Plan Ahead for 2014 Biennial RCRA Reports

Posted on 12/30/2013 by Scott C. Dunsmore

As the 2013 calendar year winds down, hazardous waste generators begin buttoning up their recordkeeping for the current year and planning for 2014. This process most likely includes confirming that all facility personnel completed their annual training, all manifests are accounted for, all waste and LDR determination records are in order, and their contingency plan is current. In addition to the usual year-end wrap-ups, this year generators should be sure they have all the necessary records for their 2014 biennial reporting obligation.
Section 3002 of the Resource Conservation and Recovery Act (RCRA) requires hazardous waste generators to report to the EPA every two years on their hazardous waste generation and management. The EPA has established the reporting regulations for this biennial report at 40 CFR 262.41. The next report is due March 1, 2014 and will be based on the hazardous waste generation during the 2013 calendar year. So as the generators close out this year, they should gather the records necessary to prepare the biennial report.
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Who Must Report?
Under the Federal rules, biennial reporting is only required for facilities that were large quantity generators in 2013. This would include any site that generated the following in any calendar month:
  • ≥1,000 kg of non-acute hazardous,
  • ≥1 kg of acute hazardous waste, or
  • ≥100 kg of spill cleanup material contaminated with acute hazardous waste.
Keep in mind that this includes episodic generation. If during any month of 2013 a facility generated a large quantity of hazardous waste, the generator must file a report for those months even if the facility is usually a small quantity generator.
Information You Need to Report 
In addition to reporting information regarding waste codes, form codes, and management method codes for each hazardous waste stream, the generator will need to report:
  • The total quantity generated in 2013;
  • The total quantity shipped off site in 2013 (broken down for each TSDF if multiple facilities were used); and
  • The total quantity treated, recycled, or disposed on site during 2013.
In order to complete the report, a generator may need to compile several sets of documents, including:
  • Hazardous waste manifests;
  • Waste profile sheets (hazardous waste determination records required at 40 CFR 262.40);
  • Records of waste generation activity for each point of generation (while not specifically required under the generator rules, such records may be useful in preparing reports such as the biennial report); and
  • Records tracking success in waste minimizations efforts.
Recordkeeping ComplianceThe EPA does have special reporting for particular waste streams, including lab packs, laboratory clean-out wastes, asbestos, PCBs, waste oils, mixed waste, and contaminated groundwater.
Some of these particular reports may streamline the reporting process, but others may require additional work. So before you pack up the hazardous waste records, it pays to go through the 2013 report form to be sure you have ready access to these records in the first quarter of 2014.
Changes to Look for in the 2013 Form
The EPA has made a few revisions to the 2013 report, making it different from the previous (2011) version. These changes include:
  • Consolidation of some of the waste management codes in order to ease reporting. For example, the codes H071 (chemical reduction), H073 (cyanide destruction), H075 (chemical oxidation), H076 (wet air oxidation), and H077 (other chemical precipitation) are now all covered by the new management method code H070 (chemical treatment).
  • Revisions to the waste minimization codes to assist generators with reporting their waste minimization activities. The new waste minimization codes identify when waste minimization activities occurred (whether initiated prior to the reporting year or during the reporting year) and also provide examples of types of waste minimization activities.
  • Reporting sites must now use the new 2012 NAICS codes established by the US Census Bureau. The 2012 NAICS is significantly different from the previous 2007 edition.
State Requirements May Vary
Lastly, some states may have additional reporting requirements, such as annual reporting, more reporting elements, and/or electronic reporting. Also, some states may require small quantity generators to submit reports. While reviewing the Federal reporting elements, it will be important for the generator to check state rules as part of the recordkeeping review.
Prepare to meet all of your hazardous waste management responsibilities at any of Lion Technology’s 2014 RCRA workshops! The Hazardous/Toxic Waste Management Workshop is designed to satisfy the EPA’s initial or annual refresher training requirement for waste generators. The Advanced Hazardous Waste Management Workshop also covers the latest RCRA rules and goes beyond the basics to cover waste minimization strategies, more industry best practices, and ways to capitalize on available exceptions and reliefs to ease your regulatory burden.

Tags: hazardous, RCRA, reporting and recordkeeping, state rules, waste

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