Frequent Questions

If a generator accumulates more than 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) at an SAA, when should the generator date the container(s)? When 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) is exceeded, or w

When 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) is exceeded in an SAA, the generator needs to date the container, so that the generator can move the excess to the 90-day or 180-day area within three days (262.34(c)(2)). Then when 3 days have passed, or when the container is moved to the central accumulation area, the generator needs to date the container again, so that it can be moved off-site within 90 or 180 days (262.34(a)(2) and 262.34(d)(4)), respectively. (Of course, the container does not need to be dated after it is removed from the SAA if the excess waste is moved directly to a permitted or interim status unit.) This means that an LQG has up to 93 days and a SQG has up to 183 days for on-site accumulation time once 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) has been exceeded at the SAA - up to three days in the SAA, followed by up to 90 or 180 days in the central accumulation area.

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.

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