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MRW Handling. MRW = HHW + Conditionally Exempt Small Quantity Hazardous Waste Generators (CESQGs) Guidelines for facility development and permitting first published 3/1991. Over 3 dozen facilities developed using guidelines in concert with the current rule. Basis of New Section.
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MRW Handling • MRW = HHW + Conditionally Exempt Small Quantity Hazardous Waste Generators (CESQGs) • Guidelines for facility development and permitting first published 3/1991. • Over 3 dozen facilities developed using guidelines in concert with the current rule
Basis of New Section • Started from Fixed Facility Guidelines • Supplemented from experiences of Ecology and JHDs since 1991. • Relies on standard permitting approach plus • Uniform Fire Code and WISHA rules
Key New Requirements • More explicit safe storage requirements for 55 gallon drums • Aisle space and containment • Periodic inspections, routine& annual • To assure continuing integrity of the waste containment systems
Key New Requirements (cont.) • Mandatory ventilation when bulking flammable liquids or pesticide (vapors) and lab pack drums (dust hazard) • Flammable gas monitoring with alarms in some areas of some facilities • Financial Assurance required when >9000 gallons of MRW stored on-site (exc. used oil)
Expected Impact • Most Public MRW facilities will have few upgrades, most common will probably be addition of flammable gas monitoring systems. • Some hazardous waste treatment, storage, and disposal facilities, TSDFs, may have significant upgrades to secondary containment, weather protection, etc. • Need to treat all MRW regulated sites the same, larger volume MRW private sites should have same levels of protection as smaller public ones.