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The Hazardous Waste
Generator
Improvements Rule
Ask the Expert:
Meet Your Moderator:
James
Ciccone
This is not a formal presentation, rather it is an
open Q&A forum.
All lines will be muted – please communicate via
the questions tab in your webinar panel.
Any unanswered questions will be responded to
after the session.
Recording will be emailed to you tomorrow.
What You Can Expect
Type question here
Type your
comments and
questions here
throughout the
session
How to Interact Today
Meet the Expert
Gigi
Dambreville
How concerned
are you about the
new rule?
Final Rule!Signed by the EPA
Administrator on October
28, 2016
Published in the Federal
Register November 28
2016
Made effective May 30th
2017
Goals of the Final Rule
1. Reorganize the regulations to make them more user friendly and
enable improved compliance
2. Provide greater flexibility for hazardous waste generators to
manage waste in a cost-effective manner
3. Strengthen environmental protection by addressing identified
gaps in the regulations
4. Clarify certain components of the hazardous waste generator
program to address ambiguities and foster improved compliance
Rule #11. Consolidation of CESQG Waste at LQG’s:
• CESQG to be called VSQG
• CESQG’s and LQG’s must be under the control of the
same person
• Eliminate RCRA permit requirement to accept
CESQG’s waste
• Additional option for CESQG’s to manage their waste
• Increased training and documentation
• Potentially decrease generator cost
Rule #2
2. Episodic Generation for CESQG’s and SQG’s:
• Only allowed once a year
• Would not change current generator status
• Would not have to complete biennial requirement
• Notification of planned and unplanned events
• Labeling requirement for accumulation of episodic
waste
• 45 days from initiation and completion of episodic
event
Rule #33. Emergency Planning and Preparedness:
• Only applicable to LQG’s and SQG’s
• Require generators to make arrangements with
local LEPC’s first
• If no local LEPC, generators to make arrangements
with local Fire Departments
• NEW LQG’s to submit executive summary to LEPC
rather than full contingency plans
• Eliminating employee personal information in plans
Rule #44. Labeling changes:
• Applicable to SQG’s, LQG’s and Transporters
• Marking containers with hazardous waste codes
• Make it easier for TSDF’s to identify content
• Relevant areas on site: SAA’s, CAA’s, transfer
facilities consolidating waste from different
generators
• Labeling requirement for tanks, drip pads and
containment buildings
• Recordkeeping requirements for tanks, drip pads,
containment building for 90 and 180 day storage
Rule #55. Reporting Requirements:
• Biennial reporting required only for LQG’s
• Reporting for all hazardous waste generated
during reporting year
• Not applicable to CESQG’s and SQG’s under
episodic rule
• Allow new source code for CESQG’s transferred
waste
Rule #66. Satellite Accumulation areas:
• Prohibiting incompatible waste to be mixed in the
same container
• Limited exception for keeping containers closed at
all times at SAA’s
• Modify labeling to include flexibility on hazard
category type
• Clarify the “three day” rule
“What are the impacts of the new
rules on Large Quantity
Generators?
-Jonathan
“If you are an episodic LQG, do
you notify the state of generator
status change?”
-Carrie
“Are there any new reporting
requirements for SQGs?”
-Sarah
“If generators are not required to
document all determinations that a
waste is not a hazardous waste, what
at a minimum are they required to do?”
-Steve
“Will the rule will be repealed
by the Trump Administration?”
-Gary
“Will facilities be required to submit
RCRA/ICP plans to an additional
department at EPA and/or State
Agencies?”
-Elaine
“VSQGs must make a HW
determination. Are they required
to have any specific labeling for
Hazardous Waste containers?”
-Matt
“How might Multi-Satellite Accumulation
Area generators (universities, GOV
research facilities) comply with section
262.15 - marking waste containers with
specific hazards?”
-Paul
“In the Satellite Accumulation Areas, we
are not putting a date on the drum until it
reaches 55 gallons; do we need to put the
date on the drum when we start adding
waste to it?”
-Chuck
“When will Massachusetts DEP
update their regulations in
response to this?”
-Adam
“If there is an 'audit program' you
have, would suggest, or simply the
top 10 items that should be
reviewed/confirmed internally, that
would be great.”
-Brian
Thank You For Attending!
Contact:
Gigi Dambreville
You will receive:
• A recording of this session
• A survey for you to provide
feedback on the session
• An offer for a free
administrative gap analysis
