Chapter 2: Generator Status, CESQG, SQG and LQG Regulatory Definitions
Chapter 2: Generator Status
A Generator's "status" is defined by the type of hazardous waste created and the quantity of waste that is generated and stored onsite. This chapter will discuss the different statuses and their associated regulatory requirements. There are three Generator statuses: Conditionally Exempt Small Quantity Generator (CESQG), Small Quantity Generator (SQG) and Large Quantity Generator (LQG).
Hazardous Waste Weight:
One criteria for determining a Generator's status is the weight of waste they create over time. It is important that container weight and Universal Waste weight is NOT included in this total.
CESQG: Conditionally Exempt Small Quantity Generator:
A generator is a CESQG if, in a calendar month:
- They generate no more than 220 pounds of hazardous waste, and
- They generate no more than 2.2 pounds of acute hazardous waste, and
- They generate no more than 220 pounds of material from the cleanup of a spillage of acute hazardous waste
AND, at anytime:
- They store no more than 2,200 pounds of hazardous waste, and
- They store no more than 2.2 pounds of acute hazardous waste.
A Generator that is a CESQG:
- Does not need to acquire an EPA RCRA ID Number,
- Does not need to use a Hazardous Waste Manifest form, and
- Does not need to submit an Annual Report.
While the rate of hazardous waste generation may not be controllable, the amount of hazardous waste stored onsite is controllable. Businesses should keep their waste shipments frequent enough to avoid accidentally becoming a more regulated status, due to the amount of hazardous waste stored onsite. A CESQG that stores more than 2,200 pounds of hazardous waste is now a Small Quantity Generator which requires the use of an EPA RCRA ID Number and Hazardous Waste Manifest form.
Should a CESQG get an EPA RCRA ID Number and use the Hazardous Waste Manifest form anyway?
While getting an EPA RCRA ID and using the Manifest form are not required by New York for a CESQG company, they may choose to use these items to more effectively track their hazardous waste shipments. Further, a Generator's business partners (Transporters and TSDFs) and States other than New York may require their use. If a Manifest form is used by a CESQG, they are not required to submit the form to NYS DEC.
Please see Part 371.1(f) (link leaves DEC's website) for the definition, regulatory requirements and regulatory exemptions for CESQG's.
SQG: Small Quantity Generator:
A generator is an SQG if, in a calendar month:
- They generate more than 220 pounds and less than 2,200 pounds of hazardous waste, and
- They generate no more than 2.2 pounds of acute hazardous waste
AND, at anytime:
- They store no more than 13,200 pounds of hazardous waste, and
- They store no more than 2.2 pounds of acute hazardous waste
An SQG may store non-acute hazardous waste on-site for 180 days or less without being subject to the permitting provisions of Part 373, Treatment, Storage and Disposal Facilities.
A Generator that is an SQG needs to acquire an EPA RCRA ID Number, needs to use a Hazardous Waste Manifest form and needs to submit a copy of the Manifest form to DEC. An SQG does not need to submit an Annual Report.
While the rate of hazardous waste generation may not be controllable, the amount of hazardous waste stored onsite is controllable. Businesses should keep their waste shipments frequent enough to avoid accidentally becoming a more regulated status, due to the amount of hazardous waste stored onsite. An SQG that stores more than 13,200 pounds of hazardous waste is now a Treatment, Storage and Disposal Facility which requires a permit issued by DEC.
LQG: Large Quantity Generator:
A generator is an LQG, if in a calendar month:
They generate more than 2,200 pounds of hazardous waste, or
They generate more than 2.2 pounds of acute hazardous waste
An LQG may store hazardous waste on-site for up to 90 days.
A Generator that is an LQG needs to acquire an EPA RCRA ID Number, needs to use a Hazardous Waste Manifest form, needs to submit a copy of the Manifest form to DEC and needs to submit an Annual Report. Further, an LQG needs to comply with the requirements for personnel training, preparedness and prevention, contingency plans and emergency procedures found in Part 373-3. (link leaves DEC's website)
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