The information in this section applies to a generator who generates the following amounts in a calendar month: Greater than 100 kilograms (220 lbs.) but less than 1,000 (2200 lbs) of non-acute hazardous waste; and less than or equal to 1 kilogram (2.2 lbs.) of acute listed hazardous waste listed in; and less than or equal to 100 kilograms (220 lbs.) of any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill into or on any land, water, of any acute listed hazardous waste.

Identify: SQGs must determine if they have generated a solid and hazardous waste in accordance with the regulations. Generators may use knowledge of their waste to make a solid and hazardous waste determination, or have it tested if uncertain.

Count: All generators must count all the waste they generate on a monthly basis to determine generator status. This section clarifies for SQGs the implications of mixing a solid waste with a hazardous waste resulting in the generation of a new hazardous waste.

SQG Notification: SQGs are required to submit an EPA Form 8700-12 to obtain an EPA Identification number.

SQG Re-Notification: Beginning in 2021, and every four years thereafter, SQGs must re-notify Virginia DEQ that they still maintain their SQG category using EPA Form 8700-12. This new requirement is designed to assist DEQ in understanding more accurately its SQG universe so that it can plan program activities and communicate more effectively with this universe of facilities. 

See DEQ Notification and SQG-Renotification Page for additional information.

SQGs must manage hazardous waste in containers or tanks that are in good condition to prevent spills and releases to the environment that endangers human health. Hazardous wastes can be accumulated on site for 180 days without a hazardous waste storage permit, or 270 days if the hazardous waste is shipped more than 200 miles away.

Labeling Requirements: SQGs are required to meet certain labeling requirements. These include marking containers and tanks with the words "Hazardous Waste", labeling containers and tanks to indicate the hazards of the contents (e.g. Corrosive, toxic), and identifying on containers all applicable EPA hazardous waste codes found in Subparts C and D of part 261 no later than just prior to shipping the waste off-site for subsequent management.

Recordkeeping Requirements for Tanks: SQGs may use logs, monitoring equipment or other records to demonstrate that hazardous waste is either emptied or removed from hazardous waste tanks within 180 days. Records must be kept on site, in close proximity to where hazardous waste is being accumulated in the tank, or if not practical (i.e., exposure to weather, physically infeasible, etc.) in a control room, or other central location at the facility, and readily available for inspections. The methods used to demonstrate that a tank has been emptied must be reasonable and easily discernible.

Accumulating HW by SQGs on Drip Pads and in Containment Buildings: The regulations address the accumulation of hazardous wastes by SQGs on drip pads and in containment buildings, respectively. Accumulating hazardous waste in these types of units that are only generating quantities of hazardous wastes associated with SQGs have 180 days before having to ship its hazardous wastes off-site to a RCRA permitted TSDF. SQGs accumulating hazardous wastes in a containment building have only 90 days before having to send the waste off-site to a RCRA permitted TSDF; technical requirements for containment buildings can be found here.

Labeling Requirements for Containment Buildings: To meet these requirements, the generator can keep information in logs or records near the accumulation unit. When the waste is transferred to containers for shipment, the labels should be transferred to the containers when the waste in the containment building is first put in containers.

Regulations regarding preparedness, prevention and emergency procedure for SQGs are addressed in this section.

Arrangements with Local Authorities: SQGs must maintain records documenting arrangements with local fire departments as well as any other organization necessary to respond to an emergency. Documentation must be contained in the operating record confirms such arrangements exist or confirms that attempts to make such arrangements were made in accordance with applicable regulations.

Access to Communications or Alarm System: There must be immediate access to an internal alarm or emergency communication device unless such a device is not required. In the event there is just one employee on the premises while the facility is operating, the employee must have immediate access (e.g., direct or unimpeded access) to a device, such as a telephone (immediately available at the scene of operation) or a hand-held two-way radio, capable of summoning external emergency assistance, unless such a device is not required.

SQGs Possessing 24-hour Response Capabilities: SQGs possessing 24-hour emergency response capabilities may seek a waiver from the authority having jurisdiction (AHJ) over the fire code within the facility's state or locality as far as needing to make arrangements with the local fire department as well as any other organization necessary to respond to an emergency, provided that the waiver is documented in the operating record.

Cleanup of Spills: In the event of a spill, the small quantity generator is responsible for containing the flow of hazardous waste to the extent possible, and as soon as is practicable, cleaning up the hazardous waste and any contaminated materials or soil. Such containment and cleanup can be conducted either by the small quantity generator or by a contractor on behalf of the small quantity generator.

Episodic Generation: SQGs may operate under streamlined requirements if they have a temporary change in their generator category as a result of an episodic event provided that certain requirements are met. SQGs can have one episodic event per calendar year with the ability to petition for a second episodic event. Episodic events can last 60-days. SQGs must notify DEQ about the episodic events using the Site ID form (EPA Form 8700-12). Wastes generated during the episodic event must be managed in accordance with 262 Subpart L. More information regarding regulations can be found on DEQ's website under Episodic Waste Generation.

 Transportation and Delivery: SQGs must ship hazardous waste using a hazardous waste transporter and a Uniform Hazardous Waste Manifest to a permitted hazardous waste treatment, storage, and/or disposal facility, or a RCRA recycler.