If your facility was registered as a Large Quantity Generator (LQG) of hazardous waste at any time during calendar year 2015, remember that 2016 is a reporting year for Biennial Reports. Treatment, Storage, or Disposal Facilities (TSDFs) are also required to file biennial reports by March 1st of each even-numbered year.
Biennial Reports are required to be submitted electronically, and MA DEP highly encourages the use of Florida DEP’s BRState software. A signed copy of EPA Form 8700-12 and a disk or CD containing the exported forms must be submitted by March 1st, 2016. Incomplete submittals, scanned copies of original print outs, invalid formats, or other deficient submittals are considered administratively incomplete, and can result in Administrative Penalties of up to $1000 per day!
If a facility was registered as a LQG at any point during the 2015 calendar year, a Biennial Report must be filed, even if the facility is now registered as a Small Quantity Generator or no longer registered with the MA DEP and EPA at all. If a facility registered as an LQG in 2016, but did not exceed SQG thresholds during 2015, a letter certifying that the facility was not a LQG at any point during 2015 must be submitted.
If the Biennial Report was not on your radar, it’s time to get started on preparing this required report.