Posts Tagged ‘Resource Conservation and Recovery Act’

Top 10 Problems with EPA’s Proposed Hazardous Waste Generator Rule

Wednesday, March 9th, 2016

Last fall, the U.S. Environmental Protection Agency (EPA) issued a proposed rule that would make significant changes to regulatory requirements for hazardous waste generators. Comments were accepted until December 24, 2015. Let’s take a look at what a sampling of stakeholders had to say about EPA’s proposed amendments to hazardous waste generation under the Resource Conservation and Recovery Act (RCRA).

The EPA proposed what it calls the Hazardous Waste Generator Improvements on September 25, 2015. An extended comment period closed December 24, 2015. The Agency has received over 230 comments on the proposal. The Advisor reviewed a number of them and will give you the gist of what folks are saying about the proposed amendments to hazardous waste generator requirements. All the comments can be reviewed at (more…)

What’s Not a Solid or Hazardous Waste

Wednesday, April 29th, 2015

Certain materials are excluded from the definition of solid waste under the Resource Conservation and Recovery Act (RCRA). If a material is not a solid waste, it cannot be a hazardous waste. In other words; for a material to be a hazardous waste it must first meet the definition of a solid waste.

The following materials are deemed not to be solid wastes and, therefore, are not hazardous wastes:

  • Domestic sewage and mixtures of domestic sewage and other wastes that pass through a sewer system to a Publicly Owned Treatment Works (POTW) facility for treatment. EPA interprets this exclusion to also apply to waste mixtures that pass through a Federally Owned Treatment Works (FOTW) facility.
  • Industrial wastewater discharges that are point source discharges subject to regulation under the Clean Water Act (CWA). This exclusion only applies at the discharge point where the wastes are first subject to CWA regulation. Many industrial facilities that treat wastewater on-site use this point source discharge exclusion.
  • Irrigation return flows.


Truck Manufacturer Settles Alleged RCRA Violations

Friday, February 27th, 2015

Facilities that treat, store, or dispose of hazardous waste have a range of responsibilities under the Resource Conservation and Recovery Act (RCRA). In a recent enforcement action, a major truck manufacturer was cited for numerous RCRA failures that exemplify how diverse and difficult RCRA compliance can be.

In mid-November 2014, one of North America’s largest heavy-duty truck manufacturers settled with the Environmental Protection Agency (EPA) for a range of alleged RCRA violations at its Pennsylvania truck assembly plant. (more…)

BIG RCRA Violations

Friday, August 22nd, 2014

Facilities that manage hazardous wastes received from off site are subject to the Resource Conservation and Recovery Act (RCRA) hazardous waste treatment, storage, and disposal facility (TSDF) regulations. It is not optional for these facilities to comply with RCRA’s TSDF regulations and violators can expect hefty fines as illustrated by a recent court decision.

Through a series of inspections beginning in 1999, a Roanoke, Virginia chemical distribution facility revealed a long history of problems regarding the safe and legal management of hazardous wastes. In June 2014, following a five-day hearing that laid bare that long history, a U.S. Environmental Protection Agency (EPA) Administrative Law Judge issued a 125-page compliance order that requires the owner and operator of the facility to pay $612,339 in penalties for multiple violations of RCRA and state hazardous waste regulations.  (more…)

Lists of Hazardous Wastes You Should Know

Sunday, August 11th, 2013

The Environmental Protection Agency (EPA) has established two ways of identifying solid wastes as hazardous under the Resource Conservation and Recovery Act (RCRA) regulations; keeping in mind that according to EPA’s definition of a solid waste, a solid waste can be either a liquid or solid.

First, a waste may be considered hazardous if it exhibits certain hazardous properties or “characteristics.” EPA’s regulations define four hazardous waste properties that, if exhibited, identify a waste as a “characteristic hazardous waste”. They include Ignitability, Corrosivity, Reactivity, and Toxicity

The second way to tell if a waste is hazardous is if it is included on a specific RCRA list that EPA has determined are hazardous. These “listed wastes” are placed on a list because EPA finds them to pose substantial present or potential hazards to human health or the environment, as summarized below. (more…)