The final Hazardous Waste Generator Improvements Rule (Rule), published in the Federal Register on November 28, 2016, contains two of what the U.S. Environmental Protection Agency (EPA) refers to as “voluntary programs”—meaning that generators of hazardous waste have the choice of whether to comply with the new programs’ requirements. The first program is a set […]
Q. Because of removing excess chemical inventories one month this year, I changed from being a small quantity generator (SQG) to a large quantity generator (LQG). Which set of requirements should I comply with and for how long?
As frequent visitors to EPA’s Resource Conservation and Recovery Act (RCRA) Online database already know, the Agency’s hazardous waste regulations prompt a constant stream of questions from both regulated entities and RCRA-authorized states about applicability, lack of clarity, and regulatory gaps. A small fraction of EPA’s answers and interpretations responding to such questions have now […]
Q. Our company is a 3rd party warehouse company. We have various customers and each one holds their own EPA ID number at our site. One customer is a Large Quantity Generator (LQG). Are there any regulations that specify that both us and our customer must submit the biennial report?
The U.S. Environmental Protection Agency (EPA) proposed what it calls the Hazardous Waste Generator Improvements on September 25, 2015. An extended comment period closed December 24, 2015. The Agency has received over 230 comments on the proposal. The Advisor reviewed a number of them and will give you the gist of what people are saying […]
Last fall, the U.S. Environmental Protection Agency (EPA) issued a proposed rule that would make significant changes to regulatory requirements for hazardous waste generators. Comments were accepted until December 24, 2015. Let’s take a look at what a sampling of stakeholders had to say about EPA’s proposed amendments to hazardous waste generation under the Resource […]
Are you a large quantity generator (LQG) of hazardous waste? If so, you and hazardous waste treatment, storage, and disposal facilities (TSDFs) are required to submit hazardous waste reports (aka, biennial reports) by March 1 this year. Do you even know if you are an LQG? In the newest biennial report form, released by the […]
Recap: Under the federal Resource Conservation and Recovery Act (RCRA) rules, and most state variations of the RCRA rules, there are three classes of generators: large quantity generators (LQGs), small quantity generators (SQGs), and conditionally exempt small quantity generators (CESQGs). The classes are defined by the amount of hazardous waste generated each month. If you […]
Counting Hazardous Waste You know you generate hazardous waste at your facility and you want to keep your disposal costs down. Well, then, you have to keep down the amount of hazardous waste you have on-site each month. If you are a large quantity generator (LQG), your responsibilities and costs will be greater than if […]
Under the federal Resource Conservation and Recovery Act (RCRA) rules, and most state variations of the RCRA rules, there are three classes of generators: large quantity generators (LQGs), small quantity generators (SQGs), and conditionally exempt small quantity generators (CESQGs). Note: It is critical to remember that most states have been delegated the authority to run […]