Lion will be closed on Friday, July 3. For online training support, please contact support@lion.com.
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

Lion was very responsive to my initial questions and the website was user friendly.

Michael Britt

Supply Chain Director

Very well structured, comprehensive, and comparable to live training seminars I've participated in previously. I will recommend the online course to other colleagues with training requirement needs.

Neil Luciano

EHS Manager

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

You blew the doors off the competition!

Stephen Bieschke

Facilities Manager

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

Mary Sue Michon

Environmental Administrator

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

Marc Bugg

Hazardous Waste Professional

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

Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!

Stephanie Weathers

SHE Specialist

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

Download Our Latest Whitepaper

The definitive 10-step guide for new hazardous materials shipping managers. Quickly reference the major considerations and details that impact hazmat shipping compliance.

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.