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It’s RCRA storage time.
So, let’s talk RCRA storage clocks. For satellite accumulation areas (SAAs), no time limits are prescribed, just quantity limits [§262.15], and SAAs are not subject to the §268.50 one-year storage prohibition. [OSWER Directive 9555.00-01] Still, a best management practice is to move wastes out of SAAs at least once a year.
For central accumulation areas (CAAs), large quantity generators (LQGs) may store hazardous waste without a permit for up to 90 days [§262.17], and small quantity generators (SQGs) may store up to 180 days (270 days if the waste will be shipped more than 200 miles).
[§262.16] The 90/180/270-day clock starts on the day the waste is moved into the CAA, or if accumulated in the CAA, when the first drop of waste goes into the unit. [RO 13410, 14703] The clock stops when the waste is 1) shipped offsite, 2) moved to RCRA-permitted storage, 3) rendered nonhazardous (via treatment), or 4) moved to a permit-exempt unit (e.g., recycling unit, elementary neutralization unit, wastewater treatment unit). [45 FR 76625] Generators may not store wastes in a CAA for longer than 90/180/270 days without
permit unless they are granted an extension. [§§262.16(d) and 262.17(b)]
Hazardous wastes accepted from offsite by permitted treatment, storage, and disposal facilities (TSDFs) must be placed in RCRA-permitted storage units or permit-exempt units. Offsite wastes may not be placed in SAAs or CAAs. However, TSDFs may use generator SAAs and CAAs for hazardous wastes (and treatment residues) generated onsite.
RCRA permits generally contain a one-year time limit in accordance with §268.50. The one-year clock for offsite wastes starts upon receipt of the waste. The one-year clock for wastes generated onsite starts when the waste is moved into a CAA or permitted storage. The clock stops when the waste is treated to meet land disposal restriction standards or is sent offsite. Regardless of how long the waste is actually stored, the storage must be “necessary to facilitate proper recovery, treatment, or disposal.” [§§268.50(b) and (c)] For more compliance morsels, visit our website.
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