The Complete Guide to Large Quantity Generators (LQGs): Comprehensive Requirements, Compliance Programs, and Risk Management
The Complete Guide to Large Quantity Generators (LQGs): Comprehensive Requirements, Compliance Programs, and Risk Management
Last Updated: January 2026
If your facility generates 1,000 kilograms (2,200 pounds) or more of hazardous waste per month, you're classified as a Large Quantity Generator (LQG) under EPA regulations. This is the most stringent regulatory tier for hazardous waste generators, with comprehensive compliance requirements designed to protect human health and the environment at facilities generating substantial waste volumes.
LQG status requires dedicated environmental resources, formal compliance programs, extensive documentation, and ongoing regulatory oversight. This comprehensive guide provides everything you need to understand LQG requirements, implement compliant programs, manage regulatory risk, and optimize your hazardous waste operations.
What is a Large Quantity Generator (LQG)?
A Large Quantity Generator is EPA's highest regulatory classification for hazardous waste generators under the Resource Conservation and Recovery Act (RCRA). LQGs face the most comprehensive federal environmental requirements due to the substantial waste volumes and potential environmental risk.
LQG Definition and Thresholds
Your facility qualifies as an LQG if you generate:
1,000 kilograms (2,200 pounds) or more per month of hazardous waste
OR
More than 1 kilogram (2.2 pounds) per month of acutely hazardous waste (P-listed waste)
Practical perspective:
1,000 kg is approximately five full 55-gallon drums of hazardous waste per month
Most large manufacturing facilities, chemical plants, refineries, and major industrial operations are LQGs
Even exceeding threshold by 1 kg (generating 1,001 kg instead of 999 kg) triggers LQG status
Why LQG Requirements Are So Comprehensive
High-volume waste generation creates greater risk:
More opportunities for spills and releases
Larger environmental impact if mismanaged
Greater worker exposure potential
Substantial public health consequences
LQG facilities are serious operations:
Usually industrial or manufacturing facilities
Employ environmental, health, and safety professionals
Have resources for comprehensive compliance programs
Significant enforcement priority for EPA and states
Regulations reflect risk:
90-day accumulation limit (vs. 180/270 for SQGs)
Comprehensive training requirements
Written contingency plans
Formal inspection programs
Biennial reporting to EPA
Extensive documentation
Who Typically Qualifies as an LQG?
Large industrial operations across numerous sectors commonly operate as LQGs.
Manufacturing and Chemical Processing
Chemical Manufacturing:
Specialty chemical manufacturers
Pharmaceutical manufacturing facilities
Petrochemical plants
Polymer and plastics production
Industrial chemical synthesis
Contract manufacturing operations
Examples:
Dow Chemical facilities
DuPont operations
BASF plants
Eastman Chemical
Huntsman facilities
Regional chemical manufacturers
Petroleum Refining:
Oil refineries processing crude oil
Reformulation and blending facilities
Petrochemical integration
Tank bottom cleaning
Catalyst regeneration
Major refiners:
ExxonMobil, Chevron, Marathon, Phillips 66, Valero
All major refineries are LQGs
Metal Manufacturing:
Primary metal production (steel, aluminum, copper)
Metal fabrication and finishing
Electroplating operations
Metal coating and painting
Heat treating facilities
Examples:
Steel mills (Nucor, U.S. Steel, ArcelorMittal)
Aluminum smelters (Alcoa facilities)
Metal finishing job shops
Automotive parts suppliers
Electronics and Semiconductor Manufacturing:
Semiconductor fabrication (fabs)
Printed circuit board manufacturing
Electronics assembly with cleaning
Solar panel manufacturing
Major facilities:
Intel fabs
Texas Instruments
Micron Technology
Global Foundries
All major semiconductor manufacturers are LQGs
Aerospace and Defense
Aircraft Manufacturing:
Boeing assembly plants (Everett WA, Renton WA, Charleston SC)
Airbus Mobile AL
General aviation manufacturers
Engine manufacturing (GE Aviation, Pratt & Whitney, Rolls-Royce)
Defense Contractors:
Lockheed Martin facilities
Northrop Grumman plants
Raytheon manufacturing
General Dynamics operations
Surface Treatment and Coating:
Paint stripping operations
Chromate conversion coating
Anodizing facilities
Extensive solvent use
Automotive Manufacturing
Vehicle Assembly Plants:
Major automotive OEMs (Ford, GM, Stellantis, Toyota, Honda, Nissan, Hyundai, BMW, Mercedes, Volkswagen, Tesla)
Paint shops generating substantial waste
Assembly operations
Stamping and body fabrication
Automotive Parts Suppliers:
Tier 1 suppliers (major components)
Painting and coating operations
Machining and metal working
Electronics manufacturing
Pharmaceutical and Biotechnology
Pharmaceutical Manufacturing:
Active pharmaceutical ingredient (API) synthesis
Formulation and packaging
Research and development facilities
Contract manufacturing organizations (CMOs)
Major companies (all have LQG facilities):
Pfizer, Merck, Johnson & Johnson, Bristol Myers Squibb, Eli Lilly, AbbVie, Amgen, Gilead
Biotechnology Manufacturing:
Biological drug production
Cell culture operations
Purification and processing
Fill-finish operations
Research and Development
Department of Energy national labs
National Institutes of Health facilities
Department of Defense research facilities
NASA research centers
Academic Medical Centers and Universities:
Large research universities with extensive lab programs
Academic medical centers with research missions
Veterinary schools and hospitals
Utilities and Energy
Electric Power Generation:
Coal-fired power plants (ash and scrubber waste)
Oil-fired generation facilities
Combined cycle plants
Cogeneration facilities
Nuclear Power:
Nuclear power plants (mixed waste - radioactive and hazardous)
Fuel fabrication facilities
Research reactors
Waste Management Facilities
Treatment, Storage, and Disposal Facilities (TSDFs):
Commercial hazardous waste facilities
Waste treatment operations
Incinerators
Recycling facilities
Military Installations
Department of Defense Facilities:
Major military bases with maintenance operations
Depot-level maintenance facilities
Ammunition plants
Naval shipyards
Air Force bases with aircraft maintenance
Complete LQG Requirements: The Full Compliance Program
LQGs must implement comprehensive hazardous waste management programs addressing all RCRA requirements.
1. EPA Identification Number (Mandatory)
Obtain before generating first LQG waste volume
Same as SQG requirement but more critical given regulatory scrutiny:
Complete EPA Form 8700-12 or state equivalent
Provide detailed facility information
List all waste codes generated
Update when waste streams change
Each physical location needs separate EPA ID
Verification:
Confirm EPA ID on all manifests
Ensure transporters and TSDFs have valid EPA IDs
Update registration if facility changes ownership or operations
2. Strict 90-Day Accumulation Time Limit
CRITICAL - Most common LQG violation
LQGs may accumulate hazardous waste on-site for maximum 90 days from accumulation start date.
Accumulation start date:
Date first waste added to container
NOT when container is full
Must mark clearly on container label
Calendar days, not business days (weekends and holidays count)
No quantity limit for LQGs (unlike SQGs limited to 6,000 kg)
Can accumulate unlimited quantity if within 90-day limit
Must meet all other storage requirements
If 90-day limit exceeded:
Facility becomes operating storage facility without permit
Major violation
Penalties $37,500+ per day per violation
EPA enforcement priority
May require permit application
Managing 90-Day Compliance:
Tracking systems mandatory:
Electronic database preferred (environmental software)
Spreadsheet tracking minimum
Physical tags on containers
Regular audits (weekly recommended)
Conservative pickup scheduling:
Schedule pickups at 75-80 days
Allows buffer for holidays, weather, scheduling conflicts
Emergency backup plan if scheduled pickup falls through
Day 1 verification:
Train staff: accumulation starts when FIRST waste added
Common mistake: thinking accumulation starts when container full
Mark date immediately, not later
Satellite accumulation areas (discussed later) provide additional flexibility.
3. Comprehensive Container Management
Federal Standards for Accumulation Containers:
Container Condition:
Good condition (no severe rust, dents, leaks)
Structurally sound
Compatible with waste
Appropriate for waste type and hazards
Closure:
Containers must remain closed except when adding/removing waste
Secure lids, bungs, or caps
No open-top containers unless in use
Compatibility:
Container material compatible with waste
Steel for most solvents
Poly drums for corrosives (where appropriate)
Compatibility charts available
Secondary Containment:
Required for liquids and certain semi-solids:
Must contain 110% of largest container volume OR
10% of total contained volume, whichever is greater
Impervious to waste being stored
Free of cracks or gaps
Sloped to drain to sump (for larger systems)
Secondary containment options:
Spill pallets under drums
Concrete containment berms
Steel or poly containment units
Vault storage
Double-walled containers
Labeling Requirements:
Every container must have:
"Hazardous Waste" label
Words "Hazardous Waste" clearly visible
Minimum 3-inch letters recommended
Durable, weather-resistant
Waste contents description
Specific description (not just "solvent" but "Spent Acetone")
Chemical names or common names
Enough detail for emergency responders
Accumulation start date
Date first waste added
Format: MM/DD/YYYY
Permanent, indelible marking
Hazard information
Physical hazards (flammable, corrosive, toxic)
DOT hazard class if applicable
GHS pictograms recommended
EPA waste codes (recommended)
D001, F003, etc.
Helps TSDF processing
Example LQG container label:
⚠ HAZARDOUS WASTE ⚠
Contents: Spent Paint Thinner (Mineral Spirits)
Waste Codes: D001, F005
Hazard: Flammable Liquid
Accumulation Start Date: 01/15/2026
Generator: ABC Manufacturing
EPA ID: CAD123456789
4. Designated Accumulation Areas
LQG accumulation areas must meet specific standards:
Location Requirements:
Within facility control
Away from property line (minimize public exposure)
Protected from weather (covered or weatherproof containers)
Adequate ventilation
Away from incompatible materials
Access Control:
Limited to authorized personnel only
Locked or controlled access
Signage: "Hazardous Waste Accumulation Area - Authorized Personnel Only"
Prevent unauthorized entry
Emergency Equipment:
Fire extinguishers appropriate for waste types
Spill cleanup materials (absorbents, neutralizers)
PPE (gloves, goggles, respirators if needed)
Emergency shower/eyewash (if corrosives or reactives)
Communications equipment (phone, radio, alarm)
Emergency equipment must be tested and inspected regularly
Aisle Space:
Adequate space for inspections
Emergency access and response
Equipment operation
OSHA requirements (minimum 3-foot aisles typically)
Fire code requirements
Incompatibility:
Separate incompatible wastes
Physical barriers if necessary
No acids with bases
No oxidizers with flammables
Compatibility matrix posted
Container Inspection:
Must inspect WEEKLY (documented)
Check for leaks, corrosion, damage
Verify labels accurate and legible
Confirm proper closure
Verify accumulation dates not approaching limits
Document inspections in log
5. Satellite Accumulation Areas (SAAs)
Valuable flexibility for LQGs
LQGs can use Satellite Accumulation Areas at or near waste generation points before moving waste to central accumulation area.
SAA Rules:
Location:
At or near point of generation
Under control of operator generating waste
Example: Parts washer with waste solvent drum adjacent
Quantity Limits:
Maximum 55 gallons of hazardous waste per container
OR 1 quart of acutely hazardous (P-listed) waste
Once limit reached, must move to central accumulation within 3 days
3-day period starts 90-day clock for that container
Container Requirements:
Good condition, compatible, closed except when adding waste
Marked "Hazardous Waste"
Marked with contents
NO accumulation start date required while in SAA
Benefits:
No time limit while under 55 gallons
Reduces handling (accumulate at source)
Operator oversight ensures proper management
Only starts 90-day clock when moved or full
Best Practices:
Don't abuse SAA provisions (keeping containers "perpetually under 55 gallons")
Move to central accumulation regularly
Train operators on SAA rules
Inspect SAAs during weekly inspections
6. Manifesting All Waste Shipments
Uniform Hazardous Waste Manifest required for every shipment
Same as SQG requirements but greater scrutiny and volume:
Manifest Completion:
Generator completes manifest before shipping
Lists all required information (generator, transporter, TSDF, waste description, quantity, codes)
Signs generator certification
Distributes copies to transporter and keeps copy
Waste Description:
Must be DOT proper shipping name
Hazard class
ID number (UN/NA number)
Packing group
Example: "Waste Flammable Liquids, n.o.s. (Acetone, Toluene), 3, UN1993, II"
Land Disposal Restrictions (LDR):
LQGs must provide LDR notification and certification with waste
Specifies treatment standards
Required before waste can be landfilled
Can be on manifest or separate form
Tracking Return Copies:
LQGs must receive signed manifest copy from TSDF
Exception reporting if not received within 45 days (vs. 60 days for SQGs)
Submit exception report to EPA within 60 days (vs. 75 days for SQGs)
Maintain manifest copies 3 years minimum
E-Manifest:
Electronic manifest system available
Recommended for LQGs (simplifies tracking)
Automated exception tracking
Digital recordkeeping
Fee per manifest ($5-$8)
7. Comprehensive Personnel Training
Formal training program REQUIRED
LQGs must implement and document comprehensive training for all employees handling hazardous waste.
Training Requirements:
Who must be trained:
All facility personnel handling hazardous waste
Anyone who manages containers
Personnel in accumulation areas
Shipping/receiving staff
Emergency responders
Environmental coordinators
Management overseeing waste operations
Training Frequency:
Initial training before job assignment involving hazardous waste
Annual refresher training (within 12 months of previous training)
Additional training when procedures change
Required Training Topics:
Hazardous Waste Management Procedures:
Waste identification and characterization
Proper container selection
Labeling requirements and procedures
Accumulation area rules
Accumulation time limits and tracking
Satellite accumulation procedures
Inspections and documentation
Emergency Response:
Spill response procedures
Fire prevention and suppression
Emergency equipment location and use
Evacuation procedures
Emergency contacts and communications
Incident reporting
Manifesting and Shipping:
Manifest completion
DOT requirements
Proper packaging and labeling for transport
LDR notifications
Regulatory Requirements:
RCRA overview
LQG requirements
Federal and state regulations
Consequences of non-compliance
Safety and PPE:
Hazards of specific wastes handled
PPE selection, use, and maintenance
Safe handling practices
Chemical safety and SDS review
Exposure prevention
Job-Specific Procedures:
Position-specific responsibilities
Department waste streams
Specialized equipment or procedures
Training Documentation Requirements:
Must maintain records including:
Employee name and job title
Training date(s)
Instructor or training program description
Training topics covered
Length of training session
Employee signature acknowledging training
Competency verification (test, observation, etc.)
Retention: Training records for current employees + 3 years after departure
Annual Training Planning:
Schedule training calendar
Refresher sessions for all staff
New hire orientation including hazardous waste
Track completion and maintain compliance
Update training materials as procedures change
8. Written Contingency Plan
REQUIRED - Formal emergency response planning
LQGs must develop and implement written contingency plans addressing emergency situations.
Contingency Plan Contents:
Emergency Coordinators:
Name, addresses, phone numbers (work and home) of all persons qualified as emergency coordinators
Primary and alternates
At least one on call or on-site at all times
Authority to commit resources
Emergency Equipment:
List of all emergency equipment
Fire extinguishers (types, locations, inspections)
Spill control equipment
Decontamination equipment
Communications equipment
PPE for emergency response
Location and physical description
Capabilities and limitations
Evacuation Plan:
Evacuation routes
Assembly points
Signals for evacuation
Personnel accountability procedures
Special considerations (disabled employees)
Emergency Response Procedures:
Actions for fires, explosions, or releases
Who takes what actions
When to fight fires vs. evacuate
Spill containment procedures
Exposure minimization
Facility shutdown procedures if necessary
Emergency Notifications:
When to notify authorities (fire department, EPA, state agency)
Internal notification procedures
External notification requirements
Reportable quantity releases
Contact information for all agencies
Facility Map:
Facility layout showing:
Hazardous waste accumulation areas
Emergency equipment locations
Evacuation routes and assembly points
Utility shutoffs
Water sources
Distribution:
Local fire department
Police department
Hospital emergency room
State and local emergency response authorities
Keep copy at facility (accessible 24/7)
Updates:
Review and update annually
Update whenever procedures change
Update when emergency coordinator changes
Update when facility layout changes
Document all updates
Testing and Drills: While not federally required, highly recommended:
Annual emergency drills
Tabletop exercises
Test emergency equipment
Verify contact information current
Train on plan implementation
9. Preparedness and Prevention
REQUIRED - Proactive risk management
LQGs must maintain equipment and procedures preventing releases.
Required Equipment:
Internal Communications:
Phone, intercom, or radio system
All employees can summon help
Backup systems if primary fails
External Communications:
Telephone or radio for contacting fire department, police, emergency response
Emergency contact numbers posted
After-hours access to communications
Fire Control:
Portable fire extinguishers
Appropriate for waste types stored
Inspected and maintained
Employees trained on use
Fixed fire suppression in some cases
Spill Control and Cleanup:
Absorbent materials
Neutralization agents (acids/bases)
Containment materials
Cleanup tools
Personal protective equipment
Enough capacity for largest expected spill
Decontamination Equipment:
Emergency showers
Eyewash stations
Tested weekly
Appropriate locations
Water Availability:
Adequate water pressure and supply for fire suppression and decontamination
Verify annually
Facility Design:
Adequate aisle space for emergency response
Access roads for emergency vehicles
Proper drainage preventing off-site releases
Testing Requirements:
Test emergency equipment regularly
Document testing
Repair or replace malfunctioning equipment
Maintain test logs
Arrangements with Authorities:
Familiarize local fire department with facility
Provide contingency plan
Conduct facility tours
Update on changes
10. Weekly Inspections (Documented)
REQUIRED - Formal inspection program
LQGs must inspect accumulation areas weekly and document inspections.
Weekly Inspection Requirements:
What to Inspect:
Container integrity (no leaks, rust, damage)
Proper container closure
Label accuracy and legibility
Accumulation start dates not approaching 90-day limit
Secondary containment integrity
Spills or releases
Emergency equipment condition
Aisle space adequate
Inspection Documentation:
Date and time of inspection
Inspector name/signature
Observations and findings
Corrective actions needed
Follow-up on previous issues
Problems noted and resolved
Inspection Logs:
Maintain for 3 years
Make readily available for inspections
Electronic or paper acceptable
Sign/initial each inspection
Corrective Actions:
Document problems found
Immediate action for safety hazards
Track until resolved
Follow-up verification
Example Inspection Checklist:
Hazardous Waste Weekly Inspection Log
Date: ________ Time: ________ Inspector: ________
Accumulation Area: ________
☐ Containers in good condition (no leaks, damage)
☐ All containers properly closed
☐ Labels present and legible
☐ Accumulation dates within 90-day limit
☐ Secondary containment intact and functioning
☐ No spills or releases
☐ Aisle space adequate
☐ Fire extinguisher present and inspected
☐ Spill cleanup materials available
☐ Emergency equipment functional
☐ Incompatible wastes separated
Problems Found: _______________
Corrective Actions: _______________
Follow-up Required: _______________
Inspector Signature: _______________
11. Biennial Report
REQUIRED - Every two years
LQGs must submit biennial reports to EPA by March 1 of even-numbered years.
Reporting Period:
Covers previous odd-numbered year
Example: Report due March 1, 2026 covers calendar year 2025
Required Information:
Facility Information:
Facility name and EPA ID number
Address and contact information
NAICS codes
Waste Generation:
Waste codes generated
Quantities (estimated or actual)
Waste sources and processes
Waste Management:
Management methods (recycling, treatment, disposal)
Facilities receiving waste
Quantities to each facility
Waste Minimization:
Efforts to reduce waste generation
Results of minimization activities
Certification:
Owner/operator signature certifying accuracy
Waste minimization program in place
Submission:
Some states: Paper forms
Most states: Electronic reporting systems
Federal e-manifest system
State-specific portals
Penalties for Late/Missing Reports:
Enforcement action
Fines
Potential permit issues
Best Practice:
Gather data throughout year (don't wait until deadline)
Review manifests systematically
Track waste generation monthly
Prepare draft report early
Review before submission
12. Land Disposal Restrictions (LDR)
REQUIRED - Treatment standards compliance
LQGs must ensure waste meets treatment standards before land disposal.
LDR Requirements:
Notification:
Must notify TSDF of LDR status of waste
Can be on manifest or separate form
Includes waste codes and treatment subcategories
Certification Options:
Treatment Not Required:
Waste meets treatment standards as generated (rare)
Generator certifies waste characteristics
Treatment Required:
Waste needs treatment before landfilling
TSDF treats to meet standards
Generator certifies treatment is required
One-Time Notifications:
For regular waste streams, one-time notification acceptable
Must notify if waste changes
Documentation:
Maintain LDR forms 5 years (longer than general 3-year requirement)
LQG Violation Risks and Penalties
LQGs face significant enforcement risks due to regulatory complexity and scrutiny.
Common LQG Violations
1. Exceeding 90-Day Accumulation Limit
Most frequent LQG violation
Operating storage facility without permit
Penalties: $37,500+ per day
2. Inadequate Training or Documentation
Missing training records
No annual refresher
Insufficient training content
Penalties: $10,000-$50,000
3. Missing or Late Biennial Reports
Report not filed by March 1
Incomplete information
Penalties: $5,000-$25,000
4. Improper Container Management
Open containers
Poor condition
No secondary containment
Penalties: $5,000-$50,000
5. Inadequate Inspections
No weekly inspections
Missing documentation
Penalties: $5,000-$25,000
6. Missing or Inadequate Contingency Plan
No written plan
Outdated information
Not provided to authorities
Penalties: $10,000-$50,000
7. Manifest Violations
Improper completion
Missing exception reports
Lost manifests
Penalties: $5,000-$25,000 per occurrence
Enforcement Actions
Inspection Frequency:
LQGs inspected more frequently than SQGs/VSQGs
Major LQGs: Every 2-3 years common
Some states: Annual inspections
Consequences of Violations:
Administrative Actions:
Compliance orders
Administrative penalties
Corrective action requirements
Civil Penalties:
Up to $71,433 per day per violation
Calculated based on severity, duration, compliance history
Typical penalties: $10,000-$500,000
Criminal Penalties:
Knowing violations: Fines up to $50,000 per day + imprisonment up to 5 years
Knowing endangerment: Up to $1,000,000 + imprisonment up to 15 years
Other Consequences:
Permit denial or revocation
Public disclosure (violation notices posted)
Citizen suits
Third-party liability
Damaged reputation
Managing an Effective LQG Compliance Program
Designate Environmental Coordinator
Full-time environmental staff essential for most LQGs
Environmental Coordinator Responsibilities:
Overall hazardous waste program management
Regulatory monitoring and updates
Training program development and delivery
Inspection oversight
Manifest management
Biennial reporting
Interface with regulators
Contingency plan maintenance
Recordkeeping
Continuous improvement
Qualifications:
Environmental science/engineering degree preferred
RCRA training and certification
Regulatory knowledge
Project management skills
Communication abilities
Larger Facilities:
Environmental manager
Multiple environmental coordinators
Dedicated hazardous waste staff
EH&S department
Implement Environmental Management System
Formal systems provide structure:
ISO 14001 or Equivalent:
Environmental policy
Objectives and targets
Operational controls
Monitoring and measurement
Continual improvement
Benefits:
Systematic approach
Consistent compliance
Audit readiness
Risk reduction
Efficiency gains
Leverage Technology and Software
Environmental compliance software:
Commercial Solutions:
Encamp
VelocityEHS
Triumvirate Environmental
EHS Insight
Others
Capabilities:
Accumulation time tracking (automatic alerts)
Manifest management
Training tracking and scheduling
Inspection logs and checklists
Document storage
Biennial report generation
Audit trails
Regulatory updates
Cost:
$5,000-$50,000+ annually depending on size and features
Worth investment for most LQGs
Waste Minimization Programs
LQGs must have waste minimization programs
Required for biennial reports and manifests
Strategies:
Source Reduction:
Process improvements
Raw material substitution
Equipment modifications
Inventory management
Employee training
Recycling:
On-site recycling (solvent distillation)
Off-site recycling (metals, oils, solvents)
Closed-loop systems
Material recovery
Benefits:
Reduced disposal costs (often 30-50% savings possible)
Lower regulatory burden (less waste = fewer containers to manage)
Environmental stewardship
Regulatory compliance
Cost savings
Regular Internal Audits
Proactive compliance verification:
Audit Frequency:
Annual comprehensive audits minimum
Quarterly focused audits
Pre-inspection self-audits
Audit Scope:
Container management and labeling
Accumulation time compliance
Training documentation
Inspection logs
Manifest files
Contingency plan currency
Emergency equipment
Recordkeeping
Third-Party Audits:
Independent verification
Regulatory expertise
Objective assessment
Liability protection
Recommended every 2-3 years
Develop Relationships with Regulators
Proactive engagement beneficial:
Communication:
Contact regulators with questions
Request pre-inspection consultations
Attend agency workshops and trainings
Subscribe to regulatory updates
Benefits:
Better understanding of expectations
Early warning of issues
Cooperative relationship vs. adversarial
Technical assistance
Self-Disclosure:
Voluntarily report violations discovered
Often reduces penalties
Shows good faith
EPA audit policy provides incentives
Frequently Asked Questions About LQGs
Can we ever go back to SQG status if waste generation decreases?
Yes, but you must maintain LQG compliance while you're an LQG.
If you generate ≥1,000 kg in one month, you're an LQG that month. If generation drops below 1,000 kg in subsequent months and stays there, you revert to SQG status.
However:
Waste accumulated during LQG month(s) still subject to 90-day limit
Must maintain all LQG records and documentation
Can't retroactively claim SQG status for months you were LQG
Strategic Consideration: If you're consistently near 1,000 kg threshold:
Consider staying LQG for consistency
Fluctuating status creates compliance complexity
Implement waste minimization to stay below threshold
Or commit to LQG status and build robust program
Do all employees need annual training or just those handling waste?
Only employees handling hazardous waste require annual training.
This includes:
Personnel managing containers
Staff in accumulation areas
Shipping/receiving handling hazardous waste
Emergency responders
Environmental coordinators
Not required for:
Administrative staff with no waste contact
Sales personnel
Employees in areas completely separated from hazardous waste operations
Best Practice: Provide basic awareness training to all employees:
What is hazardous waste
Where accumulation areas are located
Emergency procedures
Who to contact with questions
What happens if we miss the 90-day accumulation deadline by a few days?
You're operating a storage facility without a permit - serious violation.
Even exceeding by one day is technically violation of 90-day rule. EPA doesn't provide "grace periods."
Consequences:
Enforcement action likely if discovered
Penalties potentially $37,500+ per day
Required to ship waste immediately
Increased scrutiny going forward
If it happens:
Ship waste immediately
Document why it occurred
Implement corrective actions preventing recurrence
Consider self-disclosure to EPA (may reduce penalties)
Review tracking systems and procedures
Prevention is critical: Schedule pickups conservatively, have backup plans, use tracking software with alerts.
Can we perform on-site treatment to avoid the 90-day limit?
Generally requires permit.
Treatment of hazardous waste typically requires RCRA permit as treatment, storage, disposal facility (TSDF).
Exceptions:
Elementary Neutralization:
pH adjustment of corrosive wastes only
Limited scope
No permit required
Wastewater Treatment:
Some wastewater treatment units exempt
Specific criteria must be met
Totally Enclosed Treatment:
Closed-loop recycling
No release to environment
Most LQGs:
Don't treat waste on-site (too complex/expensive)
Send to permitted TSDFs
Focus on waste minimization instead
If considering on-site treatment:
Consult environmental attorney
Understand permit requirements
Evaluate costs vs. off-site disposal
Consider liability and operational complexity
Do we need contingency plans for satellite accumulation areas?
No separate contingency plans required for SAAs.
Your facility contingency plan should address all accumulation areas including SAAs, but no separate written plans needed.
SAA Emergency Considerations:
Include SAA locations on facility map
Emergency equipment accessible to SAAs
Operators trained on spill response
Emergency coordinator knows all SAA locations
How detailed must our training documentation be?
Very detailed - burden of proof is on you.
During inspections, EPA will review training records. If documentation is inadequate, you cannot demonstrate compliance.
Minimum documentation:
Employee name and job title
Training date(s)
Topics covered (list specifically)
Instructor or program name
Training duration
Employee signature
Competency verification
Best Practice:
Detailed training agenda
Sign-in sheets
Training materials (presentations, handouts)
Test or quiz results
Annual calendar showing all training
Database tracking all employees
"If it isn't documented, it didn't happen" - regulatory mantra.
What if our waste goes to multiple TSDFs?
Separate manifest for each TSDF.
If shipping waste to multiple facilities:
Complete manifest for waste going to each facility
Cannot send one manifest with multiple destinations
Track all manifests separately
Exception reporting for each manifest
Consolidation: Some disposal companies provide consolidation services:
You manifest to their facility
They consolidate and ship to final TSDFs
Simplifies your manifesting
Verify consolidation facility properly permitted
How long must we keep records?
Minimum 3 years, some records longer:
3 Years:
Manifests
Training records (current employees + 3 years after departure)
Inspection logs
Test results
Correspondence
5 Years:
Land Disposal Restriction (LDR) certifications and notifications
Indefinitely:
Waste determinations and characterizations
Biennial reports (recommended)
Permits and regulatory approvals
Best Practice: Keep all records 7-10 years minimum
Protects in enforcement actions
Supports due diligence for property transactions
Historical reference
Electronic storage makes long-term retention easy
Resources and Professional Support
When to Hire Environmental Consultants
Consider consultants for:
Initial LQG program development
Annual compliance audits
Training program development
Contingency plan preparation
Biennial report assistance
Regulatory interpretation
Enforcement response
Permitting needs
Waste characterization
Facility closures or decommissioning
Industry Associations
Air & Waste Management Association (A&WMA) National Waste & Recycling Association Environmental Bankers Association Specific industry groups (chemical industry, automotive, aerospace, etc.)
Benefits:
Regulatory updates
Training programs
Networking
Best practice sharing
Advocacy
Conclusion: LQG Compliance Is Manageable
Large Quantity Generator status requires significant compliance resources, but with proper systems and expertise, it's entirely manageable.
Your LQG Essentials:
1. Dedicated Resources:
Environmental coordinator
Compliance software
Professional disposal partner
Consultant support as needed
2. Formal Programs:
Comprehensive training (annual)
Written contingency plan
Waste minimization
Inspection procedures
Manifest management
3. Strict Discipline:
90-day accumulation limit
Weekly inspections
Annual training
Biennial reporting
Detailed recordkeeping
4. Continuous Improvement:
Regular audits
Waste minimization efforts
Updated procedures
Technology adoption
Staff development
Why Professional Partnership Matters
At Hazardous Waste Disposal, we specialize in supporting LQGs:
Services:
Reliable pickup within 90-day limits
Emergency response for urgent needs
Manifesting and documentation
Training assistance
Compliance guidance
Accumulation tracking support
Waste characterization
Treatment and disposal at permitted facilities
Expertise:
Decades serving major manufacturers, chemical plants, aerospace, automotive, and all LQG industries
Understanding of LQG requirements and challenges
Responsive to 90-day deadline pressures
Certificate of disposal for all waste
Professional, compliant service
Contact Us:
Call (800) 582-4833 or email info@hazardouswastedisposal.com
We serve LQGs nationwide across all industries - manufacturing, chemical processing, aerospace, automotive, pharmaceutical, research, and more.
Let our expertise support your LQG compliance program so you can focus on your core business operations. Contact us today for a consultation.
Serving Large Quantity Generators nationwide, since 1992
This guide is for informational purposes. Regulations change and vary by location. Consult with qualified environmental professionals and your regulatory agency for specific compliance requirements. Updated January 2026.