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The Hazardous Waste Generator Improvements Rule Proposal

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This presentation provides an overview of the major provisions proposed by the EPA in the new hazardous waste generator improvements rule. It outlines the four primary issues that exist with today's regulations and how some of the more significant proposals seeks to address those issues. Find out about the rule process and schedule and what this means for hazardous waste generators.

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The Hazardous Waste Generator Improvements Rule Proposal

  1. 1. The Hazardous Waste Generator Improvements Rule Proposal Analysis of the provisions and what they mean for you.
  2. 2. Meet Your Moderator James Ciccone
  3. 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. 4. Meet Your Presenter Geraldine “Gigi” Dambreville Environmental Health and Safety Consultant, Triumvirate Environmental Inc.
  5. 5. RCRA Overview Current Issues Proposed Rule Overview 7 Major Components Wrap Up/Q&A Rule Process & Schedule Agenda
  6. 6. How Concerned Are You About the Proposed Regulation? Poll Question
  7. 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. 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. 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. 10. 40 CFR Parts 260, 261, 263, 264 mainly Federal register notice September 25th, 2015 Comment period ended December 24th,2015 Proposed Regulations
  11. 11.  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?
  12. 12. 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
  13. 13. RCRA Overview Current Issues Proposed Rule Overview 7 Major Components Wrap Up/Q&A Rule Process & Schedule Agenda
  14. 14. Issue #1 Regulations are Confusing
  15. 15. Issue #2 Lack of Flexibility for Operators of Facility with Different Generator Status
  16. 16. Issue #3 Lengthy Contingency Plan Requirements & Lack of Recordkeeping Requirements
  17. 17. Issue #4 Mismanagement of Waste from Generators
  18. 18. RCRA Overview Current Issues Proposed Rule Overview 7 Major Components Wrap Up/Q&A Rule Process & Schedule Agenda
  19. 19. • Goals of the Proposed Rule • Where Will the New Regulations Live? Proposed Rule Overview
  20. 20. Goals of the Proposed 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. 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. 22. RCRA Overview Current Issues Proposed Rule Overview 7 Major Components Wrap Up/Q&A Rule Process & Schedule Agenda
  23. 23. 1. Consolidation of CESQG Waste at LQG’s: • CESQG’s and LQG’s must be under the control of the same person • CESQG to be called VSQG • 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 Proposal #1
  24. 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 • 45 days from initiation and completion of episodic event Proposal #2
  25. 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 Proposal #3
  26. 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 Proposal #4
  27. 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 Proposal #5
  28. 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 Proposal #6
  29. 29. Proposal #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. 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. 31. • CESQG consolidation • Episodic generation • Waiver from 50-foot rule Less Stringent Rules
  32. 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. 33. RCRA Overview Current Issues Proposed Rule Overview 7 Major Components Wrap Up/Q&A Rule Process & Schedule Agenda
  34. 34. Publication of the final rule in the CFR • Administrator has already signed the proposed rule on 8/31/15 • This was published on 9/25/15; 80 FR58014 There was a 60 Day Comment Period • That was extended to 12/24/15 • There have already been many requests for extension Review of Public Comment • After review the EPA will begin to finalize the rule Rule Process & Schedule
  35. 35. RCRA Overview Current Issues Proposed Rule Overview 7 Major Components Wrap Up/Q&A Rule Process & Schedule Agenda
  36. 36. Prepare yourself for drastic changes Understand how you may be affected Follow up for more information What’s next? Wrap Up
  37. 37. QUESTIONS?
  38. 38. Thank You For Attending! You Will Receive: • A recording of this presentation and a copy of this presentation • A link to a short survey • A gift to help ensure that your hazardous waste program is fully compliant Geraldine “Gigi” Dambreville gdambreville@triumvirate.com www.Triumvirate.com Contact:

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