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CESQG’s: What’s so unique about Washington anyway? A different take…

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?

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CESQG’s: What’s so unique about Washington anyway? A different take…

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  1. CESQG’s: What’s so unique about Washington anyway? A different take… David S.Misko, Supervisor Hazardous Waste Compliance Northwest Regional Office

  2. “How is education going to make me smarter?”

  3. CESQG’s in Washington • Who is a conditionally-exempt small quantity generator? • Generation defined • Waste defined • CESQG requirements

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

  5. Who’s a CESQG? • Nearly anyone could be, including: • Commercial offices • Schools • Retail businesses • Entertainment/recreation • Transportation • Government

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

  7. 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

  8. 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

  9. 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

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

  11. 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….

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

  13. 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

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

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

  16. “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.”

  17. Container Management • Closed • Good condition • Labels • Compatibility • Containment • Inspections and documentation

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

  19. 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

  20. CESQG Facility Options (cont.) • A publicly owned treatment works for waste using the domestic sewage exclusion • Universal waste handler or destination facility

  21. 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

  22. Questions?

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