Iowa RCRA Hazardous Waste Reporting

Iowa does not have its own state-based agency authorized to enforce hazardous waste regulations. The EPA monitors and enforces regulations through the U.S. EPA Region 7 office. The Resource and Conservation Recovery Act (RCRA) provides  “cradle-to-grave” management of hazardous wastes, prioritizing protecting the environment and public health. Compliance with federal RCRA regulations is mandatory for facilities that generate and manage hazardous waste above specific thresholds. Iowa has adopted all hazardous waste regulations and exemptions established under RCRA, including the biennial reporting requirements

Understanding Iowa Hazardous Waste/ RCRA Reporting Requirements

Who Needs to Report?

In IA, all generators that are considered large quantity generators in odd-numbered years and treatment, storage, and disposal facilities (TSDFs) are required to report biennially. 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 Iowa

• IA 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

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

• Waste determination
• 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 are exempt from federal reporting requirements. SQGs must still take steps to ensure compliance, including:

• Register with the EPA using RCRA Subtitle C Site Identification form (EPA Form 8700-12) to obtain an EPA number
  • Renotify the EPA every 4 years by submitting EPA form 8700-12 by September 1. First submissions were due September 2021, and now every 4 years after
• Waste determination: keep detailed records of how waste determinations are made and keep records for at least 3 years
• Ensure storage does not exceed 13,200 lbs or occur for longer than180 days 
• Store hazardous waste in appropriate containers 
  • Conduct weekly inspections of tanks 
• Post emergency contact information and procedures for spill responses
• Have a waste minimization certification 
• 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 Waste Manifests for waste shipments
  • Keep copies of manifests for a minimum of 3 years 
  • Provide land disposal restrictions (LDR) for each waste shipment
• Maintain 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
• Submit a Hazardous Waste Activities Form (DNR Form 179 (542-1248)) by April 15th of each year
  • Complete the Hazardous Waste Fee Collection Form and pay associated fees by April 15th 

Large Quantity Generator (LQG) Requirements

Large Quantity Generators (LQGs) generate more than 2,2000 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 the PDEPand obtain an EPA number
• Waste determination: Keep detailed records of how waste determinations are made. Keep records for at least 3 years
• Not store waste on-site for more than 90 days without a permit 
• Store hazardous waste in appropriate containers 
  • Must conduct weekly inspections of storage areas
  • Use the words “hazardous waste” on all storage containers 
  • Label containers with accumulation start dates 
• Use the Uniform Hazardous Waste Manifest for all waste shipments
  • Use the EPA e-Manifest System
• Provide a waste minimization certificate 
• Submit a Land Disposal Restriction (LDR) Notification with each waste shipment that will be disposed of in a land-based unit
• 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 training records for 3 years
• Submit a Hazardous Waste Activities Form (DNR Form 179 (542-1248)) by April 15th of each year
  • Complete the Hazardous Waste Fee Collection Form and pay associated fees by April 15th 

Examples of Facilities Subject to Waste Reporting

Below is a list of common facilities in Iowa and the wastes generated that would likely trigger the need to submit a biennial report.

• Ethanol Production Plants: Ignitable waste from ethanol production processes, corrosive waste from cleaning tanks and equipment, spent solvents used in facility maintenance
• Healthcare facilities: Acutely hazardous pharmaceuticals, mercury from older medical devices, formaldehyde used in labs, corrosive cleaning and disinfecting agents
• Manufacturing facilities: Chromium from electroplating, lead from batteries or old equipment, spent solvents from cleaning and degreasing operations, ignitable waste from paints and coatings 
• Automotive repair shops: Spent solvents and brake cleaners, lead waste from batteries and old components, paint-related waste from bodywork and repairs, benzene-contaminated fuels

Hazardous Waste Manifest Requirements for Iowa 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:

• IA 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 the 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 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 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 to the EPA 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 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

Iowa Electronic Waste Reporting System (RCRAInfo)

Overview of RCRAInfo

In Iowa, the RCRAInfo system serves as the primary platform for submitting biennial hazardous waste reports. 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

• 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 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
  • 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

Annual Reporting Deadline

Annual Hazardous Waste Activities forms and annual fees are due each year by April 15th for SQGs and LQGs in Iowa

Biennial Reporting Deadline

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

Additional Reporting Requirements (additional waste reports)

Episodic generation: IA allows for one episodic event, planned or unplanned, per calendar year. Generators that notify EPA 30 days before a planned event or 72 hours after an unplanned event may maintain their generator category.

Requirements for VSQGs and SQGs experiencing an episodic event include:

• An active EPA ID 
• Notify EPA 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

• Implement a centralized digital storage system to securely manage and organize essential documents and records, ensuring easy access during compliance audits, inspections, and reporting
• Conduct routine self-audits, such as quarterly or biannually, to maintain accurate and complete records that align with current RCRA and state-specific regulations about waste generation, storage, and shipment.
• Establish and maintain a clear schedule to track and meet all submission deadlines to 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 with Iowa regulations

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 Iowa 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 may fail to stay current due to a lack of dedicated staff for regulatory monitoring, make assumptions that old practices remain compliant, or overlook changes from federal agencies.

Tips:

• Dedicated Regulatory Tracking: Assign a staff member or team to specifically monitor updates to hazardous waste regulations
• Software Solutions: Utilize software to track regulatory changes and receive notifications of updates
• Subscribe to Official Updates: Stay informed by subscribing to updates from the EPA
• Participate in EHS Associations: Engage with local and state Environmental, Health, and Safety associations to stay connected and informed about industry developments and compliance requirements

Late and Missed Submissions

Iowa does not allow for late biennial report submissions without penalty. 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 of up to $10,000 per day. 

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 Iowa

Potential Fines and Legal Consequences

In Iowa, non-compliance with RCRA reporting requirements can result in penalties, including fines and civil or criminal enforcement actions. These penalties are enforced by the federal EPA. Local EPA regional offices issue administrative orders or pursue criminal charges against facilities and operators that violate RCRA regulations. Penalties and fines are determined based on factors such as the severity and frequency of violations, the facility’s knowledge of the infraction, and the duration of non-compliance. As of January 8, 2025, the maximum penalty for a RCRA violation is $93,058 per violation per day, with the EPA expected to adjust this amount annually.

Common penalties include:

• Failing to submit biennial hazardous waste reports
• Submitting annual reports late: A penalty of 8% per annum calculated from March 1, plus an additional 5% of total fees due for every 30 days the report is delayed
• Operating as a Treatment, Storage, and Disposal Facility (TSDF) without a permit
• Exceeding hazardous waste storage limits without authorization
• Failing to maintain accurate and up-to-date waste manifests 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.