HENNEPIN COUNT Y
H a z a r d ou s Wa s te G ene r ato r N ew s l ette r
Winter 2011
Assisting Generators with Hazardous Waste Management
In this issue:
Five Common Violations...............2
Five Most Common Hazardous Waste Violations
Enforcement Outcomes................3
The commercial hazardous waste unit inspects generators in Hennepin County to determine
compliance with the hazardous waste regulations and laws defined in Minnesota Rules chapter
7045, Minnesota statute and Hennepin County Ordinance 7. Listed below are the most common
hazardous waste violations observed by inspectors during compliance inspections.
Requirements for Operation.......6
Industrial Stormwater Permit......4
Resources...........................................7
2012 License Renewal...................8
1.Waste Evaluation
(Minn. Rule 7045.0214)
• Violation: Disposing of unevaluated pharmaceutical waste as infectious waste or trash.
Tip – If you opt to evaluate waste pharmaceuticals individually, we recommend maintaining
a spreadsheet to show how each pharmaceutical is or is not a hazardous waste.
For more information or to obtain a template of the evaluation spreadsheet, please
call 612-348-3777 and ask for the environmentalist-on-call.
• Violation: Disposing of unevaluated or inadequately evaluated spent parts washing
solution as nonhazardous waste.
Tip – You can evaluate your spent parts washer solvent or assume it is hazardous. Many companies
have been fined because they assumed their waste was nonhazardous but found the waste was hazardous
after inspectors ordered tests to be done. We recommend you test your waste (for flashpoint,
pH, RCRA metals, VOCs) to verify it is nonhazardous. You are also required to reevaluate the waste when
you switch to a new cleaning solvent (e.g., high-flash to low-flash solvent). [continued on page 2]
Hennepin County
Environmental Services
1
Five Common Violations (continued)
2.Labeling – Hazardous Waste (Minn. Rule 7045.0292) and Used Oil (Minn. Rule 7045.0855)
•Violation: Smudged waste description is not legible and
•Violation: The label is missing the
there is no accumulation start date: however, it is correctly
word “Used” before “Oil Filters.”
labeled “Hazardous Waste.”
Tip – Correct labeling options for
Tip – Hazardous waste containers must be labeled
used oil include:
with the words “Hazardous Waste,” a description of • Used Oil
• Used Oil Sorbents
the waste and the accumulation start date.
• Used Oil Filters
• Used Oil Rags
3.Open Container – Hazardous Waste (Minn. Rule 7045.0626) and Used Oil (Minn. Rule 7045.0855)
•Violation: Though funnel is
covered, it is not designed
with a closure device to
withhold contents if
overturned.
•Violation: Open funnel.
When done adding waste
to the drum, this funnel
must be removed and bung
screwed shut.
•Correct: Plastic funnels are
removed from the container
and the bungs (closure device)
are secured.
•Correct: This is a closed
container because the
funnel lid is closed and
latched.
4.Universal Waste-Lamp Management (Minn. Rule 7045.1400)
•Violation:
Lamps
are not
stored in
containers.
•Violation:
Containers
are not
sized
accordingly, closed or
labeled.
•Violation: Broken lamps are not secured
shut in an airtight container to prevent a
mercury release. Be aware that mercury
is odorless and can be highly volatile
at room temperature. If consumed or
inhaled, it will accumulate in human fat
as a more toxic organomercury compound.
• Correct: Used lamps are stored in closed containers and in a manner to prevent breakage.
Containers are properly labeled “Universal Waste – Lamps” or “Used Lamps” or “Waste Lamps.”
5.Record Keeping (Minn. Rule 7045.0294)
•Violation: Missing •Violation: Missing •Violation: Missing
waste evaluation
training records for
disposal records from
records. Evaluation
hazardous waste
the last three years.
records not kept at
personnel working
Disposal records
the licensed site or
at a company that
must include three
made easily availis a Small or Large
facility-signed maniable for inspection.
Quantity Generator
fests for all hazardous
waste shipments,
used lamp receipts,
battery receipts, electronics receipts, etc.
Tip – Keep your hazardous waste records organized in
three-ring binders or folders. If you have a lot of
records, maintain a separate binder or folder for
each year. Make sure back-up personnel know
the location of your
records in case you
are absent when
your company is
asked to present
them. If you keep
your records locked up in an office or cabinet,
be sure the back-up personnel still have access to
those records.
Five more common violations:
6. Failure to distribute initial and final manifest copies to proper address.
7. Failure to update annual hazardous waste management plan summary.
8. Failure to conduct or document weekly hazardous waste container inspections.
9. Failure to update or post SQG emergency telephone posting.
10.Failure to update LQG contingency plan.
2
Enforcement outcomes
The following table contains a listing of recently resolved civil and criminal cases,
including fines and penalties assessed by the U.S. Environmental Protection Agency,
the Minnesota Pollution Control Agency or Hennepin County. All of the cases
originated from violations found during hazardous waste or tank inspections at businesses in Hennepin County. These records are published to reinforce the importance
of compliance with hazardous waste and tank regulations. Fines and penalties vary
depending on the circumstances. Enforcement outcomes may also include corrective
actions, restitution, community service, supplemental environmental projects, court
costs, probation and imprisonment. If you have any questions regarding compliance
with environmental regulations or wish to report a violation, call 612-348-3777 and
ask for the environmentalist-on-call or send an email to [email protected].
Case Name
Violation
City
Size Fine
Ace label systems inc.
Failure to label a container with the words
“Hazardous Waste” and a clear description;
Failure to close hazardous waste container;
Failure to conduct and document weekly
inspeciations of hazardous waste storage
containers.
Golden Valley
VSQG
dermatology specialists
pa – edina
Failure to submit or properly update license
renewal application (hazardous waste
management plan summary).
Edina
VSQG
$608
garlock equipment co.
Failure to make records easily available.
Plymouth
SQG
$278
hawkins inc.
Failure to operate to prevent a release.
Minneapolis
LQG
$826
hex graphics
Failure to submit or properly update license
renewal application (hazardous waste
management plan summary).
Eden Prairie
VSQG
$478
interplastic corp. thermoset
Operating as a storage and treatment facility
without a permit; Shipping hazardous waste
without a manifest; Failure to operate facility
to prevent a release; Failure to evaluate waste;
Failure to label hazardous waste with an
accumulation start date and the words “Hazardous Waste;” Failure to label satellite containers
with the words “Hazardous Waste” and a clear
description; Failure to close satellite hazardous
waste container; Failure to close and label used
oil containers.
Minneapolis
LQG
$15,000;
$263,000 in
supplemental
environmental
projects for the
Minneapolis
and Vadnais
Heights facilities
lifetime fitness
Failure to submit or properly update license
renewal application (hazardous waste
management plan summary).
St. Louis Park
VSQG
$575
michaelson precision auto
repair
Operating without a hazardous waste
generator license
Minneapolis
VSQG
$493
penney (JC) co. – Ridgedale
Failure to submit or properly update license
renewal application (hazardous waste
management plan summary).
Plymouth
VSQG
$583
Rainbow foods #8858
Operating without a hazardous waste
generator license
Plymouth
VSQG
$575
$1,433
Recognizing
generator inspections
with no violations
Generators deserve recognition for
having a hazardous waste program that is in
full compliance with hazardous waste rules
and regulations. This list of generators not
only shows that it is possible for any size
generator to be in full compliance at the time
of the inspection but that it also happens
with some frequency. The following list of
Hennepin County generators had inspections
since spring 2010 where no violations were
observed by the inspector.
No Violations:
●A
One Outdoor Power Inc Hamel
VSQG
PlymouthSQG
●Arndt (James F) DDS
Minneapolis VSQG
●C & S Blacktopping
Rogers
VSQG
●Colon and Rectal Surgery
Associates LTD
Edina
VSQG
●Con Agra Foods
Maple Grove VSQG
●Consolidated Container
Company LLC
Minneapolis LQG
●Courtney Truck Service
Eden Prairie VSQG
●Eaton Group
Eden Prairie VSQG
●Excel Metal Finishing
Minneapolis SQG
●GEII Global Onsite Service Minneapolis
SQG
●Greatbatch Medical
Minneapolis SQG
●Lakeland Vet Pharmacy
Eden Prairie VSQG
●Mail Handling Inc
Eden Prairie
SQG
●Northern Tractor
Osseo
VSQG
●Sam’s Distribution
Center 6697
Bloomington VSQG
●Sarge’s Autobody
Crystal
VSQG
●Southdale Allergy and
Astma Clinic
Edina
VSQG
●St. Jude Medical
Minnetonka
SQG
●AGA
GENERATOR SIZE CLASSIFICATIONS
stremel manufacturing llc
Failure to evaluate waste.
Minneapolis
VSQG
$829
MIG - Minimal Generator
vartan engineering llc
Failure to evaluate waste.
Osseo
VSQG
$828
VSQG - Very Small Quantity Generator
Generates 220 lbs. or less per month of hazardous waste
westerN waterproofing
Failure to evaluate waste; Failure to properly
update license renewal application (hazardous
waste management plan summary); Failure to
make records easily available.
Minneapolis
VSQG
$1,028
Generates 10 gallons or less per year of hazardous waste
SQG - Small Quantity Generator
Generates more than 220 lbs. and less than 2,200 lbs. per month
of hazardous waste
LQG - Large Quantity Generator
Generates 2,200 lbs. or more per month of hazardous waste
3
Industrial Stormwater Permit:
Compliance and Monitoring Begins
These stories are from the Industrial Stormwater News
e-newsletter. Sign up to receive the newsletter at
www.pca.state.mn.us/enzqa74
The Industrial Stormwater Multi-Sector
General Permit from the Minnesota
Pollution Control Agency (MCPA) requires
industrial facilities with potentially hazardous materials, processes or wastes to
manage their stormwater runoff. The new
permits were issued about one year ago,
and many facilities are required to begin
bench monitoring this year.
For information on the Industrial Stormwater Permit, see the Steps to Compliance
at www.pca.state.mn.us/enzqa74.
One year later: Lessons learned
Since the Industrial Stormwater MultiSector General Permit was issued in April
2010, the Industrial Stormwater Program
offers the following compliance tips for
permittees based on the lessons staff have
learned during the past year:
Annual report
• Monthly inspections: monthly inspections are required for all facilities and
the results must be summarized within
the annual report. Be sure to conduct
them monthly and use the MPCA’s Site
Inspection Form. Read parts III.F of the
Multi-Sector General Permit for more
information.
• Most facilities have sector-specific
inspection requirements, and permittees need to review Part VII of the permit to comply with these requirements.
Visit Step 7: Sector-Specific Requirements in the Steps to Compliance for
more information.
• Newly listed impaired waters: Every
facility must conduct an annual review
to determine if they are discharging to
a newly listed impaired water. Visit the
Map of Impaired Waters at www.pca.state.
mn.us/nwqh94c and type in your facility
address to locate nearby impaired waters.
4
• Monitoring: The annual report does not
require any monitoring information to
be provided; those details are provided
either on the Stormwater Monitoring
Report Form for Benchmark Monitoring or Discharge Monitoring Report
Form for Effluent Monitoring.
Monitoring
• About 2 percent of all permittees have
effluent monitoring requirements. If
your facility is one of them, effluent
monitoring is a once-per-year requirement for every calendar year of the
permit’s term. In 2010, a number of
facilities did not send in Discharge
Monitoring Report forms or sampled
the wrong parameters. Visit Step 7:
Sector-Specific Requirements in the
Steps to Compliance for more information or to determine whether your
facility is required to conduct effluent
monitoring.
Sector-specific requirements
When collecting samples:
• Safety is the highest priority. Do not
endanger yourself to collect stormwater
samples.
• Take notes of site conditions, such
as weather, soil, discoloration in the
stormwater discharges, etc., right before
or during sample collection.
• Make sure samples are collected when
stormwater is flowing; stagnant water
will not give a representative sample.
• Keep the sample jar lid in a place where
it won’t be accidentally contaminated.
Do not place it on the ground or in
your pocket as it could contaminate
your sample.
For additional information about
stormwater monitoring, including what
parameters to monitor for and when,
visit the Industrial Stormwater Program
webpage at www.pca.state.mn.us/enzqa74 and
view the following tools:
• Facility owner/operators may be unaware that their industrial sector has
permit requirements pertaining to that
sector. Visit Step 7: Sector-Specific Requirements in the Steps to Compliance
for more information.
• Monitoring Guidance Manual
Monitoring tips and suggestions
In response to requests for more compliance information available electronically,
increased accessibility and data transparency, the MPCA has expanded its online
information services.
For many facilities, benchmark monitoring
begins this year. If you have not already
started monitoring at your facility, now is
the time to prepare. The better prepared
you are, the more successful your chances
of collecting samples correctly.
Before collecting samples:
• Contact your preferred lab to make
sure they can accept and process
your samples.
• Consider conducting a mock collection
opportunity (without actually collecting
a sample). This simple step can greatly
improve your actual sample collection
process.
• Industrial Stormwater Information
Access
Improved website offers
expanded information access
View all of the industrial stormwater
permit information at www.pca.state.mn.us/
enzqa74.
The “Industrial Stormwater Multi-Sector
General Permit Electronic Information
Access” offers the ability to:
• View a list of applicants who applied for
permit coverage or certified for the No
Exposure Exclusion (sortable by county,
sector, city, facility name and other
search options).
• View and confirm industrial stormwater application information, and
More e-government
services in the works
Hennepin County Environmental
Services is actively working to develop
and promote the delivery of information
and services through web-based
operations and transactions.
if necessary, download the forms to
modify/change application data or
terminate permit coverage altogether.
• View facility-specific monitoring calendars, allowing the permittee to understand exactly when stormwater samples
must be collected and submitted.
• Download a copy of the permit coverage card and/or cover letter.
• View monitoring data results, once
submitted.
You may have already experienced some
of these services, for example:
• Inspectors encouraging businesses
to submit inspection responses
via email.
• Re-prints of Bill Summaries and/or
Management Plan Summaries and
Licenses sent to you electronically.
• License forms and self-audit forms
available from our website.
• Online registration for generator
training opportunities.
Permittees who want a paper copy of the
monitoring report forms mailed to them
or have questions about this new tool can
call 651-757-2119 or email iswprogram.pca@
state.mn.us.
Compliance Update:
No Exposure Flyovers
Recently, MPCA staff conducted industrial
stormwater compliance inspections from
an airplane. The recent fly-over inspections targeted No Exposure certifiers. The
MPCA found that many of the facilities
observed do have exposure and do not
meet the No Exposure certification requirements. Facing potential enforcement
action, these facilities will have to either
make facility modifications to meet and
maintain the No Exposure exclusion status
or apply for permit coverage.
More fly-over inspections are being
planned. If your facility has certified for
No Exposure, review the No Exposure:
Qualifying For and Maintaining the
Exclusion factsheet to ensure you’re
meeting all requirements.
These facilities claimed to be eligible for the No
Exposure certification, which excludes them from the
requirements of the Industrial Stormwater Multi-Sector
General Permit. However, the activities and materials
being conducted outdoors in the photos (circled in red
are examples of exposure that require permit coverage.
Environmental Services has moved
Hennepin County Environmental Services has moved to the 701 Building in downtown Minneapolis. As of October 24, 2011, our new location is:
701 Fourth Avenue South, Suite 700, Minneapolis, MN 55415-1842
We will be working hard to increase
our e-government services in the years
to come. Some of the things we’re
considering and hope to deliver
include:
• Having our entire generator training presentation available online as a
series of interactive training modules.
• Ability to request a copy of your
existing generator license, Management Plan Summary or Bill Summary
online.
• Completion of license renewal
applications online.
• Electronic submission of license
modifications (reporting new
waste streams).
• Electronic payment of license fees.
We know that we have a lot of work
to do. However, we also recognize the
value that our customers place on the
ease and convenience that enhanced
e-government services will provide.
Generator forms and self-audits have been updated with our new address.
Please note that the mailing address for VSQG manifests have not changed (they
should be sent to the Hazardous Waste Manifest Program, Mail Code L609,
300 South 6th Street, Minneapolis, MN 55487).
Our business hours (8 a.m. to 4:30 p.m.), email addresses, phone numbers and
website addresses have not changed.
For more information about our new location, visit www.hennepin.us/701Building.
5
Requirements for operating an onsite treatment system
in accordance with Minn. R. 7045.0655 subp. 3 and 4)
Onsite treatment systems are designed to
treat hazardous waste by removing a
hazardous waste constituent (ignitable,
corrosive, oxidizer, reactive or toxic) prior
to sewering the waste. Some common
types of onsite treatment systems include:
• Dental amalgam separators that remove
mercury amalgam from wastewater at
dental clinics.
This unit was being
inspected weekly, but a
spill occurred in between
inspections. A visual check
of the unit daily would
have caught this spill so it
could have been cleaned
up immediately.
• Silver recovery units that recover silver
from the film developing process.
• Elementary neutralization units that
adjust the pH of wastewater.
• Wastewater treatment systems to
remove metals and other pretreatment
systems that remove a hazardous waste
constituent.
Onsite treatment system requirements
All types of onsite treatment systems
must be:
• Operated and maintained according
the manufacturer’s instructions.
• Inspected on a regular basis for
deterioration, discharges or malfunctions that may lead to a release of
hazardous waste to the environment.
The inspection must be documented
and available for review during a
hazardous waste inspection.
Onsite treatment system inspections
The inspection schedule will identify the
timing for determining the condition of
the treatment equipment and its proper
operation. The frequency of inspection
may vary for different parts of the treatment system. For example, an overflow
device might be tested on a monthly basis
and a pH probe might be calibrated yearly.
The inspection schedule should be based
on the rate of possible deterioration of
the equipment and the probability of an
environmental or human health incident
if any deterioration or malfunction or
operator error goes undetected between
inspections.
Staff conducting inspections should be
trained on what areas of the system to
check for releases or deterioration.
Parts of the system that should be
inspected include, but is not limited to,
piping, tanks, valves, fittings, pumps,
safety devices, monitoring and emergency
equipment, etc.
• Date (including year) and time of
inspection.
• Any observations made and the date
and nature of any repairs as a result
of the inspection.
6
During routine hazardous waste inspections our staff has observed mercury
amalgam separators not being inspected
or operated correctly. In some cases, leaks
from the pre-treatment system are occurring due to operator error when changing
out a filter.
A spill occurred
from this system
while the filter was
being changed. To
prevent spills,
follow the
manufacturer’s
instructions when
changing out filters.
If you do have a spill while servicing your
unit or from a malfunction, you must make
sure that it is cleaned up immediately.
The spill residues must be evaluated and
disposed of appropriately. Check with your
manufacturer if you are having regular
problems with leaks or other issues with
your treatment system.
If you don’t already have one, you must
develop an inspection schedule and log.
The inspection schedule and log must
have:
• Name of the employee conducting
the inspection.
Dealing with leaks and spills
Per the manufacturer’s instructions, this system’s
filter should be changed weekly. Make sure to follow
manufacturer’s instructions when establishing an
inspection and maintenance schedule.
Operating your treatment system within the
manufacturers’ guidelines and conducting
and documenting inspections and repairs of
the treatment system will help you prevent
releases of a hazardous waste and protect
human health and the environment.
Resources
Hennepin County
Environmental Services
Environmental Audit Program
Clean Air Minnesota
www.pca.state.mn.us/programs/audit_p.html
651-297-8664
Commercial Hazardous Waste Unit
Offers self-audit programs and issues
the Green Star Award.
www.environmental-initiative.org/projects/
clean-air-minnesota
612-334-3388, ext. 109
www.hennepin.us/hwgenerators
612-348-3777
We license and inspect commercial
hazardous waste generators and facilities.
We provide disposal information, regulatory interpretations and other technical
assistance to the generators and facility
community.
Environmentalist-on-call
Our technical staff is available to answer
questions on hazardous waste management. Call 612-348-3777 and ask for the
environmentalist-on-call. Hennepin Business Waste Reduction
Program – www.hennepin.us/businesswaste
612-596-0993
Non-regulatory technical assistance is
available to businesses for waste reduction,
recycling and organics recycling programs.
Training opportunities
Hennepin County Environmental Services
offers free hazardous waste training designed
to introduce hazardous waste management.
Topics include waste evaluation, labeling and
storage of hazardous wastes, license applications, selecting transporters and disposers,
record keeping, emergency planning, waste
minimization and pollution prevention.
Training for Spring 2012 have not been
set. For more information on training sessions and to register, visit www.hennepin.us/
hwgenerators or call 612-348-3777 and
ask for the environmentalist-on-call.
Minnesota Pollution
Control Agency
Library of hazardous wasterelated publications
www.pca.state.mn.us/waste/pubs/business.html
An extensive list of MPCA publications,
from hazardous waste identification to
industry and waste specific information.
Pollution Prevention and Sustainability
Program – www.pca.state.mn.us/p2/index.html
651-296-7783
Offers pollution prevention information,
assistance and grants.
Small Business Environmental
Assistance Program
www.pca.state.mn.us/index.php/topics/smallbusiness-environmental-assistance-program/smallbusiness-environmental-assistance-program.html
651-282-6143
Provides free, non-regulatory, confidential
environmental assistance to small
businesses. They also offer low-interest
loans to small businesses to finance
environmental projects.
Minnesota Technical
Assistance Program
Minnesota Technical Assistance Program
(MnTAP) – mntap.umn.edu
612-624-1300
Offers non-regulatory, free phone and site
assessments, pollution prevention and waste
minimization information, and resources
tailored to different industry sectors. Pollution prevention
Pollution Prevention Resource Exchange
www.p2rx.org
Coordinates voluntary industry-based
emission-reduction projects
Water
Sanitary sewers
Metropolitan Council Environmental
Services – www.metrocouncil.org/water
651-602-4704
City of Rogers
www.cityofrogers.org/water-a-sewer
763-428-2253
Stormwater
Minnesota Pollution Control Agency
www.pca.state.mn.us/water/stormwater/
index.html
651-296-6300
Water conservation
WaterWiser – www.waterwiser.org
Disposal resources
Resourceful Waste Management Guide
for Businesses – rethinkrecycling.com/business
• A to Z Materials Management
Directory/Disposal Options
• List of items banned from the garbage
• 8 Step Hazardous Waste Management
Guide
• Recycling drop-off centers and
pick-up service providers
Hennepin County
Environmental Protection Agency
www.hennepin.us/hazwastedisposalcompanies
www.epa.gov/p2
List of hazardous waste transporters,
facilities, consultants and brokers.
Air
Minnesota Pollution Control Agency
www.pca.state.mn.us/air/index.html
651-296-6300
Offers air quality information, regulations
and assistance programs.
Minnesota Materials Exchange
Program – www.mnexchange.org
Connects businesses that have quality
reusable goods with those who can use
them. Search the program’s website for
available and wanted materials, including
boxes, drums, office furniture and supplies, packing materials and pallets. Most
items are free or available at low cost.
7
HENNEPIN COUNT Y
H azardo u s Waste G enerator N ewsletter
Winter 2011
In this issue:
Five Common Violations...............2
Enforcement Outcomes................3
Industrial Stormwater Permit......4
Requirements for Operation.......6
Resources...........................................7
2012 License Renewal...................8
2012 License Renewal
2012 hazardous waste license applications for
non-minimal generators were sent to the mail
contact for each business by mid-November. If
your generator size is LQG, SQG or VSQG, you
should have received your 2012 Management
Plan Summary (MPS) by now. The MPS should
be reviewed, updated and returned to us by
December 15, 2011.
Please ensure that someone at your business
is reviewing all of the information on the MPS
and making adjustments that accurately reflect
your waste management practices. Someone
representing your business must also sign off
on the MPS, certifying that the information has
been reviewed and updated as necessary.
To ensure prompt processing of your completed
2012 MPS, please return it in the envelope provided. More than forty businesses were issued
a citation for failure to submit application for
license in 2011. This particular citation carries
a $500 fine plus court fees. As you can see,
not returning your MPS on time can cost your
company additional time and money.
If you need help understanding your MPS or the
license renewal process, call 612-348-3777 and
ask to speak with the environmentalist on call.
PERMIT NO. 3273
MINNEAPOLIS, MN
701 Fourth Avenue S., Suite 700
Minneapolis, MN 55415-1842
612-348-3777
PAID
U.S. POSTAGE
Environmental Services
PRSRT STD
Hennepin County