The EPA’s March 1 Biennial Reporting deadline is coming up faster than one might realize, which means Large Quantity Generators (LQGs) of hazardous waste should start preparing for what they will need to complete the report. The Biennial Report, more formally known as the National Biennial RCRA Hazardous Waste Report, is a requirement under Section 3002(a)(6) of the Resource Conservation and Recovery Act (RCRA) and must be submitted by March 1 of every even-numbered year.
Who must report?
Reporting is required for hazardous waste generators that are registered under the LQG generator status – meaning they are allowed to generate greater than 2,200 lbs (1,000 kg) of general hazardous waste, or 2.2 lbs (1 kg) of acutely hazardous waste per month. One caveat to this rule targets Small Quantity Generators (SQGs) and Very Small Quantity Generators (VSQGs) that generated hazardous waste at LQG levels during at least one month throughout the reporting period. If facility personnel are unsure of the generator status of the facility in which they operate, the EPA’s Enforcement and Compliance History Online (ECHO) service is helpful in determining such information.
What information is reported?
There are four primary pieces of information that the EPA obtains from the Biennial Report, which seeks information for the calendar year before the year in which the report is due (i.e. the report that is due March 1, 2020, will include information from 2019). The first of these being the type of hazardous waste that was generated; these are reported using Waste Codes. Each hazardous waste stream has a code or series of codes that define exactly the type of waste it is. Hazardous waste streams include those that fall into one of the four characteristic hazardous waste categories (“D” Waste Codes): ignitable, corrosive, reactive, and toxic. Additionally, any F, K, P, or U listed waste stream is considered hazardous and must be included in the Biennial Report. If you are unsure about a specific waste stream and whether or not it is considered hazardous, the EPA’s Hazardous Waste Characterization web page may be helpful.
Secondly, the EPA wants to know the amount of waste generated at each site. The EPA publishes generation totals by weight for many different criteria, including the type of wastes and their amounts generated nationally and at each individual facility. It is imperative that the generation amounts reported on the individual site level are accurate and reported in pounds. Often, shipping totals from waste manifests are noted in units other than pounds, therefore, conversions must be used when completing the Biennial Report in these cases.
The EPA uses a set of four-digit “form codes” used to identify the physical form of the waste media. There are 49 form codes, covering the majority of hazardous waste generated in the United States. Popular form codes for general industrial hazardous wastes are:
- W103, Inorganic Liquids – Spent concentrated acids
- W203, Organic Liquids – Concentrated non-halogenated solvent
- W206, Organic Liquids – Waste oil
- W209, Organic Liquids – Paint, ink, lacquer, or varnish
- W211, Organic Liquids – Paint thinner or petroleum distillates
- W406, Organic Solids – Dried paint (paint chips, filters, air filters, other)
- W505, Inorganic Sludges – Metal bearing sludges not containing cyanides
The full list of form codes may be found on the EPA’s list of Nationally Defined Values for Waste Form Code.
Lastly, the Biennial Report provides the source of the wastes generated. “Source codes” are used to determine the process or origin of the waste streams. Source codes contain three digits and follow the form “G” followed by a two-digit number. Similar to the form codes, there are 49 source codes that pertain to the major potential origins of hazardous wastes generated. A few common examples include:
- G01, Wastes from Ongoing Production and Service Processes – Dip, flush or spray rinsing
- G03, Wastes from Ongoing Production and Service Processes – Plating and phosphating
- G06, Wastes from Ongoing Production and Service Processes – Painting and coating
- G11, Wastes from Other Intermittent Events or Processes – Discarding off-specification or out-of-date chemicals or products
- G14, Wastes from Other Intermittent Events or Processes – Removal of tank sludge, sediments or slag
- G32, Wastes from Spills and Accidental Releases – Cleanup of spill residues
The full list of source codes is located on the EPA’s list of Nationally Defined Values for Waste Description Source Code.
The information contained in these four sections of the report is essential in ensuring that the national waste data is published correctly. Therefore, it is important to ensure each facility’s report is accurate and compliant with the requirements outlined in the regulation.
How does a facility report?
All states are not created equal – at least not when it comes to how they accept the Biennial Report submittals. For the vast majority of states, the Biennial Report is submitted via the EPA’s RCRAInfo reporting website. To complete the report using RCRAInfo, one must create an account and register with certifying authority for their specific site. Once registered, RCRAInfo allows for the completion of the report, as well as some other helpful features like e-manifesting. It is essential to not wait until the last minute to sign up for RCRAInfo to avoid potential issues with the system which could lead to a late report submittal.
Unfortunately, several states do not accept Biennial Report Submittals through the RCRAInfo system. A few notable states that do not use RCRAInfo include but are not limited to Illinois, Texas, and Wisconsin, which all use their own state-specific reporting software, and North Dakota, which requires paper copy submittals of the Federal 8700-12, 8700-13 A/B form. More and more states tend to be moving toward allowing RCRAInfo submittals so it is important to check with your state requirements before the March 1 deadline.
Remember, if a facility generates hazardous waste at Large Quantity Generator (LQG) levels, it is a Federal requirement to submit a Biennial Report by March 1 of 2020. Make sure that you have all that you need to get it completed accurately and on time to ensure maximum compliance.