Hazardous Waste Management

Biennial Reports—The Who and the What

Large quantity generators (LQGs) of hazardous waste and hazardous waste treatment, storage, and disposal facilities (TSDFs) are required to submit hazardous waste reports (aka, biennial reports) by March 1 this year. Today we will review some details of just who is required to submit this report and common hazardous wastes that are subject to reporting.

Biennial reports must be submitted to your state or the EPA by March 1 in even numbered years for hazardous waste activities the previous year. The reports detail the types and quantities of hazardous waste shipped off-site and the efforts a facility takes to reduce the volume and toxicity of generated wastes.
Note: Some states require annual reports or have developed their own biennial report forms that require additional information, so be sure to check state requirements. In addition, some states require other categories of generators to report as well.

Four Forms

The federal biennial report form consists of four different reporting forms or sections. Not all four sections must be completed. Submission of the various forms depends on the type of facility reporting and its specific waste-management activities. The four forms are:

  • Site Identification (Site ID) Form (all LQGs and TSDFs must complete all items on this form)
  • Waste Generation and Management (GM) Form (if you generated hazardous waste on-site or imported hazardous waste from a foreign country)
  • Waste Received from Off-site (WR) Form (if you received hazardous waste from an off-site source and managed it on-site)
  • Off-site Identification (OI) Form (not required by the EPA, but your state may require it if you received waste from an off-site source or shipped waste off-site)

What Do You Need to Fill Out the Biennial Report?

If you are required to submit a biennial report, you must submit the GM form for all hazardous waste that was used to determine your generator status. To prepare the report, review your records on quantities and types of hazardous waste your facility generated, managed, shipped, or received in the previous year. Records that may be helpful include:

  • Hazardous waste manifests;
  • Hazardous waste reports submitted in previous years;
  • Records of quantities of hazardous waste generated or accumulated on-site;
  • Results of laboratory analyses of your waste;
  • Contracts or agreements with off-site facilities managing your wastes; and
  • Copies of permits for on-site waste management systems.

What types of hazardous waste need to be reported?

Examples of common hazardous wastes to be reported include, but are not limited to, those that are:

  • Generated on-site from a production process, service activity, or routine cleanup
  • Generated from equipment decommissioning, spill cleanup, or remedial cleanup activity
  • Removed from on-site storage
  • Derived from the management of nonhazardous waste
  • Derived from the on-site treatment (including reclamation), disposal, or recycling of previously existing hazardous waste (as a residual)
  • Shipped off-site, including hazardous waste that was received from off-site (reported on the Form WR) and subsequently shipped off-site without being treated or recycled on-site
  • Radioactive wastes mixed with RCRA hazardous wastes
  • Hazardous wastes regulated only by your state if your state requires them to be reported

For tons of information about biennial reports and other hazardous waste management requirements, check out Enviro.BLR.com®.

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