If you manage hazardous waste reporting across multiple states, Tennessee can feel familiar — right up until it doesn’t. Now that Tennessee reporting has moved into RCRAInfo it mirrors many federal requirements but Tennessee applies its own rules around who must file, how often, and what documentation is required. Those differences matter, especially as facilities prepare for Report Year 2025, due March 1, 2026.

Here’s a clear breakdown of what makes Tennessee reporting unique — and where teams most often run into trouble.

Annual Means Annual — No Exceptions

The biggest distinction is also the easiest to overlook. Tennessee requires annual hazardous waste reporting, not biennial reporting like the EPA.

That means even if your facility filed last year, you are filing again this year.

For Reporting Year 2025, facilities will submit through the Biennial Report module in RCRAInfo because it is an odd-numbered year. Even-numbered years use the Annual Report module. Despite the naming difference, the data requirements remain the same — but the module selection still matters.

Small Quantity Generators Must File

Under federal rules, only Large Quantity Generators must submit hazardous waste reports. Tennessee expands that requirement.

Facilities must file an annual report if they are:

• Large Quantity Generators.
• Small Quantity Generators producing between 220 and 2,200 pounds per month.
• Very Small Quantity Generators that notified the state of an episodic event during the reporting year.
  

For organizations managing multi-state portfolios, this is an easy miss. A facility that does not report federally may still have a Tennessee reporting obligation.

Units of Measure — Pounds or Kilograms Only

This is one of the most common causes of report rejection.

While federal forms allow seven different units of measure, Tennessee accepts only two:

• Pounds.
• Kilograms.
  

No gallons. No cubic yards. No short tons.

Facilities must convert all quantities before submission. Weight-based conversions are straightforward, but volumetric conversions require accurate density data. Any submission containing disallowed units of measure will be rejected.

If your internal systems default to volumetric units, it is worth flagging Tennessee sites early so conversions are handled before quality control begins.

Waste Stream Numbers Must Carry Forward

If a waste stream has been reported in prior years, Tennessee requires that its assigned waste stream number be included in the waste description.

For example:

| WS1: Ignitable spent solvent from degreasing operations

This requirement supports continuity in Tennessee’s tracking system and enables year-over-year analysis. Facilities should reference Report Years 2023 and 2024 to identify the correct waste stream numbers before entering current-year data.

Waste Minimization Codes N and X Require an Explanation

Federally, selecting a waste minimization code is often the end of the story. Tennessee requires one more step.

If a facility selects:

• Code N — Minimization efforts were evaluated but found economically or technically impracticable.
• Code X — No waste minimization efforts were implemented.
  

A written explanation must be included in the Comments section.

The explanation does not need to be lengthy, but it must clearly state why minimization was not feasible. Submissions that include codes N or X without comments are frequently flagged for follow-up.

Inventory Carryover Must Be Documented

If the quantity generated does not equal the quantity shipped off-site plus the quantity managed on-site, Tennessee requires facilities to explain the difference.

The Comments section must include:

• Amount on-site as of January 1.
• Amount on-site as of December 31.
  

These values must be reported using the same unit of measure as the rest of the waste stream. This requirement ensures accurate reconciliation across reporting years and often surfaces when facilities rely solely on manifest totals.

H141 Is Being Phased Out

Management Method Code H141 — storage or bulking prior to transfer — is on its way out in Tennessee.

• Report Years 2025 and 2026: H141 is still accepted but discouraged. It is best to use the final management method code from your waste vendor data.
• Report Year 2027 and beyond: H141 will no longer be accepted.
  

Tennessee expects facilities to report waste through final disposition using the appropriate S-series management method codes. This is a good time to work with TSDFs to obtain final disposition data and begin transitioning away from H141 where possible.

New Waste Streams Come With a Fee

Tennessee assesses a $100 fee for each new waste stream reported for the first time through the annual report.

To determine what qualifies as “new,” facilities should compare current waste streams against those reported in 2023 and 2024. New waste streams must be accounted for on the Generator Fee Determination Sheet (G-FDS).

Fee Forms Are Submitted Separately

Submitting your report in RCRAInfo does not complete the process.

Tennessee requires fee determination forms to be submitted separately from the electronic report, with an original or encrypted electronic signature. Required forms may include:

• G-FDS — All facilities.
• TSD-FDS — Permitted treatment, storage, or disposal facilities.
• RF-FDS — Remediation sites.
  

These forms must be mailed or emailed directly to the Tennessee Department of Environment and Conservation. Facilities are often surprised to receive follow-up notices months later when this step is missed.

A Quick Pre-Submission Check

Before submitting your Tennessee Annual Hazardous Waste Report, confirm that you have:

• Verified all required facilities are filing, including SQGs.
• Converted all quantities to pounds or kilograms.
• Included waste stream numbers for previously reported streams.
• Added explanations for waste minimization codes N and X.
• Documented carryover inventory where quantities do not reconcile.
• Reviewed management method codes and limited H141 usage.
• Calculated new waste stream fees.
• Prepared fee forms for separate submission.
  

The Bottom Line

Tennessee’s requirements are not dramatically different from federal reporting — but the differences that exist are specific, enforceable, and easy to miss. Annual filing, expanded generator applicability, strict unit-of-measure rules, and added documentation requirements all demand extra attention.

Starting early gives teams time to reconcile data, validate conversions, and avoid last-minute rejections as the March 1 deadline approaches.

If you need help navigating Tennessee’s requirements — or managing hazardous waste reporting across multiple states — Encamp’s compliance experts are here to support you.