ÈÕº«ÎÞÂë

The Resource Conservation and Recovery Act allows large quantity generators of hazardous waste such as ÈÕº«ÎÞÂë to store hazardous wastes no longer than 90 days under specific conditions, unless specially permitted for longer term storage. In 1988, the University received a Notice of Violation from the Vermont Department of Environmental Conservation for infractions of these conditions. This violation resulted from a change in EPA regulations that made it impossible to ship the waste to its intended disposal facility on the day planned.

After evaluating its current and long-term hazardous waste needs, the University determined that a facility which would provide space for the management and storage of chemical waste beyond 90 days was needed. The Risk Management staff planned the building's functions and applied for permits from the state and city governments and the Architectural and Engineering Services worked on the facility design. After months of planning and writing, the University was granted a "Part B" facility permit from the Vermont Department of Environmental Conservation. The money to build the facility was appropriated by the legislature in 1992 and construction occurred through the 1993 construction season. The Part B permit has been renewed twice, most recently in July 2005.

The ESF is engineered to provide the largest amount of safe chemical storage possible. It includes the following features:

• separate storage for solvents, corrosives, toxics, reactives and explosives
• continuous 100% fresh air ventilation of all storage areas
• containment sumps and dikes to contain all chemicals within the storage room in case of a fire, leak or spill
• fire detection system throughout the building
• sprinklers throughout the building
• leak detection systems in all storage areas
• external access to all storage rooms

In addition, extensive written waste handling, training and management procedures are required by the building's operating permit.

The most important reason for building the ESF is to enable ÈÕº«ÎÞÂë to start managing its hazardous waste, rather than relying on outside contractors to provide that service at a high cost. Hazardous waste disposal costs went from about $25,000 in 1988 to $200,000 last year. The primary reason for the high waste disposal costs is that most of ÈÕº«ÎÞÂë's hazardous waste is currently packaged and transported off-site in containers called labpacks. A labpack is a waste drum filled with laboratory chemicals in individual containers packaged with sufficient absorbent material to absorb any liquid released from broken or leaking internal containers. A 55-gallon labpack drum contains approximately 15 gallons of chemical waste. The ESF design includes a pouring station which will allow facility staff to consolidate a significant amount of ÈÕº«ÎÞÂë's wastes into bulk drums, creating considerable cost savings. In addition, ÈÕº«ÎÞÂë staff will be able to do the laboratory-packing rather than paying disposal company chemists to do it.

In addition, in 1991 the Vermont Legislature passed Act 100 - Vermont's Waste Minimization and Toxic Use Reduction Law - which requires large quantity generators of hazardous wastes, including ÈÕº«ÎÞÂë, to develop a plan to reduce the generation of hazardous wastes and the use of hazardous materials wherever feasible. As research activity on campus has increased, the amount of hazardous materials used and the amount of hazardous waste generated has increased, making it difficult for ÈÕº«ÎÞÂë to show compliance with this law. Now the ESF staff will also be able to improve waste minimization strategies, such as recycling and treatment of some hazardous wastes to render them nonhazardous or less hazardous. These strategies are the hazardous waste minimization techniques for complying with pollution prevention requirements that have been shown to be useful in other university settings. The ESF will provide the means to collect and redistribute some of the chemicals which are now disposed of as waste. Currently about 40% of the chemical waste disposed of is unused excess or outdated chemicals.

In addition to improved hazardous waste handling, building the ESF will result in other improvements to the chemical safety services the Risk Management Department provides.

Chemical Distribution:

The ESF has been designed to serve as a chemical distribution center for new and recycled chemicals. We expect to provide chemicals to campus in quantities that are closer to those actually needed by laboratories rather than those most conveniently available from chemical suppliers. We hope that campus laboratories will take advantage of the ESF to avoid long-term storage of chemicals in laboratories. This will free laboratory space for other uses and lessen requirements for regulatory compliance on campus.

Safety training:

The ESF will provide an improved location for safety training sessions. The ESF's laboratory area can be set up to provide a training site for the use of various laboratory equipment, such as fume hoods, safety showers and spill kits.

Emergency response:

Because the ESF has a Part B permit, its staff are required to be trained to respond to hazardous materials emergencies and to be available 24 hours to respond to alarms from the facility. This emergency response service will be extended to include the rest of campus. The current ESF staff has completed 40 hours of emergency response training, the highest level required by OSHA for emergency response workers.