Environmental Health & Safety

Hazardous Waste Management Plan

 

Introduction
The purpose of the Fort Lewis College Hazardous Waste Management Plan is to inform faculty, staff, students and the community that the college is complying with environmental laws, rules and regulations governed by the Colorado Department of Public Health & Environment (CDPH&E).  This plan will address our actions in regards to handling hazardous wastes and universal wastes on campus.
 
This plan applies to all operations on campus, and each department has a responsibility to follow applicable sections of the plan.  The intent is to protect employees, students or members of the community who may be exposed to hazardous waste, discharge, or spill situations under normal work conditions or during emergency situations.  
 
By virtue of the small quantity of hazardous waste generated each month, Fort Lewis College operates as a Conditionally Exempt Small Quantity Generator (CESQG). Emergency response requirements and training requirements are defined by the CESQG status.  While a written plan is not required for a CSESQG, it is believed to be vitally important to the safety and health of the faculty, staff, students and the immediate community around Fort Lewis College.  With the CESQG designation, Fort Lewis College still has to comply with detailed and specific rules and regulations in how hazardous waste is handled and managed.  
 
This plan is designed to minimize hazards to human health or the environment from fires, explosions or any unplanned release of hazardous waste to the air, soil or surface waters.  The response sections should be initiated immediately whenever there is a fire, explosions or release of hazardous waste.  Please refer to the CDPH&E’s Guidance Document for the Small Quantity Generator Self-Certification Checklist for more detailed information.
 
Fort Lewis College generates hazardous waste and universal waste on a continuing basis.  Hazardous waste generated on campus from the Art, Biology, Chemistry and Geology Departments is stored in the Chemical Storage Building (#53) located between Escalante Hall and the Chapel.  Occasionally hazardous materials are generated by the Student Life Center, Student Union and Housing Departments generate hazardous waste or universal waste.  These materials are stored in the Chemical Storage Building, as well.  The Physical Plant generates used oil, antifreeze, solvent-containing shop towels which are handled with an outside contractor.  A spill contingency plan is in effect for the gasoline and diesel storage tanks located at the Physical Plant.  Universal wastes generated by the Physical Plant include mercury containing devices and equipment, lamps, batteries and aerosol cans.  All of these materials are regulated by the CDPH&E, and all are handled and disposed of according to law.
 
FLC encourages suggestion by our employees and students for improving our hazardous waste plan and continuing to maintain an effective plan.  It is hoped that clear understanding, safe behavior and personal commitment and involvement with the plan will improve overall safety on campus in regards to use and disposal of hazardous wastes.
 
Administrative Responsibilities
The Director of Environmental Health & Safety (EH&S) is responsible for maintaining and updating this plan.  Copies of this document may be obtained from this office, located in the Education – Business Building, room 227.  The Director of EH&S is responsible for:
  • All aspects of the college’s contingency plan
  • All hazardous waste operations and activities on campus
  • The location and characteristics of the hazardous wastes on campus
  • Maintaining and documenting all related records for the campus
  • That the written plan is complete and updated/reviewed on an annual basis
  • Is available for review by representatives of the CDPH&E
  • Has been shared with the Durango Fire & Rescue Authority (DF&RA)
  • Has been shared with the Fort Lewis College Health & Safety Group and Emergency Response Tea
Emergency Equipment and Procedures
Emergency equipment is located across campus.  Spill equipment for acids, bases, flammable and mercury is located in laboratories, as are acid cabinets and flammable cabinets.  Approved containers for transporting and storing hazardous wastes in laboratories are available upon request.  Additional equipment is located in the Chemical Storage Building to supplement that in the labs.  Adequate inventories are maintained in the storage building.
 
The Fort Lewis College Police Department has 8oo MHz radios and cell phones to use in the event of an emergency.  
 
Personal protective equipment (PPE) is available for use.  This includes half-mask respirators and appropriate filters, chemical splash goggles, face shields, latex and neoprene gloves, boots and clothing.  Proper training and use are required before anyone uses PPE.
 
Chemical lab hoods are located in laboratories and the flow rates are checked on an annual basis.
 
Decontamination is provided via the emergency showers and emergency eyewashes located in the laboratories and other locations on campus.
 
Fire alarm systems and fire extinguishers are tested on an annual basis.  The Chemical Storage Building has its own self-contained extinguishing system.
 
Representatives of the Durango Fire and Rescue Authority last inspected the Chemical Storage Building in 2009.  They are invited to inspect the facility at their convenience, and have been extended the offer to observe/participate in the annual chemical cleanout performed by a licensed hazardous waste hauler.
 
The following are the responsibilities of the Director of EH&S – also known as the Emergency Coordinator – in the event of a hazardous waste spill or discharge:
  • Work with campus or off-campus responders to ameliorate the situation
  • Take the necessary steps to determine the root cause and implement procedures to prevent recurrence of the event
  • Make the necessary calls to the CDPH&E or other state/federal agencies as needed
  • Assist with the cleanup of the spill if appropriate
  • Consult with local, state and federal authorities as needed
Employees working with hazardous waste must be trained to respond to spills in a safe and effective manner. Large spills require the following response:
  • Notify everyone in the immediate area
  • Evacuate the area if needed
  • Call Campus Police at 911 or 9-911 from a campus phone 
  • Call EH&S @ 7272
  • Restrict access to area
  • Avoid contact with the spilled material(s)
  • Eliminate ignition sources if present
  • Provide any needed first aid, including emergency showers and eye washing
  • Prevent released materials from entering sewers and confined spaces, if possible
  • If qualified to contain the spill or clean up the spill do so after communicating this with the Campus Police, EH&S or emergency responders.

Plan Specifics

Chemical Storage Building
The following information pertains to the Chemical Storage Building (CSB).  The CSB is a one-room steel building manufactured by Safety Storage and was installed on campus in 1999.  It is fully dry-sprinkled with thermal linked triggers and is alarmed to Escalante Hall.  In addition, a portable ABC fire extinguisher is maintained in the building.  The building contains hazardous wastes from across campus, and serves a second capacity as an auxiliary storage facility for the Chemistry Department.  It contains acids, bases, flammables, poisons, reactive materials, but no explosives. 
 
The CSB is provided electrical and water service.  As it is self-contained, there is little likelihood of a spill to a storm drain or to the ground surface.  Normal operations involve only the EH&S director processing hazardous waste. The building contains one emergency eyewash unit, a chemical hood for lab work, several flammable safety cabinets and two acid safety cabinets.
There is no phone service in the building so workers must carry cell phones at all times while processing hazardous waste in the building.  It is recommended that at least one door is propped open during work, serving both as a signal that work is in progress and to allow rapid access or egress during an emergency.
 
As the CSB is completely protected by a self-contained sump pit to collect any spilled materials, the use of dry absorbents is the preferred way of containing and managing a spill.  If this were to happen, the clean-up material would be handled as hazardous waste.  If a large enough quantity of hazardous material were to spill, or the containment capacity were to be exceeded, then the DF&RA would be contacted and the Hazard Material Response (HazMat) Team would be utilized to control the spill and perform the clean up.
 
All transport of hazardous waste on campus should be under the direct supervision of the EH&S director.  Secondary containers should be used as needed, and a 2-gallon spill clean-up kit used if necessary.  As mentioned above, any material used in a clean-up will be regarded as hazardous waste. 
 
In the event of a fire within the CSB, the portable extinguisher can be used for small fires.  Larger fires require closing the doors, turning off the fan, and pulling the emergency fire suppression control located outside the North end of the building.  DF&RA must be called following these steps.  DF&RA current strategy for fighting a fire inside the CSB is to leave the building closed and use a water spray to continuously cool the building and knock down any large smoke plumes.  After the fire is extinguished, the DF&RA HazMat team could assist in cleanup, as could a privately licensed HazMat organization.  The above describes a situation beyond the capabilities of campus personnel to remediate.
 
Laboratories
Faculty and staff are responsible to properly identify and characterize their hazardous wastes for disposal.  Before any new waste streams are generated the identity and characteristics of the waste material must be communicated to the EH&S.  EH&S should be contacted during the planning process to facilitate proper disposal of the anticipated waste, and to estimate costs associated with handling and disposal of the new waste steam(s).
 
Proper hazardous waste management in the laboratories must include the following guidelines:
  • Waste must be stored in approved containers, which have a tight fitting cap or cover
  • Approved containers must be compatible with the waste
  • Containers must be kept closed at all times unless waste is being added
  • Containers must be maintained in good condition, are not damaged or leaking. 
  • Containers must be labeled with appropriate stickers identifying the hazards
  • A secondary container is recommended to minimize spills and cleanup time and costs.
  • Containers must be stored in a secure location and under the control of the appropriate faculty or staff member.
  • No more than one container of a particular waste will be allowed in the lab.
  • When a container is 90% full, it is to be removed to the Chemical Storage Building.  Contact your lab director or EH&S for assistance.
  • Spill kits must be present in each lab.  Faculty or staff members managing the lab are responsible for insuring the spill kit is properly stocked, and for replacing used materials.
Additionally, chemicals are not to be discharged down the sink.  This includes:
  • Heavy metals, such as arsenic, barium, copper, tin, lead, silver, iron, cobalt, nickel, cadmium, chromium, zinc, manganese, selenium and mercury salts.
  • Fluorides, sulfides, bisulfides, cyanides, nitrites, peroxides, chlorates, perchlorates, and permanganates.
  • pH of liquids that may be discharged must be within the range of 5.5 – 9.0.
Physical Plant Services
Hazardous wastes generated in the Physical Plant include certain automotive fluids, oil-based paint, painting solvents, pressurized aerosol cans, parts washer solvent and waste oils.  Containers containing these wastes should be provided secondary containment.  When the container reaches 90% full, EH&S should be contacted to coordinate storage in the Chemical Storage Building and disposal via an approved hazardous waste disposal company.
 
Art Department
Hazardous waste generated in the Art Department includes silver reclaim cartridges used in photography, solvents and paints.  Mineral oil is used in lieu of other toxic solvents for cleaning brushes, and the spent oil is collected for disposal.  Paper towels are used with the mineral oil and disposed of by EH&S.  Secondary containment is required for containers containing the silver reclaim cartridge and the 5 gallon containers for solvents.
 
Custodial Staff
Hazardous waste may be handled by custodial staff on a non-routine basis.  Hazardous materials in cleaning products are encountered on a daily basis, and excess or expired materials may be treated as hazardous wastes.  Whenever there is a question regarding a chemical product being used by the custodial staff, it should be directed to the immediate supervisor for resolution.  EH&S will assist in this process.