
Experience Everything Compliance Network Has to Offer
The Resource Conservation and Recovery Act (RCRA) regulations state that “waste analysis must be repeated as often as necessary to ensure that it is accurate and up to date.” At a minimum, the analysis must be repeated as follows:
Although there are no required time intervals for re-evaluating wastes, a facility must develop a schedule for re-evaluating the waste on a regular basis. A facility will need to make an individual assessment of how often the wastes analysis is necessary to ensure compliance with interim status or Part B permit operating conditions.
Fingerprint analysis is never a substitute for conducting a complete waste analysis and, therefore, may not be defensible if a waste is misidentified by the generator and passes the fingerprint test. Though the generator is responsible for properly identifying and classifying the waste, the TSDF will be held liable by enforcement authorities if it violates its permit conditions and any other applicable regulations. The decision to conduct abbreviated corroborative testing using fingerprint analysis on a few select parameters, or to conduct a complete analysis to verify the profile, is ultimately determined by the offsite facility with this in mind.