PERC Environmental Audit Chapter 2

Toxic and radioactive wastes are a potential environmental and safety threat if produced in excessive amounts or improperly handled. This task force has conducted an inspection of the universityís production, handling, and disposal of hazardous, biomedical, and radioactive wastes as well as wastewater records. The goal was to identify areas where the university has excelled as well as areas of potential improvement, where reductions in use, changes in procedure, and increased education need to be made. With regards to radioactive waste, the university has consistently been found to act in accordance with local, state and federal regulations concerning these materials, and the university has been extremely successful in reducing the amount of radioactive wastes produced. However, regarding hazardous wastes there is insufficient record-keeping at the purchasing and disposal levels to adequately monitor use and disposal. In terms of wastewater, more attention needs to be given to the sources of recent violations, and for medical waste it is recommended that a thorough and far sighted cost-benefit analysis be carried out for the potential implementation of an on-campus medical waste disposal system. These issues can best be addressed by creating an advisory committee which would work towards implementing the following recommendations: 1) promotion of greater awareness of the environmental and safety issues in all labs, 2) organization of a faculty seminar to explain microscale experiments and encourage toxic substance use reduction, 3) establishment of a more accurate and accessible record-keeping for toxic substances through the use of an on-line computer file, and 4) initiation of a voluntary surplus chemical exchange program. The implementation of these few recommendations would be a laudable first step towards improving Princeton Universityís laboratory safety and environmental commitment.

Princeton University has not been found in serious violation of any hazardous, medical or radioactive waste regulations in recent history. ìIncidentsî of any sort have been rare. As the costs of the universityís disposal of hazardous, medical and radioactive wastes have risen, efforts have been made to reduce the volume of waste produced; however, no systematic hazardous or medical waste reduction program is in place. The university has recently been found in violation of certain waste water contaminant levels, though as of yet no fines have been imposed.

This task forceís goals focus on a greater degree of awareness of and accountability for the environmental issues surrounding the use of hazardous and medical waste on campus. Currently there are no source reduction programs for these wastes; on the one hand, waste disposal costs have been contained so there is little economic incentive to reduce hazardous material use, and on the other hand, there is an understandable hesitancy to put restrictions on research materials. Hopefully, environmental and safety concerns will become stronger incentives to reduce hazardous waste production. It is toward this end of helping engender a stronger environmental ethic in the labs that the following investigation was made. Included in the following recommendations are programs which could potentially lower the universityís costs, notably a surplus chemical exchange program and on campus medical waste disposal equipment. A more systematic record-keeping of hazardous materials at the purchasing and waste disposal levels is desirable so that future evaluations might better point out where waste reductions can be made. Procedures regarding proper disposal of contaminants into the waste water system should focus on training and proper maintenance of equipment designed to pretreat waste water before disposal.

The chapter is divided into five sections: hazardous waste, medical waste, waste water treatment, radioactive waste and recommendations. To the extent possible, data has been collected for the amounts, types and disposal costs of hazardous, biomedical and radioactive wastes that the university produced over the years 1990 - 1993, along with data from the results of recent waste water inspections.

Princeton University is classified as a ìlarge quantity generatorî of hazardous wastes. The science, engineering, and visual arts departments are the largest academic producers. Among the non-academic producers, Facilities ranks the highest. Hazardous waste is defined by a New Jersey State Administrative Code (N.J.A.C. 7:26-8.13 through 8.20) and includes materials which can be classified as corrosive, ignitable, reactive, or having high toxicity. Occupational Health and Safety is the university department responsible for contracting for hazardous waste disposal.

Princeton University is not a licensed disposal site. Hazardous wastes generated on campus are picked up and transported to other locations for ultimate disposal. Wastes generated in the labs are transported to one of the universityís waste pick-up sites and then placed in the proper packaging (to be discussed below) before being taken from campus. The four pick-up sites are Frick Laboratory, Moffett Laboratory, Engineering Quadrangle, and Forrestal Campus. The materials are picked up on a monthly schedule and are then delivered to off-campus, licensed disposal facilities for incineration, chemical treatment, solvent recycling, and in a few cases landfilled. The universityís transport and disposal contractors are listed in Appendix 2.D.

Before delivery to the pick-up sites, each waste container must be properly labeled with a sticker describing the contents. In some labs these waste descriptions are listed on a form, of which one copy is kept on file. While departments are required to keep records for only those hazardous wastes that are generated from non-academic uses (as mentioned above), OHS does keep annual records of the types and total volume of wastes that leave each of the four sites. These records are submitted to the NJDEPE and EPA each year in a Hazardous Waste Report. The data for the years 1990-1993 is given in Appendix B. It is difficult to detect any problems from this data because there is no indication of the source of the wastes, i.e. from which lab they originated. There are exceptions in the case of a few of the more specialized wastes originating from the Forrestal Campus.

fiscal year	total disposal costs

7/1/89 -- 6/30/90	$231,717.00
7/1/90 -- 6/30/91	$174,052.00
7/1/91 -- 6/30/92	$208,553.00
7/1/92 -- 6/30/93	$216,034.49
7/1/93 -- 6/30/94	$195,850.33
7/1/94 -- 11/30/94	$60,408.08*

Table 2.1 Cost of disposal of hazardous wastes. Source: Occupational Health and Safety

*This yearís disposal costs are expected to be significantly lower than previous years. Because these are nominal numbers not corrected for inflation, there has been a decline in disposal costs over the past 6 years.

The university, not the individual departments, pays the cost of disposal. This policy is designed to prevent any incentive for departments to improperly dispose of hazardous materials. While the current system does not offer any fiscal incentive for departments to control their waste levels, departments are fined if their wastes are improperly handled, e.g. mislabeled containers. The slight decline in the costs of the universityís hazardous waste disposal have been largely a result of the increased use of a more efficient packaging system. Typically, a ìlab packî refers to a 20 gallon drum in which individual bottles of waste are packed in absorbent material. Only five gallons of waste can fit into these 20 gallon lab packs. An alternative which has been encouraged by OHS is the use of five gallon plastic carboys into which wastes are poured directly. These carboys require no secondary containment or absorbent material and occupy roughly 25% the space of the typical lab packs. The cost of disposal for the carboys is roughly $90 versus $160 for the same quantity of waste in the lab packs. These carboys have been used primarily in the chemistry labs and other labs where large volumes of chemicals are generated. In those labs where hazardous waste generation is low, these containers are impractical.

There is no university waste reduction program in place though efforts to reduce waste production have been made. The chemistry department currently uses a modified version of microscale experiments in its introductory organic chemistry courses. No plans have been made to expand this program to other introductory chemistry labs or to other departments. Also, on an informal basis, Occupational Health and Safety frequently distributes to faculty and staff of relevant departments memos and articles describing ways to reduce waste production and increase lab safety.

Though not directly related to the hazardous waste audit, the universityís progress in groundskeeping should be highlighted. The university department of groundskeeping has made outstanding efforts to reduce the chemical fertilizers and pesticides through a recently introduced integrated management program.

Medical waste, as defined in N.J.A.C. 7:26-3A.69a, includes any solid waste generated from the diagnosis, treatment or immunization of human beings or animals, and from related research or testing of biologicals. Cultures and stocks of infectious agents, pathological waste, human blood and by-products, sharp implements, contaminated animal waste, and isolation waste from patients with communicable diseases are all considered to be medical waste. The main generators of medical waste on campus are the chemistry, molecular biology, and psychology departments, and McCosh medical center. Building Services is the department responsible for medical waste disposal. The universityís medical waste disposal procedures and facilities have been recently inspected by the NJ DEPE and Department of Health and have been determined to be in full compliance with state and federal regulations.

Medical waste is first collected at the site of generation in specially labeled red disposal bags. Prior to pick up for transport to disposal site, infectious waste is autoclaved. Autoclaving is a procedure where the material is heated under high pressure in order to kill any infectious organisms. Departments then call Building Services for pick-up as needed. McCosh Infirmary is an exception; its dumpsters are serviced twice weekly. All red bag waste is taken to an off-campus site where it is incinerated. South Medical Disposal handles Princetonís medical waste at a cost of $0.26 per lb.. Medical waste quantities for FY 1994 (June 22, 1993 ó June 21, 1994) are shown in Table 2.2.

As with hazardous waste, there is no formal waste reduction program in place for medical waste. In some labs there are no receptacles for non-hazardous solid waste because of fear that infectious waste might be inadvertently put in them. The current policy indicates that any ìmedical-likeî implement or material used in the lab, even though not biologically contaminated, must go into the red bag waste rather than into the general solid waste receptacle. This includes any and all syringes and needles which are to be placed into special ìsharpsî containers for red bag disposal. This policy was instituted because of the potential that such ìmedical-likeî material going into the general solid waste might be identified by landfill disposal personnel, raising their fears that the material was medical waste that had been improperly disposed. Such a circumstance could jeopardize the universityís landfill privileges. One measure in place that reduces medical waste volumes is the diversion of non-contaminated lab glass to a glass crusher, which allows this glass to be sent in the general solid waste stream. Another reduction measure that has been in place for several years is the disposal of animal bedding from psychology, EEB, and molecular biology as solid waste.

Treated (lbs)	Untreated (lbs)	Total (lbs)
57.060	45.002	102,062

The total cost for medical waste disposal was $21,000 in 1993. This cost is a minor component of the universityís operating budget. As with hazardous waste, the university, rather than the departments themselves, pays for this disposal, thereby separating fiscal responsibility from waste generation. The costs of medical waste disposal need to be considered from the standpoint of environmental impact. For example, much of the red bag material is non-infectious/non-medically-related plastic lab waste. Incinerating polyvinyl chloride plastic (PVC) produces toxic air emissions that are deleterious to human health and food sources. This represents a real though perhaps non quantifiable indirect cost of the universityís disposal of laboratory plastics. Many of the plastics now incinerated could in fact be recycled into new laboratory materials.

The cost of medical waste disposal and the amount of material being generated into this waste stream could be substantially reduced or eliminated if the university accepted the option considered several years ago to invest in equipment that can pulverize and chemically disinfect medical waste and allow it to go into the general solid waste to the landfill. This option would also eliminate the concern that has been associated with medical waste disposal over the years that material considered infectious might end up at the landfill. This discussed further in the recommendations section.

Waste water disposal from Princeton University has been monitored for approximately one year at six campus locations. Monitoring of 21 parameters is done in accordance with a pretreatment permit from Stony Brook Regional Sewerage Authority. The University is in compliance with most of the permit requirements. Though several recurring violations have occurred since January 1994, the only unresolved violations are for lead from the Engineering Quadrangle and silver from the Lewis Thomas /Guyot/Shultz Laboratories area.

The Federal Clean Water Act and United States Environmental Protection Agency regulations require many waste water treatment plants, including Stony Brook Regional Sewerage Authority, to conduct pretreatment programs. The purpose of local pretreatment programs is to keep non-residential users of the sewer system, who would otherwise be subject to federal and state waste water discharge regulations, from unregulated discharge of harmful pollutants into the sewer system. Limits are set for each pollutant at levels designed to protect the biological processes used by the sewage treatment plant. Many pollutants, especially heavy metals, are not removed by the biological processes of sewage treatment and are subsequently released to the nationís surface waters. Princeton University first received a pretreatment permit from Stony Brook Regional Sewerage Authority in November 1993. It was renewed on November 11, 1994 and will expire on November 11, 1995.

The SBRSA permit places limits on the disposal of 21 different pollutants: pH, total suspended solids, biochemical oxygen demand, ammonia, oils and grease, phosphorus, hydrogen sulfide, phenols, cyanides, arsenic, barium, cadmium, chromium, copper, iron, lead, mercury, nickel, selenium, silver, and zinc. Each of the limited pollutants is monitored at six locations on campus: Engineering Quadrangle, Frick/Hoyt Laboratories, Green Hall, Lewis Thomas/Guyot/Shultz Laboratories, MacMillan Building, and Moffett Laboratories.

Stony Brook Regional Sewerage Authority has done sampling at all locations for each pollutant limited in the permit. The university has been required to do additional sampling after violations were found at a number of locations. More than 90% of the samples taken have been in compliance with permit limits. All samples for lead (Table 2.3) taken at the Engineering Quadrangle, however, are in violation of the permit limit of 0.5 mg/l.

date tested	6/21/94	9/7/94	9/14/94	9/21/94
level found	0.728 mg/l	0.552 mg/l	1.25 mg/l	0.762 mg/l

To date, the university has been unable to determine the source of these violations.

Zinc monitoring at the Engineering Quadrangle and the MacMillan Building have shown frequent violations of the permit limit of 0.5 mg/l. SBRSA is investigating the possibility that zinc levels in the water supply may be the cause of zinc violations at many facilities in Princeton with pretreatment permitsómany of whom do not use any zinc in their facilities. Until this issue has been further studied by SBRSA and Elizabethtown Water Company, it is questionable whether the university should devote resources toward resolving the zinc violations seen so far at the Engineering Quadrangle and MacMillan Building.

As shown in Table 2.4, all five samples taken at the monitoring location for Lewis Thomas/Guyot/Shultz Laboratories have exceeded the permitís silver limit of 0.03 mg/l.

date tested	6/21/94	8/9/94	9/7/94	9/14/94	9/21/94
level found	0.045 mg/l	0.075 mg/l	0.136 mg/l	0.031 mg/l	0.085 mg/l

The university is investigating potential causes for these violations. There are silver recovery systems in place which should remove silver from waste streams before it is discharged to the sewer system. However, the company that is responsible for maintaining the systems has gone out of business. A new company has been contacted regarding continuation of the contract.

In February 1994, samples taken at Moffett Laboratory showed a pH in the range of 1.2 to 1.92, far below the minimum of 5.5 stated in the permit. The university responded by changing procedures used for dish washing. Chromic acid is no longer being added to clean the iron deposits from glassware. Violations have not recurred.

Radioactive material use at Princeton University is an example of safe use and a successful effort to substantially reduce usage and thus waste disposal costs. The universityís use of radioactive materials is regulated by the national Nuclear Regulatory Commission (NRC) as well as the New Jersey Department of Environmental Protection and Energy (NJDEPE). The NRC inspects the university every two years and the NJDEPE conducts inspections every 24 - 36 months. The university holds five licenses for the different types of radioactive material used on campus. Radioactive materials are inventoried by the researchers and/or OHS from the point of arrival until disposal. The procedures for handling, packaging, labeling, and disposing of radioactive isotopes are extremely detailed and highly regulated. Exact campus procedures are given in OHSís Radiation Safety Guide. The Nuclear Regulatory Commission examined their records back to 1988 and found only one incident of violation. On a routine inspection in 1989, it was found by NRC that certain monitoring and safety instruments had not been performance tested and recalibrated. These violations were relatively minor and were promptly corrected.

Table 2.5 lists the isotopes purchased in quantities greater than 0.001 milliCuries in 1993. Between the years 1989 and 1993, the following departments have generated radioactive wastes: molecular biology, geology, ecology and evolutionary biology, chemistry, physics, civil engineering, chemical engineering and astrophysical sciences. Currently, the molecular biology department contributes the most radioactive wastes.

The Health Physics staff of OHS maintain and update a detailed Radiation Safety Guide of Rules, Regulations and Procedures. Everyone using radioactive materials is required to attend an initial 3 hour training session and is provided with portions of the comprehensive radiation safety guide. One hour refresher courses are required of everyone handling radioactive materials.

Isotope	Half-life	Quantity purchased 1993 (mCi)
H-3	12.3 years	83.050
C-14	5730 years	2.260
P-32	14.3 days	995.2000
S-35	87.2 days	1013.000
Ca-45	162.7 days	1.000
Cr-51	27.7 days	28.000
I-125	60.1 days	5.755

Table 2.5 Radioactive materials purchasing: Source: Occupational Health and Safety

The university has recently had to make changes in its radioactive waste disposal practices. As of June 30, 1994 the disposal site in Barnwell, SC has been closed to out-of-state wastes. New Jersey, in collaboration with Connecticut, has been searching for a site for a radioactive waste disposal facility since 1993 but has yet to designate a location. It is estimated that no site will be available for 10-15 years, during which time most of the universityís radioactive waste must be stored on campus. The university has implemented a decay-in-storage program (DIS) managed by the molecular biology department whereby solid wastes with half-lives of 65 days or less are stored in the basement of Moffett for at least 10 half-lives and then disposed of as medical wastes when no longer detectably radioactive. A detailed description of all radioactive waste routes is listed in Appendix C.

In the mid 1980ís the university was generating 100 drums/year of radioactive materials, but now produces less than 5 drums/year. This 95% reduction in radioactive wastes has been largely the result of increased costs of radioactive waste disposal. Unlike medical and hazardous wastes, the departments are responsible for the cost of disposal of radioactive materials. Also, seminars have been presented on campus so that researchers could learn about lab techniques which do not use radioactive materials. Gradually labs are switching over to non-radioactive techniques when feasible. It is essential to remember that there are disadvantages as well to using non-radioactive techniques: many of these techniques generate hazardous wastes rather than radioactive wastes, some methods cost more than radioactive methods, and some techniques lack the sensitivity of radioactive techniques. The university has set up programs to reduce waste volumes including the DIS program which will ultimately reduce radioactive waste volumes by approximately 90%, a sewer disposal program, and the use of off-site waste processing methods such as compaction and steam reforming (which reduces volumes by at least 50:1). The radioactive waste program at Princeton should be recognized as highly successful in its goal of reducing waste disposal costs safely and efficiently.

2.1 Create an administrative organization for coordinating toxic substances education and handling.

The creation of an advisory panel with members from faculty, OHS, purchasing and PERC would be the most effective way to work towards implementing each of the recommendations which follow.

2.2 Create a common on-line server to record inventory and safety information.

Such a file would aid in record-keeping, assuring safe lab practices, and reducing toxic substance waste. It should hold the following information:

First, for the undergraduate lab courses, we more attention must be given to the instruction of proper disposal of the various types of wastes. It is appropriate that every lab course dealing with any form of hazardous or medical waste should begin with a presentation focusing only on the disposal methods. Such a presentation may take no more than fifteen minutes and should include a discussion of the environmental aspects of hazardous and medical waste disposal. This is an important perspective often overlooked by students who are ìjust trying not to break the rules.î Students should understand that improper sewer disposal of wastes (pouring into sinks) is not only dangerous but is illegal. To reinforce and make accessible this information throughout the course, a reference page should be included at the front of every lab manual outlining the various disposal methods in the labs.

2.4 Promote faculty awareness of conservation in the lab through seminars and education series given by peers or invited specialist speakers.

Many private pharmaceutical companies that are under tight environmental regulations are developing laboratory procedures that require fewer hazardous materials and produce less waste. An example is the replacement of radionucleotides for some biological assays with safer, non-hazardous materials. A training program for primary investigators and their technicians should be instituted that explains these environmentally-sound lab practices and encourages investigators to reduce their use of hazardous waste materials.

The university has been working with the local fire and rescue units to determine the most effective means of relaying lab materials information to response units in the event of fire or spillage. Much concern has been given to how much information needs to be relayed without being overly technical. Currently, emergency response information is held in each lab on the doors, by each department, and centrally by Public Safety. An investigation into the benefits of making this information available over the on-line server would make the information accessible almost anywhere on campus.

It is essential that departments explore methods to implement microscale experiments whenever possible. A form of such experiments was implemented in introductory organic chemistry courses with much success.

The university meets the state and federal laws and regulations regarding hazardous waste handling and disposal. However, a closer look at the handling and record-keeping procedures reveals the following observations at the different stages of use.

It is not possible to obtain the amount of hazardous material purchased by different facilities from the purchasing records because there is no provision for identification of hazardous materials on the purchase order.

Waste generation and disposal by individual laboratories are not recorded. Disposal amounts are recorded at the four pick-up sites and kept by OHS. These records, which must be reported annually to the EPA and NJDEPE, aggregate the waste from the several laboratories which use each pick-up site.

In each of these stages the common factor is the lack of data. This makes evaluation of possible waste reduction schemes difficult. The U.S. Congress has made waste minimization a national policy and goal of each waste generator, and future regulatory changes are likely to place even more emphasis on waste minimization (ACS, 1990). A key step toward waste minimization is the ability to track chemicals. While the implementation of a full Chemical Tracking System (CTS) at Princeton is not entirely plausible, some changes at each stage are needed in order to obtain better data so as to enable calculation of the need for a chemical tracking system. Based on the above observations, the following recommendations have been made; each recommendation is discussed in greater detail in Appendix 2.A. Implementation of these recommendations should proceed by consultation with an advisory panel composed of members of faculty, OHS, purchasing and PERC.

An extra questionnaire in the purchase order can be introduced which will provide the record of the user, lab code, material, and amount. This information furthermore needs to be made available to future audit teams so that identification of the source of the major hazardous waste materials can be identified.

Each laboratory should bring with all waste deliveries to the pick-up site a page listing lab code, type, quantity and comments about the waste. The university pick-up person will collect them along with the waste. Alternatively, the pickup personnel can record the amount and content of waste received from the labs. Currently, records are kept of the types and volumes of wastes that are received at the pick up sites, but there is no indication of the source of the waste (i.e. which lab or researcher).

One of the recommendations of American Chemical Society task force on the Resource Conservation and Recovery Act (RCRA) and Laboratory Waste Management is that universities develop a successful surplus chemical exchange process [ACS, 1990; ACS, 1993]. Often a chemical exchange program is coupled with a Chemical Tracking System. In place of a CTS, the following laboratory level program can be implemented with minimal system alteration. However, a successful implementation will require some degree of administrative effort in education and promotion. Features of the program are as follows:

2. Any researcher can post the following information whenever they have an excess chemical

d) comment (may contain description, purity or possible contamination and a brief use history)

3. A researcher before purchasing a chemical may check the common server. If (s)he finds something suitable, a transfer can take place and the receiving party removes that item from the server.

4. This server can double as a locator for partners in joint purchasing of chemicals.

A key concern in this process is purity. Organizing a seminar with peers from other universities currently using chemical exchange may help solve this problem.

Those looking for chemicals would contact directly the person offering the chemical to discuss purity and arrange transport. As long as the program is operated on a small scale, which is likely, costs will be minimal. In terms of transport of any chemicals, a small scale uptake of the program and its primary use within departments would not significantly increase the level of chemical transport which already takes place on campus.

One example demonstrates a potential use of such a system. Robin Izzo of OHS relayed the story of a faculty member who recently received the wrong chemical in an order. The chemical company offered to ship the proper chemical at no extra charge and advised the researcher to throw away the unwanted chemical. Reluctant to dispose of a perfectly good chemical, the researcher called OHS asking where the chemical might be needed.

The cost of medical waste disposal and the amount of material being generated into this waste stream could be substantially reduced or eliminated if the university accepted the option considered several years ago to invest in equipment which can pulverize and chemically disinfect medical waste, allowing it to be disposed of with general solid waste. This option would also eliminate the concern that has been associated with medical waste disposal over the years that material considered infectious might end up at the landfill. What follows is not a full cost benefit analysis, but a rough estimation of what the costs of such a system might look like.

These costs are based on models marketed by Medical-Safe TEC of Indianapolis, Indiana. There are two options. The first option is to install small units in the labs themselves at a cost of $100,000 per unit. While this is a significant investment, the operating costs would be around $0.06 per lb. of waste. This compares favorably with current unit disposal costs of $0.26 per lb. Assuming the installation of two of these units, a simple back-of-the-envelope calculation indicates that the units could pay for themselves in 10 - 15 years. The second option is the purchase of one large pulverizing unit at a cost of $290,000. This would also have operating costs of $0.06 per lb. A further consideration with the purchase of such a unit is that there would be the need for a full time staff member to operate the unit. In light of the potentially higher costs of the large unit, research should be done on the feasibility of investing in the smaller equipment. There would be a need for training lab personnel to operate such equipment, but such skills would not likely require a full time staff member.

Because of the possibility of costly fines for violations, the university should find and correct the source of the lead violations in the Engineering Quadrangle and silver violations in the Lewis Thomas/Guyot/Shultz Laboratories area. Because SBRSAís pretreatment program is covered by the Federal Clean Water Act, if violations continue to occur, the state or federal government could also take enforcement action against the university. Correcting the violations would also lower the amount of heavy metals (lead and silver) being discharged into local rivers and streams after going through SBRSAís waste water treatment plan. These waterways are used for drinking water and provide habitats for aquatic life.

Princeton University is definitely in compliance with state and federal hazardous waste disposal regulations. Although there are no strong fiscal incentives for the labs to reduce the hazardous or medical waste streams leaving campus, this task force recommends that the university take a leadership role in reducing the levels of hazardous chemicals entering the environment. The example of the efforts made and results achieved by the radioactive waste program should be followed for hazardous and medical wastes as completely as possible. One very simple way to help create an ethos of environmental concern and fiscal responsibility is to implement a surplus chemical program. This idea as well as other recommendations point to directions the university can begin looking to make reductions in use; however, all lab and maintenance personnel should continue to explore more detailed procedures to make even small scale waste reductions, which in the aggregate can make a big difference. Pollution prevention foresight may eventually save hundreds of thousands of dollars in environmental cleanup and health care costs that will rise inevitably with continued toxic waste production.

Robin Izzo, Asst. University Industrial Hygienist, Occupational Health and Safety

Garth Walters, University Industrial Hygienist, Occupational Health and Safety

Princeton University pretreatment file reviewed on January 10, 1995 at SBRSA plant, and discussion with:

American Chemical Society (1990). The Waste Management Manual for Laboratory Personnel, prepared by the task force on RCRA, Department of Government Relations and Science Policy.

American Chemical Society(1993). Less is Better: Laboratory Chemical Management for Waste Reduction, prepared by the task force on Laboratory Waste Management, Department of Government Relations and Science Policy.

Each generator laboratory of hazardous waste may be identified by a 5-6 digit number. The lab location and work type can be identified by that number while user list (described below) may change. The existing 3 digit department code (e.g. 165 for Civil Engineering Operations Research) may be used in conjunction with a 2-3 digit number as departments often have more than one lab. The information that should be available on the on-line server is listed here.

a) User laboratory information: This is a list of users, lab manager, principle in- vestigator and safety coordinator for each laboratory.

b) Material Safety Data Sheet: MSDS of all the hazardous materials should be made available on-line sorted alphabetically.

		1990	1991	1992	1993
waste description	units
lab packs	lbs.	40165	31041	41840	40182
mixed radioactive waste	lbs.	900	900	0	0
mercury	lbs.	0	60	200	1791
waste oil	lbs.	7230	6364	9443	7456
flammable & combustible	lbs.	2405	270	720	736
rinse water	lbs.	0	0	500	1050
solvents	lbs.	150	120	0	0
arsenic	lbs.	0	0	8000	4000
corrosive	lbs.	0	0	0	176
PCB transformer waste	lbs.	5630	38077	0	0
fly ash	lbs.	1200	0	0	0
waste electric cleaner	lbs.	0	125	0	0
chemicals from printing	lbs.	0	60	0	0
paint and paint products	lbs.	0	0	15108	9183
petroleum products	lbs.	3000	0	0	0
total	lbs.	59780	77017	75811	64574

		1990	1991	1992	1993
PCB transformer oil	gallons	170	0	0	0
waste oil	gallons	3505	289	590	1160
parts cleaner	gallons	0	0	113	345
storage tank removal waste	gallons	0	0	0	300
flammable and combustible	gallons	1100	0	0	0
antifreeze	gallons	0	0	0	225
petroleum products	gallons	0	0	1425	605
total	gallons	5455	289	2128	2635

In most cases where data is given for only one or two years for a certain material, this represents a non-regular waste stream. For example, the high paint figures for 1992 and 1993 were due to a major inventory cleanout by Facilities. Also, certain figures may be somewhat misleading because they include large volumes of non-hazardous material that has been contaminated and thus in accordance with regulations must be listed. For example, the high mass of arsenic waste reported in 1992 and 1993 is not simply arsenic disposal. This includes laboratory equipment that was contaminated with arsenic. Because of these difficulties in reading the data, no recommendations have been based on strict analysis of the above numbers. Rather they are intended to present an overall view of the type of wastes and an order of magnitude of waste mass.

These waste descriptions include but are not limited to the materials listed below them.

Since the fall of 1993 the universityís short-lived solid radioactive waste has been stored in the basement of Moffett in a facility managed by the molecular biology department. In this decay-in-storage program wastes are segregated by isotope and stored for at least 10 half-lives. A survey is then done with a Geiger counter, and, if the material is not detectably radioactive, it is treated as medical waste for disposal. Under the universityís current NRC license, this method of waste disposal is permitted for isotopes with half-lives of 65 days or less, including P-32, P-33, Cr-51, Ca-45, and I-125, which account for 50% of radioactive waste on campus.

Aqueous wastes contaminated with half-lives of 90 days or less are also stored in the molecular biology department. Other departments contact the molecular biology department for waste collection and packaging procedures.

About 40% of the radioactive waste on campus has a half life of 87 days. Another license must be obtained for decay-in-storage for these materials, i.e. S-35, so that they can be stored in the molecular biologyís DIS program. Until then these wastes will be held by the generating department.

The university has recently had a new sewer disposal program approved. Sewer disposal of wastes is desirable compared to the options for these wastes: ten-year storage in the DIS program or turning the materials into cement, which will cost $10,000 per 55 gallon drum once it is ultimately disposed of off-campus. There are two types of sewage disposal: primary and secondary. Secondary disposal allows labs to designate one sink per lab to the disposal of very dilute short-lived DIS liquids. These include P-32, P-33, Cr-51, Ca-45, and I-125. Records of these disposals must be given to the Health Physics staff of OHS. There are daily limits for each isotope. If the material does not meet the criterion, it must be stored in DIS until it does. Primary disposal refers to long lived isotopes. Each release of primary materials must first be approved by OHS in order that such releases do not exceed 1 curie per year. Training for this program is ongoing and is being done for maintenance personnel as well as for each individual lab.

A thorough study of the public health risks of the program has been undertaken. These releases are far below the stated EPA regulations and pose almost zero health risk. It is important to note that any risk at all of radioactive waste should be weighed against the societal benefits of the research using such materials, such as cancer and water pollution research.

These compounds require additional processing and are segregated from the rest of the solid wastes. These wastes must be specially packaged according to OHS procedures.

Mixed waste is defined as that which is both hazardous and radioactive. There is virtually no means of disposal of mixed waste. Princeton generates about 5 gallons or mixed waste per year. Research generating this waste is strongly discouraged. Storage of flammable mixed waste may not be possible.

These ìbiodegradableî fluids are not released to the sewers but are sent to Gainsville, Florida for incineration.

This material may be used for educational and non-profit use. Commercial use of this information is prohibited without written consent. Copyright © 1995, Princeton Environmental Reform Committee, Princeton University.

Princeton Environmental Reform Committee (PERC) Environmental Audit of Princeton University

Chapter 2 - Toxic Substances