Additionally, ACA expressed concerns over a couple of new proposed options for flexibility in the proposed rule, including 1) allowing CESQGs
to send their hazardous waste to an LQG that is under the control of the same person, and 2) allowing a CESQG
or an SQG to maintain its existing generator category even if it were to exceed its generator category limits due to an episodic event (planned or unplanned) subject to certain conditions.
For those operating as a CESQG
(or those who will be a CESQG
once the HWP regulations are effective), these rules are likely to ease their burdens.
Since less than one kilogram of acute hazardous waste is allowed per month for a CESQG, laboratories must carefully monitor these specific wastes to ensure compliance.
Storage requirements in place for SQGs and LQGs are recommended for CESQGs as well, though not regulated.
CESQGs are businesses that produce less than 220 pounds of hazardous waste a month and do not accumulate more than 2,200 pounds at any given time.
Providing secondary containment for hazardous waste or hazardous material is a BMP and is not a requirement for CESQGs.
Household Hazardous Waste (HHW), as well as CESQG
wastes are exempted from hazardous waste disposal requirements under Title 40 of the Code of Federal Regulations, Attachment 261.