Recordkeeping

The owners and operators of facilities that have a conditional exemption for LLMW must follow strict recordkeeping guidelines. Owners and operators are required to keep the following two types of records:

• Records required by the facility's NRC license or NRC Agreement State license
• Records required by the RCRA regulations (refer to 40 CFR 266.250)

The records required by the RCRA regulations include the following:

• Initial notification records, return receipts, failure reports made to the EPA director, and all records supporting any instances of reclaiming an exemption
• Records of the facility's annual inventories and quarterly inspections of the LLMW
• Certification that the facility personnel who manage the stored mixed waste are trained in the safe management of LLMW (this training must include chemical waste management and hazardous materials incident response)
• The facility's emergency plan in the event of an incident involving the exempted waste

The facility must maintain the records required by RCRA for as long as the conditional exemption is being claimed by a facility, and for three years following closure of the claim. The NRC also imposes requirements for record retention. The facility must adhere to whichever retention requirement lasts longer.

To learn more about RCRA visit our RCRA Hazardous Waste Safety Online Training web page.