A question (January 10, 2018):
Hi Daniel,
I have a specific question on the level of detail required for the haz waste report I file for our company on a biannual basis.
We had a lab pack in 2017 so I have a lot more codes than normal and want to understand the appropriate way to report.
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Note: The query contains a slight typographical error that requires clarification. The questioner uses the word “biannual” – meaning twice per year – when the correct word is “biennial” – every two years. The biennial hazardous waste report is required to be submitted by March 1st of every even-numbered year for the hazardous waste managed in the previous (odd-numbered) calendar year. |
My question is how to report labpack info consolidated on a manifest with multiple waste codes.
My concern is for example, the manifest says 60 lbs for an entry with six separate codes (U123, U147, D002, D004, D006, D007) when only ~1 lb (500g bottle) of actual material is formic acid (U123). The rest is ~5 lb other organic acids (D002), arsenic and chromium stds with nitric acid (D004, D007 – 100mL each), etc.
I guess my question is… does this 60 lbs on the manifest need to be broken down for each component with a unique waste code? If so, it would hard to determine how much is accounted for by the overpack container and vermiculite, etc.
Thanks if you can answer!
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Note: Another incorrect use of a word from the regulations could lead to confusion if not clarified. The questioner uses the term “overpack” when the correct term is “lab pack”. Overpack is the consolidation of one or more outer packages of hazardous materials or hazardous waste. A lab pack is the consolidation of inner packagings or receptacles of hazardous waste within an outer packaging. |
I could answer. And I did. (January 15, 2018):
I believe I have an answer to your questions. Please see below.
The answer depends not on the waste codes in the lab pack (e.g., U123, U147, D002, D004, D006, D007) but on their management code. If the separate containers within the lab pack will all be managed in the same way (e.g., incineration), then the management would remain the same for the entire volume of all of the containers in the lab pack.
However, if some of the hazardous waste codes will be incinerated while others within the same lab pack will be landfilled or managed in some other way then you must report the amounts separately.
More information on reporting lab packs is below, taken from the report form instructions.
I hope this helps. Please contact me with any other questions.
From the USEPA website Biennial Hazardous Waste Report Instructions and Form:
Lab packs: Lab packs are containers of multiple smaller containers for transport purposes. The following rules should be applied to the reporting of lab pack wastes in the Hazardous Waste Report:
1) You may aggregate lab pack waste containers in most cases. However, you must report them as separate waste streams under the following conditions:
a) If they contain acute hazardous wastes (EPA Waste Codes F020, F021, F022, F023, F026, F027, and all “P” Waste Codes). Report separately from lab packs containing other hazardous wastes (all other EPA Waste Codes).
b) If they are managed differently from each other. For example, report lab packs that are land filled separately from those that are incinerated.
2) Enter a Form Code indicating lab packs (“W001” or “W004”) in Form GM, Section 1. These Form Codes may be used with any lab pack, whether the wastes are gaseous, liquid, solid, or sludge.
3) It is not necessary to report every EPA Waste Code included in a batch of lab packs if there are more than five waste codes. If there are many EPA Waste Codes enter “LABP” in the first Waste Code field and leave the remaining fields blank. If there are no more than five EPA Waste Codes in a drum/barrel, they should all be listed.
4) Density may be averaged. When reporting quantities for lab packs:
a) Include the weight of the containers if they are disposed (e.g., land filled) or treated (e.g., incinerated) along with the waste.
b) Exclude the weight of the containers if the waste is removed from the containers before treatment or disposal.
5) Source codes for lab packs vary depending on the situation. Review the Source Codes carefully to determine which is most appropriate in your case.
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That was everything he needed:
This is great. Thank you Daniel.
Will contact you if have training opportunities in the future.
Appreciate your time.
Cheers,
Conclusion:
The next biennial hazardous waste report is due March 1st of 2020 for hazardous waste activities conducted in 2019. Your state, if it’s one of the below, requires the report to be submitted annually. And don’t forget, If you’re required to submit the hazardous waste report you are also required to provide annual Hazardous Waste Personnel training.
| USEPA Region | States That Require Annual Reporting |
|---|---|
| 1 | Maine, New Hampshire |
| 2 | New Jersey, New York |
| 3 | Delaware, District of Columbia |
| 4 | Georgia, Kentucky, Mississippi, South Carolina, Tennessee |
| 5 | Illinois, Indiana, Michigan, Minnesota, Wisconsin |
| 6 | Arkansas, Louisiana, Oklahoma, Texas |
| 7 | Kansas, Missouri |
| 8 | Montana |
| 9 | Arizona, California, Guam |
| 10 | Idaho, Oregon, Washington |
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Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste Daniels Training Services, Inc. 815.821.1550 |