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printreg, January, 2003
Small Qty Generator-Manage Used Oil


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From: Debra Jacobson(djacobson@istc.illinois.edu)
Date: Wed, 15 Jan 2003 08:42:25


Here's a quick synopsis the EPA regulation on how Conditionally Exempt Small Quantity Generators manage used oil mixed with hazardous waste. For more information about hazardous waste handling see the Land/Waste section found in the compliance information section of the PNEAC web site at http://pneac.org/compliance/compinfonational.cfm

For fact sheets, see the All Printing Technologies section of the fact sheet resources and scroll down to hazardous waste fact sheets at http://www.pneac.org/sheets/all/index.cfm

Not sure what your waste classification is? According to 40 CFR Parts 260 - 279:

Large Quantity Generators (LQGs). generate greater than or equal to 200 gallons of hazardous waste per month (equivalent to 1,000 kg or approximately 2,200 lb), or greater than 0.02 gallons (approximately 1 kg or 2.2 lb) of acutely hazardous waste per month.

* Small Quantity Generators (SQGs). SQGs generate more than 25 gallons (equivalent to 100 kg or approximately 220 lb), but less than 200 gallons (1,000 kg or 2,200 lb) of hazardous waste per month.

* Conditionally Exempt Small Quantity Generators (CESQGs). CESQGs generate less than 25 gallons of hazardous waste per month (or equal to 100 kg or 200 lb), and less than or equal to 0.02 gallons (1 kg or 2.2 lb) of acutely hazardous waste per month.
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How does a CESQG manage used oil that has been mixed with hazardous waste at their facility?

According to 40 CFR 261.5(j), if a conditionally exempt small quantity generator's wastes are mixed with used oil, the mixture is subject to the used oil regulations of 40 CFR 279 if it is destined to be burned for energy recovery. Any material produced from such a mixture by processing, blending, or other treatment is also regulated as used oil if it is destined to be burned for energy recovery.

If the used oil/hazardous waste mixture is not going to be burned for energy recovery, the mixture must be managed as a hazardous waste and be counted toward that generator's monthly generator status.

Source: "reg of the day" listserv operated by Tammy Silverthorne @ the Environmental Resource Center



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