Question

Explain the difference between a small quantity generator and a generator under RCRA.

Answer 1

A generator is any person who produces a hazardous waste as listed or characterized in part 261 of title 40 of the Code of Federal Regulations (CFR). Recognizing that generators produce waste in different quantities.

three categories of generators ;

• very small quantity generators,
• small quantity generators, and
• large quantity generators.

Difference between small quantity and large quantity generators :

A small quantity generator produces no more than 100 kilograms of hazardous waste, no more than 1 kilogram of “acutely” hazardous waste, and no more than 100 kilograms of acute spill residue each month while a large quantity generator produces at least 1000 kilograms of waste, more than one kilogram of acutely hazardous waste, or more than 100 kilograms of acute spill residue per month.  

A small quantity generator must adhere to the following requirements as well:

• It must ensure that the total quantity of on-site waste does not exceed 6000 kilograms at any given time.
• It is allowed to accumulate waste for no more than 180 days without obtaining a permit (extended to 270 days if the distance that the waste must be transported off-site exceeds 200 miles).
• It is also required to observe the various waste management requirements relating to transportation and storage equipment that are listed under 40 CFR Part 265.
• It must provide basic classroom and/or on-the-job training for all onsite personnel to ensure that they can handle waste materials safely and appropriately.
• It must have an employee onsite at all times who is prepared and authorized to provide emergency response when needed.
• It must assemble a “basic” emergency and contingency plan to ensure appropriate response in the event of disaster.
• It must obtain an EPA identification number.
• It must track waste shipments with the EPA’s hazardous waste manifest system.
• It must agree to put forth a "good faith effort" to minimize the amount of waste generated as part of the site's processes.
• Its off-site waste shipments must be sent to an RCRA-permitted facility. Waste must be labeled in compliance with Department of Transportation packaging rules.

while

As you might expect, a Large Quantity Generator is subject to more extensive regulations than sites in the other two categories. These rules include the following:

• An LQG is generally allowed to store waste on-site for only ninety (90) days, although—unlike the other two classifications—there is no limit to the amount that may be stored.
• Its onsite hazardous waste must be stored inside tanks or other types of containers that conform to the requirements laid out in 40 CFR Part 265.
• It must obtain an EPA identification number.
• It must have a detailed contingency plan in the event of a fire, explosion, or other adverse event at the facility. A copy of the plan must be sent to local police departments and emergency response centers.
• It must establish strict controls on storage tanks and containers to keep air emissions within acceptable boundaries. (The other two classifications have no such requirement at all.)
• Its off-site hazardous waste shipments must be labeled according to Department of Transportation guidelines and sent to an RCRA facility.
• It must fill out a waste management report on a biennial basis and send it to Regional Administrator by March 1st of every even-numbered year. This is another requirement unique to LQGs.

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