Hazardous Waste Management Plan
© 2018 Resource Training & Solutions
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:
- 40 CFR, Part 261 - Identification and Listing of Hazardous Waste
- 40 CFR, Part 262 - Standards Applicable to Generators of Hazardous Waste
- 29 CFR, Section 1910.120 - Hazardous Waste Operations and Emergency Response
- Minnesota Hazardous Waste Rules, Chapter 7045 - Hazardous Waste
- Minnesota Employee Right-To-Know Standard, Chapter 5206
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
Hazardous Waste Management Plan Review and Update 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.
Date Updates/Notes Reviewer 5/16/2016 Changed on-site and off-site emergency response coordinator contact information.
Updated appendix B web link
Hazardous Waste Determination
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:
- Is the material a "waste"?
- Is the material a "solid" waste?
- Is the material hazardous?
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.
Classification of Generators
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.
Storage in Containers
The St. Cloud School District must comply with the following requirements pertaining to storing hazardous waste in containers:
- Inspection of all areas where containers are stored and weekly inspection of all containers for evidence of leakage, corrosion or deterioration. Weekly inspection of spill containment structures will also be performed;
- Documentation of inspections should be kept in a log for at least three years from the date of inspection. The log shall contain the inspector's name, observation notes, and date and nature of any repairs or remedial action taken;
- The generator shall maintain weekly inspection logs;
- Containers shall be leak proof and in overall good condition;
- Upon identification and verification of a leaking container, the generator will promptly manage the leaking or spilled material. The hazardous waste will be transferred into a DOT compliant leak-free container;
- Containers holding hazardous waste shall be kept closed except when it is necessary to remove or add waste;
- The operator shall store containers which if exposed to moisture or direct sunlight, may create a hazardous condition or adversely affect the container's ability to contain the hazardous waste, in an area with overhead roofing or other covering that does not obstruct the visibility of the labels;
- Containers holding hazardous waste shall not be opened, handled or stored in a manner which may rupture the container or cause it to leak. Generator shall exercise care in opening, handling and storing its hazardous waste storage containers;
- Containers storing hazardous waste which are incompatible with any other waste materials stored nearby will be kept separate from them by a structure such as a dike, berm, wall or other device;
- The container must be lined with materials which will not react with or be incompatible with the hazardous waste to be stored;
- Each container will be clearly marked with the date that the current period of accumulation began. The generator will label and date mark each container when it either becomes full and/or when it is placed in the designated storage area. If a generator utilizes the satellite accumulation rule, it will use it as outlined below;
- Hazardous waste may not be placed in an unwashed container that previously held an incompatible waste or material unless the container has been properly cleaned so the placement of the waste material in the container does generate extreme heat or pressure, fire or explosion or a violent reaction. It shall not produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to threaten human health or the environment. It must not product uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosion. It must not damage the structural integrity of the device or facility containing the waste and must never threaten human health or the environment; and,
- The generator will not place incompatible wastes together in one container or wastes which are incompatible with the container or container liner.
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:
- An individual is assigned to be in charge of the area;
- Containers are leak proof and in good condition;
- Upon occurrence of a leak from a container, the contents are immediately removed and place in a leak-proof container. All spilled material must be properly cleaned up and managed;
- All containers holding hazardous waste are kept closed except when it is necessary to add or remove waste;
- Containers holding hazardous waste are not handled, opened or stored in a manner which may cause the container to rupture or leak;
- The container is not make or lined with materials which will cause the hazardous material to react or be incompatible with the waste;
- All containers will be marked with the words "HAZARDOUS WASTE" and other words that identify the contents of the containers; and,
- Within three days of when a container has reached its capacity, it is promptly removed from the accumulation area managed in accordance with the requirements of this section, the label dated and placed into hazardous waste storage until offered for transportation to a licensed Treatment Storage or Disposal (TSD) facility.
When accumulating hazardous waste on site in containers, the following requirements must be complied with:
- Within 90 days, [or 180 days (up to 3,000 kg) for a small quantity generator, and 180 days (up to 1,000 kg) for a very small generator] the accumulated waste shall be either:
- shipped off site to a facility which is permitted by the U.S. EPA or the authorized state, exempt from permitting, or has interim status under RCRA; or,
- treated, stored, disposed of or recycled in an off-site facility which has been issued a final license, interim license, variance or waiver; or,
- treated, stored, disposed of or recycled in an on-site facility which has been licensed or otherwise approved to accept the waste or is exempt from licensing.
- Generators may accumulate waste onsite for an additional 90 days if the waste is shipped to an off-site facility which is transported 200 miles or more from the generation site and written documentation is maintained regarding reason for off site facility choice.
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.
Preparedness and Prevention
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.
- An internal or external alarm or emergency communication device shall be easily accessible to employees involved in the pouring, mixing, spreading or other handling of hazardous waste.
- The alarm or device must be in visual or voice contact range with another employee.
- If only one employee is present during operation of the facility, that employee shall have immediate access to an alarm, telephone or 2-way radio.
- All communication or alarm systems, fire protection equipment, spill control equipment and decontamination equipment (where required) shall be tested and maintained to insure proper operation in time of an emergency.
- Proper aisle space which allows personnel to have unobstructed movement shall be maintained by the St Cloud School District. Aisle space shall also be allowed for fire protection equipment, spill control equipment and decontamination equipment unless it can be demonstrated that aisle space is not necessary for this equipment.
- Appropriate service arrangements shall be made by the St Cloud School District regarding the type of waste handled at the facility. The St Cloud School District shall any refusal made by any state or local authorities to participate in these arrangements.
The St Cloud School District should have the following preparedness equipment available at their facilities:
- a telephone located near scene of hazardous waste handling exposure;
- an internal communication system;
- portable fire extinguisher, fire control equipment including wet pipe sprinkler and hydrants; and
- a written Employee Right-to-Know Plan.
Storage of Hazardous Waste to Prevent Discharge
The St Cloud School District shall store its hazardous waste in such a manner that no discharge of hazardous waste will occur.
Management of Hazardous Waste Spills
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:
- At least one employee will be assigned to be the emergency coordinator. The emergency coordinator shall be responsible for coordinating all emergency response measures and shall be reachable at all times either on premises or be able to reach facility premises in a short period of time (see Appendix A for emergency coordinator designations and emergency response numbers). An alternate emergency coordinator will also be designated in the event the emergency coordinator is not available or reachable.
- Posted emergency information will be kept next to any telephone with an outside line that may be used when responding to an emergency. This posting will include the name and telephone number of emergency coordinator or procedures for contacting him/her, location of nearest fire extinguisher, spill control material and fire alarm, and telephone number of fire department unless facility has a direct alarm.
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:
- Activate internal alarms or communication systems in order to notify personnel of an emergency situation;
- In event of fire, call fire department at 911 and attempt, if appropriate, to extinguish fire;
- In event of a spill or discharge, contain flow of hazardous waste to extent possible;
- Contact the MPCA at (800) 422-0798;
- Contact the MERC at 1-800-422-0798 and comply with the reporting requirements of SARA Title III;
- Take all reasonable measures to ensure that fires, explosion and discharges do not occur, reoccur or spread to other parts of the facility. If necessary, stop processes and operations and collect and contain discharged wastes and remove or isolate containers; and,
- Arrange for complete cleanup of hazardous waste and any contaminated materials and soils as soon as possible.
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:
- Name, address, and U.S. EPA identification number of the generator;
- Date, time and type of incident;
- Quantity and type of hazardous waste involved in the incident;
- Extent of injuries, if any; and
- Estimated quantity and disposition of recovered materials.
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:
- The St Cloud School District must have a contingency plan designed to minimize the hazards to health and the environment from fires, explosions, or releases of hazardous wastes. The plan must be carried out immediately whenever there is a fires, explosion, or release;
- Copies of the plan will be maintained at the St Cloud School District Office and other specified locations;
- The plan must be kept current; and,
- The plan must designate a list of emergency coordinators. The emergency coordinator has specific responsibilities in case of a fire, explosion, or release of hazardous waste.
Emergency Response Plan
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:
- pre-emergency planning and coordination with outside parties;
- personnel roles, lines of authority, and communication;
- emergency recognition and prevention;
- safe distances and places of refuge;
- site security and control;
- evacuation routes and procedures;
- decontamination procedures;
- emergency medical treatment and first aid;
- emergency alerting and response procedures;
- critique of response and follow up;
- personal protective equipment and emergency equipment;
- site topography, layout and prevailing weather conditions;
- procedures for reporting incidents to government agencies; and
- emergency response employees shall be trained and certified annually.
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.
Labeling and Marking Hazardous Waste for Transportation
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:
- The generator name;
- U.S. DOT shipping name, hazard class and identification;
- Manifest documentation number which is the generator's U.S. EPA identification number plus the number you assign to that manifest for your own tracking;
- Pre-printed state manifest number; and,
- The words "Hazardous Waste - state and federal law prohibits improper disposal. If found, contact the nearest police department - division of environmental services or the MPCA."
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.
Placarding Hazardous Waste for Transportation
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.
Annual Hazardous Waste Activity Reporting
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:
- the MPCA identification number, name and mailing address of the exporter;
- the calendar year covered by the report;
- the name and address of each co-signer;
- a description of the hazardous waste, the hazardous waste number, the total amount of waste being used, the total amount of waste being shipped, and the number of shipments;
- a statement certifying the authenticity of the reports.
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.
Appendix A: Emergency Response Numbers
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).
- Fire: 911
- Police: 911
- Ambulance: 911
- Hospital: (local)
- Chemtrec: 1-800-424-9300
- Poison Control Center: 1-800-222-1222
- Minnesota State Duty Officer: 1-800-422-0798
- National Response Center (pollution, toxic chemical, & oil spills): 1-800-424-8802
- U.S. EPA Region 5 Emergency Response Section: 1-800-621-8431
- Minnesota Pollution Control Agency: (651) 296-6300
- National Weather: 952-361-6680
Appendix B: Hazardous Waste Identification Flow Charts
Appendix C: Listed Wastes
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)
- Part 261 - Identification and Listing of Hazardous Wastes
- Subpart D – Lists of Hazardous Wastes
- Sec. 261.30(40CFR261.30) – General
- Sec. 261.31(40CFR261.31) – Hazardous wastes from non-specific sources
- Sec. 261.32(40CFR261.32) – Hazardous wastes from specific sources
- Sec. 261.33(40CFR261.33) – Discarded commercial chemical products, off-specification species, container residues, and spill residues thereof.
- Sec. 261.35(40CFR261.35) – Deletion of certain hazardous waste codes following equipment cleaning and replacement
Appendix D: Characteristic Wastes
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)
- Part 261 - Identification and Listing of Hazardous Wastes
- Subpart B – Criteria for Identifying the Characteristics of Hazardous Waste and for Listing Hazardous Waste
- Sec. 261.11(40CFR261.11) – Criteria for listing hazardous waste
- Subpart C – Characteristics of Hazardous Wastes
Appendix E: Hazardous Waste Managemnt Checklist
Appendix F: Guide for Shippers and Generators
Appendix G: Uniform Waste Manifest