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

The summary is designed to assist hazardous waste generators in achieving and maintaining 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 in 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 hazardous waste management and transportation. The regulatory requirements associated with Very Small Quantity Generators (VSQGs) that wish to consolidate their hazardous wastes under the control of the same person (see below), and the Large Quantity Generator (LQG) that receive these wastes can be found here for VSQGs and here for LQGs.

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 regulations, "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.

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

LQG Requirements

The LQG receiving facility must do the following:

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 received 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 the LQG is participating in the consolidation program and identify which VSQGs are participating. The information regarding the types and quantities of hazardous wastes it has received from participating VSQGs must be included in the LQG's Biennial Report.

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 in-transit state to see if there are additional requirements that might apply while in transit.