Annual Hazardous Waste Reports Due March 1st

It’s that time of year again to submit your Annual Hazardous Waste Report to the New York State Department of Conservation (NYSDEC). Each calendar year, a Hazardous Waste Report must be submitted by Large Quantity Generators (LQGs) and treatment, storage and/or disposal facilities in New York State.

Annual Hazardous Waste Reports

Who needs to file?

Generators of hazardous wastes and facilities that handle hazardous wastes are required to submit an Annual Report if any one of the following criteria applies:

  • Met the definition, as presented below, of a Large Quantity Generator (LQG) at any time during the previous year; or
  • Treated, stored or disposed of hazardous waste on-site during the previous calendar year; or
  • Generated 15 tons or greater of hazardous waste or hazardous wastewater. Only universal waste is exempt from this requirement. No other exemptions or exclusions to annual hazardous waste reporting can be applied when calculating this tonnage.

Large Quantity Generator (LQG) Definition:  A site that generated 1,000 kg (2,200 lbs.) or more of hazardous waste in any single calendar month; or accumulated at any time more than 1 kg (2.2 lbs.) of acute hazardous waste in any single calendar month; or generated more than 100 kg (220 lbs.) of spill clean-up material contaminated with acute hazardous waste in any single calendar month. The Annual Hazardous Waste Report is required under 6 NYCRR (New York Codes, Rules and Regulations) Parts 372, 373 and 483. It also satisfies United States Environmental Protection Agency (USEPA) requirements and federal provisions in Sections 3002 and 3007 of the Resource Conservation and Recovery Act of 1976 (RCRA), as amended by the Hazardous and Solid Waste Amendments of 1984 (HSWA).

Annual Hazardous Waste Reports

Annual Report Changes for the 2020 Reporting Year Include:

Site Identification (SI) Form

The Site Identification form has changed significantly due to the revised RCRA Hazardous Waste Regulations. The updated SI form is now similar to USEPA’s RCRA Subtitle C Activities form.  Mixed waste was removed from the SI form and added to the GM form for each waste stream.  Other SI form changes relate to the following items:

Item 1, Reason for Submittal

Item 6, Site Land Type

Item 7, North American Industry Classification System (NAICS) Codes: All filers should confirm that they are using the 2017 NAICS codes in their annual report.

Item 10, Type of Regulated Waste Activity (at your site): If waste is generated as a result of a one-time, non-reoccurring, temporary event, the Short-Term Generator box should be checked, and relevant comments provided in the short-term generator field.

Item 11, Additional Regulated Waste Activities

Item 12, Eligible Academic Entities with Laboratories

Item 15, Notification of LQG Site Closure for a Central Accumulation Area (CAA) (optional) OR Entire Facility (required): Notification is required for: generators storing liquid hazardous waste over sole source aquifers; and if a facility as a whole is closing.

Generation & Management (GM) Form

Changes to the GM form include the following:

Source Codes

Some old codes were removed, and some were added. Editorial changes were made to the description of some source codes in order to improve clarity for filers.

Form Codes

A new code was added for Airbag waste (W006).

Waste Minimization Codes

The waste minimization codes were revised to assist filers with reporting their waste minimization activities. New waste minimization codes identify when waste minimization activities occurred (whether initiated prior to the reporting year or during the reporting year) and also provide examples of the types of waste minimization activities.

Management Method Codes (MMC)

Four new management method codes (MMC) were added:

  • H011 – Mercury recovery
  • H015 – Deployment/deactivation of airbag waste followed by metals recovery
  • H041 – Open burning/open detonation
  • H090 – Polymerization

Filing

As of January 2021, the vendor that previously supported electronic reporting for hazardous waste annual reports for DEC has ceased operation. DEC will be transitioning to EPA’s RCRAInfo system for electronic submissions of hazardous waste annual reports.

Need assistance with filing? Walden is experienced in guiding clients through the Hazardous Waste Reports and can help your facility stay in compliance with the NYSDEC hazardous waste reporting requirements. If you have any questions or concerns with the new forms, please call one of our Solid Waste engineers on staff at 516-586-0533.                                    

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