DTSC's Plan to Adopt RCRA Hazardous Waste Generator Improvements

Posted on 6/13/2019 by Roger Marks

California has unveiled a plan to adopt provisions from EPA’s 2016 Generator Improvements Rule into the state’s Title 22 hazardous waste regulations. The major EPA rulemaking overhauled the Federal hazardous waste management requirements, adding more stringent provisions as well as new reliefs for generators.

The first step in California’s plan is to adopt the more-stringent, mandatory provisions. Because all states are required to maintain hazardous waste regulations that are at least as strict as the Federal rules, the more-stringent provisions are mandatory.

Keep your Title 22 expertise up to date and meet DTSC’s annual hazardous waste training mandate. The California Hazardous Waste Management online course allows you to train at your pace .

New Rules California MUST Adopt

Mandatory provisions, which California DTSC plans to adopt in a non-substantive (Section 100) rulemaking include:
  • New notification requirements for small and large quantity generators
  • Extra marking and labeling requirements for containers and tanks
  • New pre-transport markings for hazardous waste containers
  • More regulation for ignitable and reactive waste at large quantity generator facilities
  • New closure requirements for large quantity generators
  • Stricter rules for satellite areas
  • More stringent contingency plan rules
  • Adding a contingency plan “quick reference guide” requirement for large quantity generators
In addition to adding many new regulations for generators, the Generator Improvements Rule overhauled the organization of the RCRA regulations to make them clearer and easier to navigate. California plans to use the Section 100 rulemaking to re-organize its Title 22 hazardous waste rules to align with the new structure of the RCRA regulations.

Optional, Less-stringent Hazardous Waste Rules

The next step in California’s plan will be to consider the less-stringent provisions of the Generator Improvements Rule. These are provisions that add new reliefs for generators and clarify the regulations. California can decide to adopt these provisions, or not adopt them. Californa will hold work groups to evaluate these less-stringent rules, and may adopt them in a seperate rulemaking.

The optional or less-stringent provisions include:
  • New relief for episodic generation events like spills or lab clean-outs
  • Re-naming “conditionally exempt small quantity generators” as “very small quantity generators”
  • Allowing VSQGs to send waste to a large quantity generator facility for consolidation
  • Distinguishing between independent requirements and “conditions for exemption”
  • Revised rules for hazardous waste satellite areas
  • Further re-organization of the Title 22 regulations

Re-organized Title 22 Regulations

To align its Title 22 hazardous waste rules with the new, re-shuffled RCRA regulations, California will make organizational changes, including:
  • Moving the satellite accumulation area regulations to new section 22 CCR 66262.15
  • Moving the small quantity generator rules to new section 66262.16
  • Moving the large quantity generator rules to new section 66262.17
  • Moving the preparedness, release prevention, and contingency/emergency planning procedures for large quantity generators
DTSC is running an email list for hazardous waste professionals who want to track the progress of Generator Improvements Rule adoption. You can subscribe to the list here.  
Read California’s Generator Improvements adoption plan on DTSC’s website.

Generator Improvements Rule Spreading Nationwide

All states must adopt the mandatory provisions of the Generator Improvements Rule, and many already have. Most recently, the updated requirements took effect in Arizona and Washington on March 1 and April 28, 2019, respectively. [Map updated as of 10/9/2020]

Annual DTSC Hazardous Waste Training (Title 22)

Learn what you need to know to manage hazardous waste in California under the latest regulations. The California Hazardous Waste Management online course is designed to satisfy California DTSC’s annual training requirement for hazardous waste managers and personnel. You will gain in-depth knowledge of the DTSC regulations, feeling confident in your ability to implement and comply with Title 22 regs at your facility.

Tags: hazardous waste management, new rules, RCRA, state rules, Title 22

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