New Proposal for Electronic Hazardous Waste Fee Payments

In late June, the Environmental Protection Agency (EPA) issued a new proposed rule on the methodology for setting and revising user fees for the hazardous waste electronic manifest (e-Manifest) system. This is part of a larger development project aiming for a national system of tracking hazardous waste electronically.

According to the EPA, the e-Manifest system “will improve access to higher quality and more timely shipment data and will significantly reduce burden associated with the current paper system”.

This particular proposal involves the user fee methodology, specifically the following considerations:

  • who must pay e-Manifest user fees;
  • the types of transactions that will give rise to fees;
  • the formula that will be used to set fees;
  • options for making fee payments;
  • the process EPA will use to revise fees; and
  • the possible sanctions for non-payment.

The EPA also proposes “to tailor user fees according to whether manifests are submitted electronically or via paper to reflect the varying processing costs of these options”. The rule is currently open for comment on the Federal Register.

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Philadelphia Prison Systems Receives Special Recognition from the EPA

The Environmental Protection Agency (EPA) awarded special recognition in April to the City of Philadelphia for the Philadelphia Prison Systems innovative food recovery achievements. The prison system composted 1.35 tons of wasted food each day and saved the city $31,000 a year in landfill fees.

“The Philadelphia Prison System sets a tremendous example on using innovation to reduce food waste,” said EPA Mid-Atlantic Regional Administrator Shawn M. Garvin. “Businesses and communities across America are taking positive steps to address the food waste challenge, and they’re saving money, helping the environment, and feeding hungry people in the process.”

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Latest U.S. Greenhouse Gas Inventory Report

Last week, the Environmental Protection Agency (EPA) released the 21st annual Inventory of U.S. Greenhouse Gas Emissions and Sinks, more commonly known as the GHG Inventory. The report reviews greenhouse gas emissions on a nation-wide scale from 1990-2014.

The report tracks emissions and removals by source, economic sector, and type of greenhouse gas by utilizing national energy data, data on agricultural activities, and other national statistics. Additionally, the Greenhouse Gas Reporting Program provides data from individual facilities and suppliers of certain fossil fuels and industrial gases.

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Revisions to Hazardous Waste Regulations

In September 2015, the EPA announced a proposal for a large number of changes to the existing hazardous waste regulations. The current regulations were established by the Resource Conservation and Recovery Act (RCRA) and are housed in title 40 of the Code of Federal Regulations (CFR). The proposed changes would consolidate all of the regulations into two parts, 260 and 262 with 260 focusing on the classification of waste and 262 focusing on management standards.

There are over 50 proposed changes to the regulations. In a recent webinar by Triumvirate Environmental, 7 of the major changes were discussed and are summarized below:

  1. Large Quantity Generators (LQGs) with Conditionally Exempt Small Quantity Generator (CESQG) satellite facilities can consolidate waste at one facility and send out as one waste stream. CESQG will be renamed to Very Small Quantity Generators (VSQGs).
  2. CESQGs and Small Quantity Generators (SQGs) can have one event per year out of their status limitations without having to change their current status. Notification will be required 30 days prior to the event for planned events and 24 hours after the event for unplanned events.
  3. LQGs and SQGs will need to make arrangements with Local Emergency Planning Committees (LEPC) for emergency contingency plans. New LQGs will be able to submit an executive summary to the LEPC rather than a full contingency plan.
  4. LQGs and SQGs will need to mark containers with hazardous waste codes in satellite accumulation areas and in central accumulation areas.
  5. Biennial reporting will be required only for LQGs to report all waste generated. They can include the transferred waste from CESQGs in the same report.
  6. Cannot mix incompatible waste in the same container at satellite accumulation areas. If there is a danger to keeping containers closed, the container may remain open until danger subsides.
  7. If you are an LQG and cannot close as a “clean close”, you will have to close as a landfill.

The comment period for these proposed changes closed in December of 2015. There is no word at this point as to when the final rule will be issued, however it may come out in 2016.

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EPA’s 2017-2019 Enforcement Initiatives

On February 18th, the Environmental Protection Agency (EPA) announced its seven National Enforcement Initiatives for fiscal years 2017-2019. These initiatives are selected every three years by the EPA to “focus resources on national environmental problems where there is significant non-compliance with laws, and where federal enforcement efforts can make a difference”.

Out of the seven chosen initiatives, four are retained from the current set, one is expanded from the current set, and two are new. The four being retained and the one expansion are:

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Health Systems Come Together at the Conference on Climate Change

Health system representatives from 16 countries have come together at the United Nation’s Conference on Climate Change in Paris this week to announce a number of commitments and actions to reduce carbon emissions in the healthcare industry. More than 50 health systems, representing over 8,200 hospitals, have come to the conference to join the 2020 Health Care Climate Challenge. The challenge, led by Health Care Without Harm, requires health systems to pledge “to reduce their own carbon footprint, become climate resilient anchors in their communities, and pursue both political and economic solutions that will protect public health from climate change”.

“These hospitals and health systems are leading by example, reducing their own carbon emissions by 30, 50, even 80 percent.” said Gary Cohen, Founder and President of Health Care Without Harm. “At the same time, many are investing in clean renewable energy, while calling on leaders to implement policies locally, nationally, and internationally that foster a global transition away from fossil fuels.”

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Proposed Updates to the Cross-State Air Pollution Rule

The Environmental Protection Agency (EPA) is proposing updates the existing Cross-State Air Pollution Rule (CSAPR). The goal of the updates is to reduce summertime emissions of oxides of nitrogen (NOx) from powerplants that contribute to downwind ozone issues in other states.

As part of the Clean Air Act, states are required to develop state implementation plans (SIPs) that address interstate transport of air pollution that affects the ability of downwind states to meet clean air standards. In lieu of developing their own plans, states can default to the federal implementation plan (FIP). The updates to CSAPR provide the FIP that would apply if a SIP is not developed.

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New Greenhouse Gas Emission Rules

In October, the Environmental Protection Agency (EPA) announced new actions the agency will take to curb emissions from ozone-depleting (ODS) refrigerants and hydrofluorocarbons (HFCs), greenhouse gases used in refrigeration and air conditioning. The actions were created along with private and public sector leaders to help smooth the transition from ODS and HFCs to more climate friendly alternatives.

According to the EPA press release, the following actions were included in the announcement:

  • EPA proposed a rule that would improve the way refrigerant is sold, handled, recovered, and recycled. The proposal would strengthen the existing requirements for handling refrigerants and apply those rules to ozone-depleting and HFC refrigerants. EPA estimates that this rule would further reduce enough HFC emissions in 2025 to equal 7 million metric tons of carbon dioxide.

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EPA Strengthens Ozone Standards

The Environmental Protection Agency (EPA) updated the National Ambient Air Quality Standards (NAAQS) for ground-level ozone earlier this month. The ozone standard was updated from 75 parts per billion (ppb) to 70 ppb. Ozone is created when nitrogen oxides react with volatile organic compounds in the air. The EPA states that the strengthened standards will “reduce Americans’ exposure to ozone, improving public health protection, particularly for at risk groups including children, older adults, and people of all ages who have lung diseases such as asthma”.

After the examination of almost 2,300 studies on ozone, the EPA concluded that 75 ppb was not sufficient to protect public health with an adequate margin of safety. Ozone levels have decreased by 33% from 1980 to 2014, even with a growing economy. This can be attributed to advances in pollution control technology for vehicles and industry, along with emission reduction standards for vehicles, power plants, and fuels.

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Proposed Standards for Hazardous Pharmaceutical Waste

Early this month, the Environmental Protection Agency (EPA) released proposed Management Standards for Hazardous Waste Pharmaceuticals Rule. The proposed rule would apply to both healthcare facilities (including pharmacies) and reverse distributors. Previously, hazardous pharmaceutical waste at these facilities was managed under the Resource Conservation and Recovery Act (RCRA), along with all other hazardous waste generators.

The EPA has given three reasons explaining why separate rules for pharmaceutical waste are necessary. “First, healthcare workers, whose primary focus is to provide care for patients, are not knowledgeable about the RCRA hazardous waste regulations, but are often involved in the implementation of the regulations. Second, a healthcare facility can have thousands of items in its formulary, making it difficult to ascertain which ones are hazardous wastes when disposed. Third, some active pharmaceutical ingredients are listed as acute hazardous wastes, which are regulated in small amounts.”

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