RCRA

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The U.S. Environmental Protection Agency (EPA) released a decision last week stating that revisions to the federal regulations for the management of wastes from the exploration, development, and production of crude oil, natural gas, and geothermal energy (i.e. oil and gas wastes from hydraulic fracturing and directional drilling) are not necessary at this time.  EPA…

The cradle-to-grave scheme is at the heart of the Resource Conservation and Recovery Act. RCRA, after first defining what a “hazardous waste” is and requiring permits for facilities accepting these materials, then requires a manifest to accompany the movement of the waste from the point of generation – through transportation – and then finally to…

Continuing on our discussion of the electronic manifest (e-Manifest) system, EPA Administrator, Scott Pruitt, signed the e-Manifest User Fee Final Rule on December 20, 2017.  EPA expects the final rule to be published in the Federal Register in the coming weeks.  The pre-publication version of the final rule is attached here.

Under the final…

A North Carolina appeals court has ruled that a company may be an “operator” of a hazardous waste disposal facility under RCRA Subtitle C based solely on post-closure involvement at the site.

The case, WASCO LLC v. N.C. Dep’t of Env’t & Nat. Res., Div. of Waste Mgmt., No. COA16-414, 2017 BL 125671 (N.C.

Nine trade associations, including the American Chemistry Council, the American Petroleum Institute, and the American Forest & Paper Association, have filed a Petition for Review challenging the EPA’s Hazardous Waste Generator Improvements Rule.  The rule was developed by the Obama Administration and was not finalized until after the election, on November 28, 2016.  It is…

On November 28, 2016, the EPA published its Hazardous Waste Generator Improvements Rule, finalizing a much-needed update to the 30-year old Resource Conservation and Recovery Act (RCRA) hazardous waste generator regulations.  The Rule includes over 60 changes to the hazardous waste generator regulations to make them easier to understand, which will presumably increase compliance,…