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Hazardous Waste Compliance: What You Need to Know and Do!

Learn about hazardous waste compliance and the importance of proper waste management. Discover the history of violations and corrective actions, as well as the new agreement between MnSCU and MPCA. Explore the waste evaluation plan, training requirements, and the hazardous waste stream survey plan. Ensure your college or university is in full compliance with hazardous waste regulations.

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Hazardous Waste Compliance: What You Need to Know and Do!

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  1. FACILITIES CONFERENCE April 11-13, 2012 Hazardous Waste Compliance: What You Need to Know and Do! Extraordinary Education - Partner of Choice - Best Value

  2. MnSCU and MPCA … A little history • Previous 10 years: Some campuses- no violations at inspection (bravo!). MPCA required corrective actions for others following inspections. Corrective actions, violations and enforcement actions are tracked by MPCA. • 2007: MPCA issued Notice of Violation (NOV) to a MnSCU campus • 2009: MnSCU and MPCA signed Stipulated Agreement to address compliance and areas of deficiencies with agreed upon corrective actions. • 2009 Agreement referenced corrective actions which MPCA considered as a repeat or similar in nature to corrective action at other campuses in previous years Extraordinary Education - Partner of Choice - Best Value

  3. More MnSCU and MPCA history… • 2010: Two separate campuses- MPCA inspections alleged violations at both campuses. • Some alleged violations were of same type at each campus. • Some alleged violations were same type of violations as found in 2007 NOV and previous inspection years. • 2011: MPCA sent MnSCU a proposed Stipulation Agreement with proposed corrective actions to resolve recent issues and includes financial penalty. Extraordinary Education - Partner of Choice - Best Value

  4. What Leads Us To Today…. • 2012: MnSCU and MPCA negotiated and are working towards finalizing a new Agreement. • Proposed Stipulation is not public until signed. • A Stipulation Agreement is a legally binding contract with additional financial penalties for not doing what is agreed upon or meeting agreed upon timelines. • Compliance with Hazardous Waste Regulations and Stipulated Agreements is an everyday requirement. Non-Compliance is NOT an option. Extraordinary Education - Partner of Choice - Best Value

  5. Stipulated Agreements • MnSCU will strengthen hazardous waste management best practices and continue to expect system- wide hazardous waste compliance, training and more! • Requires priority and full cooperation of each college and university location. • Note: MnSCU is considered by MPCA as one legal entity. Any violations at one campus impacts the others for purposes of MPCA increasing penalties and fines for another campus if there are future violations.

  6. Attention Please! Waste Evaluation Plan • MnSCU will formalize a Waste Stream Evaluation Plan (WSEP) for MPCA approval and system implementation. • Applies to ALL colleges and university locations. • WSEP will include how we will identify any unevaluated wastes at all of our college and university locations for any wastes identified as not being evaluated. • WSEP will include a timeline for completing evaluations. Extraordinary Education - Partner of Choice - Best Value

  7. There’s More! Training and Generator Size Survey Plan • MnSCU will propose a plan (Training and Generator Size Survey Plan) describing in detail how we will conduct a survey of all of our college and university locations, to ensure that all personnel that should be trained for hazardous waste are trained, and that all of its locations are meeting the correct generator size requirements. Extraordinary Education - Partner of Choice - Best Value

  8. Training and Generator Size Survey Plan • Timeline for completion. A timeline shall include a timeline for completion of training for any personnel that have been identified as not having training or have not been adequately trained. • Atimeline for ensuring that any locations that have been identified as not meeting the correct generator size requirements come into compliance with the correct generator size-specific requirements. Extraordinary Education - Partner of Choice - Best Value

  9. Hazardous Waste StreamSurvey Plan • MnSCU will propose a Hazardous Waste Survey Plan on how we will survey our college and university locations to ensure that none of the locations are accepting any hazardous waste from outside parties, including other MnSCU locations. • Atimeline for completion. Extraordinary Education - Partner of Choice - Best Value

  10. MnSCU Waste Stream Evaluation Plan Activities • Conduct hazardous, universal and special waste stream analysis survey at all college and university locations to: • Evaluate the campus wastes to determine if hazardous, using one of the following: • MSDS and generation process review. • Lab tests. • Manufacturer documentation. Extraordinary Education - Partner of Choice - Best Value

  11. Waste Stream Evaluation Plan (continued) • Confirm all campus waste streams; what programs or department activities generate wastes, which faculty, student workers or campus staff are involved with the generation and management of the wastes and the amounts of wastes generated. • Identify any training needs. • Standardize a campus Hazardous Waste Inventory for system wide use. Extraordinary Education - Partner of Choice - Best Value

  12. More Waste Stream Evaluation Plan Activities • Annual review procedure to be used by faculty and staff to identify: • Any new curriculum or lab practices added to an existing program which may add to hazardous waste streams and • New campus programs to determine if/what may be added to the existing campus hazardous waste streams. • Determine how donated materials are accepted—Say “No” to other’s hazardous waste. Extraordinary Education - Partner of Choice - Best Value

  13. How will we/you do this? • A WSEP Surveytoolwill be developed to review all college and university hazardous waste program compliance in the following areas: • Hazardous waste license (both the application and the license) for size determination. • Waste stream analysis documentation. • Sewered waste notification. Extraordinary Education - Partner of Choice - Best Value

  14. How will we/you do this? (Continued) • The WSEP Survey includes: • Hazardous waste manifests and universal waste shipping papers. • Inspection forms & activities. • Training documentation. • Emergency/Spill Response Plan. • Recordkeeping. Extraordinary Education - Partner of Choice - Best Value

  15. How will this be done? • Establish hazardous waste evaluation team from within MnSCU to assist with the surveys: • Team member training on the use and implementation of survey. • Team members will shadow system office personnel at one of our campuses. • Formalize a campus visit schedule for each region and conduct the survey. Extraordinary Education - Partner of Choice - Best Value

  16. System and Campus Team Collaboration and Assistance • HW Team Process includes: • All surveys completed by the team members will be sent to the system office-Public Safety and Compliance Unit (PSCU) for review. • The PSCU will work with individual campuses to address any areas for improvement or action. Extraordinary Education - Partner of Choice - Best Value

  17. Waste Stream Evaluation Plan Survey • Survey expected to be completed at all college and university locations within agree upon timelines with MPCA. • Requires priority and full cooperation of each college and university location. Extraordinary Education - Partner of Choice - Best Value

  18. Training and Generator Size Survey Plan activities • Ensure all college and university locations meet generator size requirements by: • Reviewing current license and license application information. • Reviewing MPCA web site generator ID number information. • Reviewing data for the campus survey. • Update the waste stream reporting form if necessary. Extraordinary Education - Partner of Choice - Best Value

  19. Training and Generator Size Survey Plan activities • For college and university locations that may need revision to meet generator size compliance requirements, include review the following areas for additional compliance: • License application and license posting. • Waste Stream Analysis. • Treatment/Disposal of Hazardous Waste. Extraordinary Education - Partner of Choice - Best Value

  20. Training and Generator Size Survey Plan activities • More review for compliance: • Manifests and Manifest Exception Reports. • Shipping Papers/Receipts/Logs for Universal and Recycled Wastes. • Feedstock and By-product. • Containers/Labeling/Storage/Inspections • Main Waste Collection Site. • Satellite Accumulation Sites. Extraordinary Education - Partner of Choice - Best Value

  21. Training and Generator Size Survey Plan activities • More review for compliance : • Emergency/Spill Response- • Main Waste Collection Site. • Satellite Accumulation Sites. • Training. • Record Keeping. Extraordinary Education - Partner of Choice - Best Value

  22. Training and Generator Size Survey Plan • Training focused activities: • Identify appropriate hazardous waste training for faculty and staff who may need hazardous waste training or refresher to include: • Basic Training-“10 Steps”. • Hazardous Waste Coordinator Training-Basic training plus shipping and disposal, to include manifest development, shipping coordination and disposal follow up. • Standardize a training schedule utilizing a variety of training venues. Extraordinary Education - Partner of Choice - Best Value

  23. Training continued… • Ensure the 2009 Stipulation Agreement training requirements are system wide • To be completed at all college and university locations within agree upon timelines with MPCA. • Document/Record Keeping of Training. Extraordinary Education - Partner of Choice - Best Value

  24. Hazardous Waste Survey Plan activities • Confirm all college and university locations compliance to ensure no acceptance of hazardous waste materials. • Includes: • Prohibiting acceptance of any material that is hazardous waste under the MPCA Hazardous Waste Rules. Extraordinary Education - Partner of Choice - Best Value

  25. Hazardous Waste Survey Plan activities • Prior to acceptance of any material that will create a hazardous waste the Hazardous Waste Coordinator will need to determine if (1) the material can be added to an existing waste stream or (2) creates a new waste stream. • Determine cost of disposal /benefit to the program when accepting materials that could create a waste. • Don’t accept other’s risk or liabilities-Remember, just say no to accepting hazardous waste materials from others. Extraordinary Education - Partner of Choice - Best Value

  26. Hazardous Waste Survey Plan • Don’t accept other’s risk or liabilities-Remember, just say no to accepting hazardous waste materials from others. • Hazardous Waste Survey Plan and activities to be completed at all college and university locations within agreed upon timelines with MPCA. • Requires priority and full cooperation of each college and university location. Extraordinary Education - Partner of Choice - Best Value

  27. Questions Extraordinary Education - Partner of Choice - Best Value

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