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Pennsylvania Residual Waste Reporting due March 1st

What is Residual Waste?

The Pennsylvania Department of Environmental Protection (PADEP) regulates the generation, storage, use, transportation, processing and disposal of many types of waste, including hazardous waste, municipal waste and residual waste. Residual Waste is nonhazardous industrial waste (solid, liquid or gas) that is produced by industrial, mining and agricultural operations. Residual waste is incredibly varied. A number of materials fall into the residual waste category. Some examples are:

  • Ash
  • Contaminated Soils
  • Ceramics
  • Gypsum Board
  • Plant Trash
  • Linoleum
  • Leather
  • Rubber
  • Textiles
  • Glass
  • Electronics
  • Filters
  • Fertilizers
  • Pesticides
  • Detergents & Cleaners
  • Oil
  • PCBs
  • Metal-containing Wastes
  • Paints

Each type of residual waste that a company generates is considered a “stream”. Depending on the amounts generated, each stream has to be reported to the PADEP.

Why does the PADEP require reporting of residual waste?

Although residual waste is not considered hazardous, it does include “near-hazardous” wastes. In order to ensure that the environment and/or the public are not harmed, the PADEP keeps tabs on what kinds of residual waste are generated and how they are processed or disposed of. In addition to requiring reports on residual waste, the PADEP also issues permits and performs inspections. It’s important that residual wastes are disposed of properly. If not, the outcome of such behavior could greatly harm the environment or the public.

Who has to file a report?

Residual Waste reporting is only required for industrial, mining and agricultural operations. Households are not regulated. The report you file depends upon the amounts that are generated.

If a company generates more than 13 tons of residual waste (all combined streams) in one year, they need to file Form 330 and also Form 330GM. A Form 330GM needs to be filed for each waste stream. A chemical waste analysis (Form 26R) also needs to be filed for each waste stream.

If your company generates less than 13 tons, you need only file a Form 330 and check off in the appropriate box that you generated less than 13 tons for the reporting year.

If you’re not sure whether the waste you generate is considered residual waste and needs to be reported, check with your regional PADEP office.

Many industries generate residual waste and need to file a Residual Waste report. Some common industries that generate residual waste include:

  • Manufacturing, such as:
    • Plastic Products
    • Metals
    • Foods
    • Textiles
    • Paints
    • Tobacco Products
    • Paper Products
    • Concrete
    • Asphalt
    • Machinery
    • Iron and Steel Products
  • Oil and Gas Extraction
  • Coal Mining
  • Stone and Minerals Mining and Quarrying
  • Electric Power Generation
  • Natural Gas Distribution
  • Printing
  • Pharmaceuticals
  • Automotive Industries
  • Transportation Industries
  • Waste Collection

What’s included in a report?

The Biennial Report, (Form 330 and 330GM) which is only filed once every two years, includes:

  • A description of the facility including names, addresses, ID numbers, contact information, etc.
  • The types of wastes generated, including codes, weights, physical state, etc.
  • How they are managed, such as being processed or disposed of on-site or off-site
  • The names and ID numbers of any waste management facilities that transport, process or dispose of the wastes

Form 26R which is a chemical analysis of residual waste is filed every year. One Form is filed for each waste stream. This report includes:

  • Generator Information such as names, addresses, contact information, etc.
  • Waste Description
    • General Properties such as pH range, physical state and physical appearance
    • Chemical Analysis Attachments
    • Process Description and Schematic Diagrams
  • Management of Residual Waste
    • Processing or Disposal Facilities
    • Beneficial Use
  • Certification

A Source Reduction Strategy (Form 25R) is required to be kept on the generating site if you produce more than 13 tons of residual waste per year. The Source Reduction Strategy is your plan to reduce the amount of residual waste generated each year. This plan needs to be updated every five years or whenever there are significant changes in the type of waste generated or in the manufacturing process.

How to file a report

Residual Waste Reports (Form 330 and 330GM) are biennial. They must be filed by March first of every odd year. The Chemical Waste Analysis (Form 26R) is filed annually by March 1st. All reports contain information for the previous year. Completed reports can be mailed to the PADEP Bureau of Waste Management. This year, the PADEP is also allowing online reporting. You will need to fill out an application form and send it to the Department in order to receive a username and password, as well as instructions for online reporting.

For information on how CCI can help you with Residual Waste Reporting go here. Or Contact Us.

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