Utah RCRA Hazardous Waste Reporting

Utah hazardous waste reporting is regulated by the Utah Department of Environmental Quality (DEQ). 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. Utah has adopted all hazardous waste regulations established under RCRA, including the biennial reporting requirements.

Understanding Utah Hazardous Waste/ RCRA Reporting Requirements

Who Needs to Report?

In Utah, all generators that are considered large quantity generators in odd-numbered years and treatment, storage, and disposal facilities (TSDFs) are required to report biennially. In UT, generator categories are the same as federal definitions. 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 Utah

Utah 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 

Utah 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 
• Use a permitted TSDF or LQG for the consolidation of waste

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 DEQ by submitting RCRA Subtitle C Site Identification form (EPA Form 8700-12) electronically through RCRAInfo
  • Renotify the state every 4 years by submitting EPA form 8700-12 by September 1 
• 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

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 DEQ by submitting RCRA Subtitle C Site Identification form (EPA Form 8700-12) electronically through RCRAInfo
• 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 shipment s
  • 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 federal biennial hazardous waste reports in even-numbered years

Examples of Facilities Subject to Waste Reporting

Below is a list of some common facilities in Utah and the wastes generated that would likely require the submission of a biennial report:

• Mining and mineral processing facilities: Acidic or alkaline process wastewaters, chromium-contaminated waste, lead-contaminated slag or tailings, sludge from aluminum production
• Petroleum refineries: Ignitable refinery wastes, benzene-contaminated wastewater, dissolved air flotation float, slop oil emulsion solids
• Aerospace and defense manufacturing facilities: spent solvents used in degreasing, spent solvents from paint removal, ignitable waste from propellant production, mercury-contaminated waste
• Chemical manufacturing and processing plants: spent solvents, ignitable process waste, corrosive process residuals, distillation residues from chemical manufacturing 
• Metal fabrication and welding facilities: Chromium-contaminated waste from metal finishing, lead dust, wastewater treatment sludge from electroplating
• Automotive repair: Waste paint thinners and solvents, ignitable waste from cleaning agents, lead-acid batteries, benzene from fuel system cleaning

Hazardous Waste Manifest Requirements for Utah Facilities

Utah has adopted all federal standards applicable to hazardous waste tracking, including the use of hazardous waste manifests. UT requires the use of the EPA Uniform Hazardous Waste Manifest for all shipments of hazardous waste by a Small or Large Quantity Generator. Waste manifests may be paper or electronic. Paper copies of manifests must be uploaded to the federal e-Manifest system. 

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:

• Utah does not require manifest copies to be submitted to DEQ
• UT 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 DEQ
    • 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 DEQ 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 DEQ detailing the discrepancy, copies of waste manifests, and attempts to resolve the issue.  By December 1, 2025, discrepancy reports must be submitted into eManifest within 20 days of the incident

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

 

Utah Electronic Waste Reporting System (RCRAInfo)

Overview of RCRAInfo

Utah utilizes the federal RCRAInfo system for biennial RCRA reports. Facilities may mail paper Biennial reports to DEQ if needed. Alabama encourages 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 who:
    • Shipped away waste that was on a UHWM
    • 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 method codes, waste minimization codes, and waste quantities for each waste stream
• Review and submit your waste reports
  • There are no fees associated with submitted biennial reports in UT

 

Deadlines, Timelines RCRA Reporting Frequency

In Utah, biennial hazardous waste reports for LQGs are due by March 1st each even-numbered year to RCRAInfo regarding information on hazardous wastes generated by the facility in the previous calendar year.

Additional Reporting Requirements (additional waste reports)

Episodic generation: UT allows for one planned or unplanned episodic event that would cause a facility to temporarily increase its generator status. Facilities experiencing an episodic event must notify DEQ via the electronic myRCRAid system no later than 30 days before a planned event or 72 hours after an unplanned event. Generators must obtain an active EPA ID number and remove the waste within 60 days of the event. More information about episodic generation in UT can be found here

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 Utah regulations. Consider scheduling quarterly or biannual audits of generation, storage, and shipment records and keep track of deadlines for submissions

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 UT. During inspections, waste determinations, training, records, and more may be requested

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 overreporting due to data management errors/

Tips:

• Implement a waste-tracking system 
  • Consider the use of software tools to automate waste tracking and calculate quantities accurately 
• Conduct regular waste audits monthly or quarterly  
• Standardize reporting processes through the use of standardized checklists, assigned team members, or the use of technology

Failure to Report All Hazardous Wastes

Failing to report all hazardous waste often results from misidentification or underclassification of waste streams. This may occur when facilities overlook smaller or infrequent waste streams, fail to account for mixtures of hazardous and non-hazardous waste, or rely on outdated waste determination practices. Such omissions can lead to underreporting, inaccurate generator classification, and serious compliance violations

Tips:

• Conduct thorough waste audits of waste streams, process changes, and all departments
• Ensure employees are trained annually on hazardous waste identification and classification
• Integrate technology to track waste generation, quantities, and classifications in real time 

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 DEQ 

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 Utah-Specific Waste Regulations

Failing to understand the differences between federal RCRA requirements and Utah-specific rules can lead to non-compliance at the state level.

Tips to avoid non-compliance at the state level:

• Regularly review Utah-specific regulations by consulting the DEQ or environmental compliance experts in the state
• Train employees on Utah and federal 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 Utah

Potential Fines and Legal Consequences

In Utah, 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 DEQ and the federal EPA. Utah 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 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.