United State*
Environmental Protection
Agency
Off ice of
Solid Waste and
Emergency Response
3EPA
DIRECTIVE NUMBER: 9441.05(80)
TITLE: Small Quantity Generator
»
APPROVAL DATE: 11-17-80
EFFECTIVE DATE: 11-17-80
ORIGINATING OFFICE: osw
D FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
D B — Signed by Office Director
DC — Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
-------
J.PART 261 SUBPART A - GENERAL
DOC: 9441.05(80)
Key Words: Small Quantity Generators, HSWA
Regulations: 40 CFR 261.5, HSWA. 221(d)
Subject: Small Quantity Generator
William A. McClintic, Defense Division Brunswick Corporation
Addressee:
Orginator:
Source Doc:
Date:
Summary:
Gary N. Dietrich, Associate Deputy Assistant Administrator Office
of Solid Waste
#9441.05(80)
11-17-80
A generator that generates both small quantities and large quantities of
hazardous waste does not receive the §261.5 exclusion for small quantity genera-
tors. Section 261.5 applies only to generators that generate an aggregate
amount of hazardous waste of less than 1000 kilograms per month at any one site
or facility.
However, the Hazardous and Solid Waste Amendments, require the Agency to
promulgate new regulations which will lower the exclusion level of small quantity
generators to less than 100 kilograms.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
9441.05 (80)
NOV 1 7 1980
Mr. William A. McClintic
Defense Division
Srunsv/ick Corporation
150 Johnston Road
Marion, Virginia 24354
Dear Mr. McClintic:
This is in response to your letter of September 25, 1930, asking'
for clarification of the applicability of our hazardous waste management
regulations to very small quantities of hazardous wastes generated
by a generator who also generates a large quantity of hazardous waste.
-The snail quantity generator special requirements of §261.5 of our
regulations are only available to generators that generate an aggregate
T.ount of hazardous wastes of less than 1000 kilograms per month at any
.ie site or facility. If the aggregate amount of hazardous wastes
generated at a site or facility exceeds this monthly amount, then the
special requirements of §261.5 do hot apply to any of the hazardous
wastes generated at that site or facility. I air, afraid, therefore,
that the very small quantities of hazardous waste generated at your
Marion facility are subject to the "full" regulations because the single
large quantity of hazardouo waste disqualifies the facility for the
special small quantity generator requirements .
l. ho^«. this surricieiitly answers your questions .
Sincerely yours,
Gary N. Dietrich
Associate Deputy Assistant Administrate:
for Solid Uaste
bcc: filomena Chau w/incomihg
WH:GDietrich:bm:ll/13/80:401 M
v CONCURRENCES
iQU I
AMC^
* >
^vU^lZS*
/'//3/&y
•
:
*
------- |