Preparing RCRA LQG 2019 Biennial Reports – We’re Here if You Need Us

Federal regulations require all RCRA hazardous waste Large Quantity Generators (LQGs) to submit a report, every 2 years, summarizing the waste they generated and where it went. This “Biennial Report” is due by March 1 of each even-numbered year, and it covers hazardous waste generated the previous year (2019, this go-round). You may ask, “How do I know whether this applies to me?” Simple:

• You are a RCRA LQG if your site generates in any month more than 1,000 kilograms of hazardous waste, more than 1 kg of acutely hazardous (P-list) waste or more than 100 kg of acute hazardous waste spill debris or residue.
• Only RCRA hazardous waste counts towards this total, not non-RCRA waste (for California generators), universal waste or medical waste.

The Biennial Report includes the EPA Site Identification (Site ID) form for your site plus one “waste generation and management” (GM) form for each RCRA waste generated, with certain exclusions and exceptions. More information on the forms and reporting requirements can be found at https://www.epa.gov/sites/production/files/2019-11/documents/excerpt_biennial_report_rcra_subtitlec_forms_and_instructions_september_2019.pdf. For California generators, Biennial Reports must be submitted through the EPA RCRAInfo system (https://rcrainfo.epa.gov/rcrainfoprod/action/secured/login). Other states may have different requirements for submittal. Whatever your state, reports for 2019 activities are due by March 1, 2020, so it’s high time to start preparing and gathering your hazardous waste information! If you have any questions or, better yet, would like assistance preparing your 2019 Biennial Report, please reach out to your ACTenviro account manager. If you don’t already have an account manager, email us at [email protected] and we will route you to the appropriate person. – James Kapin, head of the ACTenviro EMS team