Connecticut RCRA Hazardous Waste Reporting

Connecticut hazardous waste reporting is regulated by the Connecticut Department of Energy and Environmental Protection (DEEP). The state program is designed to ensure comprehensive “cradle-to-grave” management of hazardous wastes, while protecting the environment and public health. At the federal level, hazardous waste is governed by the Resource Conservation and Recovery Act (RCRA), and compliance with both state and federal RCRA regulations is mandatory for facilities that generate and manage hazardous waste above specific thresholds. Connecticut has adopted all hazardous waste regulations established under RCRA, including the biennial reporting requirements

Understanding Connecticut Hazardous Waste / RCRA Reporting Requirements

Who Needs to Report?

In Connecticut, all generators that are considered large quantity generators in odd-numbered years and Treatment, Storage, and Disposal Facilities (TSDFs) are required to report biennially. Connecticut still refers to Very Small Quantity Generators (VSQGs) as Conditionally Exempt Small Quantity Generators (CESQG) but otherwise generator status mirrors Federal requirements.. A large quantity generator (LQG) is a facility that:

• Generates 2,200 lbs or more of hazardous waste in a single month, or
• Generated more than 2.2 lbs of acute hazardous waste in a single month, or 
• Generated more than 220 lbs of acute hazardous waste spill residue or soil

Facilities engaged in the following activities must also report biennially:

• Treated, stored, or disposed of RCRA hazardous waste on-site in a waste management unit subject to RCRA permitting requirements

State-Listed Hazardous Waste in Connecticut

Connecticut has State Regulated Wastes with specific codes, however, provided these wastes do not meet RCRA thresholds they are not subject to RCRA regulation but must be stored and managed in an environmentally safe manner and generators mixing or treating these may run afoul of Connecticut’s Solid Waste rules.

The Connecticut State Regulated Wastes (CRW) require permits to transport and for disposal, thus simplifying requirements for Generators. As these wastes carry State Regulated Codes, if they qualify as RCRA or ship alongside RCRA wastes, they must show up in EPA’s eManifest. As many of these wastes can be RCRA Hazardous (or overlap with other regulations), Generators are indirectly required to ensure proper waste determination with these:

• CR01 – Wastes containing 50 ppm or greater of Polychlorinated Biphenyls (PCBs); these wastes may overlap with TSCA requirements and could also be a RCRA Hazardous Waste
• CR02 – Waste oil not miscible in water; these wastes can Used Oil (but needing a State Code) or simply a CRW
• CR03 – Waste water soluble oil; these wastes can be Used Oil (but needing a State Code) or simply a CRW
• CR04 – Waste chemical liquid; due to the overly broad nature of CR04, if a chemical is liquid (i.e. fails Paint Filter test) and not RCRA Hazardous, it will be managed as a CR04
• CR05 – Waste chemical solid; due to the overly broad nature of CR05, if a chemical is a solid and not RCRA Hazardous, it will be managed as a CR05. However, CR05 wastes have some exemptions regarding transport

More information on Connecticut Regulated Wastes can be found here.

A full list of EPA Hazardous Waste codes can be found here 

Connecticut Generator Statuses and Requirements

Conditionally Exempt Small Quantity Generators (CESQG) Requirements

In Connecticut, facilities that generate less than 220 lbs of hazardous waste and less than 2.2 lbs of acute hazardous waste are considered Conditionally Exempt Small Quantity Generators (CESQGs). CESQGs are exempt from reporting requirements in Connecticut, but still have regulations to follow to maintain compliance with hazardous waste, including:

• Waste determination
• Ensure storage does not exceed 2,200 lbs of hazardous waste or 220 lbs of contaminated soil on-site at any time
• Store hazardous waste in appropriate containers
• Only use permitted TSDFs for treatment
• Manage waste to minimize risk to human health 

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 state and federal reporting requirements. SQGs must still take steps to ensure compliance, including:

• Register with the DEEP using RCRA Subtitle C Site Identification form (EPA Form 8700-12) to obtain an EPA number through EPA’s myRCRAid
  • Renotify the state every 4 years by submitting EPA form 8700-12 by September 1. First submissions were due September 2021, and now every 4 years after (2025, 2029 and so forth)
• Waste determination: keep detailed records of how waste determinations are made
• Ensure storage does not exceed 2,200 lbs or occur for longer than 180 days (or 270 days if only TSDF distance is greater than 200 miles)  
• Store hazardous waste in appropriate containers 
  • Conduct weekly inspections of tanks and storage areas
  • Develop and maintain a written inspection program
• 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
  • Use the EPA eManifest system
  • Provide Land Disposal Restrictions (LDR) for each waste shipment to be disposed in a land-based unit
  • Note: Connecticut’s Regulations still state that generators must submit a copy of the UHWM within 7 days of the transporter signature to DEEP; however with the launch of eManifest this is void. See: DEEP Letter
• Maintain all records for a minimum of 3 years
• As of January 22, 2025: register in RCRAInfo and maintain an account to access the federal e-Manifest system

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 reporting requirements, LQGs must:

• Register with DEEP using EPA form 8700-12 to obtain an EPA number through EPA’s MyRCRAid 
• Waste determination: Keep detailed records of how waste determinations are made
• Not store hazardous waste on-site for more than 90 days without a permit 
• Store hazardous waste in appropriate containers 
  • Must conduct weekly inspections of tanks and storage areas
  • Develop and maintain a written inspection program
  • Use the words “hazardous waste” on all storage containers and adequate warning visuals 
  • Label containers with accumulation start dates 
• Use the UHWM for all waste shipments
  • Use the EPA e-Manifest system
  • Provide LDR for each waste shipment to be disposed of in a land-based unit
  • Note: Connecticut’s Regulations still state that generators must submit a copy of the UHWM within 7 days of the transporter signature to DEEP; however with the launch of eManifest this is void. See: DEEP Letter
• Develop a written waste minimization program
• 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 
  • Conduct annual refresher training 
• Maintain all records for 3 years
• Submit federal biennial hazardous waste reports in even-numbered years

Examples of Facilities Subject to Waste Reporting

Below are examples of common industries in Connecticut and the types of waste generated that may trigger the need to submit a biennial report:

• Aerospace and defense manufacturing: Spent solvents such as acetone, toluene, and xylene, Ignitable wastes, chromium waste, lead-contaminated waste 
• Pharmaceutical and biotech facilities: Acutely hazardous pharmaceuticals, ignitable solvents, mercury-containing devices, spent solvents
• Metal fabrication and machining shops: Cadmium-contaminated waste from welding, chromium waste from metal finishing, wastewater treatment sludge
• Electronics and semiconductor manufacturing: corrosive etching solutions, cadmium-containing waste, lead waste from soldering and assembly, spent solvents such as toluene
• Universities and Research Institutions: Ignitable solvents from laboratories, corrosive materials from experiments, reactive chemicals, acutely hazardous lab reagents 
• Automotive repair and refinishing shops: ignitable wastes such as solvents and degreases, chromium waste from surface finishing, lead-contaminated waste from batteries, spent paint thinners

Hazardous Waste Manifest Requirements for Connecticut 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:

• Connecticut 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 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 DEEP
    • 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
• A copy of the signed final manifest must be uploaded to the 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 DEEP within 15 days of accepting the waste. This report includes information about the facility, the waste type and quantity, the method of treatment, storage, and disposal, and an explanation of why the waste was unmanifested. By December 1, 2025, unmanifested waste reports must be submitted into e-Manifest within 20 days of accepting the waste.
• 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 with DEEP detailing the discrepancy, copies of waste manifests, and attempts to resolve the issue.  By December 1, 2025, discrepancy reports must be submitted to eManifest within 20 days of the incident

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 Land Disposal Restrictions 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
  • As of January 22, 2025, all SQGs and LQGs will be required to register with the federal e-Manifest system

Overview of RCRAInfo

In Connecticut, the RCRAInfo system serves as the platform for submitting biennial hazardous waste reports, ensuring alignment with federal Resource Conservation and Recovery Act (RCRA) requirements. This electronic system streamlines reporting by enabling facilities to accurately track hazardous waste generation, storage, and management. RCRAInfo’s standardized format simplifies compliance and reduces errors, while electronic submissions improve efficiency and provide real-time access to critical data for regulatory oversight and emergency planning.

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 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 form (OI) form: This form is not required for Connecticut facilities. RCRAInfo may automatically calculate and fill in data on the OI form, but facilities can disregard this data
  • 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

Biennial Reporting Deadline

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

Additional Reporting Requirements (additional waste reports)

Episodic generation: Connecticut allows for CESQGs or SQGs to have one episodic event, planned or unplanned, per calendar year. Generators who notify DEEP 30 days before a planned event or 72 hours after an unplanned event may maintain their generator category. Requirements for CESQGs and SQGs experiencing an episodic event include:

• An active EPA ID 
• Notify DEEP using EPA form 8700-12 and the Episodic Generator Addendum submitted via myRCRAid
• Use of a hazardous waste manifest for waste shipments 
• Appropriate labeling and storage 
• Conclude the event within 60 days from the start date
• Maintain records of episodic events for a minimum of 3 years

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 Connecticut-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

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 Connecticut

Common Mistakes in RCRA Reporting and How to Avoid Them

Incorrectly Estimating Quantity of Reportable Wastes

Incorrectly reporting waste quantities or generator status can occur due to underreporting in an attempt to avoid Large Quantity Generator (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 federal 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

Facilities in Connecticut may fall behind on changing regulations due to many reasons, including a lack of dedicated staff to monitor regulatory updates, the assumption that existing waste management practices are always compliant, or the failure to notice changes from state agencies.

Tips for Staying Compliant:

• Assign Responsibility: Designate a staff member or team to track hazardous waste regulation updates
• Utilize Technology: Use software to monitor regulatory changes and receive notifications when changes happen automatically
• Subscribe to Updates: Stay informed by subscribing to DEEP updates
• Participate in Industry Associations: Join local and state Environmental, Health, and Safety (EHS) associations to stay connected and informed

Late and Missed Submissions

Late biennial report submissions in Connecticut can lead to fines, increased inspections, and designations of non-compliance. 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 biennial 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 Connecticut

Potential Fines and Legal Consequences

In Connecticut, 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 DEEP and the federal EPA. Connecitcut 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 penalties include:

• Failing to submit biennial reports
• Operating as a TSDF without a permit
• Exceeding storage limits
• Failing to keep manifests up to date in the 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.