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

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities.

Pamela Embody

EHS Specialist

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

John Troy

Environmental Specialist

Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again.

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training.

Timothy Mertes

Hazmat Shipping Professional

These are the best commercial course references I have seen (10+ years). Great job!

Ed Grzybowski

EHS & Facility Engineer

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

Having the tutorial buttons for additional information was extremely beneficial.

Sharon Ziemek

EHS Manager

The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information.

Morgan Bliss

Principal Industrial Hygienist

The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!

Chelsea Minguela

Hazmat Shipping Professional

Download Our Latest Whitepaper

Get to know the top 5 changes to OSHA’s revised GHS Hazard Communication Standard at 29 CFR 1910.1200 and how the updates impacts employee safety at your facility.

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.