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Hazardous Waste Generator Categories

Generators of hazardous waste must comply with the hazardous waste regulations in the Code of Federal Regulations (40 CFR 262) and Indiana Administrative Code (329 IAC 3.1 [PDF]) that are specific to their generator category. The U.S. Environmental Protection Agency (U.S. EPA) established three generator categories based on the quantity of hazardous waste they generate per month.

Very Small Quantity Generators

Very small quantity generators (VSQGs), previously known as conditionally exempt small quantity generators, generate less than 100 kilograms (220 pounds) of hazardous waste or less than one kilogram (2.2 pounds) of acutely toxic hazardous waste per calendar month, and accumulate on-site at any time a total of less than 1,000 kilograms (2,200 pounds) of hazardous waste.

The requirements for VSQGs include:

  • VSQGs must determine whether generated solid waste is hazardous waste as set forth in 40 CFR 262.11. IDEM’s Understanding the Hazardous Waste Determination Process Guidance Document [PDF] provides details.
  • VSQGs may not accumulate more than 1,000 kilograms (2,200 pounds) of hazardous waste or one kilogram (2.2 pounds) of acutely toxic hazardous waste at any time.
  • VSQGs must ensure that hazardous waste is delivered to a person or a facility that is authorized to manage it.
  • VSQGs may, but are not required to, notify IDEM to obtain a Resource Conservation and Recovery Act (RCRA) identification (ID) number.
    • A RCRA ID number will be necessary if there is a planned or unplanned episodic event. An episodic event is an activity that does not normally occur during a generator’s operations and that causes the generator to exceed the threshold for its normal generator category for that month. Both VSQGs and small quantity generators can experience episodic events. More information about episodic generation is available on U.S. EPA’s hazardous waste generator site.
  • A VSQG who accumulates on-site at any one time more than 1,000 kilograms (2,200 lbs., or 1.1 tons) of hazardous waste is subject to all the requirements applicable to a small quantity generator.
  • A VSQG who accumulates on-site at any one time more than one kilogram (2.2 pounds) of acutely toxic hazardous waste is subject to the requirements of a large quantity generator.

Regulatory requirements for VSQGs are in 40 CFR 262.14. VSQGs who wish to be excluded from full hazardous waste regulations must meet all the conditions for exemption listed in 40 CFR 262.14.

Small Quantity Generators

Small quantity generators (SQGs) generate more than 100 kilograms (220 pounds), but less than 1,000 kilograms (2,200 pounds), of hazardous waste during a calendar month, and never accumulate on-site at any time more than 6,000 kilograms (13,227 pounds, or 6.61 tons) of hazardous waste.

The requirements for SQGs include:

  • SQGs must register with IDEM as generators of hazardous waste.
  • SQGs must obtain a RCRA ID number. U.S. EPA and IDEM use these 12-digit numbers to monitor and track hazardous waste activities. SQGs must use their RCRA ID number when they manifest hazardous waste off-site. If a generator is an SQG (or moves into this classification) and does not have a RCRA ID number, they still need to obtain one.
  • SQGs are not required to pay an annual registration fee. However, any SQG who accumulates more than 6,000 kilograms (13,227 pounds, or 6.61 tons) of hazardous waste or one kilogram (2.2 pounds) of acutely toxic hazardous waste on-site at any one time is subject to the requirements of a large quantity generator, including the annual permit fee and reporting requirements for that year.
  • SQGs must comply with many regulations in 40 CFR 262.16, which include, but are not limited to, container and tank management, accumulation time limits, manifests, emergency response, personnel training, and recordkeeping requirements.
  • SQGs who store their hazardous waste on-site for more than 180 days (or 270 days if the waste is shipped more than 200 miles) are considered to be a storage facility, which requires a permit from IDEM.

Large Quantity Generators

Large quantity generators (LQGs) generate more than 1,000 kilograms (2,200 pounds) of hazardous waste or one kilogram (2.2 pounds) of acutely toxic hazardous waste during any month. From the perspective of fees and reporting, even if those limits are only exceeded for one month of the year, the generator is still considered an LQG for that calendar year. Other requirements are based on status during each calendar month.

The requirements for LQGs include:

  • LQGs must notify IDEM to obtain a RCRA ID number and pay the annual operation fee of $1,565. U.S. EPA and IDEM use these 12-digit numbers to monitor and track hazardous waste activities. LQGs must use their RCRA ID number when they manifest hazardous waste off-site. If a generator is an LQG (or moves into this classification) and does not have a RCRA ID number, they should still obtain one.
  • LQGs must comply with many regulations in 40 CFR 262.17, which include, but are not limited to, container and tank management, accumulation time limits, manifests, emergency procedures and preparedness, personnel training, and recordkeeping requirements.
  • LQGs who store hazardous waste on-site for more than 90 days are considered a storage facility, and must obtain a permit from IDEM.

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