Requirements for Hazardous Waste Generators in Wisconsin

Hazardous Waste in Wisconsin @DanielsTraining 1

REQUIREMENTS FOR
HAZARDOUS WASTE
GENERATORS IN
WISCONSIN
A very brief summary of the steps to identify
and comply with the applicable regulations
for the generation of hazardous waste in
the State of Wisconsin. And how to avoid
the WDNR’s Common Hazardous Waste
Violations.


PRESENTED BY:
Daniels Training Services
815.821.1550
www.DanielsTraining.com
Info@DanielsTraining.com

A different kind of training.


A LITTLE BACKGROUND
It’s important to understand the basis for the
regulations and what agency enforces them.


Regulatory Agencies

• USEPA regulates
environmental
protection nationwide.
• Approved State
programs may be
more stringent and
more broad.
• In Wisconsin: The WI
Department of Natural
Resources (WDNR).


What is Cradle to Grave for
Hazardous Waste?
• If you generate a hazardous waste,
regulations are applicable throughout its
lifecycle.
FOREVER!!!


HAZARDOUS WASTE
DETERMINATION
Required for all the waste you generate.


All Generators Must Complete a
Hazardous Waste Determination
• Sole responsibility of the generator.
• Must be documented.
• Maintain records for 3 years.
• Determination may be based on:
1. Analysis of samples.
2. Generator’s knowledge.


Is it a Solid Waste?
• Any discarded
material.
• Liquid, solid, semi-
solid.
• Garbage or trash.
• Industrial waste.
• Residential waste.
• Food waste.
• Containers &
packaging.


Two Types of Hazardous Waste
1. Listed 2. Characteristic

• Identified by: • Exhibits defined
1. Process of characteristics.
generation • Usually determined by
2. Technical name sample analysis.
• Usually knowledge-
based.


Listed Hazardous Waste
• F-Codes:
• Non-specific sources.
• Spent solvents, WWT sludge, more…
• K-Codes:
• Specific sources.
• Petroleum refining, primary metal
processing, more…


More Listed Hazardous Waste
• P & U Codes:
• Listed by technical
name.
• Must be
virgin, unreacted
material.
• Unused product
• Spill clean-up
• Container residue


Characteristic Hazardous Waste
• Ignitable (D001):
• Liquid with flashpoint <140˚F.
• Spontaneously combustible solid.
• Oxidizer.
• Flammable gas.
• Corrosive (D002):
• Aqueous with pH ≤2 or ≥12.5, and/or
• Liquid that corrodes steel at defined rate.
• Can’t be a solid.


More Characteristic Hazardous Waste
• Reactive (D003):
• Unstable under normal conditions.
• Water reactive.
• Explosive.
• Toxic (D004 – D043):
• Poisonous to living organisms.
• Toxins will leach from waste above a
threshold concentration.


Is it Excluded by Regulation?
• Excluded by rule from definition of solid waste.
• Excluded by rule from definition of hazardous
waste.
• Excluded from regulation due to recycling.
• Excluded as material in an out-of-service
process for ≤90 days.
• Excluded as a waste determination or treatability
study sample.


Common Hazardous Waste Violations
• Misclassifying a hazardous waste as non-
hazardous or vice-versa.
• Incorrect application of generator knowledge
where sample analysis would yield better used.
• Use of a lab for sample analysis that is not
certified by the WDNR.


HAZARDOUS WASTE
GENERATOR STATUS
The requirements of regulatory compliance
depends upon your hazardous waste generator
status.


Large Quantity Generator
• GENERATES:
• ≥1,000 kg hazardous
waste/calendar mo.
• ≥1 kg acute
hazardous
waste/calendar mo.


Small Quantity Generator
• GENERATES:
• >100 kg <1,000 kg
hazardous
waste/calendar mo.
• ACCUMULATES:
• ≤6,000 kg hazardous
waste.


Very Small Quantity Generator
• GENERATES:
• ≤100 kg hazardous
waste/calendar mo.
• ≤1 kg acute
hazardous
waste/calendar mo.
• ACCUMULATES:
• <1,000 kg hazardous
waste.


PREVENTING AND
PREPARING FOR
EMERGENCIES
Your requirements for preparation and
prevention of emergencies will differ based on
your generator status.


Emergency Preparedness & Prevention
• Attempt arrangements w/ local emergency
services.
• Internal & external emergency communication.
• Personnel must have immediate access.
• Fire suppression, spill control, & decontamination
equipment.
• Must be tested and maintained.


Small Quantity Generator Requirements:
• Post emergency
response information.
• ID one employee
available for
coordinating
emergency response.


Hazardous Waste Contingency Plan
• Arrangements agreed to by local authorities,
emergency response contractors, and equipment
suppliers.
• Phone numbers of local authorities & contractors.
• Emergency coordinator’s address & phone (office
and home).
• Up to date list of emergency equipment &
capabilities.
• Evacuation plan and directions.


Common Hazardous Waste Violation
• Failure to have or update the Contingency Plan.
• Missing name & home address of emergency
coordinators.
• Inadequate description of all waste and hazards.
• Missing description and location of emergency
equipment & accumulation areas.


HAZARDOUS WASTE
CONTAINER MANAGEMENT
Proper container management is the way to
prevent spills, releases, and WDNR violations.


Hazardous Waste Container
Management
• In good condition.
• No residue on outside.
• Compatible with waste.
• Store in proper location:
• Indoors
• Controlled access


• Using improper
containers.
• Containers in poor
condition.
• Storage in poor
location.


Markings for Containers & Tanks
“Hazardous Waste” Accumulation Start Date


• Containers & tanks must be clearly marked as
“Hazardous Waste”.
• Accumulation containers must be marked with the
date the first drop of hazardous waste is added.
• Accumulation time limit begins on this date.


Keep Container Closed
• Container must be
closed except when
adding or removing
waste.
• Intent is for container
to be:
• Vapor tight.
• Spill proof.


• Containers not kept
closed except to add
or remove waste.


Time Limit for Onsite Accumulation of
Hazardous Waste
Large Quantity Small Quantity
Generator Generator
• No more than 90 days • No more than 180
from date of initial days from date of
accumulation. initial accumulation.


Time Limit for Onsite Accumulation of
Hazardous Waste
• Very Small Quantity
Generator:
• No onsite time limit
for accumulation of
hazardous waste.


• Accumulate hazardous
waste onsite for
greater than 90 or 180
days without approval.


Weekly Inspections
• Weekly inspections are
required for LQG’s &
SQG’s:
• Hazardous waste
containers.
• Hazardous waste
accumulation areas.
• Must maintain a log
of completed
inspections.


• Not maintaining
records of waste
container inspection
logs.


SATELLITE ACCUMULATION
OF HAZARDOUS WASTE
The satellite accumulation regulations give you
a break from some of the requirements for
hazardous waste.


Container Volume Restrictions in SAA’s
• ≤55 gallons of
hazardous waste.
• ≤1 quart of acute
hazardous waste.


Container Requirements in SAA’s
• Label: “Hazardous
Waste”
• or chemical name.
• Other “basic” container
requirements.


The Tricky Part of SAA’s
1. At or near the point
of generation.
2. Under the control of
the operator of the
process that
generated the
waste.


When Volume Limit is Met
1. Final closure.
2. Date container was full.
3. 3 days to move to Central Accumulation Area.
4. 90 or 180 day limit begins.


• Accumulating >55
gallons of hazardous
waste at a Satellite
Accumulation Area.


REPORTING
REQUIREMENTS
Make sure you are in compliance with the
WDNR reporting requirements.


Reporting Requirements
Annual Hazardous
EPA Form 8700-12
Waste Report
• Must be used to • Due March 1st for
document facility’s: previous year.
• Generator status • LQG’s and SQG’s.
• Wastes generated
• Ownership


TRAINING OF HAZARDOUS
WASTE PERSONNEL
WDNR and US EPA agree on this one: You must
annually train all hazardous waste personnel at an
LQG. Some training for SQG’s as well.


Training Requirements
LQG SQG
• Initial w/i 180 days of • “Ensure facility
employment. personnel are
• Annual review. thoroughly familiar
• Program directed by with proper waste
trained personnel. handling and
• Trained to perform job emergency
in compliance with procedures, relevant
regulations. to their
• Document correctly. responsibilities…”


• Not providing annual
training.
• Not providing training
in implementation of
contingency plan.
• Not maintaining
training records.


THE UNIFORM HAZARDOUS
WASTE MANIFEST
Required nationwide since 9.5.06. There are
Federal and State requirements you must
follow.


Uniform Hazardous Waste Manifest
• Must use for:
• Hazardous waste
from LQG & SQG.
• Used Oil from all
generators.
• PCB’s from all
generators.
• Hazardous waste from
VSQG does not
require manifest.


Uniform Hazardous Waste Manifest in
Wisconsin
• For out-of-State TSDF,
generator must submit
final, signed copy to
WDNR w/i 30 days of
receiving.
• Not required for in-
state TSDF.


• Not having all required
manifests.
• Improperly filling out
manifests.
• Not sending final
signed copy to WDNR
if TSDF out-of-State.


LAND DISPOSAL
RESTRICTIONS
aka: LDR or Land Ban. Be aware of your
requirements as a generator of hazardous
waste.


Land Disposal Restrictions for Hazardous
Waste
• Generator responsibility:
1. Determine applicable LDR’s for their waste.
2. Provide signed LDR Notice or Certification to
TSDF.
3. Maintain signed copy of LDR Notice or
Certification.
4. Update LDR if changes to waste.


• Not having signed LDR
notices or
certifications.


UNIVERSAL WASTE
A “de-regulation” of some hazardous waste at
the Federal level and in Wisconsin. Be aware
of your requirements.


Federal Universal Wastes
• Electric lamps.
• Batteries.
• Mercury-containing
devices.
• Recalled or cancelled
pesticides.


Wisconsin Universal Wastes

• Federal UW’s
and…
• Antifreeze to be
recycled
• E-waste
• Refer to my
presentation:
Universal Waste in
Wisconsin.


Common Universal Waste Violation
• Not closing and
labeling container
properly.


USED OIL
Another “de-regulation” of what might be a
hazardous waste.


Used Oil Management
• Manage in tanks &
containers only.
• Label: “Used Oil”.
• Practice good
housekeeping.
• Refer to my article:
Used Oil Management
in Wisconsin.


For More Information
• Database of WDNR-Certified Labs
• The ID and Management of Universal Waste in
Wisconsin
• Hazardous Waste Manifests – A Guide for
Hazardous Waste Generators
• WDNR’s Common Hazardous Waste Violations
• Used Oil Management in Wisconsin
• Is Your Waste Hazardous?


Got Questions
About RCRA or
HazMat
Transportation?
Annual Hazardous
Waste Personnel
Training.
and
Triennial HazMat
Employee Training.

Public
Seminars or Daniels Training Services
Onsite. 815.821.1550
Info@DanielsTraining.com
www.DanielsTraining.com

Requirements for Hazardous Waste Generators in Wisconsin

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