Dating Hazardous Waste Containers
Q. One of the more common ways to manage hazardous waste is to temporarily accumulate hazardous waste in 55-gallon drums or other containers at or near waste-generating processes in satellite accumulation areas. Then, once the containers are full, the waste is moved to a central accumulation area for a few months before shipping it to an authorized facility for treatment, long-term storage, or disposal.
In addition to the words “Hazardous Waste,” generators must mark each container with “the date upon which each period of accumulation begins…” [40 CFR 262.34(a)(2)]. But which date must they mark?
A. A hazardous waste container used like this can have up to four important dates in its lifecycle, and as a generator it is important to keep track of them. But, not all of them need to be marked on the container. And, not all of them are clearly called out in the regulations.
- Satellite Accumulation Start Date—Keeping track of when a container first started holding hazardous waste is important, but nothing in 40 CFR requires you to mark this date on the container. Keeping track of this date, either by marking the container or keeping written records, will help you keep an accurate count of the amount of hazardous waste you generate each calendar month and year. Some State/local waste management authorities discourage or prohibit generators from accumulating hazardous waste in satellite areas for excessive periods, thus recording the first date of satellite accumulation can be necessary to forestall any citations.
- Satellite Accumulation End Date—This is a date that you must mark on a container. When a generator accumulates an excess of hazardous waste (55 gallons for most wastes, 1 quart for acutely hazardous wastes) in a satellite accumulation area (SAA), “the generator must mark the container holding the excess accumulation of hazardous waste with the date the excess amount began accumulating.” Afterwards, the generator has three days to either transfer the marked waste to a central accumulation area or get it offsite and on its way to an authorized treatment, storage, or disposal facility. [40 CFR 262.34(c)(2)]
- Central Accumulation Start Date—This is another date you must mark on a container. When you transfer a waste container to a central accumulation area (CAA), either from a SAA, an inventory, or directly from a waste-generating process, you must mark the container with “the date upon which each period of accumulation begins…” [40 CFR 262.34(a)(2)] For a container transferred from a SAA, this accumulation start date may be up to three days after you reached the 55-gallon limit in the satellite area.
- Manifest Date—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. Before this time limit is up, a generator must either ship the waste to an off-site treatment, storage, or disposal facility or treat the waste to render it non-hazardous. This time limit is measured in calendar days from the time the waste was first managed in a central accumulation area under the 90- or 180-day rules. If generators keep storing their waste for more than 90 (or 180 or 270 days), then they are an unpermitted storage facility and must begin complying with all of the requirements in 40 CFR Part 265 and get a storage permit. [40 CFR 262.34(b)]
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