The Ohio Environmental Protection Agency (Ohio EPA) has specific regulations regarding the management of hazardous waste, particularly concerning generators. Under the Ohio Administrative Code (OAC) Chapter 3745-52, a hazardous waste 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 (approximately 220 to 2,200 pounds) of hazardous waste per month, or accumulates no more than 1 kilogram of acute hazardous waste per month. A “large quantity generator” (LQG) is defined as a generator who produces 1,000 kilograms or more of hazardous waste per month, or accumulates 1 kilogram or more of acute hazardous waste per month. An “excepted quantity generator” or “conditionally exempt small quantity generator” (CESQG) is a generator who produces 100 kilograms or less of hazardous waste per month, or accumulates no more than 1 kilogram of acute hazardous waste per month. Therefore, a facility generating 950 kilograms of hazardous waste in a calendar month would fall under the small quantity generator category in Ohio. This classification dictates the specific regulatory requirements for storage, record-keeping, and reporting that the facility must adhere to under Ohio’s hazardous waste program, which is authorized by the U.S. Environmental Protection Agency under the Resource Conservation and Recovery Act (RCRA).

The Ohio Environmental Protection Agency (Ohio EPA) regulates hazardous waste management under the authority of the Ohio Revised Code (ORC) Chapter 3734, often referred to as the “Hazardous Waste Facility Law.” This chapter, along with its corresponding Ohio Administrative Code (OAC) rules, particularly those within OAC Chapter 3745-50 through 3745-69, establishes the framework for identifying, managing, and disposing of hazardous waste within the state. Generators of hazardous waste are subject to specific requirements based on the quantity of waste they produce per month. The regulations define different generator categories: very small quantity generators (VSQGs), small quantity generators (SQGs), and large quantity generators (LQGs). The threshold for classifying a generator as an SQG versus an LQG is a key distinction. Specifically, a generator is classified as an LQG if they accumulate 1,000 kilograms (kg) or more of hazardous waste, or more than 1 kilogram (kg) of acute hazardous waste, at any time during a calendar month. An SQG, conversely, generates between 100 kg and 1,000 kg of hazardous waste per month and does not accumulate more than 1,000 kg of hazardous waste at any time. VSQGs generate 100 kg or less of hazardous waste per month. The scenario describes a facility that generates 1,100 kg of hazardous waste in a month and stores it on-site for 45 days. Since the monthly generation quantity (1,100 kg) exceeds the 1,000 kg threshold for LQGs, and the waste is stored on-site for a period not exceeding 90 days (which is the standard accumulation time for LQGs before shipment), the facility must comply with the regulations applicable to large quantity generators. This includes obtaining an EPA identification number, adhering to manifest requirements for off-site shipment, and meeting stringent storage and record-keeping standards. The question tests the understanding of these generator category thresholds and the implications for compliance under Ohio’s hazardous waste regulations.

The Ohio EPA, under the authority of the Ohio Revised Code (ORC) Chapter 3734, regulates hazardous waste management. A key aspect of this regulation involves the identification and management of hazardous waste. When a generator determines that a solid waste exhibits a characteristic of hazardous waste, as defined in Ohio Administrative Code (OAC) Rule 3745-51-20 through 3745-51-23, they must manage it accordingly. This includes proper storage, labeling, manifesting, and disposal at a permitted treatment, storage, and disposal facility (TSDF). The generator is responsible for accurately classifying their waste. If a waste exhibits ignitability, corrosivity, reactivity, or toxicity, it is considered hazardous. The toxicity characteristic is determined by the Toxicity Characteristic Leaching Procedure (TCLP), outlined in OAC Rule 3745-51-24. If the TCLP extract from a waste contains any of the specified contaminants at or above the regulatory levels, the waste is classified as hazardous. For instance, if a waste generates a TCLP extract with a lead concentration of 6 mg/L, and the regulatory limit for lead is 5 mg/L, then the waste exhibits the toxicity characteristic for lead and must be managed as hazardous waste in Ohio. This classification triggers a cascade of regulatory requirements for the generator.

The Ohio Environmental Protection Agency (Ohio EPA) establishes specific requirements for hazardous waste management, including those related to the accumulation of hazardous waste on-site. For a small quantity generator (SQG) in Ohio, the primary regulation governing on-site accumulation of hazardous waste without a permit is found within the Ohio Administrative Code (OAC), specifically Chapter 3745-52. This chapter details the conditions under which generators can accumulate waste. An SQG, as defined by OAC 3745-52-34, can accumulate hazardous waste on-site for up to 180 days without a storage permit, provided they meet certain conditions. These conditions include not exceeding a quantity limit of 1,000 kilograms (approximately 2,200 pounds) of hazardous waste at any one time, and storing the waste in containers or tanks that meet specific design and management standards. Furthermore, SQGs must have an emergency preparedness and prevention plan and ensure personnel are adequately trained. The question asks about the maximum quantity of hazardous waste an SQG can accumulate on-site without a permit. Based on OAC 3745-52-34(d)(1)(B), the limit is 6,000 kilograms (13,200 pounds) for a period not exceeding 180 days. The explanation incorrectly stated 1,000 kg. The correct limit for an SQG to accumulate hazardous waste on-site for up to 180 days without a storage permit, as per OAC 3745-52-34(d)(1)(B), is 6,000 kilograms.

The scenario describes a facility that generates hazardous waste in Ohio. The question focuses on the generator status determination. Ohio EPA regulations, specifically Ohio Administrative Code (OAC) Chapter 3745-50, define generator categories based on the quantity of hazardous waste produced per month. A Very Small Quantity Generator (VSQG) generates 100 kilograms or less of hazardous waste per month, or 1 kilogram or less of acute hazardous waste per month. A Small Quantity Generator (SQG) generates more than 100 kilograms but less than 1,000 kilograms of hazardous waste per month. A Large Quantity Generator (LQG) generates 1,000 kilograms or more of hazardous waste per month. The facility in the scenario generates 150 kilograms of non-acute hazardous waste and 0.5 kilograms of acute hazardous waste per month. To determine the generator status, we must consider the total hazardous waste generated. The 150 kg of non-acute hazardous waste places the facility beyond the VSQG threshold. The 0.5 kg of acute hazardous waste is also below the VSQG threshold for acute hazardous waste (1 kg or less). However, the presence of 150 kg of non-acute hazardous waste, which is greater than 100 kg but less than 1,000 kg, classifies the facility as a Small Quantity Generator. The acute hazardous waste quantity does not elevate the status in this specific instance because it remains below the SQG threshold for acute hazardous waste (which is also 1 kg or less, but the primary driver here is the non-acute waste quantity). The regulations require aggregation of all hazardous waste generated to determine the status, but the highest category of waste (acute vs. non-acute) and its quantity are critical. In this case, the 150 kg of non-acute waste is the determining factor for classification as a Small Quantity Generator.

The Ohio Environmental Protection Agency (Ohio EPA) categorizes hazardous waste generators based on the quantity of hazardous waste produced per month. These categories are: Very Small Quantity Generators (VSQGs), Small Quantity Generators (SQGs), and Large Quantity Generators (LQGs). 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 between 100 and 1,000 kilograms of hazardous waste per month, and does not generate more than 1 kilogram of acute hazardous waste per month. An LQG generates more than 1,000 kilograms of hazardous waste per month, or more than 1 kilogram of acute hazardous waste per month. In this scenario, the facility produces 950 kilograms of hazardous waste in January and 1100 kilograms of hazardous waste in February. Additionally, it produces 0.5 kilograms of acute hazardous waste in January and 1.5 kilograms of acute hazardous waste in February. For January: Hazardous waste: 950 kg. This is greater than 100 kg but less than 1,000 kg, classifying it as SQG. Acute hazardous waste: 0.5 kg. This is less than or equal to 1 kg, which does not trigger LQG status for acute hazardous waste. For February: Hazardous waste: 1100 kg. This is greater than 1,000 kg, classifying it as LQG. Acute hazardous waste: 1.5 kg. This is greater than 1 kg, which also classifies it as LQG. Since the generator’s status is determined by the highest category met in any given month, and February’s production of both hazardous waste and acute hazardous waste exceeds the thresholds for LQG, the facility is classified as a Large Quantity Generator for the month of February and subsequently for any period where these conditions persist or are exceeded. The question asks for the classification based on the *most recent* monthly activity described, which is February. Therefore, the facility is a Large Quantity Generator.

The Ohio Environmental Protection Agency (Ohio EPA) oversees hazardous waste management under the authority of the Resource Conservation and Recovery Act (RCRA) and its state-specific implementing regulations found in the Ohio Administrative Code (OAC) Chapter 3745-50 through 3745-270. A key aspect of hazardous waste regulation involves the management of universal waste, which is a category of hazardous waste that is commonly generated, relatively low in toxicity, and poses a less significant hazard to human health and the environment when managed appropriately. Universal waste regulations aim to streamline the management of these wastes by reducing the regulatory burden on generators, thereby encouraging proper management and recycling. Ohio has adopted universal waste regulations for several categories, including batteries, pesticides, mercury-containing equipment, and lamps. Under OAC 3745-273, a generator is considered a small quantity handler of universal waste if they accumulate less than 1,000 kilograms of universal waste at any time. Large quantity handlers accumulate 1,000 kilograms or more. The accumulation time limit for universal waste is generally 180 days for handlers located within 200 miles of a designated receiving facility, and 365 days for handlers located more than 200 miles from such a facility. Proper labeling of universal waste containers is critical, requiring the words “Universal Waste—Batteries” (or the specific universal waste type), the accumulation start date, and the handler’s name and address. Emergency preparedness and response requirements are also tailored for universal waste handlers, being less stringent than those for fully regulated hazardous waste facilities. The specific requirements for record-keeping, training, and emergency procedures are detailed within OAC 3745-273.

The Ohio Environmental Protection Agency (Ohio EPA) categorizes hazardous waste generators based on the amount of hazardous waste produced per month. This categorization dictates the specific management standards a facility must follow. The three main categories are: Large Quantity Generators (LQGs), Small Quantity Generators (SQGs), and Very Small Quantity Generators (VSQGs). A facility is classified as a VSQG if it generates 100 kilograms (approximately 220 pounds) or less of hazardous waste per month, or 1 kilogram (approximately 2.2 pounds) or less of acute hazardous waste per month, and accumulates no more than 1,000 kilograms (approximately 2,200 pounds) of hazardous waste at any one time. An SQG generates between 100 and 1,000 kilograms of hazardous waste per month and accumulates no more than 6,000 kilograms (approximately 13,200 pounds) at any one time. An LQG generates over 1,000 kilograms of hazardous waste per month or more than 1 kilogram of acute hazardous waste per month. In this scenario, the facility consistently generates 150 kilograms of hazardous waste per month and has a single shipment of 500 kilograms of hazardous waste that was returned due to a shipping error. The returned waste is considered part of the facility’s on-site accumulation. Therefore, the total hazardous waste accumulated on-site at the end of the month, considering the monthly generation and the returned shipment, is \(150 \text{ kg} + 500 \text{ kg} = 650 \text{ kg}\). This amount, 650 kg, is less than the 1,000 kg threshold for VSQG status and also less than the 6,000 kg threshold for SQG status. However, the question asks about the *monthly generation* which is 150 kg. This places the facility in the SQG category for its ongoing generation activities. The presence of the returned shipment, while affecting total accumulation, does not change the generator status based on monthly generation rates unless it pushes the *total accumulation* above the SQG limit. Since the total accumulation (650 kg) is below the SQG limit of 6,000 kg, the facility remains an SQG based on its monthly generation of 150 kg. The question specifically asks about the generator status based on the *monthly generation* of hazardous waste.

The Ohio Environmental Protection Agency (Ohio EPA) oversees hazardous waste management under the authority of the Ohio Revised Code (ORC) Chapter 3734, often referred to as the hazardous waste management law. This chapter establishes the framework for identifying, managing, and disposing of hazardous waste within the state, aligning with federal regulations under the Resource Conservation and Recovery Act (RCRA). A key aspect of this framework is the requirement for facilities that generate, treat, store, or dispose of hazardous waste to obtain permits or licenses from the Ohio EPA. The definition of a “hazardous waste facility” under ORC 3734.01(F) is broad and encompasses any site where hazardous waste is treated, stored, or disposed of. Furthermore, ORC 3734.02 mandates that no person shall operate a hazardous waste facility without a license issued by the agency. The licensing process involves a thorough review of the facility’s operations, waste streams, and management practices to ensure compliance with environmental protection standards. This licensing requirement is a fundamental mechanism for the Ohio EPA to maintain oversight and control over hazardous waste activities, thereby protecting public health and the environment. Therefore, any entity engaged in these activities must secure the appropriate license.

The Ohio Environmental Protection Agency (Ohio EPA) has specific requirements for the management of hazardous waste. Under Ohio Administrative Code (OAC) Chapter 3745-52, which largely mirrors federal regulations under the Resource Conservation and Recovery Act (RCRA), generators of hazardous waste are responsible for determining if their waste is hazardous. This determination is a critical first step. If a waste is determined to be hazardous, it must be managed according to the applicable regulations, which include manifesting for off-site shipment, proper storage, and disposal at a permitted facility. The concept of “cradle-to-grave” management is central, meaning the generator remains responsible for the waste until it is properly disposed of. The specific requirements for a generator depend on their generator status (e.g., large quantity, small quantity, or conditionally exempt small quantity generator), which is determined by the amount of hazardous waste they produce per month. However, the fundamental obligation to correctly identify and manage hazardous waste applies universally to all generators. The scenario presented focuses on a facility that has identified a waste stream. The question then probes the immediate regulatory obligation following this identification, assuming the waste is indeed hazardous. The correct regulatory pathway involves ensuring the waste is managed according to its hazardous characteristics, which includes proper labeling, accumulation, and preparation for transport, adhering to all applicable Ohio EPA and federal RCRA requirements for hazardous waste management.

The Ohio EPA, under the authority of the Ohio Revised Code (ORC) Chapter 3734, regulates hazardous waste management. A key aspect of this regulation is the identification and management of hazardous waste. The definition of hazardous waste in Ohio generally aligns with the federal Resource Conservation and Recovery Act (RCRA) but can also include wastes identified as hazardous by the Ohio EPA through specific criteria. A waste is classified as hazardous in Ohio if it is specifically listed by the Ohio EPA as hazardous or if it exhibits one or more hazardous characteristics: ignitability, corrosivity, reactivity, or toxicity. The toxicity characteristic is determined by the Toxicity Characteristic Leaching Procedure (TCLP), outlined in Ohio Administrative Code (OAC) Rule 3745-51-24. If a waste exhibits any of these characteristics or is listed, it is subject to the hazardous waste regulations. The question asks about a waste that is not specifically listed but exhibits a hazardous characteristic. The scenario describes a waste that, when subjected to the TCLP, shows leachate concentrations of specific contaminants exceeding the regulatory thresholds defined in OAC Rule 3745-51-24, Appendix VII. This directly indicates the waste possesses the toxicity characteristic. Therefore, the waste is considered hazardous by definition under Ohio law, irrespective of whether it is explicitly listed.

The Ohio Environmental Protection Agency (Ohio EPA) categorizes hazardous waste based on its characteristics and source. Characteristic hazardous wastes are those that exhibit one or more of the following properties: ignitability, corrosivity, reactivity, or toxicity. Listed hazardous wastes are specific wastes identified by the U.S. Environmental Protection Agency (EPA) or the Ohio EPA as hazardous due to their origin or composition, such as wastes from specific industrial processes or discarded commercial chemical products. Ohio Administrative Code (OAC) Rule 3745-51-11 defines ignitability. A liquid waste is considered ignitable if it has a flash point below \(60^\circ C\) (\(140^\circ F\)). A solid waste is ignitable if it is capable of causing fire through friction, moisture absorption, or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard. An ignitable compressed gas is defined by its flammability. Oxidizers are also considered ignitable. Ohio EPA’s hazardous waste management program, primarily governed by OAC Chapter 3745-51, aligns with the federal Resource Conservation and Recovery Act (RCRA). Facilities generating, transporting, treating, storing, or disposing of hazardous waste must comply with these regulations. The determination of whether a waste is hazardous under Ohio law involves a multi-step process, including checking if it is a listed waste and, if not, evaluating it for hazardous characteristics. This classification dictates the management standards that apply to the waste.

The scenario describes a facility in Ohio that generates a hazardous waste stream containing spent solvents exhibiting the characteristic of ignitability. The generator is a small quantity generator (SQG) based on their overall monthly hazardous waste generation rate. For SQGs, the accumulation time limit for hazardous waste is 180 days, unless the waste is transported to a facility located more than 200 miles away, in which case the limit is extended to 270 days. The waste in question is stored in drums. The core of the question lies in understanding the SQG accumulation time limits and how they apply to on-site storage. The Ohio Administrative Code (OAC) Chapter 3745-52 governs hazardous waste generator requirements. Specifically, OAC 3745-52-17 details the accumulation of hazardous waste for SQGs. This rule permits SQGs to accumulate hazardous waste on-site for up to 180 days without a permit, provided they meet certain conditions, including proper container management and marking. If the generator can demonstrate that transporting the waste to a facility over 200 miles away is necessary, the accumulation period can be extended to 270 days. The question implies the waste is being stored on-site and the generator needs to comply with the accumulation time limits. Therefore, the maximum permissible on-site storage duration without a permit, assuming the destination is within 200 miles, is 180 days. If the destination is beyond 200 miles, it can be 270 days. Since the question does not specify the distance to the treatment facility, the most common and general SQG limit applies.

The scenario presented involves a generator in Ohio that produces a waste stream exhibiting characteristics of ignitability and corrosivity, as defined by the Resource Conservation and Recovery Act (RCRA) and further elaborated by Ohio Administrative Code (OAC) Chapter 3745-51. Specifically, the waste has a flash point below 60 degrees Celsius (140 degrees Fahrenheit) and a pH less than or equal to 2. These characteristics classify the waste as hazardous. Under Ohio’s hazardous waste regulations, generators are responsible for determining if their waste is hazardous. Once a waste is determined to be hazardous, it must be managed according to the regulations applicable to its generator status (e.g., very small quantity generator, small quantity generator, or large quantity generator). The key regulatory requirement is that hazardous waste must be properly identified, managed, and disposed of at a permitted treatment, storage, and disposal facility (TSDF). The specific hazardous waste codes associated with these characteristics are D001 for ignitability and D002 for corrosivity. Therefore, the waste is a hazardous waste due to both ignitability and corrosivity.

The question probes the understanding of the definition of a “mixture” as it pertains to hazardous waste under Ohio EPA regulations, specifically referencing the criteria that would exempt a material from being classified as a hazardous waste solely due to its admixture. Under Ohio Administrative Code (OAC) Chapter 3745-51, a solid waste is considered hazardous if it exhibits a characteristic of hazardous waste or is listed as hazardous. However, certain mixtures are excluded. The key to this question lies in understanding when a mixture’s hazardous characteristics are solely derived from a listed hazardous waste component and whether the admixture process itself alters the fundamental nature or toxicity of the waste in a way that aligns with the regulatory intent of exclusion. Specifically, if a non-hazardous solid waste is mixed with a listed hazardous waste, and the resultant mixture is hazardous *only* because of the listed hazardous waste component, and if the generator can demonstrate that the mixture does not exhibit any hazardous characteristics (e.g., ignitability, corrosivity, reactivity, toxicity) beyond those inherent to the listed component, then the mixture might be excluded from certain hazardous waste management requirements under specific conditions. This exclusion is not automatic and requires careful evaluation of the waste streams and the mixing process, ensuring no new hazardous properties are created or amplified. The Ohio EPA’s interpretation and application of these rules, often aligning with federal RCRA interpretations, focus on preventing the dilution or “disguising” of hazardous waste through mixing. Therefore, the scenario where a non-hazardous solid waste is mixed with a listed hazardous waste, and the resulting mixture’s hazardous nature is solely attributable to the listed component, without introducing new hazardous characteristics, is the most likely scenario for potential exclusion or exemption from certain hazardous waste management requirements, provided all other regulatory conditions are met.

Ohio Administrative Code (OAC) rule 3745-52-10 governs the management of hazardous waste by small quantity generators (SQGs). SQGs are defined by their weekly or monthly generation of hazardous waste. Specifically, an SQG is a generator who generates more than 100 kilograms but less than 1,000 kilograms of hazardous waste in a calendar month, or who generates more than 1 kilogram but less than 100 kilograms of acute hazardous waste in a calendar month. Generators who produce 1,000 kilograms or more of hazardous waste in a calendar month are considered large quantity generators (LQGs). The regulatory requirements for SQGs are less stringent than those for LQGs, reflecting the reduced risk associated with smaller volumes of hazardous waste. For instance, SQGs have longer accumulation time limits and different personnel training requirements compared to LQGs. The key distinction lies in the quantity of hazardous waste generated per month. A facility generating 150 kilograms of hazardous waste and 5 kilograms of acute hazardous waste in a given month would be classified as an SQG because neither threshold for LQG status (1,000 kg of hazardous waste or 100 kg of acute hazardous waste) has been met. The acute hazardous waste threshold is significantly lower and is a separate consideration from the general hazardous waste threshold.

The Ohio Environmental Protection Agency (Ohio EPA) oversees hazardous waste management under the authority of the Ohio Revised Code (ORC) Chapter 3734. This chapter, along with the Ohio Administrative Code (OAC) Chapter 3745-50 through 3745-270, establishes the framework for hazardous waste identification, generation, transportation, treatment, storage, and disposal. Generators of hazardous waste are categorized based on the quantity of hazardous waste they produce per month. These categories include very small quantity generators (VSQGs), small quantity generators (SQGs), and large quantity generators (LQGs). The specific requirements for each category vary significantly. For instance, VSQGs have the least stringent requirements, often exempt from many permitting and manifest requirements, provided they meet certain accumulation time limits and quantity thresholds. SQGs have more obligations than VSQGs but fewer than LQGs, typically involving manifest usage, record-keeping, and specific accumulation limits. LQGs face the most comprehensive regulatory burdens, including strict on-site accumulation time limits, detailed contingency plans, personnel training, biennial reporting, and adherence to stringent manifest and record-keeping protocols. The scenario describes a facility that generates 1,500 kilograms of hazardous waste in a calendar month. This quantity clearly places the facility into the Large Quantity Generator (LQG) category, as the threshold for LQGs is generation of 1,000 kilograms or more of hazardous waste per calendar month, or the generation of 1 kilogram or more of acute hazardous waste per calendar month, or the accumulation of more than 6,000 kilograms of hazardous waste at any time. Therefore, the facility must comply with all applicable LQG requirements as outlined in Ohio’s hazardous waste regulations.

The Ohio Environmental Protection Agency (Ohio EPA) utilizes the Resource Conservation and Recovery Act (RCRA) framework for hazardous waste management. Under RCRA, specific criteria define what constitutes hazardous waste. These criteria include listing specific wastes as hazardous (listed wastes) and wastes exhibiting hazardous characteristics (characteristic wastes). Characteristic wastes are identified by ignitability, corrosivity, reactivity, and toxicity. The toxicity characteristic is determined through the Toxicity Characteristic Leaching Procedure (TCLP). If a waste fails the TCLP for any of the specified contaminants above regulatory thresholds, it is classified as a hazardous waste. For instance, if a solid waste from a metal plating facility in Ohio contains lead at a concentration of 8.0 mg/L after undergoing the TCLP, and the regulatory limit for lead under the toxicity characteristic is 5.0 mg/L, then this waste would be classified as a characteristic hazardous waste due to toxicity. This classification triggers stringent management requirements for generation, transportation, treatment, storage, and disposal, as mandated by the Ohio Administrative Code (OAC) Chapter 3745-51. The core principle is to prevent harm to human health and the environment.

The Ohio Environmental Protection Agency (Ohio EPA) regulates hazardous waste management under the authority of the Ohio Revised Code (ORC) Chapter 3734, often referred to as the “Hazardous Waste Management Act.” This chapter, along with the corresponding Ohio Administrative Code (OAC) rules, particularly Chapter 3745-50 through 3745-69, establishes the framework for hazardous waste identification, generation, transportation, treatment, storage, and disposal within the state. A critical aspect of this regulatory scheme is the concept of “generator status,” which determines the specific requirements a facility must adhere to based on the quantity of hazardous waste it produces within a calendar month. Ohio EPA categorizes generators into three main tiers: very small quantity generators (VSQGs), small quantity generators (SQGs), and large quantity generators (LQGs). These classifications are primarily based on the amount of hazardous waste generated per month, as well as the amount of acute hazardous waste generated per month. VSQGs are subject to the least stringent requirements, typically needing to manage their waste in a manner that prevents release to the environment and to dispose of it at an authorized facility. SQGs have more stringent requirements, including obtaining an EPA identification number, adhering to specific storage limits and timeframes, and manifesting shipments of hazardous waste. LQGs face the most comprehensive set of regulations, encompassing detailed record-keeping, reporting, personnel training, contingency planning, and more rigorous management standards for treatment, storage, and disposal facilities. The distinction between these categories is crucial for compliance, as exceeding the generation thresholds for a particular category can result in a facility being reclassified to a more stringent generator status, thereby triggering a new set of regulatory obligations under Ohio law. Understanding these thresholds and their implications is fundamental for any entity managing hazardous waste in Ohio.

The scenario involves a generator in Ohio that has accumulated hazardous waste on-site for longer than the allowed time period under the Resource Conservation and Recovery Act (RCRA) as implemented by Ohio EPA. Specifically, the waste has been stored for 180 days and the generator is a large quantity generator (LQG). LQGs are permitted to accumulate hazardous waste on-site for 90 days in approved containers or tanks. Exceeding this timeframe without proper authorization or shipment constitutes a violation. The question probes the regulatory status of the waste once the accumulation period is exceeded. When a generator exceeds the 90-day accumulation limit (or 180 days for small quantity generators, or 270 days for generators accumulating waste off-site at a third-party facility) without proper management, the waste is considered to be “accumulated without benefit of a RCRA permit or interim status.” This designation triggers more stringent regulatory requirements, often aligning with those of treatment, storage, and disposal facilities (TSDFs), even if the waste remains on the generator’s property. The generator would need to either ship the waste to a permitted TSDF or obtain a RCRA permit for on-site storage, which is a complex and lengthy process. Therefore, the waste is no longer merely “generator accumulated waste” but has transitioned into a status requiring a higher level of regulatory control due to the temporal violation. This emphasizes the critical nature of adhering to accumulation time limits to maintain generator status and avoid the more burdensome requirements associated with unauthorized accumulation.

Ohio’s hazardous waste regulations, primarily found within the Ohio Revised Code (ORC) Chapter 3734 and Ohio Administrative Code (OAC) Chapter 3745-50 through 3745-271, establish a comprehensive framework for managing hazardous waste from generation to disposal. A key aspect of this framework is the identification and management of hazardous waste. The Ohio Environmental Protection Agency (Ohio EPA) adopts regulations that are largely, but not entirely, identical to the federal Resource Conservation and Recovery Act (RCRA) regulations. Generators of hazardous waste are responsible for determining if their waste is hazardous. This determination involves consulting lists of hazardous wastes (listed wastes) and evaluating waste characteristics (characteristic wastes). Characteristic wastes exhibit ignitability, corrosivity, reactivity, or toxicity. The toxicity characteristic is determined by the Toxicity Characteristic Leaching Procedure (TCLP). If a waste meets any of these criteria, it is considered hazardous. The generator must then obtain an EPA identification number and comply with accumulation time limits, storage requirements, manifesting procedures for off-site shipment, and record-keeping obligations. Ohio EPA oversees compliance through inspections and enforcement actions. The specific requirements for a generator depend on the quantity of hazardous waste they produce per month, categorizing them as either a large quantity generator, a small quantity generator, or a very small quantity generator, each with distinct regulatory burdens.

The Ohio Environmental Protection Agency (Ohio EPA) regulates hazardous waste management under the framework established by the Resource Conservation and Recovery Act (RCRA) and its state-specific implementing regulations. A critical aspect of this regulation involves the management of hazardous waste containers. Specifically, Ohio Administrative Code (OAC) Chapter 3745-52 addresses the standards applicable to generators of hazardous waste. For a generator to accumulate hazardous waste on-site for a period exceeding 90 days but not exceeding 180 days, they must meet certain requirements. One such requirement, outlined in OAC 3745-52-16(A)(3), pertains to the quantity of waste that can be accumulated. A large quantity generator (LQG), as defined by OAC 3745-52-10, can accumulate up to 6,000 kilograms (approximately 13,228 pounds) of hazardous waste in a single accumulation area. Accumulating more than this threshold, or exceeding the 180-day time limit without proper authorization, would necessitate a hazardous waste storage permit or an extension, and could lead to non-compliance. The question focuses on the specific quantity limit for a particular accumulation scenario, testing the generator’s knowledge of the 90-day to 180-day accumulation period for LQGs in Ohio. The calculation is a direct recall of the regulatory limit: 6,000 kilograms.

The scenario presented involves a facility in Ohio that generates hazardous waste. The core of the question revolves around understanding the specific requirements for a generator who accumulates hazardous waste on-site for a period exceeding 90 days but not exceeding 180 days, and who intends to ship this waste to a treatment, storage, and disposal facility (TSDF) that is also located within Ohio. Under Ohio Administrative Code (OAC) Rule 3745-52-10, a hazardous waste generator who accumulates waste on-site for more than 90 days but less than 180 days is classified as a “large quantity generator” if they meet certain accumulation quantity limits. However, the question specifies a situation where the generator is not a large quantity generator and is shipping to an in-state TSDF. This particular scenario falls under the provisions for generators who are not yet large quantity generators but have accumulated waste for longer than the typical 90-day limit. Ohio EPA regulations, specifically OAC Chapter 3745-52, govern generator requirements. While federal regulations under 40 CFR Part 262 provide the framework, Ohio has adopted these with specific state-level modifications. When a generator accumulates hazardous waste for more than 90 days but less than 180 days, and is not a large quantity generator, they must still meet specific manifest requirements and ensure proper transportation. The key distinction here is the generator’s status and the destination of the waste. The requirement to obtain an EPA identification number is fundamental for any entity that generates, transports, treats, stores, or disposes of hazardous waste. This identification number is a prerequisite for all regulated activities. Therefore, even if the waste is being shipped within Ohio to an in-state TSDF, and the generator is not a large quantity generator, obtaining an EPA identification number is a mandatory step before the waste can be legally transported. The question tests the understanding that the EPA ID number is a universal requirement for regulated hazardous waste activities, regardless of the generator’s size category or the destination of the waste within the state, as long as it is being shipped off-site for management.

The Ohio Environmental Protection Agency (Ohio EPA) regulates hazardous waste management under the authority of the Resource Conservation and Recovery Act (RCRA) and its state-specific implementing regulations, primarily found in the Ohio Administrative Code (OAC) Chapter 3745-50 through 3745-69. A key aspect of this regulation is the generator status, which dictates the requirements a facility must adhere to. Generators are classified based on the quantity of hazardous waste they produce per calendar month. A Very Small Quantity Generator (VSQG) is defined as a generator who generates 100 kilograms (220 pounds) or less of hazardous waste per month, or 1 kilogram (2.2 pounds) or less of acute hazardous waste per month, or less than or equal to 1 metric ton (2200 pounds) of hazardous waste in any single calendar month. A Small Quantity Generator (SQG) is defined as a generator who generates more than 100 kilograms but less than 1,000 kilograms (2,200 pounds) of hazardous waste per month. A Large Quantity Generator (LQG) is defined as a generator who generates 1,000 kilograms (2,200 pounds) or more of hazardous waste per month, or more than 1 kilogram (2.2 pounds) of acute hazardous waste per month. The scenario describes a facility generating 150 kilograms of hazardous waste in January and 200 kilograms in February. Since the generator status is determined by the *maximum* amount of hazardous waste generated in *any* single calendar month, and the facility generated 200 kilograms in February, it exceeds the 100-kilogram threshold for VSQG and falls below the 1,000-kilogram threshold for LQG. Therefore, the facility is classified as a Small Quantity Generator for both months.

The scenario presented concerns the management of a specific type of waste by a generator in Ohio. The generator produces a waste stream that exhibits the characteristic of toxicity as defined under Ohio Administrative Code (OAC) Chapter 3745-51. Specifically, the waste, when subjected to the Toxicity Characteristic Leaching Procedure (TCLP) in accordance with OAC 3745-51-24, yields a leachate concentration of lead at 8.5 mg/L. Under OAC 3745-51-22, a solid waste is classified as hazardous if it exhibits any of the characteristics of hazardous waste, including toxicity. The TCLP regulatory limit for lead is 5.0 mg/L. Since the determined leachate concentration of 8.5 mg/L exceeds the regulatory limit of 5.0 mg/L, the waste is classified as a hazardous waste due to toxicity. This classification triggers the requirements of the Resource Conservation and Recovery Act (RCRA) as implemented by Ohio EPA, including generator status determination, manifesting, and proper storage, treatment, and disposal. The generator must therefore manage this waste as hazardous waste, adhering to all applicable federal and state regulations for hazardous waste generators, transporters, and treatment, storage, and disposal facilities (TSDFs). This includes proper identification, labeling, accumulation time limits, personnel training, contingency planning, and record-keeping as outlined in OAC Chapter 3745-52 for hazardous waste generators. The correct classification as hazardous waste is fundamental to ensuring environmental protection and compliance with Ohio’s hazardous waste management program.

Ohio Administrative Code (OAC) rule 3745-52-10 addresses the management of universal waste. Universal waste, as defined in OAC 3745-52-10(A), includes certain batteries, pesticides, mercury-containing equipment, and lamps that are widely generated. Generators of universal waste are subject to less stringent management standards compared to hazardous waste generators. Specifically, OAC 3745-52-10(E)(1) allows universal waste handlers to accumulate universal waste for up to one year from the date it is generated or received, provided they maintain records demonstrating that the total quantity handled does not exceed certain limits and that the waste is managed in accordance with the rule. The rule also requires that handlers manage universal waste in a way that prevents release to the environment and that all universal waste is either sent to a universal waste destination facility, a recycling facility, or a treatment facility. The key distinction for a universal waste handler is the ability to accumulate for a longer period and with fewer manifest requirements than typical hazardous waste. The question tests the understanding of the primary regulatory difference in accumulation time for universal waste compared to hazardous waste, which is a fundamental concept in managing these waste streams under Ohio law.

The Ohio Environmental Protection Agency (Ohio EPA) regulates hazardous waste management under the authority of the Ohio Revised Code (ORC) Chapter 3734, often referred to as the “Hazardous Waste Management Act.” This chapter, along with the corresponding Ohio Administrative Code (OAC) rules, particularly Chapter 3745-50 through 3745-69, establishes the framework for hazardous waste identification, generation, transportation, treatment, storage, and disposal within the state. A key aspect of this framework is the generator’s responsibility to determine if a solid waste is a hazardous waste. This determination is primarily guided by the criteria outlined in OAC 3745-51-02 and 3745-51-03. OAC 3745-51-03 specifically details the characteristics of hazardous waste: ignitability, corrosivity, reactivity, and toxicity. If a solid waste exhibits any of these characteristics, it is classified as a hazardous waste. Furthermore, OAC 3745-51-04 through 3745-51-11 list specific wastes that are also deemed hazardous. For a generator to correctly classify a waste, they must conduct a thorough analysis, which may involve laboratory testing or applying knowledge of the waste’s origin and composition, to ascertain if it meets any of the characteristic definitions or is a listed hazardous waste. This initial classification is fundamental to complying with all subsequent hazardous waste management requirements in Ohio, including manifesting, record-keeping, and reporting.

The Ohio Environmental Protection Agency (Ohio EPA) regulates hazardous waste management under the authority of the Ohio Revised Code (ORC) Chapter 3734 and associated administrative rules, primarily Chapter 3745-50 through 3745-69 of the Ohio Administrative Code (OAC). These regulations are largely based on the federal Resource Conservation and Recovery Act (RCRA). A key aspect of hazardous waste management is the determination of whether a waste is hazardous. This determination involves a multi-step process. First, a generator must determine if their waste is excluded from regulation under OAC 3745-51-04. If not excluded, the generator must then determine if the waste is listed as hazardous (OAC 3745-51-11 through 3745-51-24) or if it exhibits a hazardous characteristic (OAC 3745-51-20 through 3745-51-24). The characteristics are ignitability, corrosivity, reactivity, and toxicity. For toxicity, generators often use the Toxicity Characteristic Leaching Procedure (TCLP) test, as outlined in OAC 3745-51-24, to determine if specific contaminants leach from the waste at concentrations exceeding regulatory thresholds. If a waste meets any of these criteria, it is considered a hazardous waste and must be managed accordingly, including proper storage, transportation, and disposal. The question asks about the primary mechanism by which a waste becomes regulated as hazardous if it is not specifically listed. This points to the characteristic waste provisions. The characteristic of toxicity is assessed by comparing the leachate concentration of certain contaminants to specified regulatory levels. Therefore, a waste is considered hazardous due to toxicity if it fails the TCLP test for any of the regulated constituents.

The scenario describes a facility in Ohio that generates hazardous waste. The core of the question lies in determining the appropriate regulatory framework for managing this waste, specifically regarding record-keeping requirements. Ohio Administrative Code (OAC) Chapter 3745-52 governs hazardous waste generator requirements. Within this chapter, OAC 3745-52-40 specifically addresses the record-keeping obligations for hazardous waste generators. This rule mandates that generators must maintain records of all hazardous waste generated, including manifests, test results, and other information necessary to demonstrate compliance with the hazardous waste regulations. The required retention period for these records, as per OAC 3745-52-40(a), is a minimum of three years from the date the waste is no longer subject to the requirements of OAC 3745-52. This three-year period is crucial for demonstrating compliance during potential inspections or audits by the Ohio Environmental Protection Agency (Ohio EPA). Therefore, the facility must retain its hazardous waste generation records for at least three years.

The Ohio Environmental Protection Agency (Ohio EPA) employs a rigorous process for classifying solid waste as hazardous. This classification hinges on whether the waste exhibits characteristics of hazardous waste or is listed as hazardous. Characteristic wastes, as defined under Ohio Administrative Code (OAC) Chapter 3745-51, include ignitability, corrosivity, reactivity, and toxicity. For toxicity, the Toxicity Characteristic Leaching Procedure (TCLP) is utilized, outlined in OAC 3745-51-22. If a waste, when subjected to TCLP, leaches any of the specific contaminants listed in OAC 3745-51-24 at or above the regulatory thresholds, it is classified as a toxic hazardous waste. For example, if a waste sample, after TCLP testing, shows a concentration of lead of 5.5 milligrams per liter, this would exceed the regulatory limit of 5.0 milligrams per liter for lead, thus rendering the waste a characteristic hazardous waste due to toxicity. Listed wastes, on the other hand, are specifically identified by the Ohio EPA in OAC 3745-51-23 due to their inherent hazardous properties, regardless of whether they exhibit a characteristic. These lists include generic wastes from common industrial processes (F-list), discarded commercial chemical products (P-list and U-list), and specific wastes from particular industries or processes (K-list). A generator must determine if their waste falls into any of these categories. If a waste is not listed and does not exhibit any of the hazardous characteristics, it is considered non-hazardous solid waste. The generator bears the responsibility of making this hazardous waste determination, often through testing or process knowledge.