Common RCRA Violations, and Universal Waste Mgt. at DoD Facilities Presented by: Rhonda J. Rollins (404)

Overview RCRA Issues Common to DoD Facilities Universal Wastes What is their Purpose? What are They? How Do We Manage Them ? CRTs Contact Info Questions

Common RCRA Regulatory Issues in DoD Facilities Container Mgt (90 Day Storage and SAAs)  Open containers  Unlabeled containers – requires “Hazardous Waste” or its contents  Containers not dated Records Mgt.  Inspection Logs – (d)  Contingency Plan – thru.54 (include everything, KEEP UPDATED, send out)

Other Common Issues  Used Oil / Universal Waste Mgt. (label & date it!) -273 & 279  Keep in CLOSED containers (esp. lamps)  Waste determination

Universal Waste Characteristics Four types of Federal universal wastes:  Universal waste categories must be hazardous waste before they can be designated as universal wastes  States can add addt’l universal wastes  Florida recently added pharmaceutical wastes  FAC Universal Pharmaceutical Waste (effective 4/22/07)

Purpose of Universal Waste Rules The universal waste rule streamlines the hazardous waste regulations by:  reducing barriers to collection programs  reducing complexities  reducing cost of compliance  reduces volume of waste going to landfills or incinerators.

What are Universal Wastes? Batteries Lamps Mercury Containing Equipment Pesticides

Examples  Waste Lamps – May include fluorescent, high- pressure sodium, mercury-vapor, metal-halide, high intensity discharge, and incandescent  Batteries – May include Lead-acid, Nickel- cadmium, Lithium, and others  Mercury containing equipment – May include thermostats, barometers, manometers, temperature and pressure gauges, and mercury switches  Pesticides – Resulting from a pesticide recall, or unused pesticides collected as part of a waste pesticide collection program

Options to Manage These Wastes  Can be managed as Hazardous wastes under 40 CFR 262 OR  Managed as Universal Wastes under 40 CFR 273 (much less stringent) Note: the rule provides an alternative set of management standards in lieu of more stringent regulation under parts

Who is exempt from the Regs?  Households - excluded under §261.4(b)(1)  Conditionally exempt small quantity generator (CESQG) - (<100 kg, 220 lbs, approx. 300 gallons per month)-  exempt under §261.5 Note: These wastes can be managed under the universal waste rule if preferred. EPA encourages voluntary recycling even for exempt entities.

Is Military Housing A Household?  It depends….  Facilities (typically maintenance), still responsible for universal waste management.

Universal Waste Performance Standard (Part 273)  Universal wastes must be managed to prevent releases to the environment (e.g. mercury emissions).  Containment  Labeling  Accumulation  Off site management  Record keeping

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

Universal Waste Handlers SQHUWs  Accumulate ≤5,000 kg (11,000 lbs)  No EPA ID #  Label containers  Train employees  No shipping records  Accumulate no longer than 1 year LQHUWs  Accumulate >5,000 kg  Must get EPA ID #  Label containers  Train employees  Keep shipping records for 3 years  Accumulate no longer than 1 year

Classification EPA Identification Number On-Site Accumulation Limit Manifest Employee Training 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) SQHUW (part 273 subpart B) LQHUW (part 273 subpart C) Universal Waste Handler Requirements

Prohibitions Waste Management Labeling/ Marking Accumulation Time Limit Response to Releases Shipments SQHUW and LQHUW (part 273 subparts B and C) Disposing of, diluting, or treating universal waste - although some exceptions apply (§ or §273.31) Must manage universal waste in a way that prevents releases into the environment -specific standards apply to each type (§ or §273.33) Must label or mark universal waste or containers of universal waste to identify universal waste type (§ or §273.34) One year unless for proper recovery treatment or disposal (§ or §273.35) Must immediately contain releases and handle residues appropriately and make hazardous waste determination on material resulting from release (§ or §273.37) Must send universal waste only to other handlers, destination facilities, or foreign destination (§ or §273.38) Universal Waste Handler Requirements

What NOT to Do!

Overview of Universal Waste Regs Must be containerized (if applicable) Must be labeled ONE OF THESE ONLY…: “Universal Waste ______”, “Waste _____”, or “Used ______.” Can be accumulated or stored up to one year. Must be able to prove time onsite.

Overview (cont’d) Must be shipped to another handler or a destination facility, under DOT shipping regs. Must clean up and containerize spills/breaks. Train employees in handling No hazardous waste manifest needed

Mercury (Hg)-Lamps, Equipment Approx. 670 million fluorescent bulbs discarded yearly in U.S. Of these, only about 23% are recycled, leaving 77% to be land filled or incinerated  Hg is:  Neurotoxin  Can bioaccumulate in tissues

Waste Lamps (usually fluorescent)  Spent waste lamps must be:  Stored in containers that are structurally sound, to prevent breakage  Boxes must remain closed  Labeled “Universal Waste Lamps” or “Waste Lamps,” or “Used Lamps”  Stored onsite less than one year (Recommend dating the container, from 1 st lamp)  Must immediately clean up and containerize broken lamps.

What about Green Tips?  Green tips still contain mercury  Numerous states ban any mercury containing lamps in landfills, regardless of TCLP.  Best to recycle under Universal Waste Rules.  If you claim non-hazardous, be ready to prove (e.g. MSDS, etc.)  environmentally-safer lamps = Request mercury content info and choose the lowest mercury models

Crushing Lamps- Is it Allowed Under Universal Waste?  NO.  Incidental breakage must be containerized = still universal waste.  Intentional breakage = HAZARDOUS waste. Must manage under 40 CFR 262.

P2 Options- Lamps  Use mercury-free lighting (e.g. LED or Hg- free high pressure sodium vapor lamps).  Use low-Hg lamps with longest life rating  Extend lamp life by encouraging conservation  Install motion sensors  – List of lamp recyclers by state, + addt’l info.

Waste Battery Mgt.  Spent batteries must be:  Labeled “Universal Waste Battery(ies)” or “Waste Battery(ies),” or “Used Battery(ies)”  Stored onsite less than one year (Recommend dating the container/pallet, from 1 st battery)  Must immediately clean up and containerize broken batteries. Note: Lead-acid batteries can also be managed under 40 CFR 266 Subpart G, IF being recycled..

P2 Options – Batteries  Use rechargeable batteries to reduce disposal frequency  Where possible, use solar battery re-chargers to further reduce energy usage (e.g. AA, cell phones, etc.)  – Links to collection sites for battery recyclers, Call2Recycle Program

Mercury Containing Equipment  Includes thermostats, barometers, manometers, temperature and pressure gauges, mercury switches, AND any other equipment that may fail TCLP for mercury  Likely in labs, power plant areas, medical segments, etc.

Examples of Hg Containing Equipment (not all inclusive) Barometer Manometer Mercury switch Thermostat Pressure Gauge

Mercury Handlers (Continued) All handlers of mercury equipment:  Must package and label the equipment- (e.g. “Universal Waste—Mercury Containing Equipment,” “Universal Waste—Mercury Thermostat(s)”, etc)  May accumulate it on-site for one year.  Must train employees for handling and emergencies.

Handlers (Continued) 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.

Pesticides  Store in tank, container or vehicle that prevents spill  Labeled “Universal Waste-Pesticides” or “Waste-Pesticides,” or “Used Pesticides”  Can accumulate for up to one year Note: Only pesticides which are suspended or canceled as part of a recall, and unused pesticides collected as part of a waste pesticide collection program are covered by this Rule.

Recap of Universal Wastes C.L.D.C. C: C ontainerize L: L abel D: D ate C: C ontain spills

CRTs  Effective Jan. 29, 2007  CRTs sent for recycling = exempt from 40 CFR 262 or Universal Waste (includes broken & unbroken)  CRTs sent for disposal (e.g. to a landfill or incinerator) = fully regulated as hazardous wastes (assuming they test hazardous)

IF Recycling…40 CFR Used, broken CRTs must be:  Stored in a building or in a container  Labeled: “Used cathode ray tubes(s)-contains leaded glass” OR “Leaded glass from televisions or computers”  Must also be labeled: “Do not mix with other glass materials”

Region 4 RCRA Enforcement and Compliance Coordinators  AL: Brian Gross, Alabama (404)  FL: Alan Annicella, Florida (404)  GA: Parvez Mallick, Georgia (404)  KY: William Kappler, Kentucky (404)  MS: Lonnie Jenkins, Mississippi (404)  NC: Nancy McKee, North Carolina (404)  SC: Alan Newman, South Carolina (404)  TN: John Goodwin, Tennessee (404)

Questions? Comments?