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Q. I manage our filter cake waste as a hazardous secondary material (HSM) and notified the EPA and state environmental protection agency before managing the waste as a HSM. Are there any other reporting requirements after the initial notification?
Generators of hazardous waste that meet the current Resource Conservation and Recovery Act (RCRA) standards for being conditionally exempt small quantity generators (CESQGs) will be “rebranded” as “very small quantity generators” (VSQGs) when the proposed Hazardous Waste Generator Improvements Rule (Rule) is finalized (most likely this month). Whether such generators are called CESQGs or VSQGs, […]
Q. Our company is a 3rd party warehouse company. We have various customers and each one holds their own EPA ID number at our site. One customer is a Large Quantity Generator (LQG). Are there any regulations that specify that both us and our customer must submit the biennial report?
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 […]