The Biennial Report for RCRA Hazardous Waste Generators

It's that time of year again! The Biennial Report form (8700-13A/B) must be submitted to your authorized state agency or EPA regional office by March 1 of every even-numbered year. You'll report on the previous year's (2015) generation, management, and final disposition of hazardous waste regulated under RCRA. See 40 CFR 262.41(a).

Paper submissions are acceptable, but the EPA encourages you to file electronically. The form is available as a "fillable" pdf file and is available here.

Which Hazardous Waste Generators Must Report?

Any facility designated as a large quantity generator (LQG) in 2015 must file. For the purpose of the biennial report, you were a LQG in 2015 if your site generated any of the following amounts in any calendar month:

• Greater than or equal to 1,000 kilograms (i.e., 2,200 lbs.) of hazardous waste; or
• Greater than 1 kg (2.2 lbs.) of any acute hazardous wastes listed at 40 CFR 261.31 (F-listed waste with the hazard code "H") or 261.33(e) (P-listed waste); or
• Greater than 100 kg (220 lbs.) of any residue or contaminated soil, waste, or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute hazardous wastes listed 40 CFR 261.31 or 261.33(e).

When you report, you will indicate your current generator status (i.e., LQG, SQG, or CESQG).
 

If you were not previously registered as an LQG, SQG, or CESQG and were a "short-term" generator in 2015 (i.e., your site generated waste from a short-term or one-time event and not from ongoing processes) that triggered the requirement to submit the biennial report, you will have to complete EPA forms 8700-12, 8700-13 A/B, and 8700-23 RCRA SUBTITLE C SITE IDENTIFICATION FORM.

Which Wastes Go in the RCRA Biennial Report?

Generators must report RCRA hazardous waste generated and accumulated on site:

• And subsequently managed on site or shipped off site in 2015;
• In 2015, but not managed on site or shipped off site until after 2015; or
• Prior to 2015, but either managed on site or shipped off site in 2015

The following are some of the typical wastes generated that are not reportable:

1. Materials that are excluded from regulation as solid wastes at 40 CFR 261.4(a).
2. Solid wastes that are excluded from regulation as hazardous wastes at 40 CFR 261.4(b).
3. Most hazardous wastes that are not counted toward your generator status as specified at 40 CFR 261.5(c) and elsewhere:
   • Wastes that have not yet exited process units [40 CFR 261.4(c)];
   • Samples sent for analysis [40 CFR 261.4(d)];
   • Treatability study samples and facilities [40 CFR 261.4(e)-(f)];
   • Excluded recyclable materials named at 40 CFR 261.6(a)(3);
   • Any residue remaining in RCRA-empty containers as defined at 40 CFR 261.7(a);
   • PCB wastes described at 40 CFR 261.8;
   • Wastes managed immediately upon generation in on-site elementary neutralization units, wastewater treatment units, or totally enclosed treatment facilities [40 CFR 261.4(c)(2)];
   • Materials that are recycled on site without prior storage meeting the requirements of 40 CFR 261.6(c)(2);
   • Used oil managed under 40 CFR 279;
   • Spent lead-acid batteries managed under the requirements of 40 CFR 266; and
   • Universal wastes managed under 40 CFR 273.
4. Precious metals reclamation following 40 CFR 266.70.

Unique State RCRA Reporting Requirements

Some state-level RCRA programs require annual reporting. In Texas, for example, the Texas Commission on Environmental Quality (TCEQ) requires Texas-based facilities to file annual reports. The TCEQ then submits that information to the USEPA annually on behalf of hazardous waste generator and TSDFs.

Who Can You Contact for Help?

If you need assistance, a list of State and EPA regional office addresses, contact names, telephone numbers, and e-mail addresses can be accessed here.

You can submit questions directly to the EPA by going here.

Lion Members can direct hazardous waste reporting questions to the Finder Service by logging in here: www.Lion.com/Members.

Interactive, Engaging Annual RCRA Training

Time flies when you're managing hazardous waste. EPA's annual training requirement can sneak up on managers and personnel, causing facilities to fall out of compliance. Presented live by an expert instructor, the RCRA Hazardous Waste Management Refresher Webinar is an interactive, one-day webinar designed for experienced RCRA professionals. Get up to speed with new and changing RCRA requirements and satisfy EPA's annual training mandate (40 CFR 262.34 and 265.16) without leaving the facility.

The first session of 2016 will be presented on January 26. Reserve your seat now.
 

Tags: hazardous, RCRA, Recordkeeping and Reporting, TCEQ, waste