Hazardous Waste Section Universal Waste
Mar 31, 2015
Hazardous Waste Section
Universal Waste
Universal Waste
Management Standards
For
3
Universal Waste
• Waste Batteries
• Waste Pesticides
• Waste Mercury - Containing Devices
• Waste Lamps
• Waste Pharmaceuticals
4
Universal Waste (UW) Handlers
• Small Quantity Handler (SQHs) Does not accumulate 5,000 kilograms or more of universal
waste (batteries, pesticides, mercury-containing equipment or lamps, or pharmaceuticals) at any time
• Large Quantity Handlers (LQHs) Accumulates 5,000 kilograms or more of total universal waste
(batteries, pesticides, mercury-containing equipment or lamps, or pharmaceuticals) at any time
Accumulates UPW consisting of > 1 Kg total of pharmaceuticals listed as acute hazardous waste (P-listed)
This designation is retained through the end of the calendar year
5
Universal Waste
• Note: If managed as UW, waste does not count towards HW generator status
• Four unbroken lamps = 1Kg (per 62-737 FAC)
• DEP Notification Requirements only required for LQHs
6
Universal Waste
• SQHs – 40 CFR 273.16
Personnel Training:
o A SQH must inform all employees who handle or have responsibility for managing UW. The information must describe proper handling and emergency procedures.
7
Universal Waste
• LQHs – 40 CFR 273.36
Personnel Training:
A LQH must ensure all employees are thoroughly familiar with proper handling and emergency procedures, relative to their responsibilities during normal facility operations.
8
Universal Waste
• SQHs – 40 CFR 273.15 (a - c)• LQHs – 40 CFR 273.35 (a - c)
Accumulation Time Limits:oOne YearoLonger than one year (if solely for purpose of
accumulation and other requirements are met)oAccumulation Start Date, Inventory system or other
method
9
Universal Waste
• SQHs – 40 CFR 273.17 (a and b) • LQHs – 40 CFR 273.37 (a and b)
Response to releases:
o Immediately contain releasesoPerform a hazardous waste determination on
residues from releases and properly manage residues
10
Universal Waste
• SQHs – 40 CFR 273.18 (a - h)• LQHs – 40 CFR 273.38 (a - h)
Off-Site Shipments:
oSend UW only to a UW handler, destination facility, or foreign destination
oMay self-transport if complying with transporter requirements in subpart D
oComply with DOT requirements if UW is a hazmat
oBefore shipment, ensure that it will be received
11
Universal Waste
• SQHs – 40 CFR 273.18 (a - h) • LQHs - 40 CFR 273.38 (a - h)
Off-Site Shipments (continued):
o If shipment is rejected, receive it back or ship to another destination facility
o If rejecting a shipment, contact originating handler, ship to originating handler or to another destination facility
o If shipment received is hazardous waste and not UW, notify EPA/DEP
o If shipment received is non-hazardous, but not UW, the waste may be managed appropriately
12
Universal Waste
• SQHs – 40 CFR 273.19 – Tracking UW Shipments:
A SQH is not required to keep records of shipments, however you should be able to demonstrate proper recycling during an inspection.
13
Universal Waste
• LQHs – 40 CFR 273.39 – Tracking UW Shipments:
UW Shipped:o Keep records – logs, invoices, manifests, bills of lading or
other shipping documents– Name and address where UW shipped– Quantity of each type shipped– Date of shipment
Records retained for three years
14
Universal Waste Batteries
15
Universal Waste Batteries
• Spent lead acid not managed under 40 CFR 266 subpart G
• Hazardous waste batteries (those that exhibit a characteristic)
• Becomes waste on the date the handler decides to discard it (see definition of discarded material 261.2(a)(2))
16
Universal Waste Batteries SQH/LQH Requirements
17
Universal Waste Batteries
• SQHs – 40 CFR 273.13 (a)• LQHs – 40 CFR 273.33(a)
Managed in a way to prevent releaseso Must contain leaking batterieso Container must be closed, structurally sound, and
compatibleo Container must lack evidence of leakage, spillage or
damage
18
Universal Waste Batteries
• SQHs – 40 CFR 273.14(a)• LQHs – 40 CFR 273.33(a)
Clearly labeled:o“Universal Waste – Battery(ies)”
o“Waste Battery(ies)”
o“Used Battery(ies)”
19
DOT Transport Concerns
• All Batteries are subject to requirements in HMR (49 CFR 171-180) Chemical or other materials contained in battery Electrical potential of the battery
20
DOT Transport Concerns
• Common violations & safety concerns
Used batteries collected in large containers that do not adequately prevent damage or releases during transport
Outer packages/shipping documents not marked and/or labeled as required
No action is being taken to prevent a short circuit, such as separating the batteries or taping
21
22
Universal Waste BatteriesSQH Improper Management
23
Universal Waste Batteries SQH Proper Management
24
UW pesticides
25
Universal Waste Mercury – Containing Equipment
26
Universal Waste Mercury – Containing Equipment
27
Universal Waste Mercury – Containing Equipment
• Device or part of a device that contains elemental mercury integral to its function
• Excludes waste that is non-hazardous
• Excludes equipment or devices where mercury-containing components have been removed
• Becomes waste on the date the handler decides to discard it
28
Universal Waste Mercury – Containing Equipment
• SQHs – 40 CFR 273.13 (c) • LQHs – 40 CFR 273.33 (c)
Managed in a way to prevent releasesoContain leaking equipment in containers that are:
– Closed
– Structurally sound
– Compatible with contents
– Lack evidence of leakage
– Designed to prevent escape of mercury
29
Universal Waste Mercury – Containing Equipment
• Ampules may be removed from equipment, provided that:
They are removed and managed in a proper manner
They are removed over or in a container
There is a mercury clean-up system in place
Spills are managed properly
It is ensured the area is well ventilated and monitored
30
Universal Waste Mercury – Containing Equipment
• Ampules may be removed from equipment, provided that:
Proper employee training is ensured
Removed ampules are stored in proper containers with adequate packing material
A hazardous waste determination will be performed on clean-up waste or equipment and then properly managed based upon the determination
31
Universal Waste Mercury – Containing Equipment
SQH Improper Management
32
Universal Waste Mercury – Containing Equipment
• SQHs – 40 CFR 273.14 (d)(1) • LQHS – 40 CFR 273. 34(d)(1)
Clearly labeled:o “Universal Waste – Mercury - Containing Equipment”o “Waste Mercury - Containing Equipment”o “Used Mercury - Containing Equipment”
• SQHs – 40 CFR 273.14 (d)(2) • LQHs – 40 CFR 273.34(d)(2)
Clearly labeled:o “Universal Waste – Mercury Thermostat(s)”o “Waste Mercury Thermostat(s)”o “Used Mercury Thermostat(s)”
33
Universal Waste Lamps
34
Universal Waste Lamps Requirements
• SQHs – 40 CFR 273.13 (d)• LQHs – 40 CFR 273.33 (d)
Managed in a way to prevent releaseso Contain lamps in containers
– Closed– Not leaking– Structurally sound
o Immediately clean up broken lamps and place in containers
35
Universal Waste Lamps
• SQHs – 40 CFR 273.14 (e) • LQHs – 40 CFR 273.34(e)
Clearly labeled:o “Universal Waste – Lamp(s)”o “Waste Lamp(s)”o “Used Lamp(s)”
36
Universal Waste Lamps – Improper Management
37
Universal Waste Lamps – Improper Management
38
Universal Waste Lamps – Proper Management
Universal Waste Lamps
Improper Response to Releases
39
40
Universal Waste Lamps
Improper Response
41
Universal Waste Lamps
Improper Response
42
Universal Waste LampsBulb Crushers
43
Bulb Crushers
• 62-737.400(6)(b) FAC
A generator of universal waste lamps may use crushing equipment on site to reduce the volume of stored lamps provided:
The lamps are crushed in a controlled manner that prevents the release of mercury vapor
The crushing operations and maintenance of the unit are performed in accordance with manufacturer’s instructions (filter change outs and operator training)
44
Universal Waste LampsBulb Crushers
45
Universal Waste Lamps – Improper Management
46
Universal Waste Lamps – Improper Management
47
Universal Waste Pharmaceuticals
48
UPW
• SQH of Universal Pharmaceutical Waste no longer need to notify
49
Questions?