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Hazardous Waste Section

Hazardous Waste Section. Universal Waste. Management Standards For. Universal Waste. Universal Waste. Waste Batteries Waste Pesticides Waste Mercury - Containing Devices Waste Lamps Waste Pharmaceuticals. Universal Waste (UW) Handlers. Small Quantity Handler (SQHs)

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Hazardous Waste Section

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  1. Hazardous Waste Section Universal Waste

  2. Management Standards For Universal Waste

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

  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

  5. Universal Waste • Note: If managed as UW, waste does not count towards HW generator status • Four unbroken lamps = 1Kg (per 62-737 FAC) • DEP Notification Requirements • only required for LQHs

  6. Universal Waste • SQHs – 40 CFR 273.16 • Personnel Training: • A SQH must inform all employees who handle or have responsibility for managing UW. The information must describe proper handling and emergency procedures.

  7. Universal Waste • LQHs – 40 CFR 273.36 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.

  8. Universal Waste • SQHs – 40 CFR 273.15 (a - c) • LQHs – 40 CFR 273.35 (a - c) Accumulation Time Limits: • One Year • Longer than one year (if solely for purpose of accumulation and other requirements are met) • Accumulation Start Date, Inventory system or other method

  9. Universal Waste • SQHs – 40 CFR 273.17 (a and b) • LQHs – 40 CFR 273.37 (a and b) Response to releases: • Immediately contain releases • Perform a hazardous waste determination on residues from releases and properly manage residues

  10. Universal Waste • SQHs – 40 CFR 273.18 (a - h) • LQHs – 40 CFR 273.38 (a - h) • Off-Site Shipments: • Send UW only to a UW handler, destination facility, or foreign destination • May self-transport if complying with transporter requirements in subpart D • Comply with DOT requirements if UW is a hazmat • Before shipment, ensure that it will be received

  11. Universal Waste • SQHs – 40 CFR 273.18 (a - h) • LQHs - 40 CFR 273.38 (a - h) • Off-Site Shipments (continued): • If shipment is rejected, receive it back or ship to another destination facility • If rejecting a shipment, contact originating handler, ship to originating handler or to another destination facility • If shipment received is hazardous waste and not UW, notify EPA/DEP • If shipment received is non-hazardous, but not UW, the waste may be managed appropriately

  12. Universal Waste • SQHs – 40 CFR 273.19 – 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.

  13. Universal Waste • LQHs – 40 CFR 273.39 – Tracking UW Shipments: • UW Shipped: • 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

  14. Universal Waste Batteries

  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))

  16. Universal Waste Batteries SQH/LQH Requirements

  17. Universal Waste Batteries • SQHs – 40 CFR 273.13 (a) • LQHs – 40 CFR 273.33(a) • Managed in a way to prevent releases • Must contain leaking batteries • Container must be closed, structurally sound, and compatible • Container must lack evidence of leakage, spillage or damage

  18. Universal Waste Batteries • SQHs – 40 CFR 273.14(a) • LQHs – 40 CFR 273.33(a) • Clearly labeled: • “Universal Waste – Battery(ies)” • “Waste Battery(ies)” • “Used Battery(ies)”

  19. DOT Transport Concerns • All Batteries are subject to requirements in HMR (49 CFR 171-180) • Chemical or other materials contained in battery • Electrical potential of the battery

  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

  21. Universal Waste BatteriesSQH Improper Management

  22. Universal Waste Batteries SQH Proper Management

  23. UW pesticides

  24. Universal Waste Mercury – Containing Equipment

  25. Universal Waste Mercury – Containing Equipment

  26. 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. Universal Waste Mercury – Containing Equipment • SQHs – 40 CFR 273.13 (c) • LQHs – 40 CFR 273.33 (c) • Managed in a way to prevent releases • Contain leaking equipment in containers that are: • Closed • Structurally sound • Compatible with contents • Lack evidence of leakage • Designed to prevent escape of mercury

  28. 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. 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. Universal Waste Mercury – Containing Equipment SQH Improper Management

  31. Universal Waste Mercury – Containing Equipment • SQHs – 40 CFR 273.14 (d)(1) • LQHS – 40 CFR 273. 34(d)(1) • Clearly labeled: • “Universal Waste – Mercury - Containing Equipment” • “Waste Mercury - Containing Equipment” • “Used Mercury - Containing Equipment” • SQHs – 40 CFR 273.14 (d)(2) • LQHs – 40 CFR 273.34(d)(2) • Clearly labeled: • “Universal Waste – Mercury Thermostat(s)” • “Waste Mercury Thermostat(s)” • “Used Mercury Thermostat(s)”

  32. Universal Waste Lamps

  33. Universal Waste Lamps Requirements • SQHs – 40 CFR 273.13 (d) • LQHs – 40 CFR 273.33 (d) • Managed in a way to prevent releases • Contain lamps in containers • Closed • Not leaking • Structurally sound • Immediately clean up broken lamps and place in containers

  34. Universal Waste Lamps • SQHs – 40 CFR 273.14 (e) • LQHs – 40 CFR 273.34(e) • Clearly labeled: • “Universal Waste – Lamp(s)” • “Waste Lamp(s)” • “Used Lamp(s)”

  35. Universal Waste Lamps – Improper Management

  36. Universal Waste Lamps – Improper Management

  37. Universal Waste Lamps – Proper Management

  38. Universal Waste Lamps Improper Response to Releases

  39. Universal Waste Lamps Improper Response

  40. Universal Waste Lamps Improper Response

  41. Universal Waste LampsBulb Crushers

  42. Bulb Crushers • 62-737.400(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 manufacturer’s instructions (filter change outs and operator training)

  43. Universal Waste LampsBulb Crushers

  44. Universal Waste Lamps – Improper Management

  45. Universal Waste Lamps – Improper Management

  46. Universal Waste Pharmaceuticals

  47. UPW • SQH of Universal Pharmaceutical Waste no longer need to notify

  48. Questions?

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