Hazardous Waste Generation
From the EPA's Hazardous Waste website, "a hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. Hazardous waste is generated from many sources, ranging from industrial manufacturing process wastes to batteries and may come in many forms, including liquids, solids gases, and sludges." Hazardous waste status can be determined by using the Toxicity Characteristic Leaching Procedure (TCLP). A TCLP involves a chemical analysis process used to determine whether there are hazardous elements in a waste.
Hazardous waste generators are individuals or businesses that produce hazardous waste in amounts beyond established thresholds. Kentucky defines three categories of hazardous waste generators: Very Small Quantity Generators (VSQGs), Small Quantity Generators (SQGs), and Large Quantity Generators (LQGs). Categories are based on the quantity of hazardous waste generated in one calendar month.
Depending on the amount of hazardous waste and/or the type of activity, a registration or permit may be required.
VSQG
| ≤ 220 lbs
| ≤ 2.2 lbs
|
SQG
| > 220 ≤ 2,200 lbs
| ≤ 2.2 lbs
|
LQG
| ≥ 2,200 lbs
| > 2.2 lbs
|
VSQGs generate less than 220 pounds of HW and less than 2.2 pounds of acute HW in one month. SQGs generate between 220 and 2,200 pounds of HW and less than 2.2 pounds of acute HW per month. LQGs generate more than 2,200 pounds of HW or more than 2.2 pounds of acute HW per month.
VSQGs are not required to register unless site-specific operations necessitate obtaining an EPA ID number. Generator status affects how HW is managed in terms of storage, storage times, recordkeeping, reporting, transportation, processing, and/or final disposal. SQGs and LQGs must notify and register with DWM using the "Hazardous Waste Form" 8700 RCRA Form (eForm ID 108), an intuitive eForm that encompasses the EPA 8700 Form and the associated Kentucky addendum forms. This eForm will be used for both generator registrations and annual reports.
More information on generator registration, annual report, and assessment programs can be found on the DWM's "Hazardous Waste Generation in Kentucky" webpage and in the "ECAP RECAP: Hazardous Waste Generator Forms" video.
The DWM's "Registration Fee Schedule" provides information on the fees associated with various HW generator activities.
On-site Treatment of Hazardous Waste
Hazardous waste may be treated onsite by the generator under certain conditions and with approval by DWM's Hazardous Waste Branch. An initial proposal for onsite treatment activities by a generator must be accompanied by a clear explanation of the process, a description of all wastes to be handled by the process, the capacity of the process, the type of unit in which the process will be conducted, documentation that the process will adequately protect public health and the environment, and other pertinent information. A list of requirements for on-site treatment can be found in the Hazardous Waste Branch's "Treatment On-Site Determination Request" document.
Hazardous Waste Treatment, Storage, and Disposal Facilities
A Hazardous Waste Treatment, Storage and Disposal (TSD) Facility Permit is required before constructing and operating a facility that treats, stores, or disposes of hazardous waste onsite. Some industries obtain TSD permits to store containers or tanks for extended periods. Information on the fees to construct and operate TSD facilities can be found in the Hazardous Waste Branch's "Permit Fee Schedule" document.
More information on HW in Kentucky can be found on the DWM's Hazardous Waste Branch's webpage.