Re-Notification Requirement for Small Quantity Generators

As referenced in one of our previous Stakeholder Communications, Small Quantity Generators of Hazardous Waste are now required to submit a Re-Notification of their activities every four years. The first submission was due on September 1, 2021 and then every four years thereafter.  The 2016 Hazardous Waste Generator Improvements Rule included this requirement. Here are some details on what needs to be submitted:

The Re-Notification needs to be submitted on the USEPA 8700-12 Notification of RCRA Subtitle C Activities (Site Identification Form) or state equivalent. Generators should check with their respective states for proper guidance.

This Re-Notification requirement is currently effective in authorized states that have adopted the Generator Improvements Rule, as well as non-authorized states (Iowa and Alaska), Indian Country and most U.S. Territories. Use this link to EPA’s map of where the Generator Improvements Rule is currently in effect

If the generators state has opted into the MyRCRAID electronic reporting system, generators are encouraged to use the same.

For Re-Notification purposes, in Box 1 on the 8700-12 form, SQG’s should check:

Obtaining or updating an EPA ID number for on‐going regulated activities (Items 10‐17 below) that will continue for a period of time

And then complete the applicable sections of the form.

In a somewhat confusing caveat, EPA considers SQG submittal of the Site ID form (in full) anytime within the four years before the deadline to meet this requirement. SQGs should contact their state to ensure this requirement is effective in their state as well as whether their state requires more frequent Re-Notification than every four years.

As always, please contact your WTS Technical Representative if you have any questions on this matter.

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