Who needs an EPA RCRA identification number? If you are a generator who produces over 100 kilograms (kg) of hazardous waste or over 1 kg of acutely hazardous waste per month (i.e. a small quantity generator (SQG) or a large quantity generator (LQG), a hazardous waste transporter, or a TSDF owner or operator, you must have an EPA ID number. Completing EPA Form 8700-12 is what's required.
It's easy to determine whether you're a hazardous waste transporter or TSDF, but sometimes less obvious as to whether your business generates hazardous waste. The answer is yes if it uses, consumes, or handles:
- Petroleum products
- Paints, dyes, printing inks, thinners, solvents, or cleaning fluids
- Pesticides, herbicides, insecticides, or rodenticides
- Materials that dissolve metals, paints, paper, or clothing
- Flammable or combustible materials
- Products that are accompanied by a shipping label or placard, indicating that the product is hazardous, corrosive, flammable, toxic, ignitable, or reactive
You need to calculate the quantity of hazardous wastes generated each month and to inventory the total accumulation of hazardous waste on-site. This information will be the basis for your EPA generator categorization. How much hazardous waste you can keep on-site and how long you can accumulate it will depend on this classification. Each individual activity conducted at your facility may generate quantities of hazardous wastes under the reporting threshold, but when added together, the facility may still fall into a category required to obtain a site-specific EPA ID number.
EPA ID numbers are issued on a per-site basis. This means, for example, if a business has two sites where hazardous waste is treated, both sites must have their own EPA ID number. It also means that you must obtain a new EPA ID number if your business moves to a new location.
In addition and with a few exceptions, sources who engage in used oil operations must have an EPA ID number and submit a notification of hazardous waste activities.
To obtain an EPA ID number, you must complete the federal "Notification of Hazardous Waste Activity" Form 8700-12, which may be obtained from EPA or your state environmental agency.
Although not indicated in the RCRA regulations, the form's instructions require you to submit a revised form when any of the following occur:
- Your facility moves
- Ownership changes (including the addition or replacement of an owner)
- The type of regulated waste activity conducted at the facility changes
- You commence to market or burn hazardous waste for energy recovery
- The person you've listed on the form as the "installation contact" changes