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RCRA Generators

ASTM search distance Subject property and adjoining properties
Scope Federal

RCRA Generators

Facilities that generate hazardous waste under RCRA, tiered by monthly generation volume (larger generators must notify EPA or the state; the smallest tier appears in the data mostly through state requirements or voluntary filings):

  • LQG: Large Quantity Generator (1,000 kg/month or more, or far smaller amounts of acute hazardous waste)
  • SQG: Small Quantity Generator (100 to 1,000 kg/month)
  • VSQG: Very Small Quantity Generator (under 100 kg/month), called CESQG (Conditionally Exempt SQG) before the 2016 Generator Improvements Rule. Both labels survive in vendor reports.
  • Non-generator / no longer reporting: a facility that once notified and has since dropped off

In a Phase I ESA

The ASTM E1527-21 search scope is subject property and adjoining properties only. Generator status matters as a signal about operations at and next to the site, not across a radius.

A generator listing is a notification, not a release. It tells you the facility handles (or handled) hazardous waste and roughly at what scale, which tells you what to look for in site reconnaissance and interviews: waste streams, storage areas, floor drains, disposal practices. A dry cleaner listed as an SQG for spent perchloroethylene is a classic example. The listing itself is routine; the operation it evidences is the real subject of inquiry. Historical generator status at a property with no current operations is a flag for past use.

Where the data lives

EPA RCRAInfo holds notifications, handler details, and inspection and violation history.