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UVM Project XL Baseline Report |
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| HCOC | Waste Generation Rates | Environmental Awareness | Chemical Recycling | Costs of Compliance |
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UVM's hazardous chemicals of concern (HCOC) inventory is based on the requirements of SARA Title III reporting. In 1990, a variety of regulatory chemical lists were reviewed to generate a list of about 400 hazardous chemicals of considered to be of potential environmental or safety risk and likely to be found at UVM. This list is distributed to laboratories every January, and the laboratories report the quantity class of each chemical on the list that is stored there on a daily average basis (the original list of 400 was shortened after a couple of years of results had been gathered and certain chemicals were determined to be unnecessary). The cumulative totals for each building are reported to the Vermont Department of Emergency Management as the SARA Title III report for UVM. (For Title III report purposes, heating oil and other fuels and physical plant chemicals are included as well.)
This process also serves as the HCOC survey required by the Project XL regulation. The major pollution prevention aspect of this effort is that the inventory process regularly results in lab workers discovering materials being stored in the laboratory which can be discarded. The first several years the inventory form was used, chemical wastes generated by laboratories increased significantly in February and March. This effect has lessened in recent years, but there is still some evidence that the inventory stimulates improved housekeeping of chemicals in laboratory storage.
Baseline data provided with regards to the HCOC survey are:
1) the list of HCOC's inventoried at UVM, PDF format, and
2) the results of the 2000 inventory, summarized on a building and chemical subtotal basis.
The waste generation rates being reported as part of this baseline report are based on UVM's hazardous waste annual reports generated for the Vermont Department of Environmental Conservation. Because UVM's Environmental Safety Facility (ESF) is a Part B storage facility, UVM is required to file two reports Ð one for the waste streams generated on campus and another for those shipped out of the ESF. The numbers reported here are the amounts shipped from the campus to the ESF. We chose to report these numbers because at this point in the waste handling process, laboratory waste streams are easily distinguished from other campus waste streams.
The amount of hazardous waste shipped from UVM's laboratories (about 550) has been reasonably consistent from 1995-1999, with an average amount of just over 36,000 pounds during that period. It should be noted that the 1996 number does not include a large chemical clean out of the Chemistry Department that took place that year. This clean out produced more material than expected (about 11,000 pounds) and was not representative of a single year's waste production.
The annual variation from average of laboratory wastes (less than 10%) is much less than that observed for other campus wastes, whose totals are often driven by large construction and renovation projects which produce oil contaminated soils, lead paint debris, and other sporadic hazardous waste streams.
The Environmental Awareness Survey developed for the Project XL baseline was a cooperative effort among the three pilot schools, in consultation with a experienced survey professional from the University of Massachusetts Boston. Because of the size of UVM's laboratory population (about 1500 full time people) a random selection of 100 people was generated by taking every sixth name off the people who participated in the laboratory storage survey conducted over the last two years. The demographics of the sampled population and the results of their answers are presented in the accompanying table. The following points should be noted when reviewing the results:
1. The Environmental Management Plan has not been accepted by the Vermont Department of Environmental Conservation, therefore it has not been publicized to the laboratory community. That is why no one gave the proper answer to Question 14.
2. Questions 3, 8, 11 and 13 asked respondents to provide a list of answers, rather than asking for a correct answer. The number of answers provided reflects their familiarity with the issue at hand. We expect that the number of responses will increase over the course of the project.
3. It is clear that the laboratory population is unfamiliar with the regulatory concept of "acutely hazardous laboratory waste", which is specific to the Project XL regulation, as well as the RCRA concept of acutely hazardous waste. This point will be specifically covered during the training program delivered during the course of the XL project.
4. Question 12 (about the largest environmental impact of laboratory work) relies on a general judgement about the relative hazard of different environmental aspects. Therefore, it is likely that this question will continue to results in varied answers over the course of the project. It does point out an important issue of laboratory work, however, particularly in light of the EPA Labs21 initiative.
5. In general, we expect the answers to the other questions in the survey to produce higher proportions of correct answers over the course of the XL project as increased opportunities for training lab workers arise.
UVM's chemical recycling program has two portions: the centrally administered ChemSource program and informal departmental programs that occur in a decentralized manner. We estimate that the amount of chemicals recycled as a result of the combination is less than 1% of the chemical waste generated by UVM (36,000 pounds/year).
ChemSource is the chemical distribution program managed by the Environmental Safety Facility staff. We purchase chemicals from commercial suppliers in case quantities and sell containers within the case to campus chemical users. This allows laboratories to buy small quantities of chemicals while realizing the price advantage of case purchases. The amount of materials sold through this program has increased steadily over its 4 year history and is currently about 6600 pounds per year.
ChemSource also takes advantage of opportunities to recycle chemicals that are reusable. Materials of good quality (i.e. no sign of physical degradation) that ESF staff collect as hazardous waste are stored separately from other chemical wastes and can be purchased through the ChemSource program for $2 per container. Because of the uncertain quality of these materials, they are generally general lab use chemicals such as solvents and acids that are used for glass washing that are recycled this way. We estimate that about 60 pounds of chemicals are recycled annually through the ChemSource program.
As might be expected, the departmental chemical recycling efforts varied in focus and effectiveness. For example, the Pathology Department moves chemicals from lab to lab only when a laboratory is being decommissioned because a researcher is leaving. This happens about every year and a half and the only chemicals of interest to other researchers are general laboratory chemicals that are of general use. Specific chemical regents critical to experimental procedures are never moved from one laboratory to another because of concerns about quality and purity. About 100 pounds per year of chemicals is recycled in this way within the Pathology Department.
In the Animal Sciences Department, most chemical purchases are arranged through the departmental business manager, who is generally aware of what chemicals are already in the department. She takes advantage of opportunities to move chemicals from one laboratory to another to avoid the excessive purchase of new chemicals.
The Microbiology and Molecular Genetics Department has no centrally managed chemical management program Ð each laboratory acquires and stores chemicals on their own. According to the department lab coordinator, because of the small amounts of chemicals used and the high need for purity, there is very little interchange of chemicals (i.e. "not significantly different from zero") between laboratories.
The costs of UVM's compliance program for hazardous wastes refers only to the costs associated with proper disposal of chemical wastes from the laboratory. They do not include radioactive or biowaste. This cost consists of 5 components:
1. The amount billed to UVM by the disposal contractors.
2. The labor associated with collection of waste from laboratories, transportation of this waste to the ESF, repackaging of this waste for shipment from campus, and arranging for disposal, including proper paperwork through all of these steps. This cost is estimated as 50% of the ESF salary budget.
3. The training costs presented at estimated to be 15% of the ESF salary budget. This includes most of the effort of the Environmental Safety Specialists, and in addition includes training time for all ESF staff with regard to regulatory compliance, including updates.
4. Equipment costs are estimated to be 50% of the supplies budget for the ESF.
5. Fees associated with chemical hazardous waste disposal include primarily taxes on hazardous waste imposed by the State of Vermont