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Instructions for Specific Hazardous Waste Reporters

This page supplies specific information regarding specific hazardous waste annual reporting. On this page find information on: asbestos, PCBs, waste oils; groundwater contaminated by leachate; hazardous/radioactive nuclear mixed wastes; lab packs; and waste from foreign countries.

Asbestos, PCBs and Waste Oils

Do not report asbestos, PCBs and waste oils in most cases. Do report them if any of the following conditions exist:

  1. If a listed hazardous waste (this is, a waste whose Hazardous Waste Code begins with "F," "P," "U," or "K") is mixed with the asbestos, PCBs or waste oil. In this case, the entire mixture becomes a hazardous waste; or
  2. If the waste possesses one or more of the characteristics that result in assigning a Hazardous Waste Code beginning with "D".

Do not report "used oil that exhibits one or more of the characteristics of hazardous waste (criterion 2 above) but is recycled in some manner other than being burned for energy recovery" (40 CFR 261.6(a)(iii)). Do report if the waste oil is burned or disposed.

Groundwater Contaminated by Leachate

Groundwater that is contaminated by hazardous waste leachate is not considered a solid waste while it is in the ground and is, therefore, not classified as a hazardous waste. However, when the groundwater is removed, it must be managed as a hazardous waste. When reporting groundwater contaminated by leachate on the Hazardous Waste Annual Report, observe the following conventions:

  1. Do not report generation quantities for contaminated groundwater; and
  2. Do report quantities managed on-site; quantities shipped off-site; and quantities received from off-site.

Hazardous/Radioactive Nuclear Mixed Wastes

By themselves, source material, special nuclear material or byproduct materials (See Definitions) as defined by the Atomic Energy Act of 1954, as amended, 42 US Code 2011 et. seq, are not classified as solid or hazardous waste under hazardous waste regulation. However, if these materials are mixed with a hazardous waste, the material is controlled under hazardous waste regulation, as well as under the Atomic Energy Act (DOE, NRC and EPA) regulations, and is to be reported in the Hazardous Waste Annual Report.

Lab Packs

The following rules should be applied to the reporting of lab pack wastes in the Hazardous Waste Annual Report:

  1. You may aggregate lab pack waste containers in most cases. However, you must report them as separate waste types under the following conditions:
    1. If they contain acute hazardous wastes (Hazardous Waste Codes F020, F021, F022, F023, F026, F027, and all "P" Waste Codes). Report separately from lab packs containing other hazardous wastes (all other Hazardous Waste Codes).
    2. If they are managed differently from each other. For example, report lab packs that are shipped to landfills separately from those that are incinerated.
  2. Enter a form code indicating lab packs ("W001" or "W004") in Generated and Managed (GM) Form. These form codes are to be used with any lab pack, whether the wastes are gaseous, liquid, solid or sludge.
  3. It is not necessary to report every Hazardous Waste Code included in a batch of lab packs. Record one Hazardous Waste Code in the space for Primary Hazardous Waste Code GM Form, If there are many Hazardous Waste Codes enter "LABP" in GM Form.
  4. When reporting quantities for lab packs:
    1. Include the weight of the containers if they are disposed (e.g., landfilled) or treated (e.g., incinerated) along with the wastes.
    2. Exclude the weight of the containers if the waste is removed from the containers before treatment or disposal.

Wastes from Foreign Countries

Report on GM Form- If your site was the generator of record and was the U.S. importer for hazardous waste received from a foreign country, complete GM Form for this waste. Enter the appropriate source code from the list of codes G63 through G75. Report the name and address of the foreign generator in the Comment section. Also check box 1b. United States Importer of Hazardous Waste on the Identification (IC) Form screen to indicate this activity.

Report on Waste Received (WR) Form - If your site received hazardous waste directly from a generator in a foreign country, complete a WR Form for the waste treated, recovered or disposed at your site. This waste was not shipped to your site by a U.S. importer. If the foreign site has an EPA Identification (ID) Number, report receipts from that site just as you would report receipts from a domestic site. If the site does not have an EPA ID Number, enter "FC9999999999" in WR Form and note the name and address of the foreign generator in the Comment section for that waste section.

Contact Information

For questions and assistance in completing the hazardous waste annual report, contact your local Environmental Program Associate.

For general questions and comments about the hazardous waste annual reports, please contact:

DNR Waste Materials@Wisconsin.gov

Last Revised: Wednesday January 13 2010