RCRA Audits

Are you a large quantity generator of hazardous waste? If so, are you comfortable that your compliance program meets all the EPA requirements and can come through an inspection with flying colors? Are you sure? If not, PPM can help. We have hazardous waste experts who have assisted clients with EPA inspections and can audit your program. The audit will review the following required items:

 

 

  • Waste characterization records – all wastes generated at the site must be evaluated to determine if they are hazardous. The profiles established with disposers must be accurate.  EPA currently has a national enforcement initiative on air emissions from hazardous waste; your disposer cannot comply if they do not have correct information.
  • Hazardous Waste Manifests, Land Disposal Restriction Forms (LDR) and reporting – manifests and LDRs must be filled out correctly and records maintained at the site. The information in the manifests is used to complete the Annual (or biennial depending on your state) Generator Report.
  • Job Descriptions, Procedures and Training – RCRA requires detailed job descriptions for all personnel involved in waste management at the site. The descriptions must be specific for waste management.  Procedures must be available for waste management activities and you must be able to show that all employees have been trained on those procedures.  Additionally, the manifest signer and emergency responders must receive annual RCRA training.
  • Drum Management – RCRA has detailed requirements for the management of drums from the first generation of a waste to the disposal. This includes Satellite Accumulation Areas and the less than 90 day Container Storage Area.
  • Contingency Plan – your plan must be up to date and include information that will allow first responders to assist during an emergency. You must be able to show that the first responders and hospital have received copies of the plan and have the ability to respond if needed.

Now that you’ve read through the above list; are you REALLY sure your program is up to snuff? If not, let PPM conduct an audit of your facility and make sure you are ready for the next inspection. For more information, please call or e-mail your PPM contact or Karen Brignac in our Baton Rouge office.

Contributed by:

Karen Brignac

Environmental Compliance Manager, Baton Rouge, LA Office

(225) 293-7270

Karen.brignac@ppmco.com