Category: Hazardous Waste Operations

Who Will Pay EPA’s e-Manifest Fees?

The 2012 Hazardous Waste Electronic Manifest Establishment Act (e-Manifest Act) directed the U.S. Environmental Protection Agency (EPA) to establish a hazardous waste e-manifesting system. The EPA recently proposed a system of user fees for e-manifests. Today we will take a look at how these fees are intended to work and who will actually end up […]

What You Should Know About Changing Your HazWaste Generator Status?

Stuff happens. One day you’re a conditionally exempt small quantity generator (CESQG) of hazardous waste, and then the next day you realize you’re a small quantity generator (SQG) of hazardous waste. Only it’s not one day that’s the issue; it’s one month, as hazardous waste generator status is determined by the volumes of hazardous waste […]

EPA Adds Three Categories of Nonwaste Fuels

In a final rule, the EPA has added three categories of non-hazardous secondary materials (NHSMs)—construction and demolition (C&D) wood, paper recycling residuals, and creosote-treated railroad ties—to the initial list of four categories it published in a 2013 rule. NHSMs in these seven categories can be burned in combustion units as nonwaste fuels without the owner […]

Top 10 Problems with EPA’s Proposed Hazwaste Generator Rule

Last fall, the U.S. Environmental Protection Agency (EPA) issued a proposed rule that would make significant changes to regulatory requirements for hazardous waste generators. Comments were accepted until December 24, 2015. Let’s take a look at what a sampling of stakeholders had to say about EPA’s proposed amendments to hazardous waste generation under the Resource […]