Hazardous Waste Update for Texas Facilities

Effective in February, the Texas Commission on Environmental Quality finally adopted EPA’s Generator Improvements rule for generators of hazardous waste under the Resource Conservation and Recovery Act.  The most consequential piece of the new rule is the “episodic generator” standard, which allows companies who carefully follow the rule an opportunity to retain the lighter regulatory burdens of small quantity generator status despite episodically generating large quantities of waste during events like turnarounds, maintenance, cleanouts, or spills.