Biennial Hazardous Waste Reports and Supplementary Annual Reports for Groundwater Due March 1

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Biennial Hazardous Waste Reports and Supplementary Annual Reports for Groundwater Due March 1

By: George Colvin, CPG, CHMM

Published in January 2020 Focus on the Environment Newsletter

EPA in partnership with the states, biennially collects information from hazardous waste large quantity generators (LQGs) and treatment storage and disposal facilities (TSDFs) about the generation, management, and final disposition of hazardous waste regulated under the Resource Conservation and Recovery Act (RCRA).  The information is provided by LQGs and TSDs in what is known as the Hazardous Waste Report or Biennial Hazardous Waste Report.

If a site was a LQG or a TSD in one or more calendar months of an odd-numbered year, they are required to file a Hazardous Waste Report. A LQG is a site that generates 2200 or more pounds of hazardous waste in a calendar month (or 2.2 pounds or more of acute hazardous waste). The HWR is due no later than March 1 of the following even-numbered year and covers all hazardous waste activities conducted in the previous calendar year. The data in the report is reviewed by Ohio EPA and forwarded to U.S. EPA in fulfillment of the Biennial Report requirement.

2020 being an even year, if your facility was a LQG or TSD in 2019 you will need to submit a biennial report to EPA or your state equivalent by March 1, 2020.  Keep in mind that March 1, 2020 falls on a Sunday.  In Ohio, the business day due date is actually March 2, 2020. Ohio facilities are encouraged to file electronically through the eDRUMS web-based Hazardous Waste Report Service through Ohio EPA’s eBusiness Center. For Ohio e-filers, note that the following new activities were added to the Site ID Summary/Hazardous Waste Activities screen in the eBusiness Center eDRUMS app due to changes in federal requirements:

  • Pharmaceutical Activities including Healthcare Facility and Reverse Distributor designations
  • Large Quantity Generator Site Closure  
  • Large Quantity Generator Consolidation of Very Small Quantity Generator Hazardous Waste

While these activities have been included on the Site ID Summary/Hazardous Waste Activities screen in eDRUMS in anticipation of rule adoption, they should not be reported until the corresponding rules are effective in Ohio.  The Ohio EPA is in the process of adopting these federal regulations (Management Standards for Hazardous Pharmaceuticals and Hazardous Waste Generator Improvements Rule) and therefore, industry must refrain from notifying about any of the above-mentioned activities unless the Hazardous Waste Report is submitted late, after the rules are effective in Ohio.

March 1 is also the deadline for submitting the related Supplementary Annual Report for Groundwater.  Facilities conducting RCRA post-closure groundwater monitoring must prepare and submit groundwater monitoring specific reports each year (not biannually) for the prior year.  The Supplementary Annual Report is also submitted electronically. Instruction for completing the Supplementary Annual Report for Groundwater are available through the Ohio EPA’s Hazardous Waste Reporting Page.  If you are new to the Supplementary Annual Report, the formatting requirements can be overwhelming and fraught with potential for error. 

Cox-Colvin & Associates, Inc. has been assisting clients with both Hazardous Waste Reports and Supplementary Annual Reports for nearly 25 years and have developed web-based applications to assist with the reports.  For further information, contact the author.

George H. Colvin is a hydrogeologist with over 30 years of consulting experience. Much of his experience has focused on RCRA Corrective Action, RCRA closure, and groundwater investigation, monitoring, and cleanup. He holds a BS in Geology from Ohio University and MS in geology and hydrology from Vanderbilt University. He is a Certified Professional Geologist with the American Institute of Professional Geologists, a registered geologist in Kentucky, Pennsylvania, and Tennessee, and a Certified Hazardous Materials Manager.