1. What is the Hazardous Waste Report?
The Hazardous Waste Report, commonly referred to as the “Biennial Report”, is a mechanism for the collection of information from hazardous waste generators and hazardous waste treatment, storage or disposal (TSD) facilities. The report describes each hazardous waste generated, the activity by which the wastes are generated and the waste quantity. The report also lists the management method by which each waste is treated, recycled or disposed and the quantity managed. The Hazardous Waste Report data can be used by federal and state agencies for planning and developing regulations and compliance monitoring and enforcement activities.
2. Who is required to file a Hazardous Waste Report?
Title 128-Nebraska Hazardous Waste Regulations requires anyone subject to the requirements for large quantity generators (generates more than 1,000 kilograms (2,200 pounds) of hazardous waste per month) at any time during a calendar year and/or facilities that treat, store or dispose of hazardous waste to prepare and submit to the Nebraska Department of Environmental Quality (NDEQ) by March 1 of each even numbered year a Hazardous Waste Report for the reporting cycle.
3. Are short-term and episodic large quantity generators required to file a Hazardous Waste Report?
Yes. All short term (one-time) and episodic large quantity generators are subject to reporting requirements. An episodic generator must report the total amount of hazardous waste generated for the entire calendar year and not just for the month(s) they were a large quantity generator (LQG).
4. Do I need to file a Hazardous Waste Report if my facility was not a large quantity generator in 2017?
No. However, you must re-notify the Department of a change in your generator status by completing and submitting a RCRA Subtitle C Site Identification Form 8700-12 (Site ID form). Mark the box “Obtaining or updating an EPA ID number …” under Section 1 Reason for Submittal of the Site ID form and report your current hazardous waste generator status in Section 10A1. Note in Section 18 Comments that you are not required to submit the Hazardous Waste Report for the 2017 reporting cycle and state the reason for same. When entering information in the Comments Section, enter the section number and box number/letter to which the comment refers.
There are two options for notifying the NDEQ of your regulated waste activity using the Site ID form - electronic and paper-based. Subsequent notifications updating site identification information can now be submitted online using myRCRAid, a component of the RCRAInfo Industry Application developed by the U.S. Environmental Protection Agency (EPA). The paper-based RCRA Subtitle C reporting forms are screen fillable. To complete the form on-screen, you must have either the full Adobe Acrobat or Adobe Acrobat Reader version 4.0 or higher. Instructions for completing and submitting a Site ID form updating facility information can be found on the Department’s website at http://deq.ne.gov/ under Publications and Forms → RCRA Program → Applications and Forms.
NOTE: If your site was not a LQG of hazardous waste in 2017, but you wish to retain your status (i.e., decline to re-notify of your current generator status) and comply with all hazardous waste requirements of a higher generator status, you must file a Hazardous Waste Report for the total quantity of hazardous waste generated during the reporting year.
5. How do I file a Hazardous Waste Report with the NDEQ?
For the 2017 reporting cycle, the NDEQ is once again requiring use of the American Resource Management (ARM) EasiTrak hazardous waste reporting software. EasiTrak is a web-based program available on ARM’s secure website and can be accessed from a PC using Microsoft Internet Explorer. There is no cost to use the software and no downloading of software is needed.
To access the web-based software go to www.arminc.net * and select EasiTrak 2017. Before you start, make sure your pop-up blocker is turned off. Whether you used EasiTrak in 2015 or are using EasiTrak for the first time, you must register each year you use EasiTrak. Simply click on “Registration for Generator”, enter the facility NDEQ/EPA ID Number and create your password. Write down your password and your answers to the security questions. Your Login ID will always be the NDEQ/EPA ID Number. If you are filing for multiple sites, you will have to register separately for each facility using the NDEQ/EPA ID Number for each site. If you used EasiTrak in 2015, your site information will be available to transfer to EasiTrak 2017. Make sure the boxes regarding submittal of the Hazardous Waste Report under Section 1 Reason for Submittal of the Site ID form are marked.
The report does not have to be completed in one login session. You may save your work, close and re-enter EasiTrak to edit data and/or complete the report. If you have already registered for 2017 and need to continue working, enter your NDEQ/EPA ID Number and your password under “Log in to Access the EasiTrak 2017”. Do not use the "back" or "forward" buttons on your browser tool bar when you are going back or forward to a page. Also, when doing any data entry, do not use carriage returns (i.e., do not hit the "enter" key to start a new line). The EasiTrak software auto word wraps. If you are going to leave EasiTrak, click the “Logout” button. Once you have completed the report, the EasiTrak reporting software will check/validate your data prior to submittal.
For further information and assistance regarding use of the EasiTrak reporting software you may contact Jeff Waites with American Resource Management at email@example.com.*
6. Can I update site information required on the Site ID form at the time of submittal of the Hazardous Waste Report?
Yes. It is important to notify of changes to facility name, address, site contact, owner/operator or any other changes to required data that have occurred since submittal of your last Site ID form. Please enter information describing the changes in Section 18 Comments of Site ID form. When entering information in the Comments Section, enter the section number and box number/letter to which the comment refers.
7. Does the NDEQ require completion of all sections of the Site ID Form?
No. There are differences between EPA and NDEQ regulations and therefore some sections of the Site ID form do not require completion. These sections include:
- Section 10C – Waste Codes for State Regulated (non-Federal) HazardousWastes
- Section 11C - Used Oil Activities
Section 12 – Eligible Academic Entities with Laboratories
Section 13 – Episodic Generation
Section 14 – LQG Consolidation of VSQG Waste
Section 15 – Notification of LQG Site Closure for a Central Accumulation (CAA) OR Entire Facility
- Used Oil Transporter
- Used Oil Processor and/or Re-refiner
8. Does the NDEQ require completion of the Off-Site Identification (OI) Form?
9. Should universal waste be reported?
10. Who is required to sign the Site ID form Certification?
11. When is the deadline to file the Hazardous Waste Report?
The Certification must be signed by the owner(s), operator(s), responsible official(s), or authorized representative(s) of a facility that is subject to the hazardous waste reporting requirements. An "authorized representative" is a person responsible for the overall operation of the site (e.g., plant manager or superintendent, or a person of equal responsibility).
If you are a consultant and/or other representative completing the 2017 Hazardous Waste Report on behalf of a client, the NDEQ requires submittal of written verification from the client delegating responsibility as an authorized representative for purposes of certification.
A signed copy of the EasiTrak Declaration of Electronic Filing must be received by the NDEQ by March 1, 2018 or postmarked no later than March 1, 2018. Submit the Declaration of Electronic Filing to the NDEQ at the following address:
Nebraska Department of Environmental Quality
Waste Management Section
1200 N Street
Suite 400, The Atrium
Lincoln, NE 68509-8922
12. What if I can’t meet the March 1, 2018 deadline?
If you are unable to submit the form by March 1, 2018, you may request an extension. Your request for an extension must be made in writing and sent to the NDEQ at the address listed above; must state the reason for which the extension is requested; and must state the amount of additional time required to file the report. All requests for an extension of deadlines will expire on April 1, 2018.
13. Does submittal of the Hazardous Waste Report to the NDEQ satisfy the requirement to send the report to EPA?
14. Does Nebraska require annual reporting?
Yes. Nebraska is an authorized state. Facilities are required to send the Hazardous Waste Report to the NDEQ. The NDEQ will then compile all the reports and translate the information into EPA’s RCRAInfo database.
No. Nebraska does not have a RCRA annual report requirement.
15. Are there any fees required for filing the Hazardous Waste Report?
There are no fees required for filing the Hazardous Waste Report. However, failure to comply with Federal and State regulations regarding Hazardous Waste Reports may result in fines and penalties.
16. What documents are helpful in filling out the forms?
To prepare the 2017 Hazardous Waste Report, you should consult your records on quantities and types of hazardous waste that your site generated, managed, shipped or received in 2017. Some records that may be helpful include:
- Hazardous Waste Report forms submitted in previous years.
- Records of quantities of hazardous waste generated or accumulated onsite including results of laboratory analysis of your waste.
- Invoices related to waste management and contracts or tolling agreements with off-site facilities managing your wastes.
- Hazardous waste manifests.
For reference, the U.S. Environmental Protection Agency has prepared a booklet for hazardous waste generators and for facilities that treat, store, or dispose hazardous waste to report their hazardous waste activities for calendar year 2017. The 2017 Hazardous Waste Report Instructions and Forms (8700-13(A/B)) may be viewed at https://rcrainfo.epa.gov/rcrainfoweb/action/main-menu/view *
If you have any other questions, please contact the NDEQ at (402) 471-4210.
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