Hazardous Construction and Demolition Waste
Hazardous Materials in Construction and Demolition waste must be properly managed to avoid fines or environmental liability. Proper management includes identification, accumulation, and disposal. Identification and accumulation prior to disposal is the responsibility of the contractor or department performing the work however the liability for not doing this properly is shared by the University. Therefore all project managers should be thoroughly aware of the following requirements. All disposal shall be through, coordinated by, or approved by Environmental Health and Safety.
Hazardous waste from construction projects is to be paid for by the University of Florida from construction funds. The contractor will make arrangements for the waste to be picked up or delivered to the Waste Management Facility, Surge Area. The building and project number should be clearly identified on the Chemical Waste Pickup Request form. EH&S will send a bill to the UF Project Manager. If the terms of the contract indicate that the contractor is ultimately responsible for the cost of disposal of hazardous materials in construction debris, these costs may be billed to the contractor by the UF Project Manager or deducted from payments. As a hazardous waste facility, regulations prevent UF EH&S from working as a subcontractor, which would be the case of UF accepted waste from contractors and charged the contractor a fee for such services.
All contractors who will handle or accumulate hazardous materials shall be able to document that their staff has had appropriate training to identify, manage, and safely handle the hazardous materials.
Typical Waste Streams
An updated asbestos survey of any building or section of a building that is scheduled for renovation or demolition shall be conducted to identify both friable and non-friable asbestos containing materials. A draft copy of the survey must be reviewed by the University Asbestos Coordinator for completeness prior to accepting the final product. A copy of the updated survey must be kept on site until the renovation or demolition activities are completed.
The survey shall be conducted prior to the start of renovation or demolition under the supervision of a Florida-licensed asbestos consultant. Individuals performing asbestos surveys must be certified as EPA asbestos inspectors through a Florida-approved training provider.
A lead paint survey must be provided for any building constructed prior to 1980 and for any exterior structure (i.e. painted handrails) that may be affected by a construction project, regardless of age. Materials identified as having lead paint must be further characterized to determine if they are subject to hazardous waste disposal restrictions.
Lead survey information must be provided to the contractor and the contractor must comply with applicable training requirements as required by OSHA and the EPA.
Samples of caulking in buildings constructed prior to 1978 must be analyzed for the presence of polychlorinated biphenyls (PCB) if the material will be impacted by renovation or demolition activities. Caulking containing concentrations of PCBs equal to or greater than 50 ppm shall be handled and disposed of as hazardous waste.
All ballasts (PCB and non PCB) must be collected for disposal, containers for ballast disposal can be obtained by contacting EHS Hazardous Materials Management. Barrels must be labeled and closed during accumulation. 55 gallon barrels should not be filled more than half way due to the weight. PCB ballasts must be segregated from non PCB ballasts.
Lamps and HID Light Bulbs
Fluorescent and high-intensity discharge (HID) bulbs must be handled by EH&S HMM. Other specialty bulbs which also may contain mercury must be handled by EH&S as well. All spent lamps, or the container which they are in, must be labeled clearly using the following phrases: “Universal Waste—Lamp(s),” or “Waste Lamp(s),” or “Used Lamp(s)”. Lamp boxes are available through EH&S at no cost. Protect lamps from breaking and the containers from moisture.
Mercury switches – Mercury Containing Equipment
There are many types of equipment that contain elemental mercury. Before disposing of any of these types of equipment, you should verify that they do not contain mercury. Mercury containing devices should be handled with caution to prevent spillage. Devices should be handled intact, sealed, and packaged to prevent breakage. All used mercury containing equipment must be labeled clearly as “Universal Waste—Mercury Containing Equipment,” “Waste Mercury-Containing Equipment,” or “Used Mercury-Containing Equipment.”
- Heating and air conditioning thermostats
- Tilt switches used in silent light switches,
- Pressure gauges, displacement/plunger relays
- Flow meters
- Float switches
- Drain traps in old buildings
Storage batteries and other batteries which contain hazardous metals such as mercury, lead, silver and cadmium must be handled by EH&S. All used batteries must be clearly labeled using the following phrases: “Universal Waste — Battery(ies)”, “Waste Battery(ies)” or “Used Battery(ies)” during accumulation. Bagging small batteries in non conductive material will help prevent fires.
Disposal of hazardous chemicals must be coordinated with EHS. Never dispose of chemicals onto the ground, into water bodies, or the stormwater system.
Disposal of electronic waste should be coordinated with Assett Management.
Ionizing Smoke Detectors
Ionizing type smoke detectors contain an ionizing radiation source, typically the isotope Americium 241 (241Am). These must be collected and disposed of through EH&S. It is critical that the entire smoke detector unit is collected as some designs use multiple radioactive sources located in different parts of the unit. Ionizing smoke detectors are marked with the isotope and the amount of activity present. If you have questions about identifying and or disposing of smoke detectors contact Chemical and Radioactive Waste Disposal at 352-392-8400.
Storm Water Protection/Illicit Discharge Prevention
Under its NPDES Phase II Municipal Separate Storm Sewer System (MS4) permit, the University of Florida is required to protect storm water by informing businesses operating on campus of the hazards associated with illicit discharges and improper disposal of waste. Illicit discharges to UF’s storm sewer system are carried to Lake Alice and other local waterbodies where they will adversely impact water quality and the aquatic environment.
Illicit discharges are prohibited under the UF Policy to Prohibit Illicit Storm Water Discharge. Businesses (vendors or contractors) operating on campus on a regular or temporary basis are subject to any and all consequences listed in this policy up to and including trespass from campus, contract termination and civil or criminal prosecution for violation of UF policy or state and federal regulation.
Any discharge of materials or waste other than rainwater to the University of Florida storm sewer system is considered an illicit discharge. Illicit discharges may occur intentionally or by failure to prevent discharge or release of materials used or generated on campus by the business or its employees.
Common materials prohibited from entering the storm water system include but are not limited to the following:
- Hazardous Materials/Waste
- Paint or paint washings or waste
- Food Service/Cooking Oil Waste
- Vehicle/equipment/building wash effluent
- Leaks/discharges from vehicles/equipment
Reporting Spills to the Storm Water System
Upon discovery, any illicit discharge to the UF storm sewer system must be reported immediately to UF Environmental Health and Safety (352)-392-8400 during normal work hours or to University Police Department (352) 392-1111 after normal work hours.
POLICY: UF Physical Plant provides a Utilities Policy document that contains the UF Policy to Prohibit Illicit Storm Water Discharge (found at the end of the document).
PROJECT MANAGEMENT: The UF Design & Construction Standards document provides storm water guidance for construction projects in paragraphs 1.2F and 1.6B of the General Requirements section, and Appendix C Storm Water Management .
EDUCATION RESOURCES: The UF Clean Water Campaign webpage links to topics such as water quality monitoring, pollution source information, and best management practices for protecting water resources.
Waste labels are available at no cost from Hazardous Materials Management
- Matt Doty
Assistance for all waste streams (except asbestos and lead)
- Matt Doty
Assistance for asbestos and lead waste streams
- Tom Ladun