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 regulated waste activities. The report, which covers activity during the previous calendar year, is completed and submitted through an online reporting system and due March 1.
The DNR uses annual report data for planning, fee assessment, compliance monitoring and enforcement efforts. Additionally, this data is submitted to the U.S. Environmental Protection Agency for odd-numbered report years to be used for evaluation and planning, developing regulations, compliance monitoring and enforcement.
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., small quantity generator to large quantity generator or very small quantity generator to small quantity generator or to large quantity generator).
A very small quantity generator (VSQG) that properly notified the DNR of an episodic hazardous waste generation event is not required to complete an annual report unless the VSQG has engaged in other hazardous waste activities that require an annual report to be completed. No base fees or tonnage fees are associated with the VSQG if it does not have to report, even if it experienced an episodic generation event.
A small quantity generator (SQG) must complete an annual report. An episodic hazardous waste generation event does not require an SQG to report as a large quantity generator (LQG). However, the SQG will need to pay the SQG base fee and tonnage fee for all the hazardous waste it generated, including the episodic hazardous waste, during the reporting year.
2021 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 2021 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. (Note that if the video appears blurry, you can change the resolution to 720p in the lower right corner of the video player.)
Getting Access to the Online Reporting System
To access the online reporting system, you must have a Wisconsin User ID (sometimes called a 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
- Find your personal Wisconsin User ID and password.
- Go to the DNR Switchboard and click the "Log in" button near the top.
- Enter your Wisconsin User ID and password in the corresponding boxes.
- Click on the Log In button.
Once you have logged in, one of three events will occur:
- You will click on “My Facilities & Roles” to see a screen listing all the facilities and reporting roles that you expected. You can begin reporting.
- You will click on “My Facilities & Roles” to see some of the facilities and/or reporting roles that you expected. If this happens, please click on “Request Access” to request your additional roles. You can begin reporting on the facility or facilities shown on “My Facilities & Roles.”
- If the system does not accept your password, you will need to go through the password account recovery procedure.
Report Section Information
To learn more about the different sections of the annual report, review the other tabs of this page.
The links below list the available codes used on the Hazardous Waste Annual Report. The links are excerpts from the EPA Form 8700-13 instructions. Please see EPA Biennial Hazardous Waste Report for the full document.
Certifying Hazardous Waste Report Information
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 must be printed and signed by the waste report certifier at your facility (whose name will be pre-filled on the document) and emailed to the DNR at DNRHazardousWasteReporting@wisconsin.gov.
WA Section and Exemption
Regulated Waste Activity (WA) Section
The regulated waste activity (WA) section is required every reporting year. The online reporting system collects regulated waste activity information to populate the other sections required to complete your report.
The purpose of the WA section is to collect additional identifying information about the hazardous waste activities associated with the facility.
Starting with the 2021 report, the WA section will also be used as a notification record to update state and federal databases, similar to when a facility submits a RCRA Subtitle C (8700-12) Form. You will be asked the following:
- The current generator status of your facility at the time of completing the report,
- The highest generator status the facility operated at or chose to operate at for the reporting year.
Completing the WA section and submitting the report by March 1 will satisfy SQG and LQG re-notification requirements under s. NR 662.018(4), Wis. Adm. Code.
If you received a notice to complete this report and your facility did not fit any of the reporting requirements during the report year, you will be directed to complete the exemption details section of the report. Choose the reason for not generating and provide any relevant comments.
Reasons for not generating include:
- hazardous waste minimization activity;
- the facility only generated hazardous waste that is excluded or has been delisted by the EPA;
- for the reporting year, the facility was a very small quantity generator; or
- another reason (you will be required to justify in comments).
DNR regional staff will review your exemption request. To have your facility removed from reporting in future years, you must complete the WA section (explained above). This will notify the DNR of the change in generator status or other regulated activities that excludes you from reporting in future years.
Hazardous waste generator environmental repair fee payments
You do not need to pay the fee until you receive an environmental fee statement from the DNR in June. That statement will include the hazardous waste generator fee and other DNR environmental fees you may owe.
Fee Worksheet (FW) Section
The fee worksheet (FW) section is required every report year for facilities that do not file exempt from reporting requirements. The online reporting system will provide the FW section when required.
Annual fees are calculated based on activity, generated status and the amount of hazardous waste generated during the reporting year. For generators, fees are as follows:
- The base fee is $470 for a large quantity generator (LQG).
- The base fee is $350 for a small quantity generator (SQG).
- The tonnage fee portion 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.
Wastes exempt from tonnage fees include the following:
- waste recovered for recycling or reuse (including hazardous wastes burned for the purpose of energy recovery);
- hazardous waste leachate that was transported to a wastewater treatment plant or discharged directly to a sewer pipe;
- hazardous waste removed from a site to repair environmental pollution (soil or groundwater remediation); and
- hazardous waste collected by a municipality under its household hazardous waste collection program or by a county under its agricultural chemical waste collection program.
Even though certain hazardous wastes are exempt from the tonnage fee, they must still be reported on the FW section as hazardous waste generated and tonnage fee exempted. For more information, see ss. 289.67(2)(a) through (e), Wis. Stats.
Waste Generation and Management (GM) Section
The GM section is required for large quantity generators on odd-numbered report years (i.e., 2021, 2023, etc.), and every year for licensed treatment, storage or disposal facilities.
The GM section documents:
- the source, characteristics and quantity of hazardous waste generated on-site;
- waste minimization activities and results for each type of waste;
- the quantity of hazardous waste managed on-site and the on-site management methods; and
- the quantity of hazardous waste shipped off-site and the off-site management methods.
Waste That Must Be Reported on the GM Section
In the GM section, each type of hazardous waste generated on-site must be reported, including those generated from production processes, from the treatment of non-hazardous waste and from hazardous waste residuals generated from the management of a hazardous waste.
A separate and independent GM section must be submitted for each type of hazardous waste, including hazardous waste that was:
- generated on-site from production processes or service activities;
- generated as the result of a spill cleanup, equipment decommissioning or other remedial cleanup activity;
- generated from the management of a nonhazardous waste type;
- shipped off-site; received from off-site and not recycled, blended or otherwise treated on-site;
- residual generated from the on-site treatment, disposal or recycling of hazardous waste;
- removed from on-site storage for treating, recycling or disposal on-site or shipment off-site; and
- imported from a foreign country during the report year.
Alternative Submittal of GM Section Information
For facilities needing to report a large number (20+) of the GM sections, there is an alternative submittal method outside the online reporting system. Send an email with your site information (facility name, EPA ID and facility ID number) requesting the GM section specifications. File specifications and instructions will be sent by email.
Wastes that do not need to be reported on the GM section
The following wastes should NOT be reported in the GM section:
- hazardous waste exported directly to a foreign country;
- materials that are excluded from being a solid waste;
- solid wastes that are excluded from being hazardous waste;
- waste exempt from regulation because it has not exited the raw material storage or production unit yet;
- hazardous waste that has been collected as a sample(s) for the purpose of determining its characteristic or composition;
- sample(s) undergoing treatability studies;
- hazardous waste that is a specified recyclable material;
- a residue of hazardous waste in an empty container or in an inner liner removed from an empty container;
- any PCB waste regulated under the Toxic Substance Control Act;
- wastes managed immediately upon generation only in on-site elementary neutralization units, wastewater treatment units or totally enclosed treatment facilities. Note: Any hazardous waste residues generated from these units, however, must be reported on GM section;
- wastes recycled, without prior storage, only in an on-site process subject to regulation;
- used oil that is recycled;
- spent lead-acid batteries. Note: Any hazardous waste generated during battery reclamation, however, must be reported on GM section; and
- universal wastes.
See ss. NR 661.0004, NR 661.0007, NR 661.0008 and NR 661.0009, Wis. Adm. Code, for more information.
Waste received from off-site (WR) Section
The WR section is completed by licensed treatment, storage and disposal facilities that receive hazardous waste from off-site during the report year or by publicly owned wastewater treatment works (POTWs) that accept hazardous waste. Any facility that received hazardous waste from off-site during the report year is required to complete the waste received from off-site (WR). The online reporting system automatically determines which facilities need to submit the WR section.
The WR section collects information about the quantities and characteristics of each hazardous waste received from an off-site source and the method(s) used to manage them.
Alternative submittal of WR section information
For sites needing to report a large number (20+) of the WR section, there is an alternative submittal method outside the online reporting system. Send an email with your site information (facility name, EPA ID and facility ID number), requesting the WR section specifications. File specifications and instructions will be sent by email.
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
In most cases, do not report asbestos, PCBs or waste oils. However, they must be reported when any of the following conditions exist:
- If a listed hazardous waste (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.
- If the waste possesses one or more of the characteristics that result in assigning a hazardous waste code beginning with "D."
Do not report waste oil that is "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)). However, waste oil must be reported when burned or disposed.
Groundwater Contaminated by Leachate
Groundwater that is contaminated by hazardous waste leachate is not considered a solid waste while it remains in the ground (in situ) and is, therefore, not classified as a hazardous waste. However, when the groundwater is removed from the ground it may require management as a hazardous waste. When reporting extracted groundwater contaminated by leachate on the hazardous waste annual report, observe the following conventions:
- Do not report generation quantities for contaminated groundwater.
- 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. Recordkeeping requirements for these wastes are found in ss. NR 666.502(10) and NR 666.503(5), Wis. Adm. Code.
All 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.
The following rules should be applied to the reporting of lab pack wastes in the hazardous waste annual report.
- 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.
- 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.
- 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.
- 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.