Hazardous Waste FAQs

Hazardous Waste
What is RCRA?RCRA is the acronym for the Resource Conservation and Recovery Act, a law that creates the framework for the management of hazardous waste as well as non-hazardous solid waste. It establishes “cradle to grave” control of hazardous waste. The regulations that lay out the provisions of RCRA can be found in title 40 of the Code of Federal Regulations in parts 239 through 282.
What is an EPA ID number?An EPA ID number is somewhat like a Social Security Number (SSN). They are both relatively permanent and essential. Where a SSN is assigned to a person, the EPA ID is assigned to a facility that is a generator, a transporter, a treatment, storage and disposal (TSD) facility, or a recycler of hazardous waste. Keep in mind, the number is assigned to the facility address, not the company. If you move, you will need to obtain a new EPA ID number for your new facility.

The EPA ID number itself has three letters at the beginning which are followed by 9 numbers. The first two letters correspond to the state abbreviation where the number was issued. The EPA ID number assures that waste is tracked cradle to grave.

For more information you can visit the NDEP website.
Who needs to get an EPA ID number?Generators (Large Quantity Generators and Small Quantity Generators), transporters and facilities that treat, store or dispose of hazardous waste are required by RCRA to notify their state or US EPA of the location and general description of hazardous waste management activities and what characteristic or listed waste(s) are being handled. Conditionally exempt small quantity generators (CESQG) are exempt from the requirement to obtain an EPA ID number except where a more stringent state program requires it. If the state where the CESQG is located does not require an EPA ID, but the state where the CESQG’s waste is being shipped does, then the CESQG should obtain an EPA ID.
How do I apply for an EPA ID number?That is relatively simple. There is no charge or fee for getting an EPA ID number.

To submit a paper copy of the notification, click here.

It will open a document from the USEPA titled “RCRA Subtitle C Reporting Instructions and Forms”. This is a long document, the actual form to fill out is found in the section titled “RCRA Subtitle C Activities Forms” near the end of the document. Please do not just skip to the form and start filling it in. Read the instructions for each section prior to filling it out. If you have questions, contact BEP at 800.882.3233.

When you complete this form, whether it is for an initial notification and to request an EPA ID or to update information, always check to be sure that the form you are using is not expired. In the form accessed from the link above, the expiration date is in the top right-hand corner of each page. Once completed and signed (did you remember to make a copy to keep in your records?) mail the form to:

Nevada Division of Environmental Protection
Bureau of Waste Management
901 South Stewart Street, Suite 4001
Carson City, Nevada 89701-5249

To submit the notification electronically, the U.S. EPA has an online tool called myRCRAid, a module within the RCRAInfo Industry Application, which allows handlers to submit initial and/or subsequent notifications. You must first register to obtain an Industry User account through the RCRAInfo Industry User Application. Once you have registered, you may log into the RCRAInfo Sign In page with your newly established user name and password to submit the EPA Form 8700-12 online to the Nevada Division of Environmental Protection.
How do I deactivate my EPA ID number?You can deactivate your EPA ID number by going to the following link. EPA ID number deactivation. Once you have compiled the necessary information you should mail the letter to:

Nevada Division of Environmental Protection
Bureau of Waste Management
901 South Stewart Street, Suite 4001
Carson City, Nevada 89701-5249
What is my generator status?There are three statuses that a generator may have (Episodic Generator is not a status that has been adopted for use in Nevada):

Conditionally Exempt Small Generator (CESQG) generates 220 pounds (100 kilograms) or less of hazardous waste per month.

Small Quantity Generator (SQG) generates more than 220 pounds (100 kilograms) but less than 2200 pounds (1000 kilograms) of hazardous waste per month.

Large Quantity Generator (LQG) generates 2200 pounds (1000 kilograms) or more of hazardous waste per month.

There are things that can impact what wastes or materials are counted toward your generator status. Recycling and reclamation, for example, MAY reduce what gets counted toward generator status. The generation of 2.2 pounds (1 kilogram) of an acute hazardous waste* in a calendar month will place a generator in LQG status. Contact the Business Environmental Program for assistance determining your status if you have questions.
*An acute hazardous waste is a waste that carries a P-code, which is found in 40 CFR 261.33.

What are the recordkeeping requirements?Recordkeeping requirements for LQGs are found at 40 CFR 262.40-262.43. 40 CFR 262.44 codifies the requirements for SQGs. Conditionally Exempt Small Quantity Generators have very few record keeping requirements. However, keep in mind that a state, county or local jurisdiction may have more stringent requirements. The summary table on this EPA webpage is a good starting point.
What is waste minimization?Waste minimization refers to using source reduction (i.e. using less hazardous materials in the process’s feedstock or reorganizing a work flow to reduce the number of cleaning operations) and/or environmentally sound recycling methods prior to the treatment or disposal of waste. US EPA’s preferred hierarchy for waste management is:

1. Source Reduction
2. Recycling
3. Energy Recovery
4. Treatment
5. Disposal
What are the benefits of waste minimization?Simply put, money and time. The reduction of the quantity and toxicity/hazard of waste protects the environment along with the people, plants and animals that live in it.

Waste minimization practices can help you change the RCRA regulatory status of your business from that of an LQG down to an SQG or even an CESQG. Each step down the generator status hierarchy reduces the regulatory burden on your business.

Waste minimization can potentially reduce liability and it can increase production efficiency and profits. Environmental performance, overall environmental sustainability, and perception by neighbors and others within industry can also be improved with effective waste minimization measures.