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By March 1 of each year, certain hazardous waste generators and facilities are required by law to submit a report to the Wisconsin Department of Natural Resources (DNR) outlining hazardous waste generation and treatment activities conducted in the previous year. Entities that are required to report include:
- Small quantity generators (SQGs) and large quantity generators (LQGs)
- Licensed treatment, storage or disposal (TSD) facilities
- Permanent household hazardous waste (HHW) and very small quantity generator (VSQG) collection facilities
- Publicly owned wastewater treatment works (POTWs)
Reminder: If a facility was a large or small quantity generator for at least one month during a calendar year they are required to submit an annual report per s. NR 662.041, Wis. Adm. Code. This does not apply to those generators that qualified for the episodic event allowance.
2021 Report Form Available Early 2022
The DNR anticipates releasing the 2021 report form in late January or early February of 2022. When the report form becomes available, an email will be sent to the individuals assigned as the report preparer and/or signatory. While the report window is a few months away, now is the best time to review facility information and make necessary updates.
Form Updates & Changes
- In addition to reporting on hazardous waste activities in 2021, this year's annual report will require that facilities include the generator operating status at the time the report is submitted in 2022. This will satisfy the renotification requirements for both large and small quantity generators.
- The fee exemption form will now include additional clarification questions for facilities requesting exemptions from the environmental repair fees.
Complete These Steps Prior To Reporting
Along with gathering information on all hazardous waste generation for the calendar year 2021, including hazardous waste that remains on-site as of Dec. 31, 2021, hazardous waste facilities should prepare for reporting by taking the following steps.
Step 1: Update Facility Changes Through myRCRAid
If there has been a change in the past year for any of the following, facilities must provide updated information through myRCRAid or by submitting a completed RCRA Subtitle C Site ID form (EPA 8700-12), to their regional DNR environmental program associate.
Step 2: Establish or Update a DNR Switchboard Account
The person responsible for the hazardous waste facility's annual report must have a DNR Switchboard account (commonly referred to WAMS ID or Wisconsin User ID) to complete the report. Checking prior to reporting season and ensuring that the account information is accurate is an important early step. The Switchboard FAQ explains how to establish or update an account.
Step 3: Check Facilities and Roles in DNR Switchboard
DNR Switchboard account holders that have submitted prior hazardous waste annual reports can access those reports and view the facilities linked to their account through the platform. Prior to reporting, account holders should check their DNR Switchboard account to ensure:
- Every facility they are responsible for is included in their account.
- That correct roles are assigned. Report preparers can edit information but cannot submit the report; signatories can edit information and submit the report.
- Every facility has an established signatory. Only the signatory can electronically submit the report and complete the signature (either an electronic or paper signature).
Step 4: Review Annual Reporting Resources
The DNR's Wisconsin Hazardous Waste Annual Report webpage provides useful information, including a tutorial video under the Report Instructions tab. The video walks through the steps of requesting report access through the DNR Switchboard, how to complete the report, how to use the digital signature option and provides answers to common questions. An updated tutorial that includes information on the 2021 report will be uploaded in the coming weeks.
In 2018, the DNR’s Air Management Program started accepting electronically signed monitoring reports, compliance certifications and next day deviation notifications. To date, 616 of Wisconsin’s air permitted facilities have used the e-Signature service as an easy and convenient method for signing and submitting documents to the Air Management database.
All facilities not yet taking advantage of the program’s e-Signature service are invited to give it a try. Here’s just a few benefits to submitting document signatures electronically:
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Timeliness: The DNR Air Management database is updated immediately upon submission. There is no wait time for mailing, reviewing and data entry. The facility also receives submittal confirmation.
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Ease: After document uploading, the signature process takes just a few minutes. No U.S. post mailing necessary.
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Cost: e-Signature is free!
Documents That Require Signatures
Monitoring reports, compliance certifications and next day deviation notifications require a signature from the responsible official. To use e-Signature, the responsible official must:
- Have a unique Wisconsin User (WAMS) ID and the air compliance submittal role, and
- Mailed an ink-signed Electronic Signature Agreement (ESA), available in the Switchboard, to DNR.
Paper copies of ink signatures will still be accepted for these reports. Only one signature, either ink or electronic, per document is required.
Questions?
For more information about creating a WAMS ID or logging in to the switchboard, refer to the DNR Switchboard secure eBusiness portal.
For more information about submitting reports using e-Signature, refer to the updated guidebooks and quick instructions on DNR’s Air Compliance Electronic Reporting webpage.
For specific questions about a facility’s monitoring reports, compliance certifications or next day deviation notifications, contact the facility-assigned compliance engineer.
For technical questions about using e-Signature for monitoring reports, compliance certifications or next day deviation notifications, contact Emily Houtler at Emily.Houtler@wisconsin.gov or 608-267-0803.
Following a public comment period and consideration of the comments received, the publication RR-619, Guidance: General Liability Clarification Letters, is now posted and available online.
RR-619 describes when general liability clarification letters, as defined in Wis. Stat. § 292.55, may be helpful and how parties can request a general liability clarification letter from the DNR.
The document can be found here. Additional documents and guidance from the Remediation and Redevelopment Program may be found using the search tools available on the publications and forms webpage.
Questions regarding these documents may be submitted to Michael Prager at Michael.Prager@wisconsin.gov.
The Environmental Protection Agency (EPA) announced the launch of the “Companies Crushing Pollution” Video Challenge. The Challenge invites students and others, including people who live near industrial facilities, to create videos illustrating how businesses in the U.S. are reducing toxic chemical releases through innovative pollution prevention (P2) practices, and by having a positive impact on the environment and communities. Participants have a chance to win up to $5,000.
The Challenge invites students and other individuals, including residents of communities with facilities that report to EPA’s Toxic Release Inventory (TRI), to use the TRI P2 Search Tool to identify a facility that has reported innovative pollution prevention techniques to EPA and make a video illustrating those techniques. All videos must be submitted by March 1, 2022.
EPA will award a total of $50,000 in prize money through the video challenge. Awards will be given to individuals and/or teams in three categories: High School, Colleges/Universities, and “Open,” with up to 9 awards in each category. The “Companies Crushing Pollution” Video Challenge aims to:
- Promote pollution prevention innovation among companies operating in the U.S.
- Raise awareness of the potential for businesses to save money, reduce regulatory burden, and have positive environmental impacts on communities through pollution prevention.
- Increase knowledge of TRI reporting and analytical tools to find and communicate information about pollution prevention actions that have been implemented.
- Showcase companies implementing forward-looking pollution prevention practices and highlight their success stories.
On December 15, 2021, EPA will host a webinar to discuss challenge logistics and rules. Participants will also have an opportunity to ask questions. Register for the webinar.
Pollution prevention is any practice that reduces, eliminates, or prevents pollution at its source. Pollution prevention, also known as "source reduction," is the “ounce-of-prevention is worth a pound-of-cure” approach that helps businesses to succeed. EPA works closely with stakeholders including companies, consumers and organizations serving overburdened and underserved communities to help facilitate adoption of pollution prevention practices. Reducing the amount of pollution means reduced costs for businesses because there is less waste to control, treat, or dispose of. More importantly, less pollution means less hazards posed to workers and communities, helping to improve public health and environmental conditions.
Webinar: Safer Cleaners & Degreasers for Electronics
Join Clean Production Action, Apple, Clean Electronics Production Network, and TCO Development to learn about safer cleaners and degreasers in the electronics sector. The webinar is scheduled on December 15, 2021, at 10:00 AM CDT.
Learn the details of GreenScreen Certified for Cleaners & Degreasers. Hear how Apple is integrating green chemistry into its supply chains. Find out how CEPN is scaling safer chemicals in the manufacturing of electronics. Learn how CPA and TCO Development collaborated on TCO Certified Accepted Substances List and the addition of safer cleaners to that list.
For information on the webinar and to register, go to: https://www.greenscreenchemicals.org/resources/entry/webinar-safer-cleaners-degreasers-for-electronics.
Weekly WisCon Webinars
Weekly online webinars from WisCon Safety Consultation Program, held at 1:00 pm each Monday. Join the webinar via the ZOOM link: https://uwmadison.zoom.us/j/99797590129. Enter the passcode 500711 when prompted.
The next webinar is Dec 20 - How to Record Injuries and Illnesses on the OSHA 300 log. There will not be webinars on December 27 or January 3.
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