Key Annual RCRA Notifications for SQG and VSQG’s

Two agency notifications may be required for Small Quantity Generators (SQG’s) and Very Small Quantity Generators (VSQG’s).  VSQG’s were formerly known as Conditionally Exempt Small Quantity Generators (CESQG’s).   The 2016 Hazardous Waste Generator Improvement Rule requires SQG’s to re-notify the US EPA or state agency concerning their hazardous waste activities.  SQGs are now required to re-notify EPA or their state environmental agency as to their generator status every four years by completing and submitting the Notification of Resource Conservation and Recovery Act (RCRA) Subtitle C Activities (Site Identification Form) in full, also known as EPA Form 8700-12, or state equivalent.  The purpose of the re-notification requirement is to improve the SQG universe data and to maintain more accurate data into the future for outreach, compliance assistance, and oversight activities.

The first re-notification is due by September 1, 2021, and then every four years thereafter i.e., September 1, 2025, September 1, 2029, etc.  However, if you have re-notified for other reasons after 2016 and before September 1, 2021 no re-notification is necessary. 

Sometimes as a VSQG or SQG has more hazardous waste generated in a month than normal, usually due to cleaning events and/or plant shutdowns and/or other circumstances.  This is a One-Time Episodic event and requires submittal of information to the agency in order to retain their generator status.  SQGs and VSQGs must notify the EPA or their state at least 30 days prior to a planned event, and within 72 hours of an unplanned event. If a VSQG does not already have an EPA identification number, then one must be obtained.  Waste generated during this one-time event can be accumulated in tanks drums and containers but should be labeled, “Episodic Hazardous Waste.” 

If there is an additional event in the calendar year the generator must submit a petition to the agency.  Episodic hazardous waste must be removed 60-days after the accumulation event started.  For example if the notifications were in place for a “Planned,” event and the waste was generated on day one then there are 59 remaining days until the waste must be removed. 

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