Comparison of State and Federal Hazardous Waste Rules
General Summary (find a description of Federal Rules here).
Missouri generally follows the federal rules for hazardous waste management and also has more stringent state requirements.
1. Do I need an EPA ID number to handle hazardous wastes
In Missouri, you submit a copy of the Notification of Regulated Waste Activity, Form--MO 780-1164, to obtain an EPA ID Number. A $100 fee is required for all new registrations or to re-activate a currently inactive registration. Mail completed forms and $100 fee, if applicable, to Missouri Department of Natural Resources, Hazardous Waste Program, P.O. Box 176, 1738 E. Elm, Jefferson City, MO 65101.
2. How do I determine my generator status?
Missouri generally follows the federal rules for defining generator status. Any person generating one gram of 2,3,7,8, TCDD (a dioxin-containing acutely hazardous waste with the state hazardous waste number MH02) or, who accumulates 1,000 kg of hazardous waste at any time, must comply with the on-site accumulation time rules applicable to LQGs. As soon as an SQG accumulates 1,000 kg of hazardous waste, they become subject to the on-site accumulation rules for LQGs.When a CESQG accumulates 100 kg of non-acute hazardous waste; one kg of acutely hazardous waste; one gram of 2,3,7,8TCDD; or the aggregate of 100 kg of acutely hazardous and non-acute hazardous waste, they lose their CESQG status and have to comply with either SQG or LQG requirements.
3. How can I tell if the waste materials I handle are considered
Missouri generally follows the federal rules for defining hazardous wastes.Hazardous waste may not be diluted solely for the purpose of rendering it nonhazardous unless the dilution is warranted in an emergency response measure or part of a regulated or exempted hazardous waste treatment process.Material that is stored or accumulated in surface impoundments or waste piles is a solid waste regardless of whether the material is recycled. One household hazardous waste is accepted at a TSDF, it becomes a regulated hazardous waste. Fly ash that does not meet Missouri's exclusion's criteria must be disposed of in a permitted hazardous waste facility.Used oil that exhibits a hazardous waste characteristic and that is released into the environment is subject to the hazardous waste rules. Missouri has its own listed wastes and includes federal hazardous waste numbers F020, F023, and F027; any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill of waste listed in F020, F021, F022, F023, F026, and F027, regardless of the quantity or time of the spill or release, excluding hexachlorophene soap rinses resulting from medical uses; 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) is an acutely hazardous waste and is designated with the Missouri hazardous waste code MH02; and non-wastewater splash condenser dross residue from the treatment of K061 waste in high temperature metals recovery units
4. How long can I store hazardous wastes on site?
Missouri generally follows the federal rules for storing hazardous wastes.Generators that store hazardous waste on-site without a storage facility permit must comply with additional state requirements in regard to tank and container management; limitations on the quantity of waste stored by SQG's, and containment systems for containers stored by LQGs, SQG's and LQGs that accumulate ignitable, reactive, incompatible, or volatile waste on-site in tanks must meet state requirements in regard to tanks contents and take measures to prevent releases or ignitions of the waste.Storage areas that store 1,000 kg or more of hazardous waste containing free liquids must maintain and operate a containment system that meets the federal requirements for hazardous waste storage facilities. A containment system is not required for storage areas that store containers holding only wastes that do not contain free liquids. However, these storage areas be sloped or otherwise designed and operated to drain and remove liquid resulting from precipitation, or that the containers are elevated or are otherwise protected from contact with accumulated liquid.SQG's may only store up to a total of 999 kg of non-acute hazardous waste on-site. SQG's are not exempt from complying with the federal requirement for ignitable or reactive wastes stored in containers.LQGs and SQG's must within one year from the date satellite storage begins, transfer the hazardous waste to the area where the hazardous waste is stored during the (as applicable) 90-, 180-, and 270-day storage periods; and mark containers with the beginning date of satellite storage. LQGs and SQG's must provide safety equipment in addition to the equipment required under the federal rules.Storage areas must be closed when hazardous waste has not been stored or is not expected to be stored for one year.
5. Who can transport and receive the wastes I ship off site?
Missouri generally follows the federal rules for shipping hazardous wastes to a TSD.Transporters must also meet state requirements in regard special operating licenses, recordkeeping, 10-day transit limits, fees, emergency response procedures and insurance.
6. What records do I have to keep?
Missouri generally follows the federal rules for recordkeeping.Hazardous waste generators must file a quarterly annual manifest summary report and keep on file for at least three years.TSDF's must file a quarterly annual manifest summary report and keep on file for at least three years.TSDF's must include additional information in their operating report that includes manifest information; locations and concentrations of contamination from releases of hazardous waste; information leachates removed from collection points; a copy of the final, approved permit application with all approved engineering plans. These must be kept on file until the facility closes, and then this information must be submitted to DNR.Transporters must document in writing annual employees training, vehicle inspections and maintenance, and keep on file for at least three years.
7. Do I have to file reports?
Missouri generally follows the federal rules for reporting. Hazardous waste generators must file a quarterly annual manifest summary report and keep on file for at least three years.TSDF's must file a quarterly annual manifest summary report and keep on file for at least three years.TSDF's must file an operating report and keep on file until facility closure.
8. What training requirements do I have to meet?
Missouri follows the federal rules for training.DOT requirements apply to hazardous waste transporters.
9. What differences between states may exist with regard to use of the the new standardized manifest form?
As of September 5, 2006, the new standardized manifest form (EPA Form 8700-22) and its continuation sheet (EPA Form 8700-22A) must be used in every state to track hazardous waste shipments. There will be no state variations of the new federal form and states may not require information to be included on the form that is in addition to that required by federal rules. That said, some differences between states may exist with regard to use of the form. For Missouri these differences include:
Generators should use state waste codes on the Uniform Hazardous Waste Manifest if federal waste codes do not apply. These include M001 through M012 for PCB wastes, MH02 for dioxin waste, D096 for the disposal of used oil with less than 50 ppm PCB's and D098 for the disposal of used oil.
The generator must ensure that the designated facility returns the completed manifest to the generator within 35 days after the hazardous waste is accepted by the initial transporter The generator must also send a copy of the completed manifest to DNR. TSDFs will still send the appropriate page of the manifest to: Missouri Department of Natural Resources, Hazardous Waste Program, P.O. Box 176, Jefferson City, Missouri, 65102-0176.
Generators of only one shipment in a calendar year must submit an annual report. Generators with more than one shipment of hazardous waste a year must submit quarterly manifest summary reports to DNR. Generators must contract with the designated facility to return the completed manifest within 35 days to the generator after the date the waste was accepted by the initial transporter. Generators who are required to file exception reports must comply with the state's detailed content and certification requirements. SQGs are not provided with less stringent reporting requirements.
Other Notes, Comments::
Generators may still use specific gravity to calculate the weight of hazardous waste in order to calculate hazardous waste fees; however, Missouri can no longer require specific gravity be recorded on the Uniform Hazardous Waste Manifest. Generators do not need to include their Missouri generator identification number on the Uniform Hazardous Waste Manifest.
10. What are some other differences between federal and state
Generators of hazardous waste must register with DNR. LQGs and SQG's are responsible for regular inspections of their facilities for malfunctions or deterioration, operator error, and any evidence of discharges that may be causing, or could cause, the release of hazardous waste constituents or pose a threat to human health. Missouri follows the federal CESQG generator rules, with some additional provisions and exceptions.LQGs and SQG's, with certain exceptions, must pay annual generator fees, land disposal taxes, landfill taxes, and generator taxes.