The document summarizes changes to EPA's hazardous waste generator regulations known as the Hazardous Waste Generator Improvement Rule (HWGIR). Some of the major changes include: allowing very small quantity generators to send their waste to large quantity generators under common control for consolidation; clarifying hazardous waste determination requirements; allowing generators to conduct episodic generation; revising labeling and marking standards; updating biennial reporting for small quantity generators; and strengthening preparedness and planning requirements for small and large quantity generators. The revisions are aimed at simplifying and clarifying the regulations based on input from states and stakeholders.
This is one of the presentations at the 1st day of "Technical Exchange on Jurisdictional REDD". See more at: http://www.idesam.org.br/technical-exchange-on-jurisdictional-redd-presentations/
NSPS Subpart OOOO: Applicability and Compliance BasicsAll4 Inc.
Roy Rakiewicz of ALL4 Inc, presents "General Applicability of NSPS Subpart OOOO: Applicability and Compliance Basics". The presentation provides detailed information on: affected facilities, rule structure, storage vessel affected facilities, and gas well affected facilities.
This is one of the presentations at the 1st day of "Technical Exchange on Jurisdictional REDD". See more at: http://www.idesam.org.br/technical-exchange-on-jurisdictional-redd-presentations/
NSPS Subpart OOOO: Applicability and Compliance BasicsAll4 Inc.
Roy Rakiewicz of ALL4 Inc, presents "General Applicability of NSPS Subpart OOOO: Applicability and Compliance Basics". The presentation provides detailed information on: affected facilities, rule structure, storage vessel affected facilities, and gas well affected facilities.
Clean Air Act Compliance, Risk Management Plans, and Preparing for the July 1...Triumvirate Environmental
The Clean Air Act (42 U.S.C. 7401) of 1963 controls air pollution on a national level. The 1990 amendments to the act created regulations aimed at protecting the ozone layer, reducing acid rain and toxic pollutants, and improving air quality through the Risk Management Plan Rule and the Toxics Release Inventory (TRI) Program. With the TRI deadline rapidly approaching, it is important to carefully review chemical release activities from the past year as you prepare to file your 2019 report.
2018.09.05 tiktak efsa pe cs in soil guidanceaaldrik_tiktak
Learn about the new PECs in Soil Guidance by the European Food Safety Authority (EFSA). The presentation also gives an impact assessment and compares the old and new regulatory framework.
A Deep Dive into the RCRA Regulations: Are You Aware of These Lesser Known Re...Triumvirate Environmental
We are all familiar with the standard requirements found within the hazardous waste regulations such as labeling, closure requirements, secondary containment, training, and other basic rules and requirements. But are you aware that there are more? Taking a deeper look into RCRA regulations reveals much more, including:
Daily Tank Inspections and Recording Requirements
Subpart AA- Organic Emission Standards
Subpart BB- Air Emission Standards
And more…
We will review each of the lesser known RCRA requirements to provide you with a complete understanding of the regulation and help ensure compliance.
Theme 1: Main session outcomes and key messagesFAO
This presentation was presented during the Plenary 3, Working group, Conclusion and Closure of the Global Symposium on Soil Organic Carbon that took place in Rome 21-23 March 2017. The presentation was made by Ms. Liesl Wiese from GSP Secretariat, in FAO Hq, Rome
Presented by Oswaldo Carrillo from CIFOR, at Online Workshop Capacity Building on the IPCC 2013 Wetlands Supplement, FREL Diagnostic and Uncertainty Analysis, 20-22 September 2021
Diagnostic of how the submitted FREL could be improved to better align with ...CIFOR-ICRAF
Presented by Zuelclady M.F Araujo Gutierrez from IDOM, at Online Workshop Capacity Building on the IPCC 2013 Wetlands Supplement, FREL Diagnostic and Uncertainty Analysis, 20-22 September 2021
BlueScape How to Create a CEQA Air Quality Analysis for Development Projects ...BlueScape
This webinar by James Westbrook, President of BlueScape Environmental, provides an overview of how to create a CEQA Air Quality Analysis. The first section of the webinar discusses when an Air Quality Analysis must be completed under CEQA; project types including construction and operation phases; air pollutant emission sources and applicable CEQA significance thresholds; how to construct a conservative analysis while filling in assumption “holes;” review of project alternatives and mitigation requirements; the role of air agencies in CEQA review and relationship to other actions such as air permitting; special analysis cases; and strategies to work with agencies and the public throughout the air quality impact review process. The webinar is presented from the standpoint of CEQA air quality guidelines provided by the South Coast Air Quality Management District (SCAQMD).
The second part of the webinar presents a technical discussion on methods and tools used to complete air quality studies, including CalEEMod emission modeling software, CARB EMFAC and OFFROAD databases, and AERMOD and HARP2 impact modeling software. A case example for completing an air quality study for a commercial development using CalEEMod is presented.
James Westbrook can be reached at training@bluescapeinc.com or 877-486-9257. Please contact us for questions and support for how to create a CEQA Air Quality Analysis.
California Air Quality in 2019: What You Need to KnowBlueScape
This webinar by James Westbrook, President of BlueScape Environmental, provides businesses with a 2019 update on California air quality regulations.
The webinar topics include: recent and upcoming changes in US EPA air quality regulations, including Ozone Standards, New Source Review, Greenhouse Gas (GHG) Emissions regulations, and NSPS/MACT Standards; new state legislative bills and changes in important state regulations, including AB617, Clean Energy and GHG regulations, Proposition 65, and onroad/offroad emission standards; an update on Air District regulations in Southern California, the Bay Area, and the Central Valley; updates to Technical Guidelines and common tools used in California for air quality technical analysis, such as CalEEMod, AERMOD and HARP2; recent court decisions affecting CEQA air quality review, such as the Friant Case, Sierra Club v. San Diego County, and other important decisions; regulation changes impacting such industries as power generation, chemical manufacturing, oil & gas production, oil refining, and heavy manufacturing; and strategic business decisions companies should consider making in 2019.
James Westbrook can be reached at jwestbrook@bluescapeinc.com or 877-486-9257. Please contact us for any questions or support you need to work with the air agencies to design effective NSR permits for your operations.
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.
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.
In October of 2016, the EPA signed the final Hazardous Waste Generator Improvements Rule to provide greater flexibility for hazardous waste generators and clarification around certain components of the hazardous generator program in an effort to improve compliance and environmental protection. The EPA has described the rule as “an overhaul of the hazardous waste generator regulatory program.” Some revisions appear to be more lenient than existing regulations, while others are more stringent, such as documenting hazardous waste determinations.
Clean Air Act Compliance, Risk Management Plans, and Preparing for the July 1...Triumvirate Environmental
The Clean Air Act (42 U.S.C. 7401) of 1963 controls air pollution on a national level. The 1990 amendments to the act created regulations aimed at protecting the ozone layer, reducing acid rain and toxic pollutants, and improving air quality through the Risk Management Plan Rule and the Toxics Release Inventory (TRI) Program. With the TRI deadline rapidly approaching, it is important to carefully review chemical release activities from the past year as you prepare to file your 2019 report.
2018.09.05 tiktak efsa pe cs in soil guidanceaaldrik_tiktak
Learn about the new PECs in Soil Guidance by the European Food Safety Authority (EFSA). The presentation also gives an impact assessment and compares the old and new regulatory framework.
A Deep Dive into the RCRA Regulations: Are You Aware of These Lesser Known Re...Triumvirate Environmental
We are all familiar with the standard requirements found within the hazardous waste regulations such as labeling, closure requirements, secondary containment, training, and other basic rules and requirements. But are you aware that there are more? Taking a deeper look into RCRA regulations reveals much more, including:
Daily Tank Inspections and Recording Requirements
Subpart AA- Organic Emission Standards
Subpart BB- Air Emission Standards
And more…
We will review each of the lesser known RCRA requirements to provide you with a complete understanding of the regulation and help ensure compliance.
Theme 1: Main session outcomes and key messagesFAO
This presentation was presented during the Plenary 3, Working group, Conclusion and Closure of the Global Symposium on Soil Organic Carbon that took place in Rome 21-23 March 2017. The presentation was made by Ms. Liesl Wiese from GSP Secretariat, in FAO Hq, Rome
Presented by Oswaldo Carrillo from CIFOR, at Online Workshop Capacity Building on the IPCC 2013 Wetlands Supplement, FREL Diagnostic and Uncertainty Analysis, 20-22 September 2021
Diagnostic of how the submitted FREL could be improved to better align with ...CIFOR-ICRAF
Presented by Zuelclady M.F Araujo Gutierrez from IDOM, at Online Workshop Capacity Building on the IPCC 2013 Wetlands Supplement, FREL Diagnostic and Uncertainty Analysis, 20-22 September 2021
BlueScape How to Create a CEQA Air Quality Analysis for Development Projects ...BlueScape
This webinar by James Westbrook, President of BlueScape Environmental, provides an overview of how to create a CEQA Air Quality Analysis. The first section of the webinar discusses when an Air Quality Analysis must be completed under CEQA; project types including construction and operation phases; air pollutant emission sources and applicable CEQA significance thresholds; how to construct a conservative analysis while filling in assumption “holes;” review of project alternatives and mitigation requirements; the role of air agencies in CEQA review and relationship to other actions such as air permitting; special analysis cases; and strategies to work with agencies and the public throughout the air quality impact review process. The webinar is presented from the standpoint of CEQA air quality guidelines provided by the South Coast Air Quality Management District (SCAQMD).
The second part of the webinar presents a technical discussion on methods and tools used to complete air quality studies, including CalEEMod emission modeling software, CARB EMFAC and OFFROAD databases, and AERMOD and HARP2 impact modeling software. A case example for completing an air quality study for a commercial development using CalEEMod is presented.
James Westbrook can be reached at training@bluescapeinc.com or 877-486-9257. Please contact us for questions and support for how to create a CEQA Air Quality Analysis.
California Air Quality in 2019: What You Need to KnowBlueScape
This webinar by James Westbrook, President of BlueScape Environmental, provides businesses with a 2019 update on California air quality regulations.
The webinar topics include: recent and upcoming changes in US EPA air quality regulations, including Ozone Standards, New Source Review, Greenhouse Gas (GHG) Emissions regulations, and NSPS/MACT Standards; new state legislative bills and changes in important state regulations, including AB617, Clean Energy and GHG regulations, Proposition 65, and onroad/offroad emission standards; an update on Air District regulations in Southern California, the Bay Area, and the Central Valley; updates to Technical Guidelines and common tools used in California for air quality technical analysis, such as CalEEMod, AERMOD and HARP2; recent court decisions affecting CEQA air quality review, such as the Friant Case, Sierra Club v. San Diego County, and other important decisions; regulation changes impacting such industries as power generation, chemical manufacturing, oil & gas production, oil refining, and heavy manufacturing; and strategic business decisions companies should consider making in 2019.
James Westbrook can be reached at jwestbrook@bluescapeinc.com or 877-486-9257. Please contact us for any questions or support you need to work with the air agencies to design effective NSR permits for your operations.
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.
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.
In October of 2016, the EPA signed the final Hazardous Waste Generator Improvements Rule to provide greater flexibility for hazardous waste generators and clarification around certain components of the hazardous generator program in an effort to improve compliance and environmental protection. The EPA has described the rule as “an overhaul of the hazardous waste generator regulatory program.” Some revisions appear to be more lenient than existing regulations, while others are more stringent, such as documenting hazardous waste determinations.
How well do you know your local EHS regulators? As 2019 rule proposals continue to develop, meet your local regulator to discuss how you may be impacted as an EHS practitioner. Do you have questions about existing regulations? This is the perfect opportunity to get them answered.
This past October, the EPA signed the final Hazardous Waste Generator Improvements Rule to provide greater flexibility for hazardous waste generators and clarification around certain components of the hazardous generator program in an effort to improve compliance and environmental protection. The EPA has described the rule as “an overhaul of the hazardous waste generator regulatory program.” Some revisions appear to be more lenient than existing regulations, while others are more stringent, such as documenting hazardous waste determinations. Learn more in this presentation.
The Emergency Planning Community Right-to-Know Act (EPCRA) of 1986 states that Tier II Reports must be submitted annually by March 1st to your State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department(s). Each violation of the Tier II Reporting requirements may result in civil penalties of up to $25,000 per day.
It is important to take the time to carefully review your facility to determine the quantity of chemicals stored onsite and understand if these quantities require reporting via the annual Tier II report.
BlueScape Get the Air Permit for Energy Projects Webinar 9-10-13BlueScape
This webinar by James Westbrook at BlueScape describes the air permitting process for energy projects, from early planning and technical feasibility review to application submittal and permit negotiation. The webinar presents tips to avoid delays and move quickly, save money, and address issues and hurdles that can impact the project. Issues such as emission limits and BACT emission controls, offsets, Title V permitting, and modeling impacts are discussed. The presenter provides tips on how to conduct the permitting process to be successful, and maximize operational flexibility. Mr. Westbrook can be reached at 858-774-2009 for more information. For a video presentation go to youtube.com/watch?v=AB84GQORp2w. Also see www.bluescapeinc.com.
LA HUG - Video Testimonials with Chynna Morgan - June 2024Lital Barkan
Have you ever heard that user-generated content or video testimonials can take your brand to the next level? We will explore how you can effectively use video testimonials to leverage and boost your sales, content strategy, and increase your CRM data.🤯
We will dig deeper into:
1. How to capture video testimonials that convert from your audience 🎥
2. How to leverage your testimonials to boost your sales 💲
3. How you can capture more CRM data to understand your audience better through video testimonials. 📊
What is the TDS Return Filing Due Date for FY 2024-25.pdfseoforlegalpillers
It is crucial for the taxpayers to understand about the TDS Return Filing Due Date, so that they can fulfill your TDS obligations efficiently. Taxpayers can avoid penalties by sticking to the deadlines and by accurate filing of TDS. Timely filing of TDS will make sure about the availability of tax credits. You can also seek the professional guidance of experts like Legal Pillers for timely filing of the TDS Return.
Premium MEAN Stack Development Solutions for Modern BusinessesSynapseIndia
Stay ahead of the curve with our premium MEAN Stack Development Solutions. Our expert developers utilize MongoDB, Express.js, AngularJS, and Node.js to create modern and responsive web applications. Trust us for cutting-edge solutions that drive your business growth and success.
Know more: https://www.synapseindia.com/technology/mean-stack-development-company.html
Tata Group Dials Taiwan for Its Chipmaking Ambition in Gujarat’s DholeraAvirahi City Dholera
The Tata Group, a titan of Indian industry, is making waves with its advanced talks with Taiwanese chipmakers Powerchip Semiconductor Manufacturing Corporation (PSMC) and UMC Group. The goal? Establishing a cutting-edge semiconductor fabrication unit (fab) in Dholera, Gujarat. This isn’t just any project; it’s a potential game changer for India’s chipmaking aspirations and a boon for investors seeking promising residential projects in dholera sir.
Visit : https://www.avirahi.com/blog/tata-group-dials-taiwan-for-its-chipmaking-ambition-in-gujarats-dholera/
Enterprise Excellence is Inclusive Excellence.pdfKaiNexus
Enterprise excellence and inclusive excellence are closely linked, and real-world challenges have shown that both are essential to the success of any organization. To achieve enterprise excellence, organizations must focus on improving their operations and processes while creating an inclusive environment that engages everyone. In this interactive session, the facilitator will highlight commonly established business practices and how they limit our ability to engage everyone every day. More importantly, though, participants will likely gain increased awareness of what we can do differently to maximize enterprise excellence through deliberate inclusion.
What is Enterprise Excellence?
Enterprise Excellence is a holistic approach that's aimed at achieving world-class performance across all aspects of the organization.
What might I learn?
A way to engage all in creating Inclusive Excellence. Lessons from the US military and their parallels to the story of Harry Potter. How belt systems and CI teams can destroy inclusive practices. How leadership language invites people to the party. There are three things leaders can do to engage everyone every day: maximizing psychological safety to create environments where folks learn, contribute, and challenge the status quo.
Who might benefit? Anyone and everyone leading folks from the shop floor to top floor.
Dr. William Harvey is a seasoned Operations Leader with extensive experience in chemical processing, manufacturing, and operations management. At Michelman, he currently oversees multiple sites, leading teams in strategic planning and coaching/practicing continuous improvement. William is set to start his eighth year of teaching at the University of Cincinnati where he teaches marketing, finance, and management. William holds various certifications in change management, quality, leadership, operational excellence, team building, and DiSC, among others.
"𝑩𝑬𝑮𝑼𝑵 𝑾𝑰𝑻𝑯 𝑻𝑱 𝑰𝑺 𝑯𝑨𝑳𝑭 𝑫𝑶𝑵𝑬"
𝐓𝐉 𝐂𝐨𝐦𝐬 (𝐓𝐉 𝐂𝐨𝐦𝐦𝐮𝐧𝐢𝐜𝐚𝐭𝐢𝐨𝐧𝐬) is a professional event agency that includes experts in the event-organizing market in Vietnam, Korea, and ASEAN countries. We provide unlimited types of events from Music concerts, Fan meetings, and Culture festivals to Corporate events, Internal company events, Golf tournaments, MICE events, and Exhibitions.
𝐓𝐉 𝐂𝐨𝐦𝐬 provides unlimited package services including such as Event organizing, Event planning, Event production, Manpower, PR marketing, Design 2D/3D, VIP protocols, Interpreter agency, etc.
Sports events - Golf competitions/billiards competitions/company sports events: dynamic and challenging
⭐ 𝐅𝐞𝐚𝐭𝐮𝐫𝐞𝐝 𝐩𝐫𝐨𝐣𝐞𝐜𝐭𝐬:
➢ 2024 BAEKHYUN [Lonsdaleite] IN HO CHI MINH
➢ SUPER JUNIOR-L.S.S. THE SHOW : Th3ee Guys in HO CHI MINH
➢FreenBecky 1st Fan Meeting in Vietnam
➢CHILDREN ART EXHIBITION 2024: BEYOND BARRIERS
➢ WOW K-Music Festival 2023
➢ Winner [CROSS] Tour in HCM
➢ Super Show 9 in HCM with Super Junior
➢ HCMC - Gyeongsangbuk-do Culture and Tourism Festival
➢ Korean Vietnam Partnership - Fair with LG
➢ Korean President visits Samsung Electronics R&D Center
➢ Vietnam Food Expo with Lotte Wellfood
"𝐄𝐯𝐞𝐫𝐲 𝐞𝐯𝐞𝐧𝐭 𝐢𝐬 𝐚 𝐬𝐭𝐨𝐫𝐲, 𝐚 𝐬𝐩𝐞𝐜𝐢𝐚𝐥 𝐣𝐨𝐮𝐫𝐧𝐞𝐲. 𝐖𝐞 𝐚𝐥𝐰𝐚𝐲𝐬 𝐛𝐞𝐥𝐢𝐞𝐯𝐞 𝐭𝐡𝐚𝐭 𝐬𝐡𝐨𝐫𝐭𝐥𝐲 𝐲𝐨𝐮 𝐰𝐢𝐥𝐥 𝐛𝐞 𝐚 𝐩𝐚𝐫𝐭 𝐨𝐟 𝐨𝐮𝐫 𝐬𝐭𝐨𝐫𝐢𝐞𝐬."
The world of search engine optimization (SEO) is buzzing with discussions after Google confirmed that around 2,500 leaked internal documents related to its Search feature are indeed authentic. The revelation has sparked significant concerns within the SEO community. The leaked documents were initially reported by SEO experts Rand Fishkin and Mike King, igniting widespread analysis and discourse. For More Info:- https://news.arihantwebtech.com/search-disrupted-googles-leaked-documents-rock-the-seo-world/
Discover the innovative and creative projects that highlight my journey throu...dylandmeas
Discover the innovative and creative projects that highlight my journey through Full Sail University. Below, you’ll find a collection of my work showcasing my skills and expertise in digital marketing, event planning, and media production.
Implicitly or explicitly all competing businesses employ a strategy to select a mix
of marketing resources. Formulating such competitive strategies fundamentally
involves recognizing relationships between elements of the marketing mix (e.g.,
price and product quality), as well as assessing competitive and market conditions
(i.e., industry structure in the language of economics).
Memorandum Of Association Constitution of Company.pptseri bangash
www.seribangash.com
A Memorandum of Association (MOA) is a legal document that outlines the fundamental principles and objectives upon which a company operates. It serves as the company's charter or constitution and defines the scope of its activities. Here's a detailed note on the MOA:
Contents of Memorandum of Association:
Name Clause: This clause states the name of the company, which should end with words like "Limited" or "Ltd." for a public limited company and "Private Limited" or "Pvt. Ltd." for a private limited company.
https://seribangash.com/article-of-association-is-legal-doc-of-company/
Registered Office Clause: It specifies the location where the company's registered office is situated. This office is where all official communications and notices are sent.
Objective Clause: This clause delineates the main objectives for which the company is formed. It's important to define these objectives clearly, as the company cannot undertake activities beyond those mentioned in this clause.
www.seribangash.com
Liability Clause: It outlines the extent of liability of the company's members. In the case of companies limited by shares, the liability of members is limited to the amount unpaid on their shares. For companies limited by guarantee, members' liability is limited to the amount they undertake to contribute if the company is wound up.
https://seribangash.com/promotors-is-person-conceived-formation-company/
Capital Clause: This clause specifies the authorized capital of the company, i.e., the maximum amount of share capital the company is authorized to issue. It also mentions the division of this capital into shares and their respective nominal value.
Association Clause: It simply states that the subscribers wish to form a company and agree to become members of it, in accordance with the terms of the MOA.
Importance of Memorandum of Association:
Legal Requirement: The MOA is a legal requirement for the formation of a company. It must be filed with the Registrar of Companies during the incorporation process.
Constitutional Document: It serves as the company's constitutional document, defining its scope, powers, and limitations.
Protection of Members: It protects the interests of the company's members by clearly defining the objectives and limiting their liability.
External Communication: It provides clarity to external parties, such as investors, creditors, and regulatory authorities, regarding the company's objectives and powers.
https://seribangash.com/difference-public-and-private-company-law/
Binding Authority: The company and its members are bound by the provisions of the MOA. Any action taken beyond its scope may be considered ultra vires (beyond the powers) of the company and therefore void.
Amendment of MOA:
While the MOA lays down the company's fundamental principles, it is not entirely immutable. It can be amended, but only under specific circumstances and in compliance with legal procedures. Amendments typically require shareholder
3.0 Project 2_ Developing My Brand Identity Kit.pptxtanyjahb
A personal brand exploration presentation summarizes an individual's unique qualities and goals, covering strengths, values, passions, and target audience. It helps individuals understand what makes them stand out, their desired image, and how they aim to achieve it.
2. Hazardous Waste Generator Improvements
Purpose of the Rule:
• Making the rules easier to understand and providing
generators with greater flexibility in how hazardous waste is
managed
• Enhance the safety of facilities that generate hazardous waste
and the response capabilities of ER responders by improving
risk communication
• To incorporate feedback from the regulated community, states
and stakeholders to improve the hazardous waste generator
program
3. Background
• Congress passes Resource Conservation and Recovery
Act (RCRA) in 1976
• EPA promulgates the regulations in 1980
• Congress passes Hazardous and Solid Waste
Amendment (HSWA) in 1984 (Land bans)
• HWGIR represents the first real changes to the basic
waste regulations in 36 years
• Designed to incorporate years of experience in
implementing the program to simplify, clarify ambiguities
and inconsistencies in the regulations with input from
states and stakeholders
4. Revisions
• There are more than 60 changes to the hazardous waste
generator regulations that clarify existing requirements,
increase flexibility and improve environmental protection
• Some minor, technical in nature
• Others more significant
• Effective Date: May 30, 2017 (Alaska & Iowa)
• Effective in Colorado: ??? (Likely Spring 2018)
5. Reorganized Rule Structure
(Where do I find it?)
Provision Original Citation in 40 CFR New Generator Citation in 40 CFR
Definition of Generator Categories §260.10, 261.5, &262.34 §260.10
Hazardous Waste Determination
and Recordkeeping
§262.11 and 262.40 (c) §262.11
Generator Category Determination §261.5 (c) - (e) §262.13
VSQG Provisions §261.5 (a), (b), (f) – (j), and 258.28 §262.14
Satellite Accumulation Area
Provisions
§262.34 (c), 265, 171, 265, 172,
and 265.173 (a)
§262.15
SQG Provisions §262.34 (d) – (f) and 268 §262.16
LQG Provisions §262.34 (a), (b), (g)-(i), (m), and
268
§262.17
EPA Identification Numbers §262.12 §262.18
Landfill Ban for Liquids §258.28 §262.35
6. New Definitions / Clarifications
• Acute Hazardous Waste Listing (H) in 262.31 and
262.33 (U and P-Codes)
• Central Accumulation Area-on site storage for
LQG/SQG (formerly 90-day or 180-day area)
• Non-Acute Hazardous Waste
• Very Small Quantity Generator (replaces CESQG)
7. Independent Requirements vs.
Condition for Exemptions
• Independent Requirement
-- A standard that must be met, that applies regardless of a conditional
exemption (All generator categories)
• Condition for Exemption
-- A requirement(s) that must be met in order to get the conditional
exemption from more burdensome requirements (periodic inspections of
the waste area, RCRA training requirements, accumulation time limits, etc.)
• If “condition” is not met, EPA may penalize the generator
for failure to meet the condition and may apply ALL
requirements for non-exempt facilities (Part B permit)
8. Summary of Changes
• VSQG waste consolidation
• Hazardous Waste Determinations
• Episodic Generation
• Labeling & Marking of Containers
• Reporting – Biennial & Re-notification (SQG)
• Satellite Accumulations Areas (SAA)
• Preparedness and Planning
9. VSQG Waste Consolidation
• VSQGs may send their waste to LQGs under the control
of the same person for consolidation and management
provided certain conditions are meet by VSQG and LQG.
• “Control” means: power to direct the policies of the
generator, whether by stock ownership, voting rights or
otherwise. (does not include contractors)
• In some cases organizations, government and academia
may have SAAs that qualify as VSQGs and could take
advantage of this provision to send waste to an LQG
within their company or campus.
10. VSQG Waste Consolidation (cont.)
• LQGs must meet the following conditions:
– Make a 30 day notification prior to receiving first shipment
– Must include VSQG name, address contact phone
– Update notice within 30 days of any changes
• Retains shipment records for 3 years from receipt date
• Manage under 90-day rules
• Label with date received in addition to 90-day markings
11. Hazardous Waste Determinations
A person who generates a solid waste must
determine if hazardous waste
Hazardous Waste Identification Listings
• At point of generation
• Before diluting, mixing alteration
• At any time it changes its properties as a
result of exposure to the environment or
other factors
• Must determine if listed and/or
characteristic
- Determine all applicable waste codes
• Knowledge of the waste
-Waste origin
-Composition
-The process
-Feedstock
-Any other reliable or relevant information
-Process knowledge
-Product, by-product intermediate information
-Chemical physical properties
-Testing
-Other reliable or relevant information
• Generators must test when knowledge is inadequate Representative sample
12. Hazardous Waste Determinations (cont.)
• Record Keeping Requirements
– 3 year record retention of waste determinations from date
last shipped to off-site TSDF
– Documentation of generator knowledge
• Records must include (as applicable)
– Test results/waste analysis
– Test/analytical methods
– Records review
13. Episodic Generation
• Change in generator status due to a planned or
unplanned event
– Keep current generator status provided certain conditions are
met
– Episodic waste not counted towards status
• One (1) episodic event per year (may petition for a second)
• Event notification to EPA
– > 30 days before a planned event (ie: plant maintenance)
– < 72 hours after unplanned event
14. Episodic Generation (cont.)
• Must obtain EPA ID number (if you don’t have one)
• Notification Must Include:
– Event detail
– Reason
– Start/End Date
– Emergency Coordinator and Facility Contact
• 24-hour phone access
• Able to discuss notification or respond to emergency
15. Labeling and Marking
• Revised labeling and marking requirements (applies to both
containers and tanks)-must clearly indicate hazardous of the
hazardous waste contained inside
• Applies to LQGs and SGQs
• Markings must include:
– The words “Hazardous Waste” and Accumulation Start Date
– Indication of the hazards including:
• EPA Waste Codes (incineration of Lab Packs exempt-except D004-D011)
• HazCom consistent with DOT (shipper info, PSN, UN/NA number, etc.)
• Statement or pictogram consistent with OSHA-HazCom program
• National Fire Protection Association (NFPA) chemical hazard label
16. Reporting
• Biennial Reporting- revision in the current regulations
for completing the biennial report to be consistent with
the instructions distributed with the form
• SQGs must re-notify status every four (4) years
– Effective 2021
– By September 1st
• LQGs Closure-if closing a unit or the facility must
perform one of the following notifications:
– Place a notice in operating record within 30 days after closure
– Meet all closer performance standards (document file)
17. Satellite Accumulation Areas (SAA)
• SQGs/LQGs accumulating hazardous waste in SAAs
now have special requirements for incompatible
materials
– Do not place in same container
– Do not place in unwashed containers
– Separate or protected by any “practical means”
• Exceptions to “closed” container rule:
– Adding
– Removing
– Consolidating
– Temporarily Venting
• Properly operate equipment
• Prevent dangerous situation
18. Satellite Accumulation Areas (SAA) (cont)
• Containers (55-gallon max) must be in good
condition or transferred to a good container or
Central Accumulation area
• Acute Hazardous Waste Limits
– 1 quart (liquids)
– 1 Kg (solids) –(first application of a weight limit)
• Clarification of Three Day limit to transfer waste;
means “three consecutive days” (note: only 24 hours in
Colorado)
19. Satellite Accumulation Areas (SAA) (cont)
• Language Modification for Exceeding Limits-
must remove excess waste to Central Accumulation
Area or ship to off-site TSDF
• Preparedness and Prevention in SAAs
– SQGs must meet requirements of 262.16(b)(8)
– LQGs must meet emergency procedures in subpart M of
the regulations
20. Preparedness and Planning
• Updating emergency response and contingency planning
provisions for SQGs and LQGs to include Local
Emergency Planning Committees (LEPC) among those
emergency planning organizations with which a
generator may make response arrangements. (can’t just
send certified mail; they have to receive it)
• Facilities with 24-hour response capabilities may seek a
waiver form local authorities with jurisdiction over fire
code from making arrangements with local fire dept.
21. Preparedness and Planning (cont.)
• SQGs now must post required information by the
phone of in “areas directly involved in the generation
or accumulation”
• SQG/LQG must have required equipment:
– “Most appropriate Locations”
– Anywhere Hazardous Waste in generated or accumulated
– Unless:
• No hazards posed by any waste
• Area does not lend itself for safety reasons for a particular kind of
equipment
22. Preparedness and Planning (cont.)
• LQGs must submit a Quick Reference Guide with new or
updated contingency plans
• Quick Reference Guide must include:
– Hazardous Waste Type
– Waste (generic) name
– Hazards
– Maximum amount on site at any time
– Unique/special treatment
– Facility map
– Street map (locations of schools, businesses, water supply, etc)
– Identification of on-site monitor/alarms (smoke detectors, CO2)
– Emergency Coordinators
– 7 day/24 hour-emergency phone numbers
23. Other Changes
• All generators may not dispose of hazardous waste
in landfills
• Generators may apply for a waiver for storage of
Ignitables and Reactives greater than 50 ft from
property boundary (written approval from local fire authority)
• More on Ignitables and Reactives:
– Precautions to prevent accidental ignition or reaction
– Separate and protect from sources of ignition and radiant
heat
– Confine smoking to designated locations
– Post “No Smoking” signs by ignitable and reactive waste