Hazardous wastes require special management practices to protect both our workers and the environment. This section describes basic hazardous waste requirements.
STEPS TO HAZARDOUS WASTE EVALUTION
Step 1A: Evaluate the Wastes
Waste is an unwanted material that must be identified or inventoried carefully for proper disposal. Material Safety Data Sheets (MSDSs) and generator (faculty, staff and or student) who have knowledge of the process resulting in waste are two most helpful sources of information in the identification. It may also be necessary to have the wastes analyzed by a laboratory for characterization. The evaluation process may determine the waste to be exempt or listed hazardous. “Exempt” wastes are materials that by rule are not considered hazardous waste. “Listed” hazardous wastes are materials that the U.S. Environmental Protection Agency, or EPA, has classified as hazardous. The rule cited includes all the materials that are considered exempt or listed hazardous wastes.
Question 1: Is the waste exempt?
Exempt wastes (MN Rule 7045.0120 and 7045.0127) include:
- Normal household refuse
- Nonhousehold refuse (unusable paper, cardboard, untreated wood and plastic)
- Samples sent to a testing laboratory
- Demolition debris
- Used oil (not contaminated with any other solvents) that is recycled
- Scrap metal that is recycled
- Waste discharged to surface waters under a National Pollution Discharge Elimination System (NPDES) permit
- Waste from emergency spill cleanups approved by the MPCA
- Certain wastes containing trivalent chromium
- Empty containers and liners used to hold a hazardous material (except for compressed gases or acutely-hazardous waste). For non-acute hazardous waste, an empty container is defined as having:
- no more than one inch of residue in the bottom
- no more than 3 percent by weight of residue in a container 110 gallons or less in capacity
- no more than 0.3 percent by weight of residue in a container more than 110 gallons in capacity
- aerosol cans that contain no product and no pressure
Question 2: Is the waste a listed a hazardous waste?
Certain classes of chemical wastes are specifically called out or listed in the rules as being hazardous (MN Rule 7045.0135). EPA has assigned a code for each different type of hazardous waste that is listed (e.g., F001).
These wastes are known as listed hazardous wastes. Common listed wastes include:
Hazardous wastes from nonspecific sources:
- F001: Spent halogenated solvents used in degreasing, such as trichloroethylene,methylene chloride, 1,1,1-trichloroethane and carbon tetrachloride.
- F002: Spent halogenated solvents, such as those above but not used as degreasers. Other examples are 1,1,2-trichloro-1,2,2-trifluoroethane and chlorobenzene.
- F003: Spent nonhalogenated, ignitable-only solvents, such as xylene, acetone, methanol and methyl isobutyl ketone.
- F004: Spent nonhalogenated solvents, such as cresols, cresylic acid and nitrobenzene.
- F005: Spent nonhalogenated solvents such as toluene, methyl ethyl ketone, carbon disulfide and benzene. Spent solvent mixtures/blends containing 10 percent before use of F001, F002, F004 and/or F005 compounds.
- F006-F039: Various spent baths and solutions, distillation bottoms, wastewater and filters.
- K-listed wastes: wastes from specific manufacturing processes, such as preserving wood, formulating inks, pigments, chemicals and pharmaceuticals, refining petroleum and metal smelting.
- P-listed acute hazardous and U-listed toxic wastes: typically these materials are discarded chemical products, off-specification products and/or spill residues.
Question 3: Is the waste hazardous because it exhibits a hazardous characteristic?
A waste that exhibits one or more hazardous characteristics is a hazardous waste. Hazardous characteristics include:
Ignitable waste - D001
Liquid wastes having a flashpoint below 140 degrees Fahrenheit; or, a non-liquid waste capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture, or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard; or, an ignitable compressed gas. Examples of ignitable wastes include spent parts-washer waste and spent solvents.
Oxidizing waste - D001
Wastes that add oxygen to a fire. Oxidizing substances often have “per...” at the beginning of the name, “oxide” at the end of the name, or “...ate” in its chemical name. Oxidizers may be used in a manufacturing process to add oxygen. Typically, these materials are used up but, if they are not, the waste material may be hazardous.
Corrosive waste - D001
Water-based wastes having a pH of 2.0 or less (strong acids) or 12.5 or more (strong bases); also, any liquid able to corrode 1/4 inch of steel per year. Automotive battery acid is an example of a corrosive waste.
Reactive waste - D001
Unstable or explosive wastes; wastes that react violently in the presence of water; and, sulfide or cyanide-bearing wastes which give off toxic vapors when exposed to pH conditions between 2.0 and 12.5. Lithium batteries (even spent ones) are an example of a reactive waste.
Lethal waste - D001
Wastes that have been found through testing to cause death when ingested inhaled or absorbed. Typically, lethal wastes are poisons.
Toxicity Characteristic waste - D001
Wastes that, under acidic conditions, release toxic metals, pesticides or volatile organic chemicals above certain limits. Examples of toxic hazardous wastes are photographic fixers, some paints and chemical wastes.
How much Hazardous waste does CSB/SJU Generate?
Excluding exempted waste, College of St. Benedict and St. John’s University each generate an average of < 220 pounds of hazardous waste per month. Based on the table below, both institutions are classified as “Very Small Quantity Generator” (VSQG). This is good, because the less waste we generate, the fewer the regulatory requirements are and the less money we pay for disposal and the annual license fee and finally it is good for our environment.
220 pounds of hazardous waste or less per month (about one-half a 55-gallon drum of liquid waste)
VSQG (Very Small Quantity Generator)
More than 220 pounds but less than 2,200 pounds of hazardous waste per month (about one-half to four 55-gallon drums of liquid waste)
SQG (Small Quantity Generator)
2,200 pounds or more of hazardous waste per month (four or more 55-gallon drums of liquid waste)
LQG (Large Quantity Generator)
Both College of St. Benedict and St. John’s University have Hazardous Waste ID numbers (formerly called EPA ID numbers) that is unique and specific to each location and are used for tracking where wastes are generated and where they are disposed of. We may not ship hazardous wastes legally out of our contiguous property without an ID number.
Waste tracking and annual generator license
CSB/SJU must obtain an annual Hazardous Waste Generator License from Minnesota pollution control agency and pay an annual fee. The application must be submitted by end of January and Licenses are issued by the MPCA just before June 30 of each year. All licensed generators are charged a license fee that varies, depending on the amount of waste generated and how the waste is managed. Generators are also subject to a generator (Superfund) tax which is based on generator size or waste volume and management method.
Waste collection, storage and management
Containers used for storing hazardous wastes must be sturdy, leakproof and made of, or lined with, materials compatible with the wastes stored. Containers must be marked with the following information:
- The words “hazardous waste,”
- Name of the contents of the container (e.g., waste Methyl Ethyl Ketone or paint waste)
- The date the first waste was placed inside (called the “accumulation start date”)
Preprinted labels are available (but not required) for marking containers.
Additional information is required when the waste is shipped. The required Minnesota Department of Transportation (MnDOT) shipping label may also be used for storage. Your waste transporter should be familiar and able to help you with MnDOT shipping requirements.
Step 5: Store wastes correctly
Follow all fire and building codes for wastes stored indoors. In addition:
- Keep containers closed except when wastes are added or removed (this includes bungs and snap rings).
- Place containers holding liquids on a surface impermeable to that particular waste.
- Provide enough aisle space for easy access and visibility.
- Inspect containers at least weekly to ensure they have not deteriorated or are not leaking.
- Separate incompatible wastes, within the storage area.
- Store wastes in an area without floor drains.
We do not recommend this, but if storing wastes outdoors:
- Follow all requirements for indoor storage, listed above.
- Restrict access to individuals responsible for managing the wastes.
- Store wastes on a curbed, impermeable surface.
- Protect wastes from the elements (rain, snow, sunlight) and the risk of inadvertent damage.
You must also meet storage time limits. If you store wastes past storage time limits, you will be subject to additional hazardous waste requirements.
Size Accumulation Limit Storage time Limit
VSQG 2,200 lbs. Ship stored waste within 180 days of the time it is accumulated. Mark on the container the date it became full.
SQG 6,600 lbs. Ship stored waste within 180 days of the accumulation start date.
LQG No limit Ship waste within 90 days of the accumulation start date unless a storage facility permit is obtained.*
* If the treatment, storage or disposal facility is more than 200 miles away, the storage time limit is 270 days.
If you are unable to ship waste within the storage time limit, you may request a 30-day extension from the MPCA (or your metropolitan county hazardous waste office). The request must be made in writing before you reach the storage time limit. Explain why the extension is necessary, the types and amounts of waste affected and the date you now anticipate shipping the waste.
If granted, the extension allows your business to remain within its generator status.
For wastes that accumulate very slowly, designate the container a “satellite accumulation container.” This allows you to accumulate up to one 55-gallon drum of that waste (or one quart of acute hazardous waste) before the storage time clock starts. Mark the accumulation start date on the container when you begin filling it, then the fill date when the container becomes full. Move the satellite container to the permanent storage area within three days of the fill date. Based on the fill date, ship the container off-site according to the storage time limit in the table above. For more information on satellite accumulation requirements, call the MPCA or visit www.pca.state.mn.us/waste/pubs/1-041-05.pdf.
Step 6: transport and dispose of waste correctly
Generators of wastes are responsible forever for their hazardous wastes. This means that even when you give your waste to a transporter or disposal facility, you may be liable for cleanup costs if a release occurs. To ensure your wastes are properly managed and to reduce your liability, choose a transporter and disposal facility with care.
Before you contact a transporter, you need to know:
- Kinds and amounts of waste you wish to have picked up
- Form of the wastes (solid, liquid or sludge)
- Types of containers holding the waste
- How often you need to ship the waste
- Which recycling, treatment or disposal facility the wastes are to be shipped to
Most hazardous wastes are managed by sending them off site. Some wastes can be treated and disposed of on site. Used oil generated by your business or dropped off by the public (not from another business) can be burned for heat recovery on site provided the burner is rated at less than 500,000 Btu/hour and is vented outside. If the total capacity of all fuel-burning equipment on site is less than or equal to 2,000,000 Btu/hour, these emissions are insignificant in terms of air emissions permits. No other hazardous wastes may be burned on site.
Corrosive wastes may be discharged to the sewer once they are neutralized. Before you discharge any materials, check with your local wastewater treatment plant to ensure it can accept these wastes. A sewering notification form may also be necessary before you discharge wastes.
Check with the appropriate metro county hazardous waste office or the MPCA to determine whether you need to complete this notification form. Do not place any industrial wastes in a septic system.
Septic systems are not designed to handle this type of material even if it has been neutralized.
Do not let cost be the only criterion you use in selecting a transporter or disposal facility. Other important factors in selecting a transporter include:
- Is the transporter currently licensed by the Minnesota Department of Transportation (MnDOT)? See www.dot.state.mn.us/cvo/carriersnapshot.html.
- Does the transporter have a good track record? Have they been cited for violations within the last two years? Have they had spills or accidents within the past two years? If so, were appropriate cleanup actions taken? Ask the transporter for the names of other customers and call them for their opinion.
- Does the transporter maintain adequate insurance? Depending on what is hauled and how it is transported, the transporter is required to have between $1 million and $5 million liability insurance.
- Are drivers given proper training? Drivers must be trained on emergency-response procedures, placarding and labeling vehicles, filling out shipping papers, manifesting wastes, labeling and marking hazardous waste containers, loading and handling wastes, and safe vehicle operations.
- Will the transporter ship wastes to the disposal facility you select?
Very Small Quantity Generators (VSQGs) may be able to drop off their own wastes at a collection site where wastes from many VSQGs are consolidated and then shipped to a disposal facility. Although each business must still pay disposal fees, the drop-off program is a convenient and low-cost disposal option. To take advantage of this, you must:
- Apply and receive approval from the drop-off collection site. (There are certain cases where a HW ID number is not needed. The drop-off collection sites can help you determine whether you need a HW ID number).
- Transport wastes from your business only in your business vehicle.
- Follow MnDOT requirements for transporting wastes. For more information, contact the collection program you intend to use.
- Keep all receipts for wastes delivered to drop-off sites. For a list of VSQG drop-off sites, see www.pca.state.mn.us/publications/w-hw2-51.pdf.
Factors to consider when selecting a disposal facility include:
- Does the facility have a good track record? Check with the environmental regulatory agency (similar to the MPCA) in the state where it is based and check with other customers. Often trade associations or peers can also help you.
- How will the facility dispose of your waste? The longer a waste remains in a form that can be released, the higher the liability. For example, incinerating wastes may be more expensive, but liability is much lower.
- Does the facility carry the necessary insurance?
- Does the facility have a plan to deal with spills or accidents? Has the facility ever had to use it?
- How are ash, sludge and empty containers managed?
If possible, visit the facility. Look for general good housekeeping, workers using safety equipment, warning signs, fencing to restrict access to the site, and condition of building, tanks and equipment.
Questions to consider in selecting a trasporter
Step 7: Manifest hazardous waste shipments
A manifest is a multiple-page shipping paper that must accompany each shipment of hazardous waste (VSQGs using drop-off sites only need shipping papers per MnDOT requirements). The manifest is the tracking document used to show that your wastes reached their proper destination. One manifest is prepared for each shipment of waste.
You can obtain blank manifests from your transporter, disposal facility or the Minnesota Bookstore (651)297-3000. http://www.comm.media.state.mn.us. Make sure the manifest information is correct. Remember, you are responsible, not the transporter. The most common problems found on manifests include:
- Not legible — use a ball-point pen, press hard and print legibly.
- Missing required signatures and dates — make sure to complete all information in the certification section.
- Valid numbers — make sure you use a valid HW ID number for your location and that the transporter and disposal facility also use valid ID numbers.
- MnDOT information missing or incorrect — make sure to complete all information in this section carefully.
The universal manifest contains six pages which are distributed as follows:
- Give pages 1-5 to transporter
- Gend a photocopy of page 6 to the appropriate address in the chart below
- Keep page 6 for your records
When the disposal facility receives the waste, it will sign and send a page back to you. Within five days of receiving it, make a photocopy and mail to the appropriate address above. Keep the page with your records for at least three years. If the disposal facility does not send you a signed page within 35 days, contact them to ensure they received the waste. If you do not receive it within 45 days of shipment, notify the MPCA.