Pennsylvania no longer issues temporary “PADEP” EPA ID numbers. Facilities that normally do not generate hazardous waste but are currently generating hazardous waste as a result of a one-time, non-recurring, temporary event that is not related to normal production processes, should notify as a short-term generator utilizing the EPA Site Identification Form (8700-12) (see Item 10.A.2. on the form) to obtain an EPA ID number.
Short-term generators produce hazardous waste from a particular activity for a limited time and then cease conducting that activity. Examples of short-term generators include:
- one-time highway bridge waste generation;
- underground storage tank removals;
- generation of off-specification or out-of-date chemicals at a site that normally doesn’t generate hazardous waste;
- remediation or spill clean-up at sites with no previous EPA ID number; and
- site or production process decommissions by a new operator.
Once the short-term activity is complete, the EPA Site Identification Form (8700-12) should be completed and notification made that regulated activity is no longer occurring at the site so that the number can be deactivated. Otherwise, the EPA ID number will remain active for the site.
Episodic generators are not short-term generators because episodic generators (i.e., SQGs and VSQGs) regularly generate hazardous waste as a part of normal operations but elevate to a higher generator category as a result of a planned or unplanned event.
Pennsylvania's hazardous waste management regulations allow for "episodic" generation events. Episodic event means an activity, either planned or unplanned, that does not normally occur during routine operations, resulting in an increase in the generation of hazardous wastes that exceeds the calendar month quantity limits. VSQGs and SQGs may maintain their existing generator category for hazardous waste generated during an episodic event provided certain conditions are met. 40 CFR 262.232
For a planned episodic event, a generator must notify the DEP thirty (30) calendar days prior to initiating the event using the EPA Form 8700-12. For an unplanned episodic event, the generator must notify DEP within 72 hours of the event via phone, email or fax and subsequently submit EPA Form 8700-12. Any notifications of episodic generation events that are not within the time limits noted above or claims made within one year of a previous episodic event without Department approval, may result in an enforcement action.
Generators must have or obtain an EPA ID number to take advantage of the episodic generator provision. Generators are limited to claiming one episodic event per calendar year, unless a petition to manage one additional episodic event is granted by DEP under 40 CFR 262.233. A generator who has already held a planned episodic event may petition for an additional unplanned episodic event. Likewise, a generator who has already held an unplanned episodic event may petition for an additional planned episodic event.
A VSQG or SQG that generates more than their established category amount as part of an episodic event does not become a large quantity generator and does not need to complete a Biennial Report. The episodic generator provision allows a VSQG or an SQG to generate additional quantities of hazardous waste — temporarily exceeding its normal generator category limits — and still maintain its existing generator category, provided the generator complies with the specified conditions.
No, EPA ID numbers are site (location) specific. When a facility relocates, they should notify DEP (via EPA Form 8700-12) so 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 (via EPA Form 8700-12) so the existing number can be reactivated. If the new location does not have an EPA ID number, the facility must obtain an EPA ID number for the new location. Very small quantity generators (VSQGs) are not required to notify.
The regulations do not 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.
Yes. Pennsylvania incorporates the federal guidelines for satellite accumulation found in 40 CFR 262.15. The satellite accumulation point must be at or near the point of generation and must be under control of the operator.
Yes, more than one waste may be accumulated at a satellite location. A total of 55-gallons consisting of non-acute hazardous waste and/or one quart of liquid acute or one kg (2.2 lbs.) of solid acute hazardous waste may be accumulated at a satellite location, but not 55-gallons of each waste. In no instance may more than 55-gallons be accumulated at a satellite location. For example, if three wastes are accumulated at a location, the total volume of the three wastes accumulated at the satellite location cannot exceed 55-gallons.