What to Count
Generators must count the quantity of hazardous waste generated each month in order to determine their generator classification.
The rules that set forth which wastes are counted, and which wastes are excluded from being counted, are applicable to all three classes of generators– small quantity generators (SQGs), large quantity generators (LQGs), and conditionally exempt small quantify generators (CESQGs). When counting hazardous waste, you need to include all hazardous waste you generate except hazardous waste that:
- Is exempt from regulation under 40 CFR 261.4(c) to (f) (wastes generated in a product or raw material unit as well as waste samples used for characteristic determination or treatability studies)
- Is exempt from regulation under 40 CFR 261.6(a)(3) (certain recyclable materials)
- Is exempt from regulation under 40 CFR 261.7(a)(1) (hazardous waste remaining in an empty container or its inner liner)
- Is exempt from regulation under 40 CFR 261.8 (polychlorinated biphenyls regulated under the Toxic Substances Control Act)
- Is managed immediately upon generation only in on-site elementary neutralization units, wastewater treatment units, or totally enclosed treatment facilities as defined in 40 CFR 260.10
- Is recycled, without prior storage or accumulation, only in an on-site process subject to regulation under 40 CFR 261.6(c)(2)
- Is used oil managed under 40 CFR 261.6(a)(4) and 40 CFR 279
- Is spent lead-acid batteries managed under 40 CFR 266, Subpart G
- Is universal waste managed under 40 CFR 261.9 and 40 CFR 273
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Don’t Double Count
To avoid double counting, the regulation states that wastes that do not need to be counted when determining generator class, provided they were counted when they were initially generated, are:
- Hazardous waste when removed from on-site storage
- Hazardous waste that is produced from on-site treatment (including reclamation) of hazardous waste
- Spent materials that are generated, reclaimed, and subsequently reused on-site
How to Count
The regulations set forth the generated quantities in kilograms (kg), the equivalent quantities in pounds (lb) are:
- 1 kg = 2.2 lb
- 100 kg = 220 lb
- 1,000 kg = 2,200 lb
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However, a large percentage of hazardous wastes are liquids, not solids, and are measured in gallons. Therefore, in order to measure liquid wastes, the gallons must be converted to pounds. The conversion will depend on the density of the liquid. A rough guide is to figure that 30 gallons (gal) (a little more than half of a 55-gal drum) of waste with a density similar to water will weigh about 220 pounds (100 kg). Consequently, a 55-gal drum holds slightly less than 200 kg of liquid waste with a density similar to water.
Your State May Be Stricter
The list of hazardous wastes that are excluded from being counted may vary in some states, making the state rule more stringent than its federal counterpart. In other words, a waste that does not need to be counted under the federal rule may have to be counted under a state rule. Similarly, a state may have designated certain wastes as hazardous that are not so designated under federal law. These state hazardous wastes must be counted.
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