Acute Waste Threshold Register

PROBLEM: Acute hazardous waste — P-listed waste — plays by different numbers: more than 1 kg a month makes a facility a large quantity generator regardless of its total waste, and more than 100 kg of acute spill residue or contaminated soil does the same. One kilogram of the wrong waste changes everything about a facility's obligations, yet acute waste is usually tracked inside the same totals as ordinary waste, where 1 kg disappears.

SOLUTION: An acute waste threshold register: acute waste and acute spill residue tracked separately from ordinary hazardous waste, against the 1 kg and 100 kg thresholds, with any month that crosses a threshold flagged — so a kilogram of acute waste is never lost inside a ton of ordinary waste.

EVIDENCE BASIS: DOCUMENTED — >1 kg/month acute hazardous waste or >100 kg/month acute spill residue triggers LQG status; sources: EPA generator regulatory summary; EPA "Categories of Hazardous Waste Generators."