Hazardous Waste

Businesses, governmental agencies, institutions and other organizations can produce hazardous wastes. Known as "hazardous waste generators," these entities are strictly regulated in Minnesota. Hazardous waste generators are classified into three categories: Large Quantity Generators (LQGs) -- producing more than 2200 pounds of hazardous waste per month; Small Quantity Generators (SQGs) -- producing 220 to 2200 pounds per month; and Very Small Quantity Generators (VSQGs) -- producing less than 220 pounds per month. In Minnesota, any amount of hazardous waste (except household hazardous waste) is regulated.

Hazardous waste generators can include auto repair shops, metal platers, dry cleaners, printers, public works departments, school maintenance departments, utilities, etc. In the metropolitan area, counties regulate hazardous waste generators. In Greater Minnesota, the Minnesota Pollution Control Agency (MPCA) regulates these entities.

Hazardous wastes from households (paint, solvent, pesticides, etc.) are not regulated (except for bans on use and disposal of specific materials), although they contain many of the same chemicals as business waste. Minnesota counties operate household hazardous waste collection and education programs, in cooperation with the MPCA.

A list of state and county contacts with telephone numbers is included as Appendix A.

The following is a list of activities a public water supplier could choose to include in Wellhead Protection plans to target hazardous waste generators and household hazardous waste. These activities are not required of public water suppliers, but provide a menu of choices -- the methods chosen will depend on the local situation. 

Education:

If a public water supplier chooses to focus on hazardous waste in the wellhead protection area, education should be included as a component of the management plan, regardless of whether other methods are also used. Messages to highlight in an educational program on hazardous wastes include:

• importance of proper management of hazardous materials and hazardous wastes in wellhead protection area (making the connection between personal actions and the water supply)
• read product labels to identify what is hazardous
• purchase fewer hazardous materials; choose the least toxic product; consider changing business/household practices to avoid producing wastes
• reduce, reuse and recycle hazardous wastes
• manage hazardous wastes responsibly: use, store and dispose of properly
• problems associated with improper management of hazardous materials and waste

Because Minnesota counties have on-going household hazardous waste education programs, it is important for water suppliers to coordinate educational activities on household hazardous waste with county programs. Contact your county solid waste or environmental office for more information.

Listed below are a variety of educational activities that public water suppliers can undertake; these can be used as stand-alone educational activities or paired with voluntary practices or regulatory activities to help manage hazardous wastes. In each activity, we have indicated whether the activity is appropriate for generators, households or both.

Special Events: Several types of events are available, which public water suppliers can sponsor or participate in. These events offer a good opportunity to make hazardous waste generators and households aware of hazardous waste issues, through speakers, displays and making print information materials available:

Luncheon meetings for business people: This type of meeting can be sponsored by the water supplier or in conjunction with the Chamber of Commerce, Kiwanis, Rotary, Lions or other service organizations. The public water supplier can arrange for speakers on hazardous waste management and waste reduction (for both business waste and household hazardous waste), along with making information packets available. 

Fairs and festivals: For households and generators, public water suppliers can sponsor or co-sponsor a booth at community fairs and festivals. Annual wellhead protection festivals, county fairs, County Ground Water Festivals, Public Works Department Open Houses, and Lake Association "Lake Days" offer opportunities for water suppliers to highlight the Wellhead Protection area and provide handouts on household hazardous wastes, hazardous waste and other potential contaminant sources. When designing a booth, it’s important to use large visuals, such as a poster of the wellhead area.

Demonstration projects: For hazardous waste generators, demonstration projects can be an effective educational tool. At the local level, a public water supplier can work with a hazardous waste generator (who is managing waste correctly and/or reducing the hazardous materials used) to host an "open house" to provide ideas for other local generators. In undertaking this effort, it will be important to choose an appropriate generator -- generators receiving awards from the MPCA or recipients of the Governor’s pollution prevention awards would be good choices. At the demonstration project, public water suppliers can also provide case studies of other waste reduction efforts by businesses; contact the Office of Environmental Assistance for information.

Tours: For all residents of the wellhead protection area, the public water supplier can offer tours of the city’s water supply system. Another opportunity for a tour would be to work with county staff to offer tours of the county’s household hazardous waste facility.

Workshops/Training: Public water suppliers can encourage hazardous waste generators in wellhead protection areas to attend workshops and training on waste management and pollution prevention. Ways to encourage this include mailing or dropping off training schedules to generators; providing a reduction in utility bills for attending training; providing scholarships for attending training; and establishing a city-sponsored recognition program for generators attending training (the city provides a plaque or certificate to generators attending training).

A variety of training opportunities are available for hazardous waste generators. The MPCA and metro-area counties offer workshops on hazardous waste management; the Minnesota Technical Assistance Program (MnTAP) and the Office of Environmental Assistance offer workshops on a variety of pollution prevention topics; and some trade associations (printing and auto repair industries) offer environmental training. MPCA, MnTAP and metro-area counties may be able to conduct smaller-scale or industry-specific training programs; contact the MPCA Business Assistance Unit, your metro-area county or MnTAP for more information.

In addition to encouraging hazardous waste generators to attend training, workshops on hazardous waste issues may also be beneficial for public water suppliers and other city staff. By becoming more educated about hazardous waste regulations, city staff may gain the knowledge necessary to conduct first-level assessments of waste-management practices of hazardous waste generators in wellhead protection areas. 

Information Packets. Public water suppliers can use information packets to reach generators and households on hazardous waste issues. Existing print information is listed below for use in wellhead protection areas. The listings below include general information, applicable to a variety of generator types, as well as print information specific to some of the more common generator categories. Appendix B contains comprehensive lists of fact sheets, brochures, etc. available from the MPCA and MnTAP.

Information packets can be distributed in a number of ways. For generators, personal visits may be the most effective. Direct mail (flyers or water utility bill stuffers) and passive distribution methods such as making print information available at city halls, fire halls, libraries, community bulletin boards, and special events can be used for both households and generators. When distributing information to residents of the wellhead protection area, public water suppliers may want to use existing, organized groups to assist in the task, such as lake associations, homeowners groups, or senior citizen organizations. Appendix B contains a list of printed materials available on hazardous waste and household hazardous waste. In the seven-county metropolitan area, counties have printed materials in addition to the resources listed. Check with your county first. 

Video. Videos on both hazardous waste and household hazardous waste issues can be made available locally for both generators and households. A variety of videos, listed below, can be made available for loan through local libraries, chambers of commerce, city halls, Extension offices, household hazardous waste collection facilities or aired on local cable television. Public water suppliers may also want to work with local cable access stations to develop a video about their wellhead protection program which can be run regularly on cable access. The Minnesota Rural Water Association loans videos on wellhead protection. Appendix B contains a list of videos available on hazardous waste and household hazardous waste. 

School Programs. Providing school programs on household hazardous waste can be a good way to educate residents in wellhead protection areas. Some public water suppliers may already have existing programs established to work with schools, and these programs can be expanded to include household hazardous waste issues. Most counties have household hazardous waste education programs, which may include school programs. Public water suppliers should work with their counties in designing school programs on household hazardous waste. The Office of Environmental Assistance has a K-12 curriculum on waste, which may also be available from counties.

For generators, public water suppliers can work with technical colleges and arrange to bring speakers on hazardous waste issues to appropriate students (auto repair classes, printing classes, etc.). 

News Media. Public water suppliers can provide information on both hazardous wastes and household hazardous wastes to residents of a wellhead protection area through local newspapers and radio. County solid waste or environmental offices may also be working in this area for household hazardous waste and are good contacts for news media ideas. Working with cable access as discussed in Videos above is also a way to reach audiences. 

Newsletters. Public water suppliers can provide articles to local newsletters as a good way to get information out, especially if the newsletter is targeted to a specific group. For example, articles in trade association or chamber of commerce newsletters can be an effective way to reach hazardous waste generators. Newsletters reaching a more general audience, such as community newsletters, lake association newsletters and others, can be useful for household hazardous waste information. 

Displays. Public water suppliers can set up displays on their wellhead protection program. Displays can be used in conjunction with special events as described above or used on a longer-term basis at city halls, shopping malls, supermarkets, libraries, community centers and other places frequented by community residents. Displays should be accompanied with print information on business hazardous waste, household hazardous waste and other contaminant sources for residents to pick up. Appendix B contains a list of displays available on hazardous waste and household hazardous waste. 

Recognition Programs. For hazardous waste generators, cities could establish recognition programs (businesses could become "Wellhead Protectors," for example). Cities could provide certificates, plaques or other recognition awards to generators who meet certain criteria established by the city. The qualifying criteria could include: attending workshops; conducting audits of waste management practices; reducing wastes produced; obtaining a hazardous waste license from the MPCA or metro county; and other indicators of managing wastes responsibly.

Services:

In addition to education, public water suppliers can provide services to help manage a particular contaminant source. These services go beyond education but do not involve regulation. For hazardous waste generators and household hazardous waste, services can include both technical assistance and financial assistance.

Activities undertaken by public water suppliers to assist businesses and homeowners with hazardous waste management fall into the technical assistance category. Also included here are monitoring activities that may be instituted to track changed practices and potential problems. 

Waste Collection Programs. Public water suppliers can work with other organizations to sponsor or encourage waste collection programs for specific categories of waste. When undertaking this type of activity, it is important to work closely with the other governmental organizations discussed below.

Household hazardous waste collections. Counties operate household hazardous waste collection programs. These programs are usually open to households only (generator waste cannot be collected). Public water suppliers can encourage residents of wellhead protection areas to participate in county collection sites by helping to publicize these events through posters, flyers or water utility bill inserts. Public water suppliers may also contact county staff to explore the possibility of jointly sponsoring a collection day in the community. (Note: household hazardous waste collection and disposal programs are expensive and require extensive planning; work closely with your county solid waste or environmental staff or the MPCA’s household hazardous waste program if you are interested in sponsoring a collection program.)

Very Small Quantity Generator (VSQG) collections. VSQGs often have difficulty finding a good way to manage their hazardous wastes. VSQG collections allow these small generators to bring wastes to a central collection point, where the waste is consolidated with other VSQG waste. VSQGs pay the cost of waste disposal and the collection operator must have a special license from the MPCA. Public water suppliers could hire a contractor to provide a VSQG collection for wellhead-area VSQGs, promote (through flyers or personal visits) existing collection programs available to VSQGs, or work with a community business to sponsor a VSQG collection. For assistance on VSQG collection programs, contact the MPCA’s VSQG Collection Program (for Greater Minnesota communities) or your county (metro-area communities). See Appendix A for telephone numbers.

Special Waste collections. Special wastes include batteries, antifreeze, mercury switches, and other mercury-containing items. Special collection programs for these wastes can be established, or public water suppliers can encourage residents of wellhead protection areas to participate in existing programs, using many of the methods described above. For information on special waste collections, contact the MPCA’s Special Waste Collection Program (see Appendix A for telephone numbers).

Hazardous Waste Audits for hazardous waste generators. By evaluating waste management practices, hazardous waste generators have an opportunity to determine whether they are in compliance with hazardous waste requirements and/or whether there are business practice changes which can be made to reduce their wastes. A 1995 law allows small businesses to voluntarily self-audit their compliance with environmental laws, report violations to the MPCA, and commit to a schedule to correct any noncompliance. If a company meets all requirements of the program, the state will not assess any administrative, civil or criminal penalties to the owner or operator of the business for reported violations, with certain exceptions.

Public water suppliers can encourage local businesses to participate in self-audits. One way to do this would be to coordinate a meeting between audit providers and generators in the wellhead area. Or, the public water supplier could provide financial assistance to generators interested in hiring a private consultant to conduct an assessment. Assistance with hazardous waste compliance assessment is available from several sources: county staff (in the metro area), MPCA staff, trade associations (printing and auto dealers), and private consultants. 

MnTAP Site Visits. Site visits differ from hazardous waste audits discussed above in that they focus on more than waste management -- waste reduction and pollution prevention. MnTAP provides site visits at the request of individual business owners to assist businesses in identifying pollution prevention opportunities. These site visits are offered at no charge. Public water suppliers could encourage businesses in the wellhead protection area to request a site visit from MnTAP, by providing businesses with MnTAP’s brochure: MnTAP site visits can help you identify options, save money and avoid problems later. Public water suppliers could also coordinate a meeting of area businesses and arrange for a MnTAP presentation. 

Spill Reporting: Currently, state law requires spills to be reported to the State Duty Officer at the Division of Emergency Services, Department of Public Safety. The Duty Officer then notifies the state and county emergency response departments of the spill. Cities may want to work with county emergency response officials to ensure that the county notifies the city of spills in the wellhead protection area. 

Monitoring. Monitoring can include a variety of tracking/evaluation activities, as well as ground water monitoring. In general, monitoring activities may require follow-up actions if monitoring indicates potential problems.

• Surveying hazardous waste generators and/or households in wellhead protection areas to determine information needs, for use in targeting educational efforts.
• Identifying new businesses that may be hazardous waste generators, using a questionnaire as part of the city permitting process. This information could be provided to the MPCA or the metro-area county, to ensure that generators are aware of their responsibilities under hazardous waste laws and regulations.
• Public water suppliers may choose to conduct periodic soil or ground water sampling at businesses with large quantities of hazardous waste, to alert the city to potential contamination before it reaches the water supply well.

Grants and Loans. Public water suppliers can act as an information and referral service for hazardous waste generators on available grants and loans. Existing grant and loan programs include County Challenge Grants, available through your county water planning office; Pollution Prevention Grants, available through the Office of Environmental Assistance; and Hazardous waste cleanup loans, available from the MPCA. In some cases, public water suppliers may choose to establish grant and loan programs for wellhead protection activities.

Public water suppliers can promote the availability of grants and loans to hazardous waste generators through flyers and direct mail. Grants and loans can be used for a variety of activities:

• sponsoring workshops;
• hiring private consultants to conduct audits;
• upgrading management practices as the result of an audit;
• establishing a collection program;
• purchasing recycling equipment;
• upgrading hazardous waste/hazardous materials storage areas

Regulation:

Regulation is another category of methods a public water supplier can undertake to manage hazardous waste generators and household hazardous wastes in a wellhead protection area. 

Regulatory Ideas for household hazardous waste:

Prohibition of dumping and requiring proper disposal: Public water suppliers may work with the appropriate local government to prohibit disposal of household chemicals down the drain, on the ground or in the trash and to require proper disposal. The public water supplier should work closely with the county to make sure that alternative management methods exist for the types of wastes to be included in this requirement.

Regulatory Ideas for hazardous waste generators:

State law prohibits local units of government from setting standards for hazardous waste which are in conflict or inconsistent with those set by the MPCA. Currently, state law and regulations require stringent management standards for all hazardous waste generators. Among these are requirements that hazardous waste generators must have a license from the MPCA or metro county; hazardous wastes must be stored in closed containers; hazardous wastes must be shipped off-site within specified time periods depending on the size of the generator; hazardous waste must be transported using a licensed transporter, except in specific circumstances; and hazardous waste must be disposed of at a permitted hazardous waste facility.

Because these regulations apply to all hazardous waste generators and are designed to prevent releases, public water suppliers are encouraged to concentrate on providing education and services to hazardous waste generators. If local regulation is desired, options for regulatory activities are listed below. In undertaking many of these regulatory activities, public water suppliers will need to work closely with local planning and zoning commissions with jurisdiction in the wellhead protection area.

Work with Hazardous Waste Regulatory Programs: Public water suppliers should work closely with state or metro-county hazardous waste programs on regulatory efforts. Public water suppliers could explore the possibility of prioritizing wellhead protection area generators for technical assistance and inspections by state and county programs.  

Environmental Issues Checklist: Public water suppliers could work with the appropriate authorities to require new businesses locating in the wellhead protection area to submit an environmental issues checklist to the local unit of government. The Ramsey County Soil and Water Conservation District has an example checklist which includes several questions to ensure that new businesses have applied for and received the required approvals and permits from state and county environmental agencies. 

Adopt Ordinances in Support of the State’s Hazardous Waste Program: Public water suppliers could explore adopting ordinances in support of the state’s hazardous waste program. The options listed below are grouped into those which would duplicate requirements that businesses already have to follow under the state’s hazardous waste rules and those that go beyond the requirements of the state’s rules. 

Currently required, or required in part, by state hazardous waste rules:

• Requiring proof of hazardous waste licensure by the state or metro county program
   
• Requiring the contingency plans required by the state’s hazardous waste rules to be filed with the appropriate local agencies (for a description of the requirements for these plans, order MPCA fact sheet #’s 1.055, 1.06 and 1.07 in Appendix B)
   
• Requiring hazardous wastes stored in wellhead protection areas to be properly containerized, labeled and stored as required by state hazardous waste rules (for a description of these requirements order MPCA fact sheet #1.02 in Appendix B)
   
• Requiring secondary containment for storage areas (state rules already require secondary containment for outdoor storage of hazardous waste).
   
• Requiring weekly inspections of hazardous waste containers and waste storage areas, as required by the state’s hazardous waste rules (for a description of these requirements order MPCA fact sheet #1.26 in Appendix B)
   
• Prohibiting floor drains in hazardous materials and hazardous waste storage areas (state rules already prohibit drains in waste storage areas).

Regulations not required by the state hazardous waste program (go beyond the state program)

• Requiring pollution prevention plans for businesses within the wellhead protection area. For example, businesses could be required to reduce their use of hazardous substances and production of waste by a certain percentage over a number of years. To establish this type of system, it will be important to work cooperatively with businesses to develop workable requirements.
   
• Requiring hazardous waste generators in wellhead protection areas to undertake soil or ground water monitoring on a periodic basis, in certain circumstances. For example, large quantity generators or generators where there is reason to suspect a problem is occurring could be required to conduct sampling as an early-warning-system to detect ground water contamination before it reaches the water supply.

County Adoption of State Hazardous Waste Program: Public water suppliers may choose to explore with their county the feasibility of the county adopting and implementing the state’s hazardous waste program locally (counties have authority to adopt the state’s program). Currently, the seven metro-area counties have adopted the state’s rules by ordinance and operate county hazardous waste programs. To adopt the state’s program, a county needs to seek and obtain authority from the MPCA. Contact the MPCA’s Business Assistance program for information.

Phase-Out Zoning: In Dayton, Ohio, the city developed a scoring system for businesses located in the wellhead protection area, based on the quantities and toxicity of hazardous substances and wastes used and produced. Each business receives a numerical score. When a business in the wellhead protection area relocates or leaves the area, the city ordinance requires that the next business to occupy the property must have a "score" equal to or less than the previous business’ score.

Prohibitive Zoning: A number of wellhead protection programs across the country have adopted ordinances prohibiting new businesses involving hazardous substances or wastes from locating in the wellhead area, creating "green spaces." If public water suppliers are considering this type of ordinance, they will need to work very closely with the Planning and Zoning Commission of the local unit of government with jurisdiction in the wellhead area.  

APPENDIX A: Telephone Contacts for state and county hazardous waste and household hazardous waste program assistance:

Minnesota Pollution Control Agency: 651/296-6300 or 800/657-3864
Hazardous Waste Business Assistance: 651/297-8362
VSQG Collection Program: Ned Brooks, 651/297-8498
Special Waste Collection Program: Pat Carey, 651/297-8680
Household Hazardous Waste Program: 651/297-8675 

Minnesota Technical Assistance Program (MnTAP): 612/627-4646 or 800/247-0015
(printed materials available in alternative formats) 

Minnesota Office of Environmental Assistance: 651/296-3417 or 800/657-3843
Waste Education Clearinghouse: 651/215-0232 or 800/877-6300
Pollution Prevention: 651/296-3417 or 800/657-3843 

Metro County Hazardous Waste staff:

Anoka:	763/422-7093
Carver:	952/361-1800
Dakota:	952/891-7011
Hennepin:	612/348-4919
Ramsey:	651/733-4466
Scott:	952/496-8177
Washington:	952/430-6655

 Greater Minnesota Solid Waste Officers: see pages following: 

Appendix B: Available Resources for Hazardous Waste and Household Hazardous Waste

Printed Information for Hazardous Waste: (see also Fact Sheet checklists attached)

General information:

Your business and its waste, MnTAP
Summary of Generator Requirements, MPCA
Consequences of Non-compliance, MPCA
Labeling and Storage of Hazardous Waste, MPCA
Selecting a Licensed Hazardous Waste Transporter, MPCA
Choosing a Hazardous Waste Management Facility, MPCA
Minnesota Waste Wise: your program to reduce waste in Minnesota, Minnesota Chamber of Commerce
Minnesota Technical Assistance Program: helping businesses prevent pollution and properly manage waste, MnTAP
Minnesota Guide to Pollution Prevention Planning, OEA
Source Reduction Now! manual, OEA 

Specific to Printers

Evaluating Paint and & Ink Wastes, MPCA
Waste Reduction: Printing Industries, MPCA
Removing Solvent & Ink from Printer Shop Towels and Disposable Wipes, MnTAP 

Specific to Metal Plating

Heavy Metal Sludges, MPCA
Metal Manufacturing and Finishing, MPCA
Resource Recovery in Plating Operations, MnTAP 

Specific to Dry Cleaning

Hazardous Waste from Drycleaning, MPCA
Waste Reduction: Drycleaning, MPCA

Specific to Vehicle Maintenance and Repair

Vehicle Maintenance/Equipment Repair, MPCA
Vehicle Maintenance and Repair Self-Assessment, MnTAP
Managing Used Oil/Used Oil Telephone Contacts, MPCA
Used Oil Haulers, MPCA
Managing Used Oil Filters, MPCA
Used Oil Filter Haulers, MPCA
Managing Used Antifreeze, MPCA
Antifreeze Recycling Equipment and Services, MPCA
Managing Used Lead-Acid Batteries, MPCA
Hazardous Waste Fact Sheet: Solvents, MPCA
Autobody Repair: Waste Management and Reduction, MnTAP
Radiator Repair: Waste Management and Reduction, MPCA
Waste Reduction: Vehicle Maintenance, MPCA
Car Wash and vehicle Maintenance Facilities (for unsewered facilities), MPCA
Best Management Practices for Vehicle Maintenance Facilities (for unsewered facilities), MPCA

Printed Information for Household Hazardous Waste

Most Minnesota counties have print materials on household hazardous waste issues, specific to their county. Check with your county solid waste or environmental offices. The Waste Education Clearinghouse at the Office of Environmental Assistance has a variety of materials. In addition, the MPCA has the following resources available:

Household Hazardous Waste fact sheet series, MPCA
Household Hazardous Waste Disposal Guide, MPCA
Checklist for Storing Household Chemicals, MPCA 

Videos Available on Hazardous Waste:

Salvage Yard video, MPCA, available for purchase from the Minnesota Bookstore
Storing Hazardous Wastes, MPCA, available from the MPCA Hazardous Waste Division
Evaluating hazardous wastes, MPCA, available from the MPCA Hazardous Waste Division
Managing common hazardous wastes, MPCA, to be available in late 1995
Handling Hazardous Waste: With a Little Help from the MPCA, MPCA, to be available in late 1995 (this video is designed for businesses which may be unaware that they are generators of hazardous waste)
Source Reduction Now, Office of Environmental Assistance

Videos Available on Household Hazardous Waste:

Your county household hazardous waste program or solid waste department may have videos available on household hazardous waste. In addition, a variety of videos on household hazardous waste are available through the Office of Environmental Assistance, Waste Education Clearinghouse, 800/877-6300.

Displays Available:

Ground Water Model Display, available from some county water planning offices, the Board of Water and Soil Resources, the Department of Natural Resources, and the Minnesota Rural Water Association

Household Hazardous Waste Display, available from county solid waste offices or the MPCA.

Mercury Display, available from the MPCA