Overall Rating Bronze
Overall Score 27.31
Liaison Adam Strzemienski
Submission Date Dec. 21, 2019

STARS v2.2

University of North Georgia
OP-20: Hazardous Waste Management

Status Score Responsible Party
Complete 0.50 / 1.00
"---" indicates that no data was submitted for this field

Does the institution have strategies in place to safely dispose of all hazardous, special (e.g. coal ash), universal, and non-regulated chemical waste and seek to minimize the presence of these materials on campus?:
Yes

A brief description of steps taken to reduce hazardous, special (e.g. coal ash), universal, and non-regulated chemical waste:

Per policy:

Hazardous Waste Management
The two primary regulatory drivers for hazardous waste at USG institutions are the Resource Conservation and Recovery Act (RCRA) and the Georgia Environmental Protection Division (EPD) Rules for Hazardous Waste Management.
RCRA is a federal law that gave the U.S. Environmental Protection Agency the authority to implement regulations to control hazardous waste from the point of generation ("cradle") to its ultimate disposal point ("grave"). The waste generator is one of the principal parties responsible for meeting these regulations.
The Georgia EPD Rules for Hazardous Waste Management essentially adopt the federal RCRA regulations and are promulgated for the purpose of protecting and enhancing the quality of Georgia's environment and protecting the public health, safety and well-being of its citizens.
Identification of Hazardous Waste
The first step in the management of hazardous waste is to determine whether a material is a "waste" and whether it is "hazardous". Subsequent steps are used to properly classify the waste and determine the action necessary for proper management of the waste.
Simply defined, a hazardous waste is a material with properties that make it dangerous or capable of harming humans or the environment if not properly managed. Making the determination of whether a waste is hazardous is complicated and requires an extensive understanding of such information as the waste constituents, how it was generated, the material's chemical and physical characteristics, an understanding of EPA and GA EPD regulations, and experience classifying waste products.
Materials are usually considered "waste" when the generator has determined that the material has no further use and will be discarded. Hazardous waste regulations apply to any material that will be discarded, or will likely to be discarded. (The latter point is important because materials that have no further use and will eventually be discarded may be considered hazardous waste by regulatory agencies even though there are no current plans to discard the material. Therefore, it is imperative that the department of EH&S or the Hazardous Waste Coordinator be consulted if materials will be stored for long periods without use or if the use of a material is not anticipated for extended periods.)
Waste materials can be solid, liquid, semi-solid or compressed gas. All such materials must be evaluated to determine if the hazardous waste regulations apply.

Identification of Hazardous Waste
Listed Hazardous Waste
A material is considered to be a hazardous waste if the EPA or the State of Georgia specifically lists it as a hazardous waste.
Lists of hazardous wastes identified by the EPA are as follows:
• Source-specific list (e.g. wastes from petroleum refining, metal fabrication, etc.; these are often referred to as K-wastes)
• Non-source-specific list (e.g. degreasing solvents, etc.; these are often referred to as F-wastes)
• Discarded commercial chemical products and spill residues (these are often referred to as P- and U-wastes; P-wastes are also known as acutely hazardous waste.
Identification of Hazardous Waste
Characteristic Hazardous Waste
A material is also considered a hazardous waste if it meets certain characteristics. The characteristics include the following:
• Ignitability
o A liquid that has a flash point of less than 140°F.
o A solid that is capable of causing fire through friction or absorption of moisture, or can undergo spontaneous chemical change that can result in vigorous and persistent burning.
o A substance that is an ignitable compressed gas or oxidizer.
• Corrosivity
o An aqueous solution that has a pH less than or equal to 2.0 or greater than or equal to 12.5.
• Reactivity
o A material that is normally unstable or undergoes violent chemical change without detonating.
o A material that can react violently with water to form potentially explosive mixtures or can generate dangerous or possibly lethal gases (cyanide or sulfide bearing).
o A material capable of detonation or explosive reaction.
• Toxicity (Please see the next page for defining criteria of a toxic waste.)
Two methods can be used to determine if the waste exhibits hazardous "characteristics". These include (1) testing or (2) applying "generator knowledge". Testing must be done following strict regulatory protocols established by the GA EPD or EPA. Generator knowledge involves applying an understanding of the hazardous nature or characteristics of the waste based on the materials or processes used to generate the waste.
Determining Hazardous Waste Generator Status
The next step in the management of hazardous waste is to determine the institution's "generator classification". Each generator category has specific generation, accumulation and storage requirements and corresponding time limits. Knowledge of the generator category enables the institution to ensure that the quantity of waste generated, how the waste is accumulated, and storage time limits, comply with EPA / GA EPD requirements. The following outlines the three generator categories:
Conditionally Exempt Small Quantity Generator (CESQG)
This is the most desirable category due to the fact that fewer regulatory requirements apply. This category applies to a generator of hazardous waste that generates less than 100 kilograms (220 lbs) of hazardous waste and less than one (1) kilogram (2.2 lbs) of acutely hazardous waste (P-wastes) per calendar month.
Small Quantity Generator (SQG)
This category applies to a generator of hazardous waste that generates more than 100 kilograms (220 lbs), but less than 1,000 kilograms (2,200 lbs) of hazardous waste and less than 1 kilogram (2.2 lbs) of acutely hazardous waste (P-wastes) per calendar month.
Large Quantity Generator (LQG)
This category applies to a generator of hazardous waste that generates more than 1,000 kilograms (2,200 lbs) of hazardous waste OR greater than 1 kilogram (2.2 lbs) of acutely hazardous waste (P-wastes) per calendar month.
Hazardous Waste Generator Identification Number
The EPA requires all hazardous waste generators to register their generator status by obtaining an EPA identification number. This number is used to track waste from generation to ultimate disposal, and beyond. Each institution in the USG must obtain an EPA ID number before treating, storing, disposing, or transporting (or offering for transport) hazardous waste. EPA ID numbers are site-specific numbers assigned to generators, transporters, and TSDFs and need only be obtained once.
Each EPA ID number consists of three letters and nine digits. The first two letters are simply the two-letter abbreviation for the state in which the facility is located. The third letter is either a "D" for facilities with permanent ID numbers or a "T" for a facility with a temporary number. A nine-digit number, uniquely associated with each site, follows the three letters.
Common Areas on Campus Generating Hazardous Waste
Areas where hazardous wastes may be generated on campus might include, but are not limited to, the following:
• Science Labs (i.e. spent or expired chemicals from chemistry, biology or other labs; abandoned compressed gases, etc.)
• Art Departments (i.e. paints, thinners, photo developing chemicals, glazes, contaminated brushes/rags, etc. )
• Physical Plant Shops (i.e. paints, thinners, solvents, certain pressurized aerosol spray cans, spent fuels, spent mercury-containing fluorescent lamps, unless properly recycled, which is discussed later in this manual.)
• Automotive Shops (i.e. spent solvents, degreasers, antifreeze, lead acid batteries, oil spill cleanup residue, etc.)
• Other Areas (i.e. wastes generated from research and teaching processes in schools of pharmacy, medicine, dentistry, veterinary medicine, etc.)

• Hazardous Waste Accumulation

• Hazardous waste should be temporarily staged in Satellite Accumulation Areas (SAA). Satellite accumulation is the temporary storage of hazardous waste at or near the initial point of generation of the hazardous waste. "At or near the point of generation" means that the SAA shall be located in the same or adjacent room or work area and shall be under the control of the generator. RCRA regulations governing the management of hazardous wastes allow the accumulation of up to 55 gallons of hazardous waste or one quart of acutely hazardous waste for up to one year at or near the point of generation without obtaining a permit.
• Each waste container in the SAA shall have an appropriate label identifying it as hazardous waste, radioactive waste, or mixed waste. When waste is first placed in a container, the waste generator shall record the accumulation start date on the label.
• When a container is full or has reached the allowable time limit, the container must be moved to a central accumulation area or disposed of within three (3) days.

• Hazardous Waste Disposal

• When contracting for hazardous waste disposal services, it is critical for USG institutions to contract with reputable, qualified and permitted vendors for hazardous waste packaging, transportation and disposal services. As the generator, the institution is responsible for the waste even after it has been taken to the final disposal location. USG institutions in the CESQG or SQG category should generally arrange for hazardous waste pick-up and disposal services at least twice a year since the maximum allowable storage time for full containers is 180 days (while mandatory for SQGs, this is a recommended practice for CESQGs). LQGs will need to arrange for more frequent pick-up and disposal services (perhaps monthly, bi-monthly or quarterly).


A brief description of how the institution safely disposes of hazardous, universal, and non-regulated chemical waste:

Per policy:

Universal Waste Management

EMS Universal Waste:

2.2.2

Effective Date:

04/30/2013

Reviewed/ Revised:

Subject:

Universal Waste Management

Introduction

The Environmental Protection Agency (EPA) enacted the Federal “Universal Waste Rule” to simplify the requirements for some wastes that would otherwise be subject to the EPA’s full hazardous waste procedures. The College’s universal waste disposal procedure will reduce the volume of hazardous waste in municipal waste facilities by managing these wastes.

The departments of Environmental Health & Safety and Facilities Management will oversee the management of the University’s universal waste disposal procedure to ensure compliance with all regulations. This procedure is designed to provide information to the University’s personnel on the requirements for implementing the procedures.

The University is a small quantity handler of universal waste and can accumulate up to 5000kg of waste at any one time. The storage time for this waste is limited to one year. Universal wastes must be managed in a way that prevents the release of hazardous components to the environment. As a handler of waste the College cannot treat or directly dispose of universal wastes.

Types of Universal Waste

• Hazardous waste batteries – nickel cadmium (NiCd), lithium and mercury containing button batteries. Lead Acid batteries are not required to be managed as universal waste if they are intact and are to be recycled through a distributor. Otherwise they must be managed as universal waste or as hazardous waste if leaking (contact EHS 309-0027).

• Hazardous waste lamps – these bulbs may include fluorescent, high intensity discharge, mercury vapor, neon, incandescent, metal halide and high pressure sodium lamps. It is prohibited to crush lamps. Accidentally broken lamps must be stored in a separately closed container to prevent the release of mercury or lead to the environment. See below.

• Hazardous waste mercury containing equipment – devices such as thermostats and thermometers. If leaking, the equipment must be managed as hazardous waste (contact EHS 309-0027).

• Hazardous waste pesticides – recalled or unused pesticides.

Universal Waste Storage Procedures

I. Batteries

1. Collect in a cardboard box or plastic container.

2. If a battery is leaking or damaged – seal it in a plastic bag before placing it in the

accumulation container.

3. Label the container with the words “Universal Waste – Batteries”.

4. Date the container with the date you start accumulation.

II. Mercury Thermostats

1. Collect in a cardboard box or plastic container.

2. If a thermostat is cracked or damaged – seal it in a plastic bag before placing it in

the accumulation container.

3. Label the container with the words “Universal Waste – Thermostats”.

4. Date the container with the date you start accumulation.

III. Pesticides

1. If a container of pesticide is not used until empty and is no longer needed it must

be disposed as Universal Waste.

2. If the original container is leaking or damaged - place it in a secondary plastic

container and keep the container closed.

3. Label the container with the words “Universal Waste – Pesticides”.

4. Date the container with the date that it is determined to be waste.

IV. Lamps

1. See form 2.2.2.1. Procedure for Universal Waste Lamps form


A brief description of any significant hazardous material release incidents during the previous three years, including volume, impact and response/remediation:

Unknown


A brief description of any inventory system employed by the institution to facilitate the reuse or redistribution of laboratory chemicals:

Hazardous Waste Management
The two primary regulatory drivers for hazardous waste at USG institutions are the Resource Conservation and Recovery Act (RCRA) and the Georgia Environmental Protection Division (EPD) Rules for Hazardous Waste Management.
RCRA is a federal law that gave the U.S. Environmental Protection Agency the authority to implement regulations to control hazardous waste from the point of generation ("cradle") to its ultimate disposal point ("grave"). The waste generator is one of the principal parties responsible for meeting these regulations.
The Georgia EPD Rules for Hazardous Waste Management essentially adopt the federal RCRA regulations and are promulgated for the purpose of protecting and enhancing the quality of Georgia's environment and protecting the public health, safety and well-being of its citizens.
Identification of Hazardous Waste
The first step in the management of hazardous waste is to determine whether a material is a "waste" and whether it is "hazardous". Subsequent steps are used to properly classify the waste and determine the action necessary for proper management of the waste.
Simply defined, a hazardous waste is a material with properties that make it dangerous or capable of harming humans or the environment if not properly managed. Making the determination of whether a waste is hazardous is complicated and requires an extensive understanding of such information as the waste constituents, how it was generated, the material's chemical and physical characteristics, an understanding of EPA and GA EPD regulations, and experience classifying waste products.
Materials are usually considered "waste" when the generator has determined that the material has no further use and will be discarded. Hazardous waste regulations apply to any material that will be discarded, or will likely to be discarded. (The latter point is important because materials that have no further use and will eventually be discarded may be considered hazardous waste by regulatory agencies even though there are no current plans to discard the material. Therefore, it is imperative that the department of EH&S or the Hazardous Waste Coordinator be consulted if materials will be stored for long periods without use or if the use of a material is not anticipated for extended periods.)
Waste materials can be solid, liquid, semi-solid or compressed gas. All such materials must be evaluated to determine if the hazardous waste regulations apply.

Identification of Hazardous Waste
Listed Hazardous Waste
A material is considered to be a hazardous waste if the EPA or the State of Georgia specifically lists it as a hazardous waste.
Lists of hazardous wastes identified by the EPA are as follows:
• Source-specific list (e.g. wastes from petroleum refining, metal fabrication, etc.; these are often referred to as K-wastes)
• Non-source-specific list (e.g. degreasing solvents, etc.; these are often referred to as F-wastes)
• Discarded commercial chemical products and spill residues (these are often referred to as P- and U-wastes; P-wastes are also known as acutely hazardous waste.
Identification of Hazardous Waste
Characteristic Hazardous Waste
A material is also considered a hazardous waste if it meets certain characteristics. The characteristics include the following:
• Ignitability
o A liquid that has a flash point of less than 140°F.
o A solid that is capable of causing fire through friction or absorption of moisture, or can undergo spontaneous chemical change that can result in vigorous and persistent burning.
o A substance that is an ignitable compressed gas or oxidizer.
• Corrosivity
o An aqueous solution that has a pH less than or equal to 2.0 or greater than or equal to 12.5.
• Reactivity
o A material that is normally unstable or undergoes violent chemical change without detonating.
o A material that can react violently with water to form potentially explosive mixtures or can generate dangerous or possibly lethal gases (cyanide or sulfide bearing).
o A material capable of detonation or explosive reaction.
• Toxicity (Please see the next page for defining criteria of a toxic waste.)
Two methods can be used to determine if the waste exhibits hazardous "characteristics". These include (1) testing or (2) applying "generator knowledge". Testing must be done following strict regulatory protocols established by the GA EPD or EPA. Generator knowledge involves applying an understanding of the hazardous nature or characteristics of the waste based on the materials or processes used to generate the waste.
Determining Hazardous Waste Generator Status
The next step in the management of hazardous waste is to determine the institution's "generator classification". Each generator category has specific generation, accumulation and storage requirements and corresponding time limits. Knowledge of the generator category enables the institution to ensure that the quantity of waste generated, how the waste is accumulated, and storage time limits, comply with EPA / GA EPD requirements. The following outlines the three generator categories:
Conditionally Exempt Small Quantity Generator (CESQG)
This is the most desirable category due to the fact that fewer regulatory requirements apply. This category applies to a generator of hazardous waste that generates less than 100 kilograms (220 lbs) of hazardous waste and less than one (1) kilogram (2.2 lbs) of acutely hazardous waste (P-wastes) per calendar month.
Small Quantity Generator (SQG)
This category applies to a generator of hazardous waste that generates more than 100 kilograms (220 lbs), but less than 1,000 kilograms (2,200 lbs) of hazardous waste and less than 1 kilogram (2.2 lbs) of acutely hazardous waste (P-wastes) per calendar month.
Large Quantity Generator (LQG)
This category applies to a generator of hazardous waste that generates more than 1,000 kilograms (2,200 lbs) of hazardous waste OR greater than 1 kilogram (2.2 lbs) of acutely hazardous waste (P-wastes) per calendar month.
Hazardous Waste Generator Identification Number
The EPA requires all hazardous waste generators to register their generator status by obtaining an EPA identification number. This number is used to track waste from generation to ultimate disposal, and beyond. Each institution in the USG must obtain an EPA ID number before treating, storing, disposing, or transporting (or offering for transport) hazardous waste. EPA ID numbers are site-specific numbers assigned to generators, transporters, and TSDFs and need only be obtained once.
Each EPA ID number consists of three letters and nine digits. The first two letters are simply the two-letter abbreviation for the state in which the facility is located. The third letter is either a "D" for facilities with permanent ID numbers or a "T" for a facility with a temporary number. A nine-digit number, uniquely associated with each site, follows the three letters.
Common Areas on Campus Generating Hazardous Waste
Areas where hazardous wastes may be generated on campus might include, but are not limited to, the following:
• Science Labs (i.e. spent or expired chemicals from chemistry, biology or other labs; abandoned compressed gases, etc.)
• Art Departments (i.e. paints, thinners, photo developing chemicals, glazes, contaminated brushes/rags, etc. )
• Physical Plant Shops (i.e. paints, thinners, solvents, certain pressurized aerosol spray cans, spent fuels, spent mercury-containing fluorescent lamps, unless properly recycled, which is discussed later in this manual.)
• Automotive Shops (i.e. spent solvents, degreasers, antifreeze, lead acid batteries, oil spill cleanup residue, etc.)
• Other Areas (i.e. wastes generated from research and teaching processes in schools of pharmacy, medicine, dentistry, veterinary medicine, etc.)

• Hazardous Waste Accumulation

• Hazardous waste should be temporarily staged in Satellite Accumulation Areas (SAA). Satellite accumulation is the temporary storage of hazardous waste at or near the initial point of generation of the hazardous waste. "At or near the point of generation" means that the SAA shall be located in the same or adjacent room or work area and shall be under the control of the generator. RCRA regulations governing the management of hazardous wastes allow the accumulation of up to 55 gallons of hazardous waste or one quart of acutely hazardous waste for up to one year at or near the point of generation without obtaining a permit.
• Each waste container in the SAA shall have an appropriate label identifying it as hazardous waste, radioactive waste, or mixed waste. When waste is first placed in a container, the waste generator shall record the accumulation start date on the label.
• When a container is full or has reached the allowable time limit, the container must be moved to a central accumulation area or disposed of within three (3) days.

• Hazardous Waste Disposal

• When contracting for hazardous waste disposal services, it is critical for USG institutions to contract with reputable, qualified and permitted vendors for hazardous waste packaging, transportation and disposal services. As the generator, the institution is responsible for the waste even after it has been taken to the final disposal location. USG institutions in the CESQG or SQG category should generally arrange for hazardous waste pick-up and disposal services at least twice a year since the maximum allowable storage time for full containers is 180 days (while mandatory for SQGs, this is a recommended practice for CESQGs). LQGs will need to arrange for more frequent pick-up and disposal services (perhaps monthly, bi-monthly or quarterly).


Does the institution have or participate in a program to responsibly recycle, reuse, and/or refurbish electronic waste generated by the institution?:
Yes

Does the institution have or participate in a program to responsibly recycle, reuse, and/or refurbish electronic waste generated by students?:
Yes

A brief description of the electronic waste recycling program(s), including information about how electronic waste generated by the institution and/or students is recycled:

All batteries and electronics are sent to IT to be recycled if possible.


Is the institution’s electronic waste recycler certified under the e-Stewards and/or Responsible Recycling (R2) standards?:
---

Website URL where information about the institution’s hazardous waste program is available:
---

Additional documentation to support the submission:

UNG Environmental Health & Safety Specialist
Steve Thellman
steve.thellman@ung.edu
6787173434

The information presented here is self-reported. While AASHE staff review portions of all STARS reports and institutions are welcome to seek additional forms of review, the data in STARS reports are not verified by AASHE. If you believe any of this information is erroneous or inconsistent with credit criteria, please review the process for inquiring about the information reported by an institution and complete the Data Inquiry Form.