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Yale RCRA Inspection and Supplementary Environmental Projects

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Elan Gandsman
Director, Environmental Health and Safety
Yale University
New Haven, Connecticut

Environmental Protection Agency Inspection

First academic institution to be inspected by EPA Region I


Inspection May 3 and 4,1994
  • May 3, 1994- 2 inspectors, Science Hill
  • May 4, 1994- 5 inspectors, Medical School/Records

Report supposed to be available in 30 days

Filed for report through Freedom of Information Act

Request For Information

Received request from EPA - February 2, 1995
Sent information to EPA - March 16, 1995

Example request:

For each of the waste containers observed by EPA inspectors and identified below, you are requested to:
    1) provide a MSDS,
    2) identify the primary chemical constituent,
    3) identify all applicable EPA hazardous waste codes.
a) Lab, Room 171A:
    1. containers marked "halogenated solvent"
    2. containers marked "non-halogenated solvent"
    3. containers marked "organic halogenated waste"
Identify each employee involved in hazardous waste management at this location and provide the following information:
    a) job title;
    b) written job description;
    c) the date of employment;
    d) documentation of initial hazardous waste training; and
    e) documentation of annual hazardous waste training for calendar years 1992, 1993, and 1994.

Laboratory Satellite Accumulation Areas (LSAA)

A. All LSAAs shall be labeled as "Hazardous Waste Satellite Accumulation Area - Unauthorized Access Prohibited Use Restricted to Personnel Working in (insert room numbers of laboratory rooms).

B. Any person who generates hazardous waste that is accumulated in an LSAA shall receive training pursuant to the training plan attached as Exhibit ____ to this consent agreement in compliance with the schedule set forth in Paragraph ____ of this consent agreement.

C. Use of LSAAs shall be restricted to "authorized users" of the area

D. Hazardous waste accumulated in any one LSAA shall be limited to a total of 55 gallons, regardless of the number of containers or waste streams.

E. A container holding a hazardous waste that is incompatible with any waste or other materials accumulated nearby in other containers must be separated from the other materials, in accordance with 40 CFR 265.177

F. The operator of an LSAA shall prepare and maintain a written inspection checklist for the purpose of conducting weekly inspections of his/her LSAA.

Yale and EPA Complete Consent Agreement

  • Civil penalty
  • Supplementary Environmental Projects
  • Restructure waste management program in laboratories

I. Re-Scaling Of Undergraduate Organic Chemistry Laboratory

A. Description

Yale University shall, as a Supplemental Environmental Project, transition the undergraduate organic chemistry laboratories from what is typically described as ''macro-scale'' to ''micro-scale.'' This project involves the modification of the Yale University undergraduate organic chemistry laboratory curriculum to introduce microscale experiments and to enhance existing semi-microscale experiments in a manner that will further minimize hazardous waste generation.

Undergraduate organic chemistry laboratory courses currently enroll approximately 300 students per semester. Implementation of microscaling is expected not only to reduce the hazardous waste generated by the laboratory sessions associated with these courses but also to reinforce students' awareness of hazardous waste management issues and familiarize them with waste minimization techniques that many will continue to apply in their scientific careers. By reducing both the quantity of reagent used and the time (and, therefore, the fatigue) involved in executing experiments, microscaling and enhanced semi-microscaling techniques also have the potential to enhance the safety of the teaching laboratories.

The goal of this SEP is to enhance the semimicroscale experiments performed in the first semester laboratory courses and to replace approximately 50 percent of second semester experiments with microscale experiments. In redesigning the curriculum, the faculty will focus on the conversion or replacement of those experiments that generate relatively large chemical waste streams. Retention of some semi-microscale experiments will be necessary to assure that inexperienced students develop proper experimental technique.

B. Proposed Budget

Phase (1) Total $93,735

II. Hazardous Chemical Waste Management Training Program

A. Description

The University shall, as a Supplemental Environmental Project, develop and make available appropriate "internal" hazardous chemical waste management training to Principal Investigators and laboratory personnel operating laboratories characterized by EPA New England as satellite accumulation areas under 40 C.F.R. 262.34 (c) (1). In addition, as an "external" component of the project, the University shall develop a hazardous waste management/waste minimization workshop, which will be presented by the University in an effort to educate faculty members and environmental health and safety professionals from other educational institutions, research institutions and/or small industrial research and development companies on the proper laboratory management of chemical wastes.

Under the "internal" training component of this SEP, University personnel will evaluate various methods by which hazardous chemical waste management training may be delivered to Principal Investigators and laboratory personnel operating laboratories characterized as satellite accumulation areas. It is expected that the primary, if not exclusive, delivery methods to be evaluated for possible implementation will be:

(1) face-to-face instruction of Principal Investigators and laboratory personnel on a departmental basis by trained OEH&S personnel; and/or

(2) a computer interactive instructional program.

Following the evaluation of alternatives, a hazardous chemical waste training program shall be developed for implementation at the University, which may involve one delivery system or a combination of delivery systems. It is expected that a minimum of 650 Principal Investigators and/or laboratory personnel will be trained using one or a combination of the delivery systems. Yale shall maintain a list of those individuals trained until such time that the provisions of the Consent Agreement that relate to this SEP terminate.


A. Description

Yale University shall, as a Supplemental Environmental Project, fund certain capital and one-time nondepreciable projects necessary to upgrade the Lead Poisoning Resource Center ("Resource Center"), which Yale shall make available at the current location or a satisfactory alternate location for three (3) years. The Resource Center is a joint project between the City of New Haven and the Department of Pediatrics at the Yale School of Medicine and is part of the Yale Lead Program. The purpose of the Lead Program is to integrate and coordinate the delivery of care to children affected by severe lead poisoning by enabling both families and property owners to access many different types of educational information and services simultaneously under one roof.