Tuesday, November 29, 2011

Changes Proposed To Georgia Hazardous Waste Rules

The Georgia Environmental Protection Division (EPD) is proposing changes to State rules governing the management of hazardous wastes in Chapter 391-3-11. The proposed rule amendment is currently released for public comment. The public comment period ends on December 29, 2011.

Some of the key changes proposed are:

  1. The Environmental Protection Division is proposing regulations to clarify notification requirements, specifically for hazardous waste transfer facilities and used oil facilities, and documentation and record keeping requirements for hazardous waste accumulation areas. Also clarifying that used oil containers and tanks must be kept closed except when adding or removing waste.

  2. Amends the F019 listing to exempt the wastewater treatment sludge generated from zinc phosphating processes used in automobile assembly, provided the wastes are not placed outside on the land prior to shipment to a landfill for disposal and it is disposed in a landfill unit subject to certain liner requirements.

  3. Establishes an alternative set of generator requirements applicable to eligible academic entities that are flexible and protective. It also addresses the specific nature of hazardous waste generation and accumulation in these laboratories. The rules are also amended for technical corrections to these requirements. EPD believes this change provides incentives for eligible academic entities to conduct laboratory clean outs of old, unneeded chemicals.

  4. Termination of the National Environmental Performance Track Program. Former members of this program must now comply with the standard Resource Conservation and Recovery Act (RCRA) requirements for hazardous waste accumulation times and facility inspections.

  5. Finalizes amendments to National Emission Standards for Hazardous Air Pollutants and Final Standards for Hazardous Air Pollutants for hazardous waste combustors.

  6. Changes requirements for the management of used oil. New rules require that used oil tanks and containers be kept closed to prevent releases to the environment. Tanks and containers must be kept closed except when adding or removing used oil, or if tanks and containers are kept indoors or within secondary containment areas.

Caltha LLP provides specialized expertise to clients in Georgia and nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.

For further information contact Caltha LLP at

info@calthacompany.com or Caltha LLP Website

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