Search
Search

Question of the Week: CESQG & Waste Disposal

Posted on 8/23/2011 by James Griffin

Q. I am a Conditionally Exempt Small Quantity Generator (CESQG) of hazardous waste. What requirements do I have to meet when disposing of my waste?
 
A. The EPA provides significant relief for CESQGs at 40 CFR 261.5. In order to be exempt from most of the RCRA hazardous waste regulations, most CESQGs need to do three things:
 
  • Identify their waste (i.e. they still need to know whether they have generated hazardous waste), 
  • Remain below generation and accumulation limits (the federal rules specify <100 kg/month, <1 kg/month acutely hazardous waste, and <1,000 kg total), and 
  • Ensure their waste is delivered to an appropriate location (more below). 
If you meet these requirements, you are relieved from typically applicable rules for generators (40 CFR 262.34, etc.). These reliefs include not having time limits for how long you can hold your waste on site, not having to use a hazardous waste manifest when shipping off site, not having to treat your waste to meet land disposal restrictions (LDRs), and not having to use only permitted TSDFs (treatment, storage, and disposal facilities).
 
In fact, CESQG waste can be delivered to any of the following:
 
  • A hazardous waste TSDF, 
  • A facility authorized by the state to accept waste (which could be something like a solid waste landfill), 
  • A recycling facility, or 
  • A household hazardous waste facility. 
Of course, these facilities would have to be willing to take the CESQG waste. And in addition to those, because CESQG hazardous wastes are exempt from 40 CFR 270, a permit is not required for a facility to accept CESQG hazardous waste from off site. That means a CESQG can also send its waste to a small quantity generator (SQG) or a large quantity generator (LQG). However, that waste would then have to be counted by those facilities toward their generator status.
 
Reference: [40 CFR 261.5] 
 

Tags: hazarodus waste, RCRA

Find a Post

Recent Posts

Compliance Topics

Compliance Archives

Lion - Quotes

This is the best RCRA training I've experienced! I will be visiting Lion training again.

Cynthia L. Logsdon

Principal Environmental Engineer

The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing.

Linda Arlen

Safety & Environmental Compliance Officer

The instructor was great, explaining complex topics in terms that were easily understandable and answering questions clearly and thoroughly.

Brittany Holm

Lab Supervisor

This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.

Rachel Stewart

Environmental Manager

Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider.

Francisco Gallardo

HES Technician

Lion does a great job summarizing and communicating complicated EH&S-related regulations.

Michele Irmen

Sr. Environmental Engineer

Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic.

Dorothy Rurak

Environmental Specialist

Lion is easily and consistently the best option for compliance training. I've learned new information from every instructor I've had.

Rachel Mathis

EHS Specialist

Course instructor was better prepared and presented better than other trainers. Course manual and references were easier to use as well.

Marty Brownfield

Hazardous Waste Professional

The instructor was very engaging and helped less experienced people understand the concepts.

Steve Gall

Safety Leader

Download Our Latest Whitepaper

This report details major changes for hazardous waste generators from US EPA’s Generator Improvements Rule, as well as the latest updates from states that are still working to adopt new, stricter Federal requirements.

Download
Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.