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My Watershed

Frequently Asked Annual Reporting Questions

Site Identification (Site ID form) questions:

  1. I didn't generate regulated waste during Reporting Year.
  2. I had a one-time disposal of someone else’s waste.
  3. How do I decide which NAICS codes to use on my Annual Report?
  4. I sold my business during Reporting Year.
  5. How can I find out my Generator Status?
  6. How do I report my waste in accumulation at year end?
  7. Should I check the TSD or R box if I store (or recycle, or treat) waste on site?
  8. What should I put in Section 10, “Waste Management Activities”?

Generation and Management  (GM form) questions:

  1. I can’t find the Management Method Code on the manifest.
  2. Why can’t I use the D.O.T. waste description?

Off-site Identification (OI form) questions:

  1. Where can I find the RCRA Site ID number for a transporter?
  2. How do I list the RCRA Site ID number for a foreign company?

Waste Received (WR form) questions:

  1. How do I report waste regulated only in another state?

Site Identification (Site ID form) questions:

  1. I didn't generate regulated waste during Reporting Year. Do I still have to fill out the report?

Yes, all sites with an active RCRA Site ID number are required to report to Ecology with an Annual Report.

  • If you want to keep your RCRA Site ID number active (in case you do generate regulated amounts of waste again in the future), check "No Waste Generated" in Section 10.A.1 on the back of the Site ID Form.
  • If you want to withdraw your RCRA ID number
    • Check the "Withdraw" box in Section 1 of the Site ID Form, enter the effective date of the withdrawal.
    • Annual reports for the years your RCRA Site ID number was active must be filed before the number can be withdrawn.

    Your RCRA Site ID number can be re-activated anytime by submitting a reactivate Site Identification form to Ecology.

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    2.   I had a one-time disposal of someone else’s waste. I’m not a HW generator. Why is it my responsibility to fill out an Annual Report?

    Both State and Federal government consider property owners to be ultimately responsible for waste left on their property. Property owners who have waste disputes with tenants can seek relief through their rental or lease contracts and the legal system. If waste was left on your property by a unknown dumper there may be some financial assistance through your county. For example, Thurston County has a program to pay for hauling abandoned vehicles to a wrecking yard. If you are a contractor your customer is responsible for the proper disposal of waste that you generate. However, contractors are responsible for managing the waste safely until it is disposed.

    Annual reporting for “one-time-only” disposal has the same requirements as any other situation.

    • Small Quantity Generators only complete the Site Identification form (Site ID).
    • Medium or Large Quantity Generators complete the Site Identification form, a Generation & Management form (GM) for each waste stream generated, and an Off-site Identification Information form (OI) listing all Transporters and Treatment, Storage, Disposal, or Recycling facilities that handled the waste.
    • To withdraw your RCRA Site ID number, check "Withdraw" in Section 1 at the top of your Site Identification form and enter the effective date your dangerous waste activities stopped. Your RCRA Site ID number will remain active until the required Site ID form has been received and processed, and all annual reporting requirements have been satisfied.

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    3.  How do I decide which NAICS codes to use on my Annual Report? Several codes seem to apply to my business.

    A business may generate dangerous wastes from maintenance activities, as well as multiple production processes. Use the NAICS code that corresponds to your major business activity (for example manufacturing paint), rather than just your waste activity.

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    4.  I sold my business during the Reporting Year The report was sent to me. Do I fill out the report or does it go to the new owner?

    Fill out the Annual Report forms for the period of time you owned the business.

    • In Section 1, for "Effective Date", enter the date the business was sold.
    • Check "Withdraw" in Section 1 at the top of your Site Identification form
    • Enter your own information for the "Forms Contact" in Section 9 so Ecology can contact you for information about the annual report.

    Important!  You need to withdraw the RCRA Site ID number for your business. Your RCRA Site ID number will remain active until the Site ID form has been received and processed, and all annual reporting requirements have been satisfied.

    The new owner needs to file a new Site Identification, Notification of Dangerous Waste Activity form to reactive the RCRA Site ID # for their company.

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    5.  How can I find out my Generator Status?

    Generator status is determined by how many pounds of Dangerous Waste you generate each month and how much you accumulate on-site before shipping it off-site. First you need to assemble the following records:

    1. Your waste manifests for Reporting Year.
    2. Waste profiles or test results.
    3. Any logs or records of dangerous waste generation, accumulation on-site or other waste management activities.
    4. See the Dangerous Waste Generator Status Table

    Then, organize the records by month:

    • Sort the documents by month so that you can tell what and how much you generated and how much you accumulated on site each month.
    • Each dangerous waste that you generated in Reporting Year had one or more waste codes such as "D001". Each waste code has a Quantity Exclusion Limit (QEL) of 2.2 pounds or 220 pounds. For example, the QEL for "D001" is 220 pounds per month. You can look up the QEL for each of your wastes on the Quantity Exclusion Limit (QEL) chart.
    • Do not count wastes that do not need to be reported. See How do I count my wastes for my annual report?
    • For each month that you generated dangerous waste add up the total pounds of waste with a 220 pound QEL and the total pounds of waste with a 2.2 pound QEL. (Note: Many generators do not have 2.2 pound QEL waste.)
    • For annual reporting purposes, use the month with the greatest generator status for your reporting basis for the year.
    • For regulatory compliance purposes you need to know your generator status each month, as it might fluctuate throughout the year.

    Next, you have two options:

    1. Call your regional office and ask for help from an Environmental Specialist.  Phone numbers for the regional staff help are on the Annual Reporting Contact Phone Numbers page in this web site.
    2. Or, you can follow the directions below:

    Important! if you generated 2.2 or more pounds of a waste with a WT01 waste code in any given month, you became a Large Quantity Generator (LQG) that month!

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    6. How do I report my waste in accumulation at year end?

    Do not report it.

    Waste in accumulation areas is counted toward your generator status - see Question 5 above, but will not be reported until the following year when it is managed.

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    7.  Should I check the TSD or R box if I store (or recycle, or treat) waste on site?

    Only if you have a final or interim Part A or Part B permit from the Department of Ecology's Permit Section or you recycle wastes received from off site, or if you recycle precious metals.

    Companies with Part A or Part B permits receive dangerous waste from off-site customers or they are large companies that manage some of their own waste on-site.

    The following activities are not TSDR management:

    • Treatment by generator activities such as waste neutralization. You notify Ecology that you do treatment by generator but you do not receive a permit in return.
    • Permit by rule waste water discharge to your local waste-water treatment plant. The permit comes from the Waste-water Authority.
    • Temporary storage of regulated wastes in an accumulation area before it is moved off-site for management.
    • On-site stills and parts washers.

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    8.  What should I put in Section 10, “Waste Management Activities”?

    Check boxes only if they apply to your site. Most of these activities do not apply to companies that only generate dangerous waste and send it off-site for management.

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    Generation and Management (GM form) questions:

    9.  I can’t find the Management Method Code on the manifest.

    They are on the Uniform Hazardous Waste Manifest in Box 19.

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    10.  Why can’t I use the D.O.T. waste description? The description “flammable liquid, organic, N.O.S” listed on my Uniform Hazardous Waste Manifest looks like it describes my waste.

    Department of Transportation hazardous class name descriptions are not usable for determining recycling credits or describing wastes. Ecology needs a more recognizable description such as “used paint”; “parts washer solvents”; etc. to review your report.

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    Off-site Identification (OI form) questions:

    11.  Where can I find the RCRA Site ID number for a transporter? I can't read it on my copy of the manifest.

    1. Look for the transporters phone number on your paperwork or bill and call their office.
    2. Call the waste broker or receiving facility and ask them.
    3. Check the EPA's RCRAInfo Queries web site for RCRA ID numbers and site information at  http://www.epa.gov/enviro/html/rcris/rcris_query_java.html . You will need some identifying information such as the company name and address to search.

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    12.  How do I list the RCRA Site ID number for a foreign company?

    • Use the letters "FC" for Foreign Country, followed by the country name. Add a sequence number if you have more than one foreign waste handler from that country.

    For example, if you sent waste to the Safety Kleen facility in in British Columbia, Canada and you also used a Canadian transporter with a different company:

    • FCCanada1 for the Safety Kleen facility, and
    • FCCanada2 for the Canadian transporter

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    Waste Received (WR form) questions:

    13.  How do I report waste regulated only in another state?

    Designate any waste brought into Washington State for Washington State dangerous waste codes.

    • If the waste does not designate in Washington and it does not have any federal waste codes, leave it off your Annual Report.
    • If any federal waste codes such as "D001" apply to the waste, you enter them in Section 3 and report the waste.

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