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EPA/600/R-10/092 October 2010

Laboratory Environmental Sample Disposal Information Document Companion to Standardized Analytical Methods for Environmental Restoration Following Homeland Security Events (SAM) - Revision 5.0

SCIENCOffice of Research and Development E National Homeland Security Research Center

Laboratory Environmental Sample Disposal Information Document

Companion to Standard Analytical Methods for Environmental Restoration Following Homeland Security Events (SAM) – Revision 5.0

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Office of Research and Development, National Homeland Security Research Center Cincinnati, OH 45268

Office of Research and Development National Homeland Security Research Center, Threat and Consequence Assessment Division

Acknowledgments

This document was developed by the U.S. Environmental Protection Agency’s (EPA) National Homeland Security Research Center (NHSRC) within EPA’s Office of Research and Development as a companion to NHSRC’s Standardized Methods for Environmental Restoration Following Homeland Security Events (SAM). We wish to acknowledge the external peer reviews conducted by Matthew Arduino of the U.S. Centers for Disease Control and Prevention, Larry Burchfield of the Radiochemistry Society, Jordan Peccia of Yale University, and Fred Lee of G. Fred Lee & Associates, whose thoughtful comments contributed greatly to the quality of the information. The document was prepared by Computer Sciences Corporation (CSC) under EPA Contract No. EP-W-06-046.

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Disclaimer

Mention of trade names or commercial products in this document does not constitute endorsement or recommendation for use.

Questions concerning this document or its application should be addressed to:

Romy Lee National Homeland Security Research Center Office of Research and Development (NG16) U.S. Environmental Protection Agency 26 West Martin Luther King Drive Cincinnati, OH 45268 (513) 569-7016 [email protected]

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Foreword

Following the events of September 11, 2001, EPA’s mission was expanded to account for critical needs related to homeland security. Presidential Directives identified EPA as the primary federal agency responsible for the country’s water supplies and for decontamination following a chemical, biological, and/or radiological (CBR) attack. To provide scientific and technical support to help EPA meet this expanded role, EPA’s National Homeland Security Research Center (NHSRC) was established. The NHSRC research program is focused on conducting research and delivering products that improve the capability of the Agency to carry out its homeland security responsibilities.

One specific focus area of NHSRC’s research is to support the Environmental Response Laboratory Network (ERLN), a nationwide association of federal, state, local, and commercial environmental , established by EPA. The ERLN can be deployed in response to a large-scale environmental disaster by providing consistent analytical capabilities, capacities, and quality data in a systematic, coordinated manner. Toward this end, NHSRC has worked with experts from across EPA and other federal agencies to develop a compendium of analytical methods to be used in support of remediation following national homeland security related incidents. For specific analytes that have been determined to be of concern during a homeland security related event, analytical methods have been chosen to measure levels of contamination in different environmental matrices. The results of these efforts have been published in EPA’s Standardized Analytical Methods for Environmental Restoration Following Homeland Security Events (SAM), available at http://www.epa.gov/sam.

In identifying and selecting appropriate analytical methods to be used in such instances, EPA recognized the need for guidelines regarding disposal of samples analyzed by the methods listed in SAM. This sample disposal information document partially addresses this need by providing general guidelines for use by EPA and EPA-contracted laboratories when disposing of samples and associated analytical following use of the analytical methods listed in SAM.

NHSRC has made this publication available to assist in preparing for and recovering from disasters involving chemical, radiochemical, and biological contamination; it specifically represents an important next step in supporting the ERLN. We value your comments as we move toward the development of an efficient process to manage environmental samples and move EPA one step closer to achieving its homeland security mission and its overall mission of protecting human health and the environment while supporting sustainable solutions.

Cynthia Sonich-Mullin, Acting Director National Homeland Security Research Center

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Table of Contents Acknowledgements ...... i Disclaimer...... ii Foreword ...... iii Table of Contents...... iv List of Tables...... vi Acronyms and Abbreviations...... vii 1.0: Background...... 1 2.0: Scope and Application...... 2 3.0: Overview of Laboratory Responsibilities...... 3 ...... 3 Guidelines for Waste Minimization ...... 5 Waste Categorization and Segregation...... 5 Safety ...... 6 Primary Organizations and Acts that Dictate Waste Handling and Disposal...... 7 Resource Conservation and Recovery Act (RCRA) ...... 8 4.0: Handling and Disposal of Samples and Analytical Waste Containing Chemical ...... 13 Regulations...... 14 Storage ...... 14 Treatment ...... 15 Packaging...... 17 Disposal...... 18 5.0: Handling and Disposal of Samples and Analytical Waste Containing Radiological Hazards...... 20 Regulations...... 20 Storage ...... 22 Treatment ...... 25 Packaging...... 25 Disposal...... 26 6.0: Handling and Disposal of Samples and Analytical Waste Containing Biological Hazards...... 27 Packaging...... 32 Disposal...... 32 7.0: Handling and Disposal of Samples and Analytical Waste Containing Mixed Hazards ...... 34 Multi-hazardous Samples and ...... 34 iv

Mixed Waste Samples and Waste...... 35 8.0: Shipping...... 38 9.0: Disposal Sites ...... 39 Treatment, Storage, and Disposal Facilities (TSDFs)...... 39 Radiological Waste Disposal Sites ...... 40 Biological Waste Disposal Sites...... 40 10.0: References and Resources...... 41 General Resources...... 41 Resources for Wastes Containing Chemical Hazards...... 41 Resources for Wastes Containing Radiological Hazards ...... 41 Resources for Wastes Containing Biological Hazards ...... 42 Appendix A: State Regulatory Information Sources for Disposal of Waste Containing Chemical Contamination...... 43 Appendix B: State Regulatory Information Sources for Disposal of Waste Containing Radioactive Contamination...... 46 Appendix C: State Regulatory Information Sources for Disposal of Waste Containing Biological Contamination...... 54 Appendix D: Storage and Disposal Information (For Chemical Analytes Listed in SAM, Revision 5 ...... 57 Appendix E: Example Manifest Form...... 79

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List of Tables

Table 1: RCRA Water Generator Status Requirements ...... 9

Table 2: EPA and DOT Shipping Regulations ...... 11

Table 3: Posting Requirements for Storage of Radioactive Samples and Waste...... 24

Table 4: Comparison of Decontamination Procedures ...... 29

Table 5: Comparison of Decontamination Procedures for Non-protein Biotoxins...... 30

Table 6: Guidlines for Disposal of Multi-hazardous Laboratory Wastes ...... 35

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Acronyms and Abbreviations

AEA Atomic Energy Act ALARA As Low as Reasonably Achievable APHIS Animal and Plant Health Inspection Service BSL Biosafety Level CAA Clean Air Act CDC U.S. Centers for Disease Control and Prevention CDL Commercial Drivers License CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CESQG Conditionally Exempt Small Quantity Generator CFR Code of Federal Regulations CWA DAC Derived Air Concentration DDESB Department of Defense Explosives Safety Board DERP Defense Environmental Restoration Program DGR Dangerous Goods Regulations DoD U.S. Department of Defense DOE U.S. Department of Energy DOT U.S. Department of Transportation EPA U.S. Environmental Protection Agency ESS Explosives Safety Submissions FIFRA Federal Insecticide, Fungicide, and Act FUDS Formerly Used Defense Sites g Gram(s) HAZMAT Hazardous Materials HDPE High Density HHS U.S. Department of Health and Human Services HSWA Hazardous and Waste Amendments IAEA International Atomic Energy Agency IATA International Air Association ICS Incident Command System LLRW Low-level LLRWPA Low-Level Radioactive Waste Policy Act LQG Large Quantity Generator m3 Cubic meter mCi Millicurie(s) mg Milligram(s) min Minute(s) mm Millimeter(s) mR Milliroentgen(s) mrem Millirem(s) MSDS Material MTRU Mixed Transuranic N Normal – 1 equivalent weight per liter NARM Naturally Occurring, and/or Accelerator-Produced Radioactive Material nCi Nanocurie(s) NCP National Oil and Hazardous Substances Contingency Plan NHSRC National Homeland Security Research Center NIMS National Incident Management System nm Nanometer(s) NOS Not Otherwise Specified

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NPDES National Discharge Elimination System NRC Nuclear Regulatory Commission NWPA Nuclear Waste Policy Act OSHA U.S. Occupational Safety and Health Administration PCB(s) Polychlorinated biphenyl(s) PPE Personal Protective Equipment ppm Parts per million POTW Publicly Owned Treatment Works psi Pounds per square inch PSN Proper Shipping Name RCRA Resource Conservation and Recovery Act SAM Standard Analytical Methods for Environmental Restoration Following Homeland Security Events SARA Superfund Amendments and Reauthorization Act SOP Standard Operating Procedure spp. Species SQG Small Quantity Generator TBq Terabecquerel TCLP Characteristic Procedure TNT Trinitrotoluene TSCA Toxic Substances Control Act TSDF Treatment, Storage, and Disposal Facility µCi Microcurie(s) µm Micrometer(s) UN The United Nations UN ID United Nations Identification Number µR Microroentgen(s) URL Uniform Resource Locator UV Ultraviolet WIPP Waste Isolation Pilot Plan

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1.0 Background

The U.S. Environmental Protection Agency’s effort is published in EPA’s Standard Analytical (EPA) National Homeland Security Research Methods for Environmental Restoration Center (NHSRC) has been working with experts Following Homeland Security Events (SAM), from across EPA and its sister agencies since Revision 5.0 (September 2009), and is available 2004, to develop a compendium of procedures to at: http://www.epa.gov/sam/. be used when EPA is tasked with environmental restoration following national homeland security During development of SAM, EPA recognized related incidents. Analytical methods have been the need for companion documents, including a selected for chemical, radiochemical, pathogen, document to provide guidelines regarding and biotoxin analytes of concern for the disposal of samples analyzed by the methods environmental sample types that are anticipated listed in SAM. in such incidents. The most recent result of this

This document addresses laboratory disposal of samples and associated analytical waste unique to remediation activities following a homeland security incident when SAM methods would be applied, and assumes specific environmental sample types (i.e., water, soil,

, and air) will be analyzed by laboratories using the methods listed in SAM.

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2.0 Scope and Application

This sample disposal information document is documents. intended to provide general guidelines for use by EPA and EPA-contracted laboratories when It is assumed that laboratories using this disposing of samples and associated analytical document will be handling environmental waste following use of the analytical methods samples that contain one or more of the listed in SAM. chemical, biological, or radiochemical analytes listed in SAM at levels that would be expected The document includes information regarding to be found in samples that are collected in laboratory responsibilities, waste minimization, support of site remediation and clearance. It is federal and state regulations, treatment, storage, also assumed that these samples and the packaging, disposal, and decontamination corresponding analytical waste are thoroughly procedures. The information provided in this characterized, and the hazardous components document is intended only as a guide and is and concentration levels understood. Guidelines based on the current federal and state regulations are provided for handling and disposal of cited; laboratories must consult and comply with samples that may contain SAM chemical these regulations prior to initiating sample (Section 4), radiochemical (Section 5), and disposal activities. This document is not biological hazards (Section 6), as well as mixed intended to be a complete compilation of all the and multiple-hazards sample waste (Section 7). regulatory requirements with which the laboratory may have to comply to meet local, Although samples received by laboratories are state, and federal mandates. It is the not considered to be regulated waste while laboratory’s responsibility to ensure that their awaiting testing, while stored after testing, or programs and procedures are in full compliance while being transported back to the sample with the applicable regulations. The World collector (40 CFR 261.4(d)), all samples should Wide Web Uniform Resource Locators (URLs) be treated as potentially hazardous. However, provided throughout this document provide the once samples are analyzed and designated for most currently available information at the time disposal or decontamination, they should be of document preparation. Please note that these treated as a regulated waste, meeting all federal links will be reviewed and updated periodically, and state requirements. following publication of updated SAM

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3.0 Overview of Laboratory Responsibilities

This section summarizes laboratory • Waste container packaging and labeling responsibilities and management strategies for • Arranging for shipment and preparation disposal of chemical, radiological, or biological of shipment papers samples and associated analytical waste. In • Packaging requirements some cases, multiple management strategies • Disposal options may be required, such as when a biological • (land-ban restrictions, laboratory uses an analytical technique with a acceptable wastes, packing requirements) chemical component, thus requiring a chemical • (acceptable wastes, packing disposal plan. requirements) • Health and safety for storage and Waste Management transportation areas • Training requirements Waste Management Plan • Personal protective equipment (PPE) Laboratories handling and disposing of samples • Exposure monitoring and analytical waste must have a Waste • Plan implementation Management Plan that is in compliance with all • Information accessibility by staff applicable local, state, and federal regulations. • Laboratory accountability Laboratories also must be able to demonstrate • Audits that this plan is being followed by personnel for • Record keeping requirements the safe handling and disposal of all waste • Requirement for review and updates materials generated. A laboratory’s Waste (e.g., at least annually) Management Plan must include information and instructions regarding: Waste Management Administrator • Types of wastes expected to be generated at the laboratory In addition to a Waste Management Plan, • Responsibilities of laboratory personnel laboratories must have a Waste Management Administrator with knowledge of all regulations • Management authorization (signatures) concerning waste handling, shipping, and • Accumulation of wastes for disposal disposal. As laws and statutes are periodically • Identification and inspection of waste updated and modified with respect to hazardous storage areas waste identification, shipment, and disposal, the • Waste classification and segregation administrator must frequently review regulations • Record keeping concerning contaminants and different levels of • Decontamination materials (storage of contamination, packaging, markings, shipping unused and spent decontamination regulations, and safety requirements as materials) prescribed by the U.S. Department of Labor • Publicly-owned treatment works Occupation Safety and Health Administration (POTW) disposal (OSHA). In most states, Waste Management • Permit and reporting requirements Administrators are required to attend and pass a • Waste neutralization requirements one to two day training course, and are • Waste storage responsible for the following: • requirements • Identifying waste-generating processes, • Storage accumulation and date type of waste generated, expected requirements contaminant concentrations, and expected • Primary containment amounts generated during a specified time • Waste shipment period • Federal and state regulations • Maintaining a Waste Management Plan

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and/or a Chemical Hygiene Plan, Generator Status Radiological Safety Plan, and/or Biological Laboratories with chemical and/or radiological Safety Plan waste must have a waste generator status and an • Identifying the local POTW and understanding of the required limits and ensuring proper communication and permit documentation to maintain this status (see requirements Section 3.4.4 and Table 3-1). Unlike processors • Coordinating with waste brokers; waste and manufacturers, which generate large haulers; and Treatment, Storage, and amounts of consistent waste types, most Disposal Facilities (TSDFs) approved to laboratories typically generate small amounts of handle each waste identified varying wastes and therefore face challenges in • Identifying proper storage containers for costs and planning. Although laboratories likely each waste type will be small quantity generators, disposal of • Completing waste labels for each highly contaminated sample wastes might alter storage and shipping container this status for a specific period. The Waste • Tracking opening and closing dates for Management Administrator must review the each storage container at satellite locations appropriate regulations carefully to ensure and in bulk waste storage location records and reporting are completed properly. • Completing required or neutralization Waste Broker • Completing Waste Profiles with the Laboratories with chemical or radiological waste waste broker, and receiving TSDF must have an identified waste broker who can acceptance for each waste prior to shipment assist in profiling, manifesting, and inspecting • Receiving and maintaining copies of laboratory waste prior to shipment; a certified waste hauler identification documents and TSDF; and a hauler capable of properly handling certified driver’s licenses, and TSDF the type of waste that can be expected following permits as required for each waste type. analysis of samples containing the SAM Also maintaining copies of hauler and analytes. Many states require waste brokers to TSDF insurance attend and pass a hazardous materials disposal • Ensuring wastes are properly packaged training course for chemical wastes. A waste and labeled for transportation using Packing broker is not needed for disposal of treated, non- Groups and proper shipping names infectious biological waste. Depending on state • Completing the Waste Manifest and Bill and local regulations, a waste broker also may of Lading for each waste shipment not be required for disposal of untreated • Submitting copies of the Waste Manifest biological waste. to each required government office • Ensuring transportation vehicles meet Documentation placard requirements, wastes are properly Laboratories must maintain accurate, up-to-date, segregated and secured, and vehicles are in and easily retrievable records of sample and good working condition waste handling. This documentation is essential • Ensuring waste shipments arrive as for meeting state regulations, planning and specified and are accepted at the approved tracking sample disposition, reducing liability, TSDF facilitating inspections, and responding to • Receiving and maintaining disposal inquiries and information requests. Many certificates documenting that the TSDF has regulations and regulatory authorities require completed disposal, and containing dates, comprehensive documentation of these activities batch identification, and disposal location to assure compliance. Each agency has unique • Visiting TSDFs and specific reporting periods and submission • Reviewing laboratory procedures for dates, data reporting formats, and record waste minimization and reduction retention times. Documentation requirements and procedures must be included in the • Completing annual reports for laboratory’s Waste Management Plan. regulatory agencies

These requirements typically include:

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• Preliminary documentation of sample or Energy Act (AEA), RCRA, and Toxic site characterization Substances Control Act (TSCA). • Waste Profile acceptance • Open/close dates for storage containers Regulatory Exemptions • Shipping container purchase records Some wastes may be exempt from regulations • Waste manifests and bill of lading because of the production process, level of • Disposal certificate contaminants, volume of waste, or the waste • Waste minimization review findings management option chosen. For example:

Guidelines for Waste Minimization Some wastes may be disposed of in a wastewater discharge if the contaminants are Waste avoidance and can regulated and are below regulatory levels (see 40 significantly reduce the amount of waste a CFR Parts 136 and 403) laboratory handles, and is a critical part of any A hazardous waste generator that produces less laboratory Waste Management Plan. The than 100 kg of waste in a month may be a following guidelines are suggested for waste conditionally exempt small quantity generator minimization. and thus be exempt from many of the requirements of the RCRA Waste Categorization and Some radioactive waste may be managed as Segregation non-radioactive if the total level of radioactivity Proper waste categorization can help avoid is below an exempt or de minimis level, or if the unnecessary, inappropriate, and costly waste activity for specific radionuclides is below treatment, storage, and disposal. For example, established levels as described in 10 CFR 61 the processes and definitions that the laboratory uses to determine that a waste is radioactive or Method Selection non-radioactive will have a great influence on The analytical method selected for sample the amount of radioactive waste that the analysis or handling determines the type and laboratory must manage. Once a waste has been volume of waste generated. If two methods will properly categorized, the laboratory can achieve the required measurement quality prioritize the waste options for elimination, objectives, the laboratory might select the reduction, or modification. method that produces the least amount or most easily managed waste. For example, biological Laboratory waste can typically be segregated laboratories can minimize the use of chemical into the following categories: radioactive solid disinfectants that require handling and disposal waste, radioactive waste, Resource as hazardous substances by considering Conservation and Recovery Act (RCRA) waste, alternative disinfection procedures, such as polychlorinated biphenyl (PCB) waste, autoclaving, that do not generate hazardous biological hazards, and . waste. Current laboratory guidelines for Segregating wastes by the appropriate category working with infectious microorganisms at allows them to be managed by the most cost- Biosafety Level 3 (BSL-3) laboratories effective option. Combining highly regulated recommend that waste be decontaminated before waste streams with less stringently regulated disposal and that select agents be destroyed waste streams usually requires the total waste using a steam autoclave. Method selection is stream to meet the most stringent waste discussed in greater detail in Section 6.3. management requirements. For example: It also may be possible to replace hazardous Non-hazardous waste mixed with hazardous analytical reagents with non-hazardous reagents waste is managed as hazardous waste. and still meet method requirements and data Non-radioactive waste mixed with radioactive quality objectives (refer to analytical methods waste is managed as radioactive waste. listed in SAM for information regarding Hazardous waste mixed with radioactive waste alternative reagents and materials). In addition, (referred to as mixed waste) is managed in substituting a short-lived radionuclide for a compliance with requirements of the Atomic long-lived radionuclide may ultimately result in

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reducing radioactive waste. Methods that are decontaminated and re-used or disposed of as recommended for analysis of environmental non-hazardous waste. Pre-use of materials is samples for confirmatory identification and discussed further in Sections 4.3, 5.3, and 6.3. measurement of SAM analytes are listed in the SAM document (http://www.epa.gov.sam). 40 Safety CFR Part 136 also provides guidance regarding Laboratories must have a Chemical Hygiene analytical methods and discharge limitations Plan and/or Radiological Safety Plan or corresponding to analytes regulated by EPA in Biological Safety Plan covering all aspects of wastewater discharges. sample and waste management specific to the target contaminants. This plan must encompass Sample Amounts personnel responsibilities, engineering controls, If possible, laboratories can request that excess monitoring, emergency response, and special sample material not be collected or received. To handling criteria for samples containing minimize the amount of sample waste, significantly elevated contaminant levels. Many laboratories should receive only the amount of of the contaminants included in SAM are not sample needed for sample analysis, analytical routinely handled by laboratories, and hygiene quality control, and a limited amount of excess and safety plans must address samples and in case of sample loss or other unforeseen analytical materials containing these problems or uses. For example, laboratories contaminants.1 These plans provide guidelines might request approximately two times the for the protection of employees from health amount of sample required by the analytical effects associated with hazardous chemicals method. Approximately four times the amount used in the laboratory, and include information required may be needed if the laboratory will be regarding: analyzing matrix spikes and matrix spike • Responsibilities of laboratory personnel duplicates. Reserve sample amounts should be • Avoidance of routine exposures minimized with up-front planning. It may also • Housekeeping be possible to convert a method to a micro-scale • Chemical procurement and storage method that uses significantly less sample and • Chemical inventory reagents. To optimize method sensitivity in the • Staff training situation of evaluating the effectiveness of • Hazards identification and monitoring decontamination, however, it may be necessary to use large quantities of sample material. • Environmental maintenance and monitoring Reagent Procurement Controls • Maintenance and inspections • Medical monitoring of personnel Amounts of reagents and materials purchased by a laboratory often are determined by price • Material Safety Data Sheets (MSDSs) discounts available on large quantities, instead • Personal Protective Equipment of the amount required. The real cost of • Emergency equipment purchasing these materials should include the • Standard operating procedures (SOPs) initial purchase price plus disposal costs for health and safety (lifetime costs). Procurement of hazardous • Employee training, including dry runs material should be initiated only if a non- for handling hazardous samples hazardous substitute is not available. Rotating • Waste disposal procedures (included in chemical stock (first in, first out) also can help Waste Management Plan) avoid expiration. • Chemical or biological handling procedures (e.g., flammable, corrosive, Re-Use of Materials reactive chemicals; compressed ; Some materials may be recovered from the radioactivity; , , analytical process and re-used in subsequent reproductive ) analyses. For example, distillation of certain used organic may purify them

sufficiently for . Glassware and some 1 disposable equipment can often be An example chemical hygiene plan can be found at: http://ehs.okstate.edu/statestuff/samplechp.pdf.

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• Working with moderate to highly reviewed for regulations having provisions that chronic toxic substances pertain to laboratory disposal of analytical waste • Working with highly acute toxic expected to be generated by laboratories substances analyzing samples during remediation activities following homeland security events. Wastes All laboratory staff require training related to the generated from samples and sample analysis tasks that they perform in relation to hazardous must comply with EPA regulations at 40 CFR substances. This training will vary greatly by Part 260 and with DOT regulations at 49 CFR the tasks performed, the type(s) of hazardous Parts 171 - 199, which regulate packaging, substance(s), and the intensity of the handling, labeling, marking, placarding, and (e.g., low level . high level). Regardless of routing of all hazardous shipments within the these factors, OSHA regulations at 29 CFR U.S. The location of this information in the 1910.132(f) require that staff be trained in the CFR is provided in Table 3-2 (Section 3.4.7). A use of Personal Protective Equipment (PPE). condensed summary of these regulations and of Training should be completed in a non- U.S. Department of Defense (DoD) directives is hazardous environment prior to PPE use, and provided below. This section provides only should be repeated at the frequency required in summary information; it is the laboratory’s OSHA and Superfund Amendments and responsibility to have a Waste Management Authorization Act (SARA), Title III. At a Administrator (Section 3.1.2) who is fully aware minimum, the training must include: of and familiar with federal, state, and local • Proper use and maintenance of selected regulations affecting disposal of hazardous protective clothing waste. • Nature of hazards and the consequences of not using the protective clothing U.S. Occupational Safety and Health • Instructions in inspecting, donning, Administration (OSHA) checking, fitting, and using protective OSHA regulations (29 CFR Part 1960) provide clothing for the safety of personnel working with • PPE user's responsibility (if any) for hazardous materials and wastes. Training decontamination, cleaning, maintenance, requirements for handling sample wastes and for and repair of protective clothing general safety also are covered. Laboratories • Emergency procedures and self-rescue using this document must have an approved in the event of protective Health and Safety Plan and laboratory staff must clothing/equipment failure be trained in procedures and requirements for • The buddy system handling hazardous materials, samples, and waste. The health and well being of laboratory Primary Organizations and Acts that staff is paramount in handling and disposing of Dictate Waste Handling and Disposal these potentially hazardous environmental samples and associated analytical waste. The guidelines provided in this document are not Accordingly, OSHA regulations pertaining to intended to be used without knowledge and PPE must be reviewed in Sections 132–138 of comprehension of applicable federal, state, or 29 CFR 1910, as well as Section 22 for general local regulations. These regulations must be “housekeeping” and Section 141 for general consulted prior to development and environmental controls. implementation of a laboratory’s waste management activities. Summary information Regulations involving employee safety and regarding general waste management regulations emergency response under the Incident is provided in Sections 3.4.1 through 3.4.7. Command System (ICS) and National Incident Summary information regarding regulations Management System (NIMS) are covered in 29 applying to chemical, radiological, biological, CFR 1910.1200, 1910.120, and 1926.65. OSHA and multi-hazardous wastes is provided in does not provide blanket exemptions or waivers Sections 4.0, 5.0, 6.0, and 7.0, respectively. In to regulations involving personal safety, even preparing this document, the U.S. Code of during emergency conditions and operations. Federal Regulations (CFR) and U.S. Department However, as part of the ICS, the Incident of Transportation (DOT) directives were

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Commander must consider the risks associated final disposal), and provides regulations at 40 with operations that have the potential to result CFR Parts 239 - 299. This Act is intended not in exposures exceeding permissible exposure only to protect human health and the limits and manage the response accordingly. environment by prohibiting open dumping, but also to conserve materials and energy resources Clean Water Act (CWA) by encouraging waste , reuse, and The Clean Water Act provides for the protection treatment. Pursuant to RCRA, EPA developed and maintenance of the chemical, physical, and hazardous waste management regulations for biological integrity of the nation’s water. CWA generators and for TSDFs. In 1984, Congress regulations (40 CFR Parts 112 – 503) address expanded the scope of RCRA with passage of the control of discharges into U.S. waterways, the Hazardous and Solid Waste Amendments including direct and indirect discharges, as well (HSWA), which directed EPA to adopt as the injection of wastewater into the ground. regulations governing small quantity generators Direct discharges into surface waters are (SQGs) of hazardous waste, such as many small regulated by National Pollutant Discharge laboratories. Most laboratories routinely Elimination System (NPDES) permit conditions. generate hazardous waste and, therefore, are Indirect discharges to a POTW is controlled subject to RCRA hazardous waste management under the National Pretreatment Standards regulations at 40 CFR Parts 260 to 270. These (§403). regulations include requirements governing waste classification, accumulation, disposal, Comprehensive Environmental recordkeeping, and emergency preparedness. Response, Compensation, and Liability This Act addresses sample wastes by regulating Act (CERCLA) and the Superfund the identification of the hazardous constituent, Amendments and Reauthorization Act storage of the sample waste, and proper (SARA) shipment and disposal of the sample waste. Regulations under CERCLA (40 CFR Parts 300 to 302) provide a mechanism for the federal Under RCRA regulations, there are three classes government to respond to hazards posed by of generators: (1) Conditionally Exempt Small uncontrolled release of hazardous substances. Quantity Generator (CESQG); (2) SQG; and (3) By liabilities imposed on all parties connected to Large Quantity Generator (LQG). Each level a release. As a laboratory may be held has specific accumulation levels, holding times, responsible for the entire costs associated with a disposal options, and reporting criteria. cleanup of a hazardous material, all aspects of Information regarding these criteria, including processing, handling, and disposal (e.g., changes needed when status is increased, is selecting the proper waste transporter and provided in Table 3-1. Laboratories accepting disposal facility) should be undertaken with samples in large quantities might change great care. generator status, requiring an increase in both reporting requirements and training of staff. Resource Conservation and Many states have modified these requirements Recovery Act (RCRA) and often have removed the lowest level (CESQG). RCRA provides for tracking of all hazardous substances from “cradle to grave” (generation to

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Table 1: RCRA Water Generator Status Requirements Requirement CESQG SQG LQG (40 CFR) Waste Determination Applicable Applicable Applicable (262.11) Generation Rate Limits <100 kg/month 100 – 1,000 kg/month 1,000 kg/mo or greater ( 261.5 and 262.34) Accumulation Not to exceed 1,000 kg Quantity Limit w/o hazardous waste or 1 kg Not to exceed 6,000 kg No limit Permit acute hazardous waste at at any time (261.5 and 262.34) any time. 180 days (or 270 days if Accumulation Time waste is to be No limit 90 days (261.5 and 262.34) transported over 200 miles) EPA ID Number Not required*; possible Required Required (262.12) state requirement Mark Containers Not applicable with Start Date Applicable Applicable

(262.34) Mark Containers “Hazardous Waste” Not applicable Applicable Applicable (262.34(a)) Air Emission Standards Not applicable Not applicable Applicable (265 Subpart C) Satellite Accumulation Not applicable Applicable Applicable (262.34(c)) Use Manifests Not required, possible state Required Required (262, Subpart B) requirement Exception Reporting Not required Required after 45 days Required after 35 days (262.42) Biennial Report Not required; possible Not required Required (262.41) state requirement Basic planning required Full written plan in Not required, but OSHA in accordance with accordance with 265 Contingency Plan (29 CFR 1910.38) requires 262.34(d)(4) and (5) and Subpart D, is required by (265, Subpart D) emergency planning 265, Subpart C as well 262.34(a)(4) and OSHA as OSHA regulations regulations Full compliance with RCRA Personnel Not required, but Basic training required training requirements in Training recommended by 262.34(d)(5)(iii) 265.16 is required by (262.34 and 65.16) 262.34(a)(4) Compliance with Compliance with Storage None, but OSHA technical standards in technical standards in Requirements regulations under 29 CFR Part 265, Subparts I and Part 265, Subparts I, J, (without permit) 1910, Subparts H and N, J; for containers and W, and DD, is required (262.34 and 265) apply, particularly 29 CFR tanks, is required by by 262.34(a)(1) and 1910.106 262.34(d)(2) and (3) and OSHA regulations OSHA regulations

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Requirement CESQG SQG LQG (40 CFR) Notification of regulated waste activity, determinations, Notification of regulated generation, manifests, waste activity, waste Waste determinations and land disposal restriction, determinations, generation log required exception reports, Recordkeeping generation log, (notification of regulated biennial reports, Requirements manifests, land disposal waste activity, training correspondence with (262.40) restriction notifications, records, manifests, and land local responders, RCRA exception reports, and disposal restriction training records, and correspondence with notifications recommended) contingency plan; weekly local emergency container inspection is responders required; equipment maintenance logs recommended. Waste “Designated State-approved or RCRA RCRA-permitted facility RCRA-permitted facility Facility” (264 and permitted facility or or legitimate recycler or legitimate recycler 172) legitimate recycler Land Disposal Possible state requirement Applicable Applicable Restrictions (268.7) Note: CESQG - Conditionally Exempt Small Quantity Generator SQG - Small Quantity Generator LQG - Large Quantity Generator

RCRA Laboratory Wastewater be carried out in consultation with the Under 40 CFR 261.3(E), wastewater that is Administrator of the EPA and the states. The generated by laboratory operations, and that program has three goals: (1) identification and contains toxic wastes listed in Subpart D of 40 cleanup of contamination from hazardous CFR Part 261, is not considered a hazardous substances consistent with CERCLA cleanup waste if it meets the following conditions: the requirements; (2) correction of environmental annualized average flow of laboratory damage, such as detection and disposal of wastewater does not exceed one percent of total unexploded ordnance, that creates an imminent wastewater flow into the head works of the and substantial endangerment to public health facility’s wastewater treatment or pre-treatment and the environment; and (3) demolition and system, or the wastes combined annualized removal of unsafe buildings and structures, average concentration does not exceed one part including those at Formerly Used Defense Sites per million in the head works of the facility’s (FUDS). wastewater treatment or pre-treatment facility. Toxic wastes used in laboratories that are The DoD Explosives Safety Board (DDESB) demonstrated not to be discharged to wastewater provides an objective expert to advise the are not to be included in this calculation. Secretary of Defense and the Service Secretaries on matters concerning explosives safety, as well U.S. Department of Defense (DoD) as to prevent hazardous conditions for life and Directives property (both on and off DoD installations) that The DoD has been implementing an Installation result from the presence of explosives and the Restoration Program since the mid-1970's, environmental effects of DoD munitions. The which was formalized by statute with the roles and responsibilities of the DDESB were passage of SARA in 1986, amending CERCLA. expanded in 1996 with the issuance of DoD Section 211 of SARA established the Defense Directive 6055.9 on July 29, 1996, and modified Environmental Restoration Program (DERP) to in 2004. The directive provides the DDESB with responsibility for serving as the DoD advocate

10 for resolving issues between explosive safety Hazardous Materials (HAZMAT) standards (DoD-Directives) and environmental Transportation Act standards (EPA-RCRA regulations). DDESB is Wastes generated from samples and sample responsible for promulgating safety analysis must comply with EPA regulations at requirements and overseeing their 40 CFR Part 260 and with DOT regulations at implementation as necessary to protect human 49 CFR Parts 171 - 199, which regulate welfare and the environment. These packaging, handling, labeling, marking, requirements provide for extensive management placarding, and routing of all hazardous of explosive materials. shipments within the U.S. The location of this information in the CFR is provided in Table 3-2.

Table 2: EPA and DOT Shipping Regulations EPA 40 CFR Topics DOT 49 CFR Regulations Regulations Definitions Section 260.10 Section 171.8 Identification and listing of Part 261 Section 172.1 hazardous materials Characteristic of hazardous Sections 261.20 to 261.24 Sections 171.8, Part 173 materials Sections 262.20 to 262.23 Compliance with manifesting Section 172.205 and 263.20 to 263.21 Packaging and containers Section 262.30 Parts 173, 178 and 179 Labeling requirements Section 263.31 Section 172.400 Marking requirements Section 262.32 Sections 172.300 to 172.330 Placarding requirements Section 263.33 Sections 172.500 to 172.558 Hazardous material and waste Sections 263.30 and Sections 171.15 to 171.16 discharge incidents 263.31 Sections 262.34 Part 370 – reporting Section 171.1 for storage while Storage requirements to local and in transit state government

Waste Management Administrators and other detailed on a state by state basis. In this case the staff responsible for preparing waste for state offers a course and/or has a certification shipment must be trained in waste handling, process for the laboratory waste management packaging, and corresponding regulations (49 administrator. The following general practices CFR 172.704). Many states offer a course provide a summary of DOT requirements (at 49 and/or have a certification process. DOT CFR173.24) for packaging wastes for disposal: regulations also require that each shipment must • Except as otherwise provided in this be certified by the person offering hazardous subchapter, there will be no identifiable material for transportation (49 CFR 172), to (without the use of instruments) release of certify that the materials are properly classified, hazardous materials to the environment described, packaged, marked, and labeled, and • The effectiveness of the package will are in proper condition for transportation not be substantially reduced; for example, according to DOT. Many laboratories have a impact resistance, strength, packaging certified treatment, storage, and disposal facility compatibility, etc., must be maintained for pick up their hazardous waste. Thus, often the minimum and maximum temperatures, laboratory staff are not certified to ship changes in humidity and pressure, and hazardous waste. In this scenario, hazardous shocks, loadings, and vibrations normally waste shipments are certified by the shipper who encountered during transportation picks up the waste, not a laboratory employee. • There will be no mixture of gases or Some states require certification for laboratories in the package which could, through that store waste, but this requirement can only be

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any credible spontaneous increase of heat or impacting laboratory waste disposal. EPA pressure, significantly reduce the listings of state Internet sites and regulation effectiveness of the packaging sources are provided in Appendix A for • There will be no hazardous material chemicals, Appendix B for radiologicals, and residue adhering to the outside of the Appendix C for biologicals. Information also package during transport can be found at: • Chemicals State Regulations (http://www.epa.gov/osw/hazard/wastetypes State regulators can incorporate, and even /universal/statespf.htm) increase, the level of compliance needed in the • Radiologicals (http://nrc- federal regulations. RCRA regulations in 40 stp.ornl.gov/stpdirectr.html) CFR Parts 256 and 271 provide guidelines to • Biologicals states for producing acceptable waste (http://www.epa.gov/osw/nonhaz/industrial/ management plans. In addition to complying medical/programs.htm) with federal regulations, laboratories must comply with all pertinent state regulations

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4.0 Handling and Disposal of Samples and Analytical Waste Containing Chemical Hazards

Hazardous waste contains properties that make it Ignitability (D001) – Ignitable wastes can dangerous or potentially harmful to human create fires under certain conditions, are health or the environment, and is regulated spontaneously combustible, or have a flash point under RCRA Subtitle C. A RCRA hazardous less than 60 °C (140 °F). Examples include waste is a waste that appears on one of four waste oils and used solvents. For more details, hazardous wastes lists (F-list, K-list, P-list, or U- see 40 CFR §261.21. Many military munitions list), or exhibits at least one of four are hazardous via this characteristic, even characteristics (ignitability, corrosivity, without a detonation source being present. reactivity, or toxicity). RCRA lists are organized into three categories: Corrosivity (D002) – Corrosive wastes include or bases (pH ≤ 2 or ≥ 12.5) that are The F-list (non-specific source wastes) capable of corroding containers, such as identifies wastes from common manufacturing storage tanks, drums, and barrels. Battery and industrial processes, such as solvents that is an example. For more details, see 40 CFR have been used in cleaning or degreasing §261.22. operations. Because the processes producing these wastes can occur in different sectors of Reactivity (D003) – Reactive wastes are industry, the F-listed wastes are known as unstable under "normal" conditions, and can wastes from non-specific sources. Wastes cause explosions, toxic fumes, gases, or vapors included on the F-list can be found in the when heated, compressed, or mixed with water. regulations at 40 CFR §261.31. Examples include lithium-sulfur batteries and explosives. For more details, see 40 CFR The K-list (source-specific wastes) includes §261.23. There are currently no test methods certain wastes from specific industries, such as available. petroleum refining or manufacturing. Certain sludges and wastewaters from treatment Toxicity (D004 and D043) – Toxic wastes are and production processes in these industries are harmful or fatal when ingested or absorbed (e.g., examples of source-specific wastes. Wastes containing , lead, etc.). When toxic included on the K-list can be found in the wastes are land disposed, contaminated liquid regulations at 40 CFR §261.32. may leach from the waste and pollute ground water. For more details, see 40 CFR §261.24. The P-list and the U-list (discarded commercial chemical products) include specific commercial The United Nations (UN) Chemical Weapons chemical products in an unused form. Some Convention defines a agent as and some pharmaceutical products “any chemical which, through its chemical effect become hazardous waste when discarded. on living processes, may cause death, temporary Wastes included on the P- and U-lists can be loss of performance, or permanent injury to found in the regulations at 40 CFR §261.33. people and animals.” Nerve and blister agents are the two classes of chemical warfare agents Waste that does not meet any of the listings that have been most widely manufactured and explained above may still be considered a used for military purposes. Common blistering hazardous waste if it exhibits one of the four agents include mustard (HD), nitrogen mustards characteristics defined in 40 CFR Part 261 (HN-1, HN-2, HN-3), and (L). Subpart C (commonly referred to as the RCRA Common choking agents include D List). (PS), , (CG), and

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(DP). Common organo-phosphorous nerve phosphonothiolate). Common chlorinated agents are GA (), GB (), GD (), blister agents include mustard (HD) and GF (cyclohexylsarin) and VX (O-ethyl-S-[2- nitrogen mustards (HN-1, HN-2, and HN-3). diisopropylaminoethyl]methyl-

Note: Laboratory waste containing CWAs must be handled only by trained personnel, using appropriate safety precautions. In all cases, laboratories must contact appropriate authorities identified by the EPA Project Manager and should follow procedures that have been approved specifically for handling these wastes and that are included in the laboratory’s approved Waste Management Plan. Small-scale treatment of waste containing dilute chemical warfare agent is discussed in Section 4.3.6.

Regulations In addition to the regulations summarized in limitations and reporting information for each Section 3.4, the laboratory must be aware of level of generation status. A generator may requirements included in Title III of SARA for store hazardous waste up to 90 days, 180 days, notification of municipalities. The Emergency or 270 days depending on its status as defined by Planning and Community Right-to-Know Act the regulations or the distance the generator is (EPCRA or Title III of SARA) requires all from the disposal facility (40 CFR 262.34). A facilities storing or producing hazardous generator may accumulate as much as 55 gallons materials to inform local and state communities. of hazardous waste or one quart of acutely This requirement is necessary if the laboratory hazardous waste in containers at or near the meets the quantities of any one or more point of generation where wastes initially chemicals on the list of “extremely hazardous accumulate, which is under the control of the substances” at 40 CFR Part 372. The owner of operator of the process generating the waste (40 the laboratory must report the chemical to the CFR 262.34). The storage time clock (90, 180, state and local emergency response commission or 270 days) does not begin until the waste and have action plans in the event of a release. volume reaches 55 gallons (or one quart, in the case of acutely hazardous waste), or whenever Storage waste is stored in a 90-day accumulation area. The operator of a hazardous waste storage area A small laboratory may require additional must inspect areas in which waste containers are training, reporting, and time management if stored, at least weekly, looking for leaks and large amounts of contaminated wastes are deterioration caused by corrosion or other generated during a short time period. A factors (40 CFR 265.174). 40 CFR 262.34 summary of requirements for storage of these addresses requirements for prevention and waste materials is provided below. preparedness, contingency plans, and emergency procedures that may apply to a laboratory that All sample and sample preparation (extraction) stores RCRA waste. Laboratory management wastes should be segregated according to should review 40 CFR 262.34 prior to storing chemical class. Acidic wastes should be stored these wastes. separately from basic wastes, oxidizers should be stored separately from organics, and Samples and analytical wastes containing positive wastes should be stored separately from reportable levels of RCRA hazardous chemical acids to reduce the possibility of inadvertent analytes (RCRA List D) must be stored between potentially dangerous releases/exposures, fires, 4 ºC and 6 ºC and segregated from lower level or increased hazardous status. contaminated samples and from non- environmental samples. However, once Each type of waste (based on the specific designated for disposal by the laboratory, the chemical contamination, level, and initial samples must be treated as a regulated waste, generation site) must be stored in a separate, meeting all RCRA and generator status labeled container to help reduce multi-hazardous requirements. Table 3-1 lists quantity storage wastes and assist in source reduction.

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The label must contain the chemical explosives [such as trinitrotoluene (TNT)] contaminant, the waste generation point, the date are capable of propagating (transmitting) a of generation, and the initials of the technician detonation if initiated by flame. Soils responsible for the initial generation of the containing more than 15 percent secondary waste. explosives by weight are susceptible to initiation by shock. To be safe, the U.S. The laboratory must use proper storage Army Environmental Center considers all containers, limiting the container size to soils containing 10 percent or more of properly reflect the amount of sample and secondary explosives or mixtures of sample waste expected to be generated. The secondary explosives to be reactive or storage container must be properly designed, ignitable soil. meeting Packing Group I, II, or III criteria (49 CFR Part 173, Subpart D), to double as the The laboratory must designate a labeled correct transport/disposal container (e.g., drum, container for wastes containing RCRA List D Packing Group) to reduce handling of the waste levels of hazardous materials. This container materials. Storage containers must be made of must be labeled with all information necessary proper materials with sealable lids. to completely identify the original sample or site location. All solid wastes generated during the Once samples and analytical waste are sample preparation phase of analysis must be designated for disposal by the laboratory, all placed in this container, and the container must waste locations that have not been identified as be stored with the original sample(s) to reduce the main storage location must meet the satellite the amount of waste needing to comply with location rules (40 CFR Part 262) and waste increased levels of sample handling holding times, as described in Appendix D. requirements and disposal criteria. Sample extract waste must be contained and maintained The Generator Status will determine the length with the original sample or, if appropriate (see of storage time allowed (see Appendix). Section 4.3.2), discharged to the municipal water treatment system. Storage locations must be properly labeled and documented (49 CFR 173 subpart B). For sample extract wastes, the laboratory must allow solvents to evaporate in a hood with Special storage precautions must be taken for appropriate safety considerations, leaving only a samples and wastes containing military ordnance residue. This container should be placed with or chemical warfare agents. These storage the solid sample waste or liquid sample for precautions include: disposal (40 CFR 264.1030). Evaporation is not • Limiting potential contact and increased always a legal form of treatment. See more secondary containment. The secondary details at 40 CFR 264.1030. containment must contain an excess of absorbent that would absorb all of the liquid Treatment if spilled from the primary container. • Refrigerating samples containing dilute Aqueous and Water Soluble Waste chemical warfare agents It may be possible to treat aqueous and water • Wearing protective covering, such as soluble wastes for disposal through discharge to lab-coats, safety goggles/, nitrile a POTW. The laboratory must notify the POTW gloves, and a pair of butyl rubber gloves of potential discharges prior to using this option over the nitrile gloves and must have gained a permit, if applicable, • Limiting volumes of samples and all that meets municipality requirements. See related wastes, if possible, to those deemed Section 4.3.2 for approved federal pretreatment non-explosive by contact or impact options. If the laboratory disposes of more than • Familiarizing all employees with 15 kg of hazardous waste (or any acute wastes) MSDSs and special handing requirements. per month to a POTW, the EPA, state waste For example, soils with a 12 percent or authority, and POTW must be notified (40 CFR greater concentration of secondary 403.12). Discharges to storm drains or septic

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systems are prohibited. important that only elementary neutralization occurs and that it is under a RCRA exemption To completely understand and effectively for hazardous waste treatment without a permit. manage its wastewater program, the laboratory Non-exempted treatment, without an RCRA must develop a wastewater management system permit, is a serious RCRA violation. The local that includes: POTW can assist with this action and provide • An inventory of wastewater (samples additional resources or necessary permits. and contaminants) discharges • Programs and practices for minimizing Air Sample Waste wastewater Some air samples with elevated contamination • Operating and maintenance procedures can be forced through media to absorb for wastewater discharge systems contaminants. The carbon material is disposed (collection and treatment, if required by of as a solid. Air filters also can be disposed of permit) as with other samples of the same hazard • Monitoring to check operations (as class. required by permit) • Recordkeeping to document compliance Solid Waste with permits Solid wastes should be collected and segregated. • Procedures to respond to emergencies Most solid wastes cannot be treated at the • Training program to ensure operators laboratory and should be properly characterized meet regulatory requirements and and disposed of at an approved disposal facility. operational requirements All free should be removed prior to • Procedures to assess planned changes disposal, and treated according to Section 4.3.2 as appropriate. Liquid Waste The treatment of liquid wastes is strictly Re-useable and Disposable Containers regulated by RCRA regulations. The fine for and Equipment violations is significant, and laboratory Empty containers that once held hazardous personnel must be familiar with the correct materials are not regulated as hazardous waste if procedure for pretreatment and disposal. Liquid they meet the definition of “empty.” Empty sample preparation wastes must be neutralized means that all hazardous materials have been prior to disposal. removed from the container and, for containers of 110 gallons or less, residue is no more than Hazardous Waste Mixed with Domestic . 3% by weight of the total capacity; for EPA's hazardous waste management regulations containers greater than 110 gallons, residue is no exclude from the definition of hazardous waste greater than 0.3% by weight of the total any wastes mixed with domestic sewage that capacity. Containers that held acutely hazardous enters a POTW (40 CFR 261.4(a)(1)). In most waste are considered empty only after being cases, laboratories must avoid discharging triple rinsed with a capable of removing regulated hazardous waste down the drain. the acutely hazardous waste residue. Disposable Generally, any laboratory that discharges down laboratory equipment also can be the drain more than 15 kg of hazardous waste decontaminated by triple rinsing with a solvent per month (40 CFR 403.12(p)(2)), or acutely capable of removing residue. The solvent rinse hazardous waste in any amount, is required to then must be managed as acutely hazardous notify the EPA Regional Office, the state waste. hazardous waste authorities, and the POTW of such discharges. Laboratory glassware and other re-useable equipment can be decontaminated using the Neutralization. In most states, it is acceptable to same procedures used to decontaminate empty neutralize acidic and caustic liquid sample containers, and cleaned in the same manner used wastes and dispose of the neutralized solution to clean glassware for laboratory use. Cleaning down the drain if it has no other hazardous solvents and procedures for these materials are characteristics. Where permissible, it is somewhat dependent on the intended use.

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Glassware intended for use during analysis of , for example, is cleaned differently than Each hazardous compound is grouped into a glassware intended for use in analyzing organic common characteristic hazardous class (40 CFR compounds. 172.101) for shipment. The sample wastes must be separated by hazard class and then by analyte Wastes Containing Chemical Warfare of concern for disposal. Agents Small amounts of chemical agents and glassware The laboratory should then apply for a waste contaminated with chemical agents can be profile from the selected TSDF. Waste profiles neutralized prior to disposal, using a solution of typically cover a period of one year. However, 5 – 10% sodium hypochlorite (NaOCl). other periods may be used depending on TSDF Reactions between NaOCl and waste, requirements. The waste profile lists the particularly solvents, can be highly exothermic contaminant concentration, contaminant by and the bleach must be added to and mixed with shipping name, frequency in shipping, generator the waste slowly in a hood. Complete ID, disposal method, land ban information, and neutralization may require mixing times from selected other information. This profile helps to several hours to overnight. Approximately 200 ensure the TSDF is capable of proper disposal. mL 5 – 10% NaOCl solutions can be added to The TSDF will provide the generator with a small amounts of waste (≤4 liters or ≤200 g Profile ID (Approval Code) to be listed on the solids) to result in a waste stream that is shipping manifest for the specific waste. primarily an aqueous solution of NaOCl. When Additional waste types cannot be shipped for neutralizing waste containing chemical agents, disposal without modifying or preparing a new the resulting waste should be analyzed and profile. handled as hazardous waste as defined by the results of analysis. Samples and sample wastes must be packaged for shipment according to the packing group Decontamination Waste criteria for the hazard class (40 CFR 173.2). Most decontamination wastes are solvents or Small quantities of materials that meet the aqueous solutions that have been used to rinse or definition of one or more of the following wash contaminated materials. This rinse hazard classes are not subject to any special material should be treated as contaminated requirements when in compliance with 49 CFR waste. Waste that the laboratory cannot treat 173.4: should be stored and segregated by contaminant • Class 3: Flammable and combustible (Section 4.2), and disposed of by a licensed liquid (see 49 CFR 173.120) TSDF and hauler. • Class 4, Division 1 (Division 4.1): Flammable solid (see 49 CFR 173.124) Packaging • Class 4, Division 2 (Division 4.2): Packing Groups II and III: Spontaneously Individuals involved in packaging hazardous combustible material (see 49 CFR 173.124) laboratory waste for shipment must have successfully completed DOT HAZMAT training • Class 5, Division 1 (Division 5.1): (see 49 CFR 173.12 regarding regulations Oxidizer (see 49 CFR 173.127) governing “lab-packs,” 49 CFR 173 Subpart B • Class 5, Division 2 (Division 5.2): regarding regulations governing packaging of Organic peroxide (see 49 CFR 173.128) hazardous materials, and 49 CFR 172 Subpart H • Class 6, Division 1 (Division 6.1): regarding DOT training regulations). Many Poisonous materials (see 49 CFR 173.132) laboratories contract hazardous material disposal • Class 7: Radioactive material (see 49 companies that have completed DOT HAZMAT CFR 173.403) training. Laboratory waste brokers (Section • Class 8: Corrosive material (see 49 CFR 3.1.4) that work in the laboratory often are 173.136) required to pass a state training course. This • Class 9: Miscellaneous hazardous requirement is state-specific. A summary of material (see 49 CFR 173.140) information provided in these regulations is provided below. The requirements for this exception are strictly

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monitored and many transporters will not accept Overpack drums might be required for DOT packages for shipment. Each hazard class is Shipments and should be sized to most closely divided into three packing groups with Level 1 secure the original shipping container. (I) being greatest degree of danger and Level 3 (III) being least degree of danger. Most laboratory hazardous sample wastes can be packaged in “lab packs” due to the small Packing materials and containers are quantity. This process uses smaller shipping manufactured to meet performance standards containers (30 gallons or less) that meet the described in 49 CFR 173.4. The laboratory must specified packaging requirements (40 CFR determine that the packaging or container is 173.2). The initial sample containers are placed consistent with the requirements for the in the shipping container and surrounded with respective packing group, and that the package absorbent materials, and the outside container is has been manufactured, assembled, and marked sealed. Each lab pack must be labeled with the in accordance. The manufacturer's marking proper Hazard Chemical name, the UN ID, the requirement is contained in 49 CFR 178.503 and total weight, and the closing date. An inventory consists of the following: containing the weight of each internal container • UN symbol and the proper shipping name and level of • Packaging identification code contamination of each internal container must be designating: attached to the shipping container and shipping • Type of packaging manifest. Each lab pack containing aqueous • Material of construction materials must be enclosed in a plastic bag, and • Category of packaging (when contain twice the amount of absorbent material appropriate) necessary to absorb the entire liquid content in • A letter identifying the performance the event of leakage. standard under which the packaging design has been tested: Note: Although lab packs eliminate the need to transfer wastes and reduce the occurrence of • X: Packages meeting Packing Group I, dangerous reactions resulting from mixing II, and III tests incompatible materials, this packing procedure • Y: Packages meeting Packing Group II is also often the most expensive. and III tests

• Z: Packages meeting only Packing If larger containers are used, the laboratory Group III tests should limit the size to 55 gallons. A solid 55 • Specific gravity or mass for which the gallon drum can weigh more than 350 pounds, packaging design type has been tested requiring a forklift to load it onto a truck. • Test pressure (for packaging intended to contain liquids); the letter “S” for packaging Solid material requires passing a paint filter test intended to contain solids (EPA SW-846 Method 9095B) specifying no • Last two digits of the year of “free liquid” is present. If the waste material manufacture, and (in some cases) the month fails the paint filter test, additional absorption of manufacture materials should be added. • Authorizing state • Name and address, or symbol, of Disposal manufacturer or approval agency Prior to disposal or transfer of waste to a waste • Packaging thickness (for metal or plastic hauler, laboratories must identify whether the drums or jerricans intended for reuse) waste is (1) a solid waste and/or (2) a hazardous • Rated capacity waste. The term solid waste is used very broadly in RCRA and refers to both Most laboratory waste drums will be UN1A1 nonhazardous and hazardous waste including (Liquids) or UN1A2 (Solids) steel or stainless solids, liquids, semi-solids, sludges, and steel drums that resist impact and corrosion compressed gases. EPA defines hazardous damage. Polyethylene (HDPE) should be waste in 40 CFR 261 as consisting of or partially labeled UN1H2 (Solids) or UN1H1 (Liquids), containing a “listed” waste or if it demonstrates and can be incinerated without removing wastes.

18 any one or more of the following characteristics: Land Disposal ignitability, corrosivity, reactivity, or toxicity Waste is removed to a certified landfill facility (see introduction to Section 4.0). The laboratory (typically in bulk shipping containers) and should use either documented analytical results buried in a matrix system. Each landfill operator or manufacturer’s certifications of reagents to is certified to accept specific wastes in determine the hazard characteristics of samples composition, quantity, and concentration. The and related waste. laboratory will need to ensure proper disposal requirements can be met and that the shipped The selection of a proper waste hauler is material meets the requirements of the landfill important. The laboratory is responsible for permit. Most hazardous wastes have been waste shipments and should expect proper designated under RCRA’s list of compounds documentation from the transporter for all that cannot be landfilled (i.e., the Land Disposal shipments. The waste hauler should assist in Restrictions [LDR] at 40 CFR Part 268) and properly completing the documentation for cannot be buried. shipment, manifest, or bill of lading, and in outfitting the truck in accordance with the Recycling correct hazard class. Wastes that meet specific requirements can be sent for recycling within the laboratory or off The selection of a proper TSDF is also site. For example, some solvents can be purified important. The TSDF must forward a copy of and reused for sample extraction; mercury can the approved Part A or B permit (see Section be sent for recycling. This waste is then 9.1.1) to the laboratory. The facility must be reclassified as hazardous material. This disposal capable of completing the required disposal option is not easily completed and often requires activities and associated requirements. Waste individual approval from permitting agencies. packed in a lab pack will be unpacked, checked against the manifest/bill of lading, and then Military Return placed into a disposal stream. When the waste is disposed of, the TSDF will issue a disposal Wastes that are identified as military wastes or certificate to the laboratory. The laboratory military explosives may need to be sent to a must maintain this documentation indefinitely. military facility for final disposal. The EPA Coordinator must provide additional information Incineration if this disposal option is required. Information is also provided by the EPA in the Handbook on Waste is removed to a certified incinerator the Management of Munitions Response Action (typically in bulk shipping containers) and (Section 10.2). destroyed by burning. Each incinerator operator is certified to accept specific wastes in Storage composition, quantity, and concentration. The laboratory will need to ensure proper disposal In some specific incidences, samples and sample can be met and that the shipped material meets wastes will be returned to the point of origin. the requirements of the incinerator permit. This return will require interfacing with the EPA Coordinator.

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5.0 Handling and Disposal of Samples and Analytical Waste Containing Radiological Hazards

Any activity that uses or produces radioactive Laboratory samples containing radiation levels materials generates radioactive waste. This that are greater than background (i.e., ambient waste can exist in gas, liquid, or solid form with level of radioactivity occurring at a site or in the varying levels of radioactivity, and can remain laboratory) must be treated as radioactive. radioactive for a few hours, several months, or Waste material containing licensable quantities hundreds of thousands of years. The Nuclear of radioactivity (as indicated in the laboratory’s Regulatory Commission (NRC) separates radioactive materials license) must be disposed radioactive wastes into two broad classifications: of in accordance with applicable federal and/or high-level or low-level. High-level radioactive state regulations. waste results primarily from the fuel used by reactors to produce electricity. Low-level Regulations radioactive waste (LLRW) is defined as any Any person or laboratory possessing, using, radioactive waste that does not belong in one of storing, or transporting quantities of radioactive the following three categories: (1) high-level materials must have a radioactive materials waste (spent nuclear fuel or the highly license in accordance with applicable state radioactive waste produced if spent fuel is and/or NRC regulations reprocessed), (2) uranium milling residues, and (http://www.nrc.gov/materials/miau/regs-guides- (3) waste with greater than specified quantities comm.html, contact number 1-800-368-5642, or of elements heavier than uranium (transuranics). 301-415-7000). Laboratories disposing of Low-level waste includes items that have radioactive waste must have a Radiation Safety become contaminated with radioactive material Officer on staff, as required by their radioactive or have become radioactive through exposure to materials license, with knowledge of all neutron radiation. This waste typically consists regulations concerning radioactivity. To obtain of environmental samples containing a license, laboratories must submit an radiological contamination, contaminated application to NRC and/or the applicable state. protective clothing, cleaning cloths, mops, This application must demonstrate how the filters, equipment, and tools. It is assumed that handling of these materials will meet the safety samples analyzed by laboratories supporting requirements in NRC regulations found in 10 EPA remediation activities will not include CFR Parts 19 - 21 and 30 - 39, or applicable high-level radiation, therefore, this document state regulations. Guidelines for obtaining a provides guidelines for handling samples state license can be found using the state Web containing low-level radioactive contamination site sources listed in Appendix B. Items and associated analytical waste. A radioactive typically addressed in a radioactive materials sample is defined by NRC as either: license include: • Any sample with activity concentrations • Types and quantities of licensable greater than the “Exemption Concentration” radioactive materials limits specified in 10 CFR 30.70, Schedule • Waste storage volume and time A constraints • Any sample containing a quantity of • Waste survey requirements activity greater than the “Exempt Quantity” • Personnel monitoring requirements limits specified in 10 CFR 30.71, Schedule

B Disposal of radioactive waste is a complex issue,

not only because of the nature of the waste, but

20 also because of the complicated regulatory Operations structure for managing it. There are a variety of • Part 40 - Domestic Licensing of Source stakeholders affected, and a number of Material regulatory entities involved. Government • Part 70 - Domestic Licensing of Special agencies involved in radioactive waste Nuclear Material management include EPA, NRC, Department of • Part 71 - Packaging and Transportation Energy (DOE), DOT, states, and affected tribes. of Radioactive Material Responsibilities of government agencies in the • Part 110 Export and Import of management of radioactive waste include the - Nuclear Equipment and Material following: • Section 150.20 - Recognition of Nuclear Regulatory Commission (NRC) Agreement State Licenses [Reciprocity]

The NRC has regulatory authority over storage Additional NRC requirements at 10 CFR that are and disposal of radiological wastes generated in pertinent to laboratories disposing of radioactive the United States. Part 61 of the NRC waste include: regulations (10 CFR) sets forth the procedures, criteria, terms and conditions for licensing sites • Part 2 - Specifies the licensing process for land disposal of low-level waste. The and requires an electronic record-keeping requirements established under Part 61 also system to preserve data needed for licensing provide the basis for agreement with state • Section 20.2002 - General provision regulations, since state rules must be compatible that allows for alternative disposal methods, with NRC requirements. Additionally, 10 CFR provided that doses are maintained As Low 20.2002 is available for use by licensees for As Reasonably Achievable (ALARA) and disposal of low-level wastes for which the within the dose limits of Part 20 extensive controls in Part 61 are not needed to • Part 61 -Licensing requirements for ensure protection of public health and safety and land disposal of radioactive waste the environment. Regulations require • Part 62 -Criteria and procedures for conformance with minimum acceptable criteria emergency access to non-federal and for waste management activities. NRC's regional low-level waste disposal facilities regulations are found in 10 CFR Chapter I, • Part 74 - Establishes requirements for which is divided into Parts 1 through 199. The control and accounting of special nuclear following are the principal requirements material, including documentation of governing the licensing of laboratory handling transfer of material and use of nuclear materials: • Part 19 - Notices, Instructions and NRC also provides guidance to licensees and Reports to Workers: Inspection and other stakeholders regarding transportation of Investigations packages containing radioactive material in its • Part 20 - Standards for Protection Standard Review Plan for Transportation Against Radiation Packages for Radioactive Material (NUREG- • Part 21 - Reporting of Defects and 1609). Noncompliance The U.S. Environmental Protection • Part 30 - Rules of General Applicability to Domestic Licensing of Byproduct Agency (EPA) Material Under Section 121(a) of the Nuclear Waste • Part 32 - Specific Domestic Licenses to Policy Act (NWPA), EPA is required to Manufacture or Transfer Certain Items promulgate generally applicable standards for Containing Byproduct Material protection of the environment from off-site releases of radioactive materials in repositories. • Part 33 - Specific Domestic Licenses of The standards are intended to limit the amount Broad Scope for Byproduct Material of radioactivity entering the biosphere outside • Part 34 Licenses for Industrial - the boundaries of a facility and the radiation Radiography and Radiation Safety exposure to the public from management of Requirements for Industrial Radiographic waste prior to disposal, and provide criteria to be

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followed for disposal of these wastes. These measure, but favors disposal rather than storage standards are found at 40 CFR Part 191 over the long term. Waste must be stored in an (Environmental Radiation Protection Standards appropriate container (e.g., 55-gallon drum, for Management and Disposal of Spent Nuclear , or DOT-approved B-12, B-25, or B-52 Fuel, High-Level and Transuranic Radioactive container) that complies with the laboratory’s Wastes). radioactive materials license.

The Department of Transportation (DOT) In addition to DOT requirements summarized in DOT regulates packaging and transport of all Section 3.4.7, radiological waste containers must hazardous materials including nuclear waste. be labeled in accordance with requirements at 10 Packaging must meet NRC regulations, which CFR Part 61. are compatible with and generally derived from internationally developed standards (e.g., Storage Areas International Atomic Energy Agency, IAEA), According to NRC regulations at 10 CFR and the package design must be reviewed and 20.1801 and 1802, all samples containing certified by NRC. DOT prescribes limits for radioactive contamination and all licensed external radiation levels and contamination, and material possessed by the laboratory must be controls the mechanical condition of carrier stored in a designated storage location that is equipment and qualifications of carrier secure from unauthorized access or removal. personnel. DOT regulations at 49 CFR 171 - The storage location must, at a minimum, be 179 (Hazardous Materials Regulations) specify posted as described in Section 5.2.3. General requirements for the transportation of storage requirements include: radioactive materials. • Waste containing gamma exposure rates > 5,000 μR/hr or with individual Storage radioisotope activity levels > 1 µCi/gram Storage of low-level radioactive waste requires must be segregated from waste with lesser an NRC or agreement state license. NRC or gamma exposure rates (≤ 5,000 μR/hr or agreement state regulations generally require activity levels ≤ 1 µCi/gram), and must be that waste be stored in a manner that keeps stored in an area posted or otherwise radiation doses to workers and the public below identified for “High Activity Sample NRC-specified levels. Licensees must further Storage.” reduce these doses to levels that are ALARA. • Radioactive and mixed wastes awaiting Actual doses, in most cases, are a small fraction disposal must be segregated from non- of the NRC limits. radioactive process wastes. Liquid waste must be stored in closed containers. Waste Containers • The total used volume of these Low-level radioactive waste is packaged in containers must not exceed 55 gallons. containers appropriate to its level of hazard. Some low-level radioactive wastes require Time constraints for storing radioactive waste shielding with lead, concrete, or other materials are contained in the laboratory’s radioactive to protect workers and the public. Laboratory material license, which generally contain staff must be trained to maintain a safe distance language similar to the following: Waste from more highly radioactive materials, to limit generated during sample preparation, analysis, the amount of time near the materials, and to and cleanup operations containing licensable monitor the waste to detect any releases. quantities of radioactive material shall be Radioactive waste storage areas are posted to returned to the client submitting the sample as identify the waste so that workers and the public soon as practicable, or shall be shipped to a will not inadvertently enter the area. Low-level licensed disposal facility. Waste material waste may be stored to allow short-lived containing licensable quantities of radioactive radionuclides to decay to innocuous levels and material, which is to be shipped to a disposal to provide safe-keeping when access to disposal facility, must be stored in closed containers. sites is not available. The NRC believes storage The activity of waste material awaiting shipment can be safe over the short term as an interim shall not exceed 100 mCi per single radionuclide

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(mass number 3 through 247) or a total of 2,000 exceptions may apply to the requirements listed mCi for all radionuclides combined. in Table 5-1: • Caution signs are not required in areas Storage Area Posting Requirements or rooms containing sources of radiation for Areas of radioactive material handling and periods of less than eight hours if each of contamination must be posted with appropriate the following conditions is met: caution signs in accordance with 10 CFR o sources of radiation are constantly 20.1902 and 10 CFR 20.1904. The signs must attended by an individual who takes bear the conventional radiation colors (magenta, precautions to prevent exposure of purple, or black on a yellow background) and individuals to radiation in excess of the three-blade tri-foil design, and postings must the limits established in 10 CFR Part be the size and quantity needed to properly alert 20 personnel of the radiological hazards. All o the area or room is under the control of radiological postings must be conspicuously the laboratory posted so that personnel engaged in work • A room or area containing a sealed activities in the area can readily view them. source is not required to be posted with a When possible, the size of the posted area will caution sign provided that the radiation level be limited to the immediate area of concern, at 30 centimeters from the surface of the rather than posting large non-specific areas, to sealed source container or housing does not provide more specific worker guidelines while exceed 5 mrem per hour. limiting the chance of causing undue worker or public alarm. Table 5-1 provides a summary of area posting requirements. The following

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Table 3: Posting Requirements for Storage of Radioactive Samples and Waste Area Area Posting Requirements A Restricted Area is defined as "any area, access to which is controlled by the licensee for the purpose of protection of individuals from exposure to radiation and radioactive materials." The immediate area in which radiological activities are taking place (i.e., areas where contaminated land is being remediated or where decontamination is taking place) shall be Restricted Area considered Restricted Areas.

The maximum dose rate allowed at the boundary of a restricted area is 2 millirem per hour (mrem/hr), or an exposure rate that could result in more than 100 millirem per year (mrem/yr), whichever is more restrictive. Areas, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 5 mrem in 1 hour at 30 Radiation Area centimeters from the radiation source or from any surface that the radiation penetrates, or in any 5 consecutive days a dose in excess of 100 mrem, shall be posted "Caution: Radiation Area." Areas accessible to individuals, in which radiation levels could result in an High Radiation individual receiving a dose equivalent in excess of 100 mrem in 1 hour at 30 Areas centimeters from the source or 30 centimeters from any surface that the radiation penetrates shall be posted “Caution: High Radiation Area.” Areas, accessible to individuals, in which radiation levels could result in an Very High individual receiving an absorbed dose in excess of 5 mR in 1 hour at 1 meter Radiation Areas from a source of radiation or from any surface that radiation penetrates shall be posted “Grave Danger: Very High Radiation Area.” An area, room, or enclosure shall be posted “Caution: Airborne Radioactive Materials” when airborne radioactive materials exist in concentrations that are either: Airborne in excess of the derived air concentrations (DACs) specified in 10 CFR Part Radioactive 20, Appendix A, Table I Materials to such a degree that an individual without respiratory protective equipment could exceed, during the hours an individual is present in a week, an intake of 0.6 percent of the annual limit on intake (ALI) or 12 DAC-hours Each area or room in which there is used or stored an amount of licensed or registered source of radiation exceeding 10 times the quantity of such source Radioactive of radiation specified in 10 CFR Part 20, Appendix B shall be posted with a Materials Areas conspicuous sign or signs bearing the radiation symbol and the words “Caution: Radioactive Material(s).” Each area, room, or enclosure which contains hot particles shall be posted Hot Particle with a conspicuous sign or signs bearing the radiation symbol and the words Areas “Caution: Hot Particles” or “Caution: Hot Particle Area.” In the event the laboratory designates an area as a temporary "Radioactive Temporary Material Storage Area," the storage area shall be posted with a conspicuous Storage Areas sign or signs bearing the radiation symbol and, at a minimum, the words "Caution: Radioactive Materials, Restricted Area."

Monitoring and Documentation Radioactive waste storage areas must be material. surveyed and personnel monitored in accordance with the laboratory’s radioactive material license An inventory of analytical sources and which must specify requirements for surveys, radioactive tracers must be performed in personnel monitoring, and storage of radioactive accordance with the laboratory’s radioactive

24 material license, at least semi-annually, and a reduce the waste volume. written inventory must be maintained. A written • Glassware, disposable laboratory inventory also must be maintained of all equipment, and other radioactive waste may radioactive samples received by the laboratory be decontaminated for unrestricted release for analysis. This inventory must, at a by removal of surface radioactivity through minimum, include the following information: chemical (e.g., weak nitric acid rinse) or • Date of sample receipt physical means. The residue from the • Sample origin decontamination of a surface may require • Date samples returned to sample owner disposal as a radioactive waste. or shipped for disposal • Since the level of radioactivity decreases with time, it may be possible to store Inventory records of analytical source standards, samples or materials containing a short- tracers, and samples received must be lived radionuclide (e.g., Se-75, Ru-103, Ru- maintained by the laboratory for a minimum of 106, Ir-192, Po-210) until the natural-decay three years. process reduces the radioactivity to a level at which the waste can be considered non- Treatment radioactive for waste management purposes. Both radioactive and mixed waste may require treatment to meet one or more objectives prior to Packaging final disposal (see Section 7 regarding mixed Packaging of low-level radioactive waste for waste). Treatment involves physical or chemical disposal must be in accordance with 10 CFR processes that result in a waste form that is 20.2006(d) requirements. Each container of low acceptable for disposal or further treatment. level radioactive waste must be clearly labeled Treatment objectives include: (1) producing a to identify whether it is Class A, Class B, or waste form acceptable for land disposal; (2) Class C, as defined at 10 CFR 61.55. Containers volume/mobility reduction through possible must be labeled in accordance with requirements solidification or sizing; (3) producing a waste at 10 CFR Part 71 and 49 CFR Part 172. The more amenable for further treatment; or (4) following minimum requirements for all classes separating radioactive components from RCRA of low-level radioactive waste are intended to or TSCA components. Another treatment facilitate handling and provide protection of objective is to convert a radioactive RCRA health and safety of personnel at a disposal site: regulated waste to a radioactive non-RCRA • Wastes must be packaged in waste. Laboratory management should conformance with the conditions of the determine if special permits or licenses are disposal site license. Where conditions of required from various regulatory agencies prior the laboratory license are more restrictive to the treatment of waste. than the disposal site license, the laboratory license conditions must be followed. Radioactive wastes may require treatment to • Wastes must not be packaged for meet the waste characteristics provided in 10 disposal in cardboard or fiberboard boxes. CFR 61.56 prior to disposal. The following • Liquid waste must be packaged in types of treatment may be used to meet those sufficient absorbent material to absorb twice requirements: the volume of the liquid. • Non-solid radioactive waste may be • Solid waste containing liquid must treated with various solidification agents contain as little free-standing and non- (such as cement, asphalt, or polymers) to corrosive liquid as is reasonably achievable, immobilize waste or sludge not otherwise but in no case shall the liquid exceed one acceptable for disposal. Low-level percent of the volume. radioactive waste may be absorbed onto a • Waste shall not be readily capable of porous material, such as silica, vermiculite, detonation or of explosive decomposition or or organic materials to reduce the liquid reaction at normal pressures and volume. temperatures, or of explosive reactions with • Dry radioactive waste may be treated water. with compaction or super-compaction to • Waste shall not contain, or be capable of

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generating, quantities of toxic gases, vapors, Disposal or fumes harmful to persons transporting, Disposal of radioactive wastes generated by the handling, or disposing of the waste. laboratory is regulated by the NRC, regulating • Waste must not be pyrophoric. state, and/or other agreement state. Records of • Waste in a gaseous form shall be all waste disposed of must be maintained in packaged at an absolute pressure that does accordance with 10 CFR 20.2108 until not exceed 1.5 atmospheres at 20 ºC. Total termination of the laboratory’s license. activity shall not exceed 3.7 TBq (100 Ci) per container. Sample and analytical waste generated during • Wastes containing hazardous, sample preparation, analysis, and cleanup biological, pathogenic, or infectious operations containing licensable quantities of material shall be treated to reduce, to the radioactive material must either be returned to maximum extent practicable, the potential the client submitting the sample (or site of hazard from the non-radiological materials. sample origination) as soon as practicable, or • Package must be sufficiently stable to shipped to a licensed disposal facility. Wastes ensure that the waste does not degrade and containing licensable quantities of radioactive affect overall stability of the disposal site material, which is to be shipped to a disposal through slumping, collapse, or other failure facility, must be stored in closed containers. and thereby lead to water infiltration. The The requirements of Waste Disposal (10 CFR following requirements should be followed Part 20, Subpart K) must be followed, when to provide stability of the waste at the applicable, when solid waste material cannot be disposal site: returned to a client and must be disposed. A o Waste packaging must have sample of all liquid waste must be taken and structural stability, allowing it to analyzed for radioactive contents and activity maintain its physical dimensions prior to disposal. In general: and its form, under the expected • Radioactive Solid Waste - Radioactive disposal conditions such as weight solid waste shall be disposed at a facility of overburden and compaction licensed by the regulatory state for such equipment, the presence of disposal, another agreement state, or the moisture, microbial activity, and NRC. internal factors such as radiation • Radioactive Liquid Waste - Certain effects and chemical changes. water-soluble liquid wastes may be disposed Structural stability can be provided of by release into sanitary sewage systems by the waste form itself, processing in accordance with the laboratory’s the waste to a stable form, or radioactive material license. Sewage placing the waste in a disposal disposal is commonly used for low-level container or structure that provides radioactive liquid waste (usually in the form stability after disposal. of pH-neutralized waste) as long as it is o Wastes containing liquid should be readily soluble in water and meets converted to a form that contains as requirements and limits set forth in 10 CFR little freestanding liquid as is 20.2003. reasonably achievable, but in no case shall the liquid exceed one percent of the volume of the waste when the waste is in a disposal container designed to ensure stability, or 0.5 percent of the volume of the waste for waste processed to a stable form. o Void spaces within the waste and between the waste and its package should be reduced to the extent practicable.

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6.0 Handling and Disposal of Samples and Analytical Waste Containing Biological Hazards

Microorganisms are a natural part of the Procedures and regulations for handling and environment and are found in soil, water, air, disposal of environmental samples containing and on plants and animals. Most organisms are these biological contaminants and the associated harmless or may be beneficial to humans or the analytical waste are similar to those for environment; however, some microorganisms infectious or and are can cause disease (pathogens) and their summarized in this section. dissemination in the environment and disease Regulations transmission to human and animal populations In 1988, Congress passed the Medical Waste must be either reduced or eliminated. Samples Tracking Act of 1988, which resulted in and waste containing pathogenic Standards for the Tracking and Management of microorganisms require treatment either with Medical Waste (40 CFR 22 and 259) and was in chemicals such as bleach, or use of non- effect for two years. At its expiration, individual chemical procedures such as autoclaving or states and localities implemented a variety of ultraviolet radiation, to render them non- similar rules and regulations applying to non- infectious prior to disposal. household-generated (e.g., laboratory and hospital) biomedical waste. Currently, there are EPA’s Standardized Analytical Methods for no federal biomedical waste tracking and Environmental Restoration Following Homeland management regulations in effect. As state and Security Events, (SAM) recognizes the local requirements vary considerably, following categories of pathogens for laboratories must consult individual agencies remediation: governing their locality. A list of the agencies • Bacteria – (1 – 10 µm) single cells governing medical and biological waste disposal lacking complex internal structures for each state and supporting documents can be (prokaryotes) found in Appendix C and at: • Viruses – (0.005 – 0.300 µm) particles http://www.epa.gov/osw/nonhaz/industrial/medi incapable of replicating except within a host cal/programs.htm. In addition to the regulations cell summarized in Section 3.4, the regulations • Protozoa – (1 – 300 µm) single cells summarized below must be considered by with complex internal structures laboratories generating biological waste. (eukaryotes) • Employee safety while handling and • Helminths – parasitic worms (20 µm – disposing of biological samples is addressed greater than 50 mm) under OSHA regulations 29 CFR 1910. These regulations include general hazardous Some microorganisms produce metabolic materials sections on employee training (29 products (biotoxins) that can cause disease even CFR 1910.1200(h)), written hazard if the microorganism is not present or is no communication (29 CFR 1910.1200(e)), and longer viable (e.g., botulinum ). MSDS requirements (29 CFR Biotoxins also can be produced by plants (e.g., 1910.1200(g)). The Bloodborne Pathogens from castor beans) as well as animals (α- regulations (29 CFR 1910.1030) are specific conotoxin from snails). Biotoxins can be for exposure to blood or other potentially proteins that are readily destroyed by addition of infectious materials containing pathogens bleach, or they can be small molecules that may and do not apply to environmental samples. require an extreme treatment such as • While medical and biological waste is incineration. not regulated under current federal RCRA regulations, there are federal requirements

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for incineration of medical waste under the - Brucella spp. Clean Air Act (CAA Sections 129 and 130). - Burkholderia mallei Incineration is the method of choice for - Burkholderia pseudomallei large amounts of infectious waste, and - Coxiella burnetii incinerator operators must comply with EPA - Francisella tularensis standards for clean air and emissions. If - Yersinia pestis chemicals or pesticides are used in the treatment of medical waste, the appropriate Biotoxins are regulated as select agents only if Federal Insecticide, Fungicide, and the aggregate amount of the biotoxin exceeds a Rodenticide Act (FIFRA) regulations must threshold level. Select agent toxins are handled be followed. Section 18 of FIFRA provides and disposed of under BSL-2 or BSL-3 procedures and authorizes the Administrator conditions (Section 10.4, Richmond, 2002). The to exempt state and federal agencies from following select agent biotoxins (with the provisions of the Act if it is determined that regulated threshold in parenthesis) are listed in emergency conditions exist that require an SAM, Revision 5.0: exemption. - Abrin (100 mg) • 42 CFR Parts 72 and 73 describe the - Botulinum (0.5 mg) possession, use, transfer, and disposal of - Conotoxins (100 mg) select agents and toxins (Section 10.4; - Diacetoxyscirpenol (1000 mg) Richmond, 2002). Select agent pathogens - Ricin (100 mg) are handled and disposed of under BSL-2, - (100 mg) BSL-3, or BSL-4 conditions (Section 10.4; - Shiga and Shiga-like toxins (100 National Committee on Clinical Laboratory mg) Standards, 2002 and Richmond, 2002). - Staphylococcal enterotoxins (5 mg) Clinical or diagnostic laboratories that - (100 mg) possess, use, or transfer a select agent or - T-2 (1000 mg) toxin that is contained in a specimen Storage presented for diagnosis or verification will Prior to storage, samples and associated waste be exempt from the requirements of this part must be clearly identified and segregated by provided that within seven calendar days placement in leakproof bags or containers. after identification, the select agent or toxin Disposable, puncture-resistant cardboard is transferred in accordance with Part 73.16 containers and leakproof bags are commercially or destroyed on-site by a recognized available, as well as reusable plastic and metal sterilization or inactivation process. If pans. Many states require that biological waste exempted, the identified select agent or have a primary and secondary container (e.g., toxin is reported to the U.S. Centers for either a bag within a box, or double-bagged). Disease Control and Prevention (CDC) or Biological waste storage facilities or areas must other appropriate agencies using Animal and have appropriate state and local permits, and Plan Health Inspection Service must be fully enclosed, secured to prevent entry (APHIS)/CDC Form 4 within seven of unauthorized persons, not used for other calendar days after identification and a copy purposes, and operated in such a manner as to of the form maintained for three years. minimize odor and entry by rodents and insect Under extraordinary circumstances, such as vectors. These areas must be conspicuously a widespread outbreak, less stringent identified with signs containing the International reporting may be required. Laboratories Symbol or phrases such as performing regular testing and using control “Infectious Waste” or “Bio-Hazard.” Waste stocks containing a select agent or toxin storage containers must be handled in a manner must conform to all regulations for select that does not affect the integrity of the agents. These regulations should be packaging. Containers or packaging must consulted for the proper accounting and remain intact without signs of leakage. record keeping requirements. The following Damaged or leaking containers may be packed select agent pathogens are listed in SAM, into appropriately labeled and constructed Revision 5.0 (September 2009): containers. Waste held for more than seven days - Bacillus anthracis must be maintained at temperatures below 10 28

°C. Records should contain the name and Containerized treated solid waste can be mixed location of the waste generator, quantity of with other solid waste for storage prior to waste generated, date accepted, contact person transport and disposal. Relevant health for waste, and quantity removed. department requirements must be met for solid waste storage.

Note: Laboratory waste containing select agents must be handled separately from other biological wastes; storage of select agent samples and waste must comply with requirements at 42 CFR Parts 72 and 73 (see Section 5.2.4 and Reference 9.3.7).

Treatment Laboratories can reach waste decontamination materials can be disposed of along with objectives by selecting acceptable treatment associated solid hazardous waste; techniques and applying them diligently. Prior decontaminated re-useable equipment can be to decontamination, samples and associated cleaned as required for its intended used. waste (e.g., glassware or disposable equipment Information regarding the effectiveness of such as micro-pipette tips) must be clearly procedures for decontamination of laboratory identified and segregated by placement in waste containing specific pathogens and leakproof bags or containers. Disposable, biotoxins (i.e., listed in SAM, Revision 5.0) is puncture-resistant cardboard containers and provided in Tables 6-1 and 6-2 below. leakproof bags are commercially available, as Pathogens and Protein Biotoxins well as reusable plastic and metal pans. If Sterilization and inactivation techniques and samples are not decontaminated within 48 hours, their applicability to various pathogens, protein consideration must be given to storage in biotoxins, and equipment (Section 10.4) are appropriate containers at reduced temperatures provided in Table 6-1. (i.e., below 10ºC). Decontaminated disposable

Table 4: Comparison of Decontamination Procedures Autoclave Dry-heat Chlorine Phenolic Parameter Incinerator UV 15 lb/in2 Oven Compound Compound Contact 50–90 180–240 1≥60 10–30 10–30 10–30 10–30 Time (min) Liquids + – – – – + – Infectious + – + – – + – Waste Glassware + + – – + + – Instruments ± + – – + + – Vegetative + + + + + + + Bacteria Bacterial + + + – ± – – Spores Hydrophilic + + + ± + ± ± Viruses Lipid + + + – + + + Viruses Protein + + + – + + – Toxins + Effective treatment ± Somewhat effective treatment – Non-effective or not applicable treatment

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Non-Protein Biotoxins Decontamination parameters for non-protein minutes. Some non-protein biotoxins are biotoxins are provided in Table 6-2. Do not use extremely resistant to inactivation and should be steam sterilization (autoclave) for destruction of treated only by incineration (Section 10.3). non-protein biotoxins. Unless otherwise stated, contact time for chemical inactivation is 30

Table 5: Comparison of Decontamination Procedures for Non-protein Biotoxins 2.5% NaOCl 1% Parameter Incinerator 2.5% NaOCl with 0.25 N NaOH NaOCl Aflatoxin + + + / Α-Amanitin + / + + Anatoxin + – – – Brevetoxin + + + + Cylindrospermopsin + / + + Diacetoxyscirpenol + + + (at 3 – 5% NaOCl) – Microcystins + + + + + – – – Saxitoxin + + + + T-2 Mycotoxin + + (4 hr) – – Tetrodotoxin + + + + + Effective treatment – Non-effective or not applicable treatment / Treatment results unknown

Non-Chemical Treatment • Steam sterilization – All laboratories materials such as oils, greases, and powders, handling moderate- to high-risk agents as the moisture component of saturated (BSL-3 and BSL-4) must have a steam steam will not adequately penetrate autoclave within the restricted area. For anhydrous materials and closed containers. low-risk agents (BSL-2), an autoclave must Temperatures of 160 °C – 180 °C can be be available, preferably on the same floor selected. Contact time of 180 – 240 minutes and in the general vicinity of the laboratory. takes into account the lag time for certain The processing time will depend upon materials to reach the temperature in the loading factors such as the type of autoclave oven and may or may not be applicable to pan (metal versus polypropylene), the use of all situations. Good examples of the times autoclavable waste bags, the amount of required to decontaminate various materials water in the waste, and the weight of the are presented in Rutala, 1982 (Section 10.4). waste load. The moisture content of • Incineration – Incineration is the saturated steam at 121 °C – 132 °C is method of choice for large amounts of responsible for the rapid destruction of infectious waste. Non-protein toxins that microbes. Thus, if sufficient water is not are resistant to other methods of present, water should be added. Steam decontamination can be disposed of by sterilizers must be equipped to continuously incineration. Difficulty in building, monitor and record temperature and running, and meeting regulatory guidelines pressure. Alternative methods of evaluating for incinerators prevents many laboratories effectiveness, such as temperature-sensitive from using this method for disposal. Where tape affixed to each container, may be used. available, however, samples and waste can Sterilizers must be periodically evaluated for effectiveness. • Dry heat – Dry-heat ovens are used for glassware, instruments, and anhydrous

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be outsourced to commercial facilities with used with caution and in well-ventilated approved incinerators. Section 6.4.2 areas. describes the storage conditions, containers, • Phenolic and phenolic-detergent and labeling of untreated waste prior to based compounds – These compounds pickup by the waste transport facility. have a broad microbicidal spectrum and are • Ultraviolet radiation – Germicidal less affected by organic matter than are ultraviolet (UV) radiation at 253.7 nm is other chemical treatments. However, effective against most vegetative cell phenolic and phenolic-detergent based microbes and some bacterial spores, but has compounds can corrode some plastics and limited penetrating power. It is thus used very high concentrations are needed to primarily with unprotected microbes on inactivate hydrophilic viruses. exposed surfaces or in the air. Germicidal Commercially available products include UV will not penetrate accumulated organic Lysol® and Pine-Sol®. material, opaque liquids, packaging • Alcohol – Ethyl or (70 material, soil, dust, or other solids. The – 85%) is used to disinfect contaminated intensity, or destructive power, of the lamp surfaces. Paper towels and wipes that have decreases by the square of the distance from been used to apply and remove alcohol the lamp; thus, effectiveness is related to solutions should be decontaminated prior to exposure time and distance from the UV disposal. As alcohol is combustible, make source. The intensity of the lamp will also sure that the alcohol has evaporated if a heat decrease with time and should be checked treatment is used for decontaminating used yearly with a UV meter. The intensity of towels and wipes. are ineffective the lamp also is drastically affected by the against spores, hydrophilic viruses, parasite accumulation of dust and dirt, and the cysts and ova, and toxins. surface of the lamp should be wiped weekly • Other compounds – Various other with alcohol. UV lights are not intended to chemicals also are available and used for replace routine decontamination processes decontamination. Quaternary ammonium for the interior of a biosafety cabinet and compounds (Roccal®, or equivalent) are must be used in conjunction with odorless and non-irritating, but some established disinfection procedures. This formulations are inactivated by soap and restriction is especially important to note soap residues. Glutaraldehyde is used as a when working with unknown and/or 2% solution for re-usable instruments that possibly resistant microorganisms such as cannot be autoclaved. Glutaraldehyde has spores. Due to the short time for UV been implicated as an occupational hazard overexposure (e.g., 1.3 – 6.7 minutes at the due to sensitivity problems in workers using face of a biological safety cabinet), it is it as a high-level disinfectant. Iodine recommended that neither laboratory nor compounds are available as iodophors, maintenance personnel work in a room with which are combinations of elemental iodine UV lighting. and a substance that makes the iodine soluble in water. Iodine compounds are Chemical Treatment effective against many microbes, but do not • Chlorine compounds – Inexpensive work well in the presence of organic treatments can be made from commercial material and can stain clothing and surfaces. products such as Clorox® (NaOCl, 5% or Bromine also is a known and can be 52,500 ppm Cl2). Non-protein biotoxins are used for disinfection, sometimes as a more readily inactivated by the addition of substitute for chlorine. Stabilized bromine NaOH (final concentration 0.25 N) to the biocide is used for industrial water treatment chlorine solution. These compounds are to control microbiological activity. quickly inactivated by organic matter, work Chlorine dioxide is often used to best at pH 6.0 – 8.0, and perform most decontaminate medical waste. has rapidly at higher temperatures. Chlorine been used for treatment of both sludge and solutions are skin irritants and corrosive to water. metal. Hence, these solutions should be

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Packaging as a phenolic or iodophor compound, followed During and following analytical procedures in by steam, if compatible. the laboratory, analytical solid waste and residual samples are accumulated in red Disposal leakproof bags with identifying markings such Waste disposal regulations vary from locality to as “Bio-Hazard.” Markings must be indelible locality, and laboratories must understand the and permanent. Many states require that applicable state and local requirements for biological wastes have a primary and secondary proper disposal (Appendix C). Common container such as a second bag (double- procedures for disposal of treated and untreated bagging), or a labeled, puncture-resistant waste are described in Sections 6.5.1 and 6.5.2, cardboard container. Containers holding sharp respectively. objects must also be rigid and puncture-resistant. Liquid waste is accumulated in leakproof plastic, Treated Waste metal, or containers. Waste can either be • Transportation – Decontaminated decontaminated on-site or transported off-site biological waste may be transported with for treatment. Disposal is the same whether the other solid waste. State or local regulations material has been treated on- or off-site. Select may require that written certification agents must be handled separately from other (stating that the waste has been rendered biological wastes, and handling procedures must non-infectious or inactivated) be given to comply with requirements at 42 CFR 72 and 73. the transporter on a per load, annual, or other basis. Preparation of Treated Waste for Off-site • Disposal – Solid waste can be disposed Disposal of either by incineration or by landfilling. Treated waste can be mixed with other solid As with transportation, state or local waste for landfilling. Decontaminated regulations may require written certification biological waste containing free liquids that that the waste has been rendered non- would prevent blade mixing at the disposal infectious or inactivated. Most sewer facility must be further processed to eliminate authorities allow appropriately treated the liquids. Treated waste containers that have biological wastes resulting in water-soluble identifying phrases such as “Infectious Waste” liquids to be disposed of in the sanitary or “Bio-Hazard,” are red in color, or display the sewer system, with the permission of the International Biological Hazard Symbol, must system authorities. be processed by grinding, incineration, or other method to remove such markings. Untreated Waste • Transportation – Untreated biological Preparation of Untreated Waste for Off- waste must not be transported with solid site Treatment and Disposal waste, and must be transported to an Small containers may be combined and placed approved storage or disposal facility. inside larger containers as long as the Vehicles must be enclosed to prevent escape identifiable markings are repeated on the of waste into the environment, with exterior of the larger container. The outermost notification of authorities if a spill occurs. packaging must have the International Transport vehicle surfaces must be capable Biological Hazard Symbol and an identifying of being easily cleaned and decontaminated phrase such as “Infectious Waste” or “Bio- if they come in contact with untreated Hazard,” the date of packaging, and the name waste. The vehicle must be identified with and address of the packager. the name of the transporter, name and telephone number of a contact person, and Single-use containers must be burnable if the International Biological Hazard Symbol destined for incineration. Multiple-use and/or phrase such as “Infectious Waste.” containers must be smooth, cleanable, and Transport personnel must wear impermeable resistant to corrosion. After pickup, emptied gloves and protective clothing. Transporters containers must be cleaned at a site next to the also must have the appropriate state and pickup area with a disinfectant-detergent, such local permits and maintain applicable

32 records. If waste is shipped to a disposal combustible waste must be reduced to ash facility, shipping regulations must be and non-combustible waste such as metal followed. Select agents must be handled must be processed by grinding or shredding separately from other biological waste, and to render the waste unrecognizable as handling procedures must comply with biological waste. If steam sterilization is requirements at 42 CFR Parts 72 and 73. used, similar additional processing also may be required to render the waste Disposal – Untreated biological waste must unrecognizable as biological waste. After be treated before disposal. Biological waste treatment, incineration ash or treated waste not treated at the point of generation can be may be disposed of in a landfill treated by incineration or steam sterilization at an off-site facility. After incineration, all

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7.0 Handling and Disposal of Samples and Analytical Waste Containing Mixed Hazards

Multi-hazardous waste is waste that contains • Class 9 (miscellaneous hazardous two or more of the following: radioactive, materials) infectious agent(s), or hazardous chemical(s). Mixed waste is one type of multi-hazardous The NRC and DOE regulate the radioactive waste, and contains both a chemical component portion of mixed waste under Atomic Energy (regulated by the EPA as a hazardous waste) and Act (AEA) authority, while EPA regulates the radioactive material (regulated by the NRC). hazardous waste portion of mixed waste under Mixed transuranic waste (MTRU) is waste that RCRA authority. Therefore, all AEA and has a hazardous component and contains RCRA requirements for waste generation, radioactive elements that are heavier than storage, and disposal must be met for each uranium. The radioactivity in the MTRU must sample or waste defined as a “mixed waste.” In be greater than 100 nCi/g, and the waste must cases where this waste contains chemical include RCRA hazardous constituents. These warfare agents, laboratories must contact the wastes typically are classified according to the EPA Coordinator for instructions. highest applicable hazard type, which are listed below in descending order of hazard: Multi-hazardous Samples and Wastes • Radioactive materials, other than limited Multi-hazardous waste typically contains two or quantities (Class 7) more RCRA contaminants and/or infectious • Poisonous gases (Class 2, Division 3) agents and is regulated as a hazardous waste • Flammable gases (Class 2, Division 1) based on the higher applicable hazard class • Nonflammable gases (Class 2, Division listed above. EPA regulates multi-hazardous 2) wastes under RCRA requirements for • Poisonous liquids (Division 6.1, Packing generation, storage, and disposal for each waste Group I, poisonous-by-inhalation only) component. • Waste meeting the definition of a pyrophoric material in § 173.124(b)(1) Handling (Class 4, Division 2, Packing Group 1, Samples and analytical materials designated as liquids only) multi-hazardous waste must be handled as a • Waste meeting the definition of a self- RCRA-contaminated waste and handling reactive material in § 173.124(a)(2) (Class procedures must follow requirements noted in 4, Division 1) Section 4 for each waste component. Each • Flammable liquids (Class 3), corrosive compound contained in the waste must be materials (Class 8), flammable solids (Class documented, and special notice must be made if 4, Division 1), spontaneously combustible the two (or more) chemical compounds are materials (Class 4, Division 2), dangerous incompatible or if degradation products can materials when wet (Class 4, Division 3), increase the hazard or instability of the waste. oxidizers (Class 5, Division 1) or poisonous This waste must be treated only with careful liquids or solids other than Packing Group I, consideration of the impact on all components of poisonous-by-inhalation (Class 6, Division the waste, including potential byproducts. 1). The hazard class and packing group for Procedures for handling this type of waste must a material meeting more than one of these be included in the laboratory’s Waste hazards is determined using the precedence Management Plan. Recommended general table in 49 CFR 173.2. practices include: • Combustible liquids

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• If possible, generation of multi- Disposal hazardous wastes should be avoided; Multi-hazardous waste is disposed of using disposal can be difficult and expensive. technologies that are compatible with the • If generation cannot be avoided, destruction or containment of all contaminants minimize volumes generated. without increasing the hazard of the waste. • If multi-hazardous waste contains an Some multi-hazardous wastes may require infectious agent(s), inactivation of the multiple steps or increased environmental agent may be possible with proper monitoring for complete disposal. Table 7-1 consideration of other hazardous presents information provided by the National components of the waste. Institutes of Health (NIH) for disposal of multi- • Segregate the waste as much as possible, hazardous waste for example: liquid from solid waste; (http://orf.od.nih.gov/Environmental+Protection/ non-water soluble waste from aqueous Waste+Disposal/multiwaste.htm). waste; by isotope half-life: short (≤ 120 days) or long (> 120 days); oxidizers from organic compounds, flammable, combustible, and reducing agents (e.g., zinc, alkaline metals).

Table 6: Guidelines for Disposal of Multi-hazardous Laboratory Wastes Waste Description Disposal Method "Mixed Waste" Hazardous Use the smallest non-glass container possible. Complete and attach to container a: chemical(s) ‚Chemical waste label and ‚Radioactive Waste Pickup Receipt Radioactive material ‚Radioactive material label "Mixed Waste" Infectious agent(s) Use the smallest non-glass container possible. Complete and Infectious agent and attach to container a: Hazardous inactivated ‚Chemical waste label chemical(s) ‚Radioactive Waste Pickup Receipt Radioactive material and label. Radioactive material Infectious agent not Contact regulatory authority. inactivated Infectious agent(s) Infectious agent not Contact regulatory authority. and inactivated Hazardous Infectious agent Treat as chemical waste. Follow chemical waste chemical(s) inactivated procedures. Infectious agent Treat as radioactive waste. Follow radioactive waste Infectious agent(s) inactivated procedures. and Treat as radioactive biological waste. Infectious agent not Radioactive material Follow radioactive biological waste disposal procedures inactivated included in Waste Management Plan.

Mixed Waste Samples and Waste Mixed waste is composed of radioactive waste found to be inconsistent, the AEA takes defined under the AEA and hazardous waste as precedence. Laboratories should contact the defined under RCRA. As a result, treatment and NRC to develop the information that should be regulation of these wastes is complex. In included in a plan to store mixed waste. general, the requirements of RCRA and AEA are consistent and compatible. However, in EPA's Mixed Waste Rule, finalized on May 16, cases where requirements of the two acts are 2001, provides increased flexibility to generators

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and facilities that manage low-level mixed waste safe storage of mixed-waste containing special (LLMW) and technologically-enhanced, nuclear material. Appropriate security measures naturally-occurring, and/or accelerator-produced are to be taken, and documented, to ensure the radioactive material (NARM) containing physical security of special nuclear material at hazardous waste. LLMW is exempt from some the storage facility. The laboratory must comply RCRA storage and treatment regulations, and with all requirements stipulated in their license LLMW or eligible NARM are exempt from and with the requirements in 10 CFR Part 70, RCRA hazardous waste transportation and "Domestic Licensing of Special Nuclear disposal regulations. These wastes are exempt Material." from RCRA Subtitle C requirements, including permitting, provided they meet specific Handling and Storage conditions (e.g., see U.S. Army Corps of Procedures for handling and storing mixed Engineers (ACE) Compliance Fact Sheets at: wastes must follow requirements for labeling, http://www.environmental.usace.army.mil/comp storing, packaging, and monitoring noted in lyfs.htm). The exempt wastes must then be Sections 4 and 5 of this document. Container managed as radioactive waste in accordance labels must indicate the RCRA chemical with NRC or NRC agreement state regulations. contaminant(s) and list the associated UN ID(s). All safety concerns specific to both the Regulations radiological and RCRA chemical compounds To remain in compliance with regulatory must be observed. In general, mixed-waste must requirements for mixed-waste storage, the be stored in a manner that ensures the waste laboratory may need to obtain an EPA (or does not create a radiological hazard to authorized state) storage permit and/or amend surrounding areas, increase the potential for a their NRC (or agreement state) license. release of radioactive materials to unrestricted Examples of instances where an NRC license areas, or pose an increased hazard to facility amendment may be needed include: personnel. The physical, chemical, and • If the total activity of the radioactive radiological characteristics of the waste, as well material at the facility (in use, in storage, or as any other characteristics that could pose a in waste) would exceed the activity potential health and safety problem in the authorized by the facility license storage area, must be identified and evaluated. • If the laboratory intends to store the waste in a portion of the facility not The NRC generally allows facilities to store authorized by the license waste containing radionuclides with half-lives of • If the chemical or physical form of the less than 65 days until 10 half-lives have elapsed waste is not authorized by the license and the radiation emitted from the unshielded • If the storage program is not specifically surface of the waste (as measured with an included within the scope of the appropriate survey instrument) is authorization indistinguishable from background levels. The waste may then be disposed of as non- If a laboratory is required to amend its radioactive, but still RCRA waste, after ensuring radioactive materials license, NRC will require that all radioactive material labels are rendered the laboratory to provide sufficient information unrecognizable (see 10 CFR 35.92). to evaluate the request and determine if the Radioactive waste may also be stored for decay proposed amendment impacts the level of under certain circumstances in accordance with protection afforded by the existing license. If a 10 CFR 20.2001. For mixed waste, storage for laboratory stores mixed-waste containing special decay is particularly advantageous, since the nuclear material, it must address the special waste may be managed solely as a hazardous properties of the fissile radioisotopes in the waste after the radionuclides decay to waste. The laboratory’s mixed-waste storage background levels. Thus, the management and program must address the spatial distribution, regulation of these mixed wastes are greatly geometry, volume, and the concentration of this simplified. waste at the storage facility. Strict controls must be implemented and documented to assure the Before disposing of this waste after decay, the

36 licensee must survey the waste using an laboratory’s waste broker (Section 3.1.4) to appropriate survey instrument and technique, identify appropriate disposal sites or facilities and demonstrate that any radiation emitted is for these waste types. indistinguishable from background levels. Laboratories not already authorized to hold If a laboratory generates a quantity of low-level wastes for decay-in-storage, but wish to hold mixed waste that, combined with on-site RCRA mixed waste for decay-in-storage, may need to non-mixed hazardous waste generation, does not obtain a license amendment from NRC prior to exceed 100 kg/mo (or one kilogram of acutely storing the mixed waste. Many licensees in hazardous waste as defined in 40 CFR possession of mixed waste and using decay-in- 261.11(a)(2) and listed in 40 CFR 261.31-33), it storage options will be required to obtain an qualifies as a conditionally-exempt SQG. As a amendment to store the mixed waste as result, it can dispose of the low-level mixed hazardous waste. waste as low-level radioactive waste, if these materials meet the disposal site's waste The following must be included in a license acceptance criteria (40 CFR 261.5). amendment request to NRC: • a description of the survey procedures to RCRA disposal permit requirements are unit- be used during storage and prior to release specific (i.e., dependent on compound and of the waste to a hazardous waste-only concentration) and are described in 40 CFR Part facility 264 for permitted facilities and 40 CFR Part 265 • a description of the procedures for for interim status facilities. Interim status segregating and tracking waste, from requirements are self-implementing waste storage to release to a hazardous waste-only management requirements which are limited to facility facilities that were already in existence on the • a commitment that waste will be held date that a new regulation or statutory for a minimum of ten half-lives prior to requirement took effect and which subjected the performing the final radiation survey before facility to RCRA. For mixed-waste facilities in release to a hazardous waste-only facility authorized states, this date generally corresponds • a statement that the decayed radioactive to the date that the state received authorization waste will not be released to a hazardous for a mixed-waste program, although state waste-only facility unless the radiation requirements may differ. emitted from the waste is indistinguishable from background radiation Mixed waste is sent to a limited number of facilities that are licensed under both of the While NRC licensing amendments address the appropriate laws. For example, radioactive management of the radioactive component of RCRA waste cannot go to a RCRA landfill that these wastes, they generally have no effect on is not licensed under the Low Level Radioactive the applicable RCRA storage provisions. Waste Policy Act (LLRWPA) nor can it be Storage requirements under RCRA should be disposed at a LLRW site that is not licensed. No implemented in a manner that provides treatment or disposal options exist for certain appropriate protection of health and the classes of mixed waste, such as a mixture of environment, without setting up undue radiation and PCB wastes or radiation and long- impediments to well-conducted decay programs. lived warfare agents. Indefinite storage is the only option for these waste streams with no Disposal treatment or disposal capacity.

Mixed waste and mixed transuranic wastes are disposed of in a limited number of facilities in the U.S. It is typically the responsibility of the

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8.0 Shipping

Shippers are responsible for ensuring and United Nations (January 1, 2007) require compliance with DOT, UN, and International retraining of personnel as of these dates under Air Transport Association (IATA) regulations 49 CFR 172.702 regarding the transfer of hazardous substances (http://hazmat.dot.gov/regs/49cfr/172/172.702.ht and environmental samples. These regulations m) and 49 CFR 172.704 (CFR 49 Parts 171 through 180 for DOT, 40 (http://hazmat.dot.gov/regs/49cfr/ CFR Part 172 for UN, and the Dangerous Goods 172/172.704.htm). Regulations for IATA), provide specific details regarding proper marking, labeling, placarding, The laboratory is responsible for ensuring that packaging, and shipment of hazardous materials, transport drivers are properly licensed and that substances and wastes, and regulatory the route selected is correct for the type of exceptions, and must be consulted prior to hazard being shipped. Laboratories should preparation of or planning for sample shipment. obtain and keep copies of all driver endorsement licenses, and most haulers will provide this IATA and DOT both require specific training for information when asked. All waste shipments anyone directly involved in the shipping of must be properly documented with a manifest dangerous goods (IATA 1.5, 49 CFR 172.700). and bill of lading. Laboratories should file the IATA requires training and re-certification every correct manifesting forms with the appropriate two years, while DOT requires training and re- state and disposal agencies. certification every three years. Recent changes in DOT shipping regulations (October 1, 2006)

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9.0 Disposal Sites

Laboratories are responsible for the proper CFR 270.42). transport and disposal of its solid waste. If using a private hauler, laboratory staff must make sure A Type B permit requires specification of the the vehicles being used are enclosed or can hazardous wastes listed or designated under 40 otherwise prevent spills, and that they are CFR Part 261 to be treated, stored, or disposed adequately maintained. Laboratory staff also of at the facility; an estimate of the quantity of must make sure that the waste is being disposed such wastes to be treated, stored, or disposed of of at a permitted facility. annually; a general description of the processes to be used for such wastes; and the location of Treatment, Storage, and Disposal the facility, including a full geologic assessment, Facilities (TSDFs) plans for release prevention and containment, RCRA provides direction and requirements that structural engineering studies for plant must be followed by chemical TSDFs. U.S. development and containment, responses to Army guidelines (based on 50 U.S.C. 1512- cover 100-year environmental events, 1521) express a preference for on-site treatment groundwater evaluation and monitoring plans, of chemical warfare munitions. A military fixed owner information, and obtained permits. The treatment and disposal facility differs from TSDF can modify their permit acceptances with commercial TSDF, as commercial TSDFs the approval of EPA (40 CFR 270.42). cannot be used to treat these munitions. Commercial TSDFs, however, can accept The TSDF must maintain the ability to properly secondary waste generated by either mobile dispose of the individual waste in an EPA systems or individual treatment technologies if approved manner with completed disposal the waste no longer contains agent (except at de actions certified. The TSDF can apply to minimis levels). modify their permit with EPA when necessary. The laboratory will be responsible to meet all TSDF Permits generator status requirements even if the selected TSDF fails to gain the modification. Owners and operators of hazardous waste management units must have permits (40 CFR TSDF Waste Acceptance Criteria Part 264) during the active life (including the closure period) of the unit. Each TSDF site Each TSDF has criteria and limits for acceptance requires an EPA ID and a Part A or Part B of wastes as delineated by the facility’s EPA permit. TSDFs are authorized to accept and Part A or Part B permit. Waste profiles are dispose of wastes as indicated by the facility’s approved by the TSDF prior to acceptance of the permit. laboratory’s waste for disposal at the facility. Waste Profiles typically include information A Type A permit requires specification of the regarding the following: hazardous wastes listed or designated under 40 • Waste generator (laboratory) by proper CFR Part 261 to be treated, stored, or disposed company name, address, phone, and EPA ID of at the facility; an estimate of the quantity of • Generator contact information, such wastes to be treated, stored, or disposed of including a 24-hour phone number annually; and a general description of the • Type of waste (solid, liquid, aqueous, processes to be used for such wastes, along with mixed material, etc.) location of facility, owner information, obtained • Amount expected to be disposed of and permits, and building/construction designs for frequency of shipment the facility. The TSDF can modify permit • Chemical composition, including all UN acceptances (quantity and concentration of IDs and proper shipping names chemicals accepted) with EPA approval (40 • Land ban notification

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• Hazard class and shipping container from academic users, and the rest (0.2%) was regulations undefined. • Any other information considered critical to disposal Biological Waste Disposal Sites Laboratory biological wastes must be rendered Radiological Waste Disposal Sites non-infectious (pathogens) or inactivated Low-level radiological wastes are commonly (biotoxins) prior to disposal at a landfill or in a disposed of in a limited number of near-surface . Waste must also be de-identified facilities rather than in geologic repositories, as infectious/medical waste. This de- such are those required for high-level wastes. identification includes using processes such as Once disposed of, there is no intent to recover shredding and grinding to obliterate the these wastes. The waste must meet site waste International Biohazard Sign, intact red acceptance criteria prior to disposal. Burial of biohazard bags, and phrases on waste such as transuranic waste is limited at all sites. In 2000, “Biohazard” or “Medical Waste.” Generators of low-level waste disposal facilities received biological waste may be asked to provide approximately 3.3 million cubic feet of transporters and site authorities with written commercially-generated radioactive waste. Of certification for these steps. this, 8.2% came from nuclear reactors, 83.8% from industrial users, 7.6% from government sources (other than nuclear weapons sites), 0.2%

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10.0 References and Resources

The resources listed in this section were used in preparing this document and/or are recommended for additional information and guidelines regarding laboratory waste handling and disposal.

General Resources • Clinical and Laboratory Standards Institute (CLSI). 2004. Clinical Laboratory Safety; Approved Guideline—Second Edition. Wayne, PA: NCCLS. • Clinical and Laboratory Standards Institute (CLSI). 2005. Protection of Laboratory Workers from Occupationally Acquired Infections; Approved Guideline—Third Edition. Wayne, PA: NCCLS. • Fleming, D. O. 2006. Biological Safety, Principles and Practices. 4th Edition. Washington, D.C.: ASM Press. • International Organization for Standardization. 2003. Medical Laboratories – Requirements for Safety. ISO 15190:2003. • U.S. Environmental Protection Agency. May 2000. Environmental Management Guide for Small Laboratories. EPA 233-B-00-001. http://www.montclair.edu/facilities/ehs/plans/EPA_BiologicalWaste.pdf (accessed 11/25/09)

Resources for Wastes Containing Chemical Hazards • Armour, M.A. 2003. Hazardous Laboratory Chemicals Disposal Guide, 3rd Edition. Boca Raton, FL: CRC Press. • Keegan, R.J. IV, and R.J. Keegan. 1997. Hazardous Materials, Substances and Wastes Compliance Guide. Kutztown, PA: Hazardous Materials Publishing Co. • James Lieberman. 1994. A Practical Guide for Hazardous Waste Management, Administration and Compliance. ISBN: 9781566701150 • U.S. Environmental Protection Agency. May 2005. Handbook on the Management of Munitions Response Action. Interim Final. EPA 505 B-01-001. http://epa.gov/fedfac/pdf/mra_hbook_5_05.pdf (accessed 11/24/09)

Resources for Wastes Containing Radiological Hazards • U.S. Nuclear Regulatory Commission. Radioactive Waste. (http://www.nrc.gov/waste.html) (accessed 11/24/09) • U.S. Nuclear Regulatory Commission. May 2002. Radioactive Waste: Production, Storage, Disposal, Revision 2. NUREG/BR-0216. http://www.nrc.gov/reading-rm/doc- collections/nuregs/brochures/br0216/r2/br0216r2.pdf (accessed 11/24/09) • U.S. Nuclear Regulatory Commission. Low-Level Waste Disposal. http://www.nrc.gov/waste/llw- disposal.html (accessed 11/24/09) • U.S. Nuclear Regulatory Commission. February 2007. Standard Review for Transportation Packages (NUREG-1609). Supplements 1 and 2. http://www.nrc.gov/reading-rm/doc- collections/nuregs/staff/sr1609/ (accessed 11/24/09) • U.S. Nuclear Regulatory Commission. NRC Regulatory Guidelines – Transportation (Division 7). http://www.nrc.gov/reading-rm/doc-collections/reg-guides/transportation/active/ (accessed 11/24/09) • U.S. Nuclear Regulatory Commission. NRC Regulatory Guides – Environmental and Siting (Division 4). http://www.nrc.gov/reading-rm/doc-collections/reg-guides/environmental-siting/active/ (accessed 11/24/09) • U.S. Nuclear Regulatory Commission. Final Rules and Policy Statements.

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• http://www.nrc.gov/reading-rm/doc-collections/cfr/ • U.S. Nuclear Regulatory Commission. NRC Regulatory Guides – General (Division 10). http://www.nrc.gov/reading-rm/doc-collections/reg-guides/general/active/ (accessed 11/25/09)

Resources for Wastes Containing Biological Hazards • National Committee on Clinical Laboratory Standards. 2002. Clinical Laboratory Waste Management; Approved Guideline—Second Edition. Wayne, PA: NCCLS. http://www.clsi.org/source/orders/free/gp5-a2.pdf (accessed 11/24/09) • Reddish, G. F. (ed.). 1975. Antiseptics, Disinfectants, Fungicides, and Chemical and Physical Sterilization. Philadelphia, PA: Lea and Febiger. • Richmond, J.Y., and Nesby-O’dell, S.L. 2002. “Laboratory Security and Emergency Response Guidance for Laboratories Working with Select Agents.” Morbidity and Mortality Weekly Report (MMWR™). 51(RR-19): 1–8. http://www.cdc.gov/mmwr/preview/mmwrhtml/rr5119a1.htm (accessed 11/24/09) • Rutala, W.A., Stiefel, M.M., and Sarubbi, F.A. 1982. “Decontamination of Laboratory Microbiological Waste by Steam Sterilization.” Applied and Environmental Microbiology. 43(6): 13311-1316. • U.S. Department of Health and Human Services, Centers for Disease Control and Prevention and National Institutes of Health. 2007. Biosafety in Microbiological and Biomedical Laboratories (BMBL), 5th Edition. http://www.cdc.gov/OD/ohs/biosfty/bmbl5/bmbl5toc.htm (accessed 11/25/09) • U.S. Centers for Disease Control and Prevention. 2000. Laboratory Waste Disposal Guide. http://www.cdc.gov/od/ohs/pdffiles/autoclave1.pdf (accessed 11/24/09) • U.S. Department of Health and Human Services, Office of Inspector General, CDC. 240 FR 76886, December 13, 2002. “Possession, Use, and Transfer of Select Agents and Toxins; Interim Final Rule” (42 CFR Parts 73 and 1003). http://oig.hhs.gov/authorities/docs/SelectAgentsToxinsCMPAuthorityIF.pdf (accessed 11/29/09) • U.S. Department of Health and Human Services. 70 FR 13294, March 18, 2005. “Possession, Use, and Transfer of Select Agents and Toxins; Final Rule.” (42 CFR Parts 72 and 73 and 42 CFR Part 1003). http://oig.hhs.gov/authorities/docs/05/032905FRselectagents.pdf (accessed 10/09/09) • U.S. Department of Labor, Occupational Health and Safety Administration 29 CFR 1910. http://www.osha.gov/pls/oshaweb/owastand.display_standard_group?p_toc_level=1&p_part_number =1910 (accessed 11/25/09) • U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration. 2006. Transporting Infectious Substances Safely. Federal Register: Infectious Substances; Harmonization with the United Nations Recommendations. http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/Transporting_Infectious_Substanc es_brochure.pdf (accessed 11/24/09) • Wannemacher, R.W. 1989. Procedures for Inactivation and Safety Containment of Toxins. Proceedings Symposium on Agents of Biological Origin. Aberdeen Proving Ground, MD: U.S. Army Research, Development and Engineering Center. 115–122.

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Appendix A State Regulatory Information Sources for Disposal of Waste Containing Chemical Contamination

State Admin. Code State State Web Address - Chemistry Location http://www.adem.state.al.us/Regulations/Div14/Div14effectiv Alabama Division 14 e3-31-09.pdf http://www.legis.state.ak.us/basis/folioproxy.asp?url=http://w wwjnu01.legis.state.ak.us/cgi- Alaska Title 18 bin/folioisa.dll/aac/query=[group+t!2E+18!3A]/doc/{@1}/hits _only Arizona http://www.azsos.gov/public_services/Title_18/18-08.pdf Title 18 Arkansas http://www.adeq.state.ar.us/regs/files/reg23_final_080526.pdf Regulation 23 http://www.dtsc.ca.gov/LawsRegsPolicies/Title22/index.cfm California http://www.dtsc.ca.gov/LawsRegsPolicies/upload/LEG_HSC. Title 22 and HSC pdf Colorado http://www.cdphe.state.co.us/hm/index.htm Title 6, 1007-3 http://www.ct.gov/dep/cwp/view.asp?a=2704&q=323512&de Connecticut 22a pNav_GID=1511&depNav=| Delaware http://www.dnrec.delaware.gov/Info/Pages/Rules.aspx - http://app.doh.dc.gov/services/administration_offices/environ mental/services2/waste/index.shtm District of Title 20 Columbia http://app.doh.dc.gov/services/administration_offices/environ mental/services2/waste/pdf/hw_regulations.shtm http://www.dep.state.fl.us/waste/quick_topics/rules/documents Florida FAC, Chapters 62–730 /62-730.pdf Georgia http://www.gaepd.org/Documents/rules_exist.html Chapter 391 Hawaii http://hawaii.gov/health/environmental/waste/hw/index.html HAR 11 Idaho http://www.deq.idaho.gov/inl_oversight/waste.cfm Title 16 http://www.ipcb.state.il.us/SLR/IPCBandIEPAEnvironmental Illinois Title 35 Regulations-Title35.asp Indiana http://www.in.gov/legislative/ic/code/title13/ Code 329 Iowa http://www.iowadnr.gov/waste/policy/index.html - Kansas http://www.kdheks.gov/waste/regsstatutes/hw_laws.pdf KAR title 28

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State Admin. Code State State Web Address - Chemistry Location

http://www.waste.ky.gov/branches/hw/Hazardous+Waste+Re Title 401, Kentucky gulations+with+links.htm Chapters 31–39 Louisiana http://www.deq.louisiana.gov/portal/ LAC 33:V Maine http://www.maine.gov/dep/rwm/hazardouswaste/ Chapters 850–857 http://www.mde.maryland.gov/Programs/LandPrograms/Haza Maryland Title 26 rdous_Waste/home/index.asp Massachusetts http://www.mass.gov/dep/recycle/hazwaste.htm Title 310

http://www.michigan.gov/deq/0,1607,7-135-3312_9280--- Rules Michigan ,00.html 299.9101–299.11107 Minnesota http://www.pca.state.mn.us/waste/waste_rulesregs.html Chapter 7045 http://www.deq.state.ms.us/MDEQ.nsf/page/Cleanup_Hazard Mississippi Federal ousWaste?OpenDocument Missouri http://www.dnr.mo.gov/env/hwp/lawsregs.htm Title 10, 25 Montana http://www.dnr.mo.gov/assistance/laws-regulations.htm Title 17 Nebraska http://www.deq.state.ne.us/ Title 128 Nevada http://ndep.nv.gov/admin/nrs.htm Chapter 444 Env-Wm New Hampshire http://des.nh.gov/organization/commissioner/legal/index.htm Chapters 100–1000 New Jersey http://www.state.nj.us/dep/dshw/resource/rules.html#rules Title 7 New Mexico http://www.nmenv.state.nm.us/hwb/stareg.html Title 20 New York http://www.dec.ny.gov/25.html 6 NYCRR North Carolina http://www.enr.state.nc.us/html/rules.html Title 15A North Dakota http://www.ndhealth.gov/WM/ NDAC 33–24 http://www.epa.ohio.gov/Default.aspx?alias=www.epa.ohio.g Ohio Chapter 3745 ov/dhwm Oklahoma www.deq.state.ok.us/ Title 252 Oregon http://www.deq.state.or.us/regulations/rulesandlaws.htm Chapter 340 http://www.depweb.state.pa.us/landrecwaste/cwp/view.asp?a= 1216&Q=442095&landrecwasteNav=| Pennsylvania Title 25 http://www.pacode.com/secure/data/025/chapter284/chap284t oc.html Rhode Island http://www.dem.ri.gov/programs/benviron/waste/index.htm - South Carolina http://www.scdhec.gov/environment/lwm/regulatory.htm R.61–79 South Dakota http://denr.sd.gov/des/wm/hw/hwmainpage.aspx 74:28 Tennessee http://www.state.tn.us/environment/swm/ Chapter 1200

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State Admin. Code State State Web Address - Chemistry Location Texas http://www.tceq.state.tx.us/nav/permits/hiw.html 335 Utah http://www.hazardouswaste.utah.gov/ R315 Vermont www.anr.state.vt.us/dec/wmd.htm Chapter 7 Virginia http://www.deq.state.va.us/waste/hazardous.html 9 VAC 20 Washington http://www.ecy.wa.gov/waste.html Chapters 173–303 West Virginia http://www.wvdep.org/item.cfm?ssid=11 33 CSR 20 Wisconsin http://www.dnr.state.wi.us/org/aw/wm/hazard/ NR 600 Wyoming http://deq.state.wy.us/shwd/ Chapter 12

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Appendix B State Regulatory Information Sources for Disposal of Waste Containing Radioactive Contamination

State State Addresses & Web Site URLs (if available) Department of Environmental Management Office of Radiation Control 1400 Coliseum Blvd. Alabama Department of Public Health Alabama P.O. Box 301463 The RSA Tower, Suite 700 Montgomery, AL 36130 P.O. Box 303017 http://www.adem.state.al.us/ Montgomery, AL 36130-3017 Department of Environmental Conservation Radiological Health Program Division of Air Quality Section of State Laboratories Radiation Monitoring Project Department of Health and Social Services Alaska 610 University Avenue State of Alaska Fairbanks, AK 99709-3643 4500 Boniface Parkway http://www.state.ak.us/ Anchorage, AK 99507-1270 Environmental Quality Commission American Government of American Samoa Samoa Pago Pago, American Samoa 96799 http://asepa.gov/hazardous-materials.asp Department of Environmental Quality Waste Programs Division Radiation Regulatory Agency 3033 North Central Avenue Arizona 4814 South 40th Street Phoenix, AZ 85012 Phoenix, AZ 85040 http://www.azdeq.gov/environ/waste/hazwaste/i ndex.html

Department of Environmental Quality Department of Health Hazardous Waste Division 8001 National Drive, P.O. Box 9583 (use Zip Division of Radiation Control and Arkansas code 72219-8913 for P.O. Box only) Emergency Management Little Rock, AR 72209 4815 West Markham Street, Slot 30 http://www.adeq.state.ar.us/regs/default.htm Little Rock, AR 72205-38 Radiologic Health Branch Division of Food, Drugs, and Radiation Safety State Control Board and California Department of Health Services Integrated Waste Management Board P.O. Box 942732 1001 I Street California Sacramento, CA 94234-7320 Sacramento, CA 95814 Department of Health Services http://www.swrcb.ca.gov/ or 714 P Street, #1492 http://www.ciwmb.ca.gov/ Sacramento, CA 95814

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State State Addresses & Web Site URLs (if available) Department of Health, Radiation Control Division (RCD-DO-B1) Colorado 4300 Cherry Creek Drive South Denver, CO 80220-1530 http://www.cdphe.state.co.us/hm/rad/radregs.htm Commonwealth of the Northern Mariana Islands Division of Environmental Quality Commonwealth P.O. Box 1304, 3rd Floor, Morgens Building of Northern San Jose, Saipan, Mariana Islands 96950 Mariana Islands http://www.deq.gov.mp/article.aspx?secID=11&artID=30 Division of Radiation Department of Environmental Protection Connecticut 79 Elm Street Hartford, CT 06106-5127 http://www.ct.gov/dep/cwp/view.asp?a=2713&q=324812&depNav_GID=1639 Division of Public Health Department of Natural Resources and Office of Radiation Control Environmental Control P.O. Box 637 Delaware Solid Waste Management Branch Dover, DE 19903 89 Kings Highway http://www.dnrec.state.de.us/DNREC200 Dover, DE 19901 0/Divisions/AWM/hw/index.htm Association of State and Territorial Solid Waste Management Officials Suite 345, Hall of the States Department of Consumer and Regulatory 444 North Capitol Street, NW Affairs Pesticides and Hazardous Waste District of Washington, DC 20001 Materials Division Columbia 614 H Street, NW, Room 505 Bureau of Food, Drugs and Radiation Protection, Washington, DC 20001 Department of Health http://dcra.dc.gov/dcra/site/default.asp 614 H Streets, N.W., Room 1016 Washington, DC 20001 Department of Health Department of Environmental Protection Bureau of Radiation Control, State Health Division of Waste Management Office Twin Towers Office Building Florida 4052 Bald Cypress Way 2600 Blair Stone Road Tallahassee, FL 32399 Tallahassee, FL 32399 http://www.doh.state.fl.us/environment/ra http://www.dep.state.fl.us/waste/default.htm diation/index.html Radioactive Materials Program Department of Natural Resources Environmental Protection Land Protection 4244 International Parkway, Suite 114 Branch Atlanta, GA 30354 Industrial and Hazardous Waste Management http://www.gainsurance.org/Other/Rules.a Georgia Program spx?URL=http://rules.sos.state.ga.us/cgi- Floyd Towers East bin/page.cgi?g=GEORGIA_DEPARTME 205 Butler Street, SE NT_OF_NATURAL_RESOURCES/ENV Atlanta, GA 30334 IRONMENTAL_PROTECTION/index.ht ml

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State State Addresses & Web Site URLs (if available) Radiation Section Noise, Radiation and Department of Health Branch Environmental Health Division Department of Health Hawaii Solid and Hazardous Waste Branch 591 Ala Moana Boulevard P.O. Box 3378 Honolulu, HI 96813-4921 Honolulu, HI 96801 http://www.hawaii.gov/health/environmen tal/ DEQ, Waste Management & Remediation DEQ State Office INEEL Oversight Program Idaho 1410 N. Hilton 900 N. Skyline, Suite C Boise, ID 83706 Idaho Falls, ID 83402 http://www.deq.state.id.us/ Environmental Protection Agency, Bureau of Department of Nuclear Safety Land 1035 Outer Park Drive Illinois 1021 North Grand Avenue East Springfield, IL 62704 Springfield, IL 62702 http://www.state.il.us/idns/ http://www.epa.state.il.us/land/index.html Department of Environmental Management Indoor & Radiologic Health Division Indian Government Center North State Department of Health Indiana 100 N. Senate / P.O. Box 6015 2 N. Meridian Street Indianapolis, IN 46206-6015 Indianapolis, IN 46204-3003 http://www.in.gov/idem/ Bureau of Radiological Health Department of Natural Resources Iowa Department of Public Health Environmental Protection Division Lucas State Office Building Iowa 900 East Grand Avenue, Henry A. Wallace Des Moines, IA 50319-6075 Building http://www.idph.state.ia.us/eh/radiologica Des Moines, IA 50319 l_health.asp Radiation Control Program Department of Health and Environment Kansas Department of Health & Bureau of Waste Management Environment Kansas Forbes Field, Building 740 Bureau of Air & Radiation Topeka, KS 66620 Forbes Field, Building 283 http://www.kdheks.gov/waste/ Topeka, KS 66620-0001 http://www.kdheks.gov/bar/ Department of Environmental Protection Division of Waste Management Cabinet for Natural Resources and Radiation & Toxic Agents Control Environmental Protection Branch, Cabinet for Health Services Kentucky 14 Reilly Road 275 East Main Street Frankfort, KY 40601 Frankfort, KY 40621-0001 www.nr.state.ky.us/nrepc/dep/waste/dwmhome. htm

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State State Addresses & Web Site URLs (if available) Office of Solid and Hazardous Waste Radiation Protection Division Hazardous Waste Division Office of Air Quality & Radiation Department Of Environmental Quality Protection Louisiana P.O. Box 82178 Department of Environmental Quality 525 North 4th Street 7290 Bluebonnet Road, P.O. Box 82135 Baton Rouge, LA 70884-0259 Baton Rouge, LA 70884-2135 Department of Environmental Protection Radiation Control Program Bureau of Oil and Hazardous Materials Control Division of Health Engineering Maine State House Station #17 10 State House Station Augusta, ME 04333 Augusta, ME 04333 http://www.maine.gov/dep/index.shtml Radiological Health Program Air and Radiation Management Administration Maryland Department of the Environment Maryland 2500 Broening Highway Baltimore, MD 21224 http://www.mde.state.md.us/Programs/AirPrograms/Radiological_Health/index.asp Department of Environmental Quality Engineering Division of Solid and Hazardous Radiation Control Program Waste Department of Public Health Massachusetts One Winter Street 174 Portland Street, 5th Floor Boston, MA 02108 Boston, MA 02114 www.state.ma.us/dep Radiological Protection Section Drinking Water & Radiological Department of Environmental Quality Protection Division Waste Management Division Michigan Department of Environmental Michigan P.O. Box 30241 Quality Lansing, Michigan 48909 3423 N. Martin Luther King, Jr. http://www.michigan.gov/deq Boulevard P.O. Box 30630 Lansing, MI 48909-8130 Indoor Air Lead and Radiation Division Pollution Control Agency of Environmental Health Solid and Hazardous Waste Division Department of Health Minnesota 520 Lafayette Road 121 E. Seventh Place, Suite 220 St. Paul, MN 55155 P.O. Box 64975 http://www.pca.state.mn.us/waste/index.html St. Paul, MN 55164-0975 Department of Environmental Quality Division of Radiological Health Office of Pollution Control Hazardous Waste State Department of Health P.O. Box 10385 Mississippi 3150 Lawson Street, P.O. Box 1700 Jackson, MS 39289 Jackson, MS 39215-1700 http://www.deq.state.ms.us/MDEQ.nsf/page/Mai http://www.msdh.state.ms.us/index.htm n_Home?OpenDocument

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State State Addresses & Web Site URLs (if available) Department of Natural Resources, Division of Section for Environmental Public Health Environmental Quality, Solid Waste Division of Environmental Health & Management Program Missouri Communicable Disease Prevention 205 Jefferson Street, P.O. Box 176 P.O. Box 570 Jefferson City, MO 65102 Jefferson City, MO 65102-0570 http://www.dnr.mo.gov/env/index.html Department of Health and Environmental Radiological Health Program Sciences Solid and Hazardous Waste Bureau Department of Public Health & Human Montana Cogswell Building Services Helena, MT 59620 P.O. Box 202951 http://www.deq.state.mt.us Helena, MT 59620-2951 Department of Environmental Quality Department of Regulation and Licensure, Air & Waste Management Division Nebraska Health and Human Services Nebraska 1200 N Street, Suite 400, P.O. Box 98922 System Lincoln, NE 68509 P.O. Box 95007 http://www.deq.state.ne.us/ Lincoln, NE 68590-5007 Department of Conservation and Natural Resources, Division of Environmental Nevada State Health Division Protection Radiological Health Section Nevada Bureau of Waste Management 4150 Technology Drive, Room 300 123 West Nye Lane, Room 120 Carson City, Nevada 89706 Carson City, NV 89706-0851 http://water.nv.gov/ Department of Environmental Services Radiological Health Bureau Office of Waste Management Division of Public Health Services New Hampshire 6 Hazen Drive Health & Welfare Building Concord, NH 03301 6 Hazen Drive http://www.des.state.nh.us/waste_intro.htm Concord, NH 03301-6527 Department of Environmental Protection Department of Environmental Protection Division of Solid & Hazardous Waste Radiation Protection Programs New Jersey 401 E. State Street 25 Arctic Parkway, PO 415 Trenton, NJ 08625 Trenton, New Jersey 08625-0415 http://www.state.nj.us/dep/dshw/ http://www.state.nj.us/dep/rpp/index.htm Environment Department Bureau of Hazardous & Radioactive Ground Bureau Materials, Water and Waste Management Harold Runnels Building Division New Mexico 1190 St. Francis Drive Department of Environment Santa Fe, NM 87502-0110 2044 Galisteo Road http://www.nmenv.state.nm.us/nmrcb/home.htm Santa Fe, NM 87502 l http://www.nmenv.state.nm.us/hwb/

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State State Addresses & Web Site URLs (if available) Bureau of Environmental Radiation Division of Solid and Hazardous Materials Protection 625 Broadway, Fl.9 New York State Department of Health Albany, New York 12233-7250 Two University Place http://www.dec.ny.gov/ Albany, NY 12203 Radiological Health Unit New York Bureau of Radiological Health Division of Safety and Health, New York City Department of Health New York State Department of Labor Two Lafayette Street, 11th Floor New York State Office Campus New York, NY 10007 Building 12, Room 134A http://www.nyc.gov/html/doh/html/radioh Albany, NY 12240 /radioh.shtml Division of Radiation Protection Department of Environment and Natural Department of Environment & Natural Resources Resources North Carolina Division of Waste Management 3825 Barrett Drive 1601 Mail Service Center Raleigh, NC 27609-7221 Raleigh, NC 27669-1601 http://www.ncradiation.net/ Department of Health Division of Environmental Engineering Division of Waste Management North Dakota Department of Health 1200 Missouri Avenue, Room 302 1200 Missouri Avenue, Room 304 North Dakota P.O. Box 5520 P.O. Box 5520 Bismarck, ND 58506-5520 Bismarck, ND 58506-5520 http://www.health.state.nd.us/wm/ http://www.health.state.nd.us/aq/ Ohio EPA Division of Hazardous Waste Management Bureau of Radiation Protection 122 South Front Street Ohio Department of Health Ohio P.O. Box 1049 (use zip code 43216-1049 for 35 East Chestnut Street P.O. Box only) Columbus, OH 43266 Columbus, OH 43215 http://www.epa.state.oh.us/dhwm/index.html Oklahoma State Department of Health, Waste Radiation Management Section Management Service Department of Environmental Quality Oklahoma 1000 NE 10th Street P.O. Box 1677 Oklahoma City, OK 73117 Oklahoma City, OK 73101-1677 http://www.health.state.ok.us/ Department of Environmental Quality Radiation Protection Services Waste Prevention & Management Oregon State Health Division Oregon 811 SW Sixth Avenue 800 N.E. Oregon Street, Suite 260 Portland, OR 97204 Portland, OR 97232 http://www.deq.state.or.us/lq/hw/index.htm http://oregon.gov/DHS/ph/rps/index.shtml Department of Environmental Protection Bureau of Land Recycling and Waste Bureau of Radiation Protection Management Department of Environmental Protection Pennsylvania P.O. Box 8471 Rachel Carson State Office Building Harrisburg, PA 17105-8471 P.O. Box 8469 http://www.depweb.state.pa.us/landrecwaste/site Harrisburg, PA 17105-8469 /default.asp

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State State Addresses & Web Site URLs (if available) Environmental Quality Board Radiological Health Division Puerto Rico P.O. Box 11488 G.P.O. Call Box 70184 Santurce, Puerto Rico 0010 Rio Piedras, PR 00936 Department of Environmental Management Division of Occupational & Radiological Office of Waste Management Health Department of Health Rhode Island 235 Promenade Street 3 Capitol Hill, Room 206 Providence, RI 02908-5767 Providence, RI 02908-5097 http://www.health.state.ri.us/ Division of Radioactive Waste Division of Waste Management Management Department of Health and Environmental Bureau of Land and Waste Management Control Department of Health & Environmental South Carolina J. Marion Sims Building Control 2600 Bull Street 2600 Bull Street Columbia, SC 29201 Columbia, SC 29201 http://www.scdhec.net/eqc/lwm/html/radio.html http://www.scdhec.net/health/ Department of Environmental & Natural Resources Waste Management Program Foss Building South Dakota 523 East Capitol Pierre, SD 57501 http://www.state.sd.us/denr/DES/WasteMgn/WMPpage1.htm Department of Environment and Conservation Division of Radiological Health Division of Solid/Hazardous Waste Management Tennessee Department of Environment 5th Floor, L &C Tower and Conservation Tennessee 401 Church Street L&C Annex, Third Floor Nashville, TN 37243-1535 401 Church Street http://www.state.tn.us/environment/# Nashville, TN 37243-1532 Bureau of Radiation Control Natural Resources Conservation Bureau of Environmental Health Commission Industrial & Hazardous Texas Department of Health Texas Waste Division 1100 West 49th Street P.O. Box 13087 Austin, TX 78756-3189 Austin, TX 78711 http://www.tceq.state.tx.us/ Division of Radiation Control Division of Solid and Hazardous Waste Department of Environmental Quality Department of Environmental Quality 168 North 1950 West Utah 288 North 1460 West, P.O. Box 144880 P.O. Box 144850 Salt Lake City, UT 84114-4880 Salt Lake City, UT 84114-4850 http://www.hazardouswaste.utah.gov/ http://www.radiationcontrol.utah.gov/ Division of Occupational & Radiological Department of Environmental Conservation Health Department of Health Waste Management Division Vermont 108 Cherry Street, P.O. Box 70 103 South Main Street, West Building Burlington, VT 05402 Waterbury, VT 05671-0401 http://www.anr.state.vt.us/dec/wmd.htm

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State State Addresses & Web Site URLs (if available) Department of Planning and Natural Resources Division of Environmental Protection Virgin Islands Government of the Virgin Islands 396-1 Annas Retreat-Foster Building Charlotte Amalie, U.S. Virgin Island 00802 Radiological Health Programs Department of Environmental Quality Division of Health Hazards Control Waste Management Department of Health Virginia 629 East Main Street Main Street Station Richmond, VA 23219 1500 East Main, Room 240 http://www.deq.state.va.us/waste/ Richmond, VA 23219 Division of Radiation Protection Department of Ecology Department of Health Solid and Hazardous Waste Management Building #5, P.O. Box 47827 Division Washington 7171 Clean Water Lane P.O. Box 47600 Olympia, WA 98504-7827 Olympia, WA 98504 http://www.doh.wa.gov/ehp/rp/Default.ht http://www.ecy.wa.gov/ m West Virginia Division of Natural Resources State Capitol Complex, Bldg. 3 Radiological Health Program 1900 Kanawha Blvd. West Virginia 815 Quarrier Street Charleston, WV 25305-0060 Charleston, WV 25301 http://www.wv.gov/offsite.aspx?u=http://www. wvdhhr.org/rtia/ Department of Natural Resources Radiation Protection Unit Waste Management Program Bureau of Public Health 101 South Webster Street Department of Health and Family Wisconsin Madison, WI 53703 Services http://www.dnr.state.wi.us/org/aw/wm/index.ht P.O. Box 309 m Madison, WI 53701-0309 Solid & Hazardous Waste Division Department of Environmental Quality 122 West 25th Street Wyoming Herschler Building, 4W Cheyenne, WY 82002 http://deq.state.wy.us/shwd/index.asp?pageid=4

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Appendix C State Regulatory Information Sources Disposal of Waste Containing Biological Contamination

Administrative Code / State Web Address Document http://www.adem.state.al.us/Regulations/Div13/Div13Effect 1975, §§ 22-27-1 to 7 and Alabama ive5-26-09.pdf Chapter 335-13-7 https://www.dec.state.ak.us/water/npdes/Final_Application_ Alaska Title 18 AAC 60.030 2008/03_08_18AAC60.pdf Title 18, Chapter 13, Supp. 03- Arizona http://www.azsos.gov/public_services/Title_18/18-13.htm 2, Article 14, Sections R18- 13-1401–R18-13-1420 http://www.healthyarkansas.com/rules_regs/0601medwaster eg.pdf Act 96 or 1913, Act 41 of Arkansas 1992, Act 491 of 1993, Act http://www.healthyarkansas.com/rules_regs/medical_waste. 861 of 1993, Act 150 of 1999 pdf Division 104 Part 14 Sections http://www.cdph.ca.gov/certlic/medicalwaste/Pages/default. California 117600–118360 of California aspx Health and Safety Code Title 25 Article 15 Part 4, 6 Colorado http://www.cdphe.state.co.us/hm/infects.pdf CCR 1007-2 Section 13 Biomedical Waste Frequently Asked Questions http://www.ct.gov/dep/cwp/view.asp?a=2718&q=325338&d Connecticut Sections 22a-208a-1, 22a-209- epNav_GID=1646 15, Sections 22a-208a-1, 22a- 209-15, and 22a-449(c)-11 22a-449(c)-11 http://regulations.delaware.gov/AdminCode/title7/1000/130 Section 11 Part 1 Special Delaware 0/1302/index.shtml Waste Management http://www.doh.state.fl.us/environment/community/biomedi cal/pdfs/64E16.pdf Florida Chapter 64E-16 http://www.doh.state.fl.us/environment/community/biomedi cal/index.html Georgia http://rules.sos.state.ga.us/docs/391/3/4/15.pdf 391-3-4, Rule 15 http://www.hawaii.gov/health/environmental/waste/sw/pdf/1 Hawaii 11-58.1-52 1-581.pdf http://www.deq.idaho.gov/ieg/waste/medical_pharm.cfm Idaho http://www.deq.idaho.gov/water/prog_issues/surface_water/ None pharmaceuticals/index.cfm http://www.epa.state.il.us/land/waste-mgmt/potentially- 35 Illinois Admin. Code: Illinois infectious-medical-waste.html Subtitle M, and 1420.102 Indiana http://www.in.gov/legislative/ic/code/title16/ar41/ch16.html IC-16-41-16

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Administrative Code / State Web Address Document Iowa http://www.iowadnr.com/waste/policy/files/nd1.pdf 33-20-01.1 Kansas http://www.kdheks.gov/environment/servguid.html K.A.R.28-29 Kentucky http://www.waste.ky.gov/branches/rla/Medical+Waste.htm None L.A.C. Title 33 Part VII Louisiana http://www.deq.louisiana.gov/portal/Default.aspx?tabid=264 Chapter 13 Paragraphs 1350.D.1(a) and 13305.1.1(a) 38 M.R.S.A. Sec. 1319-O Maine http://www.epa.gov/osw/laws-regs/state/stats/safrn/me.htm 06-096 C.M.R. 900 Maryland http://cha.maryland.gov/oeh/html/medical_waste.cfm COMAR 26.04.07 State Sanitary Code Title VIII, Massachusetts http://www.mass.gov/dep/recycle/hazardous/infwaste.htm 105 CMR 4800.00 and 310 CMR 19.000 http://www.michigan.gov/deq/0,1607,7-135-3312_4119--- ,00.html MWRA Part 138 Sec. Michigan http://www.deq.state.mi.us/documents/deq-whm-hwrp- 333.13801 –333.13831 mwRegAct-Rules.pdf Minnesota Statutes Sec. Minnesota https://www.revisor.mn.gov/statutes/?topic=520256 116.76 –116.82 http://www.deq.state.ms.us/MDEQ.nsf/pdf/SW_MedicalWa Medical Waste Fact Sheet; no Mississippi steFactSheet/$File/MedWasteFactSheet.pdf?OpenElement applicable state regulations http://cms.h2e-online.org/ee/rmw/rmw-regulations/state- Missouri 10 CSR 807.010 rmw-regulations/missouri/ http://cms.h2e-online.org/ee/rmw/rmw-regulations/state- Montana Title 75, Chapter 10, Part 1002 rmw-regulations/montana/ http://www.deq.state.ne.us/ (type “medical waste” in webpage search engine) Title 132, Chapter 1 and Nebraska http://cms.h2e-online.org/ee/rmw/rmw-regulations/state- Chapter 13 rmw-regulations/nebraska/ Nevada http://ndep.nv.gov/bwm/special.htm N.A.C. 444.646 and 444.662 New http://des.nh.gov/organization/commissioner/legal/rules/inde NHCAR Part Env-Sw 904 Hampshire x.htm http://www.nj.gov/dep/dshw/rrtp/rmw.htm New Jersey N.J.A.C. 7:26 http://www.nj.gov/dep/dshw/resource/rules.html http://www.nmenv.state.nm.us/NMED_regs/swb/20nmac9_ 20 NMAC 9.1.706 Paragraph New Mexico 1.html F New York http://www.health.state.ny.us/facilities/waste/ Title 10 NYCRR Part 70 http://www.wastenotnc.org/SWHOME/Rules/SWStatutes_R North Carolina 15A NCAC 13B Section 1200 ulesAug2008/Section.1200.pdf Title 33, Article 20, Chapter http://www.legis.nd.gov/information/acdata/pdf/33-20- North Dakota 12 (33-20-12) and 23-29-03.5 12.pdf NDCC Ohio http://www.epa.ohio.gov/dsiwm/pages/3745_27.aspx OAC Chapter 3745.27

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Administrative Code / State Web Address Document http://cms.h2e-online.org/ee/rmw/rmw-regulations/state- Oklahoma Title 252.515 rmw-regulations/oklahoma http://www.deq.state.or.us/lq/sw/infectiouswaste/index.htm Oregon Law 1989, Chapter Oregon http://oregon.gov/DHS/ph/acd/infectwaste/infectw.shtml 763 and ORS 459 http://www.depweb.state.pa.us/landrecwaste/cwp/view.asp? a=1238&Q=463634&landrecwasteNav=| Pennsylvania Title 25 PAC 284 http://www.pacode.com/secure/data/025/chapter284/chap28 4toc.html Rhode Island http://www.dem.ri.gov/pubs/regs/regs/waste/medwaste.pdf DEM-DAH-MW-01-92 R 61-1-5 South Carolina http://www.scdhec.net/eqc/lwm/regs/R61-105.pdf S.C. Code Ann. 44-93-10 South Dakota http://legis.state.sd.us/rules/rules/74/35/7435.doc Article 74:35 http://www.state.tn.us/sos/rules/1200/1200-01/1200-01- 07.pdf Chapter 1200-1-7-, 04, Tennessee http://www.tennessee.gov/environment/swm/pdf/SWPolicy Paragraph (1) (k) 4 Manual.pdf http://www.tceq.state.tx.us/nav/permits/mw.html Title 30, Chapter 330, Texas http://www.tceq.state.tx.us/assets/public/legal/rules/rules/pd Subchapter Y, Parts 330.1201- flib/330y.pdf 330.1221 http://www.hazardouswaste.utah.gov/SWBranch/SWSection /Adobe/SolidWaste Utah /2006_Infectious_Waste_Management_Guidance.pdf Title R315-316 http://www.rules.utah.gov/publicat/code/r315/r315-316.htm http://www.anr.state.vt.us/dec/wastediv/solid/pubs/MedWas Vermont 10 VSA 6602 te.pdf http://www.deq.virginia.gov/waste/wastereg120.html Virginia Title 9 VAC 20-120 http://www.deq.state.va.us/waste/pdf/wstregs/medwaste.pdf http://www.ecy.wa.gov/programs/hwtr/pharmaceuticals/pag Washington es/faqs.html RCW Chapter 70.95K http://apps.leg.wa.gov/RCW/default.aspx?cite=70.95K Code of State Rules, Title 64- West Virginia http://www.wvdhhr.org/wvimw/index.asp 56 http://www.legis.state.wi.us/rsb/code/nr/nr526.pdf Wisconsin WAC 526 http://www.dnr.state.wi.us/org/aw/wm/medinf/ WS 35-11-101, 102, 109, and Wyoming http://deq.state.wy.us/out/downloads/medwast.htm 501

56

Appendix D Storage and Disposal Information (for Chemical Analytes Listed in SAM, Revision 5)

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 UN 3018 [Organophosphorus (liq) Store in original container 2 30560-19-1 Alkaline materials Not Listed 6.1 / I, II, III pesticides, liquid/solid, UN 2783 in a cool, dry area toxic] (solid) Acids, oxidizing agents, UN 3426 and bases. Recycle Dust is combustable; store Acrylamide (liq) Spontaneously reacts standards to 79-06-1 away from sunlight, heat, 5000 6.1 / III [Acrylamide] UN 2074 with hydroxyl-, amino-, vendor; sparks (solid) and sulfhydryl- Incineration containing compounds. Acrylonitrile Acids, bases, oxidizing Requires stabilization by Treatment; [Acrylonitrile, 107-13-1 UN 1093 agents, amines, the addition of 4- 100 3 / I 4 Incineration stabilized] bromine methoxyphenol (Temik) UN 2992 Store in a cool, dry place. [ (liq) Alkaline materials / Incineration; 116-06-3 Dust may present 1 6.1 / I,II,III pesticides, liquid/solid, UN 2757 strong bases Landfill explosion hazard. toxic] (solid) Aldicarb sulfone UN 2992 Store in a cool, dry place. [Carbamate (liq) Alkaline materials / 1646-88-4 Dust may present 100 6.1 / I,II,III pesticides, liquid/solid, UN 2757 strong bases explosion hazard. toxic] (solid) Aldicarb sulfoxide UN 2992 Store in a cool, dry place. [Carbamate (liq) Alkaline materials / 1646-87-3 Dust may present Not Listed 2 6.1 / I,II,III pesticides, liquid/solid, UN 2757 strong bases explosion hazard. toxic] (solid) 57 57 58

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 Strong oxidizing agents, strong acids, oleum, diallyl phosphite, metal halides, , 6 Allyl alcohol 107-18-6 UN 1098 Good laboratory practices 100 3, 6.1 / I Incineration tetrachloromethane, tri- N-bromoaniline, sodium, potassium, magnesium, aluminum. Polymerizes during prolonged storage. Strong oxidizers, acids, Avoid dust generation, 4-Aminopyridine 504-24-5 UN 2671 Not Listed 2 6.1 / II Incineration chlorides, anhydrides ignition hazard Mercury, chlorine, calcium hypochlorite, hydrofluoric acid (anhydrous), bromine UN 2672 (if pentafluoride, chlorine Recycle greater trifluoride, Store in high density standards to [Shipping name is 2.2, 2.3 or 8 7664-41-7 than 10% chloroformates, strong polyethylene (HDPE) 100 vendor; Landfill concentration / I ammonia acids, strong oxidizing containers when possible standards and dependent] by volume) agents, brass, zinc, samples aluminum, copper, bronze, most common metals and Ammonium metavanadate Avoid dust generation, 7803-55-6 UN 2859 Strong oxidizers, acids Not Listed 2 6.1 / II Incineration (analyze as total ignition hazard vanadium) Oxidizing agents, acids, Arsenic, Total 7440-38-2 UN 1558 Good laboratory practices 6 1 6.1 / II Landfill moisture Arsenic trioxide Acids, Al, Cl, trifluoride, Reacts with metals in the (analyze for total 1327-53-3 UN 1561 fluoride, oxygen 1 6.1 / II Landfill presents of moisture arsenic) disulfide, Hg, Zn

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 Store in stainless steel or Treatment of Teflon® (PTFE) cylinders. standards with Treatment of small KMNO4 and 7784-42-1 UN 2188 Heat, acid, oxidizers amounts (<100 mL) of 1 2.3 landfill; laboratory standards by Incineration of absorption with KMNO4 standards and solution is possible. samples Asbestos 1332-21-4 NA 2212 None Good laboratory practices 6 1 9 / III Landfill

Avoid moisture as it will Recycle Water, bases, alkaline Boron trifluoride form hydrofluoric acid; standards to 7637-07-2 UN 1008 metals, brass, Not Listed 2 2.3 [Boron trifluoride] store in stainless steel or vendor; Store aluminum Teflon® (PTFE) cylinders samples UN 3023 None known. [ derivative (liq) 6 2 56073-10-0 Apply good laboratory Good laboratory practices Not Listed 9 / III Incineration pesticides, liquid/solid, UN 3026 6 practices. toxic] (solid) UN 3023 [Coumarin derivative (liq) Store in original container 28772-56-7 Alkaline materials 1 6.1 / II Landfill pesticides, liquid/solid, UN 3026 in a cool, dry area toxic] (solid)

BZ [Quinuclidinyl Information 5 5 2 Information 5 6581-06-2 5 Information limited Information limited Not Listed 5 Military benzilate] limited Limited Calcium arsenate Store in original container (analyze as total 7778-44-1 UN 1573 Acids 1 6.1 / II in a cool, dry area arsenic) (Furadan) UN 2992 [Carbamate (liq) Store in original container 1563-66-2 Heat, fire 10 6.1 / I Landfill pesticides, liquid/solid, UN 2757 in a cool, dry area toxic] (solid) Information Information Carfentanil 59708-52-0 Information limited 5 Information Limited 5 Not Listed 2 limited 5 Limited 5 59 59 60

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 Strong oxidizers, chemically-active Recycle Iron, steel, porcelain, or materials (such as standards to Carbon disulfide 75-15-0 UN 1131 glass containers should be 100 3 / I sodium, potassium, and vendor; Store used for storage zinc), azides, halogens, samples and organic amines UN 3018 Metal and high density [Organophosphorus (liq) 470-90-6 polyethylene (HDPE) Store in glass containers Not Listed 2 6.1 / I, II, III pesticides, liquid/solid, UN 2783 containers toxic] (solid) Water, bases, alkaline metals, brass, Chlorine 7782-50-5 UN 1017 aluminum, Good laboratory practices 6 10 2.3 Landfill combustibles, reducing agents 2-Chloroethanol 107-07-3 UN 1135 Fire or ignition sources Good laboratory practices 6 Not Listed 2 6.1 / III Incineration

Do not store in direct sunlight; keep container closed when not in use; 3-Chloro-1,2- store in a cool, dry, well- 96-24-2 UN 2689 Strong oxidizing agents Not Listed 2 6.1 / III Incineration propanediol ventilated area away from incompatible substances; keep containers tightly closed

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 Bulk containers are shock sensitive and can detonate, especially when heat is available for initiation; Store in a cool, dry, well- producing phosgene is ventilated area away from Chloropicrin 76-06-2 UN 1580 possible; strong incompatible materials, Not Listed 2 6.1 / I Landfill oxidizers, organic direct sunlight and heat acids, reducing agents, and/or sparks sulfuric acid, aluminum, magnesium or magnesium alloys, aniline, sodium methoxide Information Information 1445-76-7 Information limited 5 Information limited 5 Not Listed 2 Military 5 limited 5 Limited 5

Information 5 5 2 Information 5 Chlorosoman 7040-57-5 5 Information limited Information limited Not Listed 5 Military limited Limited

Store in a cool, dry, well- 2-Chlorovinylarsonous ventilated area away from acid (2-CVAA) Information Information 85090-33-1 Strong oxidizers, heat incompatible materials, Not Listed 2 Military 5 (degradation product limited 5 Limited 5 direct sunlight and heat of Lewisite) and/or sparks UN 3018 [Organophosphorus (liq) 5 Store in original container 2 2921-88-2 Information limited Not Listed 6.1 / I, II, III pesticides, liquid/solid, UN 2783 in a cool, dry area toxic] (solid) Chlorpyrifos oxon UN 3018 [Organophosphorus (liq) Store in original container 5598-15-2 Information limited 5 Not Listed 2 6.1 / I, II, III pesticides, liquid/solid, UN 2783 in a cool, dry area toxic] (solid)

6 2 Information Recycle; Crimidine 535-89-7 UN 2588 Strong acids Good laboratory practices Not Listed 5 Limited Incineration 61 61 62

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 Cyanide, Amenable to UN 1935 chlorination (liq) [Cyanide solutions, NA Ignition sources, acids Good laboratory practices 6 10 6.1 / I,II,III UN 1588 n.o.s or Cyanide (solid) inorganic solid, n.o.s] Cyanide, Total UN 1935 [Cyanide solutions, (liq) 57-12-5 Ignition sources, acids Good laboratory practices 6 10 6.1 / I,II,III Incineration n.o.s. or , UN 1588 inorganic, solid, n.o.s.] (solid) Water, acids, alkalis, chloride 506-77-4 UN 1589 Good laboratory practices 6 10 2.3 Incineration ammonia, alcohols Information Moderately stable in Information Cyclohexyl sarin (GF) 329-99-7 Water, bleach products Not Listed 2 Military 5 limited 5 stainless steel containers Limited 5 Liquid ammonia, dimethylamino- propylamine, nitrogen tetroxide, metal powders, organic peroxides reducing Small quantities can be agents, and alkali and stored in brown bottles or Recycle alkali earth metals; opaque containers due to standards to 1,2- mixtures with nitric acid solvent's light sensitivity; vendor; Dichloroethane[Ethyle 107-06-2 UN 1184 100 3 / II are easily detonated by electrically ground metal Incineration ne dichloride] heat, impact, or friction; containers for liquid standards and mixtures with transfers to prevent static samples mercaptans form sparks thioethers and generate heat; mixtures with nitrides generate heat and ammonia forming toxic fumes

Recycle UN 3018 standards to [Organophosphorus (liq) Strong acids, strong Material should be stored in vendor; 62-73-7 10 6.1 / I, II, III pesticides, liquid/solid, UN 2783 alkalis glass containers Incineration toxic] (solid) standards and samples

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 UN 3018 Corrosive to cast iron, [Organophosphorus (liq) 6 2 141-66-2 mild steel, brass, and Good laboratory practices Not Listed 6.1 / I, II, III Incineration pesticides, liquid/solid, UN 2783 stainless steel toxic] (solid) Diesel Range NA UN 1202 Ignition sources, acids Good laboratory practices 6 Not Listed 2 3 / III Incineration Organics Diisopropyl Information Information methylphosphonate 1445-75-6 Information limited 5 Information Limited 5 Not Listed 2 Military 5 limited 5 Limited 5 (DIMP) Dimethylphosphite UN 3278 Recycle [Organophosphorus (liq) 6 2 Information standards to 868-85-9 Heat sources Good laboratory practices Not Listed compound liquid/solid, UN 3464 Limited 5 vendor; toxic] (solid) Military 5 Dimethylphosphorami UN 3278 dic acid (liq) Information [Organophosphorus 33876-51-6 Information limited 5 Information limited 5 Not Listed 2 Military 5 UN 3464 Limited 5 compound liquid/solid, (solid) toxic] Diphacinone UN 3023 [Coumarin derivative (liq) 6 82-66-6 Alkalis Good laboratory practices 10 6.1 / II Incineration pesticides, liquid/solid, UN 3026 toxic] (solid) UN 3018 [Organophosphorus (liq) Strong acids, bases, 298-04-4 Good laboratory practices 6 1 6.1 / I, II, III pesticides, liquid/solid, UN 2783 and alkaline conditions toxic] (solid) Disulfoton sulfoxide UN 3018 [Organophosphorus (liq) Strong acids, bases, 2497-07-6 Good laboratory practices 6 Not Listed 2 6.1 / I, II, III pesticides, liquid/solid, UN 2783 and alkaline conditions toxic] (solid) Recycle Information Information standards to 1,4-Dithiane 505-29-3 Strong oxidizers Information limited 5 Not Listed 2 limited 5 Limited 5 vendor; Military 5 63 63 64

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 EA2192 [Diisopropylaminoethy l Information Information 73207-98-4 Information limited 5 Information limited 5 Not Listed 2 Military 5 methylthiolophosphon limited 5 Limited 5 ate] (hydrolysis product of VX) Ethyl methylphosphonic acid (EMPA) UN 3278 (degradation product Information 1832-53-7 (liq) UN Information limited 5 Information limited 5 Not Listed 2 Military 5 of Limited 5 3464 (solid) VX)[Organophosphor us compound liquid/solid, toxic] Strong oxidizing Incineration; Should be stored in glass 598-14-1 UN 1892 agents, strong acids, Not Listed 2 6.1 / I Landfill at low (ED) or steel containers water, brass concentrations N- Ethyldiethanolamine Information 5 5 2 Information 5 139-87-7 5 Information limited Information limited Not Listed 5 Military (EDEA) (degradation limited Limited product of HN-1)

Store in distant outdoor Water, bases, oxidizing tank or container protected metals, acids, alcohols, from direct sunlight, lined alkali metals, ammonia, with insulating material, VARIOUS chemically active equipped with an adequate depending Incineration; metals and their salts. refrigeration and water Ethylene oxide 75-21-8 on 10 2.2, 2.3, 6.1 Landfill at low Highly flammable. system. Indoor storage concentrati concentrations Forms explosive should be restricted to on mixtures with air which small quantities. Place in a may be ignited by rapid fireproof, combustible liquid compression cabinet that conforms to regulations.

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 UN 3018 Recycle Effluent from fire [Organophosphorus (liq) Hydrolyzed by strong standards to 22224-92-6 suppression should be 10 6.1 / I, II, III pesticides, liquid/solid, UN 2783 acids and alkalis vendor; contained toxic] (solid) Incineration None known. Information Fentanyl 437-38-7 Apply good laboratory Good laboratory practices 6 Not Listed 2 6.1 / II Incineration limited 5 practices. 6

Recycle standards to Fluoride 16984-48-8 UN 1690 Mineral acids, glass Good laboratory practices 6 Not Listed 2 9 / III vendor; Landfill standards and samples

Information Store in original container Information 640-19-7 Acids Not Listed 2 limited 5 in a cool, dry area Limited 5 Fluoroacetic acid and fluoroacetate salts Incineration; (analyze for NA UN 2642 Mineral acids May require refrigeration 10 6.1 / I Landfill fluoroacetate ion) [Fluoroacetic acid] Strong oxidizing and reducing agents, acids, Information Incineration; 2-Fluoroethanol 371-62-0 acid chlorides, acid Room temperature limited 5 Landfill anhydrides, halides Amines, caustics, alkali VARIOUS Formaldehyde and alkaline earth depending Incineration; [Shipping name is metals, nitrides, organic 6 50-00-0 on Good laboratory practices 100 3, 8 / III Landfill at low concentration peroxides, oxidizing concentrati concentrations dependent] agents, reducing on agents None known. Apply Range Information NA good laboratory Good laboratory practices 6 Not Listed 2 2.3 Incineration Organics limited 5 practices. 6 65 65 66

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 Hexahydro-1,3,5- Shock & detonators, trinitro-1,3,5-triazine 121-82-4 UN 0483 oxidizing materials, & Explosion-proof containers Not Listed 2 1.1 (RDX) combustibles and/or Landfill Hexamethylenetri- None known. Shipping Store in designated Information peroxidediamine 283-66-9 Apply good laboratory Not Listed 2 Storage Forbidden segregated laboratory unit Limited 5 (HMTD) practices. 6 Moisture, bases, Hydrogen bromide 10035-10-6 UN 1048 metals, ammonia, Good laboratory practices 6 Not Listed 2 2.3 Incineration oxidizers, fluoride Alkalis, most metals. Hydrogen chloride 7647-01-0 UN 1050 Avoid contact with Well-ventilated area 5000 2.3 Incineration water.

Can become instable over time. Treatment of small Bases such as amounts (standards and Treatment; 74-90-8 UN 1956 10 6.1 / I caustics, amines samples <100 mL) with Incineration 4 NaOH and hypochlorite solution is possible.

Hygroscopic. Good laboratory practices. Incompatible with 6 Small amounts may be Treatment; Hydrogen fluoride 7664-39-3 UN 1052 glass, alkali metals, 100 8 / I 4 treated with water and Incineration light metals, alkaline CaCO earth metals 3.

Be aware of any signs of dizziness or fatigue; exposures to fatal Strong oxidizers, strong 7783-06-4 UN 1053 concentrations of hydrogen 100 2.3 Incineration nitric acid, metals sulfide could occur without significant warning symptoms

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 Isopropyl methylphosphonic acid (IMPA) UN 3278 (degradation product (liq) Information 1832-54-8 Decomposes in water Store in stainless steel Not Listed 2 Military 5 of GB) UN 3464 Limited 5 [Organophosphorus (solid) compound liquid/solid, toxic] Recycle standards to vendor; Kerosene 64742-81-0 UN 1223 Oxidizers Good laboratory practices 6 Not Listed 2 3 / III Incineration at low concentration Lead arsenate Strong bases, strong Store in original container (analyze as total 7645-25-2 UN 1617 acids, and alkaline 1 6.1 / II in a cool, dry area arsenic) conditions Lewisite 1 (L-1) Inactivation Inactivated by bleaching (2- Information Decomposed by water Information treatment prior 541-25-3 powder, sodium Not Listed 2 chlorovinyldichloroarsi Limited 5 and alkalis Limited 5 to shipping; hypochlorite ne) Military 5

Inactivation Lewisite 2 (L-2) [bis(2- Inactivated by bleaching Information Decomposed by water Information treatment prior chlorovinyl)chloroarsin 40334-69-8 powder, sodium Not Listed 2 Limited 5 and alkalis Limited 5 to shipping; e] hypochlorite Military 5

Inactivation Lewisite 3 (L-3) Inactivated by bleaching Information Decomposed by water 2 Information treatment prior [tris(2- 40334-70-1 5 powder, sodium Not Listed 5 limited and alkalis Limited to shipping; chlorovinyl)arsine] hypochlorite Military 5

UN 1556 Inactivation Inactivated by bleaching (liq) Decomposed by water treatment prior Lewisite oxide 1306-02-1 powder, sodium Not Listed 2 6.1 / I UN and alkalis to shipping; hypochlorite 1557(solid) Military 5 67 67 68

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 Mercuric chloride Store in non-metal (analyze for total 7487-94-7 UN 1624 Nitromethane Not Listed 2 6.1 / II container mercury) Acetylene and acetylene derivatives, amines, ammonia, 3- bromopropyne, boron diiodophosphide, methyl azide, sodium , heated sulfuric acid, methylsilane/oxygen mixtures; nitric Recycle Mercury, Total 7439-97-6 UN 2809 acid/alcohol mixtures, Good laboratory practices 6 1 8 / III standards to tetracarbonylnickel/oxy vendor; Landfill gen mixtures, alkyne/silver perchlorate mixtures, halogens (i.e., chlorine, bromine) and strong oxidizers (i.e., chlorine dioxide, perchlorates); copper, aluminum, rubidium UN 3018 Optional Optional treatment by [Organophosphorus (liq) hydrolysis 10265-92-6 Alkaline materials hydrolysis and good 100 6.2 / II pesticides, liquid/solid, UN 2783 6 treatment and laboratory practices toxic] (solid) Incineration UN 2992 [Carbamate (liq) 6 Incineration; 16752-77-5 Strong bases Good laboratory practices 100 6.1 / II pesticides, liquid/solid, UN 2757 Landfill toxic] (solid) Methoxyethylmercuric UN 2024 acetate (analyze for Recycle if high (liq) total mercury) 151-38-2 Strong acids Good laboratory practices 6 Not Listed 2 8 / III concentration; UN 2025 [Mercury compounds, Landfill (solid) liquid/solid, n.o.s.] Methyl acrylonitrile 126-98-7 UN 3079 Strong oxidizers, acids Good laboratory practices 6 1000 3 Incineration

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 Information Oxidizing materials, Information Information (analyze for 453-18-9 Good laboratory practices 6 Not Listed 2 limited 5 oxygen, and peroxides Limited 5 Limited 5 fluoroacetate ion) Treatment; Recycle Oxidizing materials, standards to Store in a cool, dry, well- Methyl hydrazine 60-34-4 UN 1244 oxygen, peroxides, 10 6.1 / I vendor; ventilated area metals Incineration for all concentrations

Recycle standards to Fireproof containers Methyl isocyanate 624-83-9 UN 2480 Oxidizers, water 10 6.1 / I vendor; preferred incineration samples Methyl UN 3018 [Organophosphorus (liq) 5 Store in original container 2 950-35-6 Information limited Not Listed 6.1 / I, II, III pesticides, liquid/solid, UN 2783 in a cool, dry area toxic] (solid) Recycle Methyl UN 3018 standards to [Organophosphorus (liq) 6 298-00-0 Oxidizers, water Good laboratory practices 100 6.1 / I vendor; pesticides, liquid/solid, UN 2783 incineration toxic, n.o.s.] (solid) samples Acids, oxidizing materials, chlorine, hypochlorite, Methylamine halogenated [Methylamine, 74-89-5 UN 1235 compounds, reactive Good laboratory practices 6 100 2.1 Incineration aqueous solution] organic compounds and some metals, and mercury and nitrosating compounds N- Information 5 2 Information 5 Methyldiethanolamine 105-59-9 5 Strong oxidizers, acids Information limited Not Listed 5 Military limited Limited (MDEA) 69 69 70

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 1-Methylethyl ester ethylphosphonofluorid UN 3278 ic acid (GE) (liq) Information 1189-87-3 Information limited 5 Information limited 5 Not Listed 2 Military 5 [Organophosphorus UN 3464 Limited 5 compound, toxic, (solid) liquid/solid, n.o.s] Methylphosphonic UN 3278 acid (MPA) (liq) 5 2 Information 5 [Organophosphorus 993-13-5 Strong oxidizers, bases Information limited Not Listed 5 Military UN 3464 Limited compound, toxic, (solid) liquid/solid, n.o.s] UN 3018 In situ disposal [Organophosphorus (liq) procedure (air 7786-34-7 Strong oxidizers Good laboratory practices 6 10 6.1 / I, II, III pesticides, liquid/solid, UN 2783 stripping); toxic] (solid) Incineration Mustard, nitrogen (HN-1) Information Information [bis(2- 538-07-8 Ferrous alloys Information limited 5 Not Listed 2 Military 5 limited 5 Limited 5 chloroethyl)ethylamin e] Mustard, nitrogen (HN-2) [2,2'-dichloro-N- Information 5 2 Information 5 methyldiethylamine 51-75-2 5 Ferrous alloys Information limited Not Listed 5 Military limited Limited N,N-bis(2- chloroethyl)methylami ne] Mustard, nitrogen (HN-3) Information 5 2 Information 5 555-77-1 5 Combustible materials Information limited Not Listed 5 Military [tris(2- limited Limited chloroethyl)amine]

Mustard, sulfur / Information 5 2 Information 5 505-60-2 5 Oxidizers, acids Information limited Not Listed 5 Military (HD) limited Limited

Nicotine compounds UN 3144 100 (as (analyze as nicotine) (liq) nicotine 54-11-5 Oxidizers, combustibles Good laboratory practices 6 6.1 / II,III Incineration [Nicotine compounds, UN 1655 sulfate / liquid/solid, NOS] (solid) nicotine salts)

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 Octahydro-1,3,5,7- Information Explosive, store in fireproof Information tetranitro-1,3,5,7- 2691-41-0 Oxidizable materials Not Listed 2 Military 5 limited 5 container Limited 5 tetrazocine (HMX) Organophosphate UN 3018 pesticides, NOS (liq) [Organophosphorus NA Strong oxidizers Good laboratory practices 6 Not Listed 2 6.1 / I, II, III Incineration UN 2783 pesticides, liquid/solid, (solid) toxic] Recycle Osmium tetroxide standards; Oxidizers, 1- Secondary containment (analyze for total 20816-12-0 UN 2471 1000 6.1 / I Landfill methylimidazole required osmium) standards or samples UN 2992 [Carbamate (liq) Refrigeration 23135-22-0 Alkaline materials Not Listed 2 6.1 / I Landfill pesticides, liquid/solid, UN 2757 recommended toxic] (solid) Paraquat UN 3016 Strong oxidizers, [Bipyridilium (liq) Chemical degradation Incineration; 4685-14-7 alkylaryl-sulfonate Not Listed 2 6.1 / I, II, III pesticides, liquid/solid, UN 2781 possible Landfill wetting agents toxic] (solid) Paraoxon UN 3018 [Organophosphorus (liq) Strong oxidizers, 311-45-5 Good laboratory practices 6 Not Listed 2 6.1 / I, II, III pesticides, liquid/solid, UN 2783 alkalines toxic] (solid) Parathion UN 3018 [Organophosphorus (liq) Strong oxidizers, 6 56-38-2 Good laboratory practices 10 6.1 / I, II, III Incineration pesticides, liquid/solid, UN 2783 alkalines toxic] (solid) Pentaerythritol Shipping Information 78-11-5 Heat Store below 40°C Not Listed 2 Military 5 tetranitrate (PETN) forbidden Limited 5

Increased documentation Incineration Information 2 Information Phencyclidine 77-10-1 5 Oxidizers for tracking contaminated Not Listed 5 (Tracking limited Limited materials requirements) 71 71 72

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3

Store in closed containers with room ventilation to Recycle UN 2821 Strong oxidizers, prevent airborne phenol standards; (liq) calcium hypochlorite, concentrations >20 mg/m3; Phenol 108-95-2 1000 6.1 / II Landfill UN 1671 aluminum chloride, control conditions to standards or (solid) acids prevent overheating and samples the buildup of pressure in phenol containers

Phorate UN 3018 [Organophosphorus (liq) 6 298-02-2 Water, alkalis Good laboratory practices 10 6.1 / I, II, III Incineration pesticides, liquid/solid, UN 2783 toxic] (solid) UN 3018 sulfone[Organophosp 2588-04-7 (liq) UN Water, alkalis Good laboratory practices 6 Not Listed 2 6.1 / I, II, III horus pesticides, 2783 (solid) liquid/solid, toxic] Phorate sulfoxide UN 3018 [Organophosphorus (liq) 2588-03-6 Water, alkalis Good laboratory practices 6 Not Listed 2 6.1 / I, II, III pesticides, liquid/solid, UN 2783 toxic] (solid) Treatment by Moisture, alkalis, Possible treatment to disposal Phosgene 75-44-5 UN 1076 ammonia, alcohols, reduce hazard component 10 2.3 company; copper by immersion in oil Incineration 4 UN 3018 [Organophosphorus (liq) Hydrolysis and good 2 Hydrolysis prior 13171-21-6 Reacts with bases Not Listed 6.1 / I, II, III pesticides, liquid/solid, UN 2783 laboratory practices 6 to Incineration 4 toxic] (solid)

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 The building should be adequately ventilated and equipped with a continuous Air, oxidizers, chlorine, monitoring and acids, moisture, Phosphine 7803-51-2 UN 2199 alarm system that is 100 2.3 Incineration halogenated activated at the TLV of 0.3 , copper ppm. In some jurisdictions, the indoor storage of toxic gases is prohibited. Recycle Water, chemically standards; active metals, strong Phosphorus trichloride 7719-12-2 UN 1809 Good laboratory practices 6 1000 6.1 / I Landfill nitric acid, acetic acid, standards or organic matter samples Pinacolyl methyl phosphonic acid UN 3278 (PMPA) (degradation (liq) Information product of GD) 616-52-4 Information limited 5 Information limited 5 Not Listed 2 Incineration UN 3464 Limited 5 [Organophosphorus (solid) compound, toxic, liquid/solid, n.o.s] Oxidizers, anhydrous Use glass or metal metal chlorides, iron, Propylene oxide 75-56-9 UN 1280 containers sealed with 100 3 / I Incineration strong acids, caustics, nitrogen and peroxides R-33 (VR) [methylphosphonothio c acid, S-[2- Information Information 159939-87-4 Information limited 5 Information limited 5 Not Listed 2 Military 5 (diethylamino)ethyl] limited 5 Limited 5 O-2-methylpropyl ester] Information Decomposes in water. Information Sarin (GB) 107-44-8 Store in stainless steel. Not Listed 2 Military 5 limited 5 Reacts with bleach. Limited 5 Semivolatile organic compounds, NOS Additional Additional Apply good laboratory 6 2 [Shipping name is NA analysis 6 Good laboratory practices Not Listed Analysis Incineration practices contaminant required required dependent] 73 73 74

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 Recycle Sodium arsenite UN 1686 standards; Strong oxidizers, (analyze for total 7784-46-5 (liq) UN Good laboratory practices 6 1 6.1 / II,III Landfill bromide azide arsenic) 2027 (solid) standards or samples

Sodium azide 26628-22-8 UN 1687 Metals, acid, water Good laboratory practices 6 1000 6.1 / II Incineration (analyze as azide ion)

Information Soman (GD) 96-64-0 Decomposes in water Information limited 5 Military 5 limited 5 Oxidizers, alkali hydroxides and 57-24-9 UN 1692 , aromatic Good laboratory practices 6 10 6.1 / I Incineration ammonia spirit, bromides and iodides Powdered alkali metal (such as sodium & potassium), water, 7446-09-5 UN 1079 Good laboratory practices 6 Not Listed 2 2.3 Landfill ammonia, zinc, aluminum, brass, copper Moisture, organics, Sulfur trioxide 744-11-9 UN 1829 Good laboratory practices 6 Not Listed 2 6.1, 8 / I Incineration metals Information Information Tabun (GA) 77-81-6 Decomposes in water Destroyed by bleach Not Listed 2 Military 5 limited 5 Limited 5 Tetraethyl UN 3018 pyrophosphate (liq) Strong oxidizers, [Organophosphorus 107-49-3 Good laboratory practices 6 10 6.1 / I, II, III Incineration UN 2783 alkalis, water pesticides, liquid/solid, (solid) toxic] Tetramethylenedisulfo UN 2902 tetramine (liq) Apply good laboratory [Pesticides, 80-12-6 Good laboratory practices 6 Not Listed 2 6.1 / I, II, III Incineration UN 2588 practices 6 liquid/solid, toxic, (solid) n.o.s]

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 Thallium sulfate Apply good laboratory 6 [Thallium compounds, 7446-18-6 UN 1707 6 Good laboratory practices 100 6.1 / II Landfill practices n.o.s.] Thiodiglycol (TDG) (degradation product Strong acids and strong of HD) 111-48-8 UN 3334 Good laboratory practices 6 Not Listed 2 9 / I Incineration oxidants [Aviation regulated, n.o.s.] UN 2992 [Carbamate (liq) 6 39196-18-4 Alkaline materials Good laboratory practices 100 6.1 / I, II, III pesticides, liquid/solid, UN 2757 toxic] (solid)

Store in a cool, dry, well- ventilated area away from 1,4-Thioxane sunlight. Seal tightly, [Flammable liquids, 15980-15-1 UN 1993 Oxidizers Not Listed 2 3 Incineration may form explosive n.o.s.] peroxides under certain conditions.

Titanium tetrachloride Lab standards can be (analyze as total 7550-45-0 UN 1838 Oxidizers neutralized using a variety 1000 8 / II Landfill titanium) of procedures Triethanolamine (TEA) (degradation product of HN-3) 102-71-6 UN 2491 Oxidizers Good laboratory practices 6 Not Listed 2 6.1 / I Incineration [Ethanolamine solutions] Magnesium Incineration or Trimethyl phosphite 121-45-9 UN 2329 Good laboratory practices 6 Not Listed 2 3 / III perchlorate, water landfill 1,3,5-Trinitrobenzene 99-35-4 UN 0388 Reducing agents Good laboratory practices 6 10 6.1 / II Incineration (1,3,5-TNB) Strong oxidizers, 2,4,6-Trinitrotoluene ammonia, strong Explosive; fireproof Incineration or 118-96-7 UN 0388 Not Listed 2 1.1D / II (2,4,6-TNT) alkalis, combustible containers required Landfill materials, heat 75 75 76

STORAGE / HANDLING DISPOSAL / TREATMENT Hazard Analyte(s) 1 Reportable CAS RN UN ID Incompatibility Handling / Storage / Class / Disposal [shipping name] Quantity (Do not store with) Treatment Options 2 Packing Method (lbs) Group3 Vanadium pentoxide (analyze for total 1314-62-1 UN 2862 Calcium, sodium, water Good laboratory practices 6 1000 6.1 / III Landfill vanadium) VE [phosphonothioic acid, ethyl-, Information Information S-(2- 21738-25-0 Oxidizers Information limited 5 Not Listed 2 Military 5 limited 5 Limited 5 (diethylamino)ethyl) O-ethyl ester] VG [phosphonothioic acid, S-(2- Information Information 78-53-5 Oxidizers Information limited 5 Not Listed 2 Military 5 (diethylamino)ethyl) limited 5 Limited 5 O,O-diethyl ester] VM [phosphonothioic acid, methyl-, Information Information S-(2- 21770-86-5 Oxidizers Information limited 5 Not Listed 2 Military 5 limited 5 Limited 5 (diethylamino)ethyl) O-ethyl ester] VX [O-ethyl-S-(2- diisopropylaminoethyl) Information Information 50782-69-9 Oxidizers Information limited 5 Not Listed 2 Military 5 methyl- limited 5 Limited 5 phosphonothiolate]

White phosphorus Material should be stored Dependent on [Phosphorus, white 12185-10-3 UN 1381 Air, oxidizers 1 Incineration under water or inert gas concentration (dry or wetted)]

1 Refer to the tables included in 49 CFR Part 172 for additional Information (http://ecfr.gpoaccess.gov/cgi/t/text/text- idx?c=ecfr&sid=d683a122678fef011339e6de2a067132&tpl=/ecfrbrowse/Title49/49cfr172_main_02.tpl).

2 The Reportable Quantity (RQ) for liquid material will vary. Not all compounds have a specified RQ. The analyte may not be listed in the regulations (49 CFR 172.101, Appendix A), or, if listed, the analyte may not have an RQ.

3 Packing Group requirements modified by increasing contamination concentrations. 4 Treatment is required (e.g., stabilization) prior to storage, transportation, and disposal procedures (e.g., incineration). Treatment methods are listed in the Disposal/Treatment column. 5 Information on specific compound is limited or restricted. Contact the EPA Coordinator and/or the local military coordinator for additional information. (For military information and contacts, see: http://www.cma.army.mil/contactus.aspx)

6 The good laboratory practices designation indicates no specific storage or special treatment is required; the laboratory should use best professional judgment.

Appendix E Example Hazardous Waste Manifest Form

77

SCIENCE PRESORTED STANDARD POSTAGE & FEES PAID EPA PERMIT NO. G-35

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