All generators in Vermont are required to determine if their waste is subject to regulation as hazardous waste under the Vermont Hazardous Waste Management Regulations (VHWMR). If you generate hazardous waste in Vermont, you are required to obtain an EPA Identification Number from the Vermont Hazardous Waste Program. Regulatory requirements and generator fees increase with waste generator category, so it is important that generators accurately determine their generator category.
| Requirements | VSQG | SQG | LQG |
|---|---|---|---|
| Generation Rates: | Less than 220 lbs. of hazarous waste, or 2.2 lbs. of acutely hazardous waste per month. |
Generates between 220 and 2,200 lbs. of hazardous waste and less than 2.2 lbs. of acutely hazardous waste per month. |
Greater than 2,200 lbs. of hazardous waste or 2.2 lbs. of acutely hazardous waste per month or has more than 13,200 lbs. of hazardous waste onsite |
| Subject to Inspection by the Hazardous Waste Program | 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 | Not Required | Required |
| Inventory and Weekly Inspection | Not required | Required | Required |
| Episodic Generation | Available option | Available option | Not a hazardous waste management option |
| Required to Renotify | Not required | Every four (4) years | Every two (2) years. Note: Biennial Reporting Satisfies this requirement |