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Wisconsin hazardous waste annual report

Wisconsin's hazardous waste regulations require several types of hazardous waste generators to report to the Department of Natural Resources every year on their regulated waste activities. The report, which covers activity during the previous calendar year, is generally available in mid-January and must be submitted to the DNR by March 1 each year. The report is completed and submitted through an online reporting system.

Information on annual report sections

Detailed information on each section of the hazardous waste annual report can be found on the DNR's hazardous waste annual report section information page.


Who must submit a hazardous waste report

A facility must submit an annual report if, during the report year, the facility did any of the following:

  • Generated in any calendar month:
    • more than 100 kilograms (220 pounds) of hazardous waste;
    • more than 1 kilogram (2.2 pounds) of acute hazardous waste; or
    • more than 100 kilograms (220 pounds) of acute hazardous waste spill cleanup material.
  • Accumulated at any time:
    • more than 1,000 kilograms (2,205 pounds) of hazardous waste;
    • more than 1 kilogram (2.2 pounds) of acute hazardous waste; or
    • more than 100 kilograms (220 pounds) of acute hazardous waste spill cleanup material that was generated onsite.
  • Was a publicly owned (wastewater) treatment works that accepted hazardous waste (via truck, rail or dedicated pipe) for treatment and complied with s. NR 670.001(3)(b)9, Wis. Adm. Code.
  • Was a permanent household and very small quantity generator hazardous waste collection facility that shipped hazardous waste offsite to a licensed or permitted hazardous waste treatment, storage or disposal facility;.
  • Performed any other hazardous waste treatment, storage or disposal activities onsite that required a hazardous waste facility license.
  • Chose to operate under a higher generator status than it previously had (i.e., SQG to LQG or VSQG to SQG or to LQG).

Hazardous waste annual report sections

The sections of the hazardous waste annual report are summarized below. For more details, see hazardous waste annual report section information.

Regulated Waste Activity (WA) Section

The WA section is required every year. All facilities must provide the minimal site activity information on the reporting requirements for the report year. The WA section also collects additional identifying information.

Fee Worksheet (FW) Section

The FW section is required every year for sites that were a small quantity generator; a large quantity generator; a treatment, storage or disposal facility; or a permanent household and very small quantity generator hazardous waste collection facility that ships hazardous waste offsite to a licensed or permitted hazardous waste treatment, storage or disposal facility.

Waste Generation and Management (GM) Section

The GM section is required for odd-numbered report years (i.e., 2021, 2023, etc.) for facilities that were large quantity generators. The GM section is required annually for licensed treatment, storage or disposal facilities. Separate GM section information must be completed for each type of hazardous waste generated, accumulated, managed onsite, shipped offsite or imported from a foreign country during the report year.

Waste Received from Offsite (WR) Section

The WR section is required annually for licensed treatment, storage or disposal facilities and publicly owned wastewater treatment works that received hazardous waste from offsite during the report year. Separate WR section information must be completed for each type of hazardous waste received from an offsite source during the report year and managed onsite.

Use of data submitted in annual reports

The DNR shares hazardous waste annual report data for odd-numbered report years with the U.S. Environmental Protection Agency. The EPA uses the data for planning and developing regulations, compliance monitoring and enforcement. The data also allow the EPA to determine whether its regulations are having the desired effect on the generation and management of hazardous waste. For example, the data provide information on whether waste management has shifted from one method of disposal to another. The DNR uses the data for planning, fee assessment, compliance monitoring and enforcement.

Additional resources

2020 report instructions

The DNR has updated the hazardous waste annual report with some formatting changes, and the submittal process now provides an electronic signature option. This may require you, your report preparer or your facility's report certifier to take additional steps in preparation for completing the 2020 hazardous waste annual report. To avoid delays or missing the deadline of March 1, please review the information below and take the necessary actions now.

Hazardous waste report tutorial

DNR staff have put together a tutorial video on how to complete the hazardous waste annual report during a short report year.

Getting access to the online reporting system

To access the online reporting system, you must have a web access management system (WAMS) ID and have registered for access on the DNR switchboard. If you have done neither, follow the process on the DNR switchboard page before you begin the hazardous waste reporting process.

Step-by-step instructions for logging in to online reporting system

  1. Find your personal WAMS ID and password.
  2. Go to the DNR Switchboard and click the "Log in" button near the top.
  3. Enter your WAMS ID and password in the corresponding boxes.
  4. Click on the Log In button.

Once you have logged in, one of three events will occur:

  • You will see a screen listing all the facilities and reporting roles that you expected. You can begin reporting.
  • You will see a screen listing some of the facilities and/or all of the reporting roles that you expected. If this happens, please contact your local environmental program associate and request reporting authorization for the missing facility or facilities. You can begin reporting on the facility or facilities shown on your screen.
  • If the system does not accept your password, you will need to go through the password account recovery procedure [exit DNR].

Report section information

To learn more about the different sections of the annual report, see hazardous waste annual report section information.

Certifying hazardous waste report information

E-signature option

A facility's authorized certifier/signatory may submit the report with an electronic signature option, avoiding the print, sign and mailing of the certification page. The set up only needs to occur once. A temporary passcode is generated and sent via email each time use of e-signature is requested. The passcode expires 72 hours after the request. Additional instructions are provided in the reporting system.

If you choose not to use the electronic signature option, after submitting the online reporting information, the one-page certification form (or the exemption form, if completed instead) must be printed and signed by the waste report certifier at your facility (whose name will be pre-filled on the document) and mailed to the DNR address printed at the top of the form. Alternatively, you may send a hard copy to:

DNR Hazardous Waste Reporting - WA/5
PO Box 7921
Madison WI 53707-7921

Special waste types

Below is information for specific waste types that may or may not need to be included in the report, including asbestos, PCBs, waste oils, groundwater contaminated by leachate, hazardous waste pharmaceuticals, hazardous/radioactive nuclear mixed wastes, lab packs and waste from foreign countries.

Asbestos, PCBs and waste oils

Do not report asbestos, PCBs and waste oils in most cases. Do report them if any of the following conditions exist.

  1. If a listed hazardous waste (this is, a waste whose hazardous waste code begins with "F," "P," "U," or "K") is mixed with the asbestos, PCBs or waste oil. In this case, the entire mixture becomes a hazardous waste.
  2. If the waste possesses one or more of the characteristics that result in assigning a hazardous waste code beginning with "D."

Do not report "used oil that exhibits one or more of the characteristics of hazardous waste (criterion 2 above) but is recycled in some manner other than being burned for energy recovery" (40 CFR 261.6(a)(iii)). Do report if this waste oil is burned or disposed.

Groundwater contaminated by leachate

Groundwater that is contaminated by hazardous waste leachate is not considered a solid waste while it is in the ground and is, therefore, not classified as a hazardous waste. However, when the groundwater is removed, it must be managed as a hazardous waste. When reporting groundwater contaminated by leachate on the hazardous waste annual report, observe the following conventions.

  1. Do not report generation quantities for contaminated groundwater.
  2. Do report quantities managed onsite, quantities shipped offsite and quantities received from offsite.

Hazardous waste pharmaceuticals

Healthcare facilities do not count non-creditable hazardous waste pharmaceuticals (PHRM) or potentially creditable hazardous waste pharmaceuticals for annual reporting purposes when they are managed under Subchapter P. Other hazardous wastes generated by LQGs and SQGs must be included in the annual report.

Hazardous/radioactive nuclear mixed wastes

By themselves, source material, special nuclear material or byproduct materials as defined by the Atomic Energy Act of 1954, as amended, 42 US Code 2011 et. seq, are not classified as solid or hazardous waste under hazardous waste regulation. However, if these materials are mixed with a hazardous waste, the material is controlled under hazardous waste regulation, as well as under the Atomic Energy Act (DOE, NRC and EPA) regulations, and must be reported in the hazardous waste annual report.

Lab packs

The following rules should be applied to the reporting of lab pack wastes in the hazardous waste annual report.

  1. You may aggregate lab pack waste containers in most cases. However, you must report them as separate waste types under the following conditions:
    • if they contain acute hazardous wastes (hazardous waste codes F020, F021, F022, F023, F026, F027, and all "P" waste codes). Report separately from lab packs containing other hazardous wastes (all other hazardous waste codes); or
    • if they are managed differently from each other. For example, report lab packs that are shipped to landfills separately from those that are incinerated.
  2. Enter a form code indicating lab packs ("W001" or "W004") in generated and managed (GM) section. These form codes are to be used with any lab pack, whether the wastes are gaseous, liquid, solid or sludge.
  3. It is not necessary to report every hazardous waste code included in a batch of lab packs. Record one hazardous waste code in the space for primary hazardous waste code GM section, if there are many hazardous waste codes enter "LABP" in GM section.
  4. When reporting quantities for lab packs:
    • include the weight of the containers if they are disposed (e.g., landfilled) or treated (e.g., incinerated) along with the wastes; and
    • exclude the weight of the containers if the waste is removed from the containers before treatment or disposal.

Wastes from foreign countries

  • Report in GM section - If your facility was the generator of record and was the U.S. importer for hazardous waste received from a foreign country, complete GM section for this waste. Enter the appropriate source code, either G62 or G68. Identify the name and address of the foreign generator in the comment section. Also verify you indicated “Yes” for United States importer of hazardous waste in the WA section under “Other regulated waste activities” to indicate this activity.
  • Report in waste received (WR) section - If your facility received hazardous waste directly from a generator in a foreign country, complete a WR section for the waste treated, recovered or disposed at your facility. (This waste was not shipped to your facility by a U.S. importer.) If the foreign site has an EPA Identification (ID) number, report waste received from that site just as you would report waste received from a domestic site. If the site does not have an EPA ID number, enter "FC9999999999" in WR section and identify the name and address of the foreign generator in the comment section.

Generator fees

Hazardous waste generator environmental repair fee

Fee payments

Do not send an environmental fee payment to the DNR until you receive a cumulative environmental fee statement in June.

As part of the hazardous waste annual reporting process, some generators of hazardous waste must pay fees to the DNR. There is a base fee for some generators, and a fee based on the tonnage of hazardous waste generated.

The base fee portion is $470 for a large quantity generator (LQG) and $350 for a small quantity generator (SQG). There is no longer an exemption from the base fee for generators who meet certain criteria, so all large and small quantity generators must now pay the base fee. The tonnage fee portion of the fee is $20 per ton, with some exemptions. The maximum total hazardous waste generator fee that may be assessed is $17,500 per year, regardless of the amount of hazardous waste generated.

In the online reporting system for the hazardous waste annual report, the Fee Worksheet (FW) Section calculates a hazardous waste generator fee according to the statutory language that requires the fee (s.289.67(2), Wis. Stats.). The total fee is estimated by adding a site's base fee and tonnage fees. The base fee is determined by the site's hazardous waste generator status during the report year (indicated on the reporting requirements screen of the hazardous waste annual report). Tonnage fees are based on the amount of hazardous waste generated minus the amounts of waste exempted from tonnage fees.

By statute, no tonnage fees may be assessed for the following:

  • hazardous wastes recovered for recycling or reuse;
  • hazardous waste-contaminated leachate transported to a wastewater treatment plant or discharged directly to a sewer pipe;
  • hazardous wastes removed from a site or facility to repair environmental pollution;
  • household hazardous wastes collected by a municipality under its household hazardous waste collection program; and
  • hazardous wastes collected by a county under its agricultural chemical waste collection program.

The FW section collects information about the amounts of these tonnage fee-exempted wastes so that fees are not assessed for them. For more information, see ss. 289.67(2)(a) through (e), Wis. Stats [PDF exit DNR].