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…)