hazardous waste section universal waste. management standards for

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

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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

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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

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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.

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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.

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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

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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

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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

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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

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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.

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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

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Universal Waste Batteries

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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))

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Universal Waste Batteries SQH/LQH Requirements

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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

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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)”

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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

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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

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Universal Waste BatteriesSQH Improper Management

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Universal Waste Batteries SQH Proper Management

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UW pesticides

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Universal Waste Mercury – Containing Equipment

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Universal Waste Mercury – Containing Equipment

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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

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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

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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

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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

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Universal Waste Mercury – Containing Equipment

SQH Improper Management

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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)”

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Universal Waste Lamps

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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

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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)”

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Universal Waste Lamps – Improper Management

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Universal Waste Lamps – Improper Management

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Universal Waste Lamps – Proper Management

Universal Waste Lamps

Improper Response to Releases

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Universal Waste Lamps

Improper Response

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Universal Waste Lamps

Improper Response

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Universal Waste LampsBulb Crushers

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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)

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Universal Waste LampsBulb Crushers

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Universal Waste Lamps – Improper Management

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Universal Waste Lamps – Improper Management

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Universal Waste Pharmaceuticals

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UPW

• SQH of Universal Pharmaceutical Waste no longer need to notify

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Questions?