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Nebraska Department of Environmental Quality
Waste Management Division
• Universal Wastes? • Two Recent Universal Wastes
– Electronic Items – Mercury-Containing Items
• Enforcement Observations • Hazardous Waste Electronic Items • E-Waste Management Options
• Alternate Management Standards for Specified Hazardous Wastes
– If it’s not hazardous waste, UW does not apply – To be UW, it must be managed as UW – Refurbishment means the material is not a solid waste
• Must be able to demonstrate the conditions of the exemption were met • NE honors other states UW regulations
– In transit question has never occurred in practice
Universal Wastes? • Reference Title 128 – Nebraska Hazardous Waste Regulations – Chapter 25 • Two newest universal wastes approved by Nebraska Environmental Quality Council in 2004 and published in December 5. 2004 Title 128. • Note:August 5. 2005 Federal Register Final Rule added “Mercury Containing Items – 70 FR 45508 .
Universal Wastes? • • • • • • Batteries Electronic Items Mercury-Containing Thermostats Mercury-Containing Items Hazardous Waste Lamps Certain Pesticides Newer additions to UW .
UW does not apply. .Universal Wastes? If it’s not hazardous waste. UW does not require recycling.
Lead-Acid • Does Not Include Non-Hazardous Waste Batteries – Alkaline. Mercuric Oxide. Lithium. Nickel-metal Hydride. Lithium Ion.Batteries (no changes) • Examples: Ni-Cad. Silver. Zinc Carbon • Can Include Lead-Acid Batteries – But Why Do That? . Magnesium.
proper packaging • Contain broken lamps to minimize releases .Hazardous Waste Lamps (no changes) • Include: – – – – – Fluorescent High Pressure Sodium Mercury Vapor Metal Halide Neon • Must minimize breakage.
Two Newer Universal Wastes .
Does not include discarded household appliances per Title 132. Chapter 1.Electronic Items • Electronic equipment containing one or more electronic circuit boards or other complex circuitry. §034 • Includes components and subassemblies or other parts derived from the disassembly of electronic devices .
– TVs & remote controls – Telephones (cell & wired) – Stereo equipment – DVD & VCR players – Digital cameras – Circuit boards – Etc. scanner. printer. etc. keyboard. laptop.Electronic Items • Includes: – Computer monitors • Recent 40 CFR exclusion for CRTs being reclaimed in Title 128 – Computers • Mouse. – But – Only Hazardous Waste Items Red items considered haz waste in NE .
but --– Prevent release to environment – Written procedure • Type of equipment.Electronic Item Management • Containerize in compatible container • Disassembly – Allows full recycling operations with UW electronics. segregation of incompatible waste. O & M of equipment. waste characterization – Spill clean-up kit readily available – Immediately segregate & transfer disassembled items to proper container . proper waste management practices.
Electronic Item Management • Disassembly (cont) – Employee training – Maintain a system to ensure compliance with written procedures – Handler who disassembles or generates waste from disassembly – any handler • Do waste determination on disassembled items or waste materials • If hazardous waste: – May continue to be managed as Universal Waste OR – Handler becomes haz waste generator AND – Accumulation time starts anew at that point in either event • If not hazardous waste: – Comply with appropriate solid waste regulations .
. or plastic casing. glass. mechanical.Mercury-Containing Items • Any electrical. • Mercury must be housed within an outer metal. or medical product or component (excluding batteries and lamps) containing elemental mercury and the elemental mercury is necessary for its operation where mercury acts as a conductor of temperature. pressure. or electricity or acts as a weight damper.
Mercury-Containing Items • Includes: – – – – – – – Thermostats Electrical switches Gauges Sphygmomanometers Thermocouples Mercury-filled pumps Thermometers .
Mercury-Containing Item Management • Containerize leaking items or damaged items that could leak – Closed & structurally sound • Ampoule Removal (same as before) – – – – Prevent breakage Removal over a containment device Mercury clean-up system readily available Immediately transfer leakage/spill to proper container – that becomes hazardous waste – Comply with OSHA mercury levels (ventilate) .
Mercury-Containing Item Management • Ampule Removal (cont) – – – – Employee training Store ampules in closed. waste characterization . sound container Pack with material to prevent breakage Waste determination for residues/other wastes • Mercury Draining – Allowed from open ended items • Aids scrap metal designation – Over containment device – Written procedure • Equipment. O & M of equipment. waste management.
Mercury-Containing Item Management • Mercury Draining (cont) – Spill clean-up kit readily available – Immediately transfer drained mercury to proper container • that mercury is either hazardous waste or CCP – Comply with OSHA mercury levels (ventilate) – Employee training – Store drained mercury in closed. sound container • Document date of accumulation • Max accumulation 45 kg (≈100 pounds) – Waste determination for residues/other wastes .
– Is it a UW violation? – Is it a HW violation? – “It Depends” .Universal Waste Basics • Essentially same as 40 CFR • A claim that something is UW requires full compliance with UW rules.
000 kg (11.000 lbs) accumulated at any time – None in NE (twko) .Hazardous Waste • Small Quantity Handler of Universal Waste – < 5.Universal Waste – Generator -.000 lbs) • Large Quantity Handler of Universal Waste – > or = 5.000 kg (11.Universal Waste Handlers • Difference between HANDLER & GENERATOR – Handler -.
or – Mark each item. or – Accumulation area earliest date.Accumulation • No Longer Than One Year – The great UW shell game sometimes played • Must Be Able To Demonstrate Time Length – Mark container with earliest date UW received in container became UW. or – Inventory system (earliest/each). or – Another method .
so no “used” marking applies . Mercury-Containing Items.XXXX”.Labeling/Marking • “Universal Waste -. Electronic Items. or • “Used XXXX” XXXX = Batteries. or Lamps “Used Pesticides” not allowed. or • “Waste XXXX”.
Comply with UW Transporter Requirements . Chapter 25” • Self-Transport OK -.Shipping • To Another UW Handler or Destination Facility • DOT Rules Apply to Hazardous Materials – Does it have a “proper shipping name?” (49 CFR 172.But: – Non-UW States still need a haz waste manifest • Even if only transport through the state – Comment in Line 15: “Managed as Universal Waste in Nebraska per Title 128.101) • No Hazardous Waste Manifest -.
date • Record off-site shipments – Name & address. Bill of Lading.Required • Record receipt of shipments – Name & address. amount. type. Manifest • Keep three (3) years .Shipping (Cont) • Tracking – Small quantity handler -. Invoice. type. date • Log. amount .Not required – Large quantity handler -.
notification. training • Large Quantity Handlers of UW must obtain a NDEQ ID Number – Easier transportation and tracking • Common carrier • No hazardous waste manifest • Can move between UW handlers (Self Transport) .What Universal Waste Means To Regulated Community • Reduced Regulatory Burden – Can accumulate on-site with reduced labeling. accumulation time.
What Universal Waste Means To Regulated Community • “Counting” – Can generate & accumulate Universal Waste without having to include these wastes when counting hazardous waste generation weights • Storage Time – Can accumulate up to one year vice 90 or 180/270 days • Encourages recycling by relaxing stringent RCRA requirements .
Common Questions • Containers Closed? – Yes.” etc. if a UW pesticide or lamps (broken or unbroken) – No container required. but do it anyway – No for electronic items When Does Accumulation Time Start For Shipment Receipt? – When it is accepted. if non-damaged batteries or mercury-containing items. if the UW shows evidence of “leakage. . except for electronic items – Yes.
Hazardous Waste Electronic Items • Color CRTs (TVs.) • Individual circuit boards • And (items fail TCLP >75% of the time for Pb) – – – – – Laptop computers (100%) Cell Phones Smoke detectors TV remote control (100%) Mouse (100%) • Based on failing standard TCLP – Some other devices “fail” based on a “modified “ TCLP • Above considered HW unless demonstrated otherwise . etc. computer monitors.
Disposal to permitted facilities • Municipal Solid Waste Landfill • Haz Waste Permitted Facility .but…….E-Waste Management Options • Waste determination ! • Management options for electronics that are not hazardous waste: – – – – – Continued use/Reuse Recycling Scrap metal Accumulate Indefinitely --.
E-Waste Management Options • Management options for electronics that exhibit toxicity hazardous waste characteristic: – Hazardous waste • • • • CESQG – Landfill (a non-preferred option) SQG/LQG – HW Manifest Scrap Metal Exemption UW if covered – Refurbishment • “Continued Use” criteria – no change • Generator responsibility to ensure no sham refurbishment • Not HW .
Monitors. and Electronics” – Covers sham refurbishment cues – On NDEQ Web Site .E-Waste Management Options – Variance • Managed by entity with a specific solid waste variance – NE had 1 until new CRT exemption became effective • Not HW – Universal Waste • Not HW – Scrap metal exemption (if warranted) • Not HW • Environmental Guidance Document – “Waste Computers.
Assistance • Jim Harford.state.not inspections – General and specific questions . CHMM • RCRA Compliance Assistance – On-site visits -.ne.call • (402) 471-8308/4210 • jim.us • Web Site: firstname.lastname@example.org/ .state.
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