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                       Hazardous Waste Generator Requirements                                      399

                                TABLE 12.4
                                Major CESQG Industries and Waste Types

                                Major CESQ Generating Industries      Major CESQG Waste Types
                                Vehicle maintenance                   Lead-acid batteries (61%)
                                Metals manufacturing                  Spent solvents/still bottoms (18%)
                                Laundries                             Dry cleaning filter residues (5%)
                                Printing/ceramics                     Photographic wastes (4%)
                                Pesticide users/appliers              Formaldehyde (3%)
                                Construction                          Acids and alkalis (2%)
                                Stone, clay, glass, and concrete
                                Food and kindred products
                                Primary steel and iron
                                Textile manufacturing
                                Pulp and paper
                                Source: U.S. EPA, 1994. With permission.



                          The CESQG is exempt from most hazardous waste management requirements. A facility meet-
                       ing the test for a conditionally exempt generator (generating < 100 kg per month and < 1 kg of acute
                       hazardous waste) is out of the RCRA cradle-to-grave system, provided the waste is sent to a facil-
                       ity that is at least state-approved. Details of the major CESQG industries and waste types are listed
                       in Table 12.4.

                       12.3.5 EPISODIC GENERATORS
                       Depending on the type of business and the amount of hazardous waste generated monthly, a facil-
                       ity might be regulated under different rules at different times. If, for example, a metal plating firm
                       generates between 100 and 1000 kg (220 and 2200 lb) of hazardous waste during January, it would
                       be considered a SQG for that month and its waste would be subject to the hazardous waste man-
                       agement requirements for SQGs. If, in June, it generates more than 1000 kg (2200 lb) of hazardous
                       waste, its generator status would change, and it would be considered a LQG for June. Its waste for
                       that month would then be subject to the management requirements for LQGs. For such generators
                       it is to the firm’s advantage to maintain all records, management protocols for storage, transporta-
                       tion, and so on, as a LQG.


                       12.4 REQUIREMENTS FOR LQGS AND SQGS

                       Once the waste is determined to be hazardous and is counted, the LQG must comply with the full
                       spectrum of federal hazardous waste regulations under 40 CFR as well as 49 CFR (Department of
                       Transportation; see Chapter 13). The SQG is subject to less stringent requirements. The LQG and
                       SQG must notify the EPA and state regulatory agency of hazardous waste activity and obtain a U.S.
                       EPA ID number.

                       12.4.1 THE EPA IDENTIFICATION NUMBER
                       Identification numbers are required for facilities that generate or manage hazardous waste, includ-
                       ing LQGs and SQGs, transporters, and treatment, storage, and disposal facilities (TSDFs) (Chapter
                       14). Once the state regulatory authority is contacted, the generator will be sent EPA Form 8700-12,
                       Notification of Regulated Waste Activity (Figure 12.1). An EPA identification number will be sub-
                       sequently provided for each facility location.
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