Comparison of State and Federal Hazardous Waste Rules
General Summary (find a description of Federal Rules here).
Arizona 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 Arizona, use the EPA Form 8700-12: Notification of Regulated Waste Activity Forms and Instructions, to determine if you are subject to the requirements under the Resource Conservation and Recovery Act (RCRA) for notifying the State of Arizona of your regulated waste activities. To obtain the form from the ADEQ, call (602) 771-4147 or write to ADEQ, Hazardous Waste Section, Facility
Assistance Unit, 1110 W. Washington St., Phoenix, Arizona, 85007, and request a copy of
EPA Form 8700-12. Send your completed form(s) to the designated contact listed in the instructions. For further information and instructions, view the Arizona permit information web page.
2. How do I determine my generator status?
Arizona generally follows the federal rules for defining generator status.
LQGs AND SQG's must submit a copy of each manifest to ADEQ
LQGs and SQG's must annually register annually with ADEQ and pay registration fees.
Generators must pay disposal fees if they ship hazardous waste off-site to disposal facilities not owned by them; if they ship hazardous waste off-site for disposal to a facility owned by them and the facility is located out-of-state; or if they dispose of their waste on-site. If the generator is on compliance with the state's pollution prevention requirements, they only have to pay half of specified fees for each ton of hazardous waste, and only if they provide written certification that they are in compliance with the manifest.
A burning fee is imposed for each gallon of hazardous waste fuel or hazardous waste that is burned for energy recovery and that was not generated by the operation of the business of the facility burning the waste.
3. How can I tell if the waste materials I handle are considered
Arizona generally follows the federal rules for defining hazardous wastes.
Documentation must be provided to the ADEQ that the exclusion requirement has been met, when one claims the exclusion from hazardous waste found in the federal regulations, for wastes that fail the test for the toxicity characteristic because chromium is present.
4. How long can I store hazardous wastes on site?
Arizona generally follows the federal rules for storing hazardous wastes.
Generators in Arizona that store hazardous waste on-site without a storage facility permit must do so in accordance with the federal accumulation time and on-site storage requirements.
Generators inspecting their containers, tanks, or containment buildings in accordance with the federal regulation must keep a written log of the weekly inspections.
Generators accumulating ignitable, reactive, or incompatible waste must comply with the federal TSDF requirements.
5. Who can transport and receive the wastes I ship off site?
Arizona generally follows the federal rules for transporting hazardous wastes.
Transporters must also meet state requirements for registration, fees, manifests, and hazardous waste release reports.
6. What records do I have to keep?
Arizona follows the federal rules for recordkeeping.
Generators who inspect their containers, tanks, or containment buildings under federal rules must maintain a written log of weekly inspections and keep on file for at least three years.
7. Do I have to file reports?
Arizona generally follows the federal rules for reporting.
LQGs are required to file annual reports with ADEQ.
LQGs must file an annual Toxic Data Report and submit and implement a 2-year pollution prevention plan.
CESQG's may be required to maintain and provide reports regarding the treatment, storage, transportation, disposal, or management of hazardous waste if the waste poses a substantial present or potential hazard to human health or the environment when it is improperly treated, stored, transported, disposed, or otherwise managed.
8. What training requirements do I have to meet?
Arizona generally follows the federal rules for training.
Arizona has state-specific training requirements for pesticide workers and UST service providers. The state has its own certification requirements for wastewater treatment plant and collection system, and drinking water system operators.
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 Arizona these differences include:
Additional Wastes: None.
Generators must submit the completed manifest to ADEQ within 45 days following the end of the month of shipment. Transporters of shipments originating in the state must send one copy of the manifest, with the transporter's signature, to ADEQ no later than 30 days following the end of the month of shipment. TSDF's must send one copy of the manifest, with the facility owner's or operator's signature, to ADEQ within 30 days following the end of the month of shipment.
Exception reports must be submitted by LQG's within 45 days following the end of the month of shipment of the waste. SQG's must submit the report to ADEQ within 60 days following the end of the month of shipment of the waste.
Other Notes, Comments::
If ADEQ receives a required, but improperly completed manifest, they can require the completion and resubmission of the manifest, along with a $20 fee.
10. What are some other differences between federal and state
Storage facilities must provide additional reporting information, pay permit application and/or modification fees. They must also register annually and pay annual fees.
Underground storage tank owners whose tanks do not meet the federal standards must measure daily levels; record and calculate material balance; and test yearly for leaks.
In the event of an explosion, fire, other release, or if a spill has reached groundwater or discharged into a dry well or sewer system, generators must immediately notify the ADEQ at its 24-hour emergency number or other contact number.
CESQG's must obtain the approval of the solid waste facility to accept the CESQG's hazardous or acute hazardous waste.
- Chris Salem, General, (602) 771-4673, firstname.lastname@example.org
- Anthony Leverock, TSD Permitting, (602) 771-4160, email@example.com
- Dee Woodard, EPA Identification Numbers, (602) 771-4232, firstname.lastname@example.org
- David Alamillo, Hazardous Waste Manifests, (602) 771-4743, email@example.com
- Kathy Feliberty, Hazardous Waste Facility Annual Reports, (602) 771-4214, firstname.lastname@example.org