October 10, 2017

Site ID Form (Form 8700-12) Revamped

With the exception of very small quantity generators (VSQGs), a generator of hazardous waste must obtain an EPA identification (ID) number before it can manage (i.e., treat, store, dispose, transport, or offer for transportation) hazardous waste. [§262.18(a)] Additionally, generators (other than VSQGs) must use hazardous waste transporters and TSD facilities with EPA ID numbers. [§262.18(c)] The 12-character EPA ID number is used by states and EPA to track hazardous waste activities. An EPA ID number is obtained by completing the Notification of RCRA Subtitle C Activities, EPA Form 8700-12 (also known as the Site ID form). [§262.18(b)]

This form has recently been modified and revamped, adding numerous additional data fields that support the various new notifications required by the November 28, 2016 generator improvements rule [81 FR 85732] and import-export rule. [81 FR 85696] The table below summarizes the activities that trigger initial notification and those activities that would trigger subsequent renotification.

Activities That Trigger RCRA Subtitle C Notification or Renotification

RCRA Subtitle C activity	Initial notification	Renotification
Generate, store, transport, recycle, treat, import/export, or dispose hazardous waste	X
Transport, process, or re-refine used oil	X
Burn off-spec used oil for energy recovery¹	X
Market used oil fuel	X
Large quantity universal waste handler² or universal waste destination facility	X
Move the business to another location and conduct hazardous waste activities at the new location	X
VSQG/SQG notification of episodic generation	X
LQG consolidation of VSQG hazardous waste	X
LQG notification of closure for central accumulation area or entire facility	X
Electronic manifest broker	X
Opt into or withdraw from the Part 262, Subpart K alternative program for managing hazardous waste at an eligible academic laboratory	X (opt into)	X (withdraw from)
Begin or stop managing hazardous secondary materials outside of the RCRA program under §§261.4(a)(23), (24), or (27)³	X (begin)	X (stop)
Change the ownership of the site	X⁴	X
Change the contact or mailing address for the site		X
Add or replace an owner since the last notification was submitted		X
Change the type of regulated waste activity conducted at the site		X⁵

¹Used oil generators are not required to notify EPA, even if they burn their own off-spec used oil in used oil-fired space heaters per §279.23.

²If the large quantity handler already has an EPA ID number, he/she does not have to notify. [§273.32(a)(2), RO 13783, 14088]

³Such facilities must submit an addendum to the Site ID form. This form can also be used to make a §260.43(a)(4)(iii) notification that recycling is legitimate. Note that the verified recycler exclusion at §261.4(a)(24) was vacated by the U.S. Court of Appeals for the DC Circuit on July 7, 2017.

⁴If a new owner/operator notifies for a location that already has an EPA ID number, it can still be an initial notification if the new owner/operator has not previously submitted a notification form. [RCRA Subtitle C EPA Identification Number, Site Status, and Site Tracking Guidance, March 21, 2005]

⁵Sites must use the Site ID form to submit a subsequent notification if they wish to change generator status (i.e., LQG, SQG, or VSQG).

Source: Adapted from Notification of RCRA Subtitle C Activities (Site ID Form), EPA Form 8700-12.

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Disclaimer

Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.

This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.