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Counting Spent Solvents to Determine Hazardous Waste Generator Status


									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

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