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Air Indoor Resources - Hazardous Waste Management

Generator Size Determination

Generator size determination is based on the amount of hazardous waste you generate per month or that is stored on-site. A running inventory is invaluable and should include date of accumulation and number of containers for each waste type. At this time, there are three categories of generator size:

Conditionally Exempt Small Quantity Generators (CESQG) – Conditionally Exempt Small Quantity Generators generate less than 220 pounds (100 kilograms), which is approximately one half of a 55-gallon drum or not to exceed 2.2 pounds (1 kilogram) of acute RCRA hazardous waste in any one month. CESQGs are not allowed to accumulate over 2,200 pounds (1,000 kilograms) at any one time. CESQGs are not necessarily subject to the requirement of using EPA Identification Numbers and using a manifest when shipping hazardous waste. Proper RCRA disposal is required with three-year record retention of all receipts, bills of lading, shipping papers, or records with name and address of generator(s) and disposal facility, type and amount of hazardous waste, and date of shipment.

See DEP’s CESQG Checklist. (Word)

Approximately one-half of a 55-gallon drum or less of hazardous waste per month qualifies you as a Conditionally Exempt Small Quantity Generator.

Small Quantity Generator (SQG) – Small Quantity Generators generate more than 220 pounds but less than 2,200 pounds per month, which is up to five 55-gallon drums of hazardous waste per month. SQGs have many more management responsibilities than CESQGs, such as:

  1. Obtaining DEP/EPA Identification Number;
  2. Use of a multiple-copy disposal manifest;
  3. Never exceeding 13,228 pounds or 6,000 kilogram hazardous waste at any one time;
  4. Not storing hazardous waste more than 180 days;
  5. Emergency Planning and the appointment of a 24-hour Emergency Coordinator with emergency telephone numbers posted near the telephone;
  6. Use of DEP-registered waste transporters for off-site shipments;
  7. Three-year record retention for manifests, analytical tests, and documentation;
  8. Documented weekly hazardous waste container inspection;
  9. Personnel training regarding hazardous waste handling and emergency response; and
  10. Filing an exception report to the DEP, if the three signature manifest is not received within 60 days from the date of shipment.

See DEP’s Small Quantity Generator Checklist. (Word)

Large Quantity Generator (LQG) – Large Quantity Generators generate over 2,200 pounds or 2.2 pounds of acute hazardous waste per month that cannot be stored on-site for more than 90 days. The voluminous LQG requirements will not be discussed since only the University of Florida is considered an LQG.

The rule of thumb is that one gallon of hazardous waste on average weighs ten pounds per gallon. The volumes cited above for generator size use the weight of water at 8 pounds per gallon as an estimate for conversion. Heavier wastes, such as metal sludge, use 20 pounds per gallons, and chlorinated solvents use 12 to13.5 pounds per gallon. The actual weight per gallon of the waste (including the tare weight of the container) can also be used to evaluate generator status.

In Florida, certain wastes that go for recycling or reclamation may not count against your generator status for wastes. These exceptions include:

  1. Spent lead-acid batteries for off-site reclamation.
  2. Used oil for recycling that has not been mixed with any hazardous waste.
  3. Antifreeze for recycling.
  4. Petroleum Contact Water managed in accordance with Chapter 62-740, FAC.
  5. Hazardous waste batteries, pesticides, and mercury-containing devices managed as an EPA Universal Waste per 40 CFR Part 273 and Chapter 62-737, FAC.

Universal Waste rules cover common low-hazard wastes that have less stringent waste management rules to encourage their disposal in a timely fashion.

For more information, please see:

Contact Information

Wendy Murphy
325 West Gaines Street
Suite, 1054
Tallahassee, FL 32399
Phone: (850) 245-9295