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 or 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) of 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 or 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 or 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
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