2009 Biennial Report Training Jarrett Keck ODEQ Land Protection Division

Objectives Purpose of the Biennial Report Parts of the Biennial Report Introduction to EASITRAK electronic reporting Frequently Asked Questions

Purpose of the Biennial Report The Biennial Report information will: Provide the EPA and the States with an understanding of hazardous waste generation and management in the United States. Help the EPA measure the quality of the environment. Inform the public through the publication of the National Biennial RCRA Hazardous Waste Report.

National Biennial RCRA Hazardous Waste Report Consists of three volumes: Volume 1: National Analysis Presents a detailed look at national waste handling practices by region, states, and largest facilities nationally.

Continued: National Biennial RCRA Hazardous Waste Report Volume 2: State Detail Analysis A detailed look at each State’s waste handling practices, including overall totals for generation, management, and shipments and receipts, as well as totals for the largest fifty facilities in each State. Volume 3: List of Reported RCRA Sites Identifies every hazardous waste facility in the United States that submitted a hazardous waste report.

Why does my facility have to file a Biennial Report? 40 CFR 262.41 The authority for the Hazardous Waste Report is contained in Sections 3002 and 3004 of the RCRA of 1976, as amended by the Hazardous and Solid Waste Amendments of 1984 (HSWA).

Who is required to file a Biennial Report? Section 3002 requires large quantity hazardous waste generators to report to the EPA or the authorized States, at least every two years, the quantities, nature, and disposition of generated hazardous waste. Any facility that meets the requirements ( generates MORE than 2200 Lbs. of hazardous waste/month) of a RCRA Large Quantity Generator (LQG) or 2.2 Lbs. acutely hazardous waste (P-listed waste) for at least one calendar month in the odd numbered reporting years (i.e. 2009, 2011 etc.)

Continued… Who is required to file a Biennial Report? Section 3004, requires reporting to the EPA by treatment, storage, and disposal facilities for the waste they receive. Any facility that treated, stored, or disposed (TSD’s) of RCRA hazardous wastes on site for at least one calendar month in the odd numbered reporting years.

Continued… Who is required to file a Biennial Report? TSD facilities, which are undergoing closure or with a post-closure permit, must complete the Biennial Report Form until the 30-year post-closure period is completed. Facilities undergoing clean closure under RCRA must submit this report until certification of clean closure is received and certified by the DEQ.

What do I need to include in the Biennial Report? Hazardous Waste(HW) that was: Generated and accumulated on site during 2009, even if it’s not shipped off site until 2010; OR…..

Continued…. What do I need to include in the Biennial Report? HW generated and accumulated on site in 2008 but not shipped off site until 2009; or HW imported from a foreign country in a reporting year (2009). Any hazardous waste generated and accumulated on-site and/or waste shipped off site in 2009 (odd numbered year) must be reported.

Is there anything that I do not include on the Biennial Report? DO NOT include Materials and wastes addressed under 40 CFR 261.4(a) and (b) and 261.5(c). Examples: Do not include materials which are excluded from being a solid waste (products) Do not include solid wastes that are excluded from being hazardous waste (non-hazardous waste) Do not include Universal Waste

Continued: Materials which should not be included Do not include Spent lead-acid batteries (universal waste) Any hazardous wastes generated during battery reclamation must be reported on Form GM Do not include PCB wastes unless mixed with a hazardous waste (universal waste) Do not include Samples undergoing treatability studies Do not include Hazardous waste that has been collected as a sample for the purpose of determining its characteristic or composition Do not include Scrap Metal Do not include Used Oil

When are the Biennial Reports due? Biennial Reports must be submitted electronically or hardcopy to the DEQ's Biennial Report representative by March 1st of 2010. (or April 1st if an extension is granted) A 30-day extension can be granted by the ODEQ on a case by case basis making April 1st of 2010 the latest a Biennial Report can be accepted.

Where do I file the Biennial Report? Electronic reporting using EASITRAK is the preferred method for submitting the Biennial Report (easy, step-by-step, data entry and cross-checks for mistakes). 2009 version will be accessible late December 2009 Biennial Reporting software found at the “Easitrak” web page: http://www.arminc.net Easitrak provides easy, free registration for the user, which includes picking a personal password.

Parts of the Biennial Report: RCRA Subtitle C Site Identification Form EASITRAK USERS :A hardcopy of this form with signature MUST be mailed to DEQ in addition to electronic filing. GM Form (Waste Generation and Management) Separate form for each waste stream generated WR Form (Waste Received from Off Site) Separate form for each waste stream received OI Form (Off-Site Identification) This form is NOT required for the State of Oklahoma

Information NOT Required on the Oklahoma Biennial Report Eligible Academic Entities with Laboratories—Notification for opting into or withdrawing from managing laboratory hazardous wastes pursuant to 40 CFR Part 262 Subpart K 40 CFR Part 262 Subpart K Has NOT been adopted by Oklahoma DEQ Waste Codes for State-Regulated (i.e., non-Federal) Hazardous Wastes. Oklahoma does NOT have State-specific waste codes. Notification of Hazardous Secondary Material (HSM) Activity managing hazardous secondary material under 40 CFR 261.2(a)(2)(ii), 40 CFR 261.4(a)(23), (24), or (25) Oklahoma has NOT adopted these rules. DISREGARD THESE SECTIONS IN THE BIENNIAL REPORT

Using Easitrak 2009 Biennial Reporting Software Introduction to Using Easitrak 2009 Biennial Reporting Software (2009 version will be accessible late December 2009) http://www.arminc.net

Using Easitrak The EPA made considerable changes in SI forms this year. Be sure to you visit the EASITRAK documentation page for supporting documentation.  If you were an EASITRAK user in 2007 or 2008 versions, your site information will automatically transferred to the 2009 version for minimizing your data entry.  However, you still need to correct and complete all required SI forms.  

Using Easitrack Easitrak instructions are found both at the Easitrak website and the DEQ website: http://www.arminc.net (Easitrack electronic reporting instructions) Technical questions made to Easitrak via email at: info@arminc.net Or http://www.deq.state.ok.us/lpdnew/forms/indexhazforms.html

Easitrak Features Certification Letter Generator signs and mails into state after submitting. Date and Time Stamp Once the “submit to state” button is pressed a date a time stamp will be put on the SI form, all GM forms and the Certification Letter Step-by-step data entry , Drop down selection menus, Error checks at each step Save and return anytime prior to final submittal

Easitrak continued: What do I mail in to the State? Mail in the completed 3-page Site Identification Form With hand written signature on the third page Mail in the Certification Form GM forms and WR forms do not need to be mailed in. Please note: each GM (Waste Generation and Management) Form, make note of the stream number from your disposal plan.

Making Changes after Submitting theEasitrak Report If you find errors in your report after electronically submitting using Easitrak: Contact DEQ representative, Jarrett Keck (405) 701- 5219 or jarrett.keck@deq.ok.gov The DEQ representative can unlock your submittal for further editing and resubmission.

RCRA Subtitle C Site Identification Form (hardcopy version)

Reason for Submitting the Form Hazardous Waste Report Site’s EPA Identification Number Name of Site Physical Location of Site Physical Address Only Not a P.O. Box

Land Type of Site NAICS code(s) for site Use the 6 or 5 digit codes Do not enter any 4 or less digit codes A list of acceptable codes is on the internet: www.naics.com/search.h tm www.census.gov/naics/ 2007/index.html SIC Code / NAICS Code Cross Reference Database www.siccode.com/naics earch.php

Mailing Address for your Site Name and Phone Number of Contact Person at your Site Names of the Operator(s) and the Legal owner(s) of you Site

Your Site’s Regulated Waste Activities

Description of Hazardous Waste Additional Comments Certification / Handwritten Signature

GM Form (Waste Generation and Management)

Divided into three sections “GM” Form Continued… Divided into three sections The source, characteristics, and quantity of hazardous waste generated The quantity of hazardous waste managed on site and the Management Method used The quantity of hazardous waste shipped off site for treatment, disposal, or recycling and the Management Method used One form must be filled out for each hazardous waste stream generated

Section 1 A. Waste Description Provide a short narrative description of the waste General type, source, type of hazard; and/or generic chemical name or primary hazardous constituents. B. EPA hazardous waste codes C. State hazardous waste codes Not applicable

F. Quantity generated in reporting year D. Source Code Enter the code that best describes how the hazardous waste was generated E. Form Code Enter the code the best corresponds to the physical form or chemical composition of the hazardous waste reported (ash, sludge etc..) F. Quantity generated in reporting year

G. Units of Measure Note: if you select a volumetric measure (gallons, liters, or cubic yards), you must also report the density of the waste Density is reported in either pounds per gallon (lbs/gal) or specific gravity (sg) *note – conversions will be automatic if filed electronically)

1 Pounds 2 Short Ton (2,000 lbs) 3 Kilograms 4 Metric tons (1,000 kg) Code Unit of Measure 1 Pounds 2 Short Ton (2,000 lbs) 3 Kilograms 4 Metric tons (1,000 kg) 5 Gallons 6 Liters 7 Cubic yards

Weight and Volume Conversions (automatically converted if filed electronically via Easitrak 1 kilogram (kg) = 2.2046 pounds (lbs) 1 short ton = 2,000 lbs 1 metric ton = 1,000 kg 1.1023 short tons 1 cubic meter = 1.3079 cubic yards 1 cubic yard = 27 cubic feet 1 liter = 0.2642 gallons

Section 2 (on-site generation and management) Was any of this waste managed on site? If yes, fill out onsite Management Code and the Quantity disposed, treated, or recycled on site only during the reporting year.

Section 3 (off-site Shipment of Hazardous Waste) Was any of this waste shipped off site for treatment, disposal, or recycling? If yes, fill out the EPA ID # of facility to which waste was shipped, off-site Management Method Code, and total quantity shipped during reporting year.

The amounts in Sections 2 and 3 should equal the total of quarterly report amounts Comments Section This section can be used for additional room for the waste description, etc. Please note which “block” is being continued. This is also a good place on Form GM to write the stream number from your disposal plan

WR Form (Waste Received from Off Site)

Form WR Fill out one form per facility from which you have received waste Can use more than one page if needed Form WR is divided into three identical parts (i.e. waste blocks), labeled Waste 1, Waste 2, Waste 3 (each individual waste stream).

Each waste block requires the same information A. Description of hazardous waste B. EPA hazardous waste codes C. State hazardous waste codes Not applicable D. Off-site handler EPA ID #

E. Quantity received in reporting year F. Unit of Measure Report density if using a volumetric measurement G. Form Code (lab- pack, ash, sludge, etc…) H. Management Method code

FAQ What happens if we’re late in turning them in? An NOV is issued to your facility and could possibly lead to fines. If a facility receives waste from another facility, do they have to include the extra waste in their biennial report? Yes, the Form WR will need to be filled out.

FAQ Continued If a waste stream is recycled, does it have to be counted on the biennial report? Yes, unless the material and/or wastes are addressed under 40 CFR 261.4(a) and (b) and 261.5(c). Does waste that is treated on-site and becomes non-hazardous, have to be included on the biennial report? Yes, it will be reported in Section 2 of Form GM.

Can the report be emailed to the DEQ? Faxed? Ans: Electronic or Mail FAQ Continued Can the report be emailed to the DEQ? Faxed? Ans: Electronic or Mail Submitting the report electronically via Easitrak is the preferred method. Emails or faxes are not acceptable. Regardless of how the report is submitted, the Site ID form (3 page form) MUST be mailed in to the DEQ. If the information we send turns out to be incorrect for some reason, can we retroactively correct it? Yes, if the report is submitted electronically, the State Biennial Report Representative (Jarrett Keck - jarrett.keck@deq.ok.gov or call 405-702-5219) can unlock the report giving you access to make corrections as needed.

Upcoming Information 2009 Hazardous Waste Report Instructions and Forms from EPA (hardcopy version) www.epa.gov/epaoswer/hazwaste/data/biennialreport/index.htm The Easitrak web page will be noted on the cover letter for the DEQ Biennial Report Notification mailing, November 2009.

Additional questions? Please contact: Jarrett Keck (405) 702-5219 or jarrett.keck@deq.ok.gov or Al Coulter (405) 702-5189 al.coulter@deq.ok.gov Easitrak electronic reporting instructions and technical questions can be found at: (http://www.arminc.net (login is required)