Does your facility generate, treat, store or dispose of hazardous wastes? If so, take the time to read and comment on EPA’s revision to “Waste Analysis at Facilities That Generate, Treat, Store, and Dispose of Hazardous Wastes: A Guidance Manual.” The guidance manual was last updated in 1994. The current version of the guidance manual (dated January 2013) is available here.
Even if you don’t want to provide comment, the manual provides helpful input on developing and implementing a Waste Analysis Plan in accordance with RCRA.
EPA identified the following areas as in particular need of clarification in the revised guidance manual:
- Design of characterization studies;
- Recharacterization frequency;
- How to address issues of waste variability;
- Establishing and employing data quality objectives;
- Selection of indicator parameters to reduce testing costs;
- Measurement uncertainty; and
- Using statistical concepts to guide the characterization process.
EPA will accept comments through April 30, 2013. More information is available on the EPA website. If you need help preparing comments or understanding the guidance, please contact SMG’s Government Relations team at scottr.smith@smithmanage.com or koria@smithmanage.com. Additionally, if you would like to see more regulatory updates, please see our Reg Watch page or contact us for monthly delivery.