Hazardous Waste Inspections

Purpose

This fact sheet answers general questions and provides basic information on hazardous waste inspection requirements. The information provided below addresses the requirements applicable only to large quantity generators (LQG) and small quantity generators (SQG). The hazardous waste inspection requirements are found in Section 22a-449(c)-102(a)(1) and (b)(2) of the Regulations of Connecticut State Agencies ("RCSA"), incorporating 40 CFR 262.34(a)(1), 265.15 , 265.174 , and 265.195 . 

This fact sheet is not intended to supersede the applicable regulations. You should refer to the appropriate statutes and regulations for specific regulatory language.  It is your responsibility to comply with all applicable laws and regulations.

In summary, a generator must:

1. inspect his facility for any deficiencies which may cause or lead to a release of hazardous waste or which may pose a threat to human health;

2. develop and follow a written schedule for inspecting all of the following:

   • monitoring equipment
   • safety and emergency equipment
   • security devices
   • operating and structural equipment
   • containers
   • container storage areas
   • containment systems
   • tanks and ancillary equipment
   • loading and unloading areas

   The written inspection schedule must:

   • be kept at the facility;
   • identify the types of problems to be looked for during an inspection; and
   • specify the frequency of inspection for all items on the schedule (at a minimum, containers, container storage areas, containment systems, and battery storage areas must be inspected weekly; tanks and loading/unloading areas subject to spills must be inspected daily; and safety and emergency equipment must be inspected at least monthly);

3. remedy any deterioration or malfunction of equipment or structures which the inspection reveals; and

4. record inspections in an inspection log or summary.

Discussion

It is highly recommended that the generator design an inspection log that specifically lists out all the items that must be checked during an inspection.  Doing this will ensure consistency of inspections, and help to ensure that no items or potential problems are overlooked during an inspection. For your assistance, a Sample Log format is available. You may use this Sample Log as a model in developing an inspection log specific to your facility.

Also available is a "List of Equipment, Structures, Areas to be Considered for Inclusion in an Inspection Schedule"; this may also be of use to you in developing your inspection schedule and log.

For further information please contact the DEEP’s toll-free Compliance Assistance (COMPASS) hotline at 1-888-424-4193, or send us an email.

Content Last Updated February 4, 2020