Tag: RCRA

Biennial reports, paperwork

Are You Ready to Submit Your 2019 Biennial Report?

As hazardous waste large quantity generators (LQGs) and hazardous waste treatment, storage, and disposal facilities (TSDFs) know all too well, the Resource Conservation and Recovery Act (RCRA) requires them to report every two years on the quantities, types, and management methods of hazardous wastes generated on-site and hazardous wastes received from off-site sources. Referred to […]

Montana landscape

The Montana Exceptions and a Hazardous Waste Case

In Montana v. United States (1981), the U.S. Supreme Court found that Indian tribes do not have civil or criminal jurisdiction over nontribal members within a reservation. This opinion has proven to be one of the clearest indications that Indian tribes possess no authority over lands they do not own (called non-Indian fee lands), even […]

Pill bottles, pharmaceuticals

EPA’s Regulations on Waste Prescription and Nonprescription Pharmaceuticals

The EPA has long emphasized that the Resource Conservation and Recovery Act (RCRA) and its regulations were written to address the generation of solid and hazardous wastes by industrial plants and the storage, treatment, and disposal of such wastes at permitted facilities and landfills. What the regulations were not intended to cover is the generation […]

Simultaneous EPA Proposals Look to Cut Costs for Coal-Fired Power

The Trump administration is relying heavily on its environmental authority to try to reverse the declining role of coal in energy generation. Under both the Resource Conservation and Recovery Act (RCRA) and the Clean Water Act (CWA), the Agency has the power to regulate how much the coal-fired electricity sector must do and how much […]

Fireworks over Honolulu

RCRA Emergency Permits and Safe Disposal of Waste Fireworks

In 2013, the U.S. Chemical Safety and Hazard Investigation Board (CSB) reported on an explosion and fire that occurred in 2011 at a fireworks disposal magazine in Hawaii in which five personnel were killed. According to the CSB, the use of equipment that could cause a spark likely ignited black powder that had accumulated inside […]

Contaminated wipes, solvents

Contaminated Wipes and the ‘No-Free-Liquids’ Condition

In 2013, the EPA promulgated a final rule that removed solvent-contaminated wipes that are either cleaned and reused or disposed of from regulation under the Resource Conservation and Recovery Act (RCRA). The exclusions come with conditions, meaning the generators of these wipes must conduct certain actions to qualify. One such condition described here is that […]

Oil barrels or chemical drums stacked up

Is Your Waste Hazardous? If You Don’t Know, It Could Be Costly

“Is my waste hazardous?” This is a question common to generators of wastes in all industries. The answer to this question is essential, as it’s at the heart of the Resource Conservation and Recovery Act (RCRA) regulations for handlers of hazardous waste. Generators as well as owners/operators of treatment, storage, and disposal facilities (TSDFs) cannot […]