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14 St. B. Tex. Envtl. L.J. 1 (1983-1984)
A Critical Examination of the Small Quantity Generator Exemption

handle is hein.journals/txenvlw14 and id is 39 raw text is: ICERS IRMAN k Sk Ilern s Tech University ol of Law ock, Texas 79409 742-3791 IRMAN-ELECT ,an Radford City Tower ;ton, Texas 77002 651-2496 -CHAIRMAN .rt Lloyd ; 302 Jacinto Bldg. in. Texas 78701 )478-9506 RETARY a Dutton i Republic Bank Dallas Bldg. is, Texas 75201 655-2855 ASURER nas Buckle W. 11th Street in, Texas 78701 478-4651 RD ADVISOR im Ellis 'ORS OF JOURNAL 'OR Cross Box 12548 in. Texas 78711 475-4143 EDITOR (AIR) Turney I Hwy. 290 East in. Texas 78723 ODITOR (CASES) .y N. Lynch Box 12548 in, Texas 78711 EDITOR (PUBLICATIONS) dCrain . Box 13087 in, Texas 78711 EDITOR (SOLID WASTE) Reagan 13087 in, Texas 78711 --DITOR (SURFACE MINING) innah Robinson 13087 in, Texas 78711 EDITOR (WATER QUALITY) ny Alan Halt W. 15th in. Texas 78701 EDITOR (WATER RIGHTS) inne Schwartz 13087 in, Texas 78711 A CRITICAL EXAMINATION OF THE SMALL QUANTITY GENERATOR EXEMPTION JOHN A. CONNOR AND JAMES B. BLACKBURN, JR. INTRODUCTION Major controversy in reauthorization of the 1976 Resource Conservation and Recovery Act (RCRA)1 has centered on appropriate regulatory policy regarding the so-called small-quantity generator of hazardous wastes. Under RCRA mandate, the U.S. Environmental Protection Agency (EPA) has established comprehensive regulations governing the generation, transporta- tion, and disposal of hazardous waste materials.2 However, for the purpose of administrative efficiency, the EPA has chosen to exempt from this regulatory program the nation's many small- quantity generators - those commercial establishments generating less than 1000 kilograms of hazardous waste per month. Consequently, hazardous wastes produced by metal fabricators, auto repair shops, printers, dry cleaners, and the numerous minor industries qualifying as small- quantity generators (SQG's) are not subject to full RCRA requirements and may be legally disposed in municipal landfills not designed for long-term containment of hazardous chemicals. On the basis of technical information developed by the TRW Corporation,3 the EPA contends that the total volume of hazardous waste produced by SQG's is too small to pose a serious environ- mental threat, regardless of the manner in which this waste is disposed. However, this contention has been challenged in a recent study by the U.S. Office of Technology Assessment (OTA)4 which suggests that SQG's may account for as much as 10% of the national hazardous waste stream - a waste load that could seriously endanger both public health and the environment if improperly regulated. In response to the OTA findings, concerned members of Congress have proposed a RCRA amendment requiring the EPA to reduce the small-quantity generator exemption limit significantly - an action strongly opposed by the EPA due to the extreme administrative expense involved,5 IN THIS ISSUE... TROUBLED TEXAS AIR CONTROL BOARD FACES SUNSET GLARE Jo Clifton See page 6.

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