The 3 Date Rule for Hazardous Waste Satellite Areas
There are rules to follow when you’re on a date. Don’t talk about your ex too much. Don’t stare at your phone. Don’t use the face-morphing app to show the other person what your children would look like.
You can find “dating rules” in the RCRA hazardous waste regulations, too. When managing hazardous waste in a satellite accumulation area (SAA), for example, generators must mark as many as three different dates on the container. Knowing when to date your container is essential to comply with RCRA time and quantity limits.
First Date: Satellite “Initial” Date
First dates can be awkward. Luckily, satellite area container prefer not to be tied down by labels.
Keeping track of when a container first starts holding hazardous waste may be important for your management procedures, but nothing in the Federal RCRA regulations requires you to mark this date on the container.
Some state RCRA programs prohibit generators from accumulating hazardous waste in satellite areas for more than a year and require marking an accumulation start date on the container. California and Pennsylvania are two examples. If your state requires this, this first date marking must make clear it is the “initial” start date to distinguish it from the other dates discussed below.
Second Date: SAA “Excess” Date
Every budding relationship needs clear boundaries.
When a generator accumulates hazardous waste in a satellite area in excess of the limits for satellite areas (55 gallons for non-acute wastes, or 1 quart or 1 kg for acutely hazardous wastes) “the generator must mark the container holding the excess accumulation of hazardous waste with the date the excess amount began accumulating.”
Once any satellite area quantity limit is exceeded, the generator has three days to either transfer the excess waste to a central accumulation (CAA) area or ship it offsite to an authorized treatment, storage, or disposal facility (TSDF). [40 CFR 262.15(a)(6)]
Third Date: Central Accumulation Area "Start" Date
Once you hit the 3rd date, it’s time to take things to the next level. Generators must mark containers with "the date upon which each period of accumulation begins..." This means that a container must be marked with the date the generator:
- Moves a waste container from a satellite area to a CAA; or
- Starts to accumulate waste directly in a CAA, without using a satellite area.
[40 CFR 262.16(b)(6)(i)(C) and 262.17(a)(5)(i)(C)]
Depending on your generator status and situation, you may accumulate hazardous waste in a central accumulation area for up to 90, 180, or even 270 days. The date starts the clock ticking. Before this time limit is up, a generator must either ship the waste to an off-site TSDF or treat the waste to render it non-hazardous.
The Federal RCRA regulations allow the generator to remove (or obliterate) the SAA “excess” date and replace it with the CAA accumulation “start” date. A few states, however, require generators to continue counting out from the “excess” date rather than indicate a new “start” date.
If you forget the RCRA dating rules, getting ghosted by your sweetie will be the least of your worries. The maximum civil penalty for a typical violation of the RCRA hazardous waste management standards for generators increased to $87,855 per day, per violation. You can't go Dutch on that bill.
Learn more about RCRA Satellite Areas:
RCRA Basics: Hazardous Waste Satellite Areas
3 Wrong Ways to Place RCRA Satellite Areas
Emergency Preparedness in Hazardous Waste Satellite Areas
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