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Frequently Asked Questions

Biennial Reporting System (BRS) 
EPA Identification Numbers 
Freedom of Information (FOIA) 
Hazardous Waste 
Lead Poisoning Prevention 
Toxic Substances (PCBs) 
Underground Storage Tanks 



Q. What is friable and non-friable asbestos containing material? 

A. Friable ACM is any material containing more than one percent asbestos (as determined by Polarized Light Microscopy) that, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable ACM is any material containing more than one percent asbestos (as determined by Polarized Light Microscopy) that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. Under the Asbestos NESHAP, non-friable ACM is divided into two categories. Category I non-friable ACM are asbestos-containing resilient floor coverings (commonly known as vinyl asbestos tile (VAT)), asphalt roofing products, packaging and gaskets. These materials rarely become friable. All other non-friable ACM are considered category II non-friable ACM. 

Q. Are single-family private residences regulated by the Asbestos NESHAP? 

A. No. 

Q. How much asbestos must be present before the Asbestos NESHAP work practice standards apply to renovation projects? 

A. Asbestos NESHAP regulations must be followed for all renovations of facilities with at least 80 linear meters (260 linear feet) of regulated asbestos-containing materials (RACM) on pipes, or 15 square meters (160 square feet) of regulated asbestos-containing materials on other facility components, or at least one cubic meter (35 cubic feet) off facility components where the amount of RACM previously removed from pipes and other facility components could not be measured before stripping. These amounts are known s the "threshold" amounts. 

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Q. I Am Going to Renovate a Building That Used to Be a School. It is going to be put back in service as an office complex for a commercial firm. Must I use AHERA Standards for the asbestos removal during the renovation? 

A. AHERA does not apply, this facility is in fact now a public building as defined by ASHARA, and ASHARA and Clean Air Act Standards apply. 

Q. We are going to utilize a community center for training our swimming team, and a special education class for 10th grader's. In addition we are going to start an adult education program of college level courses. Does AHERA apply? 

A. The area used by the swimming team and the special education area including lunch rooms if used are an extension of the school district and require an inspection by an accredited inspector and a management plan no later than 30 days prior to use identifying, and quantifying all known or suspect asbestos-containing material, all AHERA protocols apply to these areas, establish an O&M plan, maintain 6 mos surveillance and reinspect every three years. The area used by the adult education program does not come under AHERA as it does not fit the definition of elementary or secondary education institutions. 

Q. I am going to open a Pre-school in Gettysburg, PA and also one in Hagerstown Maryland, will these two Pre-schools fall under AHERA? 

A. The site in Gettysburg will not, however the one in Hagerstown, Md will. The reason for the difference lies in the definition of a school which is an elementary or secondary education center as defined by the individual state. Pennsylvania identified this as Kindergarten through 12th grade, and Maryland defines this as Pre-school, Day Care centers through 12th grade. 

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Q. How can I obtain information on the Biennial Reporting System (BRS)? 

A. All BRS data information can be found under the Office of Solid Waste, Hazardous Waste Data on the worldwide web.  

You can download the latest Biennial Reporting Data (most current data is from 2011) from EPA's FTP site (note this file is for entire USA and is a compressed (zip) 34.8 MB file. If you are interested only in data for a particular geographic area or a specific facililty you can go to the EPA's Facility Registry System (FRS) and do a FRS query selecting "Biennal Reports" in the "National System Search" Section of the FRS query.

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Q. How can I obtain information under the Freedom of Information Act (FOIA)? 

Under the Freedom of Information Action (FOIA), information on facilities that generate, treat, store or dispose of hazardous waste within RCRA EPA Region 3 may be requested from us. 

Requests for records held by or believed to be held by this office, should be written requests. The request must give a clear description of the requested information so that the government documents or records can be properly identified. After your request has been processed you will receive a hard copy of your request. Particular reports are available on 3.5 floppy disk and can be sent to you at your request. 

Written request, describing the document or records desired should be sent to: 

Rita Tate (3PA00)
FOIA Coordinator
U.S. Environmental Protection Agency
Region 3
1650 Arch Street
Philadelphia, PA 19103-2029
email: tate.rita@epa.gov

Voluminous records may be reviewed at our location. 


Photocopying = .15 per page 
Search time = $4.00 per half hour (if applicable) 
Review time = $4.00 per half hour (if applicable) 

If the charges amount to less than $25.00, the fee is waived. 

Some reduction in fee may apply to Educational and Non-Commercial Scientific Institutions, Representatives of the News Media, and other non categorized requestors. 

We have also provided public access to certain RCRA EPA Region 3 reports through the Internet at the following web address http://www.epa.gov/reg3wcmd/rcrainfo.htm.

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Q. I handle/have hazardous waste. How can I get an EPA Identification Number? How can I obtain EPA Form 8700-12 (Notification of Hazardous Waste Activity)? 

A. EPA Identification numbers can be obtained by filling out a Notification of Regulated Waste Activity Form and sending it to the agency responsible for issuing and processing identification numbers. 

Obtain information or forms from, 
and mail completed forms to: 
Delaware Department of Natural Resources 
& Environmental Control 
Hazardous Waste Management Branch 
P.O. Box 1401, 89 Kings Highway 
Dover, DE 19903 
(302) 739-3689 
(302) 739-3672 

District of Columbia 
Obtain information or forms from, 
and mail completed forms to: 
Department of Consumer and 
Regulatory Affairs 
Environmental Regulation Administration 
Hazardous Waste Branch 
2100 Martin Luther King Jr. Ave., S.E. 
Washington, DC 20020 
(202) 645-6080, extension 3023 

Obtain information or forms from, 
and mail completed forms to: 
Maryland Department of the Environment 
Waste Management Administration 
Hazardous Waste Program 
1800 Washington Boulevard
Baltimore MD 21230-1719
(410) 537-3000

Obtain information or forms from, 
and mail completed forms to: 
Pennsylvania Department of 
Environmental Protection 
Rachel Carson State Office Building
Notifications Section 
P.O.Box 8471 
Harrisburg, PA 17105-8471 
(717) 787-6239 


Obtain information or forms from, 
and mail completed forms to: 
U.S. Environmental Protection Agency 
Region 3
RCRA Programs Branch 
Pennsylvania Section (3WC11) 
1650 Arch Street 
Philadelphia, PA 19103 
(215) 814-3408 

Obtain information or forms from, 
and mail completed forms to: 
Department of Environmental Quality 
629 East Main Street 
Richmond, VA 23219 
(804) 698-4177 

West Virginia 
Obtain information or forms from, 
and mail completed forms to: 
Department of Commerce, Labor and 
Environmental Protection 
Division of Environmental Protection 
Office of Waste Management 
1356 Hansford Street 
Charleston, WV 25301 
(304) 558-5393 

Q. I applied for an EPA Hazardous Waste Identification Number. What is my EPA Identification Number? 

A. Hazardous Waste Identification Numbers for States in Region 3 can be accessed by calling the EPA RCRA Interactive Voice Response System -- (202 ) 260-4300. This service is available 24 hours a day seven days a week. 

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Q. What is RCRA? 

A. RCRA is the Resource Conservation and Recovery Act, which was enacted by Congress in 1976. RCRA's primary goals are to protect human health and the environment from the potential hazards of waste disposal, to conserve energy and natural resources, to reduce the amount of waste generated, and to ensure that wastes are managed in an environmentally sound manner. 

Q. What is regulated under RCRA? 

A. RCRA regulates the management of solid waste (e.g., garbage), hazardous waste, and underground storage tanks holding petroleum products or certain chemicals. 

Q. What is a RCRA hazardous waste? 

A. Wastes that exhibit certain characteristics may be regulated by RCRA. A waste may be considered hazardous if it is ignitable (i.e., burns readily), corrosive, or reactive (e.g., explosive). Waste may also be considered hazardous if it contains certain amounts of toxic chemicals. In addition to these characteristic wastes, EPA has also developed a list of over 500 specific hazardous wastes. Hazardous waste takes many physical forms and may be solid, semi-solid, or even liquid. 

Q. What is a RCRA solid waste? 

A. According to the EPA regulations, solid waste means any garbage, or refuse, sludge from a wastewater treatment plant, water supply treatment plant, or air pollution control facility and other discarded material, including solid, liquid, semi-solid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations, and from community activities. 

Q. Who is regulated by the RCRA hazardous waste program? And... Who is regulated by the RCRA municipal solid waste program? 

A. The RCRA hazardous waste program regulates commercial businesses as well as federal, state and local government facilities that generate, transport, treat, store, or dispose of hazardous waste. Each of these entities is regulated to ensure proper management of hazardous waste from the moment it is generated until its ultimate disposal or destruction. The RCRA municipal solid waste program regulates owners and operators of municipal solid waste landfills. The regulations stipulate minimum criteria that each landfill must meet in order to continue operating. 

Q. Can anyone handle RCRA hazardous waste? 

A. No. Handlers of hazardous waste must meet certain regulatory requirements. Generators and transporters must have government issued identification numbers, and comply with other regulations regarding the handling of hazardous waste. Treatment, storage and disposal facilities must meet even more stringent requirements, and must have a permit to operate. 

Q. Do citizens have any control over the construction of a waste facility in their community? 

A. The RCRA regulations require public participation, such as public meetings, throughout the permitting process for new Hazardous and solid waste treatment, storage, or disposal facilities. Public participation provides citizens with a forum to express their concerns over the construction of a new facility. 

Q. What types of businesses generate hazardous waste? 

A. Many types of businesses generate hazardous waste. Some are small companies that may be located in your community. For example, the following types of businesses typically generate hazardous waste: dry cleaners, auto repair shops, hospitals, exterminators, and photo processing centers. Some hazardous waste generators are larger companies like chemical manufacturers, electroplating companies, and petroleum refineries. 

Q. How should household hazardous waste (e.g., paint, paint thinner, batteries, used oil) be disposed? 

A. Hazardous wastes that are generated in the home, like mineral spirits and old paint, are not regulated by the federal RCRA program. Many communities provide collection centers or pick-up services for the management of household hazardous waste. 

Q. Who regulates landfills that accept municipal garbage? And... Can these municipal landfills accept hazardous waste? 

A. Landfills that collect household garbage are predominately regulated by State and local governments. EPA has, however, established minimum criteria that these landfills must meet in order to stay open. The only hazardous waste that municipal landfills can accept is household hazardous waste and waste that is exempt from hazardous waste regulation. 

Q. Where can I get answers to more questions about RCRA? 

A. Call the RCRA Hotline at (800) 424-9346 or (703) 412-9810 (from the Washington, DC area). The Hotline is open Monday through Friday, 9:00 a.m. to 6:00 p.m. eastern time. 

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Q. I have concerns over an existing (or proposed) solid waste landfill in my area impacting my health and/or polluting the environment. What are the rules/regulations that a landfill operator must comply with? How can I find out about if my local landfill is in compliance with these rules, and/or express my concerns over a proposed landfill? 

A. EPA has issued national criteria for the proper siting, construction, and operation of municipal solid waste landfills to minimize the environmental impact of land disposal of wastes.. These criteria can be found on EPA's national homepage. The states in Region 3 have adopted these national criteria as their own state requirements, and in many cases added additional requirements. Since EPA is not authorized by federal laws to issue permits for the operation of non-hazardous waste landfills, the federal criteria are implemented by each state's environmental agency as part of their landfill permitting and enforcement regulations. Therefore, if you have a question about a specific landfill in your area, you can contact your state landfill permitting agency (state solid waste contacts) to determine the status of its compliance with its state landfill permit, and/or the status of the state's review of any applications for new or expanded landfills. 

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Q. What are the chances my older home has lead-based paint? How can I tell if it does? 

A. The older the home, the better chance it contains some lead-based paint (LBP). A rule of thumb: built before 1950 -- probably LBP both inside and out. Between 1950 and 1960 -- probably LBP outside, maybe not inside. Between 1961 and 1970 --some chance for outside LBP, probably not inside. Between 1971 and 1978 -- slight chance of LBP. NOTE: Although LBP was essentially banned in 1978, some existing LBP might have been used for two or more years afterwards (i.e., to 1980 or 1981). 

The only way to tell positively if you have LBP is to have it properly tested by a professional. 

Q. Who is most at risk of lead poisoning and why? I'm sure my kids won't eat lead paint. If they got it on their hands I surely would see it. 

A. Children under six years old are most at risk because their brains and nervous systems are still developing. Of these, children between ages one and three are especially vulnerable, since they are walking playing and crawling on the floors where lead dust can accumulate. They get the dust into their bodies through hand-to-mouth activity. They also put toys and pacifiers in their mouths which have fallen on the floor. 

Lead makes things taste sweet. The Romans used lead to sweeten their wines. So children and pets are attracted to the taste of lead paint chips and especially to lead dust. 

Put two single grains of sugar on the bottom of a fingertip. Do you see it? It only takes lead dust equal to two grains of sugar a day on a child's fingertips then transferred to the mouth, for perhaps a month, to cause that child's nerve velocity decrease, making the child slower both physically and mentally -- perhaps for life. While the change may not be easily noticeable, it could cost a budding scholar or athlete their competitive edge. 

Q. But didn't we all grow up with lead? They even used it in gasoline. What's the big deal now? 

A. That's true. The lead alert level used to be 40 micrograms per deciliter of whole blood until the mid seventies, then was reduced to 30 in the mid eighties, 25 between 1985 and 1992 then the present ten. It wasn't until we took it out of gasoline in the mid seventies to mid eighties that we were able to discern how devastating it can be, especially to children under six years of age. So most of us could probably have been smarter and faster than we are. NOTE: Pregnant women can also transfer lead in their blood streams to a developing fetus at concentrations only half the present alert level (also called level of concern). 

Lead was used in gasoline because it increased the efficiency of the gasoline while also lubricating the valves. But now we know: while lead has many uses, they can come with a high, toxic price tag. 

Now that we know how toxic lead is, we want to take every precaution which is practicable to control it and prevent serious health effects. The cost of ignoring it are too great in decreased capabilities, earnings and enjoyment of life. It makes both good health and economic sense to take proper precautions now. 

Q. Where can I get more information? 

A. Call your state lead program. It should be listed in the pamphlet, Protect Your Family From Lead in Your Home, which every landlord and property owner are required to give to prospective renters and buyers. If you do not have a copy, call 1-800-424-LEAD and ask them to send you one. You can also call your EPA Regional Office as listed in the pamphlet for additional help and information. 

You can obtain additional pamphlets and articles from these sources, including a booklet on simple repairs and remodeling which you can do safely. You can get lists of certified professionals from your state program. You can get additional information by calling the National Lead Information Center at 1-800-424-LEAD and/or talk to a lead program expert in EPA Region 3 (DC, DE, MD, PA, VA, WV) via E-mail or by calling, toll free, 1-800-438-2474. 

If you have extensive renovations to do and are handy, you can find a qualified instruction provider by calling your state lead program. After taking a course (which lasts a matter of days, depending on what depth of training you desire) you not only will be able to do your own renovations safely but will qualify to do work part-time to help others and earn extra money. 

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Q. What is a pesticide? 

A. The term "pesticide" means any substance or mixture of substances intended for preventing, destroying, repelling, or mitigating any organism or pest. 

Q. How Do I Come into Compliance? 

A. View information on the national EPA site  

Q. What are the Alternatives? 

A. IPM Link to Pesticide Page 

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Q. Where can I take things from my trash to be recycled? 

A. Because recycling collection programs are very specific depending on your location, the best source of information on where to take materials for recycling is usually your local county recycling coordinators. In Region 3, the states of Maryland, Virginia, and Pennsylvania provide this information on the Internet. They can be accessed directly at Maryland County Recycling Coordinators, Pennsylvania County Recycling Coordinators, or Virginia County Recycling Coordinators. In the District of Columbia, call 202-727-5887. In Delaware, call 1-800-404-7080. And in West Virginia, call 304-55-3370. 

Another source of recycling information is through the National Recycling Hotline, which can be accessed through the Internet or by telephone at 1-800-CLEANUP. 

Q. How do I get a grant from EPA for recycling? 

A. There are several EPA grant programs which fund State and local governments and non-profit organizations to promote and support the principles of integrated solid waste management, especially recycling. See the discussion of funding programs under Recycling. The regional RCRA solid waste program does not have monies available to fund directly individuals who want to start up a recycling-related business. However, some states have seed money and/or tax incentives for private businesses. See the discussion of state contacts under Recycling. 

For state and local governments and non-profit organizations that may be eligible for EPA funding, a general solicitation for grant proposals are issued in the fall of each year by the RCRA Solid Waste program. To discuss your eligibility, and/or to be put on the regional mailing list for the solicitations, call 215-814-3298 or 215-814-3375. 

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Note: Currently, there is information regarding PCBs on the Internet. This information pertains to general requirements for PCB Transformers and requirements for fluorescent light ballasts which may contain PCBs. 

Q. Is my facility subject to the requirements of the PCB Spill Cleanup Policy even if the spill occurred before 1987? 

A. For pre-1987 PCB spills, the cleanup requirements are evaluated on a case-by-case basis. However, most cases are usually subject to the cleanup requirements in accordance with 40 C.F.R. Part 761, Subpart G. 

Q. Are there certain tasks I should perform when a spill occurs? 

A. When a spill occurs, you should immediately contact the National Response Center (NRC -1-800-424-8802) and the corresponding EPA Regional Office Spill Response Hotline for where the facility is located. The Spill Response Hotline number for Region 3 is 215-814-3255. You should also immediately implement the following: 

Cordon off the spill area 

Immediately apply absorbent materials (cloths/rags, vermiculite, etc.) to the visibly wet areas -Note: These items should be placed in a container/drum after use for future proper disposal. 

Maintain a written record of the immediate and future remediation actions 

Further requirements for sampling and the decontamination levels are located at 40 C.F.R. Part 761, Subpart G. 

Q. Are there any record keeping requirements before I begin cleanup operations? 

A. Prior to initiating a cleanup action, you should complete the Notification of PCB Activity form (EPA Form 7710-53). These forms may be obtained from the Washington, DC Headquarters, the Federal Register -Volume 54, Number 244, dated Thursday, December 21, 1989, page 52725, or the corresponding EPA Regional Office of the facility location. 

Q. Is there a general number that I can call for other questions? 

A. The Toxic Substances Control Act (TSCA) hotline number located in Washington, DC is 202-554-0515. 

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Q. Is my tank regulated? 

A. Not all UST systems are Federally regulated, although they may be regulated by the state or local agency that implements an UST program and you should first check with them. You should refer to the Code of Federal Regulations, 40 CFR Part 280 for a complete definition. 

Q. I want to buy a property which may contain USTs? What should I do to protect myself from liability? 

A. A way to investigate property for USTs is to have the property owner contract to conduct a home survey or an environmental site assessment of the entire property. The question of possible contamination from a leaking tank (past or present) will almost certainly come up in any transaction involving a property which has or had an UST. You should contact the State Environmental Agency for records on a property which may shed light on this question. A thorough site assessment of the property should provide the UST owner with details on any contamination found. 

Q. I want to close my UST. Can the tank be left in the ground or does it have to be dug up? 

A. EPA requires that all tanks taken out of service permanently must be either removed from the ground or filled with an inert solid material Some state agencies, however, require that the tank be removed from the ground unless special permission is granted. You should contact the State Environmental Agency regarding state UST regulations. 

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Region 3 The Mid-Atlantic States

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