Hot Topics in RCRA

RCRA is changing. This presentation will update the audience on the following new rules and other current topics of interest:

• Solvent-contaminated wipes rule: In an effort to provide national con-sistency for the management of solvent-contaminated rags and wipes, EPA is-sued a final rule on July 31, 2013. The rule contains two conditional ex-clusions from RCRA for solvent-contaminated wipes. We’ll explain which wipes are eligible for the exclusions (and which aren’t) and we’ll identify the conditions that must be met for the new exclusions to apply.
• Electronic-manifest final rule: On February 7, 2014, EPA issued the e-manifest rule. The primary purpose of the rule is to clarify that electron-ic manifests that are obtained, executed, and signed as specified in the rule are authorized for use as legally valid manifests for all RCRA purpos-es. We’ll discuss the provisions of the final rule, its potential benefits, and EPA’s implementation schedule.
• Changes to the definition of solid waste: If a material is not a solid waste, it can’t be a hazardous waste. On July 22, 2011, EPA proposed to amend the definition of “solid waste” as it applies to hazardous secondary materials being recycled. We’ll explain the proposed changes and update you on the current status of the rule.
• Aerosol cans: Are aerosol cans D003 reactive hazardous wastes? We’ll review EPA’s guidance on this issue and present a straight-forward approach for managing waste aerosol cans.