Demystifying New EPA Rules for Recycling Selected Hazardous Wastes

Posted: February 19, 2015
Source: Environmental Leader.com By: Jon Elliott, President, Touchstone Environmental Contributor, Specialty Technical Publishers

The Resource Conservation and Recovery Act (RCRA) and its state counterparts provide requirements to govern hazardous wastes during every step of their management, from “cradle to grave.” Although these rules are intended to improve management and provide incentives for recycling and other beneficial uses of hazardous wastes, many organizations find many of the rules unnecessarily onerous – and therefore potentially counterproductive if they actually discourage beneficial activities. In addition, over time changes in technologies, commercial activities and regulatory priorities reveal gaps in existing rules. In January, the Environmental Protection Agency (EPA) revised its “Definition of Solid Waste” rules governing a number of potentially hazardous wastes that it instead considers to be “hazardous secondary materials,” and the range of recycling and recovery activities eligible for special regulatory considerations. The revisions become effective on July 13, 2015.

What Are ‘Hazardous Secondary Materials?’

EPA has revised exclusions from the category of (potential) hazardous wastes defined as hazardous secondary materials. The general definition remains the same:

Hazardous secondary material means a secondary material (e.g., spent material, by-product, or sludge) that, when discarded, would be identified as hazardous waste under part 261 of this chapter.

EPA’s use of the subjunctive “would be discarded” tells us how EPA considers spent materials, by-products and sludges that are managed in some way other than being discarded. The most recent changes revise the lists of materials being addressed, and the non-discard activities that qualify for special regulatory consideration. Most importantly, reclamation of a hazardous secondary material may qualify for one of two dozen exclusions—a specified material managed in a specified way is not a solid waste (i.e., is excluded from the definition, and therefore from all associated regulatory requirements).
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Hazardous Materials Recycling Rule Finalized

Posted: December 11, 2014
Source: Environmental Leader.com

The EPA has finalized a hazardous materials recycling rule that requires, among other things, off-site recycling at a facility with a RCRA permit or verified recycler variance.

The agency says this will allow it and individual states to verify that a facility has the equipment and trained personnel to safely manage the material, adequate financial assurance, is prepared to respond in case of an emergency, and can demonstrate that the recycling is not disposal in the guise of recycling.

The new verified recycler exclusion also includes a public participation requirement for recyclers seeking variances, so that communities are notified prior to the start of recycling operations.
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Help Your Business By Understanding Hazardous Waste Treatment

Posted: July 2, 2014
Source: Environmental Leader.com

The EPA’s definition of waste treatment can be confusing and potentially costly, so it is important that hazardous waste generators be clear as to what activities might be considered as treatment of hazardous waste, according to Pollution Engineering.

Under the Resource Conservation and Recovery Act, treating a waste means changing the physical, chemical or biological characteristics of it. Examples of these types of change might be:

  • Making a waste less corrosive or toxic
  • Reducing a waste’s volume through evaporation
  • Burning waste to obtain energy from it
  • Leaving waste paint in the open to let volatile organic compounds in it vaporize
  • Adding an acid or alkaline into a waste stream to reduce its corrosivity
  • Doing something to waste to make it easier or less costly to transport or store

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EPA Takes Important Step in Implementing the Hazardous Waste Electronic Manifest Establishment Act

Posted January 17, 2014
Source: EPA

WASHINGTON – The U.S. Environmental Protection Agency (EPA) today issued a final rule that is a crucial step in the development of a national electronic manifest (e-Manifest) system, which will upgrade the current paper-based system of tracking hazardous waste to an electronic one.

“Today’s action is a key step in bringing the oversight of these potentially dangerous materials into the 21st century,” said Mathy Stanislaus, EPA assistant administrator for the Office of Solid Waste and Emergency Response. “Once fully implemented, the national e-Manifest system will provide greater access for emergency responders to information about the types and sources of hazardous waste that are in transit between generator sites and waste management facilities.”

The final rule authorizes the use of e-Manifests to track hazardous wastes under the Resource Conservation and Recovery Act. This will allow the current process, which requires paper forms, to be streamlined and greatly reduce the millions of paper manifests produced each year.
Continue reading EPA Takes Important Step in Implementing the Hazardous Waste Electronic Manifest Establishment Act