Friday, November 25, 2016

New Rule On Episodic Hazardous Waste Generation For VSQG & SQG Facilities

One of the persistent issues for hazardous waste generators has been when short term spikes in hazardous waste generation elevate facilities to a higher generator class, resulting the requirement to meet additional generator requirements. The Hazardous Waste Generator Improvements Rule addresses this issue by creating another type of waste generation – episodic hazardous waste generation. Because large quantity generators are not limited by monthly generation, this rule only affects VSQG and SQG generators.

Two types of episodic hazardous waste generation are created – planned and unplanned. Planned episodes, as the name suggests, can be planned ahead of time and include activities such has facility cleanups, obsolete inventory disposal, demolition projects, etc. Unplanned episodes include spills, fires, and other emergency incidents. Under the new rule, hazardous waste generated during these events will not count against monthly waste total and will not change generator status, if conditions are met.

Generators taking advantage of this option will be limited to one event per calendar; with opportunity to petition for one additional unplanned event in the same year.

For planned events the generator must:
  • notify agency at least 30 days prior,
  • identify start/end dates (60 day max),
  • have EPA ID #, and
  • ship within 60 days using a hazardous waste manifest.
For an unplanned event the generator must notify agency within 72 hr after incident. For either type of episode, the generator must label wastes “Episodic Hazardous Waste” and identify hazard characteristic (example, corrosive, flammable). Episodic waste totals are not added to monthly facility total; separate records must be kept of episodic wastes.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at or Caltha LLP Website 

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