Generator Emissions: Environmental Compliance Guide

Environmental Compliance Generator Regulations

Environmental regulations related to generators of hazardous waste are complex and crucial for protecting human health and the environment. Understanding your generator status and the associated responsibilities is paramount to avoid penalties and contribute to a sustainable future. This page provides a comprehensive overview of these regulations, focusing on US federal requirements under the Resource Conservation and Recovery Act (RCRA).

Generator Categories

The EPA classifies hazardous waste generators into three categories based on the amount of hazardous waste they generate in a calendar month:

• Very Small Quantity Generators (VSQGs): Generate less than 100 kg (220 lbs) of hazardous waste and less than 1 kg (2.2 lbs) of acutely hazardous waste per month.
• Small Quantity Generators (SQGs): Generate between 100 kg (220 lbs) and 1,000 kg (2,205 lbs) of hazardous waste and less than 1 kg (2.2 lbs) of acutely hazardous waste per month.
• Large Quantity Generators (LQGs): Generate 1,000 kg (2,205 lbs) or more of hazardous waste or more than 1 kg (2.2 lbs) of acutely hazardous waste per month.

Key Regulatory Requirements

Waste Determination

Generators must determine if their waste is hazardous. This involves evaluating the waste’s characteristics (ignitability, corrosivity, reactivity, toxicity) and listing it against the EPA’s hazardous waste lists (F-list, K-list, P-list, and U-list).

Waste Management

Proper waste management practices are essential. This includes:

• Storing hazardous waste in appropriate containers labeled with the words “Hazardous Waste” and the accumulation start date.
• Maintaining accurate records of waste generation and disposal.
• Preparing manifests for off-site shipments of hazardous waste.
• Ensuring proper disposal at permitted Treatment, Storage, and Disposal Facilities (TSDFs).

Training Requirements

Personnel who handle hazardous waste must receive appropriate training on proper handling procedures, emergency response, and regulatory compliance.

Recordkeeping and Reporting

Maintaining meticulous records is vital for demonstrating compliance. Generators must keep records of:

1. Waste determinations.
2. Manifests.
3. Waste analyses.
4. Training records.
5. Exception reports (for SQGs).
6. Biennial reports (for LQGs).

Emergency Preparedness and Response

Generators are required to have contingency plans in place to address potential releases of hazardous waste. These plans should include:

• Emergency contact information.
• Procedures for containing spills and releases.
• Training for emergency responders.
• Arrangements with local emergency services.

Conclusion

Navigating the complexities of environmental compliance for hazardous waste generators requires diligence and a thorough understanding of the regulations. By correctly identifying your generator status, implementing proper waste management practices, maintaining accurate records, and preparing for emergencies, you can contribute to environmental protection and avoid costly penalties. It is highly recommended to consult with environmental professionals and legal counsel for specific guidance tailored to your operations. Staying informed about regulatory updates and best practices is crucial for long-term compliance and sustainability.