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Introduction
Welcome to the third edition of the Hazardous Waste Newsletter from the Montana DEQ Hazardous Waste Program. In this semi-annual publication, we hope to provide program updates, spotlight new or commonly missed regulations, and let you get to know our staff. Please feel free to contact us anytime with questions or comments!
-Denise 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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Note: The DEQ Hazardous Waste Program incorporates by reference the Code of Federal Regulations (CFR) in the Administrative Rules of Montana (ARM). For ease of reading, we are not noting the ARM citations in this newsletter. Please call or email us if you have any questions.
What's Up
The 2023 Montana Hazardous Waste Reporting Season is rapidly approaching!
Forms and instructions for the 2023 Montana Hazardous Waste Generator Biennial Report will be emailed in early January 2024 to the site contact listed in our database based on the generator’s most recent submission of an EPA Site Identification Form 8700-12. Forms and instructions will also be available on the Hazardous Waste Program website. Please take a moment to ensure that your site contact is updated prior to the end of the year as necessary.
Your information will not be auto populated on the reporting forms. 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 find the information 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.
What’s the difference between annual and biennial reporting?
Reports pertaining to even numbered calendar years are referred to as Annual Reports. All hazardous waste generators that are registered as an LQG, SQG, or took part in an Episodic Event at any time during the calendar year are required to submit a report detailing hazardous waste activities each year. Additionally, Commercial Transfer Facilities, Exporters of hazardous waste to foreign countries, and Treatment, Storage, and Disposal Facilities are required to submit a report specific to those activities each year.
Reports pertaining to odd numbered calendar years are referred to as Biennial Reports. In addition to all those required to submit an annual report, Used Oil Transfer Facilities/Processors/Re-Refiners are required to submit a report specific to those activities during a Biennial Report year. Additionally, hazardous waste generators that were an LQG at any time during the calendar year of a Biennial Report year are required to provide additional information to ensure compliance with EPA specific reporting requirements.
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Regulatory Spotlight - Emergency Preparedness
Have you heard the adage “Failure to Plan is a Plan to Fail”? No one wants to think that an emergency can happen at their site, but emergencies do happen and a failure to plan could result in harm to your workers or community. One of the issues we see regularly during inspections is a lack of preparation for emergencies and the records of those preparations. As with many regulations, there are some differences between requirements for small and large quantity generators.
SQG Requirements are listed in two parts:
Preparedness and Prevention: 40 CFR 262.16(b)(8) covers required equipment, access to communication or alarm systems, required isle space, and arrangements with local emergency response authorities.
Emergency Procedures: 40 CFR 262.16(b)(9) requires at least one employee be designated as an emergency response coordinator and that their name and contact information, along with other information, be posted in areas where waste is generated or stored. Also included in this part are the training requirements covered in our last newsletter.
The most common issues we see at SQGs are a lack of an emergency coordinator and no emergency contacts posting. Free templates for this posting can be found online.
LQG Requirements:
The Generator Improvements Rule (adopted in Montana in May 2022), consolidated emergency preparedness requirements for LQGs and compiled them in a separate section of Part 262. 40 CFR 262.17(a)(6) requires compliance with 40 CFR Part 262 Subpart M (40 CFR 262.250-265). This is a long list of requirements that we will not detail here. The most common issues seen during inspections are 1) Lack of, incomplete, or non-current contingency plan; 2) Lack of or incomplete contingency plan quick reference guide; and 3) Failure to coordinate with local response agencies.
VSQG Requirements:
There are no regulations covering emergency preparedness for very small quantity generators. However it is never a bad idea to think through what emergencies could occur and how you would respond. As with the larger generators, VSQGs are responsible for cleaning up any environmental contamination that may be caused from an accidental spill of hazardous waste.
If you have questions about emergency preparedness requirements, please contact our office.
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Get to Know Our Staff
Nolan Golz is the Data Control Specialist for the Hazardous Waste program here at DEQ. He joined the program in May of 2023. He is learning the ins and outs of RCRA and the RCRAInfo system. Nolan grew up in Helena, MT and graduated with a bachelor’s degree from Montana State University. He moved to Alaska for 8 years and started a family before returning to Helena.
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He enjoys spending his time outdoors with his family hunting, golfing, mountain biking, and much more. Nolan can be contacted at Nolan.Golz@mt.gov or (406) 444-5852. |
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By the Numbers...
As of November 15, 2023:
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 We train for emergencies too! Live-fire fire extinguisher training at DEQ in Spring 2023.
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New Training Resources
During inspections over the last few years, we have frequently been asked about training resources. To help keep our regulated community in compliance we have begun developing short training videos for some of the most commonly seen violations.
Click here to view our new videos. The videos are on our main website, just below the Program Overview section. We currently have videos covering hazardous waste determinations, universal waste, and healthcare facilities and will be adding more in the coming weeks.
Want more hazardous waste training from DEQ? Click the button below to take our short survey and help us learn what training would be useful to you. Please respond by November 22nd.
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We're Hiring!
DEQ's Waste Management Bureau has openings for hazardous waste specialists, asbestos specialists, and solid waste specialists. The positions will be advertised in January. 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 E-Mailed
- March 1 - Annual Reports Due to DEQ
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