Determining Generator Size

Last month we discussed EVALUATING EVERY WASTE and the purpose of doing so. Now you can take that information to help determine your company’s generator size. Generator size is based on the volume and type of hazardous waste generated at a given site each calendar month. Each site’s generator size determines the requirements the site must meet.

The Minnesota Pollution Control Agency (MPCA) and the metro counties oversee the hazardous waste generator size requirements. These requirements are specific to Minnesota and differ from federal requirements.

What wastes do I count?

Count the amount generated of each hazardous waste listed below for each calendar month and year.

Hazardous waste that is…

  • Accumulated onsite
  • Mixed into used oil by a Very Small Quantity Generator (VSQG)
  • Recycled off-site, unless it is eligible to be feedstocks or byproducts (see ‘feedstocks or byproducts’ below)
  • Recycled and reused again onsite
  • Sewered
  • Shipped off-site for treatment or disposal using a hazardous waste manifest
  • Transported to a VSQG Collection Program or Licensed Paint Collection Site (LPCS)
  • Treated onsite

Do not count hazardous wastes that are:

  • Recycled, electronic waste
  • Exempt wastes
  • Feedstocks or byproducts
  • Pharmaceuticals managed through reverse distribution
  • Polychlorinated biphenyls (PCBs)
  • Recyclable fuel
  • Sewered after pretreatment onsite to remove ³80% of their hazardous constituents
  • Universal waste
  • Recycled or burned for energy recovery (such as used oil)

Note: Hazardous wastes that are not counted towards your site’s hazardous waste generator size may still need to be reported annually to the MPCA or your metro county.

How do I count wastes at cleanup sites?

If you are cleaning up a new hazardous waste spill, count the volume of recovered hazardous waste. Contaminated spill cleanup materials are considered newly generated wastes and must be either assumed to be hazardous waste and counted or evaluated as non-hazardous.

What is my site’s generator size?

Count the maximum weight of hazardous waste you generate each calendar month and year. Do not average multiple months.

Count acute hazardous wastes separately.

Generator Size

If your site generates: …then your site’s generator size is:
Less than 100 pounds per year and no acute hazardous waste Minimal Quantity Generator (MiniQG). Follows all requirements for VSQGs. No annual license fees. Not applicable in all metro counties.
Less than 220 pounds per month and less then 2.2 pounds per month of acute hazardous waste Very Small Quantity Generator (VSQG). Note: The federal Conditionally Exempt Small Quantity Generator (CESGQ) generator size does not exist in Minnesota.
Between 220 to 2,200 pounds per month and less then 2.2 pounds per month of acute hazardous waste Small Quantity Generator (SQG)
More than 2,200 pounds per month or more then 2.2 pounds per month of acute hazardous waste Large Quantity Generator (LQG)

What if the amount of waste I generate changes?

While the amount of hazardous waste generated at most sites varies from month to month, it usually does not fluctuate enough to change a site’s regulated size. However, if your business is cyclical or seasonal or if you have a spill, clean out stored stock materials or have another major hazardous waste generation event, your generation may increase or decrease enough to affect your site’s size.

If your site’s generation increases enough to raise your generator size, you must meet all of the hazardous waste requirements applicable to the larger size during the month when the size increased. You must also continue to meet the larger size requirements for the subsequent months of that calendar year, unless your site is reclassified back down to your original, lower size, either automatically or by request.

Below you will find the methods of reclassification:

  • If your site will be automatically reclassified or you decide to remain at the larger generator size, you do not need to notify the MPCA. If your site is located in a metro county, contact your county to determine if they require notice of generator size changes.
  • If your site is ineligible for automatic reclassification and you wish to return to your original, lower generator size, then you must submit a written reclassification request to the MPCA or your metro county.

To learn the different generator size reclassification methods:

  • Contact the MPCA with your questions. The MPCA’s Small Business Environmental Assistance Program (SBEAP) can also provide free, confidential regulatory compliance assistance.
  • Contact your metro county
  • Contact Industrial Waste Services at 952-474-2628

Who is responsible for determining my site’s size?

The operator of a site generating hazardous waste is responsible for determining its current hazardous waste generator size and for following all the hazardous waste requirements related to that size.

The generator size contained in the MPCA’s databases and shown in the MPCA’s public tools below are estimates only and are based on information reported for previous calendar years.

As your trusted compliance partner always feel free to call our office with questions at 952-474-2628!

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Industrial Compliance Services

St. Paul, MN

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