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RCRA Updates

RCRA Updates. Larry L. Lamberth Enforcement and Compliance Branch Resource Conservation and Restoration Division US EPA, Region 4. Rulemaking. Rulemaking. Advanced Notice of Proposed Rule Making Solicit Public Comments Publish the Proposed Rule Receive Formal Comments Publish Final Rule.

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RCRA Updates

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  1. RCRA Updates Larry L. Lamberth Enforcement and Compliance Branch Resource Conservation and Restoration Division US EPA, Region 4

  2. Rulemaking

  3. Rulemaking • Advanced Notice of Proposed Rule Making • Solicit Public Comments • Publish the Proposed Rule • Receive Formal Comments • Publish Final Rule

  4. Aerosol Cans Proposed Rule • Universal Waste aerosol cans or a container in which the aerosol cans are contained, must be labeled or marked clearly with any of the following phrases: “Universal Waste- Aerosol Can(s)”, “Waste Aerosol Can(s)”, or “Used Aerosol Can(s)”. • Storage of universal waste aerosol cans is limited to one year. • No manifest is required for transport of universal waste.

  5. Aerosol Cans Proposed Rule • The proposed rule allows for puncturing and draining of hazardous waste aerosol cans provided that: • Emptied, punctured aerosol cans are recycled, • Puncturing is conducted using a device specifically designed to safely puncture aerosol cans and contain residual contents and air emissions, • A written procedure is established detailing safe puncturing measures, including a copy of the puncturing device manufacturer instructions, and spill/release response,

  6. Pharmaceutical Rule • The Proposed Rule was published in the FR on September 25, 2015 (80 FR 58014) and the final Rule was published on February 22, 2019 (84 FR 5816) and becomes effective on August 21, 2019 • Only those pharmaceuticals that are already considered hazardous waste will be covered by the new rule • Rule bans the sewering of HW pharmaceuticals (only provision immediately effective) • This Rule adds management practices for pharmaceuticals at healthcare facilities and reverse distributors.

  7. Pharmaceutical Rule • The Rule addresses non-prescription pharmaceuticals going through reverse logistics • This Rule established policy for regulatory status for unsold retail items that are not pharmaceuticals • Removes FDA approved OTC nicotine replacement therapies from definition of P075 HW listing • Maintains household exemption for take back programs

  8. Hazardous Waste Generator Improvements Rule • Revised the RCRA hazardous waste generator regulations to enhance flexibility, strengthen environmental protection, and improve compliance • Final rule was published on November 28, 2016. • The Rule was effective on May 30, 2017.

  9. Stringency of Final Rule More Stringent: VSQG consolidation Episodic generation Waiver from 50-foot rule Less Stringent • SQG re-notification • Identifying hazardous of waste being accumulated and labeling • Notification of closure with a closure standard for all 90-day areas. • Biennial reporting for whole year, not just months the generator was an LQG • Biennial reporting for recyclers who don’t store prior to recycling • Quick Reference guide for contingency plans

  10. Hazardous Waste Generator Improvements Rule - Status • Alabama – adopted, effective 04/06/18 – not submitted for authorization • Florida – adopted, effective 06/18/18 – submitted for authorization (02/22/19) • Georgia – adopted, effective 09/28/17 – authorized 02/22/19 • Kentucky – adopted, effective 12/07/17 – authorized 04/03/19 • Mississippi – adopted, effective 05/24/18 – not submitted for authorization • North Carolina – adopted, effective 03/01/18 – submitted for authorization (01/31/19) • South Carolina and Tennessee – not adopted.

  11. E-Manifest Update • December 2017, the Final Rule for User Fees – Established user fees and other actions necessary to establish the system. The Final Rule effective on June 30, 2018. • On June 30, 2018, EPA launched new fully electronic manifest tracking system, called e-Manifest

  12. RCRA Air Emissions NCI • Bring national attention to the importance of the control of hazardous waste air emissions from RCRA units. • Ensure the use of a full range of tools for controlling hazardous/toxic air emissions. • Minimize the potential for uncontrolled air releases of hazardous wastes into the environment.

  13. Air Emission NEI Scope • RCRA Subpart AA: Regulates RCRA hazardous waste treatment unit process vents. • RCRA Subpart BB: Regulates RCRA hazardous waste valves, flanges, pumps, compressors, pipe runs and pressure relief equipment. • RCRA Subpart CC: Regulates RCRA hazardous waste tanks, surface impoundments, and containers. • This equipment must be appropriately designed, monitored, and maintained to appropriately detect and limit releases of hazardous waste to the air.

  14. Inspection Scope and Focus • Utilizing next generation compliance tools • FLIR (Forward Looking Infrared) Camera • PID (Photoionization Detector) • Observation of tanks, containers, and ancillary equipment • Sampling • Records/Paperwork review

  15. Common violations (Nationally) • Improperly monitored / inspected equipment • Equipment leaks / failure to seal equipment • Failure to tag equipment • Failure to maintain records • The majority of the cases are not against CAA major sources

  16. Questions?

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