Very Small Quantity Generator (VSQG) Consolidation by Large Quantity Generator (LQG)

The summary is designed to assist hazardous waste generators in developing and assessing their processes and procedures to maintain compliance with the Virginia Hazardous Waste Management Regulations (VHWMR). The information in this section applies to hazardous waste generators, organizations with multiple facilities, such as the retail sector, academic and industrial laboratories, and military installations. These type of facilities may have the ability to consolidate hazardous wastes generated from their own VSQG sites at a LQG site under the control of the same organization (or person) for more efficient shipping and hazardous waste management. The regulatory requirements associated with Very Small Quantity Generators (VSQGs) and Large Quantity Generator (LQG) that wish to consolidate their hazardous wastes under the control of the same person as defined at 40 CFR § 260.10, can be found at 40 CFR § 262.14 (a)(5)(viii) (VSQG) and 40 CFR § 262.17 (f) (LQG). 

Definitions

Person: A "person" for the purposes of this regulation is an individual, trust, firm, joint stock company, Federal Agency, corporation (including a government corporation), partnership, association, State, municipality, commission, political subdivision of a State, or any interstate body.

Control: For the purposes of this section of the regulation, "control" means the power to direct policies at the facility.

VSQG Requirements

Labeling: VSQGs wishing to take advantage of this provision must mark and label their hazardous waste containers with the words "Hazardous Waste" and the hazards of the contents associated with that waste. VSQGs will have the option of how they indicate the hazards. Options include, but are not limited to, the applicable hazardous waste characteristic(s) (i.e., ignitable, corrosive, reactive, toxic); hazard communication consistent with the Department of Transportation requirements at 49 CFR part 172 Subpart E (labeling) or Subpart F (placarding); a hazard statement or pictogram consistent with the Occupational Safety and Health Administration Hazard Communication Standard at 29 CFR §1910.1200; or a chemical hazard label consistent with the National Fire Protection Association code 704.

Recordkeeping: No hazardous waste manifest is required and hazardous waste transporters do not have to be used by the VSQG to ship its waste to the receiving LQG.

LQG Requirements

Labeling: Label the container or unit with the date accumulation starts (i.e., the date the hazardous waste was received from the VSQG). If the LQG is consolidating incoming hazardous waste from a VSQG with either its own hazardous waste or with hazardous waste from other VSQGs, the LQG must label each container or unit with the earliest date any hazardous waste in the container was accumulated on site at the LQG location.

Recordkeeping: Manage consolidated waste as LQG hazardous waste including ensuring final treatment or disposal is at a RCRA designated facility (TSDF or recycler), and maintain records for each shipment for three (3) years these records must include the name, site address, and contact information for the VSQG, as well as a description of the hazardous waste received including the quantity and the date the waste was received.

Reporting: Notify DEQ using the Site ID Form (8700-12) that it is participating in this activity and identify which VSQGs are participating, and report in the LQG's Biennial Report the types and quantities of hazardous wastes it has received from participating VSQGs.

Note: There will be a different source code for the VSQG consolidated waste to distinguish from the LQGs own generated waste.

Additional Information about the Consolidation Provision

Accumulation: The 90-day waste accumulation clock starts for VSQG consolidated waste when the VSQG waste arrives at the LQG facility.

Accumulation Limits for LQG form VSQGs: There is no accumulation limit for how much waste can be consolidated at an LQG from VSQGs, but the waste must be sent off-site to a RCRA TSDF or recycler within 90 days, and the LQG must be able to maintain adequate aisle at all times.

Quantity Limits: There are no quantity limitations for shipments from the VSQG, but the VSQG must stay within its own accumulation and generation limits.

Locations of VSQGs and LQG: The VSQG and the LQG can be in different states if both states have adopted the consolidation provision. If the hazardous waste is transported through states that have not adopted the consolidation provision, the generator should check with the transit state to see if there are additional requirements that might apply while in transit.

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Virginia Department of
Environmental Quality
P.O. Box 1105
Richmond, VA 23218
(804) 698-4000


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