Universal Waste Management
Documents:
Please see the Environmental Documents page for program-specific environmental documents and work instructions.
Universal wastes are hazardous wastes that are subject to
less stringent hazardous waste management regulations, particularly by
allowing more time for accumulation of these wastes in order to facilitate
appropriate recycling or disposal. Five types of waste are covered under the
universal waste regulations:
Universal waste can be stored for up to one calendar year before
being shipped off site. However, Fort Novosel requires generators to turn
them in for disposal within six months in order to ensure the shipment
timeframe is met.
The accumulation
start date must be marked on all universal waste containers, indicating the
date the first item was added.
Labeling and storage requirements differ for hazardous waste
and universal waste. Please ensure personnel handling these wastes receive
proper training and follow the proper procedure for each type. For additional
information on Universal Waste Management, please refer to the HWMP and the
associated Work Instructions. For more information on hazardous waste, please
see the
Hazardous Waste Management program page.
Batteries
A used battery is a device that produced electricity and may
have several primary or secondary cells arranged in parallel or series. The
following table provides common battery types used on Fort Novosel. Non-hazardous,
universal waste, and lead-acid batteries should each be segregated from the
other types to ensure proper handling.
All containers of batteries will be reviewed by HMCC staff
prior to turn in. Please coordinate in advance with HMCC (Bldg. 1315, 334-598-1037)
for amounts in excess of one 5-gallon container of batteries. Following HMCC
review, of large quantities of batteries should be taken to the Fort Novosel
Recycling Center (Bldg. 9322, 334-255-0468).
Used batteries must be accumulated in a properly labeled, DOT-approved
container with a closing lid; or, for larger lead-acid batteries, stored in
covered areas on pallets or in a covered spill containment pallet. Batteries
should not be stored directly on the ground or the floor. All batteries must be
stored with consideration for potential compatibility issues. Example labels by
battery type are provided in the table below.
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Battery Types
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Management
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Example Label
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Alkaline (9-volt, D, C, AA,
AAA, alkaline button, etc.)
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Non-Hazardous Waste (NR),
recycled when possible
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|
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Lithium, Nickel-Cadmium,
Mercuric-Oxide (button and other), Nickel-Metal Hydride, Silver Oxide,
Silver-Zinc, Zinc-Carbon, Zinc Air
|
Universal Waste (UW), recycled
when possible. Generators are required to prevent short-circuiting by:
·
Placing batteries in the original inner
package,
·
Taping the positive end of the batteries, or
·
By using plastic "baggies" to
separate individual batteries
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|
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Leaking / Damaged NR or UW Batteries
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Place in a sealed plastic bag or wrap with plastic and seal with tape
before adding to container with intact used batteries
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Either NR or UW label depending on type
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Lead-Acid
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Managed as one-for-one exchange
for recycling; coordinate through HMCC
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No label required
|
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Leaking / Damaged Lead-Acid Batteries
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Hazardous Waste (HW), turn in through 90-Day site.
Refer to ENV-SW010: Contractor Hazardous Waste Management and call 334-255-1024
for assistance.
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|
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Battery Containing Equipment
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Remove and manage batteries by
type when possible; turn in batteries to HMCC and equipment to Recycling
Center.
If batteries cannot be safely
removed, ensure they are securely installed in the equipment and turn in to
Recycling Center.
|
Label
container with removed batteries by type.
No
label required on equipment.
|
Please refer to the HWMP and ENV-SW002: Used Battery
Management for details.
Pesticides
The universal waste requirements do not apply to pesticides
that are not wastes or are not hazardous wastes. See Pest
Management program page for more information on pesticides.
Mercury-Containing Equipment
Mercury-containing equipment means a device or part of a
device (including thermostats but excluding batteries and lamps) that contains
elemental mercury integral to its function. Thermostats and thermometers that
contain mercury are the most common types of this equipment found on Fort
Novosel.
Organizations manage these items as a universal waste when
they are no longer usable. The items must be accumulated in a DOT-approved
closed container that is labeled “UNIVERSAL WASTE - MERCURY CONTAINING
EQUIPMENT.” Because the thermostats and thermometers can be easily broken, care
must be taken when packaging this waste. Organizations should obtain
vermiculite to package these items in a manner to prevent accidental breakage. Before
the six-month mark is reached, the organization should turn in the waste to the
HMCC for disposal through the DLADS contractor.
Lamps
Lamps are the bulb or tube portion of an electric lighting
device. Universal waste lamps include all fluorescent and high-intensity
discharge (HID) lamps, including mercury vapor, metal halide, metal hydride,
halogen and high-pressure sodium lamps, as described in ENV-SW003: Used Lamps
Management. Many of these lamps contain levels of mercury which require special
handling and disposal. Lamps that are not waste because they have not been
discarded or that are not hazardous waste are not universal wastes.
Used lamps must be accumulated in a DOT-approved container
(or the original container and sealed with tape), labeled “UNIVERSAL WASTE –
USED LAMPS”. The container must be kept closed at all times except when adding
or removing bulbs.
Broken lamps shall be collected, doubled-bagged in plastic
bags, and containerized in accordance with the procedures in ENV-SW003: Used
Lamps Management. The collected waste shall be managed as hazardous waste in a
HWSAA or 90-HWCAA in accordance with the HWMP. Vacuums/HEPA vacs shall not be
used to clean up broken lamp spill residue because the mercury vapor may be
released when heated during subsequent uses of the equipment.
Aerosol Cans
An aerosol can is a non-refillable receptacle containing a
gas compressed, liquefied, or dissolved under pressure, the sole purpose of
which is to expel a liquid, paste, or powder and fitted with a self-closing
release device allowing the contents to be ejected by the gas. (40 CFR 273.9)
All aerosol containers must be turned in to the HMCC for
proper management and/or disposal. The HMCC will make the determination of
aerosol serviceability.
Used aerosol cans must be accumulated in a compatible,
structurally sound container labeled “USED AEROSOL CANS” and “RETURN TO HMCC”.
Leaking aerosol cans must be packaged in a separate closed container or overpacked
with absorbents and be turned in immediately to be safely punctured and drained
by HMCC staff.
Aerosol cans with product may be put into the Free Issue
Program. The Free Issue Program allows excess, usable materials to be donated
back to the HMCC for redistribution to minimize hazardous waste generation.
Aerosol cans that are not a hazardous waste are not a
universal waste (ex: compressed air for cleaning electronics, sunscreen or
whipped cream). Empty aerosol cans (defined in 40 CFR 261.7) are not a universal
waste. Nonhazardous and empty aerosol cans are punctured and recycled as scrap
metal.
Aerosol cans are frequently hazardous due to flammable
propellants such as propane or butane, or for other listed hazardous components
or characteristics. Aerosols that are not functioning will either be punctured
and processed as scrap metal or will be properly disposed of by the HMCC.
Universal
Waste Inspections
In order to help ensure universal waste is properly managed,
organizations are encouraged to use the universal waste section of USAACE Form
2717, Environmental Compliance Inspection Checklist (from the link on this
page) to assess compliance of their accumulation practices.
Contact Information
Hazardous Waste Program Manager: Bldg. 1121, 334-255-1024
Hazardous Materials Control Center (HMCC): Bldg. 1315,
334-598-1037