Vermont Accumulation Time regulations & environmental compliance analysis

Vermont Accumulation Time: What you need to know

Governing Law and Regulations

Accumulation time requirements for generators: Large quantity generators (LQGs): Vermont Administrative Rule (VAR) 12-032-001 Section 7-308(b) and VAR 12-032-001 Section 7-310 Small quantity generators (SQGs): VAR 12-032-001 Section 7-307(c) and VAR 12-032-001 Section 7-310

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Short-term storage area time limit extensions for LQGs and SQGs: VAR 12-032-001 Section 7-307(c)(2), VAR 12-032-001 Section 7-308(b)(2), and VAR 12-032-001 Section 7-311

Regulatory Agency

Vermont Agency of Natural Resources Department of Environmental Conservation (DEC) Waste Management Division Hazardous Waste Management Program

Comparison: State vs. Federal

· Rules. Vermont follows the federal hazardous waste accumulation time rule for generators but does not follow the federal provision that allows SQGs to accumulate hazardous waste for 270 days if it must be transported 200 miles or more for disposal or storage.

See the state section HAZARDOUS WASTE STORAGE for information on how to store hazardous waste on-site without a permit.

· Administration and enforcement. DEC’s Waste Management Division administers and enforces the accumulation time regulations in Vermont.

State Requirements


As under the federal rules, SQGs and LQGs can accumulate their hazardous waste on-site by obtaining storage facility certification from the state for, respectively, 180 days and 90 days due only to unforeseen, temporary and uncontrollable circumstances (VAR 12-032-001 Section 7-311(c)). An extension is granted at the discretion of DEC. Unlike the federal rules, however, Vermont regulations do not include the provision that allows SQGs to accumulate hazardous waste for up to 270 days if the waste must be transported ...

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