What this lesson covers
Store Materials with Hazard is 9.22% of IHMM's CHMM blueprint, and almost every question in it depends on one fact: the site's generator category. The category sets how long waste may sit on site, how much may pile up, and which plans, training and reports apply. This lesson shows how to find it from a month's waste tally, line by line, and where people go wrong.
The three categories
The category is set for each calendar month from the hazardous waste the site generated in that month. Three columns are checked, and the highest result wins.
| Category | Non-acute hazardous waste in the month | Acute hazardous waste in the month | Residue from cleaning up a spill of acute waste in the month |
|---|---|---|---|
| Very small quantity generator (VSQG) | 100 kg or less | 1 kg or less | 100 kg or less |
| Small quantity generator (SQG) | More than 100 kg and less than 1,000 kg | 1 kg or less | 100 kg or less |
| Large quantity generator (LQG) | 1,000 kg or more | More than 1 kg | More than 100 kg |
The rule also gives these in pounds, rounded: 100 kg is 220 lb, 1,000 kg is 2,200 lb, and 1 kg is 2.2 lb. If your log is in pounds, convert with the factor the question gives (this lesson uses 1 kg = 2.2046 lb).
Watch the boundary words. Exactly 100 kg of non-acute waste is still a VSQG month ("100 kg or less"). Exactly 1,000 kg is an LQG month ("1,000 kg or more"). Exactly 1 kg of acute waste does not make an LQG ("more than 1 kg").
What to leave out of the count
Some wastes are left out of the monthly count, even though they are wastes. The common ones:
| Leave out | Why |
|---|---|
| Universal waste (batteries, lamps, mercury-containing equipment, pesticides, aerosol cans) managed under the universal waste rule | Managed under its own rule |
| Used oil managed under the used oil rules | Managed under its own rule |
| Spent lead-acid batteries sent for reclamation under their own rule | Managed under their own rule |
| Waste managed immediately on generation in an on-site elementary neutralization unit, wastewater treatment unit or totally enclosed treatment facility | Never accumulated |
| Waste recycled without prior storage in an on-site process that the rule allows | Never accumulated |
| Waste already counted once: waste leaving accumulation, residues from on-site treatment or reclamation of counted waste, and counted spent materials reclaimed and reused on site | No double counting |
And some things that are counted, even though people often leave them out:
- Characteristic wastes count, not only listed ones.
- Waste you will ship for recycling after storing it counts.
- Acute wastes count, in their own column.
- Spill cleanup residue counts: in the acute residue column if the spilled material was an acute waste, and as ordinary hazardous waste otherwise.
Worked example 1: a full monthly tally
A coatings plant keeps this log for March. Every value needed is here.
| Line | Stream | Amount | Count it? |
|---|---|---|---|
| 1 | Spent xylene and toluene cleaning solvent (F005), 3 drums at 165 kg each | 3 x 165 = 495 kg | Yes, non-acute |
| 2 | Paint sludge, ignitable (D001), 2 drums at 140 kg each | 2 x 140 = 280 kg | Yes, non-acute |
| 3 | Acid rinse water piped straight from the line into the plant's elementary neutralization tank | 1,200 kg | No, managed immediately on generation |
| 4 | Spent fluorescent lamps managed as universal waste | 45 kg | No, universal waste |
| 5 | Used oil from the compressors, sent to a used oil processor | 410 kg | No, used oil |
| 6 | Spent lead-acid forklift batteries sent for reclamation | 90 kg | No, under their own rule |
| 7 | Discarded unused product that is a P-listed (acute) waste | 0.6 kg | Yes, acute column |
| 8 | Six drums shipped off site in March, filled and counted in February | 990 kg | No, already counted |
The working (4 steps)
Step 1, non-acute column. Lines 1 and 2 only: 495 + 280 = 775 kg.
Step 2, acute column. Line 7: 0.6 kg.
Step 3, acute cleanup residue column. No acute spill this month: 0 kg.
Step 4, compare. 775 kg is more than 100 kg and less than 1,000 kg, which is SQG. 0.6 kg of acute waste is not more than 1 kg. No acute residue. The highest result is SQG, so the plant is a small quantity generator for March.
Check it a second way. Total of every line: 495 + 280 + 1,200 + 45 + 410 + 90 + 0.6 + 990 = 3,510.6 kg. Excluded lines: 1,200 + 45 + 410 + 90 + 990 = 2,735 kg. Counted: 3,510.6 - 2,735 = 775.6 kg, of which 0.6 kg is acute and 775 kg non-acute. The same answer.
The wrong answers this tally invites:
| Mistake | Total | Wrong category |
|---|---|---|
| Counting the neutralization rinse | 775 + 1,200 = 1,975 kg | LQG |
| Counting the March shipment again | 775 + 990 = 1,765 kg | LQG |
| Counting used oil and lamps | 775 + 410 + 45 = 1,230 kg | LQG |
| Counting only the listed solvent | 495 kg | SQG (right answer, wrong method) |
Three of the four slips make the plant look like an LQG, with a 90-day limit and a contingency plan it does not need.
Worked example 2: the acute column decides
In April the same plant generates 640 kg of non-acute waste and discards 1.3 kg of the same P-listed product. Non-acute: 640 kg, an SQG amount. Acute: 1.3 kg, which is more than 1 kg. April is an LQG month because of the acute column alone.
Worked example 3: a log kept in pounds
In May the plant's log shows 2,050 lb of counted non-acute waste and no acute waste. Convert with 1 kg = 2.2046 lb:
2,050 / 2.2046 = 929.9 kg
929.9 kg is less than 1,000 kg, so May is an SQG month. Check: 929.9 x 2.2046 = 2,050.0 lb. Two slips to avoid: reading 2,050 as kilograms (an LQG month by mistake), and multiplying by 2.2046 instead of dividing (4,519 kg, also a false LQG).
Worked example 4: when a VSQG's stockpile matters
A small shop generates 70 kg of non-acute hazardous waste every month, so it is a VSQG each month. It has shipped nothing for a long time. A VSQG that accumulates 1,000 kg or more on site at any time must follow the SQG accumulation conditions. After 14 months it holds 14 x 70 = 980 kg; after 15 months, 15 x 70 = 1,050 kg. In the 15th month it crosses the line, even though its monthly category never changed.
What the category changes
| VSQG | SQG | LQG | |
|---|---|---|---|
| Time in central accumulation | No federal limit (but see the 1,000 kg trigger) | 180 days, or 270 days if the waste travels 200 miles or more | 90 days |
| Amount on site | Under 1,000 kg to stay on VSQG conditions | Never more than 6,000 kg | No quantity cap |
| Central area inspections | Not set by the federal VSQG rule | At least weekly | At least weekly |
| Manifest follow-up | Not covered by the exception rule | Copy with a note at 60 days | Contact at 45 days, Exception Report at 60 days |
A five-step routine for exam questions
- List every stream for the calendar month in question, not the year or the quarter.
- Strike out what is excluded (universal waste, used oil, lead-acid batteries for reclamation, immediate treatment in exempt units, waste already counted).
- Sort what remains into the three columns: non-acute, acute, acute spill residue.
- Convert units with the factor given, then compare each column with its limits, minding "or less", "or more" and "more than".
- Take the highest category any column gives.
Check yourself
Try the ten questions in the free practice set for this lesson. Each one gives every value you need.
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