CESQG’s: What’s so unique

about Washington

anyway? A different take…

David S.Misko, Supervisor Hazardous Waste Compliance

Northwest Regional Office

“How is education going to make me smarter?”

CESQG’s in Washington• Who is a conditionally-exempt small quantity

generator?• Generation defined• Waste defined• CESQG requirements

“Go ahead and play the blues if it’ll make you happy.”

Who’s a CESQG?• Nearly anyone could be, including:

› Commercial offices› Schools› Retail businesses› Entertainment/recreation› Transportation› Government

“Marge, how many pounds are in a gallon?”

CESQG’s Defined• First, generation of <220 pounds of most

dangerous waste per month• Watch for generation of >2.2 pounds of

acutely hazardous (or extremely dangerous) waste

• Next, waste accumulation always <2,200 pounds on-site

Generators of Dangerous Waste• GENERATOR means “any person, by site,

whose act or process produces dangerous waste or whose act first causes a dangerous waste to be subject to regulation”

WAC 173-303-040

Common interpretation of this definition also includes the activities of any contractor that might be hired in lieu of you doing the job

Generation of Dangerous Waste• DANGEROUS WASTE means “the full universe

of wastes regulated by Washington that designate by Federal listings and characteristics as well as state-only criteria or listing found in Chapter 173-303 WAC”

WAC 173-303-040

Every listed, characteristic, and criteria waste defined by USEPA and/or Ecology

“Roads are simply a suggestion, Marge. Just like pants.”

CESQG Requirements• WAC 173-303-070(8)

› Designate the waste› Manage the waste in a way that does not pose a

threat to human health or the environment› Treat or dispose in an on-site facility or ensure

delivery to an off-site facility that is….

“All these guys with six-pack abs and I’m the only one with a keg.”

Determining Generator Status• Be prepared by knowing the industry, its raw

materials, processes, products, and wastes• Consider occasional or non-recurrent waste

streams generated on-site• Don’t forget contracted services and the waste

that they may generate• Generator status is determined by the sum of

all activities conducted on-site

“If something’s hard to do, then it’s not worth doing.”

Designate the Waste• Is it a solid waste? • Is it excluded?• Can it be recycled?• Is it listed? • Characteristic? • Criteria?

“Son, if you really want something in this life, you have to work for it. Now, quiet. They’re about to announce the lottery numbers.”

Container Management

• Closed• Good condition• Labels• Compatibility• Containment• Inspections and documentation

“American donuts: glazed, powdered, and raspberry-filled. Now, how’s that for freedom of choice?”

Off-site Facility Options

• Permitted to receive dangerous waste in WA• Authorized to manage DW in another state• Permitted to manage moderate risk waste• Beneficially reuses or legitimately recycles• Permitted to manage municipal solid waste• Permitted to manage non-municipal, non-

hazardous waste in another state

CESQG Facility Options (cont.)• A publicly owned treatment works for waste

using the domestic sewage exclusion• Universal waste handler or destination facility

Organizing a Program• Mission, e.g., “Protect health & environment”• Authority, i.e., solid waste delegation• Community awareness – strengths and

weaknesses, i.e., leaders, organizations• Funding (even better, dedicated funding)• Resources, i.e., staff, vehicles, supplies, tools• Experience and network, e.g., IRAC• Training, e.g., NAHMMA

Questions?