Pennsylvania Residual Waste Reporting (Primer)

Residual Waste is nonhazardous industrial waste (solid, liquid or gas) that is produced by industrial, mining and agricultural operations. Residual waste is incredibly varied and generally includes any waste that is not hazardous waste. Certain exception applies! For example: sanitary sewage, uncontaminated non-contact cooling water, office/lunchroom/restroom waste, and construction/demolition debris is not reportable.

Pennsylvania’s solid waste regulations require that Generators of Residual Waste that produced more than 13 tons of residual waste in 2016 submit a residual waste biennial report to PADEP and develop source reduction strategies. Biennial reports (Form330 and Form 330GM) are due March 1, 2017.

Residual waste generators that generate more than 2,200 pounds of residual waste in any month must perform detailed analysis that fully characterize the physical properties and chemical compositions of each type of waste. A chemical waste analysis (Form 26R) needs to be submitted to PADEP annually for each waste stream.  Form 26R is due on March 1.

A Source Reduction Strategy (Form 25R) is required to be kept on the generating site if the generator produces more than 13 tons of residual waste per year. The Source Reduction Strategy is a 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.

Pennsylvania residual waste regulations are codified in Article IX: Residual Waste Management (25 Pa. Code § 287 – 299).

Determination of what waste streams are subject to residual waste reporting and recordkeeping requirements can be challenging and can lead to incorrect reporting.  Contact Sam Joshi, P.E. at (215) 389-2811 if you have any questions.