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Summary of Hazardous Waste Generator Status Options


Thursday, March 24, 2016

A brief summary of the hazardous waste generator status options is provided below. Consult the regulations (DC and Federal) for additional information.
LQG: Large Quantity Generator

The site is a Large Quantity Generator (LQG) if the site generates any of the following amounts in a calendar month:

(i) Greater than or equal to 1,000 kilograms (kg; ~2,200 pounds [lbs]) of non-acute RCRA hazardous waste; or

(ii) Greater than 1 kg (~2.2 lbs) of any RCRA acute hazardous waste listed in sections 261.31 or 261.33(e); or

(iii) Greater than 100 kg (~220 lbs) of any residue or contaminated soil, waste, or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute hazardous wastes listed in sections 261.31 or 261.33(e).

 

In DC, an initial registration fee of $1,000 is required.  A renewal fee of $1,000 is due each year on March 1st.

SQG: Small Quantity Generator

The site is a SQG if the site meets all of the following criteria:

 

(i) Generates, in any calendar month, more than 100 kg (~220 lbs) but less than 1,000 kg (~2,200 lbs) of RCRA hazardous waste; and

(ii) Does not generate, in any calendar month, more than 1 kg (~2.2 lbs.) of acute hazardous waste listed in sections 261.31 or 261.33(e); and

(iii) Does not generate more than 100 kg (~220 lbs) of material from the cleanup of any residue or contaminated soil, waste, or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute hazardous wastes listed in sections 261.31 or 261.33(e).; and

(iv) Does not accumulate more than 6000 kg (~13,200 lbs) of hazardous waste at the site.

 

In DC, an initial registration fee of $500 is required.  A renewal fee of $500 is due each year on March 1st

CESQG: Conditionally Exempt Small Quantity Generator

The site is a CESQG if the site meets all of the following criteria:

(i) Generates, in any calendar month, less than or equal to 100 kg (~220 lbs) of hazardous waste; and
(ii) Does not generate, in any calendar month, more than 1 kg (~2.2 lbs) of acute hazardous wastes listed in sections 261.31, or 261.33(e); and
(iii) Does not generate more than 100 kg (~220 lbs) of any residue or contaminated soil, waste, or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute hazardous wastes listed in sections 261.31, or 261.33(e); and
(iv) Does not accumulate more than 1000 kg (~2,200 lbs) of hazardous waste at the site.

In DC, an initial registration fee of $250 is required for CESQGs.  A renewal fee of $250 is due each year on March 1st.  An initial registration fee of $100 is required for CESQGs with less than eight (8) employees. A renewal fee of $100 is due each year on March 1st.

In DC, if the only regulated waste your facility generates is universal waste fluorescent lamps, and/or universal waste batteries, and/or used motor oil, your facility will register as CESQG.

Short-Term Generators

If the facility is currently generating hazardous waste only as the result of a one-time, nonrecurring, temporary event that is not related to normal production processes then the facility may register as a short term or temporary generator.  In other words, short-term generators produce hazardous waste from a particular activity for a limited time and then cease conducting that activity.

 

Examples of short-term generators include:

  1. one-time highway bridge waste generation;underground storage tank removals;
  2. generation of off-spec or out-of-date chemicals at a site that normally doesn’t generate hazardous   waste;
  3. remediation or spill clean-up at sites with no previous EPA Identification Number; and
  4. site or production process decommissions by a new operator.
In DC, short term or temp EPA ID numbers are also known as provisional EPA ID numbers.  They are issued for 30 consecutive calendar days only.  No extensions are allowed, and only one may be issued per location each year.  The fee is $100.  An EPA ID number must be obtained BEFORE regulated waste is generated unless it is for spill response.
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