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Region 1: EPA New England

Common Violations: RCRA

Common RCRA (Resource Conservation Recovery Act) Violations and CFR (Code of Federal Regulations) Cites

This page provides useful information to help colleges and universities comply with some basic environmental regulatory requirements. This page, however, does not list all the applicable regulatory requirements that might apply to your campus. Please be sure to comply with all applicable requirements.
  • Failure to clearly label and mark satellite accumulation containers with the words "hazardous waste" and other words that identify the contents of the containers, such as the chemical name [40 CFR 262.34(a)(3)]
  • Failure to clearly mark and date the period of accumulation for each accumulation container. [40 CFR 262.34(a)(2)]
  • Failure to provide and document initial hazardous waste training. [40 CFR 265.16]
  • Failure to separate or otherwise protect containers of hazardous waste from other containers storing incompatible materials or wastes [40 CFR 265.177(c)]
  • Failure to make hazardous waste determinations. [40 CFR 262.11, 40 CFR 268.7(a), 40 CFR 268.9(a)
  • Failure to accumulate hazardous waste in a closed container except when adding or removing waste. [40 CFR 265.173(a)]
  • Failure to obtain a permit when storing hazardous waste for greater than 90 days. [40 CFR 262.34(a), 270.10]
  • Failure to inspect hazardous waste containers, specifically failure to inspect on a weekly basis. [40 CFR 265.15(a), 40 CFR 265.174]
  • Failure to have an adequate Contingency Plan for new operations. [40 CFR 265.54(c)]
  • Failure to provide secondary containment around hazardous waste container storage areas in an area with a functional floor drain. [40 CFR 264.175 and 264.193]
  • Failure to maintain and operate the facility in a manner to minimize the possibility any planned or unplanned release of hazardous constituents to air, soil, or surface water which could threaten human health or the environment. [40 CFR 265.31]
  • Failure to maintain adequate aisle space to allow the unobstructed movement of personnel or emergency equipment in the container storage areas. [40 CFR 265.35]

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