2011 RCRA Biennial Hazardous Waste Report

January 17, 2012

This blog was prepared as a reminder that your facility is required to complete and file the 2011 RCRA Hazardous Waste Report (also known as the “Biennial Report”) or your State’s equivalent hazardous waste report by March 1, 2012 if your facility met the definition of a RCRA Large Quantity Generator (LQG) during 2011; or if your facility treated, stored, or disposed of RCRA hazardous wastes on-site during 2011. Although the requirement for submitting the Biennial Reports has been in place for some time, we thought this blog could be helpful to new environmental managers/professionals or as a reminder to the busy environmental managers who face numerous reporting deadlines.

Your facility is a RCRA LQG for 2011 if your facility met any of the following criteria:

  • Your facility generated, in any single calendar month, 1,000 kg (2,200 lbs.) or more of RCRA non-acute hazardous waste; or
  • Your facility generated, in any single calendar month, or accumulated at any time, more than 1 kg (2.2 lbs.) of RCRA acute hazardous waste; or
  • Your facility 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.

Report your facility’s current Hazardous Waste Generator status based on the date you submit your 2011 Hazardous Waste Report on the Site ID Form. Your facility’s current status could be different from the status during the 2011 Hazardous Waste Report year.  Hazardous waste imported from a foreign country in 2011 must be counted in determining your facility’s generator status if your facility is the U.S. Importer.

 Do not file the 2011 Hazardous Waste Report if, during 2011, your facility was not a RCRA LQG and your facility did not treat, store, or dispose of RCRA hazardous wastes on-site in waste management units subject to a RCRA operating permit.  Unless specifically required by your state, do not file the 2011 Hazardous Waste Report if, during 2011, all hazardous waste generated at your facility was exported directly out of the United States to a foreign country.  An Annual Report must be filed in this case as required under 40 CFR 262.56.

States may impose reporting requirements above and beyond the Federal requirements. Some States use a modified version of this report or their own instructions and forms to fulfill their reporting requirements. Please contact your State Office about State-specific requirements. Locate your State Contact here.

EPA has made a number of changes to the Biennial Reporting Form this year.  A summary of the 2011 changes is provided here.

 The 2011 Hazardous Waste Report contains the following four forms: RCRA Subtitle C Site Identification (Site ID Form), Waste Generation and Management (GM Form), Waste Received From Off-site (WR Form), and Off-Site Identification (OI Form).  More information about these forms is provided here.

 As noted previously, the 2011 Hazardous Waste Report is due to your State or EPA Regional Office by Monday, March 1, 2012.  Your State reporting requirements or forms may differ from the Federal requirements.  Return your completed Hazardous Waste Report to the address listed for your State or Regional contact.

Be sure to make a photocopy of your completed Hazardous Waste Report and keep a copy for at least three years from the due date of the report as required by 40 CFR 262.40(b).

 If you have any questions about RCRA Biennial Hazardous Waste reporting requirements and whether your facility may be subject to these regulations, please contact Paul Tomiczek III, REM, P.E. at ptomiczek3@cecinc.com or 800-365-2324. More information on RCRA Biennial Reporting obligations, and detailed instructions for completing the hazardous waste report available in EPA’s 2011 Hazardous Waste Report Instructions and Forms document.

About the Author

Paul W. Tomiczek III, REM, P.E.

Paul W. Tomiczek III, REM, P.E., is a Vice President in CEC's Environmental Engineering and Sciences Practice and serves as our corporate Chief Technical Office. He works out of our Pittsburgh headquarters office and is a registered P.E. in Pennsylvania, Ohio, West Virginia, South Carolina, Georgia, Kentucky, Connecticut, and Alabama. He is certified as an ISO 14001 Environmental Management Systems Lead Auditor, OHSAS 18001 Certified Auditor, SP001 Above Ground Storage Tank Systems Inspector, and Michigan DEQ Industrial Site Certified Stormwater Operator.

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