Generator Treatment Requirements If a HW generator conducts exempt permissible treatment, how does this impact generator recordkeeping and reporting requirements? Can one be categorized as a lower generator category [Large Quantity Generator (LQG) to Small Quantity Generator (SQG) to Very Small Quantity Generator (VSQG)] if treating waste? The answers depend primarily on whether the treatment conducted produces a final waste stream which is no longer characterized as hazardous waste. In general, most forms of generator treatment do not occur immediately upon generation or remove characteristic waste codes such as those treatment processes performed at RCRA permitted Treatment, Storage, and Disposal Facilities (TSDF). For example, compacting a drum with solvent-contaminated debris to minimize the number of hazardous waste drums shipped offsite does not change the ignitability concern of the solvent-contaminated debris (and in-turn, does not change the facility’s generator category). There are several federal provisions that exempt HW from being counted towards the monthly generator total and associated Waste Generation and Management (GM) reporting required by the federal or state agency (i.e., federal biennial report for LQG, state-specific annual or biennial HW reporting). However, only two (2) exemptions pertain directly to treatment: f HW managed immediately upon generation including: • Corrosive HW managed in an on-site ENU • HW managed in a WTU or TETU • Any hazardous byproducts exiting the WTU and TETU must
familiarize themselves with state agency requirements which may offer additional operational flexibility. Examples include: f Washington Department of Ecology • Washington defines RCRA hazardous waste as “dangerous waste”, which is more robust than the federal definition, and has developed guidance allowing generators to treat
hazardous waste without a permit via the following: solidification, evaporation, filtration, carbon adsorption, separation, polymerization, aldehyde deactivation
f Ohio Environmental Protection Agency • Ohio allows for generator treatment without a permit to the fullest intent of EPA’s rules including use of evaporators to concentrate inorganic wastes f Indiana Department of Environmental Management • Use of evaporators for aqueous waste is permissible if performed in tanks meeting specific design standards and only water is being evaporated from waste which contains less than one (1) part per million volatile hazardous constituents f California Department of Toxic Substances Control • California has developed Permit by Rule (PBR) requirements allowing operation of certain generator hazardous waste treatment activities in tanks or containers, designated Fixed Treatment Units (FTU) and Transportable Treatment Units (TTU), without a state-issued Hazardous Waste Facilities Permit • The PBR excludes reactive and extremely hazardous waste
be counted towards the generator total (e.g., distillation column bottoms, WTU sludge, treatment residuals that do not satisfy the LDR treatment standards)
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