The Environmental Protection Agency (EPA) is planning to inspect numerous Kentucky facilities during the remainder of 2018 to evaluate compliance with Resource Conservation and Recovery Act (RCRA) requirements. During the Meet with the Regulators panel discussion at the 21st Annual Kentucky Environmental Permitting and Reporting Conference, Jon Maybriar (Director, Division of Waste Management, Kentucky Department for Environmental Protection) mentioned that EPA would be conducting RCRA inspections of various Kentucky facilities in the next few months. Specifically, Mr. Maybriar explained that EPA is planning to inspect two (2) hazardous waste treatment, storage, and disposal facilities (TSDF) and ten (10) large quantity generators (LQGs) of hazardous waste.

The likely targets for these inspections are facilities with previously identified RCRA compliance issues. Common compliance concerns include not obtaining the appropriate permits or registrations for hazardous waste management activities, leaving hazardous waste on-site past the regulatory timeframe, and maintaining insufficient training records for personnel involved in hazardous waste management. Furthermore, facilities should ensure that they are in compliance with the recent Hazardous Waste Generator Improvements Rule (finalized November 28, 2016).

If you have any questions about applicable requirements for your hazardous waste management activities, the recent generator improvements rule, or the RCRA program in general, please contact Christa Russell at (317) 451-8106.