Q. I am an SQG of hazardous waste. When should the accumulation date be written on the hazwaste label placed on a 55-gallon drum that would apply to my allowable monthly accumulation amount which is 1,000 kilograms? Is it when the drum becomes full at the satellite area and is sealed and moved to the hazwaste storage location where it is stored until it is shipped out, or is it when waste begins to be accumulated in the drum at the satellite area?
A. An SQG (or large quantity generator (LQG)) container in a satellite accumulation area (SAA) must be marked with a date when the SAA container has reached the quantity limits specified in the SAA regulation. Although the dating requirement hasn’t changed, the federal SAA regulation is now found, under the new Hazardous Waste Generator Improvements Rule, at 40 CFR 262.15. The date the SAA container is full (or, as the EPA says, the date “the excess amount began accumulating”) must be marked on the container. This date starts the three consecutive calendar day period that a generator has to remove the excess hazardous waste from the satellite accumulation area to either the central accumulation area or to an on- or off-site facility permitted to treat, store, or dispose of the hazardous waste.
The requirements are different regarding the dating of containers of hazardous waste in a generator’s CAA, where a generator’s container must be marked with the date the first quantity of hazardous waste is placed in the container. That is the date that the storage period begins and the date that starts the clock for the SQG’s 180-day accumulation period (or 90-day period for an LQG).
Also note that the 1,000 kg limitation for SQGs is not a monthly accumulation limit, but a monthly generation limit for non-acute hazardous waste. SQGs are prohibited from on-site accumulation at anytime of more than 6,000 kg of non-acute hazardous waste.