Nothing up my sleeve........PRESTO!

For a lot of folks, the EPA appears to have pulled not one, but two rabbits out of their hats. After having made no substantive changes to the regulations resulting from the Resource Conservation and Recovery Act in the last 30-40 years (depending on how you define substantive), the EPA rolled out the Generator Improvement Rule in May of 2017 and then launched the e-manifesting program in June of 2018.

The Generator Improvement Rule is a mix of both more and less restrictive elements of waste management practices. It remains to be seen if states will adopt all of the rules or only the more restrictive aspects. At the time of the paper submissions, only 8 states have adopted. The new e-manifest system will only be a couple of months in when we all meet up in Reno. Will everybody be up to speed on that....I wouldn’t BET on it.

In this session, we will provide a review of the changes of the new generator improvement rule including some insights and oversights in some of the chosen language of regulatory doublespeak. We will also give you a guided tour of the e-manifesting system as it exists at the time of the seminar. We might even provide seat belts for this bumpy ride.

Specific elements will include -

Conditions for exemption, Generator Status, Waste Determinations, Preparedness vs. Emergency, Episodic Generation, Onsite management changes, and as many of you have come to expect.....I have some tricks up sleeve.