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The 2023 hazardous waste licensing process is already under way. The hazardous waste portal administrator for each location that is subject to annual licensing (generator size is LQG, SQG, or VSQG) was sent email notification in early November telling them that their 2023 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.
New for 2023: All invoices will be sent by email to the portal administrator in February 2023. An additional email notice regarding the invoice will be sent to the billing contact, if the billing contact is not the portal administrator. The billing contact information is now one of the items that must be reviewed and updated during the MPS review 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 2022. 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 2023 MPS is December 15, 2022. License fees for the 2023 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 2023.
167 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 June 2022, the county conducted 167 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 167 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 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.
Hennepin Technical College, Brooklyn Park
- Violation: Failure to label containers "Hazardous Waste" and a clear, descriptive name; Failure to store universal waste lamps in properly labeled containers.
- Generator size: SQG
- Outcome: $928.00 and corrective actions
Leroy Sign Company, Brooklyn Park
- Violation: Failure to operate to prevent a release; Failure to update management plan summary
- Generator size: VSQG
- Outcome: $1,278.00 and corrective actions
The Sierra Company LLC, Minnetonka
- Violation: Failure to conduct and document hazardous waste personnel training; Failure to label containers "Hazardous Waste" and a clear, descriptive name; Failure to close hazardous waste containers
- Generator size: LQG
- Outcome: $1,678.00 and corrective actions
World Transload & Logistics LLC, New Hope
- Violation: Failure to label containers "Hazardous Waste" and a clear, descriptive name; Failure to label used oil container
- Generator size: VSQG
- Outcome: $528.00 and corrective actions
Click here for a printable version (PDF) of these enforcement outcomes.
With the recent shortage of truck drivers, transport companies have had to use secondary transporters to ship hazardous waste to the final disposal facilities. While acting on behalf of the generator, the transport company may change or add transporters after the waste has left the generator location. Whether there is a contractual agreement in place or not, there are additional requirements that must be met under CFR 263.61-Compliance with the manifest.
Can a generator authorize a transporter to add selected additional transporters to the hazardous waste manifest after they have signed the manifest and shipped the waste?
A generator can authorize a transporter to add selected additional transporters to the hazardous waste manifest after they have signed the manifest and shipped the waste. This may be done in emergencies, or for transporter efficiency, convenience, and safety. A generator, however, must grant the transporter authority via some contractual arrangement to act as the agent of the generator with respect to adding or substituting other transporters while hazardous waste is in transport (Title 40 of the Code of Federal Regulations (CFR) Section 263.21(b)(3)). The transporter making such changes must record the following statement regarding its contractual authorization in Item 14 of each manifest for which such a change is made, ‘‘Contract retained by generator confers agency authority on initial transporter to add or substitute additional transporters on generator’s behalf.’’
Transporters who do not have contractual authorization from the generator must obtain approval from the generator before making changes to the chain of transportation (40 CFR Section 263.21(b)(2)). Although a generator may grant a transporter authority to act as the agent on his or her behalf to make changes to transporter designations on the manifest, the generator remains liable and responsible with respect to those changes and for complying with any applicable generator requirements under 40 CFR part 262. In addition, this granted authority does not provide any additional authority to the transporter to make changes to the manifest on behalf of the generator without prior approval from the generator (e.g., changes to the receiving facility designated in Item 8 of the manifest) (40 CFR Section 263.21(b)(4)).
For additional information see:
The City of Minneapolis recently adopted a modification to the Paint Booth requirements ordinance. Minneapolis won’t be enforcing this ordinance until September 1, 2026. Under the new requirements, automotive refinishers must switch to waterborne basecoats or low-VOC basecoats. Exemptions for small shops must be approved by the City of Minneapolis. View the revised ordinance section.
The City of Minneapolis is offering funding to help shops convert to waterborne paint. Minneapolis will match 75% (previously 25%), up to $50,000, to make the switch. This funding opportunity will expire on September 1, 2026. Learn more about this funding.
For questions on this upcoming requirement, please contact Jenni Lansing at jenni.lansing@minneapolismn.gov or 612-709-9977.
This year’s MnTAP Intern Symposium, held and broadcast virtually on August 17, featured 16 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.
View recordings of the intern’s ten-minute project summaries.
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 about MnTAP.
Environmental assistance loans from the MPCA
The Minnesota Pollution Control Agency (MPCA) has financial assistance available to accelerate the application and/or improvement of environmental processes and technologies in Minnesota. The assistance can help with capital costs (machinery and equipment) of eligible projects.
Priority eligible projects: green chemistry, pollution prevention, source reduction, recycling, and source-separated compostable materials. Learn more and apply.
Small business environmental improvement loans from the MPCA
The Minnesota Pollution Control Agency (MPCA) provides loans between $1,000 and $75,000 at zero-percent interest to small businesses for capital equipment purchases that help the company meet or exceed environmental regulations, and covering costs associated with the investigation and cleanup of contaminated sites. Learn more and apply.
Dry cleaner cost share funding available from the MPCA
The Minnesota Pollution Control Agency (MPCA) has cost-share funding available for projects that eliminate PERC with an alternative dry-cleaning product that is technically viable and environmentally preferable. Those intending to decommission a PERC machine with no replacement (a dry facility no longer cleaning on site) are also eligible. Up to $20,000 is available per project. Learn more and apply.
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