5 Things to Know About Episodic Hazardous Waste Generation

With the Hazardous Waste Generator Improvements Rule, EPA provided relief for so-called “episodic hazardous waste generation” events – occasions when a facility that is usually a small quantity generator (SQG) or a very small quantity generator (VSQG, formerly conditionally exempt small quantity generator) of hazardous waste generates more than its monthly limits, potentially elevating the facility into a higher generator category.

Now that the rule change has passed and been adopted by many states (including Florida, Georgia and Alabama), your facility may be able to maintain its normal generator status in the event of a one-time exceedance of your monthly threshold (i.e., 100 kilograms or 220 pounds per month for VSQGs, 1,000 kilos per month for SQGs with more limited thresholds for listed, “acute” hazardous waste). The Hazardous Waste Generator Improvements Rule established criteria (at 40 CFR 262, Subpart L) for episodic generation of hazardous waste that allow you to continue to comply with the rules applicable to your usual generator status.

Here are 5 key things to keep in mind when dealing with an episodic hazardous waste generation event.

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Generator Improvement Rule: Relief for Hazardous Waste Generators?

Well, certainly some relief for the very little ones – what we used to call “conditionally exempt small quantity generators” – henceforth (or beginning on the effective date of the Environmental Protection Agency’s Hazardous Waste Generator Improvements Rule, published in the Federal Register on November 28, 2016) to be known as Very Small Quantity Generators or VSQGs.

The Hazardous Waste Generator Improvement Rule, which EPA describes as the culmination of a review that began over 10 years ago, is meant to “improve program effectiveness, reduce compliance costs, and foster an improved relationship with states and the regulated communities.”

The final rule contains a number of provisions which EPA identifies as “more stringent”, including marking and labeling of wastes to identify hazards, Small Quantity Generator recertification, notification of facility closure and requirement that a Large Quantity Generator close as a landfill if it cannot meet closure standards, extending biennial reporting for the whole year rather than just months when the facility was an LQG, biennial reporting for recyclers even when they do not store waste prior to recycling, and a requirement that LQGs provide a “quick reference guide” for distribution with their Contingency Plans. “More stringent” standards must be adopted by states that manage their own hazardous waste programs.

The rule also contains “less stringent” provisions, of a kind that may elicit appreciative nods from industries. These address (1) consolidation of VSQG waste at a LQG facility under the same ownership; (2) allowing VSQGs and SQGs to retain their classification in the event that “episodic generation” would bump them up to a higher generator category; and (3) waiver from the requirement that ignitable and reactive wastes be stored at least 50 feet from a facility’s property line under certain circumstances.

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