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Three days!
Most generators swap the full container (typically a 55-gallon drum) with an empty in their satellite accumulation areas (SAAs). And they don’t trigger the excess quantity clock because this prevents them from exceeding 55 gallons (or 1 quart for acute hazardous waste) in their SAAs. From a compliance perspective, this is perfect. But what happens if you do exceed the limits?
Exceeding the quantity limits starts a 3-day clock, and the generator is required to put a date on the container holding the “excess quantity” (i.e., the full container). The generator must move this container out of the SAA by the end of the third calendar day, so if the date were July 28, this would be by the end of July 31. The excess quantity is typically moved 1) to the central accumulation area (CAA), 2) directly offsite, or 3) to permitted storage. [§262.15(a)(6), RO 12503, 13410, 14703] We have additional compliance morsels on our website.
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McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided above. 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 such guidance may conflict. Any guidance above is general in nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with environmental 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.
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