EPA530-R-02-005g
RCRA, SUPERFUND & EPCRA CALL CENTER MONTHLY REPORT
July 2002
1. Generator Accumulation Requirements for Hazardous Waste that is Not
Being Shipped Off Site
Large quantity generators (LQGs) and small quantity generators (SQGs) may treat
hazardous waste on site without obtaining a permit provided they are in compliance with
40 CFR Section 262.34 and all applicable unit standards (e.g., Part 265, Subpart J, if the
facility treats in tanks) (51 FR 10146, 10168; March 24, 1986). A LQG decharacterizes
1,500 kilograms of hazardous waste in a tank before discharging it via a Clean Water Act
(CWA) permit. Is the generator subject to accumulation requirements in addition to unit
standards?
The LQG would be subject to all applicable accumulation requirements. LQGs that
generate hazardous waste on site and subsequently treat or dispose of that same
hazardous waste on site are required to follow the generator accumulation requirements
in Section 262.34. According to Section 262.10, Note 1, the provisions in Section 262.34
apply to owners and operators who are "shipping hazardous waste generated at their
facility." The language in Section 262.10, Note 1, was not intended to exclude waste that
is treated or disposed of on site; therefore, all applicable Section 262.34 accumulation
requirements apply to these wastes as well.
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