Review Articles

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

e-Manifest fees add up

June 30 is right around the corner, and that is the date the e-manifest system goes live. EPA will be doling out new fees for manifest usage, and these increased costs could affect everyone in the industry. We’ve summarized what’s happening so you can prepare for the big day. READ MORE

Inflation bumps RCRA penalties

It’s that time of year again. No, not the family reunion (although maybe that too)—annual penalty increases! Effective January 15, 2018, RCRA civil penalties are being raised to keep up with inflation. Read on to see the new costs for noncompliance. READ MORE

RCRA rules on the horizon

EPA has now formally announced its new RCRA rulemakings in the agency’s Fall 2017 regulatory agenda. Last month, when it was posted online, we gave you a rundown of the agency’s outlook. Jump over to our article to see how the new waste rulemakings may impact you. READ MORE

Satellite container management upgrade

State adoption of the Generator Improvements Rule is happening as we speak. And most states will complete their adoption by June 30. Some of the changes affect how facilities manage their satellite accumulation containers. We break down the intricacies to prepare you for the road ahead. READ MORE

Rulemaking priorities revealed

EPA has released their Fall 2017 agenda. In addition to the two final rules discussed elsewhere in this newsletter, EPA is working on five 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 you can expect in 2018. READ MORE

NORM issues?

People periodically ask us: “How should we manage NORM?” They are not referring to their coworker—Norm, but to naturally occurring radioactive material—NORM. Unfortunately, there is no simple or nationally consistent answer to managing Norm or NORM. We can’t help you with the former, but we’ve got some considerable background information to get you going in the right direction on NORM. READ MORE

No secrets here

Documentation for regulatory compliance sometimes involves confidential business information, which can be protected under law. On the other hand, EPA has finalized a rule to exclude hazardous waste import-export documents from confidentiality claims. This action is consistent with the agency’s previous decision that manifest data is not confidential business information. READ MORE

e-Manifest launches June 30, 2018
Fee rule finalized

Put it on your calendar! June 30, 2018 is the day EPA expects that the new e-manifest system will be up and running. But, who’s going to pay and how much? A final rule issued by the agency has answers. We’ve summarized the final fee structure and other changes being made to the manifest management system. READ MORE

Annual RCRA training required if…

The regs say that “facility personnel” need annual RCRA training. But who is that exactly? Sometimes, you have to look past the job title to what the person actually does. The preamble to the November 28, 2016 generator improvements rule has given us guidance on what job functions at a facility trigger the annual RCRA training requirement. READ MORE

Ready for the new container standards?

The November 28, 2016 generator improvements rule made some significant changes to the management of hazardous waste in containers. Some states have already adopted these changes and because they are more-stringent, they are coming to your state, too. The good news is that compliance should not be too difficult. In order to assist you, we’ve summarized the new RCRA container requirements. READ MORE

EPA reveals its strategic plan

Every four years, EPA is required to give us an update on where it’s going and how it’s going to get there. The agency has released its draft FY 2018–2022 strategic plan. In this time of uncertainty, it is well worth a read. READ MORE

DOT puts thumb print on manifest

Because most RCRA hazardous waste meets DOT’s hazardous material definition, and waste is often transported, there is significant interface between these two programs. Thus, a few recent DOT interpretations may affect hazardous waste manifest preparation. READ MORE



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