Category: Hazardous and Solid Waste

WEEE Directive 2012/19/EU: 3 Questions for U.S. Electronic Equipment Manufacturers

Since August 2005, manufacturers of electronic goods sold in Europe have had to conform to the European Union’s (EU) Waste Electrical and Electronic Equipment (WEEE) Directive. WEEE Directive 2012/19/EU, which EU member states were required to adopt by February 14, 2014, replaced the earlier, and now repealed, WEEE Directive 2002/96/EU.

Is this Tank Subject to RCRA?

Q. The wrong feedstock was placed in Tank A which holds a different one. The resulting mixed ignitable material (D001) is not usable. We intend to move this mixture out of Tank A quickly. Is Tank A subject to RCRA, or is it still a product tank?

Your Hazardous Secondary Materials Recycling: Legit or Sham?

EPA’s Definition of Solid Waste (DSW) Rule, which the U.S. Environmental Protection Agency (EPA) finalized in December 2014 and which went into effect in July 2015, is complicated. While a lot of focus has been on the DSW Rule’s revised “generator-controlled exclusion” and two new exclusions—the “verified recycler” exclusion and the “remanufacturing of solvents” exclusion—in […]

Is Paint a Hazardous Waste?

Q. We spray paint small items such as pumps and motors and puncture the empty paint cans to capture the remaining teaspoon or so of paint that is placed in a drum. Is this remaining paint a hazardous material, and if so, how should we label the drum?

Accumulating Universal Waste: The One-Year Factor

“One year” is the operative time frame for managing universal wastes under the RCRA regulations at 40 CFR 273. All handlers of universal waste have one year to keep universal waste onsite. To prove that it meets this time limitation, the handler must be able to demonstrate the number of days the universal waste has […]

Used Oil Management

Q. As long as the used oil’s flash point is => 140°F, can my spent acetone (used as a degreaser) be disposed of in my onsite oily wastewater treatment facility that has two 30,000 gallon used oil tanks holding used oil sold as on-spec oil?

Reusing Drums for Transport

Q. Can we reuse drums with UN rating code Y1.5/100 to transport two hazardous wastes with the DOT UN numbers of UN1263 and NA3077?

EPA Asks D.C. Circuit to Remand Portions of CCR Rule

The EPA has filed a petition with the U.S. Court of Appeals for the D.C. Circuit to either remand without vacatur or remand with vacatur certain provisions in the Agency’s final rule governing the management and disposal of coal combustion residuals (CCRs) from electric utilities (CCR rule, April 17, 2015, FR). Both industry and environmental […]

CESQG Status

Q. Can we keep our CESQG status if we ship more than 220 lb (e.g. 400 lb) of waste accumulated over an extended period?