A waste generator classification is based upon the amount of hazardous waste generated and the potential volume of hazardous waste accumulated in the waste generator's waste. An unconventional ranking scheme is now applied for VSQGs regardless of their historical waste generator category.
Gasoline generation is no longer a decoupling factor and will be subject to regulation. A new regulator / compliance for generators is expected to be established shortly with the Exigent need for decoupling no longer recognized.
Volatile hazardous waste generators such as generators of household trash and wastewater, are now fully subject to regulation under hazardous waste NESHAP. These waste generators have been managing hazardous waste in the past under NESHAP but now they must manage it under hazardous waste NESHAP and will eventually have to manage their volatile waste under hazardous NESHAP as well.
Generators have a new deadline for compliance with Subtitle C hazardous waste NESHAP for the Subtitle C requirements of generators to be 1.5 from the date of promulgation of that rule, so the deadline to clean up volatile waste from waste generators and transport it from the waste generators to the generators NESHAP compliant point of custodian is now March 31, 2020.
A simple calculation of the number of operational hazardous waste generators in the US (approximately 300,000) shows that compliance with the Subtitle C NESHAP compliance deadline of March 31, 2020 is virtually impossible for most hazardous waste generators, except for the large quantity chemical manufacturing and manufacturing chemical distributors. Most of these generators are going to need some form of interim solutions until the Subtitle C NESHAP requirements are implemented, and there is no such interim. The interim requirements are all contained in the hazardous waste NESHAP. d2c66b5586