Universal Waste

1
PROPOSED CRT RULE
2
Purpose of Rule
To encourage greater reuse, recycling and better
management of cathode ray tubes (CRTs) a rapidly
growing wastestream.
3
Background

• Electronics are a very fast growing waste
  stream over 250 million computers will be
  retired over the next five years.
• CRTs The video display component of computer
  and TV monitors. Many CRTs from color monitors
  fail the toxicity characteristic (TC) for lead.

4
Background (continued)

• CSI Recommendations EPA should streamline its
  RCRA management requirements for CRTs.
• - Rationale to encourage collection,
  glass-to-glass recycling and better management.
• EPAs proposed rule an important first step in
  dealing with issues posed by end-of-life
  electronics.

5
Summary of Proposed Rule
Who Is Regulated and Who Is Not? Not Regulated
1. Households may send used monitors to any
collector for recycling or disposal. 2. CESQGs
Non-residential generators of less than 100 kg.
per month (about 7 or 8 computers) are not
subject to most Subtitle C standards. 3. User
who sends CRTs to a collector or reseller for
potential reuse or repair if the CRTs may be
reused, they are products, not wastes.
Continued...
6
Summary of Proposed Rule

.
(Continued)

• Who Is Regulated and Who Is Not?
• Not Regulated (continued)
• 4. Intact, off-spec CRTs sent for recycling
  these are products, not wastes.
• 5. Non-CRT electronic materials
• Whole used circuit boards and shredded circuit
  boards are not regulated.
• Other electronics No reason to think these are
  hazardous, but EPA is examining.

7
Summary of Proposed Rule

.
(Continued)

• Who Is Regulated and Who Is Not?
• Regulated With Streamlined Requirements
• 1. Used Broken CRTs Sent for Recycling
• Conditionally excluded if they comply with
  universal waste-type packaging and labeling
  requirements for storage and shipment.
• No speculative accumulation.

Continued...
8
Summary of Proposed Rule

.
(Continued)

• Who Is Regulated and Who Is Not?
• Regulated With Streamlined Requirements
  (continued)
• 2. Glass Processors
• Must store broken CRTs indoors or in accordance
  with universal waste-type packaging and labeling,
  no speculative accumulation.
• May not use temperatures high enough to
  volatilize lead.

9
Summary of Proposed Rule

.
(Continued)

• Who Is Regulated and Who Is Not?
• Regulated With Streamlined Requirements
  (continued)
• 3. Processed Glass
• If sent to a glass-to-glass manufacturer or
  lead smelter, not regulated.
• If sent to other kinds of recycling, must
  comply with universal waste-type packaging and
  labeling.
• No speculative accumulation.

10
Summary of Proposed Rule

.
(Continued)

• Regulated Under Full Subtitle C
• Disposal in a landfill or incinerator, unless
  the disposer is a household or a CESQG.

11
Summary of Proposed Rule

.
(Continued)

• Solicitation of Comment
• Universal-waste type tracking and notification
  requirements for larger generators of CRTs.
• Speculative accumulation for used CRTs.
• Whether processed glass sent to recyclers other
  than glass-to-glass manufacturers should be
  regulated.
• Whether disposal requirements should be
  streamlined.

12
Basics of the Universal Waste Rule
Hazardous Waste Lamps
Pesticides
Batteries
Thermostats

• 40 CFR 273
• May 11, 1995 (60 FR 25492)

13
Overview

• The universal waste rule streamlines the
  hazardous waste regulations by
• reducing barriers to collection programs
• reducing complexities
• reducing cost of compliance
• Note the rule provides an alternative set of
  management standards in lieu of regulation under
  parts 260-272

14
Goals of the Universal Waste Rule

• Encourage environmentally sound collection and
  recycling or treatment of universal waste
• Improve implementation of the hazardous waste
  system
• Ease regulatory burden
• Reduce the hazardous wastes going to municipal
  landfills or municipal combustors

15
Universal Waste Characteristics

• Frequently generated as a waste in a wide variety
  of non-industrial settings
• Generated by a vast community (size of community
  poses implementation difficulties)
• Present in significant volumes in non-hazardous
  waste management systems

16
Types of Waste Covered

• Four types of Federal universal wastes
• - Universal waste categories must be hazardous
  waste before they can be designated as universal
  wastes
• Batteries (e.g., nickel cadmium)
• Certain pesticides that are either recalled or
  collected in waste pesticides collection programs
• Mercury-containing thermostats
• Lamps (e.g., fluorescent bulbs)

17
Adding New Wastes

• The State or Federal program may add new
  categories of universal wastes or be petitioned
  to add new categories of universal waste.

18
Universal Waste Rule Status
March 30, 2001
DC
Note States can implement the universal waste
rule before authorization. - July 20, 1998 Memo
Authorized The Region Administers Rule Adopted
Not adopted or authorized
19
Exempt Wastes

• Household hazardous waste
• excluded under 261.4(b)(1)
• Conditionally exempt small quantity generator
  waste
• exempt under 261.5
• Note These wastes can be managed under the
  universal waste rule if preferred. Persons who
  commingle either of the two categories of waste
  listed above with universal waste must manage the
  commingled waste under the requirements of the
  universal waste rule.

20
Definition of Universal Waste Handler

• A universal waste handler is someone that
• generates universal waste,
• receives universal waste, or
• accumulates universal waste
• A universal waste handler is not
• a person who treats, disposes of, or recycles
  universal waste

21
Regulated Community

• Four types of regulated persons manage universal
  waste
• 1. Small Quantity Handlers of Universal Waste
  (SQHUW)
• accumulate less than 5,000 kg of universal waste
• 2. Large Quantity Handlers of Universal Waste
  (LQHUW)
• accumulate 5,000 kg or more of universal waste

22
Regulated Community (continued)

• 3. Transporters
• transport universal waste from handlers to other
  handlers, destination facilities or foreign
  destinations
• 4. Destination facilities
• treat, dispose of, or recycle universal wastes as
  hazardous waste (no longer universal waste)
• note this does not include facilities that store
  universal waste

23
Regulatory Summary

• The Universal Waste Rule was published in the
  Federal Register May 11, 1995 (60 FR 25492) and
  codified at 40 CFR 273
• The Mercury-Containing and Rechargeable Battery
  Management Act was signed on May 13, 1996
  (PL 104-142)
• A technical correction was published in the
  Federal Register December 24, 1998 (63 FR 71225)
• Lamps were added as a new Federal universal waste
  July 6, 1999 (64 FR 36466)

24
Universal Waste Handler Requirements
SQHUW (part 273 subpart B)
LQHUW(part 273 subpart C)
A universal waste handler who accumulates up
to, but not including, 5,000 Kg on-site at any
one time (273.6) Not Required (273.12) Less
than 5,000 Kg (273.6) Not Required (273.19) Pr
oper handling and emergency procedures (273.16)
A universal waste handler who accumulates 5,000
Kg or more on-site at any one time (273.6) Requir
ed (273.32) No limit Not required, but must
keep basic shipping records (273.39) Training
geared towards employee responsibilities (273.36)

Classification EPA Identification
Number On-Site Accumulation Limit Manifest Empl
oyee Training
25
Universal Waste Handler Requirements
SQHUW and LQHUW (part 273 subparts B
and C) Disposing of, diluting, or treating
universal waste - although some exceptions apply
(273.11 or 273.31) Must manage universal waste
in a way that prevents releases into the
environment -specific standards apply to each
type (273.13 or 273.33) Must label or mark
universal waste or containers of universal waste
to identify universal waste type (273.14 or
273.34) One year unless for proper recovery
treatment or disposal (273.15 or 273.35) Must
immediately contain releases and handle residues
appropriately and make hazardous waste
determination on material resulting from release
(273.17 or 273.37) Must send universal waste
only to other handlers, destination facilities,
or foreign destination (273.18 or 273.38)
Prohibitions Waste Management Labeling/ Marking
Accumulation Time Limit Response to
Releases Shipments
26
Universal Waste Transporter Requirements
Transporters (part 273 subpart D) A
person engaged in the off-site transportation of
universal waste by highway, rail, air or water
(273.6) Disposing of, diluting, or treating
universal waste (273.51) Must comply with
applicable DOT regulations (49 CFR 171)
(273.52) Ten days at a transfer facility
(273.53) Must immediately contain releases and
handle residues appropriately make hazardous
waste determination on material resulting from
release (273.54) Must transport universal waste
only to other handlers, destination facilities,
or foreign destination (273.55)
Definition Prohibitions Waste Management Stor
age Time Limit Response to Releases
Shipments
27
Destination Facility Requirements
Destination Facilities (part 273 subpart
E) A facility that treats disposes of or
recycles universal waste (273.6) Subject to all
applicable requirements of parts 264, 265, 266,
268, 270, and 124 and notification under 3010 of
RCRA, while recyclers that do not store before
they recycle have the reduced requirements of
(261.6(c)(2) (273.60) Prohibited from
sending universal waste to a place other than
universal waste handlers, other destination
facilities, or foreign destinations
(273.61) Must maintain basic records
documenting shipments received on-site (273.62)
Definition Standards Off-Site Shipments Tr
acking
28
PROPOSED RULE FOR MERCURY-CONTAINING EQUIPMENT
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History

• USWAG Petition
• 1996 Utilities Solid Waste Activities Group
• (USWAG) and other utility groups submitted a
• petition to EPA.
• Gave information about mercury-containing
  equipment, such as
• Manometers, barometers, relay switches,
  regulators, meters, pressure and temperature
  gauges, sprinkler system contacts.

• Asked EPA to add this equipment to the universal
  waste rule.

30
EPA Decision

• EPAs decision this equipment is OK for
  universal waste because
• Devices often fail the TC for mercury.
• Found in many industries.
• Generated by many generators in small quantities.
  
• Risk relatively low compared to other hazardous
  waste.
• Will be diverted from municipal wastestream.

31
Proposed Management Requirements for
Mercury-Containing Equipment.

• Equipment must be discarded. If still in use,
  not regulated under RCRA.
• CESQG and household waste exemptions still apply.
  
• - But we encourage voluntary recycling.
• Check with States about their exemptions.

32
Handlers

• Handlers they produce, store, collect, or
  accumulate mercury equipment.
• May not treat, recycle, or dispose.
• They benefit most from the universal waste
  program.
• SQHUWs accumulate less than 5000 kg of all
  universal waste categories
• LQHUWs accumulate 5000 kg or more of all
  universal waste categories.

33
Handlers (Continued)
All handlers of mercury equipment 1. May
accumulate it on-site for one year. 2. Must
train employees for handling and emergencies.
3. Must package and label the equipment. 4.
No hazardous waste manifest needed.
34
Handlers (Continued)

• All handlers of mercury equipment (continued)
• 5. People removing ampules must
• Prevent breakage.
• Keep removal area ventilated and monitored.
• Remove the ampule over a container.
• Transfer spills to a container.
• Pack removed ampules in a container.

35
Handlers (Continued)

• All handlers must notify EPA if they receive
  illegal shipments.
• LQHUWs must also
• - Notify EPA of universal waste management
  activities.
• - Get an EPA ID number, unless they have
  already submitted a notification.
• - Maintain records of all universal waste
  shipments (may be usual business records).
• - If they remove mercury ampules, must handle
  characteristic spills under full Subtitle C.

36
Transporters

• Transporters they move mercury equipment from
  one handler to another handler or to a
  destination facility.
• May not treat equipment or dispose of it.
• May store equipment at a transfer facility only
  for ten days or less.
• Must comply with all applicable DOT shipping
  requirements.

37
Destination Facilities

• Destination facilities they treat, dispose of,
  or recycle mercury equipment.
• Must comply with all applicable RCRA
  requirements.
• Recyclers who dont store before recycling need
  not get a RCRA permit.
• Must keep records of all shipments sent and
  received.

38
State-Only Universal Wastes
39
Adding New State-Only Wastes
States must ensure that universal waste
regulations, for proposed state-only wastes are

• Appropriate for the waste or category of waste
• Will improve management practices of category of
  waste and
• Will improve the overall implementation of the
  hazardous waste management program

40
Factors for Additional Waste to be Added

• 1. Generated by a wide variety of generators
• 2. Not exclusive to a specific industry or group
  of industries
• 3. Collection systems provide close stewardship
• 4. Accumulation and transport risk is relatively
  low
• 5. Specific management is protective of human
  health and the environment

41
Factors for Additional Waste to be Added
(continued)

• 6. Will likely be diverted from non-hazardous to
  Subtitle C waste management systems
• 7. Management under 273 will improve
  implementation of and compliance with hazardous
  waste regulatory program
• 8. Other factors may be appropriate depending on
  wastestream
• Note the full requirements are found in 273.81

42
Enforcement Memo

• In states that have not been authorized for the
  universal waste rule, and have added new
  state-only universal wastes, EPA will not take
  enforcement action in situations where the wastes
  meet the criteria set forth in 273.81
• July 20, 1998 Memo

43
States with State-Only Universal Wastes
DC
Note, this information came from state web sites
and may be incomplete
State-Only Wastes Only Federal Types of
Universal Waste (including hazardous waste
lamps) Not adopted or authorized
44
Types of State-Only Universal Wastes
Colorado - aerosol cans, electronic devices and
electronic components Louisiana -
antifreeze Maine - PCB ballast's Michigan -
electric lamp Texas - paint and paint-related
waste Vermont - fluorescent light ballasts
Continued...
45
Types of State-Only Universal Wastes (continued)
State-Only Types of Mercury-Containing Equipment
and CRTs
Colorado - mercury-containing devices Maine -
cathode ray tubes (CRTs) Mass -
mercury-containing devices Michigan - mercury
switch, mercury thermometer, waste device which
contains only elemental mercury as the
hazardous constituent Missouri - mercury
switches, mercury-containing thermometers,
manometers North Dakota - mercury containing
devices Pennsylvania - mercury containing
devices
46
Contacts
Current rulemaking on CRTs and Mercury-Containing
Equipment Marilyn Goode [phone] EPA,
Office of Solid Waste General Universal Waste
Rule Tab Tesnau [phone] EPA, Office of
Solid Waste RCRA Hotline [phone]