Q. Because of removing excess chemical inventories one month this year, I changed from being a small quantity generator (SQG) to a large quantity generator (LQG). Which set of requirements should I comply with and for how long?
A. This question comes up when the amount of hazardous waste generated in a given calendar month places the generator in a larger generator category. Although not actually a generator class, EPA uses the term “episodic generator” to describe a generator in this situation.
An “episodic generator” is responsible for complying with all applicable requirements of the generator category for all waste generated during that calendar month in which an episodic event occurred. For example, if an SQG produces 300 kg of hazardous waste in May, that waste must be managed in accordance with the SQG regulations; if the same generator produces 1,500 kg of hazardous waste in June, that waste must be managed in accordance with the LQG regulations.
Generators often wonder if once they’ve become a different category of generator due to an episodic event, they remain in that category for the rest of the calendar year. Regarding the example, the EPA would say that the generator must comply with all applicable LQG requirements for hazardous wastes generated in June for as long as that waste remains on-site. If the generator reverts back to SQG status in July, the generator must continue to manage the hazardous waste generated during the month it became an LQG according to all applicable LQG requirements. (What LQG requirements that situation involves, in practice, will be determined by the state environmental regulatory agency.) Hazardous waste generated during any months the generator was an SQG can be managed under SQG requirements. So, in effect, a generator could be an SQG for 11 months of a year, but because of exceeding its generation limit in one month, is considered an LQG for that one month of the year.
If this sounds confusing and unworkable, it is, which is probably why this issue of episodic generation which moves a CESQG or SQG into a higher class for a month is addressed in EPA’s newly finalized Generator Improvements Rule. If you find yourself in this position, it’s a good idea to contact your state environmental regulatory agency.