Determining Small Quantity Generators

The law says that a small quantity generator is one that generates less than 1,000 kilograms of hazardous waste in a calendar month. RCRA Title 40 Code of the Federal Register (CFR), Part 261 contains lists specifying wastes that are regulated and characteristics for identifying non-listed hazardous wastes.

The unlisted hazardous wastes may be identified as one if it exhibits any of the four characteristics of a hazardous waste:

• Ignitability: The waste material (solid, gas, or liquid) must have a flash point of less than 140°F and/or be an aqueous solution with an alcohol content of greater than or equal to 24%. Examples are solvents, paint thinners, and oxidizers.
• Corrosivity: The waste material must be a liquid and have a pH of less than 2.0 or greater than 12.5. Examples are acids and caustics.
• Reactivity: The waste material is reactive to water, shock, heat, and pressure, and undergoes a rapid violent chemical reaction. Examples are perchlorates, peroxides, and cyanides.
• Toxicity Characteristics (TC): This category includes eight heavy metals and thirty-one organic chemicals including ten pesticides. Waste in this category need only contain very small amounts of arsenic, lead, mercury, or one of the other heavy metals, or organics such as benzene, trichloroethylene, per chloroethylene, vinyl chloride, methyl ethyl keytone, or one of the ten pesticides.

Groups

Small quantity generator groups fall into two categories:

• Conditionally Exempt Small Quantity Generator (CESQG) – It generates no more than 100 kilograms (220 pounds or about half a 55-gallon drum) in any one month, or less than one kilogram of an acute hazardous waste (e.g., arsenic and cyanide compounds), and never accumulates more than 1,000 kilograms (2,200 pounds) of hazardous waste at any time.
• Small Quantity Generator (SQG) – It generates more than 100 kilograms (220 pounds) but less than 1,000 kilograms (2,200 pounds) in any one month, approximately one-half to five drums.

Small Quantity Generators (SQGs) must:

• Obtain a EPA / DEP identification number
• Accumulate no more than 6,000 kilograms (13,200 pounds) of hazardous waste for longer than 180 days
• Implement a Preparedness and Prevention Plan
• Use a DEP-approved transporter for off-site shipment of hazardous material
• Use a multiple-copy manifest
• Maintain a copy of the manifest for a period of three years
• Dispose hazardous waste only at a permitted RCRA facility
• File an exception report if a copy of the manifest is not returned from the disposal facility within 60 days of the date the waste was shipped

For more information, please contact Flagler County Solid Waste at 386-517-2075 or the Florida Department of Environmental Protection Hazardous Waste Regulation Section at 800-741-4337.