This section of the tour addresses the recordkeeping requirements of the Resource Conservation and Recovery Act (RCRA), which govern hazardous waste management. Although it is typically up to the central EH&S or Facilities Management offices of a college or university to maintain RCRA recordkeeping, other personnel at some schools may have some responsibility in this regard. You'll find a summary of relevant information in this section; for more in-depth descriptions of what is required, refer to the expanded content section.
Depending on how your college or university is classified as a generator of hazardous waste [Large Quantity Generators (LQGs), Small Quantity Generators (SQGs) or Conditionally Exempt Small Quantity Generators (CESQGs)], your facility may be required to have the following:
- EPA Identification Numbers (SQG and LQG facilities only)
- Manifests, including documentation that the waste shipment was received and treated or disposed of at the waste facility (SQG and LQG facilities only)
- Certification of Land Disposal Restriction (LDR) Notification with Manifests
- Source reduction strategy and the ability to sign a manifest stating such
- Biennial Reports (LQG facilities only)
- Copies of Waste Analysis to document proper hazardous waste identification
While there are additional requirements for record keeping for facilities that transfer, store and dispose of used oil, or used oil marketers, a typical campus power plant does not engage in these activities; hence, those requirements are not included in this tour. Depending on whether your campus power plant is a used oil generator or burner, the following recordkeeping requirements may be applicable:
- Records demonstrating that used oil does not contain hazardous waste (40 CFR 279.44; 279.63)
- Generator records of burner notification/certification (40 CFR 270.75)
- Used oil burner records (40 CFR 279.65; 279.66)
- Generator or burner records demonstrating that used oil is "on-specification" (40 CFR 279.72; 279.74)
Continue on through this section to learn more about the recordkeeping requirements of RCRA.