Hazardous Waste Generator newsletter: fall 2020

hazardous waste generator newsletter

MDA waste pesticide collection event

bucket of pesticide bottles

 

The Minnesota Department of Agriculture (MDA) sponsors opportunities to properly dispose of unwanted pesticides from farms and businesses only.

Minnesota pesticide users can bring their waste pesticides to this event and dispose of up to 300 pounds free of charge.

Monday, October 26, 9 - 11 a.m. Hennepin County Recycling Center and Transfer Station 8100 Jefferson Highway, Brooklyn Park, MN 55445

The event will be held on a Monday, when BPTS is closed to residents. Only waste pesticides will be accepted at this event by the MDA. No paint, no fuels, no crop oils, no rinsates, no recycling.

Contact MDA with any questions: 612-214-6843

Resuming onsite inspections during pandemic

Our inspection staff are back out in the field conducting hazardous waste compliance inspections. We have seen that many businesses without public facing interactions are not typically allowing drop-in visits at this time. While we recognize there may be, in some cases, a dramatic difference in how business is conducted during the pandemic, we do want to stress that it would be difficult to schedule all of our compliance inspections in advance. We will try to be flexible when visiting your facility and we also appreciate the efforts businesses have made so far to accommodate our visits on short notice.

We will be wearing protective face coverings and practicing social distancing during our inspections and we ask that all employees meeting with the inspector follow those safe practices as well. We understand there may be screening questions and temperature checks in store for us too, used to help ensure the health and safety of your employees during our inspections.  Thank you for your cooperation during these challenging times.

Generators impacted by civil unrest in Hennepin County

Hennepin County’s Environment and Energy Department has reached out to licensed hazardous waste generators that sustained severe damage or were destroyed in the recent civil unrest in Hennepin County. We are so sorry about the damage to these businesses and understand this is a very difficult time.

Hennepin County staff is available should businesses have questions or need guidance in dealing with hazardous wastes and problem wastes that were involved in or generated as a result of fires, vandalism and looting. We also have a specialist available who can answer questions and offer guidance on properly managing contaminated ash, hazardous building components (such as asbestos and mercury thermostats) and demolition debris that resulted from the damage. If you have any questions about how to manage hazardous and problem wastes, please call 612-348-3777 and ask to speak to the Environmental Protection Specialist-on-call or email environment@hennepin.us. There is also information about hazardous waste, including a list of disposal companies, available on our website. For information about properly managing demolition debris, visit hennepin.us/demolition.

Additional information:

  • Report any hazardous material incidents, including spills of hazardous wastes, to the Minnesota Duty Officer at 651-649-5451. If there is an immediate threat to life or property, call 911 first.
  • If you are planning to permanently close your business, please fill out the hazardous waste generator license closure form.
  • Your business may be eligible for the Minnesota Pollution Control Agency’s Small Business Environmental Improvement Loans to help cover costs associated with the investigation and cleanup of contaminated sites.

If other funding resources become available, we will let businesses know as soon as possible.

MPCA updates about COVID-19

With the onset of the coronavirus (COVID-19) and the Governor’s declaration of a state of peacetime emergency in Minnesota, the Minnesota Pollution Control Agency (MPCA) is aware that regulated entities may be impacted from a reduced workforce necessary to maintain normal operations at some facilities. All regulated entities remain obligated to take all available actions necessary to ensure compliance with environmental laws, regulations and permit requirements to protect the health and safety of the citizens of Minnesota and the environment. However, in the instance where regulated entities will have an unavoidable noncompliance situation, directly due to impact from the coronavirus, the MPCA has established an email box to accept requests for the Commissioner of the MPCA to consider providing regulatory flexibility, where possible, to assist entities in alternative approaches to maintaining compliance, such as extending reporting deadlines, extensions of operator certifications, and other forms of regulatory flexibility.

Regulated entities should email MPCA.COVID19REGFLEX@state.mn.us with specific information related to a request for regulatory flexibility. This email box will be monitored daily and the MPCA will work diligently to expeditiously review and respond to incoming requests from regulated entities. MPCA approval is required prior to implementing alternative measures. The email should at a minimum include the following:

  • Requests should come from an individual party (company/county/individual) and identify the party requesting the flexibility by name and applicable permit number;
  • Requests should include a phone number(s) of the individual to contact regarding the request;
  • Request should state what specific statute/rule/permit condition the individual party is looking for flexibility on;
  • Request should include the reasoning/rationale for the request (1 paragraph summary on why the peacetime emergency makes the flexibility sought necessary and what actions the requestor took prior to the request to meet the requirement);
  • Request should include bulleted points of what measures will be taken to mitigate/minimize the potential environmental impacts (if any); and
  • Request should specify the specific time period that the request is for including the rationale.

Where alternative compliance options are authorized by the MPCA, regulated entities must maintain records adequate to document implementation of authorized alternative compliance options, and activities related to the noncompliance.

The MPCA will work as quickly as possible with an individual party on a solution in response to the request. Requests can be amended by sending another e-mail if something has been approved for a specific time period and that time period needs to be extended or if a change to approved compliance options is needed. Again, the reason for the extension should be included. If the MPCA receives multiple requests for regulatory flexibility on a specific requirement and the MPCA determines it is appropriate across a specific sector, the MPCA may grant the specific sector flexibility for that requirement. 

Any questions regarding this guidance should be submitted to the email box for a response.

  • Please note: Even though your hazardous waste generator license is issued by Hennepin County, any request for regulatory flexibility must be submitted to the MPCA for their review and authorization. 
  • Hennepin County has inspection staff available each day to answer your questions regarding proper hazardous waste management. To speak with someone, call 612-348-3777 and ask for the environmental specialist on call. There are also resources available on our website.

2021 license renewal

The 2021 hazardous waste licensing process will be starting soon. The hazardous waste portal administrator for each location that is subject to annual licensing (generator size is LQG, SQG, or VSQG) will be sent email notification in early November telling them that their 2021 management plan summary (MPS) is now available for review and revision. Operations that are currently licensed as minimal generators (MIG) are not subject to the annual license renewal process.

The portal administrator must ensure that someone representing the operation is reviewing all required fields on the electronic MPS form and making adjustments that accurately reflect your waste management practices and quantities generated during calendar year 2020. After all required fields have been reviewed and updated, the portal administrator is responsible for submitting the MPS on behalf of the operation, certifying that the information has been reviewed and updated as necessary. The portal administrator will be unable to submit the MPS if there are any required fields that have not been updated.

The due date for completion of the 2021 MPS is December 15, 2020. License fees for the 2021 license period will be calculated using the most current information that has been reported and approved by Hennepin County staff at the time of invoicing in February 2021.

Hennepin County has created an iCalendar feed to help you remember all of the generator licensing deadlines, including due dates for management plan summaries, license payments and printing/posting your new generator license.

You can subscribe here if you have calendar software that accepts the iCalendar format.

Use this link to access your calendar in any web browser.

Inspection outcomes

63 inspections without a violation

Hennepin County wants to recognize generators and facilities that have a hazardous waste program that is in full compliance with hazardous waste rules and regulations. 

Since October 2019, the county conducted 63 inspections where no violations were observed, and the operations were deemed to have been in full compliance. The listing below shows that it is possible for any size generator or facility to be in full compliance at the time of inspection and it also shows that this happens quite frequently.

Click here for a printable list (PDF) of the 63 generators without a violation. This list also identifies the operation size.

 

Enforcement outcomes

The following is a list of enforcement outcomes from recently resolved civil and criminal cases, including fines and penalties assessed by the U.S. Environmental Protection Agency, the Minnesota Pollution Control Agency (MPCA) or Hennepin County. All of the cases involve hazardous waste generators, hazardous waste facilities or tank operators located in Hennepin County.

This list is intended to reinforce the importance of compliance with hazardous waste and tank regulations.

Medtronic APV, Plymouth

  • Violation: Failure to keep records at the licensed site and make them easily available for inspection.
  • Generator size: LQG
  • Outcome: $303.00 fine and corrective actions

Click here for a printable version (PDF) of this enforcement outcome.

New portal feature – portal inspection letters and compliance orders

A hazardous waste portal update was recently rolled out which allows portal users to view historical generator inspection information online. As a result, the portal now displays the inspection date, inspection type and inspector name for past inspections. Starting in the next few months, inspectors will have the ability to create and post certain types of inspection letters to the portal for new inspections, as well as issue corrective actions and/or information requests electronically. These new portal inspection features will give generators a more convenient way to electronically respond to outstanding orders as well as monitor the status of their inspection from beginning to end in real-time.

When an inspector creates and posts their inspection letter to the portal, the portal administrator and inspection contact will be notified by email with instructions on how to view the letter(s) and respond to any outstanding orders. Please keep in mind that any portal user will have the ability to log into the portal and edit a response to any individual outstanding corrective action or information request, but only the portal administrator will have authorization to submit the final generator response for Hennepin County review and approval.

To view this new portal inspection feature, log into the portal at hennepinhazwaste.us and click on the “Inspections” tab.

As a reminder, portal administrators are the only portal user type authorized to add and remove other back-up portal users for their given operation(s), and it is important for portal administrators to keep their portal user team updated with current personnel. If you have any questions, including how to reach out to your company’s portal administrator, please contact hwgsupport@hennepin.us or contact 612-348-3777 and ask for the environmentalist-on-call.

Updated storage tank requirements

Underground storage tanks (USTs) that contain petroleum or hazardous substances are subject to Minnesota Pollution Control Agency (MPCA) design and operating rules for USTs. Tank system components, such as piping, fittings, flanges, valves, dispensers and pumps are also subject to those rules.

The MPCA promulgated UST rules in 1991 and those rules were most recently amended in 2019 to conform with the 2015 revisions to Federal UST regulations that are administered by the US Environmental Protection Agency. The rules were also amended to include new technologies, codes of practice, industry standards, and address concerns that have emerged during the past 29 years of UST program regulation.

Learn more about the new requirements from the MPCA's fact sheet (PDF).

Hazardous waste management and flooding

One of the effects of climate change that we’re seeing is the expansion of flood risk areas due to increased precipitation. The historical 500-year flood risk areas are rapidly becoming the new 100-year flood risk areas.  Flooding may be one type of emergency that you simply never considered in the past.

Perhaps it’s time to take a closer look at your emergency planning and consider incorporating response to flooding events or other climate change impacts into your plans.

We will soon be mapping our hazardous waste generator data with flood plain data to get a better idea of just how many companies this might impact. We will keep you updated on our progress in our Spring 2021 Generator Newsletter and we will provide a targeted message to those who are most vulnerable, based on the mapping exercise.

2020 MnTAP intern project symposium

collage of MNTap interns

This year’s MnTAP Intern Symposium, held virtually on August 19, featured 18 projects at companies around the state. The interns highlighted the opportunities they have identified for saving water, energy, and waste during their 3-month internships.

Click here to view the event program and here to view the list of projects.

Your business may be able to address waste reduction and energy efficiency projects sooner and faster with the help of a MnTAP intern. Learn more on the MnTAP website.

Hazardous Waste Identification Number – make sure your facility is up to date

Your business's Hazardous Waste Identification Number (HWID) is a unique number used to simultaneously identify both a physical location at which hazardous waste is generated or handled and the operator of that site. The Minnesota Pollution Control Agency (MPCA) assigns HWIDs in Minnesota. Because the U.S. Environmental Protection Agency (EPA) coordinates this numbering system nationwide, HWIDs are also referred to as EPA ID Numbers. It is the site’s responsibility to update MPCA with site contact specific information, including hazardous waste and fee and billing contacts, as it relates to their HWID. Please submit your Notification of Regulated Waste Activity electronically to modify your existing HWID contact information to be sure that your site is up to date. You can access MPCA e-services here. Step-by-step instructions can be found here (PDF). If you need assistance with e-services please contact the e-service helpline at 651-757-2728.

Notifying your metro county hazardous waste licensing program about site contact information does NOT automatically update this information.

Loan programs for small businesses affected by COVID-19

Small Business Administration

Small business owners are eligible to apply for a long term, low-interest loan due to COVID-19. The United States Small Business Administration (SBA) Economic Injury Disaster Loan program provides small businesses with working capital loans of up to $2 million that can provide vital economic support to small businesses to help overcome the temporary loss of revenue they are experiencing. Learn more and apply.

 

MN DEED

Minnesota Department for Employment and Economic Development (MN DEED) is establishing a loan program to assist small businesses directly and adversely affected following the COVID-19 pandemic. Loans will range from $2,500 to $35,000, be interest free, paid back monthly over 5 years with payments deferred six months. Learn more and apply.

Updates around TCE

TCE: the partial ban

The trichloroethylene (TCE) partial ban legislation was signed in May 2020. The text of the new law: Minn. Stat. 116.385 Trichloroethylene; Ban

The ban becomes effective June 2022 and will apply only to sites required to have an air quality permit from the MPCA. Businesses with less than 500 full time employees may apply for a one-year extension.

  • A facility is not subject to the ban if it is exempted from needing an air quality permit by following specific requirements as a conditionally exempt source.
  • A facility is not subject to the ban if it has potential air emissions below air quality permit thresholds, such as an insignificant facility.

Contacts and resources

Watch MnTAP’s TCE alternatives webinars and training videos to help you find out if you are using TCE at your business and other short videos on TCE.

 

TCE: small business loans

The MPCA has made up to $250,000 in Small Business Environmental Improvement Loans available at zero-percent interest to small businesses for installation and equipment purchases associated with a switch from the use of TCE to an alternative demonstrated to be less toxic. Learn more and apply.

Contact us 

612-348-3777, ask for the environmentalist on call

HWGLicensing@hennepin.us

Resources

Hennepin County hazardous waste licensing portal

Hennepin County hazardous waste training and resources

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