Um, yeah, this may not be the best example of drum storage…
Once again, the March 1 deadline looms for large quantity generators of hazardous waste as well as facilities that treated, stored or disposed of hazardous waste on-site to submit their hazardous waste biennial reports to the US Environmental Protection Agency.
If in any month in 2013 your facility
- generated more than 1,000 kilograms (2,200 pounds, or about four to five 55-gallon barrels) of RCRA hazardous waste,
- generated or accumulated more than 1 kg of acute hazardous waste, or
- generated or accumulated more than 100 kg of spill cleanup material contaminated with acute hazardous waste,
then you are a RCRA Large Quantity Generator (LQG) and must complete and file the 2013 Hazardous Waste Report. Hazardous wastes imported to your facility from a foreign country should be included in your generator count.
And if in 2013 your facility treated, stored or disposed of hazardous wastes on-site as a permitted hazardous waste facility, you must complete and file the 2013 report.
As for changes in the reporting requirements and guidelines, some of the codes used on the forms, such as those for waste management methods, waste minimization, and source code descriptions, have been revised. Additionally, 2013 reporters should use the updated 2012 NAICS codes for their industry classification.
As (almost) always with such things, be aware that your state may have additional or somewhat different reporting requirements that also must be met.
For more information including forms, instructions and State contacts, visit www.epa.gov/osw/inforesources/data/biennialreport/.
For assistance with preparation of the biennial hazardous waste generator’s report, contact T. Cozzie Consulting.