RCRA
Review Articles
 
 

Maximum RCRA civil penalties on the rise

By law, EPA must adjust maximum RCRA civil penalties annually, and this year's adjustment has been made. Per-day penalties approaching $100,000 are now in effect, depending on the type of violation. See how costly noncompliance can be for 2019. READ MORE

Suggestions on improving the manifest?

Have you ever wanted to enter a waste quantity on a manifest smaller than one pound? What about using a more precise quantity amount, such as 2.3 tons? Better yet, did you ever wish manifest information was the same as that required in your biennial report? EPA is seeking comment on multiple proposals regarding these very issues. We’ve summarized the goals and proposals to help you weigh in with your thoughts and suggestions. READ MORE

Final pharmaceutical rule promulgated

EPA’s final pharmaceutical rule was promulgated on February 22, 2019. The rule will take effect at the federal level on August 21, 2019. EPA hosted a webinar and provided answers to a variety of questions asked by the regulated community concerning this new rule. A recording of the webinar may be accessed via EPA’s CLU-IN website. Last month, we provided a detailed analysis of its various provisions, including management standards for healthcare facilities and reverse distributors, revisions to the P075 nicotine listing, and more. We’ve updated it with links to new Subpart P on the e-CFR. READ MORE

EPA’s 2018 enforcement stats

The agency’s environmental enforcement results are now available for FY2018, detailing the agency’s civil, criminal, and Superfund enforcement achievements. A new feature in this year’s report is a story map, highlighting the agency’s achievements and also providing interactive case maps to track individual enforcement actions. READ MORE

Detailed analysis of RCRA pharmaceutical rule

Last month, we provided an introduction to the new Subpart P pharmaceutical rule. Although the final rule has not yet been promulgated in the Federal Register, we’ve dug dig deeper into the details. Whether you’re at a hospital, a health clinic, or a reverse distributor, this new rule will greatly impact how you manage your unusable pharmaceuticals and empty pharmaceutical containers. See how this rule will affect you before it goes live. READ MORE

Used oil clarifications

From the largest manufacturing facilities to the smallest service centers, just about every site generates used oil. While the used oil regulations of Part 279 might not be particularly lengthy, there are some issues in those regs that you don’t necessarily find in other hazardous waste regulations. What happens when your used oil is mixed with a fuel? How do you manage your oil-soaked absorbents? We investigate these issues, so you don’t have to. READ MORE

New petroleum industry white paper released

Our latest white paper, “RCRA Compliance in the Petroleum Industry,” is available on our website. This guide breaks down the various petroleum-related RCRA issues you may face at your facility. From the E&P exclusion to K-wastes, this paper starts with what is discussed in RCRA Unraveled and takes it to the next level. We hope you find this white paper an excellent addition to our other resources at your disposal.

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.






 

 

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