Question December 03, 2020:
Hi Daniel,
Hope you are doing well and enjoying the season so far 😊
I was hoping you could help me with another regulatory question regarding counting waste – or point me in the right direction. My question is about weekly inspections when a site becomes a SQG (200-2,200 lbs./mo.). Here’s the scenario:
A generator became a SQG in October when hazardous waste was generated in that month and weekly inspections have been conducted since that time while the waste has been on site. The weekly inspections will be stopped once the hazardous waste is shipped off-site which will be sometime this month (December). However a very small amount (less than 5 lbs) of new hazardous waste item was generated at the site today.
- Does the small amount of new hazardous waste need to be included on the weekly inspection form with the other October waste items?
- If so, once the October waste items are hauled off, would this new small December item need to have weekly inspections continued until it is shipped off?
Hopefully this is an easy answer for you. Thank you for your time and help!
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Daniels Training Services, Inc. 815.821.1550 |
My reply the same day:
Thank you for contacting me. Please see below for an answer:
- In the month of October the site was a small quantity generator of hazardous waste (SQG). I presume prior to that the site was a very small quantity generator of hazardous waste (VSQG).
- You are correct that for the month of October the site must comply with SQG requirements at 40 CFR 262.16 for any hazardous waste generated in that month.
- The site must continue to comply with SQG regulations for the hazardous waste generated in October for as long as it remains on-site. That includes into November & December.
- I presume in November & December the site reverted back to its usual amount of hazardous waste generation and the VSQG category. Any Haz Waste generated in those months would be managed subject to VSQG regulations.
- The small amount of hazardous waste generated at the site in December while it was a VSQG is not subject to weekly inspection requirements. You may manage it subject to VSQG regulations.
- If your state has adopted the Generator Improvements Rule the site has the option of the Episodic Waste Generation for VSQG.
I hope this helps. Please contact me with any other questions.
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Not sure of your hazardous waste generator category? |
Another question:
Thank you for your response!
Currently the October hazardous waste is still on-site and the generator is still complying with SQG requirements. So my question is about the new hazardous waste. Does it need to be included with the October waste count and therefore required to have weekly inspections until it is shipped off?
The October waste has taken a long time to get profiled and ready for disposal which will be hauled off in a couple weeks. Once hauled off, the ship off date will be entered on the weekly inspection form and normally that would close it out. However, if the small amount of new waste that was generated today has to be included on the weekly inspections, then does that mean it has to continue inspections until it is shipped off?
I also responded back in your email below in bold red font.
Thank you for contacting me. Please see below for an answer:
- In the month of October the site was a small quantity generator of hazardous waste (SQG). I presume prior to that the site was a very small quantity generator of hazardous waste (VSQG). Correct – SQG for the month of October to present. Prior to that it was VSQG.
- You are correct that for the month of October the site must comply with SQG requirements at 40 CFR 262.16 for any hazardous waste generated in that month. Agreed.
- The site must continue to comply with SQG regulations for that hazardous waste for as long as it remains on-site. That includes into November & December. Agreed – SQG requirements are still being adhered to since the hazardous waste is still there.
- I presume in November & December the site reverted back to its usual amount of hazardous waste generation and VSQG category. Any Haz Waste generated in those months would be managed as a VSQG. November and December still had haz waste there.
- The small amount of hazardous waste generated at the site in December while it was a VSQG is not subject to weekly inspection requirements. You must manage subject to VSQG regulations. Understood, but the site was and is still SQG.
- If your state has adopted the Generator Improvements Rule the site has the option of the Episodic Waste Generation for VSQG. Thank you! Yes our state has adopted that rule.
My answer:
I’ll clarify.
- The site is a SQG for October due to the hazardous waste it generated in that calendar month.
- Any hazardous waste generated in October must be managed in compliance with the SQG regulations until it is shipped off-site. This includes weekly inspections for all hazardous waste generated in October and for as long as it remains on-site.
- The site was a VSQG for November and December. Any hazardous waste generated in November or December is subject to VSQG regulations.
- The hazardous waste generated in October remains subject to SQG regulations for as long as it remains on-site.
- The site is not a SQG in November or December unless it generated more than 100 kg of hazardous waste in either of those months.
- The small amount of hazardous waste generated in December as a VSQG is subject to VSQG regulations only. This means no weekly inspection for the hazardous waste generated in December.
- The hazardous waste generated in October while the site was a SQG remains subject to SQG regulations for as long as it’s on-site.
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Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste Daniels Training Services, Inc. 815.821.1550 |
And that did it!
Changes to the hazardous waste generator category present a challenge due to the necessary changes to regulatory compliance requirements. Some generators maintain compliance with the large quantity generator of hazardous waste (LQG) regulations solely for the one or two months of the year they may generate enough hazardous waste to qualify for that category.
Regardless of your generator category, make certain you comply with the regulations applicable to your category.