Some states have already started sending out reminders to Large Quantity Generators (LQGs) of Resource Conservation and Recovery Act (RCRA) hazardous waste that the reporting deadline is March 1, 2022. Remember, RCRA hazardous waste shipped in odd years may trigger reporting in even years. The federal and state hazardous waste regulations require certain federally-regulated (RCRA) hazardous waste generators, as well as, facilities that treat, store or dispose of RCRA hazardous waste to report their activities every two years (biennially). Even if you do not receive a notice from your local agency, you may still be required to file.
Biennial Reports are required if you are a RCRA LQG and your site:
Generated, in one calendar month 1,000 kg (2,200 lbs.) or more RCRA hazardous waste (including quantities imported by an importer site); or
Generated, in one calendar month or accumulated at any time 1 kg (2.2 lbs.) or more of any RCRA acute hazardous wastes listed in 40 CFR sections 261.31 or 261.33; or
Generated or accumulated in one calendar month greater than 100 kg (220 lbs.) of spill cleanup materials contaminated with RCRA acute hazardous wastes listed in 40 CFR sections 261.31 or 261.33(e); or
Treated, stored, or disposed of RCRA hazardous waste onsite in units subject to RCRA permitting requirements during the reporting year.
Similar to years past it needs to be filed by MARCH 1st using the RCRAInfo System’s Biennial Report Module. If you believe you are exempt, some states such as CA, allow sites to file a 2021 Biennial Hazardous Waste Report Exemption Request Form to confirm the BR is not required. DTSC and CalEPA put together some helpful training videos to walk through the reporting process.
ALG routinely works with companies, small and large, to review their annual waste manifest trends and file biennial reports, if necessary. Given ALG’s wide variety of clients, we’re able to apply our extensive hazardous waste experience to streamline the reporting process and enable our clients to better track their hazardous waste totals and trend their hazardous waste minimization measures.
If you would like assistance determining if your site is subject to Biennial Reporting and/or completing your Biennial Report, contact Jayme Dryden at firstname.lastname@example.org or at (805) 764-6005.