Tag: RCRA

EPA Offices, Washington DC

What’s EPA Enforcement Like at Other Federal Facilities and Agencies?

The EPA’s enforcement of violations of environmental laws and regulations at federal facilities is a complicated business that has been addressed by the U.S. Supreme Court (Ohio v. United States Department of Energy, 1992, which affirmed federal facility sovereign immunity with respect to the Resource Conservation and Recovery Act (RCRA)), presidential Executive Orders, and by […]

Opioid epidemic

The EPA, Law Enforcement, and Waste Opioids

The EPA is playing a minor but important role in the federal government’s efforts to control America’s opioid overdose epidemic. In its latest action, the Agency’s Office of Resource Conservation and Recovery (ORCR), which implements the EPA’s solid waste program under the Resource Conservation and Recovery Act (RCRA), issued a memo to encourage law enforcement […]

Environmental Law

A New Enviro Enforcement Roundup

While our September 2018 environmental enforcement roundup isn’t as dramatic as some of our other recent reports, it still provides valuable lessons for organizations that want to avoid becoming the next statistic. It’s also worth noting that a provider of environmental services (which you’d think would know compliance backwards and forwards) made this month’s list, […]

Recycling

EPA Moves to Implement HSM Orders from D.C. Circuit

In a final rule promulgated without a prior proposal, the EPA is revising regulations associated with the definition of solid waste under the Resource Conservation and Recovery Act (RCRA). The revisions apply specifically to rules the Agency issued in 2008 and 2015, which addressed the conditions under which hazardous secondary materials (HSMs) are legitimately recycled.

Hazardous Waste Generator Rule Changes Finalized

As frequent visitors to EPA’s Resource Conservation and Recovery Act (RCRA) Online database already know, the Agency’s hazardous waste regulations prompt a constant stream of questions from both regulated entities and RCRA-authorized states about applicability, lack of clarity, and regulatory gaps. A small fraction of EPA’s answers and interpretations responding to such questions have now […]

Update to SW-846 Nonregulatory Methods

EPA’s Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, also known as SW-846, is the Agency’s official compendium of methods for use in complying with Resource Conservation and Recovery Act (RCRA) regulations. SW-846 comprises over 200 analytical methods for sampling and analyzing waste and other matrices. Most methods are intended as guidance (i.e., nonregulatory or […]

What You May Not Know About CESQGs (Soon to Be ‘VSQGs’)

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, […]