New Ohio EPA Jobs Determine Hazardous Waste "Generator Improvement" Rules

Those that hold Ohio EPA jobs have finalized the hazardous waste “generator improvement” rules. These rules, which were finalized at the federal level in 2016, include many significant changes that apply to small quantity generators and large quantity generators of hazardous waste.  These include:

• Small quantity generators must submit an updated generator Notification of Generator Activity to Ohio EPA by September 1, 2021 and every four (4) years after that;
• When large quantity generators (LQGs) create a new or updated Contingency Plan, they also need to create and submit to emergency response agencies a “Quick Reference Guide” that includes a facility map showing waste locations and how to access them, locations of water supplies (hydrants), an area map showing surrounding residences, businesses and schools, and a list of the wastes described in “layman’s” terms with the associated hazards and estimated amount of each waste;
• Large quantity generator closure requirements (previously only in guidance);
• A new emphasis on characterizing waste “at the point of generation”;
• Changes the term “conditionally exempt small quantity generator” to “very small quantity generator” (VSQG);
• If a company operates a plant that is a VSQG and another plant that is a LQG, the company can consolidate the waste from the VSQG to the LQG plant prior to transportation for disposal.  Additional recordkeeping is required; and,
• Containers in satellite accumulation areas must be marked with the words “Hazardous Waste” and their contents.  The words “Hazardous Waste” were previously optional.

For more information on these important rules changes, please contact Barbara Knecht, CHMM (bknecht@hzwenv.com).