Universal Waste Aerosol Cans Final Rule Summary
The Aerosol Cans Universal Waste Final Rule (UW Rule) incorporates aerosol cans containing hazardous waste that are generated and accumulated by various entities into the EPA’s Federal Universal Waste Rules found in Title 40 of the Code of Federal Regulations (40 CFR) Part 273. Federally (and in states which have adopted this rule, including South Carolina), aerosol cans containing hazardous wastes may now be managed in accordance with the more streamlined provisions of the UW Rule as opposed to the traditional hazardous waste management requirements of the Resource Conservation and Recovery Act (RCRA) regulations. …
read moreTCLP vs SPLP and the Proper Applications for Each
Questions frequently arise within the regulated community regarding the differences between the TCLP and SPLP laboratory tests, and the proper applications for each. TCLP is an abbreviation of Toxicity Characteristic Leaching Procedure and SPLP is an abbreviation of Synthetic Precipitation Leaching Procedure. Both procedures are laboratory tests used to analyze leachate. …
read moreThe U.S. EPA's HWGIR Update of Container Accumulation Requirements for CAAs vs SAAs
The hazardous waste generator improvements rule (HWGIR), has created changes in some of the requirements for Central Accumulation Areas (CAAs) and Satellite Accumulation Areas (SAAs). The following table has been developed by Novesis to summarize the differing requirements for the accumulation/storage of hazardous wastes in containers by generators in CAAs versus SAAs. We hope you find it helpful. …
read moreRepresentative Sampling of a Waste Pile
When using testing (to make a hazardous waste determination), the Agency considers the most important aspect of the testing procedure is to obtain a representative sample of the waste. A representative sample of a waste is a sample of the total amount of waste that will represent the average properties of the whole waste. Certain wastes and management units (e.g., a waste pile, lagoon, etc.) may pose unique and difficult problems regarding the acquisition of a representative sample. SW-846 Provides protocols for proper sampling of waste piles, lagoons, etc. …
read moreThe U.S. EPA’s View on Solvents Used As Ingredients
When solvents are utilized by a process as an ingredient, they are no longer considered "spent" or "discarded", therefore they cannot be considered a listed hazardous waste (e.g. F001-F005 do not apply). …
read moreNew Hazardous Waste Regulations - Hazardous Waste Generator Improvements Rule (HWGIR)
There are over sixty (60) changes to the hazardous waste management program for generators, some of which are sure to surprise unsuspecting generators. Many of these changes are more stringent than the current hazardous waste requirements. …
read moreNew Requirements for Hazardous Waste Determinations as a Result of the Hazardous Waste Generator Improvements Rule (HWGIR)
The United States Environmental Protection Agency (U.S. EPA) published the final version of the Hazardous Waste Generator Improvements Rule (HWGIR or Rule) on November 28, 2016 and it became effective federally May 30, 2017. States have been allowed up to two (2) years from the effective date of the Rule to incorporate/adopt the more stringent elements of the Rule into their state programs. The Rule significantly changes the hazardous waste determination landscape for companies. …
read moreNew HWGIR Contingency Plan Requirements
U.S. EPA Hazardous Waste Generator Improvements Rule (HWGIR) ‐ New RCRA Hazardous Waste Contingency Plan Requirements …
read more7 Changes to SAAs by HWGIR
Seven (7) Significant Changes for the Management of Hazardous Waste in Satellite Accumulation Areas as a Result of the U.S. EPA’s Hazardous Waste Generator Improvements Rule …
read moreNew HWGIR LQG Closure Requirements
U.S. EPA Hazardous Waste Generator Improvements Rule (HWGIR) - New RCRA Hazardous Waste Large Quantity Generator Closure Requirements …
read moreThe U.S. EPA “Continued Use” Policy
Materials are not solid wastes until the decision is made to discard them. Materials that are not solid wastes cannot be RCRA regulated hazardous wastes. In the case of solvents, they are used until considered spent at which point they will be discarded. The U.S. EPA has a long established concept that materials are not solid wastes when they qualify for the Agency’s continued use policy, or in similar fashion, the secondary materials exemption regarding source substitution. …
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