40 CFR 261.4(a)(9) – The Hazardous Waste Exclusion for Spent Wood Preservatives
Waste Characterization and Generator Status: What You Need to Know. Wednesday September 25, 2013, 10 – 11 a.m., EST
Hosted by Ohio EPA’s Office of Compliance Assistance and Pollution Prevention (OCAPP). This free 1-hour webinar will discuss the basics of how to determine if a waste meets the definition of hazardous waste, how to properly characterize those wastes, and how to count them in determining your company’s generator status. Examples of common hazardous wastes, excluded wastes, universal wastes, and waste evaluation methods and tips will be explained. The practical impacts of proper waste characterization, accounting, and waste reduction practices will also be discussed. Presenter: Dan Sowry, OCAPP, Environmental Specialist, Central District Office, Columbus, OH.
Webinar seats are limited, click here to register.
After this free webinar on September 25th, come to my full day training seminar in Columbus, OH on September 26th. There is a fee, but in 8 hours you’ll learn more about the hazardous waste determination, how to manage hazardous waste and how to transport hazardous materials.
RCRA Conditional Exclusion for Solvent-Contaminated Wipes
In a press release dated July 23, 2013 the USEPA announced a modification of the RCRA regulations to conditionally exclude solvent-contaminated wipes from certain hazardous waste requirements. This long-awaited final rule makes the following changes to the USEPA’s hazardous waste regulations:
A new conditional exclusion in the RCRA regulations is available for solvent contaminated wipes
- Creates the following new terms and definitions at 40 CFR 260.10:
- No free liquids
- Solvent-contaminated wipes
- Wipe
- Creates a new conditional exclusion from definition as a solid waste at 40 CFR 261.4(a)(26): Solvent-Contaminated Wipes Sent for Cleaning and Reuse
- Creates a new conditional exclusion from definition as a hazardous waste at 40 CFR 261.4(b)(18): Solvent-Contaminated Wipes, Except Wipes with Trichloroethylene, Sent for Disposal
The effective date for this regulation – ie. the date it becomes an enforceable USEPA regulation – is set as six (6) months from the date of its publication in the Federal Register. It was published in the FR today (July 31, 2013) making it effective on January 31, 2014.
The exclusion is expected to be used by and be a significant cost-savings for thousands of US businesses. To ensure you are one of them, carefully review the regulatory requirements and modify your operations accordingly. (more…)
40 CFR 261.4(b)(5) – The Hazardous Waste Exclusion for Oil, Gas, & Geothermal E&P Waste
RCRA Exclusions From the Definition of Hazardous Waste @ 40 CFR 261.4(b)
The regulations of the USEPA include exclusions from the definition of hazardous waste for certain discarded materials. This exclusion is limited to specific industries, processes, and chemicals identified by regulation. This exclusion is important since if a discarded material is not a hazardous waste it is not subject to complicated and expensive regulation under the Resource Conservation and Recovery Act (RCRA).
This article is meant to serve as an introduction and a starting point for all of the exclusions of §261.4(b). Below are links to articles which themselves are Power Point presentation previously uploaded to SlideShare and later posted on my blog. As of June 2013 I am still a long way from completion, but be patient, I’ll eventually get to them all. If you are not patient, then contact me with a request, I’ll do my best to accommodate your wishes as soon as I can by posting another blog post/SlideShare Upload.
40 CFR 261.4(b)…
(3) Mining overburden.
(4) Fossil fuel combustion waste.
(5) Oil, gas, or geothermal exploration & production wastes.
(6) Trivalent chromium wastes.
(7) Mining and mineral processing waste.
(8) Cement kiln dust.
(9) Arsenic-treated wood.
(10) Petroleum-contaminated waste from underground storage tanks.
(11) Petroleum-contaminated injected groundwater.
(12) Used chlorofluorocarbon refrigerants.
(13) Non-terne plated used oil filters.
(14) Used oil re-refining distillation bottoms that are used as feedstock to manufacture asphalt products.
(15) Leachate or gas condensate collected from landfills where certain solid wastes have been disposed.
(16) [Reserved]
(17) Solid waste that would otherwise meet the definition of low-level mixed wastes (LLMW) pursuant to §266.210 of this chapter that is generated at the Ortho-McNeil Pharmaceutical, Inc. (OMP Spring House) research and development facility in Spring House, Pennsylvania and treated on-site using a bench-scale high temperature catalytic oxidation unit [expired June 27, 2010].
(18) Solvent-contaminated wipes, except for wipes that are hazardous waste due to the presence of trichloroethylene, that are sent for disposal.
The Used Oil Filter Exclusion from Regulation as a Hazardous Waste @ 40 CFR 261.4(b)(13)
40 CFR 261.4(b)(13) excludes non-terne plated used oil filters, a solid waste, from regulation as a hazardous waste if the requirements of the regulations are met. This presentation briefly summarizes the requirements of this RCRA exclusion from regulation.
The Hazardous Waste Determination for a Waste that Changes from Non-Hazardous to Hazardous
A generator of any solid waste is required to complete a hazardous waste determination according to the procedure at 40 CFR 262.11. This determination is typically made at the point of generation, ie., at the moment the solid waste is first generated. However, a generator’s responsibility to complete the hazardous waste determination may continue beyond the initial point of generation if the solid waste may later undergo a chemical or physical change. (more…)
40 CFR 261.4(a)(11) The Splash Condenser Dross Residue for Recycling Exclusion from Regulation as a Solid Waste
What Does RCRA Mean by a Commercial Chemical Product?
The phrase “Commercial Chemical Product” is used in two critical positions in the hazardous waste regulations of the USEPA. In either position it may play an important role in your Hazardous Waste Determination which is required by 40 CFR 262.11 for all waste you generate. The purpose of this article will be to explain the difference in USEPA’s interpretation of this phrase in its two locations and how its interpretation might affect your hazardous waste determination. (more…)