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ONLINE SELF-STUDY
Hazardous Waste Management on Construction Sites at UNC-CH
Clear understanding of the responsibilities of waste management at a construction site.
Demonstrate the proper methods of hazardous waste management for compliance with state and federal regulations.
Generate awareness to avoid potential illegal shipments of waste.
Be properly prepared for potential inspection by state and/or federal inspectors.
Training Goals
Hazardous Waste
Waste that poses a threat to the environment or
human health if not handled or disposed of
properly.
Resource Conservation and Recovery Act (RCRA)
passed in 1976:
Called for the establishment of regulations.
Directed by the Environmental Protection Agency (EPA)
to regulate proper management of hazardous wastes.
Defined characteristics of Solid and Hazardous Waste.
“Cradle to Grave”
EPA’s comprehensive system of regulations.
Governs the following hazardous waste
management activities:
Generation
Transportation
Treatment
Storage
Disposal
Responsibilities of UNC-CH
EPA views UNC as a large quantity hazardous
waste generator.
Generators such as UNC are responsible for
properly identifying hazardous waste and proper
management of hazardous waste (use, storage and
disposal).
From the “cradle” (point of generation) to the
“grave” (point of disposal and beyond).
UNC is ultimately responsible for all waste.
EPA Fines for Non-compliance
The EPA does impose fines against universities and
colleges.
Recent examples include:
Boston University - $800,000
Penn State - $1 million
UC Berkeley - $1 million
Stanford University - $1 million
UNC-Chapel Hill - $75,000
Most Common EPA HW
Management Violations
Most commonly cited EPA violations of hazardous waste regulations are:
Open containers or lids not on tight
Improper labels/identification
Lack of secondary containment
Hazardous waste storage location
The 4L’s – Lids, Leaks, Labels, and Location
Covered in the Construction Guidelines in Chapter IV, Section B, Item 6 of the Supplemental Guidelines. http://www.eis.facilities.unc.edu/DesignGuidelines.aspx
Lids
Are all containers labeled as hazardous waste
closed and secured with proper lids?
Lids on drums must be closed and latched unless adding
material.
Boxes of lamps must be closed unless adding material.
A closed container, when tipped over, won’t leak!
Lids
Incorrect – Open Container Correct – Sealed Container
Lids
Incorrect – No Container
Correct – Sealed and Labeled Containers
Leaks
Are containers compatible with the waste being
stored?
Are containers stored in a manner to prevent
leaks or spillage?
Leaks
Incorrect - Incompatible or
Leaking Container
Correct – Closed, Labeled,
and stored to prevent Leaks
Labels
Are all containers labeled as hazardous waste
properly labeled?
Hazardous waste regulations require the words
“Hazardous Waste”, or words which clearly identify the
contents such as “Acetone Waste”, be on each waste
container in Satellite Accumulation Areas.
Labels
Location
Are all containers labeled as hazardous waste
stored at or near the point of generation?
Hazardous waste satellite accumulation regulations
require that the generator accumulate hazardous waste
in containers at or near the point of generation where
waste is initially accumulated, and which is under the
control of the operator who generated the waste.
If 55 gallons is exceeded, the generator then has 72
hours to remove the waste or the generator must create
a less than 90 day storage area.
Location
Incorrect
Correct
Less Than 90 Day Storage Areas
Creation of a Less than 90 Day Storage area requires EHS Director approval.
Contingency Plan Required
Used to minimize hazards to human health or the environment from fires, explosion, or any unplanned sudden or non-sudden release of hazardous waste.
Must:
Describe facility actions in response to a release.
Describe arrangements made with local authorities.
List names, addresses, and phone numbers of any emergency coordinators.
List and location of any response equipment.
Post evacuation plans – primary and secondary.
Copies must be maintained on-site and be sent to local authorities.
Less Than 90 Day Storage Areas
Containers are in good condition and non-leaking. §264.171
Waste is compatible with container that it is stored in. §264.172
Container is closed except when adding or removing waste. §264.173(a)
Container not stored in a way that would cause it to spill or leak. §264.173(b)
Weekly inspections are conducted. §264.174
Ignitable and reactive wastes are stored at least 15 meters (50 feet) from facility’s property line. §264.176
Facility is maintained in a manner to prevent fire, explosions or spills. §264.31
Facility must be equipped with (unless hazards posed would not require):
1. Internal communications to signal emergency to facility personnel.
2. Communication device to alert local emergency response personnel.
3. Fire extinguishers.
4. Fire suppression: adequate water supply or foam producing equipment. §264.32
Testing and maintenance of emergency equipment. §264.33
Adequate aisle space. §264.35
Hazardous personnel Training records must be maintained on-site. §264.16
Lead Paint Chips
Containerize in Drums.
Label, and Keep Closed.
Store in a locked area.
Store in boxes. Label, Date, and Keep Closed
Pass TCLP
Construction Waste Process: Hazardous, TSCA, Universal, Recyclables, and Other Solid Wastes
Mercury Containing Articles
Mercury Contaminated Debris – including casework, piping, p-traps, etc.
Fluorescent Lamps: CFL, Long Tubes,
HID, U-Tube
PCB Ballasts (TSCA Waste)
Non-PCB Ballasts: Labeled “No PCBs” or
Electronic
Waste Determination by TCLP
Disposal in C&D Landfill
Store in a locked area for up to 1 yr.
Lead Based Paint Debris and PPE
Fail TCLP
>55 gallons: Date Container; Within 72 hours of accumulation date, transport to UNC TSD for storage until either treatment or
disposal
Shipment of Waste through
EHS.
Shipment of Waste via Contractor
EHS must validate ultimate disposal site to protect UNC from future liabilities.
EHS should be notified to help generate and sign waste profiles.
EHS MUST Be Present for and Sign Any Manifest or BOL for Any
Universal, TSCA, or Hazardous Waste Shipment.
Drum, Label, Date, and Recycle as Scrap
Metal
Contractor EHS SharedResponsibilities
<55 gallons: Store waste in satellite accumulation area, near
the point of generation, and under the control of the
contractor
Consequences of Non-Compliance
Fines up to $30,000 per day, per violation.
EPA and NCDENR have the authority to shut down
the job-site.
If violations are found on one visit, inspectors are
required to return within 30 days to ensure
compliance is achieved. Violations found during this
follow-up visit may be considered in addition to the
initial enforcement action items.
Summary
UNC is responsible for ultimate waste disposal and would be responsible for any fines by NCDENR or EPA.
Lids.
Leaks.
Labels.
Location.
No waste can legally be shipped off-site without proper notification and signature of EHS.
