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How many ID Numbers do I need? ID Numbers are site-specific and there is normal- ly only one number at a business address. If you have a business that generates waste at multiple addresses that are not physically connected (con- tiguous), each address needs a separate ID Num- ber. In the case where generators are independent businesses that operate in suites within the same building, each business must have their own ID Number. If you are not clear as to whether you operate on one site or multiple sites, contact your local environmental agency or the DTSC information resources listed at the end of this fact sheet. Do I need a U.S. EPA ID Number, or a California ID Number? If you generate more than 1 kilogram of RCRA acutely hazardous waste per month or more than 100 kilograms of other RCRA waste per month, you must get a U.S. EPA ID Number. If you generate 100 kilograms or less of RCRA waste or one kilogram or less per month of acutely ha- zardous waste, and meet certain other require- ments, you are exempted by U.S. EPA from many of its regulations, including the require- ment to have an EPA ID Number. These busi- nesses are called "conditionally exempt small - quantity generators", or CESQGs. The regulato- ry citation is 40 CFR section 261.5 However, California regulations do not have an equivalent small quantity generator exemption. Almost all business generators of hazardous waste in California that are not required to have a U.S. EPA ID Number must, in practice, have a California ID Number. See California Code of Regulations title 22, section 66262.12. Howev- er: 1. Generators handling only hazardous waste produced incidental to owning and maintaining their own place of residence do not need an ID Number, either federal or state. 1 2. Businesses whose ONLY hazardous waste generation is 100 kilograms or less per month of waste that is hazardous solely because of its sil- ver content ("silver -only waste") do not need an ID Number. This is true even if they treat the waste in silver -recovery units and then send the silver for reclamation. See Health and Safety Code section 25143.13. Also see the DTSC Fact Sheet, "Onsite Tiered Permitting: Changes in Regulation of Silver Wastes." 3. Businesses that generate and manage less than 11,000 lbs (about 5 tons) of universal waste on- site at any one time may need to get a Federal EPA number. For information about obtaining a Federal EPA number, call (415) 495-8895. For information about Universal Waste, see DTSC's "Managing Universal Waste in California". In summary, except for the above-mentioned ex- emptions, if you generate only non-RCRA ha- zardous wastes, or you generate less than 100 kilograms of RCRA hazardous waste per month (or less than 1 kilogram of RCRA acutely ha- zardous waste), you must get a California ID Number. If you generate more than 100 kilo- grams of RCRA waste per month or more than 1 kilogram of RCRA acutely hazardous waste per month, then you must get a U.S. EPA ID Num- ber. I used to be exempt from ID Number requirements. What happened? The passage of Senate Bill 271 (effective January 1, 2002) removed the exemption that once al- lowed small generators of used oil and solvents to offer waste for transport without an EPA ID Number (former milkrun or modified manifest procedures.) The Consolidated Manifesting procedure that re- placed the milkrun manifesting procedure re- quires that generators using consolidated transporters provide theIt Sart r__ ERVIRONMENTAI HMA ITU