VSQG Consolidation to LQG - Hanley 5-23-18

School: Pennsylvania State University - Course: ENVE 425 - Subject: Accounting

VSQG/LQG Waste Consolidation ▪ The Hazardous Waste Generator Improvements Rule allows a very small quantity generator (VSQG) to consolidate their hazardous waste at a large quantity generator (LQG) site providing the two sites are under the controlof thesame person.

VSQG/LQG Waste Consolidation ▪ Control - the power to direct policies at the generator sites ▪ Same person- -individual-corporation(including a government corp.) -trust-partnership -firm-association -joint stock company-State -Federal Agency-municipality -commission-political subdivision of a State -any interstate body *contractors are not included* (as defined under 40 CFR 260.10)

VSQG/LQG Waste Consolidation ▪ This new provision allows a company with various locations to consolidate the hazardous waste generated at their VSQG site with the hazardous waste stored at their LQG site.

Generator sites can be down the street or across state lines as long as both states have adopted the consolidation provision.

VSQG/LQG Waste Consolidation ▪ This new provision helps with managing and shipping of the VSQG hazardous waste more efficiently. ▪ Ensures proper management of the VSQG waste at the LQG site.

Requirements for VSQG 40 CFR 262.14(a)(5)(viii) ▪ VSQG must mark it's hazardous waste containers with: -the words "Hazardous Waste" - an indication of the hazards of the contents of the container Such as: -hazardous waste characteristics - DOT labeling/placarding symbols -OSHA pictograms -NFPA chemical hazard labels