Question 1

What is a Large Quantity Generator (LQG) vs Small Quantity Generator (SQG)?

Accepted Answer

LQGs generate ≥2,200 lbs/month of RCRA hazardous waste. They must remove waste within 90 days, provide RCRA training, maintain a contingency plan, and submit biennial reports. SQGs generate 220–2,200 lbs/month and have 270 days. VSQGs generate <220 lbs/month. Generator status determines your regulatory obligations.

Question 2

What are Uniform Hazardous Waste Manifests?

Accepted Answer

Manifests are the cradle-to-grave paper trail for RCRA hazardous waste. They document the generator, waste type, quantity, transporter, and receiving TSDF. Both generator and transporter must sign. Generators keep copies for 3 years. Exodus prepares and manages manifests for every shipment.

Question 3

What are Land Disposal Restrictions (LDRs)?

Accepted Answer

LDRs under 40 CFR Part 268 prohibit land disposal of untreated hazardous waste. Generators must provide LDR notifications to TSDFs documenting that waste meets treatment standards before disposal. Exodus prepares LDR notifications for every hazardous waste shipment it manages.

Question 4

Can manufacturing waste be recycled instead of disposed of?

Accepted Answer

Yes, for some waste streams. Spent solvents can be reclaimed and redistributed. Some metal-containing waste can be recycled for metal recovery. Recycling a hazardous waste under RCRA can reduce or eliminate regulatory requirements — but the recycling process must meet specific EPA conditions. Exodus can evaluate your waste streams for recycling eligibility.

Question 5

What RCRA violations are most common at manufacturing facilities?

Accepted Answer

Common RCRA violations at manufacturers include: improper container labeling, exceeding accumulation time limits, missing manifests, failure to perform weekly inspections, inadequate emergency planning, and improper waste characterization. EPA civil penalties can reach $70,117 per day per violation. Exodus's program is designed to prevent these violations.

Manufacturing Hazardous Waste Disposal Florida