Understanding Universal & Understanding Universal & Hazardous WasteHazardous Waste

Objectives – Objectives – Hazardous Waste Hazardous Waste

ManagementManagementDefinition of Solid WasteDefinition of Hazardous Waste

– Characteristic– Listed

Generator Status and RequirementsWaste ManifestsSpecial Solid Waste Procedures

Solid Waste DefinitionSolid Waste Definition Not based on physical form of the material

(i.e., solid, liquid, or contained gas) Defined as any material that is

– Discarded by being abandoned (disposed of, burned, or incinerated)

– Inherently waste-like (e.g., dioxin wastes)– Military munitions– Recycled (reuse or reclamation)

Hazardous WasteHazardous Waste

Waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment

Generated from many types of sourcesEPA developed identification system using four

questions to determine if waste is hazardous

Hazardous WasteHazardous Waste Hazardous waste is a subset of solid waste,

defined at 40 CFR 261.3 Treatment, Storage and Disposal of hazardous

waste is covered by Subtitle C of RCRA A material must first meet the definition of a

solid waste in order to be considered a hazardous waste

Categories of hazardous waste include:– Characteristic Waste (D-listed)– Listed Waste (F,U,P, or K-listed)

Hazardous Waste Hazardous Waste DeterminationDetermination

Waste determinations may be made using either knowledge of the process or testing of a representative sample of the waste

– Re-evaluated upon process change– Some facilities require annual re-testing

Samples must be collected on an “as generated” basis (prior to treatment mixture with other waste streams, etc.)

Characteristics tested for are:– Ignitibility, Corrosivity, Reactivity, Toxicity

Listed wastes – No testing needed

HW Identification ProcessHW Identification Process

1. Is material a solid waste (SW)?

2. Is material excluded from SW or HW definition?

3. Is the waste a listed or characteristic hazardous waste?

4. Is the waste delisted?

HW Identification Process – HW Identification Process – Step 1Step 1

1. Is material a solid waste (SW)?

Does the material meet the definition of a solid waste?

If yes, move to question 2

If no, it is not a hazardous waste

HW Identification Process HW Identification Process Step 2Step 2

2. Is material excluded from SW or HW definition?

If waste is not exempt or excluded, evaluate if it meets the HW definition

Hazardous Waste DefinitionHazardous Waste Definition

Solid Waste which:

Exhibits characteristic of a hazardous wasteOR

Is Listed as hazardous waste

Hazardous Waste ExemptionsHazardous Waste Exemptions A number of exemptions exist for waste that

would otherwise be considered hazardous Exemption and exclusions are defined in 40 CFR

261.3 and 261.4 and include:– Domestic sewage– Industrial wastewater discharges covered by an

NPDES permit– Several low toxicity, high volume wastes such as fly

ash, cement kiln dust and certain drilling and mining wastes

HW Identification Process HW Identification Process Step 3Step 3

3. Is the waste a listed or characteristic hazardous waste?

Listed WastesListed Wastes

40 CFR 261 Subpart D

Four categories of listed wastes – F, U, P and K lists

EPA also includes a hazard code explaining why the waste was defined as hazardous at 261 Appendix VII

F, U, P, and K-Listed WasteF, U, P, and K-Listed Waste F-listed = non-source specific

– F001–F005 is for certain spent solvents K-Listed = waste from specific sources U-listed wastes are discarded commercial chemical

products that are toxic or display other hazardous characteristics

P-listed wastes are discarded commercial chemical products that are acutely toxic

U and P-listed wastes are relatively rare, except for labs and other applications where commercially pure grade chemicals are used

Waste (40 CFR 261.21 thru 24)Waste (40 CFR 261.21 thru 24) Ignitibility – waste code D001

– Flash point < 140 degrees F (60 C) Corrosivity - waste code D002

– pH < 2 or >12.5 Reactivity - D003

– Unstable, reacts violently with water, generates toxic fumes, readily capable of detonation at Standard Temperature and Pressure

Toxicity – waste codes D004 through D043– Exceed the TCLP threshold for a toxic constituent– TCLP = Toxicity Characteristics Leaching Procedure, a test method that is

intended to represent how a waste would act if placed in a landfill

Solid Waste meeting any of these limits is a Characteristic Waste

HW Identification Process – HW Identification Process – Step 4Step 4

4. Is the waste delisted?

Listed wastes may changes as wastes are added or delisted

Waste handler may petition EPA for a site-specific delisting of a listed waste.

Delisting requirements are found at 40 CFR 260.22

Recycled MaterialsRecycled Materials

Special subset of solid wasteWhen recycled, some materials are not

hazardous wastesSubject to less stringent regulatory controlsRecycling methodology determines whether

waste is a regulated solid waste

Special WasteSpecial Waste A subcategory of solid waste that is not “hazardous

waste” but requires specific handling.– Drums of industrial waste– Asbestos– Between landfill and generator to determine how to handle it– Must be tracked by location in the landfill

Waste that presents a threat to human health or the environment or a waste with inherent properties which make the disposal of the waste in a sanitary landfill difficult to manage

Special waste authorizations may be required

Hazardous Waste MixturesHazardous Waste Mixtures Never mix hazardous waste with nonhazardous waste

without knowing the regulatory implications A mixture of hazardous waste with non hazardous

waste may be a hazardous waste EPA developed the Mixture Rule to prevent facilities

from mixing their hazardous wastes with nonhazardous solid wastes to avoid regulations

A mixture of any amount of a listed hazardous waste with a non-hazardous waste is a hazardous waste

Mixture rule applies to listed hazardous wastes, but not characteristic hazardous wastes.

Hazardous Waste MixturesHazardous Waste Mixtures Mixing a hazardous waste with a nonhazardous

waste to achieve a nonhazardous waste is prohibited

However, a mixture of nonhazardous or exempt waste with characteristic hazardous waste is only defined as a hazardous waste if it exhibits one of more of the four hazardous characteristics– Ignitability– Corrosiveness– Reactivity– Toxicity

Containerized MaterialsContainerized Materials

If a material in a container meets the definition of a hazardous waste when discarded, it must be treated as a hazardous waste even if it is still in its original container and has not been contaminated with anything

Empty ContainersEmpty Containers

Container may be considered a hazardous waste unless it is properly empty

Section 261.7 sets regulatory guidance for when a container is empty for the purposes of the Act

Waste Characterization Waste Characterization SummarySummary

EPA developed a four question test to use when characterizing waste

Hazardous waste may be a listed waste or a characteristic waste

Universal wastes are exempt from hazardous waste procedures as long as specific procedures are followed

Never mix hazardous waste with nonhazardous waste without knowing the regulatory impact

Hazardous Waste GeneratorHazardous Waste Generator

Generator status is based on quantity of waste generated on site in a calendar month

Generator status may change due to an unusual event or disposal requirement

Change in Generator status may trigger additional training, inspection and record keeping requirements

Hazardous Waste GeneratorHazardous Waste GeneratorThree tiers of generators : Fully Regulated -Large Quantity (LQG) Small Quantity (SQG) Conditionally Exempt Small Quantity (CESQG)

States generally follow RCRA classification scheme, but may set different standards.

Non-Generator Status generates NO hazardous wastes at any time

Hazardous Waste Generator Hazardous Waste Generator (federal definition – states may vary)(federal definition – states may vary)

Large Quantity (LQG) – Greater than 2,200 pounds of hazardous waste/month and/or greater than 2.2 pounds of acute hazardous waste/month. LQG can accumulate more than 13,200 pounds of HW on site at any time.

Small Quantity (SQG) – Between 220 and 2,200 pound of hazardous waste/month and up to 2.2 pounds of acute hazardous waste/month. SQG can accumulate between 2,200 and 13,200 pounds of HW on site at any time.

Conditionally Exempt Small Quantity (CESQG) – Less than 220 pounds of hazardous waste/month and up to 2.2 pounds of acute hazardous waste/month. CESQG can accumulate less than 2,200 pounds of HW on site at any time

Note: No averaging allowed on these quantities!

Hazardous Waste TrackingHazardous Waste Tracking

List each hazardous waste generated at the facility on the Hazardous Waste Tracking Form

Whenever hazardous waste is generated, record the amount on the Form for that month

On the last day of the month, total the amount of hazardous waste generated on site that month

Determine generator status for the facility that month. Confirm that facility is meeting the compliance

requirements for that level of generator

Hazardous Waste NotificationHazardous Waste Notification EPA requires SQG and LQG to submit notification to

the agency. A site specific identification number will be issued.

CESQG do not need to notify the agency, but transporters or disposal companies may require them to complete the notification

Use EPA Form 8700-12 Notification of Hazardous Waste Activity

Update 8700-12 Form with changes in hazardous waste streams

Hazardous Waste General Hazardous Waste General RequirementsRequirements

Generators must determine whether wastes are hazardous or non-hazardous

SQG and LQG must have an EPA identification number Hazardous waste accumulation start date must be tracked from

– When the waste is first generated

OR– When the quantity being accumulated in a container in a satellite area

exceeds 55 gallons

Hazardous waste accumulation time allowed is based on generator status

Hazardous Waste General Hazardous Waste General RequirementsRequirements

Properly label with the words “Hazardous Waste” on each container or tank used to collect hazardous waste

Mark accumulation start date on each drum or container used to store HW. If satellite container, make date when it becomes full and move to storage area within 3 days

Only one container of up to 55 gallons of each separate waste stream allowed for each satellite accumulation area

Comply with container and/or tank storage requirements including inspections Properly design facilities and communicate with local authorities as required by

Preparedness and Prevention Measures Designate Emergency coordinator(s) Comply with Waste Minimization requirements

Large Quantity GeneratorLarge Quantity Generator

LQG generates greater than 2,200 pounds of hazardous waste/month and/or greater than 2.2 pounds of acute hazardous waste/month

Accumulation time is limited to 90 days Prepare a Contingency Plan and emergency procedures Document training of personnel Submit Biennial Reports on even-number years Comply with Air Emission Standards from 40 CFR

part 265 Subpart CC

Small Quantity GeneratorSmall Quantity Generator SQG generates between 220 and 2,200 pound of hazardous waste/month and up

to 2.2 pounds of acute hazardous waste/month Accumulation time is limited to 180 days, but may be extended to 270 days if

wastes are to be shipped more than 200 miles for disposal Accumulate less than 13,200 pounds of hazardous waste on site Prepare emergency procedures Train hazardous waste personnel on waste management and emergency/spill

response procedures, but not required to be documented

Conditionally Exempt Small Quantity (CESQG) – Less than 220 pounds of hazardous waste/month and up to 2.2 pounds of acute hazardous waste/month

Conditionally Exempt Small Conditionally Exempt Small Quantity GeneratorQuantity Generator

CESQGs generate less than 220 pounds of hazardous waste/month and up to 2.2 pounds of acute hazardous waste/month

Never exceed a total on site accumulation of 2,200 pounds of hazardous waste

Accumulated hazardous wastes are delivered to an approved facility using a manifest

Follow proper labeling and inspection procedures Personnel training addresses hazardous waste handling

procedures and emergency response procedures

Episodic GenerationEpisodic Generation Generator status is determined on a

calendar month basis Generator status may change from one

month to the next Referred to as episodic generation Required to comply with respective

regulatory requirements for that particular month

State Specific RequirementsState Specific Requirements States have the authority to administer the RCRA

program and may have differing or more stringent requirements, such as– Changes in generator categories and category requirements– Use of state manifests not allowed after September 2006

uniform manifest rule– More frequent and/or additional reports– Inclusion of additional materials, such as used oil, as

hazardous waste

HW Generator Status SummaryHW Generator Status Summary

Generator Category Generation Rate

(lbs/month)

Accumulation Limit

(lbs at any time)

Conditionally Exempt Small Quantity Generator

≤≤ 220 < 2,200

Small Quantity Generator

< 2,200 2,200 – 13,200

Large Quantity Generator

≥≥ 2,200 >> 13,200

HW Storage LimitsHW Storage Limits Storage limit for Large Quantity Generators is 90 days Storage limit for Small Quantity Generators is 180 days May be extended to 270 days for SQG if wastes are to be

shipped more than 200 miles for disposal Storage allowed in containers or tanks

– Tanks must meet RCRA requirements and are generally discouraged (especially USTs)

– Tanks are defined as a stationary device designed to contain an accumulation of hazardous waste

– Container means any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled (totes)

HW Satellite Accumulation HW Satellite Accumulation ContainersContainers

Satellite accumulation container– Any container ≤≤ 55 gallons used to accumulate hazardous waste (larger

containers are not eligible) Only one satellite container may be used at each point of generation

(multiple points of generation allowed) All satellite containers must be marked with the words “Hazardous

Waste” When full, satellite containers must be:

– Marked with the accumulation start date and– Moved to 90-day storage area within 3 calendar days

Containers must be closed except when adding or removing waste All containers and tanks used for storage must marked with the

accumulation start date and the words “Hazardous Waste”

HW Storage InspectionsHW Storage Inspections

Documented weekly inspections must be conducted for all 90-day storage containers– Inspect for leaks or deterioration caused by corrosion

Documented daily inspections must be conducted for all 90-day storage tanks– Inspect discharge control equipment, monitoring

equipment, level in the tank, and construction materials

– Secondary containment must be provided

HW DisposalHW Disposal SQG and LQG must ship all hazardous waste

from the facility to a permitted Treatment, Storage or Disposal Facility (TSDF)

EPA Identification number required A hazardous waste manifest must be used for all

shipments of hazardous waste– Except where tolling agreement exists (e.g., Safety

Kleen parts washer waste)

HW TrainingHW Training LQGs must have a written Contingency Plan that includes:

– A description of the actions facility personnel must take to respond to a release

– A description of the arrangements with local emergency services (fire, police, hospital)

– Designation of primary and secondary emergency coordinators– A list of all emergency equipment on site & capabilities– An evacuation plan

Copies of the plan must be maintained at the facility and submitted to local police, fire, and hospital

Anyone who handles hazardous waste must be trained annually on the contents of the Contingency Plan and the proper handling of hazardous waste

HW Record KeepingHW Record Keeping Maintain the following for at least 3 years:

– Waste analyses, test results or information supporting waste determinations

– Storage inspection records– Personnel training records– Biennial reports and Exception reports (LQGs only)

SQG and LQG must keep current emergency contact information posted near a telephone

HW ReportingHW Reporting Large Quantity Generators are required to submit

a report (Form 8700-13A) by March 1 of each even-numbered years for the previous years manifested shipments

If EPA runs the program in that state, the report is submitted to the appropriate EPA Regional Office

States may have additional reporting requirements

Common HW Violations noted Common HW Violations noted during inspectionsduring inspections

Not marking containers with “Hazardous Waste” Not marking containers with accumulation start

date Open container while not adding/removing waste Incomplete or missing inspection records

– Inspection records not signed and dated Incomplete or missing training records Out dated or missing manifest records Failure to properly characterize waste

HW Disposal RequirementsHW Disposal Requirements Properly package, label, and mark each drum or

container for transport off-site Prepare a manifest for all transported hazardous waste Comply with land disposal restrictions for certain

wastes Use a RCRA-permitted transporter for off-site

shipment to a RCRA-permitted disposal facility Maintain records of manifests, exception reports, waste

profiles, and test results

HW Generator Requirements HW Generator Requirements – Summary– Summary

Generator status is determined by the amount and type of waste generated at site and the amount of waste accumulated on site at any time

There are specific requirements for each type of generator covering– Storage and Accumulation amounts and time limits– Inspections, Training and Reporting – Transport, Disposal and Record Keeping

Use a RCRA-permitted transporter for off-site shipment to a RCRA-permitted disposal facility

Hazardous Waste Manifest - Hazardous Waste Manifest - OverviewOverview

EPA Form 8700-22 Owner fills out manifest form describing waste and

designated recipient and alternative recipient Transporter signs manifest and leaves copy with

generator Recipient signs manifest and sends copy of manifest

back to generator If signed copy of manifest is not received from

facility within 45 days (LGQ) or 60 days (SQG) of transport, follow exception reporting requirements

Waste Manifesting Waste Manifesting

Waste Generated(Create Manifest)

Generator (keep green copy)

Transporter (keep yellow copy)

Disposal Facility (keep pink copy)

Returned to Generator (all signatures) Uniform Hazardous

Waste Manifest“Cradle to Grave”

Hazardous Waste ManifestHazardous Waste Manifest

Generator’s representative certifies:That waste is properly marked, packed,

classified, and labeledProgram in place to reduce volume and

toxicity of waste (LQG)Selected Treatment /Storage /Disposal

method is best available method (LQG)

Treatment, Storage and Disposal Treatment, Storage and Disposal FacilitiesFacilities

Last link in cradle-to-grave hazardous waste management system

40 CFR Parts 264 and 265 Requirements are more extensive than

standards for generators and transporters Two categories:

– Permitted (new)– Interim Status (existing)

HW Manifest SummaryHW Manifest Summary

Use EPA Form 8700-22 or appropriate state manifest for any hazardous waste disposal

Use a RCRA-permitted transporter for off-site shipment to a RCRA-permitted disposal facility

HW Generator signs manifest to certify waste is properly marked, packed, classified, and labeled

Details of HW Manifest will be covered in Waste Management – Level 2 Module

Summary –Summary –Waste ManagementWaste Management

Definition of Solid WasteDefinition of Hazardous Waste

– Characteristic– Listed

Generator Status and RequirementsWaste ManifestsSpecial Solid Waste Procedures

Universal WasteUniversal Waste

Category of hazardous waste that is exempt from hazardous waste requirements if specified handling and recycling practices are followed (40 CFR 273)

Waste is shipped by approved universal waste handlers

Includes:– Batteries– Recalled pesticides– Mercury thermostats– Lamps (fluorescent bulbs & tube)

Universal Waste HandlersUniversal Waste HandlersUniversal Waste Handlers, two types

– First type – Person who generates or creates, universal waste or Contractors or repair people

– Second type – Person who receives universal waste from generates or

other handlers

– Universal waste handlers accumulate universal waste, but do not treat, recycle, or dispose of the waste

Universal Waste RegulationsUniversal Waste RegulationsTwo sets of regulations

– Small quantity handlers of universal waste (SQHUW)

Accumulates less than 5,000 kilograms (11,000 lbs)

– Large quantity handlers of universal waste (LQHUW)

Accumulates 5,000 kilograms or more At any one-time Designation retained through the end of the calendar year

Small Quantity Handlers UWSmall Quantity Handlers UW No notification to accumulate UW Waste Management

– Store in closed, structurally sound, and compatible containers Labeling

– Mark containers “Universal Waste – Batteries”, or “Waste – Batteries”, or “Used – Batteries”

Accumulation time – 1 year, mark the earliest date of any UW in the container

Employee Training – “Inform” all employees who handle or have responsibility for managing UW

– Proper Handling, and– Appropriate emergency procedures

Large Quantity Handlers UWLarge Quantity Handlers UW Submit notification to accumulate UW, and obtain an EPA ID Number Waste Management

– Store in closed, structurally sound, and compatible containers Labeling

– Mark containers “Universal Waste – Batteries”, or “Waste – Batteries”, or “Used – Batteries”

Accumulation time – 1 year, mark the earliest date of any UW in the container

Employee Training – “Ensure” all employees are thoroughly familiar with

– Proper Handling, and– Emergency procedures

Lead Acid BatteriesLead Acid Batteries Two managing options:

– Per 40 CFR 273.2 as “Universal Waste” or– Per 40 CFR 266.80 (Subpart G)

If you generate, collect, transport, store or regenerate lead-acid batteries for reclamation purposes,

– Exemption from certain hazardous waste management requirements Primarily used for the reclamation of spent “automotive” lead-

acid batteries Must determine which one of the five applicable requirements

under 40 CFR 266.80 No labeling requirements

UW - SummaryUW - Summary Generators responsibility to determine if the waste

should be managed as hazardous waste or UW If managed as UW, then it’s the generators

responsibility for– Notification if required– Waste Management– Labeling– Accumulation time– Employee Training