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

Excellent job. Made what is very dry material interesting. Thoroughly explained all topics in easy-to-understand terms.

David Hertvik

Vice President

I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!

George Chatman

Hazardous Material Pharmacy Technician

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

Michele Irmen

Sr. Environmental Engineer

The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable.

Marc Bugg

Hazardous Waste Professional

The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again.

John Nekoloff

Environmental Compliance Manager

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

I can't say enough how pleased I was with this course! Everything finally makes sense.

Kim Graham

Lab Manager

Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials.

John Troy

Environmental Specialist

I will never go anywhere, but to Lion Technology.

Dawn Swofford

EHS Technician

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

Download Our Latest Whitepaper

Four key considerations to help you maximize the convenience and quality of your experience with online training.

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.