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Hazardous Waste Management Program

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Generator Treatment FAQs

What is treatment?

What are some examples of hazardous waste treatment?

Do I need a permit to treat hazardous waste?

As a generator, can I treat my hazardous waste on-site without a permit?

Can I dilute my hazardous waste as a form of treatment?

Are there any restrictions for generators who want to treat hazardous waste on-site in tanks and containers?

Are my recycling units considered to be treatment units?

What do I need to do in order to treat hazardous waste on-site in containers and tanks?

If I am treating hazardous waste, do the management requirements in VHWMR Subsection 3 still apply?

Does the treated waste count against my generator status?

What is treatment?

Treatment is defined in VHWMR 7-103 as any method, technique, or process, including neutralization, designed to change the physical, chemical or biological character or composition of any hazardous or solid waste, so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to render such waste safer for transport, amenable for recovery, amenable for storage, or reduced in volume, or for hazardous wastes, so as to render such waste non-hazardous.

 

Requirements for hazardous waste treatment, storage, and disposal facilities can be found in VHWMR Subchapter 5.

 

What are some examples of hazardous waste treatment?

Some examples of generator treatment methods observed in Vermont include:

  • Solvent recycling (e.g., paint thinner recycling, acetone recycling)
  • Compaction (e.g.,  using mechanical means to press solid waste, this changing its physical character)
  • Aerosol can puncturing [see the Aerosol Can Puncturing Management Procedure <link>]

 

Do I need a permit to treat hazardous waste?

Some treatment processes are exempt under the VHWMR 7-502.  Some examples of exempt treatment include:

  • Elementary neutralization unit or wastewater treatment unit as defined in 40 CFR § 260.10 [refer to 7-502(c)]
  • Treatment or containment activities during an immediate response to a release of hazardous material or discharge of a hazardous waste and during an imminent and substantial threat of a release of hazardous material [refer to 7-502(d)]
  • Treatment of hazardous waste by mixing absorbent material with containerized hazardous waste [refer to 7-502(e)]
  • Evaporation of water from hazardous waste that is identified only by the VT02 hazardous waste code [refer to 7-502(l)]
  • Oil-water separators [refer to 7-502(m)]
  • Treatment of hazardous waste in containers or tanks by generators [refer to 7-502(o)]

As a generator, can I treat my hazardous waste on-site without a permit?

Yes.  As a generator, you are allowed to treat hazardous waste on-site without obtaining a hazardous waste permit if you comply with the requirements found in VHWMR 7-502(o). 

  

Can I dilute my hazardous waste as a form of treatment?

 

Section 7-302 of the VHWMR prohibits the dilution of hazardous waste subject to the land disposal restrictions of 40 CFR part 268.  You cannot dilute hazardous waste to render it non-hazardous.

Are there any restrictions for generators who want to treat hazardous waste on-site in tanks and containers?

Yes.  Generators cannot treat hazardous waste using thermal treatment processes (Note: Distillation is not considered a thermal treatment process).  Generators also cannot treat mercury-containing wastes or devices (e.g., fluorescent lamps, thermostats).

 

Are my recycling units considered to be treatment units?

 

It depends.  If wastes are recycled in accordance with the exemptions specified in  VHWMR 7-204, then the recycling of that waste is not considered to be treatment.  For example, a recycling unit for used anti-freeze would be exempt from 7-502(o) requirements based on 7-204(i).  However, a laboratory with an ethanol recycling unit would be subject to the requirements of 7-502(o).

What do I need to do in order to treat hazardous waste on-site in containers and tanks?

Requirements are outlined in VHWMR 7-502(o).  The general requirements include:

  • Generator treatment notification form submitted to DEC
  • The hazardous waste must be generated and treated on-site
  • Maintain a record for at least three years, including the following information:
    • The type(s) and quantity of waste treated
    • Method(s) of treatment used
    • Date(s) that treatment occurred
  • Submit revised written notification when there is significant changes

If I am treating hazardous waste, do the management requirements in VHWMR Subsection 3 still apply?

 

Yes.  Containers of hazardous waste that are destined for on-site treatment in containers and tanks must still meet the following requirements:

  • Labeled as “Hazardous Waste” and words to identify the contents.  Labels may also include words to indicate that the waste is destined for recycling
  • Containers must be closed except to add or remove waste
  • Containers must be compatible with its contents and must be in good condition.

Does the treated waste count against my generator status?

Yes.  The hazardous waste must be counted toward your generator status.  However, the waste only needs to be counted once.  For example, when a generator uses a solvent recycling unit, there is a small amount of solvent that can no longer be recycled along with the contaminants that the removed through the recycling process.  The hazardous waste can be counted either before you treat it or as the contaminated solvent waste that is removed from the recycling unit. 

 

 

Last updated: 05/03/2012

 

 

 

 

 

 

 

VT DEC Waste Management & Prevention Division 1 National Life Drive - Davis 1  Montpelier, VT  05620-3704  Tele: 802-828-1138  Fax: 802-828-1011

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