Hazardous Waste Generator Status Guidance by nyut545e2

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									Hazardous Waste Generator Status Guidance
Hazardous Waste Program fact sheet                                                         9/2007


Businesses that produce hazardous waste must follow certain federal and state laws and
regulations. The laws and regulations that apply to you depend on the amount and type of
hazardous waste your business produces. There are three waste generator categories:
1. Conditionally Exempt Small Quantity Generators
       • Produce less than 100 kilograms (kg) (220 pounds) of hazardous waste, and
       • Produce less than 1 kg (2.2 pounds) of acutely hazardous waste in one
         calendar month.
       • Do not accumulate 100 kg of hazardous waste or 1 kg of acute hazardous waste.
2. Small Quantity Generators
      • Produce or accumulate between 100 kg (220 pounds) and 1,000 kg (2,200 pounds) of
          hazardous waste, and
       • Produce or accumulate less than 1 kg (2.2 pounds) of acutely hazardous waste in one
          calendar month.
3. Large Quantity Generators
       • Produce 1,000 kg (2,200 pounds) or more of hazardous waste, or
       • Produce or accumulate 1 kg or more (2.2 pounds) of acutely hazardous waste, or
       • Produce or accumulate 1 gram or more of dioxin waste
          (2,3,7,8-tetrachlorodibenzo-p-dioxin) in one calendar month.
You cannot manage your business’ acute hazardous wastes separately from your other
hazardous wastes. For example: You cannot maintain Large Quantity Generator status for your
acute waste and maintain Small Quantity Generator status for all other hazardous wastes.
Change in Generator Status
According to the Code of State Regulations (CSR), businesses that produce or accumulate
100 kg or more of hazardous waste, or 1 kg or more of acutely hazardous waste, are required
to register with the Missouri Department of Natural Resources (department). According to
10 CSR 25-5.262(2)(A)3.B., those businesses are also required to complete and file an updated
generator registration form, known as a Notification of Regulated Waste Activity form, if any of
their information changes.




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When do I update my Notification of Regulated Waste Activity form for my business?
Whenever there is any change in
• Contact person,
• Business name,
• Mailing address,
• Phone number or area code,
• Ownership,
• Waste stream(s),
• Generator status, or
• Proper street address.
You must submit a Notification of Regulated Waste Activity form with any updated information to
the department. For a change in ownership, businesses must pay the usual registration fee.
If your proper street address changes, such as when a town renames a street or alters
numbering on a block, your business will keep its original generator identification number. If your
business changes locations, you will need to register the new location and request a new
generator identification number using the Notification of Regulated Waste Activity form. Your old
generator identification number is not transferable. The Notification of Regulated Waste Activity
form is available on the department’s Web site at www.dnr.mo.gov/forms/780-0408.pdf. You can
also contact the department’s Hazardous Waste Program at (573) 751-2524 to obtain a form.
Episodic Generators
Many businesses experience a one-time hazardous waste generation event where they produce
more hazardous waste than their current generator status. This event could be caused by a
change in product line, production error, recall of product, spill cleanup or similar event.
When this type of event happens and a Conditionally Exempt Small Quantity Generator business
produces or stores over 100 kg (220 pounds) of hazardous waste, then the business’ generator
status changes. The business is required to register as either a Small Quantity Generator or
Large Quantity Generator generator, depending on how much hazardous waste was produced
or stored. The business must also follow the regulations for that generator category. This
includes submitting a Generator Summary Report. This form is available on the department’s
Web site at www.dnr.mo.gov/forms/780-1097.xls. After the one time generation event, the
business can chose to return to their Conditionally Exempt Small Quantity Generator status as
long as they no longer produce or store at the higher level; however, hazardous waste fees and
taxes will apply to the waste produced during the event.
When this type of event happens at a Small Quantity Generator business, the event can be
considered an episodic event, if it occurs only once in 12 months and the business does not
store the extra waste for more than 30 days. Because the situation is temporary, the department
considers the business is in episodic generator status. There are three things to keep in mind
when trying to decide if your business qualifies as an episodic generator:
1. Amount of hazardous waste currently at the business.
2. Amount of hazardous waste the business has produced in the past.
3. Amount of hazardous waste the business plans to produce in the foreseeable future.


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You must notify the department of the episodic event in writing. Be sure to include the
following information:
• Business contact information,
• Missouri generator identification number,
• Reason for the extra hazardous waste,
• Estimated amount of extra waste,
• Anticipated time period for the event, and
• A statement that at the end of the period you will return to Small Quantity Generator status.
Send your notification by mail to the Missouri Department of Natural Resources, Hazardous
Waste Program, P.O. Box 176, Jefferson City, Missouri 65102-0176 or by fax to (573) 751-7869.
If you notify the department of your episodic event immediately, you may continue to provide an
annual Generator Summary Report. However, you are required to submit a biennial report to the
U.S. Environmental Protection Agency if the event occurs in an odd numbered calendar year.
For more information on biennial reporting, please contact the department’s Hazardous Waste
Program at (573) 751-3176.
Inspectors may check your hazardous waste records to make sure your business is classified
in the correct hazardous waste generator category and is following the regulations for that
category. You can simplify your business operations by remaining classified as a Large Quantity
Generator if you believe your business will repeatedly cross the limit between Small Quantity
Generator and Large Quantity Generator.
Episodic Generators - Example
A Conditionally Exempt Small Quantity Generator business performs a one time clean out of its
maintenance shed. One hundred kg of hazardous waste is produced as a result of the clean
out. The business must register as a Small Quantity Generator with the department, provide the
required hazardous waste reporting and pay the associated fees and taxes. The business must
follow all Small Quantity Generator requirements while the waste remains on site. The business
can return to Conditionally Exempt Small Quantity Generator status after the waste is
transported and as long as they do not produce 100 kg or more in any one calendar month
during the next 12 months.
Storage of 1,000 kg of hazardous waste
Many requirements for Small Quantity Generator and Large Quantity Generator businesses
are the same. However, according to 10 CSR 25-5.262(2)(C)2.A, you must meet additional
requirements if your business does the following:
• Produces hazardous waste at the Small Quantity Generator level, and
• Stores 1,000 kg (2,200 pounds) or more of hazardous waste.
In this case, your business would keep its Small Quantity Generator status but would also need
to meet some Large Quantity Generator requirements. These requirements include creating
and maintaining a personnel training plan like those required for Large Quantity Generators and
preparing and maintaining a contingency plan.




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Usually Small Quantity Generator businesses decide it is not cost-effective to store hazardous
waste because of the additional requirements. It is also important to remember that a Small
Quantity Generator business can not store more than 6,000 kg of hazardous waste, according to
40 CFR 262.34 (d)(1) without applying for a permit for hazardous waste storage.
Businesses that store over 1,000 kg of liquid hazardous waste, regardless of whether they are a
Small Quantity Generator or a Large Quantity Generator, must provide a containment system.
The containment system must have an impervious base and be free of cracks and gaps. The
base of the containment system must be either sloped or the hazardous waste containers must
be elevated off the base so that they are protected from contact with accumulated liquids. The
containment system must either have a capacity equal to 10 percent of the total volume of all the
liquid hazardous waste or the volume of the largest liquid hazardous waste container, whichever
is greater. Finally, businesses must prevent liquids from entering the containment system and
remove liquids as necessary to prevent overflow of the collection system.
Intermittent Generator Status
If you believe your business will not routinely store 1,000 kg of hazardous waste then you may be
considered by the department to be an intermittent generator. To qualify as an intermittent
generator your business
• Must not store 1,000 kg of hazardous waste for a day on more than two occasions a year, and
• Must not store 1,000 kg of hazardous waste over 30 days at one time.
Intermittent generators do not need to meet the personnel training plan and contingency plan. If
your business can not stay within the above limitations, then a personnel training plan and a
contingency plan must be created and maintained on site. If your business stores 1,000 kg of
liquid hazardous waste, you must have a containment system for the waste.
Intermittent Generator Status - Examples
A Small Quantity Generator business regularly produces 200 kg of liquid hazardous waste in one
calendar month. Once the business stores 1,000 kg or more of liquid hazardous waste, they
must also meet the Large Quantity Generator personnel training and contingency plan require-
ments. The business must also store their liquid hazardous waste in an appropriate contain-
ment system. Because the business only produces waste at the Small Quantity Generator rate,
the Small Quantity Generator storage timeframe of 180 days (or 270 days if shipped 200 miles
or more) still applies.
A Large Quantity Generator business produces over 1,000 kg of hazardous waste at one time.
However, the waste is pumped directly from the production unit into a tank truck for transport.
The business is not required to meet Large Quantity Generator accumulation standards, such
as a contingency plan and personnel training, if the waste is not stored for more than 24 hours.
The business must meet Large Quantity Generator accumulation standards if the waste is
stored for more than 24 hours. Regardless of whether the waste is stored or not, the business
is still a Large Quantity Generator due to the amount of hazardous waste they produce. Large
Quantity Generator reporting requirements still apply.
For more information
Missouri Department of Natural Resources
Hazardous Waste Program
P.O. Box 176
Jefferson City, MO 65102-0176
1-800-361-4827 or (573) 751-7136
www.dnr.mo.gov/env/hwp/index.html
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