1. 2009 Biennial Report Training
Jarrett Keck
ODEQ
Land Protection Division

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

3. 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.

4. 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.

5. 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.

6. Why does my facility have to file a Biennial Report?
40 CFR
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 (HSWA).

7. 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.)

8. 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.

9. 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.

10. 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…..

11. Continued…. What do I need to include in the Biennial Report?
HW generated and accumulated on site in 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.

12. 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 (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

13. 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

14. 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 (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 the latest a Biennial Report can be accepted.

15. 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:
Easitrak provides easy, free registration for the user, which includes picking a personal password.

16. 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

17. 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 (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

18. Using Easitrak 2009 Biennial Reporting Software
Introduction to
Using Easitrak Biennial Reporting Software
(2009 version will be accessible late December 2009)

19. 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 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.  

20. Using Easitrack
Easitrak instructions are found both at the Easitrak website and the DEQ website:
(Easitrack electronic reporting instructions)
Technical questions made to Easitrak via at: Or

21. 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

22. 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.

23. Making Changes after Submitting theEasitrak Report
If you find errors in your report after electronically submitting using Easitrak:
Contact DEQ representative, Jarrett Keck (405) or
The DEQ representative can unlock your submittal for further editing and resubmission.

24. RCRA Subtitle C Site Identification Form (hardcopy version)

25. 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

26. 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: tm
2007/index.html
SIC Code / NAICS Code Cross Reference Database
earch.php

27. 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

28. Your Site’s Regulated Waste Activities

29. Description of Hazardous Waste
Additional Comments
Certification / Handwritten Signature

30. GM Form (Waste Generation and Management)

31. 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

32. 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

33. 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

34. 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)

35. 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

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

37. 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.

38. 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.

39. 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

40. WR Form (Waste Received from Off Site)

41. 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).

42. 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 #

43. 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

44. 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.

45. 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 (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.

46. Can the report be emailed to the DEQ? Faxed? Ans: Electronic or Mail
FAQ Continued
Can the report be ed to the DEQ? Faxed? Ans: Electronic or Mail
Submitting the report electronically via Easitrak is the preferred method. s 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 - or call ) can unlock the report giving you access to make corrections as needed.

47. Upcoming Information
2009 Hazardous Waste Report Instructions and Forms from EPA (hardcopy version)
The Easitrak web page will be noted on the cover letter for the DEQ Biennial Report Notification mailing, November 2009.

48. Additional questions? Please contact: Jarrett Keck (405) or or Al Coulter (405) Easitrak electronic reporting instructions and technical questions can be found at: ( (login is required)