RCRA - STORAGE/DISPOSAL > Overview

This section of the EVC covers the topic of hazardous waste management in a medical area, specifically associated with developer/fixer disposal. A typical medical institution within a university setting can potentially generate wastes as a result of developer/fixer waste, radiographic x-rays, photochemicals, film processing, scrap film, discarded imaging films, fixer solutions and outdated chemicals. Depending on the composition of these materials, they may be considered hazardous waste by characteristic (for example, corrosive) and/or be listed wastes due to their metal content.

Processing spent developer/fixer (and other silver containing material for that matter) through a silver recovery unit can allow the material to be considered non-hazardous, however you should check with EH&S staff to determine your school's procedure on this issue. Some hospitals/dental facilities have on-site silver recovery units, while other facilities contract this to a licensed contractor. More information concerning waste management and reduction is presented in the "Best Practices" and the Resource, Conservation and Recovery Act (RCRA) expanded section of this EVC section.

As you may know, the federal Resource Conservation and Recovery Act (RCRA) and the implementing federal regulations at 40 CFR Parts 260-272 govern hazardous waste management. Many states also have their own, sometimes more stringent, regulations. Not only is hazardous waste management one of the most common environmental issues at college and university campuses, but the specific requirements for hazardous waste (RCRA) are so numerous, the EVC has, as appropriate, split the content into three areas as follows:

• RCRA (Storage/Disposal)
• RCRA (Record keeping)
• RCRA (Training/Other)

The overall intent of RCRA is to manage hazardous waste from generation to ultimate disposal. This "cradle to grave" approach has resulted in regulations governing hazardous waste generators, transporters, and treatment, storage, and disposal (TSD) facilities. Given that most university facilities do not themselves transport hazardous waste to an off-site hazardous waste disposal facility, treat hazardous waste, or operate a hazardous waste disposal facility, the regulations governing these activities are not addressed in the EVC. More typically, your facility would generate, store the waste and then have a contractor transport the waste off site for disposal. The specific hazardous waste management requirements a facility must follow depend on the facility's generator status and the types of waste it produces. In other words, the generator status of the college or university will determine the type of requirements individual departments may need to follow.

Most colleges and universities have Satellite Accumulation Areas. A Satellite Accumulation Area is a designated area near a process or location that generates hazardous waste where wastes are stored until they are moved to a central Hazardous Waste Accumulation area. Federal regulations allow generators to store up to 55 gallons of hazardous waste or 1 quart of an acutely hazardous waste in the satellite accumulation area. There is no time limit on the amount of time to accumulate the waste. However, once a container is considered full, the generator has 72 hours to have the container transferred to the institution's hazardous waste storage area. From there the waste is shipped to a licensed hazardous waste treatment, storage or disposal facility.

Continue further along the EVC tour and learn more about RCRA storage/disposal requirements.