Practical EHS Tips, News & Advice. Updated Daily.
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, […]
In response to an order from the U.S. Court of Appeals for the D.C. Circuit, the EPA has issued a direct final rule amending its regulations (April 17, 2015, FR) governing the disposal of coal combustion residuals (CCRs) as solid waste under Resource Conservation and Recovery Act (RCRA) Subtitle D. In the CCR rule, the […]
Q. The wrong feedstock was placed in Tank A which holds a different one. The resulting mixed ignitable material (D001) is not usable. We intend to move this mixture out of Tank A quickly. Is Tank A subject to RCRA, or is it still a product tank?
The EPA has moved one step closer to implementing an electronic manifest (e-Manifest) system intended to replace the existing paper manifest system used for cradle-to-grave tracking of hazardous waste. Specifically, the Agency is proposing a methodology for imposing fees on users of the e-Manifest system. The fee would cover the use of either e-manifests or […]
Q. Are there compliance issues that would prevent our installation of a compressor on a concrete slab on which our (now clean-closed) RCRA-permitted hazardous waste boiler sat? Our Closure Plan states that we will close the slab when the facility closes.
“One year” is the operative time frame for managing universal wastes under the RCRA regulations at 40 CFR 273. All handlers of universal waste have one year to keep universal waste onsite. To prove that it meets this time limitation, the handler must be able to demonstrate the number of days the universal waste has […]
Under the RCRA used oil regulations at 40 CFR 279, a used oil generator is “any person, by site, who produces used oil or causes used oil to become subject to regulation.” Generators include all persons who produce used oil through commercial or industrial operations and vehicle services.
Q. What EPA Hazardous Waste Number should be assigned on the Hazardous Waste Manifest when shipping for disposal un-punctured, aerosol cans with carbon dioxide propellant that are assumed to be empty of the product they were intended to spray (e.g. paint)?
It would be reasonable to think that when hazardous waste is produced that there is only one hazardous waste generator, given the U.S. Environmental Protection Agency’s (EPA) definition, which states that “Generator means any person, by site, whose act or process produces hazardous waste identified or listed in [40 CFR 261] or whose act first […]
It’s been over a year since the U.S. Environmental Protection Agency (EPA) published in the Federal Register its long-awaited final rule revising regulations affecting recycling of hazardous materials under the Resource Conservation and Recovery Act (RCRA). Known as the 2015 Definition of Solid Waste rule (2015 DSW rule), this final rule exempts certain hazardous secondary […]