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Large Quantity Generators (LQGs)

Identifying the Hazardous Wastes You Generate (40 CFR 262.11 and Part 268)

  • Listed wastes
  • Characteristic wastes

Determining Your Generator Category (40 CFR 262.10(b) and 262.13)

  • Accumulated on site for any time before disposal or recycling.
  • Placed directly into an on-site treatment or disposal unit.
  • Generated as still bottoms or sludges and removed from product storage tanks.

Obtaining an EPA Identification Number 40 CFR 262.18
LQGs must have an EPA identification (EPA ID) number for each site that generates hazardous waste. To obtain an EPA ID number, you must complete and submit EPA Form 8700-12, Notification of Regulated Waste Activity, otherwise known as the Site ID Form.

Managing Hazardous Waste On-Site (40 CFR 262.17)

  • An LQG may accumulate any quantity of hazardous waste in containers, tanks, drip pads, and containment buildings for up to 90 days without a RCRA permit, provided that you meet the technical standards for the containment unit.
  • Under the Land Disposal Restrictions (LDRs), most hazardous wastes may not be land disposed until they meet “treatment standards.” It is your responsibility to ensure that your waste is treated to these standards.
  • LQGs are also responsible for complying with “emergency preparedness and prevention” requirements. The LQG must prepare a written contingency plan, make arrangements with local emergency responders, and train employees on hazardous waste management and emergency response.
  • If your facility accumulates wastes for more than 90 days, it is considered a storage facility and must follow regulations described in 40 CFR Parts 264/265 and 270, unless you have been granted an extension by your EPA Regional Administrator.

Acceptable Generator Knowledge for Making Hazardous Waste Determinations

  • Waste origin
  • Composition.
  • Process knowledge (e.g., information about chemical feedstocks and other inputs to the production process).
  • Knowledge of products, by-products, and intermediates produced by the manufacturing process.
  • Chemical or physical characterization of wastes.
  • Information on the chemical and physical properties of the chemicals used or produced by the process or otherwise contained in the waste.
  • Testing that illustrates the properties of the waste.
  • Other reliable and relevant information about the properties of the waste or its constituents.

Preparing Hazardous Waste for Shipment Off Site (40 CFR 262.30–262.33)

You must package, label, and mark your waste containers, and placard vehicles that carry the wastes according to the DOT Hazardous Materials Transportation Act requirements (49 CFR Parts 172, 173, 178, and 179). Commercial waste handlers can advise you on the proper procedures, but you remain responsible for compliance.

Containers also must be labeled with all applicable RCRA waste codes prior to shipment. Alternative systems like barcoding or radio frequency identification are acceptable as well, as long as they can identify the wastes contained in a specific container.

Manifesting Requirements (40 CFR 262.20–262.27)

  • A Uniform Hazardous Waste Manifest (EPA Form 8700- 22) must accompany all hazardous waste that is shipped off site.
  • A manifest is a multipart form designed to track hazardous waste from the time it leaves the generation site until it reaches the treatment, storage, and disposal facility (TSDF) specified on the manifest.
  • All generators now have the option of creating and submitting their Uniform Hazardous Waste Manifests electronically using the e-Manifest system.

Reporting (40 CFR 262.41–262.43)

  • Biennial Reporting
  • Exception Reporting

Recordkeeping (40 CFR 262.40)

Complying with Land Disposal Restrictions (40 CFR Part 268)

Export/Import Requirements (40 CFR Part 262 Subpart H)

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