Summary
On 04/13/2017, the Waste Management and Radiation Control Board authorized the proposed changes to be published for public review and comment. Proposed changes to Section R315-301-2 reflect those corresponding revisions made by the final HWGIR to 40 CFR 258, as promulgated on 11/28/2016 (81 FR 85732). While many of the changes are required to retain primacy of the hazardous waste program, others provide added clarification or correct textual errors. Specifically, incorporating into Section R315-301-2 and into the other companion rules of Title R315, the revisions promulgated by EPA make significant improvements to the hazardous waste generation requirements by: 1) reorganizing and consolidating the generator requirements for added convenience and clarity, 2) providing added flexibility for generators to manage their hazardous waste in a more cost-effective and equally protective manner, and 3) revising the title of the lowest category of hazardous waste generation from "conditionally exempt small quantity generator" to "very small quantity generator". The change in the title of the lowest category of hazardous waste generation will result in less confusion on the part of hazardous waste generators regarding the essential requirements for managing hazardous waste produced in very small quantities. Changing the title of this generation category to "very small quantity generator" makes clear that limited rules apply to the generation and management of hazardous waste in very small quantities rather than potentially mislead by using the phrase "conditionally exempt", which may imply that no requirements or rules apply.