Facility: Date: UNIVERSAL WASTE CHECKLIST Note: The Oklahoma Hazardous Waste Management Regulations [OK Adm. Code (OAC) 252:205] incorporates by reference at OAC 252:205-3-2 the applicable federal hazardous waste and used oil regulations of 40 CFR 260-279. Additional state regulations of OAC 252:205 are further identified. 40 CFR Part 273 provides an alternative set of management standards in lieu of regulation under 40 CFR parts 260 through 272 for managing universal wastes. This checklist is applicable to universal waste management standards for batteries as described in 40 CFR 273.2; pesticides as described in 40 CFR 273.3; and thermostats as described in 40 CFR 273.4. EPA ID# Section A - Applicability (Subpart A) 1. What universal waste is/are managed? Batteries [273.2] Pesticides [273.3] Thermostats [273.4] 2. Which type of universal waste handler is the facility? [273.6] (Circle as appropriate) -Small Quantity Handler -Transfer Facility -Destination Facility -Large Quantity Handler -Transporter Note: Universal Waste Destination Facilities are regulated in accordance with full RCRA hazardous waste requirements even when managing universal wastes. Accordingly, facilities recycling universal wastes are subject to the same regulation as any other hazardous waste recycler. Typically, Universal Waste Destination Facilities are existing hazardous waste Treatment/Storage/Disposal Facilites subject to 40 CFR 264, 265, 266, 268, 270, and 124. Section B - Small Quantity Handler of Universal Waste (Subpart B) A Universal Waste Handler who does not accumulate more than 5,000 kgrams total of universal wastes at any time. 1. Has Handler disposed of Universal Waste? [40 CFR 273.11(a)] If yes, where? _ 2. Has Handler diluted or treated Universal Waste? [40 CFR 273.11(b)] If yes, how? Page 1 of 10 Rev. 2/99
Facility: Date: Waste Management (273.13) Batteries 3. Has the Handler managed the Universal Waste Batteries in a manner that prevents releases to the environment? [40 CFR 273.13(a)] (a) Has the Handler contained any universal waste batteries, that show evidence of leakage or damage, in a compatable/closed container? [273.13(a)(1)] (b) Has Handler conducted the following activities: [273.13(a)(2)] - sorting batteries by type, - mixing battery types in one container, - discharging batteries, - regenerating used batteries, - disassembling batteries or battery packs, - removing batteries from consumer products, - removing electrolytes from batteries. Pesticides (c) Has the Handler determined if the material/residue resulting from processing of the batteries or from any releases is hazardous waste, and if so, has the handler managed the material/residue as a hazardous waste? [273.13(a)(2) &(3)] 4. Has the Handler managed the Universal Waste Pesticides in a manner that prevents releases to the environment? [40 CFR 273.13(b)] (a) Has the Handler used compatable/closed containers? [273.13(b)(1)] (b) Has the Handler overpacked any damaged containers? [273.13(b)(2)] Page 2 of 10 Rev. 2/99
Facility: Date: (c) Has the Handler used a Tank that meets the requirements of 40 CFR Subpart J? [273.13(b)(3)] (d) Had the Handler used a compatible/closed transport vehicle? [273.13(b)(4)] Thermostats 5. Has the Handler managed the Universal Waste Thermostats in a manner that prevents releases to the environment? [40 CFR 273.13(c)] (a) Has the Handler used compatable/closed containers? [273.13(c)(1)] (b) Has the Handler processed the thermostats in a manner designed to prevent breakage and prevent releases in the event of breakage? [273.13(c)(2)] (c) Has the Handler determined if the material/residue resulting from processing of the thermostats or from any releases is hazardous waste, and if so, has the handler managed the material/residue as a hazardous waste? [273.13(c)(3)] Batteries, Pesticides, Thermostats 6. Has the handler properly labeled/marked the universal waste? [273.14] Batteries each battery or container of batteries must be labeled or marked clearly with one of the following phrases: Universal Waste-Battery(ies), or Waste Battery(ies), or Used Battery(ies). [273.14(a)] Pesticides each container (or multiple container package unit), tank, transport vehicle or vessel must be labeled or marked clearly with the following: the label originally on the product when sold and the words Universal Waste-Pesticide(s) or Waste-Pesticide(s). [273.14(b) & (c)] Page 3 of 10 Rev. 2/99
Facility: Date: Thermostats - each thermostat or container of thermostats must be labeled or marked clearly with one of the following phrases: Universal Waste-Mercury Thermostat(s), or Waste Mercury Thermostat(s), or Used Mercury Thermostat(s). [273.14(d)] 7. Has the handler adequately demonstrated the length of time the Universal waste has been stored? [273.15(c)] -Marking containers with the date the waste was generated/received, OR -Marking each individual item with the date the waste was generated/received, OR -Maintain an inventory system showing date waste was generated/received, OR -Placing waste in specific area, identify date waste put in that area, OR -Other method clearly showing length of time waste has been accumulating. 8. Has the Universal Waste been stored on-site less than one year? [273.15] If No, handler must prove the longer storage is necessary to facilitate proper recovery or treatment. 9. Has the handler provided employee training? [273.16] 10. Has handler sent universal waste only to another universal waste handler, a destination facility or a foreign destination? [273.18(a)] List name/ EPA ID# of facilities receiving waste. _ 11. Has handler followed DOT regulations for off-site shipments? [273.18(c)] 12. Has handler ensured (prior to shipment) that receiving handler agrees to receive the shipment? [273.18(d)] Page 4 of 10 Rev. 2/99
Facility: Date: 13. Has Universal Waste been limited to management in the U.S.? [273.20] If No, (i.e. Exported) has handlers? -complied with 40CFR262.53, 262.56(a)(1)-(4), (6), and (b), and 262.57 -export only upon consent of receiving country -provide EPA Acknowledgement of Consent for shipment to Transporter Section C - Large Quantity Handler of Universal Waste (Subpart C) A Universal Waste Handler who accumulates 5,000 kilograms or more (total) of universal wastes at any one time. This designation is retained through the end of the calendar year in which the 5,000 kilograms or more total universal waste is accumulated. 1. Has Handler disposed of Universal Waste? [40 CFR 273.31(a)] _ 2. Has Handler diluted or treated Universal Waste? [40 CFR 273.31(b)] Waste Management (273.33) Batteries _ 3. Has the Handler managed the Universal Waste Batteries in a manner that prevents releases to the environment? [40 CFR 273.33(a)] (a) Has the Handler contained any universal waste batteries, that show evidence of leakage or damage, in a compatable/closed container? [273.33(a)(1)] (b) Has the Handler determined if the material/residue resulting from processing of the Page 5 of 10 Rev. 2/99
Facility: Date: batteries or from any releases is hazardous waste, and if so, has the handler managed the material/residue as a hazardous waste? [273.33(a)(2) &(3)] Pesticides 4. Has the Handler managed the Universal Waste Pesticides in a manner that prevents releases to the environment? [40 CFR 273.33(b)] (a) Has the Handler used compatable/closed containers? [273.33(b)(1)] (b) Has the Handler overpacked any damaged containers? [273.33(b)(2)] (c) Has the Handler used a Tank that meets the requirements of 40 CFR Subpart J? [273.33(b)(3)] (d) Had the Handler used a compatible/closed transport vehicle? [273.33(b)(4)] Thermostats 5. Has the Handler managed the Universal Waste Thermostats in a manner that prevents releases to the environment? [40 CFR 273.33(c)] (a) Has the Handler used compatable/closed containers? [273.33(c)(1)] (b) Has the handler processed the thermostats in a manner designed to prevent breakage and prevent releases in the event of breakage? [273.33(c)(2)] (c) Has the Handler determined if the material/residue resulting from processing of the thermostats or from any releases is hazardous waste, and if so, Page 6 of 10 Rev. 2/99
Facility: Date: has the handler managed the material/residue as a hazardous waste? [273.33(c)(3)] Batteries, Pesticides, Thermostats 6. Has the Handler properly labeled/marked the universal waste? [273.34] Batteries each battery or container of batteries must be labeled or marked clearly with one of the following phrases: Universal Waste-Battery(ies), or Waste Battery(ies), or Used Battery(ies). [273.34(a)] Pesticides each container (or multiple container package unit), tank, transport vehicle or vessel must be labeled or marked clearly with the following: the label originally on the product when sold and the words Universal Waste-Pesticide(s) or Waste-Pesticide(s). [273.34(b) & (c)] Thermostats - each thermostat or container of thermostats must be labeled or marked clearly with one of the following phrases: Universal Waste-Mercury Thermostat(s), or Waste Mercury Thermostat(s), or Used Mercury Thermostat(s). [273.34(d)] 7. Has the Handler adequately demonstrated the length of time the Universal waste has been stored? [273.35(c)] -Marking containers with the date the waste was generated/received, OR -Marking each individual item with the date the waste was generated/received, OR -Maintain an inventory system showing date waste was generated/received, OR -Placing waste in specific area, identify date waste put in that area, OR -Other method clearly showing length of time waste has been accumulating. 8. Has the Universal Waste been stored on-site less than one year? [273.35] If No, handler must prove the longer storage is necessary to facilitate proper recovery or treatment. 9. Has the Handler provided employee training? [273.36] 10. Has Handler sent universal waste only to Page 7 of 10 Rev. 2/99
another universal waste handler, a destination facility or a foreign destination? [273.38(a)] Facility: Date: List name/ EPA ID# of facilities receiving waste. _ 11. Has Handler followed DOT regulations for off-site shipments? [273.18(c)] 12. Has Handler ensured (prior to shipment) that receiving handler agrees to receive the shipment? [273.38(d)] 13. Has Universal Waste been limited to management in the U.S.? [273.40] If No, (i.e. Exported) has handlers? -complied with 40CFR262.53, 262.56(a)(1)-(4), (6), and (b), and 262.57 -export only upon consent of receiving country -provide EPA Acknowledgement of Consent for shipment to Transporter 14. Has written notification of Universal Waste management been submitted and an EPA Identification number received before meeting or exceeding the 5,000 kilogram storage limit? [273.32(a)(1)] 15. Does the notification include: Handler name and mailing address, contact name and telephone, physical location of activity, list of types of waste handled, a statement that the 5,000 kilogram limit has been exceeded? [273.32(b)] 16. Does Handler track each shipment of Universal Waste received showing the name/address of the originator, quantity of waste received and date of receipt (record can be in the form of a log, invoice, manifest, bill of lading, or other shipping document)? [273.39(a)] Page 8 of 10 Rev. 2/99
Facility: Date: 17. Does Handler track each shipment of Universal Waste shipped off-site showing the name/address of the receiving facility, quantity of waste sent and date shipment was sent (record can be in the form of a log, invoice, manifest, bill of lading, or other shipping document)? [273.39(b)] 18. Does Handler keep records for at least three years from the date shipment is received/sent off-site? [273.39(c)] Section D Standards for Universal Waste Transporters (Subpart D) Note: applies to a person engaged in the off-site transportation of Universal Waste by air, rail, highway or water. 1. Has Transporter disposed of Universal Waste? [40 CFR 273.51(a)] If yes, where? _ 2. Has Transporter diluted or treated Universal Waste? [40 CFR 273.51(b)] If yes, how? 3. Has Transporter complied with all applicable U.S. DOT regulations in 49 CFR Part 171 180? [273.52(a) and (b)] Note: Since no manifest is required, Universal Wastes cannot be described by the DOT shipping name hazardous waste, N.O.S. nor may the shipping name used be modified by adding the word waste 4. Has Transporter stored Universal Waste at a transfer facility for >10 days? [273.53] Note: If yes, The Transporter is subject to applicable small or large handler requirements. 5. Has Transporter responded immediately to contain all releases? [273.54(a)] 6. Has the Transporter determined if the material/residue resulting from any releases is hazardous waste, and if so, has the handler managed the material/residue as a Page 9 of 10 Rev. 2/99
hazardous waste? [273.54(b)] 7. Has Transporter sent universal waste only to another universal waste handler, a destination facility or a foreign destination? [273.55(a)] 8. Has Transporter followed DOT regulations for off-site shipments? [273.55(b)] 9. For foreign shipments, has a copy of the EPA Acknowledgment of Consent accompanied the shipment? [273.56] Facility: Date: Section E Standards for Destination Facilities (Subpart E) 1. Has the Destination Facility managed the Universal Waste under 40 CFR 264, 265, 266, 268, 270, and 124? [273.60] 2. Has Destination Facility sent universal waste only to another universal waste handler, a destination facility or a foreign destination? [273.61(a)] 3. Does Destination Facility track each shipment of Universal Waste received showing the name/address of the originator, quantity of waste received and date of receipt (record can be in the form of a log, invoice, manifest, bill of lading, or other shipping document)? [273.62(a)] 4. Does Destination Facility keep records for at least three years from the date shipment is received/sent off-site? [273.62(b)] Page 10 of 10 Rev. 2/99