Management of Hazardous Waste in Missouri

The Management of Hazardous Waste in

MissouriA summary of the regulations of the MDNR

pertaining to hazardous waste, non-hazardous waste, universal waste, and used

oil

Presented by: Daniels Training Services

State Administered Hazardous Waste Programs

• To be authorized a State program must be at least as stringent and as broad as the Federal program.

• The MDNR manages the State’s hazardous waste program.

Federal regulations adopted by MDNR

The Hazardous Waste Determination• The generator of any

waste, must determine what, if any, hazards it contains.

• Process must be documented & records retained.

• May rely on:– Generator

knowledge.– Sample analysis.MDNR doesn’t have a certification program for labs

1. Is it a Solid Waste?

• Any discarded material.• Not necessarily a hazardous waste.• Solid Waste ≠ Solid• May be solid,

liquid,

gas,

or semi-solid.

2. Is it Excluded From Regulation due to Recycling?

• USEPA & MDNR regulations identify exclusions from regulation if waste is recycled.

• Recycling method must be:– Identified by

regulation.Or…– “Legitimate”.

3. Is it Excluded by Regulationas a Solid Waste?

• USEPA & MDNR regulations may exclude a waste.– By type.

Or…– By industry/source.

SOLIDWASTE

• Identified by USEPA and/or States, by:– Process generating.– Technical name.

4. Is it a Hazardous Waste?

Listed Characteristic• Characteristics must be

present.

Federal waste codes will apply

Four Types ofListed Hazardous Waste

Type Waste codeNon-Specific Sources F001 – F039Specific Sources K001 – K181Acute Hazardous Waste P001 – P205

Toxic Hazardous Waste

U001 – U411

Four Types ofCharacteristic Hazardous Waste

Type Waste codeIgnitable D001Corrosive D002Reactive D003Toxic D004-D043

5. Is it a Non-Hazardous WasteThat is Recycled?

• A non-hazardous waste that is recycled is not a solid waste.

• Includes discarded material from an industrial process.– Non-hazardous scrap– Paper– Textiles– Rubber

6. Is it an MDNR Special Waste?

• Discarded non-hazardous waste.• No free liquids.• Differs from municipal, construction, & other wastes.• Requires “special” handling.• Examples:– Raw animal manure.– Contaminated soil.– Incinerator ash.– Industrial or manufacturing process waste & sludge.

More on MDNR Special Waste

• Must be managed on-site in, “an environmentally sound manner.”

• If sent to landfill:– Complete hazardous waste determination.– Submit Special Waste Disposal Request Form to

landfill & obtain approval for disposal.– Provide additional information re. health hazards

or handling/safety requirements.– Update information if changes to wastestream.

7. Is it Trash or Garbage?

• Discarded non-hazardous waste from non-industrial/ commercial process.– Containers and

packaging.– Food waste.– Miscellaneous

office trash.

8. Is it Excluded From Regulationas a Hazardous Waste?

• Regulations may exclude a waste.– By type of waste.

Or…– By industry/source.

HAZARDOUSWASTE

9. Is it a Universal Waste?• Hazardous waste (characteristic or

listed) if managed properly:– Lamps (fluorescent or other).– Batteries.– Mercury containing devices.– Recalled or canceled pesticides.

10. Is it a Used Oil?

• A characteristic hazardous waste destined for recycling or fuel blending.

HAZARDOUS WASTE GENERATOR STATUS

After the identification of all of your wastes, you must determine your generator status from one of the following:Large Quantity Generator (LQG)Small Quantity Generator (SQG)Conditionally Exempt Small Quantity Generator (CESQG)

MDNR differs slightly in its thresholds for the next 18 months

Are you a Large Quantity Generatorof Hazardous Waste (1.0)?

• Generate ≥1,000 kg (~2,200 lbs) of hazardous waste in a calendar month.

1,000 kg/month

100 kg/month

HAZARDOUS WASTE

Are you an LQG (2.0)?

• Generate or accumulate ≥1 kg (~2.2 lbs) of acute hazardous waste in a calendar month.

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1 kg/month

USEPA threshold is >1 kg/mo

Are you an LQG (3.0)?

• Generate or accumulate ≥1 g of dioxin waste in a calendar month.

• Dioxin waste:– 2,3,7,8 –

tetrachlorodibenzo-p-dioxin

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1 g/month

Are you a Small Quantity Generatorof Hazardous Waste?

• Generate or accumulate ≥100 kg (~220 lbs) but ˂1,000 kg (~2,200 lbs) of hazardous waste in a calendar month.

1,000 kg/month

100 kg/month

HAZARDOUS WASTE

USEPA threshold is >100 kg/mo

Are you a Conditionally ExemptSmall Quantity Generatorof Hazardous Waste (1.0)?

• Generate and accumulate <100 kg (~220 lbs) of hazardous waste in a calendar month.

1,000 kg/month

100 kg/month

HAZARDOUS WASTE

USEPA threshold is ≤100 kg/mo

Are you a CESQG (2.0)?

• Generate and accumulate <1.0 kg of acute hazardous waste in a calendar month.

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1 kg/monthUSEPA threshold is ≤1 kg/mo

MANAGEMENT OF HAZARDOUS WASTE IN CONTAINERS FOR LQG’S & SQG’S

The most common option for hazardous waste management differs depending on your hazardous waste generator status. Large Quantity Generators of hazardous waste have the greatest regulatory burden.

HAZARDOUS WASTE MANAGEMENT UNITS

A generator of hazardous waste has four options for the on-site management and accumulation of their hazardous waste. They are…1. Containers2. Tanks3. Containment Buildings.4. Drip Pads.

Obtain a US EPA & MDNR ID #

• ID # is affixed permanently to the geographic location.

• Transfer of ownership requires transfer of ID # to new owner.

Recommended for CESQG in MO

Container Condition

• Container in good condition.• No waste on outside of

container.• Container compatible with

waste.

MDNR Requirementsfor Reuse of Containers

• Original good condition.• Tested for leaks.– Visual OK.

• Proper hazard class labeling.

• Ensure compatibility.

Closed Containers

• Must be closed except when adding or removing waste.

• EPA intent for container:– Vapor tight.– Spill proof.

• Compliance will depend on type of waste (solid v. liquid).

1. “Hazardous Waste.”2. “Federal Law

Prohibits…”3. Generator's name

and address.4. Date of accumulation.

On-Site Hazardous Waste Container Labeling Requirements

From the 1st drop!

• Must have the appropriate USDOT HazMat label:– Corrosive– Flammable– Oxidizer– Other

• Doesn’t apply to satellite.

Hazardous Waste ContainerLabeling Requirements

From the 1st drop!

HazMat Employee Training

• Purpose of MDNR container labeling regs is to have HW containers “ready to ship”.

• Must comply with USDOT/PHMSA regs when HW in storage.

• Therefore, HazMat Employee training is required per USDOT/PHMSA.

Containment System Requirements if >1,000 kg of Liquid Hazardous Waste

• Solid, impervious base.• Drainage control designed

to remove liquids, or;• Containers elevated.• Contain 10% of total

volume or largest container.• Prevent run-on.• Remove overflow.• Doesn’t apply to satellite.

Minimum Requirements forHW Container Storage

• Containers must be protected from contact w/ liquids:– Containment system for >1,000 kg.– Storage designed & operated to drain & remove

accumulated liquid.– Elevate or otherwise protect from liquids.

• If outdoors: Protect containers from precipitation.

Sources of Ignition or Reaction

• Ignitable & reactive waste must be separated & protected from sources of ignition/reaction:– Open flame.– Hot surfaces.– Electromagnetic

radiation.– Sparks.

No Smoking Signs Required

• Required even if entire facility is no smoking.

• Must be conspicuous near reactive & ignitable waste.

• Required in hazardous waste storage areas.

Distance from Property Line

• Reactive or ignitable waste >50 feet from facility property line.

Property Line

>50 ft

Some exceptions

Hazardous Waste On-Site Accumulation Time Limit for LQG

• ≤90 days.• Accumulation begins 1st

moment hazardous waste is generated.

Except for Satellite.• Extension may be granted

by MDNR in special circumstances upon request.

Hazardous Waste On-SiteAccumulation Time Limit for SQG

• ≤180 days.• ≤270 days if TSDF >200

miles away.– Except for Satellite.

• May be granted an extension beyond 180 or 270 days if “unforeseen, temporary, and uncontrollable circumstances”.

Weekly & Daily Inspections

• Inspect facility weekly:– Containers & containment systems.– Include areas outside of Haz Waste storage areas.– Look for leaks & deterioration.

• Inspect areas subject to spills daily:– Loading/unloading areas.– Spill control equipment.– Additional inspections for Haz Waste in tanks.

Preparedness & Prevention

• Internal & external emergency communication.• Fire suppression equipment.– And ensure adequate water supply.

• Spill control & decontamination equipment.• Maintain adequate aisle space (~24-36”).• Attempt arrangements & agreements w/ emergency

responders.

Decontamination Equipment

• MDNR recommends decon equipment be w/i 10 second radius of potential hazard.

• No door should separate hazard from decon equipment.

• Adequate signs.• Well lit.• 15 minutes of water.

Hazardous Waste Release Reporting

• If a fire, explosion, or spill involving HW.

And…• Spill endangers surface

water, human health, or the environment.

• Call National Response Center (NRC) @ 800.424.8802

Call 911 if threat to life or property

• MO Emergency Response Center @ 573.634.2436.

And…

After the Release or Emergency

• Provide for disposal of all wastes.

• Ensure all emergency equipment is fit for use prior to resumption of operations.

• Prepare and maintain a written report documenting the incident & submit to MDNR.

Our

Incident

Within 15 days

MANAGEMENT OF HAZARDOUS WASTE IN CONTAINERS FOR LQG’S

The most common option for hazardous waste management differs depending on your hazardous waste generator status. Large Quantity Generators of hazardous waste have the greatest regulatory burden.

Comply With RCRA AirEmission Standards

• Required for organic solvent Haz Waste.

1. Use UN performance oriented packaging.

2. Must have a cover that forms a continuous barrier with no openings.

Contingency Plan

• Detailed response actions specific to facility for hazardous waste emergency.

• To be immediately implemented in an emergency.• Must contain:– Agreements w/ emergency responders.– Facility emergency coordinator(s):• Home & office: address & phone.

– Emergency response equipment.– Evacuation plan.

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HAZARDOUS WASTE GENERATOR REQUIREMENTS FOR CESQG

Though a CESQG is excluded from compliance with a majority of the RCRA regulations, there are some requirements that apply just to them.

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CESQG Must Complete theHazardous Waste Determination

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CESQG On-Site Accumulation Limit

• Don’t accumulate ≥1,000 Kg of hazardous waste.– If so,

CESQG becomes Small Quantity Generator.

1,000 Kg

HAZARDOUS WASTE

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The “Grave” for CESQGHazardous Waste

• Ensure disposal of hazardous waste at a state approved or RCRA permitted facility.

Approved?Yes No

SATELLITE ACCUMULATION AREA (SAA) REGULATIONS

An important subset of the hazardous waste accumulation regulations. The SAA regulations can be very useful, but are often misunderstood, resulting in violations.

Missouri SAA regulations are very unique

Two ImportantRequirements of SAA’s

1. Must be under the control of the operator of the process generating the waste.

2. Must be at or near point of generation where wastes initially accumulate.

MDNR wants “clear view of SAA at most times”

SAA Limits in Missouri

• No more than 1 x 55 gallon container per hazardous waste per SAA.

Or…• 1 x 1qt container per

acute hazardous waste per SAA.

When Container of any Size is Full

• Date container.– 3 calendar days to

move to Central Accumulation Area.

Friday

Saturday

SundayMonday

• Closed at all times.• Labeled:– “Hazardous Waste”

Or…– Other words that identify the contents.

• Date of accumulation – MISSOURI ONLY.• 1 year limit for on-site accumulation.• No limit on number of SAAs at a generator site or

cumulative total volume.

Final Requirements for SAA’s

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The Four Universal Waste

1. Batteries2. Lamps3. Mercury-containing

devices4. Recalled or canceled

pesticides

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What is a Universal Waste Battery?

• NiCad, lead acid, lithium, mercury, silver, etc.

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What isn’t a Universal Waste Battery?

• Non-hazardous (alkaline) batteries.

• Lead acid batteries being reclaimed.

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What is a Universal WasteMercury Containing Device?

• Device or part of a device with elemental mercury integral to its function.

• Includes:– Thermometers,

thermostats, switches, gauges, manometers, more...

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What isn’t a Universal Waste Mercury Containing Device?

• Liquid metallic mercury.

• Spill clean-up.• Batteries• Lamps

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What is a Universal Waste Lamp?

• Bulb or tube of electric lighting device.

• Includes:– Fluorescent, HID,

sodium vapor, neon, mercury vapor, metal halide, incandescent, & etc.

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What isn’t a Universal Waste Lamp?

• “Green Cap” fluorescents.

“Green Caps” still contain Mercury

What is, and isn’t, aRecalled/Canceled Pesticide

Is• Suspended or canceled

pesticides that are part of a recall.

• Unused pesticides that are the result of a collection program.

Isn’t• Recalled and unused

pesticides managed by farmers per 40 CFR 262.70.

• Those cans of bug spray or unused weed & feed you have in storage.

MDNR-specific requirements for pesticides

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Universal Waste – Handler Status

Small Quantity Handler• Generate or receive UW

for consolidation.• Accumulate <5,000 kg

of Universal Waste.

Large Quantity Handler• Generate or receive UW

for consolidation.• Accumulate ≥5,000 kg

of Universal Waste.

• Also: Transporters & Destination Facilities

Universal WasteHandler Requirements

• Manage to prevent spills & releases.– Spills of UW are a hazardous waste.

• Label containers to ID waste:– “Universal Waste - “

• Train employees or ensure knowledge of proper handling & emergency response.

• Accumulate in appropriate containers.• 1 year of on-site accumulation.– Longer if solely to facilitate disposal.

Additional MDNR regs for LQH’s

What is a Used Oil?

1. Petroleum based or synthetic.– Not animal or

vegetable.2. Used– Not virgin.

And…3. Contaminated by use.

Used Oil General Management

• Labeled “Used Oil”.• Spills and leaks cleaned-up immediately.• No on-site time limit.• Sufficiently impervious secondary containment.• Containers kept closed if exposed to rainfall.• State waste codes if disposed of instead of recycled

or burned for energy recovery:– D096 w/ < 50 ppm PCB’s.– D098 w/ no PCB’s.

OFF SITE SHIPMENTS OF HAZARDOUS WASTE

Unless you treat or dispose of your hazardous waste on site, eventually you must ship it off site for disposal. This step is the “to” in the “Cradle to Grave” management of hazardous waste.The transportation of a hazardous waste is regulated by both the US EPA and the US DOT.

Container Condition

• MDNR on-site storage requirements comply with USDOT/PHMSA regulations.

The Uniform HazardousWaste Manifest

• Required by MDNR, USDOT/PHMSA, & USEPA.

• Documents a shipment of hazardous waste.– From Cradle to

Grave.• Follow USEPA

instructions.

Requires HazMat Employee Training

The Waste Minimization CertificationLarge Quantity Generator

§ 262.27(a)“I am a large quantity generator. I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and I have selected the practicable method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment.”

Small Quantity Generator§ 262.27(b)

“I am a small quantity generator. I have made a good faith effort to minimize my waste generation and select the best waste management method that is available to me and that I can afford.”

• Contact primary transporter or TSDF if no signed copy of the manifest w/i 35 days of signing.

• Submit Exception Report to State if no signed copy of the manifest w/i 45 days of signing.

After the Hazardous Waste Shipment

REGISTERING, REPORTING, & RECORDKEEPING

Compliance with the regulations is never enough. You also must have the documentation to demonstrate a history of compliance. This information is vitally important in the event of an inspection from MDNR.

Notification of Regulated Waste Activity (Form-MO 780-1164)

• Initial registration (w/ $100 fee) to receive:– USEPA Generator ID #:

MOD#########– MO Generator ID #:

00####• Must update for

changes.• Annual registration

renewal w/ fee.

Generator HW Summary Reports

• Reporting year: July 1 to June 30.• LQG’s report quarterly w/i 45 days of end of quarter.• SQG’s report annually by August 14 (w/i 45 days).• Fees based on amount of hazardous waste:– Generated– Land disposed

• Invoices sent in November. Payment due January 1.

Biennial HazardousWaste Report for LQG’s

• Due March 1st of even- numbered year for previous calendar year.

• Report generation and off-site shipment of hazardous waste.

For Additional Information

• Hazardous Waste Management – Handbook for Small-Quantity Generators (Pub2174)

• Hazardous Waste Program: Missouri Specific Requirements

• Hazardous Waste Satellite Accumulation (PUB002215)• Special Waste (PUB002050)• The Universal Waste Rule in Missouri (PUB002058)• Used Oil Contaminated Waste (PUB000153)• Fluorescent Lamps (PUB000024)• Hazardous Waste Generator Registration, Reporting &

Waste Fees (PUB2254)• Hazardous Waste Generator Status Guidance (PUB002

224)

THIS CONCLUDES THE SUMMARY OF MISSOURI HAZARDOUS WASTE MANAGEMENT REGULATIONS

ANY QUESTIONS?