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Frequently Asked Questions

This page contains answers to commonly asked questions. The answers are generalized and are not applicable in all circumstances. If you are seeking an answer to a question requiring more specific information, please contact the Hazardous Waste Division directly at 717-787-6239.
 
Where can I get help to reduce my hazardous waste? 
 The Hazardous Waste Minimization Program offers services to companies that generate waste. These services include free Waste Minimization/Pollution Prevention Site Visits, Source Reduction Strategy development, as well as recognition programs for companies who voluntarily reduce hazardous waste. For more information on the services available to you please click on the following link: Hazardous Waste Minimization
  
Does PA recognize the universal waste program? If so, what are the wastes? 
 
Does PA have universal wastes different than the Federal program? 
Pennsylvania incorporates the federal regulations by reference, thus the universal waste program is part of PA regulation. PA recognizes the wastes termed as universal wastes under the federal program along with mercury-containing devices. Other wastes are presently under consideration to be included as universal wastes. Universal Wastes
  
What do I do with a spent fluorescent light bulb from my house? 
Spent fluorescent lamps should be recycled by taking them to a household hazardous waste collection event, or by shipping them to a mercury recycler. They can be put out with other household trash as hazardous waste from a household is exempt from hazardous waste regulation in PA and most other states. Fluorescent Lamp Recycling
  
Does PA allow the use of commercial drum-top bulb crushers for spent fluorescent lamps? 
 Not at this time. The federal regulations prohibit the use of bulb crushers without a permit and PA incorporates those regulations. Fluorescent lamps contain mercury that is very pervasive throughout the environment. If the drum-top crushers receive federal approval, PA will consider their use.
  
Do I have to complete a new form 8700-12 (renotify) if I only generate an increased amount of hazardous waste for one month? 
The PA regulations allow for ‘episodic' generation events. Renotification is not necessary if the frequency of episodic generation is every other year or less. If the amount generated puts the facility over the large quantity generator limits for that month, they must complete a biennial report for that year. Other renotification requirements are found in the regulations at 25 Pa Code 262a.12.
  
If I move my facility to a different location can I still use my same EPA ID number? 
No, EPA ID numbers are site (location) specific. When a facility relocates they should notify DEP so that the old number can be inactivated. If the facility moves to a location that has an existing identification number, the regulations require the facility to notify the DEP so that the existing number can be reactivated. If the new location does not have an EPA ID number, the facility must renotify (complete form 8700-12) for the new location. Conditionally exempt small quantity generators (CESQGs) are not required to notify.
  
If I own a facility which has an EPA ID number for that address, and I sell, rent or lease part of it to another generator, do they use the same number? 
The regulations don't specifically prohibit that from happening. It is generally not advantageous for a person or facility to be responsible for the hazardous waste someone else generates at that location. In this case the facility should differentiate the address for the leased (or sold) space from the rest of the facility, and a different ID number obtained for the leased portion of the facility.
  
Does PA allow ‘satellite accumulation'? 
Yes. PA follows the federal guidelines for satellite accumulation. The satellite accumulation point must be at or near the point of generation, and must be under control of the operator.
  
Can I accumulate more than one waste at a satellite location and what is the maximum amount that I can accumulate? 
Yes, more than one waste may be accumulated at a satellite location. A total of 55 gallons of hazardous waste may be accumulated at a satellite location, not 55 gallons of each waste. In no instance may more than 55 gallons be accumulated at a satellite location. E.G. if three wastes are accumulated at a location, the total volume of the three wastes accumulated at the satellite location cannot exceed 55 gallons.
  
Does PA require any special license to transport hazardous waste in the state? 
Yes, a Hazardous Waste Transporter license must be obtained from the DEP if hazardous waste is picked up or delivered to PA. A PA hazardous waste permit is not required if only passing through the state.
  
How do I obtain a PA Hazardous Waste Transporter license? 
An application may be downloaded from the Hazardous Waste Management web page at Hazardous Waste Transporter License Application
  
When applying for a Hazardous Waste Transporter License, can I submit a surety bond? 
No, surety bonds are not acceptable for Transporter license.
  
If I am a conditionally exempt small quantity generator can I transport my own hazardous waste in PA without a Hazardous Waste Transporter license? 
A conditionally exempt small quantity generator (CESQG) may transport their own waste in PA for treatment storage or disposal without obtaining a formal PA Hazardous Waste Transporter license through a license by rule process found in the regulations. Large Quantity Generators (>2200 pounds of hazardous waste per month) and Small Quantity Generators (>220 but <2200 pounds of hazardous waste per month) must obtain their own hazardous waste transporter license or hire an already-licensed PA hazardous waste transporter.
 
I am a conditionally exempt small quantity generator, do I have to use a manifest to ship hazardous waste in PA? 
The regulations do not require a CESQG to use a manifest, however most treatment, storage or disposal facilities require a manifest before accepting hazardous waste for management.
  
What is permit-by-rule? 
The term "permit-by-rule" refers to the mechanism whereby the owners or operators of certain types of facilities, which are required to have a permit from the Department, are deemed to have a permit without proceeding through the entire permitting process. In general, permit-by-rule facilities pose little or no threat to public health or the environment. Qualification for and retention of permit-by-rule status is contingent upon the operator's compliance with the applicable provisions of the regulations. The Department may require the owner or operator of a permit-by-rule facility to obtain a written permit when the facility is not in compliance with the applicable provisions of the regulations, or is engaged in an activity that harms or presents a threat of harm to public health or the environment.
  
What types of hazardous waste facilities are eligible to operate under permit-by-rule? 
 Pennsylvania's hazardous waste regulations identify six general types of hazardous waste treatment facilities that are eligible to operate under permit-by-rule. They are: (1) “elementary neutralization units ”; (2) “wastewater treatment units”; (3) treatment in generator accumulation units (“containers”, “tanks”, or “ containment buildings”); (4) battery manufacturing facilities reclaiming spent, lead-acid batteries; (5) treatment onsite, at the site of generation, prior to reclamation at the same site; and (6) treatment of hazardous waste to make it suitable for recovery of economically significant amounts of certain precious metals. Provisions applicable to each of these permit-by-rule types are outlined in 25 Pa. Code § 270a.60 of Pennsylvania's hazardous waste regulations (note that it is also important to check the definitions of certain terms, incorporated by reference from the Federal hazardous waste regulations at 40 CFR § 260.10, such as those italicized and enclosed in quotation marks above).
  
What do I have to do to operate under a hazardous waste permit-by-rule? 
 A notification must be submitted to the appropriate DEP Regional Office on a form provided by the Department. Click here to get a copy of the form. Compliance with the regulatory provisions applicable to the specific type of permit-by-rule is necessary to qualify and retain the permit-by-rule.
  
What type of treatment in hazardous waste generator accumulation units is eligible to be performed under permit-by-rule? 
 Generally, any treatment for which the regulatory standards applicable to the particular generator accumulation unit (container, tank, or containment building) are designed to protect human health and the environment may be performed under this permit-by-rule. Other types of treatment for which specific standards have otherwise been developed (i.e. thermal treatment, incineration, etc.) are not eligible to be performed in generator accumulation units. Permit-by-rule treatment must be performed within the applicable generator accumulation period (generally 90 or 180 days after the waste has been generated).
  
Has Pennsylvania adopted the Federal Solvent-Contaminated Wipes Rule? 
 The Federal Solvent-Contaminated Wipes Final Rule was published on July 31, 2013, and became effective January 30, 2014.   Pennsylvania incorporates this rule by reference at 25 Pa. Code § 260a.3 (e ), so this rule is now effective in Pennsylvania.
  
Highlights of the solvent-contaminated wipe rule include:
 
  • A definition of “wipe” at 40 CFR § 260.10 stating that the term means a woven or non-woven shop towel, rag, pad, or swab made of wood pulp, fabric, cotton, polyester blends, or other material.
  • A definition of “solvent-contaminated wipe” at 40 CFR § 260.10 establishing that the term refers to a wipe that, after use or after cleaning up a spill, either: 1) contains one or more F001 – F005 solvent or the corresponding P- or U-listed solvent; 2) exhibits a hazardous characteristic when that characteristic results from a listed solvent; or 3) exhibits only the hazardous characteristic of ignitability due to the presence of one or more non-listed solvents.
  • A definition of “No free liquids” at 40 CFR § 260.10 establishing that, in the context of the solvent-contaminated wipe provisions, “no free liquids” means that wipes may not contain free liquids as determined by the SW-846 Paint Filters Liquids Test and that there is no free liquid in the container holding the wipes.
  • Adds a conditional exclusion from classification as solid waste at 40 CFR § 261.4(a)(26) for solvent-contaminated wipes that are sent for cleaning and reuse (note that these wipes will not be further subject to Pennsylvania residual or municipal waste regulations since the only hazardous waste exclusions and exemptions subject to further solid waste regulation in Pennsylvania are those at 40 CFR § 260.2 [see 25 Pa. Code § 260a.2]).  Conditions which must be met in order to be eligible for this solid waste exclusion include:
    • When accumulated, stored, and transported, the wipes must be contained in non-leaking, closed containers that are labeled “Excluded Solvent-Contaminated Wipes” (more detail regarding the term “closed” is in the rule at 261.4(a)(26)(i)); 
    • Wipes may be accumulated by the generator for up to 180 days from the accumulation start date prior to being sent for cleaning; 
    • At the point of being sent for cleaning on-site or at the point of being transported off-site for cleaning, the wipes must contain “no free liquids” as defined at 40 CFR § 260.10; 
    • Free liquids removed from the wipes or the container holding the wipes must be managed according to applicable regulations; 
    • Generators must maintain documentation regarding the receiving laundry or dry cleaner, documentation demonstrating that the 180 day accumulation time limit is being met, and documentation describing the process used to ensure the wipes contain no free liquids; and 
    • Wipes must be sent to a laundry or dry cleaner whose discharge, if any, is regulated under NPDES or pretreatment water program provisions.
  
  • Adds a conditional exclusion from classification as hazardous waste at 40 CFR § 261.4(b)(18) for solvent-contaminated wipes that are sent for disposal (note that these wipes will be further subject to Pennsylvania residual or municipal waste regulations since the exclusion is only from classification as hazardous waste and not from classification as solid waste).  This hazardous waste exclusion is NOT available for wipes that are hazardous due to the presence of trichloroethylene.  Conditions which must be met in order to be eligible for this hazardous waste exclusion include:
    • When accumulated, stored, and transported, the wipes must be contained in non-leaking, closed containers that are labeled “Excluded Solvent-Contaminated Wipes” (more detail regarding the term “closed” is in the rule at 261.4(b)(18)(i)); 
    • Wipes may be accumulated by the generator for up to 180 days from the accumulation start date prior to being sent for disposal; 
    • At the point of being transported for disposal, the wipes the wipes must contain “no free liquids” as defined at 40 CFR § 260.10; 
    • Free liquids removed from the wipes or the container holding the wipes must be managed according to applicable regulations; 
    • Generators must maintain documentation regarding the receiving landfill or combustor, documentation demonstrating that the 180 day accumulation time limit is being met, and documentation  describing the process used to ensure the wipes contain no free liquids; and 
    • Wipes must be sent for disposal at a regulated solid or hazardous waste landfill, to a regulated municipal waste or other combustion facility, to a regulated hazardous waste combustion facility, or to a regulated hazardous waste boiler or industrial furnace.
 
For additional infomation regarding the rule refer to the US EPA Solvent-Contaminated Wipes Rulemaking web page.