Is your facility a hazardous waste generator, and if so, do you know what kind of generator you are? Many companies are often surprised to discover that they generate regulated waste and exactly how much they generate. A facility can be considered a hazardous waste generator if they generate trigger amounts of less hazardous substances like oil-based paint to the most extreme hazardous substances like hydrofluoric acid.
If a company generates a certain amount of hazardous waste they’re required to register with the United States Environmental Protection Agency (EPA) and obtain an EPA Identification Number (EPA ID Number). State and local agencies may also have registration, fee, and regulatory requirements that need to be adhered too.
EPA divides hazardous waste generators into three categories, based on the quantity of waste they produce on a monthly basis. The first category is large quantity generator (LQG). An LQG generates ≥2,200 pounds of hazardous waste per month. The second category is a small quantity generator (SQG), and they generate >220 pounds but <2,200 pounds of hazardous waste per month. The last category is the conditionally exempt small quantity generator (CESQG), which generates ≤220 pounds of hazardous waste per month.
As a hazardous waste generator, it is the company’s responsibility to apply for and obtain an EPA ID Number prior to generating, storing or transporting a hazardous waste. The EPA ID Number application can be found on EPA’s website http://www.epa.gov/osw/inforesources/data/form8700/forms.htm under Notification of Regulated Waste Activity and Resource Conservation and Recovery Act (RCRA) Hazardous Waste Part A Permit Application. If you are a CESQG, you don’t need to complete the application. CESQGs are not regulated by EPA, and therefore do not need to submit a notification. However, some states and local agencies require CESQGs to register with them.
The Notification of Regulated Waste Activity and RCRA Hazardous Waste Part A Permit Application has detailed instructions for completion and submittal. The forms are fairly straight forward asking for general information such as site address, phone number and types of waste that may be generated. The instructions are easy-to-follow and provide line-by-line details for completion. The application and instructions are available for completion online; however, EPA does require an original, ink signature copy be sent to the state or EPA regional contact.
The EPA ID Number is facility/location specific, so if a company has more than one facility that generates hazardous waste, each facility will require an individual EPA ID Number. If the facility relocates, a new EPA ID Number must be obtained.
One of the reasons for EPA ID Numbers is to track the number of facilities that generate hazardous waste and the amount of waste they generate. In addition, many states and local agencies are concerned with the types and amounts of hazardous waste being generated in their jurisdiction and the methods of disposal. Therefore, most require facilities to complete and submit an annual hazardous waste report, which is used as a management and tracking tool. The fees charged by the state and local agencies are often based on the amount of hazardous waste reported on the annual hazardous waste report.
The waste reports require generators to list the types and amounts of hazardous waste generated for a specific year and often request specific details as to how the waste was disposed of (e.g. recycle, incineration, landfill), what transportation company was used to haul the waste, the date the waste was removed from the generator’s site and reference numbers from the waste shipment documents. Some states have adopted on-line reporting systems.
A few examples of states that require annual waste reporting with specific requirements are California, New Jersey, New York and Texas. Some states assign a distinct hazardous waste identification number through a designated state agency. Also, in some states CESQGs are required to register and are assigned a hazardous waste identification number. In other states a temporary identification number is required for one-time generators. For example, if a facility discovers even a small quantity of a hazardous chemical during a cleanup, they’re required to obtain a temporary hazardous waste identification number before they can dispose of the chemicals.
Some states require a waste minimization plan to be submitted annually. In this plan, a facility must describe the measures it will take or methods it will use to reduce the amount of hazardous waste generated at the facility. Many states and EPA have suggestions on how companies can reduce the amount of hazardous waste they generate or provide suggestions for alternate ways of disposing the wastes. Often, a facility can reduce the amount of hazardous waste by changing just one practice.
With an increasing focus being made on reducing, reusing and recycling, some facilities that previously were exempt from the regulatory requirements are now pulled into the system. It is extremely important for a hazardous waste generator to keep well-organized and accurate records, not only for reporting purposes, but also because the EPA and state agencies are looking for offenders.