September 1 Deadline for RCRA SQGs to Re-Notify EPA

Posted on 8/20/2021 by Roseanne Bottone

September 1, 2021 is the first deadline for small quantity generators (SQGs) of hazardous wastes to re-notify EPA (or their state environmental agency) of their activities. EPA’s 2016 RCRA Generator Improvements Rule added a provision to the hazardous waste regulations to require re-notification from SQGs once every four years on September 1 (40 CFR 262.18(d)(1)).

Small quantity generators must re-notify EPA using Form 8700-12, also called a Site ID Form (or the state equivalent). Electronic reporting via the MyRCRAID system is an option in some states.

By requiring re-notification from small quantity generators every four years, EPA can “maintain more accurate data into the future for outreach, compliance assistance, and oversight activities.”

Why EPA Requires Notification from Generators

Generators must not treat, store, dispose of, transport, or offer for transportation, hazardous waste without having first received an EPA identification number. They must apply for the ID number for their site by submitting the Site ID Form.

Among other information required on the form, regulated persons notify the EPA of their generator status–large, small, or very small.

What About Large Quantity Generators?

Large quantity generators of hazardous waste, or LQGs, are required to re-notify EPA of their status by March 1 of each even-numbered year using Form 8700-12. LQGs may submit this re-notification as part of the Biennial Report required under 40 CFR 262.41.

Updated Annual RCRA Training

The addition of a re-notification mandate for SQGs is just one of the many substantive RCRA updates that generators must identify to stay in compliance in 2022. Others include stricter contingency planning requirements, updated container marking standards, new rules for satellite areas, and more.

Get RCRA training that covers the latest rules for generators. These updated online courses guide you through the updated rules you must know to keep your facility in compliance with RCRA.

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Tags: biennial reporting, Form 8700-12, hazardous waste, hazardous waste reporting, RCRA, small quantity generator

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