BYU and Subpart K Alfredo Chandia Risk Management Brigham Young University Provo, Utah

Brigham Young University Located in Provo, Utah Located in Provo, Utah

Private University founded in 1875 and is affiliated with the Church of Jesus Christ of Latter Day Saints. It offers BS, MS and PhD degrees. Private University founded in 1875 and is affiliated with the Church of Jesus Christ of Latter Day Saints. It offers BS, MS and PhD degrees. Undergraduate body of approximately 30K students. Undergraduate body of approximately 30K students.

Some interesting facts about BYU: Some interesting facts about BYU: Approximately 70% of students speaks a second language (numbering 107 languages in total)... Fluently! Approximately 70% of students speaks a second language (numbering 107 languages in total)... Fluently! 55 languages are taught on campus 55 languages are taught on campus BYU Ballroom Dance Company has won the US National Formation Dance Championship every year since 1982 BYU Ballroom Dance Company has won the US National Formation Dance Championship every year since 1982 Ice Cream is now cheaper on campus than in 1950 (if you adjust for inflation) Ice Cream is now cheaper on campus than in 1950 (if you adjust for inflation)

BYUs Waste Operations as of May 2013 Overview Generator makes request for waste pickup via our web page or via phone Generator makes request for waste pickup via our web page or via phone We collect from the laboratory and bring the material to our central accumulation area (90-Day Area) We collect from the laboratory and bring the material to our central accumulation area (90-Day Area) If regulated, we assign waste codes If regulated, we assign waste codes We prepare waste for shipment We prepare waste for shipment Ship waste via vendors Ship waste via vendors

BYUs Waste Operations as of May 2013 Overview BYUs Container Management We provide containers to generators for collection We provide containers to generators for collection We give unique IDs to each container We give unique IDs to each container Each container ID is tracked online Each container ID is tracked online Each container has an online log sheet Each container has an online log sheet Each container is associated with a waste stream Each container is associated with a waste stream We bulk our waste We bulk our waste We reuse containers We reuse containers

Subpart K 40 CFR 262 Subpart K - Alternative Requirements for Hazardous Waste Determination and Accumulation of Unwanted Material for Laboratories Owned by Eligible Academic Entities 40 CFR 262 Subpart K - Alternative Requirements for Hazardous Waste Determination and Accumulation of Unwanted Material for Laboratories Owned by Eligible Academic Entities Effective on December 2008 Effective on December 2008 Volunteer program Volunteer program Effective in Utah Effective in Utah Why did we adopt Subpart K at BYU? Why did we adopt Subpart K at BYU?

Utah Department of Environmental Quality Inspection in March 2011 From UDEQs letter dated 5/23/2011 From UDEQs letter dated 5/23/2011 Subpart K of 40 CFR 262 provides standards for managing hazardous waste in academic laboratories as an alternative to the satellite accumulation area generators regulation. Subpart K may better suit the Universitys specific circumstances of managing waste from teaching and research laboratories. Subpart K of 40 CFR 262 provides standards for managing hazardous waste in academic laboratories as an alternative to the satellite accumulation area generators regulation. Subpart K may better suit the Universitys specific circumstances of managing waste from teaching and research laboratories.

BYUs Situation – Discussion We have been operating under a scheme that resembled the Subpart K model We have been operating under a scheme that resembled the Subpart K model UDEQ has been aware of it and not said too much about it. UDEQ has been aware of it and not said too much about it. Our regulators are aware the SAA model doesnt fit the academic environment Our regulators are aware the SAA model doesnt fit the academic environment It was time to adopt Subpart K It was time to adopt Subpart K We finally decided to adopt the regulation We finally decided to adopt the regulation

Adopting Subpart K Looked into the regulation itself Looked into the regulation itself Watched the training EPA offers online Watched the training EPA offers online Looked at other schools Looked at other schools Met with University of Utah to get their input (already working under Subpart K) Met with University of Utah to get their input (already working under Subpart K) Developed our Laboratory Management Plan (LMP) Developed our Laboratory Management Plan (LMP) Development of Laboratory workers online training Development of Laboratory workers online training Approval by BYUs Academic Safety Committee Approval by BYUs Academic Safety Committee Signature of our Administrative Vice President Signature of our Administrative Vice President

Submittal of Form to Utah Department of Environmental Quality Submittal of Form to Utah Department of Environmental Quality

Changes to our Operations (Academic Side) Labels Labels

Purpose of labels Purpose of labels Aid First Responders Aid First Responders Aid laboratory users in where to put their unwanted lab material Aid laboratory users in where to put their unwanted lab material

Unique Container Label Unique Container Label Constituents (Waste Profiles) Constituents (Waste Profiles) Date created (important for Rolling 6 months collection) Date created (important for Rolling 6 months collection) Generators contact information Generators contact information Additional information Additional information ID #57

Webpage Content Update Webpage Content Update

Training Training Delivered online (and tracked) for all Laboratory Workers (PIs & student workers) Delivered online (and tracked) for all Laboratory Workers (PIs & student workers) Commensurate with their duties Commensurate with their duties Initial training and every two years thereafter Initial training and every two years thereafter Fail proof training Fail proof training Must have training completed to request unwanted lab material pickup Must have training completed to request unwanted lab material pickup Consulted with Faculty and Staff for best format Consulted with Faculty and Staff for best format

Trained Professionals at BYU: Trained Professionals at BYU: Professional staff oversee all unwanted lab material management Professional staff oversee all unwanted lab material management Student employees work under the direct supervision of professional staff Student employees work under the direct supervision of professional staff Training: Training: 40-Hour HAZWOPER Training 40-Hour HAZWOPER Training RCRA Regulations Training RCRA Regulations Training DOT Training DOT Training Biological Waste Management Training Biological Waste Management Training Radiological Training Radiological Training Truck Driving Training Truck Driving Training In-House Training in Waste Container Management Database In-House Training in Waste Container Management Database Chemical Compatibility Training Chemical Compatibility Training Other training as needed Other training as needed

Container Management Container Management Labels (already discussed) Labels (already discussed) Good laboratory practices for using and handling containers Good laboratory practices for using and handling containers We gave ourselves up to 10 calendar days to pick up the container(s) on our Laboratory Management Plan. Internally, we gave ourselves up to 3 business days. We gave ourselves up to 10 calendar days to pick up the container(s) on our Laboratory Management Plan. Internally, we gave ourselves up to 3 business days. All containers will be removed every 6 months (from start of accumulation date) All containers will be removed every 6 months (from start of accumulation date) We will automatically remove the container 30 days before its 6 month due date We will automatically remove the container 30 days before its 6 month due date It can be removed for other reasons as well (full, project ends, 90%full, etc.) It can be removed for other reasons as well (full, project ends, 90%full, etc.)

Container Management Container Management Use of working containers Use of working containers < 2 gallons of less < 2 gallons of less May be open till the end shift or until full (whichever is first) May be open till the end shift or until full (whichever is first) Hazardous Waste Determination Hazardous Waste Determination Done by us at our Central Accumulation Area Done by us at our Central Accumulation Area BYUs Chemicals Management Building BYUs Chemicals Management Building Made the determination within 4 days Made the determination within 4 days Move some chemicals (unused chemicals) to BYUs chemical redistribution program Move some chemicals (unused chemicals) to BYUs chemical redistribution program

Lab Cleanouts Lab Cleanouts It doesnt help us on our generator status It doesnt help us on our generator status It gives us flexibility on how we manage cleanout It gives us flexibility on how we manage cleanout We have 30 days We have 30 days We have BIG lab moves = cleanouts We have BIG lab moves = cleanouts John A.Widtsoe Building Life Science Building (no official name yet) Once a year per laboratory Once a year per laboratory All cleanouts will be documented (lab id, date started/ended, volume generated, etc.) and the records kept for 3 years All cleanouts will be documented (lab id, date started/ended, volume generated, etc.) and the records kept for 3 years

Questions, Comments, Discussion, Etc. Questions, Comments, Discussion, Etc.

See you next year in Park City, Utah!