As part of its mission to protect environmental and human health, EPA tracks hazardous waste generation activity through a Biennial Report that large quantity generators must submit to state environmental agencies or regional EPA offices. The Biennial Report is due by March 1st
of every even numbered year.
Who Must Submit a RCRA Biennial Report?
Currently, only large quantity generators of hazardous waste must submit the RCRA Biennial Report.
A large quantity generator of hazardous waste is any site that, in any single month
- Generated 1000 kg or more of non-acute hazardous waste
- Generated or accumulated 1 kg or more of acute hazardous waste; or
- Generated or accumulated 100 kg or more of spill cleanup material contaminated with acute hazardous waste.
Sites that meet any of these thresholds in even one month of the most recent odd-numbered year
must report on all their hazardous waste activity from that entire year.
In other words, if your site met any
of the above criteria during any
month in 2019, you must submit a Biennial Report in 2020. Biennial Reports submitted in 2022 will cover wastes generated in 2021, and so on.
What’s Required in the RCRA Biennial Report?
The Federal EPA requires that certain information be submitted on the Biennial Report form (EPA form 8700-13A/B).
The form includes information such as:
- Facility’s EPA ID Number,
- Facility’s name and address,
- Quantity and nature of hazardous waste generated, and
- Whether the hazardous waste was sent for recycling, treatment, storage, or disposal.
Under the RCRA Generator Improvements Rule, large quantity generators must also submit re-notification to EPA using Form 8700-12 in every even numbered year. LQGs may submit Form 8700-12 as part of the Biennial Report (40 CFR 262.18(d)(2)).
More at EPA’s website: 2020 EPA Biennial Report instructions and forms
Small Quantity Generators: New Re-notification Requirement
Small quantity generators (SQGs) and very small quantity generators (VSQGs) of hazardous waste are not
required to submit Biennial Reports.
Starting in 2021, though, small quantity generators will be required to re-notify EPA of their generator status on September 21st
of every fourth year (i.e., 2021, 2025, 2029, etc.). This re-notification requirement for SQGs was added as part of EPA’s Generator Improvements Rule as well. (40 CFR 262.18(d)(1)).
Even if your state has not yet adopted the RCRA Generator Improvements Rule
, all generators of hazardous waste may be subject to additional state-specific reporting requirements. All generators should consult their state agencies to clarify the specific reporting requirements for that state.
Need a hand with your next RCRA Biennial Report?
Lion provides expert consulting services for hazardous waste generators. We can help with reporting, RCRA compliance assessments, contingency planning, hazardous waste training, and more. Reach out to us today at Lion.com/Consulting
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