UNDERSTANDING UNIVERSAL WASTE RULES & HANDLING IN NEBRASKA

What is Universal Waste? In 1995 the EPA issued the universal waste rule (UWR) in order to streamline environmental regulations for wastes that are generated by large numbers of businesses in relatively small quantities. Fluorescent Lamps Batteries Mercury Items Electronics Universal Wastes are usually items commonly thrown into the trash by households and small businesses. Includes BATTERIES, LAMPS, THERMOSTATS (Mercury Items). The State of MN has adopted regulations above the national standard http://www.pca.state.mn.us/ is the online source for MPCA information

UWR was designed for 3 reasons: To reduce the amount of hazardous waste items in the municipal solid waste stream To encourage the recycling and proper disposal of some common hazardous wastes To reduce the regulatory burden on businesses that generate these wastes December 2004, Changes to UWR in NE allow businesses to manage (haz) e-waste as Universal Waste. July 2005, EPA added e-waste to UWR. Nebraska added E-Waste to Universal Waste Regulations before the EPA did!

Benefits of UWR Universal Wastes do not count against your Hazardous Waste Generator status. Increased Storage Time, UW may be stored for up to one calendar year, instead of 90 or 180/270 days. Reduces Regulatory Burden, fewer requirements for labeling, notification, accumulation time and training. - Large Quantity Handlers of UW must obtain a NDEQ ID Number - Large Quantity Handlers must complete training Ease of Transportation and Tracking - Common carrier - No hazardous waste manifest required - Waste can move between UW handlers

Universal Waste Handler Separate terms are used for people who manage different wastes “UNIVERSAL WASTE HANDLER” “HAZARDOUS WASTE GENERATOR” Small Quantity Handler: A handler who, in a calendar year, generates less than 5,000 kilograms (11,000 lbs) of Universal Waste Large Quantity Handler: A handler who, in a calendar year, generates more than 5,000 kilograms (11,000 lbs) of Universal Waste

Accumulation & Labeling Handler may not accumulate for more than one year at a time Storage container must be dated and labeled to demonstrate length of accumulation - Mark each container with earliest date of UW received, or - Mark each item separately, or - Determine an inventory system (earliest/each), or - Accumulation area, earliest date, or - Another method Labels for waste items must follow one of three methods: 1) “Universal Waste: (Insert Waste Type)” 2) “ Waste (Insert Waste Type)” 3) “Used (Insert Waste Type)”

Shipping & Tracking Destinations: another UW handler or End Facility DOT Rules Apply No Hazardous Waste Manifest Required - Non UW States will need HW manifest - Comment in Line 15: “managed as Universal Waste in NE per Title 128, Chapter 25” Self Transport OK, must comply with Chapter 25 UW Transporter Requirements. Large Quantity Handler Tracking Requirements - Record receipt of shipments: name, address, amounts, types, date - Record off-site shipments: name, address, amounts, types, date Log, Invoice, Bill of Lading, Manifest, keep on file for 3 years

Recycling Containers Store the waste in the container you will ship it in. Save time and eliminate possible spills during transfer Close the Container Except When Adding or Removing Waste Mark the Container When waste is placed in a container, the container must be marked with: • a clear description of the waste; and • the date (called the accumulation start date). Protect labels: cover with clear packing tape or enclose in adhesive plastic pouch Put all marks and labels on the same side of the container Make sure labels are still readable and well attached before shipping Waste must be stored in containers or packages that are structurally sound, adequate to prevent breakage, and compatible with the contents. Such containers and packages must remain closed and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions. Containers come in several sizes and types. Please make sure you use the proper container approved for the waste you intend to store in it. Containers must be sealed at all times. Containers must be properly labeled. Common sizes of containers include: • 5 gallon; • 15 gallon; • 30 gallon; and • 55 gallon. Common types of containers include: • fiberboard drums (for solid materials destined for incineration; with a polyethylene liner, they may also be appropriate for some liquids); • steel drums (used for a variety of wastes but never corrosive wastes, including MERCURY); • polyethylene drums (used for a variety of wastes but never certain solvents that will dissolve polyethylene); and • gaylord boxes. (cubic yard sized corrugated cardboard containers) ● cardboard boxes: 2’, 4’ & 8’ lengths, used for fluorescent lamps

Recycling Mercury Containing Lamps ABOUT: Fluorescent lamps and high-intensity discharge (HID) lamps, are discouraged from landfill disposal in nearly all areas because they contain mercury. NOTE: Lancaster County landfill does not allow any CESQG waste. Even though new technology has reduced the amount of mercury in a fluorescent lamp and lamps may pass the Toxicity Characteristic Leaching Procedure (TCLP), it is encouraged that they still be recycled. HANDLING & STORAGE: Do not place used lamps in the trash. Do not break or crush lamps because mercury may be released, posing health and environmental risks. Store lamps in a manner that will prevent them from breaking. Recycling facilities request that you do not tape lamps together for storage or shipment. Lamp/Ballast Record Keeping Requirements Keep these records for a minimum of 3 years: 1. the number of lamps removed from service during each calendar year; and 2. waste-tracking invoices for ballasts and lamps. If lamps are stored off site, also keep a record of the storage location of the lamps. _____________________________________________________ Preventing Pollution: Compared to incandescent lighting, fluorescent lighting uses less energy. Less energy not only means lower lighting costs for your business, but also fewer air pollutants such as mercury, lead, nitrogen oxides and sulfur dioxide emitted by power plants. Even though fluorescent lamps contain mercury, when managed properly, they have less environmental impact on our environment than conventional incandescent lamps. Consider using fluorescent lamps whenever and where ever possible. MPCA discourages use of lamp-crushers on site. This process maybe considered ‘treatment’ which requires a facility permit, and may release mercury. HOW MUCH MERCURY IS IN A LAMP? T8 - 1 inch in diameter: 10-15 milligrams Compact Fluorescent: 5-10 milligrams Mercury vapor and metal halide: 75 watt bulb ~20 mg 1000 watt bulb~250 mg High pressure sodium:  50 watt bulb~8.3 mg 1000 watt bulb~25 mg ______________________________________________ http://www.dnr.state.mn.us/lakefind/index.html Visit the website above to find out about mercury levels in your area lakes, and fish consumption advisories

Recycling Batteries ABOUT: Battery types must be packaged separately Types of batteries Alkaline Dry Cell NiCad Nickel Metal Hydride Carbon Zinc Lead Acid Non-Spillable Wet Cell Lead Acid Wet Cell Nickel Cadmium Lithium [Lithium Polymer, Lithium Ion] Mercury Silver Oxide Each Battery Type must be packaged separately in UN Approved, plastic containers or, if large enough, firmly secured to pallets capable of withstanding the shocks normally incident to transportation.

Recycling Batteries (2) STORAGE METHOD: DO NOT mix battery types. Only chemically compatible battery types should be packed in the same package. DO Ensure that all exposed terminals are protected. Proper insulation includes taping the terminals of the batteries, Or packaging in individual plastic bags. Clear tape is preferred so that battery identification is still possible. Other forms of insulation may also be used. DO Label storage /shipping containers Acceptable methods for protecting battery terminals: DO Securely attach covers of sufficient strength to protect the terminals; DO Package in DOT Approved UN Containers. DO Package leaking batteries individually. These may require shipment as an EPA hazardous waste. DO Store batteries in a cool, dry environment. *For full battery recycling guidance download this document: http://retrofitcompanies.com/documents/battery-recycling-guidelines.pdf

Recycling Mercury Items ABOUT: Any electrical, mechanical or medical product or component (excluding batteries and lamps) containing elemental mercury, which is necessary for operation as a conductor of temperature, pressure or electricity, or which is acting as a weight damper. Mercury must be housed within an outer casing. Thermostats Electrical Switches Gauges Sphygmomanometers Thermocouples Mercury-filled pumps Thermometers and other items.

Recycling Mercury Items (2) STORAGE & HANDLING: Containerize all leaking or potentially leaking (broken) items in DOT approved, sealed, leak proof containers. When removing ampules: - prevent breakage - work over a containment device - observe OSHA requirements (ventilate!) - keep emergency cleanup kit available - immediately transfer leakage/spills to proper container (haz. waste) - train employees for proper handling - pack with material to prevent breakage

Recycling Mercury Items (3) When draining items: - allowable for open-ended items - work over a containment device - written procedure: equipment, O & M of equipment, waste management, waste characterization - observe OSHA requirements (ventilate!) - keep emergency cleanup kit available - immediately transfer drained mercury to proper container (haz. waste) - train employees for proper handling - store drained mercury in sealed, leak-proof, DOT approved poly container - document accumulation date, max amt. 45kg (100 lbs) - waste determination for residues/other wastes

Recycling Electronic Waste What is e-waste? E-waste is any waste that has a circuit board or a cathode ray tube (CRT). The list of e-wastes here are considered haz waste by NDEQ because they fail the TCLP for lead. This includes items that businesses use every day:  Monitors  Remote Controls  Televisions  Circuit Boards  Cell Phones  Smoke Detectors  Computer Mice and more… Electronics contain many recyclable commodities: Lead, Mercury, Cadmium, Steel, Copper, Plastic, Glass One CRT can contain up to seven pounds of lead Electronic scrap is the fastest growing waste stream today. Because the process of testing e-waste may be more expensive than simply managing it as a hazardous waste in the first place, most generators assume that their e-waste is hazardous. Be aware – Under the State Superfund law, businesses are liable for any mismanagement of their waste even after it leaves their control. It is much more expensive to be a party to a cleanup than to pay to properly recycle the waste Remember: if you are identified as the source of an abandoned waste, you will be a responsible party in the cleanup. 2) E-waste regulations are very likely to change in the future. Generators should monitor changes in the requirements at the county, state and federal levels. • As a generator of e-waste, you do not need to report e-waste to the MPCA or obtain a hazardous waste license if e-waste is the only hazardous waste you generate. If you are located in the seven-county Twin Cities area, contact your county environmental department to determine if licensing is required. • There is no storage time limit for a generator accumulating e-waste on-site. However, the MPCA recommends that e-waste be stored indoors. If you must store outdoors, place it in containers that will prevent release of hazardous components to the environment. Protect stored ewaste from vandalism and inadvertent damage. • The MPCA recommends that generators do not dismantle e-waste. Dismantling, especially of CRTs, can pose a safety hazard and may diminish the recycling potential. Also, generators should not break CRTs. Dispose of it correctly. Hazardous e-waste may not be disposed of as a solid waste (e.g. landfilling or incineration). Either recycle hazardous e-waste or send it to a hazardous waste disposal facility.

Avoid Electronics as Hazardous Waste. NDEQ: regulations follow EPA 40CFR (RCRA), and “Waste Computers and Monitors Guidance Document” (www.ndeq.state.ne.us) Send to “Legitimate Refurbisher” as “still usable product.” Manage as Universal Waste Never let a CRT become “WASTE”…recycle or handle as UW. If the weight of ‘waste’ CRT’s causes a facility to be a SQG, then all haz waste generated that month must also be managed under SQG Management Requirements Avoid becoming SQG by staying under 220 lbs per month of HW.

Electronic Waste & Liability Confidential Information is Your Responsibility Reformatting drives does not entirely eliminate your information, look for secure options. (effective software, physical destruction) Be aware of what happens to your disposed materials, ask for proper documentation: Certificate of Refurbishment/ Destruction/ Recycling Environmental Liability is the responsibility of both the Universal Waste Handler and the End Facility WASTE MANAGEMENT OPTIONS RECYCLE (see next slide) REFURBISH: some recyclers may offer refurbishing as a pre-cursor to recycling, find out their credentials REUSE employ old, usable equipment in new ways, if possible. DONATION: ask what happens to non-working equipment be aware of minimum specs required for agency to accept your electronics call first, don’t just drop off keep in mind that leaving non-working/unusable equipment may cause agency to become SQG Waste Management Options  RECYCLE  REFURBISH  REUSE  DONATE

Choose a Reputable Recycler 1) Competitive Pricing: “You get what you pay for…” Look for recyclers who can service your needs, meet your goals and protect you from future legal and financial liability or negative public relations! 2) Sound Practices: E-Waste Recycling is not regulated Make sure materials are being recycled, check up on end-markets, ask for references, look for recyclers with service capabilities and resources you need: - Trained Personnel - Proper Equipment - Safety Awareness - Flexibility to meet your needs - Valid Track Record - Capacity to handle wastes - Processing/Technologies/Outlets are environmentally sound

Choose a Reputable Recycler (2) 3) Risk Management: Your recycler should have you covered! Indemnification: Insurance (with Additional Insured) -Automotive, Workers Comp, Pollution Liability Financial Health: Revenue Growth, Profitability Environmental Record: Look for qualified information - Permits (Facilities and Transportation) - Compliance History - Operating Procedures - Facility Closure Plans - Regulatory Contacts - Facility Audits E-waste regulations are very likely to change in the future. Handlers should monitor changes in the requirements at the county, state and federal levels.

QUESTIONS? QUESTIONS? RESOURCES http://www.ndeq.state.ne.us http://www.wastecapne.org http://www.knb.org http://www.retrofitcompanies.com http://www.epa.gov

Thank You! Marie Magadan Retrofit Recycling, Inc. 2960 Yorkton Blvd. Little Canada, MN 55117 Toll free (800) 274-1309 Fax (651) 766-9900 www.retrofitcompanies.com recycle@retrofitcompanies.com Keeping Mercury Out of the Environment Minnesota has taken a number of steps to keep mercury out of the environment, including: Minnesota was the first state to prohibit using mercury in dry-cell batteries; The mercury from thermostats, thermometers, gauges, medical and scientific equipment, electrical devices, motor vehicles and household appliances must be removed for reuse or recycling before these products can be disposed of or scrapped; Fluorescent lamps must be disposed of at special facilities licensed to recycle the mercury; Certain toxic substances, including mercury, are prohibited in inks, dyes, pigments, paints or fungicides as well as in any packaging products; MPCA permits for incinerators include limits on the amount of mercury they may release. Other states have also adopted many of these laws. The federal government has adopted several laws to prevent mercury releases as well, including banning using mercury as an agricultural fungicide and in latex paints. What You Can Do Consumers Consumers can help keep mercury out of the environment by: Avoiding buying products containing mercury; Not discarding mercury-containing products in their household trash. Take them to your county household hazardous waste collection facility (contact your county solid waste officer for location and hours); Taking their used fluorescent bulbs to a licensed fluorescent lamp recycling facility; Checking to be sure the mercury will be removed from their appliances and cars when they are accepted for scrap; Conserving energy, which reduces the need for utilities to burn coal; Supporting other efforts to prevent mercury contamination.