Arizona RCRA Hazardous Waste Reporting

In Arizona, hazardous waste reporting under the Resource Conservation and Recovery Act (RCRA) is managed by the Arizona Department of Environmental Quality (ADEQ). This federal program, enforced at the state level, ensures the proper tracking, management, and disposal of hazardous waste from its generation to its final treatment or disposal. Facilities in Arizona that generate hazardous waste are required to comply with both federal and state-specific RCRA regulations, including reporting requirements. The goal of ADEQ’s hazardous waste management is to provide transparency and accountability while protecting Arizona’s public and environmental health. Compliance with RCRA at the federal and state levels in Arizona contributes to the safe management of hazardous wastes, reducing risks to communities and ecosystems

Understanding Arizona Hazardous Waste / RCRA Reporting Requirements

Who Needs to Report?

In Arizona, reporting requirements are based on a facility’s generator category. Annual registration reports are due by March 1 each year

• Very Small Quantity Generators (VSQGs) must submit registration reports annually 
  • Must submit registration reports annually by March 1 (Note: The registration report differs from the generation report and must be completed prior to the generation report)
• Small Quantity Generators (SQGs) must submit registration reports annually 
  • Must submit registration reports annually by March 1
• Large Quantity Generators (LQGs) must submit registration reports annually
  • Submit generation reports quarterly (due April 30th [1Q], July 30th [2Q], October 30th [3Q] and March 1st [4Q]) 
  • Submit federal RCRA reports biennially 
• Treatment, Storage, Disposal, and Facilities (TSDFs) must submit registration reports annually
• Transporters (including out of state) must submit registration reports annually 
• Key Point:
  • In Pima County, hazardous waste is managed by the Pima County Department of Environmental Quality (PDEQ). PDEQ forms, fees, and reporting requirements can vary from other counties throughout the state. For information on reporting requirements in Pima County, visit the PDEQ website here https://www.pima.gov/562/Hazardous-Waste-Program 

State-Listed Hazardous Waste in Arizona

• Arizona does not have any state-specific wastes subject to RCRA manifest and reporting requirements and follows federal waste designations and waste codes
• A full list of EPA hazardous waste codes can be found here https://www.epa.gov/hw/defining-hazardous-waste-listed-characteristic-and-mixed-radiological-wastes  

Arizona 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 have compliance and reporting requirements in Arizona, which include:

• • Register with the ADEQ (EPA) using ADEQ’s state portal (myDEQ) to obtain an EPA number
  • Submit registration reports annually by March 1st
    • VSQGs have no registration fees

• Note: Annual registration reports must be submitted before generation reports can be completed 

• Submit generation reports annually by January 30th 
  • Pay generation fees 
• Conduct waste determinations for all waste streams 
• Ensure storage does not exceed 2,200 lbs of hazardous waste on-site at any time
• Store hazardous waste in appropriate containers
• Manage waste to minimize risk to human health 
• Keep documents relating to waste determination and shipments 

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 in Arizona must take steps to ensure compliance, including:

• • Submit registration reports annually by March 1st
    • Pay the annual reporting fee
    • Note: Annual registration reports must be submitted before generation reports can be completed 
  • Submit generation reports annually by January 30th 
    • Pay generation fees
  • Conduct waste determinations for all waste streams: keep detailed records of how waste determinations are made
  • Ensure storage does not exceed 13,200 lbs or occur for longer than 180 days (or 270 days if the only TSDF is 200 miles or more miles away) 
  • Store hazardous waste in appropriate containers 
    • Conduct weekly inspections of tanks and storage containers Note: While documentation of inspection is implied by Federal requirements, Arizona explicitly requires documentation
    • Use the words “hazardous waste” on all storage containers 
    • Label containers with accumulation start dates 
  • Post emergency contact information and procedures for spill responses 
  • Provide basic training for employees handling hazardous waste
  • Name an emergency coordinator who is available 24 hours a day to respond to emergencies
  • Only use permitted TSDFs 
  • Use Uniform Hazardous Waste Manifests (UHWM) for waste shipments via the e-Manifest system
    • Provide Land Disposal Restrictions (LDR) for each waste shipment that will be disposed of in a land-based unit
  • Maintain all records for a minimum of 3 years
  • Starting January 22, 2025: register in RCRAInfo and maintain an account to access the federal e-Manifest system
• Note: As Arizona maintains EPA ID requests through myDEQ, facilities will have to manage site contacts associated with the EPA ID number in two portals: RCRAinfo and myDEQ.

Large Quantity Generator (LQG) Requirements

LQGs generate more than 2,200 lbs per month of hazardous waste or more than 2.2 lbs per month of acutely hazardous waste. LQGs must submit federal biennial reports to the EPA every 2 years. In addition to federal reporting requirements, LQGs must:

• • Submit registration reports annually by March 1
    • Pay the annual registration fee 

• Note: Annual registration reports must be submitted before generation reports can be completed 

• Submit generation reports quarterly (due date 30 days after the quarter’s end)
  • Pay generation fees
• 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 
  • Conduct weekly inspections of tanks and storage containers Note: While documentation of inspection is implied by Federal requirements, Arizona explicitly requires documentation
  • Use the words “hazardous waste” on all storage containers 
  • Label containers with accumulation start dates
• Use the UHWM for all waste shipments via the e-Manifest system
  • Submit a LDR Notification with each waste shipment that will be disposed of in a land-based unit
• Develop a waste minimization plan 
• Develop and maintain a contingency plan addressing emergency response procedure
  • Provide copies to local emergency responders and document arrangements with those emergency responders
  • Develop a Quick Reference Guide (QRG)
• Provide formal training to all employees on hazardous waste handling and emergency response within 6 months of hire 
  • Conduct annual refresher training 

• Submit federal biennial hazardous waste reports in even-numbered years
• Maintain all records for a minimum of 3 years

Examples of Facilities Subject to Waste Reporting

Below is a list of common facilities in Arizona and the wastes they generate that would likely require the submission of a RCRA biennial waste report:

• Mining operations: Chromium waste from metal extraction, corrosive tailing waste, wastewater treatment sludge, mercury-containing waste from ore processing
• Aerospace operations: Spent solvents, flammable wastes from paints and coatings, chromium waste from plating, glycol-containing waste from de-icing
• Healthcare facilities: Acutely hazardous pharmaceuticals, mercury-containing devices, formaldehyde from labs, corrosive cleaning agents 
• Renewable energy facilities: Corrosive waste from batteries, lead-containing waste from solar panels, mercury-containing materials in older panels and equipment, solvent waste from cleaning 
• Dry cleaners: Perchloroethylene 
• Retail and big-box stores: Ignitable waste from returned or damaged goods, lead-containing electronics, discarded or expired products, wastes containing ethylene glycol 
• Telecommunications facilities: Lead-acid batteries from equipment, corrosive cleaning agents, mercury-containing components from old devices, spend solvents used in cleaning 

Hazardous Waste Manifest Requirements for Arizona Facilities

All shipments of hazardous waste must use hazardous waste manifests for waste shipments. All shipments must use the federal Uniform Hazardous Waste Manifest (EPA Form 8700-22, or UHWM)

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:

• Arizona requires 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 SQGs 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 ADEQ
    • Starting December 1, 2025, exception reports must be submitted electronically through e-Manifest 

Common Manifest Errors

• Missing information: including EPA ID numbers, container counts, and waste codes
• Inaccurate information: Transposed numbers, incorrect dates, incorrect units of measure for waste quantities.
• Incorrect waste codes 
• Failure to include LDRs when needed
• Failure to maintain copies: final manifests must be maintained as paper or electronic copies in the e-Manifest system. Facilities may be required to provide copies of manifests during inspections or demonstrate the ability to access the federal e-Manifest system
  • Starting January 22, 2025, all SQGs and LQGs will be required to register with the federal e-Manifest system

Arizona Electronic Waste Reporting System (myDEQ)

Overview of myDEQ

Arizona utilizes the state-based myDEQ system for annual registration reports and generation reports. LQGs required to submit federal biennial reports must use RCRAInfo to comply with federal reporting requirements. Arizona requires electronic reporting to ensure a unified, standardized platform that is accessible to all authorized agencies across the state. 

How to Submit an Annual Registration Report in myDEQ

• Go to myDEQ and login
  • Locate the facility to be reported, and select the action “Registration Report” from the drop-down menu
• Verify your generator category and fees 
• Certify the information and pay reporting fees 
• Return to myDEQ homepage and print the certification form 

How to Submit a Generation Report in myDEQ

• Compile information needed to submit the report:
  • RCRA hazardous waste generated for each open reporting period
• Go to myDEQ and login
  • Locate the facility to be reported, and select the action “Generation Reporting” from the drop-down menu
• Enter the quantity of wastes disposed on site and waste shipped off-site
• Review information and fee amounts, certify the report, and submit 
  • Reporting fees can be paid at the time of submission or at a later date 
• Download and print the confirmation report. Store this confirmation for a minimum of 3 years 

How to Submit a Hazardous Waste Report in RCRAInfo

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

• Go to https://rcrainfo.epa.gov/rcrainfoprod/action/secured/login and either create a new account or sign in with your existing credentials. 
• Access the biennial reporting 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 (OI) Form: this form must be submitted for all off-site receiving facilities who:
    • Shipped away waste that was on a UHWM
    • Generated special waste, regardless of generator status
    • Received waste from off-site
  • 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
  • Waste Received (WR) Form: If the facility received RCRA hazardous waste from off-site sources 
• Review and submit your waste reports

Deadlines, Timelines RCRA Reporting Frequency

Generation Reporting Deadlines

• For VSQGS and SQGs, annual generation reports are due by March 1st. 

• For LQGs, generation reports are due quarterly by:
  • First quarter – April 30th
  • Second quarter – July 30th
  • Third quarter – October 30th
  • Fourth quarter – March 1st 

Annual Registration Reporting Deadline

Annual registration reports are due by March 1 each year to ADEQ for all generators and TSDFs. It is important to note that annual registration reports must be submitted before generation reports can be completed

RCRA Biennial Reporting Deadline

Biennial reports are due by March 1st of every even number year regarding information from the previous year

Tips for Effective RCRA Reporting

Maintain Continuous Records

• Establish a centralized storage system to facilitate quick and efficient access to essential documents and records. These materials may be required during compliance audits or inspections and can streamline the reporting process. Using electronic storage or digital management software can enhance accessibility and improve data security
• Perform regular self-audits to verify that records are accurate, complete, and in compliance with current RCRA and Arizona-specific regulations. Schedule audits quarterly or semi-annually to review records related to waste generation, storage, and shipment. Additionally, maintain a clear schedule to monitor submission deadlines and ensure timely compliance

Understand State-Specific Reporting Requirements

In Arizona, hazardous waste generators must track their waste generation activities to ensure they meet the state’s reporting requirements. Reporting requirements and deadlines vary depending on generator classification. If your facility increases its waste generation and is reclassified as a higher generator category, your reporting deadlines may change

• Keep in mind that Pima county has its own agency enforcing hazardous waste regulations. Report requirements, deadlines, and fees may vary in Pima county compared to the rest of the state

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 Arizona

Common Mistakes in RCRA Reporting and How to Avoid Them

Incorrectly reporting waste quantities or generator status can occur due to underreporting in an attempt to avoid LQG classification or overreporting caused by data management errors

Tips:

• Develop standardized reporting checklists to ensure the accuracy of submitted information
• Use electronic tracking systems or digital software to automate calculations for waste generation and shipments
• Keep accurate and updated logs of waste generation and disposal throughout the year to maintain reliable records

Failure to Report All Hazardous Wastes

Failing to include certain waste types in reporting can occur unintentionally due to factors such as misunderstanding Arizona regulations, misidentifying waste streams, or not assigning the correct waste codes

Tips:

• Perform regular waste assessments to ensure accurate classification of all waste types
• Update waste determinations periodically to reflect current operations and regulatory changes
• Cross-check waste information with disposal facilities to confirm proper classification and handling

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

Failing to stay current with regulatory changes in Arizona can result from several factors. Facilities may lack dedicated staff to monitor updates, assume that long-standing waste management practices remain compliant, or overlook changes issued by state agencies.

Tips:

• Assign a dedicated staff member or team to track updates to hazardous waste regulations
• Utilize software solutions that monitor regulatory changes and provide notifications about updates
• Stay informed by subscribing to updates from the ADEQ to receive timely notifications about regulatory changes
• Participate in local and state Environmental, Health, and Safety (EHS) associations to stay connected and informed about industry developments and compliance requirements

Late and Missed Submissions

Arizona does not allow for extensions of late biennial report submissions. Ineffective timeline management can lead to missed report submissions. Lacking a centralized compliance center, unclear designation of responsibilities, and insufficient training can contribute to missing deadlines. Failing to submit reports may result in fines. 

Tips:

• Create a shared compliance calendar and set reminders well in advance
• Start compiling hazardous waste data and facility information early (by January at the latest) to avoid last-minute errors
• Use a centralized digital filing system so data can be easily and readily accessed

Penalties for Non-Compliance with RCRA Reporting in Arizona

Potential Fines and Legal Consequences

In Arizona, 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 ADEQ and the federal EPA. ADEQ also issues administrative orders and criminal charges to facilities and operators who violate RCRA. Fines can be based on the severity and frequency of violations, knowledge of the violation, and other factors. As of January 8th, 2025, the maximum penalty for a RCRA violation is $93,058 per violation per day. The EPA is likely to increase this maximum penalty each year. 

• Common violations include:
  • Failing to submit annual or biennial reports
  • Operating as a TSDF without a permit
  • Exceeding storage limits 
  • Improper labeling and storage systems 
  • Failing to keep manifests up to date in e-Manifest system

Disclaimer: Every effort has been made to ensure the accuracy of the information herein. If you have further questions, we encourage you to reach out to a compliance expert or the regulating body for the jurisdiction in which you operate.