RCRA
Review Articles
 
 

CCR rules in reverse

The DC Circuit Court of Appeals has issued a decision vacating portions of EPA’s current coal combustion residues (CCR) rule for not being stringent enough. Because of this, the agency will likely need to forgo its current two-phase relaxation of CCR regs and instead reverse course to strengthen regulatory requirements. Additionally, states regulators that are crafting their own CCR programs are now faced with significant uncertainty. READ MORE

ID your BB equipment

Did you know there is a leak detection and repair (LDAR) program in RCRA just like those in the CAA? If you operate hazardous waste equipment that is not controlled under the CAA, you may need to demonstrate compliance with Parts 264/265, Subpart BB. These standards are designed to prevent fugitive emissions, and compliance begins with the proper identification of your equipment. Because this is a national compliance initiative, it’s a good idea to identify all your BB equipment now. READ MORE

Cookin’ up some RCRA rules

If you’ve checked out the latest regulatory agenda, you know that EPA’s Office of Land and Emergency Management has been busy working on some very interesting RCRA rules. These include a new program for managing hazardous pharmaceuticals as well as adding aerosol cans as universal waste. We’ve got a summary of what’s cooking in the agency’s kitchen. READ MORE

e-Manifest for e-mergency personnel

If you manage emergency response and cleanup personnel, they may need authorization to sign e-manifests. EPA has released a new fact sheet to help explain how these personnel may be affected and what they must do to gain access to the e-manifest system. Five-page paper manifests may still be used to track wastes generated during emergency responses. But as with all other paper manifests, this information will ultimately be entered into the e-manifest system.

How-tos for household pharma takebacks

Household pharmaceutical wastes are not subject to RCRA, but they may be dangerous none the less. Mismanaged, unwanted pharmaceuticals can be, and are, abused by people and released into the environment. To help prevent this, DEA and law enforcement agencies have programs for the safe collection of these unwanted pharmaceuticals. EPA has provided guidance on how law enforcement can manage this process. READ MORE

Airbag guidance glossed up

If you are in the auto industry, you will likely have to manage airbags at some point. What do you do when you make the decision to discard some? Are they solid waste? Are they hazardous? What if you are dealing with recalled Takata brand airbags? EPA has issued some clarifying guidance that summarizes the agency’s position on the regulatory status of these materials. READ MORE

RCRA Online 2.0

EPA has revamped their RCRA Online database to provide an updated look and streamlined experience. While the guidance documents have not changed, the URLs are now a simplified format containing the RO document number. The old RCRA Online website is fading into history, so now is the time to update your links and bookmarks. READ MORE

e-Manifests: updates and developments

We are just over two months into the e-manifest system, and its usage has rapidly risen since June 30. EPA continues to provide new updates and keep us abreast of upcoming functionality. Recently, there have even been changes to manifest submissions for shipments containing Department of Homeland Security chemicals of interest. As always, we have the skinny on the latest and greatest. READ MORE

GIR tightens container labeling

Like to label your drums “Spent Solvents”? Prefer a more casual approach such as “Bad Stuff”? Maybe you really like exclamation points and use “Hey homies! No rags allowed!” Well forget about any of those satisfying the generator improvements rule (GIR) labeling requirements. The GIR requires a more-stringent and standardized approach to how containers are labeled. This includes nuanced pretransportation requirements as well. See how you can maintain compliance without exceeding your exclamation point quota. READ MORE

Address change for import/export paperwork

Effective August 6, 2018, there is a change in the address where paper notification documents for imports/exports of hazardous waste and conditionally excluded cathode ray tubes must be sent [see §262.82(e)(1)]. Notifications must now be addressed to EPA at the “Office of Land and Emergency Management, Office of Resource Conservation and Recovery, Materials Recovery and Waste Management Division, International Branch (Mail Code 2255A) Environmental Protection Agency, 1200 Pennsylvania Ave. NW, Washington, DC 20460.” [83 FR 38262]

SAAs see shrinking benefits

In the mid-eighties, to ease compliance with full 90-/180-day requirements when waste is first collected, EPA implemented the satellite accumulation area (SAA) provisions. Since then, there had been no substantive changes in these regulations until the 2016 generator improvements rule. As a result of the latest changes, there are now fewer benefits to using these units compared to 90/180-day accumulation containers. READ MORE

More e-manifest morsels

The e-manifest system has now been up and running for more than a month. Since its launch on June 30, there have continued to be updates and changes from EPA. And since EPA has continued to provide new information, we would like to do the same. We’ve got an update on what’s been happening over the last month. READ MORE

CCR tweaks finalized (partially)

EPA has issued a final rule that addresses recent court action in response to the promulgation of the 2015 coal combustion residue (CCR) rule. The final rule provides some breaks to facility owners who are managing these Bevill Amendment wastes. However, not all of the originally proposed revisions were finalized. We have a brief summary of EPA’s most recent rule. READ MORE

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.






 

 

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