Hazardous Waste Generator Requirements

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					 Waste Management
Instructor: Skip Ricarte
1.   Introduction
2.   Definition of Waste
3.   Requirements as a Haz Waste Generator
4.   Shipment of Hazardous Waste
5.   Treatment of Hazardous Waste Onsite
6.   Recycling of Hazardous Waste
7.   Universal Waste Rule Standards
8.   Pollution Prevention
9.   Resource Information
                  Brief History
                           Issues: (1) Advancement in
• Solid Waste Disposal      technology; (2) Population growth in
  Act (1965) SWDA           metropolitan areas
                           Attempted to address nation’s
                            disposal needs through research,
                            training, investigations, surveys,
                            demo projects.

• Resource Conservation
                           Amended SWDA and set goals for
  & Recovery Act (1976)     protecting human health and
  RCRA                      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            Addresses past practices at
                            inactive disposal site
  Environmental            Establishes Superfund
  Compensation, and
  Liability Act (1980)

• Hazardous and Solid      Phased-out H.W. land disposal
  Waste Amendments         Increased EPA enforcement
                            authority and TSDF standards
  (1984) HSWA              Increased UST requirements

• Californians use more than 164 million
  pounds of chemical products daily from
  solvents to adhesives to personal care
• 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
• 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
• 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,
     Example Of Schools/Universities Waste
• Waste Solvent & Solvent    • Refrigerants from air
  Sludge                       conditioning system
• Waste Antifreeze           • Batteries
• Used aerosol cans          • Used paints
• Used rags & paper towels   • Used containers
• Used Absorbents            • Used papers & Packaging
• Sludge from traps and        materials
  oil/water separators       • Lamps
• Wash water or mop water    • Used tires
• Waste filters              • Garden wastes
• Waste aqueous Solution     • Food wastes and other
• Used Oil                     cafeteria wastes
• Brake, Transmission, and
  Hydraulic fluids
      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
• Waste Solvent & Solvent    • Antifreeze recycling filters
  Sludge                        – metal
   – Spent brake washing        – non-metal
      solvent                • Used Oil
• Waste Antifreeze           • Brake, Transmission, and
• Used aerosol cans            Hydraulic fluids
• Used rags & Paper towels   • Used Oil Filters
• Used Absorbents            • Refrigerants from air
• Sludge from traps and        conditioning system
  oil/water separators       • Batteries
• Wash water or mop water    • Switches, lamps
• Waste filters              • Used tires
• Waste aqueous Solution
                    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
(HS&C 25124 and CCR§ 66261.2)
• 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

• Read the labels and the MSDS for each
  product for “characteristics.”
• See if it is “listed.”
• Have the waste analyzed for hazardous
                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 Waste
             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
   – 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

• 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
4. Aboveground Petroleum Storage Act requirements for Spill
   Prevention, Control and Countermeasure (SPCC) Plans
5. Hazardous Waste Generator and Onsite Hazardous Waste
   Treatment (tiered permitting) Programs
6. California Uniform Fire Code: Hazardous Material
    Management Plans and Hazardous Material Inventory
      Requirements As A Hazardous Waste
            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
        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
                        Required by Law
• 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
   – Analytical testing using certified EPA SW846 Methods

• DTSC concurrence/re-classification [66260.200]
                Generator Knowledge
• Chemical Name
• Manufacturer’s ID
• 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
• Total amount of hazardous waste on-site at any given
  (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
• 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 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.
                    Accumulation Time
        Generator Status                    Accumulation Time
• Large Quantity Generator (LQG)       90 days from the first drop
  > 1000 kg (2200 lbs)/month

• Small Quantity Generator (SQG)       180 days or 270 days if TSDF is
  > 100 - <1000 kg (220 -2200 lbs)/     200 miles from point of
  month OR <1kg (2.2 lbs)/month         generation and 90 days for
  of acutely and extremely H.W.         acutely and extremely H.W. from
  AND < 6000 kgs (13,200 lbs)           the first drop
  accumulated onsite
                                       180 days or 270 days if TSDF is
• Conditionally Exempt SQG              200 miles from point of
  (CESQG) < 100 kg (220                 generation and 90 days for
  lbs)/month OR < 1 kg (2.2             acutely and extremely H.W. from
  lbs)/month acutely and extremely      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

1. “Hazardous Waste….”
2. Name and address of
   generator and
3. EPA ID Number
4. Accumulation start date
5. Composition and
   physical state
6. Hazardous properties
7. 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

• 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
• “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.
         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
• 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
•   Inspection logs (e.g., cathodic protection system, valves, overfill
    protection, throughput calculations).
•   Annual integrity assessments, if tank system has no secondary
•   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                • Ensure that your waste is
                                             delivered to a permitted facility or
•   Package, label, and mark all             authorized recycler [Check the
    containers in accordance with            DTSC web site]
    Department of Transportation
    regulations prior to shipment
                                           • Use a HW manifest
•   Use a hazardous waste transporter
    registered with DTSC [ 916-255-4368]   •   Provide any Land Disposal
•   Verify driver license class                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 Restriction
• 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

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),
  – 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 Manifests
   P.O. Box 400
   Sacramento, CA 95812-0400

For rejected shipments mail either top or second copy
   DTSC Facility Manifests
   P.O. Box 3000
   Sacramento, CA 95812-3000
Treatment of Hazardous
                           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
 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
• 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 Determination
                                          <55 gal/mo/facility CESQT
                    Ion Exchange
                    pH Adjust
                    Metalic Replacement           <1400 ppm
    Aqueous        Precipitation or
                                              >55 gal/mo/fac.
     Waste          Crystalization
    with metals                                   >1400 ppm     PBR

                    Phase Separation
    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-
• 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
            HSC 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.
Recycling generally takes the form of one of three exclusions or
• 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
• 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
• 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
• 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
      • 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-containing
• Mercury Thermostats         Gauges
• Lamps                     • Mercury-added Novelties
• Cathode Ray Tubes/Glass   • Counterweights And
• Electronic Devices        • Mercury Thermometers
• Aerosol Cans              • Mercury-containing
• Mercury- Containing         Medical Devices
  Motor Vehicle Light       • Mercury-containing
  Switches                    Rubber Flooring
• Dental Amalgam Wastes     • Mercury Gas Flow
    Electronic Devices that are E-Waste when
              Destined for Recycling

•   Computers              • Tape players/recorders
•   Computer peripherals   • Phonographs
                           • Video cassette players and
•   Telephones               recorders
•   Answering machines     • Compact disc players and
•   Radios                   recorders, calculators
•   Stereo equipment       • 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         •   Employee Training
•   Notification         •   Response to Releases
•   Waste Management     •   Offsite Shipments
•   Labeling/Marking     •   Tracking Shipments
•   Accumulation Time    •   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
                  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-
• 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)”

                  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”


                 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

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

     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
  for easy instructions on how to get a federal EPA ID#

               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

Pollution Prevention
      Waste Minimization (SB 14)
• SB 14 applies to generators who routinely
  generate >12,000 kg haz waste or >12 kg
  extremely hazardous waste during a reporting
     12,000 kg = 26,400 lbs
              = 13.2 tons
              = 3,165 gallons
     12 kg = 26.4 lbs = 3.2 gallons
   Some excluded hazardous wastes and activities
   [22 CCR, 67100.2]
         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 businesses
3. 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,
             Source Reduction

Source reduction is Any action which:
(A) reduces the generation of hazardous
(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,
•   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
•   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
•   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) &
                 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
• 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 Practices
      Good housekeeping, training, purchasing, waste
        segregation, preventive maintenance.
• Changes in Technology
      Equipment layout, automation, process efficiencies,
        closed loop recycling,
• Input Material Substitution
      Utilize less toxic alternatives
• Product Reformulation
      Changes in design, composition, or specifications of
      end product, including product substitution
• Energy Conservation
      Insulation, Star-energy equipments, Green Building
             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
•   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

•   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 (Homepage – Fact Sheets, Publications, and Forms)
• State Regulations:
• State Statute:
                      Additional Resources
•   P2 Resource Exchange – Topic Hubs
•   Western Regional P2 Network-Topic Hubs
•   American Electroplaters & Surface Finishers
•   National Metal Finishing Resource Center
•   Strategic Goals Program for Metal Finishers
•   California Government Online to Desktops (CalGold):
•   US EPA Enviro$en$e
•   Business Assistance Auto Repair Industry Resources: Links to P2 information for the
    automotive repair industry
•   CCAR – Greenlink:Compliance assistance.
               Additional Resources
• Rechargeable
• Thermostats:
• Lamps and mercury:
• Household hazardous waste (and used oil):
• CRTs and electronic waste:
• HW Manifest 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
•   Keeping wastes on-site for longer than the law allows

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