What’s So Special About September 1st?
That, in 1914 the last known passenger pigeon, a female named Martha, died in captivity at the Cincinnati Zoo, that in 1939 Germany invaded Poland, starting World War II and that in 1972 American Bobby Fischer beat Russian Boris Spassky in Reykjavík, Iceland to become the world chess champion?
Probably, but for Small Quantity Generators (SQGs), September 1st 2021 is special because of the re-notification requirements prominently mentioned in Lisa's recent flash. Thank you for the responses. Below, we have two of the questions we received, a pun and our (disclaimer) interpretations.
Question 1: Do existing SQG have to refile this form by Sept 1st this year, or in 4 years?
YES, Small Quantity Generators (SQGs) must re-notify by reviewing and updating their information by September 1st and then every four (4) years (starting in 2021).
Here is the link to the instructions and forms: RCRA Subtitle C Reporting Instructions and Forms
Question 2: if we generate three 55 gallon drums of Hazardous waste a year totaling 1376 lbs., could we be a VSQG because 1376 / 12 months is 115 lbs. a month, which is less than 220 lbs.?
YES, you can be a Very Small Quantity Generator VSQG, according to 40 CFR 262.14, if you generate less than 100 kg (220 pounds) per month. However, you can not average it over the 12 months. You would have to make sure each month there was less than 220 pounds.
But, if you would go over 220 pounds, up to twice a year you could take an episodic event exception and maintain your VSQG, or even Small Quantity Generator SQG, status using planned and unplanned episodic events as defined in 262.231. As described in 262.232, this allows a VSQG to generate over 220 pounds of hazardous waste for approximately two months. This could be used in the case of recalled material, off-spec inventory, unexpected large waste accumulation because of maintenance or higher capacity production runs. This would trigger the requirement for VSQG to apply for an EPA hazardous waste number. Which is a “very small” price to pay!
The second avenue of relief that should be considered by all generators when authorized, universal waste in Part 273 Standards for Universal Waste Management for batteries, pesticides, mercury containing equipment, lamps and aerosol cans.
Utilize these strategies so that your hazardous waste doesn’t count as hazardous waste.
Please remember that we are here to assist you, do not hesitate to contact us and we will do our best to give you an answer or direct you to where the answer can be found. This information and more can be found in our New 2021/2022 Hazardous Materials, Substances and Wastes Compliance Guide or better yet, discuss it further with me at one of my Transportation Skills Programs training seminars.
As always thank you for your patronage,
Robert J. Keegan
Publisher and President
Hazardous Materials Publishing Co.
Transportation Skills Programs
www.hazmat.tsp@gmail.com
Phone 610-683-6721