and sends universal waste to another universal waste handler, to a destination facility, or to a foreign destination. (b) Does not mean: (i) A person who treats [except under the provisions of paragraph (A) or (C) of rule of the Administrative Code, or paragraph (A) or (C) of rule of the Administrative Code], disposes of, or recycles universal waste; or (ii) A person engaged in the off-site transportation of universal waste by air, rail, highway, or water, including a universal waste transfer facility. Handler Categories: UW handlers are classified into two categories based on the quantity of UW waste they accumulate at any time: Small quantity handlers [accumulate less than 5,000 kilograms (11,023 pounds) of UW (not by type) at any time], or Large quantity handlers [accumulate more than 5,000 kilograms (11,023 pounds) of UW (not by type) at any time]. If a small quantity UW handler accumulates more than 5,000 kilograms of UW on-site at any time, they must comply with the large quantity UW handler requirements for the remainder of the calendar year. All generators have the option of handling their UW under the UWR or under Ohio s hazardous waste generator requirements found in OAC Chapter Universal Waste Transporter - means a person engaged in the off-site transportation of universal waste by air, rail, highway, or water. Hazardous Waste - waste" which because of its quantity, concentration, or physical, chemical, or infectious characteristics may:

16 Otterbein University 14 Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored or disposed of, or otherwise mismanaged; or Cause or contribute to an increase in mortality, or an increase in irreversible or incapacitating illness.

17 Otterbein University 15 APPENDIX B Hazardous Waste Inspection Form

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