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03/16/2020

EPA Enforcement Roundup: Week of 3/16

In this week's Roundup, a pipeline company agrees to pay over $60 million to resolve alleged Clean Water Act violations from a 2015 oil spill outside Santa Barbara, CA. Plus, a Virginia recycling facility settles with EPA for $50K over alleged hazardous waste violations.

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02/19/2019

The Business Case for Effective Hazardous Waste Management

From legal exposure to liability to making money by recycling, instructor Rosie Bottone provides some guidance on how to make a business case for effective RCRA hazardous waste management. 

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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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05/23/2018

Can I Use State Waste Codes on the e-Manifest?

EPA's Electronic Hazardous Waste Manifest (e-Manifest) System launches in about 40 days. A major concern about the adoption of e-Manifests is how EPA will implement unique state hazardous waste codes from states like California, New York, Texas, and others.  

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03/05/2018

Refinery Ordered to Move 6,000 Cubic Yards of Oil Bearing Materials

California’s Department of Toxic Substances Control (DTSC) on Friday ordered a California refinery to dispose of 329 dumpster-sized bins of oil bearing materials that DTSC says the owners accumulated speculatively on site.   

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02/26/2018

RCRA Reporting Requirements to Be Extended

US EPA today proposed an extension of an “information collection request,” or ICR, that requires hazardous waste generators, contractors, and others to keep records related to the recycling of hazardous secondary materials.   

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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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08/14/2017

Court Invalidates Parts of EPA's 2015 Definition of Solid Waste Rule

A D.C. Circuit Court last month invalidated parts of EPA’s 2015 update to the Definition of Solid Waste (DSW) pertaining to the reclamation of hazardous secondary materials. Find out what it means for hazardous waste generators   

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05/22/2017

The 4 Keys to Legitimate RCRA Recycling

Have you ever wished there were some (legal) way around the RCRA hazardous waste requirements? Recycling certain hazardous secondary materials offers a number of ways for facilities to exclude those materials from US EPA’s definition of solid waste (DSW). If a material is not a solid waste, then by definition it cannot be a hazardous waste. 

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05/15/2017

RCRA Recycling for Scrap Metal Powders

A new EPA hazardous waste interpretation letter answers a question about whether or not “items consisting of scrap metal anodes, wires, pellets, pins, and powders” may be excluded from hazardous waste import/export requirements...

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