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The Hazardous Waste Generator Improvements Rule Proposal
The document outlines a webinar discussing proposed changes to the hazardous waste generator improvements rule under the Resource Conservation and Recovery Act (RCRA). Key proposals aim to reorganize regulations for user-friendliness, enhance flexibility for generators, and strengthen environmental protections. Various generator statuses and reporting requirements, as well as emergency preparedness measures and labeling changes, are among the significant components of the proposed rule.
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The Hazardous Waste Generator Improvements Rule Proposal
- 1. The Hazardous Waste GeneratorImprovements Rule Proposal Analysis of the provisions and what they mean for you.
- 2. Meet Your Moderator JamesCiccone
- 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 ProposedRule Overview 7 Major Components Wrap Up/Q&A Rule Process & Schedule Agenda
- 6. How Concerned Are YouAbout the Proposed Regulation? Poll Question
- 7. The Resource Conservationand 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 whereRCRA, 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 theRule • Hazardous Waste Generator Program evaluation – April 2004 • Hazardous Waste Determination Program evaluation – 2013 • Hazardous Waste Generator Proposed Rule – 2015
- 10. 40 CFR Parts260, 261, 263, 264 mainly Federal register notice September 25th, 2015 Comment period ended December 24th,2015 Proposed Regulations
- 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. The amount andtype 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. RCRA Overview Current Issues ProposedRule Overview 7 Major Components Wrap Up/Q&A Rule Process & Schedule Agenda
- 14.
- 15. Issue #2 Lack ofFlexibility for Operators of Facility with Different Generator Status
- 16. Issue #3 Lengthy ContingencyPlan Requirements & Lack of Recordkeeping Requirements
- 17. Issue #4 Mismanagement of Wastefrom Generators
- 18. RCRA Overview Current Issues ProposedRule Overview 7 Major Components Wrap Up/Q&A Rule Process & Schedule Agenda
- 19. • Goals ofthe Proposed Rule • Where Will the New Regulations Live? Proposed Rule Overview
- 20. Goals of the ProposedRule 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 Part260 – 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 ProposedRule Overview 7 Major Components Wrap Up/Q&A Rule Process & Schedule Agenda
- 23. 1. Consolidation ofCESQG 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. 2. Episodic Generationfor 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. 3. Emergency Planningand 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. 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. 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. 6. Satellite Accumulationareas: • 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. 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. • Documenting hazardouswaste 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 certainproposed 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 ProposedRule Overview 7 Major Components Wrap Up/Q&A Rule Process & Schedule Agenda
- 34. Publication of thefinal 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. RCRA Overview Current Issues ProposedRule Overview 7 Major Components Wrap Up/Q&A Rule Process & Schedule Agenda
- 36. Prepare yourself fordrastic changes Understand how you may be affected Follow up for more information What’s next? Wrap Up
- 37.
- 38. Thank You ForAttending! 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: