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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]
SAAs see shrinking benefits
In the mid-eighties, to ease compliance with full 90-/180-day requirements when waste is first collected, EPA implemented the satellite accumulation area (SAA) provisions. Since then, there had been no substantive changes in these regulations until the 2016 generator improvements rule. As a result of the latest changes, there are now fewer benefits to using these units compared to 90/180-day accumulation containers. READ MORE
More e-manifest morsels
The e-manifest system has now been up and running for more than a month. Since its launch on June 30, there have continued to be updates and changes from EPA. And since EPA has continued to provide new information, we would like to do the same. We’ve got an update on what’s been happening over the last month. READ MORE
CCR tweaks finalized (partially)
EPA has issued a final rule that addresses recent court action in response to the promulgation of the 2015 coal combustion residue (CCR) rule. The final rule provides some breaks to facility owners who are managing these Bevill Amendment wastes. However, not all of the originally proposed revisions were finalized. We have a brief summary of EPA’s most recent rule. READ MORE
Regulatory relief for episodic generators
Some generators are VSQGs or SQGs—except when a planned or unplanned event occurs that pushes them into a higher generator category. This is known as “episodic generation.” One portion of the 2016 generator improvements rule provides regulatory relief for episodic generators. These new provisions allow VSQGs and SQGs to maintain their lower generator category during an episodic event if certain conditions are met. READ MORE
e-Manifest is live—no going back
As of June 30, 2018, the e-manifest system is live in all states, and although EPA didn’t burn the paper manifests, there’s no going back. Whether you will be fully utilizing e-manifest or are still working with paper manifests, this system impacts your operations. The agency has provided a great deal of information in the last year to prepare the regulated community, and we have summarized that information. READ MORE
State of the DSW rules
Over the past decade, EPA has reworked the definition of solid waste (DSW) rules to promote recycling. This has resulted in several iterations and court challenges, culminating in the recent court-mandated vacaturs, So, what is the current state of the DSW rules in the federal regulations? Check out our recently updated white paper to find out.
Ruling results in revised DSW regs
EPA’s definition of solid waste (DSW) rule has been the subject of several court challenges over the years. In response to the latest ruling, EPA has issued revisions to its 2015 DSW reclamation exclusions and definition of legitimate recycling. The May 30, 2018 final rule implements the DC Circuit Court’s vacatur of certain 2015 DSW regulations and reinstatement of 2008 language. READ MORE
EPA’s spring 2018 agenda revealed
EPA’s Office of Land and Emergency Management is working on several RCRA rules. These include a revised ignitability characteristic, a new approach for hazardous waste pharmaceuticals, and managing aerosol cans as universal waste. Come see what’s on the horizon. READ MORE
Are your HW units air compliant?
One of EPA’s current national enforcement initiatives is to reduce air emissions from hazardous waste management units. Based on the results of recent inspections, EPA has released a compliance advisory providing a list of common noncompliance with the Subparts AA/BB/CC air emission regs. Before your inspector shows up, check out if these concerns might apply to you. READ MORE
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