Satellite Accumulation Area (SAA)4Ls –(Lids, Leaks, Labels and Location)

Rich Miller

UNC-Chapel Hill

Sept. 13, 2005

rich_miller@unc.edu

ehs.unc.edu

The Journey

UNC- Environmental Affairs Section

Environmental Affairs ManagerRichard Miller, Ph.D.

Environmental SpecialistLarry Daw, L.G.

Environmental SpecialistSharon Myers, L.G.

Safety OfficerMike Long

Hazardous Materials ManagerSteve Parker, CHMM

Hazardous Waste ChemistRay Bond

Hazardous Materials TechnicianRoger ConnorShawn StaudtDaryle White

Maine College fined for Violating Hazardous Waste Laws - $107,165

According to the complaint, waste glaze and related floor sweepings were put in the trash or washed down the sink, and acid pickling solution neutralized with marble was washed down the sink. In addition, cans of old waste paint, metal blasting debris and paint thinners and other solvents were managed improperly. Also, the college, which has 400 students, improperly stored and labeled fluorescent bulbs and computer monitors, EPA said.

As a result of the inspection at MCA in April 2004, EPA observed other hazardous waste management violations, such as improperly labeling containers, failing to obtain a site-specific hazardous waste generator identification number, failing to provide containment around containers in case of spills, and failing to keep containers of hazardous waste closed.

According to the complaint, Maine College of Art must comply with federal hazardous waste regulations and correct all violations. In addition, the college must comply with Maine hazardous waste regulations related to fluorescent bulbs and computer monitors, which are known as "universal wastes." The school must submit documents showing compliance.

Regulations – 40CFR 262.34 (c )(1)

262.34 (c)(1) A generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in 261.33(e) in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or interim status and without complying with paragraph (a) {accumulation time} of this section provided he:

(i) Complies with Sections 265.171,265.172 and 265.173(a) of this chapter; and(ii) Marks his containers EITHER with the words “Hazardous Waste”OR with other words that identify the contents of the containers.

Regulations – 40 CFR 265.171,172, 173(a)

265.171 Conditions of containers. If a container holding a hazardous waste is not in good condition or if it begins to leak, the owner or operator must transfer the hazardous waste from this container to a container that is in good condition ….

265.172 Compatibility of waste with containers. The owner or operator must use a container made of or lined with materials which will not react with and are otherwise compatible with the hazardous waste to be stored, so that the ability of the container to contain the waste is not impaired.

265.173(a) Management of containers. (a) A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste.

4 Ls

LIDS, LABELS, LEAKS & LOCATION

The most commonly cited violations of hazardous waste/hazardous materials regulations are: open containers or lids not screwed-on tight; improper labels/identification; lack of secondary containment, and waste storage location. What may seem as a relatively minor violation has resulted in fines of several thousands of dollars per violation. Observing these simple practices can keep your College or University in compliance.

4Ls

LIDS Lids/caps must be securely in-place except when material is

being removed or added to the container. A funnel resting on the mouth of a bottle does not constitute a lid, even when a watchglass is used. Lids/caps on waste containers must be tight (note: be sure that gas producing reactions, e.g., organics in acids, have worked to completion before transferring the material to a hazardous waste container). A good rule of thumb is: A closed container, when tipped over, won’t leak.

LABELS OSHA regulations require that the name of the chemical be

clearly identified. Chemical formulas and abbreviations, such as H2SO4, HCl, EtBr, ETOH, etc., are not acceptable.

Hazardous Waste regulations require the words “Hazardous Waste” on waste containers or words which identify the contents, e.g., “Acetone Waste”.

4Ls

LEAKS

Secondary containment is to be used to minimize the potential for breakage and to minimize the consequences in the event of breakage. Without exception, secondary containment is required for the following:

all glass containers of liquid hazardous materials stored on the floor.

all containers, with capacity of 4 liters, of liquid hazardous waste, regardless of storage location

In general, secondary containment is to be used as a means of preventing incompatible materials from interacting in the event of breakage and/or spillage of hazardous materials. For example, acid baths are to be provided with secondary containment. Hazardous materials are to be segregated by hazard class and stored in separate cabinets, trays, or pans.

4Ls

LOCATION

Hazardous waste regulations require that the generator accumulatehazardous waste in containers (properly closed, labeled, and less than 55 total gallons) at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste. Wastes cannot be stored in a separate room or down the hall.

Frisbee rule

Examples SAAs on campus

Environmental Safety Fact Sheets

Laboratories

Clean Up of Laboratory Chemical Spills Decontamination and Disposal of Infectious Waste Disposal of Laboratory Sharps Ethidium Bromide Disposal Hydrofluoric Acid Laboratory Safety Data Sheets Reducing Mercury Use in Laboratories

Environmental Safety Fact Sheets

Shops and Maintenance

Absorbent Antifreeze Aerosol Spray Cans Asbestos Brake and Carburetor Cleaner Caustic Degreaser Solutions Freon Lead Acid Batteries Parts Washers Oil Filters Paint Shop Rags Lead Solder Solvent

Environmental Safety Fact Sheets

Housekeeping

Floor Cleaning Wash Water

Offices and Elsewhere

Dry Cell Batteries Fluorescent Tubes Photographic Waste Used Oil

Satellite Accumulation Area (SAA)4Ls –(Lids, Leaks, Labels and Location)

Where do I go from here??

Back on campus – circle the wagons and determine if 4Ls are in place – labs, shops, art department - took at MSDS

Talk to your administration ($$), other colleges, and your local regulator

Ask for assistance, attend DENR seminar ehs.unc.edu. – shop talks & other information