Nelson Mullins Riley & Scarborough hosted a seminar on June 26 in regards to the U.S. Environmental Protection Agency's (EPA) publication of the Hazardous Waste Generator Improvements Rule in May. Representatives from the South Carolina Department of Health and Environmental Control, Novesis, Inc., and attorneys from Nelson Mullins presented on key aspects of how this rule affects South Carolina generators of hazardous waste. Columbia partner Bernie Hawkins organized and presented at the event.

Speakers presented on ways in which the EPA's requirements are more stringent than federal hazardous waste rules, including:

• Requiring Small Quantity Generators (SQGs), Large Quantity Generators (LQGs) and transfer facilities to better define the risks of hazardous wastes accumulated in tanks, containers, drip pads, and containment buildings, as well as when hazardous waste is accumulated in satellite accumulation areas;
• Requiring LQGs to notify EPA or their authorized state when they plan to close their facilities;
• Requiring SQGs to re-notify every four years;
• Requiring LQGs to submit a Biennial Report that identifies all of the hazardous wastes generated in the calendar year, not just for the months the facility was a LQG;
• Requiring LQGs updating their Contingency Plan to prepare a quick reference guide (QRG) for their Contingency Plan to assist responders in an emergency; and
• Requiring facilities that recycle hazardous waste, without storing the waste, to prepare and submit a Biennial Report.