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State & federal waste reports

Annual waste summaries
and biennial reports

These reports are arithmetic applied to a year of manifests. The difficulty is never the form; it is that the manifests live in several places, the codes are not consistent between them, and the quantities have to reconcile.

What actually matters

Where this one
goes wrong

01

Manifest data is the whole report

If the manifests are complete and consistent, the summary follows. If they are not, the report becomes a reconstruction exercise. Where KODA moves the material, that record is maintained as the year goes rather than gathered at the end of it.

02

Codes drift between sites

The same material classified one way at one plant and another way at a second plant produces totals that cannot be compared and a report that invites a question. Catching that is part of the work.

03

Texas has its own filing

The Annual Waste Summary is a state requirement separate from the federal biennial report, and registered generators file one whether or not they had reportable waste. Filing nothing is not the same as filing a nil return.

04

The biennial report is every other year

It covers odd-numbered years and is due the following March, which means it is easy to lose track of. It applies to large quantity generators and to facilities that treat, store or dispose.

What we need from you

To start

  • Manifests for the reporting year, across every site
  • Registration or EPA identification numbers for each facility
  • Waste codes and classifications as shipped
  • On-site management quantities, where any apply

What you get back

To file

  • Completed summaries ready for submission
  • A reconciliation showing how the totals were reached
  • Codes and classifications checked for consistency across sites
  • A standing record, so the following year is a comparison

Deadline

Texas AWS: 1 March electronically. RCRA Biennial: 1 March of even years

KODA prepares the submission. Your authorized official certifies and files it — that is how the requirement is written, and anyone telling you otherwise is describing it loosely.

Questions

Asked most often

What are the deadlines?

In Texas the Annual Waste Summary is due 1 March when filed electronically through STEERS, and 25 January on paper. The federal RCRA Biennial Report is due 1 March in even-numbered years, covering the odd-numbered year before it. Other states run their own schedules.

We had almost no waste. Do we still file?

In Texas, registered generators file an Annual Waste Summary regardless, indicating that no report is required where that is the case. A missed filing and a nil filing are not treated the same way.

We have sites in several states.

Then you have several schedules and several formats. One structure across the sites is what makes that manageable, and it is the same structure the reporting runs on.

Start before the deadline,
not on it

Tell us which filings you carry and we will tell you what we would need and when we would need it.