A question from a past Training Seminar attendee (sorry, my Seminars are Kaput for now) on September 16, 2015:

Daniel,

I have an urgent question I could use some clarification on. Our facility sends waste out as F006 except for a few solutions. If a few of our process solutions were pumped into drums to be held for treatment, do they qualify to be counted towards our generator status? If not how should they be properly labeled?

My reply that same day:

I’ll do my best to answer your question, though I could use some more information to be certain. In general, any storage of a waste before treatment to make it non-hazardous by the generator is subject to the hazardous waste generator regulations, e.g. label, date of accumulation, closed containers, inspections, &etc. It will also need to be counted toward your hazardous waste generator status.
An exclusion from regulation as a hazardous waste (and therefore not counted toward generator status) is allowed only for the following treatment if conducted immediately upon generation:

• Elementary neutralization. e.g. add NaOH to HCl bath as soon as it is determined to be spent.
• Totally Enclosed Treatment Facility
• On-site wastewater treatment facility with discharge permitted under Clean Water Act.

I hope this helps. Please don’t hesitate to contact me with any other questions.

Dan
815.821.1550