New Hazardous Waste Manifest Now Required

EPA has launched the new e-Manifest system nationwide on June 30, 2018. Beginning immediately, you will have the option to create manifests electronically, or you will be able to continue to use paper manifests. A slightly modified 5-part paper manifest was also introduced for use beginning on June 30.
The e-Manifest system allows for three types of hazardous waste manifest creation options:

• Paper (generator, transporter, and receiving facility all sign on 5-part paper manifest)
• Hybrid (starts as 5-part paper manifest signed by the generator and then is signed electronically by the transporter and receiving facility)
• Electronic (created in e-Manifest and electronically signed by all entities listed on the manifest)

If you have not already done so, you can register for e-Manifests with your site’s existing EPA ID number at: https://www.epa.gov/e-manifest. Generators remain responsible for the content of the manifest, however they can authorize others, such as brokers, waste transporters, or consultants to enter the data and sign the manifest on their behalf. EPA has encouraged each generator to assign two Site Managers, who could then authorize other users to view, create, and/or sign manifests electronically.
Starting now, all manifests, whether paper or electronic, will be submitted by the receiving facility to EPA via the Agency’s e-Manifest system. There will be several ways to submit manifests to EPA, ranging from mailing conventional paper to full electronic delivery. Receiving facilities will pay a fee that varies based on how the manifest is submitted.

The new manifest must be used for:

• RCRA federal hazardous waste
• Regulated PCB waste shipped on a manifest
• State-regulated hazardous waste (if a manifest is required by origination or destination state)
• Very Small Quantity Generator waste (if, as noted below, a manifest is required by the state)
• Imported hazardous waste

Unless required by your state, the e-Manifest is not required for wastes that did not require hazardous waste manifesting in the past, such as:

• Very Small Quantity Generators (formerly Conditionally Exempt Small Quantity Generators)
• Used Oil
• Universal Waste
• Medical Waste
• Non-hazardous Waste

You will be able to use the new e-manifest system to meet EPA’s 3-year manifest recordkeeping requirements. However, if your site does not create an e-Manifest account, you will be unable to view manifests in EPA’s e-manifest system and therefore you should make arrangements with the receiving waste treatment, storage, disposal, or recycling facilities to obtain paper copies of completed manifests so that you can meet your requirement to keep manifest copies from the destination facility for at least three years.
EPA has indicated that the Agency is evaluating whether enhanced security measures are needed for data regarding certain acute hazardous wastes. In the interim, EPA will be working directly with impacted receiving facilities on specific procedures related to those manifests. EPA recently also indicated that it would grant receiving facilities extra time to submit paper manifests in the initial months after system launch to further support industry implementation. Facilities that receive manifested waste between June 30, 2018 and September 1, 2018 will now have until September 30, 2018 to send those paper manifests to EPA. Many states will no longer require hazardous waste generators to mail copies of the new paper (or e-manifest) to the state. Check with your state environmental agency to determine if this applies to you.
Hazardous Waste Training


Annual hazardous waste training is required for anyone who generates, accumulates, stores, transports, or treats hazardous waste. Learn how to manage your hazardous waste in accordance with the latest state and federal regulations. Learn how to complete EPA’s new electronic hazardous waste manifest, and the more than 60 changes in EPA’s new Hazardous Waste Generator Improvements Rule. Environmental Resource Center’s Hazardous Waste Training is available at nationwide locations, and via live webcasts. If you plan to also attend DOT hazardous materials training, call 800-537-2372 to find out how can get your course materials on a new Amazon Fire HD10 tablet.
New TSCA Reporting Requirements for Mercury
As required under section 8(b)(10)(D) of the Toxic Substances Control Act, EPA published a final rule that establishes reporting requirements to assist in EPA's preparation of an “inventory of mercury supply, use, and trade in the United States.”
The requirements apply to anyone who manufactures (including imports) mercury or mercury-added (including mercury compound) products, or otherwise intentionally uses mercury in a manufacturing process. Based on the inventory EPA is required to "identify any manufacturing processes or products that intentionally add mercury; and . . . recommend actions, including proposed revisions of Federal law or regulations, to achieve further reductions in mercury use.'' At this time, EPA is not making these identifications or recommendations.
This final rule requires reporting from any person who manufactures (including imports) mercury or mercury-added products, or otherwise intentionally uses mercury in a manufacturing process.
The rule applies to facilities that manufacture (including import) mercury in amounts greater than or equal to 2,500 lb/year for elemental mercury or 25,000 lb/year for mercury compounds. Information that must be reported includes the amounts of mercury: stored, distributed in commerce, manufactured, imported, exported, in manufactured (other than imported) products, in imported products, in exported products, and intentionally used in a manufacturing process.
This final rule will go into effect on August 27, 2018.
NY to Adopt First Major Update to State's Environmental Quality Review Regulations in 20 Years
New York State Department of Environmental Conservation (DEC) Commissioner Basil Seggos announced that DEC has adopted a rulemaking package that will make the first major update to State Environmental Quality Review (SEQR) regulations in more than two decades, preserving the integrity of the regulations and streamlining the environmental review process.
Commissioner Seggos said, "DEC is always looking for ways to make our agency more efficient and effective for the nearly 20 million New Yorkers that depend on us to protect our natural resources. DEC's updates to SEQR will streamline the environmental review process and encourage sustainable development and renewable energy development without sacrificing SEQR's integrity or the environmental protections it affords."
The updates to SEQR will take effect on January 1, 2019 and will expand the number of actions not subject to further review, known as Type II actions, modify thresholds for actions deemed more likely to require the preparation of an environmental impact statement (EIS), and require scoping of an EIS. Additional highlights regarding content of a draft EIS, are the consideration of measures to avoid or reduce an action's impacts on climate change-induced conditions such as sea level rise and flooding, as well as enhancements to make acceptance procedures for EIS more consistent. Examples of Type II actions to be added include:

• Green infrastructure upgrades or retrofits
• Installation of solar arrays on closed landfills, cleaned-up brownfield sites,
• Wastewater treatment facilities, sites zoned for industrial use, or solar canopies on residential and commercial parking facilities
• Installation of solar arrays on an existing structure not listed on the National or State Register of Historic Places
• Reuse of a residential or commercial structure, or structure containing mixed residential and commercial uses
• Acquisition and dedication of parkland
• Land transfers in connection with one, two or three family housing
• Construction and operation of certain anaerobic digesters at operating publicly owned landfills.

DEC's updates to SEQR were subject to one of the most extensive stakeholder outreach campaigns in agency history and were designed to address concerns shared by a wide range of stakeholders while still maintaining SEQR's purpose of protecting the public and the environment. In addition to a full public scoping process for the draft EIS, DEC held 11 stakeholder meetings with representatives from the business community, environmental groups, and local governments over two years. DEC received more than 280 comments from the public after the proposed regulations were released in 2017.
The final rules will be available on DEC's website and noticed in both the Environmental Notice Bulletin and the State Register on July 18. DEC expects to release an updated SEQR Handbook and SEQR workbooks later this year to reflect the regulatory changes that take effect on January 1, 2019. In addition, DEC will provide training for lead agencies to ensure they understand the changes to the SEQR process.
Oil and Gas Wastewater on the Road Could Mean Health and Environment Woes
A truck kicking up dust as it speeds down a dirt road is a typical image in country music videos. But this dust from unpaved roads is also an environmental and health hazard. To prevent dust clouds, some states treat dirt motorways with oil and gas wastewater. Now one group reports in Environmental Science & Technology that this wastewater contains harmful pollutants that have the potential to do more harm than good.
According to the DOT, 34% of roads in the U.S. are unpaved. These unpaved roads contribute to almost half of the annual airborne particulate matter emissions -- such as dust, dirt and soot -- in the U.S., potentially causing respiratory and cardiovascular issues. In an attempt to prevent these health effects, road managers spread products on these roadways to suppress dust. Almost 200 different dust suppressants, mostly chloride salts or salt brine products that form a coating or help particles aggregate, are available. But these suppressants can be too costly in regions where budgets are tight, so many municipalities turn to a free alternative: salty oil and gas (O&G) wastewater produced from well operations. While O&G wastewater is good for a township’s bottom line, there are concerns about contaminants leaching from it into the environment. So William D. Burgos and colleagues wanted to evaluate the potential environmental and human health impacts of this practice.
The spreading of O&G wastewater on roads is permitted in at least 13 states, with significant spreading activity occurring in Ohio and Pennsylvania. The team studied O&G wastewater spread on roads and found them to contain salt, radioactivity and organic contaminant concentrations above their respective drinking water standards. These substances can be harmful to humans and aquatic life. In lab simulations, nearly all of the metals from these wastewaters leached out after simulated rain events, but metals such as radium – which is radioactive and a known carcinogen -- and lead were partially retained on roadways. The researchers speculate that the radium that did leach could end up in nearby bodies of water. The group proposes that establishing wastewater standards and treatment guidelines for O&G wastewaters spread on roads could help reduce the potential environmental impacts of this practice.
Read more on New Hazardous Waste Manifest Now Required.