This summary is designed to assist VSQGs in achieving and maintaining compliance with the Virginia Hazardous Waste Management Regulations (VHWMR). VSQGs are those generators that generate less than 100 kg (220 lbs) of hazardous waste and less than 1 kg (2.2 lb or 1 quart) of acute hazardous waste in a calendar month. Also, VSQGs may never accumulate more than 1,000 kilograms (2,200 lbs) of hazardous waste (approximately five (5), 55-gallon drums) or 1 kg of acute hazardous waste (2.2 lbs, or 1 quart) at any time. Exceeding this threshold will result in the VSQG having to comply with LQG requirements for those wastes.

Identify: VSQGs must determine if they have generated a solid and hazardous waste in accordance with the definition of solid waste, definition of hazardous waste and determination requirements. Generators may use knowledge of their waste as described in these regulations to make solid and hazardous waste determinations, or have their waste tested if uncertain.

Count:  The regulations describe the process for how a generator must count regulated acute and non-acute hazardous wastes towards its generator category for a calendar month, while this section describes the implications of a VSQG mixing a solid waste with a hazardous waste resulting in a newly generated hazardous waste.

VSQGs are recommended to manage hazardous waste in containers or tanks that are in good condition to prevent spills and releases to the environment that endangers human health. The accumulation tanks or containers are not specifically required to be marked with the words "Hazardous Waste" or dated; however, identifying the contents of the container and also identifying the risks posed by the hazardous wastes in a container or tank using a DOT or OSHA label is strongly recommended as a good management practice.

 On-Site Management: Hazardous waste may not be dumped on the ground, abandoned, burned, evaporated, or buried on-site. Approved disposal/treatment units would include an on-site Subtitle D permitted landfill only if the permit allows acceptance of VSQG hazardous waste, or a permitted wastewater pre-treatment system subject to Clean Water Act regulation (Virginia Pollutant Discharge Elimination System (VPDES) permit or Publicly Owned Treatment Works. In addition, VSQGs may treat hazardous waste on-site in other permit exempt units such as elementary neutralization units or totally enclosed treatment units. All other on-site treatment by VSQGs must be permitted under a hazardous waste permit.

Transportation and Delivery

VSQGs should be aware that the Virginia Solid Waste Management Regulations do not allow the routine disposal of regulated hazardous waste, including liquid hazardous wastes, in a sanitary landfill, and is only allowed if specific approval is obtained from DEQ or the allowance is included in the solid waste management facility's permit). Other types of chemical wastes that are not regulated as hazardous waste may also require written permission for disposal as a special solid waste.

VSQGs may either treat or dispose of hazardous waste in an on-site facility, or deliver their waste to an approved facility which is:

• Permitted or interim status hazardous waste management facility;
• Permitted, registered, or licensed municipal or industrial solid waste facility that is authorized to accept hazardous waste (of which there currently are none in Virginia); or
• Facility which beneficially uses or reuses, or legitimately recycles or reclaims the waste; or
• Facility which treats the waste prior to beneficial use or reuse, or legitimate recycling or reclamation; or
• Universal wastes, a universal waste handler or a destination facility; or
• Large Quantity Generator under the control of the same person as the very small quantity generator. See specific requirements.

VSQGs experiencing an episodic event may generate and accumulate hazardous waste under streamlined requirements in accordance with the episodic generation requirements. Visit DEQ's website for more information regarding Episodic Waste Generation. VSQGs may now be able to consolidate their hazardous waste at a large quantity generator under the control of the same person.

Accumulation: The 90-day waste accumulation clock starts for VSQG consolidated waste when the VSQG waste arrives at the LQG facility.

Accumulation Limits for LQG from VSQGs: There is no accumulation limit for how much waste can be consolidated at an LQG from VSQGs, but the waste must be sent off-site to a RCRA TSDF or recycler within 90 days, and the LQG must be able to maintain adequate aisle at all times.

Quantity Limits: There are no quantity limitations for shipments from the VSQG, but the VSQG must stay within its own accumulation and generation limits.

Locations of VSQG and LQG: The VSQG and the LQG can be in different states if both states have adopted the consolidation provision. If the hazardous waste is transported through states that have not adopted the consolidation provision, the generator should check with the in-transit state to see if there are additional requirements that might apply while in transit.

This table was designed to offer generators an overview of the VSQG regulations, and does not include all applicable citations.