Q&A: How do I manage hazardous waste during months when my generator category changes?
A question from someone who had contacted me previously (12.03.20):
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 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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Not sure of your hazardous waste generator category? |
Not an easy one, but I did have an answer:
Thank you for contacting me. Please see below for an answer:
- In the month of October you were a small quantity generator of hazardous waste (SQG). I presume prior to that you were very small quantity generator (VSQG).
- You are correct that for the month of October you must comply with SQG requirements for any hazardous waste generated in that month.
- You must also comply with SQG requirements for that hazardous waste generated in October for as long as it remains on-site.
- I presume in November & December you reverted back to VSQG category. Any Haz Waste generated in those months would be managed as a VSQG.
- The small amount of hazardous waste generated in December while you were a VSQG is not subject to weekly inspection requirements since those are required for a SQG but not VSQG.
- If your state has adopted the Generator Improvements Rule you have the option of the Episodic Waste Generation for VSQG.
I hope this helps. Please contact me with any other questions.
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Daniels Training Services, Inc. 815.821.1550 |
They required a little clarification:
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 red font.
I figured I better clarify:
I’ll clarify.
- The site is an SQG for October.
- Any waste generated in October must comply with SQG until it is shipped off-site. This includes weekly inspections.
- Site was a VSQG for November and December. Any waste generated in Nov or Dec is subject to VSQG regulations.
- The site is not a SQG in Nov & Dec unless it generated more than 100 kg of Haz Waste in either of those months.
- The small amount of waste generated in Dec as VSQG is subject to VSQG regulations. This means no weekly inspection for the waste generated in Dec.
- Waste generated in Oct while site was SQG is subject to SQG regulations for as long as it remains on-site.
The clarification helped but more assistance was necessary:
Okay great! I will wrap my head around this and re-look at it tomorrow. It makes sense. I could not find any regulation citation that points this out. Do you know where i could find that? No worries tonight of course! Thanks very much!
My reply:
There are no clearly expressed regulations on this point. However, this rather old USEPA guidance document clarifies this interpretation: Managing Hazardous Waste: A Guide for Small Businesses. On page 5 it reads:
Depending on your type of business, you might be regulated under different rules at different times. If, for example, you generate less than 220 lbs (100 kg) of hazardous waste during the month of June, you would be considered a CESQG for June, and your June waste would be subject to the hazardous waste management requirements for CESQGs. If, in July, you generate between 220 and 2,200 lbs (100 kg to 1,000 kg) of hazardous waste, your generator status would change, and you would be considered an SQG for July. Your July waste would then be subject to the management requirements for SQGs. If you mix the wastes generated during June and July, the entire mixture would be subject to the more stringent SQG standards.
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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 |
That seemed to do it!
Hi Daniel,
I think I got it now and just wanted to thank you for the sound guidance on this. It helped very much!
Take good care!
Conclusion:
The management of hazardous waste can be difficult enough when your generator category doesn’t change, but when it does, then things can get really difficult. Perhaps the easiest option is to comply with the requirements of the highest generator category, but if you can keep the wastes separate, you can manage them according to their applicable generator category.