* Revising the regulations for making hazardous waste determinations--the proposed rule would require LQGs, SQGs (and possibly CESQG) to keep very detailed records not only for wastes determined to be hazardous but also wastes determined to not be hazardous; both the initial determination if the waste is solid or not, and also if the waste "changed in property";
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.
Recognizing that generators produce waste in different quantities, EPA established three categories of generators in the regulations: conditionally exempt small quantity generators (CESQGs), small quantity generators (SQGs), and large quantity generators (LQGs).
* Allowing conditionally exempt small quantity generators (CESQGs) to send hazardous waste to a large quantity generator (LQG) that is under the control of the same person, provided certain conditions are met;
In addition, two proposals for conditionally exempt small quantity generators (CESQGs
) have the potential for easing regulatory burdens for those generators under two circumstances:
Most laboratories will likely be categorized as a CESQG, which requires the following steps per the EPA and/or state regulatory agencies: All generated hazardous waste must be identified, more than 2,200 lb of waste may not be accumulated at any one time and the waste must be delivered to a person or facility that is authorized to manage it.
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.
organizations are exempt from most of the RCRA disposal standards.
The Local Hazardous Waste Management Program (LHWMP) is a multi-agency effort mandated by the state of Washington with the goal of keeping hazardous and toxic materials out of the environment through education and behavioral changes in industries that generate hazardous wastes (LHWMP in King County, 1997; Washington State Department of Ecology, 2000), City and county governments are responsible for assisting conditionally exempt small-quantity generators (CESQGs) under this State Department of Ecology mandate.
Providing secondary containment for hazardous waste or hazardous material is a BMP and is not a requirement for CESQGs. The Audit Team recommended this practice, however, in order to prevent hazardous waste from accidentally entering the environment.
Complete disposal records, including manifests and certificate of destruction, minimize a generator's future liability, although CESQGs are required only to maintain receipts or bills of lading.