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Pre-Transport Requirements for Hazardous Waste

Posted on 1/27/2015 by Scott Dunsmore

Generators large and small commonly start their accumulation of hazardous waste at the point of generation under the satellite option at 40 CFR 262.34(c), moving the container to their central storage (i.e., 90-day or 180-day) area once it's full. In these instances, the container becomes subject to different communication requirements during its lifecycle. One of the challenges generators face is keeping the different container marking requirements straight.

Satellite Communications
There are two distinct container marking requirements while the container is under satellite accumulation—initial markings and quantity-driven markings. The EPA states that as soon as hazardous waste is added to a container under the satellite option, the generator must mark the container with either the words "hazardous waste" or some other words that describe the contents (e.g., "spent solvent"). [40 CFR 262.34(c)(1)] Regardless of the number of containers at the point of generation, the contents marking is the only communication that must be on each container until the total quantity of hazardous waste at a single point of generation exceeds 55 gallons.
Once this quantity has been exceeded, the generator must mark the date on the container that holds the excess (i.e., the container that will be moved out of the point of generation). This is the accountability marking to remind the generator that this excess hazardous waste must be removed from the point of generation within three days. [40 CFR 262.34(c)(2)]

"Central Storage" Communications
The communication requirements for containers under the 90-day and 180-day accumulation standards are the same. The EPA requires that each container be marked with two items:
  1. The words "hazardous waste," and
  2. The accumulation start date.
Unlike the content markings for satellite containers, the EPA does not give the generator an option. All containers must have the words "hazardous waste." [40 CFR 262.34(a)(3)] So if a container managed at a satellite accumulation point is marked not with "hazardous waste," but with other words describing the contents, it will need to be marked with the words "hazardous waste" upon arrival to the 90-day or 180-day area. Unless state-level rules say otherwise, the other words and additional information may remain.

The accumulation start date communicates when the waste in the container first became subject to the 90-day or 180-day requirements. For waste coming to the central storage area from a satellite accumulation point, this date will be the day that the container is delivered to the 90-day or 180-day accumulation area—also known as the "accumulation start date." Unless a satellite accumulation container is moved to the central storage area the same day that the point of generation's accumulated quantity exceeds 55 gallons, this accountability marking will be a new date. [RO 14703]

These two date requirements serve different purposes. The date marking under the satellite option tells the generator when to remove the waste from the point of generation. The date marking under the central storage requirement tells the generator when the 90-day or 180-day limit will be exceeded. (Remember, this clock does not start until the waste is actually subject to the 90-day or 180-day requirements.)

State Rules
It is important to remember that if you are accumulating hazardous waste in a RCRA-authorized state, there may be additional marking requirements for satellite and central storage containers. Some states mandate that satellite containers and/or 90-/180-day containers include both the words "hazardous waste" and words describing the contents. Generators should review their state's requirements in addition to the Federal regulations before implementing their on-site accumulation practices.

Expert RCRA Training
Be confident you're ready for compliance with the latest rules for satellite, 90-day, and 180-day hazardous waste accumulation at the Hazardous/Toxic Waste Management Workshop. At this two-day workshop, you will satisfy EPA's annual training requirement and learn what you must do to accumulate, manage, and store waste at your site under RCRA. Failure to meet your legal responsibilities can result in fines as high as $37,500 per day, per violation; emergency releases; and future liability.


Tags: hazardous waste, marks and labels, RCRA, satellite areas

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