Universal Waste Rules Tammy McConnell Ohio EPA, DERR Hazardous - - PowerPoint PPT Presentation

Universal Waste Rules

Tammy McConnell Ohio EPA, DERR Hazardous Waste Compliance Assurance Section

Learning Objectives

• What are the universal waste rules?
• How does a hazardous waste become universal waste (UW)?
• What are the Ohio-Specific UW
• What are the management standards for UW
• What can and can’t a handler do?
• Recycling is preferred, but disposal is an option

Background

What are the universal waste rules?

• Subset of hazardous waste regulations
• Intended to promote collection & recycling
• Eases certain regulatory requirements (retail stores and other generators)
• Encourages the development of municipal and commercial programs to

reduce the quantity of these wastes going to municipal solid waste landfills

• r combustors
• It does not prohibit disposal
• Ohio-Specific Universal Wastes

Background

How does a hazardous waste become a universal waste (UW)?

• Must be a hazardous waste
• Must be widespread
• Commonly found in medium to large volumes
• Exhibit low-level hazards
• Must be easily managed

Traditional Types of Universal Waste

• Discarded batteries

– Alternative option for lead acid batteries

• Hazardous waste pesticides

– Recalled or suspended under FIFRA

• Mercury-containing devices

– Includes all mercury-containing devices

• Light bulbs

– Includes incandescent, fluorescent, compact fluorescent, LED, high intensity discharge, neon, high pressure sodium, etc.

“Ohio-Specific” Universal Waste

• December 21, 2017
• Three universal waste rules became effective only within the

confines of the State of Ohio

– Antifreeze – Non-empty Aerosol Containers – Spent Paint and Related Paint Waste

Universal Waste

"Universal waste handler":

• (1) Means either of the following:
• (a) A "generator" (as defined in this rule) of universal waste.
• (b) The owner or operator of a facility, including all contiguous

property, that receives universal waste from other universal waste handlers, accumulates universal waste, and sends universal waste to another universal waste handler, to a destination facility, or to a foreign destination.

New Universal Waste

• (2) Does not mean either of the following:
• (a) A person who treats [except under paragraph (A), (C), (E),

(F), or (G) of rule 3745-273-13 of the Administrative Code, or paragraph (A), (C), (E), (F), or (G) of rule 3745-273-33 of the Administrative Code], disposes of, or recycles universal waste.

• (b) A person engaged in the off-site transportation of universal

waste by air, rail, highway, or water, including a universal waste transfer facility.

What can a UW handler do?

UW handlers are persons who may

– Generate – Receive – Store

Note: UW handlers may treat or recycle UW if authorized in the rules

What are the UW handler categories?

Two categories:

– Small quantity handlers

• Accumulates on-site less than 5,000 kilograms (11,000 pounds) of

UW (not by type) at any time.

– Large quantity handlers

• Accumulates on-site more than 5,000 kilograms (11,000 pounds)
• f UW (not by type) at any time.

– Ex Paint waste would be approximately 22 drums – T4 bulbs about 33 lbs./box approximately 333 boxes

UW handler or a Very Small Quantity Generator

If you are both a UW handler and a very small quantity generator

– If the UW and Hazardous Waste generated is less than 100 kg/mo.

• Manage all waste as hazardous

– If the UW and Hazardous Waste generated is greater than 100 kg/mo.

• Manage UW as a UW and the Hazardous Waste as a Hazardous Waste

New Universal Waste

"Destination facility" means a facility that treats, disposes of, or recycles a particular category of universal waste, except those management activities described in paragraphs (A), (C), (E), (F), and (G) of rule 3745-273-13 of the Administrative Code and in paragraphs (A), (C), (E), (F), and (G) of rule 3745-273-33 of the Administrative Code. A facility at which a particular category of universal waste is only accumulated is not a destination facility for purposes of managing that category of universal waste.

Universal Waste Rules

General - Advantages

• UWs do not count toward your HW generator status
• Waste evaluation of UW is not required
• Recycling encouraged (but not required)
• No hazardous waste manifesting required (DOT rules apply)
• HW transporter is not required

Universal Waste Rules

Common Components

– Tank & container standards – Accumulation limit – 1 year – Training requirement – Spill cleanup requirement – Notification and tracking require for LQHUWs/destination facility – Self Transport – Transportation per DOT rules

UW General Standards

Notification requirement

– LQHUW required to obtain a hazardous waste identification number if facility does not already have one

• Site ID form 9029

– SQHUW not required to obtain an identification number – Destination facilities required to have a TSD permit

UW General Standards

Tracking of UWs

– No tracking for SQHUW, but preapproval required before shipping – Applies to LQHUW and destination facilities – Incoming and outgoing shipments of UW

• Type and quantity of waste
• Date of shipment
• Name of originating handler who sent UW or name of handler to which UW is

sent

UW General Standards

Transporters of UW

– No EPA ID number required (can ship via UPS) – Transport according to U.S. DOT standards – No hazardous waste manifest required – Store UW < 10 days – Respond to release of UW

Transporters and handlers must send the UW to another handler or destination facility

Individual Ohio-Specific Standards

• Antifreeze
• Paint and
• Paint-Related Waste
• Aerosol containers

Antifreeze

“Antifreeze" means propylene glycol or ethylene glycol including aggregated batches of propylene glycol or ethylene glycol used as a heat transfer medium in an internal combustion engine; heating, ventilating, and air conditioning units; and electronics cooling applications; or used for winterizing equipment. OAC 3745-273-09 (C)

Antifreeze

A handler of universal waste shall manage universal waste antifreeze in a way that prevents releases of any universal waste

• r any component of a universal waste to the environment, as

follows: 3745-273-13, 3745-273-33

– (1) shall store antifreeze in containers or tanks that are structurally sound and compatible with the antifreeze. – (2) A container or tank that does not comply shall be overpacked or taken out of service

Antifreeze

– (3) shall keep the container closed except when adding or removing antifreeze – (4) storage of antifreeze in a tank that comply with paragraphs (B) to (H) of rule 3745-66-101 – (5) shall not commingle or contaminate antifreeze subsequent to the removal of the antifreeze from a heat exchanger or other equipment when used to winterize that equipment

66-101 regulates

– (B) Treatment in tanks – (C) Inspections – (D) Secondary containment – (E) [Reserved] – (F) Closure – (G) Ignitable and Reactive waste – (H) Incompatible waste

Antifreeze

• (6) A handler of universal waste shall develop and maintain at

the facility a procedure that describes how antifreeze will be prevented from being commingled or contaminated subsequent to removal

• (7) A handler shall use dedicated antifreeze collection and

storage containers and tanks for the management of antifreeze.

Antifreeze

Antifreeze (subsequent to generation) mixed w/used oil is classified as a used oil & subject to the used oil rules

Antifreeze reclamation

Handlers of universal waste may reclaim antifreeze provided

– (a) use commercially available equipment, or equipment specifically custom designed or retrofitted to reclaim the antifreeze – (b) use reclamation equipment that has enough processing capacity to reclaim the quantity of antifreeze received or generated by the handler within one year

Antifreeze reclamation

– (c) The handler of universal waste shall train each operator of the reclamation equipment regarding the proper operation and maintenance – (d) A handler of universal waste shall determine if the wastes generated from the reclamation of antifreeze are "hazardous wastes"

Antifreeze Release

Upon detection of a release of antifreeze

– (a) Stop the release of antifreeze – (b) Contain the released antifreeze – (c) Clean up and properly manage and dispose of the released antifreeze

Spilled universal waste antifreeze that is recovered in liquid form

• r materials used to absorb a spill of universal waste antifreeze

may be managed as universal waste antifreeze

Antifreeze Labeling

Each container or tank accumulating antifreeze shall be labeled with words that identify the contents of the container or tank, for example: used antifreeze, spent antifreeze, UW antifreeze, recyclable antifreeze. 3745-273-14

Universal Wastes

Paint and Paint-related Ohio-Specific UWs

• Paint (includes Inks)

– Mixture of pigment, binder, and liquid; powder coatings – Forms adhering surface coating – HW due to metal content or ignitability

• Paint-related wastes (Ink-related wastes)

– A material contaminated with paint – Purge solvent, Rags, PPE, Paint scrapings – HW due to metal content, F-listed, ignitability

Paint and Paint-related Ohio-Specific UW Management Standards

Handler may puncture and crush paint containers (5 gal limit)

– Use appropriately designed equipment with sufficient processing capacity – Collect contents of the containers – Train operator regarding proper operation and maintenance of equipment

Collected paint can be classified as UW

Paint and Paint-related Ohio-Specific UW Management Standards

• Recycling paint

– Paint can be reclaimed by any handler

• Paint-related waste

– Paint-related wastes can only be reclaimed on-site by the handler that generated the wastes or by a destination facility (i.e., permitted HW facility)

Paint and Paint-related Ohio-Specific UW Management Standards

• Wastes generated from the reclamation of paint or paint-

related wastes are not UWs

• Train operator regarding proper operation and maintenance of

reclamation equipment

• Tank storage in accordance with rules 3745-66-90 to 3745-66-

99 except paragraph (C) of rule 3745-66-97 for secondary containment.

Paint and Paint-related Ohio-Specific UW Tank Management Standards

Tanks Subpart J of Part 265 Rule # 3745- Rule Title Similar 40 CFR Language Current OAC Effective Date

66-90 Applicability-tanks 265.190 02/16/2009 66-91 Assessment of existing tank system’s integrity 265.191 09/05/2010 66-92 Design and installation of new tank systems or components 265.192 09/05/2010 66-93 Containment and detection of releases-tanks 265.193 10/31/2015 66-94 General operating requirements 265.194 09/02/1997 66-95 Inspections-tank systems 265.195 10/31/2015 66-96 Response to leaks or spills and disposition of leaking or unfit for use tank systems 265.196 10/31/2015 66-97 Closure and post-closure care 265.197 12/07/2004 66-98 Special requirements for ignitable waste or reactive waste- tank systems 265.198 03/24/2017 66-99 Special requirements for incompatible wastes Appendix-Examples of potentially incompatible waste 265.199

• App. V to Part 265

12/08/1988

Aerosol containers

Aerosol containers

– Non-empty containers – Above atmospheric pressure – May be HW due to propellant or contents

Aerosol containers

Satellite accumulation area (Only one for UW it is not in the Federal rule)

– One bulk container < 55 gal or a cabinet area – Container or cabinet needs labelled but not dated – Move aerosol containers to main UW storage area when container/cabinet are full

• Starts 1-year accumulation time clock

Aerosol containers

A 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

Aerosol containers

• Train operators regarding proper operation and maintenance
• f equipment
• Do not mix incompatible wastes
• Determine if contents removed from an aerosol container is a

hazardous waste;

– Exception: collected contents consisting solely of paint can be UW

Ohio-Specific UWs

Transported Out-of-State While in Ohio, the waste is a UW Upon entering another state, the waste must be classified per the receiving state’s rules

Can I use a crusher to crush my light bulbs?

• UW rules prohibit handlers from

crushing bulbs

• If you crush your bulbs, you

must manage them under the hazardous waste requirements from start to finish

Bulb Crushing

Warning about mercury…

• There is a potential for exposure to harmful mercury vapors

when bulbs are crushed.

• Crushing operations should follow the OSHA and bulb

crushers manufactures guidelines

• OSHA’s fact sheet is titled: Protecting Workers from Mercury

Exposure While Crushing and Recycling Fluorescent Bulbs.

UW Resources

Universal Waste Webpage

– http://epa.ohio.gov/derr/hazwaste/universalwaste

Links to

– Resources, Rules, Guidance's, Checklist and Contacts

Universal Waste Handler Requirement

– http://epa.ohio.gov/portals/32/pdf/UniversalWasteRequirementsTable.pdf

UW Resources

UW Resources

Key Takeaways

• Universal waste is still a Hazardous Waste
• For a VSQG the HW rules may be your best option
• Plan to meet the 1-year time frame for UW
• Check the Fact sheets
• Record keeping is important
• Call Ohio EPA if you have questions

Questions?

You can call the Hazardous Waste Compliance and Inspection Support Unit at (614) 644-2924