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Introduction
Welcome to our fifth edition of the Hazardous Waste Newsletter from the Montana DEQ Hazardous Waste Program. In this 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: DEQ 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. |
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What's Up
Invoices were emailed May 23, 2025, to all sites registered as small and large quantity generators or sites that had an episodic event in 2024. Included in the invoice is an annual registration fee and a fee based on how much waste was generated at your site in 2024. Fees may be paid electronically using the link on the invoice. After July 22, 2025, unpaid fees will be subject to a 10% late fee.
As you know from our last newsletter and information sent out by the EPA, paper manifests for SQGs and LQGs are no longer returned by mail. All SQGs and LQGs in Montana now have at least one person registered for EPA’s e-Manifest system. This allows you to view your final manifests once the hazardous waste has reached the designated facility. But what do WE do with the information in e-Manifest?
EPA utilizes a data analytics tool known as Metabase to allow regulators to explore and visualize data from RCRAInfo. Using Metabase, we can see:
- Data from e-Manifest that shows what each site shipped during a given time range (very helpful when reviewing annual reports).
- Manifests that have been in transport longer than 60 days.
- Sites that ship pharmaceutical waste without being registered as a healthcare facility under Subpart P.
- Sites that are potentially under reporting their generator status based on waste being shipped off site.
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Regulatory Spotlight - Top 10 Violations
May 14, 2025, marked the third anniversary of Montana’s adoption of the Generator Improvements Rule, the Pharmaceuticals Rule, aerosol cans as Universal Waste, and several other rules. We wondered what the top violations were since the adoption, and we thought we’d share it with you. All the numbers below are from 5/14/2022 to 5/14/2025.
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 Improperly stored fluorescent lamps.
 Properly closed, labeled, and dated fluorescent lamps.
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Number of compliance inspections conducted: 148
LQG: 27
SQG: 62
VSQG: 47
Non-generator (transporters, etc.): 12
Number of violations issued: 403
LQG: 119
SQG: 188
VSQG: 54
Non-generator: 42
% of inspections with violations: 63%
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Top 10 violations
Missing indication of hazard(s) posed by the waste – 75
Missing accumulation start date on universal waste – 66
Missing hazardous waste label - 48
Emergency preparedness violations – 44
Missing HW accumulation start date – 37
Failure to determine if waste is hazardous – 36
Missing used oil label – 36
Missing label on universal waste lamps – 25
Container of universal waste lamps not closed – 24
LQG accumulated waste longer than 90 days – 14
Short training videos on hazardous waste determinations, used oil, and universal waste can be found here.
Information on indication of hazard(s) labeling, used oil, and emergency preparedness were covered in past newsletters that can be found here.
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 Missing HW and indication of hazard labels.
 Corrected labeling.
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Get to Know Our Staff
Wally Jemmings began his career as a Hazardous Waste Specialist at Montana DEQ in 2024. His previous roles at DEQ have included positions in the Underground Storage Tank Leak Prevention Program, Brownfields, and Public Water. He was born and raised in Butte, Montana, and holds a Bachelor of Science Degree in Biological Sciences from Montana Tech.
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When Wally is not rolling around on the floor playing with his two granddaughters, you might find him at your local watering hole playing drums and singing with a local band. You may have even spotted him on stage at Grandstreet Theater in Helena a time or two.
He can be reached at wjemmings@mt.gov or (406) 444-02876.
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By the Numbers...
As of May 30, 2025:
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 Looking east from the Great Falls Airport
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Important Dates to Remember
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July 22 – Annual maintenance fee and waste generation fees due to DEQ
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