October 29, 2019

EPA Website Shows State-Specific Generator Categories

Generator category is determined by the amount of hazardous waste generated in a calendar month. Once known, a facility operator can then determine which set of RCRA requirements apply to the facility. Section 262.13 of the federal RCRA regulations defines three different generator categories: large quantity generator (LQG), small quantity generator (SQG), and very small quantity generator (VSQG, formerly known as conditionally exempt small quantity generator or CESQG). It is well understood that LQGs have the most stringent set of requirements, VSQGs have the least stringent, and SQGs fit in between.

But, there are a handful of RCRA-authorized states that have their own set of generator categories that differ from the federal program. For example, a generator who is a VSQG in a state that follows the federal definitions could be an SQG if located in a state that does not recognize VSQGs and might need to comply with more-stringent requirements. EPA maintains a state-by-state generator category website containing a color-coded map showing states that use the federal generator categories contrasted with those that have different categories. Depending on the states in which you operate, you may find there are two different types of VSQGs, there are only LQGs and SQGs, or there are some other combination of generator categories.

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Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.

This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.