April 27, 2005

MEMORANDUM	

TO:		Patricia Mercer, EPA

FROM:	Maribelle Rodríguez, Mike Hartley, and Earl Harris

SUBJECT:	College and University Large Quantity Generators in 2001; 

Work Assignment Number 3-33, Contract Number 68-W-02-006

Under the referenced work assignment, ICF identified college and
university (C/U) large quantity generators (LQGs) in 2001 and estimated
the quantity of hazardous waste generated by these sites.  Section 1 of
this memorandum describes the methodology used to identify and collect
data on C/U LQGs.  Section 2 summarizes information on the number of C/U
LQGs and the quantity of hazardous waste generated by these sites.

Please do not hesitate to contact Maribelle at (703) 218-2508 with
questions or comments.

1.	Methodology

To identify C/U LQGs in 2001 and estimate the quantity of hazardous
waste generated by these sites, ICF undertook the following steps:

Step 1:  Identify C/U LQGs in 2001  

To identify C/U LQGs in 2001, ICF referred to the Site Identification
(ID) Forms of the 2001 Biennial Report (BR).  The Site ID Form contains
basic waste handler information (e.g., EPA ID number, site name, Federal
generator status).   

Based on Federal generator status information reported in the Site ID
Forms, we identified all LQGs in 2001.  For these sites, we extracted
the following information from the Site ID Forms and used it to create a
2001 C/U LQG database:

EPA ID number;

Site name;

Address;

EPA Region;

·	Primary North American Industrial Classification System (NAICS) code;


·	Secondary NAICS code(s);

Federal generator status (i.e., LQG); and

·	Indicator of whether the site treats, stores, or disposes of
hazardous waste.

Sites represented by primary NAICS codes 6112 through 6116 were
categorized as four-year, two-year, or vocational schools.  Sites
represented by primary NAICS code 622 were categorized as hospitals. 
Sites represented by any other primary NAICS code were excluded from the
rest of the analysis.

Exhibit 1 provides a description of the NAICS codes used in this
analysis, as well as the corresponding SIC codes.  The exhibit also
indicates how the NAICS codes were used to categorize LQGs by type of
institution.

Exhibit 1

NAICS/SIC Codes and Types of Institution Included in this Analysis

NAICS 

Code	

SIC 

Code(s)	

Industry Sector	

Type of Institution

61131	8221	Colleges, Universities, and Professional Schools	Four-Year
School

61121	8222	Junior Colleges	Two-Year School

6114	8243, 8244, 8299	Business Schools and Computer and Management
Training	Vocational School

611519	8243, 8249, 8299	Other Technical and Trade Schools

	61161	7911, 8299	Fine Arts Schools	

	611699	7999, 8299	All Other Miscellaneous Schools and Instruction

	62211	8062, 8069	General Medical and Surgical Hospitals	Hospital



62231	8069	Specialty (except Psychiatric and Substance Abuse) Hospitals	
	

	

For sites categorized as four-year, two-year, or vocational schools, ICF
reviewed the list of site names to identify C/Us that have an art
program and/or a medical school.  In conducting this review, ICF
referred to the following two references:

The Art School and Program Directory, which was developed by
ArtSchools.com; and 

List of Medical Schools of the U.S. and Canada, which was developed by
the Association of American Medical Colleges. 

For sites categorized as hospitals, ICF reviewed the list of site names
to identify hospitals affiliated with a C/U.  If a hospital is
affiliated with a C/U (e.g., Howard University Hospital), the site was
considered a C/U LQG.  If a hospital is not affiliated with a C/U (e.g.,
Kaiser Permanente Medical Center), the site was excluded from the rest
of this analysis.  Note that, in determining whether a hospital is
affiliated with a C/U, we referred to List of Medical Schools of the
U.S. and Canada, which was developed by the Association of American
Medical Colleges.  If this reference did not address our need, we made a
determination based on information obtained through minimal research
(i.e., a simple Web search) or used our own judgment. 

Step 2:  Compile Information on Hazardous Waste Generated by C/U LQGs in
2001 

Once the C/U LQGs were identified, ICF compiled waste stream data
reported in Generation and Management (GM) Forms of the 2001 BR.  The GM
Form includes information on hazardous waste streams generated and
managed on site or sent off site for management.

For each hazardous waste stream generated by a C/U LQG, we compiled the
following information:

Quantity of waste generated;

Form code;

Source code;

RCRA radioactive mixed; 

EPA hazardous waste codes representing the hazardous waste;

Waste type;

Waste description;

Indicator of whether the waste is a laboratory waste;

EPA ID of the facility managing the waste stream;

Name of the facility managing the waste stream;

Code of management method used; and

Quantity of waste managed using management method code.

The above data were included in the 2001 C/U LQG database developed
under Step 1.  

Waste types were assigned to each waste stream based on the EPA
hazardous waste codes representing it.  For information on the waste
stream classification scheme used in this analysis, refer to Attachment
A.

ICF notes that, for purposes of this analysis, a waste was considered a
laboratory waste if the BR waste description contained the word
“lab.”

Step 3: Eliminate Remediation Waste Streams from the 2001 C/U LQG
Database

After compiling the waste stream information, ICF identified and
eliminated remediation waste streams from the 2001 C/U LQG database. 
For purposes of this analysis, a waste was considered a remediation
waste if it was represented by the BR source code G41-G49, or the BR
waste description contained the word “remediation.”

Step 4:  Estimate Quantity of Hazardous Waste Generated by C/U LQGs in
2001 

To estimate the total quantity of hazardous waste generated by C/U LQGs
in 2001, ICF added up the quantity of hazardous waste generated by each
of these sites in 2001. 

2.	Data Summaries

Exhibit 2 shows the number of C/U LQGs and the quantity of hazardous
waste generated by these LQGs in 2001, by type of institution (e.g.,
four-year school), industry sector, and waste type.  It also shows the
total number of LQGs (i.e., 365) and the quantity of hazardous waste
generated by these LQGs in 2001 (i.e., 34,563 tons).

Exhibit 3 shows the number of C/U LQGs that generated laboratory waste
in 2001 and the quantity of laboratory waste generated by these LQGs, by
type of institution, industry sector, and waste type.  It also shows the
total number of LQGs (i.e., 266) and the quantity of laboratory waste
generated by these LQGs in 2001 (i.e., 3,109 tons).  ICF notes that, for
purposes of this analysis, a waste was considered a laboratory waste if
the BR waste description contained the word “lab.”

Exhibit 4 shows the number of LQGs at C/Us with art programs and the
quantity of hazardous waste generated by these LQGs in 2001, by type of
institution, industry sector, and waste type.  It also shows the total
number of LQGs (i.e., 239) and the quantity of hazardous waste generated
by these LQGs in 2001 (i.e., 7,167 tons).  ICF notes that the BR does
not contain a data element that indicates positively whether a hazardous
waste stream was generated as a result of art-related activities.  Thus,
the exhibit shows data for all hazardous waste generated by LQGs at C/Us
with art programs.  The reader should not assume, however, that all of
this waste quantity is related to art activities.  In fact, some
percentage of this waste might come from LQGs within the art programs. 

Exhibit 5 shows the number of LQGs at C/Us with medical schools and the
quantity of hazardous waste generated by these LQGs in 2001, by type of
institution, industry sector, and waste type.  It also shows the total
number of LQGs (i.e., 66) and the quantity of hazardous waste generated
by these LQGs in 2001 (i.e., 1,475 tons).  ICF notes that the BR does
not contain a data element that indicates positively whether a hazardous
waste stream was generated as a result of medical school activities. 
Thus, the exhibit shows data for LQGs whose site names refer to a
medical school or to a hospital affiliated with a C/U (i.e., a
university hospital).

Exhibit 2

Number of C/U LQGs and Quantity of Hazardous Waste Generated by These
LQGs in 2001,

by Type of Institution, Industry Sector and Waste Type a

Industry Sector	NAICS

Code	SIC

Code	Waste Type	Number of LQGs 	Gen Tons	% of Total Gen Tons c

4-Year Schools

Colleges, Universities, and Professional Schools	61131	8221	Dioxin
pesticide wastes	27	2.30	0.01%

Colleges, Universities, and Professional Schools	61131	8221	Heavy metal
and cyanide wastes	1	3.49	0.01%

Colleges, Universities, and Professional Schools	61131	8221	Ignitable,
corrosive, and/or reactive characteristic wastes	249	925.44	2.68%

Colleges, Universities, and Professional Schools	61131	8221	Inorganic
(metal) wastes	268	3,157.27	9.13%

Colleges, Universities, and Professional Schools	61131	8221	Lab packs
130	758.54	2.19%

Colleges, Universities, and Professional Schools	61131	8221	Listed
discarded chemical products (i.e., 'P' and/or 'U' code wastes)	206
216.95	0.63%

Colleges, Universities, and Professional Schools	61131	8221	Mixture of
hazardous wastes from non-specific sources (i.e., mixture of 'F' code
wastes)	7	23.87	0.07%

Colleges, Universities, and Professional Schools	61131	8221	Mixture of
toxic characteristic wastes (i.e., mixture of 'D' code wastes)	61	168.24
0.49%

Colleges, Universities, and Professional Schools	61131	8221	Organic
wastes	112	220.55	0.64%

Colleges, Universities, and Professional Schools	61131	8221	Pesticide
wastes	17	5.99	0.02%

Colleges, Universities, and Professional Schools	61131	8221	Spent
solvents	239	2,982.97	8.63%

Colleges, Universities, and Professional Schools	61131	8221	Unknown	34
159.19	0.46%

Subtotal	314 b	8,625	24.95%

2-Year Schools

Junior Colleges	61121	8222	Ignitable, corrosive, and/or reactive
characteristic wastes	8	8.39	0.02%

Junior Colleges	61121	8222	Inorganic (metal) wastes	8	28.72	0.08%

Junior Colleges	61121	8222	Lab packs	3	4.75	0.01%

Junior Colleges	61121	8222	Listed discarded chemical products (i.e., 'P'
and/or 'U' code wastes)	8	4.53	0.01%

Junior Colleges	61121	8222	Mixture of toxic characteristic wastes (i.e.,
mixture of 'D' code wastes)	2	4.13	0.01%

Junior Colleges	61121	8222	Organic wastes	8	9.28	0.03%

Junior Colleges	61121	8222	Spent solvents	7	22.73	0.07%

Subtotal	13 b	83	0.24%

Vocational Schools

All Other Miscellaneous Schools and Instruction	611699	7999, 8299
Ignitable, corrosive, and/or reactive characteristic wastes	1	0.08	0.00%

All Other Miscellaneous Schools and Instruction	611699	7999, 8299
Inorganic (metal) wastes	1	25,016.09	72.38%

All Other Miscellaneous Schools and Instruction	611699	7999, 8299	Listed
discarded chemical products (i.e., 'P' and/or 'U' code wastes)	1	0.08
0.00%

All Other Miscellaneous Schools and Instruction	611699	7999, 8299
Organic wastes	1	0.65	0.00%

All Other Miscellaneous Schools and Instruction	611699	7999, 8299	Spent
solvents	1	0.87	0.00%

Fine Arts Schools	61161	7911, 8299	Ignitable, corrosive, and/or reactive
characteristic wastes	2	1.28	0.00%

Fine Arts Schools	61161	7911, 8299	Inorganic (metal) wastes	2	11.06
0.03%

Fine Arts Schools	61161	7911, 8299	Listed discarded chemical products
(i.e., 'P' and/or 'U' code wastes)	2	2.43	0.01%

Fine Arts Schools	61161	7911, 8299	Mixture of toxic characteristic
wastes (i.e., mixture of 'D' code wastes)	1	0.81	0.00%

Fine Arts Schools	61161	7911, 8299	Organic wastes	2	3.20	0.01%

Fine Arts Schools	61161	7911, 8299	Spent solvents	1	1.09	0.00%

Fine Arts Schools	61161	7911, 8299	Unknown	1	1.20	0.00%

Other Technical and Trade Schools	611519	8243, 8249, 8299	Ignitable,
corrosive, and/or reactive characteristic wastes	1	9.99	0.03%

Other Technical and Trade Schools	611519	8243, 8249, 8299	Inorganic
(metal) wastes	2	32.21	0.09%

Other Technical and Trade Schools	611519	8243, 8249, 8299	Spent solvents
1	0.15	0.00%

Subtotal	6 b	25,081	72.57%

University Hospitals

General Medical and Surgical Hospitals	62211	8062, 8069	Ignitable,
corrosive, and/or reactive characteristic wastes	20	41.71	0.12%

General Medical and Surgical Hospitals	62211	8062, 8069	Inorganic
(metal) wastes	27	278.42	0.81%

General Medical and Surgical Hospitals	62211	8062, 8069	Lab packs	10
74.98	0.22%

General Medical and Surgical Hospitals	62211	8062, 8069	Listed discarded
chemical products (i.e., 'P' and/or 'U' code wastes)	21	22.15	0.06%

General Medical and Surgical Hospitals	62211	8062, 8069	Mixture of toxic
characteristic wastes (i.e., mixture of 'D' code wastes)	4	1.28	0.00%

General Medical and Surgical Hospitals	62211	8062, 8069	Organic wastes	6
1.06	0.00%

General Medical and Surgical Hospitals	62211	8062, 8069	Spent solvents
26	317.06	0.92%

Specialty (except Psychiatric and Substance Abuse) Hospitals	62231	8069
Ignitable, corrosive, and/or reactive characteristic wastes	1	1.89	0.01%

Specialty (except Psychiatric and Substance Abuse) Hospitals	62231	8069
Inorganic (metal) wastes	1	0.30	0.00%

Specialty (except Psychiatric and Substance Abuse) Hospitals	62231	8069
Listed discarded chemical products (i.e., 'P' and/or 'U' code wastes)	1
3.50	0.01%

Specialty (except Psychiatric and Substance Abuse) Hospitals	62231	8069
Spent solvents	1	32.30	0.09%

Subtotal	32 b	775	2.24%

Total	365	34,563	100.00%

a  Exhibit does not include data on remediation wastes.  For purposes of
this analysis, a waste was considered a remediation waste if it was
represented by the Biennial Report source code G41-G49, or the Biennial
Report waste description contained the word “remediation.”

b  An LQG may generate more than one type of waste.  Thus, the number of
LQGs is not additive.

c  Based on total quantity of waste generated by C/U LQGs in 2001, i.e.,
34,563 tons.

Exhibit 3

Number of C/U LQGs that Generated Laboratory Waste in 2001 and Quantity
of Laboratory Waste Generated

by These LQGs, by Type of Institution, Industry Sector and Waste Type a,
b 

Industry Sector	NAICS

Code	SIC

Code	Waste Type	Number of LQGs 	Gen Tons	% of Total Gen Tons d

4-Year Schools

Colleges, Universities, and Professional Schools	61131	8221	Dioxin
pesticide wastes	10	1.70	0.00%

Colleges, Universities, and Professional Schools	61131	8221	Ignitable,
corrosive, and/or reactive characteristic wastes	107	244.60	0.71%

Colleges, Universities, and Professional Schools	61131	8221	Inorganic
(metal) wastes	112	328.65	0.95%

Colleges, Universities, and Professional Schools	61131	8221	Lab packs
114	653.99	1.89%

Colleges, Universities, and Professional Schools	61131	8221	Listed
discarded chemical products (i.e., 'P' and/or 'U' code wastes)	120
121.05	0.35%

Colleges, Universities, and Professional Schools	61131	8221	Mixture of
hazardous wastes from non-specific sources (i.e., mixture of 'F' code
wastes)	5	14.10	0.04%

Colleges, Universities, and Professional Schools	61131	8221	Mixture of
toxic characteristic wastes (i.e., mixture of 'D' code wastes)	28	45.18
0.13%

Colleges, Universities, and Professional Schools	61131	8221	Organic
wastes	26	22.82	0.07%

Colleges, Universities, and Professional Schools	61131	8221	Pesticide
wastes	5	0.51	0.00%

Colleges, Universities, and Professional Schools	61131	8221	Spent
solvents	137	1,484.21	4.29%

Colleges, Universities, and Professional Schools	61131	8221	Unknown	4
2.98	0.01%

Subtotal	235 c	2,920	8.45%

2-Year Schools

Junior Colleges	61121	8222	Ignitable, corrosive, and/or reactive
characteristic wastes	3	1.60	0.00%

Junior Colleges	61121	8222	Inorganic (metal) wastes	3	0.18	0.00%

Junior Colleges	61121	8222	Lab packs	3	4.68	0.01%

Junior Colleges	61121	8222	Listed discarded chemical products (i.e., 'P'
and/or 'U' code wastes)	5	2.12	0.01%

Junior Colleges	61121	8222	Spent solvents	4	6.48	0.02%

Subtotal	8 c	15	0.04%

Vocational Schools

All Other Miscellaneous Schools and Instruction	611699	7999, 8299
Ignitable, corrosive, and/or reactive characteristic wastes	1	0.08	0.00%

All Other Miscellaneous Schools and Instruction	611699	7999, 8299
Inorganic (metal) wastes	1	0.09	0.00%

All Other Miscellaneous Schools and Instruction	611699	7999, 8299	Listed
discarded chemical products (i.e., 'P' and/or 'U' code wastes)	1	0.08
0.00%

Fine Arts Schools	61161	7911, 8299	Inorganic (metal) wastes	1	3.58	0.01%

Fine Arts Schools	61161	7911, 8299	Listed discarded chemical products
(i.e., 'P' and/or 'U' code wastes)	2	0.54	0.00%

Subtotal	3 c	4	0.01%

University Hospitals

General Medical and Surgical Hospitals	62211	8062, 8069	Ignitable,
corrosive, and/or reactive characteristic wastes	10	20.94	0.06%

General Medical and Surgical Hospitals	62211	8062, 8069	Inorganic
(metal) wastes	10	2.37	0.01%

General Medical and Surgical Hospitals	62211	8062, 8069	Lab packs	6
27.91	0.08%

General Medical and Surgical Hospitals	62211	8062, 8069	Listed discarded
chemical products (i.e., 'P' and/or 'U' code wastes)	12	8.50	0.02%

General Medical and Surgical Hospitals	62211	8062, 8069	Mixture of toxic
characteristic wastes (i.e., mixture of 'D' code wastes)	2	0.79	0.00%

General Medical and Surgical Hospitals	62211	8062, 8069	Organic wastes	2
0.04	0.00%

General Medical and Surgical Hospitals	62211	8062, 8069	Spent solvents
10	71.84	0.21%

Specialty (except Psychiatric and Substance Abuse) Hospitals	62231	8069
Ignitable, corrosive, and/or reactive characteristic wastes	1	1.69	0.00%

Specialty (except Psychiatric and Substance Abuse) Hospitals	62231	8069
Inorganic (metal) wastes	1	0.22	0.00%

Specialty (except Psychiatric and Substance Abuse) Hospitals	62231	8069
Listed discarded chemical products (i.e., 'P' and/or 'U' code wastes)	1
3.42	0.01%

Specialty (except Psychiatric and Substance Abuse) Hospitals	62231	8069
Spent solvents	1	32.30	0.09%

Subtotal	20 c	170	0.49%

Total	266	3,109	9.00%

a  For purposes of this analysis, a waste was considered a laboratory
waste if the Biennial Report waste description contained the word
“lab.”

b  Exhibit does not include data on remediation wastes.  For purposes of
this analysis, a waste was considered a remediation waste if it was
represented by the Biennial Report source code G41-G49, or the Biennial
Report waste description contained the word “remediation.”

c  An LQG may generate more than one type of waste.  Thus, the number of
LQGs is not additive.

d  Based on total quantity of waste generated by C/U LQGs in 2001, i.e.,
34,563 tons.

Exhibit 4

Number of LQGs at C/Us with Art Programs and Quantity of Hazardous Waste
Generated

by These LQGs in 2001, by Type of Institution, Industry Sector, and
Waste Type a, b 

Industry Sector	NAICS

Code	SIC

Code	Waste Type	Number of LQGs 	Gen Tons	% of Total Gen Tons d

4-Year Schools

Colleges, Universities, and Professional Schools	61131	8221	Dioxin
pesticide wastes	22	1.92	0.01%

Colleges, Universities, and Professional Schools	61131	8221	Heavy metal
and cyanide wastes	1	3.49	0.01%

Colleges, Universities, and Professional Schools	61131	8221	Ignitable,
corrosive, and/or reactive characteristic wastes	190	771.26	2.23%

Colleges, Universities, and Professional Schools	61131	8221	Inorganic
(metal) wastes	200	2,814.82	8.14%

Colleges, Universities, and Professional Schools	61131	8221	Lab packs	99
589.90	1.71%

Colleges, Universities, and Professional Schools	61131	8221	Listed
discarded chemical products (i.e., 'P' and/or 'U' code wastes)	150
181.43	0.52%

Colleges, Universities, and Professional Schools	61131	8221	Mixture of
hazardous wastes from non-specific sources (i.e., mixture of 'F' code
wastes)	7	23.87	0.07%

Colleges, Universities, and Professional Schools	61131	8221	Mixture of
toxic characteristic wastes (i.e., mixture of 'D' code wastes)	44	138.96
0.40%

Colleges, Universities, and Professional Schools	61131	8221	Organic
wastes	73	100.13	0.29%

Colleges, Universities, and Professional Schools	61131	8221	Pesticide
wastes	9	1.37	0.00%

Colleges, Universities, and Professional Schools	61131	8221	Spent
solvents	180	2,370.39	6.86%

Colleges, Universities, and Professional Schools	61131	8221	Unknown	28
129.55	0.37%

Subtotal	235 c	7,127	20.62%

2-Year Schools

Junior Colleges	61121	8222	Ignitable, corrosive, and/or reactive
characteristic wastes	1	0.09	0.00%

Junior Colleges	61121	8222	Inorganic (metal) wastes	2	16.96	0.05%

Junior Colleges	61121	8222	Listed discarded chemical products (i.e., 'P'
and/or 'U' code wastes)	1	1.59	0.00%

Subtotal	2 c	19	0.05%

Vocational Schools

Fine Arts Schools	61161	7911, 8299	Ignitable, corrosive, and/or reactive
characteristic wastes	2	1.28	0.00%

Fine Arts Schools	61161	7911, 8299	Inorganic (metal) wastes	2	11.06
0.03%

Fine Arts Schools	61161	7911, 8299	Listed discarded chemical products
(i.e., 'P' and/or 'U' code wastes)	2	2.43	0.01%

Fine Arts Schools	61161	7911, 8299	Mixture of toxic characteristic
wastes (i.e., mixture of 'D' code wastes)	1	0.81	0.00%

Fine Arts Schools	61161	7911, 8299	Organic wastes	2	3.20	0.01%

Fine Arts Schools	61161	7911, 8299	Spent solvents	1	1.09	0.00%

Fine Arts Schools	61161	7911, 8299	Unknown	1	1.20	0.00%

Subtotal	2 c	21	0.06%

Total	239	7,167	20.74%

a  The Biennial Report does not contain a data element that indicates
positively whether a hazardous waste stream was generated as a result of
art-related activities.  Thus, the exhibit shows data for all hazardous
waste generated by LQGs at C/Us with art programs.  It should not be
assumed, however, that all of this waste quantity is related to art
activities.  In fact, some percentage of this waste might come from LQGs
within the art programs. 

b  Exhibit does not include data on remediation wastes.  For purposes of
this analysis, a waste was considered a remediation waste if it was
represented by the Biennial Report source code G41-G49, or the Biennial
Report waste description contained the word “remediation.”

c  An LQG may generate more than one type of waste.  Thus, the number of
LQGs is not additive.

d  Based on total quantity of waste generated by C/U LQGs in 2001, i.e.,
34,563 tons.

Exhibit 5

Number of LQGs at C/Us with Medical Schools and Quantity of Hazardous
Waste Generated

by These LQGs in 2001, by Type of Institution, Industry Sector and Waste
Type a, b 

Industry Sector	NAICS

Code	SIC

Code	Waste Type	Number of LQGs 	Gen Tons	% of Total Gen Tons d

4-Year Schools

Colleges, Universities, and Professional Schools	61131	8221	Dioxin
pesticide wastes	1	0.25	0.00%

Colleges, Universities, and Professional Schools	61131	8221	Ignitable,
corrosive, and/or reactive characteristic wastes	19	55.52	0.16%

Colleges, Universities, and Professional Schools	61131	8221	Inorganic
(metal) wastes	25	114.99	0.33%

Colleges, Universities, and Professional Schools	61131	8221	Lab packs	13
46.65	0.13%

Colleges, Universities, and Professional Schools	61131	8221	Listed
discarded chemical products (i.e., 'P' and/or 'U' code wastes)	23	34.17
0.10%

Colleges, Universities, and Professional Schools	61131	8221	Mixture of
hazardous wastes from non-specific sources (i.e., mixture of 'F' code
wastes)	1	5.17	0.01%

Colleges, Universities, and Professional Schools	61131	8221	Mixture of
toxic characteristic wastes (i.e., mixture of 'D' code wastes)	5	4.56
0.01%

Colleges, Universities, and Professional Schools	61131	8221	Organic
wastes	8	7.78	0.02%

Colleges, Universities, and Professional Schools	61131	8221	Pesticide
wastes	1	0.06	0.00%

Colleges, Universities, and Professional Schools	61131	8221	Spent
solvents	30	431.15	1.25%

Colleges, Universities, and Professional Schools	61131	8221	Unknown	1
0.32	0.00%

Subtotal	34 c	701	2.03%

University Hospitals

General Medical and Surgical Hospitals	62211	8062, 8069	Ignitable,
corrosive, and/or reactive characteristic wastes	20	41.71	0.12%

General Medical and Surgical Hospitals	62211	8062, 8069	Inorganic
(metal) wastes	27	278.42	0.81%

General Medical and Surgical Hospitals	62211	8062, 8069	Lab packs	10
74.98	0.22%

General Medical and Surgical Hospitals	62211	8062, 8069	Listed discarded
chemical products (i.e., 'P' and/or 'U' code wastes)	21	22.15	0.06%

General Medical and Surgical Hospitals	62211	8062, 8069	Mixture of toxic
characteristic wastes (i.e., mixture of 'D' code wastes)	4	1.28	0.00%

General Medical and Surgical Hospitals	62211	8062, 8069	Organic wastes	6
1.06	0.00%

General Medical and Surgical Hospitals	62211	8062, 8069	Spent solvents
26	317.06	0.92%

Specialty (except Psychiatric and Substance Abuse) Hospitals	62231	8069
Ignitable, corrosive, and/or reactive characteristic wastes	1	1.89	0.01%

Specialty (except Psychiatric and Substance Abuse) Hospitals	62231	8069
Inorganic (metal) wastes	1	0.30	0.00%

Specialty (except Psychiatric and Substance Abuse) Hospitals	62231	8069
Listed discarded chemical products (i.e., 'P' and/or 'U' code wastes)	1
3.50	0.01%

Specialty (except Psychiatric and Substance Abuse) Hospitals	62231	8069
Spent solvents	1	32.30	0.09%

Subtotal	32 c	775	2.24%

Total	66	1,475	4.27%

a  The Biennial Report does not contain a data element that indicates
positively whether a hazardous waste stream was generated as a result of
medical school activities.  Thus, the exhibit shows data for LQGs whose
site names refer to a medical school or to a hospital affiliated with a
C/U (i.e., a university hospital).

b  Exhibit does not include data on remediation wastes.  For purposes of
this analysis, a waste was considered a remediation waste if it was
represented by the Biennial Report source code G41-G49, or the Biennial
Report waste description contained the word “remediation.”

c  An LQG may generate more than one type of waste.  Thus, the number of
LQGs is not additive.

d  Based on total quantity of waste generated by C/U LQGs in 2001, i.e.,
34,563 tons.				 

Attachment A

Waste Stream Classification

Waste Stream Classification

As described in Step 2 of this memorandum, ICF has attempted to describe
the waste streams of C/U LQGs based on their waste codes.  If one waste
code was reported for a given waste stream, ICF relied on that code to
describe the waste (e.g., a waste stream with only a D004 waste code was
described as “inorganic (metal) waste”).

Note that many hazardous waste streams include two or more waste codes. 
For these waste streams, ICF developed a simplifying approach for
describing them.  Specifically, ICF used the classification scheme in
Exhibit A-1 to classify waste codes as either “primary” or
“secondary” codes.  Primary waste codes are codes that, in ICF’s
professional judgment, more accurately describe the type of waste in
comparison with secondary codes.  

ICF used primary codes to describe waste streams with two or more waste
codes.  For example, as shown in the exhibit, a waste stream containing
F001 and D001 waste codes was described in this memorandum as a “spent
solvent.”

 

Exhibit A-1

Waste Stream Classification Scheme

EPA Hazardous Waste Code(s) Representing the Waste Streams



Waste Type



Primary Waste Code(s)	

Secondary Waste Code (s)

	

One or more D001-D003 code	

None	

Ignitable, corrosive, and/or reactive characteristic wastes



One or more D004-D011 code	

None

One or more D001-D003 code	

Inorganic (metal) wastes



One or more D012-D017 code	

None

One or more D001-D003 code	

Pesticide wastes



One or more D018-D043 code	

None

One or more D001-D003 code	

Organic wastes



Any other D mixtures	

None	

Mixture of toxic characteristic wastes (i.e., mixture of “D” code
wastes)



One or more F001-F005 code	

Any P, U, or D codes	

Spent solvents



One or more F006-F012, F019 code	

Any P, U, or D codes	

Heavy metal and cyanide wastes



One or more F020-F028 code	

Any P, U, or D codes	

Dioxin pesticide wastes



One or more F032, F034-F035 code	

Any P, U, or D codes	

Wood preserving wastes



One or more F037-F038 code	

Any P, U, or D codes	

Petroleum refining sludges



F039	

Any other code	

Multi-source leachates



Any other F mixtures	

Any P, U, or D codes	

Mixture of hazardous wastes from non-specific sources (i.e., mixture of
“F” code wastes)



K001	

Any other non-K codes	

Wood preserving wastes



One K002-K008 code	

Any other non-K codes	

Inorganic pigment production wastes



One K009-K011, K013-K030, K083, K085, K093-K096, K103-K105, K107-K118,
K136, K149-K151, K156-K159, K161 code	

Any other non-K codes	

Organic chemical production wastes



One K031-K043, K097-K099, K123-K126, K131-K132 code	

Any other non-K codes	

Pesticide production wastes



One K044-K047 code	

Any other non-K codes	

Explosive manufacturing wastes



One or more K048-K052 code	

Any other non-K codes	

Petroleum refining wastes



One K060, K087, K141-K145, K147-K148 code	

Any other non-K codes	

Coking operation wastes



One K061-K062 code	

Any other non-K codes	

Iron and steel production wastes



K064	

Any other non-K codes	

Primary copper production wastes



K065	

Any other non-K codes	

Primary lead production wastes



K066	

Any other non-K codes	

Primary zinc production wastes



One K069, K100 code	

Any other non-K codes	

Secondary lead smelting wastes



One K071, K073, K106 code	

Any other non-K codes	

Inorganic chemical production wastes



One K084, K101-K102 code	

Any other non-K codes	

Veterinary pharmaceutical production wastes



K086	

Any other non-K codes	

Ink formulation wastes



K088	

Any other non-K codes	

Primary aluminum production wastes



One K090-K091 code	

Any other non-K codes	

Ferroalloy production wastes



Any other K mixtures (i.e., any non K048-K052 code combination)	

Any other non-K codes	

Mixture of hazardous wastes from specific sources (i.e., mixture of
“K” code wastes)



One or more P or U code	

	

Listed discarded chemical products (i.e., “P” and/or “U” code
wastes)



Lab packs with no identified code 

(i.e., “LABP”)	

Any other code	

Lab packs



  SIC codes are not reported in the Site ID Form.  ICF referred to the
U.S. Census Bureau’s 1997 NAICS and 1987 SIC Correspondence Tables
(available at http://www.census.gov) to identify the SIC code(s)
associated with the primary NAICS code reported in the Site ID Forms.

  Available at: http://www.artschools.com/.

  Available at:  http://www.aamc.org/members/listings/msalphaae.htm.

  Available at:  http://www.aamc.org/members/listings/msalphaae.htm.

  Based on technical direction provided by the EPA WAM on February 8,
2005.

  Based on technical direction provided by the EPA WAM on April 26,
2005.

Page  PAGE  2 

Exhibit 2 (continued)

Number of C/U LQGs and Quantity of Hazardous Waste Generated by These
LQGs in 2001,

by Type of Institution, Industry Sector and Waste Type a

Exhibit 4 (continued)

Number of LQGs at C/Us with Art Programs and Quantity of Hazardous Waste
Generated

by These LQGs in 2001, by Type of Institution, Industry Sector, and
Waste Type a, b 

Exhibit 5 (continued)

Number of LQGs at C/Us with Medical Schools and Quantity of Hazardous
Waste Generated

by These LQGs in 2001, by Type of Institution, Industry Sector and Waste
Type a, b 

Exhibit A-1 (continued)

Waste Stream Classification Scheme

Page A- PAGE  1 

