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VERY SMALL QUANTITY GENERATOR (VSQG) REQUIREMENTS
GENERATOR REQUIREMENTS

Did generator make an accurate determination as to whether a solid waste was hazardous? [40 CFR 262.11(a-d)]

Did generator maintain records that support the HW determination for at least three years? [40 CFR 262.11(f)]

Did generator determine its proper category? [40 CFR 262.13]

VSQG REQUIREMENTS

Conditions for Exemption – Generation / Accumulation: (1) Generates less than or equal to 100 kg (220 lbs) of non-acute HW, 1 kg (2.2 lbs) of acute HW & 100 kg (220 lbs) of any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute HW; (2) Complies with HW determination at 262.11(a)-(d); (3) If accumulating > 1 kg (2.2 lbs) of acute HW or 100 kg (220 lbs) of any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill of any acute HW, such waste cannot be held on site for more than 90 days and must meet the conditions for exemption in 262.17(a)-(g); (4) If accumulating at any time 1,000 kg (2,200 lbs) or greater of non-acute HW, all quantities of that HW cannot be held on site for more than 180 days, or 270 days, the quantity of HW accumulated never exceeds 6,000 kg (13,200 lbs), and must meet the conditions for exemption in 262.16(b)(2)-(f). [40 CFR 262.14(a)]

Conditions for Exemption – On-site / Off-site Destination: (5) Either treats or disposes of its HW in an on-site facility or ensures delivery to a treatment, storage and disposal facility either of which is: (i) Permitted under part 270; (ii) Interim status under parts 265 and 270; (iii) Authorized to manage HW by a state with a HW management program approved under part 271; (iv) Permitted, licensed, or registered by a state to manage municipal SW and, if managed in a municipal SW landfill, is subject to part 258; (v) Permitted, licensed, or registered by a state to manage non-municipal non-HW and, if managed in a non-municipal non-HW disposal unit, is subject to 257.5 through 257.30; (vi) A facility which beneficially uses or reuses, or legitimately recycles or reclaims its waste or treats its waste prior to beneficial use or reuse, or legitimate recycling or reclamation; (vii) Universal waste handler or destination facility subject to part 273; or (viii) LQG under the control of the same person as the VSQG and marks its container(s) of HW with the words “Hazardous Waste” and an indication of the hazards of the contents. [40 CFR 262.14(a)]

Did VSQG comply with the conditions for exemption listed in 262.14(a)(1)-(5)? [40 CFR 262.14(a)]

Did VSQG comply with the requirement prohibiting the placement of bulk or non-containerized liquid HW or HW containing free liquids (whether or not sorbents have been added) in a landfill? [40 CFR 262.14(b)]

Episodic Event – VSQG may generate and accumulate hazardous waste during this event in accordance with subpart L of 262 in lieu of sections 262.15, 262.16, and 262.17. [40 CFR 262.14(c)]

VSQG EPISODIC GENERATION

Did VSQG notify the Department no later than thirty (30) calendar days prior to initiating a planned episodic event or within 72 hours of an unplanned event by submitting EPA Form 8700-12? [40 CFR 262.232(a)(2)]

Did VSQG have an EPA Identification Number during an episodic event. [40 CFR 262.232(a)(3)]

Did VSQG comply with the requirement prohibiting the accumulation of HW from an episodic event on drip pads or in containment buildings? [40 CFR 262.232(a)(4)]

Did VSQG mark or label containers with the words “Episodic Hazardous Waste” and an indication of the hazards of the contents? [40 CFR 262.232(a)(4)(iA-B)]

Did VSQG mark or label containers with the episodic event start date, clearly visible for inspection on each container? [40 CFR 262.232(a)(4)(iC)]

Did VSQG mark or label tanks with the words “Episodic Hazardous Waste” and an indication of the hazards of the contents? [40 CFR 262.232(a)(4)(iiA-B)]

Did VSQG use inventory logs, monitoring equipment or other records showing the date upon which each episodic event began and keep required records on site readily available for inspection? [40 CFR 262.232(a)(4)(iiC-D)]

Did VSQG to ensure containers holding hazardous waste generated during an episodic event were in good condition, compatible with the HW being accumulated therein, and kept closed? [40 CFR 262.232(a)(4)(iiiA)]

Did VSQG ensure tanks holding HW generated during an episodic event were in good condition, were compatible with the HW, had procedures in place to prevent overflow, and were inspected daily to ensure all applicable discharge control equipment is in good working order and operated per its design? [40 CFR 262.232(a)(4)(iiiB)]

Did VSQG manifest and send HW generated from the episodic event to a designated facility within sixty (60) calendar days from the start of the event? [40 CFR 262.232(a)(6)]

Did VSQG maintain the required records for three years from the end date of the episodic event? [40 CFR 262.232(a)(7)]
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