In a notice of proposed information collection request published on February 8, the EPA has indicated that it is considering revisions to the RCRA Hazardous Waste Manifest, both electronic (“e-Manifest”) and paper versions. EPA invites and will accept comments on proposed changes to the manifest document through April 9, 2019.
The suggested changes include:
- additional options for reporting waste quantities, using decimal numbers and alternative units of measure;
- additional items for international shipments, such as including a separate data field for import/export consent numbers and making sure both the generator and exporter EPA ID numbers, if different, are captured on the manifest, and adding information from the Movement Document to the manifest;
- providing source and form code and density information on the (paper) manifest document to integrate better with the biennial hazardous waste report.
Continue reading “Thinking about Changes to the Hazardous Waste Manifest, EPA is”
Well, certainly some relief for the very little ones – what we used to call “conditionally exempt small quantity generators” – henceforth (or beginning on the effective date of the Environmental Protection Agency’s Hazardous Waste Generator Improvements Rule, published in the Federal Register on November 28, 2016) to be known as Very Small Quantity Generators or VSQGs.
The Hazardous Waste Generator Improvement Rule, which EPA describes as the culmination of a review that began over 10 years ago, is meant to “improve program effectiveness, reduce compliance costs, and foster an improved relationship with states and the regulated communities.”
The final rule contains a number of provisions which EPA identifies as “more stringent”, including marking and labeling of wastes to identify hazards, Small Quantity Generator recertification, notification of facility closure and requirement that a Large Quantity Generator close as a landfill if it cannot meet closure standards, extending biennial reporting for the whole year rather than just months when the facility was an LQG, biennial reporting for recyclers even when they do not store waste prior to recycling, and a requirement that LQGs provide a “quick reference guide” for distribution with their Contingency Plans. “More stringent” standards must be adopted by states that manage their own hazardous waste programs.
The rule also contains “less stringent” provisions, of a kind that may elicit appreciative nods from industries. These address (1) consolidation of VSQG waste at a LQG facility under the same ownership; (2) allowing VSQGs and SQGs to retain their classification in the event that “episodic generation” would bump them up to a higher generator category; and (3) waiver from the requirement that ignitable and reactive wastes be stored at least 50 feet from a facility’s property line under certain circumstances.
Continue reading “Generator Improvement Rule: Relief for Hazardous Waste Generators?”
Um, yeah, this may not be the best example of drum storage…
Once again, the March 1 deadline looms for large quantity generators of hazardous waste as well as facilities that treated, stored or disposed of hazardous waste on-site to submit their hazardous waste biennial reports to the US Environmental Protection Agency.
If in any month in 2013 your facility
- generated more than 1,000 kilograms (2,200 pounds, or about four to five 55-gallon barrels) of RCRA hazardous waste,
- generated or accumulated more than 1 kg of acute hazardous waste, or
- generated or accumulated more than 100 kg of spill cleanup material contaminated with acute hazardous waste,
then you are a RCRA Large Quantity Generator (LQG) and must complete and file the 2013 Hazardous Waste Report. Hazardous wastes imported to your facility from a foreign country should be included in your generator count.
And if in 2013 your facility treated, stored or disposed of hazardous wastes on-site as a permitted hazardous waste facility, you must complete and file the 2013 report.
Continue reading “As Time Goes By… the Hazardous Waste Biennial Report Comes Due!”