Small quantity generator requirements

 

Which portions of my campus or facility are covered by theses rules?

The Wisconsin Department of Natural Resources (WDNR) considers multi-building facilities on contiguous property as one generator facility for the purpose of these rules. If a portion of your campus generates hazardous waste and is not contiguous to the main campus, it may be classified as a separate generator facility and its waste counted separately to determine its generator classification. It will also need its own EPA ID number (see below). If your "facility" generates and accumulates hazardous waste in the quantity range listed below in the Generation quantity limits and On-site accumulation quantity sections, your facility will be regulated as a small quantity generator.

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Hazardous waste determination

All waste is subject to a hazardous waste determination process. You can use your knowledge about the waste you generate in conjunction with the hazardous waste rules, or you can have your waste tested by a certified laboratory.

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Who can UW System campuses call to pick up their hazardous waste?

All State of Wisconsin departments and agencies, including all UW System campuses and facilities, are covered under one contract for hazardous waste disposal. It is mandatory that all RCRA hazardous waste generated at UW System campuses and facilities be handled under this contract. Veolia Environmental Services is the current contract vendor. For more information, see our contract services page.

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Generation quantity limits

A generator is a small quantity generator in a calendar month if the generator generates greater than 100 kilograms (220 pounds) but less than 1,000 kilograms (2,205 pounds) of non-acutely hazardous waste in that month.

There are stricter limits on the generation of acute hazardous waste that apply to SQGs. To maintain SQG status, you will generate no more than 1 kg/month of acute hazardous waste, and no more than 100 kg/month of acute spill residue or soil contaminated with acute hazardous waste.

If you exceed the monthly generation limits, your facility will be subject to the stricter Large Quantity Generator classification.

Universal wastes have separate rules and limits, and are counted separately from your hazardous waste.

NR 662.190 for generation of non-acutely hazardous waste; NR 662.220 (4) for generation of acutely hazardous waste.

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On-site accumulation quantity

Never accumulate more than 6,000 kg (13,230 pounds) of hazardous waste at any one time. Also, never accumulate more than 1 kg (2.2 pounds, or one quart) of acute hazardous waste, or more than 100 kg acute spill residue.

EXTENSION: If you have unforeseen, temporary and uncontrollable circumstances that will cause you to accumulate hazardous waste in quantities exceeding 6,000 kg (13,230 pounds), YOU MUST APPLY FOR AN EXTENSION with the Wisconsin Department of Natural Resources. An extension may be granted at the discretion of the department on a case-by-case basis due to unforeseen, temporary and uncontrollable circumstances. The extension can only be for 30 days.

Warning: If you exceed the on-site accumulation limits without an approved extension, or exceed the extension, your facility may be considered an unlicensed hazardous waste storage facility. DON'T EVER LET THIS HAPPEN! This is an opportunity for the EPA and WDNR to throw the book at you, and to assess monetary fines.

Satellite accumulation areas (SAAs) have their own accumulation limits. Basically, you should not exceed 55 gallons of total hazardous waste or one quart of acutely hazardous waste at a satellite accumulation area. [If you exceed these limits at an SAA, the excess waste must be immediately dated and removed within 3 days.]

Universal wastes have separate rules and limits, and are counted separately from your hazardous waste.

NR 662.192 (l) (a), (3) and 662.194 (4)

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Acute hazardous waste

Acute hazardous waste is an important waste management concern for campuses that are SQGs, since 1 kg (appx. one quart) of generation in a calendar month will change your status to Large Quantity Generator. This change will increase costs and add requirements, including rules that you must ship those acute wastes within 90 days, have a written contingency plan and job descriptions, and must train your waste personnel annually and document training (not a complete list).

If you are conducting a large laboratory waste cleanup project (i.e., cleanup associated with building remodel), you can contact your local WDNR office to minimize the regulatory impact of this infrequent episodic generation.

See our page on acute hazardous waste for more information.

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Regulatory notification and EPA ID number

If you generate hazardous waste, you must notify the WDNR of your waste generation activity and obtain an EPA ID number.

Change in HW generator status: If you change generator classification, you must also notify the WDNR. Your EPA ID number will remain the same.

NR 662.012

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Accumulation time limits

A Small Quantity Generator may not accumulate waste for more than 180 days from its first day of accumulation at a storage area (satellite accumulation areas are excluded from this). A generator may accumulate waste up to 270 days if the treatment/storage/disposal facility that the waste will be transported to is 200 miles or more away.

Extension: If you have unforeseen, temporary and uncontrollable circumstances that will cause you to accumulate hazardous waste for more than 180 days (or for more than 270 days if the generator must transport the waste, or offer the waste for transportation, over a distance of 200 miles or more), YOU MUST APPLY FOR AN EXTENSION with the Wisconsin Department of Natural Resources. An extension may be granted at the discretion of the department on a case-by-case basis due to unforeseen, temporary and uncontrollable circumstances. The extension can be for up to 30 days.

Warning: If you exceed the on-site accumulation limits without an approved extension, or exceed the extension, your facility will be considered an unlicensed hazardous waste storage facility. DON'T EVER LET THIS HAPPEN! This is an opportunity for the EPA and WDNR to throw the book at you, and to assess monetary fines.

NR 662.192 (1) and (3)

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Storage requirements

Storage requirements for storage areas (excluding satellite accumulation areas):

  • Label your waste containers or drums with the words "HAZARDOUS WASTE," or other words that indicate that they contain hazardous waste. NR 662.192 (1)(d)2.
  • Clearly mark each container or drum with the date that you first place hazardous waste in it. This mark must be visible for inspection. SQGs must make arrangements for proper shipping within 180 days (or 270 days if more than 200 miles distant) of when the waste is first accumulated. NR 662.192 (1)(d)1.
  • Keep all waste containers and drums securely closed when you are not removing or adding waste to them. NR 665.0173 (1)
  • All containers shall be leak proof and in good overall condition. Containers holding hazardous waste may not be opened, handled or stored in a manner which may rupture the container or cause it to leak. NR 665.0171, 665.0173 (2)
  • If the container begins to leak, the contents shall be removed and placed in a leak proof container immediately. All spilled material shall be cleaned up and properly managed. NR 665.0171
  • Storage containers holding hazardous waste which is incompatible with any other waste or materials stored nearby shall be kept separated from them by means of a dike, berm, wall or other device. NR 665.0177 (3)
  • Incompatible wastes or incompatible wastes and materials may not be placed in the same container, unless the placement of the waste or material in the container does not:
    • Generate extreme heat or pressure, fire or explosion or violent reaction;
    • Produce uncontrolled toxic mists, fumes, dusts or gases in sufficient quantities to threaten human health or the environment;
    • Produce uncontrolled flammable fumes or gasses in sufficient quantities to pose a risk of fire or explosion;
    • Damage the structural integrity of the device or facility containing the waste; or
    • Through other like means threaten human health or the environment. NR 665.0177 (1)
  • Hazardous waste may not be placed in an unwashed container that previously held an incompatible waste or material unless the container has been properly cleaned so that placement of the waste or material in the container does not:
    • Generate extreme heat or pressure, fire or explosion or violent reaction;
    • Produce uncontrolled toxic mists, fumes, dusts or gases in sufficient quantities to threaten human health or the environment;
    • Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosion;
    • Damage the structural integrity of the device or facility containing the waste; or Through other like means threaten human health or the environment. NR 665.0177 (2)
  • The container shall be made or lined with materials which will not react with or be incompatible with the hazardous waste to be stored. NR 665.0172
  • Follow the accumulation limits for SAAs carefully (see section On-site accumulation quantity).

Storage requirements for satellite accumulation areas ( SAAs ):

  • All containers shall be leak proof and in good overall condition. If the container begins to leak, the contents shall be removed and placed in a leak proof container immediately. All spilled material shall be cleaned up and properly managed. NR 665.0171
  • The container shall be made or lined with materials which will not react with or be incompatible with the hazardous waste to be stored. NR 665.0172
  • Keep all waste containers and drums securely closed during storage, except when you are not removing or adding waste to them. NR 665.0173 (1)
  • Label your waste containers or drums with the words "HAZARDOUS WASTE," or other words that identify the contents. NR 662.192 (4)(a)2 .
  • Acutely hazardous waste

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Weekly inspection of storage areas and inspection logs

You need to inspect your 180-day (or 270-day) storage areas, including all containers used for storing hazardous waste, at least weekly for evidence of leakage, corrosion or deterioration. It is also recommended to inspect any spill containment structures (i.e. dikes, berms) for deterioration during those inspections..

This requirement does not apply to satellite accumulation areas ( SAA's ), though campus program managers may elect to apply it to their SAA's as a best management practice.

It is recommended though not required that you record the inspections in an inspection log. A good format for the log would include the date and time of inspection, the name of the inspector, a notation of the observations made such as the condition of the containers and the date and nature of any repairs or other remedial actions taken.

NR 665.0174, ref. by NR 662.192(1)(b)

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Annual report

You need to submit an annual DNR hazardous waste report (Wisconsin's annual reporting requirement is more stringent than the federal biennial requirement).You will be provided with summary disposal figures by the contracted hazardous waste vendor by the end of January, and will have until March 1 to submit the report. All generators should be sent information and a link for electronic filing of this information by the WDNR. For other reports that you may have to file, see our environmental reporting deadlines page.

NR 662.193 (3)

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Personnel training

Basic training is required for waste handling personnel at small quantity generation facilities. This training shall ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies.

For more information on training that may be available for personnel on your campus, check our training services page.

NR 662.192 (1)(e)3

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Written job descriptions for HW personnel

Not required

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Emergency procedures

SQGs need to follow emergency procedure requirements.

Emergency coordinator:

At least one employee responsible for coordinating all emergency response measures shall at all times be on the premises or be able to reach the facility within a short period of time. This employee shall be the emergency coordinator.

Because a campus must provide an emergency coordinator at all times, arrangements should be made in advance for times when the primary coordinator is unavailable or unable to reach the premises within a short period of time.

Posting of emergency contact information:

The following information needs to be posted next to any telephone with an outside line that may be used when responding to an emergency:

  • The name and telephone number of the emergency coordinator or the procedures for contacting that person;
  • The location of the nearest fire extinguisher, spill control material and fire alarm; and
  • The telephone number of the fire department (unless the facility has a direct alarm).

Actions required in event of a hazardous waste emergency:

In the event of a discharge or spill of hazardous waste, a fire or explosion or an imminent threat that has the potential for damaging human health or the environment, the facility's emergency coordinator or designee shall:

  • Activate internal alarms or communication systems to notify all personnel of the imminent or actual emergency situation;
  • In the event of a fire, call the fire department and if appropriate attempt to extinguish the fire;
  • In the event of a discharge or spill, contain the flow of hazardous waste to the extent possible;
  • If the spill is an oil and your campus is covered under a Spill Prevention and Countermeasures Control (SPCC) plan, follow the emergency procedures contained in your plan;
  • Telephone the Division of Emergency Government at 1–800–943–0003 and comply with the requirements of s. 292.11, Stats., ch. NR 158 and the emergency planning and community right–to–know act of 1986, 42 USC 11001 et seq., and if the discharge of hazardous waste is from an underground storage tank system, the reporting requirements of ch. NR 705 apply. [In addition, you may be required to notify the National Response Center of certain releases.];
  • Take all reasonable measures necessary to ensure that fires, explosions and discharges do not occur, reoccur or spread to other parts of the facility. Where applicable, these measures include stopping processes and operations, collection and containing discharged wastes and removing or isolating containers;
  • As soon as practical arrange for and complete cleanup of the hazardous waste and any contaminated materials or soils.

National Response Center notification:

In the event of a fire, explosion or other release which could threaten human health outside the facility or when the generator has knowledge that a spill has reached surface water, the generator shall immediately notify the national response center and submit a report which includes the following information:

  • The name, address and EPA identification number of the generator;
  • The date, time and type of incident;
  • The quantity and type of hazardous waste involved in the incident;
  • The extent of injuries, if any; and
  • The estimated quantity and disposition of recovered materials, if any.

NR 662.192 (1)(e)

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Written contingency plan

Not required

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Manifest

Off-site transport of hazardous waste requires use of the manifest, as follows:

Manifest form: You are required to prepare a federal hazardous waste manifest in accordance with the instructions in the appendix to 40 CFR 262. In practice, our contracted hazardous waste vendor has a good field system for preparing the manifest, and has demonstrated the ability to assist you in this preparation.

Designation of handling facility: The contracted waste vendor will prepare the manifests in accordance with the destination facility. Generally, a campus will manifest to one or more of the following facilities – Veolia Menomonee Falls, WI; Veolia TWI, Sauget, IL ; and Veolia Port Arthur, TX.

On-site transport: Use of manifest and DOT container marking are not required for on-site transportation. Vehicle placarding in accordance with DOT rules is required. In the event of discharge of hazardous waste on a public or private right-of-way, you must follow the transporter requirements at NR 663.30 and 663.31.

For more details about the manifest, see our manifests page.

(Technically, if a tolling arrangement is contracted that meets the conditional manifest exemption criteria set in NR 662.191, the manifest is not required.)

NR 662.020 to 662.027

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Waste minimization

On each manifest, you will sign the following statement: “I am a small quantity generator. I have made a good faith effort to minimize my waste generation and select the best waste management method that is available to me and that I can afford.”

A generator should be able to demonstrate they are making a good faith effort to minimize their waste generation. This demonstration of good faith effort is flexible. Program results, meeting notes, copies of emails or program publicity material could suffice. Efforts at pollution prevention, source reduction, recycling and reclamation can all fall under the umbrella of the requirement for waste minimization. Some possibilities for minimization efforts include:

  • adoption of microscale techniques by laboratories
  • substitution of less hazardous and/or more recyclable materials in any application
  • laboratory solvent distillation
  • chemical inventory management
  • replacement of mercury thermometers with alcohol thermometers for certain applications
  • changing management of parts cleaner operations

The treatment or disposal method chosen by the generator should be the best available and that can be afforded. Fortunately, UW System campuses do not need to figure out what these methods are, because the terms and monitoring of the hazardous waste contract accomplish this goal. Wastes are treated under a management hierarchy, and treatment sites must be approved and are audited regularly.

NR 662.027

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Recordkeeping

You are required to keep copies of waste determinations, disposal restriction (LDR) forms, and annual reports for three years. UW System Administration asks campuses to keep manifest copies in perpetuity, due to disposal liability concerns (requirement is three years).

NR 662.193 (1) and 668.07 (l) (h)

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Transport requirements

For off-site shipments of hazardous waste, you are responsible for meeting manifest requirements and DOT packaging, labeling and placarding requirements. In practice, our contracted hazardous waste vendor has done a good job of determining and meeting these requirements in preparation for shipment.

NR 662.020 through 662.027 and 662.030, 662.031, and 662.033

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Other resources for information

Other sources that provide an overview of requirements and other issues confronting a campus that is a small quantity generator of hazardous waste include the following:

Small Quantity Generator Basic Requirements (WDNR) 

Small Quantity Generator Inspection

The Basics: A Guide to Wisconsin Environmental Regulation (UW Extension) 

The Best Management Practices Catalog: Waste Management Case Studies (EPA)