Comparison of State and Federal Hazardous Waste Rules
General Summary (find a description of Federal Rules here).
Tennessee follows the federal rules for hazardous waste management and also more stringent state requirements.
1. Do I need an EPA ID number to handle hazardous wastes
In Tennessee, you submit a copy of the state's Notification Forms to the address listed on the forms to obtain an EPA ID number. The fee is $100. You can also receive Notification Packet by calling 1-800-237-7018 or 615-532-0878 them to the address located on the forms. For further information and instructions, view the Tennessee permit information web page.
2. How do I determine my generator status?
Tennessee generally follows the federal rules for defining generator status. LQGs and SQG's must file a notice that details each individual hazardous waste stream produced and the activities concerning the wastes. Notification within 90 days is required if a generator generates hazardous waste at more than one location. There is a $50 fee. Any significant changes must be reported to the state.
3. How can I tell if the waste materials I handle are considered
Tennessee generally follows the federal rules for defining hazardous wastes.Hazardous waste is a subset of waste in Tennessee. The state uses the term "solid waste," to define waste that is not hazardous. The state does not follow many of the federal exemptions, which makes more wastes hazardous, or hazardous under certain circumstances. Included are chromium and products and raw materials.
4. How long can I store hazardous wastes on site?
Tennessee follows the federal rules for storing hazardous wastes.Generators can store hazardous waste on-site without a storage facility permit if they follow federal rules, and state tank record requirements.
5. Who can transport and receive the wastes I ship off site?
Tennessee generally follows the federal rules for shipping hazardous wastes to a TSDHazardous waste transporters must obtain a valid transporter permit from TDEC, and an installation ID number and pay a $100 fee. This must be renewed annually. They must comply with the state's reporting and notification requirements.
6. What records do I have to keep?
Tennessee generally follows the federal rules for recordkeeping.Annual reports must be kept on file for at least three years.
7. Do I have to file reports?
Tennessee generally follows the federal rules for reporting. LQGs must send their federal biennial report to the U.S. EPA by March 1 of every even-numbered year. SQG's and LQGs must submit annual reports to the TDEC. CESQG's, if they generate more than 100 kg of hazardous waste in any one-month period, are required to file an annual report. Otherwise, they are exempt from reporting requirements.
8. What training requirements do I have to meet?
Tennessee generally 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 Tennessee these differences include:
Additional Wastes: None.
LQGs are required to submit an exception report to TDEC if the generator has not received a copy of the manifest signed by the TSDF owner or operator within five days after the 45-day period expires.
Other Notes, Comments:: None.
10. What are some other differences between federal and state
LQGs and SQG's must prepare hazardous waste reduction plans and provide an annual report on the progress of their efforts to minimize waste.Generators must pay fees with the annual reports, based on the prior year's waste generated. SQG's pay a fee of $550, and LQG' pay a fee of $900.Generators must pay annual fees for the state's Hazardous Waste Remedial Action Fund based on the amount of waste generated.Generators must pay fees of $14 per ton of hazardous waste, and $7 per ton for hazardous wastewater. This is for hazardous waste shipped off-site for treatment or disposal in the prior calendar year. The maximum annual off-site shipping fee for a single generator is $50,000.
- Mike Apple, Director, Solid and Hazardous Waste Program, (615) 532-0780