Lion will be closed on Friday, July 3. For online training support, please contact support@lion.com.
Search

Question of the Week: Calculating Generator Status

Posted on 1/21/2011 by James Griffin

Q. What is "generator status," and how do I calculate it?

A. Each and every person who produces hazardous waste is a generator and must determine his or her generator status each calender month. A facility’s generator status determines how stringently it is regulated and how long it may accumulate hazardous waste on site without a permit.

Three Categories of Waste Generator

Conditionally Exempt Small Quantity Generators (CESQGs) generate no more than 100 kilograms of hazardous waste per calender month [40 CFR 261.5(a)]. CESQGs are largely exempt from regulation, as long as they classify their waste and ensure that it is recycled or disposed of in an appropriate facility.

Small Quantity Generators (SQGs) generate more than 100 kilograms but less than 1,000 kilograms of hazardous waste per calender month [40 CFR 262.34(d)]. SQGs may accumulate hazardous waste on site without a permit for up to 180 days [40 CFR 262.34(d)].

Large Quantity Generators (LQGs) generate 1,000 kilograms or more of hazardous waste per calender month. LQGs may accumulate hazardous waste on-site without a permit for up to 90 days and have more paperwork obligations than SQGs [40 CFR 262.34(a)].

Don’t Count Wastes Not Subject to Substantive Regulation

As the following waste materials are not subject to substantive regulation, they do not count when calculating generator status:
  • Hazardous waste in manufacturing process units [40 CFR 261.4(c)]
  • Hazardous waste or tractability study samples [40 CFR 261.4(d), (e), (f)]
  • Ethyl alcohol, scrap metal, or petroleum refining wastes when recycled [40 CFR 261.6(a)(3)]
  • Empty hazardous waste containers [40 CFR 261.7(a)(1)]
  • Polychlorinated biphenyl (PCB) wastes managed under TSCA [40 CFR 261.8]
  • Hazardous wastes managed immediately on site in elementary neutralization units, wastewater treatment units, or totally enclosed treatment facilities [40 CFR 261.5(c)(2)]
  • Hazardous wastes recycled immediately without prior storage in an on-site process subject to 40 CFR 261.5(c)(3)
  • Used oil, spent lead-acid batteries, and universal wastes when managed under specific regulations [40 CFR 261.5(c)(4), (5), and (6)]
  • Wastes generated in laboratory cleanouts under 40 CFR Part 262 Subpart K [40 CFR 261.5(c)(7)]
Don’t Count Your Waste Twice

Generators must count their waste at the point of generation and should not re-count the same waste during the same calender month. This means that generators should NOT count when wastes are removed from a satellite accumulation area to a central accumulation area or when wastes are shipped off site. [40 CFR 261.5(d)]

If a generator reclaims hazardous waste for reuse on site, then the product and residues from the reclamation process do not count towards the generator status, as long as the hazardous waste was counted before reclamation. If the same stock of material is continually reused, then the generator must “count” the waste once a month [40 CFR 261.5(d)].

Tags: hazardous, RCRA, waste

Find a Post

Compliance Archives

Lion - Quotes

I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better.

Danny Province

EHS Professional

I attended training from another provider and learned absolutely nothing. Lion is much better. Hands down.

Nicole Eby

Environmental Specialist

We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training.

Timothy Mertes

Hazmat Shipping Professional

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable.

Marc Bugg

Hazardous Waste Professional

Lion courses are the standard to which all other workshops should strive for!

Brody Saleen

Registered Environmental Health Specialist

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.

Amanda Schwartz

Environmental Coordinator

I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!

Sara Sills

Environmental Specialist

The instructor took a rather drab set of topics and brought them to life with realistic real-life examples.

Tom Berndt

HSE Coordinator

Download Our Latest Whitepaper

This report details major changes for hazardous waste generators from US EPA’s Generator Improvements Rule, as well as the latest updates from states that are still working to adopt new, stricter Federal requirements.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.