Hot Topics in RCRA

RCRA is changing. This presentation will update the audience on new RCRA rules and guidance, including:

• Disposal/recycling of e-cigarettes: Two new guidance documents summarize EPA’s perspective on the RCRA implications of disposing or recycling e-cigarettes at non-household facilities. We’ll explain why these facilities may be unknowingly generating and mismanaging acute hazardous waste.
• New guidance on making hazardous waste determinations: EPA’s April 2015 guidance manual on making hazardous waste determinations via testing or knowledge will be reviewed. The manual contains some guidance that is at odds with previous agency policy, causing some concern in the regulated community.
• Solvent-contaminated wipes rule: We’ll discuss EPA’s July 31, 2013 solvent-contaminated wipes rule and summarize early experience in complying with the new rule. We’ll also explain which wipes are eligible for the new exclusions (and which aren’t) and we’ll identify the conditions that must be met for the new exclusions to apply.