RCRA
Review Articles
 
 

Cigarettes and fireworks, anyone?

Some of the risks associated with products are fairly obvious—like using cigarettes and fireworks simultaneously. But what happens when these products are discarded? EPA has recently weighed in on the RCRA regulatory status of unused cigarettes and fireworks. READ MORE

Burning questions on off-spec used oil

EPA regulates the combustion of off-spec used oil under the Part 279 burner standards in the RCRA regulations. But due to statutory requirements added to the CAA in 1990, the CAA has much more to say about off-spec used oil when burned for energy recovery. To understand the landscape, have a look at our summary. READ MORE

Electronic filing of export paperwork

After December 31, 2017, exporters of hazardous waste, universal waste, spent lead-acid batteries, and cathode ray tubes will be required to file information in the U.S. Customs’ Automated Export System for each export shipment. We’ve got some pointers on where to get information on accessing the system and what paperwork is required. READ MORE

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






 

 

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