RCRA
Review Articles
 
 

Regulatory relief for episodic generators

Some generators are VSQGs or SQGs—except when a planned or unplanned event occurs that pushes them into a higher generator category. This is known as “episodic generation.” One portion of the 2016 generator improvements rule provides regulatory relief for episodic generators. These new provisions allow VSQGs and SQGs to maintain their lower generator category during an episodic event if certain conditions are met. READ MORE

e-Manifest is live—no going back

As of June 30, 2018, the e-manifest system is live in all states, and although EPA didn’t burn the paper manifests, there’s no going back. Whether you will be fully utilizing e-manifest or are still working with paper manifests, this system impacts your operations. The agency has provided a great deal of information in the last year to prepare the regulated community, and we have summarized that information. READ MORE

State of the DSW rules

Over the past decade, EPA has reworked the definition of solid waste (DSW) rules to promote recycling. This has resulted in several iterations and court challenges, culminating in the recent court-mandated vacaturs, So, what is the current state of the DSW rules in the federal regulations? Check out our recently updated white paper to find out.

Ruling results in revised DSW regs

EPA’s definition of solid waste (DSW) rule has been the subject of several court challenges over the years. In response to the latest ruling, EPA has issued revisions to its 2015 DSW reclamation exclusions and definition of legitimate recycling. The May 30, 2018 final rule implements the DC Circuit Court’s vacatur of certain 2015 DSW regulations and reinstatement of 2008 language. READ MORE

EPA’s spring 2018 agenda revealed

EPA’s Office of Land and Emergency Management is working on several RCRA rules. These include a revised ignitability characteristic, a new approach for hazardous waste pharmaceuticals, and managing aerosol cans as universal waste. Come see what’s on the horizon. READ MORE

Are your HW units air compliant?

One of EPA’s current national enforcement initiatives is to reduce air emissions from hazardous waste management units. Based on the results of recent inspections, EPA has released a compliance advisory providing a list of common noncompliance with the Subparts AA/BB/CC air emission regs. Before your inspector shows up, check out if these concerns might apply to you. READ MORE

e-Manifest questions answered

The e-manifest system goes live in less than two months. The regulated community has numerous questions about the e-manifest, and EPA has provided answers to almost 90 FAQs so far. We have digested and summarized the agency’s answers to some of the key questions we are most often asked by our seminar attendees. READ MORE

EPA’s 2017 enforcement stats

If you’re wondering how enforcement for EPA stacked up in fiscal year 2017, the agency has made available its Environmental Enforcement Results for that year. An overview, details, analysis, and an interactive map showing enforcement data are provided online. Some additional background information and links to the site can be found in our article. READ MORE

Watch: Registering for the e-manifest

If you’re involved with shipping hazardous waste, it’s time to register for your e-manifest account. There are different ways of registering and different levels of account access, so you will need to familiarize yourself with the details. Fortunately, EPA has added some training videos to give you a hand. If you can spare a couple of hours now, you will be ready to rock on June 30. READ MORE

Hurricanes, tornadoes, wildfires, and RCRA

A tremendous amount of hazardous and nonhazardous debris is generated during natural disasters, including hurricanes, earthquakes, tornadoes, floods, wildfires, and winter storms. Often, this presents a challenge because proper identification and management of hazardous wastes during response and cleanup can be difficult. To assist, EPA has just released draft guidance on managing such debris and is soliciting public comment. READ MORE

Aerosols becoming universal

EPA is taking up the issue thousands of generators have been clamoring for—adding aerosol cans to the universal waste program. The benefits of Part 273 are well known, and you may soon be able to enjoy these benefits when managing your aerosols. Aerosol can puncturing would also be allowed under the proposed rule. READ MORE

Eleven CCR tweaks proposed

In response to recent Congressional legislation and court actions, EPA has issued a proposed rule that would make several adjustments to its coal combustion residue (CCR) rules. The agency has proposed 11 total changes, most of which will give more flexibility to facility owners. We’ve summarized them for you. READ MORE

Do you know CC controls?

Do your eyes glaze over when trying to navigate RCRA’s air emission standards? Since they are currently a national enforcement priority, they’re worth understanding. But don’t worry, we’ve done the reading so you don’t have to. Sip your coffee and nosh on that glazed donut while you get the skinny on Subpart CC control standards in our guide. READ MORE

GIR questions? EPA answers.

EPA has recently posted answers to frequent questions on the new generator improvements rule (GIR). Because states are currently revising their RCRA programs to adopt the GIR, and this is the first guidance the agency has provided on many provisions, it’s worth a look. If you are familiar with the GIR, you won’t find too many surprises, but there are a few sleepers worth noting. READ MORE

T minus 100 days till e-manifest launch

The countdown is nearing 100 days before June 30, 2018—the date EPA’s new e-manifest system will be officially launched. And it will become the de facto system in all 50 states on that date. We’ve met many people who are unsure of what they need to do to prepare. So, we have a list of five things to point you in the right direction. READ MORE

Clarity through litigation? DSW rule update.

Unless environmental petitioners appeal to the Supreme Court, litigation of EPA’s definition of solid waste (DSW) rule is over. After a rehearing, the DC Circuit Court of Appeals issued its final opinion on the matter. The court ultimately vacated parts of the 2015 regulation and reinstated some of the 2008 language. READ MORE

Things that aren’t waste when burned

Under the RCRA regulations, secondary materials that are burned are usually considered solid (and potentially hazardous) waste. However, EPA has promulgated a list of materials that are not considered solid wastes when burned. Recently, the agency added certain railroad ties to this list of categorical non-waste fuels in Part 241. READ MORE






 

 

See More...