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Universal Waste Rule

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Universal Waste Rule Pesticides Hazardous Waste Lamps Batteries Thermostats 40 CFR Part 273 Promulgated May 11, 1995 (60 FR 25492) http://www.epa.gov/epaoswer ... – PowerPoint PPT presentation

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Title: Universal Waste Rule


1
Universal Waste Rule
Pesticides
Hazardous Waste Lamps
Batteries
Thermostats
  • 40 CFR Part 273
  • Promulgated May 11, 1995 (60 FR 25492)

http//www.epa.gov/epaoswer/hazwaste/id/univwast.h
tm
2
Types of Waste Covered
  • Four types of Federal universal wastes
  • Batteries (e.g., nickel cadmium) (does not
    include lead acid)
  • Certain pesticides that are either recalled or
    collected in waste pesticides collection programs
  • Mercury-containing thermostats
  • Lamps
  • Universal waste categories must be
    hazardous waste before they can be designated as
    universal wastes
  • CRTs and mercury-containing devices are planned
    to be proposed this summer as Federal universal
    wastes

3
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 wastes going to municipal landfills or
    combustors

4
Questions
  • Generator status
  • What is the difference from a small quantity
    generator of hazardous waste and a universal
    waste handler?
  • The most notable difference is that for universal
    waste there are longer storage times, no manifest
    requirements. See table on pages 15 and 16 for a
    more complete comparison.
  • How does handing universal waste affect the
    generator calculations to determine if you are
    a large or small quantity generator of hazardous
    waste?
  • You must include all hazardous wastes in your
    generator calculations. If you are using
    universal waste standards for universal wastes,
    then those wastes do not count in the hazardous
    waste calculations.
  • Can SQG dispose of UW in the municipal landfill
    for regular trash
  • No

5
Questions
  • Recycling, treatment and disposal
  • Can small quantity generators of hazardous waste
    dispose of universal waste in the municipal
    landfill for regular trash?
  • No, it has to be recycled or go to a hazardous
    waste treatment or disposal facility
  • Does all universal waste have to be recycled?
  • No, it is just easier to do so, although there
    may not be any treatment option for mercury other
    than being recycled (retorted)
  • How is universal waste different when it gets to
    the recycling, treatment, or disposal facilities?
  • The universal waste no longer has different
    standards when it get to the destination
    facility. It is then handles as regular
    hazardous wastes

6
Universal Waste Rule Status
You can use universal waste rule provisions
before final authorization (during the adoption
process) as long as you comply with the federal
regulations.
Universal wastes are hazardous wastes with
streamlined handling standards. If you are not
using universal waste regulations, then you must
use hazardous waste regulations for those waste.
(The hazardous waste regulations have some
exclusions that may apply.)
7
States with Universal Waste that are Different
than Federal
This list may not be complete since it is
collected from public information on the Internet.
Types of state-only Universal Wastes Aerosol
Cans (CO) Antifreeze (LA, NH) Ballasts
(MD, ME, VT) Cathode Ray Tubes / CRT (ME, MI,
NH, RI) Electronic Devices and Electronic
Components (CO) Mercury Related Universal
Wastes - Mercury-Containing Devices (CO, MA, MI,
ND, NH, PA, RI)- Barometers (NH, RI)- Gas Flow
Regulators (NH)- Intact Mercury-Containing
Ampules (NH)- Manometers (NH, RI)- Mercury
Switches (MI) and Relays (NH, RI)- Mercury
Thermometers (MI)- Sphygmomanometers (NH, RI)-
Thermocouples (NH, RI)- Thermometers (NH, RI) -
Water meters (NH) (last updated February 2002)
Note California has proposed to add Cathode ray
tube materials, Consumer electronic devices,
Aerosol cans, Mercury-containing motor vehicle
light switches (public hearing September 30, 2002)
http//www.epa.gov/epaoswer/hazwaste/id/univwast/u
wsum.htm
8
Regulated Community
  • Groups that manage universal waste
  • 1. Small Quantity Handlers of Universal Waste
    (SQHUW)
  • accumulate less than 5,000 Kg or 11,000 lbs of
    universal waste
  • 2. Large Quantity Handlers of Universal Waste
    (LQHUW)
  • accumulate 5,000 Kg or more of universal waste
  • 3. Universal Waste Transporters

9
Management Requirements Lamps
A Universal Waste Handler must
  • Manage ALL universal waste lamps in a way that
    prevents releases
  • Must contain ALL universe waste lamps in
    appropriate containers (like the box the new ones
    come in)
  • Immediately clean up and place in an appropriate
    container any lamp that is broken

10
A Universal Waste Handler must
  • SPILLS AND CLEAN-UP
  • Determine if mercury cleanup residues and/or
    solid waste exhibit a characteristic of hazardous
    waste
  • If hazardous, manage in compliance with
    applicable Subtitle C requirements OR
  • If not hazardous, manage in compliance with
    applicable federal state and local regulations

11
Management Requirements Batteries
Are all batteries hazardous, therefor qualify as
universal waste?
  • No, but most are
  • There is interest to share battery-specific
    determinations (tests to see if they are
    hazardous)

Universal waste handler must
  • Contain batteries that show evidence of leakage,
    spillage, or damage
  • Store and transport batteries in containers
    appropriate for battery type to ensure contents
    dont spark and ignite.

12
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) Information on
    universal waste http//www.epa.gov/epaoswer/hazwa
    ste/id/univwast.htm

13
Management Requirements ELECTRONICS
Why Electronics
  • Does the equipment contain heavy metals (lead,
    cadmium, copper, zinc, mercury)?
  • We know that CRTs often contain a lot of lead,
    easily enough to fail the toxicity test (TCLP).
    We don't have a lot of info about the other
    metals - we have been going on the assumption
    that they don't have enough of any to fail the
    TCLP. EPA Regions 4 and 5 are doing a study with
    the U. of Fla to measure lead in different kinds
    of electronics, including CPUs, cell phones, and
    printers. They will also be looking at other
    metals. The results could be final by the end of
    this year.
  • Can they be landfilled legally?
  • Waste CRTs generated by businesses would often
    not be able to be legally disposed of in a
    municipal landfill. No hard data yet on other
    electronics - people should always check with
    their States, with respect to CRTs and other
    electronics.
  • Reuse programs?
  • Reuse is always the best option for usable
    equipment. There are many programs and you
    should check with your state for available ones.

14
Tables for Reference
15
Comparison to Hazardous Waste Generators Table
located at http//www.epa.gov/epaoswer/hazwaste/
id/univwast/table.htm
16
...Continued Comparison to Hazardous Waste
Generators Table located at http//www.epa.gov/e
paoswer/hazwaste/id/univwast/table.htm
Note regulations can vary by state
17
Universal Waste Handler Requirements
Differences SQHUW (273 Subpart B) LQHUW
(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 Proper
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 Required
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
18
Universal Waste Handler Requirements
Similarities
SQHUW and LQHUW (273 Subpart B and
C) Disposing of, diluting, or treating
universal waste (some exceptions apply) 273.11
or 273.31 Must manage universal waste in a way
that prevent 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 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/ Markin
g Accumulation Time Limit Response to
Releases Shipments
19
Universal Waste Transporter Requirements
Transporters 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 Stora
ge Time Limit Response to Releases Shipments
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