Download PDF
October 16, 2019

RCRA Improvement Rules: An Update and Discussion

Bergeson & Campbell, P.C.

RCRA Improvement Rules: An Update and Discussion

Wednesday, October 16, 2019

1:00 p.m. – 2:00 p.m. (EDT)

Register Today


On November 28, 2016, the U.S. Environmental Protection Agency (EPA) issued the final “Generator Improvements Rule” under the Resource Conservation and Recovery Act (RCRA). 81 Fed. Reg. 85732. The potential scope of the revised regulatory program is immense — the changes will affect almost 700,000 facilities. The rule is the most comprehensive overhaul of the RCRA generator requirements in 30 years. Although the rule took effect on May 30, 2017, it is not effective in RCRA-authorized states until the states adopt the provisions. Many states are doing so; an update on the rule thus is timely.

The rule is a hodgepodge of over 60 sweeping changes to the existing regulations and the inclusion of new requirements for generators of hazardous waste. The changes include a reorganization of the hazardous waste generator requirements to make them more user-friendly and thus easier for the regulated community to be in compliance. The changes also provide a better understanding of how the hazardous waste generator regulatory program works and address gaps in existing regulations that will bolster environmental protection. Additional flexibility for generators is also built into the changes.

Among other changes, EPA has eliminated the “conditionally exempt small quantity generator” (CESQG) category and replaced it with the “very small quantity generator” (VSQG) category. Of the three scores of changes, perhaps the most significant change allows VSQGs to send hazardous waste to a large quantity generator (LQG) that is under the control of the same person. The rule also addresses the issue of “episodic generation,” where a generator’s category could fluctuate based upon the quantity of hazardous waste generated in a calendar month. EPA’s reorganization of the generator rules fall into four broad categories that will be covered in the webinar. Other changes in the rule include revising the regulations that address closure, waste determinations, contingency plans, and emergency preparedness and prevention.

Topics Covered:

  • Overview of the significant regulatory changes, including transferring waste between generators, new requirements, and episodic generation standards.
  • Reorganization of the regulations and new standards for LQGs, SQGs, and VSQGs.
  • Practical aspects of complying with the regulatory changes.

Speakers Include:

  • Chris Bryant, Senior Regulatory Consultant, Bergeson & Campbell, P.C.