Skip to main content

Notification of hazardous waste activities

Certain types of activities related to hazardous waste require prior notification to the Wisconsin Department of Natural Resources.

EPA Form 8700-12

Regulated waste activities and EPA identification numbers

Businesses and facilities that generate or transport hazardous waste, or that own or operate a facility for the collection, treatment, storage or disposal of hazardous waste, are required to notify the DNR. Regulated waste activities include:

  • hazardous waste generation, recycling, or treatment, storage and disposal;
  • transportation of hazardous waste;
  • universal waste handling and/or destination facilities;
  • used oil transporting, processing/re-refining, burner and marketer activities;
  • academic lab hazardous waste management; and
  • household and very small quantity generator collection facilities (permanent).

A small or large quantity generator may not treat, store, dispose of, transport or offer for transportation hazardous waste until it has received an EPA identification number from the Wisconsin DNR, another authorized state or the U.S. Environmental Protection Agency. Very small quantity generators that choose to manifest their hazardous wastes must also obtain an EPA ID number.

EPA’s 8700-12 Form is used to notify the DNR of waste activities and obtain an EPA ID number under s. NR 662.012, Wis. Adm. Code. There are two ways to prepare and submit the form: EPA’s MyRCRAid online application or a fillable form. 

MyRCRAid online application

This option allows facilities to prepare and submit initial and subsequent notification forms electronically and requires a registration process that uses an electronic signature. Once the registration is complete, approval as a Wisconsin user is typically granted within one to three business days by receipt of a confirmation email. Once you have received this confirmation, the MyRCRAid application can be used to prepare and submit the 8700-12 form.

Fillable form option

The RCRA Subtitle C reporting instructions and forms contains the fillable 8700-12 form at the end of the document. Please note that none of the addendums to the form are available for use in Wisconsin as they are associated with rules that are not currently promulgated in the state. Once the form is completed, print, sign and mail or email to your DNR regional environmental program associate.

Episodic events

Episodic events

When very small quantity generators and small quantity generators notify and comply with specific requirements during an episodic hazardous waste generation event, they can maintain their existing generator category. An episodic event can occur only once per calendar year. Both planned and unplanned events requires notification to the DNR, which includes a description of the event and the hazardous wastes.

It is important to conduct the waste determination(s) prior to submitting a notification, to confirm the waste being generated is a hazardous waste.

Initial notification and EPA ID requirements

The facility must have or obtain an EPA ID number, and notify the DNR of the episodic event using EPA Form 8700-12, including the Episodic Generator Addendum. Notification requirements are also based on the type of event. Instructions for completing EPA Form 8700-12 are available on the first tab.

Facilities must notify the DNR of planned episodic events no later than 30 calendar days prior to initiating the planned event.

Facilities must notify the DNR of unplanned episodic events within 72 hours of the unplanned event. Initial notification may be via phone or email to meet the reporting timeframe with subsequent submittal of EPA Form 8700-12 to satisfy requirements.

When filling out EPA Form 8700-12, the facility notification for both planned and unplanned episodic events must include all the following information:

  • Start date and end date of the episodic event.
  • Reason(s) for the event.
  • Types and estimated quantities of hazardous waste expected to be generated from the episodic event.
  • Facility contact and emergency coordinator, with 24-hour telephone access for the duration of the event, to discuss the notification submittal or to respond to an emergency per s. NR 662.16(2)(i)1, Wis. Adm. Code.

If the exact day the event will end is unknown at the time of notification, the generator can notify using an end date that is 60 calendar days from the start of the event.

Waste management requirements

A facility must comply with the waste accumulation, on-site treatment, manifesting, shipping, disposal and recordkeeping requirements to maintain their existing generator category. Detailed information on episodic generation requirements can be found in DNR publication Episodic Generation of Hazardous Waste (WA-1872)

Filing a second event petition

A facility can petition the DNR for a second episodic event in a calendar year. However, the second event must be unplanned if the first event was planned, and vice versa. Second event petition requirements are also based on the type of event.

To file a petition, complete and submit the Additional Episodic Event Petition (Form 4430-031).

Warning: Due to the fillable nature of these PDF forms, many current browsers will not open them properly.

  1. From a desktop or laptop computer, download the PDF form (right-click on the link, then select "Save link as" or "Save target as")
  2. Make a note of the file location and file name so you can access the file from your device.
  3. Do not double-click the file. Open the Adobe Reader software then select "File > Open" then browse to the PDF file you saved on your device. See PDF Help for additional information.

Failure to submit a petition for a second event, timely notification of an unplanned event and/or failure to gain approval prior to a planned event will result in the generator being regulated in the higher generator category according to total hazardous waste generation amounts.

HHW and VSQG collection

Collection of household and very small quantity generator hazardous waste

In Wisconsin, the collection of household-generated hazardous waste and very small quantity generator waste (VSQG) is regulated under ch. NR 666, subch. HH, Wis. Adm Code, and applies to both temporary and permanent collection locations or events.

“Permanent collection facility" means a collection facility where household hazardous waste, VSQG waste, or both, is collected or stored for more than five consecutive days.

“Temporary collection facility" means a collection facility where household hazardous waste, VSQG waste, or both, is collected or stored for no more than five consecutive days.

For more information, including a definition of VSQG, see the Definitions page.

Both temporary and permanent collection facilities must notify the DNR of their operations 30 days prior to the collection of household hazardous waste and VSQG hazardous waste. Permanent facilities need only notify once. The DNR recommends temporary sites notify annually.

Prior to notification, permanent collection facilities must apply for an EPA ID number using the U.S. EPA form #8700-12.  For instructions on how to obtain an EPA ID number, refer to the EPA ID numbers tab

Warning: Due to the fillable nature of these PDF forms, many current browsers will not open them properly.

  1. From a desktop or laptop computer, download the PDF form (right-click on the link, then select "Save link as" or "Save target as")
  2. Make a note of the file location and file name so you can access the file from your device.
  3. Do not double-click the file. Open the Adobe Reader software then select "File > Open" then browse to the PDF file you saved on your device. See PDF Help for additional information.

Collection notification forms require information about:

  • facility operator,
  • collection location,
  • design and operational standards, and
  • waste types accepted.

Collection facilities can choose which types of hazardous and nonhazardous wastes to accept. The DNR recommends collection facilities provide information on accepted wastes to their community before and during the collection hours or event.

Permanent collection facilities must also identify:

  • waste management practices,
  • provide a site plan and layout, and
  • closure and financial responsibility requirements. 

If the collection facility is accepting VSQG wastes, a copy of the receipt to be issued to the businesses must be submitted with the notification. The receipt must require the following:

  • VSQG company name,
  • street address, city and state,
  • waste type(s) and quantity, and
  • waste acceptance date. 

HW accumulation time extension

Hazardous waste accumulation time extension

Wisconsin's hazardous waste regulations allow both large and small quantity generators to request an accumulation time extension in the event of unforeseen, temporary or uncontrollable circumstances that prevent shipment of hazardous waste within the 90-day timeframe for LQGs or the 180-day timeframe for SQGs. An extension of up to 30 days may be granted at the discretion of the DNR on a case-by-case basis pursuant to s. NR 662.034(3) and NR 662.192(3), Wis. Adm. Code.

A request for an extension must be made prior to the expiration of the required time limit. Potential reasons for requesting an extension must be identified to submit a request (i.e., transporter unable to meet schedule shipping date, or scheduled facility unable to accept wastes due to facility backlog or closure). To request an extension, follow the link below to submit your information to the DNR electronically. You can also contact a regional hazardous waste specialist, or Hazardous Waste Program Coordinator Mike Ellenbecker, to submit a request directly to program staff.

If a 30-day extension request is granted but the hazardous waste shipment the extension was requested for cannot occur within the extended period, contact Hazardous Waste Program Coordinator Mike Ellenbecker to discuss the regulatory requirements.