BYU and Subpart K

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

2. Brigham Young University • Located in Provo, Utah

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

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

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

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

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

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

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

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

11. Submittal of Form 8700-12 to Utah Department of Environmental Quality

13. Changes to our Operations (Academic Side) • Labels

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

15. ID #57 • Unique Container Label • Constituents (Waste Profiles) • Date created (important for “Rolling 6 months” collection) • Generator’s contact information • Additional information

16. Webpage Content Update

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

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

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

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

22. Lab Cleanouts • It doesn’t help us on our generator status • It gives us flexibility on how we manage cleanout • We have 30 days • We have BIG lab moves = cleanouts John A.Widtsoe Building Life Science Building (no official name yet) • Once a year per laboratory • All cleanouts will be documented (lab id, date started/ended, volume generated, etc.) and the records kept for 3 years

23. Questions, Comments, Discussion, Etc.

24. See you next year in Park City, Utah!