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Transporting Hazardous and PCB Waste

Hazardous waste is a subset of solid waste with stricter requirements to protect human health and the environment. Federal and state laws regulate how businesses, institutions, governments and other non-households must manage hazardous waste.

A hazardous waste transporter is anyone who hauls manifested hazardous waste off-site by air, rail, highway or water. Hazardous waste transportation requirements can be found in ch. NR 663, Wis. Adm. Code.

Do I Need a License?

Do I Need a Hazardous/PCB Waste Transportation License?

You need a license for transporting hazardous waste if you:

  • Haul hazardous waste within or through Wisconsin that was generated by small or large quantity generators; or
  • haul hazardous waste collected at a household hazardous waste collection facility or event to a treatment, storage, disposal or recycling facility.

You do not need a license if you:

  • Are a very small quantity generator transporting your own hazardous waste; 
  • are transporting household hazardous waste from your own household;
  • transport only household hazardous waste collected directly from the household and delivered directly to a treatment, storage, or disposal facility or a recycling facility;
  • transport only very small quantity generator waste directly from the generator to a treatment, storage, or disposal facility or a recycling facility; or
  • haul hazardous wastes collected at a household hazardous waste collection facility or event to a permanent household hazardous waste collection facility. 

Within Wisconsin, each regional or terminal location where transport vehicles are based must be licensed as a separate transportation service. 

Businesses that base their vehicles out-of-state must have a license for the fleet that enters Wisconsin.

Do you haul PCBs?

Haulers that transport waste containing polychlorinated biphenyls, including used oil that contains PCBs, require a hazardous waste/PCB transporter license. Proof of liability insurance, a minimum of $300,000, must also be included with your license application. Refer to ch. NR 157, Wis. Adm. Code, Management of PCBs and Products Containing PCBs.

A generator may transport its own PCBs or products containing PCBs in self-owned and operated vehicles. A transporter license is not required under ss. NR 157.03(2)(b) and NR 157.04(1), Wis Adm. Code.

Applying for a License

Applying for a hazardous waste and/or PCB transporter license

Once you have determined you need a hazardous waste transportation license, you will need to fill out an application.

Each location at which a business bases vehicles (i.e., stores or parks overnight most of the time) within Wisconsin must be licensed as a separate location. If you store or park vehicles at more than one location or are based outside Wisconsin, contact your Department of Natural Resources regional environmental program associate to determine if you need more than one license.

Preparing to apply

Before filling out a license application, have the following information ready:

  • Name of transporter (usually the company or business name)
  • Name of licensee (can be an individual at the company or the company itself)
  • Name of owner
  • Ownership type (private, state, county, local or federal)
  • Contact information for primary contact
  • Address where vehicles will be kept
  • Number of vehicles in fleet
  • Types of hazardous waste being transported are categorized by waste codes. Find a list of waste codes here: Codes and descriptions for hazardous wastes subject to Resource Conservation and Recovery Act Subtitle C regulation. On the application, list all the waste types you expect to haul on a regular basis.
  • Name and EPA ID of the facilities where you will be taking the hazardous waste.

Licensed haulers of hazardous waste/PCB waste must have an EPA ID number. To obtain a federal EPA ID number, refer to Instructions and Form to Obtain an EPA Identification Number (EPA Form 8700-12/Site Identification Form). Refer to Notification of Hazardous Waste Activities for more instructions.

Fill out the Social Security Number/FEIN Collection Request (Form 9400-568). State statute requires the DNR to obtain each applicant’s social security number or, if the applicant is not an individual, the applicant’s federal employer identification number, before issuing or renewing a license.

NOTE: PCB Haulers must provide proof of $300,000 liability insurance. Refer to ch. NR 157, Management of PCBs and Products Containing PCBs.

Having this information before attempting to fill out the application will save time and reduce confusion while filling out the application. If you have any questions about hazardous waste transportation, contact your regional DNR environmental program associate.

License fees

The annual fee for a hazardous waste transportation license is $400. Make checks payable to Wisconsin Department of Natural Resources.

Submitting your application

To apply for a hazardous waste/PCB waste transporter license, submit the following to your DNR environmental program associate.

Operating Standards

Owners and operators must do all of the following:

  • Obtain an EPA ID number for each separate location where vehicles are based, including 10-day transfer facilities.
  • Obtain a DNR hazardous waste transportation license.
  • Not harm surface water, groundwater quality or wetlands. Review s. NR 502.04, Wis. Adm. Code, for more details.
  • Be prepared to take immediate action in response to a hazardous waste discharge to protect human health and the environment. Report hazardous waste spills or discharges following the steps in the box below. 

Reporting spills

If a discharge of a hazardous waste occurs during transportation:

  1. Call the Wisconsin 24-hour number emergency spill hotline: 1-800-943-0003.
  2. Call and report the discharge to the National Response Center at 1-800-424-8802 (toll-free) or 202-267-2675. Notify as soon as practical but no later than 12 hours after the occurrence.
  3. Report the hazardous material incident in writing through the U.S. Department of Transportation Incident Reporting website. This is a U.S. DOT requirement. 

For more resources, review the DNR Spills page.

MANIFESTING WASTE

  • You may either use the transporter EPA ID associated with the transportation location or a corporate EPA ID on manifests.
  • Register for a RCRAinfo account to access the e-Manifest System.
  • Use the uniform hazardous waste manifests for all hazardous waste subject to manifesting. Ensure the manifests are:
    • signed by the generator (wet or electronic signature);
    • signed and dated by the transporter at the time the waste is accepted from the generator;
    • with the waste shipment during transit;
    • signed and dated by all intermediary transporters; and
    • signed and dated by the facility that receives the waste.

For more information, refer to the Hazardous Waste Manifest Requirements page.

TRANSPORTING WASTE

  • Before transporting waste, either the generator or the transporter (on the generator’s behalf) must package the waste according to U.S. DOT regulations for packaging under 49 CFR parts 173, 178 and 179.
  • Hazardous waste must be labeled, marked and placarded according to U.S. DOT regulations under 49 CFR part 172.
  • Secure waste containers to prevent movement, shifting, damage or potential spills.
  • If the waste cannot be delivered to the TSD/receiving facility, an alternate facility or another transporter indicated on the manifest, contact the generator for further direction. You then must revise the manifest, obtain a second manifest or return the waste to the generator.
  • Transport by rail or water may have different requirements. Contact the DNR hazardous waste specialist assigned to your county.

ADDITIONAL REQUIREMENTS FOR LICENSED PCB FULL-SERVICE CONTRACTORS

  • Have a minimum of $300,000 in liability insurance that covers damage resulting from a spill of PCBs or product containing PCBs, or damage at a disposal facility that is not approved to accept PCBs 
  • Visit Notifications for Polychlorinated Biphenyl (PCB) Activities for more information on notifying the U.S. Environmental Protection Agency of PCB activities. 
  • Contract with a facility that meets the requirements of ss. NR 157.06 and 157.07, Wis. Adm. Code, to accept PCBs or products containing PCBs. 
  • If the waste is rejected by the service or disposal facility, immediately make arrangements to deliver the waste to another facility. You may store the rejected shipment for up to 60 days unless you receive an extension from the DNR because a facility for disposal is not available. 
  • Handle and store the waste in a way that prevents any release to the environment.
  • Transport PCBs in sturdy, secured containers that will not spill or leak. Containers used for transporting or storing PCBs must not be used for any other materials. 
  • Ensure that generators and service/disposal facilities use a manifest to track waste transport. Retain copies of these forms.

If a spill of PCBs occurs:

  • Carry a supply of absorbents and equipment to contain and pick up any spills that occur during transport.
  • Repackage the PCBs and continue transporting them to the service or disposal facility. Document the amount and location of the spilled waste on the waste tracking form.
  • Promptly notify the Wisconsin Division of Emergency Management at 608-242-3000. 

Renewing and Revising

RENEWING OR REVISING YOUR LICENSE

Hazardous waste and hazardous waste - PCB transportation licenses are annual licenses that must be renewed each year. The license period begins Oct. 1 and expires Sept. 30. To remain licensed, submit a renewal form and license fees.

The DNR uses email to start the renewal process, so it is important to keep your contact information up to date to make sure you get the information you need. If at any point you need to update your contact information or designate a new contact, contact your regional DNR environmental program associate.

LICENSE RENEWAL PROCESS

Step 1: In the weeks before your license expiration date, you will receive an email from DNRWALicenseRenewals@wisconsin.gov with a unique link to renew your license electronically. The DNR recommends adding this address to your address book to make sure you receive the email.

Step 2: Follow the link in the email. Complete and submit the renewal form.

Step 3: Your fee will be displayed at the bottom of your renewal form and is due at the time of renewal. After you submit the renewal form, you will be directed to the DNR’s E-Pay system. If you are unable to pay electronically, mail a check and a printed copy of your completed renewal form to your regional DNR environmental program associate

Step 4: You will receive a confirmation email, including a copy of your license, after the license renewal form and payment have been successfully received.

REVISING YOUR LICENSE

Occasionally, transporters may need to make a revision to their license outside of the renewal period. These changes can include adding or removing vehicles, updating hauling destinations, waste types handled, etc. If you need to make changes to your license, contact your regional DNR environmental program associate for assistance.