RCRA
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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 To assist, EPA has just released draft guidance on managing such debris and is soliciting public comment.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

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






 

 

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