We recently provided a list of the ten most common RCRA hazardous waste violations. More than half of the violations are cited at satellite accumulation areas (SAA’s) or locations where used oil and universal waste are accumulated. Both Large Quantity Generators (LQG’s) and Small Quantity Generators (SQG’s) of RCRA hazardous waste are required to conduct weekly inspections of their Centralized Accumulation Areas (CAA’s), but many facilities do not have a set schedule to inspect other waste accumulation areas. NEI has found that there are many benefits to conducting routine inspections at all waste accumulation areas.
Here are some of the benefits:
- Identify safety problems such as damaged or leaking containers,
- Provide a chance to assure containers comply with requirements for marking and closing
- Assure non-hazardous waste storage areas (roll-offs, bins, dumpsters) should be free from leaking or over-filling
- Assure outside drums are inverted or have drum covers to avoid accumulating rainwater or other liquids
- Identify new waste streams,
- Identify data on generation rates
- Assure good housekeeping
Inspections other than CAA’s do not necessarily need to be conducted weekly, especially when there are a large number of locations. Monthly or even quarterly inspections may be appropriate, but a set schedule is a must to help assure compliance, provide valuable operational feedback, and identify issues before they become major.
NEI has prepared a free weekly inspection checklist that includes CAA’s, SAA’s, universal waste areas, and used oil areas. NEI can also assist with all waste management issues, from transportation and disposal to onsite management including routine inspections. Contact us today for a free copy of the inspection checklist or with any questions.