Waste Accumulation

A generator may accumulate hazardous waste on-site for 90 days or less, provided the following requirements are met:

Proper Storage. The waste must be properly stored in containers or tanks marked "Hazardous Waste" with the date accumulation began. Emergency Plan. A contingency plan and emergency procedures are developed. Generators must have a written emergency plan. Personnel Training. Facility personnel must be trained in the proper handling of hazardous waste.

The 90-day period allows more cost effective transportation. Instead of paying to haul several small shipments of waste, the generator can accumulate enough for one big shipment.

FIG. 11.10.1 DOT labels for hazardous materials packages. Source: Reprinted from U.S. Department of Transportation.
FIG. 11.10.2 DOT placards for hazardous substances. (Source: Reprinted from U.S. Department of Transportation.)

If hazardous waste is accumulated on-site for more than 90 days, the generator is considered an operator of a storage facility and becomes subject to Subtitle C requirements including permitting. Under temporary, unforeseen, or uncontrollable circumstances, the 90-day period may be extended for up to 30 days by the EPA Regional Administrator on a case-by-case basis.

Small quantity generators (SQGs), defined as those producing 100-1000 kg of hazardous waste per month, are accorded an exception to this 90-day accumulation period. The Hazardous and Solid Waste Amendments (HSWA) require, and the EPA developed, regulations allowing such generators to accumulate waste for 180 days, or 270 days if waste must be shipped over 200 miles, before SQGs are considered to be operating a storage facility.

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