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.
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).
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.
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.
LQGs and SQGs will need to mark containers with hazardous waste codes in satellite accumulation areas and in central accumulation areas.
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.
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.
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.