the hazardous waste compliance guide

The

Hazardous WasteCompliance Guide

520 Lafayette Road North St Paul Minnesota 55155-4194

This guide has been revised by the Minnesota Pollution Control Agency in cooperationwith metropolitan county hazardous waste staff the Minnesota Technical AssistanceProgram and the Minnesota Department of Transportation Revision date 1105

w-hw5-25

The purpose of the Minnesota Pollution Control Agencyrsquos Hazardous Waste Program is to preventharm to human health and the environment through proper management of hazardous wasteThe purpose of this manual is to provide information to hazardous waste generators that explainsproper waste management and encourages compliance with hazardous waste rules

Statement of Purpose

copy2004 State of Minnesota Minnesota Pollution Control AgencyAll rights reserved

EPA

MPCA

Metro CountiesAnokaCarverDakotaHennepinRamseyScottWashington

HazardousHazardousHazardousHazardousHazardousWaste Regulatory AgenciesWaste Regulatory AgenciesWaste Regulatory AgenciesWaste Regulatory AgenciesWaste Regulatory Agencies

The US EnvironmentalProtection Agency (EPA)administers the hazardouswaste programs in many statesbut not in Minnesota The EPAhas given the Minnesota PollutionControl Agency (MPCA) authority to run its own program withEPA oversight Likewise the seven metropolitan counties haveauthority to run their own programs with MPCA oversightHazardous waste generators located in Greater Minnesotareport to the MPCA Those located in the metro area report totheir respective county office

AnokaCarverDakotaHennepinScottRamseyWashington

EPA

MPCA

MetroCounties

3copy2004 State of Minnesota Minnesota Pollution Control AgencyAll rights reserved

Table of Contents

Introduction 4

Section 1 Steps to ComplianceSection 1 Steps to ComplianceSection 1 Steps to ComplianceSection 1 Steps to ComplianceSection 1 Steps to Compliance

Step 1A Evaluate Waste 5Waste Evaluation Review (flowchart) 12

Step 1B Determine Generator Size 13Step 2 Get an EPA Identification Number 16Step 3 Get a License Pay a Fee 20Step 4 Place Waste in Containers Mark Them 24Step 5 Store and Accumulate Properly 27Step 6 Transport and Dispose of Waste Correctly 31Step 7 Prepare and Distribute the Manifest 38Step 8 Plan for Emergencies 45Step 9 Train Employees 52Step 10 Keep Records 55

Section 2 Special TopicsSection 2 Special TopicsSection 2 Special TopicsSection 2 Special TopicsSection 2 Special Topics

Discharging to the Sewer 59Used Lead-Acid Batteries 61Reducing Waste 63Parts Washers 66Used Oil 67Electronic Waste 76Universal Waste 79

AppendicesAppendicesAppendicesAppendicesAppendices

A Sample Material Safety Data Sheet (MSDS) 82B Sample of Laboratory Test Results 84C Managing Empty Containers 85D Documenting Container Inspections 87E LDR Policy 90F SQG Emergency Planning Packet 92G Employee Training Documentation 97H Battery Shipping Log 98

Index 100Hazardous Waste Related Contacts 101

4copy2004 State of Minnesota Minnesota Pollution Control Agency

All rights reserved

In response to widespread public concern over the results of improperhandling and disposal of chemical wastes the US Congress enacted theResource Conservation and Recovery Act (RCRA) in 1976 RCRA(pronounced wreck-ra) is the primary legislation authorizing the USEnvironmental Protection Agency (EPA) to develop and oversee anationwide program to regulate hazardous waste management UnderRCRA EPA wrote regulations which became effective in November 1980These regulations provide

bull a definition of hazardous waste including lists of hazardouschemical wastes

bull handling requirements for generators and transporters ofhazardous waste

bull a manifest system to track hazardous waste from the site ofgeneration (ldquocradlerdquo) to final disposal (ldquograverdquo)

bull permit requirements for facilities that treat store or dispose ofhazardous waste and

bull requirements for state hazardous waste programs

The EPA delegated authority to many states to operate their ownhazardous waste regulatory programs Minnesota received thisauthorization on February 11 1985 The hazardous waste program isoperated by the Minnesota Pollution Control Agency (MPCA) underMinnesota Rules Chapters 7001 7045 and 7046 Copies of the MinnesotaHazardous Waste Rules are available for a fee from the MinnesotaDepartment of Administration Documents Section The rules can also beaccessed through the MPCA Web site

Although the MPCA is responsible for administering Minnesotarsquos overallhazardous waste program state statute requires the seven twin-citymetropolitan counties mdash Anoka Carver Dakota Hennepin Ramsey Scottand Washington mdash to adopt ordinances that embody and are consistentwith the Minnesota Hazardous Waste Rules As these hazardous wasterules are amended ordinances must also be amended Metropolitan-county generators are required to be in compliance with the MinnesotaHazardous Waste Rules as well as any applicable county ordinances

To help you comply with the rules the MPCA has developed a systematicapproach to hazardous waste management called the ldquoTen Steps toCompliancerdquo The steps are explained in this manual

Introduction


Step 1AEvaluate Waste

What is a ldquowasterdquoWhat is a ldquowasterdquoWhat is a ldquowasterdquoWhat is a ldquowasterdquoWhat is a ldquowasterdquo

A waste is a material that you no longer need use or want it is somethingthat is not usable or is intended to be discarded such as spent solventA waste is not something that you can and will use such as leftover paintfrom a project that will be used on another projectWhen you the ldquogeneratorrdquo of the waste determine a material is no longerusable it is a waste and must be managed accordingly It becomesldquowasterdquo when generated not when shippedMinnesota Hazardous Waste Rules require that ldquoanyone who produces ormanages a waste must evaluate that wasterdquo mdash that is carefully examine awastersquos characteristics in order to determine whether or not it ishazardous A waste can be nonhazardous thereby exempt from thehazardous waste rules or it can be hazardous for one of three reasons

1 it is ldquolistedrdquo mdash appears on one of four lists in the MinnesotaHazardous Waste Rules

2 it is ldquocharacteristicrdquo mdash displays one ormore of six hazardous characteristics or

3 it contains more than 50 parts permillion (ppm) polychlorinated biphenyls(PCBs)

Before You EvaluateBefore You EvaluateBefore You EvaluateBefore You EvaluateBefore You Evaluate

Make a list of all waste What does your businessactually discard Include all areas of your businessin your list Talk to purchasing production andmaintenance personnel tour production andnonproduction areas and inspect storage areas anddumpsters Donrsquot forget to include sewered andrecycled waste You may also wish to checkincoming materials and talk to your vendor tomake sure all potential wastes have been identified

EvaluateEvaluateEvaluateEvaluateEvaluate

First check to see whether any wastes areexempt from the Minnesota Hazardous WasteRules Refer to Table 1 for a list of common exemptwastes Remember an exempt waste may still beregulated as an industrial solid waste wastewaterwaste resulting from a spill or air emission

(Minn R 70450214)

Table 1 Common Exempt Wastes(Minn R pts 70450120 and 70450127)

bull Normal household refusebull Nonhousehold refuse (unusable paper

cardboard untreated wood and plastic)bull Samples sent to a testing laboratorybull Scrap metal destined for recyclingbull Demolition debrisbull Waste that meets the definition of

hazardous waste that is generated instorage tanks transport vehicles orpipelines until it leaves these units

bull Waste discharged to surface watersunder a National Pollution DischargeElimination System (NPDES) permit

bull Air emissions permitted by the MPCAbull Mining overburden and certain wastes

from processing oresbull Fly ash and related waste from burning

of fossil fuelsbull Waste from emergency spill cleanups

approved by the MPCA commissionerbull Certain wastes containing chromium IIIbull Empty containers

See Appendix C


All rights reserved

Evaluate Waste

Step 1ANext gather information about each non-exempt waste

bull For wastes that are not exempt check the raw materials that areused A Material Safety Data Sheet (MSDS) may be useful(Remember an MSDS gives information about the materialbefore use not the waste) In addition to using an MSDS aknowledgeable product supplier or manufacturer may also behelpful Some manufacturers may be willing to state that theirproducts are nonhazardous This is especially helpful in thecases of paints and inks where small amounts (one percent orless) of added metals that are not be included on the MSDS maycause the waste to be hazardous for metals (See Appendix Afor a sample MSDS)

bull Identify what happens in the waste-producing processDetermine which contaminants if any could be picked up inthe process

Finally review the information and classify the waste as nonhazardousor hazardous by answering the following three questions (A waste ishazardous if it is listed contains more than 50 ppm PCBs or displays ahazardous characteristic)

1 Is the waste listed in the Hazardous Waste Rules A ldquolistedrdquowaste is one that appears on one of four lists mdash F K P or URefer to Table 2 for common wastes on the F list (For completelists see Minnesota Rules (Minn R) pt 70450135 or HazardousWaste fact sheets 200 (F List) 201 (K List) 202 (P List)203 (U List)) Use the MSDS to identify the chemicalcomponents in the product You then need to

bull Compare the chemical names on the MSDS with those onthe F list Waste solvents appearing on the F list (F001 -F005) are the most common listed wastes (see Table 2)Examples of F-listed waste include many paint and lacquerthinners some brake and carburetor cleaners vapordegreasing and dry cleaning solvents as well as distillationbottoms

Also included on the F list (F006 - F019) are wastes such aselectroplating baths sludges and related wastes andwastewater treatment sludges

bull Check the K list if the waste is the result of a specificindustry process mdash such as wood preserving manufactureof pesticides explosives inks organic or inorganic chemicalsand inorganic pigments petroleum refining and the ironand steel industries

bull Look on the P and U lists if you are disposing of unused orunusable chemical products or spill residues To be P- or U-listed the P or U chemical must either comprise 100 percentof the waste or be the sole active ingredient



P-listed waste is also knownas ldquoacutely hazardousrdquo wastebecause it can be fatal tohumans in low doses Thedata are based on the lethaldose for 50 percent of aspecified rat population(LD50 rat) The LD50 for P-listed wastes is less than50 mgkg Examples ofacutely hazardous wasteinclude compoundscontaining arsenic strychnineand cyanides Acutelyhazardous waste hasadditional managmentrequirements for satelliteaccumulation and thecontainers that once held it(see Appendix C) Contactthe MPCA or your metrocounty hazardous waste stafffor help identifying andmanaging these types ofwastes

U-listed waste (ldquotoxicrdquohazardous waste) althoughharmful is not as toxic as P-listed waste Unlike P-listedwaste it has no additionalrequirements mdash it is managedaccording to the regularhazardous waste rulesAny waste that is mixedwith or derived from a listedwaste is also consideredlisted mdash and hazardousOne example of ldquomixedwithrdquo is mixing a listed brakecleaner with parts washersolvent or used oil Anexample of ldquoderived fromrdquodistillation bottoms [derived]from distilling listed solvents

Table 2 F-Listed Solvents

Waste Name Hazardous Waste Code(s)

Acetone F003 Benzene F005 iso-Butanol F005 n-Butyl alcohol F003 Carbon disulfide F005 Carbon tetrachloride F001 Chlorobenzene F002 Chlorinated

fluorocarbons (CFCs) F001

Cresols F004 Cresylic acid F004 Cyclohexanone F003 2-Ethoxyethanol F005 Ethyl acetate F003 Ethyl benzene F003 Ethyl ether F003 Methanol F003 Methylene chloride F001 F002 Methyl ethyl ketone

(MEK) F005

Methyl isobutyl ketone F003 Nitrobenzene F004 2-Nitropropane F005 Orthodichlorobenzene F002 Pyridine F005 Tetrachloroethylene F001 F002 Toluene F005 111-Trichloroethane F001 F002 112-Trichloroethane F002 112-Trichloro-122-

trifluoroethane F002

Trichloroethylene F001 F002 Trichlorofluoromethane F002 Xylene F003 Also listed bull Solvent blends (mixtures) containing more

than 10 percent by volume of one or more of these F-listed solvents and

bull Distillation bottoms from the recovery of these spent solvents and solvent mixtures


All rights reserved

Evaluate Waste

Step 1A2 Does the waste contain more than 50 ppm polychlorinated

biphenyls (PCBs) Examples of PCB waste include many oldfluorescent lamp ballasts capacitors in older appliances and oilfrom older utility transformers Sometimes an MSDS for productscontaining PCBs may no longer be available so you will need to testwastes that often contain PCBs or manage them as hazardous PCBwaste

3 Does the waste display a hazardous characteristic Having oneor more of the following six characteristics makes a wastehazardous

bull Ignitable (D001) A liquid with a flash point below 140deg F or anonliquid able to spontaneously combust and burn persistentlyExamples of ignitable waste include mineral spirits mostpetroleum-based parts washer solvents solvent blends andalcohols The MSDS will give the flash point of the productThis will likely be close to the flash point of the waste unless thewaste is contaminated with materials that have a very low flashpoint such as gasoline

bull Oxidizer (D001) A substance that supplies oxygen to a reactionin the absence of air Examples include organic peroxideschlorates and most nitrates An MSDS will usually tell youwhether the product is an oxidizer Most oxidizers are used in aprocess because they provide oxygen so the resulting waste maynot be an oxidizer

bull Corrosive (D002) A liquid with a pH of 20 or less 125 ormore or able to corrode steel at a rate greater than 14 inch peryear Examples include strong acids and bases such as batteryacid and radiator boil-out tanks An MSDS will often give thepH of the product Diluting the product prior to use and actualuse of the product may change the pH enough so it does notcause the waste to be hazardous Some corrosive wastes may beable to be neutralized and discharged to a sanitary sewerCheck with your wastewater treatment plant operator fordetails

bull Reactive (D003) A waste that is unstable reacts violently orforms potentially explosive mixtures when mixed with water orcan produce toxic gases Examples include explosives and somecyanide-bearing wastes The Reactivity Hazard Data Section ofthe MSDS may show the product is hazardous The chemicalmay react completely during the process in which it is usedresulting in a nonreactive and therefore nonhazardous wasteOr the product may only partially react in which case thewaste could still be reactive such as lithium batteries

bull Lethal (MN01) A waste that can cause severe health effectswhen ingested inhaled or absorbed through the skin Examplesinclude some pesticide wastes and wastes containing arsenicThe Health Hazard Data section of your MSDS may provide



Wastes whose laboratory analyses show any individual cresol above the 2000mgL threshold are hazardous for that reason When o- m- and p-cresolconcentrations cannot be differentiated the total cresol concentration is used

Table 3 TCLP Contaminants and MaximumTable 3 TCLP Contaminants and MaximumTable 3 TCLP Contaminants and MaximumTable 3 TCLP Contaminants and MaximumTable 3 TCLP Contaminants and MaximumAllowable ConcentrationsAllowable ConcentrationsAllowable ConcentrationsAllowable ConcentrationsAllowable Concentrations

Hazardous Contaminant

Hazardous Concentration (milligramsliter)

Hazardous Waste Code

Arsenic 50 D004 Barium 1000 D005 Benzene 05 D018 Cadmium 10 D006 Carbon tetrachloride 05 D019 Chlordane 003 D020 Chlorobenzene 1000 D021 Chloroform 60 D022 Chromium 50 D007 o-Cresol 2000 D023 m-Cresol 2000 D024 p-Cresol 2000 D025 Cresol 2000 D026 24-D 100 D016 14-Dichlorobenzene 75 D027 12-Dichloroethane 05 D028 11-Dichloroethylene 07 D029 24-Dinitrotoluene 013 D030 Endrin 002 D012 Heptachlor 0008 D031 Hexachlorobenzene 013 D032 Hexachloro-13-

butadiene 05 D033

Hexachloroethane 30 D034 Lead 50 D008 Lindane 04 D013 Mercury 02 D009 Methoxychlor 100 D014 Methyl ethyl ketone

(MEK) 2000 D035

Nitrobenzene 20 D036 Pentachlorophenol 1000 D037 Pyridine 50 D038 Selenium 10 D010 Silver 50 D011 Tetrachloroethylene 07 D039 Toxaphene 05 D015 Trichloroethylene 05 D040 245-Trichlorophenol 4000 D041 246-Trichlorophenol 20 D042 245-TP (Silvex) 10 D017 Vinyl chloride 02 D043

Table 4 Minnesota-specific Waste CodesTable 4 Minnesota-specific Waste CodesTable 4 Minnesota-specific Waste CodesTable 4 Minnesota-specific Waste CodesTable 4 Minnesota-specific Waste Codes

MN01 Displays characteristic oflethality(Minn R 70450131 Subp 6)

MN02 A collection of small amountsof unrelated but compatiblechemicals ndash for licensereporting only(Minn R 70450137)

MN03 Polychlorinated biphenyls(PCBs) at a concentration of 50parts per million or greater(Minn R 70450135 Subp 5)

M100 Used oil used oil filters andused oil contaminated sorbentmaterials (Minn R 70450020Subps 100 a amp b)


All rights reserved

Evaluate Waste

Step 1Ainformation that may cause you to suspect a waste maybe lethal Contact your metropolitan county or MPCAstaff for assistance and to determine whether or nottesting is required

bull Toxic (D004 - 43) A waste containing hazardouscontaminants above the maximum allowableconcentration specified in Table 3 Examples includeused photo fixer (toxic for silver) some used dry cellbatteries (toxic for mercury) sludges and sometimesliquid from water-based parts washers (toxic for leadbenzene or both) and automotive and other paint-related wastes (often toxic for chromium cadmium leador barium) Wastes may also be toxic because ofcontaminants picked up during a cleaning ormanufacturing process

If you cannot classify the waste test a sample to get theinformation you need If you strongly suspect the waste is hazardouscoordinate with a hazardous waste disposal facility Follow theirsampling and testing protocol By working with the disposalfacility the test results can also be used for waste acceptanceapproval if the waste is found to be hazardous (keep records)Retesting of a waste is not required unless product or processchanges could alter the makeup of the resulting wasteIf you strongly suspect the waste is nonhazardous coordinate with anindustrial waste (nonhazardous waste) disposal facility Follow thesampling and testing protocol outlined by the facility (keeprecords) By coordinating with an industrial waste facility testresults can be used for waste acceptance approval if the waste isnonhazardous If you need to use a commercial testing laboratorya list is available on Hazardous Waste fact sheet 605 HazardousWaste Consultants and Testing LaboratoriesIf you have determined through knowledge or testing that awaste

bull is not listed mixed with or derived from a listed waste

bull does not contain PCBs and

bull does not display a hazardous characteristicit is not hazardousHowever simply because a waste is nonhazardous does notmean it can go into a dumpster or down the drain Nonhazardouswastes are subject to industrial solid waste rules wastewater rulesor both Coordinate with the landfill industrial burner orwastewater treatment plant operator before disposal Never placeindustrial waste in a septic system



If you have determined that a waste is hazardous you must determineyour generator size and learn how to properly manage and dispose of thewaste For more help see the list of hazardous waste fact sheets on theMPCA Web site athttpwwwpcastatemnuswastepubsbusinesshtml


All rights reserved

Waste Evaluation ReviewWaste Evaluation ReviewWaste Evaluation ReviewWaste Evaluation ReviewWaste Evaluation ReviewSta

rtSta

rtSta

rtSta

rtSta

rt

Does

the

wast

e co

ntai

n m

ore

than

50

ppm

PCBs

Is th

ewa

ste

exem

pt fr

omHa

zard

ous

Was

teRu

les

Is th

ewa

ste

liste

d in

the

Haza

rdou

s W

aste

Rule

s

Is th

ewa

ste

exem

ptfro

m s

ome

rule

s if

recy

cled

reus

ed o

rre

claim

ed

Man

age

as a

nin

dust

rial s

olid

was

te o

rac

cord

ing

to a

pplic

able

requ

irem

ents

Is th

ewa

ste

mixe

d wi

th o

rde

rived

from

a lis

ted

wast

e

Man

age

acco

rdin

g to

appl

icabl

e ha

zard

ous

wast

e re

quire

men

ts

The

wast

e is

haza

rdou

s M

anag

eac

cord

ing

to a

llha

zard

ous

wast

ere

quire

men

ts

The

wast

e is

not

haza

rdou

s M

anag

eac

cord

ing

to in

dust

rial

solid

was

te o

r was

tewa

ter

requ

irem

ents

Does

the

wast

e di

spla

y a

haza

rdou

sch

arac

teris

tic

Yes

NoNo

NoNo

Yes

No

Yes

Yes

Yes

Yes

No

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous


Step 1BDetermine Generator Size

(Minn R 70450206)1B 1B 1B 1B 1B Determine Generator SizeDetermine Generator SizeDetermine Generator SizeDetermine Generator SizeDetermine Generator Size

All hazardous waste generators have basic rules to follow however as theamount of hazardous waste generated per month increases certain rulesbecome more stringentTo estimate your generator size follow these steps

1 Gather manifests and information for all hazardous wasteproduced in the last calendar year (January 1 throughDecember 31) or partial year (If you need help organizing thisinformation fact sheet 240 Hazardous Waste Shipping Logmay help you) Include parts washer waste mixed with used oiland hazardous waste generated but not yet shipped Do notinclude any wastes listed in Table 5 in your calculations

2 Convert all waste units to pounds Use the density (or specificgravity) of the waste if you know it If not use the conversionfactor 1 gallon = 10 pounds To convert gallons to poundsmultiply all waste expressed in gallons by 10

3 Add amounts for all waste to find the total for the calendar yearor partial year (in pounds)

4 Divide by 12 (or the number of months waste was produced ifyou were in business for a partial year) to find the averageamount per month

5 Refer to Chart 1 to determine the size where your averageamount falls For many companies this estimate is their actualgenerator size Companies who have seasonal or significantmonthly fluctuations in the amount of waste generated alsoneed to do Step 6

6 Total the waste generated in each month If you produce morein any one month than the limit for the generator sizedetermined in 5 see the section How Changes in WasteGeneration Affect Generator Size

Antifreeze and antifreeze filtersPCB lamp ballasts and other small

PCB capacitorsPhoto fixer reclaimed on siteWaste electronicscathode ray

tubesCircuit boardsbeing recycled as

scrap metalUsed oil used oil filters used oil

sorbents that are recycled

Table 5 Wastes That Do Not Count Toward Generator SizeTable 5 Wastes That Do Not Count Toward Generator SizeTable 5 Wastes That Do Not Count Toward Generator SizeTable 5 Wastes That Do Not Count Toward Generator SizeTable 5 Wastes That Do Not Count Toward Generator Size

Universal Wastes-FluorescentHID Lamps-Dry-cell batteries-Lead-acid batteries-Mercury-containing devices-Liquid mercury-Waste pesticides-Thermostats

Note Metropolitan Counties may require reporting of some of these wastes


All rights reserved

Determine Generator Size

Step 1BldquoldquoldquoldquoldquoMinimalrdquo Very Small Quantity GeneratorsMinimalrdquo Very Small Quantity GeneratorsMinimalrdquo Very Small Quantity GeneratorsMinimalrdquo Very Small Quantity GeneratorsMinimalrdquo Very Small Quantity Generators

Very Small Quantity Generators (VSQGs) that generate less than 100pounds (about 10 gallons) of hazardous waste in an entire calendar year are

classified as ldquominimalrdquo quantity generators (MQGs) if they meet thefollowing requirements1 Minimal quantity generators may generate only these types and

amounts of hazardous waste

bull Any amount of universal wastes mdash lamps batteries pesticidesmercury devices (see Table 5)

bull Any amount of photographic waste provided it is treated onsite to remove 80 percent of the silver and discharged directly(with permission) to a sanitary sewer connected to awastewater treatment plant

bull Any amount of used oil used oil filters and used oil-contaminated sorbents provided they are recycled

bull Any amount of spent lead-acid batteries provided they arerecycled

bull Any amount of antifreeze provided it is recycled or if less than50 gallons per month is generated discharged with permissionto a wastewater treatment plant

bull Any amount of electronic wastes circuit boards

bull Any amount of small PCB ballasts and capacitors

Chart 1 Generator Size ChartChart 1 Generator Size ChartChart 1 Generator Size ChartChart 1 Generator Size ChartChart 1 Generator Size Chart

2200

220

0

Large QuantityLarge QuantityLarge QuantityLarge QuantityLarge QuantityGeneratorGeneratorGeneratorGeneratorGenerator2200 poundsmonth or more

Small QuantitySmall QuantitySmall QuantitySmall QuantitySmall QuantityGeneratorGeneratorGeneratorGeneratorGenerator220lt2200 poundsmonth

Very Small QuantityVery Small QuantityVery Small QuantityVery Small QuantityVery Small QuantityGeneratorGeneratorGeneratorGeneratorGenerator220 poundsmonth or lessP

ound

s of

haz

ardo

us w

aste

mon

thPou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Minimal QuantityMinimal QuantityMinimal QuantityMinimal QuantityMinimal QuantityGeneratorGeneratorGeneratorGeneratorGenerator

Less than 100poundsyear



bull Any amount of fuel-water mixtures provided they are recycledand

bull One hundred pounds (about 10 gallons of liquid) or less percalendar year of all other non-acute hazardous wastes

2 Minimal quantity generators must mark store contain and recycle ordispose of waste according to the requirements found in the MinnesotaHazardous Waste Rules and explained in this manual

3 Minimal quantity generators must prepare for spills clean them up andnotify the Minnesota Duty Officer of reportable spills

4 Minimal quantity generators may take their waste to a VSQGCollection Program provided they follow Minnesota Department ofTransportation requirements (Your program operator can help you)

5 Minimal quantity generators must keep copies for 3 years of allmanifests and shipping papers used for waste recycling and disposaland keep records of any spills

The Minnesota Pollution Control Agency and some but not all of theseven Twin Cities metropolitan counties use the ldquominimalrdquo classification Ifyour county does not manage your waste according to Very SmallQuantity Generator requirementsMinimal quantity generators who fail to manage waste according to thehazardous waste requirements may lose their minimal classificationFor more information see MPCA Hazardous Waste fact sheet 150available at httpwwwpcastatemnuswastepubsbusinesshtmlgeneral Also businesses in the metropolitan area shouldcontact their county hazardous waste office for more information (seephone numbers on inside of back cover)

How Changes in Waste Generation Affect GeneratorHow Changes in Waste Generation Affect GeneratorHow Changes in Waste Generation Affect GeneratorHow Changes in Waste Generation Affect GeneratorHow Changes in Waste Generation Affect GeneratorSizeSizeSizeSizeSize

If the amount of waste you generate increases enough to put you into alarger generator size category you will have more emergency planningand employee training requirements Storage limits and accumulation timelimits will also changeIf the amount of waste decreases you may need to submit a writtenrequest to the MPCA commissioner in order to decrease your generatorsize status Contact the MPCA or your metropolitan county hazardouswaste staff for help


All rights reserved

Get an EPA Identification Number

Step 2

Notification of Regulated Waste Activity

(This form replaces EPA Form 8700-12 and EPA Form8700-13AB for Minnesota sites)

Date Received

(For Official Use Only)

Sitersquos Waste ID Number

I Sitersquos Hazardous Waste ID Number

(Mark lsquoXrsquo in the appropriate box)

A Initial Notification

(Complete all items beginning with Section

II below)

B Subsequent Notification

(Indicate Waste ID in space above and

complete sections with changes only)

C Inactivation

(Indicate Waste ID Number in space above

and complete Section X only)

II Name of Site (Include company and specific site name if a

ny)

III Location of Site (Physical address not PO Box or Route Number)

Street

Street (Continued)

City or Town

StateZip Code

County Name

IV North American Industry Classification System (NAICS) Code(s) for the site

If the location address in Section III has been changed from your initial notification please indicate the reason for the change below

Moved waste generating activities to another location

Streets andor street numbers changed by 911 (Emergency) System

Property incorporated into city limits and street was renamed Incorrect address never at site address previously identified

No change in location update of address previously identified Other (explain in Section XI Comments)

V Site Contact (Person to be contacted regarding waste activities at site)

Name (Last)

(First)

Job Title

Phone Number (Area Code and Number)

VI Contact Address

Street or PO Box

City or Town

StateZip Code

VII Ownership

A Name of Sitersquos Legal LandownerOwner of Property (if different fro

m Section II above)

Street PO Box or Route Number

City or Town

StateZip Code


B Owner Type Private

Federal State

Indian Tribe

Local Unit of Government (LUG)

C Name of Sitersquos Legal Operator (if different fro

m Sections II andor VII above)

w-hw7-09

1 of 2

September 03

Visit our Web site at httpwwwpcastatemnuswastepubsbusinesshtml for more information on the

Hazardous Waste Rules and a complete listing of fact sheets available on complying with the Hazardous Waste Rules

Majors and Remediation Division Majors Section

520 Lafayette Road N St Paul MN 55155-4194 (651) 297-2274

Who Needs an EPA Identification NumberWho Needs an EPA Identification NumberWho Needs an EPA Identification NumberWho Needs an EPA Identification NumberWho Needs an EPA Identification NumberHow Do I Get OneHow Do I Get OneHow Do I Get OneHow Do I Get OneHow Do I Get One

If your business ships hazardous waste off site using a manifest takeswaste to a Very Small Quantity Generator Collection Program oraccumulates more than 5000 kilograms of universal wastes you mustobtain a US Environmental Protection Agency (EPA) identificationnumber There is no cost to get a numberTo get an EPA ID number

1 Complete a Notification of Regulated Waste Activity formfollowing the instructions attached to it (see Hazardous Wastefact sheet 709 athttpwwwpcastatemnuspublicationsw-hw7-09pdf)and

2 Send it to the MPCA at the address given on the instructionsheet

If you have never applied for a number check Box A Initial Notification Inorder to complete the form you will need to know

bull that you must use the exact same business name and sitelocation on the form that you intend to use on hazardous wastemanifests (each site has its own specific number)

bull the waste code(s) for each hazardous waste you generate

bull your generator size

bull the owner of your business and property and

bull other information specific to your businessIf you donrsquot know this information Table 2 on theinstruction sheet may help youYour EPA ID number may also be called your Generator IDon manifests and license applications Most MinnesotaEPA ID numbers begin with the letters lsquoMNDrsquo lsquoMNrsquo orlsquoMNRrsquo followed by 9 or 10 digits The number is uniqueto your site and will be used to identify your site onmanifests (shipping papers) container labels andhazardous waste license applicationsWhen an ID number is assigned the MPCA willsend you a notification response letter If you arelocated in the metropolitan area the MPCA willalso notify your metropolitan county hazardouswaste office For your records keep the

verification letter showing your assigned numberand the information associated with it

Figure 1EPA ID form


Step 2Get an EPA Identification Number

Moving

Remember to apply for anew EPA ID number foryour new location

If You MoveIf You MoveIf You MoveIf You MoveIf You Move

EPA ID numbers are site specific mdash they are identified with your locationnot your business name mdash so if you move your business you must applyfor a new number for your new location This will be an InitialNotification for your new location At the same time attach a short letterto the form notifying the MPCA that you are no longer at your oldlocation and asking that the ID number for your old location beinactivated If the post office changes your address but youdonrsquot move refer to Subsequent Notification below

Subsequent NotificationSubsequent NotificationSubsequent NotificationSubsequent NotificationSubsequent Notification

Very Small Quantity Generators must submit a subsequentnotification to the MPCA if

bull they have not moved but the post office changes theiraddress or

bull the ownership of their company changesSmall and Large Quantity Generators must submit a subsequentnotification if any information from the previous notification changesTo submit a subsequent notification complete an EPA ID form place acheck in Box B Subsequent Notification and write your previously assignedID number in the spaces above Box C If you are notifying because yourlocation address has changed but you have not physically moved indicatethe reason for the address change after Section IV on the form

Answers to Common Questions About EPA ID NumbersAnswers to Common Questions About EPA ID NumbersAnswers to Common Questions About EPA ID NumbersAnswers to Common Questions About EPA ID NumbersAnswers to Common Questions About EPA ID Numbers

Q I only generate used oil and used oil filters Do I need an EPA IDnumber

A Maybe If your business is in Greater Minnesota you do notneed a number unless you also generate parts washer solventwaste mdash even if you manage it by mixing with your used oilSome metropolitan counties require an EPA ID number forused-oil generators Contact your metropolitan county orMPCA staff for more information

Q I burn used oil to heat my business Do I need to check lsquoburnerrsquo insection VIII B-2

A No This is only for utility or industrial boilers or industrialfurnaces such as cement and asphalt kilns and blast furnaces


All rights reserved


Step 2Q I sellgive my used oil to an oil hauler Am I a marketer (section

VIII-B1)

A Probably not If your oil hauler sells the collected used oil to aburner your oil hauler is considered a marketer However ifyou wish to give or sell your oil to another business to burn youcould become a marketer Before you give or sell oil to anotherbusiness to burn it must be tested to show it is ldquoonspecificationrdquo The business which first declares the oil to be on-specification used oil is a marketer For more informationrequest MPCA fact sheet 434 Marketing Used Oil

Q I am a Very Small Quantity Generator (section VIII A-1c) and Itransport my hazardous waste andor used oil to a very smallquantity generator collection site Am I a transporter (section VIIIA-2a or B-3a)

A No This classification refers to a licensedregistered hazardouswaste transporter or an oil hauler (someone who collects usedoil from many different businesses)

Q I am moving my business to a location that already has an EPA IDnumber Can I use that number

A Yes But you will need to complete a notification form to advisethe MPCA of the change In this case write the ID number ofyour new location in the space provided at the top of the formFill out the business information for your company (Donrsquotforget to inactivate the number for your old location bysubmitting a letter to the MPCA asking that the number beinactivated or filling out the notification of regulated wasteacvitity form and requesting that the number be inactivated)

Q My business is located in several buildings Can I use the samenumber for all

A If the buildings are on contiguous property (see Figure 2) andyou ship from one location address you may use one number Ifyou ship from more than one location address you will need anumber for each mdash identification numbers are site specific



Figure 2 Contiguous andNoncontiguous Property

Contiguous and Noncontiguous PropertyContiguous and Noncontiguous PropertyContiguous and Noncontiguous PropertyContiguous and Noncontiguous PropertyContiguous and Noncontiguous Property

Facilities such as military installationsuniversities or large industrial complexes areoften split by public or private roads Propertiesthat are adjacent owned by the same personand can be accessed by crossing (not goingdown) the right of way are ldquocontiguousrdquoRefer to Figure 2 and the following examples ofcontiguous and noncontiguous property (shadedareas represent city blocks owned by onecompany and separated by city streets)

bull A and B are contiguous because theyare located within the same block Ifthey have a common storage areathey may use the same number

bull B and C are contiguous because onecan go directly across the public streetat a 180o angle from one to the otherIf they have a common storage area they may use the samenumber

bull B and D are not contiguous because you must travel down acity street from one to the other However in this casetransportation down a public street between the two sites isallowable without using a manifest or a hazardous wastetransporter therefore if these locations have a common storagearea they may use the same number Keep in mind that iftransporting down a public street

bull Department of Transportation Hazardous MaterialsShipping standards apply and

bull emergency plans must address potential transport-relatedincidents


All rights reserved

Get a License Pay a Fee

Step 3Basic RequirementsBasic RequirementsBasic RequirementsBasic RequirementsBasic Requirements

Businesses organizations and governmental units that generate hazardouswaste are required to report that waste annually and obtain a license thatis valid for one year Waste generated ldquoone timerdquo from activities such ascleaning out a warehouse or removing a tank must also be reported(Minn R 70450255) In addition they must

bull make a copy of the completed application form and retain it forthree (3) years

bull post their license at their place of business and

bull renew their license annually

Businesses Located in Greater MinnesotaBusinesses Located in Greater MinnesotaBusinesses Located in Greater MinnesotaBusinesses Located in Greater MinnesotaBusinesses Located in Greater Minnesota

These Greater Minnesota businesses are exempt from the license and feerequirements

1 Businesses that generate only used oil andor used oil-relatedwaste (Greater Minnesota businesses that generate only used oilare also exempt from reporting requirements)

2 Businesses that generate less than 100 pounds of hazardouswaste per calendar year (Minimal Quantity Generators ndashMQGs) Silver-bearing photo fixer waste that is treated beforebeing discharged to a sanitary sewer and antifreeze are notincluded in the 100-pound total

3 Businesses that generate only silver-bearing waste that is treatedbefore discharge to a municipal sanitary sewer system (Thiswaste may not be discharged to a septic system)

Greater Minnesota businesses that generate other hazardous wasteincluding parts washer solvent mixed with used oil report to and get alicense from the MPCA To obtain a license

bull Contact the MPCA and request a form to obtain anEnvironmental Protection Agency identification (EPA ID)number (Hazardous Waste fact sheet 709 Notification ofRegulated Waste Activity) See Step 2 for more information

bull Complete the EPA ID number form according to directions andmail it to the address on the instruction sheet When you arenotified of your number your business name is placed on themailing list to receive a license application

bull When you receive a license application from the MPCAcomplete and submit it by the due date (usually within 30 days)


Step 3Get a License Pay a Fee

bull Greater Minnesota businesses are notrequired to report on the licenseapplication wastes which do not counttoward calculating generator size or thelicense fee (see Table 6)

bull If you have reported wastes on yourapplication that are subject to fees or taxyou will receive a combined billingstatement from the MPCA Afterreceiving your payment the MPCA willsend you a license document to post atyour place of business If your business is

exempt from license and fee requirements you will not receive abilling statement or a license

Businesses Located in theBusinesses Located in theBusinesses Located in theBusinesses Located in theBusinesses Located in theTwin Cities Metropolitan AreaTwin Cities Metropolitan AreaTwin Cities Metropolitan AreaTwin Cities Metropolitan AreaTwin Cities Metropolitan Area

Businesses located in the metropolitan area(Anoka Carver Dakota Hennepin RamseyScott and Washington Counties) report to andreceive their license from their county hazardouswaste office they do not report to the MPCA Ifyour business is located in one of themetropolitan counties contact your county stafffor the appropriate forms (see telephone numberson inside of back cover)All hazardous and oil wastes must be reportedhowever all wastes do not receive a license feeGenerators in the metropolitan counties shouldcheck with their county hazardous waste stafffor the fee-assessed wastes and fee schedule fortheir county

Information for New BusinessesInformation for New BusinessesInformation for New BusinessesInformation for New BusinessesInformation for New Businesses

In Greater Minnesota report hazardous wastegenerated during the previous calendar year onthe license application New businesses willreport the kind(s) of hazardous waste they intendto generate or are generating The amount generated in the last calendarmay be zeroIn the metropolitan area new businesses should report on the licenseapplication the kind(s) and amount(s) of hazardous waste they intend togenerate during the present year

Table 6 Wastes NotTable 6 Wastes NotTable 6 Wastes NotTable 6 Wastes NotTable 6 Wastes NotReported in GreaterReported in GreaterReported in GreaterReported in GreaterReported in GreaterMinnesotaMinnesotaMinnesotaMinnesotaMinnesota

bull Nonhazardous wastebull Exempt wastebull Recycled used oil and filtersbull Recycled lead-acid batteriesbull Recycled scrap metalbull Recycled photo negativesbull Recycled fluorescent lampsbull Laundered shop towels

Table 7 Wastes That May Not Count forTable 7 Wastes That May Not Count forTable 7 Wastes That May Not Count forTable 7 Wastes That May Not Count forTable 7 Wastes That May Not Count forSize or Fee in Greater MinnesotaSize or Fee in Greater MinnesotaSize or Fee in Greater MinnesotaSize or Fee in Greater MinnesotaSize or Fee in Greater Minnesota

Counts for Waste Size Fee Antifreeze recycled Antifreeze sludge from a distillation process if hazardous

Antifreeze sludge from a filtering process if hazardous

Waste pretreated to remove 80 or more of the contaminant and discharged to a city sanitary sewer system

Waste pretreated but less than 80 of contaminant removed before discharge to a city sanitary sewer

Hazardous residual from a pretreatment process

Approved feedstocks and by-products

Mixed waste streams that have already been counted individually

All other hazardous wastes SQGs and LQGs only Under limited conditions may not count for fees


All rights reserved


Step 3Table 8 Taxes and Fees Hazardous Waste Generators May PayTable 8 Taxes and Fees Hazardous Waste Generators May PayTable 8 Taxes and Fees Hazardous Waste Generators May PayTable 8 Taxes and Fees Hazardous Waste Generators May PayTable 8 Taxes and Fees Hazardous Waste Generators May Pay

Fee or Tax Paid by Amount Due Collected by Used For

Clean Air Act Fee

Emitters of air pollutants

Varies with amount of emissions Due 60 days after receiving fee statement

MPCA Air Quality Program

Funding Air Quality Program

Hazardous Waste Generator Superfund Tax

Hazardous waste generators

Varies with amount generated $50 minimum Due April 15

Minnesota Department of Revenue

Superfund site cleanups

Hazardous Waste License and Statewide Program Fee


Varies with amount generated

Minnesota Department of Revenue or Metro Counties

Partial funding of Hazardous Waste Programs

Hazardous Waste Treatment Storage and Disposal (TSD) Facility Fees

30-35 Minnesota TSD facilities

$1800 - $84000 for original application $1800 ndash $54 000 annual fees ndash varies by Metro County Greater MN fees due June 15

MPCA Hazardous Waste Program or Metro County


Hazardous Chemical Inventory Fee

Companies storing chemicals reported under SARA section 312

$25 - $1000 depending upon the number of chemicals stored Due June 1

Emergency Response Commission

Preparation for hazardous materials emergencies

Companies reporting releases on the toxic chemical release inventory (TRI) Form R

Varies depending upon the number and amount of chemicals released ($002gal and $150release minimum $500) Due January 1


Pollution Prevention Fees

Large quantity hazardous waste generators not reporting a release on TRI Form R

$500 due January 1 MPCA ndash Technology Education amp Assistance Division

Pollution prevention assistance including MnTAP

Companies storing extremely hazardous substances under SARA Section 302

$75 due June 1 Emergency Response Commission

Hazardous Materials Incident Response Act Fee Companies reporting

a release under SARA Section 313

$200 - $800 depending upon amount released Due June 1

Emergency response and chemical assessment teams



About Generator License FeesAbout Generator License FeesAbout Generator License FeesAbout Generator License FeesAbout Generator License Fees

In 1983 the Legislature chose to finance part of the MPCA HazardousWaste Program with fees Each year the hazardous waste program budgetis established by the legislature License fees are collected from hazardouswaste generators throughout the state to meet that budget Currentlyabout half the MPCA hazardous waste program is funded by fees with asmall amount coming from the state general fund The other half is fundedby the U S Environmental Protection Agency

CoCoCoCoCommmmmmon Questions About Feesmon Questions About Feesmon Questions About Feesmon Questions About Feesmon Questions About Fees

Q How are license fees calculated

A In Greater Minnesota Very Small Quantity Generators(businesses producing 220 pounds or less of hazardous waste permonth) presently pay a flat fee Small and Large QuantityGenerator fees are calculated based on

1) the quantity of hazardous waste generated per year

2) the way it is managed (management method) and

3) a statewide program fee

The statewide program fee is assessed from all generators and isused to fund statewide hazardous waste activities Wastes thathave been generated but not reported are subject to retroactivefees for up to two previous years Fees not paid by the due dateare subject to a late penalty

In the metro area each county board sets its fee schedule

Like generators in Greater Minnesota metro county generatorspay a statewide program fee that helps fund MPCA services

Q Why do fees vary between the metro counties and the State

A Metro fees are set by each county board to provide funding forthe county program State fees are set by the MPCA to meet thebudget set by the legislature

Q Do all of my wastes count when calculating my license fee

A Businesses in Greater Minnesota can refer to the list in Table 6Only those wastes checked count towards the appropriate sizeand fee Metro county businesses should check with theircounty office

Q What other fees are required for generators of hazardous waste

A Other fees that may be paid by hazardous waste generators tosatisfy requirements for other programs are listed in Table 7


All rights reserved

Place Waste in Containers Mark Them

Step 4Choose the Right Container for the WasteChoose the Right Container for the WasteChoose the Right Container for the WasteChoose the Right Container for the WasteChoose the Right Container for the Waste

Containers come in several sizes and types Common container sizesinclude 5 gallon 15 gallon 30 gallon and 55 gallonCommon types of containers include

bull fiberboard drums (for solid materials destined for incinerationwith a polyethylene liner they may also be appropriate for someliquids)

bull steel drums (used for a variety of wastes but not usually forcorrosive wastes)

bull polyethylene drums (used for a variety of wastes but nevercertain solvents that will dissolve polyethylene) and

bull gaylord boxesClosure devices commonly found on containers are a snap ring or a bungWhen choosing a container consider thefollowing

bull Is the container sturdy mdash in goodcondition Good condition meansno rust or severe dents in theseam areas which wouldweaken the container and allowit to leak

bull Is the container compatible withthe waste Ask your transporterand disposal facility forrecommendations based on theintended disposal method for thewaste The Department ofTransportation (DOT)Hazardous Materials Table mayhelp you determine the type ofcontainer to use A barrelmanufacturer or reconditionermay also be able to help you

bull Does the closure device allow employees to easily add or removewaste Choosing a closure device acceptable to your employeeswill encourage them to close the container after adding orremoving waste

TIP 1 Whenever possible store the waste in the container youwill ship it in This could be the container the product came inThis practice saves work and eliminates the possibility of spillsduring waste transfer

HazardousWaste

Waste LacquerThinner

2904


Step 4Place Waste in Containers Mark Them

Close the ContainerClose the ContainerClose the ContainerClose the ContainerClose the Container mdash mdash mdash mdash mdashExcept When Adding or Removing WasteExcept When Adding or Removing WasteExcept When Adding or Removing WasteExcept When Adding or Removing WasteExcept When Adding or Removing Waste

A closed container means the bung is screwed in or the snap ring issnapped A funnel that screws into the bung and seals with a spring-loaded hinge is accepted as a closed container An open funnel in a drumis an open container

TIP 2 Let employees choose the type of closure device thatwill work best for them

Mark the ContainerMark the ContainerMark the ContainerMark the ContainerMark the Container

When you place waste in a container the container must be marked with

bull the words ldquoHazardous Wasterdquo

bull a clear description of the waste and

bull the date (called the accumulation start date)

Satellite accumulation has different markingrequirements See the section entitled SatelliteAccumulation

Marking allows company personnel to identify what isbeing stored or shipped In case of an accident itallows first responders to determine how to handle thewasteAcceptable methods that are often used for marking acontainer include

bull writing on the container with a permanentmarker or paint

bull stenciling on the container

bull using a 3- x 5- inch accumulation label or

bull using a 6- x 6- inch pretransport label

TIP 3 If you are reusing a container removeor spray paint over old labels andormarkings that do not apply to the wasteinside

Figure 4 Hazardous WastePretransport Label ndash May be usedduring accumulation and storageprior to shipment Must be appliedto the container and completely andcorrectly filled out before the wasteis picked up by your hazardouswaste transporter

Figure 3 Accumulation Label -Used while you are accumulating orstoring hazardous waste prior toshipment An accumulation label isnot sufficient for shipping waste


All rights reserved


Step 4

UsedOil

UsedOil

FiltersUsed OilSorbents

TIP 4 To avoid waste spills from destroying your label place thelabel on the side of the container but not directly under thebung You may also wish to protect labels by applying a thincoat of varnish covering them with clear packing tape orenclosing them in a plastic pouch designed for that purpose

TIP 5 For quick identification put all marks and labels on thesame side of the container (but not directly under the bung)

TIP 6 Just prior to shipment check to make sure labels are stillreadable and well attached

Special Situation - Used OilSpecial Situation - Used OilSpecial Situation - Used OilSpecial Situation - Used OilSpecial Situation - Used Oil

When marking containers that hold used oil used oil filtersor used oil-contaminated sorbent material you needonly a clear description of the waste In thiscase the words ldquoHazardous Wasterdquoand accumulation start dateare not required andshould not be usedDo not use anaccumulation orhazardous waste label


Step 5Store and Accumulate Properly

Indoor Storage of the ContainerIndoor Storage of the ContainerIndoor Storage of the ContainerIndoor Storage of the ContainerIndoor Storage of the Container

Indoor storage means a permanent building consisting of a roof and at leastthree walls attached to an impermeable floor which is placed on theground Impermeable means a floor that will not react with the wastestored on it and that has no cracks drains or sumps that would allow aspill to escape On the ground means trailers or structures set on blocks donot qualify as indoor storage areasExample Since solvents and oils will dissolve an asphalt surface asphaltis not impermeable for solvents or oils Corrosive materials will ldquoeatrdquothrough a concrete surface unless it is well sealed with a corrosive-resistantepoxy (available from many suppliers) mdash so unsealed concrete is notimpermeable for corrosivesWhen storing a container of hazardous waste indoors

bull Close the container

bull Leave enough aisle space between containers to allow you toeasily inspect containers and remove those that are leaking orneed to be shipped

TIP 7 Placing drums in the storage area with labels facing outallows for easier identification and inspection

bull Separate wastes that may react if they come in contact with oneanother Do this by using a dike berm or other secondarycontainment for the containers

TIP 8 Separate waste from product to avoid inadvertentmixing

bull Inspect hazardous waste containers weekly Record inspectionresults Check

the condition of the container

for leaks

the floor for cracks obstructions or trash in the area

the preshipment label for completeness and correctness and

the accumulation start date to make sure the drum isshipped on time

TIP 9 Hazardous Waste Fact Sheet 241 DocumentingContainer Inspections (see Appendix D) contains an inspectionlog that you may use to record your weekly inspections Hang iton a clipboard in the storage area When it is full file it in yourpermanent records for at least three years

bull Keep emergency and spill equipment (such as fire extinguishersorbent materials spill containers) in or near the container-storage area Depending upon the wastes you store anonsparking brass or plastic shovel may also be part of your


All rights reserved

Store and Accumulate Properly

Step 5equipment For more information on planning for emergenciessee Step 8 Plan for Emergencies

Although stacking drums is allowed MPCA staff strongly recommendsplacing a stabilizing material between drums and stacking no more thantwo drums high

Outdoor Storage of the ContainerOutdoor Storage of the ContainerOutdoor Storage of the ContainerOutdoor Storage of the ContainerOutdoor Storage of the Container

If you store waste outdoors you must meet the indoor storagerequirements and these additional requirements

bull Protect outdoor storage areas from unauthorized access Positioncontainers out of the general traffic pattern to avoid inadvertentdamage

bull Liquids and lead-acid batteries must be stored on an impermeablesurface with curbing sufficient to contain a release

TIP 10 Batteries may be covered with a tarp to preventaccumulation of snow and rain water (Tarps will not work forall wastes stored outdoors)

bull Ignitable liquids require shading to prevent heat buildup A tarp isnot adequate shading for ignitable liquids because it will hold in theheat and cause expansion and a possible release

Minnesota winters present special concerns Snow makes accessing andinspecting outdoor containers difficult Remove it from the storage area

TIP 11 Store empty containers closed and on their side toprevent accumulation of rainwater and melting snow

TIP 12 A curbed containment area with no roof may requirea valve to drain rainwater

TIP 13 For a small number of drums adequate shading maysometimes be accomplished by placing them in shade on thenorth side of a building

Ship the Container Off SiteShip the Container Off SiteShip the Container Off SiteShip the Container Off SiteShip the Container Off Site

The amount of waste you may accumulate on site and the length of timeyou may store it vary with generator size (See Table 8)Except for a few special considerations hazardous waste must be shippedvia hazardous waste transporter Before you ship ask yourself thesequestions

bull Is my waste in a DOT-approved shipping container

bull Is there a completed pretransport label on the container



Figure 5Department of

Transportation(DOT) hazard labels

Depending upon the wastea DOT hazard label may alsoneed to be applied beforeshipping

bull Does the container display necessary DOT hazard labels

bull Is my manifest properly filled out If my transporter fills it outhave I checked it to make sure it is correct

bull If a Land Disposal Restriction Notification or Certificationform is required (for Small and Large Quantity Generatorsonly) is it filled out correctly

TIP 14 Make arrangements with the disposal facility 60-90 days in advance of shipment so necessary testing andpaperwork can be completed

TIP 15 Decide which containers will be shipped before thetransporter arrives Check the manifest before thetransporter leaves to make sure all the containers are listedon the manifest

TIP 16 Donrsquot move waste outside the storage area until thetransporter arrives This will prevent having to move it back incase the transporterrsquos schedule changes

Storage ExtensionStorage ExtensionStorage ExtensionStorage ExtensionStorage Extension

If you cannot ship waste according to the applicable schedule in Table 8you may apply for a 30-day storage extension To apply write a letter to

Table 9 Accumulation and Storage Limits for GeneratorsTable 9 Accumulation and Storage Limits for GeneratorsTable 9 Accumulation and Storage Limits for GeneratorsTable 9 Accumulation and Storage Limits for GeneratorsTable 9 Accumulation and Storage Limits for Generators Generator Size Accumulation Limit Storage Time Limit

Very Small Quantity Generator (VSQG)

Generates 220 pounds or less of waste per month (less than frac12 drum liquid)

2200 pounds (About four 55-gallon drums liquid) Generators exceeding this limit must manage waste according to Small Quantity Generator guidelines

Less than 2200 pounds of waste may be stored indefinitely Once 2200 pounds of waste has accumulated ship the waste off site within 180 days

Small Quantity Generator (SQG)

Generates more than 220 pounds but less than 2200 pounds of waste per month (about frac12 to 4 drums liquid)

6600 pounds (About twelve 55-gallon drums liquid) Generators exceeding this limit must manage waste according to hazardous waste storage facility standards

Ship waste off site within 180 days of the accumulation start date

Large Quantity Generator (LQG)

Generates 2200 pounds or more of waste per month (more than 4 drums liquid)

No limit to the amount of waste stored on site

Ship accumulated hazardous waste off site within 90 days of the accumulation start date If the 90-day deadline is not met the generator is required to obtain a hazardous waste storage facility permit

220 pounds is 100 kilograms (kg) or approximately 22 gallons If disposal arrangements have been made and the receiving facility is more than 200 miles from the generation site you may

store waste up to 270 days Minn R pt 70450292 Subp 11


All rights reserved


Step 5the MPCA Commissioner co HW Program (or your metro countyhazardous waste office) explaining the need for an extension Include

bull the amount and type of waste to be stored over the maximumallowable number of days

bull the date the stored waste will exceed the maximum allowablenumber of days

bull the location of the waste needing an extension

bull the reason for the extension request and

bull documentation of your efforts to shipThe MPCA (or your metro county hazardous waste office) may grant the30-day extension which would allow you to keep the waste on site withoutoveraccumulating

Satellite AccumulationSatellite AccumulationSatellite AccumulationSatellite AccumulationSatellite Accumulation

Some wastes accumulate very slowly If you were required to ship thesewastes 90 or 180 days from the date you first put waste into the containeryou might be shipping a container holding a very small amount of wasteTo eliminate this situation you can designate the container a satelliteaccumulation container You can designate more than one satelliteaccumulation container at a site but not more than one per industryprocessAll marking and storing requirements discussed in steps four and fiveapply to satellite accumulation with these exceptions

bull Satellite accumulation allows a hazardous waste generator toslowly accumulate up to 55 gal (550 lb) of hazardous waste (orup to 1 quart of acute hazardous waste)

bull Satellite accumulation containers must either be under thedirect control of the operator of the process producing the wasteand visually inspected daily or must be inspected weekly(document inspections)

bull Write on the satellite container the date you first add waste(start date) and the date you fill the container (fill date) Thestorage time clock begins on the fill date See Table 9

bull You have three days from the fill date to move the drum to yourpermanent storage area and 90 to 180 days from this date(depending on your generator size - see Table 9) to move thewaste off site

Satellite accumulation may occur at more than one location and you mayaccumulate more than one waste at a location however you may notexceed the limits (55 gal550 lb non-acute waste or 1 qt acute waste) foreach waste at each location


Step 6Transport and Dispose of Waste Correctly

Before Contacting a TransporterBefore Contacting a TransporterBefore Contacting a TransporterBefore Contacting a TransporterBefore Contacting a Transporter

A generator of hazardous waste is responsible for the waste from theldquocradlerdquo mdash the time the waste is first generated mdash to the ldquograverdquo mdash thetime the waste reaches final disposal mdash and sometimes beyond To lessenyour liability first use all methods possible to decrease the amount ofhazardous waste you generate Then lessen the chance that the waste willbe mismanaged when it leaves your hands by carefully choosing ahazardous waste transporter and facility Before contacting a prospectivehazardous waste transporter you should know

bull the kind(s) and amount(s) of waste to be picked up

bull whether the waste is a liquid solid or sludge

bull the type(s) of containers(s) holding the waste

bull how often you will need to ship waste and

bull the location of the facility you have chosen to recycle treat ordispose of your waste

Others to ContactOthers to ContactOthers to ContactOthers to ContactOthers to Contact

bull Ask prospective transporters for references and call them Findout whether present customers are satisfied

bull Call the Minnesota Department of Transportation (MnDOT) forcurrent license verification

bull Contact your metropolitan county or Minnesota PollutionControl Agency (MPCA) hazardous waste staff to see whetherthe transporter is in compliance Choose a transporter who willhandle and dispose of your waste according to Minnesota andfederal regulations

Hazardous Waste Transporter RequirementsHazardous Waste Transporter RequirementsHazardous Waste Transporter RequirementsHazardous Waste Transporter RequirementsHazardous Waste Transporter Requirements

To obtain a license or registration from MnDOT a hazardous wastetransporter must meet the requirements listed below You may wish to aska prospective transporter for proof these requirements are metTransporters must

bull have a US Environmental Protection Agency (EPA)Identification Number

bull be registered with and permitted as a hazardous wastetransporter in the Uniform Hazardous Materials RegistrationProgram A transporter participating in this reciprocal base-state registrationpermitting program must be registered with


All rights reserved

Transport and Dispose of Waste Correctly

Step 6and permitted by MnDOT or by Illinois Michigan NevadaOhio or West Virginia

bull carry a copy of the Uniform Hazardous Materials registrationpermit in each vehicle

bull be registered to haul hazardous waste in the destination stateand the states in between

bull have $5 million liability insurance if transporting hazardouswastes classified as division 11 12 13 explosives or division23 or 61 poisons in Inhalation Hazard Zone A

bull have $5 million liability insurance if transporting hazardoussubstances in cargo tanks with a capacity greater than 3500gallons

bull have $1 million liability insurance if using a tank truck with abulk capacity of less than 3500 gallons (if not required to have$5 million liability insurance)

bull have $1 million liability insurance if hauling drums or othernonbulk packages of hazardous waste (if not required to have$5 million liability insurance)

bull have a current MCS-90 liability insurance endorsement in thecorrect amounts for the class and mode of transport provided

bull have drivers qualified according to Federal Motor Carrier SafetyRegulations (FMCSR)

bull if a for-hire carrier have the appropriate inter- and intra-statemotor carrier authority and

bull have a transportation security plan conforming to therequirements in 49 CFR pt 172 subp I

An MCS-90 endorsement is an endorsement to a regular insurance policystating that the policy will cover environmental restoration in the case ofan incident or accident involving hazardous materials It is wise to get acopy of a completed MCS-90 endorsement from your transporter prior toshippingFMCSR requirements include road testing a written examinationphysical qualification drug and alcohol testing and certification showingthe driver has passed a physical examinationThis requirement also applies to shippersDrivers must be trained and tested in the following areas

bull emergency response procedures including a writtencontingency plan

bull use of DOT hazard communication standards includingshipping papers marking of packages hazard class labels andplacarding of vehicles



bull selection of authorized UN standard packaging

bull proper marking and labeling of hazardous waste containers

bull safe loading and handling procedures including inspectingcontainers segregating incompatible materials and securing theload

bull vehicle operation requirements and

bull filling out hazardous waste manifestsIn addition all hazmat employers must provide transportation securityawareness training Those shippers and carriers required to have aDepartment of Transportation security plan must have in-depth securitytrainingDrivers should visually inspect the truck prior to each trip and carryproper emergency equipment including reflective triangles fireextinguishers and spill kits

Questions to Ask a TransporterQuestions to Ask a TransporterQuestions to Ask a TransporterQuestions to Ask a TransporterQuestions to Ask a Transporter

Before making your final selection you may also wish to ask some of thesequestions of your prospective transporter

bull Will the transporter haul to your chosen facility

bull Will the transporter haul (only) as often as you need

bull How long has the transporter been in business

bull Who are some customers in your area with similar wastes

bull What is the cost of transportation Is that included in thefacilityrsquos recycle or disposal charges

bull Which parts of manifesting (production mailing) will thetransporter handle

bull Will the transporter haul hazardous waste from othercompanies in the same truck with your waste

A thorough background check before contracting with a transporter mayprevent problems


All rights reserved


Step 6Hazardous Waste Disposal OptionsHazardous Waste Disposal OptionsHazardous Waste Disposal OptionsHazardous Waste Disposal OptionsHazardous Waste Disposal Options

Often the more expensive a disposal method is the more it reduces yourlong-term liability (see Figure 6) For example incineration can be the mostexpensive disposal method but because it destroys the waste your long-term liability is very low The least expensive method is typically landdisposal which generally has higher liability because of the potential for

landfills to leak Choose the waste disposal methodthat is best for you and the waste involvedWith the exception of oil in specific circumstanceshazardous waste may not be burned on site Neithercan it be evaporated nor dumped on the groundSome corrosive wastes may be neutralized anddischarged to a sanitary sewer Some wastes such assilver-containing photo fixer may be discharged to asanitary sewer after the silver has been removed (Formore information about discharging to a sanitarysewer please call your local wastewater treatmentplant operator your metropolitan county hazardouswaste staff or the MPCA) Most hazardous wastes aremanaged by sending them to an off-site recycling ordisposal facility

Before Selecting a FacilityBefore Selecting a FacilityBefore Selecting a FacilityBefore Selecting a FacilityBefore Selecting a Facility

If possible visit the facility before shipping wastes there You can thenassess for yourself how your wastes will be managed If you cannot visit afacility you can

1 Talk to your association representative or others in yourindustry Have others used a particular facility Are theysatisfied

2 Talk to other people in your area with similar wastes What aretheir experiences with a particular facility

3 Talk to your broker transporter or facility representative Ask

bull Is the company the final disposal facility or is it a broker(A broker may only arrange for waste handling ortransportation to a facility) If the company is acting as abroker what is the name and location of the actual disposalfacility

bull How will the facility treat or dispose of your waste

bull Who are some customers in your area with similar wastes(Call them Are they satisfied)

Figure 6 Comparing Disposal Options



bull How will the waste be transported to the facility (Somecompanies use their own vehicles others use a contractcarrier In either case you will want to make sure the wasteis hauled by a licensed hazardous waste transporter)

bull Does the facility have a minimum pickup charge

bull Is a waste sample required If so what is the fee foranalysis Will the facility help fill out sample submittalpaperwork Will the facility assist in packaging anddelivering the sample If the waste has already beenanalyzed by an outside laboratory will the facility acceptthat analysis If competitive bids for analytical work areacceptable what tests and units of measurement arenecessary

bull How long will it take to arrange for shipping How long isthe approval process Does the disposal facility help withapprovaltransportation paperwork

bull Can the disposal costs be itemized (handling treatmentdisposal applicable surcharges taxes)

bull In addition you may request information showing that thefacility is permitted to receive the kind of hazardous wasteyou generate and has an EPA identification number Youmay request copies of the portion(s) of their permits thatcover the kind of treatment disposal or recycling they willperform on your waste

Alabama Dept of Environmental Management (334) 271-7700

Illinois Illinois EPA (217) 782-6760

Indiana Dept of Environmental Management (317) 232-7956

Louisiana Dept of Environmental Quality (225) 765-0741

Michigan Dept of Environmental Quality (517) 373-2730

Minnesota Pollution Control Agency (651) 297-7560

Ohio Ohio EPA (614) 644-2917

Oklahoma Dept of Environmental Quality (405) 702-5100

Texas Natural Resources Conservation Commission (512) 239-6082

Wisconsin Dept of Natural Resources (715) 839-3734

Table10 States Often Accepting Minnesota WasteTable10 States Often Accepting Minnesota WasteTable10 States Often Accepting Minnesota WasteTable10 States Often Accepting Minnesota WasteTable10 States Often Accepting Minnesota Waste


All rights reserved


Step 6 4 Call the state regulatory agency where the facility is locatedTalk to the person who inspects the facility (see Table 10 forselected regulatory agencies and telephone numbers) Ask theinspector these questions

bull Is the facility currently in compliance with all regulations Ifnot what are its deficiencies Are those deficiencies minor(such as paperwork) or major (such as impropermanagement) How are major problems if they exist beingaddressed

bull Is the facility permitted to take the kind of waste mycompany generates

bull Has the facility received any fines in the past

bull How often is the facility inspected by your staff

bull Is the facility on the Superfund Cleanup list or a statecleanup list

It is important to maintain contact with state officials especiallyif you cannot visit the facility It is reasonable to contact officialsas often as they inspect the facility

5 Before arranging shipment of your hazardous waste youshould request

bull a copy of the approval letter for the facilityrsquos financialassurance and liability coverage (reviewed annually by thestate) and

bull a contract with the facility for its services (recheck theauthorization waste codes quantities types of containersand date of expected waste shipment) and a certificate ofdisposal if available

Making a Facility VisitMaking a Facility VisitMaking a Facility VisitMaking a Facility VisitMaking a Facility Visit

If you have the opportunity to visit a facility here are suggestions that mayhelp you determine whether it can meet your waste disposal needs

1 Talk to facility officials You may wish to ask some or all ofthese questions

bull What is your facilityrsquos safety record Has your contingencyplan ever been implemented If so describe thecircumstances

bull Do you sample wastes to verify content prior to treatmentrecycling or disposal

bull Do you have lab facilities on site What kind(s) of analysescan you do

bull Can I tour the lab



bull How are wastewater effluents monitored

bull What happens to ash or sludge from processing orincineration

bull How do you handle off-specification wastes

bull How long has the firm been in business

bull Who does inspections What do they look for

bull If the facility is a hazardous waste landfill how often isground water data collected How many sampling pointsdo you have

2 Tour the facility

Look at general housekeeping spill-containment capabilitiesworkers using safety equipment security provisions such asfences warning signs etc condition of buildings tanks andequipment backlog of wastes in the plant disposition of emptydrums manifest files and other document-trackingmechanisms

In addition a hazardous waste facility which is permitted byfederal state andor local governments should have satisfactorysafety equipment in-house training manuals for employeescontainment for possible leaks or spills inspection procedures

and records closure and postclosureplans personnel records and jobdescriptions and emergencycontingency plans

Remember hazardous wastegenerators continue to be responsiblefor the waste they have generatedeven after making good off-site wastemanagement choices Know whereyour waste is going how it ismanaged and what happens toresidues ash and empty drums It isnot only your responsibility it is thelaw which protects the environment

One Minnesota generatorwho visits every facilitybefore shipping waste saysldquoI look particularly at thebacklog of waste and thegeneral housekeeping Ifthere is a lot of waste onhand or if the house-keeping is sloppy I donrsquotsend waste thererdquo


All rights reserved

Prepare and Distribute the Manifest

Step 7

What Is a Manifest and Why Is It so ImportantWhat Is a Manifest and Why Is It so ImportantWhat Is a Manifest and Why Is It so ImportantWhat Is a Manifest and Why Is It so ImportantWhat Is a Manifest and Why Is It so Important

A manifest is a multi-page shipping paper which must accompany mostoff-site shipments of hazardous waste It is a ldquocradle-to-graverdquo record ofwhat happens to your hazardous waste from the time it leaves your site(the ldquocradlerdquo) until it reaches the proper destination (the ldquograverdquo)Tracking hazardous waste helps to ensure that it is managed and disposedof in a manner that does not pose a risk to human health or theenvironmentIn addition manifests are helpful in completing license forms and tracking

waste-reduction efforts

When to Use a ManifestWhen to Use a ManifestWhen to Use a ManifestWhen to Use a ManifestWhen to Use a Manifest

Some hazardous wastes such as wastes reused as feedstocksor by-products do not need to be accompanied by amanifest however you do need documentation showingthat the waste was received by the user These wastesalso may be transported using a shipping paper ratherthan a manifest

bull lead-acid batteries

bull universal wastes

bull used oil filters and sorbents destined for recyclingand

bull waste from Very Small Quantity Generators(VSQGs) going to a licensed VSQG collection program in

MinnesotaThese wastes may be transported within Minnesota using a waste-tracking invoice rather than a manifest

bull antifreeze

bull electronicscathode ray tubes

bull circuit boards managed as scrap metal

bull PCB lamp ballasts and

bull small PCB capacitors

Figure 7 HazardousWaste Manifest


Step 7Prepare and Distribute the Manifest

Preparing the ManifestPreparing the ManifestPreparing the ManifestPreparing the ManifestPreparing the Manifest

The company that generates a hazardous waste (a ldquogeneratorrdquo) isresponsible for preparing a manifest to accompany that waste when itleaves the site Although your transporter may prepare the manifest aspart of their service you as the generator of the waste are responsible forthe contents of the manifest For this reason it is important that youbecome familiar with the document

Which Manifest to UseWhich Manifest to UseWhich Manifest to UseWhich Manifest to UseWhich Manifest to Use

The type of manifest you will use is going to change on September 5 2006Until that time Minnesota and several other states (see Table 11) requirethe use of their statersquos modified Uniform Hazardous Waste Manifest UntilSeptember 5 2006 if you are shipping waste to any of thestates listed in Table 11 you must use that statersquos modifiedUniform Hazardous Waste Manifest formYou may obtain the appropriate manifest from

bull the regulatory agency in the state to which you areshipping

bull the facility to which you are shipping or

bull your transporter

If the state you are shipping to is not on the list use aMinnesota manifest Minnesota manifests may bepurchased from Minnesotarsquos Bookstore at

660 Olive StreetSt Paul MN 55155(See phone numbers on inside of back cover)

After September 5 2006 everyone in all states must use theNational Uniform Hazardous Waste Manifest You may obtain a NationalUniform Hazardous Waste Manifest from any vendor registered with EPA

Filling Out a ManifestFilling Out a ManifestFilling Out a ManifestFilling Out a ManifestFilling Out a Manifest

Line-by-line instructions are included with each manifest Remember thatyou are completing a multi-page document so use a good ball-point penprint legibly and press hard You want to ensure the last copy is as legibleas the first If you prefer manifests may be typedMost of the information you provide is specific to your company and yourwaste shipment Whether completing the manifest yourself or using onecompleted by your transporter take a moment to check the following

bull Is the EPA ID number valid Is it the correct number for thecompany name listed on the manifest Is the EPA ID number

AlabamaArkansasConnecticutDelawareGeorgiaIllinoisLouisianaMarylandMassachusettsMinnesotaMississippi

MissouriMaineNew HampshireNew JerseyNew YorkPennsylvaniaRhode IslandSouth CarolinaTexasVermontWisconsin

Table 11 States Having TheirTable 11 States Having TheirTable 11 States Having TheirTable 11 States Having TheirTable 11 States Having TheirOwn ManifestOwn ManifestOwn ManifestOwn ManifestOwn Manifest


All rights reserved


Step 7

Figure 8 Manifest Distribution

the correct number for the generation site address listed on themanifest (Items 1 and 3)

bull Are the number of containers and total quantity of wasteshipped correct (Items 12 amp 13)

bull Is the other information (names phone numbers ID numbersDOT descriptions waste numbers) correct

bull Is the manifest signed and dated with the shipping date by bothyour company representative and the transporter

bull Is there an emergency telephone number with a 24-hour staffedline listed

Manifest Distribution for Small and Large QuantityManifest Distribution for Small and Large QuantityManifest Distribution for Small and Large QuantityManifest Distribution for Small and Large QuantityManifest Distribution for Small and Large QuantityGeneratorsGeneratorsGeneratorsGeneratorsGenerators

What happens next depends upon whether your manifest has six or eightpages Ideally this is how it will workIf your manifest has six pages your transporter will leave the last twopages with you and take the top four pages to accompany the waste Bothpages left at your site should have two signatures mdash yours and the

transporterrsquos These are sometimes called the two-signature pages When the waste leaves your sitemake a legible copy of the page labeled GeneratorRetains Place the original in your fileWithin five days of the waste leaving your site

bull mail the page labeled Generator mails toDestination State to the state to which yourwaste is going and

bull mail the copy you made to the MPCA at theaddress on the manifest

When the transporter and your waste reach thefacility the facility will sign and date the remainingfour pages of the manifest The facility will then

bull give a page to the transporter for a record ofwhen the waste was picked up and when itwas delivered

bull keep a page for its records

bull send a page to its state agency (destination state)and

bull send a page to you the generatorThe page you receive back from the facility has three signatures on it mdashyours your transporterrsquos and the facilityrsquos This is sometimes called the



three-signature page or the facility page If you send waste to a facility in astate that requires only a six-page manifest you are responsible for either

1 ensuring that the facility sends a copy of the signed manifest tothe MPCA or

2 sending the MPCA a copy of the signed manifest you havereceived from the facility

The MPCA must receive the copy within 40 days of when the facilityaccepted the waste MPCA staff match this with the two-signature copyFile the original with the two-signature pageIf your manifest has eight pages your transporter will leave the last threepages with you and take the top five pages to accompany the waste Allthree pages left at your site by the transporter will have two signatures mdashyours and the transporterrsquos These are sometimes called the two-signaturepages When the waste leaves your site place the page labeled GeneratorRetains in your fileWithin five days of the waste leaving your site

bull mail the page labeled Generator mails to Destination State to thestate to which your waste is going and

bull mail the page labeled Generator mails to Generator State to theMPCA at the address on themanifest

When the transporter and your wastereach the facility the facility will sign anddate the remaining five pages of themanifest then

bull give a page to the transporterfor a record of when the wastewas picked up and delivered


bull send a page to its state agency(destination state) and

bull send a page to you thegenerator (If the facility is outof state make a copy of thethree-signature facility pageand send the copy to the MPCAwhere MPCA staff will match itto your two-signature copy)

The page your receive back from the facility will have three signatures on itmdash yours your transporterrsquos and the facilityrsquos File this three-signature page(also called facility page) with the two-signature page

MPCA staff track about 128510 manifests each yearOf these about 1 are incorrect and require additionalfollowup The most common problems are

bull 51 General Info section mdash generator name notmatched to the EPA ID or the ID is not valid

bull 12 Certification section mdash missing signature(s)

bull 7 Manifest unreadable

bull 5 Certification section mdash missing date(s)

bull 4 DOT section missing or incorrect

bull 2 Transporter or facility ID not valid

bull 19 Other

Correcting mistakes costs us all time and money Pleasetake a moment to double-check your manifest

Table 12 Common Manifest ViolationsTable 12 Common Manifest ViolationsTable 12 Common Manifest ViolationsTable 12 Common Manifest ViolationsTable 12 Common Manifest Violations


All rights reserved


Step 7Shipping Waste to a Facility in MinnesotaShipping Waste to a Facility in MinnesotaShipping Waste to a Facility in MinnesotaShipping Waste to a Facility in MinnesotaShipping Waste to a Facility in Minnesota

If your hazardous waste is shipped to a Minnesota facility you will use theeight-page Minnesota manifest In this case since the generator state andthe destination state are the same (Minnesota) send one of the two-signature pages to the MPCA and keep one for your records You maydiscard the extra two-signature page

Manifest Distribution for Very Small QuantityManifest Distribution for Very Small QuantityManifest Distribution for Very Small QuantityManifest Distribution for Very Small QuantityManifest Distribution for Very Small QuantityGeneratorsGeneratorsGeneratorsGeneratorsGenerators

Very Small Quantity Generators (VSQGs) in the metropolitan area (AnokaCarver Dakota Hennepin Scott Ramsey and Washington Counties)should follow the Manifest Distribution for Small and Large QuantityGenerators procedures except for these changes

bull VSQGs in Scott County should send their two-signature page and acopy of their three-signature page to

Scott County Environmental Health200 Fourth Avenue WestShakopee MN 55379-1220

bull VSQGs in the other metro counties should send their two-signaturepage and a copy of their three-signature page to

Hazardous Waste Manifest ProgramMail Code 609300 South 6th StreetMinneapolis MN 55487

Very Small Quantity Generators in Greater Minnesota should keep a copyof their manifests for their records for at least three years (for the life of thebusiness is better) but they do not need to send a copy to the MPCA TheMPCA no longer collects manifest copies from VSQGs

If You Donrsquot Get the Facility PageIf You Donrsquot Get the Facility PageIf You Donrsquot Get the Facility PageIf You Donrsquot Get the Facility PageIf You Donrsquot Get the Facility Page

Within 35 days of shipping your waste you should receive a three-signature page back from the facility If you do not call the facility to findout why you have not received it (the phone number is on the two-signaturepage in your file) You may also want to call your transporterIf you do not receive the three-signature page within 45 days of theshipping date you must file an exception report with the MPCA



Filing an Exception ReportFiling an Exception ReportFiling an Exception ReportFiling an Exception ReportFiling an Exception Report

If you do not receive the three-signature page from the facility within 45days of shipping the waste you must send an exception report to theMPCA co Hazardous Waste Program An exception report is simply

bull a letter addressed to the MPCA Commissioner or your metropolitancounty hazardous waste staff stating the problem and what you havedone to locate your waste and

bull a copy of your page of the manifest that was sent with the waste

Keep a copy of the exception report for a minimum of three years

Manifest Record Keeping RequirementsManifest Record Keeping RequirementsManifest Record Keeping RequirementsManifest Record Keeping RequirementsManifest Record Keeping Requirements

Manifests must be kept for a minimum of three years An inspector visitingyour site will request to see all of your manifests for the past three years sokeep them where they can be accessed easily MPCA staff stronglyrecommends that you keep your manifests for the life of your business ifpossible If there are any future questions about where you sent waste youwill have that information readily availableSmall and Large Quantity Generators who are required to complete andkeep Land Disposal Restriction (LDR) forms (see below) often keep both theLDR forms and manifests together

Sending Manifest Pages or Copies to the MPCASending Manifest Pages or Copies to the MPCASending Manifest Pages or Copies to the MPCASending Manifest Pages or Copies to the MPCASending Manifest Pages or Copies to the MPCA

Send original pages or copies of manifest pages to

ATTN HWIMSMPCAIndustrial Division520 Lafayette Road NorthSt Paul MN 55155-4194

(HWIMS stands for Hazardous Waste Information Management Systemmdash the computer data base where manifest information is kept)

Land Disposal RestrictionsLand Disposal RestrictionsLand Disposal RestrictionsLand Disposal RestrictionsLand Disposal Restrictions

Land Disposal Restriction (LDR) requirements generally apply towastes that are hazardous due to a hazardous characteristic orthat are listed hazardous wastes All Small and Large QuantityGenerators (SQGs and LQGs) must comply with LDR rules whichprohibit the disposal of many hazardous wastes on the land unlessthey meet specified treatment standards LDR Rules do not applyto Very Small Quantity Generators (VSQGs) however treatmentstorage and disposal facilities may require VSQGs to comply with LDR

LDR regulationsLDR regulationsLDR regulationsLDR regulationsLDR regulationsprohibit dilutingprohibit dilutingprohibit dilutingprohibit dilutingprohibit dilutingto achieveto achieveto achieveto achieveto achievetreatment levelstreatment levelstreatment levelstreatment levelstreatment levels


All rights reserved


Step 7Rules For help contact the EPA toll-free hotline at the phone number onthe inside of the back cover

LDR Information and Manifests LDR Information and Manifests LDR Information and Manifests LDR Information and Manifests LDR Information and Manifests (Minn R 70451300)

When a generator ships a waste that does not meet LDR treatmentstandards the generator must submit a one-time written notification to theoff-site treatment storage or disposal facility with the initial shipment ofthe waste This notification is valid unless the waste stream changes or thefacility receiving the waste changes The notification must accompany thehazardous waste manifest during shipment and must include

bull the generatorrsquos EPA identification number

bull the manifest number associated with the shipment

bull the applicable EPA hazardous waste codes and underlyinghazardous constituents

bull the applicable wastewater or nonwastewater category

bull the applicable subdivision for each EPA hazardous waste codeand

bull waste analysis data (when available)If a waste meets LDR treatment standards the generator must submit aone-time initial notification (as explained above) and a certificationstatement verifying that the waste meets specified treatment standards andcan be land disposed without further treatment This information mustaccompany the manifestKeep copies for a minimum of three years (See Appendix E)


Step 8Plan for Emergencies

Prevention and PlanningPrevention and PlanningPrevention and PlanningPrevention and PlanningPrevention and Planning

No business ever intends to release hazardous materials or waste but spillscan still happen For this reason it is important to plan and prepare forthis type of emergency before it happensThe best preparation is prevention Do all you can to decrease yourchances of a spill train employees to do their jobs correctly and maintaingood housekeeping standards at your business Then with a good planproper equipment and employees trained to quickly respond to a spill youcan lessen your cleanup costs the impact on employee health and theenvironment and future liability for your businessKeep in mind mdash Occupational Safety and Health Administration (OSHA)regulations require employers to plan for emergencies which couldthreaten worker safety When planning for the possibility of a chemicalspill you will need to determine what size and type of spill can be handledroutinely and what size and type of spill becomes an emergency Workersshould be trained in spill cleanup procedures for routine chemical spills Ifa chemical spill occurs of a size or type that constitutes an emergency speciallytrained spill-response workers must handle the emergency It is usually notfeasible for small employers to maintain their own staff of spill-responseworkers Your plan for emergency chemical spills will likely involveevacuating your workers from the spill area and calling for outsidechemical spill-response assistance

Minimal and Very Small Quantity GeneratorMinimal and Very Small Quantity GeneratorMinimal and Very Small Quantity GeneratorMinimal and Very Small Quantity GeneratorMinimal and Very Small Quantity GeneratorRequirements Requirements Requirements Requirements Requirements (Minn R 70450292 subp 6 item G)

Hazardous Waste Rules no longer require VSQGs to complete anemergency responder notification form to notify local emergency services(such as police or other first responders) of the kind and amount ofhazardous waste stored on site Local fire protection personnel may visityour site and gather this information for their useAll Minimal Quantity Generators (MQGs) and VSQGs are required to

1 Set up and follow procedures to minimize the possibility of accidentswhich could threaten human health or the environment If youhavenrsquot already initiated these preventive measures start today

bull Close containers

bull Provide adequate aisle space in storage areas to inspect andremove containers

bull Protect storage areas from inadvertent damage from equipmentor unauthorized personnel

bull Seal floor drains to prevent releases


All rights reserved

Plan for Emergencies

Step 8bull Conduct (required) weekly inspections of storage areas

bull Store products in the original packaging or in containersapproved for the material

bull Label materials indicating health hazards flammabilityreactivity spill cleanup procedures and personal protectiveequipment necessary to prevent exposures

bull Limit the quantity of flammable and combustible liquids storedat any one time (Check httpwwwdpsstatemnusfmarshalfmarshalhtml for the Minnesota Uniform Fire Code require-ments on product storage limitations for each type of occupancy)

bull Store flammable and combustible liquids in an approvedflammable liquid storage cabinet when not in use

2 Have the following emergency equipment available

bull An easily accessible internal communications system capable ofalerting personnel (For small shops the human voice may besufficient For larger shops an intercom loudspeaker alarmsystem or telephone may be necessary)

bull A telephone to contact outside emergency personnel

bull Spill-response equipment

bull Decontamination equipment

bull Portable fire-protection equipment (such as fire extinguishers mdashremember Occupational Safety and Health Administration(OSHA) requires employees that use them to be trainedannually)

bull Water at adequate volume and pressure to meet fire-protectionneeds (Fire sprinkler systems provide superior protection forpeople property and business operations Check the MinnesotaUniform Fire Code for specific requirements)

3 Maintain and test all emergency equipment according to themanufacturerrsquos instructions to ensure proper operation in anemergency

bull Keep fire-protection equipment in operating condition at alltimes

bull Fire alarm and sprinkler systems should be inspected andtested at least annually by a competent licensed individual

Train employees on emergency operations exiting fire alarms and useof fire extinguishers



4 Provide adequate aisle space in work and storage areas for evacuatingpersonnel as well as easy access to a damaged container

bull Limit the quantities of flammable liquids stored in any one area

bull Doors from all locations in the building and to the outsideshould not be locked in such a way that would require a key orspecial knowledge to open the door from the inside (In anemergency employees may have to leave quickly)

Call your local fire chief for help They can access codespecialists at the State Fire Marshal Division about general firesafety and the Minnesota Uniform Fire Code

5 Plan for emergencies

OSHA regulations require employers to plan for emergencies whichcould threaten worker safety Train your employees how to clean uproutine chemical spills how to identify when a spill is not ldquoroutinerdquoand the steps they should take for non-routine spills

Although rapid containment can help reduce the severity of a spilluse caution Your safety and the safety of your employees should beyour main concern Persons doing cleanup or containment shouldwear proper protective equipment for the quantity and nature of thematerial spilled At a minimum cleanup personnel should wearwashable boots gloves and eye protectors

If a hazardous waste or material spill occurs follow these steps

bull Evaluate the situation If there is any potential for dangerremove the personnel at risk As an extra precautionextinguish all sources of ignition such as sparks fromequipment open flames or burning cigarettes

bull Notify the companyrsquos emergency coordinator

bull Contain and clean up the spill (You may need to call for outsidechemical spill-response assistance for this step) If theenvironment around the spilled material is safe and there is nodanger to employees prevent additional spillage and containhazardous materials with a dike made of sorbent materials Tryfirst to recover liquid materials as liquids if it can be done safely(ie donrsquot just routinely dump sorbent on a spill) Place cleanupmaterials from small spills into a container and apply acompleted hazardous waste label Manage the recovered wasteaccording to Minnesota Hazardous Waste Rules

Report the spill to

bull the 24-hour Minnesota Duty Officer

bull your local fire department and

bull the EPA National Response Center


All rights reserved


Step 8 Complete and display the telephone posting on page 94 forquick access to emergency numbers

When reporting a spill you will need to give the informationoutlined in step 6 below

6 If a release of any substance may cause pollution of the air land orwater report the incident immediately to the Minnesota Duty OfficerWhen reporting be prepared to give the following information

bull name and phone number of company contact

bull name address and EPA identification number for the company

bull date time and type of incident

bull quantity and type of waste released

bull health hazards of the waste and extent of any injuries and

bull estimated quantity and disposition of recovered materials

Small Quantity Generator RequirementsSmall Quantity Generator RequirementsSmall Quantity Generator RequirementsSmall Quantity Generator RequirementsSmall Quantity Generator Requirements(Minn R 70450292 subp 5 item H)

All Small Quantity Generators (SQGs) are required to comply with therequirements for VSQGs outlined in steps 1 through 6 above plus

7 Notify local authorities All SQGs are required to provide thefollowing information to police fire departments and emergency-response teams

bull a list of the types of hazardous waste stored on site theirphysical properties (flammability corrosivity etc) andassociated health hazards and

bull a building floor plan showing the hazardous waste storageareas building entrances evacuation routes and personnelworking areas

Note If more than one police and fire department responds toan emergency the generator must work with these departmentsto establish primary emergency authority

All SQGs are required to provide the following information to localhospitals


bull potential injuries or illnesses that could result from firesexplosions or releases



To fulfill notification requirements complete and mail pages 2 3 and4 of the packet found in Appendix F

Keep a written record of this information

8 Appoint an emergency coordinator

Appoint an emergency coordinator who will be on site or on call at alltimes This position is often filled by the company owner or operatorYou may wish to appoint an alternate coordinator for backup

List your coordinator on the first page of the packet

9 Post emergency information

Post the following information next to every telephone which mightbe used in an emergency

bull the name and telephone number of the emergency coordinator(and backup)

bull the telephone number of the fire department and

bull the location of fire extinguishers spill control equipment andfire alarms

To fulfill these requirements fill out and post page 5 of the packetNote extra telephone numbers are listed which may be helpful

10 Train employees

State law requires SQGs to train employees in proper hazardouswaste handling (see Step 9)

Requirements for Large Quantity Generators (LQGs)Requirements for Large Quantity Generators (LQGs)Requirements for Large Quantity Generators (LQGs)Requirements for Large Quantity Generators (LQGs)Requirements for Large Quantity Generators (LQGs)(Minn R 70450566 - 0576)

Emergency planning and prevention requirements for LQGs are morecomprehensive than the requirements for Very Small or Small QuantityGenerators LQGs must have all the emergency and communicationsequipment described in the Very Small Quantity Generator RequirementsThey must maintain and regularly test it to ensure it is working Theymust maintain adequate aisle space In addition LQGs are required tohave a contingency plan mdash a written document describing equipmentavailable to manage an emergency procedures to be followed andarrangements made in order to prevent or minimize the hazards associatedwith hazardous waste Requirements for contingency plans are found inMinn R 70450572-0576 The explanation of requirements for SmallQuantity Generators in this section may also help you


All rights reserved


Step 8Although the rules apply only to hazardous waste staff of the MPCA andmetropolitan county hazardous waste programs strongly recommend thata comprehensive contingency plan be developed that considers allpotential hazards at the siteAt a minimum a hazardous waste contingency plan should contain thefollowing information

1 Section I mdash Emergency Coordinator

One or more qualified employees must be available on site or oncall at all times to act as an emergency coordinator A primarycoordinator and alternates can be appointed to ensure this Theplan must include the name address and office and hometelephone numbers of each coordinator

2 Section II mdash Emergency Telephone Numbers

List the telephone numbers for the local police department firedepartment and emergency (ambulance) service Also list thenumbers for the State Duty Officer the EPA National ResponseCenter and any other appropriate numbers

3 Section III mdash Hazardous Wastes Generated On Site

For each hazardous waste generated at the facility list thename amount generated and maximum amount storedInclude a site drawing indicating where hazardous waste isstored treated or disposed of Include areas of satelliteaccumulation

4 Section IV mdash Emergency Response

Develop specific written procedures for responding to spillsfires and explosions of hazardous waste The written proceduremust include

bull who will respond

bull what they will do

bull the equipment to be used and

bull who will be contacted

Separate prodecures should be written for large incidents andsmall incidents Procedures should be written specifically forextremely hazardous wastes such as explosives or acutelyhazardous wastes if they are generated on site Otherwisewastes can be grouped if the response would be similar

5 Section V mdash Arrangements with Local Emergency ResponseServices

Describe the services which will be provided by the local policedepartment fire department and emergency hospital Includethe name and phone number of an environmental cleanupcontractor that could be called in for a major incident if needed



Cover letters used to send the contingency plan to the policefire department and emergency hospital should be included inthis section

6 Section VI mdash Release-Prevention Measures

Describe measures taken to prevent the escape of hazardouswaste For example include types of containers usedperformance of inspections employee training availability ofemergency-response equipment and anything else that pertainsto your site and situation

7 Section VII mdash Emergency Equipment

List all emergency equipment available at the facility includingfire extinguishers and equipment spill-control equipmentinternal and external communications and alarm systems anddecontamination equipment Provide a brief outline of thecapabilities and location of the equipment A facility diagramshowing locations of emergency equipment is very helpful

8 Section VIII mdash Evacuation Plan

If fires explosions or spills of a hazardous waste would makeevacuation necessary then an evacuation plan must be includedin the contingency plan Describe procedures for evacuationincluding the signals used to initiate it Include a diagram of thefacility with arrows indicating primary and secondaryevacuation routes

Keep a copy of your contingency plan (and any revisions you make) atyour facility Submit copies of the contingency plan (and any revisions) tothe local police department fire department emergency hospital and anyother emergency response teams that may be called upon in an emergencyas well as your metropolitan county hazardous waste or MPCA staffMake copies of the plan readily available throughout the facility sinceemergency coordinators and employees are required to be familiar with itscontents and how it is to be implementedRevise your contingency plan whenever the rules change the plan fails inan emergency the coordinator(s) change(s) the list of emergencyequipment changes or the facility design construction operation ormaintenance changesImproper waste handling or disposal can result in contamination of soiland water and employee exposure to hazardous materials mdash and itrsquosagainst the law The end result is increased cost and liability to theemployerThe best way to prevent generating unnecessary waste is to thoroughlytrain employees on how to perform their job duties safely and properlyThis knowledge can lead to improved efficiency and reduced waste Good


All rights reserved

Train Employees

Step 9training may also enable employees to identify ways to improveperformance and processesAlthough Very Small Quantity Generators are not required to have aformal documented training program they are required to run theirbusiness in accordance with the regulations mdash which means they mustensure employees are familiar with the rules they must follow (ldquotrainedrdquo)

Types of TrainingTypes of TrainingTypes of TrainingTypes of TrainingTypes of Training

Itrsquos not only a good idea to teach employees how to handle hazardouswaste correctly and how to respond to emergencies itrsquos the law (Minn R70450292) This training is in addition to the employee right-to-know orldquoHazwoperrdquo training required by Occupational Safety and HealthAdministration (OSHA) regulations and the hazardous materials(ldquoHazMatrdquo) training required by Department of Transportation (DOT)regulations (However all three types of training cover similar andcompatible information and may successfully be combined into onetraining program Remember documentation must meet requirements ofall three programs)To determine what kind of training each employee needs identify herhisjob responsibilities (Employees whose responsibilities include hazardouswaste management storage transport or record keeping requirehazardous-waste training The MPCA strongly recommends training allemployees in emergency response procedures) Make sure each employeewho is required to manage hazardous waste is trained sufficiently tocorrectly fulfill herhis responsibilities

Topics and InstructorsTopics and InstructorsTopics and InstructorsTopics and InstructorsTopics and Instructors

Training should include

bull Documentation mdash This means you must keep records thatinclude employee names dates of training and content of thetraining such as outlines or a written description

bull Training Relevant to Employeersquos Responsibilities mdash This meansyou must train employees who perform one or more hazardouswaste management tasks or those who respond to emergenciesTraining should be specific to the waste handling task(s) eachemployee performs

bull Proper Waste Handling mdash

bull Managing hazardous waste containers including choosingproper containers marking and labeling containers andproper container handling


Step 9Train Employees

bull Accumulating waste including storage time limits satelliteaccumulation adequate aisle space keeping containersclosed and separating incompatible wastes

bull Inspecting stored waste documenting weekly inspections

bull Shipping procedures including use of manifests and othertrackingdisposal records

bull Preparing containers for shipping and

bull Keeping required records

bull Emergency Procedures mdash Responding to emergenciesincluding locating and maintaining emergency equipmentreporting spills and reviewing specific emergency proceduresdeveloped for your company (If you donrsquot have anyone onstaff trained to respond to a hazardous waste spill or releaseyour emergency procedures may include calling a companyspecializing in emergency cleanup to come to your site tomanage a spill or release)

Training may be provided by a qualified member of your staff Thetraining should reflect employee responsibilities and procedures specific toyour company Although you are not required to train employees in areasfor which they are not normally responsible it may be advantageous toprovide more training than is needed for these reasons

bull If the employee responsible for a specific duty is not availableanother employee can easily fill in (employees cannot perform ahazardous waste-related duty for which they are not properlytrained unless directly supervised)

bull It may be easier to prepare training for several employees andtrain them all at one time rather than to perform individualtraining

bull Employees who have a broad knowledge of systems and howtheir responsibilities affect the company may be more readilyable to identify time and cost-saving procedures for thecompany

bull In order to respond quickly to emergencies it is important forall staff to be trained in emergency procedures and use of theemergency telephone posting or contingency plan

Requirements for Small Quantity Generators (SQGs)Requirements for Small Quantity Generators (SQGs)Requirements for Small Quantity Generators (SQGs)Requirements for Small Quantity Generators (SQGs)Requirements for Small Quantity Generators (SQGs)(Minn R 70450292 subp 5 Items H and J)

The personnel training rules for SQGs state ldquoSmall Quantity Generatorsmust ensure and document that all employees are thoroughtly familiarwith proper waste handling and emergency procedures relevant to their


All rights reserved

Train Employees

Step 9responsibilities during normal facility operations and emergenciesrdquoAlthough SQGs are not required to train annually they must ensure thatemployees who require training have received it within six months of thedate of their employment or a change in job responsibilities

Requirements for Large Quantity Generators (LQGs)Requirements for Large Quantity Generators (LQGs)Requirements for Large Quantity Generators (LQGs)Requirements for Large Quantity Generators (LQGs)Requirements for Large Quantity Generators (LQGs)(Minn R 70450558)

Personnel training requirements for LQGs are more comprehensive andmust include

bull designating a hazardous waste training program coordinator

bull keeping personnel records documenting job titles jobdescriptions and job requirements

bull documenting the course contents

bull training newly appointed personnel within 6 months ofassuming their job assignments

bull reviewing training annually and

bull keeping records (documentation) of all hazardous wastetraining

Training ResourcesTraining ResourcesTraining ResourcesTraining ResourcesTraining Resources

The MPCA offers fact sheets which may help you train employees For alist of available fact sheets visit the MPCA web site athttpwwwpcastatemnus Click on Waste then under Publicationsclick on Hazardous Waste Fact Sheets The MPCA also has a limited supplyof training videos available (on evaluating waste marking and storing andwhat to expect during an inspection)The MPCA offers compliance workshops that can help train your trainersand employees Because personnel training should be specific to yourcompany businesses who use these workshops to train employees shouldsupplement the training with company-specific information Forinformation about upcoming workshops check the MPCA Web site (underNewsNotices see the Training Events Calendar) Some metropolitancounties also offer compliance training workshops Check with yours tosee if it does


Step 10Keep Records

Training RecordsTraining RecordsTraining RecordsTraining RecordsTraining Records

Each business must keep good training records The form provided inAppendix G is one way to do it Use of this form is not required mdash youmay design your own Personnel training records must be kept on site andavailable for review for at least three years from the date of an employeersquostermination from the company

Required RecordsRequired RecordsRequired RecordsRequired RecordsRequired Records

Every business that generates a hazardous waste is required to keeprecords All records must be kept at the location where the waste isgenerated and must be available for inspection Electronic record keepingis acceptable as long as they are kept at the genertion location andavailable for inspection Keep the following records for at least three years

bull manifests and manifest exception reports (discussed in detail inStep 7)

bull Land Disposal Restriction (LDR) notification forms required ofSmall and Large Quantity Generators only (if you are a VerySmall Quantity Generator or VSQG and you receive LDRnotification forms MPCA and metropolitan county staffrecommend keeping them with your manifests)

bull a copy of your annual license application

bull analytical and other reports such as Toxicity CharacteristicLeaching Procedure and flash point test results

bull training documents (training is required of Small and LargeQuantity Generators only documentation must be kept threeyears from the last day the employee worked for you)

bull weekly inspection documentation logs (for more informationand a sample to help you see Appendix D DocumentingContainer Inspections)

bull shipping papers or a log showing you recycle 75 percent of thelead-acid batteries you collect each year (see Appendix H for alog to help you do this)

bull receipts or shipping papers for used oil used oil filters sorbentsspecial wastes fluorescent and high-intensity discharge lampsand VSQG wastes taken to a VSQG collection site

bull documentation for feedstocks and by-products

bull LQGs must also keep revisions to Contingency Plans(Minn R 70450572 Subp 5) and

bull Large quantity handlers of universal waste (5000 kilograms ormore) must keep records of wastes received and shipped


All rights reserved

Keep Records

Step 10Recommended RecordsRecommended RecordsRecommended RecordsRecommended RecordsRecommended Records

In addition to the records listed above staff from the MPCA and themetropolitan counties recommend keeping

bull documentation showing how you determined a potentiallyhazardous waste to be nonhazardous

bull correspondence from the MPCA your metropolitan county orthe EPA regarding hazardous wastes or wastes you havedetermined through evaluation to be nonhazardous

bull a telephone log of calls regarding hazardous wastemanagement

bull facility Certificates of Destruction or Recycling (if you receivethem)

bull spill and cleanup records and

bull shipping papers and records of universal wastes sent off siteIt is a good idea to keep records showing you have properly managed eachregulated waste your business generates and if you can to keep allrecords for the life of your businessWith the help of several Minnesota businesses that generate hazardouswaste the MPCA has developed a shipping log that may make yourrecord keeping easier This form is offered as an aid only mdash it is notrequired For a copy see Hazardous Waste fact sheet 240 HazardousWaste Shipping Log

und

This concludes the ldquo10 Steps to CompliancerdquoThis concludes the ldquo10 Steps to CompliancerdquoThis concludes the ldquo10 Steps to CompliancerdquoThis concludes the ldquo10 Steps to CompliancerdquoThis concludes the ldquo10 Steps to Compliancerdquo


1 Discharging to Sewer 592 Lead-Acid Batteries 613 Reducing Waste 634 Parts Washers 665 Used Oil 676 Used Electronics 767 Universal Wastes 79

TopicsSpecial


All rights reserved

Notes


Topic 1Discharging to the Sewer

The Resource Conservation and Recovery Act (RCRA) defines whether awaste is hazardous but not whether it can be discharged to a sewersystem Hazardous waste may be discharged to a sewer system only ifallowed under local wastewater discharge rules the Clean Water Act(CWA) and if applicable categorical pretreatment requirements Also theappropriate notification procedures must be followed To determinewhether a discharge is allowable first evaluate the waste by both RCRAand CWA regulations Then work with your local wastewater treatmentplant (WWTP) operator and MPCA (or county if in the Minneapolis-StPaul seven county metropolitan area) Individual wastewater collectionsystems and WWTPs have different capacities treatment capabilities andissues of concern Your WWTP operator may or may not be able tosuccessfully treat your particular waste or there may be other issuesrelated to a waste not being appropriate in terms of collection system issues(eg corrosivity or flammability) In addition the WWTP operatorrsquos owndischarge limits may restrict what a treatment plant can accept Your localwastewater treatment plant operator is the final authority on whether ornot you may discharge to your local wastewater treatment plantBusinesses that discharge hazardous waste are required under CWAregulations to notify (in writing) the wastewater treatment plant (WWTP)the MPCA and the US Environmental Protection Agency of the types andamounts of hazardous waste discharged Notify the WWTP when

bull Waste is hazardous at the point of discharge Some wastes may behazardous at the point of generation but not after treatment mdash forexample some neutralized acids or bases

bull More than 33 gallons per month of non-acutely hazardous waste isdischarged All acutely hazardous waste must be reported

bull Discharge is not already reported to the MPCA under a NationalPollutant Discharge Elimination System (NPDES) permit or StateDischarge System (SDS) permit

bull Discharge is to a wastewater treatment plant mdash not a septic systemdrainage ditch or other ldquowaters of the staterdquo (See Minn StatChapter 116 for a definition of ldquowaters of the staterdquo)

To notify businesses in Greater Minnesota can use the Sewered WasteNotification Form (Hazardous Waste fact sheet 711) Businesses in themetropolitan area should contact their county hazardous waste office forthe proper form


All rights reserved

Discharging to the Sewer

Topic 1Pretreatment Before Discharge to a WastewaterPretreatment Before Discharge to a WastewaterPretreatment Before Discharge to a WastewaterPretreatment Before Discharge to a WastewaterPretreatment Before Discharge to a WastewaterTreatment PlantTreatment PlantTreatment PlantTreatment PlantTreatment Plant

Pretreatment before discharge is allowable provided the subsequentdischarge meets the provisions of the CWA pretreatment regulations andthat applicable categorical pretreatment standards are met Wastesdischarged to a pretreatment unit are not exempt under the DomesticSewage Exclusion since the waste is not co-mingled with domestic sewagePretreatment units are permitted by rule mdash they do not require a specialRCRA treatment permit And since pretreatment units generally renderthe waste nonhazardous a Sewered Waste Notification Form is not usuallyrequired However the sludge needs to be evaluated to determine whetherit is hazardous A sludge may be hazardous because it exhibits ahazardous characteristic (Minn R 70450131) or because of theldquomixturesrdquo rule for wastewaters (Minn R 70450102 subp 2 item F) andsubsequent treatment (ldquoderived fromrdquo rule) of the mixture

Discharge to a System Other Than a WWTPDischarge to a System Other Than a WWTPDischarge to a System Other Than a WWTPDischarge to a System Other Than a WWTPDischarge to a System Other Than a WWTP

ldquoOther systemsrdquo include systems such as septic tankdrainfield systemsand class V injection wells Discharge of a hazardous waste to these typesof systems is not allowed under RCRA Because of the limitations of thesetypes of systems no industrial (business) waste should be discharged tothem


Topic 2Used Lead-Acid Batteries

If not managed properly spent lead-acid batteries (SLABs) may leak orspill causing lead andor acid contamination of the soil and groundwater Persons who generate collect or accumulate spent lead-acidbatteries are responsible for proper storage and containment of leaks orspillsSLAB generators may manage waste batteries under either the hazardouswaste generator standards (Minn Rules pts 70450205 to 70450320)under special battery management standards in Minn Rules 70450685 oras universal waste under Minn Rules 70451400 Most generators find thestandards of part 70450685 to be the most convenient and protectiveThey are summarized below

Storing BatteriesStoring BatteriesStoring BatteriesStoring BatteriesStoring Batteries

Spent lead-acid batteries may be stored either indoors or outdoors Indoorsmeans in a building having a roof and at least three walls which arepermanently attached to an impermeable floor which lies directly on theground Semitrailers and sheds without floors do not qualify as indoorstorage areas

Indoor StorageIndoor StorageIndoor StorageIndoor StorageIndoor Storage

Store SLABs on a nonreactive curbed and impermeable surface Anonreactive and impermeable surface will help ensure that acid and leadwill not corrode or pass through the containment area and leak into thesoil or ground water Curbing will prevent leaks or spills from running offthe edge of the containment areaIf your storage area has a floor drain place the batteries in a plastic tub orother container that will provide adequate containment of a spill or leak

Outdoor StorageOutdoor StorageOutdoor StorageOutdoor StorageOutdoor Storage

In addition to storing SLABs on a nonreactive curbed and impermeablesurface construct the outdoor storage area in a way that will prevent rainsnow and draining water from entering

Inspecting BatteriesInspecting BatteriesInspecting BatteriesInspecting BatteriesInspecting Batteries

Inspect batteries regularly for cracks or leaks SLABs stored outdoors havea greater possibility of cracking and leaking due to freezing and thawingand should be inspected more oftenPlace cracked or leaking batteries in an acid-resistant leakproof closedcontainer


All rights reserved

Used Lead-acid Batteries

Topic 2Neutralize small spills and leaks with lime cement or another causticContain the spill material and manage it as a hazardous waste

Recycling and Record KeepingRecycling and Record KeepingRecycling and Record KeepingRecycling and Record KeepingRecycling and Record Keeping

Recycle spent batteries by sending them to a reclaimer Batteries going to areclaimer may be picked up by a battery hauler (see Hazardous Waste factsheet 606 for a list of haulers and outlets) a battery supplier ortransported by the generator When transporting spent lead-acid batteriesyou do not need to use a hazardous waste manifest Persons whotransport or reclaim spent lead-acid batteries are subject to additional

requirements For moreinformation abouttransporting lead-acidbatteries request HazardousWaste fact sheet 408Transporting Spent Lead-AcidBatteries (SLABs)At least 75 percent of thebatteries you accumulateeach year must be sent to areclaimer If you do notrecycle at least 75 percent ofyour batteries each year youwill be subject to additionalstorage requirementsKeep records to documentthat you are recycling A

sample shipping log is included in Appendix H You may copy and usethis or design your ownOutside the Twin Cities Metro Area recycled SLABs do not need to bereported on hazardous waste license applications If batteries are youronly hazardous waste you do not need a hazardous waste generatorlicenseMany metropolitan counties require that SLABs be reported and alsorequire a hazardous waste generator license Check with your countyoffice

Retailers and TransportersRetailers and TransportersRetailers and TransportersRetailers and TransportersRetailers and Transporters

Retailers and transporters of lead-acid batteries have additionalrequirements These are outlined on Hazardous Waste fact sheets 407(Retailers) and 408 (Transporters)

Table 12 Battery Storage HintsTable 12 Battery Storage HintsTable 12 Battery Storage HintsTable 12 Battery Storage HintsTable 12 Battery Storage Hints

bull A number of containers are made specifically to store batteriesCapacity varies from a few batteries up to about 75 batteries Checkwith your supplier for more information

bull If storing batteries indoors on asphalt or concrete coat the surfacewith a good acid-resistant epoxy fiberglass or plastic coating or linethe area with heavy polyethylene If using a poly liner check itregularly for cracks or tears

bull Sealed five-gallon plastic (polyethylene) pails are adequate forstoring a leaking or cracked battery

bull Store batteries upright to prevent leaking from the vent holesbull Stack batteries no more than five high mdash less if the stack becomes

unstable You may wish to place wood or some other type of dividerbetween the batteries to prevent the terminal posts from puncturingthe battery stored above


Topic 3Reducing Waste

Avoiding the creation of hazardous waste is an important national goalFor any size business reducing waste is important for conserving ournationrsquos resources and for protecting our environment Federal hazardouswaste regulations require Large Quantity Generators to certify they aremaking a concerted effort to reduce the amount of waste they generate InMinnesota all companies required to report toxic chemical releases underthe Community Right to Know Act (SARA 313) are also required todevelop a Toxic Pollution Prevention Plan (Information about developingthese plans can be obtained from the Minnesota Office of EnvironmentalAssistance (MOEA) and the Minnesota Technical Assistance Program(MnTAP))But whether or not you are required by law to implement waste reductionprocedures reducing waste can benefit your business Many companiesthat have established waste-reduction practices have benefited by savingmoney both in purchasing costs and disposal fees by reducing paperworkand record keeping requirements and even by reducing employee exposureand the liability associated with it Reducing waste is not only good for theenvironment itrsquos also good for your businessrsquos bottom lineIn-plant waste reduction can only be accomplished if there is acommitment by the whole organization All staff mdash from uppermanagement to the plant worker mdash should be educated in waste reductiontechniques and encouraged to look for ways to reduce waste Incentivessuch as bonuses or awards may foster waste reduction ideas andencourage use of those having practical application

First StepsFirst StepsFirst StepsFirst StepsFirst Steps

The first step to reduce or eliminate waste is to identify all types of wastegenerated and determine which processes create the waste (See your listfrom Step 1) After each waste is identified evaluate how each might beminimized or eliminated by making one or more of these changes

1 Improve housekeeping Sloppy housekeeping can result in morewaste being generated than is necessary To reduce waste

bull Buy only the amount of raw material you need Althoughbuying in quantity may appear to save money initially itoften results in excess material which is costly to dispose of

bull Use raw materials in correct proportions so excess waste isnot generated from defective products or formulations

bull Make sure equipment is working properly Check for faultyvalves connections and pipes to ensure that product is notbeing lost or unintentionally contaminated

bull Inventory clearly label and properly store product andwaste Inadequate labeling may make it hard to identify


All rights reserved

Reducing Waste

Topic 3wastes later and necessitate expensive testing prior todisposal Proper labeling and storage also helps to preventaccidental contamination of materials or nonhazardouswaste requiring more costly disposal

2 Substitute materials By substituting non- or less-hazardous forhazardous materials (ie water for solvent) you may be able toeliminate or significantly reduce some hazardous waste streamsThe demand for nonhazardous products is increasing and asnew markets develop more nonhazardous alternatives arebecoming available

3 Redesign modernize processes Replacing existing machineswith more efficient equipment can significantly reduce wasteincluding energy For example in the coating industryreplacing conventional airatomized spray paint equipment (30-60 percent transfer efficiency) with electrostatic equipment (65-80 percent efficiency) or powder coating equipment (90-99percent efficiency) results in substantial waste reduction Evensomething as simple for a small business as retrofitting withmore energy efficient fluorescent lamp fixtures can make a bigdifference

4 Reuse recycle Closer review of the way wastes are handled cansometimes reveal opportunities for reuse or recycling Forexample waste solvent from one operation may be cleanenough to be used in a different application Keeping wastestreams separate can make it easier to reuse materials in otherprocesses or reclaim materials from a waste

Small distillation units may be used on site to reclaim solventsOther wastes may replace virgin materials in a process or bereclaimed off site Material exchange programs help linkcompanies that have unneeded materials with those needing orable to use those materials

For More HelpFor More HelpFor More HelpFor More HelpFor More Help

Your metropolitan county or MPCA hazardous waste inspector may beable to suggest some waste-reduction ideas appropriate for your facility ortell you what others in your industry are doing In addition the MinnesotaTechnical Assistance Program (MnTAP) and the Office of EnvironmentalAssistance (OEA) provide services and programs in waste-reductionassistanceMnTAP helps industry identify ways to reduce hazardous andnonhazardous industrial waste by

bull Conducting on-site visits

bull Employing student interns dedicated to specific waste reductionprojects



bull Providing information and success story examples about processequipment materials exchanges product substitutions options forprocess changes etc (see httpwwwmntapumnedu)

bull Holding presentations and seminars (general or industry specific) and

bull Offering technical assistance to help develop or improve wastereduction technologies

The OEA offers loans for recently available market-ready P2 technologies(11 match required) To find out more see the OEA Web site athttpwwwmoeastatemnusgrantscurrentcfmloanThe MPCA also has a Small Business Environmental Improvement LoanProgram that provides low-interest loans to small businesses to financeenvironmental projects such as capital equipment upgrades that meet orexceed environmental regulations and costs associated with theinvestigation and cleanup of hazardous materials To qualify a borrowermust

bull be an existing small business corporation sole proprietorshippartnership or association

bull have less than 50 full-time employees

bull have an after-tax profit of less than $500000

bull have a net worth of less than $1000000 and

bull demonstrate an ability to repay the loan

The loan amount will not be for less than $1000 nor more than $50000with an interest rate of four percent or one-half the prime rate whicheveris greater at the time the loan is awarded The loan must be repaid withinseven years collateral is required When the project is completedborrowers are asked to complete an evaluation of the projectrsquos realizedenvironmental and economic benefitsFor more information see the MPCA Web site athttpwwwpcastatemnusprogramssbomb_loanhtmlAnother program that can help businesses reduce waste is MinnesotaWaste Wise Minnesota Waste Wise is a member-supported privatenonprofit 501(c)3 corporation affiliated with the Minnesota Chamber ofCommerce Its mission is to help businesses and organizations reducewaste by offering technical and informational services to members to helpthem effectively manage their solid waste challenges There is a cost formembership For more information visit the Minnesota Waste Wise Website at httpwwwmnwastewiseorg or call themTelephone numbers for these programs are listed on the inside of the backcover


All rights reserved

Parts Washers

Topic 4Keep F-Listed Solvents Out of the Parts WasherKeep F-Listed Solvents Out of the Parts WasherKeep F-Listed Solvents Out of the Parts WasherKeep F-Listed Solvents Out of the Parts WasherKeep F-Listed Solvents Out of the Parts Washer

Parts washer solutions typically consist of petroleum-based solvents(mineral spirits Stoddard petroleum naphtha etc) organic solvents(which often contain terpenes or d-limonene) or water-based cleaners withsurfactants and degreasers When the clean solution is hazardous it isusually because the flash point is below 140o F (check your Material SafetyData Sheet to find this information) Contamination during the cleaningprocess can cause a non-hazardous product to become hazardous wasteWhen this happens the waste is generally characteristically hazardous forthe contaminantBut inspectors are seeing a different type of hazardous parts washerwaste solutions that have been contaminated with an F-listed solventThis type of contamination often happens because employees use aerosolsprays that contain F-listed solvents ndash such as methylene chloride (alsocalled methylene dichloride or dichloromethane) toluene (toluol) ormethyl ethyl ketone (MEK) or another solvent listed on the ldquoF listrdquo in thehazardous waste regulations Residual or overspray is allowed to drip intothe parts washer or sprayed parts are placed in the washer basin while thechemical works Sometimes contamination is caused by F-listed solventssuch as lacquer thinner being dumped into the washer basinWhen this happens the whole solution becomes an F-listed hazardouswaste Very Small Quantity Generators cannot mix parts washer solutioncontaining F-listed solvents with their used oil because the oil will alsobecome a listed hazardous waste and an oil hauler can no longer take itOften the parts washer waste can no longer be recycled and reused or inthe case of some water-based solutions be discharged to a sanitary sewerbut must be incinerated at a hazardous waste facility at a higher cost toyou the generator Disposal of water-based solutions as a hazardouswaste is very expensive because incineration (burning) is hard to do for asolution that is mostly waterPrevention is the best solution First make sure the type of washer solventor solution you choose works well for your application Then eliminateuse of aerosols containing an F-listed solvent if possible If you cannoteliminate them be sure you use them only when needed and in such away that overspray and residual solvent does not come in contact withyour parts washer solutionFor more information see these fact sheets available on MPCArsquos Web sitehttpwwwpcastatemnuswastepubsbusinesshtmlspecific

bull Managing Solvent-Based Parts Washers 443

bull Managing Aqueous Parts Washers 444


What Is ldquoUsed OilrdquoWhat Is ldquoUsed OilrdquoWhat Is ldquoUsed OilrdquoWhat Is ldquoUsed OilrdquoWhat Is ldquoUsed Oilrdquo

Used oil includes petroleum or synthetic oil used as a lubricant heattransfer fluid hydraulic fluid or any similar uses Some examples are

bull engine oil

bull transmission fluid

bull lubricating oil

bull hydraulic oil

bull gear oilNOTE Antifreeze fuel oil and solvents are not used oil

What are What are What are What are What are ldquoldquoldquoldquoldquoUsed Oil-Related WastesUsed Oil-Related WastesUsed Oil-Related WastesUsed Oil-Related WastesUsed Oil-Related Wastesrdquordquordquordquordquo

Used oil filters and materials used to soak up oil (sorbents) are commonused oil-related wastesUsed oil filters have a metal exterior and paper packed bed wound orsimilar interiors that are used in vehicles or machines to filter lubricatingoilExamples of sorbents often used to clean up used oil include

bull polypropylene or otherplastic resin pads tubessheets or granules

bull peat

bull corn cobs

bull cellulose fiber

bull sawdust

bull wood chips

bull paper wipes

Environmental ConcernsEnvironmental ConcernsEnvironmental ConcernsEnvironmental ConcernsEnvironmental Concerns

Used oil filters and used oil-contaminated sorbent materials often containhazardous contaminants such as flammable fuels and their additives leadand other toxic metals Used oil that is disposed of improperly can killvegetation and wildlife and pollute surface water and ground water Forthis reason it is illegal to

bull pour used oil on the ground

bull pour used oil down a drain or sewer

bull transformer fluid

bull cutting oil

bull tempering or quenching oils

bull grease

bull brake fluid

bull cloth towels or other reusablematerials

bull rice and cotton-seed hulls

bull granular clay

bull diatomaceous earth

bull amorphous silica

bull cork

bull pumice

Topic 5Used Oil


All rights reserved

Used Oil

Topic 5 bull put used oil in the trash or

bull apply used oil to roads for dust suppression(Minn R 70450845)

Waste PreventionWaste PreventionWaste PreventionWaste PreventionWaste Prevention

To decrease the amount of used oil generated encourage and practicealternative transportation such as carpooling busing biking or walkingHere are ways to decrease used oil-related wastes

bull Use drain systems designed for used oil

bull Use drip pans to capture used oil drips and spills

bull Pick up used-oil spills in liquid form by using a dustpan andsqueegee (rather than using sorbents and generating anotherwaste)

bull If sorbents must be used choose those that can be recycled thatis wrung and reused laundered or cleaned or burned forenergy

bull When possible purchase product in bulk to eliminate multiplesmall plastic containers

bull If using oil in plastic quart containers design a drain system toempty them sufficiently to allow the plastic to be recycled

Containment Storage and LabelingContainment Storage and LabelingContainment Storage and LabelingContainment Storage and LabelingContainment Storage and Labeling

Before storing filters drain them well or process them to remove all free-flowing oil Processing includes crushing or dismantling the filters toseparate the metal from the paper portion (Before crushing check withthe filter hauler you intend to use to make sure crushed filters will beaccepted) Place collected oil in the used oil-storage container destined forrecyclingBefore storing sorbents remove all free liquid Place collected oil in theused oil-storage container destined for recyclingStore used oil used-oil filters paper removed from used-oil filters and usedoil-contaminated sorbents in closed leak-proof tanks or containers(Containers receiving used oil directly from filter crushing equipment oroil-water separation equipment may have an opening sufficient to receivethat oil) Paper filter media and combustible sorbents may be combined inthe same container provided they will be disposed of in the same wayMark containers (including used-oil tanks and tank fill pipes) toappropriately identify the contents Used Oil [Filters Filter-Paper Media orSorbents] Do not mark containers of used oil destined for recycling withthe words ldquoHazardous Wasterdquo


Topic 5Used Oil

Place containers on a surface that is reasonably impervious to used oil(Minn R 70450855 subp 2) Asphalt that is in good condition may qualifyas ldquoreasonably imperviousrdquo for awhile however oil will break down theasphalt allowing the oil to filter through If solvents fuels or gasoline arepresent in the used oil the rate of breakdown increases Sealing an asphaltand concrete surface or using a secondary containment system designedfor used oil provides better protection and may reduce the possibility ofreleases and their related liability

TIP When possible store used-oil containers indoors to preventreleases caused by rain seeping into closed containers anddisplacing the oil

Storing Used Oil in TanksStoring Used Oil in TanksStoring Used Oil in TanksStoring Used Oil in TanksStoring Used Oil in Tanks

All tanks (including fill pipes) must be labeled as outlined above If usingabove-ground storage tanks (ASTs) with a capacity of 500 gallons or moreor underground storage tanks (USTs) larger than 110 gallons to store usedoil they must be registered with the MPCA A tank facility that does nothave a person on site 24 hours a day must have a sign with the nameaddress and telephone number of the facility owner operator or localemergency response The sign must be posted in a conspicuous place andbe legible from outside any secondary containment area For additionalrequirements refer to Table 1For more information call the Customer Assistance Center or access theMPCA Web site at httpwwwpcastatemnus At the site click onPrograms then Above-ground Storage Tank Systems or Storage TankCompliance and Assistance Program for more informationThe Minnesota Uniform Fire Code (MUFC) Article 79 and Article 80contain provisions relating to the storage and containment of combustibleliquids Contact your local fire marshal for requirements specific to youroperation

MixingMixingMixingMixingMixing

Do not mix antifreeze chlorinated solvents (such as many carburetor orbrake cleaners) gasoline engine degreasers paint thinners or anythingelse with used oil Used oil that has other waste mixed with it must beevaluated (tested) The mixture may be a hazardous waste

TIP To prevent inadvertent mixing and the increased disposalcosts that often result separate used-oil containers from solventand other waste containers in your storage area Mark thecontainers

One exception regarding mixing mdash Very Small Quantity Generators(those producing less than 220 pounds mdash about 22 gallons liquid mdash of


All rights reserved

Used Oil

Topic 5hazardous waste per month) may mix petroleum-based parts washerwaste that is hazardous only because it is ignitable with their used oil andmanage the mixture as used oil provided

bull the solvent does not contain metal-bearing paint

bull the solvent is not an F-listed hazardous waste or contaminatedwith an F-listed waste (many carburetor and brake cleaners areF-listed)

bull the solvent is not gasoline

bull the solvent does not exceed 10 percent of the total volume of thefinal mixture and

bull the flash point of the solvent is above 100o Fahrenheit(Minn R 70450800 subp 4(C))

Recycling Disposal OptionsRecycling Disposal OptionsRecycling Disposal OptionsRecycling Disposal OptionsRecycling Disposal Options

Used oil is prohibited from land disposal by state law Recycling optionsinclude

bull re-refining and

bull burning for energy on or off siteUsed oil filters and the paper media if separated are prohibited fromland disposal they must be recycled Recycling means sending thecomplete filter to a scrap metal-recycling facility If the paper media hasbeen removed from the filter it should be sent to a burner that is permittedto accept filter media or managed as a hazardous waste Contact theburner to which you intend to send waste for additional requirementsUsed oil-contaminated sorbents are prohibited from land disposal unlessthey have been tested and shown to be nonhazardous There is no need totest oil-contaminated sorbents if they are

bull wrung and reused

bull laundered or cleaned (sorbents sent to a commercial laundrycannot contain free liquids) or

bull burned for energy (sorbents destined for burning must have aheating value of at least 5000 BTUs per pound)

Used oil-contaminated sorbents that have been shown to be nonhazardouscan be burned at a facility that does not burn for energy recovery Disposalat a landfill is not recommended


Topic 5Used Oil

Table 1 Tank Requirements for Storing Used OilTable 1 Tank Requirements for Storing Used OilTable 1 Tank Requirements for Storing Used OilTable 1 Tank Requirements for Storing Used OilTable 1 Tank Requirements for Storing Used Oil

Above ground andIndoors andSituated on an impermeable surfaceAbove ground andOutdoors andHolds 1100 gallons or less andIs more than 500 feet from surface water

Above ground andOutdoors andHolds more than 500 gallons but 1100 gallons or lessandIs within 500 feet of surface water

These tanks are exempt from tank rules providedcontents of the tank are contained indoors (ie cannotescape through walls doors floor drains etc)The tank is exempt from regulations The MPCAstrongly recommends using the regulations outlinedbelow as best management guidelines

The tank must

1 be registered2 have secondary containment for capacity of

largest AST in containment area and if exposedto precipitation have an additional 10 percentcontainment and

3 be marked with the words ldquoUsed Oilrdquo (includinglines and fill pipes)

Follow all requirements above plus the tank must

4 have corrosion protection5 have overfill protection6 have substance-transfer area safeguards and7 have immediate leak-detection and monitoring

If your used oil tank is Then

These tanks are not regulated The MPCA stronglyrecommends using the regulations below as bestmanagement guidelines

Above ground andOutdoors andHolds more than 1100 gallons

Underground andHolds 110 gallons or less orIs a UST of 1100 gallon or less capacity used on site tostore heating oil or residential or farm motor fuel fornoncommercial use

Underground andHolds more than 110 gallons

TIP To simplify leak-detectionrequirements for the piping onunderground storage tanks use a1000-gallon or smaller tank forcollecting used oil

The tank must

1 be registered2 have corrosion protection3 have leak detection4 have spill and overfill protection unless it

receives less than 25 gallons at a time and5 have fill pipes marked ldquoUsed Oilrdquo

The tank owner must6 use certified contractors to install upgrade or

remove the tank7 notify the MPCA 10 days before any actions

outlined in 6 and8 notify the MPCA within 30 days of completion of

actions (6)


All rights reserved

Used Oil

Topic 5 Burning for EnergyBurning for EnergyBurning for EnergyBurning for EnergyBurning for Energy

Currently most used oil collected in Minnesota is shipped to asphalt plantsto be burned for energy recovery Businesses also have the option ofburning used oil and sorbents on site for heat provided

bull the used oil is generated on site brought in by the general public(do-it-yourselfers) or by farmers generating less than 25 gallonsper month on average or from another location owned oroperated by the same business (You may accept used oil fromother businesses only if it has been tested at least once persource and shown to be on-specification ldquoOn-specificationrdquomeans the used oil meets the conditions listed in Table 2 Theparty claiming the used oil is on-specification is called a ldquoused-oil marketerrdquo and has additional requirements For moreinformation see MPCA Hazardous Waste fact sheet 434Marketing Used Oil)

bull the unit burns for energy recovery

bull the used oil and sorbents are burned in a furnace designed forthat purpose and the furnace is rated at less than500000 BTUs per hour and is vented to the outdoorsIf you burn used oil on site contact local building codepersonnel to determine requirements for installation anduse of the burner Contact your local fire department todetermine whether there are additional localrequirementsThe Minnesota Uniform Fire Code (MUFC) UniformMechanical Code (UMC) and State Statute 299F015contain provisions relating to used-oil burners Contactyour local fire marshal for requirements specific to youroperation

SpillsSpillsSpillsSpillsSpills

When developing guidelines for managing oil start at the beginning mdashavoid spills Here are some tips

bull Develop and practice proper handling procedures and carefulwork habits

bull Use appropriate tools such as funnels and spigots

bull Perform regular preventive maintenance such as tightening orreplacing leaky seals gaskets and dispensers

Next be prepared Keep spill-containment and clean-up materials in aconvenient nearby area Train employees when and how to use them Forhelp preparing for spills contact the MPCA Emergency Response Team

Table 2 Conditions for On-specification Used Oil

Item Condition Flash point 100o Fahrenheit minimum

Arsenic 50 ppm maximum

Cadmium 20 ppm maximum

Chromium 100 ppm maximum

Lead 1000 ppm maximum

Total Halogens

10000 ppm maximum

parts per million A level of halogens up to 4000 ppm is allowed if it can be proven that hazardous waste has not been mixed with the used oil


Topic 5Used Oil

Some shops have oil-water separators on the drain connected to the sewerto collect small drips spills and grit To ensure oil does not enter thesanitary sewer service the separator regularly skim off the oil and place itin the used-oil container and remove and evaluate the collected grit Howoften this must be done depends upon how much oil and grit is allowed toenter the drain and the size of your grit chamberContain and clean up liquid spills on impermeable surfaces by usingsqueegees and dustpans mops or vacuums designed for liquids Combineand recycle with other liquid used oil If sorbents are required usesparingly and only after you recover all the liquid oil that you canControl spills on land by using soil sand sorbent socks or granules tobuild a barrier to contain flowing oil Recover liquid oil using appropriatepumps or vacuum trucks (you may need a contractor to assist you) andplace it in a container for recycling Contaminated soil sand and claysorbent must be excavated or recovered and treated at a permitted facilityIf the quantity is less than 10 yards and if approved by the MPCAEmergency Response Team treatment on site may be an optionReport all used oil or other petroleum spills of five gallons or more to theMinnesota Duty Officer at the 24-hour emergency number given on theinside of the back cover For additional information about reporting spillssee MPCA Emergency Response Fact Sheets Reporting Spills and Leaks andReporting Hazardous Material Spills available on the Web athttpwwwpcastatemnuscleanuppubsertpubshtmlRegardless of amount if your spill enters a sewer ditch or surfacewaterway of any kind report the spill to the National Response CenterFor more information about spill prevention and cleanup requirements seethe following MPCA Emergency Response fact sheets and others availableon the MPCA Web site athttpwwwpcastatemnuscleanuppubsertpubshtml

bull Prevention and Preparedness for Oil Delivery Companies

bull Spill Prevention and Planning

bull Minnesota Spill Bill

bull Small Petroleum Spill Cleanup

bull Spill Debris Disposal Options

bull Thin Spreading Small Quantities of Petroleum Contaminated Soils

Shipping Requirements Shipping Requirements Shipping Requirements Shipping Requirements Shipping Requirements (Minn R 70450855 subp4)

Used oil generators may transport up to 55 gallons of used oil or sorbentsin their own vehicle or any amount of used-oil filters without being subject


All rights reserved

Used Oil

Topic 5to the used oilfilter transporter requirements If hauling your own oilwastes you must

bull Take the oil filters and sorbents to a collection site or to anaggregation point owned by the generator

bull Ensure that filters and sorbents do not contain free-flowing oiland

bull Ensure that used oil does not leak during transportIf not hauled by the generator used oil must be hauled by an oil haulerhaving an US Environmental Protection Agency (EPA) identificationnumber Used oil filters must be hauled by an oil-filter hauler that has alicense from the MPCA or a metropolitan county MPCA HazardousWaste fact sheet 600 Used Oil Hauler Services includes a list of oil serviceprovidersNOTE Neither a hazardous-waste manifest nor a hazardous-wastetransporter is required when transporting used oil destined for recycling(However both must be used for oil that is too contaminated to be recycledand requires disposal as a hazardous waste)

RecordsRecordsRecordsRecordsRecords

Generators must keep records at their businesses of all shipments of usedoil used-oil filters and sorbents Used oil and used oil-filter haulers arerequired to give receipts whenever they pick up oil or filters generatorsmay use these receipts as their records or they may use a log sheetRecords for used oil used-oil filters and used-oil contaminated sorbentsshould include

bull the date of the shipment

bull the amount shipped (gallons of used oil weight number orvolume of filters and sorbents)

bull the name and identification number of the transporter (ifapplicable) and

bull where the waste was takenVery Small Quantity Generators who mix parts washer solvent with usedoil must also

bull keep records of the amount of solvent mixed

bull report it annually and

bull if generating more than 10 gallons of hazardous waste per yearobtain a Hazardous Waste Generatorrsquos License (Somemetropolitan counties require businesses generating less than 10gallons per year to get a license)


Topic 5Used Oil

ReportingReportingReportingReportingReporting

Businesses located outside the Twin Cities Metro Area that generate andrecycle only used oil used-oil filters andor used oil-contaminated sorbentsare not required to report annually or to obtain a license from the MPCAbut they must still manage the waste as outlined in this manualBusinesses located within the Twin Cities Metro Area may still havereporting and licensing requirements Contact your county hazardouswaste office for details (phone numbers are on the inside of the backcover)

Retiring Equipment Closing or Selling Your BusinessRetiring Equipment Closing or Selling Your BusinessRetiring Equipment Closing or Selling Your BusinessRetiring Equipment Closing or Selling Your BusinessRetiring Equipment Closing or Selling Your Business

When taking equipment out of service or when ceasing operationsgenerators must either remove or clean up used oil-storage equipment andany site contamination

For More InformationFor More InformationFor More InformationFor More InformationFor More Information

Oil rules are available on the Web athttpwwwrevisorlegstatemnusarule7045See particularlyhttpwwwrevisorlegstatemnusarule70450845html andhttpwwwrevisorlegstatemnusarule70450855html )Oil filter rules are available on the Web athttpwwwrevisorlegstatemnusarule70450990htmlYou metropolitan county and the Minnesota Pollution Control Agencyhave staff available to answer oil-management questions For generalinformation contact your metropolitan county hazardous waste office orthe MPCA office closest to your county See telephone numbers on theinside of the back cover


All rights reserved

Electronic Waste

Topic 6 As the number of products with electronic components continues to growthe resulting increase in electronic waste poses a management challengefor waste managers Electronic waste or ldquoe-wasterdquo includes those wastesthat have a circuit board or a cathode ray tube (CRT) Both contain leadthat can cause them to fail the Toxicity Characteristic Leaching Procedure(TCLP) for hazardous waste Other metals may also be present at levelsthat fail the TCLP Examples of e-waste include computer monitors andcomponents televisions photocopiers facsimile machines video monitorsand equipment telephones and telecommunications equipment cordlessrechargeable appliances and audio equipment

Waste EvaluationWaste EvaluationWaste EvaluationWaste EvaluationWaste Evaluation

As with any other waste the generator is required to evaluate to determinewhether their e-waste is hazardous Since both testing and gainingadequate knowledge of e-waste to allow satisfactory evaluation aredifficult the Minnesota Pollution Control Agency has approved alternatemanagement standards discussed below Provided these reducedhazardous waste management standards are met generators need notevaluate their e-waste

Storage Containment amp MarkingStorage Containment amp MarkingStorage Containment amp MarkingStorage Containment amp MarkingStorage Containment amp Marking

Disassembly of electronic devices can be a significant safety concern andcan release contaminants to the work area and the environmentBusinesses should not attempt to remove CRTs or mercury-containingcomponents from electronic devicesStore large intact electronic devices indoors in such a way that they areprotected from vandalism and inadvertent damage that may releaseharmful substances and limit recycling optionsStore small devices and electronic components such as printed wireboards and cathode ray tubes in a container that is able to contain thewaste at all timesIf stored outdoors place devices on an impermeable surface and coverthem to protect them from wind rain snow damage etcMark large items individually or collectively (eg shrink-wrapped pallet)and containers of small items with a short description mdash ldquoUsed ____ forRecyclingrdquo or ldquoWaste ____ for Recyclingrdquo mdashand the date it became awasteInspect containers regularly to make sure they are adequate and the wasteis contained Inspection documentation is recommended but not requiredBusinesses should not collect e-waste indefinitely but should ship thewaste within one year of generation


Topic 6Electronic Waste

Disposal amp Recycling OptionsDisposal amp Recycling OptionsDisposal amp Recycling OptionsDisposal amp Recycling OptionsDisposal amp Recycling Options

Do not dispose of e-waste of as solid waste either by landfilling orincineration This means you should not place electronic devices andcomponents in your solid waste (trash) You do have these options formanaging electronic equipment

1 Materials exchange The Minnesota Technical Assistance Programprovides a medium for the exchange of materials that are no longeruseable by one party but can be used by another

2 ReconditioningRefurbishingResale Programs These kinds ofprograms apply mostly to equipment that has resale value mdash such ascomputers If using this type of service ask what is being done withequipment that cannot be reconditioned refurbished or resold Alsoinquire about how unusable components are managed

3 Recycling Recyclers disassemble equipment salvage parts and sendunused materials to final processors If using this kind of service askwhat percentage of the equipment is being recycled and what is beingdone with the unusable materials

4 DealerManufacturer Take Back Some dealers or manufacturers willtake back the old equipment when you purchase new

Note Some electronics-management services ship electronic devices andcomponents overseas The MPCA cautions generators to make sure theyare aware of the final disposition of their waste electronic devices in orderto limit their ldquocradle-to-graverdquo responsibilities for these wastes (under theState Superfund Law generators are liable for their waste if it ismismanaged after it leaves their control)Businesses always have the option of disposing of e-waste under the morestringent hazardous waste rules by shipping it to a hazardous wastedisposal facility A disadvantage to this disposal method is that theequipment is destroyed preventing opportunities for recycling or reuse

Shipping RequirementsShipping RequirementsShipping RequirementsShipping RequirementsShipping Requirements

If you are transporting within Minnesota you may transport wasteelectronics in your business vehicle as long as the load is secure and youfollow any applicable Department of Transportation (DOT) HazardousMaterials shipping requirements (Contact the receiving site to find outwhether they have additional requirements) The waste must beaccompanied by a waste-tracking invoice containing

bull the name and address of your business

bull a contact person at your business


All rights reserved

Electronic Waste

Topic 6bull the name and address of the facility to which you are shipping

bull the date the shipment is initiated

bull a description of the waste and

bull the quantity or amount of waste shipped

If you are shipping to a recycler out of state you may use a shipping paperprovided the waste does not pass through a state requiring a manifestIf you are shipping to a hazardous waste disposal facility or if the wastewill pass through a state requiring a manifest you must use a hazardouswaste manifest and a licensed hazardous waste transporter

Required PaperworkRequired PaperworkRequired PaperworkRequired PaperworkRequired Paperwork

Keep copies of documents showing the disposition of the waste for at leastthree years If you perform a waste evaluation keep documentation for atleast three yearsE-waste generators in the Twin Cities Metro Area should contact theircounty to find out its reporting and licensing requirementsE-waste generators in Greater Minnesota who follow these specialrequirements need not report their e-waste to the Minnesota PollutionControl Agency If this is the only waste they generate they do not needto get an EPA ID number or hazardous waste generator license

E-waste AlertE-waste AlertE-waste AlertE-waste AlertE-waste Alert

E-waste regulations are likely to change in the future Watch forregulatory changes at both state and federal levels


Topic 7Universal Waste

What are universal wastesWhat are universal wastesWhat are universal wastesWhat are universal wastesWhat are universal wastes

Universal Wastes (UW) are a special category of hazardous wastes that canbe managed through a simplified process that minimizes paper work andencourages proper management They are called ldquouniversalrdquo waste becausethey are generated from a wide range of sources almost every businessgenerates them at some point UW include

bull lamps (fluorescent and high intensity discharge lamps)

bull batteries (dry cell button and lead-acid)

bull pesticides and

bull mercury-containing devices (thermostats thermomometers barometers)

UW regulations are optional A generator may always opt to managehazardous waste lamps batteries etc as fully-regulated hazardous wasteHowever for most generators the UW rules are a more convenient way tosafely manage these particular waste streams

What are the rulesWhat are the rulesWhat are the rulesWhat are the rulesWhat are the rules

Minnesotarsquos UW rules are essentially the same as the federal UW regulationsThe only differences are

bull Minnesotarsquos UW rules can apply to very small quantity generators ofhazardous waste (who would be exempted under the federalregulations)

bull Because Minnesota has an additional hazardous waste characteristic(Lethality) some wastes such as batteries may be hazardous inMinnesota that are not federally hazardous Wastes that are hazardousdue to the lethality characteristic may still be managed as UW

bull The Minnesota rules require financial assurance for certain handlers ofmore than 1000 fluorescent lamps

The federal UW requirements can be found in the Code of FederalRegulations title 40 part 273 For a summary of the regulations and answersto frequently asked questions see httpwwwepagovepaoswerhazwasteidunivwasthtm The state UW rules can be found at Mn Rulespt 70451400The UW rules are divided into requirements for Small Quantity Handlers(SQH) Large Quantity Handlers (LQH) Transporters and DestinationFacilities The UW rules differ from the hazardous waste rules in that theydo not distinguish between a ldquogeneratorrdquo and a ldquocollectorrdquo of UW A personwho handles UW whether the original generator or some intermediatecollection stage such as a hardware store is a ldquohandlerrdquo and subject to thehandler requirements


All rights reserved

Universal Waste

Topic 7Requirements for HandlersRequirements for HandlersRequirements for HandlersRequirements for HandlersRequirements for HandlersGenerators who do the following are not required to meet the rest of the hazardouswaste rules for the UW they handle

bull keep wastes in closed containers that will not leak

bull mark the containers to identify the contents (eg ldquoUniversal WasteLampsrdquo)

bull treat or dispose of the waste within one year

bull keep records to verify that they have not exceeded the one-yearaccumulation limit

bull clean up spills if they occur

bull provide adequate training to employees who handle the waste and

bull treat or dispose of universal waste at an approved facility

A generator does not need to obtain a license report the amount of UWgenerated pay fees for UW or use a hazardous waste manifest to transportUW wasteIn addition to the above requirements that apply to all handlers LQHsmust also

bull obtain an EPA identification number

bull provide training about the handling of UW to all their employees and

bull maintain records of waste shipments for three years

No generator is allowed to treat store or dispose of their UW on-sitethough the rules allow certain types of activities to disassemble or reducevolume of the waste being managed (eg removing batteries fromappliances)

Requirements for Transporters

Because universal waste is not required to meet manifest requirements itmay be transported without meeting requirements for hazardous wastetransporters (although all other transportation-related requirements stillapply) An SQH or an LQH may transport UW in their own vehicles ormay hire a transporter A transporter may not store UW for more than tendays and must be able to respond to spills

Requirements for Destination FacilitiesUW may only be recycled or disposed at a facility that is allowed to manage thewaste (eg a lamp recycler that has a compliance agreement with the MPCA amercury recovery facility or a permitted hazardous waste landfill)


A MSDS Sample 82B Lab Results Sample 84C Managing Empty Containers 85D Documenting Container Inspections 87E LDR Policy Statute 90F SQG Emergency Planning Packet 92-96G Employee Training Docmentation 97H Lead Acid Battery Shipping Log99

Appendices


All rights reserved

Appendix A MSDS

US DEPARTMENT OF LABOR Occupational Safety and Health Administration

MATERIAL SAFETY DATA SHEET Required under USDL Safety and Health Regulations for Ship Repairing

Shipbuilding and Shipbreaking (29 DFR 1915 1916 1917)

SECTION I

MANUFACTURERrsquoS NAME Big Manufacturing Corp EMERGENCY TELEPHONE NO (000) 123-3456 ADDRESS 234 Little Rock Road Mytown Minnesota 55000 CHEMICAL NAME AND SYNONYMS Mineral Spirits TRADE NAME AND SYNONYMS Get-it-Clean Solvent CHEMICAL FAMILY Petroleum Hydrocarbon Family FORMULA BMC Solvent 299

SECTION II ndash HAZARDOUS INGREDIENTS PAINTS PRESERVATIVES SOLVENTS TLV ALLOYS AND METALLIC COATINGS TLV

PIGMENTS BASE METAL

CATALYST ALLOYS

VEHICLE METALLIC COATINGS

SOLVENTS 999+ 100 100 FILLER METAL PLUS COATING OR CORE FLUX

ADDITIVES Dye 0003 100 OTHERS OTHERS Antistatic additive 1 ppm HAZARDOUS MIXTURES OF OTHER LIQUIDS SOLIDS OR GASES TLV

SECTION III ndash PHYSICAL DATA BOILING POINT (0oF) 310 ndash 400oF SPECIFIC GRAVITY (H2O = 1) 0775 ndash 0797

VAPOR PRESSURE 2 mm Hg 68oF PERCENT VOLATILE BY VOLUME 100

VAPOR DENSITY 49 EVAPORATION RATE (TOLUENE =1) 002 SOLUBILITY IN WATER Negligible AROMATICS (TOTAL) Less than 16 APPEARANCE AND ODOR Green clear

SECTION IV ndash FIRE AND EXPLOSION HAZARD DATA FLASH POINT(METHOD USED) 105oF TCC FLAMMABLE LIMITS

EXTINGUISHING MEDIA CO2 foam dry chemical water (mist only) SPECIAL FIRE FIGHTING PROCEDURES None

UNUSUAL FIRE AND EXPLOSION HAZARDS None


SECTION V ndash HEALTH HAZARD DATA THRESHOLD LIMIT VALUE 100 ppm

EFFECTS OF OVEREXPOSURE Severe eye irritation drying of skin excessive inhalation causes headaches dizziness and nausea Harmful or fatal if swallowed EMERGENCY AND FIRST AID PROCEDURES EYE CONTACT flush with water SKIN CONTACT wash with mild soapwater apply skin cream INHALATION remove to fresh air and call a physician Apply artificial respiration if necessary in extremes ORAL administer plain water DO NOT INDUCE VOMITING Call a physician

SECTION VI ndash REACTIVITY DATA

STABILITY UNSTABLE STABLE X

CONDITIONS TO AVOID Heat sparks open flame and fire

INCOMPATIBILTY (Materials to avoid) Strong oxidizing agents HAZARDOUS DECOMPOTITION PRODUCTS Normally none however incomplete burning may yield carbon monoxide

HAZARDOUS POLYMERIZATION MAY OCCUR WILL NOT OCCUR X

CONDITIONS TO AVOID

SECTION VII ndash SPILL OR LEAK PROCEDURES

STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED Catch and collect for recovery as soon as possible Avoid exposure to sparks fire or hot metal surfaces WASTE DISPOSAL METHOD Dispose of in accordance with company or local state or federal regulations Incinerate under safe conditions

SECTION VIII ndash SPECIAL PROTECTION INFORMATION RESPIRATORY PROTECTION (Specify type) Self-contained breathing apparatus for concentrations above TLV limits

LOCAL EXHAUST SPECIAL VENTILATION CO2 foam dry chemical water (mist only) MECHANICAL (General) OTHER

PROTECTIVE GLOVES In case of prolonged contact use protective gloves or barrier cream

EYE PROTECTION Yes Normal precautions

OTHER PROTECTIVE EQUIPMENT None

SECTION IX ndash SPECIAL PRECAUTIONS PRECAUTIONS TO BE TAKEIN IN HANDLING AND STORING Combustible Keep away from heat sparks and open flame Use adequate ventilation Avoid long and repeated contact with skin If clothes are inadvertently saturated with solvent DO NOT SMOKE ndash keep away from ignition source Keep out of reach of children

Appendix A MSDS


All rights reserved

Mr ScienceEnvironmental Testing Service

Date 12 October 2005Page 2

SAMPLE IDENTIFICATIONPaint filter

SAMPLE NUMBER 480

ANALYTICAL PROCEDURES

TC Toxicity Test The Toxicity Characteristic Leaching Procedure (TCLP) was performed according to EPA TestMethods for Evaluating Solid Wastes SW-1311

TABLE 1 TC Leach Test Results

SAMPLE IDENTIFICATION Paint filterSAMPLE NUMBER 480

Metal Result mgL Hazardous Waste Limit mgL

Lead 50 50

Cadmium 004 10

Chromium Total 404 50

Chromium Hexavalent 34 50

Materials which exceed this limit are classified as hazardous wastes

Appendix B Lab Results Sample



Just because a container is empty does not mean that it can be thrown inthe trash Some containers may have health and safety concerns because ofthe kinds of material they held This information will help you determinethe correct way to manage your empty containers


Before you buy new products think about how yoursquoll have to manage theempty containers Can you purchase the material in containers that can bereturned and refilled Can the empty containers be reconditioned andreused Can they be recycled Can you use them to store and ship thewaste Without purchasing more than you need can you buy the productin one large container rather than several small ones Making wisepurchasing choices up front can reduce the amount of waste you mustmanage Recycle empty containers whenever possible

Containers That Held Nonhazardous WasteContainers That Held Nonhazardous WasteContainers That Held Nonhazardous WasteContainers That Held Nonhazardous WasteContainers That Held Nonhazardous Waste

Containers that held nonhazardous waste are exempt from the hazardouswaste rules Reuse or recycle if possible If not manage them as anindustrial solid waste

Containers That Held Acute Hazardous WasteContainers That Held Acute Hazardous WasteContainers That Held Acute Hazardous WasteContainers That Held Acute Hazardous WasteContainers That Held Acute Hazardous Waste

Acute hazardous waste is waste that is

bull one of the following F-listed wastes F020 F021 F022 F023F026 or F027 or

bull a P-listed waste such as cyanide compounds or nitroglycerinEmpty containers that once held acute hazardous waste are exempt fromthe hazardous waste rules provided one of these three conditions has beenmet

1 the container or inner liner has been triple-rinsed using asolvent that is able to remove remaining residue or

2 the container or inner liner has been cleaned by another equallyeffective and approved method or

Appendix C Managing Empty Containers


All rights reserved

3 the inner liner that was in contact with the acute hazardousmaterial has been removed from the container

Triple-rinse means to flush the container three times each time using avolume of solvent equal to approximately 10 percent of the containerrsquoscapacity Collect the rinse material and use as product or manage it as ahazardous waste (Note the solvent may also be hazardous)Manage these inner liners as hazardous waste

Containers That Held PesticidesContainers That Held PesticidesContainers That Held PesticidesContainers That Held PesticidesContainers That Held Pesticides

Empty pesticide containers are subject to Minnesota Department ofAgriculture regulations Empty pesticide containers must be tripled-rinsed (see above) before disposal or salvage Some manufacturers havedesigned new containers that reduce waste such as dry pesticidecontainers designed to dissolve when the containers of pesticide are mixedwith water Check with your supplier to see what is available

Containers That Held Compressed GasContainers That Held Compressed GasContainers That Held Compressed GasContainers That Held Compressed GasContainers That Held Compressed Gas

Compressed-gas containers are considered empty when the pressure in thecontainer approaches atmospheric pressure Empty compressed-gascontainers are exempt from hazardous waste rules

Containers That Held Other Hazardous WasteContainers That Held Other Hazardous WasteContainers That Held Other Hazardous WasteContainers That Held Other Hazardous WasteContainers That Held Other Hazardous Waste

Hazardous waste containers (other than those that held acute hazardouswaste pesticide or compressed gas) are empty and exempt from thehazardous waste rules provided all waste that can be removed has beenremoved and one of these three conditions has been met

1 no more than one inch of residue remains on the bottom of thecontainer or liner or

2 no more than three percent material by weight remains inside acontainer or inner liner having a total capacity of 110 gallons orless or

3 no more than 03 percent material by weight remains inside acontainer or inner liner having a total capacity of over 110gallons



Making Inspections EasierMaking Inspections EasierMaking Inspections EasierMaking Inspections EasierMaking Inspections Easier

Minnesota Hazardous Waste rules require all generators of hazardous waste to inspectstorage containers and storage areas every week and to keep an inspection log Here aresome initial steps that will make inspections easier

bull Place the waste in a compatible container to prevent spills and leaks

bull Before moving a container to the storage area make sure the container isclosed marked properly and has the correct hazard labels affixed(flammable corrosive etc) If you use the yellow-and-red hazardous wastelabel used to satisfy Department of Transportation marking requirementscheck to see whether it is filled out completely and correctly

bull Make sure the floor in the storage area is impermeable to any liquid wastestored on it (A sealed concrete floor is often used)

bull If the storage area is indoors make sure leaking waste cannot enter floordrains

bull If the storage area is outdoors the floor must also be curbed to prevent leaksfrom spilling onto the ground

bull When placing containers in the storage area position them so that labels areeasily visible Leave enough space between containers to check for leaks andto remove containers if leaks are discovered

bull Stacking 55-gallon drums two-high is allowed if they are secure and can stillbe easily inspected and removed if they leak Stacking 55-gallon drums three-high is strongly discouraged

bull Train the personnel who perform the inspections to ensure they are familiarwith labeling marking and storage rules Steps 4 and 5 in this manual covermarking and storage and may assist you in training You will need todocument the training (see Appendix G)


When a business collects a certain waste so slowly that it would not fill a containerbefore storage time limits dictated it must be shipped the business can designate thatcontainer a satellite accumulation container Write on the container the date you firstplaced waste in it But for satellite accumulation containers the date the container isfilled becomes the accumulation start date for storage time purposes (the 90- or 180-daystorage time clock starts on this date) Move satellite accumulation containers to apermanent storage area within three days of this dateSatellite accumulation containers that are under direct control of an operator and arevisually inspected daily by that operator do not need documented weekly inspectionsduring the waste accumulation period Satellite accumulation containers that arelocated away from the operator during waste accumulation or that have been filled andmoved into the permanent storage area must be inspected weekly You must documentthese inspections

Appendix D Documenting Container Inspections


All rights reserved

Weekly Inspections Weekly Inspections Weekly Inspections Weekly Inspections Weekly Inspections What to Look forWhat to Look forWhat to Look forWhat to Look forWhat to Look for

When doing a weekly inspection MPCA staff recommends that each business check thefollowing for each storage container and storage area

1 Are all the containers closed

2 Do the containers have the necessary hazard labels

3 If hazardous waste pretransport labels are used to satisfy markingrequirements are they visible and filled out completely

4 Do the dates on the drums indicate they are within the storage time limits foryour generator size

5 Is the amount of waste stored within the accumulation limits for yourgenerator size

6 Are there any spills or leaks

7 Are there any cracks in the floor of the storage area

8 If the storage is outdoors is the area secure

9 If the storage is outdoors are ignitable wastes shadedMake a note of

bull the date of inspection

bull any problems that were found

bull what was done to correct each problem

bull the date each problem was corrected and

bull who corrected itThe employee doing the inspection must sign or initial the entry Keep these inspectionrecords for a minimum of three yearsThere is no special form you must use to document inspections You may use a calendardesignated for container inspections or you may use a log sheet such as the one on page87 You may copy this log sheet for your own use or use it as an example to design one ofyour ownFor example One business uses a log sheet similar to the one provided They keep it on aclipboard close to the area to be inspected Each week the inspector documents theinspection on the log sheet and signs the log When the log sheet is full it is placed in athree-ring binder that has a separate section for each inspection area then stored in acentral office

Accumulating Hazardous Waste in TanksAccumulating Hazardous Waste in TanksAccumulating Hazardous Waste in TanksAccumulating Hazardous Waste in TanksAccumulating Hazardous Waste in Tanks

If you accumulate hazardous waste in tanks there are additional rules to follow Formore information Small and Very Small Quantity Generators should refer to Minn R pt70450629 Large Quantity Generators should refer to Minn R pt 70450628 exceptsubpt 9 item C and subpt 12



Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

____

____

____

____

____

____

____

____

____

____

____

____

____

____

____

___

(are

a)

1D

rum

s cl

osed

2

Dru

ms

labe

led

corr

ectly

3

Labe

ls v

isib

le

com

plet

e

4St

orag

e tim

e lim

its o

kay

5A

ccum

ulat

ion

limits

oka

y6

Spill

s or

leak

s

7C

rack

s in

flo

or

8O

utdo

or

area

sec

ure

9 O

utdo

or

igni

tabl

essh

aded

Insp

ecti

onD

ate

Prob

lem

s no

ted

duri

ngin

spec

tion

V

isua

l In

spec

tion

by

(si

gn)

Cor

rect

ive

Act

ion

Dat

eC

orre

ctiv

e A

ctio

nC

orre

ctiv

e A

ctio

nby

(

sign

)


All rights reserved

Appendix E LDR Policy

MPCA Policy for One-Time Land Disposal Rule (LDR) Notificationfor Hazardous Waste Shipments and for Retaining Notification Records

Policy Statement The Minnesota Pollution Control Agency (MPCA) has chosen to implement as policythe US Environmental Protection Agency (EPA) rule change regarding written notification to thetreatment storage or land disposal facility for each shipment of restricted wastes The EPA regulationwas amended in May 1997 The revised language from the Code of Federal regulations is provided inAttachment 1 The corresponding State rule can be found in MN Rules Chapt 70451315 subp 1 A Band G

Background Prior to the federal rule change hazardous waste generators were required to providewritten notification and when applicable certifications with each waste shipment Generators were alsorequired to keep copies of notifications and certifications on-site for at least five years from the date thewaste was last sent to the on-site or off-site treatment storage or land disposal facility The Federal rulechange now allows generators to provide a one-time initial written notification and when applicablecertification to the receiving facility until such a time that the waste or facility change

Changes to the Federal LDR rules require generators of hazardous waste to retain notifications certifica-tions waste analysis data and other documentation for a minimum of 3 years from the date documen-tation was last sent to an on-site or off-site treatment storage or disposal facility Attachment 1 pro-vides the applicable Federal rule language

Currently MN Rules Chapt 70451315 subp 1 item A requires a written notification with each ship-ment of waste to the receiving treatment storage or land disposal facility and MN Rules Chapt70451315 subp 1 item B requires a written notification and certification be sent to the receiving treat-ment storage or land disposal facility with each shipment MN Rules Chapt 70451315 subp 1 itemG also requires generators to keep copies of notifications and certifications on-site for at least five yearsfrom the date the waste was last sent to the on-site or off-site treatment storage or land disposal facility

The MPCA has not amended its rules to reflect the Federal rule changes described above This hascaused unnecessary paperwork to continue to be required by rule within the State To resolve thisproblem this policy is being adopted until such a time that MPCA revises its rules to accommodate thechanges This policy has a practical basis and will allow entities that do business in multiple counties tohave consistent regulation MPCA staff can distribute this policy as needed to clarify requirements andour official policy on this issue

__________________ ________________________________________ Date Timothy K Scherkenbach

Division ManagerPolicy amp Planning Division

August 4 1999


ATTACHMENT 1Language from 40 CFR 2687

2687 (a) (2) If the waste does not meet the treatment standard With the initial shipment of waste toeach treatment or storage facility the generator must send a one-time written notice to each treatmentor storage facility receiving the waste and place a copy in the file The notice must include the informa-tion in column ldquo2687(a)(2)rdquo of the Generator Paperwork Requirements Table in Sec 2687(a)(4) Nofurther notification is necessary until such time that the waste or facility change in which case a newnotification must be sent and a copy placed in the generatorrsquos file

2687 (a) (3) If the waste meets the treatment standard at the original point of generation

(i) With the initial shipment of waste to each treatment storage or disposal facility the generatormust send a one-time written notice to each treatment storage or disposal facility receiving the wasteand place a copy in the file The notice must include the information indicated in column ldquo2687(a)(3)rdquoof the Generator Paperwork Requirements Table in Sec 2687(a)(4) and the following certificationstatement signed by an authorized representative

I certify under penalty of law that I personally have examined and am familiar with thewaste through analysis and testing or through knowledge of the waste to support thiscertification that the waste complies with the treatment standards specified in 40 CFR part268 subpart D I believe that the information I submitted is true accurate and complete Iam aware that there are significant penalties for submitting a false certification includingthe possibility of a fine and imprisonment

(ii) If the waste changes the generator must send a new notice and certification to the receivingfacility and place a copy in their files Generators of hazardous debris excluded from the definition ofhazardous waste under Sec 2613(f) of this chapter are not subject to these requirements

2687 (a) (8) Generators must retain on-site a copy of all notices certifications waste analysis dataand other documentation produced pursuant to this section for at least 3 years from the date that thewaste that is the subject of such documentation was last sent to on-site or off-site treatment storage ordisposal facility The three year record retention is automatically extended during the course of anyunresolved action regarding the regulated activity or as requested by the Administrator



All rights reserved

Emergency Planfor

Location Address _________________________________________________

________________________________________________________________

Mailing Address __________________________________________________

________________________________________________________________

Telephone ( ________ ) _______________________________

EPA ID ___________________________________________

Emergency Coordinator ___________________________________________

Backup Coordinator _______________________________________________

Date _____________________

This emergency planning packet is designed for the Small Quantity Hazardous Waste Generator(220-2200 pounds per month)

Appendix F SQG Emergency Planning Packet


Hazardous Waste GeneratorEmergency Responder Notification

TO ________________________________________________

________________________________________________

________________________________________________

________________________________________________

FROM ________________________________________________

________________________________________________

________________________________________________

________________________________________________

The US Environmental Protection Agency and the Minnesota Pollution Control Agencyregulations require all businesses that produce hazardous waste to notify local emergencyresponse personnel This notification is meant to establish cooperation in case of a fire or anunplanned release of hazardous waste that may require your emergency services

To enable you to respond properly to an emergency at this site I am enclosing the EmergencyResponder Notification Form

We appreciate your assistance in this matter and look forward to any comments you may haveon this plan

Sincerely



All rights reserved

N

Emergency Site Plan for _________________________________________

Draw a diagram of your site below Includebull access roadsbull hazardous waste storage areasbull entrances and evacuation routes

bull facility layoutbull hazardous material storage areas

LegendE = Entrances ExitsW = Hazardous Waste StorageM = Hazardous Material StorageP = Personnel Work AreaS = Spill Control EquipmentX = Fire Extinguisher

= Evacuation Route


Emergency Responder Notification FormCompany Name ______________________________________ EPA ID __________________________________

Address ______________________________________________________________________________________

Contact _____________________________________________ Phone _________________________________

Notification of Hazardous Waste GenerationWaste Physical Properties Health Hazards

Annual Production

Waste Physical Properties Health Hazards

Annual Production


Annual Production


Annual Production


Annual Production


Annual Production

Note Hazardous materials may be included above as a service to emergency responders If you include hazardous materials in thislist specify which are wastes and which are materials


All rights reserved

Emergency Contacts Telephone PostingFill in information and post near the telephone in areas where hazardous waste is handled or stored

Emergency Coordinator(s) Work Home_____________________________________________ ________________ _____________________________________________________________ ________________ _____________________________________________________________ ________________ _____________________________________________________________ ________________ ________________

Fire Department _________________________

Police _________________________

Hospital _________________________

MN Duty Officer (24-hr spill reporting) 1- (651) 649-5451

1- (800) 422-0798

National Response Center (24-hr spill reporting) 1- (800) 424-8802

Location of Emergency Response Equipment

Fire extinguishers ___________________________________________________________________________________________________________________________________________________________________________

Fire alarm ________________________________________________________________________________________________________________________________________________________________________________

Spill control material ______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Special equipment _______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________(When completed and posted fulfills emergency contacts telephone posting requirements for Small Quantity Generators)


Appendix G Employee Training Documentation

Employee Name_____________________________________

Job Title ____________________________________________

Record of Employee Hazardous Waste Management Training Minnesota Rule 70450292 subpt 5H(3) requires that Small Quantity Generators ensure and document that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations and emergencies SQGs are not required to conduct annual review sessions of hazardous training However additional training must be conducted for situations such as

bull hiring of new employees with hazardous waste or emergency response duties bull change in employeersquos hazardous waste duties (eg change in emergency coordinator) bull change in hazardous wastes generated by the company

Employeersquos hazardous waste management and emergency response duties

_________________________________________________________________________________________

_________________________________________________________________________________________

Summary of Hazardous Waste Training

Date of training________________________ Type of Training Introductory Refresher

Instructor Name __________________________________________________

Check the areas covered during hazardous waste training

License Requirements Manifests Emergency Response Management plans Proper completion Emergency equipment License posted Copy distribution Use of equipment

Accumulation of Wastes Land disposal restriction notices Location of equipment Hazards of each waste Record Keeping Maintenance of equipment Storage time limits Containertank inspections Telephone posting Satellite accumulation Personal training Response to spills

Containers Manifests amp shipping papers Response to fires Marking and labeling Annual reports Response to explosions Keeping containers closed Waste Reduction Local authority arrangements Weekly inspections Reduce reuse recycle Evacuation routes Aisle space Other (specify) Outdoor storage Indoor storage

Tanks Labeling Inspections

Certification I received hazardous waste training in the areas checked above

Employee Signature_______________________________________________Date ____________________


All rights reserved

IndexAppendix H Battery Shipping Log

Used Lead Acid Battery Shipping Log Number shipped Date shipped Battery hauler Battery destination


Index Notes


All rights reserved

Index

T

Test results sample 84Toxicity Characteristic Leaching Procedure 55 84Training documentation 97

U

Universal waste 79

V

Very Small Quantity Generators 14 15 17 18 23 38 42 43 4552 55

W

WasteCharacteristic 5 8 10 43Listed 5 6 7 10 43Reducing 38 52 63

B

Batteries lead acid 61Shipping log 98

C

Containers empty 28 83

D

Derived from 7 12 60

E

Emergency planning packet (SQG) 92-96Empty container 28 83EPA Identification Number 16-19 31 35 39 44 48

Subsequent notification 17Exception report 42 55

I

InspectionContainer 7 27 30 37 46 51 53 54 55 87Documenting 87

L

Land disposal restrictions 46 90 91Large quantity generator 14 17 23 29 40 43 49 50 54 55License 16 20 21 23 31 38 55

Application 16 20 21 55Fees 22 23

M

Material Safety Data Sheet 6 8 sample 82Minimal Quantity Generators14 15 20 45Mixed with 7 12 14 20

O

Oil used 7 13 14 17 18 20 21 26 27 34 55 66 67-75

P

Polychlorinated biphenyls (PCBs) 5 6 8 10 14 38

S

Satellite accumulation 7 25 30 50 53 85Sewer discharging to 5 8 14 20 34 59Small quantity generator 14 17 23 29 40 43 48 54 55Storage extension 29


Department of AdministrationMinnesotarsquos Bookstore (651) 297-3000

(800) 657-3757

Department of AgriculturePesticides (651) 297-4870

(800) 657-3986Web site httpwwwmdastatemnus

Department of Public SafetySARA Reporting (651) 297-7372

Department of Public ServiceOilLead-Acid Battery signs (651) 639-4010

Department of TransportationHazardous Materials (651) 405-6060Web site httpwwwdotstatemnus

EPA HotlinesRCRA (800) 424-9346SARA Reporting (800) 535-0202Superfund (703) 412-9810Web site httpwwwepagov

EPA National Response CenterReporting Spills (800) 424-8802

Metropolitan Council Environmental ServicesIndustrial Discharge Section (651) 602-4703Web site httpwwwmetrocouncilorg

Metropolitan County Hazardous Waste OfficesAnoka County (763) 422-7093Carver County (952) 361-1800Dakota County (952) 891-7557Hennepin County (612) 348-8100Ramsey County (651) 773-4466Scott County (952) 496-8177Washington County (651) 430-6655Web sites httpwwwco[county]mnus

Minnesota Duty Officer (651) 649-5451 (800) 422-0798

Minnesota Pollution Control AgencyToll free (800) 657-3864Customer Assistance Center (651) 297-2274Small Business Assistance (651) 282-6143

(800) 657-3938Individual Sewage Treatment Systems

(651) 282-6246Air Quality Complaint Line (651) 296-7300Brainerd (218) 828-2492Detroit Lakes (218) 847-1519Duluth (218) 723-4660Mankato (507) 389-5235Marshall (507) 537-7146Rochester (507) 285-7343St Paul (651) 297-2274Willmar (320) 214-3786Web site httpwwwpcastatemnus

Minnesota Technical Assistance ProgramMinneapolis (612) 624-1300Toll free (800) 247-0015Web site httpwwwmntapumneduMaterials Exchange Web site

httpwwwmnexchangeorg

Minnesota Waste WiseSt Paul (651) 292-4650Toll free (800) 821-2230Web site httpwwwmnwastewiseorg

Occupational Safety and Health Administration(Minn OSHA) (651) 297-2393

Small Business OmbudsmanAir Quality Requirements (651) 297-8615

(800) 985-4247

State Fire Marshal (651) 215-0500

Hazardous Waste Related Contacts

Cover

Purpose

Table of Contents

Introduction

Steps to Compliance

Step 1A Evaluate Waste

Evaluation Review Flowchart

Step 1B Determine Size

Step 2 Get an EPA Identification Number

Step 3 Get a License Pay a Fee

Step 4 Place Waste in Containers Mark Them

Step 5 Store and Accumulate Properly

Step 6 Transport amp Dispose of Waste Correctly

Step 7 Prepare amp Distribute the Manifest

Step 8 Plan for Emergencies

Step 9 Train Employees

Step 10 Keep Records

Special Topics


Lead-Acid Batteries

Reducing Waste

Parts Washers

Used Oil

Electronic Waste

Universal Waste

Appendices

MSDS Sample

Lab Results Sample

Managing Empty Containers

Documenting Container Inspections

LDR Policy

SQG Emergency Planning Packet

Employee Training Documentation

Lead-Acid Battery Shipping Log

Index

HW Contacts

The purpose of the Minnesota Pollution Control Agencyrsquos Hazardous Waste Program is to preventharm to human health and the environment through proper management of hazardous wasteThe purpose of this manual is to provide information to hazardous waste generators that explainsproper waste management and encourages compliance with hazardous waste rules

Statement of Purpose

copy2004 State of Minnesota Minnesota Pollution Control AgencyAll rights reserved

EPA

MPCA

Metro CountiesAnokaCarverDakotaHennepinRamseyScottWashington

HazardousHazardousHazardousHazardousHazardousWaste Regulatory AgenciesWaste Regulatory AgenciesWaste Regulatory AgenciesWaste Regulatory AgenciesWaste Regulatory Agencies

The US EnvironmentalProtection Agency (EPA)administers the hazardouswaste programs in many statesbut not in Minnesota The EPAhas given the Minnesota PollutionControl Agency (MPCA) authority to run its own program withEPA oversight Likewise the seven metropolitan counties haveauthority to run their own programs with MPCA oversightHazardous waste generators located in Greater Minnesotareport to the MPCA Those located in the metro area report totheir respective county office

AnokaCarverDakotaHennepinScottRamseyWashington

EPA

MPCA

MetroCounties


Table of Contents

Introduction 4










All rights reserved










Introduction












(Minn R 70450214)










See Appendix C


All rights reserved

Evaluate Waste



















(MEK) F005







All rights reserved

Evaluate Waste

















butadiene 05 D033


(MEK) 2000 D035








All rights reserved

Evaluate Waste











All rights reserved


rtSta

rtSta

rtSta

rtSta

rt

Does

the

wast

e co

ntai

n m

ore

than

50

ppm

PCBs

Is th

ewa

ste

exem

pt fr

omHa

zard

ous

Was

teRu

les

Is th

ewa

ste

liste

d in

the

Haza

rdou

s W

aste

Rule

s

Is th

ewa

ste

exem

ptfro

m s

ome

rule

s if

recy

cled

reus

ed o

rre

claim

ed

Man

age

as a

nin

dust

rial s

olid

was

te o

rac

cord

ing

to a

pplic

able

requ

irem

ents

Is th

ewa

ste

mixe

d wi

th o

rde

rived

from

a lis

ted

wast

e

Man

age

acco

rdin

g to

appl

icabl

e ha

zard

ous

wast

e re

quire

men

ts

The

wast

e is

haza

rdou

s M

anag

eac

cord

ing

to a

llha

zard

ous

wast

ere

quire

men

ts

The

wast

e is

not

haza

rdou

s M

anag

eac

cord

ing

to in

dust

rial

solid

was

te o

r was

tewa

ter

requ

irem

ents

Does

the

wast

e di

spla

y a

haza

rdou

sch

arac

teris

tic

Yes

NoNo

NoNo

Yes

No

Yes

Yes

Yes

Yes

No

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous




















All rights reserved














2200

220

0




ound

s of

haz

ardo

us w

aste

mon

thPou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth















All rights reserved


Step 2



Date Received







II below)




C Inactivation




ny)


Street

Street (Continued)

City or Town

StateZip Code

County Name








Name (Last)

(First)

Job Title


VI Contact Address

Street or PO Box

City or Town

StateZip Code

VII Ownership


m Section II above)


City or Town

StateZip Code



Federal State

Indian Tribe




w-hw7-09

1 of 2

September 03
















Figure 1EPA ID form



Moving














All rights reserved



VIII-B1)



















All rights reserved





































All rights reserved




Clean Air Act Fee


























































All rights reserved












HazardousWaste


2904





















All rights reserved


Step 4

UsedOil

UsedOil


















for leaks







All rights reserved















































All rights reserved

































All rights reserved


































All rights reserved




























Ohio Ohio EPA (614) 644-2917






All rights reserved



























2 Tour the facility







All rights reserved


Step 7











bull antifreeze

























All rights reserved


Step 7






































bull 19 Other




All rights reserved






























All rights reserved























All rights reserved































Report the spill to





All rights reserved

































10 Train employees





All rights reserved





























All rights reserved

Train Employees


























All rights reserved

Train Employees













Step 10Keep Records

















All rights reserved

Keep Records









und




TopicsSpecial


All rights reserved

Notes










All rights reserved


















All rights reserved


























All rights reserved

Reducing Waste























All rights reserved

Parts Washers








bull engine oil



bull hydraulic oil





bull peat

bull corn cobs


bull sawdust

bull wood chips

bull paper wipes






bull cutting oil


bull grease

bull brake fluid



bull granular clay



bull cork

bull pumice

Topic 5Used Oil


All rights reserved

Used Oil














Topic 5Used Oil










All rights reserved

Used Oil
















Topic 5Used Oil





The tank must












The tank must






actions (6)


All rights reserved

Used Oil


















Total Halogens

10000 ppm maximum



Topic 5Used Oil











All rights reserved

Used Oil















Topic 5Used Oil








All rights reserved

Electronic Waste




















All rights reserved

Electronic Waste
















bull pesticides and










All rights reserved

Universal Waste



















Appendices


All rights reserved

Appendix A MSDS




SECTION I



PIGMENTS BASE METAL

CATALYST ALLOYS


















CONDITIONS TO AVOID









Appendix A MSDS


All rights reserved


Date 12 October 2005


SAMPLE NUMBER 480






Lead 50 50

Cadmium 004 10




















All rights reserved




























All rights reserved





















Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

____

____

____

____

____

____

____

____

____

____

____

____

____

____

____

___

(are

a)

1D

rum

s cl

osed

2

Dru

ms

labe

led

corr

ectly

3

Labe

ls v

isib

le

com

plet

e

4St

orag

e tim

e lim

its o

kay

5A

ccum

ulat

ion

limits

oka

y6

Spill

s or

leak

s

7C

rack

s in

flo

or

8O

utdo

or

area

sec

ure

9 O

utdo

or

igni

tabl

essh

aded

Insp

ecti

onD

ate

Prob

lem

s no

ted

duri

ngin

spec

tion

V

isua

l In

spec

tion

by

(si

gn)

Cor

rect

ive

Act

ion

Dat

eC

orre

ctiv

e A

ctio

nC

orre

ctiv

e A

ctio

nby

(

sign

)


All rights reserved










August 4 1999











All rights reserved

Emergency Planfor


________________________________________________________________

Mailing Address __________________________________________________

________________________________________________________________

Telephone ( ________ ) _______________________________

EPA ID ___________________________________________



Date _____________________





TO ________________________________________________

________________________________________________

________________________________________________

________________________________________________

FROM ________________________________________________

________________________________________________

________________________________________________

________________________________________________




Sincerely



All rights reserved

N





= Evacuation Route



Address ______________________________________________________________________________________

Contact _____________________________________________ Phone _________________________________


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production



All rights reserved



Fire Department _________________________

Police _________________________

Hospital _________________________


1- (800) 422-0798




Fire alarm ________________________________________________________________________________________________________________________________________________________________________________





Employee Name_____________________________________

Job Title ____________________________________________




_________________________________________________________________________________________

_________________________________________________________________________________________



Instructor Name __________________________________________________









All rights reserved




Index Notes


All rights reserved

Index

T


U

Universal waste 79

V


W


B


C


D


E



I


L



M


O

Oil used 7 13 14 17 18 20 21 26 27 34 55 66 67-75

P


S




(800) 657-3757



















(800) 985-4247



Cover

Purpose

Table of Contents

Introduction

Steps to Compliance













Special Topics


Lead-Acid Batteries

Reducing Waste

Parts Washers

Used Oil

Electronic Waste

Universal Waste

Appendices

MSDS Sample

Lab Results Sample



LDR Policy




Index

HW Contacts


Table of Contents

Introduction 4










All rights reserved










Introduction












(Minn R 70450214)










See Appendix C


All rights reserved

Evaluate Waste



















(MEK) F005







All rights reserved

Evaluate Waste

















butadiene 05 D033


(MEK) 2000 D035








All rights reserved

Evaluate Waste











All rights reserved


rtSta

rtSta

rtSta

rtSta

rt

Does

the

wast

e co

ntai

n m

ore

than

50

ppm

PCBs

Is th

ewa

ste

exem

pt fr

omHa

zard

ous

Was

teRu

les

Is th

ewa

ste

liste

d in

the

Haza

rdou

s W

aste

Rule

s

Is th

ewa

ste

exem

ptfro

m s

ome

rule

s if

recy

cled

reus

ed o

rre

claim

ed

Man

age

as a

nin

dust

rial s

olid

was

te o

rac

cord

ing

to a

pplic

able

requ

irem

ents

Is th

ewa

ste

mixe

d wi

th o

rde

rived

from

a lis

ted

wast

e

Man

age

acco

rdin

g to

appl

icabl

e ha

zard

ous

wast

e re

quire

men

ts

The

wast

e is

haza

rdou

s M

anag

eac

cord

ing

to a

llha

zard

ous

wast

ere

quire

men

ts

The

wast

e is

not

haza

rdou

s M

anag

eac

cord

ing

to in

dust

rial

solid

was

te o

r was

tewa

ter

requ

irem

ents

Does

the

wast

e di

spla

y a

haza

rdou

sch

arac

teris

tic

Yes

NoNo

NoNo

Yes

No

Yes

Yes

Yes

Yes

No

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous




















All rights reserved














2200

220

0




ound

s of

haz

ardo

us w

aste

mon

thPou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth















All rights reserved


Step 2



Date Received







II below)




C Inactivation




ny)


Street

Street (Continued)

City or Town

StateZip Code

County Name








Name (Last)

(First)

Job Title


VI Contact Address

Street or PO Box

City or Town

StateZip Code

VII Ownership


m Section II above)


City or Town

StateZip Code



Federal State

Indian Tribe




w-hw7-09

1 of 2

September 03
















Figure 1EPA ID form



Moving














All rights reserved



VIII-B1)



















All rights reserved





































All rights reserved




Clean Air Act Fee


























































All rights reserved












HazardousWaste


2904





















All rights reserved


Step 4

UsedOil

UsedOil


















for leaks







All rights reserved















































All rights reserved

































All rights reserved


































All rights reserved




























Ohio Ohio EPA (614) 644-2917






All rights reserved



























2 Tour the facility







All rights reserved


Step 7











bull antifreeze

























All rights reserved


Step 7






































bull 19 Other




All rights reserved






























All rights reserved























All rights reserved































Report the spill to





All rights reserved

































10 Train employees





All rights reserved





























All rights reserved

Train Employees


























All rights reserved

Train Employees













Step 10Keep Records

















All rights reserved

Keep Records









und




TopicsSpecial


All rights reserved

Notes










All rights reserved


















All rights reserved


























All rights reserved

Reducing Waste























All rights reserved

Parts Washers








bull engine oil



bull hydraulic oil





bull peat

bull corn cobs


bull sawdust

bull wood chips

bull paper wipes






bull cutting oil


bull grease

bull brake fluid



bull granular clay



bull cork

bull pumice

Topic 5Used Oil


All rights reserved

Used Oil














Topic 5Used Oil










All rights reserved

Used Oil
















Topic 5Used Oil





The tank must












The tank must






actions (6)


All rights reserved

Used Oil


















Total Halogens

10000 ppm maximum



Topic 5Used Oil











All rights reserved

Used Oil















Topic 5Used Oil








All rights reserved

Electronic Waste




















All rights reserved

Electronic Waste
















bull pesticides and










All rights reserved

Universal Waste



















Appendices


All rights reserved

Appendix A MSDS




SECTION I



PIGMENTS BASE METAL

CATALYST ALLOYS


















CONDITIONS TO AVOID









Appendix A MSDS


All rights reserved




SAMPLE NUMBER 480






Lead 50 50

Cadmium 004 10




















All rights reserved




























All rights reserved





















Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

____

____

____

____

____

____

____

____

____

____

____

____

____

____

____

___

(are

a)

1D

rum

s cl

osed

2

Dru

ms

labe

led

corr

ectly

3

Labe

ls v

isib

le

com

plet

e

4St

orag

e tim

e lim

its o

kay

5A

ccum

ulat

ion

limits

oka

y6

Spill

s or

leak

s

7C

rack

s in

flo

or

8O

utdo

or

area

sec

ure

9 O

utdo

or

igni

tabl

essh

aded

Insp

ecti

onD

ate

Prob

lem

s no

ted

duri

ngin

spec

tion

V

isua

l In

spec

tion

by

(si

gn)

Cor

rect

ive

Act

ion

Dat

eC

orre

ctiv

e A

ctio

nC

orre

ctiv

e A

ctio

nby

(

sign

)


All rights reserved










August 4 1999











All rights reserved

Emergency Planfor


________________________________________________________________

Mailing Address __________________________________________________

________________________________________________________________

Telephone ( ________ ) _______________________________

EPA ID ___________________________________________



Date _____________________





TO ________________________________________________

________________________________________________

________________________________________________

________________________________________________

FROM ________________________________________________

________________________________________________

________________________________________________

________________________________________________




Sincerely



All rights reserved

N





= Evacuation Route



Address ______________________________________________________________________________________

Contact _____________________________________________ Phone _________________________________


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production



All rights reserved



Fire Department _________________________

Police _________________________

Hospital _________________________


1- (800) 422-0798




Fire alarm ________________________________________________________________________________________________________________________________________________________________________________





Employee Name_____________________________________

Job Title ____________________________________________




_________________________________________________________________________________________

_________________________________________________________________________________________



Instructor Name __________________________________________________









All rights reserved




Index Notes


All rights reserved

Index

T


U

Universal waste 79

V


W


B


C


D


E



I


L



M


O

Oil used 7 13 14 17 18 20 21 26 27 34 55 66 67-75

P


S




(800) 657-3757



















(800) 985-4247



Cover

Purpose

Table of Contents

Introduction

Steps to Compliance













Special Topics


Lead-Acid Batteries

Reducing Waste

Parts Washers

Used Oil

Electronic Waste

Universal Waste

Appendices

MSDS Sample

Lab Results Sample



LDR Policy




Index

HW Contacts


All rights reserved










Introduction












(Minn R 70450214)










See Appendix C


All rights reserved

Evaluate Waste



















(MEK) F005







All rights reserved

Evaluate Waste

















butadiene 05 D033


(MEK) 2000 D035








All rights reserved

Evaluate Waste











All rights reserved


rtSta

rtSta

rtSta

rtSta

rt

Does

the

wast

e co

ntai

n m

ore

than

50

ppm

PCBs

Is th

ewa

ste

exem

pt fr

omHa

zard

ous

Was

teRu

les

Is th

ewa

ste

liste

d in

the

Haza

rdou

s W

aste

Rule

s

Is th

ewa

ste

exem

ptfro

m s

ome

rule

s if

recy

cled

reus

ed o

rre

claim

ed

Man

age

as a

nin

dust

rial s

olid

was

te o

rac

cord

ing

to a

pplic

able

requ

irem

ents

Is th

ewa

ste

mixe

d wi

th o

rde

rived

from

a lis

ted

wast

e

Man

age

acco

rdin

g to

appl

icabl

e ha

zard

ous

wast

e re

quire

men

ts

The

wast

e is

haza

rdou

s M

anag

eac

cord

ing

to a

llha

zard

ous

wast

ere

quire

men

ts

The

wast

e is

not

haza

rdou

s M

anag

eac

cord

ing

to in

dust

rial

solid

was

te o

r was

tewa

ter

requ

irem

ents

Does

the

wast

e di

spla

y a

haza

rdou

sch

arac

teris

tic

Yes

NoNo

NoNo

Yes

No

Yes

Yes

Yes

Yes

No

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous




















All rights reserved














2200

220

0




ound

s of

haz

ardo

us w

aste

mon

thPou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth















All rights reserved


Step 2



Date Received







II below)




C Inactivation




ny)


Street

Street (Continued)

City or Town

StateZip Code

County Name








Name (Last)

(First)

Job Title


VI Contact Address

Street or PO Box

City or Town

StateZip Code

VII Ownership


m Section II above)


City or Town

StateZip Code



Federal State

Indian Tribe




w-hw7-09

1 of 2

September 03
















Figure 1EPA ID form



Moving














All rights reserved



VIII-B1)



















All rights reserved





































All rights reserved




Clean Air Act Fee


























































All rights reserved












HazardousWaste


2904





















All rights reserved


Step 4

UsedOil

UsedOil


















for leaks







All rights reserved















































All rights reserved

































All rights reserved


































All rights reserved




























Ohio Ohio EPA (614) 644-2917






All rights reserved



























2 Tour the facility







All rights reserved


Step 7











bull antifreeze

























All rights reserved


Step 7






































bull 19 Other




All rights reserved






























All rights reserved























All rights reserved































Report the spill to





All rights reserved

































10 Train employees





All rights reserved





























All rights reserved

Train Employees


























All rights reserved

Train Employees













Step 10Keep Records

















All rights reserved

Keep Records









und




TopicsSpecial


All rights reserved

Notes










All rights reserved


















All rights reserved


























All rights reserved

Reducing Waste























All rights reserved

Parts Washers








bull engine oil



bull hydraulic oil





bull peat

bull corn cobs


bull sawdust

bull wood chips

bull paper wipes






bull cutting oil


bull grease

bull brake fluid



bull granular clay



bull cork

bull pumice

Topic 5Used Oil


All rights reserved

Used Oil














Topic 5Used Oil










All rights reserved

Used Oil
















Topic 5Used Oil





The tank must












The tank must






actions (6)


All rights reserved

Used Oil


















Total Halogens

10000 ppm maximum



Topic 5Used Oil











All rights reserved

Used Oil















Topic 5Used Oil








All rights reserved

Electronic Waste




















All rights reserved

Electronic Waste
















bull pesticides and










All rights reserved

Universal Waste



















Appendices


All rights reserved

Appendix A MSDS




SECTION I



PIGMENTS BASE METAL

CATALYST ALLOYS


















CONDITIONS TO AVOID









Appendix A MSDS


All rights reserved




SAMPLE NUMBER 480






Lead 50 50

Cadmium 004 10




















All rights reserved




























All rights reserved





















Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

____

____

____

____

____

____

____

____

____

____

____

____

____

____

____

___

(are

a)

1D

rum

s cl

osed

2

Dru

ms

labe

led

corr

ectly

3

Labe

ls v

isib

le

com

plet

e

4St

orag

e tim

e lim

its o

kay

5A

ccum

ulat

ion

limits

oka

y6

Spill

s or

leak

s

7C

rack

s in

flo

or

8O

utdo

or

area

sec

ure

9 O

utdo

or

igni

tabl

essh

aded

Insp

ecti

onD

ate

Prob

lem

s no

ted

duri

ngin

spec

tion

V

isua

l In

spec

tion

by

(si

gn)

Cor

rect

ive

Act

ion

Dat

eC

orre

ctiv

e A

ctio

nC

orre

ctiv

e A

ctio

nby

(

sign

)


All rights reserved










August 4 1999











All rights reserved

Emergency Planfor


________________________________________________________________

Mailing Address __________________________________________________

________________________________________________________________

Telephone ( ________ ) _______________________________

EPA ID ___________________________________________



Date _____________________





TO ________________________________________________

________________________________________________

________________________________________________

________________________________________________

FROM ________________________________________________

________________________________________________

________________________________________________

________________________________________________




Sincerely



All rights reserved

N





= Evacuation Route



Address ______________________________________________________________________________________

Contact _____________________________________________ Phone _________________________________


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production



All rights reserved



Fire Department _________________________

Police _________________________

Hospital _________________________


1- (800) 422-0798




Fire alarm ________________________________________________________________________________________________________________________________________________________________________________





Employee Name_____________________________________

Job Title ____________________________________________




_________________________________________________________________________________________

_________________________________________________________________________________________



Instructor Name __________________________________________________









All rights reserved




Index Notes


All rights reserved

Index

T


U

Universal waste 79

V


W


B


C


D


E



I


L



M


O

Oil used 7 13 14 17 18 20 21 26 27 34 55 66 67-75

P


S




(800) 657-3757



















(800) 985-4247



Cover

Purpose

Table of Contents

Introduction

Steps to Compliance













Special Topics


Lead-Acid Batteries

Reducing Waste

Parts Washers

Used Oil

Electronic Waste

Universal Waste

Appendices

MSDS Sample

Lab Results Sample



LDR Policy




Index

HW Contacts












(Minn R 70450214)










See Appendix C


All rights reserved

Evaluate Waste



















(MEK) F005







All rights reserved

Evaluate Waste

















butadiene 05 D033


(MEK) 2000 D035








All rights reserved

Evaluate Waste











All rights reserved


rtSta

rtSta

rtSta

rtSta

rt

Does

the

wast

e co

ntai

n m

ore

than

50

ppm

PCBs

Is th

ewa

ste

exem

pt fr

omHa

zard

ous

Was

teRu

les

Is th

ewa

ste

liste

d in

the

Haza

rdou

s W

aste

Rule

s

Is th

ewa

ste

exem

ptfro

m s

ome

rule

s if

recy

cled

reus

ed o

rre

claim

ed

Man

age

as a

nin

dust

rial s

olid

was

te o

rac

cord

ing

to a

pplic

able

requ

irem

ents

Is th

ewa

ste

mixe

d wi

th o

rde

rived

from

a lis

ted

wast

e

Man

age

acco

rdin

g to

appl

icabl

e ha

zard

ous

wast

e re

quire

men

ts

The

wast

e is

haza

rdou

s M

anag

eac

cord

ing

to a

llha

zard

ous

wast

ere

quire

men

ts

The

wast

e is

not

haza

rdou

s M

anag

eac

cord

ing

to in

dust

rial

solid

was

te o

r was

tewa

ter

requ

irem

ents

Does

the

wast

e di

spla

y a

haza

rdou

sch

arac

teris

tic

Yes

NoNo

NoNo

Yes

No

Yes

Yes

Yes

Yes

No

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous




















All rights reserved














2200

220

0




ound

s of

haz

ardo

us w

aste

mon

thPou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth















All rights reserved


Step 2



Date Received







II below)




C Inactivation




ny)


Street

Street (Continued)

City or Town

StateZip Code

County Name








Name (Last)

(First)

Job Title


VI Contact Address

Street or PO Box

City or Town

StateZip Code

VII Ownership


m Section II above)


City or Town

StateZip Code



Federal State

Indian Tribe




w-hw7-09

1 of 2

September 03
















Figure 1EPA ID form



Moving














All rights reserved



VIII-B1)



















All rights reserved





































All rights reserved




Clean Air Act Fee


























































All rights reserved












HazardousWaste


2904





















All rights reserved


Step 4

UsedOil

UsedOil


















for leaks







All rights reserved















































All rights reserved

































All rights reserved


































All rights reserved




























Ohio Ohio EPA (614) 644-2917






All rights reserved



























2 Tour the facility







All rights reserved


Step 7











bull antifreeze

























All rights reserved


Step 7






































bull 19 Other




All rights reserved






























All rights reserved























All rights reserved































Report the spill to





All rights reserved

































10 Train employees





All rights reserved





























All rights reserved

Train Employees


























All rights reserved

Train Employees













Step 10Keep Records

















All rights reserved

Keep Records









und




TopicsSpecial


All rights reserved

Notes










All rights reserved


















All rights reserved


























All rights reserved

Reducing Waste























All rights reserved

Parts Washers








bull engine oil



bull hydraulic oil





bull peat

bull corn cobs


bull sawdust

bull wood chips

bull paper wipes






bull cutting oil


bull grease

bull brake fluid



bull granular clay



bull cork

bull pumice

Topic 5Used Oil


All rights reserved

Used Oil














Topic 5Used Oil










All rights reserved

Used Oil
















Topic 5Used Oil





The tank must












The tank must






actions (6)


All rights reserved

Used Oil


















Total Halogens

10000 ppm maximum



Topic 5Used Oil











All rights reserved

Used Oil















Topic 5Used Oil








All rights reserved

Electronic Waste




















All rights reserved

Electronic Waste
















bull pesticides and










All rights reserved

Universal Waste



















Appendices


All rights reserved

Appendix A MSDS




SECTION I



PIGMENTS BASE METAL

CATALYST ALLOYS


















CONDITIONS TO AVOID









Appendix A MSDS


All rights reserved




SAMPLE NUMBER 480






Lead 50 50

Cadmium 004 10




















All rights reserved




























All rights reserved





















Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

____

____

____

____

____

____

____

____

____

____

____

____

____

____

____

___

(are

a)

1D

rum

s cl

osed

2

Dru

ms

labe

led

corr

ectly

3

Labe

ls v

isib

le

com

plet

e

4St

orag

e tim

e lim

its o

kay

5A

ccum

ulat

ion

limits

oka

y6

Spill

s or

leak

s

7C

rack

s in

flo

or

8O

utdo

or

area

sec

ure

9 O

utdo

or

igni

tabl

essh

aded

Insp

ecti

onD

ate

Prob

lem

s no

ted

duri

ngin

spec

tion

V

isua

l In

spec

tion

by

(si

gn)

Cor

rect

ive

Act

ion

Dat

eC

orre

ctiv

e A

ctio

nC

orre

ctiv

e A

ctio

nby

(

sign

)


All rights reserved










August 4 1999











All rights reserved

Emergency Planfor


________________________________________________________________

Mailing Address __________________________________________________

________________________________________________________________

Telephone ( ________ ) _______________________________

EPA ID ___________________________________________



Date _____________________





TO ________________________________________________

________________________________________________

________________________________________________

________________________________________________

FROM ________________________________________________

________________________________________________

________________________________________________

________________________________________________




Sincerely



All rights reserved

N





= Evacuation Route



Address ______________________________________________________________________________________

Contact _____________________________________________ Phone _________________________________


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production



All rights reserved



Fire Department _________________________

Police _________________________

Hospital _________________________


1- (800) 422-0798




Fire alarm ________________________________________________________________________________________________________________________________________________________________________________





Employee Name_____________________________________

Job Title ____________________________________________




_________________________________________________________________________________________

_________________________________________________________________________________________



Instructor Name __________________________________________________









All rights reserved




Index Notes


All rights reserved

Index

T


U

Universal waste 79

V


W


B


C


D


E



I


L



M


O

Oil used 7 13 14 17 18 20 21 26 27 34 55 66 67-75

P


S




(800) 657-3757



















(800) 985-4247



Cover

Purpose

Table of Contents

Introduction

Steps to Compliance













Special Topics


Lead-Acid Batteries

Reducing Waste

Parts Washers

Used Oil

Electronic Waste

Universal Waste

Appendices

MSDS Sample

Lab Results Sample



LDR Policy




Index

HW Contacts


All rights reserved

Evaluate Waste



















(MEK) F005







All rights reserved

Evaluate Waste

















butadiene 05 D033


(MEK) 2000 D035








All rights reserved

Evaluate Waste











All rights reserved


rtSta

rtSta

rtSta

rtSta

rt

Does

the

wast

e co

ntai

n m

ore

than

50

ppm

PCBs

Is th

ewa

ste

exem

pt fr

omHa

zard

ous

Was

teRu

les

Is th

ewa

ste

liste

d in

the

Haza

rdou

s W

aste

Rule

s

Is th

ewa

ste

exem

ptfro

m s

ome

rule

s if

recy

cled

reus

ed o

rre

claim

ed

Man

age

as a

nin

dust

rial s

olid

was

te o

rac

cord

ing

to a

pplic

able

requ

irem

ents

Is th

ewa

ste

mixe

d wi

th o

rde

rived

from

a lis

ted

wast

e

Man

age

acco

rdin

g to

appl

icabl

e ha

zard

ous

wast

e re

quire

men

ts

The

wast

e is

haza

rdou

s M

anag

eac

cord

ing

to a

llha

zard

ous

wast

ere

quire

men

ts

The

wast

e is

not

haza

rdou

s M

anag

eac

cord

ing

to in

dust

rial

solid

was

te o

r was

tewa

ter

requ

irem

ents

Does

the

wast

e di

spla

y a

haza

rdou

sch

arac

teris

tic

Yes

NoNo

NoNo

Yes

No

Yes

Yes

Yes

Yes

No

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous




















All rights reserved














2200

220

0




ound

s of

haz

ardo

us w

aste

mon

thPou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth















All rights reserved


Step 2



Date Received







II below)




C Inactivation




ny)


Street

Street (Continued)

City or Town

StateZip Code

County Name








Name (Last)

(First)

Job Title


VI Contact Address

Street or PO Box

City or Town

StateZip Code

VII Ownership


m Section II above)


City or Town

StateZip Code



Federal State

Indian Tribe




w-hw7-09

1 of 2

September 03
















Figure 1EPA ID form



Moving














All rights reserved



VIII-B1)



















All rights reserved





































All rights reserved




Clean Air Act Fee


























































All rights reserved












HazardousWaste


2904





















All rights reserved


Step 4

UsedOil

UsedOil


















for leaks







All rights reserved















































All rights reserved

































All rights reserved


































All rights reserved




























Ohio Ohio EPA (614) 644-2917






All rights reserved



























2 Tour the facility







All rights reserved


Step 7











bull antifreeze

























All rights reserved


Step 7






































bull 19 Other




All rights reserved






























All rights reserved























All rights reserved































Report the spill to





All rights reserved

































10 Train employees





All rights reserved





























All rights reserved

Train Employees


























All rights reserved

Train Employees













Step 10Keep Records

















All rights reserved

Keep Records









und




TopicsSpecial


All rights reserved

Notes










All rights reserved


















All rights reserved


























All rights reserved

Reducing Waste























All rights reserved

Parts Washers








bull engine oil



bull hydraulic oil





bull peat

bull corn cobs


bull sawdust

bull wood chips

bull paper wipes






bull cutting oil


bull grease

bull brake fluid



bull granular clay



bull cork

bull pumice

Topic 5Used Oil


All rights reserved

Used Oil














Topic 5Used Oil










All rights reserved

Used Oil
















Topic 5Used Oil





The tank must












The tank must






actions (6)


All rights reserved

Used Oil


















Total Halogens

10000 ppm maximum



Topic 5Used Oil











All rights reserved

Used Oil















Topic 5Used Oil








All rights reserved

Electronic Waste




















All rights reserved

Electronic Waste
















bull pesticides and










All rights reserved

Universal Waste



















Appendices


All rights reserved

Appendix A MSDS




SECTION I



PIGMENTS BASE METAL

CATALYST ALLOYS


















CONDITIONS TO AVOID









Appendix A MSDS


All rights reserved




SAMPLE NUMBER 480






Lead 50 50

Cadmium 004 10




















All rights reserved




























All rights reserved





















Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

____

____

____

____

____

____

____

____

____

____

____

____

____

____

____

___

(are

a)

1D

rum

s cl

osed

2

Dru

ms

labe

led

corr

ectly

3

Labe

ls v

isib

le

com

plet

e

4St

orag

e tim

e lim

its o

kay

5A

ccum

ulat

ion

limits

oka

y6

Spill

s or

leak

s

7C

rack

s in

flo

or

8O

utdo

or

area

sec

ure

9 O

utdo

or

igni

tabl

essh

aded

Insp

ecti

onD

ate

Prob

lem

s no

ted

duri

ngin

spec

tion

V

isua

l In

spec

tion

by

(si

gn)

Cor

rect

ive

Act

ion

Dat

eC

orre

ctiv

e A

ctio

nC

orre

ctiv

e A

ctio

nby

(

sign

)


All rights reserved










August 4 1999











All rights reserved

Emergency Planfor


________________________________________________________________

Mailing Address __________________________________________________

________________________________________________________________

Telephone ( ________ ) _______________________________

EPA ID ___________________________________________



Date _____________________





TO ________________________________________________

________________________________________________

________________________________________________

________________________________________________

FROM ________________________________________________

________________________________________________

________________________________________________

________________________________________________




Sincerely



All rights reserved

N





= Evacuation Route



Address ______________________________________________________________________________________

Contact _____________________________________________ Phone _________________________________


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production



All rights reserved



Fire Department _________________________

Police _________________________

Hospital _________________________


1- (800) 422-0798




Fire alarm ________________________________________________________________________________________________________________________________________________________________________________





Employee Name_____________________________________

Job Title ____________________________________________




_________________________________________________________________________________________

_________________________________________________________________________________________



Instructor Name __________________________________________________









All rights reserved




Index Notes


All rights reserved

Index

T


U

Universal waste 79

V


W


B


C


D


E



I


L



M


O

Oil used 7 13 14 17 18 20 21 26 27 34 55 66 67-75

P


S




(800) 657-3757



















(800) 985-4247



Cover

Purpose

Table of Contents

Introduction

Steps to Compliance













Special Topics


Lead-Acid Batteries

Reducing Waste

Parts Washers

Used Oil

Electronic Waste

Universal Waste

Appendices

MSDS Sample

Lab Results Sample



LDR Policy




Index

HW Contacts










(MEK) F005







All rights reserved

Evaluate Waste

















butadiene 05 D033


(MEK) 2000 D035








All rights reserved

Evaluate Waste











All rights reserved


rtSta

rtSta

rtSta

rtSta

rt

Does

the

wast

e co

ntai

n m

ore

than

50

ppm

PCBs

Is th

ewa

ste

exem

pt fr

omHa

zard

ous

Was

teRu

les

Is th

ewa

ste

liste

d in

the

Haza

rdou

s W

aste

Rule

s

Is th

ewa

ste

exem

ptfro

m s

ome

rule

s if

recy

cled

reus

ed o

rre

claim

ed

Man

age

as a

nin

dust

rial s

olid

was

te o

rac

cord

ing

to a

pplic

able

requ

irem

ents

Is th

ewa

ste

mixe

d wi

th o

rde

rived

from

a lis

ted

wast

e

Man

age

acco

rdin

g to

appl

icabl

e ha

zard

ous

wast

e re

quire

men

ts

The

wast

e is

haza

rdou

s M

anag

eac

cord

ing

to a

llha

zard

ous

wast

ere

quire

men

ts

The

wast

e is

not

haza

rdou

s M

anag

eac

cord

ing

to in

dust

rial

solid

was

te o

r was

tewa

ter

requ

irem

ents

Does

the

wast

e di

spla

y a

haza

rdou

sch

arac

teris

tic

Yes

NoNo

NoNo

Yes

No

Yes

Yes

Yes

Yes

No

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous




















All rights reserved














2200

220

0




ound

s of

haz

ardo

us w

aste

mon

thPou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth















All rights reserved


Step 2



Date Received







II below)




C Inactivation




ny)


Street

Street (Continued)

City or Town

StateZip Code

County Name








Name (Last)

(First)

Job Title


VI Contact Address

Street or PO Box

City or Town

StateZip Code

VII Ownership


m Section II above)


City or Town

StateZip Code



Federal State

Indian Tribe




w-hw7-09

1 of 2

September 03
















Figure 1EPA ID form



Moving














All rights reserved



VIII-B1)



















All rights reserved





































All rights reserved




Clean Air Act Fee


























































All rights reserved












HazardousWaste


2904





















All rights reserved


Step 4

UsedOil

UsedOil


















for leaks







All rights reserved















































All rights reserved

































All rights reserved


































All rights reserved




























Ohio Ohio EPA (614) 644-2917






All rights reserved



























2 Tour the facility







All rights reserved


Step 7











bull antifreeze

























All rights reserved


Step 7






































bull 19 Other




All rights reserved






























All rights reserved























All rights reserved































Report the spill to





All rights reserved

































10 Train employees





All rights reserved





























All rights reserved

Train Employees


























All rights reserved

Train Employees













Step 10Keep Records

















All rights reserved

Keep Records









und




TopicsSpecial


All rights reserved

Notes










All rights reserved


















All rights reserved


























All rights reserved

Reducing Waste























All rights reserved

Parts Washers








bull engine oil



bull hydraulic oil





bull peat

bull corn cobs


bull sawdust

bull wood chips

bull paper wipes






bull cutting oil


bull grease

bull brake fluid



bull granular clay



bull cork

bull pumice

Topic 5Used Oil


All rights reserved

Used Oil














Topic 5Used Oil










All rights reserved

Used Oil
















Topic 5Used Oil





The tank must












The tank must






actions (6)


All rights reserved

Used Oil


















Total Halogens

10000 ppm maximum



Topic 5Used Oil











All rights reserved

Used Oil















Topic 5Used Oil








All rights reserved

Electronic Waste




















All rights reserved

Electronic Waste
















bull pesticides and










All rights reserved

Universal Waste



















Appendices


All rights reserved

Appendix A MSDS




SECTION I



PIGMENTS BASE METAL

CATALYST ALLOYS


















CONDITIONS TO AVOID









Appendix A MSDS


All rights reserved




SAMPLE NUMBER 480






Lead 50 50

Cadmium 004 10




















All rights reserved




























All rights reserved





















Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

____

____

____

____

____

____

____

____

____

____

____

____

____

____

____

___

(are

a)

1D

rum

s cl

osed

2

Dru

ms

labe

led

corr

ectly

3

Labe

ls v

isib

le

com

plet

e

4St

orag

e tim

e lim

its o

kay

5A

ccum

ulat

ion

limits

oka

y6

Spill

s or

leak

s

7C

rack

s in

flo

or

8O

utdo

or

area

sec

ure

9 O

utdo

or

igni

tabl

essh

aded

Insp

ecti

onD

ate

Prob

lem

s no

ted

duri

ngin

spec

tion

V

isua

l In

spec

tion

by

(si

gn)

Cor

rect

ive

Act

ion

Dat

eC

orre

ctiv

e A

ctio

nC

orre

ctiv

e A

ctio

nby

(

sign

)


All rights reserved










August 4 1999











All rights reserved

Emergency Planfor


________________________________________________________________

Mailing Address __________________________________________________

________________________________________________________________

Telephone ( ________ ) _______________________________

EPA ID ___________________________________________



Date _____________________





TO ________________________________________________

________________________________________________

________________________________________________

________________________________________________

FROM ________________________________________________

________________________________________________

________________________________________________

________________________________________________




Sincerely



All rights reserved

N





= Evacuation Route



Address ______________________________________________________________________________________

Contact _____________________________________________ Phone _________________________________


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production



All rights reserved



Fire Department _________________________

Police _________________________

Hospital _________________________


1- (800) 422-0798




Fire alarm ________________________________________________________________________________________________________________________________________________________________________________





Employee Name_____________________________________

Job Title ____________________________________________




_________________________________________________________________________________________

_________________________________________________________________________________________



Instructor Name __________________________________________________









All rights reserved




Index Notes


All rights reserved

Index

T


U

Universal waste 79

V


W


B


C


D


E



I


L



M


O

Oil used 7 13 14 17 18 20 21 26 27 34 55 66 67-75

P


S




(800) 657-3757



















(800) 985-4247



Cover

Purpose

Table of Contents

Introduction

Steps to Compliance













Special Topics


Lead-Acid Batteries

Reducing Waste

Parts Washers

Used Oil

Electronic Waste

Universal Waste

Appendices

MSDS Sample

Lab Results Sample



LDR Policy




Index

HW Contacts


All rights reserved

Evaluate Waste

















butadiene 05 D033


(MEK) 2000 D035








All rights reserved

Evaluate Waste











All rights reserved


rtSta

rtSta

rtSta

rtSta

rt

Does

the

wast

e co

ntai

n m

ore

than

50

ppm

PCBs

Is th

ewa

ste

exem

pt fr

omHa

zard

ous

Was

teRu

les

Is th

ewa

ste

liste

d in

the

Haza

rdou

s W

aste

Rule

s

Is th

ewa

ste

exem

ptfro

m s

ome

rule

s if

recy

cled

reus

ed o

rre

claim

ed

Man

age

as a

nin

dust

rial s

olid

was

te o

rac

cord

ing

to a

pplic

able

requ

irem

ents

Is th

ewa

ste

mixe

d wi

th o

rde

rived

from

a lis

ted

wast

e

Man

age

acco

rdin

g to

appl

icabl

e ha

zard

ous

wast

e re

quire

men

ts

The

wast

e is

haza

rdou

s M

anag

eac

cord

ing

to a

llha

zard

ous

wast

ere

quire

men

ts

The

wast

e is

not

haza

rdou

s M

anag

eac

cord

ing

to in

dust

rial

solid

was

te o

r was

tewa

ter

requ

irem

ents

Does

the

wast

e di

spla

y a

haza

rdou

sch

arac

teris

tic

Yes

NoNo

NoNo

Yes

No

Yes

Yes

Yes

Yes

No

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous




















All rights reserved














2200

220

0




ound

s of

haz

ardo

us w

aste

mon

thPou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth















All rights reserved


Step 2



Date Received







II below)




C Inactivation




ny)


Street

Street (Continued)

City or Town

StateZip Code

County Name








Name (Last)

(First)

Job Title


VI Contact Address

Street or PO Box

City or Town

StateZip Code

VII Ownership


m Section II above)


City or Town

StateZip Code



Federal State

Indian Tribe




w-hw7-09

1 of 2

September 03
















Figure 1EPA ID form



Moving














All rights reserved



VIII-B1)



















All rights reserved





































All rights reserved




Clean Air Act Fee


























































All rights reserved












HazardousWaste


2904





















All rights reserved


Step 4

UsedOil

UsedOil


















for leaks







All rights reserved















































All rights reserved

































All rights reserved


































All rights reserved




























Ohio Ohio EPA (614) 644-2917






All rights reserved



























2 Tour the facility







All rights reserved


Step 7











bull antifreeze

























All rights reserved


Step 7






































bull 19 Other




All rights reserved






























All rights reserved























All rights reserved































Report the spill to





All rights reserved

































10 Train employees





All rights reserved





























All rights reserved

Train Employees


























All rights reserved

Train Employees













Step 10Keep Records

















All rights reserved

Keep Records









und




TopicsSpecial


All rights reserved

Notes










All rights reserved


















All rights reserved


























All rights reserved

Reducing Waste























All rights reserved

Parts Washers








bull engine oil



bull hydraulic oil





bull peat

bull corn cobs


bull sawdust

bull wood chips

bull paper wipes






bull cutting oil


bull grease

bull brake fluid



bull granular clay



bull cork

bull pumice

Topic 5Used Oil


All rights reserved

Used Oil














Topic 5Used Oil










All rights reserved

Used Oil
















Topic 5Used Oil





The tank must












The tank must






actions (6)


All rights reserved

Used Oil


















Total Halogens

10000 ppm maximum



Topic 5Used Oil











All rights reserved

Used Oil















Topic 5Used Oil








All rights reserved

Electronic Waste




















All rights reserved

Electronic Waste
















bull pesticides and










All rights reserved

Universal Waste



















Appendices


All rights reserved

Appendix A MSDS




SECTION I



PIGMENTS BASE METAL

CATALYST ALLOYS


















CONDITIONS TO AVOID









Appendix A MSDS


All rights reserved




SAMPLE NUMBER 480






Lead 50 50

Cadmium 004 10




















All rights reserved




























All rights reserved





















Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

____

____

____

____

____

____

____

____

____

____

____

____

____

____

____

___

(are

a)

1D

rum

s cl

osed

2

Dru

ms

labe

led

corr

ectly

3

Labe

ls v

isib

le

com

plet

e

4St

orag

e tim

e lim

its o

kay

5A

ccum

ulat

ion

limits

oka

y6

Spill

s or

leak

s

7C

rack

s in

flo

or

8O

utdo

or

area

sec

ure

9 O

utdo

or

igni

tabl

essh

aded

Insp

ecti

onD

ate

Prob

lem

s no

ted

duri

ngin

spec

tion

V

isua

l In

spec

tion

by

(si

gn)

Cor

rect

ive

Act

ion

Dat

eC

orre

ctiv

e A

ctio

nC

orre

ctiv

e A

ctio

nby

(

sign

)


All rights reserved










August 4 1999











All rights reserved

Emergency Planfor


________________________________________________________________

Mailing Address __________________________________________________

________________________________________________________________

Telephone ( ________ ) _______________________________

EPA ID ___________________________________________



Date _____________________





TO ________________________________________________

________________________________________________

________________________________________________

________________________________________________

FROM ________________________________________________

________________________________________________

________________________________________________

________________________________________________




Sincerely



All rights reserved

N





= Evacuation Route



Address ______________________________________________________________________________________

Contact _____________________________________________ Phone _________________________________


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production



All rights reserved



Fire Department _________________________

Police _________________________

Hospital _________________________


1- (800) 422-0798




Fire alarm ________________________________________________________________________________________________________________________________________________________________________________





Employee Name_____________________________________

Job Title ____________________________________________




_________________________________________________________________________________________

_________________________________________________________________________________________



Instructor Name __________________________________________________









All rights reserved




Index Notes


All rights reserved

Index

T


U

Universal waste 79

V


W


B


C


D


E



I


L



M


O

Oil used 7 13 14 17 18 20 21 26 27 34 55 66 67-75

P


S




(800) 657-3757



















(800) 985-4247



Cover

Purpose

Table of Contents

Introduction

Steps to Compliance













Special Topics


Lead-Acid Batteries

Reducing Waste

Parts Washers

Used Oil

Electronic Waste

Universal Waste

Appendices

MSDS Sample

Lab Results Sample



LDR Policy




Index

HW Contacts









butadiene 05 D033


(MEK) 2000 D035








All rights reserved

Evaluate Waste











All rights reserved


rtSta

rtSta

rtSta

rtSta

rt

Does

the

wast

e co

ntai

n m

ore

than

50

ppm

PCBs

Is th

ewa

ste

exem

pt fr

omHa

zard

ous

Was

teRu

les

Is th

ewa

ste

liste

d in

the

Haza

rdou

s W

aste

Rule

s

Is th

ewa

ste

exem

ptfro

m s

ome

rule

s if

recy

cled

reus

ed o

rre

claim

ed

Man

age

as a

nin

dust

rial s

olid

was

te o

rac

cord

ing

to a

pplic

able

requ

irem

ents

Is th

ewa

ste

mixe

d wi

th o

rde

rived

from

a lis

ted

wast

e

Man

age

acco

rdin

g to

appl

icabl

e ha

zard

ous

wast

e re

quire

men

ts

The

wast

e is

haza

rdou

s M

anag

eac

cord

ing

to a

llha

zard

ous

wast

ere

quire

men

ts

The

wast

e is

not

haza

rdou

s M

anag

eac

cord

ing

to in

dust

rial

solid

was

te o

r was

tewa

ter

requ

irem

ents

Does

the

wast

e di

spla

y a

haza

rdou

sch

arac

teris

tic

Yes

NoNo

NoNo

Yes

No

Yes

Yes

Yes

Yes

No

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous

The

wast

e is

haza

rdou

sTh

e wa

ste

isha

zard

ous




















All rights reserved














2200

220

0




ound

s of

haz

ardo

us w

aste

mon

thPou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth

Pou

nds

of h

azar

dous

was

tem

onth















All rights reserved


Step 2



Date Received







II below)




C Inactivation




ny)


Street

Street (Continued)

City or Town

StateZip Code

County Name








Name (Last)

(First)

Job Title


VI Contact Address

Street or PO Box

City or Town

StateZip Code

VII Ownership


m Section II above)


City or Town

StateZip Code



Federal State

Indian Tribe




w-hw7-09

1 of 2

September 03
















Figure 1EPA ID form



Moving














All rights reserved



VIII-B1)



















All rights reserved





































All rights reserved




Clean Air Act Fee


























































All rights reserved












HazardousWaste


2904





















All rights reserved


Step 4

UsedOil

UsedOil


















for leaks







All rights reserved















































All rights reserved

































All rights reserved


































All rights reserved




























Ohio Ohio EPA (614) 644-2917






All rights reserved



























2 Tour the facility







All rights reserved


Step 7











bull antifreeze

























All rights reserved


Step 7






































bull 19 Other




All rights reserved






























All rights reserved























All rights reserved































Report the spill to





All rights reserved

































10 Train employees





All rights reserved





























All rights reserved

Train Employees


























All rights reserved

Train Employees













Step 10Keep Records

















All rights reserved

Keep Records









und




TopicsSpecial


All rights reserved

Notes










All rights reserved


















All rights reserved


























All rights reserved

Reducing Waste























All rights reserved

Parts Washers








bull engine oil



bull hydraulic oil





bull peat

bull corn cobs


bull sawdust

bull wood chips

bull paper wipes






bull cutting oil


bull grease

bull brake fluid



bull granular clay



bull cork

bull pumice

Topic 5Used Oil


All rights reserved

Used Oil














Topic 5Used Oil










All rights reserved

Used Oil
















Topic 5Used Oil





The tank must












The tank must






actions (6)


All rights reserved

Used Oil


















Total Halogens

10000 ppm maximum



Topic 5Used Oil











All rights reserved

Used Oil















Topic 5Used Oil








All rights reserved

Electronic Waste




















All rights reserved

Electronic Waste
















bull pesticides and










All rights reserved

Universal Waste



















Appendices


All rights reserved

Appendix A MSDS




SECTION I



PIGMENTS BASE METAL

CATALYST ALLOYS


















CONDITIONS TO AVOID









Appendix A MSDS


All rights reserved




SAMPLE NUMBER 480






Lead 50 50

Cadmium 004 10




















All rights reserved




























All rights reserved





















Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

____

____

____

____

____

____

____

____

____

____

____

____

____

____

____

___

(are

a)

1D

rum

s cl

osed

2

Dru

ms

labe

led

corr

ectly

3

Labe

ls v

isib

le

com

plet

e

4St

orag

e tim

e lim

its o

kay

5A

ccum

ulat

ion

limits

oka

y6

Spill

s or

leak

s

7C

rack

s in

flo

or

8O

utdo

or

area

sec

ure

9 O

utdo

or

igni

tabl

essh

aded

Insp

ecti

onD

ate

Prob

lem

s no

ted

duri

ngin

spec

tion

V

isua

l In

spec

tion

by

(si

gn)

Cor

rect

ive

Act

ion

Dat

eC

orre

ctiv

e A

ctio

nC

orre

ctiv

e A

ctio

nby

(

sign

)


All rights reserved










August 4 1999











All rights reserved

Emergency Planfor


________________________________________________________________

Mailing Address __________________________________________________

________________________________________________________________

Telephone ( ________ ) _______________________________

EPA ID ___________________________________________



Date _____________________





TO ________________________________________________

________________________________________________

________________________________________________

________________________________________________

FROM ________________________________________________

________________________________________________

________________________________________________

________________________________________________




Sincerely



All rights reserved

N





= Evacuation Route



Address ______________________________________________________________________________________

Contact _____________________________________________ Phone _________________________________


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production



All rights reserved



Fire Department _________________________

Police _________________________

Hospital _________________________


1- (800) 422-0798




Fire alarm ________________________________________________________________________________________________________________________________________________________________________________





Employee Name_____________________________________

Job Title ____________________________________________




_________________________________________________________________________________________

_________________________________________________________________________________________



Instructor Name __________________________________________________









All rights reserved




Index Notes


All rights reserved

Index

T


U

Universal waste 79

V


W


B


C


D


E



I


L



M


O

Oil used 7 13 14 17 18 20 21 26 27 34 55 66 67-75

P


S




(800) 657-3757



















(800) 985-4247



Cover

Purpose

Table of Contents

Introduction

Steps to Compliance













Special Topics


Lead-Acid Batteries

Reducing Waste

Parts Washers

Used Oil

Electronic Waste

Universal Waste

Appendices

MSDS Sample

Lab Results Sample



LDR Policy




Index

HW Contacts


All rights reserved

Evaluate Waste











All rights reserved


rtSta

rtSta

rtSta

rtSta

rt

Does

the

wast

e co

ntai

n m

ore

than

50

ppm

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The

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2200

220

0




ound

s of

haz

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us w

aste

mon

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All rights reserved


Step 2



Date Received







II below)




C Inactivation




ny)


Street

Street (Continued)

City or Town

StateZip Code

County Name








Name (Last)

(First)

Job Title


VI Contact Address

Street or PO Box

City or Town

StateZip Code

VII Ownership


m Section II above)


City or Town

StateZip Code



Federal State

Indian Tribe




w-hw7-09

1 of 2

September 03
















Figure 1EPA ID form



Moving














All rights reserved



VIII-B1)



















All rights reserved





































All rights reserved




Clean Air Act Fee


























































All rights reserved












HazardousWaste


2904





















All rights reserved


Step 4

UsedOil

UsedOil


















for leaks







All rights reserved















































All rights reserved

































All rights reserved


































All rights reserved




























Ohio Ohio EPA (614) 644-2917






All rights reserved



























2 Tour the facility







All rights reserved


Step 7











bull antifreeze

























All rights reserved


Step 7






































bull 19 Other




All rights reserved






























All rights reserved























All rights reserved































Report the spill to





All rights reserved

































10 Train employees





All rights reserved





























All rights reserved

Train Employees


























All rights reserved

Train Employees













Step 10Keep Records

















All rights reserved

Keep Records









und




TopicsSpecial


All rights reserved

Notes










All rights reserved


















All rights reserved


























All rights reserved

Reducing Waste























All rights reserved

Parts Washers








bull engine oil



bull hydraulic oil





bull peat

bull corn cobs


bull sawdust

bull wood chips

bull paper wipes






bull cutting oil


bull grease

bull brake fluid



bull granular clay



bull cork

bull pumice

Topic 5Used Oil


All rights reserved

Used Oil














Topic 5Used Oil










All rights reserved

Used Oil
















Topic 5Used Oil





The tank must












The tank must






actions (6)


All rights reserved

Used Oil


















Total Halogens

10000 ppm maximum



Topic 5Used Oil











All rights reserved

Used Oil















Topic 5Used Oil








All rights reserved

Electronic Waste




















All rights reserved

Electronic Waste
















bull pesticides and










All rights reserved

Universal Waste



















Appendices


All rights reserved

Appendix A MSDS




SECTION I



PIGMENTS BASE METAL

CATALYST ALLOYS


















CONDITIONS TO AVOID









Appendix A MSDS


All rights reserved




SAMPLE NUMBER 480






Lead 50 50

Cadmium 004 10




















All rights reserved




























All rights reserved





















Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

Insp

ecti

on l

og f

or

____

____

____

____

____

____

____

____

____

____

____

____

____

____

____

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(are

a)

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s cl

osed

2

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ms

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corr

ectly

3

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ls v

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com

plet

e

4St

orag

e tim

e lim

its o

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5A

ccum

ulat

ion

limits

oka

y6

Spill

s or

leak

s

7C

rack

s in

flo

or

8O

utdo

or

area

sec

ure

9 O

utdo

or

igni

tabl

essh

aded

Insp

ecti

onD

ate

Prob

lem

s no

ted

duri

ngin

spec

tion

V

isua

l In

spec

tion

by

(si

gn)

Cor

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ive

Act

ion

Dat

eC

orre

ctiv

e A

ctio

nC

orre

ctiv

e A

ctio

nby

(

sign

)


All rights reserved










August 4 1999











All rights reserved

Emergency Planfor


________________________________________________________________

Mailing Address __________________________________________________

________________________________________________________________

Telephone ( ________ ) _______________________________

EPA ID ___________________________________________



Date _____________________





TO ________________________________________________

________________________________________________

________________________________________________

________________________________________________

FROM ________________________________________________

________________________________________________

________________________________________________

________________________________________________




Sincerely



All rights reserved

N





= Evacuation Route



Address ______________________________________________________________________________________

Contact _____________________________________________ Phone _________________________________


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production


Annual Production



All rights reserved



Fire Department _________________________

Police _________________________

Hospital _________________________


1- (800) 422-0798




Fire alarm ________________________________________________________________________________________________________________________________________________________________________________





Employee Name_____________________________________

Job Title ____________________________________________




_________________________________________________________________________________________

_________________________________________________________________________________________



Instructor Name __________________________________________________









All rights reserved




Index Notes


All rights reserved

Index

T


U

Universal waste 79

V


W


B


C


D


E



I


L



M


O

Oil used 7 13 14 17 18 20 21 26 27 34 55 66 67-75

P


S




(800) 657-3757



















(800) 985-4247



Cover

Purpose

Table of Contents

Introduction

Steps to Compliance













Special Topics


Lead-Acid Batteries

Reducing Waste

Parts Washers

Used Oil

Electronic Waste

Universal Waste

Appendices

MSDS Sample

Lab Results Sample



LDR Policy




Index

HW Contacts