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H&H Enpmwnng Ccmstnxiion Inc[ Managing Universal Waste 212 tmdustna�Drive Sitnclmm,Ca 95206 40 CFR 273 & 22 CCR 66273 6. Unnrersal Waste Disposal Policy(22 C---C__R-6-6 2 7 3- 6.1. The Universal Waste Disposal Policy ensures minimal harm will result to people,organisms and the environment from the disposal of universal waste. 6.1.1 The policy is based on the definition that H&H Engineering Construchon Inc. is large quantity generator based on the requirements of 40 CFR 273 and 22 CCR 66273 H&H Engineering Construction lin does not accumulate 5,000 kg or more total of universal waste(batteries, pesticides —not in California, thermostats, or lamps.. calculated collectively)at any one time. Training- -*--(-2 2_CCR 6_6 2-7-3) 7.1 Employee training applicability and requirements 7.1 1 Trai0ing applies to all personnd who work with materials as defined by uoiversal was,to regulations. 7..1,4 Trafriing will include how to handle, store, package and label universal waste containers. 7.1.5 Written instructions, such as this plan, are adequate to meet training requirements 8. Procedure for Storing Universal Wastes(22 CCR 66273) 8.1 Various methods can be used to demonstrate the length of time the waste has been accumulated: a) Label container with the date of the first waste placed in the container b) Mark or label each waste (i.e. battery)when it becomes a waste c) Maintain an inventory of when each material becomes a waste d) Place waste in an accumulation area and identify the date the first waste is placed in the accumulation area. e) Universal waste can be stored for one year after generating or receiving the waste. Universal waste cannot be treated except when cleaning up a release or managing specific wastes as stated in §66273.13, for example, removing mercury ampoules from thermostats or electrolyte from batteries. 8.2 Additional Storage Requirements 8.2.1 Batteries: Applies to Alkaline, nickel-cadmium, silver button, mercury, small sealed lead acid batteries(burglar alarm and emergency light batteries), and carbon-zinc. 8,2.1.1 No storage requirement if battery is in good condition. 821.2 Batteries must be segregated based on type. Zinc batteries must never be stored in the same container as alkaline batteries. Universal Waste Procedure d.c Page 4 of 7 Version 2 (January 2014)