1. MRW Handling MRW = HHW + Conditionally Exempt Small Quantity Hazardous Waste Generators (CESQGs) Guidelines for facility development and permitting first published 3/1991. Over 3 dozen facilities developed using guidelines in concert with the current rule

2. Basis of New Section Started from Fixed Facility Guidelines Supplemented from experiences of Ecology and JHDs since 1991. Relies on standard permitting approach plus Uniform Fire Code and WISHA rules

3. Key New Requirements More explicit safe storage requirements for 55 gallon drums –Aisle space and containment Periodic inspections, routine& annual –To assure continuing integrity of the waste containment systems

4. Key New Requirements (cont.) Mandatory ventilation when bulking flammable liquids or pesticide (vapors) and lab pack drums (dust hazard) Flammable gas monitoring with alarms in some areas of some facilities Financial Assurance required when >9000 gallons of MRW stored on-site (exc. used oil)

5. Expected Impact Most Public MRW facilities will have few upgrades, most common will probably be addition of flammable gas monitoring systems. Some hazardous waste treatment, storage, and disposal facilities, TSDFs, may have significant upgrades to secondary containment, weather protection, etc. –Need to treat all MRW regulated sites the same, larger volume MRW private sites should have same levels of protection as smaller public ones.