How to Determine Your Hazardous Waste Generator Status

In the following post, we'll explain how to determine your hazardous waste generator status by calculating the amount of spent solvent that should be counted towards the amount of hazardous waste generated in a month, as governed by the EPA. (see pdf link below). The EPA regulates hazardous waste under the Resource Conservation and Recovery Act (RCRA) to ensure these wastes are managed in ways that protect human health and the environment.

What constitutes a hazardous waste generator?

A hazardous waste generator is any person(s) who produce a hazardous waste that falls under definitions of Title 40 of the Code of Federal Regulations (CFR) EPA requirements for hazardous waste generators depend on whether the generator is classified as:

  • Conditionally Exempt Small Quantity Generators
  • Small Quantity Generators
  • Large Quantity Generators

The amount of hazardous waste produced by a generator each month determines their generator status and prevailing regulatory requirements.

If a generator recycles solvent on-site, the spent solvent is not counted towards the generation rate each time it is used.

The requirements for counting hazardous waste that is reclaimed (recycled) on-site are found in the Federal regulation 40 CFR 261.5.

When Still Bottoms Are Hazardous Waste

The solid waste coming out of the solvent distillation unit may also impact your waste generator status. This waste goes by many names, including still bottoms, pancakes, cakes, distillation solids, and pugs. Still bottoms are subject to a hazardous waste determination like any other waste stream. If the spent solvent generating the still bottoms is a listed hazardous waste, the still bottoms would also be a listed hazardous waste.

If the spent solvent is not listed but exhibits the characteristic of ignitability, the still bottoms would only be hazardous if they exhibit one or more characteristics of a hazardous waste (e.g., ignitability, and/or toxicity). For more information on these waste determinations, you can refer to the EPA's Hazardous Waste Determinations and Documentation. If the still bottoms are a hazardous waste, the container of still bottoms is subject to all hazardous waste container management requirements.

Solvent Recycling Recordkeeping

Facilities should maintain a solvent distillation log or record that documents the following information for each distillation run: The date of each spent solvent batch; The amount of spent solvent being distilled in the batch; How much of the batch being distilled is: -newly spent, -previously distilled the current month, or -previously distilled from a prior month; and The weight of still bottoms produced.

FREE LOG: Determine the Hazardous Waste Generation Rate for On-Site Solvent Recycling




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