EPA ID Number Requirements

Federal regulations require all businesses with the status of Large Quantity Generator (LQG) and Small Quantity Generator (SQG) of hazardous waste to obtain an EPA identification number. Very Small Quantity Generators (VSQG, formally CESQG) of hazardous waste are not required by EPA or DEQ to obtain an EPA ID number or submit a notification form. 

Obtain an EPA Identification Number

Generators that require a new EPA ID and Generators with existing EPA ID's are required to submit an EPA 8700-12 notification form.  EPA ID numbers correspond with the facility's address, therefore if your business is new to an address, there may be an EPA ID assigned to the location. To find out if your location has been assigned an EPA ID in the past, you can search with EPA's web-based tool "ECHO" (instructions and tutorial are available on the website.)  If there is an existing EPA ID, businesses are required to submit an EPA 8700-12 form to notify any changes in waste streams, generator status, or contact information. LQGs are required to re-notify DEQ by March 1 of every even numbered year. This can be done as part of the Biennial Report. SQGs must re-notify DEQ every four years with the first re-notification due by September 1, 2021.

Submitting 8700-12 Form

EPA has implemented a mechanism that allow facilities to electronically submit 8700-12 notifications called "MyRCRAid". This online option is available for sites in Virginia, and DEQ encourages online submission. It eliminates paper forms and paper acknowledgement letters, and reduces processing time. DEQ offers a document to assist business with registration and completing a subsequent EPA 8700-12 form with MyRCRAid called "Quick Instructions for MyRCRAid".

The RCRA Subtitle C Site Identification 8700-12 Form and Instructions are available on EPA's website. The PDF form can be completed for new ID as well as subsequent notifications. DEQ has also created a document to assist in completing this form called "Quick Instructions for Completing the EPA 8700-12 Form".

Mailing and Contact Information
The RCRA Subtitle C Site Identification 8700-12 form not completed as a subsequent notification through MyRCRAid, can either be submitted to DEQ by postal or electronic mail. Please include the completed and signed 8700-12 form as an email attachment or print to submit by postal mailing.

Attn: Kim Hughes
Land Division
Virginia Department of Environmental Quality
Electronic Delivery:
kimberlyn.hughes@deq.virginia.gov
Postal Delivery:
PO Box 1105
Richmond, VA 23218
FedEx Delivery:
1111 E. Main St., Suite 1400
Richmond, VA 23219

For further assistance or questions please contact Kim Hughes, RCRA Data Administrator, at 804-698-4201 or by email.

Provisional EPA Identification Number

A provisional generator is any site currently generating hazardous waste only as the result of a one-time, non-recurring, temporary event that is not related to normal production processes. In other words, it’s a short-term generator that produces hazardous waste from a particular activity for a limited time and then ceases conducting that activity. Provisional generators are subject to the same regulations as permanent generators based in the amounts generated during the temporary event.  Generators obtaining provisional EPA ID numbers are also required to submit a EPA 8700-12 form. This does not establish a permanent EPA ID number but is required as part of our provisional number protocol. 

Notifications submitted in support of a provisional number must be sent directly to DEQ Regional Office issuing the number. Provisional ID numbers are used to track hazardous wastes generated at sites that do not have a permanent EPA ID number and that do not ordinarily generate any hazardous waste. Provisional EPA identification numbers expire thirty (30) days from the date of issue and may be used up to two times (two separate transportation events) within that 30 day period (for the same waste generation operation). The recipient of a provisional EPA identification number can request one 30-day extension to the initial 30-day expiration period. There may be certain situations where a provisional number can be issued for a project that may last for a longer period (e.g., a bridge repainting operation, or short term lead paint abatement project). Such determination must be made on a case-by-case basis. However, provisional EPA ID numbers will not be issued for any project that lasts longer than 90 days. DEQ will request that a generator obtain a permanent EPA identification number for projects lasting longer than 90 days.

The following describes some possible scenarios where a provisional number may be used more than once:
A handler has filed the 8700-12 form for a permanent number but the number has not yet been issued.
When hazardous waste has been discovered on the same property and shipments must be made separately to different TSD facilities or on different days, or if subsequent discovery occurs at some interval shortly after the first discovery.
When there is a short-term remediation project extending over a 30-day period that may involve more than one shipment, which takes place at the same location.

DEQ has created a document to provide more detailed information regarding the Issuance of Provisional EPA ID.

Notification for Episodic Waste Generation

VSQGs and SQGs may operate under streamlined requirements if they have a temporary change in their generator category because of an episodic event provided certain requirements are met.  One requirement for both planned and unplanned events, is the submittal of the 8700-12 form.  One episodic generation event is allowed per year with the opportunity to petition for a second event. More information can be found on our website regarding Episodic Generation .
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Virginia Department of
Environmental Quality
P.O. Box 1105
Richmond, VA 23218
(804) 698-4000


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