Comparison of State and Federal Hazardous Waste Rules
General Summary (find a description of Federal Rules here).
Virginia 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
2. How do I determine my generator status?
Virginia generally follows the federal rules for defining generator status. All persons involved in hazardous waste management activities must notify DEQ of their hazardous waste activities. The DEQ must be notified and told of the accumulation area's exact location prior to a generator beginning to accumulate hazardous waste.Generators may not send their hazardous waste to a TSDF that does have a permit and an EPA identification number.Virginia has incorporated the federal contingency plan rules for LQGs and added additional requirements for notification and the follow-up report. CESQG's can have their hazardous waste managed at certain solid waste facilities, but only unless the management is in full compliance with the state solid waste management regulations.
3. How can I tell if the waste materials I handle are considered
Virginia follows the federal rules for defining hazardous wastes.One additional state requirement concerns the substitution of state addresses for federal addresses.
4. How long can I store hazardous wastes on site?
Virginia follows the federal rules for storing hazardous wastes.Generators must notify DEQ before beginning to accumulate hazardous waste Permitted storage facilities must meet additional state permit application requirements, permit conditions, and pay fees.
5. Who can transport and receive the wastes I ship off site?
Virginia follows the federal rules for shipping hazardous wastes to a TSD.In addition, anyone who transports hazardous wastes that start or end in Virginia must have a permit and pay fees. Hazardous waste transporters must submit annual reports to DEQ for manifest shipments. There are also additional requirements for transporters if there is a hazardous waste discharge/spill.
6. What records do I have to keep?
Virginia follows the federal rules for recordkeeping.
7. Do I have to file reports?
Virginia follows the federal rules for reporting.
8. What training requirements do I have to meet?
Virginia follows the federal rules for training.State certification programs may contain more requirements that the federal rules.
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 Virginia these differences include:
Additional Wastes: None.
Other Notes, Comments::
Generators cannot offer hazardous waste to a transporter or a TSDF that has not received a permit and an EPA ID number.
10. What are some other differences between federal and state