This Hazardous Waste Management Plan is designed to help the St. Cloud School District comply with the Resource Conservation Act (RCRA).
The RCRA was passed by congress in 1986 and provides cradle to grave authority to control hazardous waste from their generation to their ultimate disposal.
It is the intent of RCRA to have the nation's hazardous waste management program administered by the state, with only minimal oversight from the federal government. In the state of Minnesota, RDRA is administered by the Minnesota Pollution Control Agency (MPCA). The state program is equivalent, and in some cases more stringent, than the federal program.
This plan has been designed to comply with the following state and federal regulations:
The Plan is intended to be non-site specific and may need to be modified to adapt to specific conditions at each site or school district. In addition, the St. Cloud School District is responsible for implementation, enforcement and updating their plan. It is recommended that the Plan be reviewed and updated annually. The actual use of the Plan is limited to Resource Training & Solutions and the St. Cloud School District it represents.
Plan Review and Updated Report
Program review and changes are documented below. Documented reviews indicate that the plan continues to meet the needs of the District, or has been modified to do so more effectively.
|5/16/2016||Changed on-site and off-site emergency response coordinator contact information.
Updated appendix B web link
The St. Cloud School District which generates waste materials must determine if the waste is hazardous as defined by the RCRA. Determining if the waste is subject to RCRA Subtitle C is a three-step process:
Under RCRA Subtitle C, "solid waste is defined as: any garbage, refuse, sludge from a waste treatment plant or air contaminant treatment facility, and other discarded waste material, solid, liquid, semi-solid or contained gaseous materials resulting from industrial, commercial, mining and agriculture operations and from community activities, but does not include, hazardous waste; animal waste used as fertilizer; earthen fill, boulders, rocks, sewage sludge; solid or dissolved material in domestic sewage or other common pollutants in water resources such as silt dissolved or suspended solids in industrial waste water effluents or discharges which are point sources subject to permits under section 402 of the Federal Water Pollution Control Act, as amended, dissolved materials in irrigation flows; or source, special nuclear, or by-product materials as defined by the Atomic Energy Act of 1954 as amended" [Minnesota Statutes Chapter 116 (06).
The regulation also encompasses materials that are recycled in a manner constituting disposal including land application, burning for energy recovery, reclamation, speculative accumulation, storage, or treatment before recycling. Materials that are burned or incinerated are also regulated.
Material that fits the definition of solid waste may be regulated as a solid waste under SARA Subtitle III if it poses a threat to human health or the environment. The U.S. EPA has listed some wastes which are known to be hazardous. The U.S. "listed wastes" are found in Appendix C.
If a substance is not on the list, it does not mean it is not "hazardous". It could be classified as a "characteristic waste." Waste that exhibits one or more of the characteristics of Subpart C (ignitability, corrosivity, reactivity, or toxicity) are listed as hazardous waste. The criteria for identifying the characteristics of a hazardous waste are found in Appendix D.
To determine if an unknown waste is hazardous, listed waste or a characteristic waste, a sample of the waste must be submitted to a certified laboratory for testing and analyzes. Flow diagrams depicting the definition of a solid waste and definition of a hazardous waste are found in Appendix B.
A generator is defined as a person or site whose act or process produces a hazardous waste, or whose act causes a hazardous waste to become subject to regulation. The amount of waste generated per month dictates whether a generator is a large quantity or a small quantity generator. A large quantity generator is a generator that generates over 1,000 kilograms (kg) of hazardous waste a month, or more than 1 kg of acute hazardous waste per month, or more than 100 kg of any residue or contaminated soil, water, or other debris resulting from the cleanup of any acute hazardous waste into or on any land or water. A small quantity generator is one that generates more than 100 kg of hazardous waste and less than 1,000 kg of hazardous waste per month. However, if more than 1 kg of an acute hazardous waste is generated per month, the generator must follow the regulations pertaining to large generators. Generators of less than 100 kg per month of hazardous waste (very small quantity generators) are, under the state rules, subject to fewer administrative requirements.
Generator requirements include notification to the U.S. EPA that hazardous waste is generated, and includes specific storage, labeling, record keeping, and manifesting procedures.
School Districts (Generators) which generate hazardous waste must obtain a hazardous waste license for the state. An application must be obtained from the commissioner of the MPCA. Each generator who is producing hazardous waste must submit a licensed application to the commissioner by the due date specified by the commissioner. A generator fee must accompany the license application. The commissioner will issue a hazardous waste generator license upon approval of the application and payment in full of the generator fees.
A Hazardous Waste Management Checklist is found in Appendix E.
The St. Cloud School District must comply with the following requirements pertaining to storing hazardous waste in containers:
The St Cloud School District must have knowledge of identity and location of all hazardous waste stored in its facilities. The St Cloud School District shall contact its local fire department and will work closely with its local emergency response planning commission (LEPC) so that emergency responders are informed of the location and identity of stored hazardous substances and hazardous wastes.
School districts may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste in areas that are away from the school district's main storage are for an unlimited amount of time if the following requirements are met:
When accumulating hazardous waste on site in containers, the following requirements must be complied with:
If any unforeseen, temporary and uncontrollable circumstances arise, extensions of 30 days to accumulation periods may be granted if the St Cloud School District provides the MPCA with a written request for an extension and any supporting justification that may be necessary.
The St Cloud School District shall dispose of its hazardous waste by having a licensed TSDdf off-site facility handle its waste. The St Cloud School District shall not store its waste, once accumulated in full DOT compliance containers, for more than 180 days. If unforeseen, temporary or uncontrollable circumstances arise, the St Cloud School District shall solicit a 30-day extension by written request with the MPCA.
To minimize the possibility of an explosion, fire or any unplanned sudden or non-sudden discharge of hazardous waste or hazardous waste constituents to the air, land or surface water which could be harmful to human health or the environment, facilities shall be designed, constructed, maintained and operated with the consideration of these possibilities.
The St Cloud School District should have the following preparedness equipment available at their facilities:
The St Cloud School District shall store its hazardous waste in such a manner that no discharge of hazardous waste will occur.
Any St Cloud School District facility in control of hazardous waste that spills, leaks or otherwise escapes from a container, tank, or other containment system shall immediately notify the MPCA if the hazardous waste may cause pollution of the air, land, resources or waters of the state. This spill must be reported to the MPCA using the agency's 24-hour telephone number (800) 422-0798.
A hazardous material that leaks or spills must be recovered as rapidly and thoroughly as possible.
The St Cloud School District shall provide its employees with proper training including proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations and emergencies. A written Employee Right-To-Know program should be prepared which, at a minimum, describes the training, availability of health and safety information and labeling procedures. The training and Employee Right-To-Know should be in accordance with the Minnesota Employee Right-To-Know Standard, Chapter 5206.
The following emergency procedure requirements will be followed by the St Cloud School District:
In the event of a discharge or spill of hazardous waste, a fire or explosion or an imminent threat that has potential for damaging human health or the environment, the emergency coordinator or designee shall:
If there is a threat to human health outside the facility or when the St Cloud School District has knowledge that a spill has reached surface water, the School District must notify the national response center immediately. A report must be submitted which includes the following information:
Generators and small quantity generators are required by the EPA to prepare a written contingency plan.
The contingency plan establishes the steps that will be taken when an emergency situation develops involving hazardous waste. The requirements of the contingency plan are as follows:
Large and small quantity generators are generally exempted from most of the requirements of CFR 1910.120 (Hazardous Waste Operations and Emergency Response). The following discussion presents information on how certain parts may apply to the St Cloud School District. If the St Cloud School District has no emergency response team that responds to releases of hazardous waste or hazardous substances, then the School District must have an emergency action plan meeting the requirement of29 CFR 1910.38(a) (Employee Emergency Plans and Fire Prevention Plans). The requirements for the emergency action plan deal mainly with getting people safely out of an area in case of an emergency. The emergency action plan requirement is not specifically directed at generators of hazardous wastes but to all types of facilities. The plan does require specific escape route assignments and a description of the duties of some key employees in an emergency, but it does not deal with containing the release or making arrangements with outside agencies or contractors for assistance.
lf the St Cloud School District does have an emergency response team that responds to incidents involving hazardous waste only, then the School District must have an emergency response plan that meets the requirements of 29 CFR 1910.120 (P) (8). The intent is not to duplicate the RCRA required contingency plan, the contingency plan can be made part of the emergency response plan and used to meet some of it's requirements. Briefly, the minimum elements that the emergency response plan must address are as follows:
The St Cloud School District shall prepare its hazardous waste for transport by placing it in containers per DOT regulations 49 CFR Parts 171, 172, 173, and 178.
All hazardous waste must be packaged correctly if they are to be transported over public roads. The U.S. DOT requires the packaging to be compatible with the waste shipped as described in 49 CFR Part 173 - Shippers General Requirements For Shippings and Packagings. Each container must also meet the U.S. DOT specifications for that type of package. lf the container does not meet those specifications, the container itself will be marked with the specification number.
The St Cloud School District shall label and mark each package in compliance with DOT regulations [49 CFR Part 172] before transporting or offering hazardous waste for transportation off-site.
Each container must be marked with the following information:
For many hazardous wastes, the U.S. DOT requires a hazard label identifying the type of the waste. This label is diamond shaped and contains a logo for the hazard proposed by the waste. The purpose of the label is to help identify the hazard from a distance in an emergency. Available labels include: explosive, infectious substance, radioactive, poison, flammable liquid, oxidizer, organic peroxide, harmful (stow away from foodstuffs corrosive, flammable solid, flammable gas, non-flammable gas, dangerous when wet, combustible, and poison gas. Column 6 of the table presented in Appendix F will indicate whether the waste requires a label and, if required, the type of label.
The St Cloud School District must placard or offer the initial transporter the appropriate placards required by DOT regulations for hazardous materials (49 CFR Part 172, Subpart F) before transporting hazardous waste or offering hazardous waste for transportation off site.
The St Cloud School District shall coordinate the transportation of its hazardous waste by enlisting only licensed and experienced hazardous waste transporters. The St Cloud School District shall work with the initial transporter so the transporter properly placards the waste.
A uniform manifest form must be prepared by the St Cloud School District if it transports, or offers for transportation, hazardous waste for off-site storage, treatment, disposal or recycling, before the waste is transported.
The St Cloud School District must use the form of the state to which the waste is to be sent. If that state does not have a form, the Minnesota form is used. The manifest form consists of seven carbon copies, each labeled for the party who should receive it. It is the St Cloud School District's responsibility to provide enough copies of the manifest for each of the following: the School District; each transporter; the owner or operator of the designated facility; and, the MPCA.
On the manifest, the St Cloud School District must designate one facility which is permitted to handle the waste described on the manifest.
After completing the manifest, the St Cloud School District is required to sign the manifest, obtain the handwritten signature of the initial transporter and the date of the acceptance of the manifest, keep one copy, send one copy to the commissioner within five working days of the initial transporter's acceptance of the hazardous waste shipment, and give the transporter the remaining copies.
It is the St Cloud School District's responsibility to ensure the manifest accompanies the waste. The transporter must deliver the entire quantity of the waste to the designated facility. If the designated facility receives the hazardous waste accompanied by the manifest without significant discrepancies, the facility will sign and date the manifest, give the transporter one copy of the manifest and, within 30 days of delivery, send the copy to the St Cloud School District. If the St Cloud School District does not receive a signed copy of the designated facility within 35 days after the shipment, the designated facility owner should be contacted to determine the status of the hazardous waste. If the signed manifest is not received within 45 days after the shipment, the St Cloud School District must notify the MPCA and the U.S. EPA.
A copy of the uniform hazardous waste manifest is found in Appendix G.
The St Cloud School District shall keep a copy of each manifest for a period of at least three years from the date the School District receives a signed copy from the designated facility.
An annual hazardous waste activity report should be submitted by March 1 of each calendar year. This report covers the St Cloud School District's hazardous waste generation activities for the preceding calendar year.
The reports shall include the following:
Reports shall be sent to the MPCA Hazardous Waste Division/Business Assistance Unit at:
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155
St Cloud School District shall keep a copy of each annual report for a period of at least three years from the due date of the report.
Phone Number: 320 253-9370
Fax: 320 529-4341
St. Cloud Area School District 742
District Services Building
737 Osseo Avenue South
St. Cloud MN 56301
To be made by the Emergency Coordinator (or designated school district representative).
Code of Federal Regulations: Title 40 - Protection of the Environment: Chapter 1 - Environmental Protection Agency
(Click on a link below to view the Federal Standard)
Code of Federal Regulations: Title 40 - Protection of the Environment: Chapter 1 - Environmental Protection Agency
(Click on a link below to view the Federal Standard)