[Sqg-program] Management of CESQG Waste at HHW Collection Centers Generated from Methamphetamine Clandestine Drug Labs in Florida

[Perrigan, Glen]

The purpose of this email is to provide guidance for Florida's Household Hazardous Waste Collection Centers (HHW Centers) that wish to accept hazardous waste generated from illegal methamphetamine clandestine drug labs.

Hazardous waste generated from illegal methamphetamine clandestine drug labs in Florida is not exempted household hazardous waste in 40 CFR 261.4(b)(1).  A hazardous waste determination must be made for all solid waste generated from a clandestine drug lab. One management option for clandestine drug labs identified as a Conditionally Exempt Small Quantity Generator (CESQG) is to send the hazardous waste to a HHW Center that is authorized to manage CESQG waste.

HHW Centers may be authorized to receive and manage CESQG waste pursuant to Rule 62-730.220(5), Florida Administrative Code, without being considered a hazardous waste generator.  Since HHW facilities are allowed to commingle HHW and CESQG waste, they may commingle HHW and CESQG waste and still retain their non-handler status.

To facilitate the process for HHW Centers that are interested in receiving a CESQG management authorization, the following procedures are recommended.
The Household Hazardous Waste Collection Program should:

1)      Submit a letter to the Hazardous Waste Regulation Section, Bob Martinez Center, MS 4560, 2600 Blair Stone Rd., Tallahassee, Florida 32399 showing the HHW Center has received or is receiving a DEP HHW grant.

2)      Have an EPA Identification Number.

a.       If this number has not been obtained then submit form 8700-12FL<http://www.dep.state.fl.us/waste/quick_topics/forms/pages/62-730.htm> requesting an EPA Identification Number. Check box 9.A.(5) on the form 8700-12FL indicating the facility is applying for an authorization to manage CESQG waste generated at other facilities. Identify the facility as a non-handler of hazardous waste.

3)      Attach documentation providing information on facility-specific operating conditions, including a general description how the hazardous materials are diverted and stored, how long they are stored, and how they are properly managed.



For a generic letter that addresses 1, 2 and 3 above and can be modified for your program, see http://www.dep.state.fl.us/waste/categories/hazardous/pages/publications.htm, select "Management of CESQGs Waste at Household Hazardous Waste Facilities<http://www.dep.state.fl.us/waste/quick_topics/publications/shw/hazardous/household/CESQGswastetoHHW.pdf>."


Upon receipt of information identified above, and assuming the facility is in compliance with the provisions of Rule 62-730.220(5), F.A.C., the Department will issue an authorization to the HHW Center for management of the CESQG waste, and will classify the facility as a non-handler of hazardous waste. The Hazardous Waste Regulation Section will provide a copy of the authorization to the DEP District Waste Program Administrator.

Please note that while most illegal methamphetamine clandestine drug labs are CESQGs, make sure that you do not accept quantities of hazardous waste from clandestine labs that exceed the CESQG amount of less than100 kg/month or 1 kg/month of an acute hazardous waste.


Glen Perrigan
Florida Department of Environmental Protection
2600 Blair Stone Road, MS4560
Tallahassee, FL 32399-2400
W:850-245-8749
F:850-412-0528
glen.perrigan at dep.state.fl.us
www.dep.state.fl.us


The Department of Environmental Protection values your feedback as a customer. DEP Secretary Herschel T. Vinyard Jr. is committed to continuously assessing and improving the level and quality of services provided to you. Please take a few minutes to comment on the quality of service you received. Simply click on this link to the DEP Customer Survey<http://survey.dep.state.fl.us/?refemail=Glen.Perrigan@dep.state.fl.us>. Thank you in advance for completing the survey.
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