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08/15/2011

EPA Rule on Carbamate Wastes Now in Effect

On Friday, the EPA finalized a rule that makes revisions to the land disposal restriction (LDR) treatment standards for Carbamate wastes at 40 CFR 268.40. These new standards are likely to impact manufacturers of certain pesticides, herbicides, or fungicides. The standard affect LDRS for the K156 – K159 and K161 process waste along with...

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08/02/2011

Question of the Week: Hazard Communication for CESQGs

Q. We are a conditionally exempt small quantity generator (CESQG). We hold waste on site in a central storage area for up to six months before we ship everything off site, but we don’t follow the actual 180–day rules while we’re storing the waste. We mark the words “Hazardous Waste” on our containers but nothing else. Since some of the waste is flammable, do we need to label the containers with either DOT labels or OSHA hazard communication labels while we’re storing them...

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07/26/2011

New Issues for Hazardous Waste Recycling

The EPA is proposing further amendments to the hazardous waste regulations in order to encourage the recycling of hazardous secondary materials while protecting low-income and minority communities from pollution. This proposal would limit the opportunities for waste generators to exclude hazardous secondary materials intended for recycling from the hazardous waste regulations. This proposal also introduces...

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07/26/2011

EPA Proposes Revised Definition of Solid Waste

Today, the Federal Register published the EPA’s latest attempt to redefine solid waste in a way that safeguards public health and the environment while also promoting the recycling of hazardous materials.
 
Today’s rule proposal was first announced over a week ago when Administrator Jackson signed the proposal just in time to comply with a consent decree between...

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07/19/2011

Question of the Week: DOT Rules for Reusing Drums for Shipping Hazardous Waste

Q. As a small manufacturer, we buy lots of chemicals each month to use as solvents, purifiers, or catalysts. When we’re done, we ship the used chemicals back to the supplier for recycling and, in many cases, eventual reuse.  
Most of the time, when we return-ship this hazardous waste, we refill the waste material into the...

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07/06/2011

EPA Proposes Modifications to 2008 Definition of Solid Waste Rule

Today, the U.S. Environmental Protection Agency announced a proposed rule to modify the 2008 Definition of Solid Waste (DSW) rule. The DSW rule had been intended to promote recycling of “hazardous secondary materials.” The EPA’s proposed modifications are in response to concerns raised by the Sierra Club and other environmental groups through various court actions...

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06/30/2011

Question of the Week: Classifying Aerosol Can Waste

Q. Are aerosol cans considered to be a D003 simply because they are pressurized?
 
A. When it comes to waste identification, it is the responsibility of the generator to make a waste determination based on all aspects of the material (40 CFR 262.11). RCRA programs in some authorized states simplify your waste classification process and declare that each and every aerosol can...

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06/13/2011

EPA Modifies LDRs for Carbamates

Today, the EPA published a direct final rule (76 FR 34147) and proposal (76 FR 34200) on LDRs for “Carbamate” production wastes and commercial chemical products containing carbamates. As existing test methods are inadequate, and it is difficult to determine the concentration of carbamates at the limits specified for land disposal, this rule modifies...

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05/24/2011

Question of the Week: Using a Mass Balance Approach for RCRA Tanks

Q. Does a hazardous waste storage tank need to be emptied every 90 days (or 180 days), or can a ”mass balance approach” be taken?
 
A. EPA stated in the January 11, 1982 issue of the Federal Register (47 FR 1250) that generators must remove all wastes from the tank within...

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04/29/2011

Question of the Week: Recycling Lead Batteries: Part 266 vs. Part 273

Q. EPA gives several options for managing spent lead-acid batteries. What is the benefit of choosing Universal Waste management rules versus the lead-acid battery rules in 40 CFR 266? 
 
A. Spent lead-acid batteries are exempt from the hazardous waste regulations and do not count towards a generator’s status determination as long as the generator follows either...

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Some of the limited quantity reliefs are identical across the intermodal transport rules, but others are reserved for specific modes of transport. Shippers can and should capitalize on these limited quantity reliefs when possible, but must recognize that some hazmat requirements still apply to shipping limited quantities.

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