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

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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.

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              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

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