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Hazardous Waste Plan for H.M. Cragg Company:
1. Waste Generator
Size
H.M. Cragg Company is classified as a Very Small Quantity Generator
(VSQG) meaning we generate less than 100 kg/month (or 220 lb.). This
classification was formerly referred to as Conditionally Exempt Generators
(CEG).
Our exempted wastes
include:
- Used Lead-Acid
Batteries which are recycled
- Used Fluorescent
Light Bulbs which are recycled
- Used Dry Cell
Batteries which are recycled
- Sewered Hazardous
Wastes if treated or neutralized on-site
1.1. Waste Generation
Waste generation comes from Battery Washing/Neutralizing in the form
of sewerable waste water and filters.
H.M. Cragg Company
pioneered the use of a portable, self-contained recirculating washer
system for industrial batteries. When washing and neutralizing batteries
at our facility, or on a customers site, no raw waste water goes down
the drain. Runoff is captured in pan under the shower unit and pumped
to a holding tank. The tank has a maximum capacity of 100 gallons, however
we typically keep 50-75 gallons in use.
Waste water is recirculated
from the holding tank through a series of three filters; two particle
filters (30 microns) and one activated carbon filter (10 microns). The
activated carbon filter removes oil and other inorganic compounds. After
filtering the water is reused in the wash/neutralize process.
Filtered rinse water
is constantly monitored with a digital pH/ORP instrument probe built
into the unit. An LED display indicates pH with a range of 0 to 14 pH
with an accuracy of 0.1 pH +/- 1 digit.
Filtered Rinse Water
Analysis
(Pace , Inc. Lab Analysis, 5/3/95)
Compound RegulatoryLevel (mg/L) Method Detection Limit Filtered Rinse
Water
Lead (D008) 5.0 0.025 0.60
Arsenic (D004) 5.0 0.080 not detected
Filtered rinse water
is not considered a hazardous waste. We sewer discharge the filtered
water after washing approximately 30 batteries, first insuring that
it is properly neutralized to approximately pH 7.
1.2. Spent Battery and Components Disposal
C&D Technologies, the battery manufacturer we represent, provides
H.M. Cragg Company (their Agent) with a complete battery collection
and recycling program. The program is monitored by C&D's own Environmental
Department (contact person Pam Reich 215-619-7886).
Through this program
C&D selected The Doe Run Company, Resource Recycling Division located
in Boss, Missouri. It is the largest and only fully integrated North
American refined lead producer. Doe Run has a new, state-of-the-art
facility with an approved RCRA Part B permit to receive lead-acid batteries,
D008 lead contaminated waste and K069 secondary lead dust or sludge
from secondary lead smelting waste. Doe Run's Transportation, Storage,
and Disposal (TSD) Number is MOD-059-200-089.
Therefore spent
batteries, battery parts, and filters from our battery washing unit
are consolidated and shipped in truckload quantities to Doe Run on a
regular basis.
2. EPA ID Number
and Hennepin County Licenses
Activated
as of May 1, 1995
US EPA ID Number: MNR000002006
Hennepin County Site ID: 00010186-05301959
7674 Washington Avenue South, Eden Prairie, MN 55344
3. Transportation
and Proper Disposal
H.M. Cragg Company is registered with the US Department of Transportation
(USDOT) as a Hazardous Waste Transporter. We transport batteries for
our service customers primarily in the State of Minnesota.
USDOT 124333
HazMat Registration No. 062503 700 013L
Issued: 6/26/03 Expires: 6/30/04
For shipments of
Spent Lead Acid Batteries (SLAB) we rely on The Doe Run Company mentioned
above for the dispatch of an approved DOT HazMat carrier. The carrier
varies, but most often is Waller Trucking Company of Richmond, Missouri
(USDOT 089164).
H.M. Company
Licenses / Certificates
10.1. United States Environmental Protection Agency (EPA)
Installation EPA ID Number: MNR-000-002-006
Issued: March 24, 1995 no expiration date
10.2. United States Department of Transportation(DOT) - Research
and Special Program Administration
Hazardous Materials Certificate of Registration: 062503 700 013L
Issued: June 26, 2003 Expires: June 30, 2004
10.3. Hennepin County (MN) Hazardous Waste Generator License
Company Site ID: 00010186-05301959 SIC: 7699
Generator Size: Very Small Quantity Generator
License Period: January 1, 2000 thru December 31, 2004
Please call 952-884-7775
in the twin cities metro area or toll free at 800-67CRAGG (800-672-7244).
Contact
Us for more information
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