August 13, 2013

Treating Hazardous Waste Without a Permit in 90/180-Day Units

Although not clearly spelled out in the regulations, EPA’s guidance indicates generators may treat hazardous waste in 90/180-day accumulation units (i.e., tanks, containers, containment buildings) without a RCRA permit. Numerous examples of ways generators can treat waste in a 90/180-day accumulation unit are given in the agency’s guidance:

Remember, state regulations and policies may be more stringent than the federal regulations and guidance. Before treating hazardous waste in 90/180-day units, generators should verify that their states allow such treatment without a RCRA permit.


©2013-2021 McCoy and Associates, Inc. All rights reserved.

McCoy and Associates has provided in-depth information to assist environmental professionals with complex compliance issues since 1982. Our seminars and publications are widely trusted by environmental professionals for their consistent quality, clarity, and comprehensiveness.



Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.

This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.