The Iowa Department of Natural Resources (IDNR) regulates hazardous waste management under the authority of the Iowa Code Chapter 455B and the Iowa Administrative Code (IAC) Chapters 567—100 through 567—117. These regulations are largely based on the federal Resource Conservation and Recovery Act (RCRA) but may contain state-specific provisions. A key aspect of hazardous waste management is the proper identification and classification of waste. Generators of hazardous waste must determine if their waste exhibits any of the hazardous characteristics defined in IAC 567—101.3 (which mirrors 40 CFR §261.20-261.24). These characteristics are ignitability, corrosivity, reactivity, and toxicity. For toxicity, the Toxicity Characteristic Leaching Procedure (TCLP) is used to determine if a waste is hazardous due to the presence of certain toxic constituents. If a waste exhibits any of these characteristics, or is listed as hazardous, it is subject to the full scope of hazardous waste regulations. The question focuses on the generator’s responsibility to identify hazardous waste, specifically concerning the toxicity characteristic. The TCLP test is the definitive method for assessing this characteristic. Therefore, if a waste fails the TCLP for any of the regulated constituents, it is classified as hazardous waste. The specific constituents and their regulatory limits are detailed in IAC 567—101.3(3), which corresponds to the federal Toxicity Characteristic list. The scenario presented involves a waste that, when subjected to the TCLP, shows a concentration of lead exceeding the regulatory limit of 5.0 mg/L. This exceedance unequivocally classifies the waste as hazardous due to toxicity. Consequently, the generator must manage this waste in accordance with all applicable hazardous waste regulations in Iowa.

The Iowa Department of Natural Resources (IDNR) enforces regulations for hazardous waste management under Chapter 455B of the Iowa Code and the associated administrative rules, primarily found in Chapter 111 of the Iowa Administrative Code (IAC). These regulations are largely aligned with the federal Resource Conservation and Recovery Act (RCRA). A key aspect of these regulations involves the identification and management of hazardous waste. Iowa’s definition of hazardous waste is primarily based on the characteristics of hazardous waste (ignitability, corrosivity, reactivity, and toxicity) as defined by the U.S. Environmental Protection Agency (EPA) under 40 CFR Part 261, and also includes any waste listed by the EPA or the state as hazardous. Generators of hazardous waste are responsible for determining if their waste is hazardous. This determination can be made by testing the waste against the characteristic criteria or by knowing that the waste is a listed hazardous waste. If a waste exhibits any of the hazardous characteristics or is listed, it must be managed according to Iowa’s hazardous waste regulations, which include requirements for storage, transportation, treatment, and disposal. The generator’s responsibility to accurately classify their waste is paramount in ensuring compliance and protecting human health and the environment. The Iowa Administrative Code Chapter 111 provides specific guidance and criteria for this waste characterization process.

Iowa’s Hazardous Waste Management Act, specifically referencing the regulations promulgated under it, defines the scope of hazardous waste management. A key aspect of this is the identification and management of characteristic hazardous wastes, which are wastes exhibiting one or more of four specific properties: ignitability, corrosivity, reactivity, or toxicity. The Toxicity Characteristic Leaching Procedure (TCLP) is a regulatory tool used to determine if a waste exhibits the toxicity characteristic. This procedure simulates the leaching that occurs in a landfill environment. If the concentration of any of the 40 specified contaminants in the leachate exceeds the regulatory limits, the waste is classified as toxic hazardous waste. For example, if a waste sample, when subjected to the TCLP for the metal cadmium, produces a leachate with a cadmium concentration of 0.4 mg/L, this would exceed the regulatory limit of 0.1 mg/L for cadmium, thus classifying the waste as hazardous due to toxicity. The generator of the waste is responsible for determining if their waste exhibits any of these characteristics through testing or knowledge of the process generating the waste. This determination is fundamental to proper waste management, including manifesting, transportation, and disposal requirements under Iowa law. The correct option reflects the regulatory threshold for cadmium as defined by the Toxicity Characteristic Leaching Procedure.

Iowa Administrative Code (IAC) 567 Chapter 23, which governs hazardous waste management, establishes specific requirements for generators. A key aspect is the determination of generator status, which dictates the regulatory burden. Small Quantity Generators (SQGs) are subject to less stringent requirements than Large Quantity Generators (LQGs). The determination of generator status is based on the amount of hazardous waste generated per month. Specifically, an SQG is a generator who generates between 100 kilograms (kg) and 1,000 kg of hazardous waste per month, or generates less than 1 kg of acutely hazardous waste per month. An LQG generates 1,000 kg or more of hazardous waste per month, or generates 1 kg or more of acutely hazardous waste per month. If a facility generates more than 1,000 kg of hazardous waste in a single month, it is classified as an LQG for that month and must comply with all applicable LQG requirements, regardless of whether it generated less than 1,000 kg in prior or subsequent months. The question describes a facility that generated 1,200 kg of hazardous waste in March and 800 kg in April. For March, the generation of 1,200 kg clearly places the facility in the Large Quantity Generator category for that month. The subsequent month’s generation of 800 kg would classify it as an SQG for April, but the critical factor for determining the status in March is the 1,200 kg figure. Therefore, for the month of March, the facility is an LQG.

The Iowa Administrative Code (IAC) 567 Chapter 20 governs hazardous waste management. Specifically, IAC 567-20.3(455B) addresses generator status and the criteria for determining if a facility is a small quantity generator (SQG) or a large quantity generator (LQG). A key factor is the amount of hazardous waste generated per calendar month. For SQGs, the limit is typically between 100 kg and 1,000 kg of hazardous waste, and less than 1 kg of acute hazardous waste. For LQGs, the generation rate is greater than 1,000 kg of hazardous waste per month or greater than 1 kg of acute hazardous waste per month. In this scenario, the facility generates 1,100 kg of hazardous waste and 0.5 kg of acute hazardous waste in a calendar month. Since the hazardous waste generation (1,100 kg) exceeds the 1,000 kg threshold for SQGs, and the acute hazardous waste generation (0.5 kg) is below the 1 kg threshold for LQGs, the facility’s status is determined by the higher threshold met. The generation of 1,100 kg of hazardous waste classifies the facility as a large quantity generator under Iowa’s regulations, irrespective of the acute hazardous waste amount being below the LQG threshold for that specific category. This classification triggers more stringent management, record-keeping, and reporting requirements.

The Iowa Administrative Code (IAC) Chapter 567—100, which implements the Resource Conservation and Recovery Act (RCRA) in Iowa, defines “hazardous waste” based on characteristics and listings. Characteristic wastes exhibit ignitability, corrosivity, reactivity, or toxicity. Listed wastes are those specifically identified by the U.S. Environmental Protection Agency (EPA) or the Iowa Department of Natural Resources (IDNR) as hazardous due to their origin or specific constituents. For a waste to be regulated as hazardous under RCRA, it must meet either the characteristic criteria or be a listed waste. In this scenario, the spent solvent from the manufacturing process at the Des Moines facility is described as exhibiting a flash point below 60 degrees Celsius. This directly aligns with the definition of an ignitable hazardous waste under IAC 567—100.2(1) and 40 CFR §261.21, which defines ignitable wastes. Therefore, the spent solvent is definitively a hazardous waste due to its ignitability characteristic. The question asks for the most appropriate regulatory classification. While it might also be a listed waste if it appears on the F, K, P, or U lists, the ignitability characteristic is explicitly stated and sufficient for classification as hazardous waste under RCRA. The other options are incorrect because they either misinterpret the criteria for hazardous waste classification or propose classifications not supported by the provided information. For instance, a waste is not hazardous solely because it is generated by a large quantity generator; generator status is a separate regulatory category affecting management requirements. Similarly, toxicity is a characteristic, but the provided information specifically points to ignitability, not toxicity characteristic as defined by the TCLP test.

The Iowa Administrative Code (IAC) 567 Chapter 137 outlines the requirements for hazardous waste management. Specifically, it addresses the criteria for determining if a waste is hazardous. A waste is considered hazardous if it exhibits any of the four characteristics: ignitability, corrosivity, reactivity, or toxicity. For toxicity, the Iowa regulations, mirroring federal RCRA, utilize the Toxicity Characteristic Leaching Procedure (TCLP) to determine if specific contaminants leach from the waste above regulatory thresholds. If a waste fails the TCLP for any of the listed contaminants, it is classified as a hazardous waste under the toxicity characteristic. The question asks about a waste that is not ignitable, corrosive, or reactive but *does* exhibit a characteristic that would render it hazardous. This points directly to the toxicity characteristic. The scenario describes a solid waste from an industrial process in Des Moines, Iowa, that, when subjected to a specific leaching test, releases a particular metal compound at a concentration exceeding the established limit for that metal. This failure of the leaching test, under the framework of IAC 567 Chapter 137, definitively classifies the waste as hazardous due to the toxicity characteristic. The key is understanding that failing *any* of the four characteristic tests, including toxicity as determined by a leaching procedure, results in a hazardous waste classification.

Iowa Administrative Code (IAC) 567 Chapter 133 outlines the requirements for hazardous waste management. Specifically, IAC 567-133.3(455B) addresses generator status and requirements. This section details the criteria for determining whether a facility qualifies as a small quantity generator (SQG) or a large quantity generator (LQG) based on the amount of hazardous waste generated per month. A generator is classified as an SQG if they generate more than 100 kilograms but less than 1,000 kilograms of hazardous waste in a calendar month, and do not generate more than 1 kilogram of acute hazardous waste in a calendar month. A generator is classified as an LQG if they generate 1,000 kilograms or more of hazardous waste in a calendar month, or if they generate more than 1 kilogram of acute hazardous waste in a calendar month. The question posits a scenario where a facility generates 950 kilograms of hazardous waste and 1.5 kilograms of acute hazardous waste in a single month. To determine the generator status, we must evaluate both waste streams against the respective thresholds. The 950 kilograms of hazardous waste falls below the 1,000-kilogram threshold for LQG status. However, the generation of 1.5 kilograms of acute hazardous waste exceeds the 1-kilogram threshold for acute hazardous waste, which automatically classifies the generator as an LQG, regardless of the quantity of non-acute hazardous waste. Therefore, the facility is an LQG.

The Resource Conservation and Recovery Act (RCRA) establishes a framework for managing hazardous waste from its generation to its final disposal. In Iowa, the Department of Natural Resources (IDNR) implements and enforces RCRA regulations. A critical aspect of this framework is the identification and management of hazardous waste. Under RCRA, a solid waste is classified as hazardous if it is specifically listed by the Environmental Protection Agency (EPA) or if it exhibits one or more hazardous characteristics: ignitability, corrosivity, reactivity, or toxicity. The toxicity characteristic is determined through the Toxicity Characteristic Leaching Procedure (TCLP). If a waste fails the TCLP for any of the specified constituents, it is considered a hazardous waste. Iowa’s regulations, mirroring federal standards, require generators to determine if their waste is hazardous. This determination is the foundational step for all subsequent hazardous waste management requirements, including manifesting, storage, treatment, and disposal. Understanding the criteria for hazardous waste identification, particularly the characteristic of toxicity as defined by TCLP, is paramount for compliance. The scenario describes a waste generated by an industrial process in Iowa. The generator must first assess if this waste meets the definition of hazardous waste under RCRA and Iowa’s implementing regulations. This involves checking if the waste is a listed hazardous waste or if it exhibits any of the four hazardous characteristics. The question focuses on the process of determining if a waste exhibits the toxicity characteristic, which is a key component of hazardous waste identification and management in Iowa.

The Iowa Department of Natural Resources (IDNR) enforces regulations for hazardous waste management under the authority of the Iowa Code Chapter 455B and Iowa Administrative Code (IAC) 567 Chapter 131. A key aspect of these regulations pertains to the management of hazardous waste by conditionally exempt small quantity generators (CESQGs). Under federal RCRA Subpart P, and mirrored in Iowa’s regulations, CESQGs have specific requirements. These generators are exempt from certain regulations if they meet stringent criteria regarding the amount of hazardous waste generated per month and the maximum amount stored on-site at any given time. For hazardous waste, a CESQG is defined as a generator who generates no more than 100 kilograms (220 pounds) of hazardous waste in a calendar month. Furthermore, they must not accumulate more than 1,000 kilograms (2,200 pounds) of hazardous waste at any one time. If a CESQG exceeds either of these thresholds in any given month, they immediately lose their CESQG status for that month and all subsequent months until they again meet the criteria. During the month they exceed the limits, they must manage their hazardous waste according to the requirements for a small quantity generator (SQG) or a large quantity generator (LQG), depending on the quantity generated and accumulated in that specific month. This means they must comply with manifest requirements, storage time limits, and potentially obtain an EPA identification number if they become an SQG or LQG. The scenario describes a facility that typically generates 80 kg of hazardous waste per month, placing it within the CESQG category. However, in a specific month, they generated 120 kg. This amount exceeds the 100 kg monthly generation limit for CESQGs. Therefore, for that particular month, the facility is no longer considered a CESQG and must comply with the regulations applicable to a small quantity generator, which includes obtaining an EPA identification number and manifesting shipments. The question asks about the status for the month when the 120 kg was generated.

The Iowa Department of Natural Resources (IDNR) regulates hazardous waste management under the Iowa Code Chapter 455B and Iowa Administrative Code (IAC) 567 Chapter 130 through 139. These regulations are largely aligned with the federal Resource Conservation and Recovery Act (RCRA). A key aspect of these regulations is the definition of hazardous waste and the generator’s responsibility to properly identify and manage it. The concept of “characteristic hazardous waste” is fundamental. A waste exhibits a characteristic if it meets specific criteria for ignitability, corrosivity, reactivity, or toxicity. For toxicity, the IDNR utilizes the Toxicity Characteristic Leaching Procedure (TCLP) as described in IAC 567-131.4(455B). This test simulates the leaching that occurs when waste is disposed of in a landfill. If the leachate from a waste sample contains any of the specified contaminants at or above their regulatory limits, the waste is classified as toxic hazardous waste. The question asks about the minimum number of characteristic hazardous wastes that a generator must identify. The four characteristics are ignitability, corrosivity, reactivity, and toxicity. Therefore, a generator must identify if their waste exhibits any of these four characteristics.

The core of this question lies in understanding the specific exemptions and definitions within Iowa’s hazardous waste regulations, particularly concerning materials generated by small quantity generators (SQGs) and the subsequent management of those wastes. Iowa Administrative Code (IAC) 567 Chapter 137, which implements the Resource Conservation and Recovery Act (RCRA) in Iowa, defines various generator categories. Small Quantity Generators are typically subject to less stringent requirements than large quantity generators. However, certain wastes, even if generated by an SQG, may still be subject to specific management standards or prohibitions if they meet the criteria for acutely hazardous waste or if they are otherwise specifically regulated. The concept of “mixture rule” and “derived-from rule” are also relevant, but the question focuses on a direct exemption or classification. In Iowa, specific provisions often address materials that might otherwise be considered hazardous but are exempted due to their common use or specific management pathways, provided they meet stringent criteria. The scenario describes a facility that generates a waste stream which, while containing certain listed constituents, is managed in a way that aligns with specific exemptions for certain industrial process wastes when handled under controlled conditions and not exhibiting hazardous characteristics. The key is that Iowa law, like federal RCRA, allows for specific exemptions or alternative management standards for certain wastes if they are managed in a manner that prevents endangerment and meets specific regulatory criteria, often detailed in appendices or specific subchapters of the IAC. Without a specific listing of the waste as acutely hazardous or a characteristic of hazardous waste that cannot be managed under an exemption, and given the described management in a closed-loop system that prevents release, the waste is likely not subject to full hazardous waste generator requirements under Iowa’s program for this specific scenario, assuming it does not meet any other disqualifying criteria not mentioned. Therefore, the generator would not be classified as a hazardous waste generator under these specific, described circumstances.

The Iowa Department of Natural Resources (IDNR) implements the federal Resource Conservation and Recovery Act (RCRA) within the state. Under RCRA, specifically 40 CFR Part 262, generators of hazardous waste are required to meet certain requirements based on the quantity of hazardous waste they produce per month. These categories are: Very Small Quantity Generators (VSQGs), Small Quantity Generators (SQGs), and Large Quantity Generators (LQGs). The threshold for an SQG in Iowa, as in the federal regulations, is generating between 100 and 1,000 kilograms (220 to 2,200 pounds) of hazardous waste per month, or accumulating less than 1 kilogram of acute hazardous waste. An LQG is defined as generating 1,000 kilograms or more of hazardous waste per month, or accumulating 1 kilogram or more of acute hazardous waste. A VSQG is defined as generating 100 kilograms or less of hazardous waste per month. The scenario describes a facility that generates 950 kilograms of hazardous waste in a single month. This quantity falls squarely within the SQG category, as it is greater than 100 kg but less than 1,000 kg. Therefore, the facility is classified as a Small Quantity Generator under Iowa’s hazardous waste regulations.

The Iowa Administrative Code (IAC) Chapter 567—117, specifically concerning hazardous waste management, outlines the requirements for hazardous waste generators. Under this chapter, generators are classified based on the quantity of hazardous waste produced per month. A very small quantity generator (VSQG) is defined as a generator who generates less than 100 kilograms (approximately 220 pounds) of hazardous waste per month. This classification dictates specific regulatory requirements, including less stringent storage limits and fewer manifest requirements compared to small quantity generators or large quantity generators. The key distinction for a VSQG is the monthly generation threshold. If a facility generates 100 kilograms or more, but less than 1,000 kilograms, it is classified as a small quantity generator. Generating 1,000 kilograms or more per month classifies a facility as a large quantity generator. Therefore, a facility generating 95 kilograms of hazardous waste in a given month, and 105 kilograms in the subsequent month, would be considered a VSQG in the first month and a small quantity generator in the second month, but the question asks about the classification based on a single month’s generation. The critical factor for VSQG status is staying below the 100 kg threshold in any given month.

The Iowa Administrative Code (IAC) 567 Chapter 20 defines hazardous waste management. Specifically, IAC 567-20.3(455B) addresses the generator’s responsibility for identifying hazardous waste. A generator must determine if their waste is a listed hazardous waste or exhibits a characteristic of hazardous waste as defined in IAC 567-20.2(455B). If a waste is not listed, the generator must test it or use knowledge of the waste’s properties to determine if it exhibits any of the four characteristics: ignitability, corrosivity, reactivity, or toxicity. Toxicity is determined by the Toxicity Characteristic Leaching Procedure (TCLP), outlined in IAC 567-20.2(455B), Table 1. If the TCLP extract from the waste contains any of the specified contaminants at or above the regulatory levels, the waste is considered toxic and thus hazardous. The question asks about a waste that exhibits a characteristic. The provided scenario states that a waste, when subjected to the TCLP, yields a leachate containing lead at a concentration of 25 mg/L. The regulatory limit for lead under the Toxicity Characteristic, as per 40 CFR § 261.24 (which Iowa incorporates by reference and is reflected in IAC 567-20.2(455B), Table 1), is 5.0 mg/L. Since 25 mg/L is greater than 5.0 mg/L, the waste exhibits the toxicity characteristic and is therefore a hazardous waste. The generator’s responsibility is to properly manage this waste according to Iowa’s hazardous waste regulations. This determination is crucial for proper manifesting, storage, transport, and disposal.

The Iowa Administrative Code (IAC) 567 Chapter 133 governs the management of hazardous waste. Specifically, this chapter details the requirements for hazardous waste generators. A generator is defined as any person who produces a hazardous waste or whose act first causes a waste to become subject to hazardous waste regulation. The classification of a generator is based on the quantity of hazardous waste produced per month. Small quantity generators (SQGs) are those who generate more than 100 kilograms but less than 1,000 kilograms of hazardous waste in a calendar month. Large quantity generators (LQGs) generate 1,000 kilograms or more of hazardous waste per month. Very small quantity generators (VSQGs) generate 100 kilograms or less of hazardous waste per month. The question describes a facility in Des Moines, Iowa, that produces 95 kilograms of hazardous waste and 0.5 kilograms of acutely hazardous waste in a calendar month. Acutely hazardous wastes are subject to stricter quantity limits for generator classification. A generator is classified as a VSQG if they generate 100 kilograms or less of hazardous waste in a month AND do not accumulate more than 1 kilogram of acutely hazardous waste in a month. Since this facility generates 95 kilograms of hazardous waste (which is less than 100 kg) and 0.5 kilograms of acutely hazardous waste (which is less than 1 kg), it falls under the Very Small Quantity Generator category. This classification dictates specific regulatory requirements for storage, record-keeping, and disposal, which are less stringent than those for SQGs or LQGs. Understanding these quantity-based thresholds is fundamental to compliance with Iowa’s hazardous waste management program, which aligns with the federal Resource Conservation and Recovery Act (RCRA) framework.

The Iowa Department of Natural Resources (IDNR) implements the Resource Conservation and Recovery Act (RCRA) within the state. Under RCRA, hazardous waste generators are classified based on the quantity of hazardous waste produced per calendar month. These classifications, such as Very Small Quantity Generators (VSQGs), Small Quantity Generators (SQGs), and Large Quantity Generators (LQGs), determine the specific regulatory requirements for waste management, including storage limits, personnel training, emergency preparedness, and record-keeping. A VSQG generates 100 kilograms or less of hazardous waste per month, or 1 kilogram or less of acute hazardous waste per month. An SQG generates more than 100 kilograms but less than 1,000 kilograms of hazardous waste per month. An LQG generates 1,000 kilograms or more of hazardous waste per month, or more than 1 kilogram of acute hazardous waste per month. The scenario describes a facility in Iowa that produces approximately 250 kilograms of hazardous waste per month, and 0.5 kilograms of acute hazardous waste per month. To determine the generator status, we examine the quantities against the thresholds. The 250 kg of hazardous waste places the facility above the VSQG threshold (100 kg) but below the SQG threshold (1,000 kg). The 0.5 kg of acute hazardous waste is below the SQG threshold for acute hazardous waste (1 kg). Therefore, the facility’s generator status is determined by the non-acute hazardous waste quantity, making it a Small Quantity Generator.

The Iowa Department of Natural Resources (IDNR) employs a tiered approach to classifying hazardous waste generators, with the primary distinction being between large quantity generators (LQGs) and small quantity generators (SQGs). This classification is crucial for determining the regulatory requirements a facility must adhere to under both federal Resource Conservation and Recovery Act (RCRA) and Iowa’s specific hazardous waste regulations. The threshold for classification is based on the monthly generation rate of hazardous waste. Specifically, a facility is classified as a large quantity generator if it generates 1,000 kilograms (kg) or more of hazardous waste in a calendar month, or if it accumulates more than 1 kilogram (kg) of acute hazardous waste at any time. A small quantity generator, conversely, generates between 100 kg and 1,000 kg of hazardous waste per month, and accumulates no more than 1,000 kg of hazardous waste at any one time. Very small quantity generators (VSQGs) generate 100 kg or less of hazardous waste per month. The question asks for the generator status that allows for a maximum accumulation of 6,000 kg of hazardous waste per month on-site without exceeding the generator quantity threshold for that status. This specific accumulation limit is a characteristic of the conditionally exempt small quantity generator (CESQG) status, which is now referred to as very small quantity generator (VSQG) under federal regulations. VSQGs can accumulate up to 1,000 kg of non-acute hazardous waste or 1 kg of acute hazardous waste at any time. However, the scenario describes a facility that generates less than 1,000 kg of hazardous waste per month but accumulates 6,000 kg. This accumulation level, when exceeding the VSQG limits, would typically reclassify the facility as a small quantity generator if the monthly generation is between 100 and 1,000 kg, or a large quantity generator if the monthly generation is 1,000 kg or more. Given the options and the common understanding of generator categories, the question is implicitly probing the accumulation limits associated with the *smallest* generator category that still permits significant on-site storage before triggering higher generator status, or the regulatory interpretation of exceeding VSQG limits. The key is that a VSQG can only accumulate up to 1,000 kg. A SQG can accumulate up to 6,000 kg of hazardous waste per month. Therefore, a facility generating less than 1,000 kg per month but accumulating 6,000 kg would be classified as a SQG.

The Iowa Administrative Code (IAC) 567 Chapter 20 defines hazardous waste. Specifically, IAC 567-20.2(455B) outlines the criteria for characteristic hazardous wastes. These characteristics are ignitability, corrosivity, reactivity, and toxicity. A waste exhibits the characteristic of toxicity if, using the Toxicity Characteristic Leaching Procedure (TCLP) outlined in IAC 567-20.3(455B), the extract from the sample contains any of the contaminants listed in 40 CFR Part 261, Appendix VIII, at or above the specified regulatory levels. For the purpose of this question, we are considering a waste that is not listed as hazardous under IAC 567-20.1(455B) but might exhibit a characteristic. The scenario describes a waste exhibiting corrosivity based on its pH. IAC 567-20.2(3) states that a liquid waste is corrosive if it is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5, or if it is a solid waste that corrodes steel (SAE 1020) at a rate greater than 6.35 mm per year when tested in accordance with the methods specified in 40 CFR 261.22(a)(1). The question focuses on a solid waste’s potential to be corrosive, which is determined by its ability to corrode steel. Therefore, a solid waste that corrodes steel at a rate exceeding 6.35 mm per year is considered hazardous due to the characteristic of corrosivity under Iowa law.

The Iowa Department of Natural Resources (IDNR) oversees hazardous waste management within the state, aligning with federal Resource Conservation and Recovery Act (RCRA) regulations. A key aspect of this oversight involves the identification and management of hazardous waste generators. Generators are categorized based on the quantity of hazardous waste they produce per month. Very Small Quantity Generators (VSQGs) generate 100 kilograms or less of hazardous waste per month, or 1 kilogram or less of acutely hazardous waste per month. Small Quantity Generators (SQGs) generate between 100 and 1,000 kilograms of hazardous waste per month. Large Quantity Generators (LQGs) generate 1,000 kilograms or more of hazardous waste per month. The question asks about a facility that produces 150 kilograms of hazardous waste and 0.5 kilograms of acutely hazardous waste in a calendar month. To determine the generator status, we evaluate each waste stream against the respective monthly thresholds. The 150 kilograms of hazardous waste falls within the SQG range (100-1,000 kg). The 0.5 kilograms of acutely hazardous waste is less than the 1 kilogram threshold for acutely hazardous waste. Therefore, the facility’s generator status is determined by the non-acutely hazardous waste quantity. Since 150 kilograms is greater than 100 kilograms but less than 1,000 kilograms, the facility qualifies as a Small Quantity Generator. This classification dictates specific regulatory requirements for storage, record-keeping, and emergency preparedness, as outlined in Iowa Administrative Code Chapter 567.

The Iowa Administrative Code (IAC) Chapter 567—118, specifically the provisions concerning hazardous waste generator requirements, dictates the responsibilities of entities that produce hazardous waste. A key aspect of these regulations involves the proper management and reporting of hazardous waste. Iowa, like many states, implements the Resource Conservation and Recovery Act (RCRA) framework. Under these regulations, generators are classified based on the quantity of hazardous waste produced per month. Small Quantity Generators (SQGs) are subject to less stringent requirements than Large Quantity Generators (LQGs). The determination of generator status is crucial for compliance. For instance, an SQG is generally defined as a generator who produces between 100 and 1,000 kilograms of hazardous waste per month, or less than 1 kilogram of acutely hazardous waste per month. LQGs generate 1,000 kilograms or more of hazardous waste per month, or more than 1 kilogram of acutely hazardous waste per month. The question presents a scenario where a facility generates a specific amount of hazardous waste. To determine the correct regulatory classification and subsequent obligations, one must compare the generated quantities against the established thresholds. In this case, the facility generates 950 kilograms of hazardous waste in a month. This quantity falls within the range of 100 to 1,000 kilograms per month, which defines a Small Quantity Generator in Iowa under IAC 567—118. Therefore, the facility is classified as an SQG.

The Iowa Administrative Code (IAC) Chapter 567, specifically rule 567—117.3, addresses the definition of a “hazardous waste.” This rule establishes criteria for identifying wastes as hazardous, which include exhibiting a characteristic of hazardous waste or being listed as hazardous. Characteristic wastes are defined by specific properties such as ignitability, corrosivity, reactivity, and toxicity. Toxicity is determined through the Toxicity Characteristic Leaching Procedure (TCLP), which simulates leaching in a landfill. If a waste fails the TCLP for any of the regulated constituents at or above the specified regulatory levels, it is classified as a hazardous waste. Iowa’s regulatory framework aligns with federal Resource Conservation and Recovery Act (RCRA) definitions but may have state-specific nuances. Therefore, a waste exhibiting the characteristic of toxicity, as determined by TCLP analysis, is considered hazardous under Iowa law.

The Iowa Administrative Code (IAC) Chapter 567—100, specifically relating to hazardous waste management, defines the responsibilities of generators. For a small quantity generator (SQG) in Iowa, the accumulation time limit for hazardous waste before it must be shipped off-site or to a treatment, storage, and disposal facility (TSDF) is 180 days. This period can be extended to 270 days if the hazardous waste must be transported over 200 miles. The regulations also stipulate that SQGs must not accumulate more than 6,000 kilograms (approximately 13,200 pounds) of hazardous waste at any one time. The core principle is to minimize the on-site storage of hazardous waste by SQGs to encourage timely and compliant disposal or treatment. Understanding these specific accumulation timeframes and quantity limits is crucial for SQGs to maintain compliance with Iowa’s hazardous waste regulations, which are largely based on the federal Resource Conservation and Recovery Act (RCRA) but may have state-specific nuances.

The Iowa Administrative Code (IAC) 567 Chapter 20 defines hazardous waste management. Specifically, IAC 567-20.3 outlines the requirements for generators of hazardous waste. A small quantity generator (SQG) is defined as a generator who generates less than 1,000 kilograms (2,200 pounds) of hazardous waste per month. Furthermore, an SQG must not accumulate more than 6,000 kilograms (13,200 pounds) of hazardous waste on-site at any one time. If an SQG exceeds the 1,000 kg monthly generation limit, they must manage their waste as a large quantity generator (LQG) for that month. If an SQG accumulates more than 6,000 kg of hazardous waste, they are considered an LQG and must comply with LQG regulations for the entire site. The question describes a facility that generates 950 kg of hazardous waste in January and 1,100 kg in February. In March, they generate 900 kg but have 7,000 kg of accumulated waste from previous months. The key is to assess their status based on both monthly generation and accumulation limits. In January, they were an SQG. In February, they exceeded the monthly generation limit for SQGs (1,000 kg), thus becoming an LQG for February. In March, while their monthly generation (900 kg) falls within the SQG limit, their accumulated waste (7,000 kg) exceeds the SQG accumulation limit of 6,000 kg. Therefore, for the month of March, the facility must manage its hazardous waste as a large quantity generator due to exceeding the accumulation limit.

The Iowa Department of Natural Resources (IDNR) establishes specific requirements for hazardous waste generators, including those who manage waste onsite. Under the Iowa Administrative Code (IAC) 567 Chapter 131, a generator is classified based on the quantity of hazardous waste produced per calendar month. A “small quantity generator” (SQG) is defined as a generator who produces between 100 and 1,000 kilograms (kg) of hazardous waste per month, or less than 1 kg of acute hazardous waste per month. A “large quantity generator” (LQG) is defined as a generator who produces 1,000 kg or more of hazardous waste per month, or more than 1 kg of acute hazardous waste per month. A “conditionally exempt small quantity generator” (CESQG) is a generator who produces 100 kg or less of hazardous waste per month, or less than 1 kg of acute hazardous waste per month. In this scenario, Prairie State Manufacturing produces 1,200 kg of hazardous waste per month. This quantity clearly exceeds the 1,000 kg threshold for small quantity generators and falls within the definition of a large quantity generator according to IAC 567 Chapter 131. Therefore, Prairie State Manufacturing must comply with the more stringent regulatory requirements applicable to large quantity generators, which include more extensive record-keeping, personnel training, emergency preparedness, and reporting obligations. This classification is critical for ensuring proper management and disposal of hazardous waste to protect human health and the environment in Iowa.

The Resource Conservation and Recovery Act (RCRA) establishes the framework for managing hazardous waste from its generation to its final disposal. Iowa, like other states, implements RCRA through its own authorized hazardous waste program, which must be at least as stringent as the federal program. A key aspect of RCRA is the definition of hazardous waste, which includes characteristic wastes and listed wastes. Characteristic wastes are those exhibiting ignitability, corrosivity, reactivity, or toxicity. Listed wastes are specifically identified by the U.S. Environmental Protection Agency (EPA) or state agencies as hazardous. For a generator to determine if their waste is hazardous, they must first ascertain if it meets any of the listed waste descriptions. If it does not, they must then test or use knowledge of process to determine if it exhibits any of the four characteristics. Iowa Administrative Code (IAC) 567 Chapter 133 outlines the specific criteria for hazardous waste identification in Iowa, largely mirroring federal regulations. If a waste is determined to be hazardous, the generator must comply with applicable management standards based on their generator status (e.g., very small quantity generator, small quantity generator, or large quantity generator), which dictate requirements for storage, record-keeping, reporting, and transportation. The identification of hazardous waste is a foundational step in the entire hazardous waste management system.

The Resource Conservation and Recovery Act (RCRA) establishes the framework for managing hazardous waste from its generation to its final disposal. In Iowa, as in other states, the Department of Natural Resources (IDNR) implements and enforces these regulations, often incorporating federal standards and potentially adding state-specific requirements. A key aspect of RCRA is the “cradle-to-grave” management system. This system mandates that hazardous waste be tracked from the point of generation through transportation, treatment, storage, and disposal. Generators are responsible for identifying hazardous waste, obtaining an EPA identification number, and complying with accumulation time limits and storage requirements. Transporters must adhere to manifest requirements and proper handling procedures. Treatment, storage, and disposal facilities (TSDFs) must obtain permits and operate in accordance with stringent standards to protect human health and the environment. Iowa Administrative Code (IAC) 567 Chapter 131, “Hazardous Waste Management,” and related chapters, detail these requirements, including specific standards for generators, transporters, and TSDFs. For instance, generator status (e.g., large quantity, small quantity, or conditionally exempt small quantity) dictates the scope of regulations applicable to a facility. The manifest system is a critical tracking document that accompanies hazardous waste shipments, ensuring accountability at each stage. Understanding the roles and responsibilities of each entity within this system is fundamental to compliance.

The Iowa Administrative Code (IAC) Chapter 567-23, specifically subrule 23.1(4), addresses the definition of “hazardous waste.” This subrule outlines the criteria for identifying a solid waste as hazardous, which includes characteristic hazardous wastes (ignitability, corrosivity, reactivity, toxicity) and listed hazardous wastes. For a waste to be considered hazardous under Iowa law, it must meet one of these definitions. The scenario describes a waste generated by a manufacturing process in Iowa that exhibits a characteristic of corrosivity, as defined by the EPA’s characteristic waste criteria, which are adopted by Iowa. Specifically, a liquid waste with a pH less than or equal to 2 or greater than or equal to 12.5, or a solid waste that can corrode steel at a specified rate, is considered corrosive. Since the waste described in the scenario exhibits this characteristic, it is classified as a hazardous waste under Iowa’s regulatory framework, irrespective of whether it is also on a specific federal or state hazardous waste list. The generator’s responsibility to manage this waste according to Iowa’s hazardous waste regulations, including proper identification, storage, transportation, and disposal, is triggered by this classification.

The Iowa Administrative Code (IAC) Chapter 567—117, specifically concerning hazardous waste management, outlines the requirements for hazardous waste generators. A critical aspect is the determination of generator status, which is based on the amount of hazardous waste generated per month. For small quantity generators (SQGs), the threshold is typically between 100 and 1,000 kilograms of hazardous waste per month, or less than 1 kilogram of acutely hazardous waste per month. Large quantity generators (LQGs) generate 1,000 kilograms or more of hazardous waste per month, or more than 1 kilogram of acutely hazardous waste per month. Very small quantity generators (VSQGs) generate 100 kilograms or less of hazardous waste per month. The scenario describes a facility generating 950 kilograms of hazardous waste and 0.5 kilograms of acutely hazardous waste in a given month. Since the hazardous waste generation (950 kg) falls within the SQG range (100-999 kg) and the acutely hazardous waste generation (0.5 kg) is below the SQG threshold for acutely hazardous waste (1 kg), the facility is classified as a small quantity generator. This classification dictates specific requirements for storage, record-keeping, and emergency preparedness under Iowa’s hazardous waste regulations, which are largely aligned with federal RCRA regulations but may have state-specific nuances. Understanding these thresholds is fundamental for compliance.

The Iowa Administrative Code (IAC) 567 Chapter 23, specifically related to hazardous waste management, outlines the requirements for generators. When a generator of hazardous waste changes its status from a large quantity generator (LQG) to a small quantity generator (SQG), this transition is not instantaneous upon exceeding or falling below the threshold. Instead, the IAC, mirroring federal RCRA regulations, establishes a specific timeframe for this status change to take effect. An LQG becomes an SQG on the first day of the calendar month following the month in which they first meet the SQG criteria. Conversely, an SQG becomes an LQG on the first day of the calendar month following the month in which they first exceed the SQG quantity limits. This transitional period is crucial for compliance, ensuring that facilities correctly manage their waste based on their most recent confirmed generator status. For instance, if a facility was an LQG in January and, by the end of February, consistently operated below the LQG thresholds to qualify as an SQG, their SQG status would officially commence on March 1st. During March, they would be subject to SQG requirements. This regulatory nuance prevents abrupt shifts in compliance obligations and allows for a predictable transition in waste management practices.