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Background

The Federal Resource Conservation and Recovery Act of 1976 sets strict standards for the “cradle-to-grave” management of hazardous wastes. These standards are written and enforced by the U. S. Environmental Protection Agency (EPA). The EPA has delegated to the Texas Commission on Environmental Quality (TCEQ) the responsibility of tracking hazardous waste generation and disposal within the state of Texas.

Hazardous wastes must be shipped by licensed waste transportation companies to permitted treatment, storage and disposal facilities. The regulations require the generator maintain detailed documentation concerning the generation, composition, and fate of all hazardous wastes.

In 1984, the Hazardous and Solid Waste Amendments to RCRA tightened the hazardous waste rules. It also brought the concept of waste minimization to the forefront as the preferred method of controlling hazardous waste production.

The following is a brief summary of TWU's Regulated Waste management program. A link to the full procedure can be found below.

Determining Which Wastes Are Regulated

Prior to disposal of any wastes, TWU personnel generating waste must determine (with assistance from Risk Management) whether the material meets the definition of a hazardous waste, or other regulated waste.

Hazardous Waste Determination

Hazardous Rag CanA material is "hazardous waste" if it meets one or more of the following:

  1. It is a material listed on the EPA Hazardous Waste Lists.
  2. It is a mixture or solution containing a listed material and a non-hazardous chemical.
  3. It has one or more of the following characteristics:
    • Ignitability (flashpoint <140 F or supports combustion);
    • Corrosivity (pH less than or equal to 2, or greater than or equal to 12.5);
    • Toxic (wastes that contain chemicals identified in the EPA Hazardous Waste Lists with waste codes D004-D043 in concentrations above certain regulatory limits. The concentration of these chemicals in a waste is determined through the “Toxicity Characteristic Leaching Procedure” or TCLP);
    • Reactivity (e.g., responds violently to air or water, cyanides, explosives, unstable chemicals);

Electronics are commonly overlooked as potential hazardous waste. Electronics regularly fail the TCLP testing due to the solder and other circuit board components. Therefore, TWU will assume that electronics are hazardous unless TCLP testing is conducted. However, many of the hazardous waste management rules do not apply to materials that are sent for recycling/reclamation. Contact Risk Management for additional assistance.

Other Regulated Waste

Even if a material is not determined to be a hazardous waste under EPA regulations, it may be regulated under Texas regulations or local landfill disposal prohibitions and need to be disposed of through a licensed facility.

In addition, waste streams that are non-hazardous and not regulated under the Texas rules, but contain any free liquids are not permitted to be disposed of as municipal waste (i.e. normal trash), and must be disposed of through Risk Management.

General Waste Disposal Procedure

All containers of Hazardous Waste or other regulated wastes must be labeled with the TWU Hazardous/Regulated Waste label when the first drop of waste is placed in the container:

Hazardous Waste Label

Wastes must be stored in appropriate containers which must remain closed at all times other than when waste is actively being added. Waste must also be segregated into appropriate hazard classes for storage.

Wastes must be transported off the Denton campus for disposal within 180 days of the date on the label. However, the label does not have to be dated as long as it is not moved out of the original location the waste was generated.

Contact Risk Management when you have containers that need to be removed from your area. Risk Management will also conduct a waste collection event at the end of each semester.

Universal Waste

Universal Waste is a category of hazardous waste that includes materials that are very common and represent a Universal Waste Labellower human health risk. The regulatory requirements for these materials have been reduced as a result. Materials that can be managed as universal waste include: 

  1. Batteries (that meet the hazardous waste criteria, other than lead-acid batteries that are being recycled)
  2. Pesticides
  3. Mercury Containing Equipment (such as thermometers and thermostats);
  4. Mercury Containing Lamps (e.g. fluorescent, mercury vapor, sodium vapor, and metal halide);
  5. Paint and Paint Related Material

Containers of universal waste do not have to use the Hazardous/Regulated Waste label above. However, the container does need to be dated with the date the first waste was placed in the container, and the phrase "Universal Waste" plus the type of waste (e.g. Universal Waste - Batteries).

Used Oil

Requirements for management of used oil are as follows: 

  1. Used Oil LabelContainers of used oil must be in good condition
  2. Containers must be labeled “Used Oil”
  3. Used oil must be disposed of via appropriately licensed used oil management firms
  4. Used oil must not be mixed with other wastes or it must be managed in accordance with the rules applicable to the other waste
  5. Additional requirements for oil (including used oil) management are listed in the TWU Spill Prevention, Control, and Countermeasures Plan.

Links

page updated 1/23/2014 1:56 PM

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