Category: Hazardous Waste Management

State Court Jurisdiction Upheld by 7th Circuit in Environmental Case

Two types of jurisdiction were central to a case in which two plaintiff companies deposited hazardous waste generated in Colorado into industrial wells in Illinois. The Illinois Environmental Protection Agency (IEPA) found that the injections were conducted without the required Class I permit and brought charges against the companies before the Illinois Pollution Control Board […]

Under RCRA, What Do ‘More Stringent’ and ‘Broader in Scope’ Mean?

Section 3009 of Subtitle C of the Resource Conservation and Recovery Act (RCRA) allows EPA-authorized states to promulgate hazardous waste regulations that are more stringent (MS) than counterpart federal hazardous waste (hazwaste) rules. If the EPA authorizes the MS provisions, they become part of the federal hazwaste program, which means that the EPA may enforce […]

Should Your Hazardous Waste Be Managed As Universal Waste?

Determining whether you are allowed to, and also whether you should, manage certain generated wastes as universal wastes rather than hazardous wastes is a dilemma that can plague a generator of hazardous waste. The questions the issue brings forth range from knowing what hazardous wastes qualify for universal waste management to identifying the perceivable advantages […]

Countdown to the e-Manifest System Launch!

June 30, 2018, marks the launch date of the U.S. Environmental Protection Agency’s (EPA) national e-Manifest system in all 50 states. Revised regulations are in place, the new system has been tested by users, and countless questions have been asked of the EPA, primarily regarding the mechanics of how to register for and navigate through […]

How the New e-Manifest System Affects Transporters

June 30, 2018, marks the launch of the U.S. Environmental Protection Agency (EPA) national electronic manifest (e-manifest) system. It seems as though much of the focus by the EPA and those who write about the new system has been on how the system will affect hazardous waste generators and “receiving facilities” (i.e., hazardous waste treatment, […]

Hazardous Waste: Property Owner/Operator

Q. A company on my property has generated hazardous waste from past operations (subsurface cleanup) and I’m wondering if I must be identified as the legal owner and operator on the forms for the EPA ID Number and subsequent Biennial Reporting.