EPA’s e-Manifest Fees Doubling

Authored by Angie Martin, PE, CHMM

EPA’s e-Manifest processing facility received over 1.5 million manifests from the launch of the system on June 30, 2018 through April 30, 2019. On an annualized basis, this number falls 880,000 manifests short of the projected number of manifests initially used to calculate EPA’s e-Manifest fees. The regulations require EPA to recalculate fees which are effective October 1, 2019 and every 2 years thereafter. EPA has increased fees for different types of manifest submissions from 60% to 115%. These fees are charged directly to the destination facilities. As such, Heritage is adjusting our e-Manifest fee to $25 per manifest, effective with shipments originating on October 1.

As noted below, EPA’s analysis indicated that a very low percentage of manifests have been submitted using fully electronic options (<0.3%).  This is due to a wide variety of factors (user registration, continuing software changes, technical restrictions, logistical challenges, etc.) and was the primary topic of the recent Advisory Board meeting.  EPA also has a backlog of approximately 100,000 paper manifests to process and about 270,000 data plus image manifests to process. 

At this time, Heritage submits manifests to EPA using the same two most widely used options indicated below (scanned image and data plus image). 

Manifest Submission Type Submitted (6/30/18 – 4/30/19) %
Mailed paper manifest 103,348 6.8%
Scanned image upload 272,627 18%
Data plus image 1,140,003 75%
Fully electronic 4,005 <0.3%

Source: EPA, “Hazardous Waste e-Manifest Advisory Board June 2019 Meeting Background Whitepaper.”

Heritage is committed to safely and compliantly transporting, managing, and disposing of our customers’ waste.  We will continue to follow the EPA’s progress on e-Manifest programming and implementation and to update our customers on the progress.  EPA will recalculate fees in 2021, effective October 2021.

What is an EPA ID Number and How Do I Get One?

According to the EPA, “The Resource Conservation and Recovery Act (RCRA) requires individuals who generate or transport hazardous waste, or who operate a facility for recycling, treating, storing, or disposing (TSD) of hazardous waste, to notify EPA or their authorized State waste management agency of their regulated waste activities and obtain a US EPA Identification (ID) Number (also known as a RCRA ID Number). Handlers of some Universal Waste, Used Oil, and Boilers/Industrial Furnace may require a US EPA ID Number, too. If you are regulated and do not comply with the RCRA notification requirements, you may be subject to civil and criminal penalties.” [1]

EPA ID numbers are specific to individual sites (except when they are issued to transporters) and permanent. There is an exception to the permanency in the case of provisional numbers which last for just 90 days and can be used in case of emergency or temporary one time clean-ups. After the 90 days they are no longer valid and are deleted from the national registry.

What if our site moves?

EPA ID numbers do not move in the event that the owner/operator should relocate (unless the owner or operator is a transporter). EPA ID numbers are so important because they help the EPA to track wastes through the entire cradle-to-grave cycle which follows waste from the point of generation to the point of disposal. So, “Once a US EPA ID number is assigned to a specific physical location, it belongs solely to that location and will belong to any owners/operators at that location.” [2]

Should a generator decide to move the location of their operations (even if it is just to a different place in the same town) they would need to inactivate their old ID number for the former location and request a new ID number for their new location. The EPA does note that, “If at the new location, a RCRA hazardous waste ID number had previously been issued to the former owner/operator, the number for that physical location will then be assigned to the new requester.” If not you would simply need to fill out a form as normal.

What forms do we have to fill out?

The EPA provides the Notification of Regulated Waste Activity (EPA Form 8700-12) and associated instructions in order to help these generators, transporters, and individuals determine whether or not they need to notify the EPA or authorized state of their regulated waste activities. If they do, they must submit the RCRA Subtitle C Site Identification (Site ID) Form including the following:

  • “Initial Notification of Regulated Waste Activity
  • Subsequent Notification of Regulated Waste Activity
  • First RCRA Hazardous Waste Part A Permit Application
  • Revised RCRA Hazardous Waste Part A Permit Application
  • Hazardous Waste Report
  • Notification for eligible academic entities opting into or withdrawing from managing laboratory hazardous wastes pursuant to 40 CFR Part 262 Subpart K (if in an eligible State)
  • Notification for facilities managing hazardous secondary material pursuant to 40 CFR 260.42 (if in an eligible State)” [3]

Remember, some states have additional or different requirements than the Federal requirements. It is always best to check with your state government in addition to the EPA.

“In order to determine if your location already has been assigned a US EPA Hazardous Waste ID number, look in EPA’s Envirofacts Warehouse database by the physical location first (be sure to put in the State you want to search within).” [4]

As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

How is the EPA Addressing Waste Minimization?

According to the EPA, “The National Waste Minimization Program supports efforts that promote a more sustainable society, reduce the amounts of waste generated, and lower the toxicity and persistence of wastes that are generated.”[1]  They are working to do this in a few different ways. Firstly, the EPA has a list of 31 “priority chemicals” that they are working to reduce. They are doing this by identifying where these chemicals are found in “our nation’s products and wastes [and] finding ways to eliminate or substantially reduce their use in production. If these chemicals cannot easily be eliminated or reduced at the source, [they] focus on recovering or recycling them.”[2]

In addition to working to eliminate the priority chemicals, the EPA has four major tools and projects they are supporting that help with waste minimization. These four main tools are lean manufacturing, energy recovery, environmental management systems (EMS), and green chemistry. Each of these is explained in more detail below.

What is Lean Manufacturing?

According to the EPA, “Lean manufacturing is a business model and collection of tactical methods that emphasize eliminating non-value added activities (waste) while delivering quality products on time at least cost with greater efficiency.” Engaging in lean manufacturing allows companies to “create a culture of continuous improvement, employee empowerment, and waste minimization.” What this means is that companies who support and implement lean manufacturing initiatives see benefits outside of the scope you might expect. [3]

What is Energy Recovery?

Energy recovery is done through a process called gasification. According to the EPA, “gasification converts carbon-containing materials, under high temperature and pressure, into synthesis gas… or syngas… Syngas can be used as a fuel to generate electricity or as a basic chemical building block for use in the petrochemical and refining industries. Syngas generally has a heating value that is approximately two-thirds that of natural gas and, when burned as fuel, produces emissions that are similar to natural gas. In the petroleum refining industry alone, about seven to ten million tons of hazardous byproducts containing carbon, currently managed under the Resource Conservation and Recovery Act (RCRA), could be converted into useable fuel or chemicals using gasification methods.” [4]

What are Environmental Management Systems?

The EPA defines Environmental Management Systems (EMS) as “a set of processes and practices that enable an organization to systematically assess and manage its environmental “footprint” – the environmental impact associated with its activities, products, and services.” Environmental management systems are variable in scope and practice but all have rather similar goals; to improve environmental performance by providing a company with the tools they need to manage their environmental activities and impacts in the most beneficial and cost effective manner.

The EPA lists several benefits of EMS including:

  • Helping to comply with regulatory responsibilities and providing a way to address non-regulated environmental aspects like energy use and the conservation of resources;
  • Facilitating the assessment of risks and liabilities;
  • Increasing operating efficiency by creating standard operating procedures;
  • Increasing the environmental awareness of employees;
  • Potential for environmental and financial benefits; and
  • Providing a competitive edge over competitors not using EMS. [5]

What is Green Chemistry?

The final of the four primary tools being used by the EPA for waste minimization is green chemistry. The EPA defines green chemistry as, “the design of chemical products and processes that reduce or eliminate the generation of hazardous substances.” Green chemistry prevents pollution at the molecular level and applies to all areas of chemistry. The result is “source reduction” because it actually prevents the generation of pollution. It also “reduces the negative impacts of chemical products and processes on human health and the environment, lessens and sometimes eliminates hazard from existing products and processes, [and] designs chemical products and processes to reduce their intrinsic hazards.” [6] We will talk more about Green Chemistry in a future post.

Containment Buildings: What are they and how did they come to be?

Prior to the EPA’s development of the concept of containment buildings in 1992 certain heavy or bulky hazardous wastes were a serious problem for generators. Because of the issues that these wastes posed, the EPA developed standards for a new waste management unit (containment buildings). A containment building is basically a structure in which solid hazardous wastes can be stored and managed without violating LDR. It is a fully enclosed structure (meaning it has at least 4 walls, a roof, and a floor) which houses an accumulation of noncontainerized waste.

Why did EPA need containment buildings?

Before the EPA decided that containment buildings (like tanks or containers) could serve as hazardous waste management units, a collection of noncontainerized waste within a roofed structure would have been considered an indoor waste pile and as such would have been subject to regulations and standards in Subpart L of 264/265.

Because some debris wastes are better suited to storage and treatment in waste piles as opposed to in tanks or containers it made more sense to treat them in such a way. Placement of untreated debris in piles prior to it being treated, however, violated LDR regulations in part 268.

The EPA provides the following example; “Under LDR, hazardous waste may not be placed on the land unless it meets certain standards that require treatment of the waste to reduce its hazardousness. Before land disposal, many wastes will be stored or treated to meet the LDR treatment standards in tanks and containers — units that are not considered ‘land disposal units.’ Managing hazardous waste in certain types of units, including landfills, surface impoundments, and waste piles, constitutes “land disposal,” which may not occur until the waste has been treated to meet LDR standards.

Circular BarrierCertain bulky hazardous wastes are not amenable to treatment in tanks or containers and must be treated in waste piles. Since the definition of “land disposal” includes placement of waste in a waste pile, doing so is prohibited unless the waste first meets all applicable treatment standards. Thus, to perform the treatment required before land disposal, the waste must first be land disposed. Under this scenario, the land disposal restrictions form a circular barrier to any management of certain hazardous wastes.”

What this all boils down to is that prior to the creation of containment buildings, there were some types of waste that were nearly impossible (or at least very difficult) to properly treat and dispose of. The idea behind containment buildings is that they break the aforementioned circular barrier and allow all hazardous waste to be handled properly.

The EPA made the decision to exclude containment buildings from the regulations imposed by LDR based on the belief that a totally closed off unit, designed in compliance with the regulations in Part 264/265 subpart DD, can provide an equal level of containment as tanks and containers. Ergo containment buildings joined the fold and can now house waste without violating LDR.

Keep checking the blog for more posts about containment buildings. So does your company utilize containment buildings? How have they helped your process? Let us know in the comments section!

All information for this blog post was gathered from the EPA document, “Introduction to Containment Buildings.” As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

How to Clean Up Broken CFL Bulbs

Chances are you or someone you know uses CFL (Compact Fluorescent Light) bulbs in their home, office, etc. These bulbs, while being more environmentally friendly and longer lasting, pose some danger if broken. The danger stems primarily from the mercury that is in the bulbs because it is toxic in large quantities.

The EPA has a detailed set of guidelines to be followed if you have a broken bulb that needs cleaned up. These detailed steps can be found here.

To begin you clear people and animals out of the room where the broken bulb is located and turn off any central air system. Take about 5-10 minutes to let the room air out. This is a good time to gather the supplies you will need for the clean up. You will need:

– Stiff paper or cardboard

– Sticky tape

– Damp paper towels or disposable wet wipes

– A glass jar with a metal lid or a sealable plastic bag

The basic clean up steps (as taken from the EPA website) are as follows:

1. Carefully scoop up glass fragments and powder using stiff paper or cardboard and place debris and paper/cardboard in a glass jar with a metal lid. If a glass jar is not available, use a sealable plastic bag. (NOTE: Since a plastic bag will not prevent the mercury vapor from escaping, remove the plastic bag(s) from the home after cleanup.)

2. Use sticky tape, such as duct tape, to pick up any remaining small glass fragments and powder. Place the used tape in the glass jar or plastic bag.

3. Wipe the area clean with damp paper towels or disposable wet wipes. Place the towels in the glass jar or plastic bag.

It is not recommended that you use a vacuum unless you are certain that all the glass debris is gone.

After you seal the jar or bag you should remove it from your house. Then check about local ordinances concerning the proper disposal of mercury containing wastes. And remember, while this is a good method for cleaning up an accident the best practice is proper disposal before.

What is Hazardous Waste?

The other day as I was brainstorming ideas to write about for the blog something occurred to me. Hazardous waste is a very broad concept. I realized that outside of a company that deals with theses items on a daily basis, there may be confusion about what even qualifies as hazardous. This being said, I decided to talk about what, exactly, hazardous waste is.

The EPA defines hazardous waste as, “waste that is dangerous or potentially harmful to our health or the environment.” They further break down these wastes into four categories:

– Listed Wastes: These are wastes that EPA has determined to be hazardous. These listed wastes include F-list, K-list, and P-and U-Lists.

– Characteristic Wastes: These are wastes that do not fit into any of the above listings but that exhibit ignitability, corrosivity, reactivity, or toxicity.

– Universal Wastes: This includes things like batteries, pesticides, mercury-containing equipment (e.g., thermostats, old fashioned thermometers, etc.) and fluorescent lamps.

– Mixed Wastes: These are wastes that contain both radioactive and hazardous waste components.

For all of these wastes it is vital to dispose of them in a manner that will not harm the environment. Luckily, current available technologies are able to remove toxicity and/or hazard from many of these items making them safe for reuse or disposal.