I delivered this presentation to the Greater Ozarks Chapter of the Hazardous Materials Mangers in 2013. I only had an hour to present and had a lot of information to cover, so it is only a summary. Take note: If you generate a hazardous waste in Missouri, you will subject to the regulations of the Missouri Department of Natural Resources (MDNR) which in many ways are more strict than those of surrounding states and those of the USEPA. As a matter-of-fact, some requirements of the MDNR regulations for hazardous waste generators have no equal outside of the State of California! Review this presentation, research the regulations, and contact me with any questions you may have about the generation, management, transportation, and disposal of hazardous waste in Missouri.

1. The Management of
Hazardous Waste in
Missouri
A summary of the regulations of the
MDNR pertaining to hazardous
waste, non-hazardous waste,
universal waste, and used oil
Presented by: Daniels
Training Services

2. State Administered Hazardous
Waste Programs
• To be authorized a
State program must
be at least as
stringent and as
broad as the Federal
program.
• The MDNR manages
the State’s hazardous
waste program.
Federal regulations adopted by MDNR

3. The Hazardous Waste Determination
• The generator of any
waste, must determine
what, if any, hazards it
contains.
• Process must be
documented & records
retained.
• May rely on:
– Generator
knowledge.
– Sample analysis.
MDNR doesn’t have a certification program for labs

4. 1. Is it a Solid Waste?
• Any discarded material.
• Not necessarily a hazardous waste.
• Solid Waste ≠ Solid
• May be solid,
liquid,
gas,
or semi-solid.

5. 2. Is it Excluded From Regulation
due to Recycling?
• USEPA & MDNR
regulations identify
exclusions from
regulation if waste is
recycled.
• Recycling method must
be:
– Identified by
regulation.
Or…
– “Legitimate”.

6. 3. Is it Excluded by Regulation
as a Solid Waste?
• USEPA & MDNR
regulations may exclude
a waste.
– By type.
Or…
– By industry/source.
SOLID
WASTE

7. • Identified by USEPA
and/or States, by:
– Process generating.
– Technical name.
4. Is it a Hazardous Waste?
Listed Characteristic
• Characteristics must be
present.
Federal waste codes will apply

8. Four Types of
Listed Hazardous Waste
Type Waste code
Non-Specific Sources F001 – F039
Specific Sources K001 – K181
Acute Hazardous
Waste
P001 – P205
Toxic Hazardous
Waste
U001 –
U411

9. Four Types of
Characteristic Hazardous Waste
Type Waste code
Ignitable D001
Corrosive D002
Reactive D003
Toxic D004-D043

10. 5. Is it a Non-Hazardous Waste
That is Recycled?
• A non-hazardous waste
that is recycled is not a
solid waste.
• Includes discarded
material from an
industrial process.
– Non-hazardous scrap
– Paper
– Textiles
– Rubber

11. 6. Is it an MDNR Special Waste?
• Discarded non-hazardous waste.
• No free liquids.
• Differs from municipal, construction, & other wastes.
• Requires “special” handling.
• Examples:
– Raw animal manure.
– Contaminated soil.
– Incinerator ash.
– Industrial or manufacturing process waste & sludge.

12. More on MDNR Special Waste
• Must be managed on-site in, “an environmentally
sound manner.”
• If sent to landfill:
– Complete hazardous waste determination.
– Submit Special Waste Disposal Request Form to
landfill & obtain approval for disposal.
– Provide additional information re. health hazards
or handling/safety requirements.
– Update information if changes to wastestream.

13. 7. Is it Trash or Garbage?
• Discarded non-
hazardous waste
from non-industrial/
commercial process.
– Containers and
packaging.
– Food waste.
– Miscellaneous
office trash.

14. 8. Is it Excluded From Regulation
as a Hazardous Waste?
• Regulations may exclude
a waste.
– By type of waste.
Or…
– By industry/source.
HAZARDOUS
WASTE

15. 9. Is it a Universal Waste?
• Hazardous waste (characteristic or
listed) if managed properly:
– Lamps (fluorescent or other).
– Batteries.
– Mercury containing devices.
– Recalled or canceled pesticides.

16. 10. Is it a Used Oil?
• A characteristic
hazardous waste
destined for recycling or
fuel blending.

17. HAZARDOUS WASTE GENERATOR
STATUS
After the identification of all of your wastes, you
must determine your generator status from one of
the following:
Large Quantity Generator (LQG)
Small Quantity Generator (SQG)
Conditionally Exempt Small Quantity Generator
(CESQG)
MDNR differs slightly in its thresholds for the next 18 months

18. Are you a Large Quantity Generator
of Hazardous Waste (1.0)?
• Generate ≥1,000 kg
(~2,200 lbs) of hazardous
waste in a calendar
month.
1,000
kg/month
100
kg/month
H
A
Z
A
R
D
O
U
S
W
A
S
T
E

19. Are you an LQG (2.0)?
• Generate or accumulate
≥1 kg (~2.2 lbs) of acute
hazardous waste in a
calendar month.
19
1 kg/month
USEPA threshold is >1 kg/mo

20. Are you an LQG (3.0)?
• Generate or accumulate
≥1 g of dioxin waste in a
calendar month.
• Dioxin waste:
– 2,3,7,8 –
tetrachlorodibenzo-p-
dioxin
20
1 g/month

21. Are you a Small Quantity Generator
of Hazardous Waste?
• Generate or accumulate
≥100 kg (~220 lbs) but
˂1,000 kg (~2,200 lbs) of
hazardous waste in a
calendar month.
1,000
kg/month
100
kg/month
H
A
Z
A
R
D
O
U
S
W
A
S
T
E
USEPA threshold is >100 kg/mo

22. Are you a Conditionally Exempt
Small Quantity Generator
of Hazardous Waste (1.0)?
• Generate and
accumulate <100 kg
(~220 lbs) of hazardous
waste in a calendar
month.
1,000
kg/month
100
kg/month
H
AZ
A
R
D
O
U
S
W
AS
TE
USEPA threshold is ≤100 kg/mo

23. Are you a CESQG (2.0)?
• Generate and
accumulate <1.0 kg of
acute hazardous waste
in a calendar month.
23
1 kg/monthUSEPA threshold is ≤1 kg/mo

24. MANAGEMENT OF HAZARDOUS WASTE
IN CONTAINERS FOR LQG’S & SQG’S
The most common option for hazardous waste
management differs depending on your hazardous
waste generator status. Large Quantity Generators
of hazardous waste have the greatest regulatory
burden.

25. HAZARDOUS WASTE
MANAGEMENT UNITS
A generator of hazardous waste has four options for
the on-site management and accumulation of their
hazardous waste. They are…
1. Containers
2. Tanks
3. Containment Buildings.
4. Drip Pads.

26. Obtain a US EPA & MDNR ID #
• ID # is affixed
permanently to the
geographic location.
• Transfer of ownership
requires transfer of ID #
to new owner.
Recommended for CESQG in MO

27. Container Condition
• Container in good condition.
• No waste on outside of
container.
• Container compatible with
waste.

28. MDNR Requirements
for Reuse of Containers
• Original good condition.
• Tested for leaks.
– Visual OK.
• Proper hazard class
labeling.
• Ensure compatibility.

29. Closed Containers
• Must be closed except
when adding or
removing waste.
• EPA intent for
container:
– Vapor tight.
– Spill proof.
• Compliance will depend
on type of waste (solid
v. liquid).

30. 1. “Hazardous Waste.”
2. “Federal Law
Prohibits…”
3. Generator's name
and address.
4. Date of accumulation.
On-Site Hazardous Waste
Container Labeling Requirements
From the 1st drop!

31. • Must have the
appropriate USDOT
HazMat label:
– Corrosive
– Flammable
– Oxidizer
– Other
• Doesn’t apply to
satellite.
Hazardous Waste Container
Labeling Requirements
From the 1st drop!

32. HazMat Employee Training
• Purpose of MDNR
container labeling regs is
to have HW containers
“ready to ship”.
• Must comply with
USDOT/PHMSA regs when
HW in storage.
• Therefore, HazMat
Employee training is
required per
USDOT/PHMSA.

33. Containment System Requirements if
>1,000 kg of Liquid Hazardous Waste
• Solid, impervious base.
• Drainage control designed
to remove liquids, or;
• Containers elevated.
• Contain 10% of total
volume or largest container.
• Prevent run-on.
• Remove overflow.
• Doesn’t apply to satellite.

34. Minimum Requirements for
HW Container Storage
• Containers must be protected from contact w/
liquids:
– Containment system for >1,000 kg.
– Storage designed & operated to drain & remove
accumulated liquid.
– Elevate or otherwise protect from liquids.
• If outdoors: Protect containers from precipitation.

35. Sources of Ignition or Reaction
• Ignitable & reactive
waste must be
separated & protected
from sources of
ignition/reaction:
– Open flame.
– Hot surfaces.
– Electromagnetic
radiation.
– Sparks.

36. No Smoking Signs Required
• Required even if entire
facility is no smoking.
• Must be conspicuous
near reactive &
ignitable waste.
• Required in hazardous
waste storage areas.

37. Distance from Property Line
• Reactive or ignitable
waste >50 feet from
facility property line.
P
r
o
p
e
r
t
y
L
i
n
e
>50 ft
Some exceptions

38. Hazardous Waste On-Site
Accumulation Time Limit for LQG
• ≤90 days.
• Accumulation begins 1st
moment hazardous waste
is generated.
Except for Satellite.
• Extension may be granted
by MDNR in special
circumstances upon
request.

39. Hazardous Waste On-Site
Accumulation Time Limit for SQG
• ≤180 days.
• ≤270 days if TSDF >200
miles away.
– Except for Satellite.
• May be granted an
extension beyond 180 or
270 days if “unforeseen,
temporary, and
uncontrollable
circumstances”.

40. Weekly & Daily Inspections
• Inspect facility weekly:
– Containers & containment systems.
– Include areas outside of Haz Waste storage areas.
– Look for leaks & deterioration.
• Inspect areas subject to spills daily:
– Loading/unloading areas.
– Spill control equipment.
– Additional inspections for Haz Waste in tanks.

41. Preparedness & Prevention
• Internal & external emergency communication.
• Fire suppression equipment.
– And ensure adequate water supply.
• Spill control & decontamination equipment.
• Maintain adequate aisle space (~24-36”).
• Attempt arrangements & agreements w/ emergency
responders.

42. Decontamination Equipment
• MDNR recommends
decon equipment be
w/i 10 second radius of
potential hazard.
• No door should
separate hazard from
decon equipment.
• Adequate signs.
• Well lit.
• 15 minutes of water.

43. Hazardous Waste Release Reporting
• If a fire, explosion, or
spill involving HW.
And…
• Spill endangers surface
water, human health, or
the environment.
• Call National Response
Center (NRC) @
800.424.8802
Call 911 if threat to life or property
• MO Emergency
Response Center @
573.634.2436.
And…

44. After the Release or Emergency
• Provide for disposal of
all wastes.
• Ensure all emergency
equipment is fit for use
prior to resumption of
operations.
• Prepare and maintain a
written report
documenting the
incident & submit to
MDNR.
Within 15 days

45. MANAGEMENT OF HAZARDOUS
WASTE IN CONTAINERS FOR LQG’S
The most common option for hazardous waste
management differs depending on your hazardous
waste generator status. Large Quantity Generators
of hazardous waste have the greatest regulatory
burden.

46. Comply With RCRA Air
Emission Standards
• Required for organic
solvent Haz Waste.
1. Use UN
performance
oriented
packaging.
2. Must have a cover
that forms a
continuous barrier
with no openings.

47. Contingency Plan
• Detailed response actions specific to facility for
hazardous waste emergency.
• To be immediately implemented in an emergency.
• Must contain:
– Agreements w/ emergency responders.
– Facility emergency coordinator(s):
• Home & office: address & phone.
– Emergency response equipment.
– Evacuation plan.

48. HAZARDOUS WASTE GENERATOR
REQUIREMENTS FOR CESQG
Though a CESQG is excluded from compliance with a
majority of the RCRA regulations, there are some
requirements that apply just to them.
48

49. CESQG Must Complete the
Hazardous Waste Determination
49

50. CESQG On-Site Accumulation Limit
• Don’t accumulate
≥1,000 Kg of
hazardous waste.
– If so, CESQG
becomes Small
Quantity
Generator.
50
1,000 Kg
H
A
Z
A
R
D
O
U
S
W
A
S
T
E

51. The “Grave” for CESQG
Hazardous Waste
• Ensure disposal of
hazardous waste at
a state approved or
RCRA permitted
facility.
51
Approved?
Yes No

52. SATELLITE ACCUMULATION AREA
(SAA) REGULATIONS
An important subset of the hazardous waste
accumulation regulations. The SAA regulations can
be very useful, but are often misunderstood,
resulting in violations.
Missouri SAA regulations are very unique

53. Two Important
Requirements of SAA’s
1. Must be under the
control of the
operator of the
process generating
the waste.
2. Must be at or near
point of generation
where wastes initially
accumulate.
MDNR wants “clear view of SAA at most times”

54. SAA Limits in Missouri
• No more than 1 x 55
gallon container per
hazardous waste per
SAA.
Or…
• 1 x 1qt container per
acute hazardous waste
per SAA.

55. When Container of any Size is Full
• Date container.
– 3 calendar days to
move to Central
Accumulation Area.
Friday
Saturday
Sunday
Monday

56. • Closed at all times.
• Labeled:
– “Hazardous Waste”
Or…
– Other words that identify the contents.
• Date of accumulation – MISSOURI ONLY.
• 1 year limit for on-site accumulation.
• No limit on number of SAAs at a generator site or
cumulative total volume.
Final Requirements for SAA’s

57. The Four Universal Waste
1. Batteries
2. Lamps
3. Mercury-containing
devices
4. Recalled or canceled
pesticides
57

58. What is a Universal Waste Battery?
• NiCad, lead acid,
lithium, mercury,
silver, etc.
58

59. What isn’t a Universal Waste Battery?
• Non-hazardous
(alkaline) batteries.
• Lead acid batteries
being reclaimed.
59

60. What is a Universal Waste
Mercury Containing Device?
• Device or part of a
device with elemental
mercury integral to its
function.
• Includes:
– Thermometers,
thermostats,
switches, gauges,
manometers, more...
60

61. What isn’t a Universal Waste
Mercury Containing Device?
• Liquid metallic
mercury.
• Spill clean-up.
• Batteries
• Lamps
61

62. What is a Universal Waste Lamp?
• Bulb or tube of electric
lighting device.
• Includes:
– Fluorescent, HID,
sodium vapor, neon,
mercury vapor, metal
halide, incandescent,
& etc.
62

63. What isn’t a Universal Waste Lamp?
• “Green Cap”
fluorescents.
63
“Green Caps” still contain Mercury

64. What is, and isn’t, a
Recalled/Canceled Pesticide
Is
• Suspended or canceled
pesticides that are part
of a recall.
• Unused pesticides that
are the result of a
collection program.
Isn’t
• Recalled and unused
pesticides managed by
farmers per 40 CFR
262.70.
• Those cans of bug spray
or unused weed & feed
you have in storage.
MDNR-specific requirements for pesticides

65. Universal Waste – Handler Status
Small Quantity Handler
• Generate or receive UW
for consolidation.
• Accumulate <5,000 kg
of Universal Waste.
Large Quantity Handler
• Generate or receive UW
for consolidation.
• Accumulate ≥5,000 kg
of Universal Waste.
65
• Also: Transporters & Destination Facilities

66. Universal Waste
Handler Requirements
• Manage to prevent spills & releases.
– Spills of UW are a hazardous waste.
• Label containers to ID waste:
– “Universal Waste - “
• Train employees or ensure knowledge of proper
handling & emergency response.
• Accumulate in appropriate containers.
• 1 year of on-site accumulation.
– Longer if solely to facilitate disposal.
Additional MDNR regs for LQH’s

67. What is a Used Oil?
1. Petroleum based or
synthetic.
– Not animal or
vegetable.
2. Used
– Not virgin.
And…
3. Contaminated by use.

68. Used Oil General Management
• Labeled “Used Oil”.
• Spills and leaks cleaned-up immediately.
• No on-site time limit.
• Sufficiently impervious secondary containment.
• Containers kept closed if exposed to rainfall.
• State waste codes if disposed of instead of recycled
or burned for energy recovery:
– D096 w/ < 50 ppm PCB’s.
– D098 w/ no PCB’s.

69. OFF SITE SHIPMENTS OF
HAZARDOUS WASTE
Unless you treat or dispose of your hazardous waste
on site, eventually you must ship it off site for
disposal. This step is the “to” in the “Cradle to
Grave” management of hazardous waste.
The transportation of a hazardous waste is regulated
by both the US EPA and the US DOT.

70. Container Condition
• MDNR on-site storage
requirements comply
with USDOT/PHMSA
regulations.

71. The Uniform Hazardous
Waste Manifest
• Required by MDNR,
USDOT/PHMSA, &
USEPA.
• Documents a shipment
of hazardous waste.
– From Cradle to
Grave.
• Follow USEPA
instructions.
Requires HazMat Employee Training

72. The Waste Minimization Certification
Large Quantity Generator
§ 262.27(a)
“I am a large quantity generator.
I have a program in place to
reduce the volume and toxicity
of waste generated to the degree
I have determined to be
economically practicable and I
have selected the practicable
method of treatment, storage, or
disposal currently available to
me which minimizes the present
and future threat to human
health and the environment.”
Small Quantity Generator
§ 262.27(b)
“I am a small quantity
generator. I have made
a good faith effort to
minimize my waste
generation and select
the best waste
management method
that is available to me
and that I can afford.”

73. • Contact primary
transporter or TSDF if
no signed copy of the
manifest w/i 35 days of
signing.
• Submit Exception
Report to State if no
signed copy of the
manifest w/i 45 days of
signing.
After the Hazardous Waste Shipment

74. REGISTERING, REPORTING, &
RECORDKEEPING
Compliance with the regulations is never enough.
You also must have the documentation to
demonstrate a history of compliance. This
information is vitally important in the event of an
inspection from MDNR.

75. Notification of Regulated Waste
Activity (Form-MO 780-1164)
• Initial registration (w/
$100 fee) to receive:
– USEPA Generator ID
#: MOD#########
– MO Generator ID #:
00####
• Must update for
changes.
• Annual registration
renewal w/ fee.

76. Generator HW Summary Reports
• Reporting year: July 1 to June 30.
• LQG’s report quarterly w/i 45 days of end of quarter.
• SQG’s report annually by August 14 (w/i 45 days).
• Fees based on amount of hazardous waste:
– Generated
– Land disposed
• Invoices sent in November. Payment due January 1.

77. Biennial Hazardous
Waste Report for LQG’s
• Due March 1st of even-
numbered year for
previous calendar year.
• Report generation and
off-site shipment of
hazardous waste.

78. For Additional Information
• Hazardous Waste Management – Handbook for Small-Quantity
Generators (Pub2174)
• Hazardous Waste Program: Missouri Specific Requirements
• Hazardous Waste Satellite Accumulation (PUB002215)
• Special Waste (PUB002050)
• The Universal Waste Rule in Missouri (PUB002058)
• Used Oil Contaminated Waste (PUB000153)
• Fluorescent Lamps (PUB000024)
• Hazardous Waste Generator Registration, Reporting & Waste
Fees (PUB2254)
• Hazardous Waste Generator Status Guidance (PUB002224)

79. THIS CONCLUDES THE
SUMMARY OF MISSOURI
HAZARDOUS WASTE
MANAGEMENT REGULATIONS
ANY QUESTIONS?