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RCRA rules on the horizon
EPA is working on seven rules that will make interesting changes to the hazardous waste regs. Two new rulemakings would add aerosol cans as universal waste and make changes to the ignitability characteristic. See what’s over the next hill. READ MORE
DSW rule legal woes continue
EPA’s 2015 definition of solid waste (DSW) rule was issued to resolve legal challenges to its 2008 DSW rule. And now the 2015 rule itself has been successfully challenged. The court vacated parts of the 2015 regulation—and reinstated some of the 2008 language. We kid you not. READ MORE
Thoughts on the e-manifest?
The e-manifest advisory board will hold a public meeting in September to solicit advice on the launch of the e-manifest system in 2018. To find out more about this meeting or where to get additional information on the e-manifest, check out our summary. READ MORE
Avoid this analytical pitfall
Don’t get too excited when you see a nondetect for an analytical result. First, check the method detection limit. If it’s above the regulatory level, you may not know as much as you think you do. READ MORE
Compacting = Treatment?
If you are compacting hazardous waste, would that be considered “treatment”? A company that compacts and bales its hazardous waste air filters asked EPA this question recently. And the agency has now responded with formal guidance. To find out the answer, see our summary. READ MORE
GIR guidance drips in
Now that the Generator Improvements Rule (GIR) has begun taking effect, EPA is getting inquiries about how it applies in particular situations. The wood treating industry is the first to receive any formal guidance—specifically on drip pads. We’ve summarized what the agency said. READ MORE
Manifesting off-shore wastes
Off-shore oil platforms are unusual facilities under RCRA because they are, well, off-shore. EPA recently issued some new guidance that rescinds a previous interpretation regarding when manifests must accompany wastes shipped from off-shore oil platforms. READ MORE
GIR is here—are you ready?
EPA’s Generator Improvements Rule (GIR) is now in effect in Alaska, Iowa, New Jersey, and Pennsylvania. Many of the significant new provisions will be welcomed by generators. Although states are not required to adopt all of the new rule, portions are more stringent than the existing regs, so these requirements should become effective in the other 46 states by July 1, 2018. READ MORE
VSQGs vs. CESQGs
As part of the Generator Improvements Rule (GIR), EPA renamed “conditionally exempt small quantity generators” (CESQGs) as “very small quantity generators” (VSQGs). In addition, there are some new provisions for this generator category. We’ve got a quick summary and a new detailed white paper on VSQG requirements to help you understand how these provisions may impact your operations. READ MORE