vvEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 954i.oi(8i)
TITLE: States' Role in Assigning EPA Identification Numbers
' (P1G-81-12)
APPROVAL DATE: 9-29-81
EFFECTIVE DATE: 9-29-81
ORIGINATING OFFICE:
0 FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OS WER OS WER OS WER
/£ DIRECTIVE DIRECTIVE Di
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PART 271 SUBPART A - FINAI^AUTHORIZATION
DOC: 9541.01(81)
Key Words:
Regulations
Subject:
Addressee::...
Originator:
Source Doc:
Date:
Summary:
EPA I.D. Numbers
40 CFR 271.10 (a); 271.11 (a); 271.13 (b).
States' Role in Assigning EPA Identification Numbers
(P1G-81-12)
.Program. Implementation Guidance Addressees
Christopher J. Capper, Acting Assistant Administrator
for Solid Waste
#9541.01(81)
9-29-81
.A unique identification number is assigned by EPA to every site where
hazardous waste is generated, treated, stored or disposed. In order to obtain.
final authorization, a State must require new hazardous waste generators,
transporters, owners and operators of: hazardous, waste treatment, storage, and
disposal facilities to obtain EPA identification numbers before engaging in any
hazardous waste activity. The "RCRA State Interim Authorization Guidance
Manual" and the "Additional Guidance for Cooperative Arrangements under Subtitle
C. of RCRA-" .encourage States, to/assist EPA in the assignment of these numbers
prior, to final authorization. States, with interim authorization and States
under Coopeative Arrangements are encouraged to assist specifically in distri-
buting and reviewing RCRA Notification and Part A Permit Application forms.
EPA, however, will retain full responsibility in States that do not have final
authorization. f.or: the-.other- steps necessary to assign EPA I.D. numbers.
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i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 9541.01(81)
/ WASHINGTON, O.C. 20460
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3OUO WASTE ANO EMERGENCY RESPONSE
PE - 81 - 12
MEMORANDUM
SUBJECT: States' Role in Assigning EPA Identification Numbers
a*£>
FROM:
Acting Assistant Administrator (WH-562A)
TO: .. PJ3S Addressees ...
Issue;
EPA.requires all hazardous waste I/ generators and transporters and owners
and operators,of hazardous waste treatment, storage, and*disposal facilities to
receive an EPA identification number (ID number) before they handle hazardous
waste.2/ Identification numbers are-.issued by the EPA Regional Offices,
role should .the States play, in assisting the EPA Regional Offices to-assign
identification'numbers?' '• '.'.'.. ' ' ' "' ' '"
E3ecisi'on:''
(1) -States with interin authorization and States under Cooperative Arrangements
are. encouraged to assist EPA in assigning EPA identification numbers. Specif i-
"cally/ EPA v«uld"liJce-State assistance in distributing and reviewing RCHA Notifi-
cation and Bart A-Jermi^. Application Forms. Hie responsibility for assigning
EPA ID numbers will remain in the Regional Offices.
(2) States with their own system of assigning ID numbers are encouraged to use
the SPA ID.number as the State ID number.
I/ Bazardous waste means hazardous waste as defined by EPA except where specifi-
cally noted in this memorandum.
2/ Sections 262.12, 263.11, 264.11 and 265.11 establish this requirement for persons
handling hazardous waste in States where EPA is running the hazardous waste program.
Sections 1-23.34 - 36 require-for final authorization that States mandate that person-
handling hazardous waste within their borders obtain EPA ID numbers. There is no
comparable requirement for interim authorization but to date all States have accept-
ed the use of EPA ID numbers.
17-1
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Discussion:
EPA assigns an identification number to each generator and transporter of
hazardous waste and to owners and operators of hazardous waste treatment, storage,
and disposal facilities who notify the Agency. Generators must not offer their
hazardous waste for transportation; transporters must not transport hazardous
waste; and owners and operators of hazardous waste management facilities must
not treat, store, or dispose of hazardous waste without first receiving an EPA
identification number.3/ EPA assigns a unique identification number to each
single site where- hazardous waste.- is generated, treated, stored, or disposed;
or, in the case of a transporter, to his principal place of business. The
identification number is used on all nanifests, reports, and records that EPA
requires. The EPA identification number also serves as the "password" for
entering and retrieving data from EPA's Hazardous frfeste Cata Management ADP
System (HWCMS). HWCMS is the ^ency's major source of information on hazardous
waste handlers across the country and is a critical element in implementing
Subtitle C.of HCPA. - EPA is also in the process of tying together HWCMS with
other EPA data management systems using the EPA ID number as the cannon link.
The scheme. EPA uses to assign identification numbers is based on the Data
Universal. Numbering System (DUNS number), that Dun and Bradstreet Incorporated
(D & B) has-developed. D & B has assigned approximately three million DUNS
.numbers to ail types- of businesses across the nation. EPA also assigned tem-
porary "T" numbers to persons who did not have an existing DUNS number..!/
All persons who have registered with EPA have been assigned an ID number that
is their DUNS number, a "T" number, or for some Federal activities, their GSA
Real Property Number.
Seven general steps are involved in assigning~an EPA ID number. They are
(1) answer requests for blank forms (hazardous waste generators and transporters
must submit standard EPA form 8700-12. the EPA Notification Form; owners and
operators of new hazardous- waste management, facilities must submit standard EPA
forms 3510-1 and 3510-3. the RCRA Part A Permit Application), (2) review the
submitted :infbrmation:• for completeness: and obtain any missing information, (3)
review the D & B microfiche list to determine if the site has an existing DUNS
number, (4) if' the site is not listed on the D&S microfiche, check other files
within the Region to determine if EPA has assigned an alternate DUNS number to
the site, under another program which also can be used as the EPA ID number for
the RCHA program, (S\ if the site does not have a number under another program,
assign one of the numbers from the Region's D &"B user block, (6) enter" informa-
tion about the activity into HWCMS, and (7) generate an acknowledgment from
HWCMS and issue it to the requestor to inform, him of his EPA ID number.
3/ See footnote 2.
V EPA is no longer issuing "T" numbers as of August 1, 1981. Instead, EPA
purchased from D & B a block of unassigned DUNS numbers and will assign numbers
from this block to persons who do not already have a DUNS number. EPA has be-
gun converting existing "T" numbers to DUNS numbers for facilities requiring
RQ?A permits and for generators and transporters with activities regulated under
other EPA programs. -
(2)
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There has been confusion as to what responsibilities the States can assume
in assisting EPA to carry out these steps. In order to obtain final authorization
a State most require new hazardous waste generators and transporters and owners
and operators of hazardous waste treatment, storage, and disposal facilities to
obtain EPA ID nuifcers before conducting hazardous waste activity ($$123.34 (a),
123.35 (a), and 123.37 (b)). Both the "BORA State Interim Authorization Guidance
Manual" (June 25, 1980) and the "Additional Guidance for Cooperative Arrangements
under Subtitle C of RCSA" (August 5, 1980) provide for States to assist EPA in
assigning identification numbers prior to final authorization .
^ ^"""states with interim authorization and States under Cooperative Arrangements •
"* are encouraged • to assist EPAin steps number 1 and 2.listed above. For now,
EPA will retain full responsibility for steps 3 through 7.""' Several States
have expressed an interest in assisting EPA in steps 3, 47" and 5, and further
have requested that EPA provide them widi blocks of unassigned ID numbers which
the State could, assign directly and eliminate delays in getting new numbers
one at a time from EPA. EPA prefers not to relinquish the responsibility for
stgps 3, 4, and 5. The Agency must- maintain tight control over the assign-
raer.'-. of -a .1 new numbers since the EPA identification number is the key means
of idar-;j.fying the activity in the Agency's data management systems (EPA
will continue to enter into the Agency's ADP data, base the name, address and
type of activity for all sites that are assigned an EPA ID number).
Recognizing the need for rapid issuance of new identification numbers,
EPA has assigned/contractor (Computer Sciences Corporation) personnel in each
Regional Office to-perform steps 3, 4, and 5. The plan is for the contractor to
complete these steps within one day. Steps 6 and 7 involve interacting with
EPA's ADP system. Since there is presently no capability for States to enter
information, into. HHCMS,. no. State can perform these steps.
EPA is aware that severaT States have systems for assigning State
identification "»™*y?rg to hazardous waste (as defined by the State) handlers.
Since the federal regulations require the use of EPA identification numbers,
EPA strongly encourages States that issue their own identification numbers to
adopt the EPA numbering scHenev State use of the EPA scheme should benefit the
State orcgranB ; and the regulated ccnntinity by r .
. 'eliminating duplication of effort;
'vr .-: ••••.-. "eliminating:.confusion.from the issuance of multiple numbers;
*prcviding for rapid issuance of numbers directly from the Regional
Offices, and
^ *reducing costs.
Furthermore, States employing the EPA numbering scheme will be bettar pre-
pared to use the proposed uniform national manifest form I/ which will acconmcdate
only EPA issued identification numbers.
5/ EPA plans to publish, the uniform national manifest form for public review and
comment in October 1981.
(3)
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In cases where a State has adopted a definition of hazardous waste that is
broader than the Federal definition, it nay not always be clear if the person
requesting an identification nunber in that State handles "Federally defined"
hazardous waste or hazardous waste covered under the broader portion of the
State definition. These handlers may be issued an EPA identification number
since it is not critical that only "bona fide" handlers of Federally defined
hazardous waste receive, an EPA. identificaipn .nunber.. However, it would
be helpful if States participating in Step 2, above, would point out these
cases so that we can make a note in our files that the activity has been
issued an EPA ID number but nay not be handling Federally defined hazardous
waste.
(4)
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