It’s time to start thinking about Biennial Reports again! Hazardous waste large quantity generators (LQGs) and Treatment Storage Disposal Facilities (TSDFs) are required to report their hazardous waste activities that occur during the 2015 calendar year. The report should compile information on the type, source, form, quantities and management of hazardous wastes generated and is due on March 1, 2016! The EPA requires that this information be submitted at least every two years; however, some states require it annually. The EPA uses Biennial Report data for planning and developing regulations, compliance monitoring and enforcement.
Here’s what you need to know:
How Can I Prepare?
- Ensure you have a waste minimization strategy in an attempt to remain below the reporting thresholds!
- Ensure you are tracking your waste generation and off-site disposal. Maintaining records throughout the year pays off big dividends when the Biennial (Annual in some states) Hazardous Waste Report is due!
Who Needs to Report?
Your facility needs to report if it meets any of the following criteria:
- The site generated, in any single calendar month, 1,000 kg (2,200 lbs) or more of RCRA hazardous waste; or
- The site generated, in any single calendar month, or accumulated at any time, more than 1 kg (2.2 lbs) of RCRA acute hazardous waste; or
- The site generated, in any single calendar month, or accumulated at any time, more than 100 kg (220 lbs) of spill cleanup material contaminated with RCRA acute hazardous waste.
Remember that a one-time clean-up, spill or malfunction of equipment can result in the generation of more than 2,200 pounds of hazardous waste, or more than 2.2 pounds of acutely hazardous waste, in a calendar month; the current registered generator status of a facility is not the determining factor!
What’s it all for?
Every other year, EPA prepares a Biennial Report for the whole country. Check out the 2013 National Biennial Report. Sometimes it is nice to see the end result of your hard work!
If you don’t want to find yourself sitting at a desk with the report form and instructions and a stack of the previous year’s Uniform Hazardous Waste Manifests on February 29th, let us help! We have experience completing biennial reports for many of our clients. Contact one of our consultants for more information.