Compliance Bulletin Hazardous Waste Lighting Waste reviewed/revised August PDF

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Lamp Wastes Many commonly used lamps contain small amounts of mercury and other metals. Such lamps include fluorescent, high-pressure sodium, mercury vapor and metal halide lamps. Used lamps are a Resource
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Lamp Wastes Many commonly used lamps contain small amounts of mercury and other metals. Such lamps include fluorescent, high-pressure sodium, mercury vapor and metal halide lamps. Used lamps are a Resource Conservation and Recovery Act (RCRA) hazardous waste if the material exhibits the characteristic of toxicity for these metals. According to the Environmental Protection Agency (EPA), testing of burned-out fluorescent lamps showed that a high percentage of the lamps tested exhibited the toxicity characteristic for metals, particularly mercury. Which lamps are not regulated as hazardous waste? Mercury-containing lighting wastes are not regulated as hazardous wastes if they are generated by households or other residential sources. Household includes singlefamily homes, apartments, hotels and motels, retirement homes, bunkhouses, ranger stations, crew quarters, picnic areas, campgrounds, and day-use recreation areas. Residential wastes may be recycled, disposed of through a local household chemical waste collection facility, or if these options are not available, disposed of in a municipal solid waste landfill. Several lighting manufacturers now produce lowmercury versions of their products. Testing done by the manufacturers demonstrate that these low-mercury lamps do not tend to fail the toxicity test for metals and can therefore be managed as non-hazardous solid wastes, even by non-residential facilities. These low-mercury lamps are clearly marked with either green printing or green end caps to distinguish them from higher mercury products. Mercury-containing lighting wastes from nonresidential sources that are not hazardous may be disposed of in a properly managed municipal solid waste landfill or sent to a legitimate recycler. Landfills and recyclers may impose their own restrictions to regulate incoming wastes in accordance with local rules or company guidelines. Which lamps are regulated as hazardous wastes? While household wastes are exempt from the Colorado Hazardous Waste Regulations, non-residential sources like businesses, schools and government agencies must determine if their lighting wastes are hazardous wastes. If, using the Toxicity Characteristic Leaching Procedure (TCLP) test, the extract from a representative sample of Page 1 of 6 Compliance Bulletin Hazardous Waste Lighting Waste reviewed/revised August 2002 the waste contains mercury at a concentration greater than or equal to the maximum contaminant concentration of 0.2 ppm (mg/l), the lamps would be hazardous waste. This waste would carry the hazardous waste code D009. Many mercury-containing lamps also contain elevated levels of lead and may exhibit the toxicity characteristic for lead as well (TCLP 5 ppm lead). Such wastes would also carry the hazardous waste code D008. Non-residential sources of hazardous wastes must follow State hazardous waste regulations for proper management and disposal of hazardous wastes applicable to their generator category. If the lighting wastes have not been tested to show that they are not hazardous, or if the generator doesn't have other supporting data, then the generator should assume the lamps are hazardous and manage them as hazardous waste. The generator may use data obtained from the manufacturer, other generators, or published studies to assist with their hazardous waste determination. How should lighting wastes determined to be hazardous waste be managed? Hazardous wastes lighting wastes can either be managed in full compliance with the Colorado Hazardous Waste Regulations [6 CCR ] Parts , 99 and 100, or they can be managed in compliance with the reduced requirements of the Universal Waste Rule in Part 273. The Guide to Generator Requirements of the Colorado Hazardous Waste Regulations describes the requirements applicable to each generator category if the generator decides to manage their lighting waste under the full requirements of Parts , 99 and 100. The Guide is available on the Division website or by calling the Hazardous Materials and Waste Management Division. The Universal Waste Rule provides an alternative set of reduced management standards that the generator can follow instead of the full hazardous waste requirements. This rule was designed to reduce the regulatory burden on non-residential entities that generate these wastes and to encourage recycling, while at the same time reducing the amount of hazardous waste items illegally sent to municipal solid waste landfills. What are the disposal options for hazardous waste lamps? A generator can send his/her hazardous lighting waste to a facility that legitimately recycles the waste. A recycler for hazardous lighting waste must be permitted as a hazardous waste storage facility if the material is not recycled within 24 hours of receipt at the facility, but the recycling process itself does not require a hazardous waste permit. Alternatively, a generator should ensure delivery of their hazardous lighting waste to a permitted hazardous waste treatment, storage or disposal facility (TSDF). Municipal solid waste landfills in Colorado are not permitted to accept any quantity of non-residential hazardous waste for disposal. What are Universal Wastes? The Universal Waste Rule [Colorado Hazardous Waste Regulations 6 CCR Part 273] includes certain hazardous wastes that are commonly generated by very small to very large non-residential sources such as businesses, governmental agencies, and schools. Universal wastes are subject to wide spread use, which makes disposal of these hazardous wastes difficult to control. Universal Wastes include many: batteries pesticides mercury-containing devices mercury-containing lighting wastes aerosol cans electronic devices and components Materials included as universal wastes are regulated under the Resource Conservation and Recovery Act (RCRA) and have been required to be handled as hazardous wastes since the early 1980s. In the past, if these wastes were determined to be a hazardous waste, small and large quantity generators of hazardous waste needed to manage them in full compliance with the hazardous waste regulations, including labeling, employee training, manifest requirements, and restrictive time limits. Why manage a waste as universal waste? Managing wastes as universal wastes is most beneficial to small and large quantity generators of hazardous waste, or conditionally exempt small quantity generators that would otherwise be small quantity generators if they did not manage some of their wastes as universal wastes. The primary benefits of choosing the reduced management standards of the universal waste rule are Page 2 of 6 that the waste does not count toward the monthly total of hazardous waste in determining generator category; the waste can be shipped without a hazardous waste manifest; the waste can be shipped by common carrier instead of a hazardous waste transporter; there are reduced notification and record-keeping requirements, and the storage time limits are less restrictive. Because universal waste does not require a hazardous waste manifest for shipment in Colorado, it is not considered hazardous waste under US Department of Transportation regulations, though other regulations may apply. State requirements for universal waste transporters are included in 6 CCR Part 273 Subpart D. What are the requirements for universal waste management? Categories of Universal Waste Handlers Under the Universal Waste Rule, persons who generate or accumulate waste batteries, pesticides, mercury containing devices, aerosol cans containing hazardous wastes, mercury-containing lamps or electronic devices and components are considered handlers of universal waste. [6 CCR Section 273.9] [Note: this definition is different from that of a generator of hazardous waste]. There are two categories of handlers, Small Quantity Handlers of Universal Waste and Large Quantity Handlers of Universal Waste. A small quantity handler of universal waste is one who does not accumulate more than 5,000 kilograms of total universal at any one time. A large quantity handler of universal waste is a handler of universal waste who accumulates 5,000 kilograms or more of total universal waste. [6 CCR Section 273.9] In either case, a handler cannot accumulate more than 35 kilograms (about 77 pounds) of elemental mercury at one time. The designation of small quantity or large quantity handler of universal waste has no relationship to a facility s hazardous waste generator status. Thus a small quantity generator of hazardous waste may be a large quantity handler of universal waste, and vice versa. If, at any time during a calendar year, a facility exceeds the quantities for a small quantity handler of universal waste, they would be considered a large quantity handler until the next calendar year when they can re-evaluate their status. [6 CCR Section 273.9] Labeling When a universal waste is generated, it must be labeled as either Waste Lamp (s), Used Lamp(s) or Universal Waste Lamp(s). If the waste is placed into an accumulation container, only the accumulation container needs to be labeled as containing universal waste lamps, not the individual waste lamps within it. If an individual waste lamp is not in good condition and is showing signs of breakage, leakage or damage, it must be individually over-packed in a closed packing container that is properly labeled and capable of preventing leakage or releases of hazardous constituents to the environment under reasonably foreseeable conditions. [6 CCR Sections , ] If the accumulation container is not in good condition, it must be over-packed, or the wastes must be removed and put into a container that is in good condition. Accumulation of Waste Universal waste handlers are required to manage their waste in a manner that prevents releases of the waste or waste constituents. [6 CCR Sections , ] There is a one-year accumulation time limit, and handlers must be able to demonstrate that universal waste on-site has not been accumulated for more than one year. [6 CCR Sections , ] Although it is not required to be marked with the accumulation start date, this would be the easiest way to document that the waste is in compliance with the oneyear accumulation limit. Shipment of Waste A universal waste handler cannot dispose of universal waste on site without a permit, and treatment by the handler is not allowed except under limited conditions (see the section on handler treatment). Universal waste can only be shipped to another universal waste handler, a destination facility or a foreign destination. Shipment to another universal waste handler is allowed to aid in consolidation of wastes. A destination facility is a facility that is permitted to treat, dispose, or recycle the waste. [6 CCR Section 273.9] Shipment of universal waste in Colorado does not require the use of the hazardous waste manifest system. Therefore, universal waste is not considered hazardous waste under US DOT regulations. The US DOT regulates some universal wastes as hazardous materials because they meet criteria for one or more hazard classes, but the word waste may not be used in the shipping name. [6 CCR Section ] Other states may have different requirements for wastes that are managed as universal waste in Colorado. The handler should always confirm the regulatory status of universal wastes in the destination state and in all intervening states the waste will travel through. Notification Small quantity handlers of universal waste are not required to notify the Division of their universal waste management activities. [6 CCR Section ] Large quantity handlers of universal waste are required to notify the Division of their universal waste management activities and obtain an EPA identification number using EPA Form [6 CCR Section ] This must be done even if the facility has previously given notification and received an EPA identification number for its hazardous waste activities. The EPA identification number will remain the same. Employee Training Small quantity handlers of universal waste are required to inform all employees who manage universal waste about the proper handling and emergency procedures appropriate to the types of universal waste at the facility. [6 CCR Section ] Large quantity handlers of universal waste are required to ensure that personnel are thoroughly familiar with the requirements for universal waste management and emergency response relative to their level of responsibilities in dealing with the waste. [6 CCR Section Spills All handlers of universal waste are required to immediately containerize and appropriately manage any spills or residues from releases of universal wastes. [6 CCR Sections (a), (a)] The waste generated from a release of universal waste would be considered newly generated waste, and a hazardous waste determination would need to be made. If it is determined that any or all of the released material or residue is hazardous, it must be managed in accordance with the hazardous waste regulations and not the universal waste requirements. [6 CCR Sections (b), (b)] The handler of the universal waste at the time of the release would be the generator of the newly generated hazardous waste and must adhere to all applicable requirements of the Colorado hazardous waste regulations. Record Keeping Requirements A small quantity handler of universal waste is not required to maintain records. [6 CCR Section ] However, it is strongly advisable to keep adequate records to document waste management practices and substantiate the facility s universal waste handler status. A large quantity handler of universal waste must keep written records for universal wastes shipped to and from its facilities. These records must be kept for at least three years and include: the types and quantities of universal waste shipped or received, the date the waste was shipped or received, and to whom the waste was shipped. [6 CCR Section ] There is no Page 3 of 6 requirement to maintain formal training records for either category. Transporters of universal waste are required to keep records in accordance with US DOT requirements. A destination facility is subject to all applicable requirements of 6 CCR Parts , 99 & 100. If the destination facility recycles the universal waste without storing it, they need only notify the Department of their activity under 6 CCR Part 99 and keep records of each shipment. If the destination facility is a Treatment Storage and Disposal Facility (TSDF), they are required to keep records in accordance with their hazardous waste permit. Can a universal waste handler treat its hazardous wastes? Universal waste handlers can t dispose of universal wastes on site without a permit and treatment by the handler is not allowed except under limited conditions. Crushing of universal waste lamps by handlers of waste mercury-containing lamps is allowed as long as it is conducted in accordance with the requirements of Part or of the Colorado Hazardous Waste Regulations. Prior to crushing waste lamps, a handler must develop and implement a written procedure detailing how to crush the lamps safely. Included in this document must be the type of equipment to be used, operation and maintenance of the equipment, and the precautions that need to be taken to protect all workers. In addition, the document must include a review of the wastes that will be generated from the crushing activities. Handlers of universal wastes must ensure that the waste lamps are crushed in a completely enclosed system that is designed to prevent the release of any universal waste or component of universal waste to the environment (for example, a sealed tank or container that is equipped with, at minimum, a filter to capture mercury emissions). Special management procedures necessary to manage the waste properly also need to be evaluated prior to crushing. The handler must ensure that the area in which the universal waste lamps are crushed is well ventilated and monitored to ensure compliance with applicable regulatory exposure levels for mercury. Additionally, the written procedure must detail the frequency of filter change out. [Note: it may be necessary to file an Air Pollution Emission Notice (APEN) for the crushing operation and/or to use control devices to capture airborne contamination]. A spill kit must be readily available in case wastes are spilled during the crushing activities. A small or large quantity handler of universal waste who crushes universal waste lamps must determine whether Page 4 of 6 the crushed lamp, its residues and/or any other solid wastes generated (e.g., filters) exhibit one or more characteristics of hazardous waste. If the crushed lamps exhibit such a characteristic, they may continue to be managed as universal waste, or they may be managed in compliance with 6 CCR Parts , 99 and 100. If the crushed lamps are no longer managed as universal wastes, then the handler is considered the generator of the newly generated hazardous waste. If the residues or other solid wastes generated during the crushing process exhibit one or more characteristics of hazardous waste, the handler is considered the generator of the newly generated hazardous waste and must comply with all applicable sections of 6 CCR , 99 and 100. Wastes generated during the crushing process, exclusive of the crushed lamps themselves, may not be managed as universal wastes. If the crushed universal waste lamp, its residues and/or any other solid wastes generated do not exhibit any characteristics of hazardous waste, the handler may dispose of them as solid wastes. What about Conditionally Exempt Small Quantity Generators (CESQG)? Conditionally exempt small quantity generators are those that generate less than 100 kilograms (approximately 25 gallons or 250 pounds) of total hazardous waste and no more than one kilogram of acutely hazardous waste per calendar month AND never accumulate more than 1000 kilograms of hazardous waste on site at one time. In Colorado, conditionally exempt generators are not excused from identifying which of their wastes are hazardous wastes and must ensure that their wastes are sent to a facility that is permitted to accept it. Conditionally exempt small quantity generators may choose to manage their mercury-containing lights as conditionally exempt wastes or as universal wastes. [6 CCR Section 273.8] Because of the reduced management requirements already applicable to conditionally exempt small quantity generators of hazardous waste, it is generally not to their benefit to manage their wastes as universal waste, unless they would otherwise be small quantity generators. Unlike small and large quantity generators of hazardous waste, conditionally exempt generators are not required to notify the State of their regulated waste activity or to get an EPA identification number. There is no time limit on how long they may store their hazardous waste on site as long as they don t exceed the quantity limits for conditionally exempt small quantity generators, and they may transport their hazardous waste without a hazardous waste manifest under a standard bill of lading. Conditionally exempt generators may not dispose of their hazardous wastes on site or send them to a solid waste landfill in Colorado. These wastes must be sent to a permitted hazardous waste treatment, storage or disposal facility (TSDF), sent to a legitimate recycler of the waste, or sent to an out-of-state solid waste disposal facility that is permitted to accept conditionally exempt small quantity generator hazardous wastes. PCB-containing Light Ballasts Ballasts are small metal box-shaped devices in fluorescent lamps that control the flow of electricity to the light tube. Some metals contained in the ballasts can be reclaimed, but many ballasts contain polychlorinated biphenyls (PCBs). All fluorescent light ballasts manufactured through 1979 contain PCBs. Ballasts manufactured after 19
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