- Failure to keep containers closed. Inspectors often observe hazardous waste drums that have been left open during the entire work shift, or drums with open funnels. See this Environmental Daily Advisor post for more information on closed containers.
- Failure to mark the accumulation start date on the container. Generators accumulating hazardous waste on-site without a permit must be sure to clearly mark on each container the date on which each period of accumulation begins.
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- Failure to document inspections. Generators as well as TSDF owners and operators are required to inspect, at least weekly, areas where containers are stored. These facilities often cannot produce documentation that such inspections have occurred. Inspectors may ask to review up to 3 years of inspection records.
- Containers missing the words "Hazardous Waste" or other required information on the container. Some states also require additional information on the container, such as the hazardous waste number or chemical name that identifies the container’s contents.
- Using improper containers, or containers in poor condition. Containers must be in good condition and lined with material that will not react with the hazardous waste being stored therein.
- Failing to comply with the special satellite accumulation area rules. Generators accumulating hazardous waste on-site without a permit in accordance with the accumulation time rules may accumulate up to 55 gal of hazardous waste or one quart of acutely hazardous waste in their satellite accumulation area, provided specific requirements are met. Violations include an absence of operator control of the process generating the waste, failure to list the date the satellite container reaches its accumulation limit (55 gal for hazardous waste or 1 quart of acutely hazardous waste), and failure to remove the waste from the satellite area within 3 days of exceeding the quantity limitations.
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These violations can result in the state EPA assessing civil and/or criminal penalties, and earn a generator or TSDF owner or operator the dubious distinction of being known as a facility that will need to be carefully examined during future visits by the agency’s inspectors. A history of noncompliance can affect the severity of future penalties too. Handlers should be aware that many inspectors will make the hazardous waste accumulation or storage area their first stop in your facility inspection.
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