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Hazardous waste generation

Permit Primer

 

1. Do you generate any hazardous waste/wastes at your facility?

Now review your waste inventory sheets to determine if you have any hazardous waste. If you do, select the Continue button to continue through hazardous waste. Otherwise, go directly to Waterway and wetland permits.

 

2. Do you generate acute waste?

Review all of your wastes to determine if they are an "acute hazardous wastes" (see definition below) (refer to section NR 661 Subchapter D — Lists of Hazardous Wastes. If they are acute, then check the Hazardous Waste box on your waste inventory sheets.

Acute hazardous waste

An acute hazardous waste is any hazardous waste with a Waste Code beginning with the letter "P," or any of the following "F" codes; F020, F021, F022, F023, F026, and F027 (section NR 661 Subchapter D, Wis. Adm. Code). These wastes are subject to stringent quantity standards for accumulation and generation.

There are certain requirements when a facility generates acute wastes. This is because small quantities of these wastes can be harmful.

Once you've determined whether or not you generate an acute hazardous waste and how much acute hazardous waste you generate, please select the appropriate button below. (If you don't generate acute hazardous wastes, click on the "Less than or equal to 2.2 lbs. per month" button below)

   

If you do not generate hazardous waste or generate less than or equal to 2.2 lbs per month, go to 3. How much hazardous waste do you generate?

If your generate greater than 2.2 lbs of hazardous waste per month, go to 6. You are a large quantity generator (LQG).

 

3. How much hazardous waste do you generate?

Review your inventory sheets to help you calculate your monthly hazardous waste generation rate. The reason you need to determine how much hazardous waste you generate is so you can find out which management requirements apply to you. If you are unsure how to determine your monthly hazardous waste quantity, please select "Help" below for step–by–step guidance. Once you've determined how much hazardous waste you generate monthly, please select the appropriate button below.

Help

Tip: Having good recordkeeping helps when determining how much waste you generate over time.

1) For every calendar month, total all characteristic and listed wastes that you:

  • accumulate on–site prior to management;
  • package and transport off–site;
  • place directly in a regulated on–site treatment or disposal unit;
  • generate as still bottoms or sludges and remove from product storage tanks (excluding on–site recycling still bottoms); and
  • generate as still bottoms from on–site recycling units. Don't forget the "mixture" and "empty container" (see definitions below) rules.
The Mixture Rule

The Mixture Rule: If you mix 1000 gallons of a listed hazardous waste with 1000 gallons of nonhazardous waste you end up with 2000 gallons of listed hazardous waste and your disposal costs will increase. Note that the dilution of a characteristic hazardous waste to make it nonhazardous is considered treatment and is subject to regulatory requirements.

The Empty Container Rule

The Empty Container Rule: Residues of hazardous waste in empty containers that formerly contained hazardous waste are exempt from hazardous waste regulation and thus can be managed as a nonhazardous waste. A container is empty if all wastes have been removed by the methods commonly used to empty that type of container – e.g. pouring or pumping. The container must have: a) less than one inch of waste remaining, or b) 3% or less by weight of waste remaining if the container holds 110 gallons or less, or c. 0.3% or less by weight of waste remaining if the container holds more than 110 gallons. Containers that held acutely hazardous waste must be triple rinsed to be considered empty. Acutely hazardous wastes are defined as: any hazardous waste with a Waste Code beginning with the letter P, or any of the following F codes: F020, F021, F022, F023, F026, and F027. Rinsewater from the cleaning of empty containers is regulated as hazardous waste if it has any of the hazardous waste characteristics.

2) Convert all measurements to pounds. To make an accurate calculation, follow the steps outlined below:

Tip: About one–half a 55 gallon drum of liquid waste weighs 220 lbs. (pounds determined using the weight of water)

  1. weigh an empty one gallon container;
  2. fill the container with one gallon of the waste material;
  3. weigh the filled container; and
  4. subtract the weight of the container, and you'll know the weight of one gallon of the waste material.

This must be done for each type of hazardous waste. Ideally, you should have a laboratory determine the density (weight/volume) of your wastes.

3) Subtract all of the excluded wastes (in pounds).

4) Calculate the total waste generation for the month.

All Hazardous Wastes
– Excluded Wastes

_________________________
= Total Waste Generated

Tip: When selecting your generation rate below, choose the button that reflects the highest amount that you generate in any given month, unless that month reflects a one–time cleanup.

If you generate less than 220 lbs per month, go to 4. You are a very small quantity generator (VSQG).

If you generate 220 lbs but less than 2205 lbs per month, go to 5. You are a small quantity generator (SQG).

If you generate 2205 lbs or more per month, go to 6. You are a large quantity generator (LQG).

   
 

4. You are a very small quantity generator (VSQG).

You may be able to reduce your wastes, cut costs, and limit your regulatory burden with pollution prevention. Would you like to review P2 ideas for very small quantity generators of hazardous waste? Select "Review P2 ideas for very small quantity generators" below to provide you with many pollution prevention options that may be applicable to your business.

If you don't want to review the P2 page, please select "Skip P2 ideas and continue" button below. This link will take you to the very small quantity generator requirements page.

   

If you would like to review P2 ideas for very small quantity generators, go to 9. Very small quantity generators Pollution prevention and waste minimization

If you would like to skip P2 ideas and continue, go to 10. You are a very small quantity generator (VSQG).

   
 

5. You are a small quantity generator (SQG).

You may be able to reduce your wastes, cut costs, and limit your regulatory burden with pollution prevention. Would you like to review P2 ideas for small quantity generators of hazardous waste? Select "Review P2 ideas for small quantity generators" below to provide you with many pollution prevention options that may be applicable to your business.

If you don't want to review the P2 page, please select "Skip P2 ideas and continue" button below. This link will take you to the small quantity generator requirements page.

   

If your would like to review P2 ideas for small quantity generators," go to 11. You are a small quantity generator (SQG): Pollution prevention and waste minimization.

If you would like to skip P2 ideas and continue, go to 12. You are a small quantity generator (SQG).

   
 

6. You are a large quantity generator (LQG).

You may be able to reduce your wastes, cut costs, and limit your regulatory burden with pollution prevention. Would you like to review P2 ideas for large quantity generators of hazardous waste? Select "Review P2 ideas for large quantity generators" below to provide you with many pollution prevention options that may be applicable to your business.

If you don't want to review the P2 page, please select "Skip P2 ideas and continue" button below. This link will take you to the large quantity generator requirements page.

   

Need to backtrack? Return to:

If you want to review P2 ideas for large quantity generators, go to 7. large quantity generator (LQG) Pollution prevention and waste minimization

If you would like to skip P2 ideas and continue, go to 8. You are a large quantity generator (LQG).

Return to 2. Do you generate acute waste?

Return to 3. How much hazardous waste do you generate?

 

7. Large quantity generator (LQG) (Pollution prevention and waste minimization)

As a large quantity generator, the best way to manage your waste is not to produce it in the first place. There are a wide range of source reduction options from no–cost changes that you can make (e.g., checking for leaks, tightening valves) to modifications that will pay for themselves in a few years (e.g., process modifications).

Source reduction

Source reduction is the reduction or elimination of waste at the source, usually within a process. Source reduction measures include process modification, feed-stock substitutions, improvements in feed-stock purity, housekeeping and management practices, increases in the efficiency of machinery and recycling within a process. Source reduction implies any action that reduces the amount of waste exiting a process.

Waste minimization

Waste minimization means the reduction, to the extent feasible, of hazardous waste that is generated and subsequently treated, stored or disposed of. It includes any source reduction or recycling activity undertaken by a generator that results in:

  1. the reduction of total volume or quantity of hazardous waste;
  2. the reduction of toxicity of hazardous waste; or
  3. both, as long as the reduction is consistent with the goal of minimizing present and future threats to human health and the environment.

Links

If your answer is "Continue to next section," go to 8. You are a large quantity generator (LQG).

   
 

8. You are a large quantity generator (LQG).

As a large quantity generator, there are several procedures and requirements your business needs to be aware of. Review the following table to determine which requirements apply. In addition we suggest that you review the Common Violations (WA–850) fact sheet.

Small Quantity Generator Requirements
Issue Required?
Yes/No
Available Fact Sheet or website

Waste determination

Yes
By completing this portion of the Small Business Assistance web page you have made a waste determination. If you generate a new waste or make a process change, you need to go through this review.

 

Accumulation limit

No
LQGs have no upper limit (total) of hazardous waste accumulated at their facility at any time, however, they must not exceed the 90-day accumulation time frame.

 

EPA ID number

Yes
Obtain an EPA identification number

 

Accumulation time frame/Container storage

Yes
LQGs may accumulate hazardous waste for 90 days or less. Store your waste in accordance with the regulations found along the right column.

Notice of Final Guidance & Certification (WA-1821)

Department of Transportation (DOT) requirements

Yes
Package, mark and label your wastes in accordance with the U.S. Department of Transportation's hazardous materials transportation requirements prior to shipping.

Chapter TRANS 326, Wisc. Adm. Code — Motor Carrier Safety Requirements for Transporting Hazardous Materials

Manifest requirements

Yes
Use a WI DNR licensed hazardous waste transporter and fill out a hazardous waste manifest

 

Annual reporting

Yes
Submit an annual report on your waste management activities to the DNR

Consolidated Reporting System (CRS)

Licensed transporter

Yes
Use a WI DNR licensed hazardous waste transporter. NOTE: If you will be transporting the waste yourself, you will need a Hazardous Waste Transporter License. Please Refer to the link along right column.

Transporting Hazardous Waste (WA–137)

Waste facility and transporter licenses

Proper treatment, storage and disposal of your waste

Yes
Properly recycle, treat or dispose of your hazardous waste at a licensed Treatment, Storage and Disposal (TSD) facility. NOTE: If you are a TSD, you will need a TSD license.

 

Land disposal restrictions

Yes
You must notify each TSD facility that your waste must be treated before it can be placed in a landfill. Your waste hauler may be able to provide the form or you can obtain it here (far right column).

Land Disposal Restrictions for Hazardous Waste

Safety, training & emergency procedures/Written contingency plan

Yes
Establish emergency procedures for responding to environmental emergencies such as leaks, spills and fires involving hazardous wastes. All spills should be immediately reported using the 24–hour toll free hotline (1–800–943–0003). You must have a written contingency plan on site and provide a copy to DNR.

Hazardous Waste Training Records (WA–099)

Wisconsin Spill Reporting Requirements (RR–560)

   
 

9. Very small quantity generators (Pollution prevention and waste minimization)

As a very small quantity generator, the best way to manage your waste is not to produce it in the first place. There are a wide range of source reduction options from no–cost changes that you can make (e.g., checking for leaks, tightening valves) to modifications that will pay for themselves in a few years (e.g., process modifications).

Source reduction

Source reduction is the reduction or elimination of waste at the source, usually within a process. Source reduction measures include process modification, feed-stock substitutions, improvements in feed-stock purity, housekeeping and management practices, increases in the efficiency of machinery, and recycling within a process. Source reduction implies any action that reduces the amount of waste exiting a process.

Waste minimization

Waste minimization means the reduction, to the extent feasible, of hazardous waste that is generated and subsequently treated, stored or disposed of. It includes any source reduction or recycling activity undertaken by a generator that results in:

  1. the reduction of total volume or quantity of hazardous waste;
  2. the reduction of toxicity of hazardous waste; or
  3. both, as long as the reduction is consistent with the goal of minimizing present and future threats to human health and the environment.

Links

   
 

10. You are a very small quantity generator (VSQG).

As a very small quantity generator, there are several procedures, requirements and best management practices or BMPs your business needs to be aware of. Review the following table to determine which requirements apply. In addition we suggest that you review the Common Violations (WA–850) fact sheet.

Very Small Quantity Generator Requirements
Issue Required?
Yes/No
Available Fact Sheet or website

Waste determination

Yes
By completing this portion of the Small Business Assistance webpage you have made a waste determination. If you generate a new waste or make a process change, you need to go through this review.

 

Accumulation limit

Yes
VSQGs must not accumulate more than 2,205 lbs. (total) of hazardous waste at their facility at any time.

 

Manifest requirements

No
You are not required to manifest your waste shipments but if you should choose to do so (and some disposal facilities may ask for a manifest), you need to obtain an EPA identification number and comply with the manifest requirements.

 

EPA ID number

No
Obtain an EPA ID Number only if you are manifesting your hazardous waste.

 

Container storage

Yes
VSQGs should store waste in accordance with the guidance found in the right column.

Very Small Quantity Generator Responsibilities (WA-295)

Department of Transportation (DOT) requirements

Yes
Package, mark and label your wastes in accordance with the U.S. Department of Transportation's hazardous materials transportation requirements prior to shipping

Chapter TRANS 326, Wisc. Adm. Code — Motor Carrier Safety Requirements for Transporting Hazardous Materials

Licensed transporter

Yes
Use a WI DNR licensed hazardous waste transporter. NOTE: If you will be transporting the waste yourself, you will need a hazardous waste transporter license. Please refer to the link along right column.

Waste facility and transporter licenses

Land disposal restrictions

Yes
Use a WI DNR licensed hazardous waste transporter. NOTE: If you will be transporting the waste yourself, you will need a Hazardous Waste Transporter License. Please refer to the link along right column.

Transporting Hazardous Waste (WA-137)

Waste facility and transporter licenses

Safety, training & emergency procedures

No
It is recommended, but not required, that you establish emergency procedures for responding to environmental emergencies such as leaks, spills and fires involving hazardous wastes

Hazardous Waste Training Records (WA–099)

   
 

11. You are a small quantity generator (SQG). (Pollution prevention and waste minimization)

As a small quantity generator, the best way to manage your waste is not to produce it in the first place. There are a wide range of source reduction options from no–cost changes that you can make (e.g., checking for leaks, tightening valves) to modifications that will pay for themselves in a few years (e.g., process modifications).

Source reduction

Source reduction is the reduction or elimination of waste at the source, usually within a process. Source reduction measures include process modification, feed-stock substitutions, improvements in feed-stock purity, housekeeping and management practices, increases in the efficiency of machinery, and recycling within a process. Source reduction implies any action that reduces the amount of waste exiting a process.

Pollution prevention and waste minimization

Waste minimization means the reduction, to the extent feasible, of hazardous waste that is generated and subsequently treated, stored, or disposed of. It includes any source reduction or recycling activity undertaken by a generator that results in:

  1. the reduction of total volume or quantity of hazardous waste;
  2. the reduction of toxicity of hazardous waste; or
  3. both, as long as the reduction is consistent with the goal of minimizing present and future threats to human health and the environment.

Links

   
 

12. You are a small quantity generator (SQG).

As a Small Quantity Generator, there are several procedures and requirements your business needs to be aware of. Review the following table to determine which requirements apply. In addition we suggest that you review the Common Violations (WA–850) fact sheet.

Small Quantity Generator Requirements
Issue Required?
Yes/No
Available Fact Sheet or website

Waste determination

Yes
By completing this portion of the Small Business Assistance webpage you have made a waste determination. If you generate a new waste or make a process change, you need to go through this review.

 

Accumulation limit

Yes
SQGs must not accumulate more than 13,230 lbs. (total) of hazardous waste at their facility at any time.

 

EPA ID number

Yes
Obtain an EPA identification number

 

Accumulation time frame/Container storage

Yes
SQGs may accumulate hazardous waste for 180 days or less (270 days or less if transported over 200 miles to a hazardous waste facility). Store your waste in accordance with the regulations found in the right column.

Notice of Final Guidance & Certification (WA-1821)

Department of Transportation (DOT) requirements

Yes
Package, mark and label your wastes in accordance with the U.S. Department of Transportation's hazardous materials transportation requirements prior to shipping.

Chapter TRANS 326, Wisc. Adm. Code — Motor Carrier Safety Requirements for Transporting Hazardous Materials

Manifest requirements

Yes
Use a WI DNR licensed hazardous waste transporter and fill out a hazardous waste manifest

 

Annual reporting

Yes
Submit an annual report on your waste management activities to the DNR

Consolidated Reporting System (CRS)

Licensed transporter

Yes
Use a WI DNR licensed hazardous waste transporter. NOTE: If you will be transporting the waste yourself, you will need a Hazardous Waste Transporter License. Please refer to the link along right column.

Transporting Hazardous Waste (WA–137)

Waste facility and transporter licenses

Proper treatment, storage and disposal of your waste

Yes
Properly recycle, treat or dispose of your hazardous waste at a licensed Treatment, Storage and Disposal (TSD) facility. NOTE: If you are a TSD, you will need a TSD license.

 

Land disposal restrictions

Yes
You must notify each TSD facility that your waste must be treated before it can be placed in a landfill. Your waste hauler may be able to provide the form or you can obtain it here (far right column).

Land Disposal Restrictions for Hazardous Waste

Safety, training & emergency procedures

Yes
Establish emergency procedures for responding to environmental emergencies such as leaks, spills and fires involving hazardous wastes.

Hazardous Waste Training Records (WA–099)

   
 

13. Other reminders for proper hazardous waste management

Your small business may want to consider establishing a "satellite accumulation site" (see definition below).

Satellite accumulation site

A satellite accumulation site allows a generator to slowly accumulate a hazardous waste stream at the generation point.

Satellite accumulation allows you to accumulate small amounts (not more than 55 gallons per satellite site) of hazardous waste in the production area of your business. The main reasons for satellite accumulation are:

  1. so you can conveniently accumulate waste in the area it is generated; and
  2. so you can accumulate waste over a longer period of time without having to ship within the accumulation period (90 or 180 days) and avoid shipping a partial drum of waste.

Once the container is full (55 gallons), you need to put the date on the barrel and then move it into the accumulation area. This gives you an advantage by allowing you to accumulate full containers. The 90 or 180 day accumulation period starts when the container is full.

You should be very prepared for an inspection, however here are some more tools that you can use to make sure you know what an inspector would look for.

The following forms would be used by department staff when conducting an inspection of your facility. Use them when conducting a self-audit of your workplace.

In addition, the following brochure will assist you when touring your business.

Continue on to Waterway and wetland permits.

 

Contact information
DNR Hazardous waste staff