NY Proposed Rules for Used Electronic Equipment - CRT

The New York State Department of Environmental Conservation (NYSDEC) is currently drafting a proposed rules for the management of used electronic equipment. Posting of the preliminary draft regulation is anticipated for Spring 2009, followed by further opportunity for public comment.

The resulting proposed rulemaking will amend NYSDEC regulations to streamline the management of used electronic equipment, whether regulated as hazardous waste or solid waste. The main issues to be addressed in the proposed rulemaking are:

• Adopting provisions of the Federal Cathode Ray Tube (CRT) Rule


• Adopting management standards for Collectors, Dismantlers, and Recyclers of Used Electronic Equipment


• Adopting provisions of the New York State Wireless Telephone Recycling Act


• Amending the requirements of New York's current Generator "c7" Notification

Currently in NYS, intact CRTs destined for recycling are eligible for the hazardous scrap metal exemption. However, when the CRT glass is no longer adherent to the metal, CRT glass could be regulated hazardous waste. The Federal CRT Rule contains the provisions to conditionally exclude this CRT glass from hazardous waste rules.

The current c7 notification requirements require generators (other than CESQGs) sending used electronics for recycling under the hazardous scrap metal exemption to file notifications. In the rulemaking, the NYSDEC is proposing to change the requirement to “[generators] must maintain on site, for a period of three years from the date of each shipment, the names and locations of the dismantling or recycling facilities and any intermediate receiving facilities."

Caltha LLP provides specialized expertise to clients nationwide in the evaluation solid waste and hazardous waste rules, developing waste handling procedures, and preparing cost-effective waste management programs.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

EPA Excludes Water Transfer From NPDES Requirements

EPA is publishing a final rule to exclude water transfers from regulation under the NPDES permitting program. The final rule defines a water transfer as an activity that conveys or connects waters of the United States without subjecting the transferred water to intervening industrial, municipal, or commercial use. This does not apply to pollutants introduced by the water transfer activity itself to the water being transferred.

Water transfers are activities that divert water between waterbodies, typically through the use of pumps or passive redirection through tunnels, channels, and/or natural stream water features. Water transfers are necessary to allocate water resources to meet the water needs of those downstream in the receiving waterbody. Such needs include public water supply, irrigation, power generation, flood control, and environmental restoration.

The Bureau of Reclamation administers significant transfers in western States to provide approximately 140,000 farmers with irrigation water. With the use of water transfers, the Army Corps of Engineers keeps thousands of acres of agricultural and urban land in southern Florida from flooding in former areas of Everglades wetlands. Many large cities in the west and the east would not have adequate sources of water without continuous redirection of water from outside basins. Both the cities of New York and Los Angeles are dependent on water transfers from distant watersheds to meet their municipal demand.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation NPDES permitting rules, water quality standards, and preparing cost-effective compliance management programs.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website