Managing compliance: Hazardous Waste Management: Understanding EPA and state-level categories, numbers and reports

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Courtesy of 3E Company

Many companies often are surprised to discover exactly how much hazardous waste they generate. A company can be considered a hazardous waste generator if it uses, produces or stores anything from oil-based paint to hydrofluoric acid.

If a company uses, stores or generates a certain amount of materials ranging from oil-based paint to hydrofluoric acid, it is required to register with EPA and obtain an identification number. The state and local agencies also may require additional registration and fees for the company generating the hazardous waste.

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 or more of hazardous waste per month. The second category is a small quantity generator (SQG), and they generate more than 220 pounds but less than 2,200 pounds of hazardous waste per month. The last category is the conditionally exempt small quantity generator (CESQG). The CESQG generates up to 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 identification number prior to generating, storing or transporting any hazardous waste. The EPA ID number application can be found on the EPA Web site under Notification of Regulated Waste Activity and RCRA Hazardous Waste Part A Permit Application. If you are a CESQG, you do not 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, 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 list of contacts can be found at http://www.epa.gov/osw/inforesources/data/forms8700/contact.pdf.

Once assigned, the EPA identification number is site-specific, so if a business has more than one location, and generates hazardous waste at those sites, each location will have to apply for an identification number and register with EPA. If the business relocates, a new EPA identification number must be obtained and registration completed for that address.

One of the reasons for EPA identification numbers is to track the number of businesses that generate hazardous waste and the amount of waste they generate. Many states (and some local agencies) require additional reporting and fees for hazardous waste generators. This often is done through annual waste reports. The hazardous waste generators must complete the report, listing all of the hazardous wastes generated within the year. The fees charged by the state and local agencies often are based on the amount of the hazardous waste generated by the business.

There are a number of states and local agencies that are concerned with the types and amounts of hazardous waste being generated and the methods of disposal. They have implemented annual hazardous waste reports to track this. The waste reports require that the generator list the types and amounts of hazardous waste disposed of 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. States and agencies increasingly have adopted on-line reporting systems.

Two examples of states that require annual waste reporting with specific requirements are California and Texas. California assigns a distinct hazardous waste identification numbers for generators by utilizing the EPA information and through the California Department of Toxic Substances Control (DTSC). In California, CESQGs are required to register with the DTSC and are assigned a hazardous waste identification number. Temporary identification numbers are required for one-time generators. For example, if a business is performing a site clean up and discovers several containers of bleach, they would need to contact the DTSC and obtain a temporary hazardous waste identification number for the bleach. The temporary numbers are valid for 1 year. More information about the California DTSC can be found at http://www.dtsc.ca.gov/IDManifest/index.cfm.

Texas requires any generator of hazardous waste in the state to register with the Texas Commission on Environmental Quality (TCEQ), in addition to EPA. The hazardous waste generator also must register each of their waste streams with TCEQ. The registration process for the TCEQ is handled through their online program: the State of Texas Environmental Electronic Reporting System (STEERS). California and Texas are two of the more proactive states with regards to tracking and managing of hazardous waste. Most states have Web sites that provide helpful information regarding handling and reporting of hazardous waste.

Some state and local agencies require a waste minimization plan to be submitted annually. The business describes measures it will take or methods it will use to reduce the amount of hazardous waste generated in the waste management plan. 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 business can reduce the amount of hazardous waste by changing just one practice.

It is extremely important for the hazardous waste generator to keep well-organized and accurate records of hazardous waste management, not only for possible reporting requirements, but also because EPA and other federal, state and local agencies can audit the business at any time.

With an increasing focus being made on reducing, reusing and recycling, measures are being implemented at federal, state and local levels that affect many businesses. Some businesses that previously were exempt from registering or reporting hazardous waste now are required to do so, while other businesses are changing the way they manage their hazardous waste.

Melanie Koske is an HRT specialist for 3E Co. In this role, she assists customers with concerns related to the transportation of hazardous materials.

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