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Recurrent or Non-Recurrent Waste Reporting Changes:

TurboWaste.Net was updated at the end of December, 2009, with a new validation feature to improve reporting of waste streams as recurrent or non-recurrent. There are no changes to annual reporting guidelines.

The validation feature compares the annual reporting waste Source Code in Box A-7 to the Origin Code in Box A-9 on each Generation and Management (GM) form.

• If the Source Code shows the waste was generated by a recurrent process, the Origin Code needs to show the waste was recurrent.
• If the Source Code shows the waste was generated by a non-recurrent process, the Origin Code needs to be non-recurrent.

Generally, waste from processes is recurrent and waste from remediation or site clean-ups is non-recurrent. Some wastes can be either recurrent or non-recurrent. For details see Recurrent or Non-Recurrent Waste.

What is affected?

• Waste reported on Generation and Management (GM) forms.
• During 2010, the new feature affects annual reporters who pre-file a 2010 Annual Report with GM form waste streams. This would happen if the site is withdrawing a RCRA Site ID number in 2010.
• The new feature will affect other annual reporters in 2011, when 2010 Annual Reports will be filed at the normal time.

What is not affected?

• Site Identification forms or Off-site Information forms
• Waste Received forms.
• GM forms filed for 2009 or earlier if they are amended or updated.

The new validation feature in TurboWaste.Net will result in some confusion and questions, but will reduce the number of annual reports that need to be corrected and re-submitted and will improve waste measurement in Washington State.