Frequent Questions

Is a LQG who decharacterizes 1,500 kilograms of hazardous waste in a tank before discharging it via a Clean Water Act (CWA) permit subject to accumulation requirements in addition to unit standards?

The LQG would be subject to all applicable accumulation requirements. LQGs that generate hazardous waste on site and subsequently treat or dispose of that same hazardous waste on site are required to follow the generator accumulation requirements in Section 262.34. According to Section 262.10, Note 1, the provisions in Section 262.34 apply to owners and operators who are "shipping hazardous waste generated at their facility." The language in Section 262.10, Note 1, was not intended to exclude waste that is treated or disposed of on site; therefore, all applicable Section 262.34 accumulation requirements apply to these wastes as well.

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