All Vermont generators are required to determine if their waste is subject to regulation as hazardous waste. In Vermont, if you generate hazardous waste, you are required to obtain an EPA Identification Number from the DEC's Hazardous Waste Program.
As regulatory requirements and generator fees and regulatory requirements increase with waste generator category, it is important that generators accurately determine their generator status.
| Requirements | CEG | SQG | LQG |
|---|---|---|---|
| Subject to Inspection | Yes | Yes | Yes |
| Accumulation Time Limits | None | ≤180days | ≤90 days |
| Storage | Minimum storage requirements (under cover, impervious surface, containers closed, and labeled) | Full compliance with requirements for tanks and containers | Full compliance with requirements for tanks, containers, drip pads, and containment buildings |
| Waste Disposal | Local Solid Waste District or RCRA permitted facility | RCRA permitted facility | RCRA permitted facility |
| Manifests | Not required. If used, must follow manifest instructions | Required | Required |
| Biennial Report | Not required | Not required | Required |
| Personnel Training | Not required | Basic training required | Training plan and documentation of training required |
| Contingency Plan | Not required | Not required | Full plan required |
| Emergency Procedures | Not required | Must designate emergency coordinator and post SQG Emergency Preparedness Info | Must designate emergency coordinator, maintain contingency plan, and follow specific emergency procedures |
| Facility Closure | Not required | Required | Required |