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Hazardous Waste Section Universal Waste. Management Standards For.

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Presentation on theme: "Hazardous Waste Section Universal Waste. Management Standards For."— Presentation transcript:

1 Hazardous Waste Section Universal Waste

2 Management Standards For

3 Universal Waste Waste Batteries Waste Pesticides Waste Mercury - Containing Devices Waste Lamps Waste Pharmaceuticals 3

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 4

5 Universal Waste Note: If managed as UW, waste does not count towards HW generator status Four unbroken lamps = 1Kg (per FAC) DEP Notification Requirements only required for LQHs 5

6 Universal Waste SQHs – 40 CFR 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. 6

7 Universal Waste LQHs – 40 CFR 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. 7

8 Universal Waste SQHs – 40 CFR (a - c) LQHs – 40 CFR (a - c) Accumulation Time Limits: o One Year o Longer than one year (if solely for purpose of accumulation and other requirements are met) o Accumulation Start Date, Inventory system or other method 8

9 Universal Waste SQHs – 40 CFR (a and b) LQHs – 40 CFR (a and b) Response to releases: o Immediately contain releases o Perform a hazardous waste determination on residues from releases and properly manage residues 9

10 Universal Waste SQHs – 40 CFR (a - h) LQHs – 40 CFR (a - h) Off-Site Shipments: o Send UW only to a UW handler, destination facility, or foreign destination o May self-transport if complying with transporter requirements in subpart D o Comply with DOT requirements if UW is a hazmat o Before shipment, ensure that it will be received 10

11 Universal Waste SQHs – 40 CFR (a - h) LQHs - 40 CFR (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 11

12 Universal Waste SQHs – 40 CFR – 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. 12

13 Universal Waste LQHs – 40 CFR – 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 13

14 Universal Waste Batteries 14

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)) 15

16 Universal Waste Batteries SQH/LQH Requirements 16

17 Universal Waste Batteries SQHs – 40 CFR (a) LQHs – 40 CFR (a) Managed in a way to prevent releases o Must contain leaking batteries o Container must be closed, structurally sound, and compatible o Container must lack evidence of leakage, spillage or damage 17

18 Universal Waste Batteries SQHs – 40 CFR (a) LQHs – 40 CFR (a) Clearly labeled: o Universal Waste – Battery(ies) o Waste Battery(ies) o Used Battery(ies) 18

19 DOT Transport Concerns All Batteries are subject to requirements in HMR (49 CFR ) Chemical or other materials contained in battery Electrical potential of the battery 19

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 20

21 21

22 Universal Waste Batteries SQH Improper Management 22

23 Universal Waste Batteries SQH Proper Management 23

24 UW pesticides 24

25 Universal Waste Mercury – Containing Equipment 25

26 Universal Waste Mercury – Containing Equipment 26

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 27

28 Universal Waste Mercury – Containing Equipment SQHs – 40 CFR (c) LQHs – 40 CFR (c) Managed in a way to prevent releases o Contain leaking equipment in containers that are : –Closed –Structurally sound –Compatible with contents –Lack evidence of leakage –Designed to prevent escape of mercury 28

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 29

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 30

31 Universal Waste Mercury – Containing Equipment SQH Improper Management 31

32 Universal Waste Mercury – Containing Equipment SQHs – 40 CFR (d)(1) LQHS – 40 CFR (d)(1) Clearly labeled: o Universal Waste – Mercury - Containing Equipment o Waste Mercury - Containing Equipment o Used Mercury - Containing Equipment SQHs – 40 CFR (d)(2) LQHs – 40 CFR (d)(2) Clearly labeled: o Universal Waste – Mercury Thermostat(s) o Waste Mercury Thermostat(s) o Used Mercury Thermostat(s) 32

33 Universal Waste Lamps 33

34 Universal Waste Lamps Requirements SQHs – 40 CFR (d) LQHs – 40 CFR (d) Managed in a way to prevent releases o Contain lamps in containers –Closed –Not leaking –Structurally sound o Immediately clean up broken lamps and place in containers 34

35 Universal Waste Lamps SQHs – 40 CFR (e) LQHs – 40 CFR (e) Clearly labeled: o Universal Waste – Lamp(s) o Waste Lamp(s) o Used Lamp(s) 35

36 Universal Waste Lamps – Improper Management 36

37 Universal Waste Lamps – Improper Management 37

38 Universal Waste Lamps – Proper Management 38

39 Universal Waste Lamps Improper Response to Releases 39

40 Universal Waste Lamps Improper Response 40

41 Universal Waste Lamps Improper Response 41

42 Universal Waste Lamps Bulb Crushers 42

43 Bulb Crushers (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 manufacturers instructions (filter change outs and operator training) 43

44 Universal Waste Lamps Bulb Crushers 44

45 Universal Waste Lamps – Improper Management 45

46 Universal Waste Lamps – Improper Management 46

47 Universal Waste Pharmaceuticals 47

48 UPW SQH of Universal Pharmaceutical Waste no longer need to notify 48

49 Questions? 49


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