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Materials Excluded from Being a Solid Waste


"In order for a material to be a hazardous waste, it must first be a solid waste under RCRA. But some materials aren't wastes at all. Yesterday we gave you a list of materials that are excluded from the definition of solid waste. Here's the rest of the list."

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What’s NOT a Waste


"Certain materials are excluded from the definition of solid waste under RCRA. If the material is not a solid waste, it cannot be a hazardous waste."

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Pre-Permit Checklist for Title V


"It is important to make sure that all regulated air emissions are included in operating permits. If you are applying for a Title V permit use this checklist to make sure you’ve got everything."

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TRI Exemptions—What You Don’t Have to Report


"EPA has identified more than 650 chemicals and chemical categories that are subject to the TRI annual reporting requirement. Yesterday we told you everything you need to know about reporting those chemicals on Form A, Form R, and TRI-MEweb. But there are some exemptions to TRI reporting. Before you scramble to get your reports ready before the July 1st deadline, here’s what you need to know about what you don’t have report."

Use Exemptions

Certain uses of listed toxic chemicals are exempt:

  • Use as a structural component of the facility.
  • Use in routine janitorial or facility grounds maintenance (including phenol in bathroom disinfectants and pesticides in lawn care products). Listed chemicals used in facility equipment maintenance and cleaning or maintenance activities that are integral to the production process at the facility are not exempt (e.g., herbicides used on an aboveground storage tank berm).
  • Employees’ personal use (foods, drugs, cosmetics, etc.).
  • Use of products containing toxic chemicals for facility motor vehicle maintenance.
  • Use of toxic chemicals contained in intake water (used for processing or noncontact cooling) or in intake air (used either as compressed air or for combustion).

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Do You Need an Industrial Stormwater Permit? Find Out In 3 Simple Steps


"A California recycler was recently issued an enforcement order to immediately comply with federal Clean Water Act laws after EPA found evidence of unlawful discharges of polychlorinated biphenyls (PCBs), mercury, lead, copper, and zinc into the San Francisco Bay."

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Stormwater FAQs Roundup


"Here are a few questions answered by BLR environmental experts on stormwater."

Do I need a NPDES permit if my stormwater exposure is only in the parking lot?

It may depend on several factors, including, but not limited to, the proximity of the parking lot to surface waters; the size of the parking lot; and the type of parking lot surface.

A possible option that may apply to your situation may be filing a conditional no-exposure exclusion (EPA Form 3510-11).

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