1. Presented by: Name, Title Date For Client Name Universal Waste Don Gansert Managing Consultant September 18, 2008

2. Universal Waste Regulations Category of hazardous waste that is exempt from hazardous waste requirements if specified handling and recycling practices are followed Category of hazardous waste that is exempt from hazardous waste requirements if specified handling and recycling practices are followed NAC Title 128, Chapter 25, Sections 001 through 006 NAC Title 128, Chapter 25, Sections 001 through 006 EPA regulations 40 CFR 273 EPA regulations 40 CFR 273 NDEQ Environmental Guidance Document No. 08-019, dated July 2008 NDEQ Environmental Guidance Document No. 08-019, dated July 2008 Refer to handout Refer to handout

3. Universal Waste Regulations The Universal Waste (UW) rule amends the Resource Conservation and Recovery Act (RCRA) regulations to allow for streamlined management of certain widely generated hazardous wastes The Universal Waste (UW) rule amends the Resource Conservation and Recovery Act (RCRA) regulations to allow for streamlined management of certain widely generated hazardous wastes Individuals and organizations must collect these wastes and manage them in an appropriate hazardous waste management system Individuals and organizations must collect these wastes and manage them in an appropriate hazardous waste management system A material cannot be a universal waste unless it would meet the definition of hazardous waste

4. Types of Universal Wastes Used Batteries – Ni-Cad, mercuric-oxide, certain lithium, and spent lead-acid. Used Batteries – Ni-Cad, mercuric-oxide, certain lithium, and spent lead-acid. Note: Spent lead-acid batteries usually best managed under a separate hazardous waste exemption for lead-acid batteries being reclaimed, refer to NAC Title 128, Chapter 7 Note: Spent lead-acid batteries usually best managed under a separate hazardous waste exemption for lead-acid batteries being reclaimed, refer to NAC Title 128, Chapter 7 Pesticides – Recalled (Voluntary or mandatory) and stocks of other unused pesticides Pesticides – Recalled (Voluntary or mandatory) and stocks of other unused pesticides Mercury-containing items – thermostats, barometers, thermometers, certain gages, and electrical switches Mercury-containing items – thermostats, barometers, thermometers, certain gages, and electrical switches Spent Lamps – fluorescent, high-pressure sodium, mercury vapor, and metal halide Spent Lamps – fluorescent, high-pressure sodium, mercury vapor, and metal halide Electronic Items – cathode ray tubes (CRTs) or other electronic devices Electronic Items – cathode ray tubes (CRTs) or other electronic devices

5. Categories of Waste Handlers Four categories for handlers Four categories for handlers Small quantity handlers of universal waste (SQHUW) Small quantity handlers of universal waste (SQHUW) Accumulates less than 5,000 kilograms (11,000 lbs) Accumulates less than 5,000 kilograms (11,000 lbs) Large quantity handlers of universal waste (LQHUW) Large quantity handlers of universal waste (LQHUW) Accumulates 5,000 kilograms (11,000 lbs) or more Accumulates 5,000 kilograms (11,000 lbs) or more Transporter Transporter Transport UW from handlers to other handlers, or destination facilities Transport UW from handlers to other handlers, or destination facilities Destination Facilities Destination Facilities Treat, dispose, or recycle UW Treat, dispose, or recycle UW

6. Small Quantity Handlers UW No notification to accumulate UW No notification to accumulate UW Waste Management Waste Management Store in closed, structurally sound, and compatible containers Store in closed, structurally sound, and compatible containers Labeling Labeling Mark containers Mark containers Examples of each type to follow Examples of each type to follow Accumulation time – 1 year, mark the earliest date of any UW in the container Accumulation time – 1 year, mark the earliest date of any UW in the container Employee Training (NAC Title 128, Chapter 25, Section 015 & 40 CFR 273.16) – Inform all employees who handle or have responsibility for managing UW Employee Training (NAC Title 128, Chapter 25, Section 015 & 40 CFR 273.16) – Inform all employees who handle or have responsibility for managing UW Proper Handling, and Proper Handling, and Appropriate emergency procedures Appropriate emergency procedures

7. Large Quantity Handlers UW Submit notification to accumulate UW, and obtain an EPA ID Number Submit notification to accumulate UW, and obtain an EPA ID Number Waste Management Waste Management Store in closed, structurally sound, and compatible containers Store in closed, structurally sound, and compatible containers Labeling Labeling Mark containers Mark containers Examples of each type to follow Examples of each type to follow Accumulation time – 1 year, mark the earliest date of any UW in the container Accumulation time – 1 year, mark the earliest date of any UW in the container Employee Training (NAC Title 128, Chapter 25, Section 026 & 40 CFR 273.36)– Ensure all employees are thoroughly familiar with Employee Training (NAC Title 128, Chapter 25, Section 026 & 40 CFR 273.36)– Ensure all employees are thoroughly familiar with Proper Handling, and Proper Handling, and Emergency procedures Emergency procedures

8. Container Examples

9. Closed Container Not Closed Closed

10. Closed Container

11. Structurally Sound Containers

12. Labeling of Containers (1 of 3) Used Batteries: Used Batteries: Universal Waste – Battery(ies) or Universal Waste – Battery(ies) or Waste Battery(ies) or Waste Battery(ies) or Used Battery(ies) Used Battery(ies) Pesticides; Pesticides; Universal Waste – Pesticide(s) or Universal Waste – Pesticide(s) or Waste – Pesticide(s) Waste – Pesticide(s) Mercury-containing items; Mercury-containing items; Universal Waste – Mercury –containing Item(s) or Universal Waste – Mercury –containing Item(s) or Waste Mercury-containing Item(s) or Waste Mercury-containing Item(s) or Used Mercury-containing Item(s) Used Mercury-containing Item(s)

13. Labeling of Containers (2 of 3) Spent Lamps; Spent Lamps; Universal Waste – Lamps or Universal Waste – Lamps or Waste Lamp(s) or Waste Lamp(s) or Used Lamp(s) Used Lamp(s) Electronic Items; Electronic Items; Universal Waste – Electronic Item(s) or Universal Waste – Electronic Item(s) or Waste Electronic Item(s) or Waste Electronic Item(s) or Used Electronic Item(s) Used Electronic Item(s) Note: The name of the electronic item may be substituted for the words Electronic Item(s) e.g. Universal Waste – Monitor(s)

14. Labeling of Containers (3of 3) An example of a type of UW label

15. Emergency Procedures Mercury Spills (Mercury-containing items) Mercury Spills (Mercury-containing items) Have a spill clean-up kit immediately available if you are handling elemental mercury Have a spill clean-up kit immediately available if you are handling elemental mercury Immediately contain, clean up and place in structurally sound, closed container Immediately contain, clean up and place in structurally sound, closed container Refer to Title 128, Chapter 25, 012.03 (SQHUW) or 023.03 (LQHUW) for more specific details Refer to Title 128, Chapter 25, 012.03 (SQHUW) or 023.03 (LQHUW) for more specific details Broken Lamps Broken Lamps Immediately clean up broken lamps and place in a structurally sound, closed container Immediately clean up broken lamps and place in a structurally sound, closed container Broken Electronic Item(s) Broken Electronic Item(s) Immediately clean up broke CRTs and place in a structurally sound, closed container Immediately clean up broke CRTs and place in a structurally sound, closed container

16. Lead Acid Batteries Two managing options: Two managing options: Universal Waste or Universal Waste or Title 128, Chapter 7 (40 CFR 266.80 (Subpart G)) Title 128, Chapter 7 (40 CFR 266.80 (Subpart G)) If you generate, collect, transport, store or regenerate lead-acid batteries for reclamation purposes, If you generate, collect, transport, store or regenerate lead-acid batteries for reclamation purposes, Exemption from certain hazardous waste management requirements Exemption from certain hazardous waste management requirements Primarily used for the reclamation of spent automotive lead-acid batteries Primarily used for the reclamation of spent automotive lead-acid batteries No labeling requirements No labeling requirements

17. Summary Generators responsibility to determine if the waste should be managed as hazardous waste or UW Generators responsibility to determine if the waste should be managed as hazardous waste or UW If managed as UW, then its the generators responsibility for If managed as UW, then its the generators responsibility for Notification if required Notification if required Waste Management Waste Management Labeling Labeling Accumulation time Accumulation time Employee Training Employee Training