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10/01/2018

How to Create an Integrated Contingency Plan

An integrated contingency plan (ICP) is a plan to respond to contingencies that integrates the requirements of multiple government agencies into one combined document.  

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09/10/2018

RCRA Exclusions: Waste In Process

The RCRA hazardous waste management program provides a “cradle-to-grave” management system that applies to all hazardous waste generators. But when the government creates rules broad enough to apply to everyone, those rules don’t necessarily work well in every real-world situation...  

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06/28/2018

Texas to Start Adopting RCRA Generator Improvements This Summer

In Summer 2018, the Texas Commission on Environmental Quality (TCEQ) Office of Industrial and Hazardous Waste (I&HW) will begin the internal process of adopting EPA’s “Generator Improvements” into Texas’ I&HW regulations.   

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06/04/2018

RCRA Definition of Solid Waste Revised Again

The latest update to EPA's Definition of Solid Waste will re-instate the 2008 “transfer based exclusion” for reclamation activities and adjust the “four factors” for legitimate recycling, which EPA bolstered in the 2015 DSW rule.

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06/04/2018

EPA to Rescind Parts of New Risk Management Plan Rules

EPA will rescind some new chemical Risk Management Plan requirements for chemical facitlies promulgated in response to an April 2013 ammonium nitrate explosion in West, Texas that killed fifteen, injured 160, and damaged or destroyed 150 buildings.  

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03/09/2018

EPA Proposes Adding Aerosols to Universal Waste Program

(UPDATE 11/25/2019) A pre-publication version of EPA's Final Rule to add aerosol cans to the universal waste programs is now available. 

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09/25/2017

Using RCRA Interpretations in 2017 and Beyond

Environmental professionals often look to EPA letters of interpretation for clarity on specific hazardous waste management issues that arise at their facilities. Interpretations can be a useful tool for seeing the real-world implications of environmental regulations, but should be viewed with a few cautions in mind.   

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08/21/2017

When and How to Mix Hazardous Waste With Used Oil

Knowing when and how to mix hazardous waste with used oil can save generators time and money in many ways. Some mixtures of waste and used oil are not hazardous waste, and these mixtures are not subject to RCRA accumulation time limits, inspection requirements, or manifesting. 

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08/03/2017

EPA Faces Pushback on Delayed Clean Air Regulations

Before becoming EPA Administrator, Scott Pruitt often challenged new US EPA Clean Air Act rules in court as Attorney General of Oklahoma. Now, it seems, the tables have turned—today Pruitt and his EPA face their own set of legal challenges from Attorneys General across the US.  

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06/19/2017

New RCRA Rules Training in Charlotte, Orlando, Atlanta, Nashville, Memphis, & more

In July, join us for nationally trusted training on the latest RCRA rules - including updates under EPA's "Generator Improvements Rule" - in Charlotte, Orlando, Atlanta, Birmingham, Nashville, Memphis, and more! 

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