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Are You Storing Your Hazardous Waste Too Long?

Kevin Webber - Sep 21, 2018 10:10:21 AM

Storage-of-Hazardous-Waste-DrumsThe Resource Conservation and Recovery Act (RCRA) regulations provide hazardous waste management standards for generators of hazardous waste. This framework ensures that hazardous waste is managed safely from “cradle-to-grave” – from the time it is created, while it is transported, treated, and stored, and until it is recycled or disposed. The degree of regulation that applies to each waste generator depends on the amount of waste produced. This “waste generator status” determines the length of time that hazardous waste can be stored at the point of generation, or on site. Since accumulating hazardous waste on site can pose a threat to human health and the environment, you may keep it only for a short time without a permit.

Storing Hazardous Waste On Site

As a hazardous waste generator, you are responsible for the safe management of your waste before you ship it for disposal or recycling. This includes safe storage, safe treatment, preventing accidents, and responding to any emergencies as mandated by federal and state regulations.

Very small quantity generators (VSQGs) generate 100 kilograms (220 pounds) or less per month of hazardous waste or one kilogram ( 2.2 pounds) or less per month of acutely hazardous waste. VSQs have no time limit for storing hazardous waste on site and may not accumulate more than 1,000 kilograms (2,200 pounds) of acute hazardous waste or more than 100 kilograms (220 pounds) of acute spill residue or soil.

Small quantity generators (SQGs) generate more than 100 kilograms (220 pounds) and less than 1,000 kilograms 2,200 pounds) of hazardous waste per month. SQGs may only keep their hazardous waste on site for 180 days. If the treatment, storage, and disposal facility is more than 270 miles away, they may store hazardous waste for 270 days. No more than 6,000 kilograms (13,220 pounds) may be accumulated on site.

Large quantity generators (LQGs) generate more than 1,000 kilograms (2,200 pounds) of hazardous waste or more than 1 kilogram (2.2 pounds) of acutely hazardous waste per month. LQGs are only allowed to store their hazardous waste for 90 days. If they store it longer, they are required to obtain a permit as a storage facility. There is no limit on the amount of hazardous waste LQGs can accumulate on-site without a permit.

It’s important to remember that the accumulation date is the date that the hazardous waste exceeds the allowed amount, not the date that waste was first put into the container. Using the incorrect date will decrease the amount of storage time, since the allowance begins at the accumulation start date that is marked on the container.

The most common hazardous waste container is the 55-gallon drum, which meets the EPA definition of a portable device. If hazardous waste is accumulated in tanks, they must have secondary containment, such as a liner, vault, or double-walled tank. The tanks should be designed to hold hazardous waste, properly labeled, and inspected daily. (Permanently-mounted tanks are not considered containers.)

Storage Guidelines

Proper handling and storage of hazardous waste containers will protect the health and safety of your employees and ensure compliance. Use these tips as a guideline to help keep your work environment safe.

  • Do not place incompatible waste streams in the same container
  • Use storage containers that are made of durable, corrosion-resistant materials
  • Manage containers (handling and storing) to avoid leaks or ruptures
  • Inspect your containers at least weekly
  • If a container leaks, then put the hazardous waste in another container or contain it in another way that complies with regulations
  • Make sure your storage area is clearly marked and inaccessible to unauthorized persons
  • Label containers properly
  • Keep containers closed, except when adding or removing hazardous waste
  • Monitor hazardous waste volume and limit the amount of hazardous waste on-site
  • Keep your hazardous waste contingency plan up-to-date
  • Remember that materials used to clean any leaks or spills also become hazardous waste

Finally, you should make sure that all employees are properly trained on proper handling and storage guidelines, including emergency response training.

Satellite Accumulation Areas

Satellite accumulation refers to small amounts of hazardous waste that are accumulated in satellite accumulation areas (SAAs) and are under the control of the operator of the process that generated the waste. SAAs provide a safer, more efficient way to handle hazardous waste for generators that accumulate waste in different areas of their facilities. The Alabama Department of Environmental Management (ADEM) provides an overview of the regulatory requirements governing the satellite accumulation of hazardous waste and offers guidelines for determining whether or not an area is acceptable.

When a generator has accumulated 55 gallons of hazardous waste and/or either one quart of liquid acute hazardous waste or one kilogram (two pounds) of solid acute hazardous waste in the SAA, the waste must then be moved to the 90- or 180-day central accumulation area within three days.

EPA recently made changes to RCRA generator rules, finalizing the Hazardous Waste Generator Improvements Rule. The rule includes SAA Provisions and clearly applies to both SQGs and LQGs since it’s titled, “Satellite accumulation area regulations for small and large quantity generators.” The rule also clarifies SAA provisions and distinguishes SAAs from the locations where generators accumulate hazardous waste for 90 or 180 days. A new term, “central accumulation area” (CAA), is used to refer to these locations. (The Rule’s effective date was May 30, 2017; however, the new standards are not in effect in a state until adopted. The EPA final deadline is July 2019.)

Storage Guidelines for SAAs

Hazardous waste generators who use SAAs must adhere to the following guidelines:

  • Keep containers are in good condition
  • Store the hazardous waste in compatible containers
  • Keep containers closed at all times, except to remove or add waste
  • Mark containers with the words “Hazardous Waste” and the contents
  • Make sure no more than the allowable amount of stored hazardous waste is in the SAA
  • Include SAAs in emergency and contingency planning

When the hazardous waste is beyond the allowable amount the date must be marked on that container and it must be removed within three days. When removed from the SAA, the hazardous waste may be placed in the less than 180 days (SQGs) or less than 90 days (LQGs) storage areas, shipped directly off-site, or sent to an on-site treatment, storage, or disposal facility. 

If your facility’s hazardous waste is not managed properly, it can pose a threat to human health and the environment. Compliance includes the proper storage of hazardous waste, which may only be kept on site for a short period of time without a permit. If you need help determining your generator status or implementing best management practices for hazardous waste, contact your trusted waste services provider.

Topics: Hazardous Waste

Kevin Webber

Kevin Webber

Kevin Webber is a partner at TriHaz Solutions and actively involved in the day-to-day business from a strategic and operational standpoint. He has a successful background in business/investment management and entrepreneurship, including recognition by Inc. Magazine’s 5000 list of fastest-growing private companies.

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