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New Hampshire Department of Environmental Services

Frequently Asked Questions
  • Does a New Hampshire Small Quantity Generator (SQG) need to notify the State and obtain an EPA Identification number?
    Yes, every generator of hazardous waste needs to notify the department prior to conducting activities that would generate hazardous wastes. Transporters of hazardous waste also need to notify and obtain an EPA ID number. Download a copy of the form.
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  • How much is 100 kilograms (kg)?
    About 220 pounds. For most hazardous wastes that would be less than one half of a 55 gallon drum.
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  • How do I know if I have a hazardous waste?
    By testing the final waste or knowledge of the process that created it. Get an overview of testing by visiting our SQG Resource Page. A good rule of thumb is that if you are using your EPA ID number and a manifest, there is the strong likelihood that you are a hazardous waste generator.
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  • I have just five gallons a month of hazardous waste. Does that mean I have to be part of the program?
    Yes. If you have hazardous wastes on site and you are an active small quantity generator, you will need to do the form and pay the fee.
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  • At what point do I become a full quantity generator?
    When, in any one month, you exceed 220 pounds of hazardous waste (about ½ drum), 2.2 pounds of acutely hazardous wastes, or 220 pounds of contaminated soil or absorbent. If this occurs, you will need to submit a notification form to the department.
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  • I am having a clean out of my stockroom that will likely be greater than 220 pounds. Do I become a full quantity generator?
    Yes, at least for that month. If you find that a cleanout will send you over the amounts of a SQG, you should call, write or send in a notification form to the department explaining the activity. Let us also know when you will be changing back to an SQG. Be aware that if we see it happening on a regular basis, we would interpret that as something more than cleanout. One suggestion is to spread your cleanout over two or more months in order to avoid the problem altogether.
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  • I just have a parts washer in my auto repair garage. Do I have to comply with the requirements?
    Yes, unless you have had the wastes tested (not just the original cleaning solvent), your parts washing fluid may be hazardous. If you are using a hazardous parts cleaner to start with, then the resultant waste will be hazardous. Using a non-hazardous part cleaner may not be hazardous and should be tested. The non-hazardous brands are also more environmentally friendly, safer to workers, and can lessen your liability.
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  • I have film printing operations and I no longer generate hazardous waste (switched to digital x-rays). What should I do about filling out the forms?
    If you no longer generate or store any type of hazardous waste you should fill out a declassification form, indicate that you no longer generate or store hazardous waste and submit it to the department.
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  • If I generate spent fixer from photoprocessing fluids am I a generator and am I subject to the SQG program?
    Photoprocessing activities that generate spent fixer and the spent fixer is not being accumulated (that is, stored greater than 24 hours) prior to on-site recovery through a unit to recover the "sludge" (that is, the cartridge is prepared for shipping off-site for final reclaim of the silver), do not need to notify, do not need an EPA Identification Number, and do not need to do the small quantity generator (SQG) self-certification declaration, given that the recovered material is not subject to RCRA regulation when recycled by being reclaimed under Env-Wm 803.04(b)(1).

    Certain photoprocessing activities may include silver recovery as part of the photographic process, for example, health care facilities that take X-rays and camera stores that process photographs. Silver that is immediately recovered as part of the photo process is available for recycling, and, therefore, the generator does not need to manifest or obtain an EPA identification number.

    By contrast, spent fixer that is accumulated on site and/or shipped off site for silver recovery must be manifested and the generating facility must notify as a generator, and, if generating less than 220 pounds per month, must provide self-certification and provide declaration of compliance including the associated fee.

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  • I generate only used oil that goes to recycling, do I need to comply with the program?
    No, if used oil is truly the only hazardous wastes you produce. Used oil that is not recycled and is sent for disposal is subject to the program and the fee. If you are sending used oil for disposal, you should take a look at this option.

    Note: If you received an SQG packet from the state, and your only waste stream is used oil FOR RECYCLE described above, you will need to sign and return the SQG packet (do not include the fee) and notify us that you are no longer an SQG. You can do this by indicating on the notification form sent in the packet or by sending in a new notification form, that you are NOT a hazardous waste generator. (Page 2 – check Not a Generator)

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  • Does my municipal government need to comply? The School District?
    Yes, If they generate small quantities of hazardous waste. However, both are political subdivisions and are exempt from the fee.
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  • Is training required?
    No, any training that is offered is designed to give you assistance in filling out the forms and to help you better understand how to manage your wastes. It is also free. You can also download presentations of previous trainings.
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  • I am a small quantity generator with multiple school sites. Can I self-transport to one location?
    Yes. Env-Wm 501.02(c) does have an exemption that allows small quantity generators to transport wastes to another facility in NH provided that both sites have the same owner and operator, and that the quantities of wastes are counted toward the destination facility. Thus, you want to make sure that you don’t become a full quantity generator at the final point. You will also need to notify the department that the activity is occurring. Fill out a notification form for each site, paying particular attention to question 9(a)5. Download a copy of the form. Make sure that you use DOT approved containers when transporting.
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NH Department of Environmental Services | 29 Hazen Drive | PO Box 95 | Concord, NH 03302-0095
(603) 271-3503 | TDD Access: Relay NH 1-800-735-2964 | Hours: M-F, 8am-4pm

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