United States Solid Waste and EPA530-R-99-050
Environmental Emergency Response PB2000-101 890
Protection Agency (5305W) February 2000
RCRA, Superfund & EPCRA
Hotline Training Module
Introduction to:
Hazardous Waste Biennial
Report
Updated October 1999
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DISCLAIMER
This document was developed by Booz-Allen& Hamilton Inc. under contract 68-W 0-0039 to EPA. It is intended to
be used as a training tool for Hotline specialists and does not represent a statement of EPA policy.
The information in this document is not by any means a complete representation of EPA's regulations or policies.
This document is used only in the capacity of the Hotline training and is not used as a reference toolon Hotline calls.
The Hotline revises and updates this document as regulatory pro gram areas change.
The information in this docume ntmay not necessarily reflect the current position of the Agency. This document is
not intended and cannot be relied upon to create any rights, substantive or procedural, enforceable by any party in
litigation with the United States.
RCRA, Superfund & EPCRA Hotline Phone Numbers
National toll-free (outs ide of DC area) (800) 424-9346
Loca I num ber (with! n DC a rea) (703) 412-9810
National toll-free for the hearing impaired (TDD) (800) 553-7672
The Hotline is open from 9 am to 6 pm Eastern Time,
Monday through Friday, except for federal holidays.
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HAZARDOUS WASTE BIENNIAL REPORT
CONTENTS
1. Introduction 1
2. Regulatory Summary 2
2.1 Applicability 3
3. Reporting Forms 6
3.1 FormIC 6
3.2 FormGM 6
3.3 FormWR 8
3.4 FormOI 8
3.5 Notification Postcard 9
4. Commonly Asked Questions 10
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Hazardous Waste Biennial Report - 1
1. INTRODUCTION
The Resource Conservation and Recovery Act (RCRA) sets forth management
standards for hazardous waste. RCRA's purpose is to regulate hazardous waste from
its generation to its ultimate disposal, or from "cradle to grave." Other modules have
introduced you to various aspects of this process such as the Generator module,
initiating the RCRA regulatory regime, and the Treatment, Storage, and Disposal
Facility (TSDF) module, explaining the management protocols at final deposition. Just
as the manifest serves as the recordkeeping component for generators, transporters, and
designated facilities, generators and TSDFs complete the Biennial Report to inform the
public, the states, and EPA of their waste generation and management activities.
In addition to supplying information for compliance purposes (e.g., to demonstrate the
quantity of hazardous waste generated by a particular facility) the Biennial Report helps
EPA and the states to analyze their regulatory programs and assists them in making
hazardous waste treatment and disposal capacity determinations. EPA compiles the
data obtained into national reports that contain information on hazardous waste
management. For example, the published reports contain statistical information on
quantities of hazardous waste generated, which facilities are generating what types of
wastes, and management practices.
When you have completed this module you should be able to identify the regulatory
requirements associated with the Biennial Report. Specifically, you should be able to:
• Explain who is subject to biennial reporting requirements
• Explain the different forms associated with the Biennial Report
• Describe the changes that have occurred to the Biennial Report form since the
last reporting year
• Assist callers who are completing the Biennial Report.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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2 - Hazardous Waste Biennial Report
2. REGULATORY SUMMARY
In RCRA §3002(a)(6), Congress required EPA to develop a program for hazardous
waste generators to report the nature, quantities, and disposition of hazardous waste
generated. RCRA §3004(a)(2) requires TSDFs to submit a report on the wastes that they
receive from off site. Large quantity generators (LQGs) and TSDFs must submit this
report to EPA every two years. This statutory requirement is codified in 40 CFR §262.41
for LQGs and §§264/265.75 for TSDFs. The form that LQGs and TSDFs use for
reporting purposes, EPA Form 8700-13A/B, is called the Biennial Report. Its official
title is the Hazardous Waste Report Instructions and Forms.
EPA created the Biennial Report program in order to collect information about the
generation, management, and final disposition of RCRA hazardous waste in the United
States. Once facilities complete the report, they return it to their state or regional
Biennial Report contact. States compile all of the received information and forward it to
the Regional EPA offices. All Biennial Report data from each Region is combined and
ultimately forwarded to EPA. EPA then compiles the data into a national database that
is made available to the public in the form of five reports: The National Biennial RCRA
Hazardous Waste Report, List of Large Quantity Generators in the United States, List of
Treatment, Storage, and Disposal Facilities in the United States, State Detail Analysis,
National Analysis, and State Summary Analysis.
Facilities are required to submit information on waste generation and management
activities occurring in odd numbered years. For purposes of this module, these odd
numbered years are referred to as reporting years. The Biennial Report must be
submitted to the authorized state agency or the EPA Regional office by March 1st of the
following even numbered year (§§262.41 and 264/265.75). For example, reports were
due on March 1,1998, for waste management activities that occurred in the 1997
calendar year. Facilities may request a site-specific extension to this deadline by
contacting their implementing agency in writing prior to March 1st. This requested
extension, however, may not be extend beyond April 1st.
The Biennial Report contains four separate forms. Each form requests information
concerning different aspects of the waste management process. The following table
itemizes the type of information to be reported on each form:
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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Hazardous Waste Biennial Report - 3
Form
Who must file
What type of information is
requested
How many forms needed
Form IC-
Identification
and
Certification
AU TSDFs and LQGs
Site address
Certification statement
ID number
Facility status
One per facility
Form GM-
Waste
Generation
and
Management
AU TSDFs and LQGs which
generated and managed
hazardous waste on site or
shipped the waste off site
during the reporting year
Description of the waste
including wastecodes,
origin of the waste and
physical properties
Quantity generated,
treated, stored, or recycled
on site during the reporting
year
Information about waste
shipped off site, including
information about
receiving facility
One per wastestream, although
similar waste streams can be
combined on one Form GM
Form WR -
Waste
Received
From Off Site
AU TSDFs and LQGs which
received hazardous waste
from off site during
reporting year
Description of the waste
including wastecodes,
origin of the waste and
physical properties
Information about waste
received from off site,
including information
about receiving facility
One block (3 per form) for each
off-site handler that hazardous
waste is received from
Form OI -
Off-Site
Identification
State Determined (this is a
state-required form)
Names and addresses of
off-site instaUations and
transporters
Each Form OI contains space for
5 records
2.1 APPLICABILITY
Federal law requires LQGs and TSDFs to submit the Biennial Report, although states
may have additional reporting requirements. Federal EPA allows state agencies to have
more stringent regulations. For example, some states require small quantity generators
(SQGs) and conditionally exempt small quantity generators (CESQGs) to submit the
Biennial Report. In addition, some states also require facilities to submit a hazardous
waste report annually. For discussion on states' ability to be more stringent and
broader in scope with federal regulations, see the States Programs training module.
LARGE QUANTITY GENERATOR (LQG)
A facility is considered a LQG if, during any calendar month of the reporting year, the
site generates more than the following amounts of waste:
• 1,000 kilogram (kg) of hazardous waste
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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4 - Hazardous Waste Biennial Report
OR
• 1 kg of acutely hazardous waste (i.e., wastecodes denoted with the hazard code
"H" and all P-listed wastes)
OR
• 100 kg of spill cleanup material contaminated with acutely hazardous waste.
A facility is also considered a large quantity generator if, at any one time during the
reporting year, the site accumulates more than the following amounts of waste on site:
• 1 kg of acutely hazardous waste
OR
• 100 kg of spill cleanup material contaminated with acutely hazardous waste.
Facilities meeting one or more of these criteria must submit a report on all waste
generated or managed by the facility during the reporting year. Facilities will be
reporting on wastes that were generated during odd numbered years
Recall from the Generators module that a facility becomes an "episodic generator" when
a generator exceeds or falls below their normal generation limit in a calendar month.
Episodic generators must comply with the requirements applicable to them for that
month. For biennial reporting purposes, facilities who were LQGs during any month of
a reporting year are requested to report all waste generated or managed during that
year, not just the waste generated during the month they were subject to LQG
standards.
Some states regulate additional waste streams that are not regulated by the federal
RCRA program. For purposes of the Biennial Report, only federally regulated waste is
counted towards determining a facility's generator status. For example, a facility that
generates 1200 kg of waste that is considered hazardous only on the state level and 50
kg of federally regulated hazardous waste is not considered a LQG for purposes of the
Biennial Report. States may still require these facilities to submit the Biennial Report to
the state agency.
A generator that manages waste in a RCRA permit-exempt unit (e.g., a wastewater
treatment unit) immediately upon its generation need not count that waste towards
determining their generator status for purposes of the Biennial Report (§261.5(c)(2)). If
this site is required to file the report (i.e., the site is a LQG or TSDF), however, any
waste managed in these permit-exempt units is subject to all reporting requirements.
TREATMENT, STORAGE, AND DISPOSAL FACILITIES (TSDFs)
A TSDF is a facility that is subject to the RCRA permit requirements (i.e., is permitted or
has interim status). All TSDFs are subject to the Biennial Reporting requirements
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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Hazardous Waste Biennial Report - 5
(§§264/265.75) and must submit a report for all waste managed during the reporting
year. Any waste managed at a TSDF in a unit exempt from RCRA permitting must also
be reported.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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6 - Hazardous Waste Biennial Report
3. REPORTING FORMS
The Biennial Report package consists of multiple forms, each representing different
components of RCRA's cradle-to-grave management system. States automatically
distribute the reporting forms to facilities that filed reports in the previous reporting
year. Facilities who are reporting for the first time may obtain the forms directly from
designated state contacts (available through the Hotline) or may be downloaded from
the Internet at the following address:
http://www.epa.gov/epaoswer/hazwaste/data/#brs
The reporting forms posted on the Internet are the federal forms. States may have their
own version of the reporting forms and callers should not necessarily rely on the
federal version. The Hotline can provide callers with information on whether or not
their state uses modified reporting forms. Callers may also verify if their state has
adjusted forms with their state contact.
The Biennial Report consists of four separate forms and a notification postcard. Certain
"boxes" on each form are required to be filled in whereas completion of other
information is optional. The specifics of each form are discussed below.
3.1 FORM 1C - IDENTIFICATION AND CERTIFICATION
The first form, Identification and Certification (Form 1C), must be filed by all LQGs and
TSDFs required to submit the Biennial Report (see Section 2, Applicability, for further
discussion). This two-page form is used to obtain administrative information about the
reporting facility. It requests information on the location of the site, the generator status
of the facility (e.g., SQG, LQG), and information on the waste management status of the
facility. This form also contains a certification statement, which must be signed by the
individual who supervised the completion of the report confirming that all information
contained in the report is true and accurate to the best of the signer's knowledge.
3.2 FORM GM - WASTE GENERATION AND MANAGEMENT
The second form, Waste Generation and Management (Form GM), must be submitted
by all LQGs and by TSDFs that generated or shipped off site any quantity of hazardous
waste during the reporting year. All LQGs and facilities which send waste off site for
treatment must file this form. Form GM requires information on the wastes that were
generated in the reporting year as well as wastes that were generated prior to the
reporting year, but managed during the reporting year. This form documents the
source, characteristics, and quantity of each generated wastestream, the quantities and
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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Hazardous Waste Biennial Report - 7
management methods of wastes managed on site, and the quantity and management
methods of wastes shipped off site.
A separate Form GM is required for each RCRA hazardous waste generated or shipped
off site during the reporting year. However, similar hazardous wastes may be
combined onto one Form GM if the wastes have the same Origin code and Form code.
Specifically, if a facility generates several batches of hazardous waste, but each waste
originates from the same process or management activity and shares the same physical
form or chemical composition description, the waste can be aggregated onto one Form
GM. Hazardous waste residue derived from the treatment of a waste is considered a
newly generated waste and should be filed on its own Form GM.
Form GM has three sections — Waste Characteristics, On-Site Generation and
Management, and Off-Site Management of the waste. Section I, Waste Characteristics,
requires the facility to provide the following:
• Narrative description of the waste
• Federal and state wastecodes assigned to the waste
• SIC codes of the entire facility (not of the process generating the specific waste
stream) and codes for identifying the origin of the waste (e.g., from a cleanup,
waste from a production process)
• Type of system the waste was generated (e.g., energy recovery, stabilization, or
disposal)
• Source of the waste (i.e., the process which generated the hazardous waste)
• Physical form or chemical composition of the hazardous waste (e.g., waste oil,
lab packs, or leachate).
Section II, On-Site Generation and Management, requires that facilities describe the on-
site system(s) used to treat the wastestream. Section II also requests information on the
quantity of waste treated, disposed or recycled on site during the reporting year.
Multiple On-Site Process System Type Codes may be reported if the waste is treated by
two different treatment systems or if the waste is managed in one system for part of the
year and another for the remainder of the year. However, for hazardous wastewaters
managed on site and discharged in accordance with a National Pollutant Discharge
Elimination System (NPDES) permit pursuant to §402 of the Clean Water Act (CWA), to
a Publicly Owned Treatment Works (POTW) in accordance with §307(b) of the CWA, or
to an Underground Injection Well (UIC) well regulated by the Safe Drinking Water Act
(SDWA), only management codes M136, M135, and M134, respectively, should be used
regardless of what treatment the wastewaters receive prior to discharge, and only one
Form GM should be completed. Any sludges or residues generated from the
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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8 - Hazardous Waste Biennial Report
management of these wastewaters should be reported as a newly generated waste.
When reporting the quantity treated, disposed, or recycled during the reporting year,
units of measure must be consistent. For example, pounds should not be used in one
instance and kilograms another.
Section III, Off-Site Shipment of Hazardous Waste consists of information on the facility
the waste is shipped to, the type of system the waste was shipped to for management,
and the total quantity of waste shipped off site.
3.3 FORM WR - WASTE RECEIVED FROM OFF-SITE
The third form, Waste Received from Off-Site (Form WR), must be filed by all facilities
that received RCRA hazardous waste from off site during the reporting year. For
example, a landfill facility, which receives hazardous waste for disposal, is required to
complete Form WR. Facilities must provide data on the characteristics and quantity of
the hazardous wastes received from other hazardous waste handlers as well as the
management methods used for these wastes. Hazardous wastes received from the same
handler may be aggregated onto one waste block as long as they have the same Form
Code and were managed in the same type of process. Wastes received from more than
one off-site handler may be reported on the same form, but a separate waste block must
be filled out for each handler.
Form WR contains the following information:
• Federal and state hazardous wastecodes assigned to the waste
• Narrative descriptions of each waste
• EPA identification number of the facility from which the waste was received
• Total quantity received from each off-site facility
• Physical form or the chemical composition of the hazardous waste
• Type of system in which the waste was managed.
3.4 FORM OI - OFF-SITE IDENTIFICATION
The fourth form, Off-Site Identification (Form OI) requires information on all off-site
facilities and transporters used by the facility. Form OI is not a federally required form
and should only be filed if required by the state in which the handler is located.
Questions concerning Form OI should be referred to the state contact.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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Hazardous Waste Biennial Report - '
3.5 NOTIFICATION POSTCARD
The Biennial Report form is automatically sent to all facilities that submitted forms in
the previous biennial reporting cycle. Some facilities, however, may not be required to
report for the current reporting year. For example, the facility may have reported in the
past due to a spill, that caused them to produce greater than 1,000 kg of hazardous
waste during one month, but is currently operating as a SQG. In cases where the
facility does not need to file in the current reporting year, they must notify EPA by
returning the notification postcard attached to the reporting package. In some
instances, states may require facilities to submit Form 1C in lieu of the postcard.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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10 - Hazardous Waste Biennial Report
4. COMMONLY ASKED QUESTIONS
-I received a copy of the Hazardous Waste Report Forms and Instructions, but during 19991
only generated 100 kg of hazardous waste once during the clean up of a chemical spill. Am I
required to complete this report?
No. EPA requires only LQGs and TSDFs to submit the Biennial Report, but some states
require that SQGs and CESQGs file. Information Specialists can offer callers limited
information on state requirements to offer to callers; however, callers should be referred
to their implementing agency for appropriate determinations.
-In addition to federal RCRA hazardous wastecodes, my state has other hazardous wastecodes.
Should these wastes be counted toward determining my generator status for reporting purposes?
No. Only federally regulated RCRA hazardous wastes must be counted to determine
generator status for biennial reporting purposes. However, some states may require
their wastes to be counted when determining generator status for purposes of
compliance with the RCRA Biennial Reporting requirements.
-Can I file the Biennial Report electionically?
Yes. EPA encourages electronic reporting of the Biennial Report, and many states have
electronic reporting programs for the regulated community to use. Callers requesting
information on electronic reporting should be referred to their state Biennial Report
contact. Information Specialists should first check as to whether the state allows
electronic reporting.
-What are the requirements for reporting lab packs?
Lab packs can usually be aggregated on one Form GM and Form WR when reported on
the Biennial Report. The exception is if they contain acute hazardous wastes or they are
managed differently from each other. For example, different lab packs may not be
combined onto one Form GM if one lab pack is sent off site for disposal and the other is
sent off site for recycling. Facilities should always use Form Codes B001-B004 or B009
for lab packs. If there are many wastecodes associated with a batch of lab packs, enter
"LABP" in Section I, Box B of Form GM or Box B of Form WR; then enter "NA" in the
remaining spaces. If there are numerous codes but a few major ones can be identified,
report the major codes in Box B.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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Hazardous Waste Biennial Report - 11
The weight of containers should be included only if the containers are disposed or
treated with the waste.
-Should universal wastes be reported on the Biennial Report?
Universal waste handlers, regulated under Part 273, are not required to file the Biennial
Report. In addition, universal waste need not be counted when determining whether a
facility is a LQG subject to reporting requirements (§261.5(c)(6)).
On the other hand, universal waste destination facilities are subject to full biennial
reporting requirements. These facilities are, in general, subject to all of the TSDF
requirements (§273.60).
-Is used oil reported?
Only used oil that exhibits a characteristic of hazardous waste and that is disposed of
must be reported on the Biennial Report. Used oil that is recycled in any manner is not
subject to reporting requirements.
The information in this document is not by any means a complete representation of EPA's regulations or policies,
but is an introduction to the topic used for Hotline training purposes.
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