ENV-15-66 Real Updates to RCRA

Description:

The Resource Conservation and Recovery Act of 1976 (RCRA) is approaching its 40th birthday, and many of us are busy ordering black balloons and streamers for the celebration. The Environmental Protection Agency (EPA) is actually issuing an overhaul of the generator standards, which initially was due to hit the Federal Register as a proposed rule mid to late June. The notice of proposed rulemaking was published September 25, 2015. EPA is calling this initiative “Hazardous Waste Generator Improvements Rule.” We understand EPA’s purpose behind this upcoming proposed rule is to incorporate 30 years of RCRA experience into the rules. Early reports were that the rewriting and reorganization of the rule will update all of the regulatory references that we HSE professionals have memorized over the years. These reports were accurate and are explained in this paper. We will walk through the proposed changes and also provide an update on the status of e-manifesting.