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What is an EPA ID Number and How Do I Get One?

According to the EPA, “The Resource Conservation and Recovery Act (RCRA) requires individuals who generate or transport hazardous waste, or who operate a facility for recycling, treating, storing, or disposing (TSD) of hazardous waste, to notify EPA or their authorized State waste management agency of their regulated waste activities and obtain a US EPA Identification (ID) Number (also known as a RCRA ID Number). Handlers of some Universal Waste, Used Oil, and Boilers/Industrial Furnace may require a US EPA ID Number, too. If you are regulated and do not comply with the RCRA notification requirements, you may be subject to civil and criminal penalties.” [1]

EPA ID numbers are specific to individual sites (except when they are issued to transporters) and permanent. There is an exception to the permanency in the case of provisional numbers which last for just 90 days and can be used in case of emergency or temporary one time clean-ups. After the 90 days they are no longer valid and are deleted from the national registry.

What if our site moves?

EPA ID numbers do not move in the event that the owner/operator should relocate (unless the owner or operator is a transporter). EPA ID numbers are so important because they help the EPA to track wastes through the entire cradle-to-grave cycle which follows waste from the point of generation to the point of disposal. So, “Once a US EPA ID number is assigned to a specific physical location, it belongs solely to that location and will belong to any owners/operators at that location.” [2]

Should a generator decide to move the location of their operations (even if it is just to a different place in the same town) they would need to inactivate their old ID number for the former location and request a new ID number for their new location. The EPA does note that, “If at the new location, a RCRA hazardous waste ID number had previously been issued to the former owner/operator, the number for that physical location will then be assigned to the new requester.” If not you would simply need to fill out a form as normal.

What forms do we have to fill out?

The EPA provides the Notification of Regulated Waste Activity (EPA Form 8700-12) and associated instructions in order to help these generators, transporters, and individuals determine whether or not they need to notify the EPA or authorized state of their regulated waste activities. If they do, they must submit the RCRA Subtitle C Site Identification (Site ID) Form including the following:

  • “Initial Notification of Regulated Waste Activity
  • Subsequent Notification of Regulated Waste Activity
  • First RCRA Hazardous Waste Part A Permit Application
  • Revised RCRA Hazardous Waste Part A Permit Application
  • Hazardous Waste Report
  • Notification for eligible academic entities opting into or withdrawing from managing laboratory hazardous wastes pursuant to 40 CFR Part 262 Subpart K (if in an eligible State)
  • Notification for facilities managing hazardous secondary material pursuant to 40 CFR 260.42 (if in an eligible State)” [3]

Remember, some states have additional or different requirements than the Federal requirements. It is always best to check with your state government in addition to the EPA.

“In order to determine if your location already has been assigned a US EPA Hazardous Waste ID number, look in EPA’s Envirofacts Warehouse database by the physical location first (be sure to put in the State you want to search within).” [4]

As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Satellite Accumulation Areas vs. 90-Days: Part 2

In the part one post on this subject we mentioned that the allure posed by less stringent regulations in Satellite Accumulation Areas (SAAs) can be problematic for generators who might misclassify their accumulation areas as SAAs ­instead of the more regulated 90-day areas. Since this is a violation of EPA regulations it is imperative that generators know not only the difference between the two storage area types but also what must be done at each.

What is the difference between an SAA and a 90-Day?

A 90-day storage area is different from an SAA because it is an area where wastes can be stored for less than 90 days without a permit. An SAA has no strict time limit associated with it, just a quantity limit. Additionally, the time clock for wastes stored in an SAA does not start until the waste is moved to the waste storage area, in this case a 90-day. So the two differences between SAAs and 90-days is the amount of waste that can be stored and the length of time it can be stored before needing to be treated or shipped offsite for management.

How should containers be managed in a 90-Day?

As stated by the EPA, “The moment that waste is placed in the container, containers holding hazardous waste must be managed to prevent spills of hazardous waste.” The best way to prevent spills is by making sure that your containers are in good condition before, during, and after waste is placed in them. Containers in good condition should be free of dents and corrosion (which weaken the container), free of leaks, structurally sound, and devoid of bulges.

According to §265.171, “If a container holding hazardous waste is not in good condition, or if it begins to leak, the owner or operator must transfer the hazardous waste from this container to a container that is in good condition, or manage the waste in some other way that complies with the requirements of this part.”

What if the containers in the 90-Day are already filled?

Companies that generate and store hazardous waste should have written procedures in place detailing how containers should be managed. Additionally, all employees should be trained in the procedures. At minimum the EPA requires that generators:

  • Keep containers closed at all times, except when…adding or removing waste from the container;
  • Be careful when…handling the containers. [Generators] must open, handle, and store containers to prevent ruptures or leaks. For example, use drum grapplers to lift and move drums — don’t hand-roll the drums from one area to another; and
  • [Take note] if the container begins to leak, or you notice dents or bulges, [if this happens] transfer the waste to another container.

In addition to all of this, generators must also prevent reactions of ignitable and/or incompatible wastes. We will cover this topic in an upcoming blog post.

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Satellite Accumulation Areas vs. 90-Days: Part 1

In Tuesday’s post we mentioned that the labeling and marking rules can be different for containers in Satellite Accumulation Areas (SAAs). We will cover that (as well as some other specifics of SAAs) in today’s post. It’s important to cover the guidelines for SAAs prior to covering those for 90-days so generators can make sure they are managing their accumulation areas properly.

According to 262.34(c)(1), “a generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in 261.33(e) in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or interim status and without complying with paragraph (a) of this section provided he:

  • Complies with 265.171, 265.172, and 265.173(a) of this chapter; and
  • Marks his containers either with the words “Hazardous Waste” or with other words that identify the contents of the containers.”

So in laymen’s terms, an SAA can be utilized to store up to 55 gallons of hazardous waste (or up to 1 quart of acutely hazardous waste) for an unlimited time and with only some of the requirements needed for 90-day areas. In order to store waste in an SAA the EPA requires that you:

  • Keep your containers in good condition,
  • Ensure that the waste being stored is compatible with the container type,
  • Keep containers closed unless you are adding or removing waste,
  • Make sure you handle containers in such a way that you are preventing leaks or spills, and
  • Mark containers with the words “Hazardous Waste,” or other identification of contents.

The less stringent and numerous regulations for SAAs attract a lot of generators which can cause problems. Most often, these problems arise from generators storing in waste they have designated as an SAA but which is not actually applicable to that designation. For an accumulation area to be an SAA very specific requirements must be met. Firstly, only waste which is generated at the SAA can be stored there. An SAA cannot be used as “temporary staging areas for wastes collected from other areas.” Secondly, an SAA must be located at or near the point of generation. So if waste is generated in a lab the containers should also be located in the lab.

If a generator accumulates more than the limit of 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) at an SAA the EPA requires that they:

  • “Mark the container holding the excess accumulation of hazardous waste with the date the excess amount began accumulating,” and,
  • “Move the container holding the excess accumulation to a container storage area within 3 days.”

And remember, if a generator incorrectly manages a 90-day storage area as an SAA they will be in violation of EPA regulations. For more information about managing waste in 90-day areas keep reading our blog!

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Tips for Waste Container Marking and Labeling

If you are a hazardous waste generator than you know that once you’ve placed any hazardous waste into a container it becomes necessary to properly mark and label that container. According to the EPA, a hazardous waste generator is only allowed to accumulate or store waste on-site for less than 90 days if they do not have a permit. This 90-day limit begins the moment the container becomes full. There are a couple of exceptions to the 90-day rule.

For example, if you are a small quantity generator (SQG) and you are shipping your wastes more than 200 miles away you can store waste for up to 270 days. If you’re shipping less than 200 miles away, you only have 180 days. Differing time frames aside, the important thing is that you must be able to prove to an inspector that your waste is within its storage time window.

The way you can ensure your ability to prove so is by properly dating your container. §262.34(a)(2) states that “the date upon which each period of accumulation began [must be] clearly marked and visible for inspection on each container.” Additionally, you must clearly mark and identify the container with the words “Hazardous Waste.” The one exception is for hazardous waste containers in a satellite accumulation area which we will cover in a later post.

The Ohio EPA provides the following advice for keeping your hazardous waste labels in good shape, “Pay attention to container labels. Make sure they are filled out and in good condition. If a label gets torn or becomes difficult to read, replace it. If you store hazardous waste containers outside, check labels during your inspections to ensure they haven’t fallen off or become damaged.”

In addition to the EPA regulated markings it is important to follow any state regulations as well as making sure to comply with any and all labeling requirements set forth by the Department of Transportation (DOT). DOT labels must be filled out before the container can be shipped off site. This label will exactly identify the waste including its name, characteristics, and handling requirements.

It’s not just having the labels on the container that is important though. You must also think about where on the container you place them. Proper placement is important so that labels are not missed by handlers. Labels must appear in their entirety and should not be placed near any other markings on the surface. They should always be visible (so never place them on the bottom of a container).

“If the waste has multiple hazards associated with it multiple labels should be displayed next to each other. The DOT recommends a six- inch space (15 cm) between labels. The label designating the primary hazard should be above and to the left of the label designating the subsidiary hazard.” [1]

Finally, the EPA provides the following tips for marking/labeling your containers:

  • Have all personnel use the same method (e.g., handwritten, prepared labels) to label containers. Make sure all handlers know what the markings mean.
  • Besides the start date and the words “Hazardous Waste,” include information about contents (e.g., toxic, reactive, incompatible).
  • Apply DOT labels to the container when waste is first placed in the container. The label will be in place for shipment and provides information about the waste to drum handlers.
  • Before reusing containers, make sure all old markings/labels are washed off or blacked out.

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

How do I Choose the Right Waste Container?

On Tuesday we wrote about the importance of waste characterization when it comes to containerized waste. In that post we touched briefly on the need for using an appropriate type of container to store your waste; today we’re going to look at that a little closer.

So, once a generator has their waste properly characterized they will know if it is incompatible or reactive with other waste types or even different types of containers. Once they know this, they can move on to choosing the best container in which to store their waste.

The first thing to consider when choosing your contain type is the quantity of waste you will be generating. If you know you will only be generating 20 to 25 gallons of waste than a 30-gallon drum would be more practical than a 55-gallon drum. Alternately, if you are storing contaminated gloves, coveralls, or other personal protective equipment (PPE) a 55-gallon drum would probably work best. Once you’ve decided on your container size you can move on to choosing the material your container will be made out of.

We’ve mentioned before that some wastes can actually have a negative reaction with the container they are placed in. For example, a highly corrosive waste can react with a steel drum and lead it to erode. This could make the drum leak and allow for a spill of the waste. In order to avoid this, corrosive wastes should be stored in plastic drums or plastic lined steel drums. This will prevent the waste from coming into contact with an incompatible material. As the EPA points out, “to prevent drum failure, carefully “match” the right waste with the right container.” If you are unsure if your waste and drum are compatible consult a corrosion resistance guide.

Now you’re almost in the clear but there is one more thing to consider when choosing your container. What do you do if your container once held an incompatible waste? According to §265.177(b) you are allowed to put wastes into unwashed containers that once held an incompatible waste but only if you meet the following specified conditions:

“…the mixture or commingling of incompatible wastes, or incompatible wastes and materials, must be conducted so that it does not:

  1. Generate extreme heat or pressure, fire or explosion, or violent reaction;
  2. Produce uncontrolled toxic mists, fumes, dusts, or gases in sufficient quantities to threaten human health;
  3. Produce uncontrolled flammable fumes or gases in sufficient quantities to pose a risk of fire or explosions;
  4. Damage the structural integrity of the device or facility containing the waste; or
  5. Through other like means threaten human health or the environment.”

If you cannot meet these conditions then you must make sure that the waste or material that was previously held in your container is compatible with the new waste you will be placing into it. Finally, the EPA provides the following tips for safely putting your wastes into containers:

  1. “Make sure you know which wastes are reactive and/or incompatible. Keep these wastes away from each other. Put them in separate containers.
  2. Make sure the container cannot be harmed by the waste.
  3. If you rinse out containers onsite, be aware that rinse water generated from drum washing must be contained and characterized prior to disposal.
  4. If you frequently reuse containers, consider “assigning” wastes to certain containers. This will allow you to reuse the container without washing.
  5. Use a funnel to prevent spills, and do not use the same funnel for all wastes.
  6. Certain chemicals may need room for expansion, or they may require zero headspace depending on the characteristics of the waste and storage conditions (e.g., temperature fluctuations).”

Quoted and cited information for this blog post was gathered from the EPA Handbook for Hazardous Waste Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations

Container Management & Hazardous Waste Characterization

Before you can put a waste in a container you have to ensure that you will be managing it safely. To do this, you need to know exactly what the waste you’re dealing with is comprised of/what it can do. You need to know answers to questions like, “is it toxic?” You need to determine whether or not waste handlers will need special personal protective equipment (PPE) to handle it. You will need to identify what, if any, other chemical it might react with to avoid potential explosions or fires. And especially before putting your waste in a container you need to be sure it is not corrosive in order to prevent it eating through the container you choose. All this said, it is vital that a waste be characterized before it is placed into a container.

In their manual on container management, the EPA states that there are two ways a generator can go about characterizing a waste:

  1. Generators can sample the waste and analyze it to identify any potential issues, or
  2. Generators can, “identify the waste based on process knowledge,” meaning they could look into the constituents in the process that created the waste and use the knowledge of any characteristics those constituents have to determine whether it is likely that the produced waste also has that or those characteristics.

Additionally, they provide some best practice tips for waste characterization including, looking at a material safety data sheet (MSDS) if one is available. When looking at the MSDS pay special attention to areas marked, “physical property, reactivity, fire and explosion hazard, and special protection information.”

Another best practice is related to the second way to characterize a waste. “If a product being used in a process meets one or more hazardous characteristics, the waste generated may exhibit some of the same characteristics.”

Finally, “be aware of any changes in a production process which could alter the composition of the waste generated.” But what do you do if the waste you need to characterize is already in a container? The EPA provides some tips for that too:

  1. “Pay attention to marking/labeling which may indicate that a material is flammable, corrosive, etc.
  2. Always check with your supervisor before handling unknown drums, or drums which you feel are labeled or marked incorrectly.
  3. Look at a material safety data sheet (MSDS) if it is available.
  4. If waste is in a plastic drum it is a good indication the waste may be corrosive.”

It is also important to remember that wastes which exhibit signs of corrosivity, combustibility, flammability, oxidization, poison, reactivity, or toxicity may require specialized equipment to manage. Once you’ve got your waste characterized, it’s time to put it into the proper container.

During the characterization of your waste you should have learned if it was reactive or incompatible with another waste. This is a vital step because before you can put your waste into a container you must identify and segregate and incompatible or reactive wastes in order to prevent fires or explosions. According to the EPA, “The regulations state that incompatible wastes cannot be placed in the same container, unless you comply with other requirements found in §265.17(b). This prevents the wastes from reacting with each other (e.g., exploding, catching on fire).”

There can be exceptions if you’re putting incompatible wastes in the same containers while being pursuant to the conditions found at §265.17(b). To do this you must:

  1. “Keep the waste from becoming too hot (this will prevent fire or explosions);
  2. Keep the wastes from producing toxic and/or flammable mists, gases, fumes, or dust (this will prevent workers from being exposed to the waste and will prevent fire or explosions);
  3. Make sure that mixing the incompatible wastes won’t damage the container – the container won’t rupture or bulge; and
  4. Demonstrate that mixing the wastes won’t threaten workers, or the environment in any way.”

And remember that you should always get the okay from your supervisor or environmental coordinator before you mix any materials or wastes.

Quoted and cited information for this blog post was gathered from the EPA Handbook for Hazardous Waste Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Eight Tips for LDR Compliance

Today’s post is going to be a quick one. A few posts ago we provided some basics of LDR (Land Disposal Restrictions) which we hope you found helpful!  But if you’re still looking for more information you are in the right place. Today we’re going to give you eight simple actions to take to help make sure you are compliant with LDR rules. So without further ado…

1. Determine, at the point of generation, all applicable codes, the category (WW or non-WW), and the subcategory (if any) for each restricted waste.

2. Determine which treatment standard(s) apply to each restricted waste.

3. Identify underlying hazardous constituents (where required).

4. Determine, through specified analytical techniques or knowledge of the waste, whether the treatment standard has been achieved.

5. Comply with time limitations.

6. Comply with prohibitions on evaporation and dilution.

7. Prepare notifications and/or certifications required for onsite or offsite waste management.

8. Comply with recordkeeping requirements to maintain all LDR documentation.

While this is in no way an all-inclusive list of instructions, following these suggestions will put you on a good start to maintaining Land Disposal Restriction compliance. Just make sure to always check with local and state rules as well as 40 CFR for the most up-to-date information.

Can you Treat Waste Without a Permit?

A recent article posted by the Environmental Resource Center raised an interesting question; can you treat waste without a permit? Surprisingly enough, in some cases, you can. 40 CFR 270.1(c) states that hazardous wastes listed in 40 CFR 261 require a permit for treatment, storage, and disposal. In 40 CFR 270.1(c)(2), however, you can find a list of exclusions from the requirement to have a RCRA permit. These exclusions include the following generator types and instances:

  • “Generators who accumulate hazardous waste on-site for less than the time periods provided in 40 CFR 262.34.
  • Farmers who dispose of hazardous waste pesticides from their own use as provided in §262.70 of this chapter;
  • Persons who own or operate facilities solely for the treatment, storage or disposal of hazardous waste excluded from regulations under this part by 40 CFR 261.4 or 261.5 (small generator exemption).
  • Owners or operators of totally enclosed treatment facilities as defined in 40 CFR 260.10.
  • Owners and operators of elementary neutralization units or wastewater treatment units as defined in 40 CFR 260.10.
  • Transporters storing manifested shipments of hazardous waste in containers meeting the requirements of 40 CFR 262.30 at a transfer facility for a period of ten days or less.
  • Persons adding absorbent material to waste in a container…and persons adding waste to absorbent material in a container, provided that these actions occur at the time waste is first placed in the container; and
  • Universal waste handlers and universal waste transporters managing batteries, pesticides, mercury-containing equipment, and/or lamps. “ [1]

According to the ERC, “40 CFR 262.34 requirements include the 90-day and 180-day accumulation regulations for large quantity generators (LQGs) and small quantity generators (SQGs), meaning that as long as a generator complies with the requirements of 40 CFR 262.34, they do not need a RCRA permit.”

The Environmental Resource Center also points out that, “most of the treatment technologies identified at 40 CFR 268.42 do not require a permit—with the technologies that do require a RCRA permit usually involving combustion.” Additionally, they provide a list of some of the treatment types that generators in compliance with 40 CFR 262.34 are able to perform without a permit. These include, among others, the following:

  • DEACT – “Deactivation to remove the hazardous characteristics of a waste due to its ignitability, corrosivity, and/or reactivity.”
  • MACRO – “Macroencapsulation with surface coating materials such as polymeric organics (e.g., resins and plastics) or with a jacket of inert inorganic materials to substantially reduce surface exposure to potential leaching media. Macroencapsulation specifically does not include any material that would be classified as a tank or container according to 40 CFR 260.10.”
  • NEUTR – “Neutralization with the following reagents (or waste reagents) or combinations of reagents: (1) Acids; (2) bases; or (3) water (including wastewaters) resulting in a pH greater than 2 but less than 12.5 as measured in the aqueous residuals.”
  • POLYM – “Formation of complex high-molecular weight solids through polymerization of monomers in high-TOC D001 non-wastewaters which are chemical components in the manufacture of plastics.”
  • STABL – “Stabilization with the following reagents (or waste reagents) or combinations of reagents: (1) Portland cement; or (2) lime/pozzolans (e.g., fly ash and cement kiln dust)—this does not preclude the addition of reagents (e.g., iron salts, silicates, and clays) designed to enhance the set/cure time and/or compressive strength, or to overall reduce the leachability of the metal or inorganic.” [2]

It is important to note that the exemptions listed apply only in states that allow for them. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Satellite Accumulation Area FAQ’s: Part 4

This is our final post in the SAA FAQ’s series! Remember, original and complete information from this post can be found in the EPA document on closed containers here. If you would like us to compile an eBook of these questions let us know in the comments section!

Question: Do generators have to include the hazardous waste in SAAs in the monthly quantities for determining generator status (i.e., SQG or LQG)?

Answer: Yes. Generators must include all the hazardous waste in the various SAAs in their monthly quantities for determining generator status. Sections 261.5(c) and (d) identify hazardous wastes that do not have to be counted when determining generator status. Hazardous waste stored in SAAs is not on this list; therefore, hazardous waste in SAAs must be included in the generator’s monthly quantity determination.

Question: When a facility has equipment that discharges hazardous wastes to attached containers, do the containers that collect such wastes have to be in compliance with the SAA regulations?

Answer: Yes. Even if the discharging unit is not regulated under RCRA, the attached containers that collect hazardous wastes from such equipment must be in compliance with the SAA regulations, if those containers collect wastes that are listed or characteristic hazardous wastes. Waste containers in SAAs must be:

  • In good condition (265.171),
  • Compatible with their contents (265.172),
  • Labeled with “words that identify the contents of the container” or the words “hazardous waste” (262.34(c)(l)( ii)).

In addition, the containers in SAAs must be closed, except when adding or removing hazardous waste (265.173(a)). Generators would not be required to keep such containers closed while hazardous waste is being added to the container; but generators would need to keep them closed when the hazardous waste is not being discharged to the attached container.

The container(s) attached to such equipment is a point of generation. It is possible for there to be multiple pieces of equipment within one SAA, and thus multiple points of generation within a single SAA, provided all the pieces of equipment are “at or near” each other and “under the control of the operator of the process generating the waste.” Under this scenario, the total amount of hazardous waste in the SAA would be limited to 55 gallons (or 1 quart of acute hazardous waste) and a generator would be allowed to consolidate like hazardous wastes: from multiple discharging units.

Question: If a facility has very small containers (e.g., vials or tubes) of hazardous waste that are too small to label with the words “hazardous waste” or “other words that identify the contents of the container”, how should the containers be labeled?

Answer: Generally, we would expect the small containers to be placed in properly labeled larger containers, which would have the added benefit of secondary containment should the small containers break. However, other approaches that would achieve the same result also would be acceptable.

Information for this blog post was gathered from the EPA Memorandum on Closed Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.    

Satellite Accumulation Area FAQ’s Part 3

Today we will be continuing with part three of our series of the top questions EPA has received about satellite accumulation areas. Original and complete information from this post can be found in the EPA document on closed containers here.

Question: The preamble to the final rule that added 262.34(c), states, “…only one waste will normally be accumulated at each satellite area.” Can there be more than one hazardous waste at an SAA? Can there be more than one container at an SAA?

Answer: Yes. It’s permissible to have more than one hazardous waste in an SAA. Likewise, it’s permissible to have more than one container of hazardous waste in an SAA. The regulations do not limit the number of hazardous wastes or the number of containers that can be placed in an SAA. The regulations limit only the total volume of hazardous waste at a single SAA to 55 gallons (or 1 quart of acute hazardous waste). If there are multiple containers of hazardous waste in an SAA, each container must be labeled in accordance with 262.34{c)(I)(ii). Because the Agency did not anticipate that generators would accumulate multiple hazardous wastes/containers in an SAA, a cross-reference to the requirements for the safe storage of incompatible wastes was not included as part of the container management standards for SAAs. Nevertheless, good management practices clearly dictate that incompatible wastes should be stored separately. Furthermore, in the event that any wastes, including incompatible wastes, are stored in such a way that they may pose an imminent and substantial threat to health or the environment, §7003 of RCRA allows the Agency to take enforcement action to eliminate the threat.

Question: Can a facility have multiple SAAs?

Answer: Yes. The regulations do not limit the total number of SAAs at a generator’s facility. Likewise, the regulations do not limit the total amount of hazardous waste that can be accumulated at various SAAs across a facility. The regulations limit only the volume of hazardous waste that can be accumulated at a single SAA to 55 gallons (or I quart of acute hazardous waste). It’s not possible in a memo for the Agency to delineate for all situations what constitutes a single SAA versus what constitutes separate SAAs. The regulations state that a generator may accumulate hazardous waste “in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste.” For additional guidance about the Agency’s intent, refer to the preamble to the final rule for SAAs, which states, “Certainly…a row of full 55 gallon drums spaced 5 feet apart along the factory wall,” is not a row of distinct SAAs, but is one SAA.

Question:  If a facility has multiple SAAs, can hazardous waste be moved from one SAA to another?

Answer: No. Generators may not move hazardous wastes between SAAs. Once a hazardous waste leaves an SAA, it must be destined for a central accumulation area that is regulated under 262.34(a) or (d) or for final   treatment or disposal at a facility with a permit or interim status. However, a single SAA may have multiple points of generation. Movement or consolidation of hazardous waste within an SAA is permissible, as long as it remains “at or near” the “point of generation” and “under the control of the operator of the process generating the waste.”

In addition, a generator may have more than one 90-day or 180-day central accumulation area, and the regulations do not prohibit the movement of hazardous waste from one fully regulated central accumulation area to another, as long as the hazardous waste remains on-site. However, the 90-day or 180-day “clock” for accumulation does not restart if the hazardous waste is moved to another central accumulation area.

Information for this blog post was gathered from the EPA Memorandum on Closed Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.