Hazardous Waste — Storage and Accumulation

• Select an area that is:
• Close to where the waste is generated and easily accessible
• Under the control of lab personnel
• Removed from normal laboratory activities
• Labeled with a “Danger – Haz Waste” sign.

Both conditionally-exempt small quantity generators (CE-SQG) and small quantity generators (SQG) have limits on how much hazardous waste they can store at their facility at the one time. If you go above these prescribed limits, you will need to comply with the requirements of the next higher generator category.

For non-acute hazardous waste, this limit is 1000 kg or 2,200 lbs for a CE-SQG and 6000 kg or 13,200 lbs for a SQG.

For acute hazardous waste, the limit is the same for both: 1 kg for an acute hazardous waste or 100 kg for spill residue from an acute hazardous waste. Thus, if your hospital accumulates just 1 kg of a p-listed waste on site, you will need to comply with all the RCRA Subtitle C requirements since you will be treated as a large quantity generator (LQG).

An LQG can store as much hazardous waste as it wants on site. There is no quantity limitation.

The duration of time that hazardous waste can be stored on-site at a facility varies depending on the facility's generator status:

• There are no time limits placed on a CE-SQG for the storage of hazardous waste.
• [Although there is a limit on how much hazardous waste a conditionally-exempt small quantity generator (CE-SQG) can accumulate on site.
• Small quantity generators (SQG) can only keep their waste on–site for 180 days or 270 days if their treatment, storage, and disposal facility is more than 270 miles away.
• Large quantity generators (LQG) can only store their waste for 90 days without obtaining a permit as a storage facility.

A satellite accumulation area is an area at or near the point of hazardous waste generation that is under the control of the operator of the process generating the waste. In this area, wastes are permitted to be temporarily stored for 3 days before being moved to the main hazardous waste storage area.

Up to 55 gallons of non-acute hazardous waste or one quart of acute hazardous waste can be collected in a Satellite Accumulation area at any one time. When these quantity limits are reached, the containers must be dated so that the generator can move the hazardous waste to the main hazardous waste storage area, or ship the waste off-site within 3 days of the limit being reached.

RCRA requires that SQGs and LQG generators of hazardous waste inspect containers in storage (not in satellite accumulation areas) at least weekly for signs of corrosion, leaks, or other deterioration; such inspections are required to be recorded in a log and must include the date and time of inspection, the name of the inspector, documented observations made, and the date and nature of any repairs or other remedial actions.

A facility must determine the amount of hazardous waste it generates within a calendar month by adding together the volumes of hazardous wastes and the volumes of acutely hazardous wastes generated by each department located on-site. Off-site facilities must separately determine the amount of hazardous waste they generate. The hazardous waste rules are site-specific therefore each hazardous waste generator, by site, must account for the hazardous wastes generated at their facility.

Legal requirements for shipping frequency depends on your generator status:

• Conditionally exempt: no limits or restrictions
• Small quantity: 180 days or less; 270 days or less when transporting more than two hundred miles
• Large quantity: 90 days or less

Failure to comply with these shipping times could result in an EPA fine being handed down to your place of business.