Ask the Expert, Hazardous Waste Operations

Ask the Expert: EPA ID Numbers at Different Locations

In our latest installment of Ask the Expert, brought to you by the team of industry experts at EHS Hero®, we look at a recent question from a subscriber asking about using EPA ID numbers at different lease locations. See what the experts had to say.

Q: We have a U.S. EPA ID number assigned to our location and we lease part of a building at a separate location at a different address. If we generate hazardous waste at the lease location, can we use our EPA ID number or must we apply for another one?

You would have to apply for another U.S. EPA identification number (EPA ID number) for the lease location because EPA ID numbers are issued by generator site (i.e., location), and not by generator name. It appears that your company has two, not one, generator sites.

The following EPA definition found at 40 CFR 260.10 is key to this question as to whether your site with the EPA ID number and the leased site may operate under the same EPA ID number:

Individual generation site means the contiguous site at or on which one or more hazardous wastes are generated. An individual generation site, such as a large manufacturing plant, may have one or more sources of hazardous waste but is considered a single or individual generation site if the site or property is contiguous.

If your two properties were geographically “contiguous,” you would be able to use your EPA ID number for both. However, the description of them as presented in your question suggests that they are not. Consequently, each “non-contiguous” generation site would require its own EPA ID number. Because EPA has noted in the past that “the state is the appropriate authority for making this determination,” you may want to describe your scenario to your state’s environmental agency to confirm our conclusion.

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