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The relentless advance of importation calls for a shift from the traditional emphasis on border inspections of imports to an approach that identifies high-risk segments in a product’s life cycle and verifies the safety of the product at those junctions. That’s the view of eight federal agencies, including EPA, which in 2009 issued a draft […]
According to critics, at least eight proposed or final EPA rules (air, water, and waste) may force the retirement of up to 81 gigawatts (GW) of coal-fired generating capacity. (The Energy Information Administration says the total installed generating capacity of the U.S. electric power grid is about 1,119 GW with approximately 330 GW coal-fired.) About […]
Not Required But Still a Good Idea It is important to keep in mind that ISO 14001 is not a legal requirement. It is a voluntary set of management standards that may improve your environmental performance. EPA encourages industries to adopt these standards but offers no specific incentives (such as reduced frequency of inspections) in […]
Notwithstanding the complexity inherent in the phrase closed container, managers must be confident that they understand what must be done with the hazwaste containers at their facilities to ensure that a state or federal inspector will have no doubt that the regulations are being met. Keep in mind that containers in which hazwastes are held […]
One way, called the contained-in policy, attempted to smooth over the pre-existing position held by the Agency that contaminated soil that either contained a listed hazardous waste or exhibited a hazardous waste characteristic must be managed and disposed of according to all regulations governing hazardous waste (RCRA Subtitle C). Also, soil that contained listed hazardous […]
Are You a LQG? If you generate 1,000 kg (about 2,200 pounds) or more of hazardous waste or more than 1 kg of acutely hazardous waste in any calendar month, you are a large quantity generator (LQG). LQGs must comply with all of EPA’s hazardous waste management rules although a partial exemption from some rules […]
After the decision is made to vent propane from a cylinder, up until it is vented onsite, does a propane cylinder need to be managed as D001 hazardous waste? Because the container of D001 hazardous waste does not yet meet the “RCRA empty standard” (as explained at 40 CFR 261.7) the container must be managed […]
Here’s a quick checklist of the paperwork you should have for your RCRA, hazardous waste exporting, and land ban requirements. RCRA Have you kept the following hazardous waste records for specified periods of time (if applicable)? Copies of a small quantity generator’s “reclamation agreement” for at least 3 years after the agreement’s termination or expiration […]
Is the material a solid waste? Is the waste specifically excluded from RCRA’s hazardous waste regulation? If the waste is a solid waste, is the solid waste “hazardous”? This requires you to determine: Is the waste a “listed” hazardous waste? Does the waste exhibit one or more of the four characteristics of hazardous waste? Is […]