1 Outreach Train-The-Trainer Universal Waste & Used Electronics 2014
2 Thanks to Our Generous Sponsors!
Agenda Continental Breakfast Introduction Classroom Session Practical Activities Classroom Session Practical Activities Lunch 3
Outline 4 Universal Waste Management Categories of Universal Waste Universal Waste Handler Requirements Universal Waste Transporter Requirements Universal Waste Destination Facility Requirements Vendor Selection Used Electronics Household Hazardous Waste Other Opportunities or BMPs Questions
Universal Waste Management Background Environmental Protection Agency (EPA) developed streamlined universal waste rule 40 CFR part 273 Virginia Department of Environmental Quality (VA DEQ) adopted the universal waste rule and made additional requirements 9VAC20-60-273 5
Universal Waste Management 6 Purpose Streamlined set of regulations to reduce the regulatory burden by allowing longer time for storage, reduced record-keeping, and consolidation Universal wastes are Generated in a wide variety of settings Generated by a vast community Stored in significant volumes through proper management
Universal Waste Management Goals EPA Goals To encourage resource conservation while ensuring adequate protection of human health and the environment To improve implementation of the current hazardous waste regulatory program To provide incentives for individuals and organizations to collect the unregulated portions of universal waste streams and manage them using the same systems developed for the regulated portions, thus removing them from the municipal waste stream 7
Universal Waste Management Goals VA DEQ Goals To encourage the recycling of the categories of waste designated as universal waste To improve the management of certain types of hazardous waste To reduce the amount of hazardous waste that ends up in solid waste landfills and trash to energy facilities To ease the regulatory burden on facilities that manage these wastes, particularly by allowing more time for accumulation of waste in order to facilitate appropriate recycling or disposal To ensure that these wastes go to appropriate treatment or recycling facilities 8
Categories of Universal Waste The following wastes are considered universal waste in accordance with state and federal regulations: Mercury containing equipment Pesticides Batteries Lamps 9
Categories of Universal Waste Batteries There are several types of batteries that fall under the universal waste rule, such as: Nickel-Cadmium Nickel-Metal Hydride Lithium Ion Lead-Acid 10
LED s? Categories of Universal Waste Lamps Lamps, bulbs, and tube portions of electric lighting devices can contain mercury Mercury can be very harmful to environmental and human health if it is not managed properly 11
Categories of Universal Waste Practical: Invisible Contaminates While moving a container of universal waste, the bottom breaks and universal waste falls onto the floor. Don the proper personal protective equipment (PPE) to clean up the material and be aware of the possibility of exposure to invisible contaminates such as battery acid or other heavy metals 12
Universal Waste Handler Requirements Small Quantity Handlers of Universal Waste (SQHUWs) = less than 5,000 kilograms or 11,000lbs (40 CFR 273.13) Label universal waste Prevent releases to the environment Respond to releases and properly manage material Training Accumulation time of ONE year Comply with export requirements & DOT shipping requirements 13
Universal Waste Handler Requirements Small Quantity Handlers of Universal Waste (SQHUWs) Not required to notify VA DEQ of management activities, keep records, or use hazardous waste manifests VADEQ & NVRC both recommend keeping these records as a best management practice (BMP) 14
Universal Waste Handler Requirements Large Quantity Handlers of Universal Waste (LQHUWs)= 5,000 Kilograms or 11,000lbs or more (40 CFR 273.33) Label universal waste Prevent releases to the environment Respond to releases and properly manage material Training Accumulation time of ONE year Comply with export requirements & DOT shipping requirements Maintain all records for at least three years 15
Universal Waste Handler Requirements Large Quantity Handlers of Universal Waste (LQHUWs): Notify the VADEQ of handler status Obtain EPA ID number 16
Universal Waste Handler Requirements SQHUW LQHUW Quantity limit < 5,000 kg on site 273.9 > 5,000 kg on site 273.9 EPA ID Number Not required 273.12 Required 273.32 On-Site Accumulation Limit < 5,000 kg 273.9 No Limit Storage Time Limit 1 year, unless for proper recovery, treatment, or disposal 273.15 1 year, unless for proper recovery, treatment, or disposal 273.35 Manifest Personnel Training Not required 273.19 Basic training 273.16 Not required, but must keep basic shipping records 273.39 Basic training geared toward employee responsibilities 273.36 17
Universal Waste Handler Requirements Generation to Disposal: Batteries Universal waste handlers may conduct the following activities: Sort batteries by type Mix battery types in one container Discharge batteries to remove the electric charge Regenerate used batteries Disassemble batteries or battery packs into individual batteries or cells Remove batteries from consumer products Remove electrolyte from batteries (40 CFR Part 261, Subpart C) 18
Universal Waste Handler Requirements Generation to Disposal: Batteries Containers must be: Kept closed In good condition Compatible with the contents Properly labeled 19
Universal Waste Handler Requirements Generation to Disposal: Batteries NVRC provides guidance for management: How many items in your business require rechargeable batteries Check with the Rechargeable Battery Recycling Corporation (RBRC) to see when battery and cell phone collections are taking place Explore recycling options Educate maintenance and technical staff Coordinate storage, packaging, and shipping logistics with appropriate staff Kick-off the management program with an informational meeting Periodically review the program 20
Universal Waste Handler Requirements Generation to Disposal: Lamps Containers must be: Kept closed In good condition Compatible with the contents Properly labeled 21
Universal Waste Handler Requirements 22 Generation to Disposal: Lamps NVRC provides guidance for management: Estimate how many bulbs you generate from your building based on the estimated square footage Explore disposal options Select a contractor and ensure proper recycling Educate your maintenance staff about how to implement the management strategy. Coordinate lamp storage, shipping, or crushing logistics with appropriate staff Kick-off the management program with an informational meeting with participants to recruit their support Periodically review the program
Universal Waste Handler Requirements Generation to Disposal: Lamps Box Program In a box program, a container is provided to the owner/manager who fills it. When the container is full, it can be sent to any recycler via a prepaid ground mail shipment program. Labels and shipping papers are provided to the building owner/manager by the recycling company. 23
Universal Waste Handler Requirements Generation to Disposal: Lamps Milk Run Program If your building generates large amounts of used bulbs, recyclers can arrange milk-run pick-ups. Used lamps are picked up by a vendor on a scheduled basis and transported to a certified reclamation/recycling facility. If your building generates very large amounts of used bulbs, these can be picked up in trailer loads as needed. 24
Universal Waste Handler Requirements Practical: Proper Storage While inspecting containers of universal waste, you notice that one of the containers does not look right. It appears the container was not compatible with its contents. This practical will explain what can potentially occur when universal waste is not stored properly. 25
Universal Waste Handler Requirements Lamp Crushing (9 VAC 20-60-273): 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 of the Occupational Safety and Health Administrations (OSHA) regulations on Toxic and Hazardous Substances. 26
Universal Waste Handler Requirements Lamp Crushing (9 VAC 20-60-273): All handlers of universal waste (large or small quantity) who crush mercury containing lamps under these universal waste regulations must comply with all parts identifies in 9 VAC 20-60-273 Keeping light bulbs intact until they reach a qualified recycling is the surest method to prevent mercury exposure, however the NVRC maintains a list of companies that may provide crushing units 27
Universal Waste Handler Requirements Lamp Crushing (9 VAC 20-60-273): Generators should check with destination facilities in other sates to review proper disposal and manifesting requirements. 28
Universal Waste Handler Requirements The Good, The Bad, The Ugly While inspecting universal waste containers you notice some things that are not correct in accordance with proper storage management rules. Review the pictures and identify items that must be corrected. 29
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Universal Waste Transporter Requirements A universal waste transporter is a person who moves universal waste shipments from a handler to another handler, a destination facility, or a foreign destination. Universal waste transporter regulations can be found in 40 CFR Part 273, Subpart D. 33
Universal Waste Transporter Requirements Overlap of Hazardous Material & Universal Waste Handlers do NOT have to use permitted hazardous waste transporters (self transport) Transporters must comply with applicable DOT shipping requirements if the universal waste is defined as a hazardous material: 1lb or more of Mercury in a container Lead-Acid Batteries Lithium Batteries Used Battery > 9 volt 34
Universal Waste Transporter Requirements What to Expect Once a transporter has been selected, disposal can begin Milk Run Box Program On-Call Services Community wide collection Assistance with compliance Proper management of paperwork Clear conscience contracts 35
Universal Waste Transporter Requirements Practical: Proper Storage and Transportation It is important to select a universal waste hauler that is reliable and properly handles the universal waste. While the hauler was loading a container of universal waste batteries, the container appeared to be bulging, indicating that gasses were building up inside the container and could not be released. 36
Universal Waste Destination Facility Requirements A destination facility is a facility that may treat, dispose, or recycle universal waste and is regulated under the universal waste program. If a destination facility solely accumulates universal waste, they are subject the handler requirements described previously Some destination facilities may be a handler of one type of universal waste but a destination facility for another type. This means they must comply with all applicable regulations under the universal waste program. 37
Universal Waste Destination Facility Requirements Destination Facilities If a destination facility recycles universal waste without prior storage, the facility is subject to 40 CFR 261.6(c)(2) Subject to full hazardous waste regulations as a treatment, storage, and disposal facility (TSDF) which includes permitting, general facility standards, and unit-specific standards. 38
Universal Waste Destination Facility Requirements What to Expect: SQHUW - Minimal LQHUW Maintain records of all shipment received by and sent from the facility Destination facility may provide signed copies of a manifest for proper tracking 39
Vendor Selection How to Find a Vendor Assurance that waste is being managed properly Pricing Service Risk Management Environmental and compliance history Permits and approvals Audit reports Insurance requirements 40
Helpful Hints Evaluate Vendor s Compliance Standing EPA Envirofacts EPA Enforcement and Compliance History Online (ECHO) Has vendor qualified for any performance, quality, or management system certifications? R2 Standard ISO 14001 Environmental Management System DEQ & NVRC Vendor Lists 41
Used Electronics Used Electronics are not Regulated as a Universal Waste However, the EPA has proposed that electronics destined for recycling be managed under the universal waste provisions Contain small amounts of RCRA regulated heavy metals: Lead Silver Barium Cadmium Mercury 42
Used Electronics Generation to Disposal Prevent releases to the environment Clean up spills immediately Contact computer or electronic device recycling vendors Facilities are responsible for properly recycling discarded material in a safe and environmentally sound manner 43
Used Electronics 44 The NVRC provides the following recommendations for safe management of used electronics: Survey the electronic equipment that your business uses--if you have an equipment change-out planned, include that in your estimate Explore your recycling options Training Coordinate storage, packaging, and shipping logistics with appropriate staff Kick-off the management program with an informational meeting with participants to recruit their support Periodically review the program
Used Electronics Transportation and Disposal Several frameworks for certifying that electronics recyclers are in compliance with federal, state and local regulations exist: Responsible Recyclers Practices (R2) Institute of Scrap Recycling Industries E-Stewards International Organization Standardization 45
Household Hazardous Waste Categories of Paint & Paint Related Material Categories of Commercial & Household Cleaning Chemicals Regulatory Requirements Accumulation & Storage Disposal Requirements 46
Household Hazardous Waste Household hazardous products can contain corrosive, toxic, ignitable or reactive ingredients that can make them harmful to human health and the environment We will focus on two types of household hazardous waste: Paint & Paint Related Material Commercial & Household Cleaning Chemicals 47
Household Hazardous Waste 48 Categories of Paint & Paint Related Material Flammable Non-Flammable Toxic Categories of Commercial & Household Cleaning Chemicals Flammable Corrosive Toxic
Household Hazardous Waste 49 Regulatory Requirements Improper disposal Pouring down the drain, storm sewers, trash, contaminate septic tanks & wastewater treatment systems Harmful to human health & the environment Hazardous Waste Regulations (40 CFR Subtitle C) VA DEQ (Administrative Code) Waste Management Board
Household Hazardous Waste 50 Accumulation & Storage Do not mix chemical substances Prevent the splashing of chemicals Wear gloves and eye protection when pouring chemicals Keep areas where the product is used and stored well ventilated Secure lids tightly Keep substances in original container Be sure label is securely affixed to the container Keep in a cool dry place Keep out of reach of children and pets Keep incompatible products separated If the original container is leaking, enclose it in a larger container that is labeled
Household Hazardous Waste Disposal Requirements Trash Year round collection program Drop & swap programs Recycling Returning Repurposing 51
Other Opportunities or BMPs Create revenue Alleviate regulatory burden Examples of opportunities and BMPs: Aerosol spray cans Latex paint Specific matrices Used electronics Exchange programs 52
53 Questions
54 Thanks to Our Generous Sponsors!
For More Information 55 Richard Doucette Waste Program Manager P:(703)583-3813 F:(703)583-3871 rdoucette@deq.virginia.gov 13901 Crown Court Woodbridge, VA 22193 Jeremy Paradis, Senior Project Manager P:(860)747-6181 F:(860)747-8822 jgparadis@loureiro.com 100 Northwest Drive Plainville, CT 06062
Debbie Spiliotopoulos, Senior Environmental Planner P: (703)642-4631 F: (703)642-5077 DSpilio@novaregion.org 56 3060 Williams Drive Suite 510 Fairfax, VA 22031 www.novaregion.com www.knowtoxics.com