DSHW-2024-006637

Hazardous Waste Generator Categories
Lexi AdamsEnvironmental [e-mail][phone]
Discussion Topics
Defining Hazardous
Waste
Quantifying
Hazardous Waste
Generator Categories
Very Small Quantity Generators
Small Quantity Generators
Large Quantity Generators
Episodic Generator
Status
For VSQGs and SQGs
Satellite
Accumulation Areas
Defining
Hazardous
Waste
A brief overview
Discarded Materials are considered abandoned,
recycled, or waste-like.
All Hazardous Waste is solid waste; however, not all
solid waste is Hazardous.
-A waste determination must be completed to
assess if the waste is hazardous or not.
All hazardous waste is subject to regulation under
the Resource Conservation and Recovery Act
(RCRA)
Solid Waste:
Garbage
Industrial Waste
Tank Sludges
Residential
Waste
What is Hazardous Waste?
Hazardous
Waste
Determination
Required for all waste generated
Is the SOLE responsibility of the
GENERATOR
Must be documented
Records must be retained and
available for inspection
Determination can be made
through two avenues:
•Identified by process of generation
•Technical Name
1. Listed
2. Characteristics
•Exhibits defined characteristics
•Determined by laboratory analysis
1.Is the waste a Solid Waste?
2.Is the SW excluded from RCRA?
3.Is it listed in R315-261(D)?
If it is not listed al l waste characteristics in
R315-261(C) must be identified.
Assessment Questions:
Site
Where a hazardous
waste is produced or
generated.
A site must be identified
by an EPA ID number. A
company must hold a
unique ID number for
sites on separate
properties. (does not
apply to VSQGs)
An individual, trust,
firm, joint, stock
company, agency,
corporation,
partnership,
association, etc.
Any entity involved
with a process that
generates hazardous
waste.
A Hazardous Waste Generator Is…
Person Act
“Any Person , by Site, whose act or process produces hazardous waste identified or
listed in Part 261 or whose Act first causes a hazardous waste to become subject to
Regulation.”
The activity that causes
generation of
hazardous waste and
subjects it to
regulation.
Hazardous waste may
be generated by
removing residual
materials from a tank
for maintenance
purposes.
Scenario:
A company owns a series of chemical storage tanks. During an annual shut down the product is
removed from a chemical storage tank to facilitate cleaning, maintenance, and inspection. A
qualified third party is contracted to clean out the tank and handle the waste.
Who is a Co -Generator?
Fact or Fiction?
The third party contracted to clean out the waste residuals from the tank is considered a
generator and therefore remains liable for the appropriate management of the waste.
Fact!
The third party is considered a co-generator as they are moving the waste residuals out of the
tank thereby subjecting the hazardous waste to regulation
Co -Generator Responsibilities
Scenario:
A company owns a series of chemical storage tanks. During an annual shut
down the product is removed from a chemical storage tank to facilitate
cleaning, maintenance, and inspection. A qualified third party is contracted
to clean out the tank and handle the waste.
In charge of the storage
tank –is a generator as the
act of operating the
process or unit led to the
generation of the
hazardous waste.
Owner/Operator Contractor
Is responsible for
removing waste residuals
from the storage tank,
thus the generation of
hazardous waste.
When one or more person
meets the definition of
generator all persons are
responsible for compliance
If a non-compliance occurs
all generators could be held
responsible for improper
waste management.
Responsibility
Quantifying
Hazardous
Waste
Counting Hazardous Waste
Any waste that meets the
definition of Hazardous Waste in
40 CFR part 261 and is not exempt
from regulation must be counted
toward the generator category.
Section 262.13(C) identifies
wastes that are not include in
monthly counts. Placed into an on-site
treatment or disposal unit
Or generated as still booms or
sludges from storage tanks
Wastes that are accumulated
on site any time prior to
disposal or recycling
Include in the Monthly count:
Waste
Quantification
A gallon of water weighs 8.33 lbs..
(density)
A 55gal drum of water weighs
approximately 458lbs
*Hazardous Wastes will have their
own specific density Quick Estimate
VSQG = <½ drum
SQG = >27gal -4 drums
LQG = 5+ drums
Hazardous
Waste
Generator
Categories
Generator
Categories
Based on a calendar-month hazardous
waste generation / accumulation quantity
Hazardous Waste Storage limits are based
on Generator Category
Hazardous Waste
Calendar -Month
Generation Limits
Very Small Quantity
Generator (VSQG)
Small Quantity
Generator (SQG)
Large Quantity
Generator (LQG)
Acute Hazardous
Waste <2.2lbs (1kg)<2.2lbs (1kg )> 2.2 lbs (1 kg)
Non-Acute
Hazardous Waste <220lbs (100kg)> 220lbs (100kg) up
to 2,200lbs (1,000kg)
> 2,200 lbs.
(1000kg)
Total waste
accumulation limits
(on site)
< 2,200lbs (1000kg)
of HW or 2.2lbs (1kg)
of acute
< 13,228lbs
(6,000kg) of HW or
2.2lbs (1kg) of acute
Unlimited / Does
not apply
A Generator can average waste generation month to month to determine their category.
Fact or Fiction?
Best Practice
If monthly waste generation
quantities fluctuate it is
best practice to register and
operate at a higher
generator category
Generator Categories
Fiction!
Generator Category is based on the quantity of
waste generated per calendar month.
A generator can be a Small Quantity Generator one
month, and a Very Small Quantity Generator the
next!!
Very Small
Quantity
Generators
Generate:
≤ 220lbs (100kg) hazardous waste per
calendar month
≤ 2.2lbs (1kg) acute hazardous waste
per calendar month
1.Identify all hazardous wastes
2.Ensure containers are labelled
appropriately
3.Not exceed monthly HW generation
limits
4.Not exceed total HW storage limits
5.Ensure delivery to an o-site TSDF
authorized to manage VSQGs is
completed.
VSQG Regulations (R315-262 -14)
VSQGs
Accumulate:
< 2,200lbs (1000kg) hazardous waste
(total)
VSQGs must:
Shipping
If a VSQG accumulates>2,200lbs of hazardous
waste they must:
1.Ship o-site within 180 / 270 days of the date
when the maximum accumulation limit was
reached
2.Comply with shipping requirements for SQGs
If a VSQG accumulates > 2.2lbs of Acute
hazardous waste, they must:
1.Ship o-site within 90 days of the date of the
exceedance
2.Comply with LQG requirements for that acute
hazardous waste
Disposal (R315-262 -14(a)(5))
1.VSQGs can utilize an appropriately
permied solid waste facility
•Hazardous Waste Treatment,
Storage, or Disposal Facility
•Municipal or industrial solid
waste management facility
•Universal waste handler
•Facility that can reuse or recycle
waste
2.May consolidate to a LQG under
control of the same person
VSQG Shipping and Disposal
Waste Consolidation Rules R318-262 -14(a)(5)
Very Small Quantity Generator
•Waste containers must be properly marked
•Must demonstrate that the LQG is under
control of the sam e person
•A hazardous waste manifest or transporter
is not required when shipping from the
VSQG to the LQG.
•Must comply with DOT requirements.
•Electronic manifests will require an EPA
ID number.
Large Quantity Generator
•Notifies state that it is participating and
identifies which VSQGs are consolidating
•Records kept for each shipment
•Manages consolidated waste as LQG
hazardous waste
•Ensures final treatment or disposal is at a
RCRA approved facility
•Reports in Biennial Report
Allows a Very Small Q uantity G enerator (VSQG) to ship Hazardous Waste
to a Large Q uantity Generator (LQG).
Small
Quantity
Generators
Generate:
>220lbs (100kg) but < 2,200lbs
(1,000kg) hazardous waste per
calendar month
≤ 2.2lbs (1kg) acute hazardous waste
per calendar month
1.Obtain an EPA Identification Number
2.Utilize a HW transporter that has a
valid EPA ID number
3.Utilize TSDFs that have valid EPA ID
numbers
4.Must re-notify every four (4) years
5.Not exceed monthly HW
generation/accumulation limits
6.Utilize HW manifests
SQG Regulations (R315-262 -16(a))
SQGs
Accumulate:
≤ 13,228lbs (6,000kg) hazardous
waste (total)
SQGs must:
If the quantity accumulated exceeds
13,288lbs (6000kg) then the generator must
remove excess waste from site no longer
than:
•≤ 180 days
•≤270 days if shipped 200 miles or more.
The time limit for waste accumulation starts
when waste is first placed in an empty
accumulation unit.
Tanks and containers must be marked with
the date accumulation begins.
Small Quantity Generators may only
accumulate waste in tanks or containers.
•Tanks / containers must be
compatible with waste stored within
•Storage requires 2°containment or
release detection measures.
Should SQGs wish to accumulate waste
in containment buildings or on drip pads
then LQG standards must be met.
SQG Accumulation Standards
A 30 -day extension application must be submied to the Division prior to
the accumulation limit date.
SQG Hazardous Waste Storage Container
Requirements (R315-262 -16(b))
Containers must:
•Be compatible with waste, kept closed, and in good condition
•Labelled with the words Hazardous Waste, an indication of the hazards,
and the accumulation start date
•Be handled and stored to prevent leaks, ruptures, or damage
•Inspected weekly
•Incompatible wastes must be physically separated.
SQG Hazardous Waste Storage Tank
Requirements (R315-262 -16(b)(3))
Tanks must:
•Be compatible with waste including the inner liner
•Allow a minimum of two (2) feet of freeboard in uncovered tanks
•Must have a waste feed cut-o system
•Labelled with the words Hazardous Waste, hazards, and accumulation start date
•Be situated in acceptable secondary containment
•Be inspected daily for:
•Fluid Levels
•Discharge control equipment
•Monitoring equipment data
•Be inspected weekly for:
•Tank integrity
•Within berms or dikes for leaks or water accumulation
Episodic
Waste
Generator
Status
How to manage an expected or
unexpected increase in waste volume
without changing generator category
Planned:
Generator has planned and prepared for:
-Site shut down events
-Tank Cleanouts
-Short Term Projects
-Reduction of chemical inventory
Unplanned:
An event that the generator has not
planned or did not expect to occur.
-Production and/or process upsets
-Accidental spills or releases
-Acts of Nature
What is an Episodic Event?
Episodic events may be planned or unplanned and do not normally occur during
operations.
Results in an increase of hazardous waste generation that exceeds the calendar month
quantity limits for that specific generator category.
Benefits of Episodic Events
Allows VSQGs and SQG generate more waste for one calendar month than
their category allows while maintaining their existing category.
•One event per calendar year with the ability to petition for a second event
of the other type.
•If the first event is planned a petition can be made for an unplanned
event or vice versa
But…Generators MUST follow the rules and DOCUMENT!
Communication with Division personnel is KEY to remaining in compliance and
avoiding consequences
Conditions for SQGs and VSQGs в315-262-232)
The Generator must notify the Division no later than 30 days prior to
initiating the planned event or within 72 hours of the unplanned event.
The Generator Must:
-Have or obtain an EPA ID number
-Apply within the described time frames
-Consult the guidance document on our website:
hps://documents.deq.utah.gov/waste-management -and-radiation-control/hazardous-waste/DSHW -2019-001401.pdf
Waste from the event MUST be removed within 60 days of the
occurrence.
Planned Episodic Events
Follow the GUIDANCE DOCUMENT and use EPA form 8700 -12
The 60 -day clock starts on DAY 1 of the event
Document and retain records for inspections
Unplanned Episodic Events
60 Days
Event N oti fy
Waste Off-Site
72 Hours
Notify 30 Days 60 DaysEvent Waste O-Site
•Follow the GUIDANCE DOCUMENT
•Initial contact/notification can be by
Phone or Email
•Follow up using EPA form 8700-12
!! Waste MUST be removed within 60 days or the site will have to register as and
operate in compliance with Large Quantity Generator Status Requirements!!
Large
Quantity
Generators
LQG Hazardous Waste Storage
Requirements (R315-262 -17)
Container Storage (R315-262-17)
•Compatible with waste and well
maintained
•Kept closed and labeled
•Handled and stored to prevent
damage
•A central aisle maintained for
inspection
•Central Accumulation Areas must
be inspected weekly.
Storage Tanks (R315-262 -17(a)(2))
•Compatible with waste stored
•Properly labeled
•Isolation valve or bypass if continuous feed
•Designed, installed, certified by P.Eng
•Have 2°containment and release detection
•Inspected weekly and daily as per SQGs
•Site specific spill and leak response plan
HW storage tanks are subject to applicable
requirements of 40 CFR 265 subparts AA. BB, CC
Generate:
>2,200lbs (1000kg) hazardous waste
per calendar month
>2.2lbs (1kg) acute hazardous waste
per calendar month
NO Accumulation Limits
Waste must be removed from site
within 90 days of accumulation
•Obtain an EPA Identification Number
•Utilize a HW transporter that has a valid
EPA ID number
•Utilize TSDFs that have valid EPA ID
numbers
•Must re-notify every two (2) years
using EPA Form 8700-12
•Utilize HW manifests
•Submit a Biennial hazardous waste
form using EPA form 8700 -12
LQG Regulations (R315-262 -16-18/41)
LQGs LQGs must:
LQG and SQG: Other Requirements
Small and Large Generator Categories Must:
Comply with Preparedness and Prevention
Regulations and have a plan in place
Adequately train personnel
Maintain Emergency Procedures (LQGs only)
Have a written Hazardous Waste Contingency Plan
(LQGs only)
Satellite
Accumulation
Area (SAA)
R315-262 -15
Intended for industries who
generate small amounts of
hazardous waste in one or more
locations at a facility.
SAA Requirements (r315-262 -15)
•At or Near the Point of Generation
•Under Control of the Operator of the process generating the waste
•Quantities do not exceed Table 1
•Containers are labeled as “Hazardous Waste” and indication of hazards
•Containers are kept closed (except
under limited Circumstances)
•Containers must be dated and
moved to the central accumulation
area or osite within THREE (3)
consecutive calendar days.
Table 1: SAA non-acute and acute hazardous waste limits
Waste Type:SAA Limit:
Non-Acute Hazardous Waste ≤ 55 Gallons
Liquid Acute Hazardous Waste*≤ 1 quart (0.94L)
Solid Acute Hazardous Waste*≤ 2.2 lbs. (1kg)
*not intended to be additive. If both a solid and liquid acute HW are accumulating
in the SAA the ≤ 2.2lbs (1kg) limit will apply.
SAA Requirements Continued….
•All waste containers must be in good
condition.
•The containers used to accumulate
hazardous waste must be
compatible with the waste or lined
with a non-reactive material.
•If a SAA is located in an area with
personnel other than the Operator in
charge of the generating process,
the containers must be locked to
prevent access.
•Guidance Document:
https://documents.deq.utah.gov/waste-
management-and-radiation-
control/hazardous-waste/DSHW-2021-
010963.pdf
Central
Accumulation
Area Standards
For SGQs and LQGs
LQG Labelling Requirements
At the Point of Generation
CORROSIVE
IGNITABLE
REACTIVE
TOXIC
Prior to Shipping
LQG Ignitable or Reactive Waste
Storage (R315-262 -17(a)(1)(VI))
Must be stored to prevent ignition or
reaction
•Must be stored 50 ft from the property line
•Unless wrien approval from the local fire code administrator is granted.
•Protected from sources of ignition
•No smoking signs posted
•open flames, sparks, friction
•spontaneous ignition through exothermic chemical reactions
Final Thoughts…
Take-aways
The Generator is
responsible for waste
from Cradle to Grave!
Determining if a waste
material is hazardous is the
responsibility of the
GENERATOR
.•Co-generators are equally responsible for handling and
disposing of Hazardous Waste.
•Episodic Events can benefit you IF you inform the Division
within the appropriate timeframe
You are Not
Alone!
Utah’s DEQ, Waste Management &
Radiation Control Division holds a
wealth of information! See our
Website:
https://deq.utah.gov/division-waste-management-
radiation-control
Need a HW Storage extension? Planning an Episodic Event? Have a question? Contact us!
Document EVERYTHING and retain as required. Inspectors love paperwork and will want to see ALL of it!
Find more
information on
our website.
Division of Waste Management and Radiation Control -
Utah Department of Environmental Quality.
Questions?
Questions? Contact us
Lexi Adams
Environmental Scientist
PHONE [phone]
EMAIL [e-mail]
Thank You!
Front Desk PHONE [phone]