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VSQG Hazardous Waste Consolidation

Very Small Quantity Generators (VSQGs) can send their hazardous waste to Large Quantity Generators (LQGs) under control of the same person if the generators meet certain requirements.

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What is this rule?

Very Small Quantity Generators (VSQGs) who follow the rules in 30 Texas Administrative Code 335.53(f) /40 Code of Federal Regulations 262.17(f) can send their hazardous waste to a Large Quantity Generators (LQG). This option may reduce waste management and disposal costs.

The rules allowing VSQGs to send waste to LQGs only apply to hazardous waste. Find regulations about Class 1 Industrial waste consolidation in 30 TAC 335.10(e) .

Who can consolidate?

Both the LQG and the VSQG must be under control of the same person.

  • “Control” means the power to direct the policies of the generator, whether by the ownership of stock, voting rights, or otherwise. Contractors who operate generator facilities on behalf of a different person do not “control” such generators.
  • A “person” means 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.

This rule is only available to LQGs and VSQGs. Use RG-222 to determine your generator category.

What are the requirements?

Very Small Quantity Generators

VSQGs can send their waste to LQGs under control of the same person if the VSQG meets the following requirements:

  • Get an EPA ID if the site does not already have one. Once you have an EPA ID, inform TCEQ of any changes to the site name or address within 30 days of the change. If the facility:
  • Label containers of hazardous waste with the words “Hazardous Waste.”
  • Label containers with the hazards associated with the contents of the container. Examples of hazards include ignitable, corrosive, explosion hazard, or toxic.

Large Quantity Generators

LQGs can accept unlimited amounts waste from VSQGs under the control of the same person. To accept waste from VSQGs, LQGs need to meet the following requirements:

  • Submit Parts G and I of Notification for Hazardous or Industrial Waste Management Form (TCEQ 00002)  ( Instructions) at least 30 days before accepting any VSQG waste.
  • Label the hazardous waste container with the date you receive the VSQG waste. This is the accumulation start date. The LQG must send the VSQG hazardous waste to a permitted treatment, storage, and/or disposal facility (TSDF) within 90 days of the accumulation start date.
  • Add a unique waste code for VSQG consolidated waste with Source Code G51 to their SWR.
  • Use the assigned waste code when manifesting the shipment to the TSDF.
  • Maintain records of the shipments for three years [40 CFR 262.17(f)(2)]. These records must:
    • Identify the name, site address, and contact information for the VSQG.
    • Include a description of the hazardous waste received.
    • List the quantity and the date the LQG received the waste.
  • Report the consolidated waste on the LQG's annual waste summary.

How can VSQGs transport the waste?

The VSQG does not have to use a registered hazardous waste transporter or a Uniform Hazardous Waste Manifest to ship their hazardous waste to a LQG under control of the same person. VSQGs still need to comply with U.S. Department of Transportation rules on packaging, marking, labeling, placarding, and shipping.

Can these generators ship their waste across state lines?

Very Small Quantity Generators

Before shipping waste to an out-of-state LQG, VSQGs must ensure that the LQG's state has adopted the VSQG to LQG consolidation rule. If the other state has not adopted the rule, then the LQG must have a permit to accept VSQG waste.

Large Quantity Generators

Before accepting VSQG waste from another state, the LQG must ensure that the VSQG's state has adopted the VSQG to LQG consolidation rule. The LQG should also determine if the other state adopted the manifesting exemption for VSQG waste.

What if a VSQG can’t meet the requirements?

VSQGs who can't meet the consolidation rules can send their hazardous waste to a TSDF.

VSQGs can also send less than 220 pounds per month of hazardous waste to a municipal solid waste landfill as “special waste.”

Where can I find more information and assistance?