University of Kentucky
OP-25: Hazardous Waste Management

The University maintains a waste minimization process that assists in reducing the amount of waste generated and attempts to identify opportunities for recycling or beneficial reuse of material that otherwise would be disposed. This process encourages quantity and source reduction and in some cases sharing of chemical inventory which is facilitated by maintenance of a computer based chemical inventory system. Additionally, a campus initiative has established the use of "low mercury" fluorescent lamps, and electronic ballasts. The waste minimization process also encourages recycling, substitution of less toxic materials, and treatment to reduce the toxicity and quantity of generated waste requiring disposal as hazardous waste. The waste minimization process responsibilities are included as part of the required annual Hazardous Waste Management training. The Campus Recycling Department and the Environmental Management Department work closely to determine opportunities for recycling, resale, or reuse of commodities such as lead acid batteries, lead shielding from X-ray equipment, scrap metal sale, and recovery of mercury from some fluorescent lamps, and mercury containing devices. This is accomplished through commercial recycling and metal recovery firms, as well as a campus surplus group which manages occasional auctions of unneeded equipment and supplies.

The University maintains a robust process for managing all universal, hazardous, and non-regulated chemical wastes generated on campus as well as outlying facilities. This process is managed through the Environmental Management Department (EMD) which operates a permitted waste management facility on campus. Additionally, the EMD works collaboratively with the Campus Recycling Group to effectively manage universal waste and used oil. This facility, the Environmental Quality Management Center (EQMC), is staffed by environmental professionals who provide guidance across the campus community regarding regulatory requirements and waste management practices. These waste management strategies address regulated hazardous waste as well as non-regulated materials which have other hazardous chemical properties. Some key criteria of the process are: • Hazardous and non-regulated wastes generated in campus laboratories (Satellite Accumulation Areas) are managed and tracked through a web based system known as E-Trax. Personnel generating waste prepare waste cards for each container and submit pick up requests to the EMD. Personnel from EMD then pick up waste containers and transport them back to the EQMC for consolidation, neutralization, or disposal through a commercial, contracted waste disposal facility. All steps of the process adhere to the tracking, manifesting, and management requirements of the Resource, Conservation, and Recovery Act (RCRA) regulations. • All personnel generating or managing hazardous waste are required to complete initial and annual refresher training for Hazardous Waste Management. • The waste management strategies also encompass the Patient Care Facilities of UK Healthcare to collect and manage as hazardous waste any pharmaceuticals that meet the criteria as RCRA hazardous waste, or have similar properties, such as chemotherapy agents (RCRA equivalent). • Rechargeable batteries and other universal waste are managed collaboratively by the EMD and the Campus Recycling Group, are collected for recycling and management through a commercial recycling contractor to reprocess and recover the constituents of these materials and prevent disposal as hazardous waste. * Used oil is collected on campus in appropriate containers and then picked up by a commercial petroleum recycling firm.

There has been one reportable hazardous material release during the last three years, that being a release of approximately 900 gallons of fuel oil as a result of a damaged pipe during a construction project. The release was primarily contained on site with minimal environmental impact. The response and remediation was managed by the EMD with assistance from and environmental response contractor and with collaboration with the Kentucky Division of Waste Management, Underground Storage Tank Branch. The affected site remediation was completed to the satisfaction of the branch and a letter closing the incident was received.

The University uses a web based chemical inventory system, known as Chematix. The laboratories and chemical storage areas are set up in the system such that the materials present are barcoded, and the inventory is maintained “real time”. Authorized users of the system, including Principal Investigators, Laboratory Managers, and other laboratory personnel have access to this inventory system and are encouraged to review available inventory for possible sharing and reuse prior to ordering a new supply.

E-waste generated within the University system is coordinated through the IT Department and managed by the Campus Recycling Group. The units removed from service are prepared in accordance with the University’s established security protocols prior to any further management. After the security step electronic materials are offered for sale through the periodic campus surplus property auctions or are disposed through a contracted E-waste disposal contractor. The various components are then separated and shipped to downstream vendors for recycle and reuse.

The University maintains appropriate health and safety and environmental standards, managed by the Environmental, Health and Safety Division under direction given by the University’s Administrative Regulations (AR). This AR is supportive of OSHA and EPA requirements for worker safety and environmental protection. An e-waste contractor maintains certifications as a Responsible Recycler and under RIOS.