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State of Idaho RCRA Series Department of Environmental Quality November 1997 Counting Spent Solvents to Determine Hazardous Waste Generator Status Generator between 220 lbs. and spent solvent meets the responsibility 2200 lbs. generated each definition of a regulated A generator of a solid waste, month or 13,200 lbs. hazardous waste under 40 as defined in 40 CFR §§ accumulated on-site. CFR § 261.3, as either listed 261.10 and 261.2, must and/or characteristic, the ® Large Quantity facility must count the spent determine if the solid waste Generator (LQG)—2200 solvent towards the facility’s is a regulated hazardous lbs. generated each generator status. waste under the State of month or 13, 200 lbs. Idaho Hazardous Waste accumulated on-site. How to count spent Management Act (HWMA)/ Federal Resource Conserva- solvents for on-site Generation and accumula- tion and Recovery Act tion of acutely hazardous recycling (RCRA). A generator must waste (AHW) for a facility’s Scenario A: then determine the facility’s generator status are not A facility does not recycle a generator status by totaling discussed in this document. regulated spent solvent on- the amount of regulated site, but disposes or recycles hazardous waste accumu- Spent solvents off-site. The entire amount of lated in excess of the accu- One type of solid waste is a spent solvent generated is mulation quantities under 40 spent material 40 CFR § counted in the facility’s CFR §§ 261.5 (g)(2) and 261.1 (c)(1) “A spent material generator status. 262.34(d). is any material that has been Scenario B: used and as a result of con- There are three types of A facility accumulates spent tamination can no longer regulated generator status solvent prior to recycling. serve the purpose for which facilities: Because of prior accumula- it was produced without tion the spent solvent be- ® Conditionally Exempt processing.” comes subject to the accumu- Small Quantity Spent material may be re- lation requirements of 40 Generator (CESQG)— cycled for reuse either at the CFR § 262.34 and the entire 220 lbs. generated each facility or off-site of the amount of spent solvent month or 2200 lbs. generating facility. Spent must be counted towards the accumulated on-site. solvent is one common type facility’s generator status. ® SmallQuantity of solid waste generated by a The still bottoms or sludge Generator (SQG)— variety of industries. If the from the recycling process RCRA Series should not be counted process must be counted because the spent solvent has towards the facility’s genera- already been counted once tor status. Because the spent when generated and accu- solvent is recycled on a daily mulated. basis the total spent solvent is not required and should Once the spent solvent is not be counted toward the recycled, the usable solvent facility’s generator status. is no longer regulated as a hazardous waste, but is If a solvent is spent and managed as a product. recycled more than once in a calendar month, without If a solvent is recycled more accumulation prior to each than once in a calendar recycling, the amount of still month, and accumulated bottoms or sludge must be prior to each recycling, the counted each time and amount of accumulated added towards the facility’s spend solvent must be generator status. The total counted each time and amount of spent solvent added towards the facility’s entering each recycling generator status. The still process should not be bottoms or sludge from each counted each recycling recycling process should not process. be counted because the spend solvent has already A more detailed description been counted once per each of counting of spent material generation and accumula- and recycled hazardous tion. waste is found in Federal Register Vol. 51, No. 56, Scenario C Monday, March 24, 1986 A facility does not accumu- late spent solvent prior to For more information recycling. Spent solvent is Contact the Division of recycled on a continuous or Environmental Quality, daily basis, within 24 hours Hazardous Waste Science of generation. The State of Officer at: Idaho has determined 24 hours as the allowable time 1410 N. Hilton limit for accumulation of Boise, Idaho 83706 spent materials prior to the (208) 373-0502 recycling process to allow for continuous or batch recy- cling on a daily basis. Only the amount of still bottoms generated from the recycling
"Counting Spent Solvents to Determine Hazardous Waste Generator Status"