Very small quantity generator requirements

The Office of Risk Management at UW System Administration has prepared an overview of the regulations and UW System considerations for VSQG's. Click on any item in the menu at right to read more.

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 very 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.

NR 662.011

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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 managed 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 very small quantity generator in a calendar month if the generator generates less 100 kilograms (220 pounds) or less of non-acutely hazardous waste in that month.

There are stricter limits on the generation of acute hazardous waste that apply to VSQGs. To maintain VSQG 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.

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

NR 662.220 (6) 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 1,000 kilograms (2,205 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 1,000 kilograms (2,205 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 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 662.220(6)(b) for generation of non-acutely hazardous waste; NR 662.220 (4) for generation of acutely hazardous waste.

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Acute hazardous waste

Acute hazardous waste is an important waste management concern for campuses that are VSQGs, since 1 kg (about 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 laboratory waste cleanup project (e.g., cleanup associated with building remodel), you can contact your local WDNR office to minimize the regulatory impact of this infrequent episodic generation.

See  acute hazardous waste for more information.

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Regulatory notification and EPA ID number

If you generate hazardous waste and use a hazardous waste manifest, you must notify the WDNR of your waste generation activity and obtain an EPA ID number.    NR 662.220(5)(f), NR 662.220(6)(f), NR 660.07

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 662.220

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Accumulation time limits

A Very Small Quantity Generator is not subject to an accumulation time limit, only the monthly generation (100 kilograms/220 pounds) and on-site accumulation (1000 kilograms/2205 pounds). It is recommended that UW System VSQGs dispose all accumulated waste at least once per year.

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Storage requirements

Container storage requirements:

  • Label your waste containers or drums with the words "HAZARDOUS WASTE". NR 662.220 (6) (c) (2).
  • 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
  • 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

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Personnel training

There are no specific training requirements for very small quantity generators. As a best practice, it is recommended that all UW System employees who handle waste receive training commensurate with their activities. At a minimum, training should ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies.

Staff who sign Uniform Hazardous Waste Manifests and other hazardous materials shipping documents are required to be hazmat employees in accordance with 49 CFR subpart H. See hazardous materials transportation. Training may be required under other standards as well (e.g., OSHA's Hazard Communication standard).

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

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Posting of emergency contact information:

It is recommended that the information below 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.

Manifest

A very small quantity generator is not required to use a manifest.

A very small quantity generator who chooses to use a manifest shall comply with all of the following:
1. The notification requirements of s. NR 660.07.
2. The manifest requirements of ss. NR 662.020 to 662.023.
3. The exception reporting requirement in s. NR 662.193 (2).
4. The manifest recordkeeping requirement in s. NR 662.040(1).

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. Packaging, labeling and marking requirements are recommended as a best practice. 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 the OSLP manifest page.

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Waste minimization

Though not a requirement for very small quantity generators, 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:

Hazardous Waste Generator Standards

Very Small Quantity Generator Inspection

Very Small Quantity Generator Inspection - Acute

Hazardous Waste: Your Business Responsibilities

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

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

Environmental Virtual Campus (C2E2)


Disclaimer

This publication was prepared for environmental, health and safety staff at University of Wisconsin System campuses, to assist in finding resources and information for regulatory compliance. It is not intended to render legal advice.
(Read full legal disclaimer.)