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Waste Analysis Plans: What are Your Recordkeeping Requirements?

Waste Analysis Plans: What are Your Recordkeeping Requirements?

The regulations of the Resource Conservation and Recovery Act (RCRA) require both large and small quantity generators of hazardous waste (conditionally exempt small quantity generators are exempt) to develop and adhere to a Waste Analysis Plan if they are treating a hazardous waste without a permit for the purpose of meeting a treatment standard of the Land Disposal Restrictions (LDR).  The Plan must be maintained on-site for at least three years from the date the waste was last treated on-site in the manner prescribed by the Waste Analysis Plan.

Short and sweet.  In an earlier article I explained the somewhat more complicated requirement to retain records of notifications and certifications submitted to Treatment Storage and Disposal Facilities (TSDF’s) by generators.

Please don’t hesitate to contact me with any questions about the recordkeeping requirements of RCRA.