RCRA Compliance Report 2016

Tom Hicks, Environmental Health and Safety

University of Idaho is regulated as a large quantity generator of hazardous waste. In April 2016, inspectors from the Idaho Department of Environmental Quality (DEQ) and U.S. Environmental Protection Agency evaluated the university for compliance with the Idaho Hazardous Waste Management Act of 1983 and the federal Resource Conservation and Recovery Act of 1976. The following information summarizes the results of the inspection.

During the three-day review, the inspectors visited over forty campus locations where hazardous waste is generated. In addition, they completed a comprehensive evaluation of the central accumulation area, managed by Environmental Health and Safety (EHS), where hazardous waste is temporarily stored prior to shipment to permitted treatment, storage and disposal facilities. Finally, the inspectors reviewed training and shipment records, our online chemical waste tracking system, and preparedness and emergency response procedures. According to EHS Director, Dr. Samir Shahat, the officials were particularly impressed with the chemical waste tracking system that was developed jointly by University of Idaho Information Technology Services and EHS Hazardous Materials Technician Mark Borth. “The online system provides a convenient method for requesting our waste disposal services and enables effective documentation of hazardous waste generation and disposal,” according to Dr. Shahat.

Following the on-campus review, DEQ issued a “Warning Letter” to the university, calling attention to four specific violations. All of the violations were corrected at the time of the inspection or within one day of its completion. Within DEQ’s enforcement process, a warning letter is an informal tool for gaining compliance without resorting to a more formal method such as a notice of violation. An inspector may choose to issue a warning letter to address violations that are few in number, minor, and easily corrected in a limited time with minimal oversight by DEQ. Typically, the violations addressed in a warning letter can be resolved promptly.

The four violations included:

1. Failure to perform hazardous waste determinations. The regulations require a generator to decide if a waste is hazardous before it is disposed. In several cases, the inspectors observed containers that held small quantities where it was unclear if the material was a waste or if it was a hazardous waste.
2. Movement of waste from its temporary accumulation area to another room. The regulations are very explicit in stating that a hazardous waste container must remain “at or near its point of generation.” Typically, DEQ interprets this requirement to mean that a container cannot be moved through a doorway to another room.
3. Failure to close several hazardous waste containers. A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste.
4. Failure to mark a container with the words “Used Oil.” Containers that hold used oil must be clearly marked as such.

The inspectors noted several issues of concern that were not identified as violations, but demand our attention. These issues include:

1. Excessive storage of chemicals, in some cases in a haphazard manner. DEQ is concerned that such storage methods could create unsafe conditions, or may represent a means to avoid disposal costs.
2. Discharge of oil from an air compressor to the environment. Subsequently, EHS remediated the oil discharge and submitted a report to DEQ. Facilities replaced the air compressor to eliminate the discharge.
3. Air filtration may be necessary at several art studio locations. EHS will evaluate the need for air filters and respond to DEQ.
4. Floor drains in shop areas should be plugged.

Overall, the inspection results were positive and encouraging, with no life-threatening violations or near misses. As evidence of continual improvement, the DEQ noted our efforts in the online tracking system, better training of campus personnel, and thorough documentation of waste determinations. DEQ stated that these efforts have significantly reduced the number of violations observed during previous inspections. EHS wishes to recognize the cooperation and assistance of the campus community, with particular recognition to Facilities, the College of Art and Architecture, and the Analytical Sciences Laboratory within the College of Agriculture and Life Sciences.

As we work towards our goal of full compliance with the hazardous waste rules, EHS offers this reminder of key points in managing hazardous waste:

1. Label or mark all chemical containers, including waste containers.
2. Keep containers closed except when adding waste.
3. Store containers safely, using secondary containers such as trays, dish tubs or spill pallets.
4. Submit waste promptly.
5. Seek training from EHS on proper hazardous waste management. You can register for our Hazardous Waste Management Workshop in NetLearning@uidaho, the campus learning management system for safety matters.

If you are interested in more detail, or would like to review the inspection report, please contact Tom Hicks, EHS Hazardous Materials Specialist, 208-885-6524, thicks@uidaho.edu.