It’s Not Too Early to Begin Planning for 2015 RCRA Hazardous Waste Biennial Reporting

By John Handzo

Now is a good time to prepare for the 2015 RCRA hazardous waste reporting year (also known as the RCRA Biennial Generator Report).  All facilities that generate 2,200 or more pounds of hazardous waste, or 2.2 or more pounds of acutely hazardous waste, in any calendar month during 2015 will be required to complete a Biennial Generator Report in early 2016.  A one-time clean-up, spill, or malfunction of equipment can result in the generation of more than 2,200 pounds of hazardous waste, or more than 2.2 pounds of acutely hazardous waste, in a calendar month.  Just one such event can subject a facility to Biennial Generator Reporting requirements; the current registered generator status of a facility (large quantity generator, small quantity generator, or conditionally-exempt small quantity generator) is not the determining factor.

The Nevada Business Environmental Program (BEP) recommends that facilities develop a waste minimization strategy to remain below the reporting thresholds.  For those facilities that are unable to stay below the regulatory reporting thresholds, however, the use of a tracking calendar is an easy and convenient tool that will come in handy when reports are due in early 2016.  The Nevada BEP offers a free and downloadable calendar just for this purpose.

Look for announcements in late 2015 for our next round of training on Biennial Generator Reporting.  In the meantime, to develop waste management and minimization strategies for 2015 that can keep your facility under the large quantity generator reporting threshold, thus saving valuable time and effort, contact the Nevada BEP toll free at 1.800.882.3233 to request a free and confidential site assessment by our team of experts.