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Reporting Releases under RCRA

Posted on 12/23/2014 by Ross Kellogg

Like many Federal environmental statutes, the Resource Conservation and Recovery Act (RCRA) sets requirements for reporting releases.

Several RCRA regulations address reporting releases of hazardous waste. The specific reporting requirement(s) a hazardous waste generator is subject to depends on how much waste the facility generates (small vs. large quantity), the specific consequences of the release, and in some cases the type of device in which the hazardous waste is stored.

Contingency Plan Reporting Implementation

Large quantity generators (LQG) of hazardous waste must maintain a written contingency plan to deal with fires, explosions, or releases of hazardous waste to the environment.

Whenever there is an imminent or actual emergency situation at a regulated facility, the emergency coordinator must immediately notify appropriate State or local agencies with designated response roles if their help is needed. [40 CFR 265.56(a)(2)] If there is a release of hazardous waste, a fire, an explosion, or another event that may threaten human health or the environment outside of the facility boundary, the generator must immediately notify the National Response Center (or pre-designated alternative). If the event requires evacuation of the local area, the emergency coordinator must also notify the appropriate local authorities. [40 CFR 265.56(d)(1)-(2)]

The telephone report to the National Response Center (NRC) must include:
  • The name and telephone number of the reporter;
  • The name and address of the facility;
  • The time and type (fire, explosion, spill, etc.) of incident;
  • The name and quantity of materials involved (to the extent known);
  • The extent of injuries (if any); and
  • Possible hazards to human health or the environment outside of the facility.
No later than 30 days after an incident that required the implementation of the contingency plan, the large quantity generator must file a written report with the EPA regional office and/or the State EPA. The written report must contain all the information from the immediate telephone report, as well as an estimated quantity and disposition of material recovered after the incident. [40 CFR 265.56]
Alternative Contingency Plan Reporting Procedures for Small Quantity Generators

SQGs are not required to have written contingency plans like LQGs, but they are required under the 180-day accumulation requirements to have designated emergency coordinators. The 180-day accumulation rules require that in the event of a fire, the emergency coordinator must immediately notify local responders by telephone. In the event of a fire, explosion, or other release which could threaten human health or the environment outside of the facility, the generator must notify the National Response Center using the 24/7 toll free number.

The NRC notification must include:
  • The name, address, and EPA ID# of the generator;
  • The date/time/type of incident;
  • The quantity and type of waste involved;
  • The extent of injuries (if any); and
  • The estimated quantity and disposition of recovered materials if any.
[40 CFR 262.34(d)(5)]

Federal RCRA regulations do not require SQGs to file written reports after a fire, release, or other incident involving hazardous waste. State-level regulations may require contingency planning or reporting in excess of Federal requirements.

Tank Releases

Whenever LQGs accumulating hazardous waste in tanks have a release of more than 1 lb. of hazardous waste, they must report the release by telephone to the EPA regional office or State agency within 24 hours. In addition to making the telephone notification, the rules require the LQG to submit a written report to the EPA regional office or State agency within 30 days of the event. The follow-up written report must include:
  • The likely route or migration of the release;
  • The characteristics of the surrounding soil;
  • The results of any monitoring or sampling done in conjunction with the release;
  • The proximity to down-gradient drinking water, surface water, population areas; and
  • A description of the response actions taken or planned.
[40 CFR 265.196(d)]

Small quantity generators (SQGs) of hazardous waste are only subject to the requirements at 40 CFR 265.201 and therefore not subject to the reporting requirements at 40 CFR 265.196.

Trusted Annual RCRA Training

Be confident you have the knowledge and skills to maintain compliance with the complex RCRA regulations for managing hazardous waste. From point of generation until disposal, you site's waste must be managed and stored properly to prevent releases, injury to personnel or the public, and EPA fines as high as $37,500 per day, per violation. EPA requires hazardous waste personnel to complete training annually. [40 CFR 262.34 and 265.16]

Tags: hazardous, RCRA, Recordkeeping and Reporting, waste

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