RCRA Biennial Reporting

Posted on 1/23/2012 by James Griffin

Large quantity generators and all facilities which treat, store, or dispose of hazardous waste must file a report on their waste handling activities with the EPA (or authorized state agency) by March 1 of each even-numbered year. Small and conditionally exempt generators are excluded from this report in most states. [40 CFR 262, Subpart D]
Full instructions for filling out the 2011 Hazardous Waste Report (“Biennial Report”) can be obtained from the EPA here.
This “Biennial Report” usually has a few cosmetic changes every cycle, and 2011 is no different. Most of the changes are clarifications, new examples, and minor modifications.
 Of note is that the EPA now recognizes a sub-category of “short-term generators,” including hazardous waste generators such as construction sites, whose waste generating activities are of an intentionally limited duration. The EPA also developed a reference document to help reporters determine which wastes to report, Biennial Reporting: Reportable and Non-Reportable Wastes
Item 12, the notification of hazardous secondary material activity, still exists, though the provisions for secondary material recycling are only active in a few states and overdue for revision.
The Biennial Report is due March 1, 2012. You can obtain copies of the forms and report instructions from your State or EPA Regional Office contact. A list of those contacts is available. The EPA encourages electronic reporting of the Biennial Report where possible, and the instructions for that process can also be obtained from your State or EPA Regional Office contact.

Tags: hazardous, RCRA, reporting and recordkeeping, waste

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