July 15, 2016

EPA Extends Comment Period for Corrosivity Characteristic Changes

As we reported in the May 2016 edition of McCoy’s RCRA Review, EPA was petitioned to revise the corrosivity definition due to adverse health effects suffered by first responders and others from the dust generated during the collapse of the World Trade Center towers in 2001. The petition requested that the agency lower the upper regulatory pH value for aqueous wastes from 12.5 to 11.5 and expand the definition to include nonaqueous wastes.

EPA tentatively proposed denying the petition but is taking public comment before finalizing that action. The agency recently extended the comment period until December 7, 2016. [June 10, 2016; 81 FR 37565]

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This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.