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Q. Does the headworks exemption at 40 CFR 261.3 (a)(2)(iv)(A) and (B) apply only to those spent solvents identified in the regulation? If you are below the threshold for the identified solvents, can other solvents be considered exempt?
Under the RCRA used oil regulations at 40 CFR 279, a used oil generator is “any person, by site, who produces used oil or causes used oil to become subject to regulation.” Generators include all persons who produce used oil through commercial or industrial operations and vehicle services.
It would be reasonable to think that when hazardous waste is produced that there is only one hazardous waste generator, given the U.S. Environmental Protection Agency’s (EPA) definition, which states that “Generator means any person, by site, whose act or process produces hazardous waste identified or listed in [40 CFR 261] or whose act first […]
Do you know what new requirements are proposed under the Hazardous Waste Generator Improvements Rule? This infographic provides a view into what may be in store soon for all classes of hazardous waste generators.
Q. We store Lead Metal Scrap on our property and sell it to recyclers. Would I mark Item 12 “Notification of Hazardous Secondary Material Activity” on the 2015 biennial report as “Yes” or as “No”?
Sierra Club de Puerto Rico and other environmental groups could not persuade a panel of the U.S. Court of Appeals for the D.C. Circuit that their challenge to a Clean Air Act (CAA) rule the EPA promulgated in 1980 was timely. According to the groups, that rule provided an illegal definition of any air pollutant […]
It’s been over a year since the U.S. Environmental Protection Agency (EPA) published in the Federal Register its long-awaited final rule revising regulations affecting recycling of hazardous materials under the Resource Conservation and Recovery Act (RCRA). Known as the 2015 Definition of Solid Waste rule (2015 DSW rule), this final rule exempts certain hazardous secondary […]
Scores of national and state-based environmental groups sent a letter to the leadership of the Senate Environment and Public Works Committee (EPW) expressing their opposition to a bill that would negate many aspects of EPA’s rule governing disposal of coal combustion residuals (CCRs) from electric utilities.
A generator’s hazardous waste status is based on the quantity of hazardous waste generated each month. So do all your generated hazardous wastes need to be counted? Yes, but no. The federal regulation at 40 CFR 261.5(c) and (d) sets forth a list of wastes that are exempt from being counted in connection with ascertaining […]
In a recent webinar titled “Hazardous Waste Recycling: Uncover Cost-Effective and Legally Compliant Strategies for Your Organization’s Program,” speaker Philip Comella, Esq., head of the Environmental, Safety and Toxic Torts Group in the Chicago office of Seyfarth Shaw LLP, voiced what many have suspected: that the Resource Conservation and Recovery Act (RCRA) hazardous waste recycling […]