ECAR Fact Sheet
for Vermont
Hazardous Wastes
The
intent of the hazardous waste program is to provide a cradle-to-grave
management system for hazardous wastes to ensure that these wastes
are not mismanaged in a way that will impact human health or the
environment.
The
Vermont Department of Environmental Conservation, Division of Waste
Management (VT DEC) is authorized to implement the federal hazardous
waste regulations. The VT DEC has modified the federal requirements,
which makes the state's rules more stringent than the federal rules.
Vermont regulates all generators when it comes to the storage, labeling
and transport of hazardous waste.
The
VT DEC has prepared guidance documents to help auto recyclers manage
hazardous waste. Much of the information is included in the fact
sheet below or you can access the documents under "Other Relevant
Resources."
To
comply with Vermont's hazardous waste requirements, you must follow
the steps below:
- Determine
whether any hazardous waste is generated.
- Determine
your facility's generator status.
- Determine
which regulations must be complied with depending upon your facility's
generator status, and comply with those requirements.
Regulations
All
hazardous waste handlers, including anyone who generates hazardous
wastes, transports hazardous waste, or operates a treatment/storage/disposal
facility for hazardous waste, must notify the VT DEC and receive
an EPA ID Number for their site by completing the Vermont
Hazardous Waste Handler Site ID Form. Other activities for which
completion of this form is required include the management of used
oil, and management of 5000 kg (11,000 lbs) or more of combined
universal waste on-site at any one time, and recycling of hazardous
waste.
Definition
of Hazardous Waste. Vermont defines hazardous waste as any
waste or combination of wastes of a solid, liquid, contained gaseous,
or semi-solid form. This includes but is not limited to those which
are toxic, corrosive, ignitable, reactive, strong sensitizers, or
which generate pressure through decomposition, heat or other means,
which in the judgment of the Secretary may cause, or contribute
to, an increase in mortality or an increase in serious irreversible
or incapacitating reversible illness, taking into account the toxicity
of such waste, its persistence and degradability in nature, and
its potential for assimilation, or concentration in tissue, and
other factors that may otherwise cause or contribute to adverse
acute or chronic effects on the health of persons or other living
organisms, or any matter which may have an unusually destructive
effect on water quality if discharged to ground or surface waters
of the state.
Hazardous
Waste Determination. It is the responsibility of all hazardous
waste generators to determine whether their waste is hazardous.
The procedure for this is called a "hazardous waste determination."
To make a hazardous waste determination, identify all wastes. For
each waste ask: Can it be reused without treatment? Is it exempt
from regulation? Does it exhibit a hazardous waste characteristic?
Is it on one of the lists (F, K, P, U, VT)? Is it a mixture containing
hazardous waste? Follow the steps below to made a hazardous waste
determination:
- Is
the waste excluded from or determined to be a hazardous waste
under state regulation? Determine if the waste is excluded
from or is a hazardous waste in accordance with the state's hazardous
waste regulations.
- Determine
if the waste exhibits a hazardous waste characteristic as a listed
or characteristic waste through testing or analyzing the waste
or applying knowledge of the hazard characteristic of the waste
in light of the materials or the processes used. *Waste that is
listed as Vermont regulated hazardous waste must be evaluated
to determine whether or not it exhibits a hazardous waste characteristic.
- Determine
if the waste is a mixture of listed wastes and other wastes.
A mixture containing a non-hazardous solid waste and any amount
of a listed hazardous waste is considered a hazardous waste. For
example, if a pint of spent solvent such a toluene or benzene
(an F005 listed hazardous waste) is mixed with a 55-gallon drum
of waste antifreeze, the entire mixture (e.g., 55 gallons plus
one pint) is considered a hazardous waste (as opposed to only
one pint being a hazardous waste had the two wastes not been mixed).
Hence, it is very important to keep wastes segregated. Not only
is it better for the environment, but it will reduce disposal
costs (it's more expensive to dispose of hazardous waste than
it is solid waste).
- Determine
if the waste is a universal waste. Universal wastes
have fewer waste management rules that apply to them. For more
information about the generation, storage, transportation, disposal
and recycling of universal wastes, refer to the state's universal
waste requirements.
Generator
Status. If you manage hazardous waste, you must determine
your generator status. Generator status can be determined by either
the amount of hazardous waste generated in each calendar month;
or for any hazardous waste not defined as hazardous in the federal
hazardous waste regulations (i.e., waste regulated as hazardous
by Vermont), the average amount generated over the six-month period
elapsed just prior to making the determination. Your facility will
fall under one of these three classifications.
- Conditionally
Exempt Generator (CEG). You are considered a CEG if you generate
in a calendar month less than 220 pounds (100 kilograms) of hazardous
waste; and 2.2 pounds (1 kilogram) of acutely hazardous waste;
and 220 pounds (100 kilograms) of any residue or contaminated
soil, waste, or other debris resulting from the cleanup of a discharge
of any acutely hazardous waste. You are considered a CEG if at
any one time, you accumulate less than 2,200 pounds (1000 kilograms)
of hazardous waste, 2.2 pounds (one kilogram) of acutely hazardous
waste, or 220 pounds (100 kilograms) of any residue or contaminated
soil, waste, or other debris resulting from the cleanup of a discharge
of any acutely hazardous waste.
- Small
Quantity Generator (SQG). You are considered a SQG if you
generate in a calendar month greater than or equal to 220 pounds
(100 kilograms) but less than 2,200 pounds (1,000 kilograms) of
hazardous waste, less than 2.2 pounds (1 kilogram) of acutely
hazardous waste, or less than 220 pounds (100 kilograms) of any
residue or contaminated soil, waste, or other debris resulting
from the cleanup of a discharge of any acutely hazardous waste,
and the quantity of hazardous waste accumulated on-site never
exceeds 13,200 pounds (6,000 kilograms).
- Large
Quantity Generator (LQG). You are considered a LQG if you
generate in a calendar month 2,200 pounds (1,000 kilograms) or
more of hazardous waste; or 2.2 pounds (1 kilogram) or more of
acutely hazardous waste; or 220 pounds (100 kilograms) or more
of any residue or contaminated soil, waste, or other debris resulting
from the cleanup of a discharge of any acutely hazardous waste.
You are considered a LQG if the quantity of hazardous waste accumulated
on-site exceeds 13,200 pounds (6,000 kilograms) at any one time;
or at any one time the quantity of acutely hazardous waste accumulated
on-site equals or exceeds 2.2 pounds (1 kilograms); or the quantity
of any residue or contaminated soil, waste, or other debris resulting
from the cleanup of a discharge of any acutely hazardous waste,
accumulated onsite equals or exceeds 220 pounds (100 kilograms).
Complying
with Hazardous Waste Rules. Once you have determined whether
you generate hazardous waste and your generator status, you can
determine which requirements apply to you. See Vermont's
Hazardous Waste Management Regulations as they Apply to Small Businesses guide
for more details
Links
to the Regulations. Use the following links to view the regulations
pertaining to hazardous waste management.
Vermont's Hazardous
Waste Management Requirements
Federal
EPA Standards Applicable to Generators of Hazardous Waste
Contacts
- For
more information, contact the Vermont Department of Environmental
Conservation, Waste Management Division
at 802-241-3888.
- To
report a spill or leak, call the Vermont Division of Waste Management
at 802-241-3888 (weekdays), the 24-hour spill reporting hotline
at 800-641-5005, or the National Response Center at 800-424-8802.
- To
report an environmental incident or complaint, call 802-241-3820,
or contact the nearest
regional enforcement officer.
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