Waste Minimization Plan






















Prepared by:
Environmental Health and Safety Department

Revised February 2012





Waste Minimization Plan
Table of Contents


Policy Statement ............................................................................................................. 1
Introduction ..................................................................................................................... 1
Regulatory Background ................................................................................................... 1
Responsibilities ............................................................................................................... 2
Established Operating Procedures .................................................................................. 2
Centralized Chemical Storage and Distribution Services ............................................ 3
Web Based Chemical Inventory and Database ........................................................... 3
Centralized Waste Management Program .................................................................. 4
Recycling Programs .................................................................................................... 4
Micro-scale Processes, Experiments, and Demonstrations ........................................ 5
Material Substitution ................................................................................................... 5
Spill Team Response .................................................................................................. 5
Charge Back For Actual Waste Disposal Costs .......................................................... 5
Waste Minimization Training ....................................................................................... 6
Safe Research Facilities ............................................................................................. 6
Acid Base Neutralization ............................................................................................. 6
Green Chemistry Principals ............................................................................................. 6
Program Assessment ...................................................................................................... 8
APPENDIX A - Waste Volume Sumary Tables 2001-2007 ............................................. 9








Policy Statement
The Colorado School of Mines (“Mines” or “the School”) is dedicated to educating
students and professionals in the applied sciences, engineering, and associated fields
relating to

the discovery and recovery of the Earth's resources,

their conversion to materials and energy,

their utilization in advanced processes and products, and

the economic and social systems necessary to ensure their prudent and
provident use in a sustainable global society.

This mission is achieved by the creation, integration and exchange of knowledge in
engineering, the natural sciences, the social sciences, the humanities, business, and
their union, to create processes and products to enhance the quality of life of the world’s
inhabitants. The Colorado School of Mines is consequently committed to serving the
people of Colorado, the nation, and the global community by promoting stewardship of
the Earth upon which all life and development depend. (Mines Mission Statement)
Introduction
Consistent with the School’s overall mission, the Environmental Health and Safety
(EHS) Department will maintain this Waste Minimization Plan for campus activities.
This plan identifies established procedures and provides recommendations to the
campus community to minimize or reduce the toxicity of waste generated on the Mines
campus.

Mines is classified as a large quantity generator of hazardous waste by the Colorado
Department of Public Health and Environment (CDPHE) and the U.S. Environmental
Protection Agency (EPA). It is important that every member of the School be aware of
the environmental and financial impacts related to the disposal of hazardous wastes.
Areas on campus that generate hazardous wastes include research and teaching
laboratories, Plant Facilities’ maintenance shops and the truck shop, and Student Life
maintenance shops. Waste minimization practices must be integrated into the operating
procedures of these academic and maintenance departments.
Regulatory Background
1990 Federal Pollution Prevention Act – Requires the use of materials, processes, or
practices that reduce the use of hazardous materials, energy, water, or other resources
and practices that protect natural resources through conservation or more efficient use.

1992 – Colorado Pollution Prevention Act – Makes pollution prevention the
“environmental management tool of choice.” It is the intent of the CDPHE to integrate
and incorporate pollution prevention strategies into the agency’s permitting, inspections,
enforcement, rules development, remediation, assistance, and other functions.





Responsibilities
The Environmental Health and Safety Department (EHS) is responsible for the
following:

 Develop and maintain the waste minimization program;
 Operate a centralized chemical procurement and distribution service;
 Maintain an accurate chemical inventory of chemicals stored on campus;
 Maintain a web site for campus personnel to search available chemicals in the
inventory;
 Maintain a web page that allows campus personnel to adequately identify waste
items generated on campus;
 Provide annual waste generator training that addresses the elements of this
plan, and
 Identify new opportunities to minimize wastes generated during campus
operations.

Laboratory supervisors, faculty and graduate level researchers are responsible for the
following:


Oversee activities to minimize waste generation in laboratories;

Recommend waste minimizing techniques to limit hazardous waste generating
processes;

Substitute non-hazardous or less hazardous materials for research operations;

Supervise chemical ordering practices;

Follow chemical procurement practices that help reduce the quantity and hazard
of wastes generated, and

Identify new opportunities to minimize wastes generated during campus
operations.

Students and Staff are responsible for the following:


Follow established procedures to minimize waste generation;

Participate in recycling programs on campus;

Follow chemical procurement practices that help reduce the quantity and hazard
of wastes generated, and

Identify new opportunities to minimize wastes generated during campus
operations.
Established Operating Procedures
Several waste minimization tools have been established in existing operating
procedures at the School. These tools have been successful in fostering pollution
prevention attitudes, and helping to reduce the volume and toxicity of waste generated
at the School. The following identify established operating procedures that are
incorporated into Mines operations to minimize waste generation.




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1. Centralized Chemical Storage and Distribution Services
The Chemical Storage and Distribution Facility (CSDF) provides a centralized
facility for chemical ordering and storage for reagent chemicals. The facility
operation is supervised by the EHS Department’s Chemical Hygiene Manager.

All requests for chemicals are submitted to the CSDF for processing. Chemical
requisitions are filled from existing stocks whenever practical. New chemicals
are ordered through EHS and received at the CSDF. All unused chemicals are
returned to the CSDF for redistribution to other researchers on campus. Campus
personnel must possess current Hazardous Waste Generator training to gain
access to chemical procurement services.

The operation of the CSDF reduces the quantity of reagent chemicals that need
to be ordered. Subsequently, the volume of chemical waste that requires
disposal is reduced. The CSDF provides an important control to ensure initial
chemical acquisition of reagents and raw materials is limited to amounts actually
needed. Through the operation of the CSDF and the chemical return program,
Mines minimizes the volume of chemicals purchased and reduces the potential
for the generation of unused and expired chemicals that often require
management as hazardous waste.
2. Web-Based Chemical Inventory and Database
An additional benefit of the CSDF operation is the maintenance of a campus-
wide chemical inventory system and chemical database. Individual containers
are affixed with a unique bar code identification number when received at the
CSDF and entered into the database. The database is updated when a chemical
is distributed to a laboratory to track the laboratory storage location. Upon
disposal, the container or bar code number is returned to the CSDF and the
database is revised to show the container is empty or managed as waste. The
database also tracks the age of materials so reactive, peroxide-forming and
phase sensitive chemicals can be tracked, removed and managed appropriately.

This inventory is made available to campus personnel on the EHS web site
located at https://www.is.mines.edu/ehs/SearchChem/searchlogin.asp. Access
to the inventory requires current waste generator training. Campus personnel
without current training cannot gain access to search the database. Once logged
in, campus personnel may search chemical inventories owned by their individual
department, perform a campus wide search for a reagent stored in their building
or another campus building, including a reagent stored in the CSDF.

The chemical database and searchable inventory are useful waste minimization
tools. These tools provide campus personnel with the opportunity to identify
available chemical stocks, the corresponding chemical storage locations, and
check for available non-hazardous or less hazardous alternatives before placing
an order for new reagents.


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3. Centralized Waste Management Program
The centralized waste management program allows the EHS Department to
evaluate each waste container for characterization and disposal. This program
combines waste from all over campus to one facility for evaluation and
consolidation prior to transportation to an off-site disposal facility. This program
allows for more efficient waste disposal operations and minimizes the number of
containers shipped for disposal. This program also reduces the number of waste
haulers visiting campus and minimizes the haulers’ need to visit multiple facilities
in populated areas of campus.
4. Recycling Programs
The EHS Department and Facilities Management administers recycling
programs for a variety of materials used on campus. In addition to the chemical
recycling and redistribution program described previously, Mines employs
recycling to divert many hazardous materials as well as commonly recycled
materials from waste streams that would otherwise require disposal.

Facilities Management facilitates the following items for recycling:

office paper;

newspaper;

aluminum cans;

telephone books;

cardboard;
The EHS Department facilitates the following items for recycling:

used oil;

antifreeze;

scrap metals;

batteries;

computers and monitors;

toner cartridges;

cellular telephones;

fluorescent lights; and

elemental mercury.

The Student Life Department maintains a roll-off box for recycling number 1 and
number 2 plastics, newspaper, glass and aluminum from student housing.

Purchasing gas cylinders and lecture bottles from vendors who accept unused
or partially full bottles for recycling also helps reduce waste volumes. The
School’s personnel should try to work with General Air Products for gas cylinder
services. General Air will accept full or partial cylinders from Matheson Gas
Products, Phillips 66 and Alphagas for recycling.


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5. Micro-scale Processes, Experiments, and Demonstrations
Campus personnel are encouraged to consider waste generation before the
start of teaching and research activities. Researchers and instructors are
encouraged to scale down chemical processes and experiments or consider
alternative methods to reduce quantities or toxicity of wastes generated. In many
cases, EHS will assist academic departments with both recommendations and
finances to purchase equipment to achieve waste minimization goals.
6. Material Substitution
Campus personnel are encouraged to identify non-hazardous or less hazardous
products to use in teaching and research laboratories as well as facility
maintenance operations. Often EHS will assist with material substitution by
recommending non-hazardous alternatives or offering to purchase replacement
equipment that does not contain hazardous materials. Examples of material
substitution strategies include:

Use UItima Gold Scintillation Cocktail in place of other solvent-based
cocktails.

Use ultrasonic baths, Alconox or similar detergents instead of acid-
washing solutions.

Replace mercury-containing devices such as thermometers and
manometers with alcohol or digital systems.

Use latex paints instead of oil based paints

Use citrus degreasers instead of solvent based cleaners.

Use non-halogenated solvents rather than halogenated solvents.

Use SYBR Safe DNA gel stain instead of ethidium bromide, a known
mutagen.

Use digital photography to eliminate silver containing chemical fixers and
developers.
7. Spill Team Response
The EHS Department oversees a spill response team responsible for responding
to hazardous material spills on campus. Waste minimization techniques are
implemented by the Spill Team whenever a spill response is initiated. Waste
minimization techniques employed by the Spill Team include:

Use of a mercury vacuum rather than mercury spill kit. These kits
generate increased volumes of mercury contaminated solid waste.

Use neutralization techniques to collect acid or basic spills.

Use oil sorbent pads rather than paper towels or rags to clean up oil or
nonpolar liquids.

Reinforce waste minimization techniques during Spill Team training and
spill response exercises.
8. Charge Back For Actual Waste Disposal Costs
In situations where waste generating departments or activities do not
demonstrate good waste minimization practices, EHS will pass the actual waste


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disposal costs back to the responsible department. Activities that generate large
quantities of waste or do not follow the requirements of this plan are subject to
the charge back policy. This policy is intended to make clear to responsible
individuals of the monetary consequences of ignoring waste minimization
practices. EHS pays a maximum of $5,000.00 for annual waste disposal costs
for research projects.
9. Waste Minimization Training
School policy requires all campus personnel who require chemical procurement
services to receive Waste Generator Training. Annual refresher training is
required to remain eligible. This training identifies the requirements of this Waste
Minimization Plan and includes the strategies and tools available through EHS to
improve waste minimization performance in research and facility maintenance
operations.

Additional training topics include proper chemical storage and spill prevention to
minimize or eliminate potential chemical accidents including spills, fires or
explosions. Labeling requirements are identified to limit the generation of
unknown materials. Waste disposal costs are also identified during this training
class.
10. Safe Research Facilities
Procedures such as using secondary containment, storing chemicals by hazard
class, limiting chemical purchases to only the volume needed for immediate
research needs, and minimizing chemical storage in laboratory spaces all aid in
promoting safety in laboratory settings. These procedures enhance laboratory
safety and limit the volume and toxicity of wastes generated in the case of a
spill, fire or explosion. Additionally, minimizing the amount of chemicals stored in
laboratory spaces decreases the likelihood of chemicals expiring or deteriorating
during storage.
11. Acid Base Neutralization
Using in-process acid or base neutralization as the final step before a waste
product is generated helps reduce hazardous waste volumes and toxicity. If
neutralization is not part of the research process, or is performed separately
from the experiment, it is considered hazardous waste treatment. Waste
treatment cannot be performed without a treatment permit from the CDPHE.
Please contact EHS before initiating in-process neutralization procedures for
additional information.
Green Chemistry Principals
With the implementation of the existing operating procedures, the School has
established an effective and efficient waste minimization program. However, student
enrollment has increased annually since the 2000-2001 academic year, and has
reached it highest level in school history. Additionally, pollution prevention and waste
minimization regulations require generators to evaluate the effectiveness of established


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waste minimization procedures and submit a report of the evaluation with the
generator’s biennial hazardous waste report to the CDPHE. Further improvements to
the overall performance of waste minimization program at Mines will need to include the
use of green chemistry principals.

Green chemistry is the design of chemical products and processes that reduce or
eliminate the use and generation of hazardous substances. Green chemistry relies on a
set of 12 principals that can be used to design or re-design molecules, materials and
chemical transformations to be safer for human health and the environment.

The 12 principals identified by the American Chemical Society (ACS) Green Chemistry
web site include:
1. Prevent waste: Design chemical syntheses to prevent waste, leaving no waste
to treat or clean up.
2. Design safer chemicals and products: Design chemical products to be fully
effective, yet have little or no toxicity.
3. Design less hazardous chemical syntheses: Design syntheses to use and
generate substances with little or no toxicity to humans and the environment.
4. Use renewable feedstocks: Use raw materials and feedstocks that are
renewable rather than depleting. Renewable feedstocks are often made from
agricultural products or are the wastes of other processes; depleting feedstocks
are made from fossil fuels (petroleum, natural gas, or coal) or are mined.
5. Use catalysts, not stoichiometric reagents: Minimize waste by using catalytic
reactions. Catalysts are used in small amounts and can carry out a single
reaction many times. They are preferable to stoichiometric reagents, which are
used in excess and work only once.
6. Avoid chemical derivatives: Avoid using blocking or protecting groups or any
temporary modifications if possible. Derivatives use additional reagents and
generate waste.
7. Maximize atom economy: Design syntheses so that the final product contains
the maximum proportion of the starting materials. There should be few, if any,
wasted atoms.
8. Use safer solvents and reaction conditions: Avoid using solvents, separation
agents, or other auxiliary chemicals. If these chemicals are necessary, use
innocuous chemicals.
9. Increase energy efficiency: Run chemical reactions at ambient temperature
and pressure whenever possible.
10. Design chemicals and products to degrade after use: Design chemical
products to break down to innocuous substances after use so that they do not
accumulate in the environment.
11. Analyze in real time to prevent pollution: Include in-process real-time
monitoring and control during syntheses to minimize or eliminate the formation
of byproducts.
12. Minimize the potential for accidents: Design chemicals and their forms (solid,
liquid, or gas) to minimize the potential for chemical accidents including
explosions, fires, and releases to the environment.


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Several of these green chemistry principals are already in use through the
implemenetation of the standard operating procedures that were previously identified in
this plan.

The Chemistry and Geochemistry Department has implemented green chemistry
principals into teaching and research activities. The Chemistry and Geochemistry
Department web page identifies a clear mission statement and identifies active research
projects utilizing green chemistry principals.

In order to promote and implement green chemistry principals into teaching and
research activities, EHS will take the following steps:

Identify the advantages of green chemistry principals during Waste
Generator Training classes;

Advance green chemistry initiatives by funding Safety and Environmental
Related Minor Capitol Improvement (SERMCI) proposals intended to
implement green chemistry principals.

Promote green chemistry programs through the EHS web page and
chemical procurement program.
Program Assessment

An assessment of the waste minimization program should be made on an annual basis.
Often this assessment can be used to update waste generator training programs so
current waste volumes are passed on to campus personnel. A waste minimization
assessment must be reported to the CDPHE with a biennial hazardous waste report.

A summary of the volumes of waste generated in past years is included with this Plan in
Appendix A. In order to accurately assess waste minimization efforts, total student
population as well as the amount of research activities conducted on campus must be
considered.


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Appendix A – (2012 Revision)

Waste Volume Summary
2004- 2010












Colorado School of Mines
Waste Volumes 2004-2008
12,000
11,000
10,000
9,000
s 8,000
mragol 7,000
iK ni e 6,000
muloV 5,000
etsaW 4,000
3,000
2,000
1,000
0
2004
2005
2006
2007
2008
Year
Corrosive Liquid Waste
Flammable Liquid Waste
Lab Solids
ESE TCE
Mercury Waste
Lab Packs
Chemistry Copper Waste


CSM Hazardous Waste Generation Rate
4500
4000

3500

s 3000
margoli 2500
Kn ithgi 2000
eW
1500
1000
500
0
2005
2006
2007
2008
2009
Year
Corrosive
Flammable
Expired Lab Chemicals
Contaminated Lab Solids
Mercury Waste
ESE TCE
Freshman Quant Lab Copper