Memo Detail

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RCRA Online Number: 11681
Title: RCRA SUBTITLE C REQUIREMENTS APPLICABLE TO HOUSEHOLD HAZARDOUS WASTE COLLECTION PROGRAMS COLLECTING CESQG WASTE
Document Date: 1992-07-22
To: Directors, Regions 1-10
From: Lowrance
Organization of Recipient: EPA
Description: CESQG wastes managed by state-approved Household Hazardous Waste Collection programs may be mixed with nonhazardous waste (e.g., household hazardous waste) and remain subject to the CESQG requirements, even if the mixture exhibits a characteristic. Collection programs that handle the commingled waste are subject to CESQG regulations. CESQGs who mix hazardous and nonhazardous waste and whose resultant mixtures exceed the 261.5(h) quantity limit and exhibit a characteristic are subject to 262 generator regulations.
Regulatory Citation(s): 261.4(b)(1), 261.5
RPPC Number: 9574.00-02
Official ORCR Policy: Yes
Associated Topic(s): Very Small Quantity Generators (VSQG) (formerly Conditionally Exempt, CESQG), Exclusions (RCRA), Generators, Hazardous Waste