Regulatory Updates

Attention Large Quantity Generators: Biennial Reports Due March 1, 2022

Is your facility a Large Quantity Generator (LQG)? A LQG facility generates at least 2,200 lbs of non-acute hazardous waste, or more than 2.2 lbs of acute hazardous waste in a month. If this status applies to your facility, then a Biennial Hazardous Waste Report must be filed with the Nevada Division of Environmental Protection by March 1, 2022. Who must file a Biennial Hazardous Waste Report? Any facility that generated at the LQG levels for at least one month in 2021 or is permitted …

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Final Rule for the Phasedown of Hydrofluorocarbons

Final Rule Notice Signed by US EPA Administrator September 23, 2021 What are hydrofluorocarbons? Hydrofluorocarbons (HFCs) were initially manufactured as replacements for ozone-depleting substances in refrigeration, air conditioning, aerosols, fire suppression, and foam blowing sectors. While helping protect the stratospheric ozone layer, HFCs are unfortunately also greenhouse gases that contribute to the warming climate. What is required? The American Innovation and Manufacturing Act (AIM) authorized EPA to address HFCs in three ways: (1) phasing down production and consumption, (2) maximizing reclamation …

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Toxic Substances Control Act (TSCA) Inventory

Did you know that the US Environmental Protection Agency (EPA) maintains a list of all “existing” chemicals called the Toxics Substances Control Act (TSCA) Inventory? This is a requirement of Section 8(b) of the Toxic Substances Control Act. Why is this important? If you plan to manufacture a chemical you must first check the TSCA Inventory to see if the chemical exists and if there are any importing or manufacturing restrictions. If the chemical does not exist, you must follow EPA’s review …

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Beware of Unsafe or Ineffective Antimicrobial Products

The US Environmental Protection Agency (EPA) recently announced violations by a Southern California company that was selling unregistered antimicrobial products that resulted in a $150,000 fine for the company. The company claimed their product could kill or repel microbes through a water filtration system that had not been tested or approved by the EPA. The danger to purchasers lies in the potential ineffectiveness of the product and/or harm to the user. Antimicrobial products that claim to kill or repel bacteria …

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Episodic Events in Nevada

Information Now Available on BEP’s Website What happens when a very small quantity generator (VSQG) or small quantity generator (SQG) goes over the limit for their generator status and generates more hazardous waste for just a month due to something like a planned annual clean-out or cleaning up an accidental spill? Does the business move up in generator status and need to follow all the rules that apply to the higher generator category? Not necessarily! The State of Nevada adopted the Subpart L – …

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Trend Analysis of Hazardous Waste Generation in Nevada

Large quantity generators (LQGs) of hazardous waste are required every other year to report to the State of Nevada and the US Environmental Protection Agency (EPA) on their generation activities. US EPA aggregates this information and allows website users to view trends of the data in several different ways. By looking at all Nevada LQGs included in the National Biennial Report (see above chart), we can see that hazardous waste generation by LQGs has fluctuated quite a bit between reporting periods but the overall trend …

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EPA Four-Part Webinar Series: How to Manage Asbestos in School Buildings

The US Environmental Protection Agency (EPA) is hosting a four-part webinar training series to help Asbestos Hazard Emergency Response Act (AHERA) designated persons understand their responsibilities to help local education agencies comply with federal asbestos in schools regulations.  The asbestos training will include: Part 1: Introduction to Asbestos, August 13, 2021 Part 2: Local Education Agency/Designated Person Requirements, August 16, 2021 Part 3: The AHERA Inspection and Surveillance, August 26, 2021 Part 4: AHERA Operation and Maintenance Program, September 2, 2021 For …

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Washoe County Health District Seeks Feedback on Permitting Program – Listening Sessions: August 17th and 19th

The Air Quality Management Division (AQMD) of the Washoe County Health District is reevaluating their permitting program and seeking public input. AQMD is considering revising the following aspects of the permitting program: Emission thresholds above which permitting through the AQMD would be required Annual actual emissions data reporting by the facility Regular, comprehensive review of AQMD operating permits every 5 years Who is potentially affected and should participate? Current AQMD operating permit holders Consultants with clients who have, or may …

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Updated COVID-19 Guidance for Nevada Businesses and New Healthcare Emergency Temporary Standard

On June 24, 2021, the Nevada Occupational Safety and Health Administration (Nevada OSHA) issued updated COVID-19 guidance for Nevada businesses which includes a new OSHA Healthcare COVID-19 Emergency Temporary Standard. Nevada OSHA adopted the Federal OSHA Emergency Temporary Standard (ETS) and it became effective in Nevada on July 1, 2021. Employers must comply with most provisions within 14 days and with the remaining provisions within 30 days. The ETS is aimed at protecting workers facing the highest coronavirus hazards such …

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1-Bromopropane (1-BP) To Be Added To Hazardous Air Pollutants List: EPA is Seeking Input Before Setting Standards

On June 11, 2021, the US Environmental Protection Agency (EPA) issued an Advanced Notice of Proposed Rulemaking as a next step before adding of 1-Bromopropane (1-BP) to the Clean Act Act’s list of Hazardous Air Pollutants (HAP). EPA intends to add 1-BP to the HAP list by the end of 2021. More information is available in the US EPA fact sheet on this proposal. 1-BP is commonly used in degreasing operations for cleaning metals, plastics and electronic, and optical components; …

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