12 common RCRA violations and how to avoid them

Following are the most cited hazardous waste violations by EPA and state agencies; and recommendations to minimize these violations.

1. Failure to mark containers with the “Hazardous Waste” label.

Have a steady supply of labels on hand.

2. Having more than 55 gallons of hazardous waste at the Satellite Accumulation location.

Provide periodic training to all operators.

3. Failure to mark the accumulation start date on the Hazardous Waste Label.

Provide periodic training to all operators.

4. Exceeding the storage time limit: 90 days for LQG (Large Quantity Generator) or 180 days for SQG (Small Quantity Generator)

Schedule waste pickup in advance.

5. Failure to keep hazardous waste containers closed at all times.

Provide periodic training to all operators.

6. Using improper or damaged containers to accumulate wastes.

Include in the inspection checklist.

7. Failure to update the RCRA Contingency Plan for LQG.

Assign a specific individual to update the plan.

8. Failure to provide adequate hazardous waste training.

New employees must receive initial training within 6 months and other employees must receive annual refresher training.

9. Failure to maintain training record.

Document and file sign-in sheets.

10. Failure to properly identify hazardous wastes.

Identify hazardous wastes using generator knowledge or laboratory testing.

11. Manifest records incomplete, erroneous or not readily accessible.

Keep all manifests at one location with signed return copy from the TSDF and the Land Disposal Restriction forms

If you have any questions contact Sam Joshi, P.E. at (215) 389-2811.