EPA’s Generator Improvement Rule

Hazardous waste generators have a lot to look forward to in 2016. On September 25, 2015, the EPA published their Generator Improvement Proposed Rulemaking, with the expectation of finalizing the requirements in September 2016. This is the first major change to the hazardous waste generator rules since the creation of the satellite accumulation option in 1984. When promulgated, these changes can have a significant impact on your site’s hazardous waste management procedures, regardless your site’s hazardous waste generator status.

During this session we will examine the details of the September 2015 proposed rule so that you may see how these new RCRA rules will affect your site. This will include a look at the proposed re-structuring and consolidation the RCRA hazardous waste management standards under 40 CFR Part 262. In addition, we will examine the EPA’s proposals to add:

• New rules for determining generator status
• Expanded rules for waste determination records
• New marking requirements for hazardous waste containers
• Re-notification requirements for Large and Small Quantity generators 
• EPA’s first standards for “episodic” generation of hazardous waste
• New rules for consolidating waste from Conditionally Exempt Small Quantity Generator Sites
• And more

We will examine the impact of these proposed rules on state RCRA Subtitle C programs. Lastly, we will discuss the latest on the timing for these anticipated rule changes.