PAPER MINIMIZE HAZARDOUS WASTE DISPOSAL BY RECYCLING UNIVERSAL WASTES BATTERIES MERCURY PESTICIDES LAMPS
How to Minimize Your Hazardous Waste Disposal by Recycling Universal Wastes Recycling isn t just for soda cans and cardboard. Did you know that you can also recycle some hazardous industrial wastes? The Environmental Protection Agency (EPA) encourages facilities to look for recycling options for every waste stream they generate. To sweeten the deal, facilities that choose to recycle certain types of hazardous wastes instead of disposing of them are eligible for streamlined management requirements and other benefits, such as lower hazardous waste generator status and limited future liability. Recycling also minimizes the volume of common hazardous wastes entering landfills and commercial incinerators. The Universal Waste Rule [40 CFR 273] is one example of EPA s effort to help facilities recycle hazardous wastes. Eligible universal wastes include batteries, pesticides, mercury-containing equipment and mercury lamps. Wastes managed under the Universal Waste Standard also don t count toward the facility s hazardous waste generator status. Each of these wastes has a hazardous component that would traditionally subject it to full management and regulation under the EPA s Resource Conservation Recovery Act (RCRA). But, because the hazardous component in each of these waste streams can be effectively recycled and reused, the EPA provides less stringent management rules for these wastes for facilities that choose to recycle them. Recycling helps keep countless tons of wastes out of landfills and recovers materials for reuse in new products. In this paper, we ll look at the four types of universal wastes that are eligible for relaxed management standards under the Universal Waste Rule when they will be recycled. We ll also cover how to properly manage each waste for recycling. Recycling minimizes the volume of common hazardous wastes entering landfills and commercial incinerators. 2
General Requirements for Universal Waste Recycling Although the management standards for universal wastes are relaxed, facilities are still responsible for managing these wastes in a way that won t harm the environment. Employees must also be trained on the facility s specific handling procedures to ensure that the hazardous materials aren t released to the environment. Each universal waste stream has requirements that are specific to the waste stream, but there are some commonalities, such as storing universal wastes in containers that are: Structurally sound Properly labeled Compatible with the materials stored Closed when materials are not being added or removed Not leaking Generators must also be prepared to respond to releases and manage any spills, leakage and related wastes as hazardous waste. Universal wastes may be stored onsite for up to one year unless the generator can show that a longer time is needed to accumulate enough waste necessary to facilitate proper recycling. Continue reading to learn how to manage four haz waste streams as universal waste. 3
1. Batteries Many different types of batteries are eligible for universal waste management. The rule defines a battery as a device consisting of one or more electrically connected electrochemical cells which is designed to receive, store and deliver electric energy. Some examples include: Alkaline Mercuric-oxide Alkaline-manganese Zinc carbon nickel cadmium (Ni-Cad) Button cell Silver oxide Lithium ion (Li-Ion) Not all batteries are universal wastes. For example, lead acid batteries that can be managed by 40 CFR 266 (spent automotive batteries that are going to be reclaimed) are ineligible. Different types and styles of batteries may be stored together. The terminals of each battery should be taped or otherwise shielded to prevent unintended discharges and fires while the batteries are in storage or being transported. Individual battery cells may be opened to remove the electrolyte, but must be resealed as soon as the electrolyte has been removed. Any electrolyte that has been removed is not a universal waste and must be properly managed. 4
1. 2. Assessing Pesticides Hazards Waste pesticides that prevent, destroy, repel or mitigate pests or formulas that regulate exfoliated or desiccated plants are pesticides that may be managed under universal waste rule [40 CFR 273.9]. Examples include: Recalled, suspended and canceled pesticides that are part of a voluntary or mandatory recall Pesticides that are not in compliance with the Federal Insecticide, Fungicide, Rodenticide Act (FIFRA) Unused pesticides that are collected and managed as part of a waste pesticide collection program More than 25,000 different types of pesticides are available in the United States, and more than one billion pounds are used each year. Proper management helps to prevent these materials from contaminating water and soil. Pesticides may be managed in either containers or tanks that are nonleaking, properly labeled and compatible with pesticides being stored. 1. 3. Assessing Mercury-Containing Hazards Equipment Because batteries and lamps are specifically designed as universal wastes, they are not managed as mercury-containing equipment. The devices that may be managed as mercury-containing equipment have elemental mercury somewhere inside them to function properly. Examples include: Thermostats Thermometers Mercury switches Ballasts Barometers Manometers The mercury in these devices is contained in ampules. Under universal waste management standards, ampules may be managed intact in the device that contains them or the ampules may be removed from the device if it can be done so without damaging the ampule. Facilities that choose to remove mercury ampules must properly train their personnel, perform the removal over a containment device and ensure that the area is properly ventilated. Broken mercury ampules must be properly cleaned up and managed under RCRA standards. 5
4. Lamps Unlike mercury-containing equipment, facilities are not permitted to remove mercury from lamps. The lamps must be kept intact to qualify for management as universal waste. Although different styles or lengths of lamps may be managed together, it can sometimes be more difficult to do this without the risk of breaking the lamps. The universal waste management requirements are clear about the bulbs remaining intact if facilities are going to manage them as a universal waste. Crushing bulbs can help some facilities better manage the amount of space required to store them, but it disqualifies the lamps for management as universal waste and makes them subject to full RCRA regulation as a hazardous waste. 6
State Adoption The federal Universal Waste Rule was published in 1995. States were encouraged to adopt it, but because it is less stringent than RCRA Hazardous Waste Generator Regulations, state adoption is not mandatory. Because of this, universal waste management rules vary among the states. Some have adopted the federal regulation in its entirety, some have adopted portions of the rule, some have modified the rule and others have not adopted it at all. It is important to know the requirements for the state where the wastes will be generated. The EPA provides this chart to help facilities determine where the rule is applicable. STATE BATTERIES PESTICIDES MERCURY- CONTAINING EQUIPMENT LAMPS Alabama X X X X STATE ADDITIONS STATE REGULATORY CITATION DIVISION 14 335-14-11 Alaska (uses Federal regulations) X X X X Arizona X X X X R18-8-273 Arkansas X X X X consumer electronic items; cathode ray tubes (CRTs) and other electronic wastes Regulation 23 (excludes broken and crushed lamps/debris) California X X thermostats; waste cathode ray tube R-97-08 materials Colorado X aerosol cans; electronic devices and electronic components Connecticut X X X Delaware X X X X District of Columbia X X X X Florida X X X X thermostats; lamps; used electronics universal pharmaceutical waste 22a-449(c)-100 through 119 62-730.185 Georgia X X X X 391-3-11-.18 Hawaii X X X X thermostats 11-273 Idaho X X 58.01.05.016 Illinois X X X X Part 733 7
State Adoption (continued) STATE BATTERIES PESTICIDES MERCURY- CONTAINING EQUIPMENT LAMPS Indiana X X X X Iowa (uses Federal regulations) X X X X Kansas X X X X STATE ADDITIONS discarded mercurycontaining thermostats; lamps; prohibition against intentionally breaking or crushing STATE REGULATORY CITATION Kentucky X X X X Chapter 43.10 Louisiana X X X X electronics; antifreeze Maine X X Maryland X X X X Massachusetts X X X Michigan X X X X cathode ray tubes; mercury thermostats; motor vehicle mercury switches; totally enclosed, nonleaking polychlorinated biphenyl (PCB) ballast fluorescent light ballasts that contain polychlorinated biphenyls (PCBs) mercury-containing devices antifreeze; consumer electronics; electric lamps; devices containing elemental mercury (including thermostats, switches, thermometers, manometers, barometers, antilocking braking systems (ABS), gas flow regulators, hydrometers, blood pressure cuffs and various medical devices, etc.); pharmaceuticals, including drugs for both human and veterinary use Title 33 Part V Chapter 38 310 CMR 30.000 8
State Adoption (continued) STATE BATTERIES PESTICIDES MERCURY- CONTAINING EQUIPMENT LAMPS STATE ADDITIONS STATE REGULATORY CITATION Minnesota X X X X Mississippi X X X X HW-1 Missouri X batteries 10 CSR 25-16.273 Montana X X X X requirements for treatment of electric lamps Nebraska X X X X electronic items ARM 17.53 SubChapter 13 Chapter 25 of Title 128 Nevada New Hampshire X X X X cathode ray tubes; waste antifreeze Env-Hw 1100 New Jersey X X X X oil-based finishes; consumer electronics N.J.A.C. 7:26 Subchapter 1 New Mexico New York X X X thermostats 374-3.1 North Carolina X X X X 13A.0119 North Dakota Ohio X X X X OAC 3745 Chapter 273 Oklahoma X X X X 252:205 Oregon X X X X 340-113-0000 Pennsylvania X X X X oil-based finishes CHAPTER 266b Rhode Island X X X X South Carolina thermostats; cathode ray tubes DEM OWM- HW01-07 South Dakota 74:28:33:01 9
State Adoption (continued) STATE BATTERIES PESTICIDES MERCURY- CONTAINING EQUIPMENT LAMPS STATE ADDITIONS STATE REGULATORY CITATION Tennessee X X X X 1200-01-11-.12 Texas X X X X mercury-containing equipment, including thermostats; paint and paint-related waste Title 30 Part1 Chapter 335 Sub Chapter H, 5 335.261 Utah X X X thermostats R315-16 Vermont X X X X Virginia X X X X thermostats; PCBcontaining fluorescent light ballasts; cathode ray tubes Universal waste lamps may be crushed or intentionally broken on the site of generation to reduce their volume; however, breaking, crushing, handling, and storage must occur in a safe and controlled manner that minimizes the release of mercury to the workplace and the environment and must comply with 29 CFR 1910.1000. SUBCHAPTER 9 9VAC20-60-273. Washington X X X WAC 173-303-573 West Virginia X X X X 33-20-13 Wisconsin X X X thermostats NR 673 Wyoming X X X X Ch. 14 Source: EPA Recognizing universal wastes and managing them under this standard helps to reduce the volume of hazardous waste entering landfills and prevents harmful air emissions at combustion facilities. It also helps to preserve resources and protect the environment. 10
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