Skip to main content

The New Generator Improvements Rule Implementation

Worker in lab

The Environmental Affairs section had previously analyzed the impending Generator Improvements Rule and how it would affect the University, and formulated teams to work on specific tasks relevant to the changes. The staff determined that our campus would utilize Subpart K rules for our approximately 2,900 main campus academic/teaching areas, UNC Hospital laboratories and various off-site research locations, and utilize the new Generator Improvements Rule for our non-teaching areas on and off-campus. EHS:

  • opted all our research and academic facilities into Subpart K;
  • generated new online waste labels for academic/teaching areas, and labels for non-academic areas that were then pre-approved for our use by DWM;
  • purchased new printers to label containers delivered to non-teaching areas;
  • generated new required online laboratory and non-laboratory training classes;
  • generated a GIS-based quick reference guide using five years of historical waste generation data; and
  • automated new online reports for waste generation that would email principle investigators if they have not submitted waste in a given time frame.

The hard work of the Environmental Affairs staff paid off with a positive EPA Region IV/Division of Waste Management site inspection on the first day of the implementation of the new rules.

Performance measurement is a critical part of the EHS management system. Education, customer service and internal processes are the three most essential components of our work. The chart below indicates the performance in these areas over a five-year period with Level Four representing optimum performance. The adjacent tab shows the specific performance activities and the level of that performance for 2017.

Components, Years and Level Completed
Education Customer Service Internal Processes
2013 2014 2015 2016 2017 2013 2014 2015 2016 2017 2013 2014 2015 2016 2017
4 3 4 3 2 4 4 4 4 4 4 3 2 3 4


  • Trained 1971 employees on Managing Laboratory Generated Hazardous Waste through orientation safety online training.
  • Trained 674 employees on Laboratory Chemical Waste Management through online training.
  • Trained 173 employees on Universal Waste Handling through online training.
  • Trained 435 employees from Facilities Services in stormwater awareness.
  • Trained five Service Station employees, four RDU Airport Medical Air Operations employees and seven EHS employees on stormwater permit requirements and pollution prevention.
  • Participated in a Three Zeros sustainability outreach and education event at the Carolina Student Union.

Customer Service

  • Conducted 11,427 waste pickups of 51,534 kg of hazardous waste and 40,152 kg of non-hazardous solid waste from University generators.
  • Conducted 678 pickups of radioactive waste and shipped 139.6624 mCi of radioactive waste offsite for treatment and disposal.
  • Completed 39 hazardous waste manifests for transport of hazardous waste and solid waste to an offsite vendor TSDF for treatment and disposal.
  • Shipped 114,424 kg of waste from the University TSDF to an offsite vendor TSDF for treatment and disposal.
  • Created 49 waste manifests associated with the direct shipment of solid and hazardous waste from UNC-CH laboratories to offsite vendor TSDFs for treatment and disposal.
  • Shipped 27,278 kg of solid and hazardous waste directly to offsite vendor TSDFs.
  • Shipped 7,542 kg of scrap metal (ferrous and non-ferrous) offsite for reclamation and recycle.
  • Shipped 973 regulated medical waste boxes to Stericycle for incineration.
  • Aided with controlled substances drug disposal on campus which included 17 visits by NC DHHS Drug Control Unit for 28 lab visits/inspections.
  • Conducted 88 NPDES sediment and erosion control inspections of NPDES permitted land disturbance projects.
  • Conducted Phase 1 ESAs for six properties in coordination with the UNC Property Office.
  • Conducted sampling and demolition activities at the ESE air site in Pittsboro in support of the UNC Property Office.

Internal Processes

  • Defined and began the implementation of Subpart K for laboratory hazardous waste management and the new Hazardous Waste Generator Rules for non-laboratory hazardous waste management. Created a GIS map book of all UNC-CH hazardous waste generators for this compliance activity.
  • Prepared and submitted the Low-Level Radioactive Waste Surveys to the division of Radiation Protection for the Institute of Marine Sciences, the Nutrition Research Institute, UNC Hospital and the UNC storage facility.
  • Submitted semi-annual and annual reports for the UNC Title V air permit. Prepared the annual Air Emission Inventory and completed a revised Startup/Shutdown/Malfunction Plan. Prepared the annual Greenhouse Gas submittal.
  • Conducted air permitting for a new emergency generator at FOBRL and a new fire pump at Davis Library. Renewed the Landfill Gas to Energy air permit.
  • Conducted monthly maintenance and sampling at the Mason Farm low-level radioactive waste site and Airport Road waste disposal area and prepared an annual report documenting conditions at the sites.
  • Conducted permit required sampling at the Bingham Facility wastewater system. Submitted monthly and annual reports to regulators.
  • Applied for and received a buffer authorization permit from NC DEQ for the Finley Fields North Project.
  • Completed an Environmental Assessment/Finding of No significant Impact document for the Central Campus Athletic project.
  • Received Finley Fields South Project’s reclaimed water permit modification from NC DEQ.
  • Applied for and received erosion and sedimentation control permits from NC DEQ for the Finley Fields North project, the Airport Solar project and the Central Campus Athletic project.
  • Submitted the HMF stormwater permit renewal application to NC DEQ.
  • Submitted the campus-wide NPDES Phase II annual stormwater permit report and the campus-wide NPDES Phase II stormwater permit renewal application to NC DEQ.