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EPA Plans To Amend RCRA Hazardous Waste Generator Regulations

Lynn Grayson   By E. Lynn Grayson, Partner, Jenner & Block

EPA recently announced plans to amend certain hazardous waste regulations under RCRA at 40 C.F.R. Parts 261-265 in its Action Initiation List. According to EPA, the focus will be to streamline these regulations with the overall objective to make targeted, sensible improvements to the hazardous waste regulatory program.

The new proposal will address:

   the amount of time waste accumulates at a facility for the purposes of classifying the facility as a large waste generator;

   labeling standards for storage tanks and drums;

   closure requirements for tanks, containers, drip pads, and containment buildings; and

   certification standards for recyclable materials used in a manner constituting disposal.

Many hazardous waste generation regulations date to the 1980s. EPA and State regulatory leaders agree that a comprehensive review and update is timely.

E. Lynn Grayson is a partner in Jenner & Block's Chicago office and a member of the Firm's Environmental, Energy and Natural Resources Law, Climate and Clean Technology Law, Defense & Aerospace and Environmental Litigation Practices. Ms. Grayson is AV Peer Review Rated, Martindale-Hubbell's highest peer recognition for ethical standards and legal ability. Ms. Grayson has been recognized as one of The Best Lawyers in America, an Illinois Super Lawyer and Lawdragon magazine named Ms. Grayson to its "New Stars, New Worlds" list of 500 attorneys who are "carving the path to the new heights of the legal profession." Chambers USA and Leading Lawyers Network have recognized Ms. Grayson as one of the country's leading environmental lawyers as recommended by a peer review process.

Read more at Corporate Environmental Lawyer Blog by Jenner & Block LLP.

The Corporate Environmental Lawyer Blog is a 2011 LexisNexis Top 50 Blogs for Environmental Law & Climate Change winner.

Hazardous Waste Generator

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