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STANDARDS APPLICABLE TO GENERATORS OF HAZARDOUS WASTE
SMALL QUANTITY GENERATOR (SQG) REQUIREMENTS
GENERAL REQUIREMENTS

Did Generator transport, offer for transport, or otherwise send HW only to a designated facility or a facility authorized to receive the HW? [40 CFR 262.10(a)(3)]

Did Generator make an accurate determination as to whether a solid waste was hazardous? [40 CFR 262.11(a-d)]

Did Generator maintain records that support the HW determination for at least three years? [40 CFR 262.11(f)]

Did Generator to determine its proper category? [40 CFR 262.13]

Did SQG ship HW off site within 180 days? [40 CFR 262.16(b)]

Did SQG ship HW off site within 270 days for waste transported over 200 miles? [40 CFR 262.16(c)]

Did Generator have an EPA ID number prior to treating, storing, disposing of, transporting, or offering for transportation HW? [40 CFR 262.18(a)]

Did Generator offer HW to transporters or to TSD facilities that have received an EPA ID number? [40 CFR 262.18(c)]

Did recognized trader have an EPA ID Number prior to arranging for import or export of HW? [40 CFR 262.18(e)]

USE AND MANAGEMENT OF CONTAINERS

Did SQG immediately transfer HW from a container not in good condition or leaking to a container in good condition? [40 CFR 262.16(b)(2)(i)]

Did SQG use a container made of or lined with materials that will not react with, and are otherwise compatible with, the HW being accumulated? [40 CFR 262.16(b)(2)(ii)]

Did SQG keep containers holding HW closed except when it was necessary to add or remove waste? [40 CFR 262.16(b)(2)(iiiA)]

Did SQG handle containers holding HW in a manner that prevented container rupture and leakage? [40 CFR 262.16(b)(2)(iiiB)]

Did SQG inspect central accumulation areas at least weekly looking for leaking containers and for deterioration of containers? [40 CFR 262.16(b)(2)(iv)]

Did SQG comply with the special standards for incompatible wastes in a container? [40 CFR 262.16(b)(2)(v)]

Did SQG mark or label containers with the words “Hazardous Waste” and an indication of the hazards of the contents? [40 CFR 262.16(b)(6)(iA-B)]

Did SQG mark or label its containers with the accumulation start date clearly visible for inspection on each container. [40 CFR 262.16(b)(6)(iC)]

LABELING AND MARKING CONTAINERS AND TANKS

Did SQG mark or label tanks with the words “Hazardous Waste” and an indication of the hazards of the contents. [40 CFR 262.16(b)(6)(iiA-B)]

Did SQG maintain the required records showing HW was accumulated for no more than 180 days in a tank and keep records with the required information on site and readily available for inspection? [40 CFR 262.16(b)(6)(iiC-D)]

SATTELITE ACCUMULATION AREAS (SAA) REQUIREMENTS

Did Generator immediately transfer HW from a satellite container not in good condition or leaking to a container in good condition and not leaking, or immediately transfer and manage the waste in a central accumulation area? [40 CFR 262.15(a)(1)]

Did Generator use a satellite container made of or lined with materials that will not react with, and are otherwise compatible with, the HW being accumulated? [40 CFR 262.15(a)(2)]

Did Generator comply with the special standards for incompatible wastes in a satellite container? [40 CFR 262.15(a)(3)]

Did Generator keep satellite container closed except when adding, removing, or consolidating waste, or when temporary venting of a container was necessary? [40 CFR 262.15(a)(4)]

Did Generator mark or label a satellite container with the words “Hazardous Waste” and an indication of the hazards of the contents? [40 CFR 262.15(a)(5)]

Did Generator comply within three consecutive calendar days with the applicable central accumulation area requirements or remove the excess amounts from the satellite accumulation area to either a central accumulation area or an on-site or off-site facility and mark or label satellite containers holding the excess accumulation of HW with the date the excess amount began accumulating? [40 CFR 262.15(a)(6)]

SQG operating satellite accumulation areas must meet the preparedness and prevention requirements of 262.16(b)(8) and emergency procedures of 262.16(b)(9). [40 CFR 262.15(a)(7)]

PRE-TRANSPORT REQUIREMENTS

Did Generator package hazardous waste in accordance with 49 C.F.R. Parts 173, 178, and 179? [40 CFR 262.30]

Did Generator label each package of hazardous waste in accordance with Part 172? [40 CFR 262.31]

Did Generator mark packages of hazardous waste in accordance with 49 C.F.R. Part 172? [40 CFR 262.32(a)]

Did Generator properly mark each container of HW before transporting or offering for transportation waste off site? [40 CFR 262.32(b)]

Did Generator placard or offer the appropriate placard for a vehicle containing hazardous waste, in accordance with 49 C.F.R. Part 172, Subpart F? [40 CFR 262.33]

Did Generator comply with the requirement prohibiting the placement of bulk or non-containerized liquid HW or HW containing free liquids (whether or not sorbents have been added) in a landfill? [40 CFR 262.35]

MANIFEST REQUIREMENTS

Did Generator prepare a manifest before transporting or offering hazardous waste for transport off-site? [40 CFR 262.20(a)(1)]

Did Generator designate an authorized facility on the manifest? [40 CFR 262.20(b)]

Did Generator designate an alternate facility or instruct the Transporter to return the waste when the Transporter was unable to deliver the waste? [40 CFR 262.20(d)]

Did SQG properly sign the manifest upon receipt of a returned shipment of HW? [40 CFR 262.16(e)]

Did Generator use EPA approved manifest forms for shipments of hazardous waste? [40 CFR 262.21(g)(1)]

Did Generator determine if generator or consignment state regulates additional wastes or requires the generator to submit copies of the manifest? [40 CFR 262.21(g)(2)]

Did Generator sign the manifest? [40 CFR 262.23(a)(1)]

Did Generator obtain the signature of the initial Transporter and date of acceptance on the manifest? [40 CFR 262.23(a)(2)]

Did Generator retain one copy of the manifest in accordance with Sec. 262.40(a)? [40 CFR 262.23(a)(3)]

Did Generator supply the Transporter with remaining copies of manifest? [40 CFR 262.23(b)]

Did Generator shipping hazardous waste within the U.S. solely by water send 3 copies of the manifest form signed and dated to the owner or operator of the designated facility or last water Transporter in the U.S.? [40 CFR 262.23(c)]

Did Generator send at least 3 copies of the signed and dated manifest for rail shipments of hazardous waste within the U.S. to next non-rail transporter, designated facility, or last rail transporter in the U.S.? [40 CFR 262.23(d)]

Did Generator using an electronic manifest ensure that all waste handlers named on the manifest are participants in the electronic manifest system? [40 CFR 262.24(c)]

Did Generator provide the initial Transporter with one printed copy of the electronic manifest? [40 CFR 262.24(d)]

Did Generator obtain and complete a paper manifest and continuation sheet if the electronic manifest system became unavailable prior to the time that the initial Transporter electronically signed the manifest? [40 CFR 262.24(e)]

Did the Generator certify to one of the statements in Item 15 of the hazardous waste manifest? [40 CFR 262.27]

RECORDKEEPING AND REPORTING APPLICABLE TO SMALL AND LARGE QUANTITY GENERATORS

Did Generator keep a copy of each manifest for 3 years? [40 CFR 262.40(a)]

Did Generator keep copy of hazardous waste report or exception report for 3 years? [40 CFR 262.40(b)]

Did Generator keep copies of required records during the course of any unresolved enforcement action(s) or as requested by the Department? [40 CFR 262.40(d)]

Did SQG re-notify the Department using EPA Form 8700-12 by September 1 starting in 2021 and every four years thereafter? [40 CFR 262.18(d)(1)]

Did SQG comply with exception reporting requirements? [40 CFR 262.42(b)]

PREPAREDNESS AND PREVENTION

Did SQG maintain and operate facility to minimize the possibility of a fire, explosion, or release? [40 CFR 262.16(b)(8)(i)]

Did SQG equip facility with emergency equipment? [40 CFR 262.16(b)(8)(ii)]

Did SQG test and maintain emergency equipment? [40 CFR 262.16(b)(8)(iii)]

Did SQG maintain immediate access to communications or alarm system? [40 CFR 262.16(b)(8)(iv)]

Did SQG maintain aisle space for the unobstructed movement of personnel and equipment in an emergency? [40 CFR 262.16(b)(8)(v)]

Did SQG attempt to make required arrangements with PD or FD, ER contractors, equipment suppliers, or local hospitals and maintain records documenting confirmation that the arrangements exist or attempts were made or obtain a waiver? [40 CFR 262.16(b)(8)(vi)]

EMERGENCY PROCEDURES AND TRAINING

Did SQG have an emergency coordinator available on the premises or on call? [40 CFR 262.16(b)(9)(i)]

Did SQG post the following information: (A) Name and telephone number of the emergency coordinator; (B) Location of fire extinguishers and spill control material, and, if present, fire alarm; and (C) Telephone number of the FD, unless the facility has a direct alarm? [40 CFR 262.16(b)(9)(ii)]

Did SQG ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies? [40 CFR 262.16(b)(9)(iii)]

Did SQG respond properly to emergencies? [40 CFR 262.16(b)(9)(iv)]

Episodic Event – SQG may accumulate hazardous waste during this event in accordance with subpart L of this part in lieu of 40 C.F.R. 262.17. [40 CFR 262.16(f)]

LDR REQUIREMENTS

Did the Generator, Transporter, or TSDF ensure that a restricted waste is not in any way diluted as a substitute for treatment? [40 CFR 268.3(a)]

Did Generator determine if the hazardous waste is restricted from land disposal? [40 CFR 268.7(a)(1)]

Did Generator send a one-time written notice with the initial waste shipment to the TSDF when the waste did not meet the treatment standard or place a copy in the file? [40 CFR 268.7(a)(2)]

Did Generator send a one-time written notice and certification with the initial waste shipment to the TSDF when the waste met the treatment standard or place a copy in the file? [40 CFR 268.7(a)(3)]

Did Generator of waste exempt from meeting treatment standards send a one-time written notice to the land disposal facility or place a copy in the file before the waste was land disposed? [40 CFR 268.7(a)(4)]

Did Generator who is managing and treating prohibited waste develop and follow a written waste analysis plan, and keep plan on site? [40 CFR 268.7(a)(5)]

Did Generator retain on site all data used to determine if a waste is restricted? [40 CFR 268.7(a)(6)]

Did Generator keep a one-time notice on site stating that he is managing a restricted waste that is excluded from the definition of hazardous or solid waste subsequent to the point of generation and noting the disposition of the waste? [40 CFR 268.7(a)(7)]

Did Generator retain documentation required by 268.7 for 3 years or longer during the course of any unresolved enforcement action or as requested by the Department? [40 CFR 268.7(a)(8)]

Did Generator using the alternative treatment standards for lab packs send a one-time written notice and certification with the initial waste shipment to the Treatment Facility or place a copy in the file? [40 CFR 268.7(a)(9)]

Did SQG with tolling agreements comply with applicable notification and certification requirements for the initial shipment of waste subject to the tolling agreement or retain copy(s) on site? [40 CFR 268.7(a)(10)]

Did Generator of a waste that displays a hazardous characteristic determine the underlying hazardous constituents in the waste? [40 CFR 268.9(a)]

Did Generator ensure a prohibited waste exhibiting a characteristic complied with the treatment standards under 268, Subpart D before being land disposed? [40 CFR 268.9(c)]

Did Generator or Treater of a waste that once exhibited a characteristic, but is no longer hazardous, place a one-time notification and certification in a file or send a copy to the Department? [40 CFR 268.9(d)]

Did Generator comply with the land disposal prohibitions of EPA Hazardous Waste Number K181? [40 CFR 268.20]

Did Generator comply with land disposal prohibitions of wood preserving wastes? [40 CFR 268.30]

Did Generator comply with land disposal prohibitions of dioxin-containing wastes? [40 CFR 268.31]

Did Generator comply with the land disposal prohibitions of soils exhibiting the toxicity characteristic for metals and containing PCBs? [40 CFR 268.32]

Did Generator comply with land disposal prohibitions of chlorinated aliphatic wastes? [40 CFR 268.33]

Did Generator comply with land disposal prohibitions of toxicity characteristic metal wastes? [40 CFR 268.34]

Did Generator comply with land disposal prohibitions of petroleum refining wastes? [40 CFR 268.35]

Did Generator comply with the land disposal prohibitions of inorganic chemical wastes? [40 CFR 268.36]

Did Generator comply with land disposal prohibitions of newly identified organic toxicity characteristic wastes and newly listed coke by-product and chlorotoluene production wastes? [40 CFR 268.38]

Did Generator comply with land disposal prohibitions of spent aluminum potliners, reactive and carbamate wastes? [40 CFR 268.39]

Did Generator meet treatment standard requirements found in the table in 40 C.F.R. 268.40 before land disposing of prohibited waste? [40 CFR 268.40]

Did Generator meet treatment standards before land disposing for hazardous debris? [40 CFR 268.45]

Did Generator meet treatment standards for underlying hazardous constituents? [40 CFR 268.48]

Did Generator meet the alternative LDR treatment standards for contaminated soil? [40 CFR 268.49]

Did Generator store restricted HW solely for the purpose of the accumulation of such quantities to facilitate proper recovery, treatment, or disposal? [40 CFR 268.50(a)(1)]

Did Facility store restricted HW solely for the purpose of the accumulation of such quantities to facilitate proper recovery, treatment, or disposal? [40 CFR 268.50(a)(2)]

Did Facility clearly mark container with the words “Hazardous Waste”, the applicable EPA HW codes, and an indication of the hazards of the contents? [40 CFR 268.50(a)(2)(iA-C)]

Did Facility clearly mark containers with the accumulation start date? [40 CFR 268.50(a)(2)(iD)]

Did Facility clearly mark each tank with a description of its contents, the quantity of each hazardous waste received, and the accumulation start date or record and maintain such information for each tank in the operating record? [40 CFR 268.50(a)(2)(ii)]

SQG EPISODIC GENERATION

Did SQG notify the Department no later than thirty (30) calendar days prior to initiating a planned episodic event or within 72 hours of an unplanned event by submitting EPA Form 8700-12? [40 CFR 262.232(b)(2)]

Did SQG have an EPA ID Number during an episodic event? [40 CFR 262.232(b)(3)]

Did SQG comply with the requirement prohibiting the accumulation of HW from an episodic event on drip pads or in containment buildings? [40 CFR 262.232(b)(4)]

Did SQG mark or label containers with the words “Episodic Hazardous Waste” and an indication of the hazards of the contents? [40 CFR 262.232(b)(4)(iA-B)]

Did SQG mark or label containers with the episodic event start date, clearly visible for inspection on each container? [40 CFR 262.232(b)(4)(iC)]

Did SQG mark or label tanks with the words “Episodic Hazardous Waste” and an indication of the hazards of the contents? [40 CFR 262.232(b)(4)(iiA-B)]

Did SQG use inventory logs, monitoring equipment or other records showing the date upon which each episodic event begins and keep required records on site readily available for inspection? [40 CFR 262.232(b)(4)(iiC-D)]

Did SQG treat on site or manifest and ship HW generated from the episodic event to a designated facility within sixty (60) calendar days from the start of the event? [40 CFR 262.232(b)(5)]

Did SQG maintain the required records for three years from the end date of the episodic event? [40 CFR 262.232(b)(6)][/vc_column_text][/vc_column][/vc_row][vc_row][vc_column][vc_empty_space][/vc_column][/vc_row]