Compliance
Large quantity generator requirements
The 90 day clock, the contingency plan, and the reporting that comes with the category.
A large quantity generator produces 1,000 kg or more of hazardous waste, or more than 1 kg of acute hazardous waste, in a calendar month. LQGs may accumulate for up to 90 days with no quantity limit, and carry the full set of contingency planning, training and reporting duties.
Source: 40 CFR 262.17LQG obligations
- Obtain an EPA identification number
- Accumulate for no more than 90 days, with no on site quantity limit
- Maintain a written contingency plan and a quick reference guide for responders
- Make arrangements with local police, fire and emergency services
- Provide initial and annual personnel training with documented records
- Inspect accumulation areas weekly and document the inspections
- Meet container, tank, drip pad or containment building standards as applicable
- File a biennial report by March 1 of every even numbered year
- Close accumulation units to the performance standard at 40 CFR 262.17(a)(8)
The contingency plan is the part that gets cited
The 2016 Generator Improvements Rule added the quick reference guide, a condensed summary of the contingency plan written for responders arriving at an incident. It has to be submitted to the local emergency responders the LQG has arrangements with, not simply held on site.
Inspectors look at this because it is easy to verify and frequently missing. A contingency plan sitting in a binder that the local fire department has never seen does not meet the requirement.
Biennial reporting
Due March 1 in even numbered years, covering the previous calendar year.
- Filed on EPA Form 8700-13 A/B, or through the state equivalent
- Covers quantities generated, and the designated facilities used
- Required of any site that was an LQG in any single month of the reporting year
- A site that was an LQG for one month out of twelve still reports
- Records retained for at least three years
Common questions
If I am an LQG for one month, am I an LQG all year?
For most requirements you meet LQG standards in the months you are one. Biennial reporting is the exception: a site that was an LQG in any month of a reporting year files for that year.
Can the 90 days be extended?
A 30 day extension may be granted by the regulator on a case by case basis for circumstances beyond your control. It is discretionary and has to be requested, not assumed.
What does closure mean for an accumulation area?
When an LQG stops using a central accumulation area, it must close it to the performance standard at 40 CFR 262.17(a)(8), removing or decontaminating all waste residue and contaminated containment. Notification to the regulator is required for units other than containers.
Related services
Not sure how this applies to your site?
Send a profile, an old manifest, or photographs of the drums. A technical professional will tell you where you stand.
This page summarizes federal requirements and is not legal advice. State programs can be more stringent than the federal baseline. Verify against current federal and state regulations before acting. Last reviewed September 2026.