West Virginia University
OP-20: Hazardous Waste Management

The West Virginia University Environmental Health and Safety (EH&S) Hazardous Materials Unit (HMU) has taken many steps to reduce waste. Three relatively new programs and services that are all unique in their own way are perfect examples of how WVU’s HMU continues to find new ways to improve waste minimization.

Efficient non-hazardous parts washer solvent
This program was to establish an in-house parts washer solvent substitute cleaning service. Previously this service was contracted out to a vendor whose parts washers generated a hazardous waste. In addition, service intervals had been predetermined and incorporated into the service agreements which often times the parts washer solvent wasn't dirty enough to warrant a solvent change. The HMU found an effective cleaning solvent substitute that produces a non-hazardous waste and it’s suitable for adding to the used oil recycling collection at no cost to the University. All parts washers are now WVU owned, serviced upon request only, and generate a recyclable non-hazardous spent solvent.

Aerosol can puncturing stations
To reduce the aerosol can hazardous waste stream, the university purchased thirty aerosol-puncturing systems. These have been installed in common areas accessible to almost anyone who may use an aerosol can product. Intact aerosol cans are regulated as hazardous waste in West Virginia. Once punctured, the metal cans are empty and can be managed as recyclable metal, then only the hazardous constituents drained from the cans need to be managed as hazardous waste. Users of the aerosol-puncturing systems receive annual safety training on proper use of the systems. Prior to the puncturing systems being installed it was common to ship one or more 55-gallon drums of aerosol cans a month. Now with the puncturing systems in service they rarely ship a 30-gallon drum of the liquid hazardous constituents drained from aerosol cans.

WVU rifle team lead waste reduction measures
The HMU developed and implemented a plan to include air sampling, collection and lab analysis of multiple waste samples and a thorough review of site activities. Brass from bullets is now processed by screen sifting to remove most of the lead dust and black powder resulting in an ignitable toxic hazardous waste. The bulk of the waste weight is brass, which having been processed, is now excluded from hazardous waste regulations and managed as scrap metal that does not count towards total hazardous waste generated. The rubber in the back stop historically was periodically replaced with new rubber and the spent rubber and lead projectiles were disposed of as hazardous waste. Implementation of an on-site separation process to separate lead from the rubber greatly reduced the weight of the lead contaminated rubber shipped off-site for disposal as hazardous waste.

Reusable Shop Towels
WVU has eliminated potentially solvent-contaminated shop towels from entering the hazardous waste stream. The weight of nearly 6,000 soiled shop towels has been removed from the monthly totals of hazardous waste generated by sending these towels out for laundering service. 3,000 dirty shop towels are removed from facilities maintenance, academic shops, and art studios on a bi-weekly basis to be washed and brought back for repeated use.

WVU is committed to ensuring proper disposal of hazardous, universal and non-regulated chemical wastes. To receive waste management services a user simply needs to complete a chemical disposal request form and e-mail it to EHS_Chemicals@mail.wvu.edu. All requests from the main campus are completed within 5 business days. WVU’s Waste Management Program includes standard operating procedures to properly handle and dispose of such waste incompliance with the Resource Conservation Recovery Act (RCRA) and has a contracted vendor collect and dispose of these items. WVU also has a program for universal waste like mercury containing devices, fluorescent lamps and select batteries.

The Mercury Thermometer Exchange Program was instituted in 2014. The program replaces potentially harmful mercury-containing thermometers with more environmentally friendly non-mercury devices at no cost to the department. The user picks their new device from the catalog and provides this information to HMU who orders the new device. Upon delivery of the new device, the lab surrenders the mercury containing device, so they are never without the needed equipment. This program has been such a success that it has been expanded to include barometers, manometers and other mercury devices as well. Since the inception of the Mercury Exchange Program, WVU has removed 3,037 mercury-containing devices from campus. The success of this program has resulted in very few mercury-containing devices present on campus. Only 19 devices were exchanged in 2019.

In accordance with RCRA regulations, the mercury-containing fluorescent lamps are collected and placed into boxes labeled “Used Lamps” and dated when the first lamp goes into the box. Most of the used lamps generated by facilities management on the main campus are taken to one of three warehouse locations for accumulation prior to shipment. Used lamps are picked up by HMU upon request and transported to one of the warehouses. All used fluorescent lamps, and some high intensity and specialty lamps known to contain heavy metals, are routinely shipped to a contracted lamp recycling vendor who issues WVU a recycling certificate upon completion. Shipment intervals are based on volume in the warehouse accumulation area but on an average, there are 2-3 outbound shipments each month. In 2019, 31,177 lamps were sent for recycling.

WVU provides battery recycling services. Upon request HMU will pick up universal waste batteries and lead acid batteries from all WVU entities. The lead acid batteries that are not returned for their core value when new batteries are purchased, are managed under 40 CFR Part 266. In 2019, 6,256 pounds of lead-acid batteries were transported by HMU to a local metal recycler and significantly reduced the weight from the universal waste stream. Universal waste batteries are managed in accordance with 40 CFR Part 273. The prepaid Big Green Box program is utilized for recycling these batteries. In 2019, WVU shipped 258 pounds of rechargeable universal waste batteries off site for recycling. This weight included items containing Lithium, Li Ion, NiCad, NiMH, batteries.

WVU has not had any significant hazardous material releases in the past three years. Some minor spills have occurred. All laboratories, shops, fueling stations, and central accumulation areas are equipped with spill kits. Spill kits are made in-house and provided free of charge upon request. WVU’s Environmental Health and Safety department has several Certified Hazardous Materials Technicians on staff capable of responding to incidents on campus. These individuals and Hazardous Materials Technicians in the WVU Police Department train together and do annual exercises together forming an even larger in-house hazardous materials incident response team for WVU. That team, as well as City fire officials and the County Hazardous Incident Response Team (HIRT) stand ready to respond to any hazardous material release that may occur on WVU’s Campus.

Educating Chemical Hygiene Officers (CHO), Lab Managers, Department Chairs, and researchers on the benefits of being a Very Small or Small Quantity Generator vs. a Large Quantity Generator of hazardous waste contributed to formalizing redistribution programs on WVU’s main campus. The HMU makes every effort to redistribute products on campus to other labs or shops who can use them. Unwanted chemical products were a large part of the total hazardous waste generated at the Statler College of Engineering. WVU’S EH&S encouraged the college to dedicate the resources necessary for a Central Chemical Stock Room to receive unwanted chemicals and make them available to anyone in the College who has a use for them to prevent these chemicals from automatically becoming waste. If chemicals remain in the Central Stock Room for an extended period of time, EH&S is contacted and asked to begin re-homing the items to other colleges. College of Engineering was a Large Quantity Generator of hazardous waste, however after establishing a central stock room, this site consistently stays within the limits of a Small Quantity Generator for the past two years. The CHO for the Davis College of Agriculture combines all chemical inventories into a single master sheet. When a researcher needs a small quantity of a chemical, they can request a search to see who might have some and eliminate the need to purchase more of the same chemical. Laboratory close-outs produce most of the unused chemical product waste. Working closely with the various departments to modify their lab close-out procedures to include opportunities for other researchers to see if there are any chemicals available to use, has reduced this waste stream. Further reduction has been achieved when the opportunity is expanded to include any researcher within the college. If there are still good, unused chemical products remaining once the HMU receives the waste pick-up request for the lab clean-out, HMU photographs the chemicals and attempts to re-home them in other colleges.

WVU offers electronic recycling services for both the institution and its students. When university-owned electronics become obsolete or broken, items are removed from their current location and delivered to one of six locked temporary staging areas on campus. Twice a month WVU’s contracted electronics recycling vendor removes the items from all staging areas located on campus and are delivered to their facility for receiving, sorting, dismantling, refurbishment, resale and recycling. In addition, WVU hosts an annual personally owned electronics recycling program for its students and employees. Set up in a similar design, WVU’s contracted electronics recycling vendor creates a staging area where items are sorted by like commodities and then processed at their facility.