From: Jeffrey Lewin <jclewin**At_Symbol_Here**MTU.EDU>
Subject: Re: [DCHAS-L] Nerdy RCRA question
Date: Fri, 1 Nov 2019 11:44:54 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: CAEwQnqhP6vVELZz-P=Osna=1=ugEztXc5fFce9W9GGhbtP1daQ**At_Symbol_Here**mail.gmail.com
In-Reply-To


Ralph,

To add to others, in Michigan (we've NOT adopted the EPA improvement rules, yet) we are required to tell the State every spring what our accumulation status is going to be. I run one SQG and 5 CESQGs (soon to be VSQGs under EPA's rules). Before I took over this position the previous staff member had to temporarily move one of the CESQGs to LQG for a cleanup. It was a simple email/phone call to go up then back down; there was some additional fees involved. Because it was in the "off" years, we didn't even have to file a biennial report. My understanding is that one of the "improvements" in the new EPA rules is that it will be easier to generate limited one-time excess quantities of chemicals without having to change your generator status.

As for generation, I keep a shadow spreadsheet of everything I pick up of nonRCRA and RCRA wastes. For RCRA I tally up the monthly totals, with P-listed wastes in their own column. I've never come close to generating 1000kg in a month. As mentioned, it's watching the P-listed waste accumulation that is a challenge. As an aside, my regulator allowed me to use this spreadsheet to show that, even though my vendor manifested for shipment an excess of 1kg of P-listed waste (due to the weight of the DOT drum overpack), the spreadsheet showed it was less. Note that as an SQG I can only accumulate 6000kg of RCRA waste, but because my waste vendor is more than 200 miles away I can technically pick up every 270 days...but the physical size of my SAA limits me 180-day pickups.

Jeff

On Fri, Nov 1, 2019 at 8:53 AM Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**keene.edu> wrote:
I was talking to a student about the wonders of RCRA and he asked a question that I'm not sure of the answer to. Perhaps people on the list have some experience with it.

We were talking about the RCRA system of classifying waste generators into various classes based on the amount generated - large quantity generators, small quantity generators, etc. (I would note that New Hampshire does not follow the federal model in this regard, but I don't think that nuance affects this question.) The student asked whether there was a presumption that a particular waste generator was a large quantity generator until they proved otherwise or if a generator could presume to be a small quantity generator until proven otherwise by the regulator.

Complicating this question is the fact that the regulatory concept of waste generation rates is separate from the shipping of hazardous waste from a location in this regard. So you can't just look at your manifests to determine what size generator you are. The practical version of this question is how do people track intermittent waste generators such as labs to identify what size RCRA generator a location is?

Thanks for any experiences you have on this deep dive topic.

- Ralph


Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859

ralph.stuart**At_Symbol_Here**keene.edu

---
For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org
Follow us on Twitter **At_Symbol_Here**acsdchas


--
Jeff Lewin
Chemical Safety Officer
Research Integrity Office
Laboratory Operations
207 Advanced Technology Development Complex (ATDC)
Michigan Technological University

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas

Previous post   |  Top of Page   |   Next post



The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to secretary@dchas.org.
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.