Mixing Hazardous Waste with Solid Waste

Hazardous wastes generated by generators of all sizes may be mixed with solid wastes, but the mixtures are subject to certain requirements.

Very small quantity generators may mix a portion or all of its hazardous waste with solid waste and remain subject to conditions for exemption for VSQGs, even though the resulting mixture exceeds the quantity limits identified in the definition of a VSQG.

However, if the resulting mixture exhibits one or more of the characteristics of hazardous waste, it is a newly generated hazardous waste and the VSQG must count both the resultant mixture amount plus the other hazardous waste generated in the calendar month to determine whether the total quantity exceeds the quantity limits identified in the definition of the VSQG category. If it does exceed the limits, in order to remain exempt from the permitting, interim status, and operating standards, the very small quantity generator must meet the conditions for exemption applicable to either a small quantity generator or a large quantity generator.

Hazardous wastes generated by a small quantity generator or large quantity generator may also be mixed with solid waste. These mixtures are subject to the following:

• The mixture rule
• The prohibition of dilution rule
• The land disposal restriction requirements, if a characteristic hazardous waste is mixed with a solid waste so that it no longer exhibits the hazardous characteristic
• The hazardous waste determination requirement

If the resulting mixture is found to be a hazardous waste, this resultant mixture is a newly generated hazardous waste and an SQG must count both the resultant mixture amount plus the other hazardous waste generated in the calendar month to determine whether the total quantity exceeds the calendar monthly quantity limits for the SQG category. If so, to remain exempt from the permitting, interim status, and operating standards, the SQG must meet the conditions for exemption applicable to an LQG.

To learn more about RCRA visit our RCRA Hazardous Waste Safety Online Training web page.