On September 25, 2015 the USEPA proposed a new, more practical approach to compliance requirements for episodic waste generators.
Under current rules, if facilities generate more waste than anticipated in a month, they must follow more stringent and burdensome compliance processes that month and potentially face a biannual reporting trigger.
Relatively common events such as demolition projects, tank clean outs, site remediation, equipment maintenance during plant shutdowns, and the removal of excess chemical inventories can trigger these short-term changes in a generator's status. Quickly implementing these changes can be especially challenging for smaller facilities that don’t routinely manage larger amounts of hazardous waste.
USEPA’s new approach would allow episodic waste generators to maintain their current status and be exempt from periodic requirements to comply with more stringent rules applicable to higher generator categories.
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