In Minnesota, generators can puncture waste aerosols or gas cylinders that have been shown to be empty or that have been evaluated as non-hazardous, as long as any unavoidable liquid residuals are collected and properly managed.
However, hazardous waste aerosols and gas cylinders may no longer be punctured or vented in Minnesota after January 1, 2017, unless all hazardous waste propellant gases, product gases, and liquids are captured and properly disposed. MPCA does not allow charcoal and activated carbon filters to be used to capture hazardous waste propellants or gases for disposal.
The deliberate release of hazardous waste propellant or compressed gas to the atmosphere has been prohibited by the Minnesota Hazardous Waste Rules for many years, but MPCA chose not to enforce this prohibition. This allowed generators and collection sites to puncture hazardous waste aerosols and dispose of ignitable hazardous waste to the atmosphere. This practice is not allowed after 1/1/2017.
UPDATE: The deadline for this policy change has been revised.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
Friday, September 16, 2016
New Rules Allow Handling Aerosol Cans As Universal Waste In Minnesota
A handful of States allow spent aerosol cans to be handled under State Universal Waste rules (email Caltha LLP if you would like to know if your State is included), although this waste stream is not a Federal universal waste under 40 CFR 273. The Minnesota Pollution Control Agency has finalized rules that will allow generators to manage aerosol cans as universal wastes.
Because documenting that an aerosol container or gas cylinder meets “RCRA Empty” standard can be impractical, MPCA allows generators to assume that an aerosol container is empty when both the following conditions are met:
· No liquid is felt or heard when the container is shaken by hand; and
· No gas or liquid is released when the spray/discharge valve is activated and the container rotated through all directions, as long as the valve is not observably or known to be clogged.
Hazardous waste aerosols and gas cylinders that are not empty can be managed under rules equivalent to universal wastes in Minnesota. Generators must accumulate hazardous waste aerosols and gas cylinders in closed containers labeled with one of these phrases:
· Universal Waste Aerosols/Gas Cylinders (whichever is appropriate)
· Waste Aerosols/Gas Cylinders
· Used Aerosols/Gas Cylinders
Accumulated hazardous waste aerosols/gas cylinders can be stored on-site for no more than one year and must be dated to verify how long they have been stored. Generators can ship hazardous waste aerosols/gas cylinders without a hazardous waste manifest to any site that has agreed to accept and properly manage them.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
Because documenting that an aerosol container or gas cylinder meets “RCRA Empty” standard can be impractical, MPCA allows generators to assume that an aerosol container is empty when both the following conditions are met:
· No liquid is felt or heard when the container is shaken by hand; and
· No gas or liquid is released when the spray/discharge valve is activated and the container rotated through all directions, as long as the valve is not observably or known to be clogged.
Hazardous waste aerosols and gas cylinders that are not empty can be managed under rules equivalent to universal wastes in Minnesota. Generators must accumulate hazardous waste aerosols and gas cylinders in closed containers labeled with one of these phrases:
· Universal Waste Aerosols/Gas Cylinders (whichever is appropriate)
· Waste Aerosols/Gas Cylinders
· Used Aerosols/Gas Cylinders
Accumulated hazardous waste aerosols/gas cylinders can be stored on-site for no more than one year and must be dated to verify how long they have been stored. Generators can ship hazardous waste aerosols/gas cylinders without a hazardous waste manifest to any site that has agreed to accept and properly manage them.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
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