Currently, if a Very Small Quantity Generator (VSQG) or Small Quantity Generator (SQG) generates more than 2200 pounds of hazardous waste in any month, for any reason, they are subject to Large Quantity Generator (LQG) requirements. This can include a fee, personnel training, contingency plans, accumulation time and all other applicable LQG standards.
Some generators may only exceed the LQG quantity due to a periodic event. The Indiana Department of Environmental Management (IDEM) has begun the adoption of the Generator Improvement Rule. This rule allows a VSQG or SQG to maintain its existing generator category if the facility experiences a periodic event. An example would be generating a quantity of haz waste in a calendar month that would otherwise bump the generator into a more stringent generator regulatory category.
Under this provision, generators that satisfy the listed conditions do not have to comply with the more stringent generator standards when an unusual event occurs that temporarily increases the facility’s haz waste generation.
This could represent a significant opportunity for many facilities to maintain their generator status at a lower level, meaning less regulatory burden and potential cost savings.
Contact John Crawford at NEI to discuss how your facility may benefit from the Generator Improvement Rule.