The characteristic of ignitability carries the waste number D001. Wastes that are regulated as a hazardous waste due to the characteristic of ignitability include:

• Liquids with a flash point less than 140 F
• Solids that are capable (under standard temperature and pressure) of causing fire through friction, absorption of moisture, or spontaneous chemical change, and when ignited burns so vigorously and persistently that it creates a hazard
• Compressed gases that are ignitable as defined by the Department of Transportation (DOT).
• An oxidizer as defined by the DOT

The characteristic of corrosivity carries the waste number D002. Wastes that are regulated as a hazardous waste due to the characteristic of corrosivity include:

• Aqueous solutions with a pH of 2 or less (acids)
• Aqueous solutions with a pH of 12.5 or greater (bases)
• Liquids that corrode carbon steel

The characteristic of reactivity carries the waste number D003. Wastes that are regulated as a hazardous waste due to the characteristic of reactivity include:

• A material that is normally unstable and readily undergoes violent change without detonating
• A material that reacts violently with water
• A material that forms potentially explosive mixtures with water
• A material that when mixed with water, it generates toxic gases
• Certain cyanide or sulfide bearing materials
• A material that is capable of detonation or explosion, or other DOT regulated explosives

Below are the elements/compounds that are currently regulated as hazardous wastes when present in a waste at or above the concentration listed.

Under the 1994 Nevada Division of Environmental Protection Used Oil Regulations, generators of used oil are required to provide for on-site management and record keeping in addition to those requirements currently enforced. Also in the regulations are additional requirements for bulking and blending facilities used by those transporting used oil. Most of the federal used oil management regulations as listed in 40 CFR 279, are incorporated into the Nevada regulations for used oil. However, the state of Nevada more stringently regulates mixing wastes and materials with used oil. Nevada regulations can be found in Chapter 444 of the Nevada Administrative Code. Used oil is any oil refined from crude oil or synthetic oil, that has been used and, as a result of the use, is physically or chemically contaminated. Used oil, if generated in the state of Nevada, is not considered a hazardous waste if it is collected to be recycled or burned for energy recovery.

Used oil is jointly managed by the UNLV Motor Pool and Environmental Health and Safety. If you generate a waste oil, contact RMS to arrange for characterization and proper disposal or recycling.

Managing Used Oil

Departments on the university campus that generate used oil, such as the motor pool, must collect and appropriately store the oil. Any laboratories using vacuum pumps also generate used oil. Storage of used oil includes tanks or containers which are in good condition (e.g., without leakage, rust, dents or other structural defects). Included on these storage facilities should be the words, "Used Oil." Weekly inspections should be performed and documented, indicating the relative condition of the containers as well as the general area of storage.

Mixing Provisions

Newly adopted Nevada regulations allow for the mixing of specific non-hazardous materials with used oil. Waste gasoline may be mixed with used oil, provided the resultant mixture does not exhibit any of the following characteristics of a hazardous waste: ignitability, reactivity, corrosivity, or toxicity. Waste diesel fuel as well as non-waste diesel fuel may also be mixed with used oil.

Other mixtures with used oil not allowed under the used oil regulations must be managed as a hazardous waste. However, this is not the case if the resultant mixture is shown to be non-hazardous, recycled, or burned for energy recovery. It is very important to consult with the company handling the waste oil mixture to ensure that they can accept and properly manage it.

Non-hazardous wastes mixed with used oil is allowed provided there is sufficient documentation which is to remain on-site and available for at least three years from the date of mixing.

Managing Used Oil Spills

Isolated spills of used oil may be controlled with sorbent material such as kitty litter, vermiculite, or any synthetic adsorbent provided the mixture of used oil and sorbent does not contain any free liquid. This mixture may then be disposed of as a solid waste if no free liquid remains.

Used Oil Filters

Terne is an alloy of tin and lead and functions as a plating for some oil filters. Terne filters are used in buses, heavy duty construction vehicles, and tractor-trailers. Because of the lead concentration in terne-plated filters, these filters must be managed as a hazardous waste. However, for such vehicles as automobiles, vans, and light duty trucks non-terne oil filters are used.

Under EPA's final rule, effective June 19, 1992, non-terne plated used oil filters are exempt from hazardous waste regulation if the oil filters have been gravity hot-drained. The EPA recommends a hot-drain time of 12 hours and defines hot-drained as drained near engine operating temperature and above 60 degrees Fahrenheit. The following methods are acceptable for exemption from hazardous waste regulations:

• Puncturing the filter anti-drain back valve or the filter dome end and hot-draining
• Hot-draining and crushing
• Dismantling and hot-draining
• Any other equivalent hot-draining method which will remove used oil

No determination has yet been made regarding fuel filters, transmission oil filters or specialty filters.

Antifreeze is generated mostly in part from motor vehicle maintenance performed on campus. If the antifreeze is recycled, no waste determination is necessary, but the documentation of the recycling (receipt or bill of lading) must be kept on file.

Cloth wipers and rags are widely used for cleaning applications in several departments on the university campus such as art, publications, engineering, physics, and the motor pool. The wipers and rags generated in these departments are contaminated with solvents, inks, oil, or grease and must be managed appropriately.

Federal hazardous waste regulations as listed in 40 CFR, Section 262.11, requires that generators of theses contaminated wipers and rags determine prior to disposal, whether a hazardous or non-hazardous waste has been generated. If these wipers and rags are not laundered for reuse, several criteria apply to determine if it is a hazardous waste. Several cleaning solvents are listed in the Code of Federal Regulations as hazardous wastes. These solvents have waste number's F001, F002, F003, F005 and include tetrachloroethylene, methylene chloride, 1,1,1-trichloroethane, xylene, acetone, toluene and methyl ethyl ketone. Also, if any of the listed solvents or solvent mixtures constitute 10% of the total, the wipers and rags are managed as a hazardous waste due to the level of toxicity as well as the potential for ignitability through friction or spontaneous chemical changes.

Contamination with other substances such as heavy metals, other organics, and pesticides are also possible during use and may render the wipers and rags a hazardous waste. Heavy metals include cadmium, chromium, barium, lead, mercury, or silver. Determination of whether or not these wipers and rags are hazardous or non-hazardous may be needed if any of these contaminants are expected.

Once wipers and rags are determined to be a hazardous waste, they need to be regulated as such. Requirements for regulation include a closed container, label describing the contents, and accumulation time requirements.

Wipers and rags which are laundered for reuse, are not considered a hazardous waste and are not regulated by the Nevada Division of Environmental Protection. However, the following guidelines must be followed for this exemption:

• Contaminated cloth wipers and rags must be free of any liquid which can be removed by wringing or dripping
• Contaminated cloth wipers and rags must be stored in sealed containers at all times during on-site storage, transportation to a laundering facility, and storage prior to treatment at a laundering facility

Possible options to consider when using wipers and rags are to change to paper wipes in order to reduce quantity and management costs and to use alternative non-hazardous solvents and materials to reduce the generation of hazardous wipers and rags. A list of alternative chemicals is available from the Business Environmental Program.

Fluorescent lamps and High Intensity Discharge lamps (HID's) are used as a lighting source throughout the UNLV campus. Under federal and state regulations, a business is responsible for determining whether each waste generated is hazardous or non-hazardous; typically fluorescent lamps and HID's contain some mercury vapor, which may cause the lamp to be a hazardous waste when no longer useful. The Nevada Division of Environmental Protection considers a combined total of 25 or fewer spent fluorescent lamps or HID's per month to be a de minimis rate.

UNLV RMS has begun characterization of the lamps generated on campus. If you require this information, please contact the Hazardous Materials Safety Office at 702-895-2929.

Light ballasts are found in the fluorescent lamp housings, and are located in almost every office or room on campus. Ballasts sometimes fail and need to be removed, or other times they are replaced with a more energy-efficient light fixture. Either way, it is very important to manage waste light ballasts correctly. Older light ballasts contain Poly Chlorinated Biphenyls (PCB's) which are strictly regulated. All non-PCB ballasts are labeled by the manufacturer as either "Non-PCB" or "No-PCB." If a ballast does not state that it does not contain PCB's it is assumed that it does. Light ballasts can be divided into four groups:

• Non-Leaking Non-PCB: these can be placed into the normal trash
• Leaking Non-PCB: these must be managed as an industrial waste - place into a labeled shipping container
• Non-Leaking PCB: these can be placed into the normal trash or managed as an industrial waste - place into a labeled shipping container
• Leaking PCB: these must be managed as an industrial waste - place into a labeled shipping container

Many UNLV departments use aerosol cans during normal business. Cleaning, painting, and printing tend to generate spent aerosol cans. A can that is empty (all product has been used for its intended purpose and the pressure in the can is reaching atmospheric pressure) may be disposed of as a non-hazardous waste.

Occasionally, an aerosol can become plugged or the material is no longer useable. Federal and state regulations require that these aerosol cans be managed differently than empty cans. The cans may be a hazardous waste due to the pressure contained in the can or the contents may pose a hazard.

Most aerosol cans can be safely and properly emptied with an aerosol can puncturing and emptying device. This service is free of charge. If you have any aerosol cans, contact RMS at 702-895-4226 to arrange for disposal and/or recycling.

Batteries are generated in almost all areas of the university. There are four different types of spent batteries generated: