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Biennial Reports Due March 1st, 2020

Biennial Reports Due March 1st, 2020

Large quantity waste generators (LQGs) are required by the Resource Conservation and Recovery Act (RCRA) to submit a report every two years. The report, known as the Biennial Report or the National Biennial RCRA Hazardous Waste Report (EPA form 8700-13A/B), covers the hazardous waste generated, the nature of the waste, and waste-related activities in the facility in the prior year. The EPA requires qualifying generators to submit their Biennial Report forms by March 1st of every even-numbered year. Therefore, 2020 Biennial Reports will need to be submitted by March 1st of 2020 and should contain activities that occurred during the 2019 calendar year.

Your organization is legally required to submit a Biennial Report if it meets any of the criteria below:

  • The facility generated 1,000 kg (2,200 lbs.) or more of RCRA hazardous waste in one calendar month; or
  • The facility generated or accumulated at any time, more than 1 kg (2.2 lbs.) of RCRA acute hazardous waste in one calendar month; or
  • The facility generated or accumulated at any time, over 100 kg (220 lbs.) of spill clean-up material contaminated with RCRA acute hazardous waste in one calendar month.

Although March 1st may seem like a while from now, keep in mind that your report will need to include hazardous waste-related activity from January 2019 through December 2019. This means you will have just 60 days after the end of 2019 to collect the data for your mandatory report. Along with typical requirements for standard information, such as the name and address of your facility and the assigned EPA ID number, the report will also need to include the quantity of hazardous waste you’ve sent to each Treatment, Storage, and Disposal Facility (TSDF) during 2019, as well as:

  • A description of the hazardous waste by EPA hazardous waste number
  • The name, address, and EPA ID of TSDFs your facility has used in the previous year
  • The name and EPA ID of the transporter(s) used to haul your waste there
  • Efforts you have taken in the past year to reduce the toxicity and amount of hazardous waste your facility generates
  • Any changes in hazardous waste volume and toxicity you’ve achieved during the past year compared to previous years

In past years, California generators have submitted their biennial reports to the state (DTSC) using the Waste Reporting System (WRS).  However, for the 2019 cycle, the DTSC has adopted the Federal RCRAInfo reporting system.  Generators will need to register for access to this system in order to enter and report their hazardous waste activities. This system is the same system where generators can access their e-manifests.

Your biennial report must be signed by an authorized representative likely the person who is responsible for the overall operation of the site (i.e., superintendent, operations manager or someone of equal responsibility). If you have any questions or need assistance with compiling your report, please contact us, our waste experts are here to help.

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