By Elizabeth Dickinson, J.D. BLR Legal Editor
Referred to by the U.S. Environmental Protection Agency (EPA) as the Hazardous Waste Report (EPA Form 8700-13 A/B), and by those in the environmental management field as the Biennial Report, the report must be submitted by March 1 of every even-numbered year with information of the facility’s hazardous waste activities during the previous odd-numbered calendar year. The Hazardous Waste Report consists of four reporting forms or sections: the Site ID Form, Form GM (Waste Generation and Management), Form WR (Waste Received from Off-Site), and Form OI (Off-Site Identification). A few states, but not EPA, require submission of Form OI.
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Who Has To Report?
TSDF owners or operators and LQGs must submit the 2011 Hazardous Waste Report by March 1, 2012. A facility is a TSDF if it treated, stored, or disposed of RCRA hazardous waste on-site during the reporting year (i.e., 2011). A generator is an LQG if the facility did any of the following in the reporting year:
- Generate, in any single calendar month, 1,000 kilograms (kg) (2,200 pounds (lb)) or more of hazardous waste.
- Generate, in any single calendar month, or accumulate at any time, more than 1 kg (2.2 lb) of acute hazardous waste.
- Generate, in any single calendar month, or accumulate at any time, more than 100 kg (220 lb) of spill cleanup material contaminated with RCRA acute hazardous waste.
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Changes from the 2009 Form
EPA made changes to the 2011 Hazardous Waste Report in connection with definitions, source codes, form codes, and instructions. Minor changes were also made to the Site ID Form and the Form GM.
Definitions.
- Definition of “Short-term Generator” is added and is applicable on the Site ID Form.
- Definitions added for “Waste Minimization” and “Waste Oil (Biennial Report Only)”.
Source Codes.
- The descriptions for source codes G11, G24, G25, and W206 are revised.
Form Codes.
- Form codes were added for “waste pharmaceuticals” (W005) and “dried paint” (W406).
Instructions. These instructions were revised or clarified:
- Instruction for Section 10.A.9 of the Site ID Form for underground injection control.
- Special instruction for “groundwater contaminated by hazardous waste.” Further instructions regarding contaminated media are added.
- Instruction on Form GM for on-site management now clarifies that filers should choose the management method code that best identifies the last substantive purpose/operation performed onsite.
- Instruction added for source code G61 in Section 1, Item D of Form GM.
Form GM. Changes specific to Form GM:
- An example of sequential process is added in Section 2 to complement the existing example of non-sequential process.
- This question in Section 2: “Was any of this hazardous waste that was generated at this facility treated, disposed and/or recycled on-site?” replaces a similar question.
Site ID Form. Changes specific to the Site ID Form:
- The note under Box 10.A.6 now reads: “Note: A hazardous waste Part B permit is required for these activities.”
- To help minimize confusion for reporting, the wording is revised in Box 10.D regarding academic labs as well as in the Addendum to the Site ID Form: Notification of Hazardous Secondary Material Activity.
Additional Resources on Hazardous Waste Reports
2011 Hazardous Waste Report Instructions and Form
Biennial Report Frequently Asked Questions
Management Method Codes Used With the Hazardous Waste Report
Where Can I Obtain Assistance for Data Forms?
Elizabeth M. Dickinson, J.D., is a Legal Editor for BLR’s environmental publications, focusing primarily on hazardous waste related topics. Ms. Dickinson has covered environmental developments since 1994. Before starting her career in publishing, she was a corporate and securities attorney at Cummings & Lockwood and at Aetna Life and Casualty, both in Hartford, Connecticut. She received a Bachelor of Arts degree, cum laude, in English and American Literature and Language from Harvard University and her Juris Doctorate, cum laude, from the University of Connecticut School of Law, where she was an Articles Editor of the Connecticut Law Review. Ms. Dickinson is licensed to practice law in Connecticut.