Comparison of State and Federal Hazardous Waste Rules
General Summary (find a description of Federal Rules here).
Illinois 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 Illinois, 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 Illinois of your regulated waste activities. Send your completed form(s) to the designated contact listed in the instructions, or below. If you generate over 100 kg (220 lbs) of any kind of special waste, you must obtain and use an Illinois EPA identification number. To obtain the Illinois EPA identification number application, contact the Office of Small Business and ask for a copy of the "Illinois EPA Inventory Identification Number Application." The Illinois identification number application as well as EPA 8700-12 can also be found on Illinois EPA's web page. Send both the U.S. EPA and Illinois EPA completed applications to Illinois EPA, Bureau of Land (#24), Solid Waste Management Section, 1021 North Grand Avenue East, P.O. Box 19276, Springfield, Illinois 62794-9276.For further information, view Illinois' permit information web page.
2. How do I determine my generator status?
Illinois generally follows the federal rules for defining generator status. CESQGs cannot dispose of hazardous waste in a landfill not specifically permitted to accept the particular hazardous waste.
3. How can I tell if the waste materials I handle are considered
Illinois follows the federal rules for defining hazardous wastes.
4. How long can I store hazardous wastes on site?
Illinois generally follows the federal rules for storing hazardous wastes.Owners and operators of hazardous waste tanks must submit their variance request from secondary containment requirements must submit them to IEPA. Hazardous waste storage facilities must have local approval for siting the facility.Hazardous waste storage facilities owners and operators must pay an annual hazardous waste management fee.
5. Who can transport and receive the wastes I ship off site?
Illinois follows the federal rules for shipping hazardous wastes to a TSD.Generators must use the state's manifest form and submit a copy of each manifest to IEPA within two days of shipping the waste.Hazardous waste generators must use a transporter who has a special waste hauler permit from IEPA. CESQGs are exempted from this requirement.
6. What records do I have to keep?
Illinois follows the federal rules for recordkeeping.IEPA annual reports must be kept on file for three years.
7. Do I have to file reports?
Illinois follows the federal rules for reporting. LQGs that ship hazardous waste off-site must prepare and submit an annual report to IEPA.
8. What training requirements do I have to meet?
Illinois 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 Illinois these differences include:
Illinois requires non-hazardous special waste to be manifested on the Uniform Hazardous Waste Manifest. Illinois generators and out-of-state generators sending nonhazardous waste to an Illinois receiving facility must use a manifest for all shipments of nonhazardous special waste. All nonhazardous special waste should be identified as either Class A or Class B. Copies of these manifests are not to be submitted to the State of Illinois; instead Illinois receiving facilities and Illinois generators who send their waste out-of-state are required to submit summary information in the form of the Nonhazardous Special Waste Annual Report
Effective September 5, 2006 receiving facilities do not have to submit copies of manifests to the Illinois EPA. Generators in Illinois and out-of-state generators sending manifested waste to an Illinois facility must submit copies within two days of shipment (for RCRA hazardous and PCB wastes) to: Illinois EPA -- MC24, PO Box 19276, 1021 N. Grand Avenue East, Springfield, IL 62794-9276
Other Notes, Comments:: None.
10. What are some other differences between federal and state
Generators who dispose of hazardous waste on-site must pay a fee based on the quantity of waste disposed of on-site and submit a quarterly waste summary report.
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