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Q: How does RCRA categorize different hazardous waste generators and their applicable requirements?
A: Under RCRA, any person or site that creates hazardous waste in any quantity is considered a “generator.” However, there are three categories with different levels of regulatory requirements, depending on the quantity of waste produced, all of which are defined in 40 CFR Parts 261 and 262:
1) Conditionally Exempt Small Quantity Generators (SQGs) are those that generate 100 kilograms or less per month of hazardous waste, 1 kilogram or less per month of acutely hazardous waste, or less than 100 kilograms per month of acute spill residue or soil (261(5)(a) and (e)).
2) Small Quantity Generators (SQGs) are those that generate more than 100 kilograms but less the 1,000 kilograms of hazardous waste per month (262.34(d)).
3) Large Quantity Generators (LQGs) are those that generate 1,000 kilograms or more per month, more than 1 kilogram per month of acutely hazardous waste, or more than 100 kilograms per month of acute spill residue or soil (262 and 261.5(e)).
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It is important to note that these categories are based on monthly amounts of hazardous waste generated and as a result, if a generator exceeds their normal category threshold in any given month, all requirements for the next applicable category will apply and must be met to remain in compliance.
Q: Are hazardous waste generators required to obtain a permit to accumulate hazardous wastes onsite?
A: While “storage” of hazardous waste requires a permit, RCRA provisions allow for “accumulation” without a permit when specific requirements are met for each category, as follows:
- CESQS may accumulate 1,000 kilogram of hazardous waste, 1 kilogram of acute hazardous waste and 100 kilogram of residue or contaminated soil from the cleanup of spilled acute hazardous waste without a time limit.
- SQGs may accumulate 6,000 kilograms of hazardous waste for up to 180 days onsite in tanks or containers or up to 270 days if it is shipped 200 miles or more. SQGs that accumulate hazardous waste in containment buildings or on drip pads must comply with accumulation requirements for LQGs.
- LQGs may accumulate an unlimited amount of hazardous waste onsite for up to 90 days.
All storage containers, tanks, buildings and drip pads used for accumulation must also meet the requirements of 40 CFR part 265.
Q: Are all categories of hazardous waste generators required to obtain an EPA Identification number?
A: No. CESQGs are not required to obtain an EPA ID number unless they exceed the category generation thresholds in any month. Note, however, that some states may require CESQGs to have an EPA Identification number.
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Q: What, if any, employee training is required for each of the hazardous waste generator categories?
A: According to Part 262, both SQGs and LQGs are required train employees, although the requirements differ considerably. For SQGs, training should ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures in accordance with 262.34 (d)(5)(iii). The requirements for LQGs are much more complex and include classroom or on-the-job training provided by trained hazardous waste management personnel that meets all the requirements at 265.16. Employees that receive emergency response training in accordance with the Occupational Safety and Health Administration (OSHA) regulations at 29 CFR 1910.120(p)(8) and 1910.120(q) are not required to be retained in emergency response as long as all other training requirements are met. Training records for current employees must be kept until the facility closes and records for former employees must be kept for three years from the date the employee last worked at the facility.