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What’s New in the 2009 Biennial Report Forms

Learn about the updates and changes to the Biennial Report Forms in the 2009 edition. Discover new codes and requirements for waste minimization and academic laboratories.

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What’s New in the 2009 Biennial Report Forms

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  1. What’s New in the 2009 Biennial Report Forms Amanda Geldard Jessica Biegelson RCRAInfo Regional Training October 27, 2009

  2. DRAFT

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  4. (We’ll discuss the Labs box more in detail later on.) DRAFT

  5. DRAFT

  6. (We’ll discuss the Site ID Addendum in more detail later on.) DRAFT

  7. GM Form; Box G: Waste Minimization Code Box G was added to collect information regarding waste minimization efforts. This enables cross collaboration among facilities minimizing similar wastes while meeting federal regulatory requirements. DRAFT

  8. What’s New in the Site ID Form and Biennial Report for the Academic Laboratories Rule (Subpart K) Jessica Biegelson EPA ORCR RCRAInfo Regional Training Washington, DC Oct. 27-28, 2009 8

  9. Background • Academic Laboratories Rule • Establishes new Subpart K in Part 262 • The rule is an alternate set of RCRA generator regulations for managing hazardous waste in academic labs owned by eligible academic entities • Generally labs operate under the satellite accumulation area (SAA) regulations • Eligible Academic Entities are: • Colleges and Universities (C/U) • Teaching Hospitals that are either owned by or have a formal written affiliation with a C/U • Non-profit Research Institutes that are either owned by or have a formal written affiliation with a C/U 9

  10. Background • Academic Laboratories Rule is an optional rule • Participants can choose to comply with existing regulations or Academic Laboratories Rule • The rule is deemed “as stringent” as current RCRA generator regulations • States are NOT required to adopt Academic Laboratories Rule • Because the rule is optional, inspectors need to know which set of generator regulations eligible academic entities are using for their laboratories (SAA or Academic Laboratories Rule)

  11. Labs Rule Requires Notification Because inspectors need to know which set of generator regulations a facility is operating under, the Labs Rule require notification In states that adopt rule, eligible academic entities can choose to opt into the Labs Rule for their laboratories Notification is required when eligible academic entity decides to opt into or withdraw from labs rule Proposed Rule: took comment on whether notification should be done by letter or by the Site ID Form (8700-12) Final Rule: require notification by the Site ID Form 11

  12. Labs Rule Notification Requirements Notification requirements include much of the same information already on Site ID Form Examples: site name, location, mailing address (fields 1-10 and 14) New box added Adding a box (letter D) under field 10 to the Site ID Form Eligible academic entities must specify: Whether opting into or withdrawing from Subpart K Type of eligible academic entity 12

  13. If site does not have EPA ID number, when opt into Labs Rule, check: “Provide Initial Notification”   If site has EPA ID number, when opt into or withdraw from Labs Rule, check: “Provide Subsequent Notification” DRAFT 13

  14. Existing Boxes A-C in Field 10 DRAFT 14

  15. If an eligible academic entity is opting into Labs Rule, then they should check box one and indicate what type of entity they are. More than one can apply.     If an eligible academic entity is withdrawing from Labs Rule, then they should check box two. NEW Box D in Field 10 DRAFT 15

  16. Site ID Form Changes are Almost Final Revised form is at OMB now and is expected to be finalized by the end of the year What is happening as eligible academic entities are opting in now? The preamble of the final rule instructs facilities to indicate in the comment box on the Site ID Form that: Opting into Labs Rule-Subpart K Type of eligible academic entity States should be inputting this information into the comment/notes field in RCRAInfo until the new form is finalized Labs Rule can currently be used in Pennsylvania, New Jersey, Wisconsin, South Dakota, tribal areas, many of the territories, with more on the way 16

  17. New Source Code for GM Form Subpart K includes laboratory clean-out incentives which allow a laboratory clean-out once per 12 months per lab: 30 days to conduct the laboratory clean-out Do not count unused acute and characteristic HW towards generator status All routinely generated laboratory HW must be counted toward generator status Because of this distinction between counting routinely generated laboratory HW and not counting laboratory clean-out HW, each type of HW should be reported differently To make this distinction clear for reporting, we created a new Source Code (G17) for “Subpart K laboratory clean-out waste” 17

  18. Using the New Source Code - G17 Because laboratory clean-out waste is not counted toward generator status, it should be reported with a generation quantity of zero with a source code of G17 If a facility generates greater than CESQG volume limits for the month (i.e. 1 kg of acute HW or 100 kg of HW) including laboratory clean-out waste, then this waste including laboratory clean-out waste is still managed as hazardous waste when sent off-site (i.e. manifest and LDRs) regardless if counted toward generator status With Source Code G17, generation quantity is zero, but shipped off-site for management quantity should equal the quantity of laboratory clean-out waste that is shipped off-site as HW For more details on using source code G17, see presentation on What’s Reportable and What’s Not in the BR 18

  19. Contact the ORCR Labs Team Jessica Biegelson Biegelson.Jessica@epa.gov 703-308-0026 Kristin Fitzgerald Fitzgerald.Kristin@epa.gov 703-308-8286 Trish Mercer Mercer.Patricia@epa.gov 703-308-8408 Questions? 19

  20. Appendix to the Site Identification Form: Notification of Hazardous Secondary Material Amanda Geldard RCRAInfo Regional Training October 27, 2009

  21. Why are these changes happening? • Last October, EPA finalized the “Revisions to the Definition of Solid Waste (DSW)” final rule, which excludes certain materials being reclaimed from Subtitle C Regulation. • The federal rule became effective on December 29th. However, the rule does not go into effect in an authorized state unless and until the state is authorized for the rule. • Currently, the rule is effective in: Iowa, Alaska, Pennsylvania, New Jersey, tribal lands and in most of the territories.

  22. Why are these changes happening? • The final rule includes exclusions for hazardous secondary materials… (1) Reclaimed under the control of the generator (2) Transferred to another person for reclamation • Facilities must send a notification prior to operating under these exclusions and by March 1 of every other year thereafter to the Regional Administrator using the Site ID Form.

  23. New Item 12 – Notification of HSM Activity Everyone must answer this question. This item serves as a link to the Addendum to the Site ID form.

  24. New Addendum– Notification of HSM Activity DRAFT Only facilities managing HSM must complete the Addendum. Facilities must be in a state where the DSW rule is effective.

  25. DRAFT

  26. How can we use this information?

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