July 10, 2017

GIR Guidance on Drip Pads Issued

The Treated Wood Council asked EPA some questions on how the Generator Improvements Rule (GIR) [81 FR 85732] applies to situations within their industry. EPA responded and formally published the new guidance on RCRA Online as RO 14891. The agency addressed the following questions.

  1. May very small quantity generators (VSQGs) accumulate hazardous waste onsite using drip pads?

Yes. The agency noted that it had already confirmed in the preamble to the GIR that “VSQGs may accumulate hazardous waste on drip pads as long as they also comply with the technical standards of 40 CFR Part 265, Subpart W to ensure the drip pads are operated in an environmentally safe manner.” [81 FR 85768]

  1. Must generators accumulating hazardous waste on drip pads comply with 40 CFR Part 265, Subparts G and H when undergoing closure?

No. Prior to the GIR, large quantity generators (LQGs) were subject only to two specific sections in Part 265, Subpart G:

Under the GIR, LQGs closing drip pads must comply with [§262.17(a)(8)(iv)]:

The agency also clarified that neither LQGs nor small quantity generators (SQGs) accumulating wastes on drip pads must comply with the additional closure requirements in §265.445(c).


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