GENERATION AND MANAGEMENT
OF CESQG WASTE
Office of Solid Waste
Municipal and Industrial Solid Waste Division
U.S. Environmental Protection Agency
July 1994
Prepared under contract no. 68-W3-0008 by:
ICF Incorporated
9300 Lee Highway
Fairfax, VA 22031
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TABLE OF CONTENTS
SECTION PAGE
EXECUTIVE SUMMARY I
I. INTRODUCTION 3
Background 3
Methodology and Data Sources 3
Outline of Remainder of Report 4
n. CHARACTERIZATION OF CESQGs; MAJOR FINDINGS FROM NATIONAL STUDIES 6
A. Number of CESQGs and Waste Volume 6
B. Major CESQG Waste Generating Industries and Waste Types 8
C. CESQG Waste Management Practices 12
m. CHARACTERIZATION OF CESQGs: MAJOR FINDINGS FROM STATE AND LOCAL STUDIES 17
A. Number of CESQGs and Waste Volume 17
B. Major CESQG Waste Generating Industries and Waste Types 19
C. CESQG Waste Management Practices 22
IV. FEDERAL AND STATE REQUIREMENTS FOR CESQGs 26
A. Federal Requirements 26
B. State Requirements 26
v. SCREENING MECHANISMS 31
VI. CONCLUSIONS 33
Appendix A 34
Appendix B 41
Appendix C 45
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EXECUTIVE SUMMARY
This report summarizes existing data on the waste generation and management practices of
conditionally-exempt small quantity generators (CESQCs) to help EPA satisfy the RCRA Section 40lO(c)
mandate for non-municipal facilities that may receive CESQG waste.1 The data included in this report
are summarized from seven national, state, and local studies on CESQGs. These data sources are
described in greater detail in Exhibit A-l of Appendix A. One of these sources, the National Small
Quantity Hazardous Waste Generator Survey (National SQG Survey), provides a comprehensive overview of
CESQG waste generation and management practices nationwide. This survey was conducted from 1983 to
1984. Findings from the National SQG Survey are summarized below:
+ Number of CESQGs. The lotal number of CESQGs in both manufacturing and non-
manufacturing sectors nationwide is approximately 455,000.
CESQG Waste Volume. The total waste volume generated by all CESQGs nationwide is
approximately 201,600 tons per year (tons/yr).
The remaining findings of this survey are based on detailed data collected from establishments in
125 targeted SIC codes. These industries were targeted because they were identified as most likely to be
CESQGs. The 125 SIC codes were grouped into 22 industry groups for comparison purposes.
Major CESQG Waste Generating Industries. For the 22 industry groups, approximately
80 percent of establishments are in the non-manufacturing sector and these establishments.
generate approximately 88 percent of the CESQG waste volume. The remaining 20
percent of establishments are in the manufacturing sector, generating approximately 12
percent of the CESQG waste volume. The vehicle maintenance industry is the largest
industry both in terms of number of generators (approximately 54 percent of all
generators) and waste volume (approximately 71 percent of waste volume) for the 22
industries surveyed. Other major non-manufacturing industries include laundries,
construction, and pesticide application services and end users. Key manufacturing
industries include metals manufacturing and printing and ceramics.
Major CESQG Waste Types. The major CESQG waste types for the 22 industry groups
surveyed are used lead-acid batteries, spent solvents and still bottoms, perchloroethylene,
and photographic wastes.
CESQG Waste Management Practices. For the 22 industry groups surveyed,
approximately 80 percent of CESQG waste is managed off-site, with the remainder
managed on-site. The predominant off-site management methods include:
Recycling (73 percent of waste managed off-site or 69,900 tons/yr);
Disposal at a non-hazardous solid waste landfill2 (Ten percent of waste managed
off-site, or 9300 tons/yr), either by direct haul or mixture with the solid waste
stream at the point of generation; and
Disposal at a permitted Subtitle C landfill (two percent of the waste managed off-
site, or 2,000 tons/yr).
1 Code of Federal Regulations (CFR), Title 40, Section 261.5 defines CESQGs as generators of less
than 100 kilograms per month (kg/mo) of hazardous waste or 1 kg/mo of acutely hazardous waste.
2 The National Small Quantity Hazardous Waste Generator Survey does not distinguish between a
municipal or non-municipal (e.g., industrial, construction and demolition landfill).
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Page 2 GENERATION AND MANAGEMENT OF CESQG WASTE
The predominant on-site management methods for the22 industries surveyed include:
- Disposal in the sewer and/or septic system (56 percent of the waste managed on-
site, or 14,600 tons/yr); and
Disposal in a non-hazardous solid waste landfill (two percent of the waste
managed on-site, or 509 tons/year).
Although EPA believes that the National SQC Survey provides a relatively comprehensive and
national picture of CESQC waste generation and management practices, the Agency feels that the findings
should be viewed in context; the data for the survey were collected during 1983 and 1984, nearly a decade
ago. EPA believes that the current situation regarding CESQG waste generation and management
practices is substantially different from when these data were collected. Significant changes have taken
place over the past few years, for example:
New wastes have entered and exited the hazardous waste system;
The methodology for identifying characteristic wastes has changed;
Superfund liability concerns have become an important factor for industry to consider
when determining waste management options; and
New regulatory activities, such as reporting under the Toxics Release Inventory, have been
catalysts for industry to change manufacturing processes and other practices to reduce
waste volumes and toxicity.
Other data sources reviewed in this report present findings that are both similar and dissimilar
from the National SQG Survey. The findings of these data sources should also be viewed in context. For
example, some sources are narrow in scope (i.e., state and local data), making comparisons difficult In
addition, several sources conducted surveys on a limited number of industries or on one sector (e.g.,
manufacturing sector).
One data source reviewed in this report, Hazardous Waste From Small Quantity Generators (SQC
book), provides further information on state requirements for CESQGs. This source finds that 34 states3
had one or more requirements for CESQGs that were more stringent than Federal regulations for
CESQGs. Specifically, 22 states require all or some CESQGs to manage their hazardous waste at a
permitted Subtitle C facility, thus going beyond Federal regulations and prohibiting disposal at a municipal
or industrial solid waste facility.4
3 For'the purpose of this report 'states* includes the SO states and the District of Columbia.
4 Among other options, 40 CFR 261.5(g) requires CESQGs to manage their hazardous waste in an
on-site or off-site management facility that is a permitted or interim status Subtitle C Hazardous waste
management facility, or is a state permitted, licensed, or registered municipal or industrial solid waste
management facility.
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GENERATION AND MANAGEMENT OF CESQC WASTE Page 3
SECTION I. INTRODUCTION
BACKGROUND
In 1980, EPA promulgated regulations pursuant to RCRA that, among other things, delineated
responsibilities for hazardous waste generators, transporters, and management facilities (treatment, storage,
and disposal facilities, or TSDFs). Additionally, the regulations established a conditional exclusion from
full regulation for generators that generated less than 1,000 kg/mo of hazardous waste .
In the 1984 amendments to RCRA (tbe Hazardous and Solid Waste Amendments (HSWA)),
Congress added specific provisions pertaining to generators of less than 1,000 kg/mo, including lowering
the exclusion level to 100 kg/mo. This action created three classes of generators: (1) large quantity
generators, generators of greater than 1,000 kg/mo; (2) small quantity generators, generators of 100 to
1,000 kg/mo; and (3) generators of less than 100 kg/mo, which at the time were referred to as very small
quantity generators. Congress gave EPA the discretion as to whether to promulgate new requirements for
the very small quantity generators.
EPA has since defined generators of less than 100 kg/m as conditionally-exempt small quantity
generators, or CESQGs. This conditional exemption does not require CESQGs to comply with several
regulations specified for generators of more than 100 kg/mo, such as requirements to obtain an EPA
identification number, use a manifest when shipping hazardous waste, report to EPA on a biannual basis,
or send their hazardous waste to a permitted or interim status Subtitle C facility. CESQGs, however, are
responsible for the proper management of their hazardous waste, which, among other things, includes the
options to manage their hazardous waste in a state permitted, licensed, or registered municipal or
industrial solid waste management facility, or in a permitted or interim status Subtitle C management
facility.
Section 40lO(c) of RCRA (as amended by HSWA in 1984) requires EPA to promulgate new
regulations for all solid waste (i.e., non-hazardous) facilities that may receive hazardous household wastes
or hazardous wastes from conditionally-exempt small quantity generators. In October 1991, EPA
promulgated revised criteria pursuant to Section 4010(c) for municipal solid waste landfills (codified at 40
CFR Pan 258). These revised criteria fulfilled EPA's obligation with respect to one waste category,
household hazardous wastes. Municipal solid waste landfills, however, may also accept CESQG waste; and
to the extent that they do. EPA's obligation with respect to this class of -waste has also been fulfilled. To
complete fulfillment of the statutory mandate, EPA is currently reviewing regulatory options to revise
criteria for non-municipal facilities that may receive CESQG waste.
This report summarizes existing data on CESQG waste generation and management practices 10
assist EPA in analyzing regulatory options. In addition. Exhibit C-l in Appendix C presents the results of
a brief search for available pollution prevention opportunities for some of the major CESQG waste
generating industries.
METHODOLOGY AND DATA SOURCES
This report identifies and analyzes the findings and results of seven studies that address CESQG
waste generation and management practices. A more detailed discussion of each study, including the
study's data source, scope, year of completion, methodology, and response rate, if applicable, can be found
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Page4 GENERATION AND MANAGEMENT OF CESQG WASTL
in Exhibit A-1 of Appendix A. The studies are summarized as follows:
(1) National Small Quantity Hazardous Waste Generator Survey (National SQG Survey). This is
a survey of 22 manufacturing and non-manufacturing industries conducted during 1983
and 1984 for EPA's Office of Solid Waste. The survey targeted those industries whose
firms were thought to be significant generators of less than 1.000 kg/mo of hazardous
waste. The survey distinguishes CESQGs from SQGs.
(2) Screening Survey of Industrial Subtitle D Establishments (Telephone Screening Survey
(TSS)). During 1987, EPA conducted a survey of 17 manufacturing industries that
generate significant quantities of non-hazardous waste and dispose of this waste on-site in
land-based units (i.e., surface impoundments, landfills, waste piles, and land application
units). Among those firms that disposed non-hazardous waste on-site in land-based units,
the survey sought information on whether the firms also generated CESQG waste and
whether they managed this waste in on-site, land-based units as well.
(3) Hazardous Waste From Small Quantity Generators (SQG book). This book, published in
1990, is primarily a guide for businesses and governments on the proper management of
hazardous waste from small quantity generators. The book, however, is useful for this
report because it gives an estimate of the number of CESQG establishments add details
state requirements for CESQGs as of 1990.
(4) Moderate Risk Waste: A Progress Report (Washington CESQG Report). This report,
prepared in December 1990 by the State of Washington, details the State's progress in
managing moderate risk waste, which the state defines to include CESQG waste.
(5) Washington 1988 Hazardous Waste Annual Report Summary (Washington HW Summary).
The Slate of Washington requires CESQGs, as well a& aU other hazardous waste
generators, to report annually on their waste generation and management practices. This
summary provides data for those CESQGs that submitted reports in 1988.
(6) Survey of CondittoaauyEtemptSinatt Quantity Generators of Ha
County, Maryland (Montgomery County Survey). In 1993, Montgomery County, Maryland
surveyed firms in seven industries that were thought to be major CESQG waste generating
industries. This report details the waste generation and management practices of
CESQGs responding to the survey.
(7) Hazardous Waste From CESQGs in the Municipal Waste Stream: A Literature Review
(Literature Review). Prepared for EPA in September 1993, this is a literature review of
several state and local studies that have characterized CESQG waste generation and
management practices, as well as requirements for CESQGs in several states and
municipalities.
OUTLINE OF THE REMAINDER OF THE REPORT
The remainder of this report is organized into the following five sections:
+ Section n summarizes the major findings of the national studies of CESQG waste
generation and management practices;
* Section ID summarizes the major findings of state and local studies of CESQG waste
generation and management practices;
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GENERATION AND MANAGEMENT OF CESQG WASTE Page 5
Section IV discusses Federal and state requirements for CESQGs;
Section V briefly discusses methods required by four states to screen out CESQC waste ai
off-site non-hazardous waste management facilities; and
Section VI presents conclusions for this report.
In addition, this report includes three appendices:
Appendix A provides summary data tables for the information presented in Sections II and
III;
» Appendix B provides a summary data table for Federal and State requirements for
CESQGs, discussed in Section IV; and
Appendix C presents the results of a brief search for available pollution prevention
opportunities for some of the major CESQG waste generating industries.
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Page 6 GENERATION AND MANAGEMENT OF CESQG WASTE
SECTION H. CHARACTERIZATION OF CESQGs: MAJOR FINDINGS FROM
NATIONAL STUDIES
This section summarizes the major findings from three national studies regarding CESQG waste
generation and management practices. These three studies are:
National Small Quantity Hazardous Waste Generator Survey (National SQG Survey);
Scnening Survey ofIndustrial Subtitle D Establishments (TSS); and
Hazardous Waste From Small Quantity Generators (SQG book).
The scope and methodology, as well as other information, for each of these three studies are presented in
Exhibit A-l of Appendix A. EPA believes that of these three data sources, the National SQG Survey
presents the most comprehensive information on CESQG waste generation and management practices
nationwide. However, the Agency believes that the findings of this survey should be viewed with caution,
since the data for this survey were collected in 1983-1984, nearly a decade ago. Over the past few years
several significant changes have taken place that have affected CESQG waste generation and management
practices, for example:
New waste types are generated while others may BO longer be generated;
The methodology for identifying characteristic wastes has changed;
+ Superfund liability concerns have become an important factor for industry to consider
when determining waste management options; and
+ New regulatory activities (e.g., reporting under the Toxics Release Inventory) have been
catalysts for industry to change manufacturing processes and other practices to reduce
waste volumes and toxitity.
Other data limitations of the National SQG Survey and the other two national sources are
discussed below in conjunction with a summary of the sources* major findings.
A. NUMBER OF CESQGS AND WASTE VOLUME
Exhibit 1 summarizes the findings from the three national studies regarding the number of
CESQG establishments nationwide and the total volume of CESQG waste.
Number of CESQGs
As Exhibit 1 indicates, the number of all CESQGs nationwide is estimated to range from 455,000
to 700,000. The National SQG Survey estimates that there are 455,000 CESQG establishments nationwide.
Tim data source bases this estimate on an extrapolation of data collected from a survey of 22
manufacturing and non-manufacturing industries thought to be significant generators of hazardous waste in
quantities of less than 1,000 kg/mo. The data for this survey were collected in 1983-1984. The second
estimate of the total number of CESQGs nationwide, 700,000. is found in the SQG book. The SQG book
bases this estimate on an extrapolation of data provided by two sources: (1) marketing figures from waste
management firms; and (2) CESQG data from five states and 11 counties. One limitation with the SQG
book's estimate of 700,000 is that the data were not collected from a scientific national survey, as is the
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GENERATION AND MANAGEMENT OF CESQG WASTE
Page 7
EXHIBIT I
Number of CESQGs and CESQG Waste Volume5
(national studies)
Title of National Study
National Small Quantity Hazardous Waste Generator Survey
- >~
Hazardous waste From Small Quantity Generators
Screening Survey of Industrial Subtitle D Establishments
Scope of Study
All Industries
Alt Industries
17MFR*
Industries
Number or
CESQGs
455,000
700,000
3,742
CESQG
Waste
Volume
(tons/yr)
201,600
-
-
case with the National SQG Survey. Further, the five states and 11 counties are not identified in the book,
making it difficult to determine whether these studies provided an appropriate sample from which to
extrapolate national estimates, or to identify tne age of the data collected for these studies.
The third national study, the 755, estimates that there are 3,742 CESQG establishments
nationwide. This estimate is significantly different than the other two national estimates for the following
reasons:
Whereas the other two data sources estimate the total number of CESQGs in both
manufacturing and non-manufacturing sectors, the 755 estimates the total number of
CESQG establishments in 17 manufacturing industries only; and
* Further, these 3,742 establishments are the number of establishments in 17 manufacturing
industries that in addition to generating and managing non-hazardous waste in on-site,
land-based units, also generate CESQG waste. (Exhibit A-2 in Appendix A diagrams the
sequence of questions used in the TSS.)
This source is significant, however, since an estimated 605 of the 3,742 establishments also dispose
of their CESQG waste in on-site, land-based units. These estimates should also be viewed with caution
since the 755 was conducted in 1987. Since then some of these establishments may have ceased disposal
of CESQG waste in on-site, land-based units due to state regulatory changes or increased liability
concerns. Nonetheless, to the extent that establishments continue to dispose of their CESQG waste in on-
site, land-based units, any revisions to criteria under Section 4010(c) of RCRA that EPA may consider for
facilities managing CESQG waste may impact how these establishments manage their CESQG waste.
CESQG Waste Volume
As Exhibit 1 indicates, only one national study, the National SQG Survey estimates total CESQG
waste volume nationwide, 201,600 tons per year (loosfyr). At the time that the data for this study were
5 The findings in this exhibit are taken directly from the associated study or have been calculated
using other results included in the study.
6 MFR denotes 'manufacturing" and N-MFR denotes non-manufacturing.*
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PageS
GENERATION AND MANAGEMENT OF CESQG WASTE
collected, 1983-1984, this total CESQG waste volume represented only 9.07 percent of the total amount of
hazardous waste generated by ati generators (conditionally-exempt, small quantity, and large quantity),
estimated at approximately 290,000,000 tons/yr.
More recent state and local studies suggest that these national estimates for the number of
CESQG establishments and total CESQG waste volume, however, appear to be low. For example,
according to the Washington Department of Ecology, Washington State alone had approximately 43,000
CESQGs generating 53,200 tons/yr of hazardous waste in 1990, This waste volume amount represents
nearly one-third of the total national waste volume estimate. State and local studies are discussed in
greater detail in Section III.
B. MAJOR CESQG WASTE GENERATING INDUSTRIES AND WASTE TYPES
Exhibit 2 lists the major CESQG waste generating industries and CESQG waste types identified
by two national sources; the SQG book did not provide estimates for these data elements.
EXHIBIT 2
Major CESQG Waste Generating Industries and Waste Types
(national studies)
Title of National Stud;
National SQG Survey
TSS
Scope of
Study
(22MFR,
N-MFR*
Industries)
(17MFR
Industries)
Major CESQG Generating
Industries
vehictemaintenan.ee
metals manufacturing
laundries
printing/ceramics
other services
pesticide users/appliers
construction
stone, day, glass, and concrete
# food and kindred products
» primary steel and iron
textile manu&cturiog
pulp and paper
Major CESQG Waste :
Type*7
tead-aori batteries (61%)
spent solvents/tall bottoms ( 18%)
dry cleaning filter residues (5%)
photographic wastes-(4%)
formaldehyde (3%)
acids and akalides (2%)
Not Provided in Report
MFR denotes "manufacturing" and N-MFR denotes "noa-manufactunag.*
Major CESQG Waste Generating Industries
As Exhibit 2 indicates, the National SQG Survey identifies the vehicle maintenance industry as the
largest CESQG industry (from the 22 industry groups surveyed) both in terms of number of CESQGs (54
percent) and waste volume (71 percent). This data source finds that the following industries are also
major CESQG waste generating industries:
Metals Manufacturing generates the second highest amount of CESQG waste for the
industries surveyed, approximately 6.1 percent, and nearly one half of the CESQG waste
volume in the manufacturing sector alone;
7 Percentages in parentheses shows the percent of total waste volume for the waste types as reported
in the associated study or determined through calculations using other findings reported in the study.
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GENERATION AND MANAGEMENT OF CESQG WASTE Page 9
Laundries generate approximately 4.8 percent of total CESQG waste volume for the
industries surveyed;
Printing/Ceramics generates nearly 4.8 percent of total CESQG waste volume for the
industries surveyed, and nearly 39 percent of CESQG waste in the manufacturing sector
alone;
Pesticide End Users and Application Services generate approximately 2.1 percent of all
CESQG waste volume for the industries surveyed;
Construction generates 1.9 percent of CESQG waste for the industries surveyed; and
Photography generates approximately 1.8 percent of total CESQG waste for the industries
surveyed.
Exhibit 3 compares these industries both in terms of number of generators and waste volume.
This exhibit indicates that according to the National SQG Survey, non-manufacturing industries dominate
both in terms of number of CESQG establishments and waste volume. More recent state and local studies
(discussed in Section III) also find that major CESQG industries are predominantly in the non-
manufacturing sector. Three of these studies find that the vehicle maintenance industry is the largesror
second largest CESQG industry. Comparing state and local findings with those of the National SQG
Survey should be done with caution, however, since these studies may or may not include used motor oil pr
used lead-acid batteries as a waste type for the vehicle maintenance industry, thus affecting the relative
significance of this industry. The National SQG Survey, for example, did not include used motor oil as a
waste type, while some state and local studies did.
The other national data source reviewed was the TSS. Again, it should be noted that this study
surveyed 17 manufacturing industries only, and only identified establishments as CESQGs if, in addition to
disposing non-hazardous waste in on-site, land-based units, they also generated CESQG waste. This survey
found that 60S of the 3,742 CESQGs in these 17 manufacturing industries disposed of their waste in on-
site, land-based units. The following five industries were identified as having a significant number of
establishments that in addition to generating CESQG waste, also disposed of this waste in on-site, land-
based units:
Stone, Clay, Glass, and Concrete (26 percent of CESQG establishments that dispose of
CESQG waste in on-site, land-based units);
Food and Kindred Products (22 percent);
Primary Iron and Steel (eight percent):
Textile Manufacturing (eight percent); and
Pulp and Paper (seven percent).
CESQG waste volumes are not reported in this study.
Comparing the results of the TSS to the National SQG Survey is problematic, considering that the
TSS surveyed manufacturing industries only, while the National SQG Survey looked at both manufacturing
and non-manufactunng industries. The only comparison between the two studies that can be made is for
the textile manufacturing and pulp and paper industries. The National SQG Survey estimates that each of
these two industries generates approximately 0.05 percent of the total CESQG waste volume. As a result
of this waste generation amount, the National SQG Survey found both industries to be relatively small
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EXHIBIT 3
Major CESQG Waste Generating Industries
By Number of Generators
4% 5%
By Waste Volume
13%
4%
8%
10%
54%
71%
Non-Manufacturing
Vehicle Maintenance | Construction
Other Non-manufacturing [ ] Laundries
Pesticide Application Services and End Users
Manufacturing
| Other Manufacturing
I Printing/Ceramics
I Metals Manufacturing
Source: National SmaH Quantity Hazardous Waste Generator Survey (1985). based on survey ol 22 major CESQQ industry groups
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GENERATION AND MANAGEMENT OF CESQG WASTE
Page 11
generators of CESQG waste. None of the state and local studies identified any of the industries listed in
the TSS as major CESQG waste generating industries.
CESQG Waste Types
As Exhibit 2 indicates, only one national data source, the National SQG Survey, identified major
CESQG waste types. This major waste types are presented in Exhibit 4.
EXHIBIT 4
Major CESQG Waste Types
61%
18%
Solvwtti/Btn
Dry Owning
Adds and AfcalldM Ottwr Waito TypM
Source: NatKX^Sm»«Qtwuie)tvH«zaiTlou» Waste G«n«rmlor Survey (1985): b«»«l on Mjrv«yof22 m^OfCESQQ industry group*.
With the exception of spent solvents/still bottoms and acids and aivaiMV*. these waste types are
generally specific to one industry (formaldehyde is a significant waste type for the funeral service and
crematory industry). Spent solvents/still bottoms and acids and aikaiid** however, are significant waste
types in several industries. Many state and local studies (see Section III) identified used motor oil as the
largest CESQG waste type. The National SQG Survey, however, did not include this waste type, which
probably accounts for the discrepancy. Several state and local studies found that spent solvents/still
bottoms, used lead-acid batteries, and photographic wastes were major CESQG waste types. Again,
comparing state and local studies to the National SQG Survey should be done with caution. Some state
and local studies, for example, used National SQG Survey results to target their surveys, thus one might
expect the results to be similar.
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Page 12
GENERATION AND MANAGEMENT OF CESQG WAST,.
C. CESQG WASTE MANAGEMENT PRACTICES
Exhibit 5 summarizes the results of the National SQG Survey and the 755 regarding
CESQG waste management practices.
EXHIBITS
CESQG Waste Management Practices8
(national studies)
Title of National Study
National Small Quantity
Hazardous Waste
Generator Survey
Screening Survey -of
Industrial Subtitle D
Establishments
Scope
of Study
22MFRand
NMFR industries
17 MFR mduunes
Method of Management
Off-Site
80% of CESQG waste for
the industries surveyed
(95,226 tcns/yr)
Recycling (73%)
Unknown (13%)
Solid Waste Landfill9 (10%)
Permitted Subtitle C Landfill
(2%)
84% of CESQG
establishments: u
industries surveyed
Subtitle C Facility
Incineration
Energy Recovery
Tanks
Recycling
On-Site
20% of CESQG waste for
the Industrie* surveyed
(26,176 tonayr)
Sewer (46%)
Septic System (10%)
Solid Waste Incineration ;
(3%)
Solid Waste Landfill (2%).
16% of CESQG
establishments in
industries surveyed
Landfills
Surface Impoundments
Land Application
Waste Pile
General CESQG Waste Management Practices
For the 22 industries surveyed, the National SQG Survey found that approximately.80 percent of
the CESQG waste is managed off-site, while approximately 20 percent is managed on-site. The
predominant off-site management methods for the 22 industries surveyed are:
Recycling (73 percent of waste managed off-site or 69,900 tons/yr);
a The findings in this exhibit are found in the associated study or calculated using other results
provided in the study. The waste amounts managed, as reported by the National SQG Survey, do not add
up to 201,600 tons, since the managed amounts are based on data collected from the 22 surveyed
industries, while the 201,600 figure is a national estimate extrapolated from the survey data.
The study does not distinguish between, municipal and non-municipal landfills.
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GENERATION AND MANAGEMENT OF CESQG WASTE Page 13
Disposal at a non-hazardous solid waste landfill10 (ten percent of waste managed off-
site, or 9,300 tons/yr), either by direct haul or mixture with the solid waste stream at the
point of generation; and
Disposal at a permitted Subtitle C landfill (two percent of the waste managed off-site, or
2,000 tons/yr).
The predominant on-site management methods for the 22 industries surveyed are:
Disposal in the sewer and/or septic system (56 percent of the waste managed on-site, or
14,600 tons/yr); and
* Disposal in a non-hazardous solid waste landfill (two percent of the waste managed on-
site, or 509 tons/year).
With regard to the data from the National SQG Survey four significant data limitations apply:
The data on waste management methods is for only the 22 industries surveyed. Together
these industries represented approximately 60 percent of total CESQG waste nationwide.
No extrapolations of waste management data to a national level were given.
A substantial portion of the CESQG waste from some industries is not allocated to any :
waste management method and no explanation for these data gaps is offered.
The survey reports that approximately 13 percent of waste managed off-site by the 22
industries is managed in an "unknown* facility. "Unknown* is not defined.
For off-site solid waste landfills, the study does not differentiate between municipal and
non-municipal (e.g., industrial or construction and demolition landfill). This is an
important distinction considering that EPA has revised criteria for municipal facilities,
requiring these facilities to meet more stringent design and operating criteria than non-
municipal facilities.
The National SQG Survey estimates that 1,956 generators in eight industries dispose of their
CESQG waste at on-site solid waste landfills (509 tons/yr). These industries and the amount of waste
disposed are listed in Exhibit A-3 of Appendix A. The estimates for disposal in on-site solid waste
landfills for these eight industries, however, may be unreliable based on the fact that the study does not
define the term "on-site solid waste landfill," and it seems unlikely that some of the industries cited (i.e.,
laundries, and pesticide end users) would have sufficient industrial solid waste to warrant an on-site
landfill.
The other national study identified in Exhibit 5, the TSS, estimates that 605 (16 percent) of 3,742
CESQG establishments in 17 manufacturing industries dispose of their waste in an on-site, land-based unit
that also receives non-hazardous waste. (Exhibit A-4 in Appendix A presents the results of this study.)
The top five industries in terms of the total number of CESQG establishments that dispose CESQG waste
in on-site, land-based units are identified in Exhibit 6. Again, the TSS does not provide waste volumes,
only number of establishments. Also, the data for this survey were collected in 1987. Since then CESQGs
may have ceased disposal of CESQG waste in on-site, land-based units due to changes in state
requirements or increased liability concerns.
10 The National Small Quantity Hazardous Waste Generator Survey does not distinguish between a
municipal or non-municipal (e.g., industrial, construction and demolition landfill).
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Page 14 GENERATION AND MANAGEMENT OF CESQG WASTE
The only industries that overlap between the TSS and the National SQG Survey are textile
manufacturing and pulp and paper. The National SQG Survey estimates that 14 generators in the textile
manufacturing industry dispose of their CESQG waste in an on-site landfill. Although the TSS estimates
that 50 generators in this industry dispose of their CESQG waste in an on-site, land-based unit, none of
the generators use a landfill. Rather the study estimates that all SO use a surface impoundment. Within
the pulp and paper industry, the National SQG Survey, estimates that no generators dispose of their waste
in an on-site solid waste landfill. The TSS, in contrast, estimates that six of the 43 CESQGs that dispose
CESQG waste in an on-site, land-based unit manage this waste in a landfill. Again, these discrepancies
are indicative of the difficulty in comparing these two national data sources. As discussed in Exhibit A-l
of Appendix A, each study had a different methodology and scope, which may be the underlying factors
leading to these discrepancies.
Waste Management Practices in the Major CESQG Waste Generating Industries
The National SQG Survey provides information on the management practices of the major
CESQG waste generating industries identified above. Exhibit 7 graphically shows the CESQG waste
management practices of these industries.
Exhibit 7 illustrates that all industries send some portion of their CESQG waste to an off-site
solid waste landfill (e.g., 49.5 percent of CESQG waste generated by laundries is sent to an off-site solid
waste landfill, the largest amount of the seven industries). Again, the National SQG Survey does not
distinguish between a municipal or a non-municipal solid waste landfill. With regard to disposal of
CESQG waste in an on-site solid waste landfill, three industries (vehicle maintenance, printing/ceramics,
and photography) do not use this management method, while the other four do. The construction
industry, for, example, manages approximately 10.3 percent of its CESQG waste (263 tons/yr) in an on-site
solid waste landfilL These estimates should be viewed with caution since the study does not define 'on-site
solid waste landfill."
-------
200 -i
150 -
O
5 100
50 -
EXHIBIT 6
Number of CESQG Establishments in Five Manufacturing Industries
That Dispose of Their CESQG Waste in On Site, Land-Based Units
160
Source
Stone, Clay, Food and Kindred Textile Primary Iron
Glass, and Concrete Products Manufacturing and Steel
Industry
Screening Survey of Industrial Subtitle D Establishments, (1987)
43
Pulp and Paper
173
jfl
Remaining 12
Industries
-------
EXHIBIT 7
CESQG Waste Management Practices by Major CESQG Waste Generating Industry
Vehicle Maintenance
Metals Manufacturing
Laundries
Printing/Ceramics
Pesticide Application
Services and End Users
Construction
Photography
;^fen.:'/ I
20 40 60 80
Percent of CESQG Waste
100
On-Site Solid Waste Landfill
Off-Site Solid Waste Landfill
Other
Source: National Small Quantity Hazardous Waste Generator Survey (1985); based on survey of 22 major CESQG industry groups.
* Other is al other methods of on-site and ofl site management, such as recycling, treatment, disposal in sewer, disposal at permitted Subtitle C facility, incinerators, etc.
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GENERATION AND MANAGEMENT OF CESQG WASTE Page 17
SECTION m. CHARACTERIZATION OF CESQGs: MAJOR FINDINGS FROM
STATE AND LOCAL STUDIES
This section Summarizes the major findings from four state and local studies regarding CESQG
waste generation and management practices. These studies are:
Moderate Risk Waste: A Progress Report (Washington CESQG Report);
Washington 1988 Hazardous Waste Annual Report Summary (Washington HW Summary);
Survey of Conditionally Exempt Small Quantity Generators of Hazardous Waste in Montgomery
County, Maryland (Montgomery County Survey);
Hazardous Waste From CESQGs in the Municipal Solid Waste Stream: A Literature Review
(Literature Review). This source includes several state and local studies. These studies
are identifies in the relevant sections below.
The scope and methodology, as well as other information, for each of these studies is presented in Exhibit
A-l of Appendix A.
A. NUMBER OF CESQGs AND WASTE VOLUME
Exhibit 8 lists the number of CESQGs and CESQG waste volume found in several state and local
studies.
Number of CESQGs
Seven studies listed in Exhibit 8 identify the number of CESQG establishments in the areas
covered by the study. The studies listed in Exhibit 8 present a wide range of estimates for the number of
CESQGs (from a low of 2,318 establishments in New Hampshire to a high of 43,000 establishments in
Washington).11 This wide range of estimates demonstrates the difficulty in extrapolating to national
estimates based on state and local studies. State estimates of the number of CESQG establishments may
be dependent upon various factors, such as how the state defines and counts CESQGs.
CESQG Waste Volume
One state and three local studies provide information on the volumes of CESQG waste in the
areas covered by the study. Only Washington State provides an estimate of CESQG waste volume
statewide, thus comparisons can not be made. Three local studies present varying results for CESQG
waste volume, which may be attributed to varying demographics (rural versus urban), populations, and
economic structure (manufacturing versus non-manufacturing industries). Again, the findings of these
studies point out the difficulties in extrapolating to a national level.
11 Although the Washington CESQG Report indicates that there are 240,000 CESQG establishments
statewide, this estimate has since been revised downward to 43,000. The amount of waste generated,
however, remains the same, 53,000 tons/yr. (Telephone conversation with Mr. William Green, Washington
Department of Ecology, May 4,1994.)
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Page 18
GENERATION AND MANAGEMENT OF CESQG WASTE
Notwithstanding, the data limitations of these studies, the Washington CESQG Report indicates
that the national estimates of the number of CESQGs (455,000) and CESQG waste volume (approximately
200,000 tons/yr) may be underestimates.12
EXHIBIT 8
Number of CESQGs and CESQG Waste Volume13
(state and local studies)
Title of State or Local Study
Moderate Risk Waste: A Process Report (State of
Washington)
Hazardous Waste From CESQGs in the Municipal
Waste Stream: A Literature Review
State of Maine
State of Massachusetts
State of New Hampshire
State of Vermont
Central Vermont Solid Waste Management
District
Tbuistoo County, Washington
Survey of Conditionally Exempt Smalt Quantity
Generators of Hazardous Waste in Montgomery
County, Maryland
Scope of Study
State
(An
Industries)
State
(All
Industries)
State
(All
ftutusuies)
State
(All
Industries)
State
(All
Industries)
Counties
(All
Industries)
County
(All
Industries)
County
(All
Industries)
Number of
CESQGs
43,000
5,000-
10,000
13^00
2318
2,500-
12,000
658
800-2,000
CESQG
Waste
Volume
(tons/yr)
53,200
739
864
255-484
13 The National SQG Survey did not include used motor oil al all.
13 The findings in this exhibit are taken directly from the associated study or have been calculated
using other results included in the study.
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GENERATION AND MANAGEMENT OF CESQG WASTE
Page 19
Moreover, Thurston County's report helps to understand the significance of including or excluding used
motor oil, oil filters, and/or lead-acid batteries. For example, Thurston County calculated a total waste
volume of 864 tonsftr when the waste stream included motor oil, oil filters, and lead-acid battenes for all
industries. Excluding these components from the waste stream for all industries, however, significantly
decreased CESQG waste volume to 115 tons/yr. Based on these results, it is apparent that had the
National SQC Survey included waste oil, CESQG waste volumes may have been higher than reported.
B. MAJOR CESQG WASTE GENERATING INDUSTRIES AND WASTE TYPES
Exhibit 9 lists the major CESQG waste generating industries and waste types from state and local
studies.
EXHIBIT*
Major CESQG Waste Generating Industries and Waste Types
(state and local studies)
Title of State or Local
Study
Moderate Risk Waste: A
Progress Report (State of
Washington)
WastuitgoR 1988
Hazardous Waste Annual
Repot Summary
Hazardous Waste From
CESQGs in the Municipal
Waste Stream: A
Literature Review
State of Oregon
2 Counties in
Vermont
Central
Vermont Solid
Waste
Management
District
Scope of
Study
State
(All
Industries)
State
(All
Industries)
State
{All
Industries)
Counties
(AD
Industries)
Counties
(All
Industries)
Major CESQG Generating
Industries
Not Provided in Report
business services
» human services
» wholesale and retail
trade
public administration
Uses National Figures
auto repair
* trucking
4 firms with own truck fleet
Not Provided in Report
Major CESQG Waste
Types14
» oil (53%)
paints and solvents
(14%)
batteries (14%)
antifreeze (6%)
Not provided in Report
* lead-acid batteries (61%)
» spent solvents/still bottoms
(23%)
photographic waste (4%)
« used motor oil (66%)
solvents (16%)
* lead-add batteries (7%)
photographic wastes (4%)
antifreeze (2%)
« used motor oil (54%)
solvents and degreasers
(27%)
14
Percentages in parentheses shows the percent of total waste volume for the waste types as reported
in the associated study or determined through calculations using other findings reported in the study.
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Page 20
GENERATION AND MANAGEMENT OF CESQG WASTt.
EXHIBIT 9 (continued)
Major CESQG Waste Generating Industries and Waste Types
(state and local studies)
Title of Study
Hazardous Waste From
CESQGs in the Municipal
Waste Stream: A
Literature Review
(continued)
Thurston
County,
Washington
Olmstead
ftauniv
Minnesota
Survey of Conditionally
Exempt Small Quantity
Generators of Hazardous
Waste in Montgomery
County, Maryland
Scope of
Study
County
(All
Industries)
County
/An
(na
Industries)
County
(7 MFR, N-
MFR
Industries)
Major CESQG Generating
Industries
auto repair
auto dealer
transportation
miscellaneous wholesale
miscellaneous business
Not Provided in Study
dry cleaners
auto services
printing and publishing
photography
landscapers/pesticides control
general budding contractors
woodworking/painters
Major CESQG Waste
Types
spent solvents
used motor oil
» lead-add baitenes
photographic waste
* antifreeze
* motor ofl, antifreeze,
+ lead-acid butteries
diesel, gas, kerosene
* spent solvents/still bottoms
₯ paint removers
» oil-based paints
« perchloroetnylene (31%)
* antifreeze (23%)
solvents (17%)
* photography wastes (10%)
» inks/paints (7%)
motor oil (7%)
Major CESQG Waste Generating Industries
As shown in Exhibit 9, state and local studies identify various types of industries as major CESQG
waste generating industries. A limitation in comparing the major generating industries across studies is
the basis for which a study determines the major industries. For example, the Washington HW Summary,
which finds business and human services, wholesale and retail trade, and public administration as major
CESQG generating industries, is based on those establishments thai submitted the required annual report
Of the approximate 43,000 CESQGs in the State, only 143 submitted the annual report in 1988. This
small sample size precludes the use of this study to determine major CESQG industries. Additionally,
Montgomery County, Maryland only surveyed firms in seven industries that were thought to be the largest
contributors of CESQG waste. With regard to the major CESQG waste generating industries identified in
Section II, the state and local studies listed in Exhibit 9 show the following:
Vehicle Maintenance. Thurston County, Washington reports that the vehicle maintenance
industry generates 56 percent of CESQG waste in the county if used motor oil, oil filters,
and lead-acid batteries are included and 31 percent when these three waste types are
excluded. In both instances, vehicle maintenance is the largest generating industry in the
county. In addition, the Montgomery County Survey, which excluded used motor oil and
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GENERATION AND MANAGEMENT OF CESQG WASTE Page 21
lead-acid batteries for the vehicle maintenance industry, reports that this industry still
generates nearly one-fourth of total waste volume for the businesses surveyed, second only
to laundries. Two county studies in Vermont found vehicle maintenance to be a major
CESQG industry, however, neither offered an estimate of the relative size of the industry.
Laundries. Only the Montgomery County Survey identified this industry as a major
CESQG waste generating industry. In Montgomery County, Maryland laundries generate
the most CESQG waste of the industries surveyed, 31 percent
Printing/Ceramics.15 Again, only the Montgomery County Survey identified this industry
as a major CESQG waste generating industry. Montgomery County, Maryland finds that
printing and publishing, without ceramics, generates approximately 19 percent of CESQG
waste for the industries surveyed.
Pesticide End Users and Application Services. Montgomery County, Maryland surveyed
businesses that use pesticides and other chemicals in the treatment of lawns and homes
and found that these businesses generate 7.1 percent of CESQG waste volume for the
industries surveyed. No other study identified these industries as major CESQG waste
generating industries.
Construction. In Montgomery County, Maryland and Thurston County, Washington this
industry generates 6.4 and 2.6 percent of the CESQG waste volume, respectively.
Photography. In Montgomery County, Maryland this industry generates approximately 7.3
percent of the total CESQG waste for the industries surveyed. No other study identified
this industry as a major CESQG waste generating industry.
Thus, two or more state and local studies listed in Exhibit 9 concur with the results of the National SQG
Survey (discussed in Section II) for two industries only (vehicle maintenance and construction).
CESQG Waste Types
Exhibit 9 lists several studies that identify major CESQG waste types and the relative significance
of the waste types to the study's total CESQG waste volume. A significant factor limiting the comparison
of these studies is how used motor oil and lead-acid batteries are classified. Current RCRA regulations
exclude these waste types from regulations in the hands of the generator provided that the waste types are
to be recycled or reused. As a result, some of the studies excluded these waste types from the vehicle
maintenance industry, which reclaims these materials. This reduced the relative significance of these waste
types in these studies. On the other hand, some studies included both waste types in the vehicle
maintenance industry, which greatly increased their relative significance. All studies, however, included
these waste types in other industries. As noted below, non-vehicle maintenance industries (photography,
woodworking/painting, and general building contracting) generate significant quantities of used motor oil
and lead-acid batteries.
These studies find that the following waste types are major CESQG waste types:
Used Motor OIL Six of the studies listed in Exhibit 9 identify used motor oil as a major
CESQG waste type. The percentage of total waste volume attributed to this single waste
type varies from 66 percent in one of the two county studies in Vermont to seven percent
15 Both the Montgomery County Survey and the National SQG Survey included these two separate
industries as a single industry group.
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Page 22 GENERATION AND MANAGEMENT OF CESQC WASTE
in Montgomery County, Maryland. This wide variance is attributed to the fact that some
studies include used motor oil as part of the CESQG waste stream for the vehicle
maintenance industry, while other studies do not. The two counties in Vermont, for
example, included used motor oil for vehicle maintenance industry, while the Montgomery
County Survey did not. Most importantly, however, used motor oil is a significant CESQG
waste type for many industries outside of vehicle maintenance. For example, the
Montgomery County Survey found that used motor oil is a significant waste type in the
photography, woodworking/painting, general building contracting, and landscaping/pest
control industries.
4 Used-Lead Acid Batteries. Five ofthe studies found this waste to be a major waste type,
ranging from 61 percent to seven percent of the total CESQG waste volume estimated in
the studies. Again, this wide variance is due to the fact that some studies included this
waste type for the vehicle maintenance industry (State of Oregon), while other studies did
not (Washington CESQC Report and the two county study in Vermont). Outside of the
vehicle maintenance industry, the Montgomery County Survey finds that used-lead acid
batteries are a significant waste type for the general building contracting industry.
Antifreeze. As is the case with used motor oil and lead-acid batteries, the relative
importance of this waste type varies depending on whether the study includes it as part of
the waste stream for the vehicle maintenance industry. In the Washington CESQC Report,
the State does not include antifreeze in the vehicle maintenance industry but reports that:
this waste type is six percent of the total CESQG waste volume. The Montgomery County
Survey, however, includes antifreeze in the vehicle maintenance industry and reports that
this waste type is 23 percent of the total CESQG waste volume.
Spent Solvents and Still Bottoms. All of the studies that listed waste types in Exhibit 9
identified spent solvents and still bottoms as a significant waste type, representing a fairly
consistent portion of the total CESQG waste stream across all studies (ranging from one-
seventh to one-fourth of the total CESQG waste volume estimated in the studies). More
importantly, the Montgomery County Survey finds that this waste type is significant in
several industries surveyed.
Perchloroethylene. Only one of the studies listed in Exhibit 9 identifies perchloroethylene
as a major CESQG waste type, 31 percent of the total CESQG waste volume for the
industries surveyed in Montgomery County, Maryland All of this waste is generated by
laundries.
* Photographic Wastes. Four of the studies listed in Exhibit 9 find wastes from the
photography industry to be major CESQG waste types, ranging from ten percent of the
total CESQG waste volume in Montgomery County to four percent in the other studies.
As is the case with perchloroethylene, only one industry generates these wastes, the
photography industry.
C. CESQG WASTE MANAGEMENT PRACTICES
Exhibit 10 lists CESQG waste management practices identified by two state and one local study.
General CESQG Waste Management Practices
As Exhibit 10 indicates, one state and one local study both conclude that the majority of CESQG
waste from the industries included in the studies is managed off-site (84 percent in the Montgomery County
Survey, and 88 percent in the Washington CESQG Report, assuming that all CESQG waste stored on-site is
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GENERATION AND MANAGEMENT OF CESQG WASTE
Page 23
ultimately sent to an off-site management facility). The major off-site management methods are recycling,
disposal in a permitted Subtitle C landfill, and disposal in a solid waste landfill, either by direct haul to the
facility or mixture with solid waste at the site of generation.
EXHIBIT 10
CESQG Waste Management Practices16
Title of State and Local
Study
Hazardous Waste From
CESQGs in the Municipal
Waste Stream: A Literature
Review
State of Oregon
Moderate Risk Waste: A
Progress Report (State of
Washington)
Survey of Conditionally
Exempt Small Quantity
Generators of Hazardous
Waste in Montgomery
County, Maryland
Scope
of Study
State (all industries)
State (all industries)
County (seven
industries surveyed)
Method of Management
OFF-SITE
Percentages not given
Recycling
Disposal in solid waste
landfill
Disposal in permitted
Subtitle C landfill
88% of State CESQG
waste
On-site Storage (50%)1T
Recycling (21%)
Collection and treatment
(7%)
Disposal in solid waste
landfill (2%)
84% of waste from
industries surveyed
Disposal in a Subtitle C
landfill (36%)
Recycling (33%)
Disposal in a solid waste
landfill (13%)
ON-SITE
Percentages not given
Disposal in sewer, septic
system, and dry wells
Treatment on-site
Evaporation
Burning
12% of State CESQG
waste
Disposal in sewer (7%)
Dumping on ground (5%)
16% of waste from
industries surveyed
Disposal in sewer (13%)
Evaporation (3%)
16 The findings in this exhibit are taken from the associated study or calculated using other results
provided in the study.
17
This assumes that all waste stored on-site is eventually shipped off-site for management.
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Page 24 GENERATION AND MANAGEMENT OF CESQG WASTE
The Montgomery County Survey and the Washington CESQG Repon estimate that 13 and two percent of
CESQG waste from the industries surveyed, respectively, is disposed at an off-site solid waste landfill.
None of the studies listed in Exhibit LO, however, differentiates between a municipal and non-municipal
solid waste landfill.
The Montgomery County Survey and the Washington CESQG Report estimate that 16 and 12
percent of CESQG waste is managed on-site. respectively. None of the three studies listed in Exhibit 10
indicate that any CESQG waste is disposed in an on-site landfill. This is in contrast to the National SQG
Survey, which found that at least some CESQG establishments in eight industries managed CESQG waste
in an on-site landfill. This is a possible indication of changes in waste management practices since 1985,
the year in which the National SQG Survey was published.
CESQG Waste Management Practices in the Major Generating Industries
With regard to the use of on-site and off-site landfills to manage waste from the major CESQG
waste generating industries, identified previously, state and local studies indicate the following:
Vehicle Maintenance. The Montgomery County Survey finds that none of the waste from
this industry is managed at either an on-site or off-site solid waste landfill. The waste is
recycled, put into the sewer system, or sent to a permitted Subtitle C facility. Thurston
County, Washington found that two percent of the waste from this industry is
"mismanaged."18
Laundries. The Montgomery County Survey is the only state or local study to identify the
waste management practice of this industry. The county finds that all CESQG waste
generated by this industry is recycled or managed at an off-site Subtitle C landfill.
Printing/Ceramics. The Montgomery County Survey finds that 13 percent of the waste
from this industry is managed at an off-site landfill, while none is managed in an on-site
solid waste landfill.
Pesticide Application Services and End Users. The Montgomery County Survey finds that
business using pesticides and chemicals on lawns or in homes manage more than one-third
of their waste in off-site solid waste landfills and none in an on-site solid waste landfill
* Construction. The Montgomery County Survey finds that 18 percent of the CESQG waste
from this industry is managed in an off-site solid waste landfill, while none is managed in
an on-site landfill. Counting used motor oil, oil filters, and lead-acid batteries, Thurston
County, Washington finds that only two percent of the waste from this industry is
"mismanaged.* Excluding these three waste types, however, Thurston County finds that all
of the remaining CESQG waste is "mismanaged. "l*
Photography. The Montgomery County Survey finds that none of the CESQG waste is
managed in either an on-site solid or an off-site waste landfill. Thurston County,
Washington finds that 75 percent of the waste from this industry is "mismanaged."18
The state and local studies did not discuss waste management practices for the metals manufacturing
industry.
18 Thurston County, Washington defines "mismanaged* as "not recycled, reused, or sent to a permitted
Subtitle C facility." Other examples of mismanagement are not given.
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GENERATION AND MANAGEMENT OF CESQG WASTE Page 25
Although no direct comparisons with the National SQG Survey are presented in this section, such
comparisons should be made with caution for two reasons: (1) the data for the National SQG Survey were
collected approximately, ten years prior to the data for the reports from Montgomery County, Maryland
and Thurston County, Washington, as a result, CESQG waste management practices may have changed in
the interim, and (2) it'is difficult to compare the results of a comprehensive, national survey with surveys
from only two specific counties.
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Page 26 GENERATION AND MANAGEMENT OF CESQC WASTE
SECTION IV. FEDERAL AND STATE REQUIREMENTS FOR CESQGs
A. FEDERAL REQUIREMENTS
Federal regulations delineate three categories of hazardous waste generators based on the amount
of kilograms of hazardous waste generated per month (kg/mo): generators of waste greater than 1,000
kg/mo are large quantity generators (LQGs), generators of 100 kg/mo to 1,000 kg/mo are small quantity
generators (SQGs), and generators of less than 100 kg/mo are conditionally exempt small quantity
generators, or CESQGs/9 CESQGs are exempt from several requirements with which larger generators
must comply. For example, unlike larger generators, CESQGs do not need to:
Obtain an EPA identification number,
Use a manifest when shipping hazardous waste;
Report to EPA on a biannual basis; or
« Send their hazardous waste to a permitted or interim status Subtitle C waste management
facility.
CESQGs, however, are required to comply with the following requirements of 40 CFR 261.5(g):
They must determine whether their waste is hazardous according to 40 CFR 262.11;
They may accumulate hazardous waste on-site indefinitely provided that the total amount
of waste accumulated does not exceed 1,000 kg at any one time; and
They must manage then* hazardous waste either in an on-site or off-site waste
management facility that is permitted or in interim status under the Subtitle C hazardous
waste management facility standards; is a state permitted, licensed, or registered municipal
or industrial solid waste facility, or is a facility that beneficially uses, reuses, or legitimately
recycles or reclaims waste, or treats waste prior to beneficial use, reuse, or legitimate
recycling or reclamation.
B. STATE REQUIREMENTS
At a minimum, state requirements for CESQGs must be at least as stringent as Federal
requirements. States, however, may establish more stringent requirements for CESQGs within their
jurisdiction. For example, 34 states have one or more requirements for CESQGs that are more stringent
than Federal requirements, see Exhibit 11. Moreover, these requirements vary from state to state.
Appendix B, Exhibit B-l lists the CESQG requirements for all SO states and the District of Columbia.
Significant findings are described below.20
19 40 CFR 261.5 also classifies generators as conditionally-exempt if they generate less than 1 kg/mo
of certain acutely hazardous wastes listed in 40 CFR 261.31, 261.32, and 261.33(e). This section does not
discuss Federal and state requirements for CESQGs of acutely hazardous waste. It should be noted, that
in some cases (e.g., on-site accumulation), requirements for these generators are different from those for
generators of non-acute hazardous waste.
20 Information on state CESQG requirements discussed in this section and listed in Exhibit B-l of
Appendix B is adapted from Hazardous Waste From Small Quantity Generators. Seymour I. Schwartz and
Wendy B. Pratt, Island Press, c. 1990; and Hazardous Waste From Conditionally Exempt Small Quantity
Generators in the Municipal Solid Waste Stream: A Literature Review, U.S. EPA,, September 1993.
-------
State ID Number Required
Limited Storage Period
On-Site Accumulation Limit
Less Than 1,000 kg
License Required For
Hauling Wastes
Self-Transport Limit
Manifest Required
Manage CESQG Waste at
Permitted Subtitle C Facility
Only
Reporting Required
EXHIBIT 11
Number of States With CESQG Requirements That
Are More Stringent Than Federal Requirements
(7)
S7777/. 7Z&
sf/yZ
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page 28 GENERATION AND MANAGEMENT OF CESQC WASTE
State CESQG Generator Size Categories
As noted previously, Federal regulations characterize hazardous waste generators of less than 100
kg/mo as conditionally-exempt. Most states use the same exclusion level (100 kg/mo); however, the
following three states-use a lower exclusion level:21
The District of Columbia's exclusion level is SO kg/mo. Thus, a generator is considered
conditionally-exempt only if they generate less than 50 kg/mo of hazardous waste.
Moreover, the District has some requirements for these generators that are more stringent
than Federal requirements (see Exhibit B-l, Appendix B and discussion below).
Generators of greater than SO kg/rap are fully regulated. Thus, all generators of SO kg/mo
or more must comply with requirements that are the same as Federal requirements for
LQGs.
Kansas has established an exclusion level of 25 kg/mo. Thus, a generator is considered
conditionally-exempt only if they generate less than 25 kg/mo of hazardous waste.
Moreover, Kansas has some requirements for these generators that are more stringent
than Federal requirements (see Exhibit B-l, Appendix B and discussion below). Under
Kansas law, generators of 25 to 100 kg/mo must comply with requirements that are equal
to those for Federally-defined SQGs.
Rhode Island fully regulates all hazardous waste generators and does not provide any
conditional exemptions. Thus, generators of less than 100 kg/mo must meet state
requirements that equal Federal requirements for LQGs.
State Hazardous Waste Identification Number
Unlike the Federal government, seven states (California, Illinois, Louisiana, Maine, Minnesota,
Rhode Island, and West Virginia) require aU generators of less than 100 kg/mo to obtain a state hazardous
waste identification number. Texas requires only industrial (i.e., manufacturing) CESQGs to obtain an
identification number. Also, the District of Columbia and Kansas require generators of waste amounts
ranging from 50 kg/mo to 100 kg/mo and 25 kg/mo to 100 kg/mo, respectively, to obtain identification
numbers. Generators of less than 50 kg/mo in the District of Columbia and 25 kg/ino in the State of
Kansas, because they are conditionally-exempt in these states, are not required to obtain an identification
number, as is the case under Federal regulations for CESQGs.
State Storage Time Limits and On-site Waste Accumulation Limits
The storage time limit is the maximum amount of time a generator can hold hazardous waste on-
site without a storage permit. Federal regulations allow CESQGs to store waste on-site indefinitely,
provided that the maximum amount stored does not exceed 1,000 kg in one calendar month. Once the
1,000 kg/mo limit is exceeded, all waste accumulated is subject to Federal requirements for small quantity
generators (i.e., 40 CFR Pan 262.34), which include a maximum storage time limit of 180 days, a
maximum on-site accumulation limit of 6,000 kg/mo, and other storage requirements. Unlike Federal
requirements for CESQGS, some states have a limited storage time and/or a lower maximum storage limit.
For example, five states (California, District of Columbia, Louisiana, Mississippi, and Rhode Island)
restrict storage time for all CESQGs. California, Louisiana, and Mississippi each require a maximum
storage period of 365 days. Rhode Island restricts the storage period for all CESQGs to a maximum of 90
21 Because these three states use a lower exclusion level than Federal regulations, some generators of
less than 100 kg/mo are regulated and not conditionally-exempt.
-------
GENERATION AND MANAGEMENT OF CESQG WASTE Page 29
days. In addition, the District of Columbia restricts the storage time to a maximum of 180 days for
generators of less than 50 kg/mo and 90 days for generators between 50 kg/mo and 100 kg/mo.
With regard to maximum on-site quantity limits, 11 states (California, Colorado, District of
Columbia, Maine, Maryland, Massachusetts, Nebraska, New Hampshire, New Jersey, Rhode Island, and
Washington) have a maximum on-site quantity limit of less than 1,000 kg/mo for all CESQGs. Both
Rhode Island and the District of Columbia, because they fully regulate all generators and generators of 50
to 100 kg/mo, respectively, require these generators to comply with Federal accumulation requirements for
LQGs. For generators of less than 50 kg/mo, the District of Columbia's accumulation limit is 300 kg.
State Licenses Required for Hauling Wastes and Generator Self-Transport Limits
Eleven states (Arkansas, District of Columbia, Louisiana, Maine, Minnesota, New Hampshire,
Ohio, Rhode Island, Texas, West Virginia, and Wisconsin) require all generators of less than 100 kg/mo to
use a licensed commercial hazardous waste hauler or to obtain a license if they self-transport the waste
themselves. In addition, Michigan and New Jersey require CESQGs to use a licensed hauler or obtain a
license only for the transport or self-transport of liquid industrial waste and waste oil, respectively. Also,
Kansas requires the use of a licensed hauler or a license for self-haul if the generator generates between 25
and 100 kg/mo; generators of less than 25 kg/mo need not use a licensed hauler or obtain a license for
self-transport. In Massachusetts, CESQGs who wish to self-transport their waste need only to register with
the State.
Unlike Federal regulations, 12 states (California, Colorado, Florida, Kentucky, Maryland,
Massachusetts, Missouri, Nebraska, New Jersey, New York, South Carolina, and Washington) have limits
on the amount of waste that CESQGs may self transport. Self-transport limits range from 23 kg in
California to 999 kg in Colorado.
State CESQG Manifest Requirements
Under Federal regulations, CESQGs are exempt from using a manifest. Seven states (California,
Louisiana, Maine, Minnesota, New Hampshire, Pennsylvania, and Rhode Island), however, require all
generators of less than 100 kg/mo to use a manifest. Michigan requires a manifest only for liquid
industrial waste and Texas requires only industrial (i.e., manufacturing) CESQGs to use a manifest In
addition, generators of 50 to 100 kg/mo and 25 to 100 kg/mo in the District of Columbia and Kansas,
respectively, are also required to use a manifest
States Mandating CESQG Waste Management in a Permitted Subtitle C TSDF Only
Federal regulations allow generators of less than 100 kg/mo to manage their hazardous waste in a
Subtitle C treatment, storage, and disposal facility (TSDF); or in a municipal or industrial solid waste
facility, or a recycler. Seventeen states (California, Colorado, Connecticut, Illinois, Kentucky, Louisiana,
Maine, Massachusetts, Minnesota, New Hampshire, New Mexico, North Carolina, Ohio, Pennsylvania,
Rhode Island, West Virginia, and Wisconsin), however, require these generators to manage their
hazardous waste in a permitted Subtitle C TSDF. thus prohibiting disposal in a municipal or industrial
waste landfill or other municipal, industrial facility. In addition, the District of Columbia and Kansas
require generators generating between 50 and 100 kg/mo and 25 and 100 kg/mo, respectively, to manage
their waste in a permitted Subtitle C TSDF. (Generators of less than 50 kg/mo in the District of
Columbia and 25 kg/mo in Kansas may dispose of their waste in a municipal or industrial waste facility.)
Also, three states (Michigan, New Jersey, and North Dakota) require CESQGs to manage liquid industrial
and igniiable wastes in a permitted Subtitle C TSDF.
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Page 30 GENERATION AND MANAGEMENT OF CESQC WASTE
State CESQG Reporting Requirements
Federal regulations do not require CESQGs to submit annual or biannual reports. Six states
(Arizona, California, Louisiana, Minnesota, Rhode Island, and Washington), however, have reporting
requirements for all generators of less than 100 kg/mo. California and Rhode Island require CESQGs to
report every two years. Arizona, Louisiana, Minnesota, and Washington have annual reporting
requirements. In addition, Arkansas requires only those CESQGs with a state identification number to
report annually, and Texas requires CESQGs to submit monthly reports and a copy of the manifest only if
waste is sent out of the State. The District of Columbia requires generators of SO to 100 kg/mo to submit
reports annually, while Kansas requires generators of 25 to 100 kg/mo to submit reports biennially.
Generators of less than SO kg/mo in the District of Columbia and 25 kg/mo in the State of Kansas are not
required to report, as is the case under Federal regulations.
-------
GENEKATION AND MANAGEMENT OF CESQC WASTE Page 31
SECTION V. SCREENING MECHANISMS
As discussed in Sections II and III, several studies on CESQGs find that a portion of CESQG
waste is disposed at off-site solid waste landfills. These studies, however, do not indicate whether the type
of landfill receiving this CESQG waste is a municipal, industrial, or construction and demolition (C&D)
debris landfill. This distinction is important in order to understand the potential risks and issues
associated with CESQG waste management practices. While municipal solid waste landfills must meet
newly promulgated revised criteria under 40 CFR Part 258, all other types of solid waste disposal facilities
or practices remain subject to the less stringent, 'minimum" criteria under 40 CFR Part 257 as well as
applicable individual state requirements.
This section focuses on the procedures that four states require to screen out (i.e., exclude)
CESQG waste from C&D landfills, which is one type of disposal option available to CESQGs.22 There
are approximately 1,800 C&D landfills operating nationwide.23 Seven states have promulgated
regulations requiring C&D landfills to meet the criteria for municipal solid waste landfills. Forty-three
states, however, have promulgated separate, less stringent regulations for C&D landfills.24 In some
instances, these regulations prescribe mechanisms for C&D landfills to screen out incoming hazardous
waste. This section presents the results of a review of the separate C&D regulations of four states
(Arkansas, Connecticut, Delaware, and Florida) chosen at random, to determine the types of screening
mechanisms prescribed.
Arkansas
Arkansas has established four classes of solid waste landfills, two of which may receive C&D
wastes, Class III and Class IV. Both landfill classes may receive CESQG waste (defined as "special
materials*) for disposal only with the written approval of the State. The only mechanism for screening out
prohibited wastes is the requirement that Class III and Class IV landfills operate in accordance with
approved plans (which may or may not include screening mechanisms depending on approval from the
State), including the requirement that unloading at the site must be supervised. (Arkansas Solid Waste
Management Code, Chapter 4.)
Connecticut
C&D landfills in the State of Connecticut are regulated as "special waste" landfills. Connecticut
prohibits disposal of hazardous wastes (including CESQG waste) in these landfills. The regulations do not
include specific screening mechanisms. Operators of special waste landfills, however, are required to
submit to the State operating procedures that include specific personnel training in the unique
characteristics and handling requirements of special wastes to be disposed at the landfill. Additionally, for
each specific waste disposed at the landfill, the State requires the operator to submit a report on the
physical, chemical, and leachate potential characteristics. (Connecticut Solid Waste Management
Regulations, Title 22a, Chapter 209.)
22 States may require screening mechanisms for off-site commercial industrial landfills and on-site
industrial non-hazardous waste management facilities, as well; however, these procedures are not discussed
in this section.
23 "Construction Waste & Demolition Debris Recycling ... A Primer," Gershman, Brickner &
Bratton, Inc. October, 1993.
24 Ibid.
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Page 32 GENERATION AND MANAGEMENT OF CESQG WASTE
Delaware
C&D landfills in Delaware are regulated as "dry waste* landfills, with dry wastes defined as those
wastes with reduced potential for environmental degradation and leachate production. The Delaware Solid
Waste Authority's solid waste licensing and disposal regulations prohibit disposal of hazardous waste in
any solid waste management facility, including a dry waste landfill. Under the Authority's operating
procedures for solid waste facilities, the Authority reserves the right to require unloading of the contents
of the vehicle hauling the waste for inspection. If hazardous wastes are found, the Authority reserves the
right to sanction the hauler of the waste. (Delaware Solid Waste Disposal Regulations and Delaware
Solid Waste Authority - Solid Waste Licensing and Disposal Regulations.)
Florida
Florida's regulations for C&D landfills are the only regulations of the four states reviewed that
detail specific screening mechanisms. In Florida, C&D landfills may operate under one of two permits, a
solid waste facility permit or a general permit Operators under both permits may not accept hazardous
waste, including CESQG waste, for disposal. Florida's regulations describe screening procedures for
facilities operating under a solid waste permit as follows: (1) at least one trained operator must be at the
landfill during all hours of operation; (2) at least one spotter must be at each working face at all times
when the landfill receives waste to detect unauthorized wastes; (3) an operational plan must detail the
control of waste received at the site, including inspection procedures, number and location of spotters at
each working face, and procedures to be followed if prohibited wastes are discovered; and (4) each facility
must undertake a load checking program, whereby the operator must examine at least three loads of waste
per week. If any hazardous wastes are identified by random load checking, or otherwise, the landfill
operator must notify the State, the hauler, and the generator. If the generator or the hauler cannot be
identified, the landfill operator is responsible for delivery of the waste to a permitted hazardous waste
facility. Subsequent shipments from sources identified as responsible for previous delivery of hazardous
wastes are subject to precautionary measures.
Florida's regulations for C&D landfills operating under a general permit do not describe any
screening procedures. (Florida Administrative Code, Title 17, Chapter 701.)
-------
GENERATION AND MANAGEMENT OF CESQG WASTE Page 33
SECTION VI. CONCLUSIONS
EPA is currently reviewing regulatory options to revise criteria under Section 4010(c) of RCRA
for non-municipal solid waste facilities that may receive CESQG waste. The purpose of this report is to
compile existing information on CESQG waste generation and management practices to be used as
background for the proposed regulation.
Overall, the data sources reviewed for this report provide information on the number of CESQG
establishments, how much CESQG waste they generate, the major CESQG waste types, and how this
waste is managed. The most comprehensive, national data source reviewed for this report, the National
SQC Survey, uses data that is nearly ten years old. EPA believes that the current situation regarding
CESQG waste generation and management practices is significantly different from when the data for this
study were collected.
With regard to the other data sources reviewed for this report, EPA is reluctant to use them to
draw overall conclusions at the national level for two primary reasons:
Some studies focus on a narrow subset of CESQGs (e.g., the TSS focuses on
manufacturing industries only and the Montgomery County Survey focuses on seven
industries only), making it difficult to compare these studies to the more comprehensive
National SQG Survey, and
The state and local studies are limited in geographic area and are too few in number,
which precludes a sufficient sample size from which to extrapolate to the national level.
Notwithstanding future EPA regulations, many states have already begun to address proper
management of CESQG waste in a variety of ways, for example:
Seventeen states prohibit disposal of CESQG waste at municipal and industrial solid waste
landfills, requiring that all CESQG waste be disposed at permitted Subtitle C facilities.
Many states, and EPA, have developed numerous technical assistance and outreach
programs targeted at CESQGs to encourage them to first reduce their use of hazardous
waste and, secondly, to manage the hazardous waste they generate properly.
Seven states require non-municipal landfills, such as C&D landfills, to meet the regulatory
requirements for municipal landfills.
Moreover, states, such as Florida, may also require non-municipal facilities to screen out
CESQG waste from the incoming waste stream. Even without specific state screening
requirements, landfill operators may implement screening procedures due to potential
liability concerns.
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Page 34 GENERATION AND MANAGEMENT OF CESQG WASTE
Appendix A
This Appendix contains four exhibits used to support the summary of major findings of the
national and state and local findings presented in Sections II and III.
-------
EXHIBIT A-l
Data Sources
Title
National Small Quantity
Hazardous Wane
Generator Survey
Screening Survey of
Industrial Subtitle D
Establttrunenu
Date Published/
Author
Febniaiy 1985
EPA's Office of Solid
Waste
December 29. 1987
EPA's Office of Solid
Waste
Scope
National survey of 48.849
small quantity hazardous
waste generators in 125
SIC codes, condensed into
22 MFR* and NMFR
industry groups
National survey of 18,051
establishments in 17 MFR
industry groups with on-
sile Subtitle D land-based
units.
Methodology
(1) developed survey
sample using available data
sources; (2) developed
written questionnaire
seeking information on
waste generation and
management practices;
(3) developed estimates of
generators in non-surveyed
industries by analogy to
surveyed industries and
review of available data
sources; and (4)
extrapolated results to
national level.
(1) developed survey
sample from available data
sources; (2) narrowed
sample frame to 17 MFR
industry groups believed to
generate 99 percent of all
industrial process waste;
(3) developed and
administered a telephone
survey (sequence of
questions found in Exhibit
A-2); and extrapolated
results to the national
level.
Response Rate
Survey responses
totaled 18,648
99 percent. Survey was
mandatory.
Comments
Most comprehensive.
natiopal data source on
CESQGs. . However, data
is nearly ten yean old and
should be viewed wiih
caulion considering the
number of significant
changes that have
occurred in hazardous
waste management since
the data were collected
(See Executive Summary)
Purpose of survey was to
determine number of
establishments generating
industrial D waste and
managing this waste in on-
site, land-based units
Only those establishments
that managed industrial D
waste on-site were asked
whether 1 hey also
generated CESQG waste.
Thus, industrial D
generators who managed
this waste off -site were
not asked if they were
CESQGs. For this
reason, this study does not
provide a complete
picture of CESQGs in
these 17 industry groups
25
"MFR" denotes manufacturing and "NMFR" denotes non-manufacturing.
-------
EXHIBIT A-l (continued)
Data Sources
Title
Hazardous Waste From
Small Quantity Generators
Moderate Risk Wane
Volumes 2-1 and 2-2
Washington Sum 1988
Hazardous Waste Annual
Report Summary
Date Published/
Author
Copyright 1990, bland
Press
Seymour I. Schwartz and
Wendy B. Pratt
December 15, 1990
Washington Slate
Department ol Ecology
lane 1991
Washington Stale
Department of Ecology
Scope
Discusses strategies and
solutions for businesses
and governments io reduce
improper management of
hazardous waste from
small quantity generators.
Documents the scope of
moderate nsk waste
(including CESQG waste)
in the State of Washington
and examines progress of
State and local
governments in addressing
these wastes
Summarizes statewide
generation and
management data for
generators of dangerous
wastes (including
hazardous waste)
Methodology
Telephone interviews with
300 people in stale and
local government, waste
management industry, and
trade associations.
To determine volumes and
composition of waste
stream, Stale tallied waste
figures from 26 statewide
planning areas and
developed estimates for
remaining seven planning
aieas. Also, conducted
comparative study of
planning areas to
characterize waste
management methods
Data is obtained from
annual reports submit led
by generators and
management facilities
pursuant to Slate statute.
Response Rate
Not Applicable
Not Applicable
143 CESQGs
submitted reports.
Comments
Provides limned data on
CESQGs. Only data used
in this report are an
estimate of the number of
CESQGs and stale
requirements for
CESQGs.
Study is limited to one
slate, Washington
Information on how
planning areas obtained
information is not given
Because number of
CESQGs reporting is
small (143 of estimated
43,000), the data included
in this study is not used in
this report.
-------
EXHIBIT A-l (continued)
Data Sources
Title
Survty of Conditionally
Exempt Saudi Quantity
Generaiort of Hazardous
Watte in Montgomery
County, Maryland
Hazardous Waste from
Conditionally Exempt
Small Quantity Generators
in the Municipal SoUd
Waste Stream: A Literature
Review
Date Published/
Author
May 21, 1993
Montgomery County
Department of
Environmental Protection
September 1993
EPA
Scope
Survey of 1,009 firms
located in the county
grouped into seven
industry groups.
Summarizes available
information on CESQGs
obtained from a literature
review of slate and local
studies.
Methodology
(1) targeted firms in seven
industry groups expected
to generate majority of
county CESQG waste; (2)
sent written questionnaires
to obtain information on
CESQG waste generation
and management practices
and conducted follow-up
telephone calls; (3) and
extrapolated results of
survey to county level.
Conducted literature
review and contacted state
government officials
responsible for CESQG
programs in their states.
Response Rate
Collected 374 usable
responses, of which
125 (12 percent of
those surveyed) were
CESQGs.
Not Applicable
Comments
Data is limited to one
county, Montgomery
County, Maryland
Further, the County
surveyed only seven
industry groups.
Information on
methodology and response
rates of studies
summarized in review is
loo limited to describe
accurately. The studies,
however, are cited in the
review. This original
source material was noi
reviewed for this report
-------
Page 38
GENERATION AND MANAGEMENT OF CESQG WASTi
Exhibit A-2
Sequence of Questions for Screening Survey of Industrial Subtitle D Eaabluhrieatr
Does Establishment
Generaie/Manage Imtusmal
Non-Hazardous Waste?
Does Estabhshiwve
Manage Waste in Land-Based Units
On-Site?
Does Establishment
Also Generate CESQG Waste?
Manage CESQG Waste ia
On-Site. Land-Baaed Units?
1
How Does
Establishment Manage
Waste?
f
None
Generated
*
Alununve
Practices
(off-site)
* Ttenudy«xnpo\aiea^nanbeTfram fte tetephooe survey results
10 estunate the total number of establishments in die 17 indusmes nationwide.
-------
GENERATION AND MANAGEMENT OF CESQG WASTE
Page 39
EXHIBIT A-3
Generators Disposing CESQG Waste in On-Site Solid Waste Landfills26
Industry
Metals Manufacturing
Pesticide Application Services
Construction
Laundries
Wholesale/Retail Trade
Educational/Vocational Establishments
Pesticide End Users
Textile Manufacturing
TOTAL FOR ALL 22 INDUSTRIES
Number of CESQG
Establishments in Industry
Disposing CESQG Waste in
On-Site Solid Waste Landfill
677
406
366
178
112
104
99
14
L95C
Percent of Total
CESQG
Establishments
in Industry
2.6
5.2
3.2
13
2.2
3.2
7.1
9.4
ft?*17
Total
Waste
Volume
(tons/yr)
101
54
239
93
22
3
7
1
520
26 Source: National Small Quantity Hazardous Waste Generator Survey.
21 This exhibit lists only those eight Industries of the 22 surveyed that have any CESQGs disposing
their CESQG waste in an on-site solid waste landfill. The percentages in the exhibit represent the percent
of CESQG establishments within each of the eight industries that dispose of their CESQG waste in an on-
site solid waste landfill. Of the estimated 250,000 CESQG establishments in all 22 industries surveyed,
1,956, or 0.75 percent, dispose of their CESQG waste in on-site solid waste landfills.
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Page 40
GENERATION AND MANAGEMENT OF CESQG WASTE
EXHIBIT A-4
Number of CESQGs Disposing CESQG Waste in Oil-Site, Land-Based Units28
Industry
Stone, Clay, Glass, and Concrete
Food and Kindred Products
Textile Manufacturing
Primary Iron and Steel
Pulp and Paper
Rubber and Miscellaneous Products
Petroleum Refining
Selected Chemical and Allied Products
Primary Nonferrous Metals
Electric Power Generation
Water Treatment
Transportation Equipment
Fertilizer and Agricultural Chemicals
Plastics and Resins Manufacturing
Organic Chemicals
Inorganic Chemicals
Leather and Leather Products
TOTAL FOR ALL 17 INDUSTRIES
Estimated Nnmber
of CESQGs
in Industry
1266
896
207
182
169
48
196
31
148
224
111
S3
45
19
13
122
12
3,742
Estimated Number of
CESQGs Disposing
CESQG Waste fat On-
Stte, Land-Based Unit
160
131
50
48
43
30
28
25
24
22
15
15
5
4
3
2
0
695
Percent of Total
CESQGs in
Industry Group
12.6
14.6
24.2
26.4
25.4
615
14.3
80.6 .
16.2
9.8
13.5
28J
11.1
21.1
23.1
1.6
~
16.2
28 Source: Screening Survey of Industrial Subtitie D Establishments.
-------
GENERATION AND MANAGEMENT OF CESQC WASTE Page 41
Appendix B
This Appendix -contains an exhibit listing requirements for CESQGs in all SO states and the
District of Columbia. This exhibit corresponds to Section IV. Information in this exhibit was obtained
from Hazardous Waste From Small Quantity Generators (Seymour Schwartz and Wendy Pratt, Island Press,
c. 1990) and Hazardous Waste From Conditionally Exempt Small Quantity Generators in the Municipal Solid
Waste Stream (USEPA, September 1993).
-------
EXHIBIT B-l
State Requirements For CESQGs That Are More Stringent Than Federal Regulations
(1990, except where noted)
State
FEDERAL
Alabama
Alaska (1993)
Arizona
Arkansas
California (1993)
Colorado
Connecticut (1993)
Delaware
DBlrict of Columbia
Florida (1993)
Georgia
HawaH
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
CESQG
Generator
Size
(kgftno)
0-100
0-100
0-100
0-100
0-100
0-100
0-100
0-100
0-100
50-100
0-50
0-100
0-100
0-100
0-100
0-100
0-100
0-100
25-100
0-25
0-100
State ID*
Required
No
Limited
Storage
Period
(Days)
IndcQaJte
Accumulation
Limit On-sHe
(ki)
1,000
Licensed
Huter or
License
Required for
Hauling
No
Generator
Self-
Transport
Limit (kg)
None
Manliest
Required
No
Disposal only
Kt Permitted
Subtitle C
TSOF
No
Reporting
Required
No
Slate requirements no more stringent than Federal regulations.
State requirements no more stringent than Federal regulations.
Yes
365
100
999
Yes
23
999
Yes
Yes
Yes
Yes
Annual1
Annual1
Biennial
State requirements no more stringent than Federal regulations.
Yes
90
180
300
Yes
Yes
100
Yes
Yes
Annual
State requirement^ no more stringent than Federal regulations.
State requirements no more stringent than Federal regulations.
State requirements no more stringent than Federal regulations.
Yes
Yes
YesJ
State requirements no more stringent than Federal regulations.
Yes
Yes
25
100
Yes
Yes
Yes
Biennial
-------
EXHIBIT B-l
State Requirements For CESQGs That Are More Stringent Than Federal Regulations
(1990, except where noted)
State
FEDERAL
Louisiana
Maine (1993)
Maryland
Massachusetts (1993)
Michigan
Minnesota (1993)
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire (1993)
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon (1993)
CESQG
Generator
Size
(kg/mo)
0-100
0-100
0-100
0-100
0-100
0-100
0-100
0-100
0-100
0-100
0-100
0-100
0-100
0-100
(MOO
0-100
0-100
0-100
0-100
0-100
0-100
State ID*
Required
No
Yes
Yes
Yes
United
Storage
Period
(Days)
Indefinite
365
365
Accumulation
Limit On-site
(kg)
1,000
100
100
600
Licensed
Hauler or
License
Required for
Hauling
No
Yes
Yes
Yes*
Yes
Generator
Self-
Transport
Limit (kg)
None
-
100
200
.
100
Manifest
Required
No
Yes
Yes
Yes*
Yes
Disposal only
at Permitted
Subtitle C
TSDF
No
Yes
Yes
Yes
Yes*
Yes
Reporting
Required
No
Annual
Annual
Slate requirements no more stringent than Federal regulations.
100
100
Stale requirements no more stringent than Federal regulations.
100
100*
Yes
Yes'
Yes
-
100
100
-
Yes
Yes
Yes*
Yes
Yes
Yes*
Yes
Stale requirements no more stringent than Federal regulations.
Stale requirements no more stringent than Federal regulations.
-------
EXHIBIT B-l
Slate Requirements For CESQGs That Are More Stringent Than Federal Regulations
(1990, except where noted)
Slate
FEDERAL
Pennsylvania
Rhode Island (1993)
South Carolina
SouUi Dakota
Tennessee
Teas
Utah
Vermont (1993)
Virginia
Washington (1993)
West Virginia
Wisconsin
Wyoming
CESQG
Generator
Size
(kg/mo)
0-100
0-100
No CESQG
0-100
0-100
0-100
0-100
0-100
0-100
0-100
(MOD
0-100
0-100
0-100
Stale ID#
Required
No
Yes
United
Storage
Period
(Itays)
Indefinite
90
Accumulation
Limit On-site
(kg)
1,000
-
Licensed
Hauler or
License
Required for
Hauling
No
Yes
Generator
Self-
Transport
Limit (kg)
None
-
100
Manifest
Required
No
Yes
Yes
' Disposal only
at Permitted
Subtitle C
TSDF
.No
Yes
Yes
Reporting
Required
No
Biennial
State requirements no more stringent than Federal regulations.
State requirements no more stringent than Federal regulations.
Yes'
Yes
-
Yes7
Monthly1
Stale requirements no more stringent than Federal regulations.
Stale requirements Po more stringent than Federal regulations.
State requirements no more stringent than Federal regulations.
Yes
100
Yes
Yes
100
-
Yes' ,
Yes
Annual
State requirements no more stringent lhan Federal regulations.
1 First page of annual report only.
1 Only CESQGs wilh Slate identification numbers need to report annually.
* IgnitaMe or infectious waste may not be disposed of in non-hazardous waste tandftlb.
4 Required for liquid industrial waste only.
1 100 kg of hazardous waste or 1,001 gallons of waste oil.
6 License required to haul waste oil only.
1 Not required for non-industnal CESQG waste.
1 Only if waste is sent out of stale.
9 Disposal at out of Stale MSWLFs arc permissible; regulation is under review.
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GENERATION AND MANAGEMENT OF CESQG WASTE Page 45
Appendix C
Exhibit C-l lists available Federal and state documents that encourage pollution prevention and proper waste
management by CESQGs in some CESQG waste generating industries. Those documents that are available from the
Pollution Prevention Information Clearinghouse (PPIC) may be obtained by contacting PPIC at the following address:
PPIC
Environmental Protection Agency
401 M St, SW (7409)
Washington, D.C 20460
PPIC Reference and Referral: (202) 260-1023
PPIC Fax Line: (202) 260-0178
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EXHIBIT C-l
Available Pollution Prevention and Proper Waste Management Documents
Industry
Vehicle
Maintenance
Title of Document
Pollution Prevention Tips for Automotive Maintenance Shops
Environmental Guidelines and Pollution Prevention for the
Automotive Service Industry
A Pollution Prevention Guide for Automotive Repair Shops
Waste Management Practices of Vehicle Maintenance Businesses
and Local Government Vehicle Fleet Management Operations
Waste Minimization Works for Businesses and Iowa - leaflet on
vehicle maintenance operations
Case Study: Waste Minimization in the Auto Repair Sector
Pollution Prevention in the Commercial Sector A Waste Stream
Assessment in the Vehicle Service and Repair Sector
Waste Management and Reduction for Automotive Repair Shops
Model Tones Use and Hazardous Waste Reduction Plan for
Oregon Automotive Services Industries, 1992
Source
Alaska Department of Conservation, Pollution Prevention Office
(907) 465-5275
Colorado Department of Health, Pollution Prevention Waste '
Reduction Programs
(303)692-3003
Delaware Department of Natural Resources and Environmental
Control, Pollution Prevention Program
(302) 739-5071/3822
District of Columbia, Metropolitan Washington Council of
Governments, Department of Environmental Programs
(202) 962-3355
Iowa Department of Natural Resources, Waste Management
Authority Division
(515)281-8941
University of Nebraska - Lincoln Center for Infrastructure
ReseartiJ
(402) 472-5022
University of Nevada, Reno, Small Business Development Center,
Business Environmental Program
(702) 784-1717
Oregon Department of Environmental Quality, Hazardous Waste
Reduction and Technical Assistance Program
(503)229-6585
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EXHIBIT C-l (continued)
Available Pollution Prevention and Proper Waste Management Documents
Industry
Metals
Manufacturing
Title of Document
Waste Minimization Works for Businesses and Iowa - leaflet on
metals fabrication/farm equipment manufacturing
Case Study: Alpha Metal Finishing Company - fact sheet
Waste Minimization in a Metal-Finishing Industry: A Pilot Project
NJTAP Literature Review, Metals Finishing
Waste Reduction Assessment Report, The Forging Company
Case Study of Waste Minimization at a Metal Fabricating Facility
Case Study of Waste Minimization at a Metal Machining Facility
Fabricated Metal Products Industry, Pollution Prevention
Information Packet
Source
Iowa Department of Natural Resources, Waste Management
Authority Division
(515) 281-8941
Michigan Department of Natural Resources, Office of Waste
Reduction Services, Environmental Services Division
(517)335-1178
University of Nebraska - Lincoln Center for Infrastructure
Research
(402) 472-5022
New Jersey institute of Technology, New Jersey Technical
Assistance Program, Hazardous Substance Research Center
(201) 596-5864
Ohio Environmental Protection Agency, Division of Hazardous
Waste Management, Pollution Prevention Section
(614) 644-3969
Pennsylvania, Center for Hazardous Materials Research, University
of Pittsburgh
(411) 826-5320
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EXHIBIT C-l (continued)
Available Pollution Prevention and Proper Waste Management Documents
Industry
Metals
Manufacturing
(continued)
Laundries
Title of Document
Guidelines for Waste Reduction and Recycling: Metals Finishing,
Electroplating, Printed Circuit Board Manufacturing
Case Studies for Meiate finishing
Pollution Prevention In Metals Manufacturing: Saving Money
Through Pollution Prevention
Pollution Prevention Options in Metals Fabricated Products
Industries: A Bibliographic Report
A Practical Guide to Pollution Prevention Planning for the Iron and
Steel Industries
Waste Minimization in Metals Parts Cleaning
Dry Cleaning and Laundries
Pollution Prevention Guide for the Dry Cleaning Industry
Pollution Prevention Success Story: Capitol Cleaners
Pollution Prevention in the Commercial Sector: A Waste Stream
Assessment in the Solvent Based Dry Cleaning Industry
Dry Cleaning Project
Multiprocess Wet Cleaning: Cost Performance Comparison of
Conventional Dry Cleaning and an Alternative Process
Multiprocess Wet Cleaning Demonstration Study. Background and
Results
Source
PPIC
PPIC
PPIC
PPIC
PPIC
PPIC
Colorado Department of Health, Pollution Prevention Waste
Reduction Programs
(303) 692-3003
Delaware Department of Natural Resources and Environmental
Control, Pollution Prevention Program
(302) 739.5071/1822
University of Nebraska - Lincoln Center for Infrastructure
Research
(402) 472-5022
PPIC
PPIC
PPIC
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EXHIBIT C.I (continued)
Available Pollution Prevention and Proper Waste Management Documents
Industry
Printers
Title of Document
Print Shops
A Pollution Prevention Guide for the Priming Industry
Waste Minimization Works for Businesses and Iowa
Pollution Prevention for the Commercial Printing Industry
Winning Environmental Strategies for Printers
Pollution Prevention, Commercial Printing Industry
Case Studies in Printing
Pollution Prevention in Printing and Allied Industries: Saving
Money Through Pollution Prevention
Case Study #1: Managing Solvents and Wipes
Case Study #2: Reducing the Use of Reclamation Chemicals in
Screen Cleaning
EPA Chemical Lists for the Printing Industry
Federal Environmental Regulations Potentially Affecting the
Commercial Printing Industry
Printing Project
Use Ouster Analysis of the Printing Industry - Executive Summary
Source
Colorado Department of Health, Pollution Prevention Waste '
Reduction Programs
(303) 692-3003
Delaware Department of Natural Resources
Control, Pollution Prevention Program
{302] 7S9-5071/3822
and Environmental
Iowa Department of Natural Resources, Waste Management
Authority Division
(515)281-8941
University of Nevada, Reno, Small Business
Business Environmental Program
(702) 784-1717
Development Center,
New Jersey Institute of Technology
New Jersey Technical Assistance Program, Hazardous Substance
Research Center
(201) 596-5864
PPJC
PPIC
PPIC
PPIC
PPIC
PPIC
PPIC
PPIC
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EXHIBIT C-l (continued)
Available Pollution Prevention and Proper Waste Management Documents
Industry
Pulp and Paper
Petroleum
Refining
Pesticides
Title of Document
Results of the 1988 Toxics Release Inventory Reporting fat the
Pulp and Paper Industry in New England
Handbook on Pollution Prevention Opportunities for Bleached
Kraft Pulp and Paper Mills
Pollution Prevention Tecnnotogtes for the Bleached Kraft Segment
of the UJS. Pulp and Paper Industry
Case Study of Minimization of Phololithiography and Ink Wastes in
an Ink and Printer Manufacturing Facility
Pollution Prevention Options in Petroleum Refining: A
Bibliographic Report
Indiana Pesticides News
The Label, Purdue Pesticide Programs newsletter
PoDulion Prevention Pesticide Container Management
Pollution Prevention at Agnchemical Dealerships
Waste Management in Rural Sectors with Emphasis on Farm
Cooperatives and Pesticide Applicators
Guide to Pollution Prevention: Non Agricultural Pesticide Users
Source
Massachusetts, Northeast Waste Management Officials'
Association (NEWMOA)
(617) 367-8558
PPIC
PPIC
Ohio Environmental Protection Agency, Division of Hazardous
Waste Management, Pollution Prevention Section
(614) 644-3969
PPIC
Indiana Department of Environmental Management, Office of
Pollution Prevention and Technical Assistance
(317) 232-8172
Purdue University Cooperative Extensions Service, Indiana
Pollution Prevention Program, Environmental Management and
Education Program
(317) 494-5038
Missouri Department of Natural Resources, Hazardous Waste
Program, Division of Environmental Quality
(314)751-3176
University of Nebraska - Lincoln Center for Infrastructure
Research
(402) 472-5022
Center for Environmental Research Information (CERI)
26 West Martin Luther King Drive
Cincinnati, OH 45268
Phone (5 13) 569-7562 Fax (513) 569-7566
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