Are two structures in one complex owned by a single owner considered separate generators under RCRA?

Are two structures in one complex owned by a single owner considered separate generators under RCRA? This is an office building and a factory. The office building generates one kilogram of hazardous waste and the factory generates 1000 kilograms of hazardous waste.

For the purposes of generator notification and obtaining EPA identification numbers, one identification number is sufficient for the two structures. Note, the wastes generated by the office building would be subject to the requirements for large quantity generators of hazardous wastes. And a manifest would have to be completed if waste must be shipped on roads or other right-of-ways to which the public has access.

If the two structures were owned by different people, then under federal regulations one identification number would be needed for each structure even if the regulated activity is taking place on a contiguous piece of property. However, check with your state for specific guidance on the issuance of identification numbers.