Cost-control techniques for hazardous waste management

Linda M . Kurtz

What to do, beyond waste minimization, to reduce hazardous waste disposal costs
ost control is a fundamental element of any successful hazardous waste management program. At the university and college level, administrators typically stress the importance of fiscal responsibility. Because of the diversity of wastes generated at most teaching and research institutions, controlling disposal costs can be challenging. However, a number of management practices can help keep hazardous waste disposal costs in check. Waste minimization is perhaps the best method to keep costs under control. The link between these two ideas is clear--less waste means lower costs. Waste minimization should be practiced in the lab and by Environmental Health & Safety (EH&S) departments. Laboratory waste minimization techniques have been discussed in previous issues of this publication, and many resources are available that offer guidance. A list of several sources for more information is included in the box on page 31. Beyond waste minimization, several other practices can help to further reduce disposal costs. At Northwestern University (NU), the hazardous waste management staff has been successful at controlling disposal costs by reducing the amount of waste sent off site for disposal, optimizing waste packaging techniques, and negotiating with hazardous waste disposal vendors. These practices have helped offset the relatively high cost of managing waste from two geographically distinct campuses, both of which are located in urban environments. Once a researcher turns over a chemical to the EH&S department, its fate lies with the hazardous waste

management staff. The usual practice might be to send it to a permitted treatment, storage, and disposal facility (TSDF). First, consider the alternatives of on-site disposal or treatment, returning it to the manufacturer, or redistributing the material to others within your institution. Reducing the amount of material sent to a TSDF is one of the best ways to control costs. As with waste minimization, the lower the volume of material sent to a TSDF, the lower the associated disposal costs.

Alternative disposal Review the types of materials you currently ship for off-site disposal. Investigate the possibility of discharging nonregulated, nonhazardous materials to the sanitary sewer or local landfill. Nonregulated materials refer to those chemicals that are not regulated by EPA or DOT. Nonhazardous refers to materials of relatively low toxicity. In many locations, it may be possible to discharge nonregulated solutions of readily biodegradable organics such as sugars or nonflammable alcohols to the sewer system. Likewise, the local landfill may accept nonregulated solids. Before engaging in these practices, it is wise to contact the landfill operator and sanitary district agency to obtain permission. It may also be possible to dispose of other wastes, including some regulated materials, on site after they have been treated. The May/June issue of Chemical Health & Safety published an article that discussed the regulatory ramification of waste treatment by generators (1). Not all wastes can be treated without a permit, but genera-

tots are allowed to perform elementary acid and base neutralization under current environmental regulations. Neutralized acids and bases can be discharged down the drain, thereby eliminating the need to send the materials to a TSDE Nonregulated yet hazardous wastes can also be treated. For example, ethidium bromide can be removed from aqueous solutions by activated carbon filtration, and the resulting solution can be discharged to the drain. The carbon filter, when saturated, should be disposed of through incineration, but the volume of liquid requiring disposal can be reduced significantly by filtration. Alternatively, ethidium bromide can be degraded by reaction with potassium permanganate and sulfuric acid. Kaufman (2) and Pitt (3) discuss treatment methods for ethidium bromide and other materials such as carcinogenic aromatic amines. Before discharging reaction products to the sanitary sewer system, check with the appropriate agencies.

Return of materials
Another method to reduce the amount of material requiring off-site disposal is to return lecture bottles to the supplier when possible. Disposal fees for lecture bottles and other small gas cylinders can often greatly exceed the original purchase price. Several suppliers will accept returns either free of charge or for a small fee. Either way, the cost is typically much less than disposal fees charged by a TSDE At NU, the E H & S department makes all the necessary arrangements, such as packaging, completing paperwork, and arranging transportation, in the return of lecture bottles

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and organometallic bubblers to suppliers. We also encourage investigators to purchase gas cylinders and lecture bottles from suppliers that will accept returns.

Redistribution program Yet another cost-mitigating technique of reducing the volume sent to a TSDF is a redistribution program. Surplus, reagent-grade chemicals that are turned over to the waste program are good candidates for an exchange program. Many universities that have implemented redistribution programs report great success. Both disposal and chemical purchasing costs are reduced. It is important to point out that an EH&S-administered exchange program requires staff support, space to store the materials, and a method to advertise the availability of chemicals to the research community. Care must be taken to ensure that chemicals are still useable and that expiration dates have not been exceeded. Last, a decision matrix should be established that alerts the hazardous waste management staff when it should take unclaimed materials out of the program and declare them a waste.

Inventory control Inventory control can help ensure that laboratories properly manage their chemical stocks. Maintaining chemical inventories is a good practice and becomes even more crucial in large laboratories where many students work. Allowing lab workers to quickly identify the availability and location of chemicals means that new stocks are less likely to be ordered before current stocks are depleted. Well-maintained inventories also help identify old chemicals or those nearing their expiration dates. Because some chemicals, such as peroxide formers, can become unstable over time or develop dangerous degradation products, the disposal of these materials can be quite hazardous and expensive. Over the years, we have occasionally encountered old chemicals at NU. Although most of these chemicals do not present additional age-related hazards, the disposal of some items, like a 25-year old bottle of dioxane or ether, has proven to be extremely hazardous and costly. Inventory control helps track the age of chemicals and ensure disposal before hazardous degradation prod-

ucts have an opportunity to accumulate. At NU, the E H & S department administers a comprehensive invento- = ry program for the chemistry department. The software supporting the program was purchased from an outside vendor. Users assign a bar code to materials upon receipt or synthesis; create an entry into a database for the material; and enter data such as the responsible person, chemical storage location, chemical name, and quantity. Records are then automatically updated with hazard and regulatory information. When appropriate, users also input disposal or consumption data. To date, approximately 20,000 chemicals are tracked with the system. Originally implemented to comply with new building code requirements in a renovated facility, the inventory has additional safety advantages. The program has reduced the number of expired containers of peroxidizable solvents turned over for disposal at NU. When these kinds of materials are received, expiration dates are now typically exceeded by just a few months at most. Hence, the likelihood of formation of dangerous concentrations of
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peroxides is diminished. Our experience indicates that the inventory program helps researchers track their chemicals and makes them more aware of the shelf life of certain potentially hazardous materials. Once you have minimized the amount of waste requiring disposal at a TSDF, it is time to concentrate on controlling outside disposal costs through vendor negotiations and inhouse waste processing procedures.

per volume unit than smaller institutions. Negotiating with contractors for low disposal prices depends upon a number of factors such as the size of the institution, quantity and frequency of waste generated, and location.

Vendor negotiation Whether quarterly, annually, or biannually, always review contracts and discuss methods to cut disposal prices with your contractors. Obtain pricing or bids from several companies and compare. NU maintains environmental service agreements with several different companies but does not rely upon time-dependent contracts. Our service agreements include pricing for waste streams and a fee structure based on weight for reactive and nonreactive labpacks. Because we are not restricted to a single contractor or locked into a yearly contract, we are often able to negotiate pricing. The disadvantage of this method is that it may be difficult to obtain the same low disposal pricing as institutions that agree to a one- or two-year contract with a single disposal company. However, if you work with your hazardous waste vendor and know what other institutions are paying for hazardous waste disposal, you may still be able to obtain low fees. I was recently successful in obtaining lower pricing for the disposal of the university's reactives after learning about the low price quoted to a nearby school from the same contractor. After calling my customer service representative to report the discrepancy, our price was adjusted to match the neighboring university. I have also done this between companies. I use the price quoted by one company to negotiate with another for similar or, ideally, lower pricing. This way, I take advantage of the competitive nature of disposal firms and have the flexibility of using whichever company is most advantageous at a particular time. Disposal fees will vary between university and college research facilities. Generally, larger institutions pay less
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Waste consolidation Consolidating as many wastes as possible is a proven method to reduce costs. Compared to the conventional labpack, waste consolidation is a more efficient means to process material for shipment to a TSDE Work with your vendor to identify waste types that can be combined into waste streams. Wastes such as solvents, oils, acids, and bases--in short, most liquid mixtures that are not reactive--can be combined directly into drums. At NU, we consolidate many wastes so that the number of labpacks we ship is minimized. Typically, only reactives, characterized unknowns, inhalation hazards, and certain EPA-listed wastes are labpacked. Nonhalogenated solvents are combined into 55-gallon drums for off-site shipment to fuel blenders. Used oils are also combined for the same disposal method. Halogenated solvents and compatible liquid organics are bulked into drums for incineration. Although the practice is not common at NU, some nonregulated organic solids can be dissolved into the solvents that are commingled in drums. In fact, the disposal guides provided by some chemical suppliers recommend mixing certain solid organic compounds with combustible solvents, followed by incineration. The time that it takes to open individual containers of materials and remove the material and the additional responsibility of management of the empties are two drawbacks to the dissolution of solids. Any residue remaining in the container should be removed and any rinsate collected for disposal. An alternative to mixing solid organics into your solvent waste streams is to package the entire container into a dry waste stream, when appropriate. Many solid materials can be packed into "waste stream" drums, eliminating the need for a labpack inventory. By identifying recurring wastes that can be placed directly into

a drum, the packing time is reduced because the detailed labpack inventory is eliminated. Further, the amount of material packaged into a waste stream drum is maximized compared with the traditional labpack approach. At NU, our dry waste stream consists of gloves, paper, and small amounts of glass contaminated with traces of organic solvents, heavy metals, and various organics. It carries many of the EPA toxic waste codes and is classified as a 6.1 by the DOT for shipping purposes. We also include certain non-EPA-regulated solids (e.g., ethidium bromide, phenylenediamine, and diaminobenzidine) that are best destroyed by incineration. The entire container is placed into a 55-gaUon open-top drum, along with other contaminated materials, manually compacted, and shipped to an incinerator. We also have a mercury thermometer and debris waste stream. We collect as much free mercury as possible for recycling and pack the remaining contaminated materials into drums. In order to comply with our 90-day largequantity generator requirement, we typically pack these into 5- or 14-gallon drums so that our quarterly shipments contain full drums. This waste is sent to a mercury retort facility. Used silica gel is also bulked into drums for shipment to an incinerator, as is agarose get, contaminated with ethidium bromide. Although not regulated by the EPA, the gel waste is sent by the university to an incinerator because of the mutagenic nature of ethidium bromide. In our waste facility, we have many waste stream drums accumulating simultaneously. Once items are brought to our central storage facilities, those items meeting a particular waste stream profile are packed or emptied directly into the appropriate drum after recording of the container identification number. All drums are then shipped to the appropriate disposal company on a quarterly basis. Typically, disposal costs are less per pound for waste stream drums than for labpacks. Waste stream approval fees can sometimes be waived depending on the vendor. Generator knowledge is usually sufficient to properly characterize a waste stream so that analytical costs are also minimal.

Keep in mind that while waste consolidation is a great method for controlling disposal costs, it requires adequate space and trained personnel. Bulking solvents and corrosive materials requires ventilation and exhaust controls, bonding and grounding of containers and drums, adequate personal protective equipment, and chemical knowledge. These factors are important and apply to the consolidation of other wastes as well.

Labpacking Now that you have minimized the amount of waste going to a TSDF and have identified wastes that can be combined, what can you do for the materials that are not suitable for consolidation with a waste stream? At NU, researchers generate cyanide wastes, P-coded waste chemicals, reactives, inhalation hazards, and unknowns. These types of waste must be labpacked. If the volume of waste is relatively low, consider using the EH&S staff to labpack the materials. Using in-house labor saves money because you are not paying a contractor for this service. Several disposal companies offer guidance for generators who wish to pack their own waste. Supplies can be costly but if you have room to store excess materials, order in bulk. Most suppliers offer discounts for bulk orders. Once drums are packed, the inventories are submitted to the intended disposal company for review and approval. Once approval is granted, shipping arrangements are made. Although packing wastes in-house is certainly a cost-saving mechanism, it requires significant time and effort. A working knowledge of EPA and DOT regulations is a must, as well as a solid background in chemistry. Adequate space and personnel are necessary to pack the materials and temporarily store drums until approvals are granted and transportation arrangements are made. Vendo~assisted packing If you lack the space to store packing materials or if your expertise or staff is limited, consider asking your vendor if they will pack the materials "on paper" for you. In programs like these,

the generator submits a list of materials for disposal to the intended company. The disposal company then reviews the list of waste materials and determines which items can be packed together. Directions, supplies, drum inventories, and manifests are then returned to the generator. The generator supplies the labpacking labor but uses the expertise of the disposal company. Vendor-assisted programs eliminate or reduce the decision-making element for the generator. This review of cost-control mechanisms for hazardous waste disposal is intended as guidance. Program managers undoubtedly will determine other cost-control techniques that work for their specific institutions. As always, it is best to check with regulators before engaging in any new practices. NU has implemented most of the items mentioned above with the exception of a direct recycling pro-

gram. Our indirect program consists of the comprehensive, computerized chemical inventory that we maintain for the chemistry department. The inventory allows for the sharing and exchange of chemicals between research groups for those who have access to the program. In the future, we hope to expand this service to further facilitate sharing and, thus, further reduce our disposal costs.

References (1) Phifer, R. W.; Milbum, M. M. Chem. Health Saf. 1998, 5(3), 19-22. (2) Kaufman, J. A. Waste Disposal in Academic Institutions, 1st ed.; Lewis Publishers, Inc.: Chelsea, MI, 1990. (3) Pitt, I. M.; Pitt, E. Handbook of Laboratory Waste Disposal, 1st ed.; Wiley: New York, 1985.
Linda hi. Kurtz is a hazardous materials manager at the O[fice of Research Safety at the Technological Institute (2145 Sheridan Rd., Evanston, IL 60208-3121; 847-491-5581; fax 847-467-2797).
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