Waste Management Instructor: Skip Ricarte

Topics

1. Introduction2. Definition of Waste3. Requirements as a Haz Waste Generator4. Shipment of Hazardous Waste 5. Treatment of Hazardous Waste Onsite6. Recycling of Hazardous Waste7. Universal Waste Rule Standards8. Pollution Prevention9. Resource Information

Introduction

Brief History

• Solid Waste Disposal Act (1965) SWDA

• Resource Conservation & Recovery Act (1976) RCRA

Issues: (1) Advancement in technology; (2) Population growth in metropolitan areas

Attempted to address nation’s disposal needs through research, training, investigations, surveys, demo projects.

Amended SWDA and set goals for protecting human health and environment, conserving energy and natural resources, reducing waste generation, managing waste in an environmentally-sound manner.

Established programs for solid waste, hazardous waste, and UST

“Cradle to Grave”

Brief History (cont.)

• Comprehensive Environmental Response, Compensation, and Liability Act (1980) CERCLA

• Hazardous and Solid Waste Amendments (1984) HSWA

Addresses past practices at inactive disposal site

Establishes Superfund

Phased-out H.W. land disposal Increased EPA enforcement

authority and TSDF standards Increased UST requirements

Facts

• Californians use more than 164 million pounds of chemical products daily from solvents to adhesives to personal care products.

• U.S. produces or imports 42 billion pounds of chemicals daily.

• Global production is of chemical products is expected to double every 25 years.

Hazardous Waste Sources

• Industrial [generate & dispose of approximately 7.6 billion tons of industrial solid wastes each year]

• Non-industrial [e.g., medical centers]• Household [1.6 million tons of household

HW generated every year- Every house has accumulated as much as 100 kg of HHW]

• Natural disaster

Definition of Waste

What Is A Waste?

• Almost any operation will generate some sort of waste-” If it’s not a product or material, it’s a waste”.

• A waste is a material that has been used or has otherwise served its intended purpose and, for whatever reason (contaminated, spent, or intent) can or will no longer be used for its intended purpose.

• All other waste management requirements hinge upon your answer to this question.

Example of Common Metal Finishing Wastes

• Rinse water effluent• Spent plating baths• Spent alkaline and acidic etchants and cleaners• Spent strippers• Spent solvent degreasers• Waste and process bath treatment sludges• Others (filters, off-spec chemicals, universal wastes,

etc.)

Example Of Schools/Universities Waste Streams

• Waste Solvent & Solvent Sludge

• Waste Antifreeze • Used aerosol cans• Used rags & paper towels• Used Absorbents• Sludge from traps and

oil/water separators• Wash water or mop water • Waste filters• Waste aqueous Solution • Used Oil• Brake, Transmission, and

Hydraulic fluids

• Refrigerants from air conditioning system

• Batteries• Used paints• Used containers• Used papers & Packaging

materials• Lamps• Used tires• Garden wastes• Food wastes and other

cafeteria wastes

Example Of Schools/Universities Waste Streams (Cont.)

• Cleaning products and all other custodial chemicals• Old computers, and electronic equipments• Used Pest Control materials• Spent processor solutions and other used photography and

film chemicals• Waste building construction materials• Used chemicals or biological agents from labs• Spent fertilizers• Metal/wood scraps • Glasses• Asbestos• Other

Example Of Common Auto Repair Waste Streams

• Waste Solvent & Solvent Sludge – Spent brake washing

solvent• Waste Antifreeze • Used aerosol cans• Used rags & Paper towels• Used Absorbents• Sludge from traps and

oil/water separators• Wash water or mop water • Waste filters• Waste aqueous Solution

• Antifreeze recycling filters– metal– non-metal

• Used Oil• Brake, Transmission, and

Hydraulic fluids• Used Oil Filters• Refrigerants from air

conditioning system• Batteries• Switches, lamps• Used tires

Definition Of Waste• “..any solid, liquid, semisolid, or contained gaseous discarded

material that is not excluded ….”

• A discarded material is any material:– relinquished (disposed of, burned or incinerated, accumulated, stored, or

treated, but not recycled before) – recycled - used in a manner constituting disposal (placed on land), burned

for energy recovery, reclaimed, and accumulated speculatively.– inherently waste-like when it is recycled [RCRA waste codes F020, F021,

F022, F023, F026 and F028 (contain dioxins), secondary materials fed to a halogen acid furnace

– mislabeled or inadequately labeled (unless within 10 days to re-label)– packaged in deteriorated or damaged containers (unless repackaged in 96

hours)

(HS&C 25124 and CCR§ 66261.2)

Exclusions• Materials that are not discarded Intermediate manufacturing process streams; Coolants,

lubricants or cutting fluids that are filtered to extend their useful life.

• Materials that are not wastes:– Industrial wastewater discharges under National Pollutant

Discharge Elimination System permitting program– Source, special nuclear or by-product material as defined

by the federal Atomic Energy Act– Spent sulfuric acid used to produce virgin sulfuric acid– Pulping Liquors– Secondary materials reclamation in enclosed tanks

• Excluded Recyclable Materials §25143.2(b) & (d)

Definition of Hazardous Waste

• A waste is a hazardous waste when its quantity, concentration, or physical, chemical, or infectious characteristics cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness. It may also pose a substantial present or potential hazard to human health or the environment, due to factors that may include carcinogenicity, acute or chronic toxicity, bioaccumulation, or persistence in the environment, when improperly managed. [HSC § 25141]

Exclusions and Exemptions• Infectious wastes (animal carcasses), per FDA• Wastes excluded under 40 CFR §261.4 and they do not exhibit the

characteristics of non-RCRA hazardous waste• Used oil re-refining still bottoms used in asphalt products• Used CFCs that are reclaimed• Mining wastes.• Ash, fly ash, flue gas emission control residues from biomass• Debris contaminated with petroleum or any of its fraction.

Hazardous wastes which are exempted from certain regulations• Materials in product or raw material storage tanks are exempt until

removed (within 90 days of ceasing operation). • Samples - subject to regulation as a waste after use as a sample ceases • Treatability study samples for generator and labs. • Controlled substances • Geothermal wastes • Wood waste

How Do I know If My Waste Is Hazardous?

• Read the labels and the MSDS for each product for “characteristics.”

• See if it is “listed.”• Have the waste analyzed for hazardous

constituents

Characteristic Wastes

• Ignitability– Liquid with a flashpoint < 140°F (60°C)

OR solid that can cause fire through friction or ignitable

• Corrosivity– Aqueous solution with a pH 2 or > 12.5; Not aqueous and, when

mixed with an equal weight of water, has pH 2 or > 12.5

• Reactivity– Unstable, reacts violently with water, generates toxic gas with water,

can detonate at STP.

• Toxicity

Toxicity Review

• Lots of Tests, pick which one is best based on what you have and what you need

• TCLP- Toxicity Characteristic Leach Procedure• WET- Waste Extraction Test

– Gives you TTLC and STLC (Total Threshold Limit Concentration and Soluble Threshold Limit Concentration)

• Fish Bioassay• LD/LC 50 calculations• Carcinogenic Substances

Toxic Hazardous WasteExamples

Listing of Hazardous Wastes

• Listings– Non-specific sources: F Codes– Specific sources: K Codes– Discarded commercial chemical Products, off-specification

species, container residues, and spill residues: P and U Codes

– Mercury-containing products when discarded: M Codes

Other Hazardous Waste

• Acutely Hazardous Waste (P List & F020-F023)• Extremely Hazardous Waste (66261.107,66261.110)• Special Wastes (e.g., auto shredder, baghouse and

scrubber, sand from sandblasting, and tailing from ore processing (66261.120)

• Hazardous Wastes of Concern (66261.111)

Other Hazardous Waste(Cont.)

• Universal wastes (66261.9)• Recyclable materials (66261.6)• Appendix X

– (Title 22, Div. 4.5, Chapter 11, Art. 5)

Requirements of a Hazardous Waste Generator

HW Regulatory Agencies

• U.S. EPA• Resource Conservation and Recovery Act (RCRA)

» Title 40, Code of Federal Regulations

• Cal/EPA, Dept. of Toxic Substances Control (DTSC)

• Hazardous Waste Control Law» Health & Safety Code and Title 22, Cal. Code Regs

• “CUPA”• Unified Program

Health & Safety Code, Chapter 6.11 and Title 27, Cal. Code Regs.

The Unified Program (Up)

1. Hazardous Materials Release Response Plans and Inventories (Business Plans) 2. California Accidental Release Prevention (CalARP) Program 3. Underground Storage Tank Program Aboveground Petroleum Storage Act requirements for Spill

Prevention, Control and Countermeasure (SPCC) Plans Hazardous Waste Generator and Onsite Hazardous Waste

Treatment (tiered permitting) Programs California Uniform Fire Code: Hazardous Material Management Plans and Hazardous Material Inventory

Statements

Requirements As A Hazardous Waste Generator?

22 CCR SECTIONS 66262.10- 66262.42• Waste Determination / Generator Status• Obtain an EPA ID Number• Comply with accumulation time limits• Comply with container management standards• Comply with Tanks standards• Prepare for emergencies • Provide trainings • Comply with shipping standards • Maintain and update records • Prepare the required reports• Pay the state/local fees!!!

Importance of Waste Determination

•Required by Law (66262.11)•Determines HW Generator Status•Designates Level of Regulatory Requirements

Waste Determination

DANGER: Don’t throw any waste into the trash unless you have confirmed and demonstrated that it is that it is NOT a hazardous waste.

Required by Law(66262.11)

• Self-classify: – Generator knowledge of materials and processes used

• MSDS information• Emergency Response Guide• DOT Guide (49 CFR)• Information provided by Trade Association, Organization• Listed Hazardous Waste• Published or documented waste analysis data or studies (EPA

PublicationOSWER9938.4-03)– Analytical testing using certified EPA SW846 Methods

• www.cdph.ca.gov/certlic/labs/Pages/ELAP.aspx

• DTSC concurrence/re-classification [66260.200]

Generator Knowledge• Chemical Name• Manufacturer’s ID

&Address• Emergency Tel. No.• Physical Hazards• Storage & Handling• Personal Protective

Equipment, and Safe Working Procedures

• Warning signs: Danger = Death Warning = Serious Injury Caution = Mild Injury

Determines HW Generator Status

• Total weight of hazardous waste that you generate (produce) in any given month of the calendar year

- For example: Hazardous waste that you generate between October 1st and October 31

AND• Total amount of hazardous waste on-site at any given

time (only pertains to CESQGs)

NOTE: Generator categories are NOT determined by the weight of waste shipped off-site.

HW Generator Status

Designates Level of Regulatory Requirements

• Storage requires a “permit or grant of authorization” from DTSC

• Accumulation does not require a permit or grant of authorization as long as it meets the specified accumulation time, and the hazardous waste must be generated “onsite” or “remotely-generated”

ACCUMULATION TIMES

• Accumulation time frames depend on amount of waste generated (monthly and total), where the waste is headed for disposal and how it’s accumulated (e.g. satellite).

Accumulation TimeGenerator Status

• Large Quantity Generator (LQG) > 1000 kg (2200 lbs)/month

• Small Quantity Generator (SQG) > 100 - <1000 kg (220 -2200 lbs)/ month OR <1kg (2.2 lbs)/month of acutely and extremely H.W. AND < 6000 kgs (13,200 lbs) accumulated onsite

• Conditionally Exempt SQG (CESQG) < 100 kg (220 lbs)/month OR < 1 kg (2.2 lbs)/month acutely and extremely

Accumulation Time 90 days from the first drop

180 days or 270 days if TSDF is 200 miles from point of generation and 90 days for acutely and extremely H.W. from the first drop

180 days or 270 days if TSDF is 200 miles from point of generation and 90 days for acutely and extremely H.W. from date of amount reached

Satellite Accumulation

• Basics:– At or near the point of generation, under control of

the generator and in containers– Cannot remain on site more than 1 year from first

drop or when 90/180/270 is reached, whichever comes first.

– Mark container w/ initial date of accumulation– No more than 55 gallons per process (may use

separate containers with approval of DTSC)– Move within 3 days of reaching 55 gallons

Special Management Standards for Specific Hazardous Waste

• Hazardous Waste Fuels• Used Oil• Used Oil Filters • Lead-Acid Batteries• Waste Elemental Mercury• Universal Wastes• Spent Sulfuric Acid• Pulping Liquors • Oil-Bearing Material• Rags Reused Soiled Textiles• Small Household Batteries• Latex Paint

Container Management 66262.32

1. “Hazardous Waste….”2. Name and address of

generator and3. EPA ID Number4. Accumulation start date5. Composition and

physical state6. Hazardous properties7. Manifest Number when

prepared for transportation

Special Labels- Used Oil

– “Used Oil-Hazardous Waste” + accum date + Name/Address - Used Oil Filters

– “Drained Used Oil Filters” + accumulation date - Universal Wastes

– “Universal Waste” or “Waste” or “Used” - X - Lead-Acid Batteries

– Date the battery was generated or received. Pallets should have DOT markings or labels

- Excluded Recyclable Materials– “Excluded Recyclable Materials”

Containers & Tanks Standards

• IS IT A TANK OR A CONTAINER?

• Container means any device that is open or closed, and portable, in which HW can be stored, handled, treated, transported, recycled, or disposed of, and that is designed to be portable when it is empty [§66260.10].

• Tank means a stationary device, designed to contain an accumulation of hazardous waste which is constructed primarily of non-earthen materials [wood, steel, concrete, plastic]which provide structural support.[§ 66260.10]

Container Management

• Closed • Labeled• Compatible with contents• In good condition• Ignitable, reactive wastes 50 feet from the

property line• Incompatibles stored separately• Inspected weekly• Adequate aisle space Title 22, CCR, Chapter 15, Article 9

Empty Container Management(66261.7)

• “Empty”• All pourable/non-pourable material removed• If extremely hazardous, triple-rinsed

• If a container meets the “drip/dry” standard, the “empty” container may be managed as follows:

• A container of 5 gallons or smaller may be disposed in a non-hazardous landfill.

A container larger than 5 gallons must be reclaimed for scrap value, reconditioned, remanufactured or refilled.

• Containers holding aerosols [Title 22 CCR §66261.7(m)] must be completely discharged of contents and propellant before disposed in a non-hazardous waste landfill.

Special Provisions

• Household containers -5 gallons or less are exempt if empty

• Aerosol cans: - Empty: are exempt as long as they are sent to

metal recycler. - Non empty, subject to Universal Waste Rule • Containers made of absorptive materials – not

exempt if it was in direct contact and has absorbed hazardous materials.

• Compressed gas cylinders - exempt when pressure approaches atmospheric pressure.

TANK STANDARDS 22 CCR , Chapter 15, Article 10

– Design– Installation– Assessments & certifications– Operating requirements – Daily Inspections– Leak & spill response– Closure– Ignitable, reactive &

incompatible waste – Containment & certification– Labeled with contents and

accumulation start date

Tank Management Requirements• Provide secondary containment (unless obtain a variance, or tank is inside

a building with an impermeable floor and waste has no free liquids• Make sure that HW and tank materials and design must be compatible• Use controls and practices to prevent spillage and overflow• Maintain of freeboard (uncovered tanks) to accommodate wind, waves,

and precipitation from 24-hr, 25 yr storm (2 ft/min unless contained) • Immediately implement the Contingency Plan if a leak or spill occurs, stop

using the tank, remove the waste, contain any releases, and report the incident

• Label with the words “Hazardous Waste”, and the date of the 90 day accumulation period begins.

• Perform daily Inspections (each operating day):– Overfill & spill control equipment – Tank system, secondary containment and surrounding area for signs

of corrosion or release of HW– Data from monitoring & leak-detection equipment – If uncovered tanks, the level of available freeboard

Tank System Documentation• Diagram of secondary containment system• Volume calculations.• Statement of compatibility of waste with tank and coating.• Certification from an independent California Registered Professional

Engineer.• Inspection logs (e.g., cathodic protection system, valves, overfill

protection, throughput calculations).• Annual integrity assessments, if tank system has no secondary

containment.• Testing and maintenance of equipment.• Secondary containment certification• Record of completed training of employees for tank management.• A Contingency Plan that explains how to deal with emergencies

involving tanks and their contents.

Inspection Logs

• Written logs required only of tanks holding hazardous waste (DAILY) CCR 66264.195– Looking for corrosion, releases, working condition,

overflow, spill control and monitoring equipment

• Containers must be inspected, but no log is required (WEEKLY) CCR 66264.174

• All containment areas should be examined too

Hazardous Waste Shipment

How Should I Manage My Hazardous Waste For Proper Transportation?

• Have an EPA I.D. Number

• Package, label, and mark all containers in accordance with Department of Transportation regulations prior to shipment

• Use a hazardous waste transporter registered with DTSC [ 916-255-4368]

• Verify driver license class

• Ensure that your waste is delivered to a permitted facility or authorized recycler [Check the DTSC web site]

• Use a HW manifest

• Provide any Land Disposal Restriction (LDR) documentations

• Submit Generator copy of manifest to DTSC. Submit TSDF signed copy if TSDF is out of state

Consolidated Manifest– Used oil (no volume limits or generator eligibility rules)– Contents of oil/water separator (no volume limits or generator eligibility

rules)– Solids contaminated with used oil – Brake fluid– Antifreeze– Antifreeze sludge– Parts cleaning solvent, including aqueous cleaning solvents– Hydroxide sludge contaminated solely with metals from a wastewater

treatment process– Paint-related wastes, including paints, thinners, filters and sludge– Spent photographic solution– Dry cleaning solvents including perchloroethylene, naphtha, and silicone-

based solvents Filters, lint and sludge contaminated with dry cleaning solvent

– Asbestos and asbestos-containing materials – Inks from the printing industry – Chemicals and laboratory packs collected from K-12 schools– Filters from dispensing pumps for diesel and gasoline fuels

LDR – Land Disposal RestrictionStatement

• Two parts– Notification-- tells the TSDF that a treatment standard

exists or that it is prohibited– Certification-- tells the TSDF that the waste being sent

meets the treatment standard• Must be kept 3 years• What’s prohibited – LIQUID WASTE• For routinely generated wastes- can fill out one LDR

with the initial load if no changes to the waste stream and is sent to the same TSDF

Uniform Hazardous Waste Manifest

Who’s Responsible for Completing the Manifest?

All parties must: –Sign and date the manifest –Check for accuracy and consistency

in volumes and/or quantities–Verify names are legible, printed or

typed, next to the signature

Rejected Loads - Generators

• If a waste shipment is rejected by the TSDF, a generator may:– Identify an alternate facility and have the

waste shipped there on the same manifest (when the transporter is still at TSDF) or a new manifest (partial load or when transporter is not at TSDF), or

– Have the rejected waste returned to the generator on a new manifest.

Rejected Loads - Generators

Waste returned to the generator – Generator signs and dates manifest when

received and provides a signed manifest copy to transporter.

– Notes any discrepancies on the manifest– Submits Page 1 to DTSC and Page 3 to the

TSDF within 30 days – Retains designated facility manifest copy for 3

years– Ships rejected waste to a TSDF within 90 days

Generator - Mailing Addresses

For ALL shipments mail legible copy to:DTSC Generator ManifestsP.O. Box 400Sacramento, CA 95812-0400

For rejected shipments mail either top or second copy to: DTSC Facility ManifestsP.O. Box 3000 Sacramento, CA 95812-3000

Treatment of Hazardous Waste

Required Plans

• Contingency Plan CCR 66265.52 - Required for facilities that generate ANY quantity of H.W. - SQGs’s special posting - Can be combined with Hazardous Materials Business Plan - Should include:

Emergency Procedures» Fire, explosion, spills, floods, earthquakes» Coordination with emergency services» Internal communication

Emergency Equipment Emergency Coordinators (2) and contact info Evacuation Plan Emergency plans, coordinators, equipments

Required Plans (cont.)

• Training Plan Cover hazards, waste management, emergency preparedness (also other

training required by OSHA and DOT ). New hire: within 6 months

Documentation Program should be directed by a person trained in hazardous waste

management Program needs to be designed to ensure that facility personnel are able

to respond effectively to emergencies by familiarization to emergency procedures (including the contingency plan), emergency equipment & emergency systems.

Plan needs to be relevant to the positions in which they are employed Special requirements for SQG & CESQG.

Onsite Treatment of H.W.Treatment means changing the physical, chemical or biological character or

compostion and by that change make it less or non-hazardous or easier to dispose of. (HSC, Sections 25123.5 and 25179.2(e))

– It is illegal to throw hazardous waste away or pour hazardous waste down the sink, in the storm drain, or down the toilet.

– If you treat your hazardous waste at your shop (onsite treatment), you must have approval (permit or grant of authorization) from your local Certified Unified Program Agency (CUPA) or DTSC.

– If you are authorized and treat your hazardous waste onsite into a non-hazardous waste, it may be disposed of to the sewer upon approval of your local sewer agency. Permit/authorization is required

• Common activities:– Neutralization of acidic, alkaline wastewater– Some oil/water separators

Tiered Permitting– Full Permit Title 22, California Code of Regulations, Chapters 14 and 20– Standardized Permit Health & Safety Code, Section 25201.6 – Permit By Rule (PBR)

Title 22, California Code of Regulations, Chapter 45, Section 67450– Conditional Authorization (CA) Health & Safety Code, Section 25200.3– Conditionally Exempt (CE)

Health & Safety Code, Sections 25200.1.5, 25201.14, and 25144.6(c)• CE Specified wastestreams (CESW)• CE Small Quantity Treater (CESQT)• CE Limited (CEL)• CE Commercial Laundry (CECL)

Onsite Tier Qualifying Criteria• Onsite waste• No RCRA permit• Eligible wastestreams• No reactive or EH wastes• Eligible treatment• Specified treatment • In tanks/containers• Notification and fees• Generator requirements• Air emissions requirements

Tier DeterminationFLOWCHART

Aqueous Waste

with metals

Aqueous Waste

with metals

Ion ExchangepH AdjustElectrowinningMetalic ReplacementPrecipitation orCrystalization

Ion ExchangepH AdjustElectrowinningMetalic ReplacementPrecipitation orCrystalization

Phase SeparationPhase Separation

<55 gal/mo/facility

>55 gal/mo/fac.

<1400 ppm

>1400 ppm

CA

PBR

CESQT

Different Operating Requirements

• CE: Generator requirements plus only treat in containers or tanks, notify CUPA, keep logs of inspections and treatment, write treatment operating instructions, close properly, and notify CUPA when closing.

• CA: CE rules plus --– Financial Assurance for Closure – Corrective Action-HSC 25205.14

• Phase I Environmental Assessment + Cleanup PBR: CA +• Written closure plan• Unit(s) identification & marking• PE certification of closure

What If I Am Not Sure About My Treatment Activity?

• Contact CUPA • Use Flowchart to determine tier and waste-

stream• If CUPA ask you to obtain an authorization,

then use Tiered Permitting pages of Unified Program Consolidated Form

• Notify CUPA of any changes and closure

Recycling of Hazardous Waste

RECYCLINGHSC Section 25143.2 et seq.

• Used, reused or reclaimed– Reused

• an ingredient in a process to make a product• a substitute for a commercial product

– Reclaimed• processed to recover a usable product or regenerated • Examples: distilling solvents to regenerate them, fortifying

acid baths, smelting metals, breaking lead-acid batteries to separate the lead plates.

RecyclingRecycling generally takes the form of one of three exclusions or

exemptions:• 25143.2. (a) Recyclable materials are subject to this chapter and

the regulations adopted by the department to implement this chapter that apply to hazardous wastes, unless the department issues a variance pursuant to Section 25143, or except as provided otherwise in subdivision (b), (c), or (d) or in the regulations adopted by the department pursuant to Sections 25150 and 25151.

• 25143.2(b) Exclusion from definition of waste and apply to both RCRA & non-RCRA wastes

• 25143.2 (c)- Exemption from permit requirement and applies to both RCRA and non-RCRA wastes

• 25143.2(d)- Exclusion applies only to non-RCRA wastes

Recycling

• HSC 25143.2 (b): a direct copy of the federal direct use or reuse exclusions (40 CFR 261.2(e)(i), 261.2(e)(ii), and 261.2(e)(iii).

- ingredient in process without reclamation OR– Substitute for commercial product without reclamation OR– Returned to original process as feedstock without reclamation

• HSC 25143(c) contains two exemptions from facility permitting requirements [not exclusions from the definition of waste as in (b) and (d)].

(c)(1) applies to cokers at refineries• (c)(2) applies to all recyclable materials that recycled and reused onsite,

provided the generator standards are met: recycled where it was generated AND within accumulation time limits AND handled like a hazardous waste

• HSC 25143.2(d): This section contains seven exclusions from the definition of “waste.”– used at site which generated OR– ingredient in process to make a product OR– substitute for commercial product

Recycling

• Excluded materials from HSC 25143.2 (b) and (d) must meet conditions in 25143.9:– If held onsite, must label and placard with words

“Excluded recyclable material”– Must have an up to date Contingency Plan which

addresses the material– Stored in accordance with local ordinance regarding

storage of hazardous materials

HSC 25143.2(e) says even if (b), (c ) or (d) applied:– No disposal to land, including as an ingredient in the

manufacture of fertilizer– No burning for energy recovery– no speculative accumulation (>1 yr, use< 75%)

Recycling Records

• Any person managing a recyclable material under a claim to an exclusion or exemption must provide, upon request, to DTSC, U.S. EPA, or a CUPA the name, address, and telephone number of any facility managing the material, and any other information requested, related the management of the recyclable material.

Recycling Records

• UPCF form reporting requirements to CUPAs– those that recycle onsite >100 kg/mo, includes

description of types & constituents– those that accept & recycle offsite waste >100

kg/month• Any person claiming an exclusion or exemption must

maintain adequate records to demonstrate there is a known market or disposition for the material, and that the requirements of the exclusion or exemption are met.

• Recyclable materials excluded from classification as a waste pursuant to section 25143.2 are not excluded from the definition of hazardous substances in subdivision (g) of Section 25316.

Universal Waste Rule Standards

California UWR - Wastes

• Batteries• Mercury Thermostats• Lamps• Cathode Ray Tubes/Glass• Electronic Devices• Aerosol Cans• Mercury- Containing

Motor Vehicle Light Switches

• Dental Amalgam Wastes

• Mercury-containing Gauges

• Mercury-added Novelties • Counterweights And

Dampers• Mercury Thermometers• Mercury-containing

Medical Devices• Mercury-containing

Rubber Flooring• Mercury Gas Flow

Regulators

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Electronic Devices that are E-Waste when Destined for Recycling

• Computers• Computer peripherals• Telephones• Answering machines• Radios• Stereo equipment

• Tape players/recorders• Phonographs• Video cassette players and

recorders• Compact disc players and

recorders, calculators• Some minor appliances.

Universal Waste Rule

1. Special management standards - separate from the general hazardous waste standards

2. For “universally” generated hazardous wastes rather than industrial hazardous wastes

3. Universal wastes are different in: Quantity generated (high) Number of generators (almost everyone) Potential for harm 4. Protective of public health and the environment

5. Cost Effective

California UWR - Standards

– Handlers• Generators-The person that decides to discard the

universal waste [Households, Businesses, organizations, load check programs]

• Intermediate accumulation facilities [Household hazardous waste collection centers, Commercial universal waste collection firm, Lighting contractors, Load check program storage area]

– Transporters [exempt from manifest & using registered hauler]

– Destination facilities• Hazardous waste disposal facilities• Hazardous waste recycling facilities

California UWR - Standards

• Prohibitions• Notification• Waste Management• Labeling/Marking• Accumulation Time

Limits

• Employee Training• Response to Releases• Offsite Shipments• Tracking Shipments• Exports

Standards for UW Handlers

– Prohibitions:• Do not dispose (directly to land or trash)• Do not treat, except as allowed in the UWR

– Notification • No notification for small quantity except for UW electronic

devices (UWED) handler • U.S. EPA ID number for large quantity. • If the handler exceeds the 5,000 kg limit because of the

volume of UWEDs, no EPA ID number is required. – Waste management

• Properly contain wastes (Table 3)• Prevent any releases• Clean up releases, properly manage residuals• Treat only as allowed for specific types of universal waste

(Table 4)• Offsite shipment only to a UWH or a Destination Facility

Standards for UW Handlers-cont’d– Labeling/marking

• Use required labeling language– Accumulation Time Limits One year

• Longer times for cause (e.g., proper recovery, treatment, or disposal)• Document the accumulation start date

– Employee training • Small: Informal (poster, handout, etc.)• SQUW Electronic Devices –Worker Safety• Large: Formal training/recordkeeping

– Response to releases • Immediate cleanup all wastes• Manage residuals from UW as UW• Properly manage other cleanup wastes

85

Labeling Standards

• Each battery, or container or pallet in or on which batteries are contained, should be labeled with the following phrase: “Universal Waste-Batteries”

• Each Mercury Containing Equipment, or a container or pallet in or on which the Mercury-containing Equipment is contained, should be labeled “Universal Waste-Mercury-Containing-Equipment”

• Lamps (including M003 waste that contain lamps), or container or pallet in or on which lamps are contained, should be labeled with “Universal Waste-Lamp(s)”

86

Labeling Standards

• Each electronic device, or container or pallet in or on which e-waste is contained, should be labeled with the following phrase: “Universal Waste-Electronic Device(s)”

• Each CRT, or a container or pallet in or on which the CRTs are contained, should be labeled “Universal Waste-CRT(s)”

• A container of broken CRT glass (e.g., cleaned up from an accident within the building) should be labeled “Universal Waste-CRT glass”

However….

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Labeling Standards

• In lieu of labeling individual electronic devices, CRTs, and/or containers of CRT glass, a handler may combine, package, and accumulate those items in appropriate containers within a designated area demarcated by boundaries labeled with the applicable portion(s) of the following phrase: “Universal Waste-Electronic Device(s)/Universal Waste-CRT(s)/Universal Waste-CRT Glass”

• Labeling requirements are listed in detail in California Code of Regulations, Title 22, §66273.34.

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Do You Need an EPA ID Number?

If you exceed 5,000 kg (5.5 tons) of federally regulated universal waste (batteries, lamps, MCE), you must obtain a federal EPA ID# from U.S. EPA

– Go to http://www.epa.gov/region09/waste/epanums.html for easy instructions on how to get a federal EPA ID#

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EPA ID Number

– If you stay below the listed threshold of federally regulated UW, and accumulate more than 5,000 kg (5.5 tons) of electronic devices (which includes CRTs), you can get by with a California EPA ID# issued by DTSC • The form and instructions are located at

http://www.dtsc.ca.gov/HazardousWaste/upload/GISS_-FORM_1358.pdf

Pollution Prevention

Waste Minimization (SB 14) Applicability

• SB 14 applies to generators who routinely generate >12,000 kg haz waste or >12 kg extremely hazardous waste during a reporting year

12,000 kg = 26,400 lbs = 13.2 tons = 3,165 gallons12 kg = 26.4 lbs = 3.2 gallons

Some excluded hazardous wastes and activities [22 CCR, 67100.2]

• www.dtsc.ca.gov/PollutionPrevention/SB14/upload/sb14-guidance-manual.pdf

Compliance with SB14

1. Conduct source reduction evaluation calendar year 2006 (the reporting year)

2. Complete a Source Reduction Evaluation Review and Plan (Plan)

Checklist alternative for small businesses3. Complete a Hazardous Waste Management

Performance Report (Performance Report) USEPA biennial gen report for small businesses

4. Complete and submit a Summary Progress Report (SPR) – due on or before September 1, 2007

Source Reduction

Source reduction is Any action which: (A) reduces the generation of hazardous waste. (B) is taken before the hazardous waste is generated that results in a lessening of the properties which cause it to be classified as a hazardous waste.

[H&SC, section 25244.14(e)(1)]

Other Waste Minimization Requirements• Generators (manifest certification -T22,CCR,66262.27)• Generators> 12000 kg in reporting year- SB14 documents [HSC, 25244.15,

25244.19, 25244.20]• Large quantity RCRA generators- Biennial Report certification[T22, CCR, 6262.41(a)]• Consolidated manifest users - Certification [HSC 25160.2(b)(4)(H)]• Onsite treatment under Conditional Exemption (CE)- Certification [HSC 25201.5(d)

(9)]• Onsite treatment under Conditional authorization (CA)- Certification [HSC

25200.3( c)(2) &25202.9]• Onsite treatment under Permit by Rule (PBR)-Certification [T22, CCR, 66262.45(c)]• Transportable Treatment Units (TTUs) under PBR - Certification [T22, CCR

66262.45(a)]• Standardized Permit – Certification [T22, CCR, 67800,1(a)(1) & 66264.73)]• Onsite/Off-site Full Permit (TSDF) - Certification[T22, CCR, 66264.73)]• Exporters - Certification [T22, CCR, 66262.56(a)(5)]• At remediation sites-alternative remedial action measures [HSC 25356.1(d) (3) &

(6)]

Generator Certification

• §66262.27 Waste Minimization Certification.

A generator who initiates a shipment of hazardous waste shall certify to one of the

following statements in Item 15 of the uniform hazardous waste manifest:

(a) “I am a large quantity generator. I have a program in place to reduce The volume and toxicity of waste generated to the degree I have determined to Be economically practicable and I have selected the practicable method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment;” or

(b) “I am a small quantity generator. I have made a good faith effort to minimize my waste generation and select the best waste management method that is available to me and that I can afford.”

Consolidated Manifest User Certification

• § 25160.2(b)(4)(H)

• A statement, signed by the generator, certifying that the generator has established a program to reduce the volume or quantity and toxicity of the hazardous waste to the degree, as determined by the generator, to be economically practicable.

Conditional Authorization Certification

• Make an annual waste minimization certification “ - The generator of hazardous waste has established a

program to reduce the volume or quantity and toxicity of the hazardous waste to the degree, determined by the generator, to be economically practicable.

- The proposed method of treatment, storage, or disposal is that practicable method currently available to the generator which minimizes the present and future threat to human health and the environment”

• [§ 25200.3( c)(2) & § 25202.9]

Waste Assessment• Sources of the facility’s Waste• Determining the hazardousness, and if the waste is

RCRA/Non-RCRA• Quantities of generated wastes • What happens to the facility’s waste?• Is there any recycling conducting on-site?• Is there any treatment on-site?• Is their any waste reduction opportunity?• Is there any written pollution prevention plan?• Is there any evaluation of P2 plan?

Source Reduction Measures

• Good Operating PracticesGood housekeeping, training, purchasing, waste

segregation, preventive maintenance.• Changes in Technology

Equipment layout, automation, process efficiencies, closed loop recycling,

• Input Material SubstitutionUtilize less toxic alternatives

• Product ReformulationChanges in design, composition, or specifications of

end product, including product substitution• Energy Conservation

Insulation, Star-energy equipments, Green Building Design

P2 in Auto Repair Shops

• Aqueous Cleaning • Aqueous Brake Washing• Refillable Spray Bottles• Reusable Oil Filters• Engine Oil Life Extension/ Re-refined Oil• Antifreeze Recycling• Spill Prevention and Floor Cleanup• Oil/Water Separator

Remember…..

• Just because you have shipped the hazardous waste off your site and it is no longer in your possession, your liability has not ended.

• You are potentially liable under Superfund for any mismanagement of your

hazardous waste (e.g., illegal disposal to the sewer which could lead to ground water contamination)

• The Manifest will help you to track your waste during shipment and make sure it arrives at the proper destination.

• Reducing your hazardous waste means saving money on raw materials and reducing the costs to your business for managing and disposing of your hazardous wastes.

• If you are looking for alternatives, check the “Best Environmental Practices for Fleet/Auto Maintenance Tool Kit prepared by U.S. EPA & DTSC.

Resource Information

Additional Resources• DTSC Public & Business Liaisons (800) 72TOXIC (1-800-728-6942) or visit www.dtsc.ca.gov (Homepage – Fact Sheets, Publications, and Forms)

• www.epa.gov• www.calcupa.net• State Regulations: www.calregs.com• State Statute: www.leginfo.ca.gov• ww.earth911.org• www.P2Rx.org• www.p2pays.org

Additional Resources

• P2 Resource Exchange – Topic Hubs www.p2rx.org• Western Regional P2 Network-Topic Hubs www.westp2net.org• American Electroplaters & Surface Finishers www.aesf.org• National Metal Finishing Resource Center www.nmfrc.org• Strategic Goals Program for Metal Finishers www.strategicgoal.org• California Government Online to Desktops (CalGold): www.calgold.ca.gov• US EPA Enviro$en$e www.epa.gov/envirosense/• www.911earth.org• Business Assistance Auto Repair Industry Resources: Links to P2 information for the

automotive repair industry www.pprc.org/pprc/sbap/auto.html• CCAR – Greenlink:Compliance assistance. www.ccar-greenlink.org

Additional Resources• Rechargeable batteries:www.rbrc.org/rbrc/ • Thermostats:

www.nema.org/index_nema.cfm/664/ • Lamps and mercury: www.almr.org• Household hazardous waste (and used oil):

http://www.calrecycle.ca.gov

• CRTs and electronic waste:http://www.calrecycle.ca.gov

• HW Manifest Training: http://www.dtsc.ca.gov/IDManifest/Manifests.cfm#Manifest_Regulation_Training

In Summary: Frequently Found Hazardous Waste Violations

• Failure to evaluate wastes• Failure to label and date containers• Failure to keep containers closed and in good condition• Failure to maintain manifest and LDR documents• Failure to conduct inspections of hazardous waste containers and

emergency equipment, and/or failure to keep logs of these inspections• Failure to designate an emergency coordinator• Failure to post emergency information by the phone• Disposing of hazardous wastes improperly (for example, throwing

wastes in the trash)• Drying out cleaning filters• Storing hazardous wastes in containers that are leaking or in poor

condition• Keeping wastes on-site for longer than the law allows

Questions?