Reed College EHS - Waste Management

The Resource Conservation and Recovery Act (RCRA) passed by the United States Congress in 1976 mandates the proper handling and disposal of hazardous waste. The United States Environmental Protection Agency (EPA), authorized by RCRA, administers and enforces these requirements found in Title 40 of the Code of Federal Regulations. While RCRA focuses on the management of hazardous waste from the point of generation to the point of disposal, referred to as “cradle to grave,” it also covers solid waste management in general and encourages recycling and alternative energy sources.

A hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. RCRA defines a hazardous waste as a waste that is either “characteristic” or “listed.”

Characteristic “D” Waste includes any waste having one or more following characteristics:

The ignitability characteristic identifies wastes that can catch fire and sustain combustion. Ignitable wastes carry the waste code D001. The corrosivity characteristic (D002) identifies wastes that are acidic or alkaline (basic) and can readily corrode or dissolve flesh, metal, or other material. The reactivity characteristic (D003) identifies wastes that readily explode or undergo violent reactions. The EPA developed the toxicity characteristic to identify wastes likely to leach dangerous concentration of toxic chemicals into ground water. Specific constituents that exhibit the toxicity characteristic are listed in Table V of the RCRA Code and identified by EPA waste numbers D004 through D043.

The EPA has four lists for hazardous waste: the F list, the P list, the K list, and the U list.
The F list includes wastes from nonspecific sources. At Reed College, the most common F listed wastes are those generated from the use of solvents – both halogenated and non-halogenated. This includes waste mixtures of solvents, waste solvents, and media mixed with solvents, such as rags for cleaning. F waste also includes oil-based paints. The F list is codified in the regulations at 40 CFR 261.31. The K list, found in 40 CFR 261.32, includes wastes generated from specific industrial processes. This does not apply to Reed College. The P list and the U list include pure or commercial grade formulations of specific unused chemicals. Chemicals on the P list are acutely toxic. At Reed College, the most common “P” wastes are cyanides, azides, and nicotine. Campus-wide Reed College may only produce 1 kg (2.2 lbs.) of “P” waste each month. Thus it becomes extremely important that each generator of P waste look at their process to determine the availability of safer chemicals or alternate protocols. The U list is generally comprised of chemicals that are toxic, but also includes chemicals that display other characteristics, such as ignitability, corrosivity, or reactivity. Both the P list and U list are codified in 40 CFR 261.33.

(Amended by Ordinance Nos. 172879 and 180037, effective April 28, 2006.)

A. It is unlawful to discharge industrial wastewater into the City sewer system except in compliance with this Chapter and rules adopted hereunder.

B. Prohibited discharges. It is unlawful to discharge, cause to discharge or allow to discharge directly or indirectly into the City sewer system any of the following:

1. Wastewater containing substances in such concentrations that they inhibit or interfere with the operation or performance of the sewer system, or that are not amenable to treatment or reduction by the sewage treatment process employed, or are only partially amenable to treatment such that the sewage treatment plant effluent cannot meet the requirements of any agency having jurisdiction over its discharge to the receiving waters, or that exceed concentrations in excess of limitations in any permit issued by the City or other regulatory agency or in this Chapter or rules adopted hereunder, or that prevent or impair the use or disposal of sewage treatment plant sludge and sludge products in accordance with applicable State and federal regulations;

2. Any liquids, solids, or gases which by reason of their nature or quantity are, or may be, sufficient either alone or by interaction to cause fire or explosion or be injurious in any other way to the operation of the sewer system, or waste streams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees Celsius (using test methods prescribed at 40 CFR 261.21), or discharges which cause the atmosphere in any portion of the sewer system to reach a concentration of 10% or more of the Lower Explosive Limit (LEL).

3. Any solid or viscous substances capable of obstructing wastewater which will or may cause obstruction to the flow of wastewater or other interference with the operation of the sewer system;

4. Any noxious, malodorous or toxic liquids gases, vapors or fumes, solids, or other substances which, either singly or by interaction with other wastes, may cause acute or chronic worker health and safety problems, a public nuisance, a hazard or interference with any part of the sewer system;

5. Any industrial wastewater containing a hazardous or toxic substance which, either singly or by interaction with other substances, injures or interferes with the sewer system or constitutes a hazard to humans or animals, or creates a hazard in, or adversely affects the receiving waters, or results in such substances being discharged in combined sewer overflows or sewage treatment plant effluent in any concentrations in excess of limitations imposed by any permit, law or regulation;

6. Any wastes, wastewaters or substances having a pH less than 5.0 or more than 11.5, or capable of causing damage or hazard to structures, equipment, processes or personnel of the sewer system, unless these limits are modified by permit. Such wastes include, but are not limited to, battery or plating acids and wastes, copper sulfate, chromium salts and compounds, or salt brine;

7. Any liquid or vapor having a temperature higher than 65 degrees Celsius (149 degrees Fahrenheit) or containing heat in amounts which will inhibit biological activity, or result in interference at the treatment plant. In no case shall a discharge to the sewer system contain heat in such quantities that the temperature of the treatment plant influent exceeds 27 degrees Celsius (80 degrees Fahrenheit);

8.Any material trucked or hauled from a cesspool, holding or septic tank or any other non-domestic source, except such material received at designated locations under City contract or permit in accordance with any other applicable requirements of the City Code or rules adopted thereunder;

9. Any substance which may solidify or become discernibly viscous at temperature above 0 degrees Celsius or 32 degrees Fahrenheit;

10. Any material that has not been properly comminuted to 0.65 centimeters (1/4 inch) or less in any dimension;

11. Any slugload, as defined in this Chapter or rules adopted hereunder;

12. Any substances with excessive color, as determined by the Director of Environmental Services, which are not removed in the treatment process;

13. Any batch discharges without written permission from the Director of Environmental Services. Batch discharges shall comply with all other requirements of this Chapter and rules adopted hereunder;

14. Any concentrations of inert suspended or settleable solids which may interfere with the operation of the sewer system;

15. Any concentrations of dissolved solids which may interfere with the operation of the sewer system;

16. Any radioactive material, except in compliance with a current permit issued by the Oregon State Health Division or other state or federal agency having jurisdiction;

17. Any substance, which may cause sewer system effluent or treatment residues, sludges, or scums, to be unsuitable for reclamation and reuse or which interferes with the reclamation process. (In no case, shall a substance discharged to the sewer system cause the City to be in noncompliance with sludge use or disposal criteria, guidelines or regulations developed under the Clean Water Act; any criteria, guidelines or regulations affecting sludge use or disposal developed pursuant to the Solid Waste Disposal Act (42 USC 6901), the Clean Air Act (42 USC 1857), the Toxic Substances Control Act (15 USC 2601), or any other federal or State statutes, regulations or standards applicable to the sludge management method being used, or any amendments thereto.)

18. Petroleum oil, non-biodegradable cutting oil, or products of mineral oil origin in amounts that will cause interference or pass through.

19. Non-contact cooling water (except that non-contact cooling water may be discharged to the separate storm sewer system upon approval by the Director of Environmental Services);

20. Any substance that causes the City to violate the terms of its NPDES permit;

21. Any discharge limits in rules adopted in rules pursuant to this Chapter.

B. It is unlawful for a discharger to use dilution as a partial or complete substitute for adequate treatment to achieve compliance with the standards and limitations set forth in this Chapter or rules adopted hereunder or in an industrial waste discharge permit issued pursuant to the Chapter. The Director may impose mass limitations on dischargers who are using dilution to meet the applicable pretreatment standards or requirements of this Chapter or rules adopted hereunder, or in other cases where the Director determines that the imposition of mass limitations is deemed appropriate.

The following discharge limitations are established by the Director to meet the objectives of Section 17.34.040 of the City Code:

(1) Categorical Pretreatment Standards. All industrial users shall comply with applicable categorical pretreatment standards and requirements found at 40 CFR Chapter I, Subchapter N, Parts 405-471. All requirements and limitations shall be applied in accordance with 40 CFR 403.6(c)-(e) and 40 CFR 403.15. These standards and requirements, and any amendments, are hereby incorporated by reference.

(2) State Pretreatment Standards. All industrial users shall comply with applicable State pretreatment standards and requirements set out in OAR Chapter 340 in any instance in which they are more stringent than federal requirements and limitations, or discharge limitations established in the City Code or these rules. These standards and requirements, and any amendments, are hereby incorporated by reference.

Local limits shall apply to industrial users at the point of compliance. Compliance with local limits shall be determined through the use of composite or grab samples that are representative of the industrial user’s wastewater that enters the City sewer system.