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Biennial reports
  • Biennial reporting is required for LQGs and episodic generators.
  • If required to complete and submit a biennial report, additional documentation may need to be provided, such as a Site ID Form, Waste GM Form, Waste Received From Off-Site Forms, and Off-Site Identification Form(s).

Biennial reporting is required for large quantity generators (LQGs) and episodic generators. The report is completed in even numbered years and reports on the waste generated in the odd-numbered years. It is always due by the first of March. LQGs must report on all of the waste generated for the year, even for months when they may not have operated as LQGs. Biennial reports help the Environmental Protection Agency (EPA) and the states to keep track of hazardous waste generator activities.

EPA supplies a pre-printed form for this report: EPA form 8700-13A. Information requested on the form includes:

  • Generator activities for the previous year;
  • A description of efforts taken during the year to reduce the volume and/or toxicity of the wastes generated at the facility; and
  • An EPA identification number for the generator of the waste, each transporter, and each offsite treatment, storage, and disposal facility used during the amount of time covered by the report.

Helpful hints on filling out biennial reports

Gather materials. Consult records on quantities and types of hazardous waste that the site generated, managed, shipped, or received. These records may include:

  • Hazardous waste manifest forms;
  • Hazardous waste report forms submitted in previous years;
  • Records of quantities of hazardous waste generated or accumulated onsite; Results of laboratory analyses of waste;
  • Contracts or agreements with offsite facilities managing wastes; and
  • Copies of permits for onsite waste management systems.

If required to complete and submit a biennial report, additional documentation may need to be provided, which can include:

  • Site ID Form: If required to submit the Biennial Report, also submit the Resource Conservation and Recovery Act (RCRA) Subtitle C Site Identification Form (Site ID Form) as a component of the report. Mark, “Submitting as a component of the Hazardous Waste Report” on the form. Fill out the Site ID form by reporting all information current as of the date the form is filled out, including current generator status.
  • Waste Generation and Management (GM) Form: This form details the waste counted toward generator status. Hazardous waste must be reported if it was generated and accumulated onsite and subsequently managed onsite or shipped offsite.

Examples of RCRA hazardous wastes to be reported include those that were:

  • Generated onsite from a production process, service activity, or routine cleanup;
    • Generated from equipment decommissioning, spill cleanup, or remedial cleanup activity;
    • Shipped offsite, including hazardous waste that was received from offsite (reported on the Waste Received From Off-Site Form [WR Form]) and subsequently shipped offsite without being treated or recycled onsite;
    • Removed from onsite storage for treating, recycling, or disposing onsite or for offsite shipment;
    • Derived from the management of non-hazardous waste; or
    • Derived from the onsite treatment (including reclamation), disposal, or recycling of previously existing hazardous waste (as a residual).
  • Waste Received from Off-Site Forms(s): This includes imports of hazardous waste received from a site located in a foreign country, hazardous wastes that are received and recycled without first being stored, hazardous wastes received and stored prior to being recycled (i.e., the site has a RCRA storage permit), and hazardous wastes received from hazardous wastes generators to be partially reclaimed into commodity-like materials excluded from RCRA regulations.
  • Off-Site Identification Form(s): These forms are only required if the state calls for them.