Karen HaleHazardous Waste Program, Ohio EPA

September 27, 2017

Rules Proposed Sept. 11, 2017

The public hearing is Oct.17,2017 @

10:30, Ohio EPA Central Office

Comment period on proposed rules

closes October 17, 2017

NOTE: Comments and questions raised

during this webinar will not be

considered official comments to the

proposed rule

To submit official comments, please

email comments to:

Karen.hale@epa.ohio.gov

General overview of UW program

Proposed Ohio-specific UWs

› Non-empty aerosol cans

› Antifreeze

› Paint and paint-related wastes

Only applies to the named hazardous

wastes› If waste is not a hazardous waste (HW) – generator doesn’t

have to follow universal waste rules or HW rules

Promotes proper management/disposal

Encourages recycling

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 hazardous waste manifesting required

Current Universal Wastes

› Mercury containing equipment

› Hazadous lamps

› Batteries

› Recalled pesticides

Small quantity handler UW (SQHUW)

› Stores <5000 kg of UW

Large quantity handler UW (LQHUW)

› Stores >5000 kg of UW

UW Transporter

Destination facility

› Is a permitted HW facility

Common components used in the UW

program

› Tank & container standards

› Accumulation limit

› Training requirement

› Spill cleanup requirement

› Notification

› Tracking require for LQHUWs/destination fac.

› Transportation per DOT

› Waste specific management standards

Paint

Paint-related wastes

Antifreeze

Non-empty aerosol cans

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

› HW due to metal content, corrosivity,

ignitbility

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 containers

› HW due to propellant or contents

Containers› Structurally sound, compatible w/ waste, non-

leaking, labelled to identify contents, and kept

closed

Tank Standards› Structurally sound, compatible w/ waste, non-

leaking, labelled to identify contents,

› Specific tanks requirements are applicable

› Inspection requirements

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

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

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

Transporters of UW

› 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 UW

to another handler or destination facility

Develop procedure to prevent

commingling w/ other wastes

Use dedicated collection and storage

units

Antifreeze (subsequent to generation)

mixed w/used oil is classified as a used

oil & subject to the used oil rules

A 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

Satellite accumulation area

› 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 bulk container/cabinet

area full

Now date storage container

Starts 1-year accumulation time clock

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

Train operators regarding proper

operation and maintenance of

equipment

Do not mix incompatible wastes

Determine if contents removed from an

aerosol container is a hazardous waste; it

is not a UW

› Exception: collected contents consisting

solely of paint can be UW

Some aerosol containers should not be

punctured due to contents

› Insecticides

› Expanding foam

› Adhesives

› Pepper spray

› Reactives

Handler may puncture and crush paint

containers

› 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

Recycling paint and paint-related waste

› Paint can be reclaimed by any handler

› 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)

Wastes generated from the reclamation

of paint or paint-related wastes are not

UWs

Train operator regarding proper

operation and maintenance of

reclamation equipment

While in Ohio, the waste is a UW

Upon entering another state, classify

waste per the receiving state’s rules

If receiving state adopted 2015 Definition

of Solid Waste rule:

› waste will likely be classified as a HW in the

receiving state; check w/ receiving state

Definition of Solid Waste Rule

› Adopted by USEPA in 1/13/2015

› Pertains to the reclamation of HW

› USEPA was sued; Court 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 postponed rule development

for the time being

Generator Improvements Rule

› Adopted by USEPA 11/18/2016

› USEPA was sued

› USEPA is in negotiations to resolve issues of

concern

› Ohio EPA has begun rulemaking process to

adopt the rule; expected adoption early

2019

Federal

› Revise the ignitability characteristic

› Pharmaceutical rule expected Spring 2018

› Universal waste aerosol can rule

Ohio

› State-specific exclusion for HW

contaminated textiles that are laundered

› Solvent contaminated wipes are not eligible

Please pardon the pause and stay with us

We are reviewing your questions

We will return shortly

For more information, please contact

Karen.hale@epa.ohio.gov