LARGE QUANTITY GENERATOR

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LARGE QUANTITY GENERATOR

• Generates more than 1000 kg (2200 lbs) of
  hazardous waste per month. Approximately 5
  drums.
• Generates more than 1 kg (2.2 lbs) of acutely
  hazardous waste per month.
• No storage quantity limits/lt 90 day storage time
  limit

LQG
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LQG Requirements

• All of the SQG requirements plus ..
• Do Not Store HW gt 90 Days
• File Quarterly Report for HW generated Shipped
  Offsite
• Maintain Emergency Equipment
• Expanded Contingency Plan
• Position Descriptions
• Annual Training

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Step 3 Identifying Waste Streams

• Landscaping/Grounds Keeping
• Pesticide/Herbicide
• Fertilizer
• Rinse water from cleaning equipment
• Maintenance on equipment

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Laboratories

• Pathology
• Histology
• Microbiology
• Chemistry
• Serology

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Laboratory Wastes

• Xylene
• Alcohol
• Alcohol/xylene/stain
• Formalin
• Mercury
• Out of date chemicals

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Radiology
Spent photographic fixer containing silver
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Pharmacy

• Out of date or damaged drugs
• Chemotherapy waste

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Fleet Maintenance

• Parts washer / Mineral Spirits
• Carburetor Cleaner
• Brake Cleaner
• Used Oil
• Antifreeze
• Contaminated Rags
• Batteries

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Other Wastes

• Expired/Off Spec Chemicals, Reagents, Standards
• Lab packs

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Other Wastes(cont.)

• Miscellaneous
• Broken Thermometers
• Rinsates from cleaning glassware
• Waste pump oil
• Debris contaminated with listed waste
• i.e. chem. wipes and funnels contaminated
• with methylene chloride
• Gram Staining
• Tissue Preservation

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SO WHAT DO WE LOOK FOR DURING AN INSPECTION?
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Waste Determination

• Failure to perform hazardous waste determination
  and/or a proper waste determination.
• Failure to document claims that materials are not
  solid wastes (non-hazardous) OR are conditionally
  exempt from regulation.

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Notification

• Failure to notify/obtain an EPA ID number
• Failure to keep emergency information up to date

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Manifests

• Failure to use a hazardous waste manifest
• Failure to file an exception report (45/60 days)
• Missing or incorrect information on manifest.
• Failure to use a transporter that has a SC HW
  registered t-porter.
• Failure to retain manifests for 3 years.
• Missing LDR
• Use of old manifest after 9-05-06

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Labeling

• Failure to label drums/containers with
• the words Hazardous Waste or
• for satellite accumulation containers
• label with a description of the contents.
• Failure to label each container according to DOT
  regulations prior to shipment.
• Failure to offer transporter
  appropriate placards.

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Accumulation

• Accumulation beyond the 90(180) day limit.
• Drums/containers not marked with accumulation
  start dates.
• Accumulation of too much HW on site.

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Satellite Accumulation

• 55-gallons Maximum
• At or near the Point of Generation
• Labeled Hazardous Waste or
• other Words that Describe Contents
• Mark waste accumulated in excess
• of 55-gallons with the date of accumulation
• 72 hours to move to storage area

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Container Management

• Open, rusting or bulging drums
• No weekly inspection of containers.
• Storing ignitable waste within 50 feet of
  property line.
• Failure to maintain aisle
• space between containers.

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Record Keeping

• Failure to maintain uniform
• manifest or contractual
• agreement for 3 years.
• Failure to retain records of test results, waste
  analyses, or waste determinations.

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Personnel Training

• Failure to conduct training.
• Training does not cover all areas.
• Failure to document training
• conducted.
• Training not completed within
• 6 months of hire date.
• Training is not completed annually.
• Failure to provide job titles, job descriptions,
  and names.

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Preparedness and Prevention

• No arrangements with local authorities.
• Arrangements not documented.
• Failure to have required equipment.
• Failure to maintain and operate facility to
  minimize unplanned or sudden release.

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Contingency Plan/Emergency Procedures

• Failure to have a contingency plan.
• Incomplete or outdated contingency plan.
• Failure to submit a contingency plan to
  authorities.
• Incomplete reporting after an incident.
• Failure to implement a contingency plan.
• Failure to report emergency incident (assuming
  contingency plan was implemented).
• Failure of SQG to post information by telephone.

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Land Disposal Restrictions

• Failure to perform waste analyses prior to
  treatment of waste to determine if the waste is
  restricted from land disposal (improper disposal
  of restricted wastes).
• Failure to develop and follow a written waste
  analysis plan for on-site treatment of restricted
  wastes in tanks or containers. DILUTION of LDR
  waste or treatment of residual is not a
  substitute for adequate treatment.
• Failure to provide or use a LDR with a hazardous
  waste shipment.
• Failure to retain LDRs and waste analysis data
  for 3 years.
• Missing or incorrect information on LDR forms.

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The Process

• Warning Letter
• Inspection Report
• Pictures
• Violations
• Penalties
• Informal Conference
• YOUR chance to respond
• Discussion of alleged violations
• Consent Order
• Formal resolution of informal agreement

• Inspection Report
• Pictures