Large Quantity Generators – Business Environmental Program

BIENNIAL REPORTS are due March 1, 2024

Kat Olson is hosting open office hours and offering one-on-one appointments through Zoom to help Large Quantity Generators and Treatment, Storage, and Disposal Facilities with completing and submitting their Biennial Report for the 2023 reporting year.

Come with your questions, RCRAInfo login information, manifests, and other reports. Screen share will be available to better assist you.

CLICK HERE to join a Zoom session or schedule a one-on-one appointment.

What is a Large Quantity Generator (LQG)?

LQGs generate in a calendar month:

At least 2,200 lbs. (1,000 kg) of nonacute hazardous waste
Or more than 220 lbs. (100 kg) of acute spill cleanup residue
Or more than 2.2 lbs. (1 kg) of acute hazardous waste

LQGs are subject to extensive management requirements. Some of the requirements are summarized here. However, you should ensure your facility follows all the rules established by the EPA and the State of Nevada.

Obtain an EPA ID Number.
Identify all the hazardous wastes that you generate, at the point of generation, and count it monthly. Keep waste determination records for 3 years.
LQGs are not subject to on-site accumulation quantity limits
LQGS can store hazardous waste on-site for up to 90 days. After 90 days, the facility will need a RCRA permit
Accumulate no more than one 55-gallon drum in a Satellite Accumulation Area (SAA). Label the container with the words “Hazardous Waste”, and an indication of the hazards of the contents (e.g., flammable, toxic).
Use containers that are compatible with the hazardous waste to be stored.
Keep containers closed at all times except when adding or removing waste.
Once the container reaches the Satellite Accumulation Area limit, date the container and move the container to the 90-day central accumulation area. The container must be moved within 3 days of accumulation.

Proper labeling is required in the 90-day central accumulation area. The label must contain the start date of accumulation, the hazards associated with the waste (e.g., a pictogram), the EPA waste codes, a description of the contents, and the words “Hazardous Waste”.

Inspect hazardous waste central accumulation area weekly and keep records of inspections for 3 years (NAC 444.8677).
- Use BEP’s comprehensive LQG Weekly Inspection Checklist Tool or our annual Hazardous Waste Compliance Calendar to help your facility maintain compliance with weekly inspections.
Prepare a hazardous waste manifest either electronically or with a paper form to accompany your waste shipment. Once shipped, keep signed copies of the records for at least 3 years from the date the waste was shipped.
LQGs must have a complete preparedness and prevention plan in place. (§262 Subpart M)
LQG personnel must complete classroom and/or on the job training (§262.17(a)(7)) to ensure appropriate personnel has:
- Familiarization with proper hazardous waste management
- Ability to handle emergencies
- Knowledge on the wastes handled at the facility
- Training is required within 6 months of start date and then annually
- Keep all records of training
- Document training topics covered

LQGs are required to have a full Contingency Plan and a Quick Reference Guide of the plan. The State of Nevada is requiring a Quick Reference Guide to be completed by those facilities that are:
- a new site as of August 25, 2020
- revising their current contingency plan if in operation prior to January 1, 2021
- the quick reference guide must contain the following:
  - The types and names of the hazardous wastes on site and their hazard in layman’s terms (e.g., toxic paint wastes, spent ignitable solvents);
  - An estimated maximum amount of each hazardous waste on site at any one time;
  - The identification of any hazardous waste that would require unique or special treatment by medical staff in the event of exposure;
  - A map of the facility identifying where hazardous waste may be located;
  - A street map of the facility in relation to surrounding businesses, residences, and schools;
  - The location of the water supply;
  - Information about any on-site notification systems to communicate with people at the facility; and
  - The name of an emergency coordinator available at any time.
LQGs must submit a Biennial Report every even numbered year for the previous year’s generation. For example, the biennial reporting deadline of March 1, 2022 will contain all the data from generation in the year 2021. To submit Biennial Reports, visit RCRA Info Online. BEP routinely conducts a training on submitting these reports. Contact BEP for information.
Keep a copy of all records. (§262.11(f) and §262.40)
LQGs can now consolidate waste from VSQGs if they are under the control of the same “person”. Find more about this adopted Generator Improvement Rule and its definitions here.

While the above list is only a summary of the regulations that LQGs must adhere to, BEP can help you navigate the regulatory landscape for hazardous waste. We offer site visits to help you assess your hazardous waste management practices and are here to find answers to your questions.

And remember, it makes good business sense to limit the amounts of hazardous wastes generated even if your facility cannot step down in generator status. Employing pollution prevention techniques, implementing sustainability practices such as designing waste out of production, or using non-hazardous materials in your processes will lower your waste costs and minimize the amounts of hazardous wastes generated. There are many resources available to you.