Notification of Regulated Waste Activity

 Message: As a precautionary response to COVID-19, personnel are working remotely. Please complete all notifications electronically through myRCRAid.  We cannot guarantee that paper-based submissions will be processed in a timely manner.

U.S. EPA identification (ID) numbers are tracking numbers assigned by Ohio EPA’s Division of Environmental Response and Revitalization (DERR) for certain hazardous waste, used oil and universal waste activities. Ohio EPA utilizes U.S. EPA’s RCRAInfo database to assign these numbers. U.S. EPA identification numbers are part of a nationwide effort to track hazardous waste from “cradle to grave” and to ensure protection of human health and the environment. You may need a U.S. EPA ID number if you are a generator of hazardous waste, or if you are a handler of universal waste or used oil. You will also be required to obtain a U.S. EPA ID number if you transport or treat, store, or dispose of hazardous waste.

There is no fee associated with obtaining an ID number. The guidelines for obtaining a number can be found in the Notification of Regulated Waste Activity instruction booklet. The notification form’s official name is RCRA Subtitle C Site Identification (EPA Form 9029). It is commonly referred to as the Site ID Form. See the table below about options for completing and submitting this form.

Effective October 5, 2020
New Requirements for Notifying Ohio EPA of Your Activity

Opting into the Episodic Generator Provisions

If you are a Very Small Quantity Generator or Small Quantity Generator wanting to take advantage of the episodic generator event provisions outlined in OAC 3745-52-230 through 3745-52-233, please note the following:

  1. You may only have one planned or one unplanned event per calendar year with the ability to petition for a second event; however, if the first event was planned, the petition can only be for an unplanned event, or vice-versa.
  2. For a planned event, the Site ID Form and Episodic Generator Addendum Form must be submitted to Ohio EPA no later than 30 days prior to the event or it will not qualify for the episodic provisions.
  3. For an unplanned event, the Site ID Form and Episodic Generator Addendum Form must be submitted to Ohio EPA within 72 hours of the event or it will not qualify for the episodic provisions.
  4. All hazardous waste must be removed from the facility within 60 days of the start date specified on the Episodic Generator Addendum Form and must comply with all conditions listed in OAC 3745-52-230 through 3745-52-233.

Examples of Planned Events: excess chemical inventory removal, tank clean outs, short term construction or demolition, and equipment maintenance during plant shutdowns.

Examples of Unplanned Events: accidental spills, production process upsets, product recalls, and acts of nature such as tornadoes, hurricanes, floods, etc.

Your submission will consist of a Site ID Form (EPA 9029) and the Episodic Generator Addendum. If you need to list more waste streams than will fit on one Addendum, use extra forms as needed.

NOTE: It is recommended that your facility’s RCRA Subtitle C Site Identification Form (EPA 9029) and the required Episodic Generator Addendum Form be submitted electronically using myRCRAid, an online application provided by US EPA’s RCRAInfo system. Using myRCRAid is faster and more accurate as compared to a paper form that is completed by hand and mailed. More information about myRCRAid can be found below.

Healthcare Facilities and Reverse Distributors

If you are a healthcare facility or reverse distributor operating under the hazardous waste pharmaceuticals provisions outlined in OAC rules 3745-266-500 through 3745-266-510, please note the following:

  1. If you are a healthcare facility or reverse distributor operating under the hazardous waste pharmaceuticals provisions outlined in OAC rules 3745-266-500 through 3745-266-510, you must notify Ohio EPA of your activity within sixty days of the rule effective date using the Site ID Form (EPA 9029). If the facility still qualifies as a LQG even after becoming subject to rules 3745-266-500 to 3745-266-510, the healthcare facility or reverse distributor notification can be part of the next Biennial Report submission due 3/1/2022.
  2. Very Small Quantity Generators who choose to opt into all of the new pharmaceutical rules (OAC rules 3745-266-500 through 3745-266-510) instead of operating under 3745-52-14 are required to notify Ohio EPA using the Site ID Form.
  3. A healthcare facility that is co-located within a larger facility that is not a healthcare facility (e.g., a clinic at a military base, school, or manufacturer), must notify that it is operating as a healthcare facility under OAC rules 3745-266-500 through 3745-266-510 unless the entire site is a VSQG.
  4. Healthcare facilities that are no longer a Large Quantity Generator or Small Quantity Generator may withdraw from managing hazardous waste pharmaceuticals under OAC rules 3745-266-500 through 3745-266-510. There is box on the Site ID Form to indicate withdrawal. Reverse distributors may NOT withdraw from this rule.

NOTE: It is recommended that your facility’s RCRA Subtitle C Site Identification Form (EPA 9029) be submitted electronically using myRCRAid, an online application provided by US EPA’s RCRAInfo system. Using myRCRAid is faster and more accurate as compared to a paper form that is completed by hand and mailed. More information about myRCRAid can be found below.

LQG Closure of a Central Accumulation Area or Entire Facility

If you are a Large Quantity Generator (LQG) closing your entire facility or central accumulation area, please note the following:

  1. LQGs are required to notify Ohio EPA no later than 30 days prior to closing their entire facility.
  2. LQGs are also required to notify Ohio EPA within 90 days after closing the entire facility and having complied with the closure performance standards of OAC 3745-52-17(A)(8)(c), or notify Ohio EPA that they cannot meet the closure performance standards.
  3. Optionally, an LQG may notify they are closing a Central Accumulation Area.

If at any time on or after the 10/05/2020 effective date of OAC rule 3745-52-17 (conditions for exemption for LQGs that accumulate hazardous waste), a generator meets the definition of a LQG and accumulates hazardous waste on-site in any units subject to closure performance standards, the generator is subject to the closure notification requirements of OAC rule 3745-52-17(A)(8).

Former LQGs that are no longer LQGs as of 10/05/2020 are still subject to the applicable closure standards for the hazardous waste management units which accumulated hazardous waste.

NOTE: It is recommended that your facility’s RCRA Subtitle C Site Identification Form (EPA 9029) be submitted electronically using myRCRAid, an online application provided by US EPA’s RCRAInfo system, especially if your facility will be submitting more than one form over time. Using myRCRAid is faster and more accurate as compared to a paper form that is completed by hand and mailed. More information about myRCRAid can be found below.

LQG Consolidation of Hazardous Waste from Very Small Quantity Generators

If you are a Large Quantity Generator (LQG) wanting to consolidate hazardous waste from VSQGs, please note the following:

  1. LQGs may only receive and consolidate hazardous wastes from VSQGs if the VSQGs are under the control of the same “person” as defined in OAC 3745-50-10.
  2. If you are an LQG taking advantage of the provision found at OAC 3745-52-17 you must notify (or re-notify) Ohio EPA using the Site ID Form and the LQG Consolidation of Hazardous Waste from VSQGs Addendum Form, completing information for each VSQG from which the LQG is consolidating waste from.
  3. Each time you notify, including with the Biennial HW Report, you will need to submit the Addendum form to provide a current list of VSQGs.
  4. VSQG waste is reported separately on Biennial Hazardous Waste Report GM Forms by using a specific Source Code, G51. For reporting purposes be sure to keep good records on the VSQG waste.

NOTE: It is recommended that your facility’s RCRA Subtitle C Site Identification Form (EPA 9029) and the required Addendum form be submitted electronically using myRCRAid, an online application provided by US EPA’s RCRAInfo system, especially if your facility will be submitting more than one form over time. Using myRCRAid is faster and more accurate as compared to a paper form that is completed by hand and mailed. More information about myRCRAid can be found below.

Small Quantity Generator Renotification Required Every 4 Years

If you are a Small Quantity Generator (SQG) in the state of Ohio, please note the following:

  1. If the previous notification was prior to 9/1/2017, before 9/1/2021 you must re-notify Ohio EPA of your SQG hazardous waste activities using the Site ID Form (EPA 9029).
  2. If the previous notification of your SQG activity was on or after 9/1/2017, the requirement has been met for 9/1/2021.
  3. Every four years after 9/1/2021, your facility must re-notify Ohio EPA of your SQG hazardous waste activities. The next renotification would be due 9/1/2025 if the facility is still a SQG at that time.

To find out whether Ohio EPA lists your facility as a SQG, go to RCRAInfo Web and click on Hazardous Waste Sites and then Search by Site. The quickest way to search is by the site’s ID number (also known as an EPA ID, HW ID, or RCRA ID). Click on the search results to view the current facility details. Please submit a Site ID Form if the information is incorrect.

NOTE: It is recommended that your facility’s RCRA Subtitle C Site Identification Form (EPA 9029) be submitted electronically using myRCRAid, an online application provided by US EPA’s RCRAInfo system, especially if your facility will be submitting more than one form over time. Using myRCRAid is faster and more accurate as compared to a paper form that is completed by hand and mailed. More information about myRCRAid can be found below.

Options for Notifying of Regulated Waste Activity using the Site ID Form

Option Description Tips Links
myRCRAid Complete the form using myRCRAid through U.S. EPA’s RCRAInfo Industry Application. Use this service to request new and update existing EPA ID Numbers. This is the preferred method for companies with a large number of locations or frequent submissions. This is an all-electronic process with no need to mail the Site ID Form. It provides a quicker turn-around and email notifications are issued at each step of the process.
Microsoft Word Fillable Form Document Complete form using Microsoft Word. Print, sign and mail to address on page 1 of the form. A partially completed form can be saved and finished later.
Addendum to the Site Identification Form - Episodic Generator This addendum is to be submitted with the Site ID Form when a VSQG or SQG opts into provisions outlined in ORC 3745-52-230 through 3745-52-233.
  • For a planned event, the forms must be submitted at least thirty days prior to event
  • For an unplanned event, you must inform Ohio EPA within 72 hours of the event and follow-up with submitting the forms
Addendum to the Site Identification Form- LQG Consolidation of VSQG Hazardous Waste If an LQG is consolidating hazardous waste from VSQGs, this addendum is to be submitted with the Site ID Form each time the LQG notifies.
  • The Site ID Form and Addendum must be resubmitted if VSQG information changes.
       

 

For paper-based submissions, the Certification Section on page 3 needs to be signed before the form is mailed. Ohio EPA will not process forms without an original signature and a certification date.

Completed Site ID forms should be mailed to Ohio EPA - DERR at P.O. Box 1049, Columbus, OH, 43216-1049.

Rules and Laws

Hazardous Waste

Universal Waste

Used Oil

Guidance Documents, Fact Sheets, Forms and Reports

  • List of EPA Hazardous Waste Codes - Contains a list of the U.S. EPA Hazardous Waste Codes and their descriptions. Each hazardous waste handled by a facility is to be listed by code on the Site ID Form.

Related Webpages

  • Generator Requirements
  • Universal Waste
  • Used Oil
  • U.S Census Bureau NAICS webpage - Look up North American Industrial Classification System codes. A minimum of one code is required to be reported on the Site ID Form.
  • Ohio EPA Frequently Asked Questions — Enables users to search frequently asked questions, or submit their own question/comment on a variety of Ohio EPA issues and topics. This link is filtered to provide responses specific to hazardous waste notification. Additional questions and answers about U.S. EPA ID numbers and the notification process can be found here.
  • Publication Catalog — Enables users to search for forms, guidance documents, publications, newsletters, checklists etc. on a variety of Ohio EPA issues and topics. This link is filtered to provide publications specific to hazardous waste notification.
  • Ohio EPA Information Subscription Page

Rules and Laws

Hazardous Waste

Universal Waste

Used Oil

Guidance Documents, Fact Sheets, Forms and Reports

  • List of EPA Hazardous Waste Codes - Contains a list of the U.S. EPA Hazardous Waste Codes and their descriptions. Each hazardous waste handled by a facility is to be listed by code on the Site ID Form.
 
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Physical address:
Ohio EPA - DERR
Lazarus Government Center
50 W. Town St., Suite 700
Columbus, OH 43215

Mailing address:
Ohio EPA - DERR
Lazarus Government Center
P.O. Box 1049
Columbus, OH 43216-1049 

 Notification of Regulated Waste Activity
Mitchell, Bradley Environmental Manager (614) 728-5361
Pappas, Lexi Notification Coordinator (614) 914-2527
Harvey, Sarah Notification Coordinator  
Canter, Paula Hazardous Waste System Administrator (614) 644-2923
     
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