TOP TEN RCRA VIOLATIONS AND WHAT YOU CAN DO TO AVOID THEM

Despite the best efforts of environmental personnel, noncompliance with federal and/or state hazardous waste regulations periodically occurs. This paper identifies common RCRA violations that have resulted in notices of violations (NOVs). We present this information in the hopes that it will help people avoid RCRA compliance problems. Although we haven’t found any nationwide statistics on the most common RCRA violations, the Colorado Department of Public Health and the Environment provided us with a summary of its findings. The most common RCRA violations in Colorado, for large quantity generators of hazardous waste, from 2003 through 2012 are listed below. We believe that this list is representative of what happens in other states as well. Each RCRA violation and the underlying regulations will be discussed in detail. 

MOST COMMON RCRA VIOLATIONS BY LARGE QUANTITY GENERATORS

1. Training violations

2. Contingency plan violations

3. Labeling violations

4. Failure to make hazardous waste determinations

5. Open containers

6. Land disposal restrictions violations

7. Satellite accumulation violations

8. Improper tank management

9. Preparedness and prevention violations

10. Used oil violations