1. Ohio-Specific Universal Wastes
Soon to be Proposed
Karen Hale
Hazardous Waste Program, Ohio EPA
August 10, 2017

2. Universal Wastes (UWs)
General overview of UW program
Proposed Ohio-specific UWs
Federal and State Rule Updates

3. Universal Waste Rules General - Advantages
Only applies to the named HWs
If waste is not a HW – generator doesn’t have to follow UWRs or HW rules
Promotes proper management/disposal
UW handlers can accept UWs, generated off-site, from other handlers
Encourages recycling

4. Universal Waste Rules General - Advantages
UWs do not count toward generator’s monthly HW generation rate
Requirements can be tailored to waste stream
Waste evaluation of UW is not required
Recycling encouraged (but not required)
No manifesting

5. Wastes Classified as Universal Wastes
Current UWs
Mercury containing equipment & lamps
Batteries
Recalled pesticides

6. Universal Waste Entities General Overview
Small quantity handler UW (SQHUW)
Stores <5000 kg of UW
Large quantity handler UW (LQHUW)
Stores >5000 kg of UW
May need to obtain an ID#
Transporter
Destination facility
Permitted HW facility

7. Universal Waste General Rule Components
Common components used in the UW program
Tank & container standards
Accumulation limit
Training requirement
Spill cleanup requirement
Notification
Tracking
Transporting
Waste specific management standards

8. Proposed Ohio-specific Universal Wastes

9. Universal Wastes Proposed Ohio-specific UWs
Paint
Mixture of pigment, binder and liquid; powder coatings
Forms adhering surface coating
HW due to metal content or ignitability
Paint-related wastes
A material contaminated with paint
Purge solvent
Rags, PPE, Paint scrapings

10. Universal Wastes Proposed Ohio-specific UWs
Antifreeze
Ethylene or propylene glycol
Used in heat transfer equipment or to winterize equipment
HW due to cross contamination and heavy metals
Aerosol containers
Non-empty
HW due to propellant or contents

11. UW General Standards Aerosol containers, antifreeze, PPRW
Structurally sound, compatible w/ waste, non-leaking, labelled to identify contents, kept closed
Tank Standards
Structurally sound, compatible w/ waste, non-leaking, labelled to identify contents,
Freeboard required if open top tank
Feed cutoff required for continuous feed tank
Inspection requirements

12. UW General Standards Aerosol containers, antifreeze, PPRW
Accumulation limit is one year; tracking of storage time is required
Train employees regarding the universal waste rules and emergency procedures
Spill cleanup
Stop and contain release
Cleanup release
Remove leaking unit from service

13. UW General Standards Aerosol containers, antifreeze, PPRW
Notification requirement
LQHUW required to obtain a hazardous waste identification number if facility does not already have one
SQHUW not required to obtain an ID#

14. UW General Standards Aerosol containers, antifreeze, PPRW
Tracking of UWs
Applies to LQHUW and destination facilities
As applicable, incoming and outgoing shipments of universal waste
Type and quantity of waste
Date of shipment
Name of originating handler who sent UW or name of handler to which UW is sent

15. UW General Standards Aerosol containers, antifreeze, PPRW
Transporters of UW
Transport according to U.S. DOT standards
No manifest required
Store UW < 10 days
Respond to release of UW
Transporters and handlers must send UW to another handler or destination facility

16. Antifreeze UW Management Standards
Develop procedure to prevent commingling w/ other wastes
Use dedicated collection and storage units

17. Antifreeze UW Management Standards
Handler can recycle antifreeze
Must use appropriately designed recycling equipment with sufficient processing capacity
Determine if resulting wastes are hazardous waste
Train operator regarding operation and maintenance of recycling equipment

18. Aerosol Containers UW Management Standards
Handler may puncture and crush aerosol containers
Use appropriately designed equipment with sufficient processing capacity
Collect contents of aerosol containers
Puncture & crush in a ventilated area
Protect equipment from ignition source

19. Aerosol Containers UW Management Standards
Train operators regarding proper operation and maintenance of equipment
Do not mix incompatible wastes
Determine if contents removed from aerosol container is a hazardous waste

20. Paint & Paint-Related Wastes UW Management Standards
Handler may puncture and crush paint containers
Use appropriately designed equipment with sufficient processing capacity
Collect contents of containers
Train operator regarding proper operation and maintenance of equipment
Collected paint can be classified as UW

21. Paint & Paint-Related Wastes UW Management Standards
Recycling of paint and PRWs
Collected paint can be recycled by a handler
PRWs can only be reclaimed on-site by the handler that generated the PRWs
Wastes generated from a reclamation process are not UWs
Train operator regarding proper operation and maintenance of equipment

22. State and Federal Regulatory Updates
Generator Improvements Rule
Adopted by EPA 11/18/2016
EPA was sued
EPA is in negotiations to resolve issues of concern
Ohio EPA has begun rulemaking process to adopt the rule; expected adoption early 2019

23. State and Federal Regulatory Updates
Definition of Solid Waste
Adopted by EPA in 1/13/2015
Pertains to the recycling of hazardous waste
EPA was sued; Court recently tentatively vacated two components of the rule
Verified recyclers exclusion
Legitimacy criteria 4 (toxics-along-for-the-ride)
Final court decision expected early 2018
Ohio EPA has posponed rule development for the time being

24. Future Federal Rule Development
Revise the ignitability characteristic
Pharmaceutical rule
Aerosol can rule

25. QUESTIONS?