UNDERSTANDING UNDERSTANDING

UNIVERSAL WASTEUNIVERSAL WASTE

RULES & HANDLING RULES & HANDLING IN NEBRASKA IN NEBRASKA

What is Universal Waste?

• Fluorescent Lamps

• Batteries

• Mercury Items

• Electronics

In 1995 the EPA issued the universal waste rule (UWR) in order to streamline environmental regulations for wastes that are generated by large numbers of businesses in relatively small quantities.

UWR was designed for 3 reasons:

• To reduce the amount of hazardous waste items in the municipal solid waste stream

• To encourage the recycling and proper disposal of some common hazardous wastes

• To reduce the regulatory burden on businesses that generate these wastes

December 2004, Changes to UWR in NE allow businesses to manage (haz) e-waste as Universal Waste.

July 2005, EPA added e-waste to UWR.

• Universal Wastes do not count against your Hazardous Waste Generator status.

• Increased Storage Time, UW may be stored for up to one calendar year, instead of 90 or 180/270 days.

• Reduces Regulatory Burden, fewer requirements for labeling, notification, accumulation time and training.

- Large Quantity Handlers of UW must obtain a NDEQ ID Number

- Large Quantity Handlers must complete training

• Ease of Transportation and Tracking- Common carrier- No hazardous waste manifest required- Waste can move between UW handlers

Benefits of UWR

Universal Waste Handler

Separate terms are used for people who manage different wastes

““UNIVERSAL WASTE HANDLER”UNIVERSAL WASTE HANDLER”

““HAZARDOUS WASTE GENERATOR”HAZARDOUS WASTE GENERATOR”

1) Small Quantity Handler: A handler who, in a calendar year, generates less than 5,000 kilograms (11,000 lbs) of Universal Waste

2) Large Quantity Handler: A handler who, in a calendar year, generates more than 5,000 kilograms (11,000 lbs) of Universal Waste

Accumulation & Labeling

Handler may not accumulate for more than one year at a time

Storage container must be dated and labeled to demonstrate length of accumulation

- Mark each container with earliest date of UW received, or

- Mark each item separately, or- Determine an inventory system (earliest/each), or- Accumulation area, earliest date, or- Another method

Labels for waste items must follow one of three methods:1) “Universal Waste: (Insert Waste Type)”2) “ Waste (Insert Waste Type)”3) “Used (Insert Waste Type)”

Shipping & Tracking

• Destinations: another UW handler or End Facility

• DOT Rules Apply

• No Hazardous Waste Manifest Required - Non UW States will need HW manifest- Comment in Line 15: “managed as Universal Waste in NE

per Title 128, Chapter 25”• Self Transport OK, must comply with Chapter 25 UW Transporter Requirements.

• Large Quantity Handler Tracking Requirements- Record receipt of shipments: name, address, amounts, types,

date- Record off-site shipments: name, address, amounts, types,

date

• Log, Invoice, Bill of Lading, Manifest, keep on file for 3 years

Recycling Containers

Store the waste in the container you will ship it in. Save time and eliminate possible spills during transfer

Close the Container Except When Adding or Removing Waste

Mark the ContainerWhen waste is placed in a container, the container must be marked with:• a clear description of the waste; and• the date (called the accumulation start date).

Protect labels: cover with clear packing tape or enclose in adhesive plastic pouch

Put all marks and labels on the same side of the container

Make sure labels are still readable and well attached before shipping

Recycling Mercury Containing Lamps

ABOUT:Fluorescent lamps and high-intensity discharge (HID) lamps, are discouraged from landfill disposal in nearly all areas because they contain mercury. NOTE: Lancaster County landfill does not allow any CESQG waste.

Even though new technology has reduced the amount of mercury in a fluorescent lamp and lamps may pass the Toxicity Characteristic Leaching Procedure (TCLP), it is encouraged that they still be recycled.

HANDLING & STORAGE:Do not place used lamps in the trash.

Do not break or crush lamps because mercury may be released, posing health and environmental risks.

Store lamps in a manner that will prevent them from breaking. Recycling facilities request that you do not tape lamps together for storage or shipment.

Recycling Batteries

ABOUT: Battery types must be packaged separately

Types of batteries • Alkaline• Dry Cell NiCad• Nickel Metal Hydride• Carbon Zinc• Lead Acid Non-Spillable• Wet Cell Lead Acid• Wet Cell Nickel Cadmium• Lithium [Lithium Polymer, Lithium Ion]• Mercury• Silver Oxide

Each Battery Type must be packaged separately in UN Approved, plastic containers or, if large enough, firmly secured to pallets capable of withstanding the shocks normally incident to transportation.

Recycling Batteries (2)

STORAGE METHOD:DO NOT mix battery types.

Only chemically compatible battery types should be packed in the same package. DO Ensure that all exposed terminals are protected.

Proper insulation includes taping the terminals of the batteries,

Or packaging in individual plastic bags.

Clear tape is preferred so that battery identification is still possible.

Other forms of insulation may also be used.DO Label storage /shipping containers

Acceptable methods for protecting battery terminals:DO Securely attach covers of

sufficient strength to protect the terminals; DO Package in DOT Approved UN

Containers. DO Package leaking batteries

individually.These may require

shipment as an EPA hazardous waste.DO Store batteries in a cool, dry environment.

*For full battery recycling guidance download this document:http://retrofitcompanies.com/documents/battery-recycling-guidelines.pdf

Recycling Mercury Items

ABOUT:Any electrical, mechanical or medical product or component (excluding batteries and lamps) containing elemental mercury, which is necessary for operation as a conductor of temperature, pressure or electricity, or which is acting as a weight damper. Mercury must be housed within an outer casing.

• Thermostats• Electrical Switches• Gauges• Sphygmomanometers • Thermocouples• Mercury-filled pumps• Thermometers• and other items.

Recycling Mercury Items (2)

STORAGE & HANDLING:Containerize all leaking or potentially leaking (broken) items in DOT approved, sealed, leak proof containers.

When removing ampules:- prevent breakage- work over a containment device- observe OSHA requirements (ventilate!)- keep emergency cleanup kit available- immediately transfer leakage/spills to proper

container (haz. waste)- train employees for proper handling- pack with material to prevent breakage

Recycling Mercury Items (3)

When draining items:- allowable for open-ended items- work over a containment device- written procedure: equipment, O & M of equipment, waste management, waste characterization

- observe OSHA requirements (ventilate!)- keep emergency cleanup kit available- immediately transfer drained mercury to proper

container (haz. waste)- train employees for proper handling- store drained mercury in sealed, leak-proof, DOT approved poly container- document accumulation date, max amt. 45kg (100 lbs)- waste determination for residues/other wastes

Recycling Electronic Waste

What is e-waste?E-waste is any waste that has a circuit board or a cathode ray tube (CRT). The list of e-wastes here are considered haz waste by NDEQ because they fail the TCLP for lead. This includes items that businesses use every day:

Monitors Remote Controls Televisions Circuit Boards Cell Phones Smoke Detectors Computer Mice and more…

Electronics contain many recyclable commodities: Lead, Mercury, Cadmium, Steel, Copper, Plastic, Glass One CRT can contain up to seven pounds of lead

Electronic scrap is the fastest growing waste stream today.

Avoid Electronics as Hazardous Waste.

NDEQ: regulations follow EPA 40CFR (RCRA), and“Waste Computers and Monitors Guidance Document”(www.ndeq.state.ne.us)

Send to “Legitimate Refurbisher” as “still usable product.”

Manage as Universal WasteNever let a CRT become “WASTE”…recycle or handle as UW.

If the weight of ‘waste’ CRT’s causes a facility to be a SQG, then all haz waste generated that month must also be

managed under SQG Management Requirements

Avoid becoming SQG by staying under 220 lbs per month of HW.

Electronic Waste & Liability

Confidential Information is Your Responsibility

Reformatting drives does not entirely eliminate your information, look for secure options. (effective software, physical destruction)

Be aware of what happens to your disposed materials, ask for proper documentation: Certificate of Refurbishment/ Destruction/ Recycling

Environmental Liability is the responsibility of both the Universal Waste Handler and the End Facility

Waste Management Options

RECYCLERECYCLE REFURBISH

REUSE DONATE

Choose a Reputable Recycler

1) Competitive Pricing: “You get what you pay for…”

Look for recyclers who can service your needs, meet your goals and protect you from future legal and financial liability or negative public relations!

2) Sound Practices: E-Waste Recycling is not regulated

Make sure materials are being recycled, check up on end-markets, ask for references, look for recyclers with service capabilities and resources you need:

- Trained Personnel - Proper Equipment - Safety Awareness - Flexibility to meet your needs - Valid Track Record - Capacity to handle wastes - Processing/Technologies/Outlets are environmentally sound

Choose a Reputable Recycler (2)

3) Risk Management: Your recycler should have you covered!

Indemnification: Insurance (with Additional Insured) -Automotive, Workers Comp, Pollution Liability

Financial Health: Revenue Growth, Profitability

Environmental Record: Look for qualified information

- Permits (Facilities and Transportation)- Compliance History- Operating Procedures- Facility Closure Plans- Regulatory Contacts- Facility Audits

E-waste regulations are very likely to change in the future. Handlers should monitor changes in the requirements at the county, state and federal levels.

http://www.ndeq.state.ne.us

http://www.wastecapne.org

http://www.knb.org

http://www.retrofitcompanies.com

http://www.epa.gov

RESOURCES

Marie MagadanRetrofit Recycling, Inc.

2960 Yorkton Blvd.Little Canada, MN 55117

Toll free (800) 274-1309Fax (651) 766-9900

www.retrofitcompanies.comrecycle@retrofitcompanies.com