The Hazardous Waste Generator Improvements Rule
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The document discusses a webinar about the EPA's Hazardous Waste Generator Improvements Rule. The webinar covered an overview of RCRA regulations for hazardous waste generators, current issues with the existing rules, details on the 7 major components of the finalized rule, and next steps for compliance. Attendees would receive a copy of the presentation, recording, and link to provide feedback on the webinar.
The Hazardous Waste Generator Improvements Rule
- 1. The Hazardous Waste Generator Improvements Rule Analysis of the provisions and what they mean for you.
- 2. Meet Your Moderator James Ciccone
- 3. During this Webinar All lines will be muted. Communicate via the questions tab in your webinar panel. Unanswered questions will be responded to after the webinar. Webinar recording and slides will be emailed to you tomorrow.
- 4. Meet Your Presenter Geraldine “Gigi” Dambreville Environmental Health and Safety Consultant, Triumvirate Environmental Inc.
- 5. RCRA Overview Current Issues Final Rule Overview 7 Major Components Wrap Up/Q&A Agenda
- 6. How Concerned Are You About the New Rule? Poll Question
- 7. The Resource Conservation and Recovery Act of 1976: Originally conceived as a law addressing municipal trash disposal, Subtitle C of RCRA was included to give the U.S. Environmental Protection Agency (EPA) the authority to regulate hazardous waste. This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. RCRA and Generators
- 8. HSWA continued where RCRA, Subtitle C left off, including: adding mandates for the regulation of small quantity generators, restrictions on land disposal of hazardous waste, regulation of underground storage tanks (USTs), and corrective action provisions to prevent RCRA facilities from becoming Superfund sites. The Hazardous and Solid Waste Amendments of 1984: HSWA and Generators
- 9. History of the Rule • Hazardous Waste Generator Program evaluation – April 2004 • Hazardous Waste Determination Program evaluation – 2013 • Hazardous Waste Generator Proposed Rule – 2015
- 10. 40 CFR Parts 260 – 265 mainly Federal register notice September 25th, 2015 Comment period ended December 24th,2015 Proposed Regulations
- 11. Final Rule! Signed by the EPA Administrator on October 28, 2016 Will be published in the Federal Register in the coming weeks Made effective May 30th 2017
- 12. Generators Transporters Treatment, Storage and Disposal Facilities (TSDFs) • Part 261- Waste Identification • Part 262- Generator Requirements • Part 263- Transporter Requirements • Part 264- 265- TSDF Requirements • Part 266- Recycling • Part 268- Land Disposal Restrictions • Part 270- TSDF Permitting • Part 271- State RCRA Programs 40 CFR Parts: 260-281 Who’s Covered Under State & Federal RCRA Regulations?
- 13. The amount and type of hazardous waste generated in a given calendar month will determine your “generator status”. Large Quantity Generators (LQGs) Small Quantity Generators (SQG) Conditionally Exempt Small Quantity Generators (CESQGs) Generator Status
- 14. RCRA Overview Current Issues Final Rule Overview 7 Major Components Wrap Up/Q&A Agenda
- 16. Issue #2 Lack of Flexibility for Operators of Facility with Different Generator Status
- 17. Issue #3 Lengthy Contingency Plan Requirements & Lack of Recordkeeping Requirements
- 18. Issue #4 Mismanagement of Waste from Generators
- 19. RCRA Overview Current Issues Final Rule Overview 7 Major Components Wrap Up/Q&A Agenda
- 20. Goals of the Final Rule 1. Reorganize the regulations to make them more user friendly and enable improved compliance 2. Provide greater flexibility for hazardous waste generators to manage waste in a cost-effective manner 3. Strengthen environmental protection by addressing identified gaps in the regulations 4. Clarify certain components of the hazardous waste generator program to address ambiguities and foster improved compliance
- 21. 40 CFR Part 260 – Standards for the classification of hazardous wastes generators and specific Types of Hazardous Waste Management Facilities Part 262 – Management Standards for Hazardous Waste Where Will the Regulations Live?
- 22. RCRA Overview Current Issues Final Rule Overview 7 Major Components Wrap Up/Q&A Agenda
- 23. 1. Consolidation of CESQG Waste at LQG’s: • CESQG to be called VSQG • CESQG’s and LQG’s must be under the control of the same person • Eliminate RCRA permit requirement to accept CESQG’s waste • Additional option for CESQG’s to manage their waste • Increased training and documentation • Potentially decrease generator cost Rule #1
- 24. 2. Episodic Generation for CESQG’s and SQG’s: • Only allowed once a year • Would not change current generator status • Would not have to complete biennial requirement • Notification of planned and unplanned events • Labeling requirement for accumulation of episodic waste • 60 days from initiation and completion of episodic event Rule #2
- 25. 3. Emergency Planning and Preparedness: • Only applicable to LQG’s and SQG’s • Require generators to make arrangements with local LEPC’s first • If no local LEPC, generators to make arrangements with local Fire Departments • NEW LQG’s to submit executive summary to LEPC rather than full contingency plans • Eliminating employee personal information in plans Rule #3
- 26. 4. Labeling changes: • Applicable to SQG’s, LQG’s and Transporters • Marking containers with hazardous waste codes • Make it easier for TSDF’s to identify content • Relevant areas on site: SAA’s, CAA’s, transfer facilities consolidating waste from different generators • Labeling requirement for tanks, drip pads and containment buildings • Recordkeeping requirements for tanks, drip pads, containment building for 90 and 180 day storage Rule #4
- 27. 5. Reporting Requirements: • Biennial reporting required only for LQG’s • Reporting for all hazardous waste generated during reporting year • Not applicable to CESQG’s and SQG’s under episodic rule • Allow new source code for CESQG’s transferred waste Rule #5
- 28. 6. Satellite Accumulation areas: • Prohibiting incompatible waste to be mixed in the same container • Limited exception for keeping containers closed at all times at SAA’s • Modify labeling to include flexibility on hazard category type • Clarify the “three day” rule Rule #6
- 29. Rule #7 7. Closure: • Require closure as landfill for when LQG’s accumulating in containers fail to clean close • Notification to EPA or authorized state 30 days prior to closing an accumulation area or within 90 days after closure of unit or facility
- 30. • Documenting hazardous waste determinations • SQG re-notification • Labeling • Notification of closure • Biennial reporting for the whole year • Executive summary for contingency plan More Stringent Rules
- 31. • CESQG consolidation • Episodic generation • Waiver from 50-foot rule Less Stringent Rules
- 32. EPA Considers certain proposed provisions to be more stringent than current regulations • More stringent regulations – all states will be required to adopt the final rule • Less stringent regulations – states may but are not required to adopt federal regulations No final authorization on base State RCRA program • Will be effective in these states on the effective date for the final rule, even before the state adopts it State Adoption
- 33. RCRA Overview Current Issues Final Rule Overview 7 Major Components Wrap Up/Q&A Agenda
- 34. Prepare yourself for drastic changes Understand how you may be affected Follow up for more information What’s next? Wrap Up
- 35. Thank You For Attending! You Will Receive: • A copy of this presentation and the webinar recording • A link to a short survey • A special offer to help ensure that your hazardous waste program is fully compliant Geraldine “Gigi” Dambreville gdambreville@triumvirate.com www.Triumvirate.com Contact: