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Hazardous Waste; RCRA Subtitle C

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The Resource Conservation and Recovery Act (RCRA) Subtitle C establishes a federal program to manage hazardous wastes from cradle to grave. The objective of the Subtitle C program is to ensure that hazardous waste is handled in a manner that protects human health and the environment. To this end, there are Subtitle C regulations for the generation; transportation; and treatment, storage or disposal of hazardous wastes. In practical terms, this means regulating a large number of hazardous waste handlers. The RCRA Subtitle C program also:

The Subtitle C program has resulted in perhaps the most comprehensive regulations EPA has ever developed. The regulations first identify the criteria to determine which solid wastes are hazardous, and then establish various requirements for the three categories of hazardous waste handlers: generators, transporters, and treatment, storage and disposal facilities (TSDFs). In addition, the Subtitle C regulations set technical standards for the design and safe operation of TSDFs. These standards are designed to minimize the release of hazardous waste into the environment. Furthermore, the regulations for TSDFs serve as a basis for developing and issuing the permits required by the Act for each facility. Permits are essential to making the Subtitle C regulatory program work, since it is through the permitting process that the EPA or state applies standards to TSDFs.

The RCRA Corrective Action program is a result of the 1984 Hazardous and Solid Waste Amendments (HSWA) passed by Congress. These amendments required the cleanup of contamination from improper waste management practices both prior and after the passage of RCRA. The statute requires responsible parties that are seeking a permit to treat, store or dispose of hazardous wastes to clean up environmental contaminants at their sites regardless of the time of release. EPA’s Corrective Action authority was substantially expanded by HSWA, allowing the Agency to address any releases of hazardous waste or hazardous waste constituents to all environmental media at both RCRA permitted and non-permitted facilities.

EPA Identification Numbers

All persons who generate, transport, treat, store, or dispose of hazardous waste and all persons who store recyclable materials prior to recycling them are required under the Resource Conservation and Recovery Act (RCRA) to notify EPA of their hazardous waste activities. The persons located in NJ and NY should notify their New Jersey Exit EPA disclaimer or New York Exit EPA disclaimer State agency if the State is authorized to operate its own hazardous waste program. These persons must obtain an EPA Identification Number unless their solid waste has been excluded from regulation or their hazardous waste has been exempt.

Identification and listing of hazardous waste can be found in CFR Title 40 - Protection of Environment Chapter I, Part 261.

An EPA Identification Number is issued based on the submitted Notification of Regulated Waste Activity form (EPA Form 8700-12.)

If your business moves to another location, the operator or the owner must notify the State and EPA Regional Office of this change. Since your business has changed locations, a new EPA Identification Number will be assigned based on the new Notification form submittal.

RCRA requires anyone who owns or operates a facility where hazardous waste is treated, stored, or disposed of to have a permit. To start the permitting process the owner of the facility is required to submit a RCRA Hazardous Waste Part A Permit Application (EPA Form 8700-23). The submission of a revised application is required when modifying the hazardous waste permit.

For more information on all of the RCRA regulations governing hazardous waste identification, classification, generation, management and disposal visit EPA's Hazardous Waste Regulations website.

A completed notification form for each site located in New York, Puerto Rico and U.S. Virgin Islands, should be mailed to:

U.S. Environmental Protection Agency - Region 2
Clean Air and Sustainability Division
Hazardous Waste Programs Branch
290 Broadway, 22nd Floor
New York, NY 10007-1866
Attn.: RCRA Notifications

The forms sent by regular mail are generally processed within two weeks. A written Acknowledgment of the Notification of Regulated Waste Activity form is sent within three weeks from the receipt date of the form. The forms sent to EPA by Express Mail Services are usually processed within 24 hours. The person is notified of the issued EPA ID number by telephone.

A completed notification form for each site located in New Jersey should be mailed to:

NJ Department of Environmental Protection
Hazardous Waste Compliance & Enforcement 
9 Ewing Street, 3rd Floor     
Mail Code 09-03
P.O. Box 420  
Trenton, NJ 08625-0420              

There are two types of Identification Numbers being issued by EPA Region 2 and NJDEP:

Please mail a deactivation request letter to the appropriate State or EPA Office listed below:

  • Puerto Rico or U.S. Virgin Islands

U.S. Environmental Protection Agency - Region 2
Clean Air and Sustainability Division
Hazardous Waste Programs Branch
290 Broadway, 22nd Floor
New York, NY 10007-1866
Attn.: RCRA Notifications  

  • New Jersey

Mail an original request to:

NJ Department of Environmental Protection
Hazardous Waste Compliance & Enforcement 
9 Ewing Street, 3rd Floor     
Mail Code 09-03 
P.O. Box 420 
Trenton, NJ 08625-0420    

Mail a copy to:

U.S. Environmental Protection Agency - Region 2
Clean Air and Sustainability Division
Hazardous Waste Programs Branch
290 Broadway, 22nd Floor
New York, NY 10007-1866
Attn.: RCRA Notifications  

  • New York State

Mail an original request to:

U.S. Environmental Protection Agency - Region 2
Clean Air and Sustainability Division
Hazardous Waste Programs Branch
290 Broadway, 22nd Floor
New York, NY 10007-1866
Attn.: RCRA Notifications  

Mail a copy to:

NYS Department of Environmental Conservation
DER, Manifest and Reporting Section
625 Broadway, Floor 12
Albany, NY 12233-7252

You will be required to provide detailed information about the accident:

The emergency number will be given to you immediately. This number is valid for 30 days only.

The above procedure is for obtaining an emergency EPA ID number only. Other Federal and State reporting requirements may apply. For example:

For additional sources to help with your questions and provide information on EPA and State regulations contact:

Other Regulatory and Technical Assistance Information Related

Wastes Laws and Regulations
Asbestos and Small Business Ombudsman Office -- 1-800-368-5888
Hazardous Waste Requirements for Large Quantity Generators [PDF 396.6 KB, 4 p]
Fluorescent Lamp Disposal and Recycling in EPA Region 2 - A guide for businesses in NJ, NY, PR and VI (April 2007). [PDF 328.42 KB, 4 p]
Regulation of Fluorescent Lamps in New York and New Jersey Exit EPA disclaimer
Regulation of Medical Waste in New York and New Jersey Exit EPA disclaimer
National Compliance Assistance Centers Exit EPA disclaimer

Other Points of Interest

EPA Office of Solid Waste and Emergency Response 
EPA Wastes 
Issues for Industry
Issues for State/Tribal
Issues for Concerned Citizens 
Issues for State/Tribal
Issues for Concerned Citizens 

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