Tier II, Annual Waste Summary, and Biennial Hazardous Waste Reporting
TIER II/AWS/BIENNIAL REPORTING OVERVIEW
Tier II reporting is required for any facility that stores hazardous chemical(s) that meet or exceed chemical thresholds at any one time. Annual Waste Summary (AWS) is required for facilities that are registered with the Texas Commission on Environmental Quality (TCEQ) with an active solid waste registration. The AWS reports information on the amount of hazardous waste and Class 1 Industrial waste generated or managed at the facility during the 2022 calendar year. The Biennial Hazardous Waste Report is similar to the AWS; however, large quantity generators of hazardous waste are required to submit a report every two years to the U.S. Environmental Protection Agency (EPA) regarding the origination, disposition, and quantities of the hazardous waste. All three reports are required to be submitted by March 1, 2023.
Potential fees/violations may be accrued. There is also the potential of being audited by a local, state, or federal entity for non-compliance with these issues, which could open the door for regulators to see other areas at the facility that may be out of compliance.
TIER II/AWS/BILENNIAL REPORTING GENERAL APPLICABILITY
Tier II: If the facility stores hazardous chemicals in quantities equal to or greater than the reporting threshold for that chemical, a Tier II must be submitted.
• Reporting Threshold: Hazardous Chemicals: 10,000 lbs
• Extremely Hazardous Substance (EHS): 500 lbs or the threshold planning quantity, whichever is less.
AWS: If the facility generates and accumulates the following quantities of hazardous and Class 1 Industrial Waste, an AWS must be submitted.
• More than 2.2 lbs of acute hazardous waste
• More than 2,200 lbs of hazardous waste or Class 1 industrial waste
Biennial Reporting: Large quantity generators of hazardous waste are required to submit a report every 2 years.
HOW WE CAN SUPPORT YOU
WGA can provide the environmental compliance support needed to complete the reports such as reviewing their 2022 records, make a determination on behalf of client as to whether they meet the Tier II/AWS/Biennial Hazardous Waste Report requirements, and file the applicable reports for the client. WGA can also answer any of the Client’s questions and provide documentation for them to utilize in order to become familiar with the applicable reports required for the facility.
Please contact Richard Fontenot and Kim Martinez for assistance:
HELPFUL RESOURCES AND MATERIALS
TCEQ Tier II Applicability: https://www.tceq.texas.gov/permitting/tier2/am-i-regulated
TCEQ AWS Applicability: https://www.tceq.texas.gov/permitting/registration/ihw/waste_reporting.html
EPA Biennial Report Applicability: https://www.epa.gov/hwgenerators/biennial-hazardous-waste-report