SQG Hazardous Waste Generators 2021 Re-Notification Deadline Approaching

Hazardous waste generators are subject to the requirements of the Resource Conservation and Recovery Act (RCRA), which is implemented by the United States Environmental Protection Agency (US EPA). The regulatory requirements of RCRA vary based on the volume of hazardous waste generated by a facility in a calendar month. There are three generator categories – large quantity generators (LQG), small quantity generators (SQG), and very small quantity generators (VSQG). The generator categories are determined as follows:

 

	Large Quantity Generator (LQG)	Small Quantity Generator (SQG)	Very Small Quantity Generator (VSQG, formerly CSEQG)
Hazardous Waste Quantity Limit	Greater than or equal to 2,220 lb (1,000 kg) per month; greater than 2.2 lb (1 kg) per month of acute hazardous waste; and greater than 220 lb (100 kg) of acute spill residue or soil.	More than 220 lb (100 kg) but less than 2,220 lb (1,000 kg) per month.	Less than or equal to 220 lb (100 kg) per month; less than or equal to 2.2 lb (1 kg) per month of acute hazardous waste; and less than or equal to 220 lb (100 kg) per month of acute spill residue or soil.

 

The US EPA published an amendment to RCRA, the final Hazardous Waste Generator Improvements Rule, in the Federal Register on November 28, 2016, and it became effective May 30, 2017. The new rule brought multiple improvements and changes to the RCRA regulations, including the SQG re-notification requirement. Previously, SQGs were only required to submit a one-time notice when they first identified themselves as a hazardous waste generator to obtain an EPA RCRA ID Number. With the re-notification requirement, EPA will stay up to date if SQGs go out of business, change ownership, or change their regulatory category. SQGs of hazardous waste must re-notify the EPA by September 1, 2021 and every four years thereafter, using EPA Form 8700-12.

In Pennsylvania, if your facility has submitted an EPA RCRA Subtitle C Site Identification Form since May 30, 2017, this meets the re-notification requirement and you are not required to submit again until September 1, 2025, barring any facility changes that require you to do so. The Pennsylvania Department of Environmental Protection (DEP) is accepting paper and electronic submissions for the re-notification requirement. Electronic submissions can be made through the DEP GreenPort system’s ePermitting application.

EPA Form 8700-12 is available here https://rcrapublic.epa.gov/rcrainfoweb/documents/notification.pdf

EPA’s Re-Notification Requirements posting here https://www.epa.gov/hwgenerators/re-notification-requirement-small-quantity-generators

Questions? Call RCRA expert Katie Cirone at 800.305.6019.