The final US EPA Hazardous Waste Generators Improvement Rule was published in the Federal Register on November 28, 2016. The effective date for the rule is May 30, 2017.
Click here to review a summary of key new requirements for very small quantity generators (VSQG), small quantity generators (SQG) and large quantity generators (LQG).
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
Sunday, November 27, 2016
Friday, November 25, 2016
New Rule On Episodic Hazardous Waste Generation For VSQG & SQG Facilities
One of the persistent issues for hazardous waste generators has been when short term spikes in hazardous waste generation elevate facilities to a higher generator class, resulting the requirement to meet additional generator requirements. The Hazardous Waste Generator Improvements Rule addresses this issue by creating another type of waste generation – episodic hazardous waste generation. Because large quantity generators are not limited by monthly generation, this rule only affects VSQG and SQG generators.
Two types of episodic hazardous waste generation are created – planned and unplanned. Planned episodes, as the name suggests, can be planned ahead of time and include activities such has facility cleanups, obsolete inventory disposal, demolition projects, etc. Unplanned episodes include spills, fires, and other emergency incidents. Under the new rule, hazardous waste generated during these events will not count against monthly waste total and will not change generator status, if conditions are met.
Generators taking advantage of this option will be limited to one event per calendar; with opportunity to petition for one additional unplanned event in the same year.
For planned events the generator must:
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
Two types of episodic hazardous waste generation are created – planned and unplanned. Planned episodes, as the name suggests, can be planned ahead of time and include activities such has facility cleanups, obsolete inventory disposal, demolition projects, etc. Unplanned episodes include spills, fires, and other emergency incidents. Under the new rule, hazardous waste generated during these events will not count against monthly waste total and will not change generator status, if conditions are met.
Generators taking advantage of this option will be limited to one event per calendar; with opportunity to petition for one additional unplanned event in the same year.
For planned events the generator must:
- notify agency at least 30 days prior,
- identify start/end dates (60 day max),
- have EPA ID #, and
- ship within 60 days using a hazardous waste manifest.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
Thursday, November 24, 2016
EPA Hazardous Waste Generator Improvements Rule - What States Are Affected?
The Hazardous Waste Generator Improvements Rule is now signed and published in the Federal Register on November 28, 2016. This leaves hazardous waste generators to sort out how this will affect them, and when.
Immediate Affect of the Hazardous Waste Generator Improvements Rule
The Generator Improvements Rule modified the Federal rules under RCRA and therefore has direct affect on hazardous waste generators located in States that have not been delegated RCRA authority (Iowa and Alaska) and some other areas, including Tribal lands. However, many States have incorporated portions of the RCRA rules by reference into their authorized programs – therefore, in these States revisions to Federal RCRA rules can have an immediate affect on State rules. This can significantly increase the population of hazardous waste generators that will be affected by the Hazardous Waste Generator Improvements Rule s ix months after publication in the FR - on May 30, 2017.
For generators located in States that have not incorporated generator requirements by reference, the impact of the rule revision will be uncertain. Rule changes will only become effective when States modify their own hazardous waste generator requires. To add to the uncertainty, States will only be required to modify their rules to incorporate portions of the Hazardous Waste Generator Improvements Rule that are MORE stringent than current rules. Other portions of the new EPA rules that add flexibility, are less stringent, or are incorporate clarifications to the rule would not need to be addressed by States to maintain their authorized programs under RCRA.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
Immediate Affect of the Hazardous Waste Generator Improvements Rule
The Generator Improvements Rule modified the Federal rules under RCRA and therefore has direct affect on hazardous waste generators located in States that have not been delegated RCRA authority (Iowa and Alaska) and some other areas, including Tribal lands. However, many States have incorporated portions of the RCRA rules by reference into their authorized programs – therefore, in these States revisions to Federal RCRA rules can have an immediate affect on State rules. This can significantly increase the population of hazardous waste generators that will be affected by the Hazardous Waste Generator Improvements Rule s ix months after publication in the FR - on May 30, 2017.
For generators located in States that have not incorporated generator requirements by reference, the impact of the rule revision will be uncertain. Rule changes will only become effective when States modify their own hazardous waste generator requires. To add to the uncertainty, States will only be required to modify their rules to incorporate portions of the Hazardous Waste Generator Improvements Rule that are MORE stringent than current rules. Other portions of the new EPA rules that add flexibility, are less stringent, or are incorporate clarifications to the rule would not need to be addressed by States to maintain their authorized programs under RCRA.
Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website
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