Comparison of State and Federal Hazardous Waste Rules
General Summary (find a description of Federal Rules here).
Alabama generally follows the federal rules for hazardous waste management, and also has more stringent state requirements.
1. Do I need an EPA ID number to handle hazardous wastes
In Alabama, you submit a copy of ADEM Form 8700-12 to obtain an EPA ID number. You are also required to re-file a copy of ADEM Form 8700-12 every year to reflect current waste activities (The month for filing the form is determined by the county in which the waste is generated.). The filing fee is $75. The annual filing requirement applies to all hazardous waste generators, including CESQGs that have an active EPA ID number. If you have an active EPA Identification Number and wish to stop using it, you may send a letter to ADEM, on company letterhead, requestingthat the number be deactivated.
2. How do I determine my generator status?
Alabama generally follows the general federal rules for defining generator status. CESQGs may apply for an EPA ID number. If a CESQG has an active EPA number, they must file a copy of ADEM Form 8700-12 every year to reflect current waste activities. Also, ADEM may require a CESQG to submit a disposal plan for approval.Generators may be required to submit a plan for approval for the disposal of any hazardous waste generated, regardless of whether the waste is to be disposed of on-site or off-site. Generators (CESQGs excluded) must submit ADEM Form 8700-12 annually. There is a $75 fee.Generators who periodically switch between generator classifications should submit notification for the higher classification. Generators must report the location address of the facility receiving their hazardous waste on their biennial report.LQGs must notify ADEM in writing no less than 45 days before closing, ceasing storage in, or moving a hazardous waste container storage area, tank system, drip pad, or containment building, and provide a written report within 45 days of the closing.
3. How can I tell if the waste materials I handle are considered
Alabama follows the federal rules for defining hazardous wastes.PCBs disposed of at state commercial hazardous waste facilities are subject to an ADEM pre-approval process.
4. How long can I store hazardous wastes on site?
Alabama generally follows the federal rules for storing hazardous wastes. Containers having a capacity greater than 30 gallons to be stacked over two containers high is prohibited. Secondary containment systems for containers are required for containers used by LQGs accumulating hazardous waste on-site without a permit.Spilled or leaked waste must be removed from the sump or collection area of the secondary containment system within "24 hours after detection. "LQGs must submit a written request to ADEM to store hazardous waste on-site for up to 30 days past the expiration of the 90-day accumulation period. LQGs must mark each container with the EPA hazardous waste number.Alabama adds the requirement that the annual review of initial training be "not later than 365 days from the date of the initial training session or prior annual training review" LQGs must comply with the federal rules for contingency plans as well as an additional rule that documentation be kept to show that the plan has been submitted to the appropriate authorities.When a facility ceases to operate, moves, or closes for business, the generator must close each container storage area, storage tank, drip pad, and containment building according to state requirements. LQGs must follow the federal hazardous waste security requirements for waste treatment, storage, and disposal facilities. LQGs must have secondary containment for their containers and record their weekly inspections in a log or summary. LQGs must make all records, including plans, furnished upon request and made available at all reasonable times to ADEM. SQG's must also mark each container with the EPA hazardous waste number SQG's must also contact the state's Department of Public safety of an explosion, a fire, or other release that could threaten human health or the environment outside the facility or when the generator has knowledge that a spill has reached surface water.
5. Who can transport and receive the wastes I ship off site?
Alabama generally follows the federal rules for shipping hazardous wastes to a TSD. Generators cannot ship hazardous wastes for disposal unless they have applied to and received approval from ADEM. Hazardous waste generators should only use permitted transporters with an ADEQ approved Transport Permit and an EPA ID number. CESQG's are exempt from this requirement.
6. What records do I have to keep?
Alabama follows the federal rules for recordkeeping. Transporters must have copies of their hazardous waste transporter permit and a copy of the contingency plan with each vehicle.Container inspections must be recorded in a log or summary and kept for at least three years
7. Do I have to file reports?
Alabama generally follows the federal rules for reporting. LQGs must submit a closure report to closing, ceasing storage in, or moving a hazardous waste unit.
8. What training requirements do I have to meet?
Alabama follows the federal rules for training.
9. What differences between states may exist with regard to use of the the new standardized manifest form?
As of September 5, 2006, the new standardized manifest form (EPA Form 8700-22) and its continuation sheet (EPA Form 8700-22A) must be used in every state to track hazardous waste shipments. There will be no state variations of the new federal form and states may not require information to be included on the form that is in addition to that required by federal rules. That said, some differences between states may exist with regard to use of the form. For Alabama these differences include:
At this time there are no state-specific waste code requirements
Other Notes, Comments::
If submittal of a copy of the Hazardous Waste Manifest is required through Treatment, Storage, or Disposal facility requirements or by Alabama Hazardous Wastes Management and Minimization Act (AHWMMA) Permit, submit to the following address: Alabama Department of Environmental Management Waste Programs Branch, PO Box 301463, Montgomery, AL 36130-1463
10. What are some other differences between federal and state
Alabama allows hazardous waste generators to treat hazardous waste on-site without a permit provided the generator meets certain requirements.
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