Frequent Questions

How long can a generator accumulate hazardous waste on site without a permit or interim status?

The length of time a generator is allowed to accumulate hazardous waste on site will vary depending on the size of the generator. A large quantity generator (LQG) can accumulate hazardous waste on site for up to 90 days in specified units without obtaining a storage permit or interim status, provided the facility complies with Part 265 management standards for specific units (§262.34(a)). 

A small quantity generator (SQG) can accumulate up to 6,000 kg of hazardous waste for 180 days or less in tanks or containers if the facility complies with the modified standards in §262.34(d). A SQG can accumulate hazardous waste for up to 270 days if the treatment, storage, or disposal facility is 200 miles or more away (§262.34(e)). SQGs who accumulate waste in containment buildings or on drip pads are subject to the accumulation time limits for LQGs. Generators can receive a 30-day extension for accumulation of hazardous waste if uncontrollable and unforeseen circumstances cause them to accumulate waste on site for longer than the allowed time period. Such an extension may be granted by a Regional Administrator or authorized state on a case-by-case basis (§262.34(b) and (f)). 

Additional guidance on generator accumulation times is available in the following documents: 
Monthly Call Center Report Question; September 1994 (RCRA Online 13696) 
Memo, Porter to Evans; August 12, 1987 (RCRA Online 13013)
Monthly Call Center Report Question; November 1986 (RCRA Online 12775)
Memo, Straus to Katona; March 12, 1985 (RCRA Online 11062)

Note: On November 28, 2016, EPA published the Hazardous Waste Generator Improvements Final Rule, which makes several revisions to the hazardous waste generator regulations. These revisions may affect the information provided in this FAQ. The final rule and additional information, including a fact sheet, frequent questions, and a webinar recording and slides, are available at www.epa.gov/hwgenerators/final-rule-hazardous-waste-generator-improvements.

The Hazardous Waste Generator Improvements Final Rule is effective on May 30, 2017; however, implementation in a particular state depends on the state’s authorization status. A discussion of the effect that this final rule will have on state authorization is available on page 85801 of the rule. Information about how the rule will affect the requirements in this FAQ in a particular state is best obtained from the state hazardous waste program. A list of state hazardous waste programs is available at www.epa.gov/hwgenerators/links-hazardous-waste-programs-and-us-state-environmental-agencies.

Have more questions? Submit a request