Hazardous Waste Management

Hazardous Waste Generators FAQ Roundup

After the decision is made to vent propane from a cylinder, up until it is vented onsite, does a propane cylinder need to be managed as D001 hazardous waste?

Because the container of D001 hazardous waste does not yet meet the “RCRA empty standard” (as explained at 40 CFR 261.7) the container must be managed as a hazardous waste (40 CFR 261.7(1)(2)).

If I’m a SQG that has generated enough waste to to be considered a LQG, for how long does this new classification last?

Here is an excerpt from the “Episodic Generator” subsection of the Enviro.BLR.com National Hazardous Waste Generators Regulatory Analysis which should answer your question.

“According to EPA, if the amount of hazardous waste generated in a given calendar month places the generator in a different category, the generator is an “episodic generator” responsible for complying with all applicable requirements of the generator category for all waste generated during that calendar month. For example, if an SQG produces 300 kg of hazardous waste in May, that waste must be managed in accordance with the SQG regulations; if the same generator produces 1,500 kg of hazardous waste in June, that waste must be managed in accordance with the LQG regulations. Generators often wonder if once they’ve become a different category of generator due to an episodic event, they remain in that category for the rest of the calendar year, especially if they became a larger generator. Regarding the described example, EPA would say that the generator must comply with all applicable LQG requirements for hazardous wastes generated in June for as long as that waste remains on-site. If the generator reverts back to SQG status in July, the generator must continue to manage the hazardous waste generated during the month it became an LQG according to all applicable LQG requirements. (What requirements that situation involves, in practice, will be determined by the state environmental regulatory agency.) Hazardous waste generated during any months the generator was an SQG can be managed under SQG requirements….If you find you have had an episodic generation, contact your state environmental regulatory agency as to any particular requirements for episodic generators, such as notifying the agency of the change in generator class, requesting an EPA ID number (if you do not already have one), or filing an annual report (if your state requires them) for all or part of the calendar year.”

My facility is going from a small quantity generator of hazardous waste to a large generator due to a one time need to dispose of some obsolete or out of spec paint. Since this is a one time deal will it bumps us to a large quantity generator?

An SQG would be considered an LQG in the month where it generated the waste paint. Here is an excerpt from the “Episodic Generator” subsection of the BLR National Generator Regulatory Analysis with months mentioned in the text bracketed as they refer to a particular example, which is not unlike yours:

EPA would say that the generator must comply with all applicable LQG requirements for hazardous wastes generated in [June] for as long as that waste remains on-site. If the generator reverts back to SQG status in [July], the generator must continue to manage the hazardous waste generated during the month it became an LQG according to all applicable LQG requirements. (What requirements that situation involves, in practice, will be determined by the state environmental regulatory agency.) Hazardous waste generated during any months the generator was an SQG can be managed under SQG requirements.”