Online Reporting System RCRAInfo
Reporting Frequency Annual
Submission Type RCRAInfo
Local Thresholds No
Table of Contents

    Illinois RCRA Hazardous Waste Reporting

    Illinois hazardous waste reporting is regulated by the Illinois Environmental Protection Agency. The goal of the state program is to provide “cradle to grave” management of hazardous wastes to ensure the protection of the environment and human health.  Federally, hazardous waste is regulated under the Resource Conservation and Recovery Act (RCRA). Compliance with state and federal RCRA regulations is required for facilities that generate and dispose of hazardous waste at certain thresholds. At the federal level, RCRA requires a biennial report to be submitted by large quantity generators of hazardous waste. Illinois has more stringent reporting requirements, including increased frequency and special wastes that must be reported. 

    Understanding Illinois Hazardous Waste/ RCRA Reporting Requirements

    Who Needs to Report?

    In Illinois, generators and facilities are required to report their hazardous waste activities. Reporting requirements are based on activities and generation quantities. Facilities have to submit annual reports to the state if they generate wastes at or above certain thresholds (below)

    • Facilities that generate 2,200 lbs or more of hazardous waste or 1 kg or more of acutely hazardous waste must report annually. 
    • Treatment, storage, and disposal facilities (TSDFs) must report annually 

    State-Listed Hazardous Waste in Illinois

    Illinois does not have any state-specific wastes subject to RCRA manifest and reporting requirements. However, Illinois does regulate certain kinds of waste known as special wastes. Special wastes in IL are subject to additional reporting requirements outside of RCRA reports, manifest requirements, and generation limits. Special wastes can be hazardous or non-hazardous. 

    Special wastes: 

    • Include:
      • Potentially infectious medical waste
      • Hazardous waste
      • Pollution control waste
      • Industrial process waste 
    • Small quantity generators (between 220 and 2,200 lbs) and large quantity generators (greater than 2,200 lbs) must determine if they have special waste and ship this waste using a waste manifest, defined by:
      • Facilities generating more than 220 lbs of special waste per month must obtain an Illinois EPA ID number
      • More information about special wastes can be found here 

    Illinois Generator Statuses and Requirements

    Very Small Quantity Generators (VSQG) Requirements

    VSQGs generate less than 220 lbs of hazardous waste and less than 2.2 lbs of acutely hazardous waste per month. VSQGs are exempt from reporting requirements. VSQGs must still take steps to ensure compliance, including:

    • Waste determination: Illinois requires detailed documentation of how hazardous waste determinations are made
      • Keep records of determinations for 3 years
    • Ensure storage does not exceed 2,200 lbs of hazardous waste on-site at any time
    • Store hazardous waste in appropriate containers
    • Only use permitted TSDFs or consolidate waste with a registered LQG
    • If more than 220 lbs of special waste is accumulated, a hazardous waste manifest must be used
    • Manage waste to minimize risk to human health 
      • Illinois requires formal spill containment and cleanup procedures for VSQGs
    • Notify Illinois EPA of any episodic generation events 

    Small Quantity Generator (SQG) Requirements

    SQGs generate between 220 and 2,200 lbs of hazardous waste and less than 2.2 lbs of acutely hazardous waste per month. SQGs are exempt from reporting requirements. SQGs must still take steps to ensure compliance, including:

    • Register with Illinois EPA using RCRA Subtitle C Site Identification form (EPA Form 8700-12)
      • Re-notify the state every 4 years
    • Waste determination: keep detailed records of how waste determinations are made
    • Ensure storage does not exceed 6,000 lbs or occur for longer than180 days 
    • Store hazardous waste in appropriate containers 
    • Post emergency contact information and procedures for spill responses
    • Name an emergency coordinator who is available 24 hours a day to respond to emergencies
    • Only use permitted TSDFs 
    • Use Illinois Uniform Waste Manifests for waste shipments
      • Keep copies of manifests for a minimum 3 years 

    Large Quantity Generator (LQG) Requirements

    LQGs generate 2,200 lbs or more of hazardous waste or more than 2.2 lbs of acutely hazardous waste per month. LQGs are required to submit annual hazardous waste reports to the state. In addition to reporting requirements, LQGs must also:

    • Register with Illinois EPA using RCRA Subtitle C Site Identification form (EPA Form 8700-12)
    • Waste determination: keep detailed records of how waste determinations are made
    • Not store waste on-site for more than 90 days without a permit 
    • Store hazardous waste in appropriate containers 
    • Use the Uniform Hazardous Waste Manifest for all waste shipments
      • Use the EPA e-Manifest System
    • Develop and maintain a contingency plan addressing emergency response procedure
      • Provide copies to local emergency responders 
    • Provide formal training to all employees on hazardous waste handling and emergency response within 6 months of hire 
      • Maintain training records for 3 years
    • Submit federal biennial hazardous waste reports every 2 years
    • Submit a Land Disposal Restriction (LDR) Notification with each waste shipment

    Examples of Facilities Subject to Waste Reporting

    The following is a list of common facilities in IL and the wastes they generate that would likely trigger the need to submit an annual waste report:

    • Chemical manufacturing facilities: spent solvents such as acetone, wastewater sludges contaminated with heavy metals, and corrosive wastes 
    • Oil refineries: oily sludges from tanks, spent catalysts, benzene-contaminated wastes, ignitable waste 
    • Automotive manufacturing: paint booth sludges containing volatile organic compounds, spent lubricants, solvent-contaminated wipes, and rags, hazardous battery components from electric vehicle production

    Hazardous Waste Manifest Requirements for Illinois Facilities

    All SQGs and LQGs must use hazardous waste manifests for waste shipments. VSQGs are generally exempt from manifest requirements unless required by transporters or when generating >220 lbs of Illinois special waste. All shipments must use the federal Uniform Hazardous Waste Manifest (EPA Form 8700-22)

    Waste manifests must include:

    • Generator information including name, address, and EPA ID
    • Transporter details including ID numbers and U.S. DOT descriptions
    • TSDF information including name, address, and EPA ID
    • Waste descriptions
      • Name, hazard class, EPA waste codes, quantities 
    • Signatures from generators, transporters, and final receiving facilities
    • Emergency response numbers and emergency spill cleanup procedures 

    For Generators:

    • Waste Minimization Certification: SQGs and LQGs must certify on each manifest that they have implemented a waste minimization program
    • IL encourages the use of the federal e-Manifest system for the submission and tracking of manifests
    • If paper manifests are used, TSDFs upload the final copy to the e-Manifest system. Generators must be registered with the e-Manifest system and able to access electronic manifests during inspections. Starting January 22, 2025, federal regulations will require all SGQs and LQGs to register for the e-manifest system
    • Paper copies must be stored for at least 3 years
    • Exception reporting updates starting January 22, 2025:
      • If a signed copy of the final manifest has not been submitted to e-Manifest within 45 days of acceptance, LQGs must inquire with the TSDF on the status of the waste
      • If a signed copy has not been submitted within 60 days, LQGs and SQGs must submit an exception report with IL EPA
        • Starting December 1, 2025, exception reports must be submitted electronically through e-Manifest 

    For Treatment, Storage, and Disposal Facilities:  

    • The UHWM must accompany waste throughout its shipment and treatment process
    • Must upload a copy of the signed final manifest to e-Manifest within 35 days. 
      • Generators can access final manifests through RCRAInfo.
    • Must maintain copies of manifests for a minimum of 3 years.
    • Unmanifested Waste Reports: If a TSDF accepts hazardous waste without a manifest, a report must be submitted to the IL EPA within 15 days of accepting the waste. This report includes information about the facility, the waste type and quantity, method of treatment, storage, and disposal, and an explanation for why the waste was unmanifested
    • Discrepancy Reports: If a TSDF operator determines a discrepancy in quantities or types of waste, they must first attempt to resolve it with the generator within 15 days of the incident. If it is not resolved within 15 days, TSDFs must submit a report to IL EPA detailing the discrepancy, copies of waste manifests, and attempts to resolve the issue

    Common Manifest Errors

    • Incomplete or incorrect generator information
    • Improper waste descriptions
    • Missing signatures
    • Failing to retain copies 
    • Missing land disposal restriction notifications

    Tips to avoid errors in manifests:

    • Provide regular training for staff responsible for completing manifests
    • Double-check information such as waste codes, DOT names, hazard classes, and ID numbers 
    • Use the EPA e-Manifest system to reduce paperwork and fix errors quickly

    Illinois Electronic Waste Reporting System (RCRAInfo)

    Overview of RCRAInfo

    Illinois utilizes the federal RCRAInfo system for biennial RCRA reports and state annual reports. Facilities required to submit federal biennial reports must also use RCRAInfo to comply with federal reporting requirements. LQGs will use RCRAInfo for both annual and biennial reporting. Illinois requires electronic reporting to ensure a unified, standardized platform that is accessible to all authorized agencies across the state. 

    How to Submit a Hazardous Waste Report in RCRAInfo

    Here are the key steps for using RCRAInfo Online Reporting system:

    • Go to RCRAInfo and either create a new account or sign in with your existing credentials. 
    • Access the reporting module based on the reporting year:
      • Odd-numbered years: Use the Annual Report Module
      • Even-numbered years: Use the Biennial Report Module
    • Compile hazardous waste data including waste type, quantities generated, handling methods, shipments, and details about disposal facilities 
    • Complete the necessary forms (Federal Form 8700-12, 8700- 13 a/b)
      • Site ID Form: provides contact information and a summary of waste activities for the previous year. This form is required for all facilities, regardless of generator status.
      •  Off-site identification form (OI) form: this form must be submitted for all off-site receiving facilities that:
        • Shipped away waste that was on a UHM
        • Generated special waste, regardless of generator status
        • Received waste from off-site
        • Had a planned or unplanned episodic event
      • Generation and management (GM form) for each waste stream: describes waste streams generated and how the waste is managed. 
        • Provide federal waste codes, source codes, management methods, waste minimization codes, and waste quantities for each
    • Review and submit your waste reports
      • LQGs are required to pay a $500 fee by March 1 each year

    Deadlines, Timelines RCRA Reporting Frequency

    Annual Reporting Deadline

    In Illinois, hazardous waste reports are due by March 1st each year regarding information on hazardous wastes generated by the facility in the previous calendar year.

    Additional Reporting Requirements (additional waste reports)

    Special Waste Reports

    • Generators managing special wastes (including non-hazardous waste that is regulated under Illinois law) must document the generation and disposal of special wastes. These reports include types and quantities of wastes, along with disposal methods
      • Shipments of special waste must be accompanied by waste manifests 
      • Special waste reports are due February 1 each year with IL EPA

    Tips for Effective RCRA Reporting

    Maintain Continuous Records

    • Implement a centralized storage system to ensure quick access to required documents and records. Documents and records may be requested during compliance audits and inspections and are helpful during the reporting system. Consider electronic storage or digital software for easier access and greater security.
    • Conduct regular self-audits to ensure that records are accurate, complete, and compliant with current RCRA and Illinois regulations. Consider scheduling quarterly or biannual audits of generation, storage, and shipment records and keep track of deadlines for submissions.

    Understand State-Specific Reporting Requirements

    Illinois reporting closely mirrors federal reporting requirements. However, IL has a few key differences from federal reporting requirements. These differences include:

    • In IL, LQGs are required to submit annually through RCRAInfo 
      • The report includes a $500 fee 
    • IL requires special waste reporting for certain nonhazardous but regulated waste streams due February 1 each year

    Keep Copies of All Submitted Reports

    Make copies of all paper forms and securely store them for a minimum of 3 years to stay in compliance in IL. Forms, waste determinations, training, records, and more may be requested during compliance inspections. 

    Common Mistakes in RCRA Reporting and How to Avoid Them

    Incorrectly Estimating Quantity of Reportable Wastes

    Reporting incorrect waste quantities or generator status can be due to events of underreporting to avoid reaching large quantity generator status and over-reporting due to data management errors

    Tips:

    • Use standardized tracking systems 
      • Consider electronic tracking or digital software to automatically calculate quantities based on generation and shipments 
    • conduct regular audits of waste totals
    • Use accurate container labels

    Failure to Report All Hazardous Wastes

    Failing to report all hazardous wastes can occur for several reasons, including misidentification or under-classification of waste streams. This can happen when a facility overlooks smaller waste streams, fails to recognize mixtures of hazardous waste with non-hazardous waste, or relies on outdated waste determination rules. Failing to report all waste can lead to underreporting, misrepresentation generator categories, and issues of non-compliance. 

    Tips:

    • Conduct regular waste stream inventories 
    • Regularly update waste determinations
    • Use a digital waste management tracking system to reduce errors and improve recordkeeping
    • Consult with environmental experts 

    Failing to Keep Up-To-Date with Changes in Regulations

    Failing to keep up with changes in regulations can be due to several factors. Facilities may lack designated staff members dedicated to tracking regulatory updates, incorrectly assume that long-standing waste management practices remain compliant, or fail to monitor changes from both the EPA and state agencies, such as Illinois EPA. 

    Tips:

    • Assign a designated staff member or team to monitor current waste regulations
    • Subscribe to updates from federal agencies and local EHS groups 
    • Conduct annual compliance audits
    • Implement software solutions to track hazardous waste regulations and notify of updates 

    Lack of Compliance with Illinois-Specific Waste Regulations

    Failing to understand the differences between federal RCRA requirements and Illinois-specific rules can lead to non-compliance at the state level. Illinois has additional reporting requirements beyond federal requirements, including:

    • Special waste regulations and reporting 
    • Generator fees for waste reporting 
    • Annual reporting for LQGs 
    • Tips to avoid non-compliance at the state level:
      • Regularly review Illinois-specific regulations by consulting the Illinois EPA or environmental compliance experts in the state
      • Train employees on Illinois requirements 
      • Consider digital waste tracking and reporting software that supports state-specific monitoring 

    Late and Missed Submissions

    Ineffective timeline management can lead to late and missed report submissions. Lacking a centralized compliance center, unclear designation of responsibilities, and insufficient training can contribute to missing deadlines. 

    Tips:

    • Establish a centralized compliance calendar with reporting deadlines
    • Use software to track and notify of reporting due dates
    • Provide training to ensure employees understand when reports are due and the consequences of missing these deadlines

    Penalties for Non-Compliance with RCRA Reporting in Illinois

    Potential Fines and Legal Consequences

    In Illinois, non-compliance with RCRA reporting requirements can lead to penalties, including fines and civil or criminal enforcement actions. These penalties and fines are enforced by the Illinois EPA and the federal EPA. Fines can be based on the severity and frequency of violations, knowledge of the violation, and other factors.

    Common penalties include:

    • Failing to submit annual or biennial reports: fines of up to $25,000 per day
    • Late submissions of annual reports: 8% per annum calculated from March 1 and a penalty of 5% of total fees due for every 30 days the report is late
    • Exceeding storage limits: civil fines of up to $25,000 per day 
    • Failing to keep manifests up to date in the e-Manifest system: Civil penalties of up to $25,000 per violation

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