Page 420 - Materials Chemistry, Second Edition

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12 Hazardous Waste Generator

Requirements

“Always do right; this will gratify some people and astonish the rest”.

Mark Twain

12.1 INTRODUCTION

RCRA regulations call for cradle-to-grave management of hazardous wastes, i.e., wastes are to be
tracked from the point of their initial generation through storage and transportation, to final treat-
ment and disposal. As a first step in this management framework (and as discussed in Chapter 11),
the waste generator is required to determine if any solid wastes generated at their facility are haz-
ardous so that the wastes will be managed and tracked properly. Secondly, a waste generator’s
responsibilities regarding storage, transport, and disposal options depend upon the volume of waste
generated per calendar month. Hazardous waste generators are classified as large quantity genera-
tors (LQGs), small quantity generators (SQGs), and conditionally exempt small quantity generators
(CESQGs), based on these monthly volumes.

12.2 DETERMINING THE GENERATOR CATEGORY
According to RCRA (40 CFR Part 262), the generator must measure (count) the quantity of haz-
ardous waste generated per calendar month. Wastes that must be counted include those:

● Accumulated on-site before disposal or recycling
● Placed into a treatment or disposal unit on the facility site
● Collected as sludges and removed from product storage tanks

In the early days of RCRA, counting requirements had resulted in some confusion on the part
of both generators and regulators. In some situations, for example, the regulations were interpreted
such that the same waste was counted several times. The requirements have since been fine-tuned.
Basic principles of waste counting are as follows:

● Materials generated on-site that are either listed or characteristic hazardous wastes must
be counted.
● Materials are not counted until they are removed from the production process. For exam-
ple, plating baths which are being used and reused, or a spent solvent still in the produc-
tion process, are not counted until they are removed from the process.
● Waste is counted only once in a calendar month. In some cases, for example, a waste may
be used more than once a month by recycling within the facility. Under the current
requirements, only the initial quantity is counted.
● Wastes discharged to a publicly owned treatment works, in compliance with Clean Water
Act standards, are not covered under the RCRA system.

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