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Common RCRA Violations, and Universal Waste Mgt.
at DoD Facilities
Presented by: Rhonda J. Rollins
(404) [email protected]
Overview
RCRA Issues Common to DoD FacilitiesUniversal 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 containersUnlabeled containers – requires
“Hazardous Waste” or its contentsContainers not dated
Records Mgt. Inspection Logs – 264.15(d)Contingency Plan – 265.51 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 62-730.186 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
LampsLamps
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 260-272
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 HandlersSQHUWs 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
EPAIdentification NumberOn-SiteAccumulationLimitManifest
EmployeeTraining
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
WasteManagement
Labeling/Marking
AccumulationTime 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 (§273.11 or §273.31)
Must manage universal waste in a way that prevents releases into the environment -specific standards apply to each type (§273.13 or §273.33)
Must label or mark universal waste or containers of universal waste to identify universal waste type (§273.14 or §273.34)
One year unless for proper recovery treatment or disposal (§273.15 or §273.35)
Must immediately contain releases and handle residues appropriately and make hazardous waste determination on material resulting from release (§273.17 or §273.37)Must send universal waste only to other handlers, destination facilities, or foreign destination (§273.18 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:NeurotoxinCan 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 1st 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
www.lamprecycle.org – 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 1st 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.)
www.rbrc.com – 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: Containerize
L: Label
D: Date
C: Contain spills
CRTs
Effective Jan. 29, 2007CRTs 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 261.39
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) 562-8604
FL: Alan Annicella, Florida (404) 562-8610
GA: Parvez Mallick, Georgia (404) 562-8594
KY: William Kappler, Kentucky (404) 562-8498
MS: Lonnie Jenkins, Mississippi (404) 562-8532
NC: Nancy McKee, North Carolina (404) 562-8674
SC: Alan Newman, South Carolina (404) 562-8589
TN: John Goodwin, Tennessee (404) 562-8488
Questions?Comments?