Are you a large quantity generator (LQG) of hazardous waste? If so, you and hazardous waste treatment, storage, and disposal facilities (TSDFs), and, for the first year, certain recyclers are required to submit Hazardous Waste Reports (aka, biennial reports) by March 1, 2018. Because of a number of changes to the federal hazardous waste regulations, you may be required to submit a biennial report where you were not previously required to do so. Or, with the clarifications in the amended regulations, you may suddenly realize that you have been required to report for years!
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Biennial reports must be submitted to your state or the EPA by March 1 in even numbered years for hazardous waste activities in the previous year. The reports detail the types and quantities of hazardous waste shipped off-site and the efforts a facility takes to reduce the volume and toxicity of generated wastes.
Note: Some states require annual reports or have developed their own biennial report forms that require additional information, so be sure to check state requirements. In addition, some states require other categories of generators to report as well. However, even if your state has yet to adopt the new federal hazardous waste regulations, the Biennial Report forms as revised by the EPA in 2017 are the forms that must be submitted by those facilities that the EPA requires to file a Biennial Report.
Who Must File a Biennial Report?
You are required to submit a Hazardous Waste Report or your state’s equivalent hazardous waste report by March 1, 2018, if you:
- Meet the waste quantity criteria of a LQG in any calendar month in 2017; and you shipped any hazardous waste off-site to a TSDF within the United States or treated, stored, or disposed of hazardous waste on-site.
- Are a permitted or interim-status TSDF in 2017.
- Are a recycling facility that received regulated hazardous waste from off-site in 2017 and/or did not store incoming hazardous waste before recycling (i.e., the facility does not have a hazardous waste storage permit).
If you are not required to report for 2017, you should notify the EPA if your hazardous waste generator status has changed. To do that, fill out the RCRA Subtitle C Site Identification Form (Site ID Form), and submit it to your state regulatory agency.
Getting Ready to File
Thorough recordkeeping practices are always your friend when it comes to environmental reporting. For the biennial report, you will be required to report on quantities and types of hazardous waste that your facility generated, managed, shipped, or received. Handy records to have at your fingertips include:
- Hazardous waste manifest forms;
- Hazardous Waste Report forms submitted in previous years;
- Records of quantities of hazardous waste generated or accumulated on‐site;
- Results of laboratory analyses of your waste;
- Contracts or agreements with off‐site facilities managing your wastes; and
- Copies of permits for on‐site waste management systems.
Where to Find the 2017 Required Information
The new biennial report forms contain the information that is required of facilities. This information was deleted from the amended hazardous waste regulations because over the years the EPA has updated the data elements on the forms without modifying the regulations. Now the regulations refer you to the form.
How to Submit Your Biennial Report
The EPA encourages electronic submission of your biennial report. Contact your state agency or regional EPA office for information about filing your biennial report electronically.