RCRA
Review Articles
 
 

That’s a lot of waste…

More than 36 million tons. That’s how much hazardous waste was generated via large quantity generators (LQGs) in 2017. EPA has released the 2017 Biennial Report based on EPA Form 8700-13 filings submitted by March 1, 2018. Waste generation and management information collected from LQGs and treatment, storage, and disposal facilities is included and allows the user to examine the statistics for each state and territory and drill down to individual sites managing hazardous waste. EPA has arranged the site to allow the data to be accessed by NAICS code, management methods, and hazardous waste type and properties. Data for sites that are recycling hazardous waste, as well as the quantity of hazardous waste recycled nationally and in each state, are also available for use by the regulated community, governing agencies, and the general public.

Final pharma pre-pub rule released

Big news for healthcare facilities and reverse distributors: A pre-publication copy of the final Subpart P pharmaceutical rule has been released. If you are in the healthcare or reverse distribution industries, you may find that these new regulations will greatly clarify and improve your ability to manage hazardous pharmaceuticals. This is a significant rule with a pre-pub version preamble that is hundreds of pages long. Before the final rule goes live, see what may be in store for your facility. READ MORE

Latest e-manifest happenings

A new year brings new developments for the e-manifest system. While the monthly webinars are temporarily curtailed due to the government shutdown, new FAQs and the first batch of shipment data have been made available. Take a look at our article to help you stay in the know. READ MORE

Auto airbag waste exempted—with conditions

A new conditional exemption from RCRA was promulgated on November 30, 2018. EPA issued an interim final rule, effective immediately, that exempts airbag waste from RCRA regulation provided that certain conditions are met. If you work in the automotive industry, this could very likely benefit you. We’ve summarized the new conditional exemption and some of the associated nuances. READ MORE

Staying ahead of disasters

Nobody can predict a natural disaster, but when one happens, will your community be ready? Unforeseen events may generate millions of cubic yards of debris and other wastes that may be hazardous. Properly planning for these events will prepare communities to manage these wastes more effectively. EPA has created a pre-incident planning poster and brochure to assist stakeholders in this process. A 4-step strategy is outlined to help your community prepare, and recover, after one of these tragic events.

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]






 

 

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