DEEP: Determining H/W Generator Category

Determining Hazardous Waste Generator Category

Purpose
This fact sheet helps generators of hazardous waste determine their hazardous waste generator category.  Generator category is determined on a site-by-site basis.  Depending on the amount and types of hazardous waste generated at a particular site, the site may be classified as a Large Quantity Generator (LQG), a Small Quantity Generator (SQG), or a Conditionally-Exempt Small Quantity Generator (CESQG).

It is important to correctly determine the hazardous waste generator category for a site because different sets of requirements apply to each of these three generator categories, with LQGs having the most requirements, and CESQGs the fewest.  For more information on the requirements that apply to each of the three hazardous waste generator categories, see the DEEP webpage Information for Generators of Hazardous Waste.

In addition, Regulations of Connecticut State Agencies (RCSA) Section 22a-449(c)-102(a)(1), incorporating the federal hazardous waste regulations at 40 CFR 262.12 requires LQGs and SQGs to submit a written notification to DEEP documenting their generator category.

This fact sheet is not intended to supersede the applicable regulations. You should refer to the appropriate statutes and regulations for specific regulatory language.  It is your responsibility to comply with all applicable laws and regulations.

How do I Determine My Hazardous Waste Generator Category?
You should complete steps 1 through 3 below to determine your generator category. In addition, you should check your site’s generator category once you have established routine waste generation rates, and periodically thereafter to account for possible changes in waste generation rates at your site.

Note:  To provide assistance with step 1, DEEP has developed a Hazardous Waste Determination Summary Sheet.  To provide assistance with steps 2 and 3, DEEP has developed a Hazardous Waste Generator Category Worksheet.

Step 1: Conduct a hazardous waste determination on each waste generated at your site.  Be sure to note if any of your wastes are acute hazardous wastes.  Note:  Connecticut’s Hazardous Waste Management Regulations require that hazardous waste determinations be repeated annually, or whenever raw material or process changes occur that may affect the waste.

Step 2: For each hazardous waste generated on-site, determine the amount that is generated in kilograms per calendar month.  One kilogram equals 2.2 pounds.  Also, for each hazardous waste, determine the maximum amount that may be accumulated on-site at any one time in kilograms (if this amount is variable, assume the worst case).  Then, add together: (1) all of the monthly generation rates for the wastes generated on-site; and, (2) the maximum accumulation amounts for all the wastes generated on-site.  Acute hazardous wastes should be tallied separately from other hazardous wastes (see the Hazardous Waste Generator Category Worksheet).

Step 3: Using your results from steps 1 and 2, consult the Table of Hazardous Waste Generator Categories provided below to determine your site’s generator category.  The three possible generator categories are Conditionally Exempt Small Quantity Generator (CESQG), Small Quantity Generator (SQG) and Large Quantity Generator (LQG).

Are There Any Wastes That Should Not Be Counted?
There are certain hazardous wastes that do not need to be counted when determining your hazardous waste generator status.  These wastes are as follows:

  • Wastes that are exempt from hazardous waste regulations under 40 CFR 261.4(c) through (f) or 261.6(a)(3) .
  • Hazardous wastes that are managed immediately upon generation only in an on-site elementary neutralization unit, wastewater treatment unit, or totally-enclosed treatment facility.  Note:  these terms are defined in 40 CFR 260.10.
  • Hazardous wastes that are recycled, without prior storage or accumulation, in hazardous waste recycling units.
  • Hazardous waste residues in “empty containers” as defined in 40 CFR 261.7.
  • Universal Wastes that are managed in compliance with RCSA Section 22a-449(c)-113.
  • Used oil that is managed in compliance with RCSA Section 22a-449(c)-119 (unless the used oil is subject to regulation as a hazardous waste because it has been mixed or contaminated with hazardous waste).
  • Spent lead-acid batteries that are managed under RCSA Section 22a-449(c)-106(c) that are hazardous only because they exhibit the toxicity characteristic  for waste codes D018 through D043.
Table of Hazardous Waste Generator Categories
Once you have collected all the information required in steps 1 through 3 above, use the table below to figure out your generator category.  Each generator category is displayed as a single line in this table.  Your generator category is the lowest line on the table for which you meet either of the thresholds in columns two or three of the table.
 

Waste Generator Category

Amount of Waste Generated
Per Calendar Month

 

Amount of Waste Stored
On-Site
At Any One Time

CESQG

Conditionally Exempt Small Quantity Generator


No More than
100 kilograms*

And

No More than 1 kilogram* of Acute Hazardous Waste 
 

AND


No More than
1000 kilograms*

And

No More than 1 kilogram* of
Acute Hazardous Waste
 

SQG

Small Quantity Generator


Between
100 - 1000 kilograms*

And

No More than 1 kilogram* of Acute Hazardous Waste 

AND

No More than
1000 kilograms*

And

No More than 1 kilogram* of
Acute Hazardous Waste  

LQG

Large Quantity Generator


1000 kilograms*
or More

Or

Greater than 1 kilogram* of Acute Hazardous Waste
 

OR

More than
1000 kilograms*

 Or

Greater than 1 kilogram* of
Acute Hazardous Waste

 
* See the Hazardous Waste Generator Category Worksheet for conversion factors from kilograms to pounds and gallons, and for information on acute hazardous waste.

Hazardous wastes that contain certain especially toxic constituents are designated as "acute hazardous wastes."  A waste is an acute hazardous waste if it is any of the P-listed wastes in 40 CFR 261.33, or one of the following F-listed wastes: F020, F021, F022, F023, F026, and F027.

For further information on determining your hazardous waste generator category, please contact the DEEP’s toll-free Compliance Assistance (COMPASS) hotline at 1-888-424-4193, or send us an email.

Content Last Updated December 6, 2016