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 • : * ------- |