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How Does EPA's Generator Improvements Rule Affect CESQGs?

Posted on October 29, 2019 by Roseanne Bottone

Since EPA’s Generator Improvements Rule (GIR) was finalized in 2016, we’ve taken a close look at how that rule changed day to day RCRA compliance for large and small quantity generators—including new container marking rules, expanded contingency plan requirements, new notification and recordkeeping requirements, re-organized RCRA regulations, new reliefs for episodic generation, and more.

But what about the smallest of generator categories—known before the GIR as Conditionally Exempt Small Quantity Generators or CESQGs?

EPA didn’t forget about CESQGs when writing the Generator Improvements Rule. In fact, the rule made some important changes for this generator category.    

A New Name

Right off the bat, the Generator Improvements Rule renamed CESQGs as “Very Small Quantity Generators” or VSQGs.

The name changed, but the monthly generation limit for VSQGs remains the same – 100 kg of non-acute hazardous waste and 1 kg of acute hazardous waste.

The GIR also clarified what was always true: If the VSQG exceeds these limits, they then become a small quantity generator (SQG). As an SQG, they can hold the waste onsite up to 180 days (or 270 if shipping more than 200 miles away). They must not exceed 6,000 kg of total accumulation. And, they must follow the small quantity generator exemption (i.e., the 180-day rules) specified at 40 262.16 (b)(2) through (f).

The accumulation quantity limits for small quantity generators (1,000 kg for non-acute hazardous waste and 1 kg of acute hazardous waste) remain the same as well. The GIR clarified that if these limits are exceeded, the VSQG may accumulate the waste onsite for only 90 days more and must comply with the large quantity generator exemption (i.e. the 90-day rules) at 40 CFR 262.17(a) through (g).

Suppose you remain within the required generation and accumulation limits; how do you manage the waste? The GIR consolidated the VSQG rules at 40 CFR 262.14.

Let’s take a look:

Independent Requirements for VSQGs

All generators of hazardous waste must meet independent requirements specific to their generator category. This is just a fancy way of saying that a Very Small Quantity Generator must:
  • Identify their hazardous waste and keep records; and
  • Count the waste on a monthly basis to prove their generator category.

Conditions for Exemption for VSQGs

The RCRA permitting regulations in 40 CFR 270 state that anyone who treats, stores, or disposes of hazardous waste must have a permit to do so.

To be exempt from this permitting requirement, the generator must follow the “conditions for exemption” that apply to their generator category. For VSQGs, this means following all the rules at 40 CFR 262.14. For large quantity and small quantity generators, the conditions for exemption are found in 40 CFR 262.17 and 262.16, respectively.

This was always the case. The GIR simply re-worded and restructured the rules to clarify the intent of the RCRA regulations.

The Big News for VSQGs

The GIR added two significant new provisions for VSQG facilities:
  1. A large quantity generator owned or operated by the same entity as the VSQG may now receive the VSQG’s waste; and
  2. A VSQG experiencing an episodic event – either planned or unplanned – may manage that waste according to 40 CFR 262, subpart L and retain their generator status. Waste managed under these rules is not counted toward generator category. This might include a lab cleanout, a purge of unused commercial chemical products, a temporary rev-up of production, or a spill.
Be sure to check whether your State has adopted the GIR in its entirety. While states must adopt the changes that are more stringent than existing requirements, they are not required to adopt rules that are less stringent than their approved program.

RCRA Training for Very Small Quantity Generators 

Are you a VSQG? Be confident that you know the RCRA hazardous waste regulations that apply to your site's regulated waste streams. The RCRA for Very Small Quantity Generators online course covers the latest requirements for generators previously known as Conditionally Exempt Small Quantity Generators or CESQGs. 

For complete training to manage compliance with RCRA at any facility, large or small, join us for the two-day workshop widely considered "the standard" in hazardous waste training. The RCRA Hazardous Waste Management Workshop comes to Houston, Boston, Manchester, Hartford, Northern NJ, and Philadelphia before the end of 2019! 

Can't join us live? Learn online when and where you want with these reliable, up-to-date online courses: 

RCRA Hazardous Waste Management
RCRA Hazardous Waste Management Refresher 
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