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

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

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

Morgan Bliss

Principal Industrial Hygienist

If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials.

Bryce Parker

EHS Manager

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

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

Dorothy Rurak

Environmental Specialist

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

The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.

Mary Sue Michon

Environmental Administrator

I have been to other training companies, but Lion’s material is much better and easier to understand.

Mark Abell

Regional Manager

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

Cynthia L. Logsdon

Principal Environmental Engineer

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

David Hertvik

Vice President

Download Our Latest Whitepaper

Hazardous materials shipment rejections bear a big cost. Use this guide to end operational and logistical disruptions that severely impact your bottom line.

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.