United States Environmental Protection Agency Washington DC 20460 EPA/530-SW-86-003 March 1986 x>EPA Hazardous Waste Requirements For Small Quantity Generators of 100 to 1000 kg/mo ------- TTn 1976, Congress enacted the Resource JlConservation and Recovery Act (RCRA) to protect human health and the environment from improper waste management practices. In issuing hazardous waste regulations under RCRA, the Environmental Protection Agency (EPA) first focused on large generators who produce the greatest portion of hazardous waste. Regulations EPA published on May 19, 1980, exempted "small quantity generators"—establishments producing less than 1000 kilograms of hazardous waste in a calendar month—from most of the hazardous waste requirements. On November 8, 1984, however, the Hazardous and Solid Waste Amendments (HSWA) were signed into law. These amendments to RCRA directed EPA to establish new requirements for smaJJ quantity generators who produce between 100 and 1000 kilograms of hazardous waste in a calendar month. EPA issued final regulations for these 100 to 1000 kg/mo generators on March 24, 1986, making the elective date of the requirements September 22, 1986. In general, the new regulations for 100 to 1000 kg/mo generators are based upon the existing hazardous waste regulatory program. To lessen the burden on the small businesses which are most likely to be affected by these new regulations, EPA has exempted 100 to 1000 kg/mo generators from some of the administrative and paperwork requirements applicable to larger generators (1000 or more kg/mo). Here are answers to some basic questions about the new requirements: Who is affected by these new regulations? Establishments that generate from 100 to 1000 kilograms (approximately 220 to 2200 pounds) of hazardous waste in any calendar month. (Depending upon the weight of the contents, this amount is approximately one half-full to five full 55-gallon drums.) What kinds of businesses are likely to be 100 to 1000 kg/mo generators? Vehicle maintenance establishments (such as garages, paint and body shops, and car dealerships), metal manufacturers, printers, laundries and dry cleaners, chemical manufacturers and formulators, laboratories, equipment repair shops, construction firms, textile manufacturers, pesticide applicators, and ------- schools are among establishments likely to produce small quantities of hazardous waste. Based on a March 1985 survey of small quantity generators, EPA estimates that there are approximately 100,000 businesses which would be affected by the new regulations. What new requirements must 100 to 1000 kg/mo generators meet? By September 22, 1986, 100 to 1000 kg/mo generators must: o Obtain a U.S. EPA Identification Number. o Use the full Uniform Hazardous Waste Manifest system when shipping hazardous waste off-site. o Offer wastes only to hazardous waste transporters who have U.S. EPA Identification Numbers. o Accumulate waste on-site for no more than 180 days, or 270 days if the waste is to be shipped more than 200 miles, unless they obtain a hazardous waste permit. o Ensure that their hazardous waste is managed at a hazardous waste facility with interim status or a permit under RCRA. L£ Are these the only new requirements that 100 to 1000 kg/mo generators must meet? Not necessarily. While the items listed above briefly identify the basic new federal requirements for 100 to 1000 kg/mo generators, the actual requirements which go into effect on September 22, 1986 are more detailed. In addition, some states may impose more stringent requirements on small quantity generators. For example, four states (California, Louisiana, Minnesota, and Rhode Island] now fully regulate all generators of hazardous waste, 100 to 1000 kg/mo generators as well as larger and smaller generators. To be sure you understand all the requirements, state and federal, that you must meet, contact your state hazardous waste management agency. What is a U.S. EPA Identification Number, and how do I obtain one? A U.S. EPA Identification Number is a unique, 12-character number that EPA assigns to generators and transporters of hazardous waste, and to owners/operators of facilities that treat, ------- I\ store, or dispose of hazardous waste. The identification numbers help EPA and states compile and maintain a database on hazardous waste activities. To obtain an EPA Identification Number, you should complete EPA Form 8700-12, "Notification of Hazardous Waste Activity," or a similar form used by your particular state. To request the application form, contact your state hazardous waste management agency or EPA Regional Office. Along with the appropriate application form , you will receive instructions for completing the form and information on where you can get additional assistance. Where do I obtain the Uniform Hazardous Waste Manifest to use when I ship my hazardous waste off my plant site? A hazardous waste manifest is a multi-copy form that you must fill out completely and use to accompany your hazardous waste shipments. Some states print their own versions of the Manifest with the state's name and logo and require use of the state Manifest form. These forms are available from state hazardous waste management agencies. Many transporters and facilities may also be able to provide you with the correct Manifest. To determine which state's Manifest form you need to complete, use this system: (1) If the state to which you are shipping your waste has its own Manifest, use that Manifest form (2). If not, use the Manifest of the state in which your waste was generated. (3) If neither state requires a state-specific Manifest, you may use the "general" Uniform Hazardous Waste Manifest — EPA Form 8700-22 — which you can purchase from some commercial printers, or obtain from some transporters or waste management facilities. What information is required on the Manifest? Effective September 22, 1986, federal law requires 100 to 1000 kg/mo generators to fill out all of the unshaded items on the Uniform Hazardous Waste Manifest. (The completed Manifest will also fully satisfy Department of Transportation requirements for shipping hazardous materials.) Even now, some states require generators to complete the entire Manifest, or to provide information beyond the items 3, 9, 11, 12, 13, 14, and 16 required under federal law as of August 5, 1985. To be sure you complete all necessary parts of the Manifest, contact your state hazardous waste agency, your transporter, and your receiving facility. ------- Why are there multiple copies of the Manifest? The Manifest form is designed so that shipments of hazardous waste can be tracked from their point of generation to their final destination, the so-called "cradle-to-grave" system. The Manifest is produced in a multi-copy format so that each step in the shipment process can be documented. Thus, the generator of the hazardous waste completes the Manifest, and turns the shipment and remaining copies of the Manifest over to the transporter. The transporter or hauler signs the Manifest, returns one copy to the generator, and turns the shipment and Manifest over to the facility that the generator designated to receive the waste. The facility signs the Manifest, gives one copy back to the transporter, keeps a copy, and sends the remaining copy back to the generator so the generator knows that the hazardous waste has reached its intended destination. Some states require that a copy of the Manifest also be sent to the state hazardous waste agency each time a shipment changes hands. Generators are required to keep a copy of each Manifest, signed by the designated facility, in their files for three years following the date of the shipment. What if the generator does not receive a final copy of the Manifest confirming the facility's receipt of the shipment? .A. Under the new federal regulations, 100 to 1000 kg/mo generators are not, as are larger generators, required to file "exception reports." However, while these generators are not required to file an exception report, EPA strongly encourages generators to use good business practice and perform the necessary follow-up to make sure their waste shipments reach the destination facility. Should a shipment be truly lost, it is in the generator's interest to notify EPA or the state in order to minimize any future liability. ------- /\ How often should generators ship hazardous waste off their premises? Larger generators must ship their waste off-site at least every 90 days to avoid having to obtain a hazardous waste facility permit. The final regulations allow 100 to 1000 kg/mo generators to accumulate hazardous waste on-site for 180 days (or up to 270 days if the waste is to be shipped more than 200 miles) without the need for a permit so that generators may accumulate more economical quantities for shipment. Some states, however, allow only a 90-day accumulation period, even for 100 to 1000 kg/mo generators. Check with your state hazardous waste agency for information on the requirements that apply to you. Where can I send my waste, and who can haul it? Since hazardous waste from 100 to 1000 kg/mo generators must be managed according to RCRA hazardous waste rules, only transporters and facilities which have EPA identification numbers can handle your hazardous waste. Furthermore, they must be authorized to handle your particular kind of hazardous waste. For information on hazardous waste transporters and management facilities in your area, contact your state hazardous waste agency or EPA regional office. May I recycle my hazardous waste? Yes. In fact, EPA strongly encourages recycling as one of the best methods for managing hazardous waste. Waste shipped off-site for recycling may still be subject to manifesting as well as other transportation and storage requirements. These requirements, however, are not intended to discourage recycling. Contact your state hazardous waste agency, EPA regional office, or trade association for information on your specific waste recycling alternatives. Where can small quantity generators get further information and assistance? Generators should contact their state hazardous waste agencies for information on the requirements they must meet. For questions on the new federal requirements or hazardous waste regulations in general, or to obtain the number for their state hazardous waste agencies, generators may wish to contact their EPA ------- regional office (see list below); EPA's toll-free RCRA Hotline, 800-424-9346 (in Washington, DC, 382-3000); or EPA's toll-free Small Business Hotline, 800-368-5888 (in Virginia, 800-468-4561). EPA Regional Offices EPA Region 1 JFK Federal Building Boston, MA 02203 (617)223-7210 Connecticut, Massachusetts, Maine, New Hampshire, Rhode Island, Vermont EPA Region 2 26 Federal Plaza New York, NY 10278 (212)264-2525 New Jersey, New York, Puerto Rico, Virgin Islands EPA Region 3 841 Chestnut Street Philadelphia, PA 19107 (215) 597-9800 Delaware, Maryland, Pennsylvania, Virginia, West Virginia, District of Columbia EPA Region 4 345 Courtland Street, N.E. Atlanta, GA 30365 (404)881-4727 Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee EPA Region 5 230 South Dearborn Street Chicago, IL 60604 (312)353-2000 Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin EPA Region 6 1201 Elm Street Dallas, TX 75270 (214)767-2600 Arkansas, Louisiana, New Mexico, Oklahoma, Texas EPA Region 7 726 Minnesota Avenue Kansas City, KS 66101 (913)236-2800 Iowa, Kansas, Missouri, Nebraska EPA Region 8 One Denver Place 999 18th Street Suite 1300 Denver, CO 80202-2413 (303)293-1603 Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming EPA Region 9 215 Fremont Street San Francisco, CA 94105 (415)974-8071 Arizona, California, Hawaii Nevada, American Samoa, Guam, Trust Territories of the Pacific EPA Region 10 1200 Sixth Avenue Seattle, WA 98101 (206)442-5810 Alaska, Idaho, Oregon, Washington ------- |