The RCRA regulations @ 40 CFR 265, Subpart C – Preparedness and Prevention apply to both Large Quantity Generators and Small Quantity Generators of hazardous waste [via §262.34(a)(4) & §262.34(d)(4), respectively]. A close review of the entire Subpart reveals little in the way of a requirement for documentation or recordkeeping. The one place where a document is mentioned, “…the operating record…” is in §265.37(b), more on that later. You may, however, wish to create documents and keep records of certain activities required by the Subpart in order to demonstrate compliance with the regulations and to fulfill the wishes of the USEPA. This will include Testing and Maintenance of Equipment (§265.33) and Arrangements With Local Authorities (§265.37). (more…)
In the previous article of this series I described the requirements of 40 CFR 265.35 – Required aisle space. That section of Part 265 indicated what was needed to provide the necessary aisle space within a facility. Though §265.36 exists, it is reserved, so there are no regulations to review currently.
The purpose of this article: identify and explain the requirements of 40 CFR 265.37 – Arrangements with local authorities for generators of hazardous waste under the emergency preparedness and prevention regulations of 40 CFR 265, subpart C. This article is the seventh – and last – in a series that looked closely at each section of 40 CFR 265, Subpart C and explained its requirements, how they apply to generators of hazardous waste, and what is required for compliance. Keep in mind that the regulations of your State may differ from these Federal regulations.
Hold on a minute! These regulations were revised and moved to a new location within Title 40 of the CFR by the Generator Improvements Rule. If your state has not yet adopted the Generator Improvements Rule, then this article is still applicable to you (but it won’t be for much longer). If your state has adopted and been authorized to enforce the Generator Improvements Rule, then these regulations no longer apply to you. Read: What is the status of the Generator Improvements Rule in my state?
To see an explanation of these regulations as revised by the Generator Improvements Rule you must refer to the following:
To see an explanation of the regulations prior to the revisions of the Generator Improvements Rule, please continue reading this article. (more…)
