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Hazardous Waste Management Program

Generators

 

 

Hazardous waste regulations apply to businesses or non-household waste generators (hazardous waste generators), waste generated from a household is exempt. State and federal hazardous waste regulations classify hazardous waste generators into three categories based on the amount of hazardous waste generated each calendar month. These categories are:

 

Conditionally Exempt Generators (CEGs)

Small Quantity Generators (SQGs)

Large Quantity Generators (LQGs)

Under the Vermont Hazardous Waste Management Regulations (VHWMR), all Vermont generators are required to determine if their waste is subject to regulation as hazardous waste. In Vermont, if you generate hazardous waste, you are required to submit a Vermont Hazardous Waste Handler Site ID Form to the DEC’s Hazardous Waste Program in order to obtain an EPA Identification Number. For additional information concerning generator requirements and considerations when calculating generator status, see the following:

Generator Requirement Table

Considerations When Calculating Generator Status:

Conditionally Exempt Generators (CEGs): The CEG category is designated for hazardous waste generators who produce the least amount of hazardous waste. CEGs must comply with basic requirements for making waste determinations, notification, hazardous waste management and storage, and ensuring that their hazardous wastes are disposed of appropriately (many disposal methods are available to CEGs).

A generator is a conditionally exempt generator if they:

  • generate less than 220 pounds of hazardous waste per month; and
  • generate less than 2.2 pounds of acutely hazardous waste (P listed waste) per month; and
  • generate less than 220 pounds of any residue or contaminated soil, waste, or other debris resulting from the cleanup of a discharge of any acutely hazardous waste (P waste) per month; and
  • have accumulated less than 2,200 pounds of hazardous waste, 2.2 pounds of acutely hazardous waste (P waste), or 220 pounds of any residue or contaminated soil, waste, or other debris resulting from the cleanup of a discharge of any acutely hazardous waste (P waste) at any time.

Conditionally Exempt Generator HandbookA handbook intended for use as a guidance document to the basic VHWMR requirements as they apply to CEG which are specified under the VHWMR § 7-306.

 

 

Small Quantity Generators (SQGs) SQGs are subject to more stringent requirements than CEGs, but less stringent than LQGs. SQGs must also comply with requirements for recordkeeping, waste inventory and inspections, personnel training, emergency preparedness and prevention, facility closure, and more stringent on-site waste storage requirements. SQG requirements are specified under VHWMR § 7-307.

A generator is a small quantity generator if they:

  • generate greater than or equal to 220 pounds but less than 2,200 pounds of hazardous waste in a calendar month;
  • generate less than 2.2 pounds of acutely hazardous waste in a calendar month;
  • generate less than 220 pounds of any residue or contaminated soil, waste, or other debris resulting from the cleanup of a discharge of any acutely hazardous waste in a calendar month; and
  • accumulate a quantity of hazardous waste on-site that never exceeds 13,200 pounds.

 

 

Large Quantity Generators (LQGs) LQGs generate the most waste and are subject to most stringent requirements. LQGs must also comply with specific requirements for waste testing and recordkeeping, more stringent storage time limits, more stringent employee training and contingency planning requirements. LQG requirements are specified under VHWMR § 7-308.

A generator is a large quantity generator if they:

  • generate 2,200 pounds or more of hazardous waste or 2.2 pounds or more of acutely hazardous waste in a calendar month.
  • generate 220 pounds or more of any residue or contaminated soil, waste, or other debris resulting from the cleanup of a discharge of any acutely hazardous waste in a calendar month.
  • accumulate a quantity of hazardous waste on-site that exceeds 13,200 pounds at any one time.
  • accumulate a quantity of acutely hazardous waste on-site that equals or exceeds 2.2 pounds at any one time.
  • accumulate a quantity of any residue or contaminated soil, waste, or other debris resulting from the cleanup of a discharge of any acutely hazardous waste, onsite that equals or exceeds 220 pounds at any one time.

Generator Requirement Table:

Requirements

CEG

SQG

LQG

Accumulation Time Limits:

None

≤180days

≤90 days

Storage Requirements:

Minimum storage requirements (under cover, impervious surface, containers closed, and labeled)

Full compliance with requirements for tanks and containers

Full compliance with requirements for tanks, containers, drip pads, and containment buildings

Waste Can Be Sent To:

Local Solid Waste District or RCRA permitted

RCRA permitted facility

RCRA permitted facility

Manifests:

Not required. If used, must follow manifest instructions

Required

Required

Biennial Report:

Not required

Not required

Required

Personnel Training:

Not required however there is an on-line tutorial available at: http://www.vtceg.org/index.cfm

Basic training required

Training plan and documentation of training required

Contingency Plan:

Not required

Not required

Full plan required

Emergency Procedures:

Not required

Must designate emergency coordinator, post emergency preparedness info

Must designate emergency coordinator, maintain contingency plan, and follow specific emergency procedures

Facility Closure:

Not required

Required

Required

DOT Transport Requirements:

(as required by DOT)

(as required by DOT)

(as required by DOT)

 

Some key considerations when calculating Generator status:
  • Exempt wastes do not count toward generator status.
  • Generator status is determined based on the amount of hazardous waste generated per month, and not the amount of hazardous waste shipped in a particular month.
  • Any hazardous waste that is reclaimed and subsequently reused on-site only needs to be counted as being generated one time.
  • Because used oil and universal wastes (i.e., batteries, certain pesticides, mercury thermostats, PCB-containing fluorescent light ballasts, lamps, mercury-containing devices, and CRTs) are exempt, they should not be counted when calculating generator status.

*For additional information regarding determining generator status, see: Hazardous Waste Management Program Generator Status and Counting Your Waste Frequently Asked Questions (FAQs)

Updated: March 2013

 

 

 

VT DEC Waste Management & Prevention Division 1 National Life Drive - Davis 1  Montpelier, VT  05620-3704  Tele: 802-828-1138  Fax: 802-828-1011

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