Proper hazardous waste management is a process that involves both personnel in the unit generating the waste and the TSO personnel.  It involves the identification and characterization of a waste stream, proper containment and storage of the waste in a designated Satellite Accumulation Area (SAA), inspection of the containers in an SAA and the SAA itself on a regular basis, and scheduling for removal of the waste streams from an SAA as required by regulation.  Details of what an SAA is, how to create one, and procedures for waste removal from the ISU campus are given below.
     This information on SAAs is designed for those who generate waste on a regular basis.  Information is also presented on occasional or spot generation of hazardous waste for those who fall into that category.  If you generate hazardous waste infrequently, have questions about whether you need to establish a SAA, or questions about your active SAA, call the TSO at x2310 for information and assistance.
      Close coordination between the persons involved with a SAA and TSO personnel is vital for effective waste management, minimization, and disposal from waste generated at ISU.  Your cooperation with all procedures is essential to the future of laboratory work and scientific research at ISU. 

6.1  Satellite Accumulation Area (SAA) Definition
     A SAA is defined in 40 CFR 262.34, but is interpreted differently by each of the 10 EPA regions in the U.S.  It allows for accumulation of up to 55 gallons of hazardous waste or 1 quart of acute hazardous waste (P-listed) "..at or near any point of generation where wastes initially accumulate."  EPA region 10 defines this location as being within the room where a waste is first generated, and thus, it cannot pass through a doorway to a hall or be moved to another waste SAA, even though it may contain a compatible or identical waste stream.  Thus, a separate SAA must be created for each laboratory or room where a waste stream is generated; more than one SAA may also be needed in the same room if incompatible waste streams which need to be separated for safe storage are generated in that room.  It is important to not overlook laboratory complexes.  A doorway is the boundary, even if the doorway leads to a smaller room in the complex and not a hallway.  If you have any questions concerning the definition of an SAA or its characteristics, contact the TSO at x2310.

6.2  SAA Documentation
     Various forms of documentation are used to help manage the SAA.  These include a "SAA Registration" form, a "Satellite Accumulation Area" sign, a "Emergency Response Instruction" label, and a SAA packet (or binder) containing:

• "ISU Waste Management Guidelines" overview
• "Chain of Custody" form
• "Hazardous Waste" labels
• "SAA Inspection" form
• ISU Hazardous Waste Policies and Procedures Manual (recommended)

     All forms and labels can be obtained from the TSO at no cost to the department.  Examples of each of these can be found in Appendices L to R.  Other forms and labels can often be found in SAA binders.  Examples of these include: Hazardous Chemical labels, informative lists (such as Peroxide Forming Chemicals, and incompatibility of laboratory chemicals), segregation of incompatible chemical instructions, MSDSs, and information about the NFPA fire diamond. 
     The SAA Registration / Termination form is used to both initiate or terminate a SAA with the TSO.  This form is used by the TSO to predict the amount and frequency of hazardous waste generation, identify any unusual characteristics that would require special handling, and also to provide contact information for the responsible personnel.  When all registration information on the form is completed, it is sent to the TSO for inclusion in the records.  Occasionally the TSO will request updated information to include with this form.
     The Satellite Accumulation Area label should be placed on the outside door of the SAA enclosure.  It is designed to be highly visible and provide notification to occupants of a room as well as for emergency responders that hazardous waste is stored within the enclosure.
     The Emergency Spill Response Instructions labels are either adhesive-backed or included in the cover of the SAA binder.  The adhesive backed labels should be applied to the surface near the entrance(s) to a SAA, near a telephone or exiting door in the room containing the SAA (or nearest available telephone), and near the SAA area.  These instructions are to be followed by those who discover a leak or spill of material at a SAA location. 
     The ISU Waste Management Guidelines form is a quick reference document of SAA management responsibilities.  It should be only used as a guidance document and does not replace this manual. 
     The Chain of Custody form is used to record information on the hazardous waste container, which is placed in a SAA.  It also provides the official  record of transfer of wastes from the area of generation to the TAA.  Please press firmly with an ink pen when filling out a Chain of Custody so that all carbon copies can be read.
     The Hazardous Waste label is also used to properly identify waste chemicals and their physical properties as well as identify them for inventory purposes.  It is of utmost importance that the hazardous waste labels are completed accurately.  Improper or false labeling may lead to a serious accident.
     The SAA Inspection form is used to record the weekly inspection certification of a SAA by TSO personnel.  A signature on this form indicates that the SAA and its contents have been inspected for leaks, compatibility, proper containment, and spills.
     The Incident Notification form will be filled out by TSO personnel when a policy of this manual has not been followed.  The purpose of the form is to inform the SAA personnel that a policy has not been followed, so that corrective actions may occur and proper policy can be followed in the future.  This form is typically used when laboratory personnel can not be located and notified of the incident immediately during an SAA inspection.  This form may also be used when incidents are repeated.
     Please fill out all documentation carefully and accurately.  The information provided by SAA coordinators, SAA managers, and SAA waste generators is relied upon by others to provide information they need to work safely with the waste, and to ensure regulatory compliance.

6.3  SAA Creation and Responsibilities
     Creation of an SAA is both simple and convenient.  For each SAA, a SAA coordinator and a SAA manager (it may be the same individual) is designated.  The SAA manager should ensure that a waste is properly characterized and contained before it is placed in the SAA, and that the required paperwork is accurately filled out.  The SAA coordinator must certify that the waste stream has been properly identified and that the Chain of Custody form is signed when the waste stream is removed from an SAA for proper waste disposal.  The TSO has prepared SAA packets which contain all the forms and labels needed to originate and operate each SAA.  Examples of things found in the packets are found in Appendices L to R at the end of this manual.  TSO staff prefer to be involved in the creation of the SAA directly in order to provide training to the manager and guarantee that TSO receives all the required paperwork and has access to the room. 
     It is important for an SAA to be formally included on the list of sites inspected by the TSO.   When a new SAA is needed, please complete a SAA registration form.  TSO will work with you to choose the site and help define what waste streams can be considered compatible in the SAA. SAAs should be kept in a locked room.  Once an SAA is accepted, the TSO will notify the SAA coordinator and it will be included on the weekly inspection route of the TSO.   These steps must be completed prior to any hazardous waste being created and placed in an SAA.

6.3.1 Proper Containers 
     Hazardous wastes that are placed in an SAA must be in a proper container.  A proper container is one that meets the following regulations:

 40 CFR 264.171 Condition of containers.
     If a container holding hazardous waste in not in good condition (e.g., severe rusting, apparent structural defects) or if it begins to leak, the owner or operator must transfer the hazardous waste from this container to a container that is in good condition or manage the waste in some other way that complies with the requirements of this part.
 40 CFR 264.172 Compatibility of waste with containers.
     The owner of operator must use a container made of or lined with materials which will not react with, and are otherwise compatible with, the hazardous waste to be stored, so that the ability of the container to contain the waste is not impaired.
 40 CFR 264.173 Management of containers.
     (A) A container holding hazardous waste must always be closed during storage, except when it is necessary to add or remove waste.
     (B) A container holding hazardous waste must not be opened, handled, or stored in a manner which may rupture the container or cause it to leak.

     In addition to the federal regulations, ISU requires that no foodstuff containers be used to hold a hazardous waste.  This is a precautionary measure to prevent accidental ingestion or improper disposal. 

     Contact the TSO for more information concerning proper containers or if you need help in locating a proper container.  We recommend that whenever possible hazardous wastes are stored in the original hazardous chemical bottles and are appropriately labeled as waste with any added components also marked on the label.  TSO staff will gladly return empty waste containers to the department after the waste shipment, so long as prior arrangements have been made to do so.  TSO does not have room to store empty waste containers for departments.

6.4 SAA Management
     The persons who work with SAAs are the waste generator, the SAA manager, the SAA coordinator and TSO staff.  It is also important that students working in the laboratory containing an SAA understand these procedures and safety practices.  TSO has prepared training material for students and TAs working in laboratories and training is available upon request.
     Use of a SAA must be limited to the SAA Coordinator, SAA Manager, Generator, and TSO personnel.  This will help prevent placement of an unidentified or uncharacterized waste into an SAA.  Rooms containing SAAs should be locked when unattended.

6.4.1 Waste Generator
     A person who is directly responsible for creating a hazardous waste is referred to as the Waste Generator.  Generators are normally the laboratory workers, whether they are students, technicians, or faculty.  They are to notify their SAA Manager and TSO of laboratory activity that may potentially generate a hazardous waste.  They should be trained how to utilize the SAA management system and are responsible for handling their waste according to this manual and all training provided to them.  Spot generation also occurs at this University.  Spot generation refers to a one time or infrequent generation of hazardous waste.  Any department on campus may have spot generation occurring.  When spot generation occurs, TSO staff should be notified immediately so that the hazardous waste can be transferred to the TAA.

6.4.2 SAA Manager
     Each SAA will have a specific person referred to as the SAA Manager.  Generally, this is the laboratory's principal investigator or laboratory supervisor.  The SAA manager is specifically responsible for: 

• obtaining SAA training of lab personnel
• all material placed within the SAA
• the general safety of the SAA
• proper labeling of waste containers
• maintaining/filing Chain of Custody records 
• notifying the TSO of needed pickups 

• providing materials needed for the SAA
• assisting researchers in characterizing waste
• coordinating waste pickups where needed
• providing training to stockroom personnel
• acting as liaison between the department and TSO 

6.4.4 Technical Safety Office
    The Technical Safety Office has the sole responsibility for:

• providing SAA packets to departments
• final waste characterization
• hazardous waste removal
• hazardous waste transportation
• hazardous waste disposal
• placing the "Start Date" and "EPA #"on waste containers
• weekly SAA inspections 

6.5  Hazardous Waste Containment
     ISU’s hazardous waste containment policy includes, but is not limited to, the following:

• All hazardous waste must be properly stored in compatible containers that prevent rupture or leakage of the material contained. 
• Containers should not be filled beyond the neck or should have at least one inch headroom to allow for expansion. 
• Containers should be made of material that does not react with or absorb the contents and have a screw cap of similar material properties. 
• The cap must be in "new" condition, with no cracks or any signs of deterioration. ALL WASTE CONTAINERS MUST BE CAPPED DURING STORAGE, EXCEPT WHEN ADDING OR REMOVING WASTE. 
• No foodstuff containers may be used to store hazardous waste even if they are compatible with the material. See Section 6.3.1 for an explanation of this policy. 

6.6  Hazardous Waste Labels
     Properly labeled waste containers are critical for managing hazardous waste in a manner that is safe and compliant with regulatory requirements.  Each waste container must be labeled with the following:

• the words, "HAZARDOUS WASTE"
• the waste generator’s name, building and room number where the material was generated.
• the chemical constituents contained.  A generic title may be used only if specific waste profiles have been established with the Technical Safety Office (i.e., in teaching labs or long term research projects).

6.7  SAA Monitoring / Waste Tracking
     ISU is in a transition phase with electronic tracking systems.  Although the Hazardous Material Tracking Program (HMTP) is still available, TSO currently tracks hazardous waste using a Microsoft Access database program designed by TSO staff.  The HMTP has proven to be difficult and slow to use.  TSO is planning to procure a new chemical tracking program that will allow for all current and incoming chemicals on campus to enter the database and be tracked from their shelf location to their eventual disposal location.  Other chemical information such as health and safety data may also be included with the software.  This program will be customizable to the University’s specifications and accessible from every internet linked computer on campus.  TSO will provide training on the use of this program as soon as it is available.

6.8  Procedures for Satellite Accumulation Areas 
     The following procedures assume that the identity of a waste stream is known.  For unknowns, please contact TSO personnel.

• When a new waste stream is identified, the SAA coordinator should obtain a SAA folder which has all the required forms and labels for a SAA.
• The SAA manager should characterize the waste using either technical data or process knowledge; this may require assistance from the waste generator or TSO.
• The SAA coordinator should complete the "SAA Registration" form and receive notification from the TSO that the SAA is ready for waste storage.
• The SAA manager or generator ensures that proper containers are used for waste, that a "Hazardous Waste" label with the required information is placed on each hazardous waste container and that the required information is entered on the "Chain of Custody" form.
• When hazardous waste removal from the SAA is required, the hazardous waste coordinator should notify the TSO.  TSO personnel will pick up the waste after the SAA manger or SAA coordinator has completed "Chain of Custody" form and TSO personnel sign the "Chain of Custody" form indicating receipt of the waste containers.  A copy of the "Chain of Custody" form is left at the SAA as evidence that the waste has been accepted by TSO.  The TSO also picks up waste without having been called by SAA personnel when it is time for shipments.
• The hazardous waste is then transported by TSO personnel, as soon as reasonably achievable, to a storage facility called a Temporary Accumulation Area (TAA).  This transportation is only done by TSO personnel and only while using ISU-owned vehicles.  Once a waste container arrives at the TAA, the individual containers are segregated according to their chemical compatibility and hazard class. 

6.9  Procedure For Waste Removal From ISU Campus

    The following procedures are followed for shipment of wastes.

• The hazardous waste is packaged for shipment to an EPA approved  treatment/storage/disposal (TSD) facility.
• Each container is identified and labeled according to Department of Transportation(DOT) hazard class regulations.
• After the hazardous waste is taken by the broker for transportation to a TSD facility, aprintout of the shipment is obtained from a shipment tracking program and placed in a per-shipment file by TSO personnel.
• When a waste stream has been properly disposed of by the TSD facility, a "Certificate of Disposal" is provided by the waste broker as further evidence that a waste stream has been disposed of in accordance with all applicable regulations.  These are also kept by the TSO personnel in a per-shipment file.

6.10  Spot or Occasional Hazardous Waste Generation
     Some hazardous waste generation occurs as a result of the infrequent or one-time activities that do not warrant the creation of a SAA.  Many of the responsibilities and activities listed in section 2.4.3 through 2.4.5 are still required of spot or occasional generators.  TSO personnel should be contacted for assistance whenever a potentially hazardous waste is identified.

6.11  Hazardous Waste Treatability Studies
     Laboratory research using samples of actual hazardous waste to investigate the efficiency of treatment or recycling are termed Treatability Studies.  Researchers may use a limited amount of hazardous waste as a sample in a treatability study.  These samples are exempted from the general hazardous waste regulations but are subjected to the treatability study regulations in 40 CFR 261.4 (e) and (f).  If samples contain radioactivity as well as hazardous chemical wastes, the investigator must be approved as a "Responsible User" by the ISU Radiation Safety Committee and the Responsible User's program must encompass the amounts and types of radioactive materials involved.
     The treatability study regulations include limitations on quantity, allowed study processes, and duration of study/storage period.  The regulations also state that proposed treatability studies are subject to regulatory oversight.  The Idaho Department of Environmental Quality (IDEQ) and the TSO must be notified no less than 45 days in writing before a project begins.  The principal investigator for each project must provide IDEQ  with a contractual Treatability Study agreement with the funding agency and sample provider (prior to obtaining any sample material).  In addition, the principal investigator must provide copies of all correspondence with IDEQ to the Technical Safety Office.
     It may be desirable to conduct preliminary studies using new chemicals instead of actual hazardous waste.  Studies with new chemicals are not subject to the special treatability study regulations.  However, any hazardous waste created during the conduct of the study must be handled according to the regular ISU procedures.
     The principal researcher must work closely with the Technical Safety Office to assure regulatory compliance (e.g., a list of reporting requirements can be obtained from the TSO).  The TSO will offer technical and regulatory assistance to researchers interested in conducting Treatability Studies.  The principal investigator should notify the TSO of planned Treatability Studies as soon as feasible.

     The TSO must submit an annual report to IDEQ covering all ISU treatability studies.  In order to collect information for this report, treatability study principal investigators are required to submit a yearly Treatability Study Progress Report to the TSO by December 31 of each year.  The format of the report can be obtained from the TSO.
 

Technical Safety Office Idaho State University Campus Box 8106 785 S. 8th St. PS Rm 101  Pocatello, ID 83209 Phone: (208) 282-2310 or 282-2311 Fax: (208) 282-4649