Large Quantity Generator (LQG)

Large Quantity Generator status under RCRA (40 CFR Part 262, Subpart D) and California regulations (Title 22, Division 4.5) triggers the most comprehensive set of hazardous waste management requirements. LQGs may store hazardous waste on-site for up to 90 days without a storage permit, but must comply with specific container management standards (weekly inspections, proper labeling with accumulation start dates, secondary containment), maintain a contingency plan and emergency procedures, designate an emergency coordinator, and submit biennial reports to the EPA (or annual reports to DTSC in California).

The 90-day storage limit is a hard deadline, waste that remains on-site beyond 90 days without a permit constitutes a storage violation, which DTSC treats as a significant enforcement matter. LQGs must also conduct personnel training within six months of hire and annually thereafter, covering emergency response procedures, waste handling, and the facility's contingency plan. California adds requirements beyond federal RCRA, including annual facility inspections and notification updates when waste streams change.

BayArea Compliance helps LQG facilities maintain compliance with the full range of requirements their generator status imposes. We track accumulation start dates, schedule pickups to stay within storage time limits, prepare biennial and annual reports, develop contingency plans, and deliver the personnel training required under 40 CFR §265.16. For facilities operating near the LQG threshold, we monitor monthly generation rates and adjust your compliance program if your generator status changes.