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Introduction
Welcome to our inaugural edition of the Hazardous Waste Newsletter from the Montana Department of Environmental Quality (DEQ) Hazardous Waste Program. In this semi-annual publication, we hope to provide program updates, spotlight new or commonly missed regulations, and help you get to know our staff. Please feel free to contact us anytime with questions or comments!
-Denise A. Kirkpatrick, Section Supervisor
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Acronyms and Definitions
LQG - Large Quantity Generator: Hazardous Waste Generators that generate greater than 2,200 pounds of hazardous waste or greater than 2.2 pounds of acute hazardous waste in a calendar month
SQG - Small Quantity Generator: Hazardous waste generators that generate between 220 and 2,200 pounds of hazardous waste in calendar month
Check out our website for more detail on generator categories! -------->
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VSQG - Very Small Quantity Generator: Hazardous waste generators that generate less than 220 pounds of hazardous waste in a calendar month
CFR - Code of Federal Regulations. Hazardous waste regulations are found at 40 CFR 260-279. Montana incorporates the federal regulations by reference in the ARM.
ARM - Administrative Rules of Montana. Hazardous waste rules can be found at rule chapter 17.53.
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What's Up
It's almost that time of year again - annual reporting! All generators that were registered as a LQG, SQG, or had an Episodic Event in 2022 are required to submit a report of hazardous waste activities each year. Forms and instructions will be emailed to the site contacts listed in our database in early January. We are making some changes to the way the forms look this year. Some things you will notice with the new forms:
- Your information will no longer be auto-populated on the form. Contact us if you need to know what we currently have in our database for your site. Even better, sign up for a myRCRAid account to take a look yourself! See here for a how-to. myRCRAid allows you to update your site information electronically and access electronic copies of your waste manifests, among other features.
- Part One now has a vertical orientation and the layout matches what you would see on EPA Form 8700-12 or on the myRCRAid site. This should make it easier for you (and us) to see the information and update as needed.
- In Part Two, waste transporter(s) information is no longer needed.
Remember - the same waste stream going to the same receiving facility can all be grouped on the same line!
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Regulatory Spotlight
Montana adopted EPA's Generator Improvements Rule (GIR) (among many other rules) earlier this year. These regulations became effective in Montana on May 14, 2022. One of the new provisions changes how containers and tanks of hazardous waste are labeled. Now, in addition to the words "Hazardous Waste" and an accumulation start date, you must also indicate the hazard(s) posed by the waste. This is detailed at 40 CFR 262.15(a)(5)(ii) for satellite accumulation areas, 40 CFR 262.16(b)(6)(i)(B) for SQGs, and 40 CFR 262.17(a)(5)(i)(B) for LQGs.
The regulations give four options for compliance:
- Words indicating the applicable hazardous waste characteristic, i.e., ignitable, corrosive, toxic.
- A label or placard that meets DOT requirements at 49 CFR Part 172 Subpart E or F.
- A statement or pictogram consistent with the OSHA Hazard Communication Standard at 29 CFR 1910.1200.
- A chemical hazard label consistent with the National Fire Protection Association code 704.
This indication can either be attached to the “Hazardous Waste” label or separate. In addition, a label must be present for each hazard posed by the waste. For example, if the waste is ignitable and toxic, both hazards must be indicated. Contact us if you have questions about whether your labels comply.
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Get to Know Our Staff
Jennifer Strause is our Regulatory Specialist for western Montana. She has been with DEQ since October 2020 and is based in the Kalispell field office. She is your regulatory contact for all things hazardous waste, universal waste, used oil, and EPCRA/Tier II. Prior to DEQ, she lived in Alaska and spent eight years as the Hazardous Waste Manager for the Alaska Army National Guard and another four years overseeing all their environmental compliance. Originally from the Coeur d'Alene, Idaho area, she has degrees from the University of Idaho and Washington State University. When not at work, you can find her chasing after her four children (ages 3-11), sewing, baking, reading, gardening, hiking, at a local lake, or riding horses. She can be reached at Jennifer.Strause@mt.gov or (406) 431-3148.
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By the Numbers...
As of December 1, 2022 :
- LQG - 36
- SQG - 118
- VSQG - 1328
- TSDF - 9
- New Generators this year - 26
- Inspections this year - 23
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Now You Know...
Used Oil 101 for Used Oil Generators
Many businesses generate used oil during regular maintenance activities. While the used oil may be considered a waste stream, regulations at 40 CFR 279 require that any container that holds used oil be labeled simply “Used Oil” [40 CFR 279.22(c)]. This labeling requirement applies to the storage drum that collects used oil and to the bucket or pan that collects the used oil prior to the used oil being placed in the storage drum. Please label all containers that hold used oil with the exact words, “Used Oil”. This is a common violation found during inspections. Also, be sure all that all used oil containers are in good condition and do not leak [40 CFR 279.22(b)].
So now that your containers are labeled correctly, what can be done with used oil? First, we’ll start with what NOT to do:
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DO NOT MIX HALOGENATED MATERIALS OR WASTE WITH USED OIL. If you do, the used oil may need to be managed as hazardous waste, which can get very expensive. See the used oil specifications here.
Here is what you CAN do with used oil:
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Burn used oil in used oil-fired space heaters if you meet the requirements at 40 CFR 279.23.
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Filter, clean, or otherwise recondition the used oil to reuse it [40 CFR 279.20(b)(2)(ii)(A)] or to burn it in a space heater [40 CFR 279.20(b)(2)(ii)(E)]
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Transport the used oil to an approved used oil collection center provided that you follow 40 CFR 279.24(a)
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Arrange for used oil to be reclaimed and returned to you for use as a lubricant, cutting oil, or coolant [40 CFR 279.24(c)].
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Arrange to have the used oil collected: Used Oil Collectors (mt.gov). Ask about the used oil transporter’s EPA identification number to be sure the used oil will be disposed properly.
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Used oil may be used as a dust suppressant on roadways and/or driveways only if certain conditions are met.
We're Hiring!
Our bureau has several open positions in our hazardous waste, solid waste, and asbestos programs. Review of applicants began December 13 but applications will be accepted through January 9. If you or someone you know is interested in joining our awesome team, click the button below.
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Important Dates to Remember
- January 3 - Annual Report Forms and Instructions to be Mailed
- March 1 - Annual Reports Due to DEQ
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